Beverly Hills City Council
March 18, 2024

Tenure is an important indicator of the housing market in a community, reflecting the relative cost of housing opportunities and the ability of residents to afford housing. Tenure also influences residential mobility, with owner units generally seeing lower turnover rates than rental units.

In Beverly Hills, renter-occupied homes represented approximately 59 percent of the total, as compared to just 47.5 percent in the entire SCAG region (Figure A-17).

Figure A-17. Housing by Tenure – Beverly Hills and SCAG Region
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Figure A-18 shows that tenure is related to age, with Beverly Hills residents over age 60 more likely to be homeowners.

Figure A-18. Housing Tenure by Householder Age – Beverly Hills Vacancy
The vacancy rate measures the overall housing availability in a community and is often a good indicator of housing market conditions. A low vacancy rate may indicate that households are having difficulty finding affordable housing, which can lead to overcrowding and/or overpayment. A particularly tight housing market with insufficient vacant units to accommodate normal mobility may also lead to high competition, placing upward pressure on rents and for-sale housing prices.

A vacancy rate of 5 percent for rental housing and 2 percent for ownership housing is generally considered healthy and suggests that there is a balance between the supply and demand of housing.

Recent Census estimates reported a 10.8 percent total vacancy rate in Beverly Hills. As seen in Figure A-19, nearly a quarter of all housing units in Beverly Hills were reported as “seasonal,” which is likely to include second homes.

Figure A-19. Vacant Units by Type – Beverly Hills vs. SCAG Region
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3. Housing Age and Condition
The age of a community’s housing stock can provide an indicator of overall housing conditions. Typically, housing over 30 years in age is more likely to have rehabilitation needs that may include plumbing, roof replacement, foundation work, and other repairs. Maintenance of existing housing units is especially important in Beverly Hills given the age of the community’s housing stock.

Beverly Hills was created as a real estate development, with the original subdivision dating from 1907. A substantial number of singlefamily houses in the City were constructed prior to 1920 (prior to the period in which the City became associated with the entertainment industry), with a few dating from before 1910. The City experienced its greatest residential development during the period from the late 1920s through the 1930s.

Figure A-20 shows the age distribution for housing units in Beverly Hills compared to the region as a whole. Over 90 percent of housing units in the City were built prior to 1990 and are more than 30 years old. This indicates that a substantial number of housing units may require maintenance and rehabilitation to stem potential deterioration.

Figure A-20. Housing Units by Year Built – Beverly Hills vs. SCAG Region
Another indicator of housing problems is the availability of complete plumbing, kitchen facilities, and telephone service. Recent Census data (Figure A-21) reported that approximately 0.3 percent of Beverly Hills homes had incomplete plumbing facilities and 1.4 percent had incomplete kitchen facilities. In addition, about 1 percent of housing units lacked telephone service. However, with the increase in cell phone usage, statistics regarding telephone service may not be representative of housing conditions. Also, it is possible that some units reporting incomplete plumbing or kitchens could reflect temporary conditions due to remodeling that was underway at the time of the survey.

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Figure A-21. Substandard Housing Units – Beverly Hills vs. SCAG Region
The Building and Safety Division estimates that units requiring substantial rehabilitation constitute approximately 3 percent of the City’s housing stock, translating to an estimated 430 units. The City currently has a reactive code enforcement program but is in the process of becoming more proactive and is evaluating development of a rental housing inspection program to address this issue. There are no substandard residential structures in the community that require replacement.

The recently formed Rent Stabilization Commission reviewed a proposed program to address habitability issues for all 7,700 Rent Stabilized units in April of 2022, including the review of a potential proactive code enforcement program. The Commission
recommended that this program move forward to the City Council.

4. Housing Costs and Affordability
Affordability is determined by comparing the cost of housing to the income of local households. If costs are high relative to household incomes, problems such as overcrowding and overpayment, are more likely to occur. This section provides data regarding housing costs and affordability in Beverly Hills.

Housing Affordability Criteria
State law establishes five income categories for purposes of housing programs based on the area (i.e., county) median income (AMI):
extremely-low (30% or less of AMI), very-low (31-50% of AMI), low (51-80% of AMI), moderate (81-120% of AMI), and above-moderate (over 120% of AMI). Housing affordability is based on the relationship between housing expenses and household income. According to the U.S. Department of Housing and Urban Development (HUD) and the California Department of Housing and Community Development (HCD), housing is considered “affordable” if monthly housing cost is no more than 30 percent of a household’s gross income. In some areas, such as Los Angeles County, these income categories may be adjusted based on high housing costs.

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Table A-1 shows affordable rent levels and estimated affordable purchase prices for housing in Beverly Hills (and Los Angeles County) by income category. Based on State-adopted standards for a 4-person family, the maximum affordable monthly rent for extremelylow-income households is $845, while the maximum affordable rent for very-low-income households is $1,407. The maximum affordable rent for low-income households is $2,252, while the maximum for moderate-income households is $2,319.

Maximum purchase prices are more difficult to determine due to variations in factors such as mortgage interest rates and qualifying procedures, down payments, special tax assessments, homeowner association fees, and property insurance rates. With this caveat, the maximum affordable home purchase price for moderate-income households has been estimated at approximately $375,000 based on typical conditions. Affordable prices have not been estimated for the lower-income categories because most for-sale affordable housing is provided at the moderate-income level.

Table A-1 Income Categories and Affordable Housing Costs – Los Angeles County
2020 County Median
Income = $77,300 Income Limits* Affordable Rent
Affordable
Price (est.)
Extremely Low (<30%) $33,800 $845 *
Very Low (31-50%) $56,300 $1,407 *
Low (51-80%) $90,100 $2,252 *
Moderate (81-120%) $92,750 $2,319 $375,000
Above moderate
(120%+)
Over $92,750 Over $2,319 Over $375,000
Assumptions:
-Based on a family of 4 and 2020 State income limits
-30% of gross income for rent or principal, interest, taxes & insurance plus utility allowance
-10% down payment, 3.75% interest, 1.25% taxes & insurance, $300 HOA dues *Because of State adjustments in high housing cost areas, some of these income limits are higher than the percentages of median income
Source: Cal. HCD; JHD Planning LLC
Rental Housing Market
Across Beverly Hills’ 8,791 renter households, 4,364 (49.6%) spent 30 percent or more of gross income on housing cost compared to 55.3 percent in the SCAG region. Additionally, 2,534 renter households in Beverly Hills (28.8%) spent 50 percent or more of gross income on housing compared to 28.9 percent in the SCAG region (Figure A-22)2.

2 Source: Pre-certified local housing data from the Southern California Association of Governments (SCAG). <https://scag.ca.gov/sites/main/files/file-attachments/beverly-hillshe-0421.pdf?1620801067> DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-22. Percentage of Income Spent on Rent – Beverly Hills Recent Census data also allows analysis of Beverly Hills renter households (for which income data are available) by spending on rent by income bracket. As one might expect, the general trend is that lower-income households spend a larger share of income on housing (often more than 50%) while higher-income households are more likely to spend less than 20 percent of income on housing (Figure A-23).

Figure A-23. Percentage of Income Spent on Rent by Income Category – Beverly Hills
Homeownership Market
Median sales price trends for existing homes during 2000-2018 are shown in Figure A-24. Between 2000 and 2018, median home sales prices in Beverly Hills increased 208 percent, while prices in the SCAG region increased 151 percent. The median home sales price in Beverly Hills during 2018 was $2.6 million. Prices in Beverly Hills have ranged from a low of 271 percent of the SCAG region median in 2005 to a high of 584 percent in 2012.

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Figure A-24. Median Price for Existing Homes – Beverly Hills vs.

SCAG Region
Figure A-25 compares typical monthly mortgage costs in Beverly Hills to the SCAG region as a whole, and Figure A-26 confirms that the percentage of income spent on mortgage payments is higher for households at the lower income levels.

Figure A-25. Monthly Owner Costs – Beverly Hills vs. SCAG Region
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Overpayment
Housing overpayment is defined as a household spending more than 30 percent of its gross income on housing, while severe overpayment is considered to be spending more than 50 percent of income on housing. Figure A-27 shows that overpayment for housing in Beverly Hills is much more frequent for households at the extremely-low and very-low income levels than for households in higher income categories. However, it is possible that some households technically overpay for housing costs if their income is low, but the household is comprised of retired individuals who are not living off of income, and instead may be using their savings or assets. Therefore, these households are not cost-burdened for housing in actuality, and this may affect the statistics reflected here.

Figure A-27. Cost Burden by Income Category – Beverly Hills

5. Assisted Housing at Risk of Conversion
State law requires an analysis of existing assisted rental units that are at risk of conversion to market rate. This includes conversion through termination of a subsidy contract, mortgage prepayment, or expiring use restrictions. The following at-risk analysis covers the 10-year period of 2021 through 2031.

The City of Beverly Hills has one assisted senior housing project financed under the HUD Section 202 program. The Beverly Hills Senior Housing development has 150 units for disabled and senior residents (Table A-2). The project was developed in 1988 and has a 40-year affordability covenant. The City of Beverly Hills owns the first floor and below, while the Menorah Housing Foundation owns the air rights above the first floor. Menorah is a nonsectarian, nonprofit 501(c)(3) corporation that develops and manages affordable independentliving senior apartment units throughout Los Angeles. Residents must be 62 years of age or older and must earn 50 percent or less of the area median income. Discussion with the Menorah Housing Foundation indicates that there is a need for additional senior housing in the community and there is a long wait list for the project. The affordability covenant for the Beverly Hills Senior Housing project will DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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expire in 2028; and therefore, it is technically classified as being at-risk of conversion during this planning period. However, this property has a recorded covenant from 1986 (Document No. 86-704717) that states “the residential portion of the property shall be used for housing for senior citizens and handicapped persons”. In addition, this covenant states that if such uses are discontinued, the property shall not be used to any purpose except one approved by the City, and that if the rental rates are no longer subject to the control of a Federal, State, or other public agency, that the rental rates shall be set by the City’s Planning Commission. This covenant runs with the property and is binding on future owners and successors, and therefore, this project is not considered to be at risk of conversion during the planning period, even though the affordability covenant will expire in 2028. In addition, the City has the right to purchase the upper floors for one dollar in 2041; therefore, this project is not at risk of conversion to market rate, given the existing covenant restricting the uses on site, and the provisions allowing the City to continue to restrict the rental rates and uses on the site.

Table A-2 Assisted Housing Inventory, Beverly Hills
Project
Name Tenant Type
Project
Owner
Funding
Source
Units
Subject to
Conversion
Earliest
Date of
Conversion
Beverly Hills
Senior
Housing
Senior/disabled
—Very low
income
Menorah
Housing
202/811 150 10/26/2028
Source: Menorah Housing Foundation
Section 8 Housing
The Los Angeles County Development Authority (LACDA) administers the Section 8 Housing Choice Voucher Program throughout the county including Beverly Hills. The Section 8 program provides rent subsidies to extremely-low- and very-low-income households in the form of vouchers.

D. Regional Housing Needs Assessment
The Regional Housing Needs Assessment (RHNA) is a State-mandated process that determines the amount of additional housing cities and counties must plan for. The RHNA allocation process seeks to ensure that each jurisdiction accepts responsibility for the housing needs of not only its current population, but also for the jurisdiction’s projected share of regional housing growth among all income categories.

Regional growth needs to reflect the number of additional housing units that would have to be added in each jurisdiction to accommodate the forecasted number of households, as well as the number of units that need to be added to compensate for anticipated demolitions and changes to achieve an “ideal” vacancy DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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rate, while also eliminating the existing problems of overcrowding and overpayment.

The RHNA process begins with the California Department of Housing and Community Development’s (HCD) projection of future statewide housing growth need, and the apportionment of this need to regions throughout the state. The Southern California Association of Governments (SCAG) is the agency responsible for developing an allocation methodology to distribute the region’s share of statewide housing need to cities and counties by income level. In allocating the region’s future housing needs to jurisdictions, SCAG is required to take the following factors into consideration:
• Existing problems of overcrowding and overpayment
• Access to transportation and job opportunities
• Market demand for housing
• Availability of suitable sites and public facilities
• Commuting patterns
• Type and tenure of housing
• Loss of units in assisted housing developments
• Over-concentration of lower income households
• Physical constraints such as fire and flood hazards
SCAG’s RHNA allocation to Beverly Hills for the 2021-2029 planning period is shown in Table A-3.

Table A-3 Regional Housing Needs Assessment 2021-2029,
Beverly Hills
Income Level Percent of AMI* Units Percent
Very Low** Up to-50% 1,008 32%
Low 51-80% 680 22%
Moderate 81-120% 602 19%
Above Moderate 120%+ 814 26%
Total 3,104 100%
Source: https://scag.ca.gov/housing
* AMI – Area Median Income.
** Includes the extremely-low income category, which is estimated as half the VL need pursuant to Government Code Sec. 65583(a)(1)
The RHNA represents the minimum number of potential housing units each community must accommodate through its land use plans and development regulations. As the RHNA represents a planning target for new residential growth and not a building quota, so long as a jurisdiction provides sufficient sites and does not impose unreasonable constraints to development, it is not penalized for falling short of its RHNA target in terms of units built. Beverly Hills will continue to provide sites for a mix of single-family, multi-family and mixed-use housing, supported by a variety of programs to enhance affordability, to accommodate its RHNA allocation and help address the need for housing in the Southern California region. A detailed analysis of DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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potential sites to accommodate the City’s RHNA allocation is provided in Appendix C.

E. Fair Housing Assessment
Assembly Bill (AB) 686 requires that all housing elements due on or after January 1, 2021, must contain an Assessment of Fair Housing (AFH) consistent with the core elements of the analysis required by the federal Affirmatively Furthering Fair Housing (AFFH) Final Rule of July 16, 2015.

Under State law, affirmatively further fair housing means “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.”
There are three parts to this requirement:

1. Include a Program that Affirmatively Furthers Fair Housing and Promotes Housing Opportunities throughout the Community for Protected Classes (applies to housing elements beginning January 1, 2019).

2. Conduct an Assessment of Fair Housing that includes summary of fair housing issues, an analysis of available federal, state, and local data and local knowledge to identify, and an assessment of the contributing factors for the fair housing issues.

3. Prepare the Housing Element Land Inventory and Identification of Sites through the Lens of Affirmatively Furthering Fair Housing.

1. Assessment of Fair Housing
California Government Code Section 65583 (10)(A)(ii) requires cities to analyze areas of segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs, including displacement risk. The City has conducted the following analysis of available data to assess these issues.

Fair Housing Enforcement and Outreach
Enforcement
Federal fair housing laws prohibit discrimination based on: race, color, religion, national origin, sex/gender, handicap/disability, and familial status. Specific federal legislation and court rulings include:
• The Civil Rights Act of 1866- covers only race and was the first legislation of its kind
• The Federal Fair Housing Act 1968- covers refusal to rent, sell, or finance
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• The Fair Housing Amendment Act of 1988- added the protected classes of handicap and familial status
• The Americans with Disabilities Act (ADA)- covers public accommodations in both businesses and in multi-family
housing developments
• Shelly v. Kramer 1948- made it unconstitutional to use deed restrictions to exclude individuals from housing
• Jones v. Mayer 1968- made restrictive covenants illegal and unenforceable
California state fair housing laws protect the same classes as the federal laws with the addition of marital status, ancestry, source of income, sexual orientation, and arbitrary discrimination. Specific State legislation and regulations include:
• Unruh Civil Rights Act- extends to businesses and covers age and arbitrary discrimination
• California Fair Employment and Housing Act (Rumford Act)- covers the area of employment and housing, with the
exception of single-family houses with no more than one roomer/boarder
• California Civil Code Section 53- takes measures against restrictive covenants
• Department of Real Estate Commissioner’s Regulations 2780- 2782- defines disciplinary actions for discrimination, prohibits panic selling and affirms the broker’s duty to supervise • Business and Professions Code- covers people who hold licenses, including real estate agents, brokers, and loan officers.

The City has committed to complying with applicable federal and State fair housing laws to ensure that housing is available to all persons without regard to race, color, religion, national origin, disability, familial status, or sex as outlined in the 2018 AI. Further, the Los Angeles County Development Authority (LACDA) prohibits discrimination in any aspect of housing on the basis of race, color, religion, national origin, disability, familial status, or sex.

As presented in this Housing Element, the City has committed to meaningful actions to promote the development of housing for special needs populations, including lower income housing. Further, this Housing Element includes actions to affirmatively further fair housing through strategies related to housing mobility, new housing opportunities in high resource areas, fair housing enforcement and outreach, place-based strategies for neighborhood improvement, and tenant protection. The City continues to participate in the CDBG Urban County program contracting with the Housing Rights Center to ensure housing discrimination complaints are properly addressed and fair housing resources and services are offered to residents. The following shows applicable fair housing laws and the City’s compliance:

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• Fair Housing Act; Title VI of the Civil Rights Act of 1964 – the City complies by ensuring its actions related to housing are not discriminatory through City protocols, decision-making
procedures, and adhering to non-discrimination requirements of federal funding programs.
• Rehabilitation Act of 1973 – see Fair Housing Act; also, the City complies through its accessibility protocols, administered and enforced by the City’s ADA/504 Coordinator and Building Official.
• Americans With Disabilities Act – the City complies with the ADA through building permit review and issuance.
• California Fair Employment and Housing Act (FEHA) and FEHA Regulations – the City complies with FEHA and its regulations through established City protocols decision making, legal counsel and advisement.
• Government Code Section 65008 – the City Zoning Code is written to ensure that the City’s actions regarding the development of housing for persons and families of very low, low, moderate, and middle incomes, or emergency shelters for the unhoused, are not discriminatory. Programs are included in this Housing Element to facilitate housing for all households, including protected classes (e.g., programs regarding
residential care facilities, emergency shelters, and reasonable accommodations).
• Government Code Section 8899.50 – This section, Appendix A, of this Housing Element documents compliance with Affirmatively Furthering Fair Housing requirements.
• Government Code Section 11135 et. seq. – the City complies with anti-discrimination requirements through the City’s Human Resources programs and the City’s procurement protocols. • Density Bonus Law (Government Code Section 65915) – the City implements density bonus provisions in compliance with the Density Bonus Law.
• Housing Accountability Act (Government Code Section 65589.5) – the City has documented compliance with the HAA.
• No-Net-Loss Law (Government Code Section 65863) – the City has documented compliance with sufficient capacity for
RHNA and will ensure compliance with no-net-loss via required annual reporting to HCD.
• Least Cost Zoning Law (Government Code Section 65913.1) – the City includes programs in this Housing Element to ensure that sufficient land is zoned with appropriate standards to
accommodate its RHNA.
• Excessive Subdivision Standards (Government Code Section 65913.2) – the City’s subdivision standards are typical or not excessive in compliance with the Government Code.
• Limits On Growth Control (Government Code Section 65302.8) – the City complies as it has no growth control measures.

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• Housing Element Law (Government Code Section 65583) – this Housing Element documents compliance with Housing
Element Law.

The City’s Rent Stabilization Division administers and enforces the City's Rent Stabilization Ordinance (RSO). All multifamily rental properties, two or more residential units, are subject to the RSO unless expressly exempted by BHMC§§ 4-5-102 or 4-6-1. Pursuant to Urgency Ordinance 20-O-2818 and Urgency Ordinance 22-O-2861, the Beverly Hills moratorium on annual rent increases ended on May 31, 2022.

Some units are now eligible to receive a rent increase not to exceed

3.1%. However, this increase can only be applied to units where an allowable rent increase for the period of July 1, 2019 through June 30, 2020 was not imposed or was imposed at a rate less than 3.10%. If a rent increase of less than 3.1% was imposed between July 1, 2019 through June 30, 2020, then the rent increase for the period between June 1, 2022 and June 30, 2023 cannot exceed 3.10% when added as the sum of the increase from the period of July 1, 2019 to June 30, 2020.

Beverly Hills is served by the Housing Rights Center (HRC) as a participating City in the Los Angeles Urban County. The HRC offers the following services to Los Angeles County residents including Beverly Hills:
• Housing Counseling - Housing Counselors are available to answer questions about tenant-landlord rights and
obligations, including topics like security deposits, evictions, repairs, rent increases, and harassment. Conversations with Housing Counselors are private and confidential.
• Discrimination Investigation & Disability Accommodations - Case Analysts investigate allegations of housing discrimination and help victims of discrimination enforce their Fair Housing rights.

HRC can also help tenants with disabilities assert their right to request accommodations or modifications in their home.
• Community Workshops & Events - Education and outreach programs on fair housing laws, how to spot illegal practices, and tenant-landlord rights, including free, weekly online workshops open to the public.
• Project Place: Monthly Rental Listing - HRC's monthly rental listing, Project Place, assists residents in locating opportunities for affordable housing, senior housing, and veteran housing throughout Los Angeles County.

Regional Trend. According to HUD’s Office of Fair Housing and Equal Opportunity (FHEO) records, 130 housing discrimination cases were filed in Los Angeles County in 2020, compared to 291 in 2010. In 2020, a majority of cases were related to disability (66%). Another 21% of cases were related to racial bias. The percent of cases related to disability has increased significantly since 2010, when only 36% of DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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cases reported a disability bias. Public housing buildings, FHEO inquires by City and housing choice voucher (HCV) recipients by tract are shown in Figure A-28. HCVs are most concentrated in the area southeast of Beverly Hills, near Inglewood, the City of Los Angeles, and in the adjacent unincorporated County areas. Public housing buildings are concentrated in the same area. However, there are many public housing buildings scattered throughout the County, including in West Hollywood directly east of Beverly Hills.

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Figure A-28. Regional Public Housing Buildings, FHEO Inquiries by City, and HCV Recipients by Tract Source: HCD AFFH Data Viewer, 2023.

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Local Trend. The City of Beverly Hills is a participating jurisdiction in the Los Angeles County CDBG Urban County program. The Housing Rights Center has a main office location in downtown Los Angeles. As a participating jurisdiction in the Urban County program, Beverly Hills does not have direct access to HRC staff or service records. HRC’s contract with the Los Angeles County Development Authority (LACDA) also does not include reporting fair housing records by participating jurisdiction.

According to the HCD AFFH Data Viewer, based on 2013-2021 HUD records, the Office of Fair Housing and Equal Opportunity (FHEO) received 10 inquiries from Beverly Hills residents during this period. Of the 10 inquiries, one was related to disability, one to race, one to familial status, and seven were not related to a specific protected class. Total FHEO inquiries in Beverly Hills represent 0.29 inquiries per 1,000 people. The rate of inquiries per 1,000 persons in the City is comparable to the City of Los Angeles but lower than the adjacent jurisdictions of West Hollywood, Santa Monica, and Culver City.

There are no tracts in Beverly Hills with a substantial population of renters receiving housing choice vouchers (HCVs). To protect the confidentiality of renters receiving HCVs, tracts containing 10 or fewer voucher holders have been omitted from this dataset. West Hollywood, Santa Monica, Culver City, and the City of Los Angeles, east and south of Beverly Hills, contain tracts with larger populations of HCV recipients. There are no public housing buildings in Beverly Hills and only one subsidized housing project (Beverly Hills Sr. Housing, 150 affordable units). FEHO Inquiries and the concentration of HCV recipients by tract are shown in Figure A-29.

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Figure A-29. Public Housing Buildings, FHEO Inquiries, and HCVs Source: HCD AFFH Data Viewer, 2023.

Outreach
As discussed further in Appendix E, the City conducted extensive public outreach and held numerous public workshops and meetings during the preparation of the Housing Element in an effort to reach all economic segments of the community and persons with special needs.

The public meetings were publicized through agenda publication on the City website, at City Hall, and at the City Library. For certain public DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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meetings, courtesy notices were sent via mail to all property owners and residential occupants citywide, notices were published in the local newspapers, email notifications were sent to a list of interested parties, and information was published on the Housing Element webpage (www.beverlyhills.org/housingelementupdate). Supportive service providers, housing advocates, housing developers, businesses and residents were encouraged to participate. Interested stakeholders had the opportunity to interact with City staff in the early stages of Housing Element preparation and provide direct feedback to the City regarding housing issues and barriers to fair housing. In addition to verbal input, parties were encouraged to complete an online survey of housing issues and needs.

In addition to the broad public outreach conducted as part of the initial Housing Element update process, in response to comments received from HCD on the adopted Housing Element, the City conducted a series of focused interviews with community stakeholders involved in the fair housing arena. In designing this more intensive level of outreach, the City of Beverly Hills took a representative approach to reach a deeper level of policy analysis, by reaching out to representatives of organizations that deal with tenant advocacy and fair housing issues within the community. In doing so, the City identified the protected classes and groups underrepresented in housing in the community, and located the community-based and other organizations (CBOs) who serve them, as well as housing and community development providers, and fair housing agencies. The City also learned more about the main fair housing issues affecting residents in the City, which has informed policies and programs included under the Affirmatively Furthering Fair Housing section.

Throughout the update process, the Housing Element team regularly consulted internally with other City staff who can be considered local experts in housing and social services through their official City roles:
1) Helen Morales – (Former) Deputy Director of Rent
Stabilization, Community Development Department
2) Nestor Otazu – Deputy Director of Rent Stabilization, Community Development Department
3) Rachel Evans – (Former) Human Services Administrator, Community Services Department
4) Christopher Paulson – Human Services Administrator,
Community Services Department
Both the former and current Directors of Rent Stabilization and the Human Services Administrators provided information about the existing services provided by the City, assisted in the fair housing analysis, and provided connections to external
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contacts/organizations to gather deeper local knowledge and data.

Their expertise was relied upon in the creation of fair housing policies.

Three external stakeholders agreed to be interviewed regarding overall housing and fair housing issues in Beverly Hills. Interviews were conducted with the following representatives:
1) Cynthia Chagolla - Bet Tzedek
2) Shohreh Zerehi - Jewish Family Services
3) Mark Elliot - Beverly Hills Renters’ Alliance
Interview Questions
For the purpose of fair and impartial data collection, all of the external interviewees were asked the same set of interview questions, which were provided to them in advance of the meeting. The interviewees were offered a variety of meeting times to be selected at their convenience, as well as the option for a virtual meeting for easier access. The list of interview questions, as well as a summary of each of the interviews, can be found below.

1. Please describe your organization’s mission and what populations you serve or represent. How does your mission relate to housing? What is your organization’s role in the city of Beverly Hills?

2. In your opinion, what are the greatest housing needs and challenges facing the Beverly Hills community and the
populations that you serve or represent?

3. What segment(s) of the City’s population do you see as most vulnerable in terms of accessing or retaining affordable housing?

4. How do you think the City can best assist those population segments?

5. Within the city of Beverly Hills, are you aware of any fair housing issues facing the populations you serve? For example, are you aware of any protected classes or minority groups, or
areas/neighborhoods that currently face barriers to accessing opportunities such as jobs, housing, City services, education, or transit as a result of housing policies or practices?

6. In order to provide more housing and housing types for community members, what tools are you aware of that could help encourage diverse housing for all community members within the city?
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7. Can you identify opportunities for forging or deepening a partnership between your organization and the City of Beverly Hills to better meet the community’s housing needs? Would your organization be interested in doing so?

8. Are there other organizations you are familiar with that we should speak to regarding fair and/or affordable housing to serve Beverly Hills?
Synopsis of Interviews
Interview #1
Ms. Shohreh Zerehi is a social worker with Jewish Family Services (JFS), which is a non-profit organization in the Los Angeles region that is contracted with the City of Beverly Hills to provide social services to residents within the city. Ms. Zerehi is assigned specifically to work Beverly Hills residents, in particular seniors. As a Farsi speaker, most of Ms. Zerehi’s clients are Persian and she is able to serve this segment of the Beverly Hills population. JFS assists its clients by connecting them to housing and services, but does not act as a direct housing provider.

The greatest housing challenge Ms. Zerehi identified was the very high level of rents and the lack of affordability. She identified seniors as being the most vulnerable population, as many of them are living on low or fixed incomes. In her experiences, Ms. Zerehi has received anecdotal complaints from her clients that all low-income housing have very long waitlists, and there was a perceived questioning of the order in which the waitlist was served. However, Ms. Zerehi was not formally aware of any discrimination in housing, but rather that some confusion may be due to a lack of information. She identified that the challenges were primarily due to a supply issue, as not enough lowincome units are available to meet the demand. She noted that the City of Beverly Hills has a generous budget for care, and its attention to seniors is ample. Regarding the affordable housing development she frequently visits her clients at on North Crescent Drive in Beverly Hills, Ms. Zerehi noted that the units were generally in good condition, clean, and well-maintained. As for the cultural aspects of the Persian and Farsi-speaking populations she works with, Ms. Zerehi observed that within the Persian community, seniors wish to live near their family members, if not with them in the same household. As there may sometimes be a language barrier for these clients to access housing opportunities, she sometimes provides translation services. Lastly, Ms.

Zerehi observed that loneliness and isolation was a health consequence experienced in older adults during the ongoing COVID pandemic. Some of the suggestions generated in this interview have been incorporated into the policies in Implementation Measure 11.1 (Affirmatively Furthering Fair Housing).

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Interview #2
Ms. Cynthia Chagolla is an attorney with Bet Tzedek, which is a legal aid organization that provides free legal services to low- and moderate-income people in Los Angeles County. Bet Tzedek is contracted with the City of Beverly Hills for a program that provides free legal services to seniors, and tenants or landlords with housingrelated issues, within Beverly Hills. Ms. Chagolla identified affordability as the most prominent housing issue facing the community, and housing security/retention as the second largest challenge. Ms.

Chagolla identified seniors as the most vulnerable population, particularly those who are on a fixed income and/or are long-term renters. Most of the clients she sees are long-term renters, and she noted the positives of the rent stabilization protections in Beverly Hills.

However, she noted that still many tenants lose their housing through a formal eviction process and if they are not able to preserve that stabilized housing, that limited opportunity exists to relocate within the community and tenants would be forced to move outside of the city.

As the same issues of housing affordability permeate the entire Los Angeles region, most are forced to relocate to a further locale, and in so doing can lose their connection to social services and social networks near their prior residences. When asked about known fair housing issues, Ms. Chagolla conveyed that in her training and experience as an attorney, she found that most housing discrimination issues occur during the rental application process and that prospective tenants even from protected groups (particularly those with visible markers such persons of color or persons with physical disabilities) are rejected before or during the application process by landlords or rental agents. Chagolla noted that this type of discrimination is the hardest to prove and serves as a barrier for new tenants to relocate into the city. Additionally, Ms. Chagolla shared known instances of tenants with disabilities facing resistance or discrimination from their landlords in terms of making needed reasonable accommodation upgrades.

Ms. Chagolla was not specifically aware of historical practices that contributed to current housing patterns, but offered the suggestion that that City could possibly offer a direct rent subsidy to specific rental groups such as seniors or underrepresented racial groups. She also suggested that the city could benefit from stronger long-term tenant protections and expanded outreach opportunities between Bet Tzedek and the City of Beverly Hills. Some of the suggestions generated in this interview have been incorporated into the policies in Implementation Measure 11.1 (Affirmatively Furthering Fair Housing).

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Interview #3
Mr. Mark Elliot identified himself as a long-time tenant in Beverly Hills and a tenants’ rights advocate through the group Beverly Hills Renters’ Alliance. He identified his role as a facilitator between tenants (representing their interests) and the City (following and communicating regarding policies, programs and practices). Mr.

Elliot cited affordability as the greatest long-term housing challenge facing the community. He attributes the lack of affordability to the statewide housing crisis, and the dearth of new rental housing and/or deed-restricted affordable housing in Beverly Hills. Additional housing issues highlighted by Mr. Elliot include “precariously housed households” living in sub-standard conditions due to aging housing stock and poor maintenance by owners. He pinpointed households with a high rent burden and seniors and others on fixed incomes as the groups most vulnerable to housing instability. He asserted that once displaced, these households cannot afford replacement housing in Beverly Hills. Mr. Elliot suggested that the City could respond to these issues by “get[ting] in the affordable housing business – and not only for seniors.” Mr. Elliot highlighted “soft discrimination” as a fair housing issue that exists in the city, whereby landlords screen for “problem tenants” or for “character,” despite the existence of antidiscrimination laws that prohibit such conduct. Overall, Mr. Elliot urged efforts to support affordable housing in the city, and for greater attention to the constituency of renter households in the community.

Some of the suggestions generated in this interview have been incorporated into the policies in Implementation Measure 11.1 (Affirmatively Furthering Fair Housing).

Integration and Segregation
Race/Ethnicity
Ethnic and racial composition of a region is useful in analyzing housing demand and any related fair housing concerns, as it tends to demonstrate a relationship with other characteristics such as household size, locational preferences and mobility. For example, prior studies have identified socioeconomic status, generational care needs, and cultural preferences as factors associated with “doubling up”- households with extended family members and non-kin.3 These factors have also been associated with ethnicity and race. Other studies have also found minorities tend to congregate in metropolitan areas though their mobility trend predictions are complicated by economic status (minorities moving to the suburbs when they achieve

3 Harvey, H., Duniforn, R., & Pilkauskas, N. (2021). Under Whose Roof? Understanding the living arrangements of children in doubled-up households. Duke University Press, 58 (3): 821–846. https://doi.org/10.1215/00703370-9101102 DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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middle class) or immigration status (recent immigrants tends to stay in metro areas/ports of entry).4
To measure segregation in a given jurisdiction, the US Department of Housing and Urban Development (HUD) provides racial or ethnic dissimilarity trends. Dissimilarity indices are used to measure the evenness with which two groups (frequently defined on racial or ethnic characteristics) are distributed across the geographic units, such as block groups within a community. The index ranges from 0 to 100, with 0 denoting no segregation and 100 indicating complete segregation between the two groups. The index score can be understood as the percentage of one of the two groups that would need to move to produce an even distribution of racial/ethnic groups within the specified area. For example, if an index score above 60, 60% of people in the specified area would need to move to eliminate segregation. The following shows how HUD views various levels of the index:
• <40: Low Segregation
• 40-54: Moderate Segregation
• >55: High Segregation
Regional Trend. As presented in Table A-5, Los Angeles County is characterized by a large Hispanic/Latino population, representing

48.7% of the total population. The White population is the second largest population countywide (25.5%), followed by the Asian population (14.6%), and Black/African American population (7.6%).

Of the selected jurisdictions in the proximity of Beverly Hills, Beverly Hills has the largest White population of 74%. In general, the westside cities, Malibu, Beverly Hills, Culver City, Santa Monica, and West Hollywood, have larger White populations compared to central County cities, including the City of Los Angeles. The Hispanic/Latino population represents the largest proportion of the population in the City of Los Angeles. Comparatively, only 7.5% of the population in Beverly Hills is Hispanic or Latino, a smaller share than Culver City, Santa Monica, and West Hollywood.

As explained above, dissimilarity indices measure segregation, with higher indices signifying higher segregation. In Los Angeles County, all minority (non-White) residents combined are considered highly segregated from White residents, with an index score of 58.53 in 2020 (Table A-4). Since 1990, segregation between non-White (all nonwhite residents combined) and White residents has increased slightly, indicating Los Angeles County has become increasingly segregated.

4 Sandefur, G.D., Martin, M., Eggerling-Boeck, J., Mannon, S.E., &. Meier, A.M. (2001).

An overview of racial and ethnic demographic trends. In N. J. Smelser, W.J. Wilson, & F. Mitchell (Eds.) America becoming: Racial trends and their consequences. (Vol I, pp. 40-102). National Academy Press Washington, D.C.

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Dissimilarity indices between Black and White residents has decreased, while indices increased between Hispanic, Asian/Pacific Islander, and White residents during the same period. Based on HUD’s definition of the index, Black and White residents are highly segregated, Hispanic and White residents are highly segregated, and Asian/Pacific Islander and White residents are moderately segregated.

Table A-4 Racial/Ethnic Dissimilarity Trends – Los Angeles County (1990-2020)
1990 Trend 2000 Trend 2010 Trend Current
Non-White/White 56.66 56.72 56.55 58.53
Black/White 73.04 67.40 64.99 68.24
Hispanic/White 60.88 63.03 63.35 64.33
Asian or Pacific
Islander/White

46.13 48.19 47.62 51.59
Source: U.S. Department of Housing and Urban Development (HUD) Affirmatively Furthering Fair Housing (AFFH) Database, 2020.

Figure A-30 and Figure A-31 compare racial/ethnic minority populations by block group in the region in 2010 and 2018. Non-White populations in nearly all areas of this section of Los Angeles County have increased since 2010. Racial/ethnic minority populations throughout the central areas of the County have intensified, while block groups in the coastal areas also saw an increase in non-White populations.

Figure A-31 shows that most areas in Los Angeles County have high concentrations of racial/ethnic minorities. Westside and coastal cities, including Santa Monica, Beverly Hills, West Hollywood, and Redondo Beach generally have smaller non-White populations. Most block groups in the South Bay, San Gabriel Valley, San Fernando Valley and central Los Angeles areas have majority racial/ethnic minority populations. Block groups in Beverly Hills have racial/ethnic minority populations comparable to West Hollywood, Malibu, and the Pacific Palisades area but significantly smaller than nearly all jurisdictions to the south.

Figure A-32 shows the racial/ethnic majority population by tract in the region surrounding Beverly Hills. In general, northern and coastal areas, from Calabasas and Malibu to Redondo Beach, Beverly Hills, West Hollywood, and Burbank, contain tracts that have White majority populations. Tracts to the south of Beverly Hills, in and around the cities of Los Angeles, Downey, and South Gate, have Hispanic majority populations. Tracts north of Beverly Hills, through Reseda, Winnetka, and Canoga Park, also have Hispanic majority populations. Tracts around Inglewood have African American majority populations, and Asian majority populations are most prevalent in east Los Angeles in the cities of Monterey Park and San Gabriel.

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Table A-5 Racial/Ethnic Composition of Neighboring Cities and County (2021) Race/Ethnicity Los Angeles
County Beverly Hills Culver City Los Angeles (City) Santa Monica West Hollywood White alone 25.5% 74.0% 46.7% 28.1% 62.7% 70.7%
Black or African American alone 7.6% 1.5% 8.6% 8.3% 4.4% 4.0% American Indian and Alaska Native
alone 0.2% 0.1% 0.0% 0.2% 0.2% 0.1%
Asian alone 14.6% 11.3% 18.3% 11.6% 9.1% 5.5%
Native Hawaiian and Other Pacific
Islander alone 0.2% 0.0% 0.3% 0.1% 0.1% 0.1%
Some other race alone 0.4% 0.9% 0.7% 0.5% 0.9% 0.9%
Two or more races 2.8% 4.6% 7.0% 2.9% 6.1% 5.2%
Hispanic or Latino 48.7% 7.5% 18.4% 48.4% 16.6% 13.4%
Total 10,019,635 32,903 40,640 3,902,440 92,828 35,678
Source: 2017-2021 ACS (5-Year Estimates).

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Figure A-30. Regional Racial/Ethnic Minority Population by Block Group (2010) Source: HCD AFFH Data Viewer (ESRI 2010), 2023.

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Figure A-31. Regional Racial/Ethnic Minority Population by Block Group (2018) Source: HCD AFFH Data Viewer (ESRI 2018), 2023.

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Figure A-32. Regional Racial/Ethnic Majority Populations by Tract (2018) Source: HCD AFFH Data Viewer (ESRI 2018), 2023.

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Local Trend. As mentioned above, Beverly Hills is characterized by a White majority population. As presented in Table A-6, 74% of the Beverly Hills population is White. The Asian population is the second largest population in the City, representing 11.3% of the population.

Another 7.5% is the population is Hispanic or Latino and 4.6% is two or more races. Since the 2006-2010 ACS, the White population has decreased by 16%. During this period, the population of some other race, population of persons of two or more races, Asian population, and Hispanic/Latino population have grown.

Table A-6 Racial/Ethnic Composition (2010-2021)
Race/Ethnicity 2010 2021
Persons Percent Persons Percent
White alone 29,000 85.3% 24,360 74.0%
Black or African
American alone 836 2.5% 497 1.5%
American Indian and
Alaska Native alone 0 0.0% 27 0.1%
Asian alone 2,091 6.2% 3,728 11.3%
Native Hawaiian and
Other Pacific Islander
alone
46 0.1% 0 0.0%
Some other race alone 12 0.0% 292 0.9%
Two or more races 435 1.3% 1,519 4.6%
Hispanic or Latino 1,560 4.6% 2,480 7.5%
Total 33,980 100.0% 32,903 100.0%
Source: 2006-2010 and 2017-2021 ACS (5-Year Estimates).

Because Beverly Hills is part of the Urban County program, dissimilarity HUD dissimilarity indices are not available for the City alone. HUD provides dissimilarity data for recipients of CDBG funds. The City of Hermosa Beach, as part of the Urban County program, may receive CDBG funds indirectly from LACDA.

As seen in Figure A-34, the percentage of non-white population in the city is relatively low compared to many areas of Los Angeles County.

However, it is important to note that Census data categorizes race under broad categories, and does not capture the nuanced racial, ethnic, and religious groups that are known to be represented in Beverly Hills. The block groups with the highest percentage of nonwhite residents are located in the southern portion of the city south of Santa Monica Boulevard, and also in the northeastern area, although the non-white population of these areas is less than 40%. Since the 2006-2010 ACS, the non-White population has grown in these areas (Figure A-33).

The Diversity Index Map in Figure A-35 shows that the majority of the southern area of the City (south of Santa Monica Boulevard) as well as a portion of the Hillside (northern) area exhibit a mid-level of DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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diversity. Lower diversity rates are found in two pockets in the southern area and the remainder of the northern areas of the City.

Figure A-33. Racial/Ethnic Minority Population by Block Group (2010)
Source: HCD AFFH Data Viewer (ESRI 2010), 2023.

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Figure A-34. Racial/Ethnic Minority Population by Block Group (2018)
Source: HCD AFFH Data Viewer (ESRI 2018), 2023.

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Figure A-35. Diversity Index by Block Group (2018)
Source: HCD AFFH Data Viewer (ESRI 2018), 2023.

Persons with Disabilities
Regional Trend. Approximately 10% of the Los Angeles County population experiences one or more disability. As presented in Table A-7, the Black/African American population has the highest disability rate countywide (15.3%), followed by the American Indian/Alaska Native population (13.2%), the Native Hawaiian/Pacific Islander population (13%), and the non-Hispanic White population (12.4%), and. All other racial/ethnic groups have disability rates equal to or less DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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than the countywide average of 10.1%. Aging populations tend to have higher rates of disabilities. Over 50% of the population 75 years and older experiences a disability, compared to 23.2% of the population aged 65 to 74, and 9% of the population aged 35 to 64.

Ambulatory difficulties and independent living difficulties are the most common disability types in the County. Approximately 5.7% and 5.5% of the population, respectively, experiences these disabilities.

The population of persons experiencing disabilities at the tract-level is shown in Figure A-36 for the region. Less than 20% of the population in most tracts in Los Angeles County are persons with disabilities. Tracts with disabled populations exceeding 20% are not concentrated in one area of the County and can be found in the City of Los Angeles, Norwalk, Glendale, Burbank, and Pasadena. Tracts with larger shares of persons with disabilities closest to Beverly are in the City of Los Angeles. The concentration of persons with disabilities in Beverly Hills is generally comparable to neighboring jurisdictions. The Westside cities of Beverly Hills, West Hollywood, and Santa Monica are all comprised of tracts with populations of persons with disabilities of 20% or below.

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Table A-7 Disability Status by Race, Age, and Type – L.A.

County (2021)
Total Population Percent with
Disability
Total civilian noninstitutionalized
population 9,948,747 10.1%
Race/Ethnicity
White alone 4,350,641 10.8%
Black or African American alone 780,054 15.3%
American Indian and Alaska Native
alone 98,185 13.2%
Asian alone 1,473,046 8.7%
Native Hawaiian and Other Pacific
Islander alone 24,122 13.0%
Some other race alone 2,190,124 8.1%
Two or more races 1,032,575 9.0%
White alone, not Hispanic or Latino 2,528,424 12.4%
Hispanic or Latino (of any race) 4,853,459 8.5%
Age
Under 5 years 570,320 0.6%
5 to 17 years 1,595,537 4.1%
18 to 34 years 2,514,999 4.8%
35 to 64 years 3,921,734 9.0%
65 to 74 years 795,361 23.2%
75 years and over 550,796 50.5%
Type
With a hearing difficulty -- 2.5%
With a vision difficulty -- 2.0%
With a cognitive difficulty -- 4.2%
With an ambulatory difficulty -- 5.7%
With a self-care difficulty -- 2.9%
With an independent living difficulty -- 5.5%
Source: 2017-2021 ACS (5-Year Estimates).

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Figure A-36. Regional Population of Persons with Disabilities by Tract (2019) Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Local Trend. Beverly Hills has a slightly smaller population of persons with disabilities compared to the County. Only 9.6% of the City population experiences one or more disability compared to 10.1% countywide, despite having a larger elderly population. According to the 2017-2021 ACS, 13.7% of the population countywide is 65 or older compared to 22.9% of the population in Beverly Hills. Since the 2008- 2012 ACS, the population of persons with disabilities in Beverly Hills has decreased slightly from 1.4%.

While there is only a small population of American/Indian Alaska Native residents in the City (27 persons), a large proportion (55.6%) experience a disability (Table A-8). The Black/African American (13.3%) and non-Hispanic White (11.1%) populations also have disabilities rates exceeding the citywide average. Approximately 48% of persons aged 75 and older and 14.3% of persons aged 65 to 74 experience a disability, both smaller proportions compared to the respective populations countywide. Ambulatory difficulties and independent living difficulties are the most common disability types in the City, where 6.1% and 5.2% of the population experiences each, respectively.

The incidence of disabilities is relatively low in Beverly Hills and similar to most surrounding areas. As shown in Figure A-37, the percentage of residents reporting a disability is less than 10% in most census tracts in the City. In one tract (tract 7008.01), bound by Santa Monica Boulevard, Wilshire Boulevard, and the eastern City boundary, 19.5% of the population experiences a disability. The population of persons with disabilities in this tract is likely due to the elderly population.

According to the 2017-2021 ACS, 38.8% of the population residing in this tract are 65 or older. All other tracts have elderly populations ranging from 11.7% to 26.9%.

In the oral interviews conducted, local housing experts shared some of the accessibility challenges that disabled residents face. This has been detailed in the “Outreach” and “Summary of Fair Housing Issues and Local Conditions” analyses in the Analysis of Fair Housing.

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Table A-8 Disability Status by Race, Age, and Type – Beverly Hills (2021)
Total Population Percent with
Disability
Total civilian noninstitutionalized
population 32,855 9.6%
Race/Ethnicity
White alone 25,589 10.8%
Black or African American alone 504 13.3%
American Indian and Alaska Native
alone 27 55.6%
Asian alone 3,728 3.6%
Native Hawaiian and Other Pacific
Islander alone 0 --
Some other race alone 950 5.9%
Two or more races 2,057 4.6%
White alone, not Hispanic or Latino 24,312 11.1%
Hispanic or Latino (of any race) 2,480 4.4%
Age
Under 5 years 937 0.0%
5 to 17 years 5,535 0.9%
18 to 34 years 5,470 4.6%
35 to 64 years 13,400 3.8%
65 to 74 years 3,807 14.3%
75 years and over 3,706 48.1%
Type
With a hearing difficulty -- 4.4%
With a vision difficulty -- 1.3%
With a cognitive difficulty -- 3.6%
With an ambulatory difficulty -- 6.1%
With a self-care difficulty -- 3.3%
With an independent living difficulty -- 5.2%
Source: 2017-2021 ACS (5-Year Estimates).

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Figure A-37. Population of Persons with Disabilities by Tract (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

Familial Status
Under the Fair Housing Act, housing providers may not discriminate because of familial status. Familial status covers: the presence of children under the age of 18, pregnant persons, any person in the process of securing legal custody of a minor child (including adoptive or foster parents). Examples of familial status discrimination include refusing to rent to families with children, evicting families once a child joins the family through, e.g., birth, adoption, custody, or requiring DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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families with children to live on specific floors or in specific buildings or areas. Single parent households are also protected by fair housing law.

Regional Trend. According to the 2017-2021 ACS, 27.3% of households in Los Angeles County have children of the householder under age

18. Of the 27.3% of households with children, 18.5% are married couple households, 2.6% are male-headed households, and 6.1% are femaleheaded households. Figure A-38 shows households with children in Los Angeles County, Beverly Hills, and jurisdictions adjacent to Beverly Hills.

Of the selected jurisdictions, Culver City has the largest proportion of households with children (25.4%), followed by the City of Los Angeles (24.2%), and Beverly Hills (23.2%). West Hollywood has the smallest proportion of households with children; however, all the selected jurisdictions have smaller populations of households with children compared to the County. The City of Los Angeles has the largest proportion of single-parent households (8.5%), followed by Beverly Hills (6%). Single-parent households represent 8.7% of households countywide.

Figure A-39 shows the population of children living in single-parent female-headed households by tract in the region. Children in femaleheaded households are most concentrated in the area south of Beverly Hills, including Inglewood and the City of Los Angeles. In general, there are more children living in female-headed households in the central Los Angeles County areas compared to the Westside cities.

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Figure A-38. Households with Children in Neighboring Cities and County (2021) Source: 2017-2021 ACS (5-Year Estimates).

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Figure A-39. Regional Population of Children Residing in Single-Parent Female-Headed Households by Tract (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Local Trend. According to the 2006-2010 and 2017-2021 ACS, the proportion of households with children has generally remained constant (Table A-9). Households with children of the householder represented 23.5% of households citywide in 2010, and 23.2% in 2021.

The proportion of married couples with children has decreased slightly, from 19% to 17.2%, while the proportion of single-parent households, both male- and female-headed, has increased. Femaleheaded households with children require special consideration and assistance because of their greater need for affordable housing and accessible day care, health care, and other supportive services.

However, only 3.8% of households in Beverly Hills are single-parent female-headed households compared to 6.1% countywide.

Beverly Hills is characterized by a large population of persons living alone. Approximately 39% of households are persons living alone in the City compared to only 25.7% countywide. Further, 15.4% of households in the City are seniors living alone whereas only 8.8% of households countywide are elderly persons living alone. As discussed previously, Beverly Hills has a larger population of persons aged 65 and older (22.9%) compared to the County (13.7%). As shown in Figure A40, tracts in the southern section of the City, south of Santa Monica Boulevard, have larger populations of persons residing alone compared to the northern section.

Table A-9 Households with Children (2010-2021)
2010 2021
Household
s
Percent Household
s
Percent
Households with Children 3,439 23.5% 3,338 23.2%
Married Couple with
Children 2,783 19.0% 2,470 17.2%
Male Householder with
Children 139 1.0% 319 2.2%
Female Householder with
Children 517 3.5% 549 3.8%
Total Households 14,612 100.0% 14,401 100.0%
Source: 2006-2010 and 2017-2021 ACS (5-Year Estimates).

As presented in Figure A-41, most tracts in the City have populations of children residing in single-parent female-headed households below 20%. There are two tracts along the southern City boundary where between 20% and 40% of children reside in single-parent femaleheaded households. As discussed previously, the southern side of the City also has larger racial/ethnic minority populations compared to most of the northern area (see Figure A-34).

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Figure A-40. Population of Adults Living Alone by Tract (2019) Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Figure A-41. Population of Children Residing in Single-Parent Female-Headed Households by Tract (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

Income
Identifying low or moderate income (LMI) geographies and individuals is important to overcome patterns of segregation. HUD defines a LMI area as a Census tract or block group where over 51% of the population is LMI (based on HUD income definition of up to 80% of the Area Median Income).

Regional Trend. According to Comprehensive Housing Affordability Strategy (CHAS) data based on the 2015-2019 ACS, 55.6% of Los Angeles County households are low income, earning 80% or less than the area median income (AMI) (Table A-10). A significantly larger DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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proportion of renter households in Los Angeles County are considered lower income. Over 69% of renter households are lower income compared to only 39.3% of owner households.

Figure A-42 shows populations of low or moderate income (LMI) households in the region by block group. The central and south Los Angeles County areas and the San Fernando Valley area tend to have larger LMI household populations. Coastal areas and Westside cities, including Beverly Hills, tend to have smaller populations of low or moderate income households.

Table A-10 Households by Income and Tenure – Los Angeles County (2022)
Income Category OwnerOccupied
RenterOccupied Total
0%-30% of AMI 10.8% 30.6% 21.5%
31%-50% of AMI 11.1% 18.9% 15.3%
51%-80% of AMI 17.4% 19.9% 18.7%
81%-100% of AMI 11.0% 8.9% 9.9%
Greater than 100% of
AMI

49.7% 21.7% 34.5%
Total 1,519,515 1,797,280 3,316,795
Source: HUD CHAS Data (based on 2015-2019 ACS), 2022.

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Figure A-42. Regional LMI Household Population by Block Group (2020) Source: HCD AFFH Data Viewer (HUD 2020), 2023.

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Local Trend. Beverly Hills is characterized by a renter majority population. According to 2022 HUD CHAS data, 58.5% of households in the City are renters compared to 54.2% countywide. A larger proportion of Beverly Hills households earn 100% or more of the AMI compared to the County as a whole; 57.3% of Beverly Hills households earn 100% or more of the AMI compared to only 34.5% countywide.

The income disparity between owners and renters is also present in the City, where 45.6% of renters are lower income, earning less than 80% of the AMI, compared to only 22.5% of owners.

According to 2017-2021 ACS estimates, the median household income in Beverly Hills is $103,944. Westside cities tend to have higher median household incomes compared to the countywide median of $76,367. The median household income in Beverly Hills is higher than the neighboring cities of Los Angeles ($69,778), Santa Monica ($99,847), and West Hollywood ($78,719), but slightly lower than Culver City ($105,346).

Table A-11 Households by Income and Tenure – Beverly Hills (2022)
Income Category OwnerOccupied
RenterOccupied Total
0%-30% of AMI 9.1% 20.2% 15.6%
31%-50% of AMI 7.1% 9.7% 8.6%
51%-80% of AMI 6.4% 15.7% 11.8%
81%-100% of AMI 4.0% 8.5% 6.6%
Greater than 100% of
AMI 73.4% 45.9% 57.3%
Total 6,130 8,640 14,770
Source: HUD CHAS Data (based on 2015-2019 ACS), 2022.

LMI household populations at the block group-level are shown for Beverly Hills in Figure A-43. There are no block groups in the City that are considered LMI areas where more than 50% of household are low or moderate income. Most block groups on the northern side of the City have very small LMI household populations representing less than 25% of the block group population, with the exception of two block groups in the northeastern corner where 25% to 50% of households are LMI. Most block groups south of Santa Monica Boulevard also have LMI household populations ranging from 25% to 50%. As discussed above, the southern side of the City also has larger racial/ethnic minority populations compared to the north side (see Figure A-34).

Populations of LMI households in Beverly Hills block groups are generally lower compared to nearby jurisdictions.

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Figure A-43. LMI Household Populations by Block Group (2020) Source: HCD AFFH Data Viewer (HUD 2020), 2023.

Racially/Ethnically Concentrated Areas of Poverty (R/ECAP) In an effort to identify racially/ethnically concentrated areas of poverty (R/ECAPs), HUD has identified census tracts with a majority non-White population (greater than 50%) and a poverty rate that exceeds 40% or is three times the average tract poverty rate for the metro/micro area, whichever threshold is lower.

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Regional Trend. Figure A-44 shows tracts that have been identified as R/ECAPs or TCAC areas of high segregation and poverty. TCAC opportunity areas and scores are expanded upon in the Access to Opportunities section of this Assessment of Fair Housing. In the region, R/ECAPs and areas of high segregation and poverty are most prevalent in the City of Los Angeles and south Los Angeles areas.

There are very few R/ECAPs or areas of high segregation and poverty in coastal communities and Westside cities, including Beverly Hills. As discussed previously, these areas also have smaller LMI household and racial/ethnic minority populations (see Figure A-31 and Figure A-42).

R/ECAPs and TCAC areas of high segregation and poverty closest to Beverly Hills are in the City of Los Angeles, east, west, and south of Beverly Hills.

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Figure A-44. Regional R/ECAPs and TCAC Areas of High Segregation and Poverty Source: HCD AFFH Data Viewer (HUD 2009-2013; TCAC 2022), 2023.

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Local Trend. There are no R/ECAPs or TCAC areas of high segregation and poverty that have been identified in the City. Recent Census estimates regarding poverty status of households in Beverly Hills are shown in Figure A-45. As seen in this map, the incidence of poverty is low, with the poverty rate less than 10% for much of the city and 10- 20% for some areas south of Santa Monica Boulevard. The southern tracts tend to also have larger racial/ethnic minority and LMI household populations (see Figure A-34 and Figure A-43). As mentioned above, tract 7008.01, bound by Santa Monica Boulevard, Wilshire Boulevard, and Doheny Drive/eastern City boundary, where

10.2% of the population is below the poverty level, also has a larger population of persons with disabilities compared to the remainder of the City (see Figure A-37). This is likely due to the Beverly Hills Senior Housing project located in this tract. Beverly Hills Senior Housing is a subsidized housing project with 150 affordable units. The high poverty concentrations shown to the west of the City’s boundaries in this map are near the UCLA campus and may be due to student populations in those areas.

Figure A-45. Poverty Status by Tract (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

As presented in Table A-12, Beverly Hills has a smaller population below the poverty level compared to the County (10.2% vs. 13.9%, respectively). In Beverly Hills, the American Indian/Alaska Native population (55.6%) and Hispanic/Latino population (23.6%) have the highest poverty rates. All racial/ethnic groups besides the nonHispanic White population have poverty rates exceeding the citywide average of 10.2%. In Los Angeles County, poverty rates are the highest DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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in the Black/African American population (20%), population of some other race (17%), Hispanic/Latino population (16.2%), and American Indian/Alaska Native population (15.9%).

Table A-12 Population Below the Poverty Level by
Race/Ethnicity (2021)
Race/Ethnicity
Beverly Hills Los Angeles County
Total
Population
% Below
Poverty
Level
Total
Population
% Below
Poverty
Level
Black or African
American alone 504 12.9% 772,518 20.0%
American Indian and
Alaska Native alone 27 55.6% 97,327 15.9%
Asian alone 3,728 12.8% 1,455,158 11.0%
Native Hawaiian and
Other Pacific Islander
alone
0 - 23,967 11.3%
Some other race alone 950 18.3% 2,177,998 17.0%
Two or more races 2,057 10.7% 1,023,272 12.4%
Hispanic or Latino origin
(of any race) 2,480 23.6% 4,821,985 16.2%
White alone, not
Hispanic or Latino 24,333 8.6% 2,503,108 9.5%
Population for whom
poverty status is
determined
32,876 10.2% 9,861,892 13.9%
Source: 2017-2021 ACS (5-Year Estimates).

Racially Concentrated Areas of Affluence (RCAA)
While racially concentrated areas of poverty and segregation (R/ECAPs) have long been the focus of fair housing policies, racially concentrated areas of affluence (RCAAs) must also be analyzed to ensure housing is integrated, a key to fair housing choice. According to a policy paper published by HUD, RCAAs are defined as communities with a large proportion of affluent and non-Hispanic White residents. According to HUD's policy paper, non-Hispanic Whites are the most racially segregated group in the United States. In the same way neighborhood disadvantage is associated with
concentrated poverty and high concentrations of people of color, conversely, distinct advantages are associated with residence in affluent, White communities.

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and affluence pursuant to AB 686 and AB 1304. This section describes RCAAs using HCD’s updated methodology.5
Regional Trend. As presented in Figure A-46, RCAAs are more prevalent in Los Angeles County coastal communities and Westside cities, as well as the Pacific Palisades neighborhood, Calabasas, and Agoura Hills. In the region surrounding Beverly Hills, RCAAs have been identified along the coast from Ventura County and Malibu to Redondo Beach. RCAAs are also prevalent throughout the area from Agoura Hills to north Beverly Hills. There are no RCAAs in the central, south, and East Los Angeles area. As shown in Figure A-32 and Figure A-42 previously, coastal areas and Westside cities tend to have smaller non-White and LMI household populations compared to inland jurisdictions.

Figure A-47 shows median income by block group in the region.

Consistent with the RCAA trend, block groups with higher median incomes exceeding the statewide median of $87,100 are most prevalent along the coast and in Westside cities. In general, median incomes are lower the more inland a jurisdiction is. Most block groups in central and East Los Angeles surrounding the City of Los Angeles and in the San Fernando Valley area have median incomes below the State median.

5 HCD, Racially Concentrated Areas of Affluence. Summary and Description.

Accessed January 20, 2023.
https://www.arcgis.com/home/item.html?id=4100330678564ad699d139b1c193ef14 &sublayer=4.

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Figure A-46. Regional RCAA Tracts (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Figure A-47. Regional Median Income by Block Group (2019) Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Local Trends. Median household income by race/ethnicity in Beverly Hills and Los Angeles County is shown in Table A-13. In the City and County, White, non-Hispanic households have the highest median income of $117,109 and $96,794, respectively. Countywide, Black/African American households ($54,241), households of some other race ($61,323), and Hispanic/Latino households ($64,557) have the lowest median incomes in the County. American Indian/Alaska Native households and households of two or more races also have a median income below the countywide median of $76,367.

The median household income in Beverly Hills is $103,944, significantly higher than the median countywide. The median income amongst Hispanic/Latino households ($54,626), Asian households ($66,328), and Black/African American households ($66,347) are all below the citywide median. The median income for Asian and Hispanic/Latino households in the City are lower than the median for these racial/ethnic groups countywide. The median income for the population of householders of two or more races and non-Hispanic White householders is $108,359 and $117,109, respectively.

Table A-13 Median Household Income by Race/Ethnicity (2021) Race/Ethnicity of
Householder
Beverly Hills Los Angeles County
% of Total
Population
Median HH
Income
% of Total
Population
Median HH
Income
Black or African
American alone 2.4% $66,347 9.3% $54,241
American Indian and
Alaska Native alone 0.2% - 0.9% $70,759
Asian alone 10.2% $66,328 15.2% $89,080
Native Hawaiian and
Other Pacific Islander
alone

0.0% - 0.2% $86,302
Some other race alone 1.8% - 16.9% $61,323
Two or more races 4.4% $108,359 8.4% $76,105
Hispanic or Latino origin
(of any race) 6.2% $54,626 38.2% $64,557
White alone, not
Hispanic or Latino 77.2% $117,109 34.4% $96,794
Total Households 14,401 $103,944 3,342,811 $76,367
Source: 2017-2021 ACS (5-Year Estimates).

Tracts on the northern side of Beverly Hills, north of Santa Monica Boulevard, are considered RCAAs (Figure A-48). As presented in Figure A-49, all block groups north of Santa Monica Boulevard have median incomes exceeding $125,000. Most block groups on the north side of the City have racial/ethnic minority populations below 20% and LMI household populations below 25% (see Figure A-34 and Figure A-43).

None of the tracts south of Santa Monica Boulevard have been identified as RCAAs. Median incomes amongst block groups in the DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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southern section of the City are also variable. Several block groups south of Wilshire Boulevard and in the easternmost area of the City, east of Robertson Boulevard, have median incomes below the State median. As discussed previously, the southern area of the City has larger populations of racial/ethnic minority groups and LMI households (see Figure A-34 and Figure A-43). Non-White populations also have higher poverty rates and lower median incomes compared to non-Hispanic White populations (see Table A-12 and Table A-13).

Further, as shown in Figure A-50, the area of the City south of Santa Monica Boulevard has significantly more renters compared to the northern area. In general, renters are more likely to have lower incomes compared to owners. Tenure is further discussed in the Disproportionate Housing Needs section of this Assessment of Fair Housing.

Block group 3 of tract 7008.01 has a very low median income of only $22,813 according to the HCD AFFH Data Viewer. The Beverly Hills Senior Housing development, with 150 affordable units, is located in tract 7008.01, block group 3. According to 2015-2019 ACS estimates, consistent with the ACS data used in Figure A-49 by the HCD AFFH Data Viewer, block group 3 of tract 7008.01 contains only 685 total households. Therefore, nearly 22% of households in this block group are affordable units at the Beverly Hills Senior Housing project. There are currently no other subsidized housing projects in the City.

The City’s Zoning Map is shown in Figure A-51. Nearly all of the area north of Santa Monica Boulevard is zoned for single-family residential uses and is therefore not as conducive to affordable housing as higher density residential zones. Households residing in single-family homes are more likely to have higher median incomes. Conversely, the area south of Santa Monica Boulevard, that is not considered RCAA, is comprised of a variety of multi-family housing zoning types. In addition, the single-family areas located north of Santa Monica Boulevard are comprised of properties with larger lot areas in comparison to those located to the south of Santa Monica Boulevard, which results in a lower density of housing in the northern area.

The Hillside and Trousdale Estates areas also have some area-specific zoning regulations that take into account the topographical conditions of these areas, which can include sharply sloped lots. The Hillside area zoning regulations generally take in account the wide variability of lot shape, slope, and configuration, as well as the potential adverse impacts that intensive grading or development of previously undeveloped areas could have on the overall stability of sloped areas. The Trousdale Estates area also has specific regulations that reflect its unique history. The vast majority of the Trousdale Estates area was subdivided and developed in 1955 by Paul Trousdale, which was previously owned by the Doheny family as a few large parcels of DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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land. The subdivision was designed to provide each lot a view of the Los Angeles basin, and as such, each lot is terraced with a flat pad that is at a slightly higher elevation than the lot below. The lots were originally conditioned with Covenants, Conditions, and Restrictions (CC&Rs) that among other things, set forth a maximum building height of 14 feet, in order to preserve each homeowners’ view. The combination of the history of development in these areas, and the area-specific zoning regulations have also contributed to a lower density of development in comparison to some of the areas of the city that are relatively flat with a regular street grid pattern.

The City has identified three major contributing factors that may have led to patterns of unequal access to housing and housing financing.

These factors have also been documented throughout the Los Angeles region, Westside sub-region, and were found to have existed in Beverly Hills. Beverly Hills is one of the earliest master planned communities in southern California. The plan was designed with modest lots of 50 by 150 feet that housed small, working-class dwellings in the southern portion of the city with lots growing larger as the city plan extended north. Restrictive covenants and redlining also contributed to patterns of unequal access to housing that presently reflect RCAA trends in Beverly Hills. A detailed description of the history of Beverly Hills, including historical policies leading to patterns of unequal access, is included in Section 6, Other Relevant Factors, of this Fair Housing Assessment. The restrictive covenants and redlining practices that were present in Beverly Hills and rooted in racist and/or discriminatory beliefs contributed to the development pattern that persists in the city today, with a concentration of more affluent, white populations in the northern portion (generally north of Santa Monica Boulevard), and a concentration of a wider variety of housing types, income ranges, and ethnicities located in the southern portion (south of Santa Monica Boulevard).

Furthermore, the City has not previously provided public funding for the development of affordable housing projects within the RCAA area. Prior to the upcoming affordable housing projects for which the City will be a development partner (see Appendix C), the only affordable housing project developed by the City was the senior housing project located at 225 N. Crescent Drive. This project was developed in partnership with the Menorah Housing Foundation, and contains 150 units, constructed on a City-owned site. Menorah Housing Foundation continues to manage the units in this property and makes these available to qualified tenants. With the exception of this project, the City has not historically invested a significant amount of public resources into developing affordable housing. However, the City adopted an inclusionary housing requirement in 2019 (this was adopted on an interim basis in 2019, and then made permanent in 2021), and established the Affordable Housing Trust Fund in 2017. The DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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City’s Planning Division implements procedures to ensure compliance with state law related to replacement units (per SB 330/SB 8) in new multi-family housing developments, as well as compliance with the City’s inclusionary housing requirements. These requirements and procedures will help to ensure that affordable housing is built in the City moving forward.

While the historic development pattern, historical zoning regulations, and other factors such as restrictive covenants have resulted in the creation of an RCAA in the city, current investment by the City in public resources and improvements is equitably distributed throughout the various geographical areas. Figure A-48, below, shows the location of the planned capital improvement projects for the 2023-2024 Fiscal Year. As evidenced on the map, public investment is not concentrated in the identified RCAA north of Santa Monica Boulevard but is rather distributed throughout the singlefamily and multi-family residential areas, with a higher concentration of projects in the downtown commercial core (Business Triangle area) and adjacent commercial areas to the east. For example, there are projects for “street tree removal and replacement” along North Elm Drive (located north of Santa Monica Blvd in the RCAA), and along Olympic Blvd, which cuts across the city on the east-west axis and is not located in the RCAA. Additionally, there are improvements planned for both Greystone Manor (a publicly accessible park and estate located at the entrance to Trousdale Estates), and renovations planned for Roxbury Park and La Cienega Park (such as LED lighting for tennis courts and facilities improvements), which are both located outside of the RCAA, south of Santa Monica Blvd. This demonstrates an equitable investment of City resources into all areas of the city, and that there is not a concentration of investment in the RCAA.

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Figure A-48. Capital Improvement Project Map for Fiscal Year 2023- 24 The City has outlined meaningful actions in this Housing Element to mitigate RCAA patterns. For example, the City will adopt an ordinance by the end of 2024 to allow an additional ADU on singlefamily residential properties that are at least 13,000 square feet in size and deed-restrict at least one ADU on such property as a rental unit.

This action aims to specifically encourage additional housing opportunities in the northern area of the City that is considered an RCAA where there are larger properties.

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Figure A-49. RCAA Tract (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Figure A-50. Median Income by Block Group (2019)
Source: HCD AFFH Data Viewer (2015-2019 ACS), 2023.

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Figure A-51. Renter-Occupied Housing by Tract (2016)
Source: HCD AFFH Data Viewer (HUD 2012-2016), 2023.

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Figure A-52. Beverly Hills Zoning Map
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Access to Opportunities
Significant disparities in access to opportunity are defined by the AFFH Final Rule as “substantial and measurable differences in access to educational, transportation, economic, and other opportunities in a community based on protected class related to housing.” The Department of Housing and Community Development (HCD) and California Tax Credit Allocation Committee (TCAC) convened the California Fair Housing Task force to “provide research, evidencebased policy recommendations, and other strategic recommendations to HCD and other related state agencies/ departments to further the fair housing goals (as defined by HCD).” The Task Force has created Opportunity Maps to identify resources levels across the state “to accompany new policies aimed at increasing access to high opportunity areas for families with children in housing financed with nine percent Low Income Housing Tax Credits (LIHTCs)”. These opportunity maps are made from composite scores of three different domains made up of a set of indicators. Table A-14 shows the full list of indicators. The opportunity maps include a measure or “filter” to identify areas with poverty and racial segregation. To identify these areas, census tracts were first filtered by poverty and then by a measure of racial segregation. The criteria for these filters were:
• Poverty: Tracts with at least 30 percent of population under federal poverty line;
• Racial Segregation: Tracts with location quotient higher than

1.25 for Blacks, Hispanics, Asians, or all people of color in comparison to the County
Table A-14 Domains and List of Indicators for Opportunity Maps (2021)
Domain Indicators
Economic Poverty
Adult education
Employment
Job proximity
Median home value
Education Math proficiency
Reading proficiency
High School graduation rates
Student poverty rates
Environmental CalEnviroScreen 3.0 pollution Indicators and values Source: California Fair Housing Task Force, Methodology for the 2021 TCAC/HCD Opportunity Maps, December 2020.

TCAC/HCD assigns “scores” for each of the domain (see Table A-14) by census tracts as well as computing “composite” scores that are a combination of the three domains. Scores from each individual domain range from 0-1, where higher scores indicate higher “access” DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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to the domain or higher “outcomes.” Composite scores do not have a numerical value but rather rank census tracts by the level of resources (low, moderate, high, highest, and high poverty and segregation).

The TCAC/HCD Opportunity Maps offer a tool to visualize show areas of highest resource, high resource, moderate resource, moderate resource (rapidly changing), low resource, and high segregation and poverty and can help to identify areas within the community that provide good access to opportunity for residents or, conversely, provide low access to opportunity. They can also help to highlight areas where there are high levels of segregation and poverty.

The information from the opportunity mapping can help to highlight the need for housing element policies and programs that would help to remediate conditions in low resource areas and areas of high segregation and poverty and to encourage better access for low and moderate income and black, indigenous, and people of color (BIPOC) households to housing in high resource areas.

Regional Trend. As explained previously, TCAC composite scores categorize the level of resources in each census tract. Categorization is based on percentile rankings for census tracts within the region. In the Los Angeles County region surrounding Beverly Hills, coastal areas, Westside cities, and western County areas (Calabasas, Agoura Hills) are predominantly highest resource areas (Figure A-52). As tracts go further inland, the lower composite TCAC scores are. The central and south Los Angeles areas are predominantly low resource areas and areas of high segregation and poverty, as well as the East Los Angeles area and San Fernando Valley area. Tracts in Beverly Hills and adjacent to the east, west, and north are predominantly highest resource tracts. Tracts east of West Hollywood and south of the City, in Culver City and the City of Los Angeles, have more variable TCAC composite scores ranging from highest resource areas to areas of high segregation and poverty.

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Figure A-53. Regional TCAC Opportunity Area Composite Scores by Tract (2022) Source: HCD AFFH Data Viewer (TCAC 2022), 2023.

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While the Federal Affirmatively Furthering Fair Housing (AFFH) Rule has been repealed, the data and mapping developed by HUD for the purpose of preparing the Assessment of Fair Housing (AFH) can still be useful in informing communities about segregation in their jurisdiction and region, as well as disparities in access to opportunity. This section presents the HUD-developed index scores based on nationally available data sources to assess County residents’ access to key opportunity assets. HUD opportunity indices are provided for entitlement jurisdictions only. Opportunity indicators are not available for the City of Beverly Hills. Table A-15 provides index scores or values (the values range from 0 to 100) for the following opportunity indicator indices:
• School Proficiency Index: The school proficiency index uses school-level data on the performance of 4th grade students on state exams to describe which neighborhoods have highperforming elementary schools nearby and which are near lower performing elementary schools. The higher the index value, the higher the school system quality is in a
neighborhood.
• Labor Market Engagement Index: The labor market
engagement index provides a summary description of the
relative intensity of labor market engagement and human capital in a neighborhood. This is based upon the level of employment, labor force participation, and educational
attainment in a census tract. The higher the index value, the higher the labor force participation and human capital in a neighborhood.
• Transit Trips Index: This index is based on estimates of transit trips taken by a family that meets the following description: a 3- person single-parent family with income at 50 percent of the median income for renters for the region (i.e., the Core-Based Statistical Area (CBSA). The higher the transit trips index value, the more likely residents in that neighborhood utilize public transit.
• Low Transportation Cost Index: This index is based on estimates of transportation costs for a family that meets the following description: a 3-person single-parent family with income at 50 percent of the median income for renters for the
region/CBSA. The higher the index value, the lower the cost of transportation in that neighborhood.
• Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given residential neighborhood as a
function of its distance to all job locations within a
region/CBSA, with larger employment centers weighted
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more heavily. The higher the index value, the better the access to employment opportunities for residents in a
neighborhood.
• Environmental Health Index: The environmental health index summarizes potential exposure to harmful toxins at a
neighborhood level. The higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the index value, the better the environmental quality of a neighborhood, where a neighborhood is a census blockgroup.

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Table A-15 Opportunity Indices by Race/Ethnicity – Los Angeles County (2020) School
Proficiency
Index
Labor Market
Index
Transit Trips
Index
Low
Transportation
Cost Index
Jobs Proximity
Index
Environmental
Health Index
Total Population
White, non-Hispanic 65.09 65.41 82.63 74.09 55.80 18.99 Black, non-Hispanic 32.37 34.00 87.70 79.18 40.13 11.66 Hispanic 38.38 33.18 87.19 77.74 41.53 11.91
Asian/Pacific Islander, nonHispanic 59.34 55.94 86.52 76.45 51.82 12.16 Native American, nonHispanic 46.90 44.50 83.17 75.65 44.24 16.74 Population below federal poverty line
White, non-Hispanic 58.06 57.49 86.42 79.48 57.52 16.66 Black, non-Hispanic 27.16 25.52 88.65 81.18 36.59 11.62 Hispanic 32.87 27.66 89.45 81.02 42.84 10.30
Asian/Pacific Islander, nonHispanic 54.52 50.06 89.62 81.49 54.19 9.84 Native American, nonHispanic 35.12 32.02 85.23 78.70 46.35 16.01 Source: AFFHT Data Table 12; Data Sources: Decennial Census; ACS; Great Schools; Common Core of Data; SABINS; LAI; LEHD; NATA.

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Local Trend. According to the 2021 and 2022 California Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (TCAC) Opportunity Area Map (Table A-16 and Figure A-53), Beverly Hills is entirely within designated “Highest Resource” areas. Highest Resource areas are those with very high index scores for a variety of educational, environmental, and economic indicators. Some of the indicators identified by TCAC include high levels of employment and close proximity to jobs, access to effective educational opportunities for both children and adults, low concentration of poverty, and low levels of environmental pollutants, among others. In addition, the City’s Safety Element6, which was updated and adopted in 2022, analyzed whether any part of the city met the definition of an environmentally “disadvantaged community”, which is defined as an area identified by the CalEPA pursuant to Section 39711 of the Health and Safety Code or an area that is a low-income area that is disproportionately affected by environmental pollution or other hazards that can lead to negative health effects, exposure, or environmental degradation. This analysis looked at CalEPA’s data regarding 13 pollution burden indices and eight population characteristics and found that the seven different census tracts within the city scored between 25 and 55 percent of the statewide average. However, none of the census tracts within the city scored at 75 percent or higher on this pollution and population measure. Additionally, all of the seven census tracts have income levels that are greater than both the state median income levels and HCD state income limits. Therefore, this analysis concluded that with the combination of CalEnviroScreen data and income levels, none of the seven census tracts met the definition of a disadvantaged community.

6 The City’s Safety Element can be accessed here:
https://www.beverlyhills.org/cbhfiles/storage/files/1717622267413601751/ADOPTEDSAFETYEL EMENT-2022.pdf
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Table A-16 TCAC Opportunity Map Scores by Tract (2021)
Tract Economic
Score
Environmen
tal Score
Education
Score
Composite
Score Final Category
7006 0.962 0.798 0.889 0.912 Highest
Resource
7007 0.949 0.759 0.958 1.000 Highest
Resource
7008.0
1 0.925 0.644 0.918 0.832 Highest Resource
7008.0
2 0.941 0.593 0.863 0.751 Highest Resource
7009.0
1 0.994 0.596 0.866 0.954 Highest Resource
7009.0
2 0.986 0.628 0.893 0.952 Highest Resource
7010 0.980 0.643 0.933 1.009 Highest
Resource
Source: TCAC/HCD Opportunity Map Scores by Tract, 2021.

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Figure A-54. TCAC Opportunity Area Composite Scores by Tract (2022)
Source: HCD AFFH Data Viewer (TCAC 2022), 2023.

Economic
Regional Trend. According to World Trade Center Los Angeles, “LA County has a $707 Billion GDP. It is the #1 manufacturing center in the U.S, employing 350,600 workers in 2017.”7 The California Employment

7 World Trade Center Los Angeles – Choose LA, About. Accessed March 2023. https://wtcla.org/choose-la.

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Development Department (EDD) records a list of major employers by County. As of 2022, the largest employers in the County are as follows:
• AHMC Healthcare Inc (5,000-9,999 employees) – Alhambra • Cedars-Sinai Health System (10,000+ employees) – West Hollywood
• Kaiser Permanente Los Angeles (5,000-9,999 employees) – Los Angeles
• Lac & USC Medical Ctr (5,000-9,999 employees) – Los Angeles • Long Beach City Hall (5,000-9,999 employees) – Long Beach • Longshore Dispatch (5,000-9,999 employees) – Wilmington • Los Angeles County Sheriff (10,000+ employees) – Monterey Park • Los Angeles International Airport (10,000+ employees) – Los Angeles
• Los Angeles Medical Ctr (5,000-9,999 employees) – Los Angeles • Los Angeles Police Department (5,000-9,999 employees) – Los Angeles
• National Institutes of Health (10,000+ employees) – Pasadena • Six Flags (5,000-9,999 employees) – Valencia
• Sony Pictures Entertainment Inc (5,000-9,999 employees) – Culver City
• Space Exploration Tech Corp (5,000-9,999 employees) – Hawthorne
• Twentieth Century Fox (5,000-9,999 employees) – Los Angeles • UCLA Community Based Learning (10,000+ employees) – Los Angeles
• University of Ca Los Angeles (10,000+ employees) – Los Angeles • Vision X (10,000 employees) – Los Angeles
• Walt Disney Co (5,000-9,999 employees) -- Burbank
HUD’s opportunity indicators provide values for labor market index18F18F 8 and jobs proximity index19F19F
9 that can be measures for economic
development in Los Angeles County. Like the other HUD opportunity indicators, scores range from 0 to 100 and are published by race and poverty level to identify differences in the relevant “opportunity” (in this case economic opportunity). The labor market index value is based on the level of employment, labor force participation, and educational attainment in a census tract- a higher score means higher labor force participation and human capital in a

8 Labor Market Engagement Index: The labor market engagement index provides a summary description of the relative intensity of labor market engagement and human capital in a neighborhood. This is based upon the level of employment, labor force participation, and educational attainment in a census tract. The higher the score, the higher the labor force participation and human capital in a neighborhood.
9 Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given residential neighborhood as a function of its distance to all job locations within a region/CBSA, with larger employment centers weighted more heavily. The higher the index value, the better the access to employment opportunities for residents in a neighborhood.

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neighborhood. Los Angeles County’s labor market index values have a significant range from 33 to 65, with Hispanic residents scoring lowest and White residents scoring highest. Scores for Los Angeles County residents living below the poverty line drop most notably for Native American residents (from 44.5 to 32). For all other racial groups, labor market index scores fall between 5 and 9 points for the respective populations below the poverty level. These values indicate that Black and Hispanic residents living in poverty have the lowest labor force participation and human capital in the County.

HUD’s jobs proximity index quantifies the accessibility of a neighborhood to jobs in the region. Index values can range from 0 to 100 and a higher index value can indicate better access to employment opportunities for residents in a neighborhood. County jobs proximity index values range from 40 to 56 and are highest for White and Asian residents and lowest for Black and Hispanic residents.

The jobs proximity value map in Figure A-54 shows the distribution of scores in the region. Regionally, block groups in the Westside cities, Glendale and Burbank, and central/downtown Los Angeles have the highest jobs proximity index scores. The San Fernando Valley area and south Los Angeles region, from Inglewood to Compton, have the highest concentration of block groups scoring below 20 (worst scores).

The TCAC Economic Scores are a composite of jobs proximity index values as well as poverty, adult education, employment, and median home value characteristics. TCAC economic scores range from 0 to 1, where higher values indicate more positive economic outcomes.

The map in Figure A-55 shows that tracts with the lowest economic scores are most concentrated in the central and south Los Angeles area, eastern San Gabriel Valley, and San Fernando Valley. Westside cities and coastal jurisdictions generally are made up of tracts with higher TCAC economic scores. This is consistent with over TCAC categorizations, as many tracts in these areas are also highest or high resource tracts. As discussed above, Westside and coastal cities generally have smaller racial/ethnic minority populations and LMI household populations (see Figure A-32 and Figure A-42).

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Figure A-55. Regional HUD Jobs Proximity Index by Block Group (2017) Source: HCD AFFH Data Viewer (2014-2017 HUD), 2023.

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Figure A-56. Regional TCAC Economic Score by Tract (2022) Source: HCD AFFH Data Viewer (2014-2017 HUD), 2023.

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Local Trend. HUD’s jobs proximity scores, discussed above, are shown by block group in Figure A-55.

All tracts in Beverly Hills scored in the highest range, over 80, for jobs proximity. This indicates that all areas of the City have employment opportunities that are highly accessible to Beverly Hills residents.

The TCAC Economic Scores are a composite of jobs proximity as well as poverty, adult education, employment, and median home value characteristics. The map in Figure A-56 shows that all tracts in Beverly Hills scored in the highest quartile for economic opportunities. There are no areas where residents are exposed to reduced economic opportunities in Beverly Hills.

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Figure A-57. Jobs Proximity Score by Tract (2022)
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Figure A-58. TCAC Economic Score by Tract (2022)
Education
All tracts in Beverly Hills scored in the highest quartile for educational opportunities. The Westside neighborhood of Los Angeles County tends to have higher education scores compared to the central and southern county areas.

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Figure A-59. Regional TCAC Education Score by Tract (2022) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-60. TCAC Education Score by Tract (2022)
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Disproportionate Housing Needs
The AFFH Rule Guidebook defines disproportionate housing needs as a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing needs when compared to the proportion of a member of any other relevant groups or the total population experiencing the category of housing need in the applicable geographic area (24 C.F.R. § 5.152).

The analysis is completed by assessing cost burden, overcrowding, and substandard housing.

The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census for HUD provides detailed information on housing needs by income level for different types of households in Los Angeles County. Housing problems considered by CHAS include:
• Housing cost burden, including utilities, exceeding 30% of gross income;
• Severe housing cost burden, including utilities, exceeding 50% of gross income;
• Overcrowded conditions (housing units with more than one person per room); and
• Units with physical defects (lacking complete kitchen or bathroom
According to 2022 HUD CHAS data based on the 2015-2019 ACS, approximately 51% of Los Angeles County households experience housing problems, compared to 47% of households in Beverly Hills. In both the County and Hermosa Beach, renters are more likely to be affected by housing problems than owners.

Cost Burden
Regional Trend. As presented in 0, in Los Angeles County, approximately 44% of households are cost burdened. Renters experience cost burden at higher rates than owners (52.8% vs. 33.7%), regardless of race. Among renters, Black and Hispanic households are cost burdened at the highest rate (58.8% and 56.1%, respectively). All other racial/ethnic renter groups are cost burdened at a rate below the citywide average of 52.8% for renter-occupied households.

Geographically, tracts with larger populations of cost burdened owners are more concentrated in the central and south Los Angeles areas (Figure A-60). However, tracts with populations of owners exceeding 60% are dispersed throughout the region, including in coastal areas such as Santa Monica and East Los Angeles. Tracts with larger populations of overpaying renters are also prevalent throughout the County. Areas with smaller populations of overpaying renters include Pacific Palisades, Santa Monica, and some San Gabriel Valley cities (Figure A-61).

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Table A-17 Housing Problems and Cost Burden by
Race/Ethnicity – L.A. County (2019)
White Black Asian Amer.

Ind.

Pac. Isl. Hispanic All
With Housing Problem
Owner-Occupied 31.7% 41.3% 36.7% 34.7% 41.6% 45.8% 37.8% Renter-Occupied 51.9% 92.7% 56.1% 56.1% 54.0% 69.4% 61.2% All Households 41.0% 55.5% 45.7% 47.0% 49.5% 60.3% 50.5% With Cost Burden
Owner-Occupied 30.7% 39.8% 33.0% 33.1% 31.0% 36.7% 33.7% Renter-Occupied 48.6% 58.8% 47.3% 51.3% 45.3% 56.1% 52.8% All Households 38.9% 52.4% 39.7% 43.6% 40.1% 48.6% 44.1% Source: HUD CHAS Data (based on 2015-2019 ACS), 2022.

Housing problems and cost burdens can also affect special needs populations disproportionately. 0 shows that elderly renters and large renter households experience housing problems at rates exceeding the countywide average for renter-occupied households. Over 83% of large renter households have one or more housing problem but only 52.5% are cost burdened. This is likely due to the population of large households that are overcrowded. Large owner households also experience housing problems at a rate exceeding the countywide average for owner-occupied households. Approximately 56% of elderly renters are cost burdened compared to only 52.8% countywide. Elderly households are more likely to have fixed incomes and overpay for housing.

Table A-18 Housing Problems and Cost Burden by Household Type – L.A. County (2019)
Owner-Occupied Renter-Occupied All HHs Elderly Large HH All Owner Elderly Large HH All Owner Any housing problem 37.0% 52.1% 37.8% 65.7% 83.3% 61.2% 50.5% Cost burden >30% 37.8% 30.0% 33.7% 56.3% 52.5% 52.8% 44.1% Source: HUD CHAS Data (based on 2015-2019 ACS), 2022.

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Figure A-61. Regional Population of Cost Burdened Owners by Tract (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-62. Regional Population of Cost Burdened Renters by Tract (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Local Trends. Beverly Hills has a smaller proportion of households with housing problems but larger proportion of cost burdened households (47.7% and 45.4%, respectively, 0) compared to the County overall (50.5% and 44.1%, respectively, 0). As presented in 0, the Black and Asian household populations have higher percentages of housing problems than the rate of 47.4% citywide. However, the White households have the highest rate of cost burden compared to other racial/ethnic groups in Beverly Hills.

As shown in Figure A-62, between 40% and 80% of owners are cost burdened in most Beverly Hills tracts. Between 20% and 60% of renters are cost burdened in most Beverly Hills tracts (Figure A-63). A larger proportion of renters are cost burdened in the southeast corner of the City, south of Wilshire Boulevard.

Table A-19 Housing Problems and Cost Burden by
Race/Ethnicity – Beverly Hills (2019)
White Black Asian Amer.

Ind.

Pac. Isl. Hispanic All
With Housing Problem
Owner-Occupied 45.3% 0.0% 30.6% 0.0% -- 33.3% 44.3%
Renter-Occupied 49.1% 57.6% 57.5% 0.0% -- 41.3% 49.6%
All Households 47.4% 51.5% 48.2% 0.0% -- 40.3% 47.4%
With Cost Burden
Owner-Occupied 44.8% 0.0% 27.1% 0.0% -- 33.3% 43.6%
Renter-Occupied 46.8% 33.9% 53.8% 0.0% -- 40.6% 46.6%
All Households 45.9% 30.3% 44.5% 0.0% -- 39.6% 45.4%
Source: HUD CHAS Data (based on 2015-2019 ACS), 2022.

Like the trend countywide, larger owner- and renter-occupied households are more likely to experience housing problems in the City (Table D-20). Large households are also more likely to be cost burdened. Approximately 58% of large renter households and 49% of large owner households are cost burdened compared to only 47% of renters and 44% of owners citywide. Elderly renter households also overpay for housing at rates exceeding the citywide average.

The City has several policies in place and has taken action to address potential resident displacement. First, the City has had tenant protections in place for over 45 years, since the City’s Rent Stabilization Ordinance (RSO) was adopted in 1978. The RSO was recently updated in 2018, and a dedicated division of the Community Development Department, the Rent Stabilization Division, was established in 2018. Since this date, the City has dedicated significant resources to tenant protections through the Rent Stabilization Division, including the addition of dedicated staff members to this team: two customer service representatives, one management analyst, one enforcement officer, and one deputy director currently comprise this DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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team. Local knowledge regarding housing conditions has been provided with the input of Rent Stabilization Division staff, including the Deputy Director of Rent Stabilization, as follows:
• Housing Conditions and Habitability: There are not necessarily concentrated areas of the City in which habitability and maintenance issues are more prevalent, however, buildings with non-institutional landlords may be more likely to
experience maintenance issues. Anecdotally, this lack of maintenance is often due to a lack of resources available to such landlords. Generally, since multi-family residential housing is located in the area of the City south of Santa Monica Boulevard, the majority of rent-stabilized housing units are also located in this area. As such, there would be a higher
concentration of potential issues with housing conditions in this area, though there is not a specific census tract or block in which these issues are concentrated. Habitability complaints are assigned to the Rent Stabilization Code Enforcement Officer for initial response (site visit) to confirm any violations.

Confirmed violations result in the issuance of Notice of Violation establishing a compliance date for follow up and possible further enforcement to ensure compliance. The Division also publishes information on its website aimed to both educate and inform owners and tenants of habitability regulations.

When a habitability complaint is received, a general site inspection is performed to ensure the overall condition of the unit is code compliant. When possible, complaining party information is protected. The owners are provided with code and regulation information aimed to set expectations and prevent further reoccurrence. Additionally, during
construction/repairs (within an occupied unit) regulated by the Means and Method Plan, the RS code enforcement officer
monitors construction activity and responds to tenant
complaints related to construction impacts or deviations from city approved mitigation measures.
• Displacement Prevention: The Rent Stabilization Division provides several services to help prevent displacement. The Division offers free legal services to elderly and income-eligible residents through a contract with Bet Tzedek, and the City has various contracts through the Human Services Division for elderly tenants or other tenants who are displaced. The Rent Stabilization Division also has Just Cause eviction protections in place which require the provision of relocation fees. The City requires that landlords submit information on each of their units on an annual basis (known as the rent registration process).

Staff subsequently vets these submissions for any violating rent increases or other violations of the RSO, and requires landlords to come into compliance with these protections by rescinding DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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any increase in excess of the allowable and issuing tenants a credit where owed. After staff vetting, tenants have the right to appeal the rent amount reported by their landlord to the City is they feel it is not accurate or that the rent amount paid is not fair.

The Affordable Housing staff also works on placing income-qualified tenants into the set-aside affordable housing units in the City. This process looks at both income qualification, and the City’s housing priority list. The priority list was recently updated in 2019, and specifically provides priority for qualified tenants who have been displaced by redevelopment in the City and may have other unique housing needs (such as senior citizens, families with children in the Beverly Hills Unified School District). The priority list gives priority in the following order: senior applicants who were displaced from the particular development site, applicants with students in the BHUSD system that were displaced from the particular development site, any applicant who was displaced from the particular development site, senior applicants who were displaced from any site in the City due to redevelopment, applicants with students in the BHUSD system who were displaced from any site in the City due to redevelopment, and applicant who was displaced from any site in the City due to redevelopment, senior applicants, and all other applicants.

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Table A-20 Housing Problems and Cost Burden by Household Type – Beverly Hills (2019)
Owner-Occupied Renter-Occupied All HHs Elderly Large HH All Owner Elderly Large HH All Renter Any housing problem 43.4% 49.3% 44.3% 63.8% 57.5% 49.6% 47.4% Cost burden >30% 42.4% 49.2% 43.7% 51.1% 57.5% 46.6% 45.4% Source: HUD CHAS Data (based on 2015-2019 ACS), 2022.

Figure A-63. Population of Cost Burdened Owners by Tract (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-64. Population of Cost Burdened Renters by Tract (2021) Overcrowding
Regional Trends. Overcrowding is defined as housing units with more than one person per room (including dining and living rooms but excluding bathrooms and kitchen). According to 2016-2020 ACS estimates, 11.2% of households in Los Angeles County are living in overcrowded conditions (0). About 16% of renter households are living in overcrowded conditions in the County, compared to only 5.7% of owner households. Similarly, 7.4% of renter households are severely overcrowded, with more than 1.5 persons per room, compared to only 1.6% of owners. According to 2015-2019 HUD CHAS data, there 203,320 large renter-occupied households with five or more persons, representing 11.3% of renters countywide. There are slightly more large owner households, 214,590, representing 14.1% of owners countywide.

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Table A-21 Overcrowded Households by Tenure – Los Angeles County (2020)
Owner-Occupied Renter-Occupied Total
Household
s
Percent Household
s
Percent Household
s
Percent
Overcrowded
(>1.0 persons per
room)
87,325 5.7% 286,881 16.0% 374,206 11.2%
Severely
Overcrowded (>1.5
persons per room)
23,819 1.6% 133,699 7.4% 157,518 4.7%
Total 1,534,472 100.0% 1,798,032 100.0% 3,332,504 100.0% Source: 2016-2020 ACS (5-Year Estimates).

As presented in Figure A-64 below, tracts with larger populations of overcrowded households in the region surrounding Beverly Hills are most prevalent in the central and south County areas in and around the cities of Los Angeles, Compton, Hawthorne, South Gate, and parts of Long Beach. Coastal County areas, from Malibu to Ranchos Palos Verdes, are nearly all comprised of tracts with populations of overcrowded households below 5%. As discussed throughout this Assessment of Fair Housing Issues, coastal Los Angeles County areas also have smaller racial/ethnic minority populations, fewer LMI households, and higher median incomes compared to inland County areas.

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Figure A-65. Regional Overcrowded Households by Tract (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Local Trends. Overcrowding is generally not an issue in the City compared to the County. As shown in 0, 0.7% of owner-occupied households and 5.1% of renter-occupied households ae
overcrowded. Only 0.2% of owner households and 4% of renter households are severely overcrowded. According to the HCD Data Viewer 2.0, there are no tracts in Beverly Hills where more than 5% of households are overcrowded.

Table A-22 Overcrowded Households by Tenure – Beverly Hills (2020)
Owner-Occupied Renter-Occupied Total
Households Percent Households Percent Households Percent Overcrowded
(>1.0 persons per room)
45 0.7% 422 5.1% 467 3.2%
Severely Overcrowded
(>1.5 persons per room)
14 0.2% 335 4.0% 349 2.4%
Total 6,365 100.0% 8,320 100.0% 14,685 100.0%
Source: 2016-2020 ACS (5-Year Estimates).

Figure A-66. Overcrowded Households by Tract (2021)
Substandard Housing Conditions
Regional Trends. Incomplete plumbing or kitchen facilities can be used to measure substandard housing conditions. Incomplete facilities and housing age are estimated using the 2016-2020 ACS. In general, residential structures over 30 years of age require minor DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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repairs and modernization improvements, while units over 50 years of age are likely to require major rehabilitation such as roofing, plumbing, and electrical system repairs.

According 2016-2020 ACS estimates, shown in 0, 1.6% of households in Los Angeles County lack complete kitchen facilities and 0.5% lack complete plumbing facilities. Incomplete facilities affect renter households more than owner households. Approximately 0.4% of owner households lack complete kitchen facilities and 0.3% lack complete plumbing facilities compared to 2.6% and 0.6%, respectively, amongst renter households countywide.

Housing age can also be used as an indicator for substandard housing and rehabilitation needs. As stated above, structures over 30 years of age require minor repairs and modernization improvements, while units over 50 years of age are likely to require major rehabilitation. Housing units vary in age throughout the region. In general, coastal areas including Malibu, Santa Monica and Redondo Beach, have younger housing structures compared to south, east, and central Los Angeles County, with the exception of the Downtown LA area (Figure A-66)
Table A-23 Substandard Housing Conditions by Tenure – L.A.

County (2020)
Owner-Occupied Renter-Occupied Total
Household
s
Percent Household
s
Percent Household
s
Percent
Lacking complete
kitchen facilities
6,186 0.4% 46,465 2.6% 52,651 1.6%
Lacking complete
plumbing facilities
3,884 0.3% 11,381 0.6% 15,265 0.5%
Total 1,534,472 100.0% 1,798,032 100.0% 3,332,504 100.0% Source: 2016-2020 ACS (5-Year Estimates).

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Figure A-67. Regional Age of Housing Structures by Tract (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Local Trends. There are no owner-occupied households in Beverly Hills lacking complete plumbing facilities (0). Of all Beverly Hills households,

1.5% lack complete kitchen facilities and 0.5% lack complete plumbing facilities, comparable to the trend countywide. As shown in Figure A-67, tracts along the western City boundary tend to have older housing units compared to other areas of Beverly Hills.

Table A-24 Substandard Housing Conditions by Tenure –
Beverly Hills (2020)
Owner-Occupied Renter-Occupied Total
Household
s
Percent Household
s
Percent Household
s
Percent
Lacking complete
kitchen facilities
29 0.5% 192 2.3% 221 1.5%
Lacking complete
plumbing facilities
0 0.0% 68 0.8% 68 0.5%
Total 6365 100.0% 8320 100.0% 14685 100.0%
Source: 2016-2020 ACS (5-Year Estimates).

Figure A-68. Age of Housing Structures by Tract (2021)
Displacement
Regional Trends. UC Berkley’s Urban Displacement project defines residential displacement as “the process by which a household is forced to move from its residence - or is prevented from moving into a neighborhood that was previously accessible to them because of conditions beyond their control.” As part of this project, the research has identified populations vulnerable to displacement (named “sensitive communities”) in the event of increased redevelopment DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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and drastic shifts in housing cost. Vulnerability is defined based on the share of low-income residents per tract and other criteria including:
share of renters above 40%, share of people of color more than 50%, share of low income households severely rent burdened, and proximity to displacement pressures. Displacement pressures were defined based on median rent increases and rent gaps. Using this methodology, sensitive communities in the Los Angeles County region surrounding Beverly Hills were identified throughout the central and south County areas. Sensitive communities are the most
concentrated in the area spanning from West Hollywood, throughout the City of Los Angeles, Inglewood, Compton, and El Monte. There are significantly fewer sensitive communities in the coastal County cities from Malibu to Ranchos Palos Verdes. As mentioned previously, this area also has smaller non-White and LMI household populations and higher median incomes compared to inland County areas.

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Figure A-69. Regional Sensitive Communities At Risk of Displacement by Tract (2022) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Local Trends. As shown in Figure A-69, there are no tracts in Beverly Hills that are considered at risk of displacement.

Displacement of low-income households can occur through the expiration of affordability restrictions on assisted low-income housing, escalation of market rents, or demolition of existing rental units. As noted in the Needs Assessment of this Housing Element, there are no low-income rental projects at risk of conversion to market rate during the 2021-2031 period.

Figure A-70. Sensitive Communities At Risk of Displacement by Tract (2022)
Unhoused Conditions & Homelessness
The Los Angeles Homeless Services Authority (LAHSA) estimates there were 69,144 persons experiencing homelessness in the Los Angeles County, based on the 2022 Greater Los Angeles Homeless Point-inTime (PIT) Count. Figure A-55 shows the Los Angeles County unhoused populations from 2017 to 2022. As of 2022, 70% of the unhoused population is unsheltered and 30% is sheltered. The proportion of sheltered individuals has increased slightly since 2017, when 27.2% of the population experiencing homelessness was sheltered. The unhoused population has increased over 25% since 2017, and 4.1% since 2020.

As shown in Table D-28, of the individuals experiencing homelessness,

3.5% were transitional age youths aged 18 to 24 and 0.2% were DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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unaccompanied minors under the age of 18. Another 5.7% of the unhoused population were veterans and 41.3% were experiencing chronic homelessness. A household is considered chronically unhoused if any of its members have (1) a long-term disabling condition; and (2) been unhoused for 12 months or more within the last 3 years as specified by HUD.

There are many emergency shelters in Los Angeles County.

Emergency shelters are most prevalent in the central County areas such as the City of Los Angeles.

Figure A-71. LA County Population of Persons Experiencing Homelessness (2017-2022)
Note: LA County data includes the Los Angeles Continuum of Care, and the cities of Pasadena, Glendale, and Long Beach.

Source: Los Angeles County Homeless Services Authority (LAHSA) Greater Los Angeles Homeless Count – Los Angeles County, 2017-2022.

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Table A-25 Characteristics of Persons Experiencing
Homelessness – LA County (2022)
Sheltered Unsheltered Total
Persons Percent
Total Persons 20,596 48,548 69,144 --
Total Households 14,248 47,586 61,834 --
Individuals (those not in
family units)
11,153 47,098 58,251 --
Transitional Age Youth
(18-24)1
994 1,073 2,067 3.5%
Unaccompanied
Minors (under 18)1
116 5 121 0.2%
Family Households (at
least 1 child under 18)
3,095 488 3,583 --
All Family Members 9,443 1,450 10,893 --
Veterans2 929 3,013 3,942 5.7%
People Experiencing
Chronic Homelessness
(all)2
4,992 23,584 28,576 41.3%
Notes: 1 = percent of individuals; 2= percent of total persons.

Source: LAHSA 2022 Greater Los Angeles Homeless Count – Los Angeles County.

Figure A-72. Emergency Shelters – Los Angeles County (2021) The last count, which was conducted in January 2023, found approximately 75,518 people were experiencing homelessness across DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Los Angeles County. According to data released by LAHSA, that number jumped up by 9% from 2022, which found 69,144 unhoused people in the county. Of those 69,144, LAHSA reported 39 were in Beverly Hills. All 39 people were unsheltered; 36 were living on the street and 3 were living in tents.

According to the 2022 Homeless Count data for Beverly Hills tracts, there were 33 people experiencing homelessness in tract 7007, 3 in tract 7008.01, and 3 in tract 7010. A map of the tracts in Beverly Hills is shown as Figure A-72. The northwestern tract, 7007, has the largest population of people experiencing homelessness. This tract is considered an RCAA.

The City’s Community Services team works closely on homelessness issues in the city, and provided some local knowledge regarding the unhoused population patterns. The staff provided the following input:
• Location of Unhoused Populations: Unhoused populations are often concentrated in the parks, followed by the City Library and the Business Triangle area (downtown commercial core area). The parks are concentrated with these populations because the parks are well-maintained and safe, with Park Rangers providing nearly 24/7 coverage, which creates a safe environment for the unhoused. Beverly Gardens runs the entire length of the north side of North Santa Monica Blvd, and the Maltz Mini Park and Will Rogers Park are also located in the northwest area of the city. The City Library is popular because it is indoors, has free computers and internet access, and the unhoused outreach teams are based in the Library, and
libraries are welcoming and do not turn people away. The Business Triangle area also remains a popular area for
panhandling or soliciting handouts from residents and
shoppers. All of these areas are located within census tract 7007, which is why there is a slight concentration in this tract.

The Will Rogers Park and Beverly Gardens Park, which are both located have unhoused people in them every day.
• Unhoused Population Characteristics: The unhoused persons that are often located in the City are individuals, not families (no children); 72% are men, 17% are female and the remaining 11% are unknown or other. Amongst this population, there are no known Veterans or victims of domestic violence among our chronically unhoused. From March 1 — December 31, 2023 the City’s outreach teams made contact with 1,450 unduplicated unhoused individuals through 14,261 encounters. Many of these individuals do not spend the night in Beverly Hills, and many come through the city on their way to another
destination. Of those who spend the night in Beverly Hills, almost all are living outside with no tents or vehicles. From March 1 — December 31, 2023 there were approximately four separate DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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unhoused individuals using their cars as shelter, and no unhoused individuals using tents for shelter. The majority of the unhoused are male and between the ages of 25-69. In
addition, there are several categories of the unhoused
population in the City:
o Chronically homeless individuals have a disabling
condition, and have been homeless for a year or more,
or have had at least four episodes of homelessness in
the past three years. These individuals are well known to the Beverly Hills Police Department patrol officers, Park Rangers, outreach workers, librarians, businesses, and
the faith community, and are often the source of calls
received by the City’s Ambassadors, Rangers, Police,
and outreach team. They usually have co-occurring
substance use disorders and mental illness, and many
have been unwilling to take advantage of services
when they are offered.
o Non-Chronically or recently or situationally homeless people have lost their housing during the past year for reasons such as losing a job, medical bills, marital
breakdown, or a property owner’s decision to go out of
the rental business.
o Transients often find their way to Beverly Hills and use services such as meals and food pantries offered by the faith community inside the City or in adjacent cities.

Some of these people may be willing to return to their
home outside of Los Angeles County or out of state if
resources are available.
o People at imminent risk of homelessness are City
residents who have experienced life changes that
affect their ability to remain housed. Interventions,
including rental assistance and case management, can
prevent an increase in homelessness among City
residents.
• Access to Services: The City provides outreach services to unhoused persons, which includes providing information
regarding access to the various services provided by the City.

These staff members include Park Rangers, Ambassadors,
Police, and the City’s third-party security services. However, the City also has staff dedicated to homelessness outreach, called the Beverly Hills Outreach Team, which is contracted through five staff members from the organization “Step-Up on Second”.

This team is in the field seven days a week, and focuses on connecting long-time unhoused individuals residing in Beverly Hills with supportive services to move from the streets into permanent housing, and quickly linking new arrivals to services throughout the region that will address their immediate needs.

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engagement and assessment, and then, developing a plan
appropriate to their presenting issue. Case management
services may include: family reunification, linkages to benefits, food, medical/mental health, shelter beds, permanent
supportive housing and other pertinent supports. The program was launched in November 2023, and as such, there is not robust data available on the utilization of these services.

However, prior to the start of this program, the Community Services team would refer unhoused persons to services and other shelters, and currently there are 19 units remaining out of 30 units available for emergency or transitional shelter. At least 10 of the chronically unhoused persons located in the city have turned down the housing units available, but the outreach team will continue to offer the units.

Figure A-73. Beverly Hills Census Tracts (2020)
Other Relevant Factors
Historical Overview of the Development of Beverly Hills10 An overview of the development of the area now incorporated as the City of Beverly Hills is provided herein to set the framework for the Fair Housing section of the Housing Element. This history is not necessarily all-encompassing, but rather is a focused history intended to provide context for understanding the existing land use and housing patterns in the city; to help aid in the identification of fair housing issues; and to

10 Source: Historic Resources Group (HRG)
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use the past to inform future policies and actions that the City can undertake to affirmatively further fair housing.

The Los Angeles basin and southern coast, including the area encompassing Beverly Hills was historically occupied by the Native American tribe known as the Gabrieleño (or Gabrieliño or Gabrielino).

The Gabrieleño established large permanent villages throughout their territory. The name Gabrieleño was applied by the Spanish to those natives that were attached to Mission San Gabriel. Today, most contemporary Gabrieleño prefer to identify themselves as Tongva; however, one contemporary group, the Gabrieleño Band of Mission Indians – Kizh Nation, prefer the term “Kizh.” The first Europeans to come to Beverly Hills were the Spanish explorers of the Gaspar de Portola party who passed through the area in 1769. Further development, however, did not take place for another fifty years.

Around 1822, Mexican settlers Maria Rita Valdez and her husband Vicente Valdez were granted the Rancho Rodeo de las Aguas (Ranch of the Gathering of the Waters) by the Mexican government.

In 1854, the ranch was sold to Benjamin Davis "Don Benito" Wilson and Major Henry Hancock. Both were major figures in the development of Southern California. Hancock and Wilson planned to farm the ranch; however, their efforts failed after the first year due to a severe drought, which affected many other area landowners as well. As a result, many ranchos were sold off piecemeal to smaller landowners. Small parcels of Rancho Rodeo de las Aguas were sold off during the 1860s. They subdivided the ranch into 75-acre farms, and reserved a site at the center of the farms for the proposed community of “Santa Maria.” However, the Preuss and Temple subdivision plan was not successful.

Subsequently, much of the rancho passed into the hands of Henry Hammel and Charles Denker.

Hammel and Denker farmed the land and raised cattle until Southern California entered a land boom in the late 1880s. At that time, the two men proposed their own town site for the area, to be called “Morocco.” Morocco was centered around a proposed train station, dubbed “Morocco Junction,” at the intersection of what was then Burton Way and Santa Monica Boulevard (in the vicinity of Canon and Beverly Drives today). Plans for Morocco were never fully realized, however. After the collapse of the real estate boom the property was sold to the Amalgamated Oil Company in 1900. Partners in the Amalgamated Oil Company included well-known entrepreneurs Charles Canfield, Max Whittier, Burton Green, and Henry Huntington.

As the name of the company indicated, the men had hoped to find oil on the ranch, which they renamed Morocco Junction. Their drilling efforts were unsuccessful, however, and the venture ultimately failed.

In 1906, the company was reorganized as the Rodeo Land & Water Company, with many of the same partners. The new endeavor DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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focused its efforts on subdividing the Beverly Hills area as a real estate development. At this time, the ranch boundaries were Whittier Drive on the west, Doheny Drive on the east, Wilshire Boulevard on the south, and the foothills above Sunset Boulevard on the north. Burton Green played a leading role in formulating the plans for a garden city.

The syndicate hired landscape architect Wilbur D. Cook, Jr. to plan the community. Cook had worked with noted landscape architect Frederick Law Olmsted, famed designer of New York's Central Park and several garden communities across the United States.

The developers filed subdivision maps based on the Cook Plan (Figure A-67) in 1906 and 1907 and began to build model homes, but the Rodeo Land & Water Company's plans for development languished during the depression of 1907-1908, in part due to the location that was a considerable distance west of the center of downtown Los Angeles. To inspire people to come to Beverly Hills, the Rodeo Land & Water Company financed a hotel that would introduce the area to tourists and establish the reputation of the proposed development. As a result, the Beverly Hills Hotel was constructed in 1911-1912. Even with the addition of this important amenity, residential development in Beverly Hills remained slow through the second decade of the 20th century.

A campaign for the city to incorporate in order to address water and school issues was initiated around the same time, and it was formally incorporated in 1914. By 1915, the City boundaries became similar to what they are today, with the annexation of the area south of Wilshire Boulevard. At the time of incorporation, most of the city was still open land. Early development was sparse, concentrated around Cañon Drive, Beverly Drive, Crescent Drive, the downtown triangle, and hillside areas.

The arrival of the1920s marked the beginning of a period of dramatic change for Beverly Hills. The majority of its residential and commercial lots were still vacant, but enough development had occurred to make it clear that a town was being formed. The Los Angeles Auto Speedway occupied the area south of Wilshire and west of Beverly Drive (later defunct and subdivided after 1924 for housing as the Speedway Tract 7710), and a long grove of eucalyptus ran along the approximate route of Charleville. All of the area south of Wilshire, west of Roxbury, and east of Foothill was vacant. The City experienced a rapid and significant transformation in the 1920s and 1930s.

Development during this period created the basic form and architectural character of Beverly Hills as we know it today.

Commercial development in the downtown core and multi-family residential development in the area south of Wilshire and Santa Monica Boulevards completed the transformation of the city. Many other members of the upper echelon of the entertainment industry DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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followed, and the city quickly became the “social center of the movie colony and goal of tourists,” as W.W. Robinson noted in his 1939 history of Beverly Hills.

As the population of Beverly Hills skyrocketed during the 1920s, rising from less than 700 people in 1920 to 12,000 in 1926, there was an overwhelming demand for housing. Many developers turned to constructing multi-family residences, and the duplex, fourplex, and central hall apartment building all became significant housing types in the southern section of the city during this period. Many of these “middle housing” types still exist as part of the housing stock in the city today.

Downtown commercial development also flourished during the 1920s.

Beverly Hills was fully developed within the current city limits by the end of the 1940s, even though construction throughout the country largely halted during World War II. The city continued to develop during the postwar era through the subdivision of large estates and the demolition of existing structures for higher-density apartments, stores, and offices. An entirely new residential area was created when the Trousdale Estates neighborhood was subdivided on former Doheny family ranch land in 1955. The subdivision was designed to provide each lot with a view of the Los Angeles basin, with each lot terraced up the slope of the hillside, and restrictions related to maximum building heights. The configuration of the majority of these lots have remain unchanged from the original subdivision in 1955.

From the 1950s onward, Beverly Hills continued to gain prominence as a center of commercial and retail activity. During the 1960s and 70s, Beverly Hills’ downtown urbanization continued until the westernmost section of the downtown triangle was the most densely developed office cluster outside of downtown Los Angeles. By the 1980s, new construction in Beverly Hills was scattered throughout the City on undeveloped properties in the hills and on redeveloped parcels in the residential and commercial sections of the "flats."
Historical Policies and Practices Leading to Patterns of Unequal Access
According to Affirmatively Furthering Fair Housing: Guidance for All Public Entities and for Housing Elements (April 2021 Update), HCD identifies factors such as “past redlining and greenlining, patterns of institutionalization, restrictive covenants and other discriminatory practices, presence and history of place-based investment, mobility option patterns and outreach and community engagement” as examples of relevant factors that may have existed across the state and should be considered in the assessment of fair housing.

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The City’s research has identified three major contributing factors that may have led to patterns of unequal access to housing and housing financing. These factors have also been documented throughout the Los Angeles region, Westside sub-region, and were found to have existed in Beverly Hills.
a. Master Planned Community11
A lesser known fact about Beverly Hills may be that it represents one of the earliest master-planned communities in Southern California, dating from the turn of the 20th century. The Rodeo Land & Water Company commissioned landscape architect and urban planner Wilbur Cook and architect Myron Hunt to design the master plan for the new community of Beverly Hills. Cook is believed to be largely responsible for convincing the members of the Rodeo Land & Water Company to develop “an economically balanced community,” which included both upscale and middle class development set within a lush, park-like environment. The relatively remote location of Beverly Hills necessitated providing housing for the workers who served the middle-class and wealthy residents that they most hoped to attract to the city.

Beverly Hills as envisioned by Cook was one of the earliest planned communities in Southern California. Cook designed a three-tiered plan that included modest lots of 50 by 150 feet that housed small, working-class dwellings in the southern portion of the city. Lots grew larger as the city plan extended to the north, encompassing the moderately-sized lots for middle-class residents in the “flats” between Santa Monica and Sunset Boulevard. The largest lots for the city’s wealthiest residents extended north from Sunset Boulevard and started at 80 by 175 feet, with some lots comprising more than five acres.

The City was designed so that there was a transition from the smaller lots at its southern edge to the large estates in the foothills to the north. Cook also developed the street plan for Beverly Hills, and at Clark’s suggestion designed a loose network of gently curving streets that followed the rolling contours of the landscape.

The curved streets form a “tulip plan,” which is unique to the area.

The elite northern portion was divided from the southern portion by the railroad tracks and a commercial triangle between Santa Monica and Wilshire Boulevards. At the base of the “tulip,” opposite the train station, three blocks were set aside for a park.

Land along the railway line east of Canon Drive was set aside for industrial uses. The part of the City that lies below the train tracks

11 Source: Historic Resources Group (HRG)
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(along present day Santa Monica Boulevard) that was set-aside for the “support community” and adheres to a strict orthogonal grid plan. Lush landscaping and generous setbacks were
employed to create the park-like setting the developers had envisioned. A master planting scheme was also implemented throughout the city’s residential streets. In addition to their layout, the streets of Beverly Hills were distinctive for their generous width.

Streets were between 70 and 90 feet wide and boulevards and drives were between 100 and 110 feet in width. As one visitor to Beverly Hills recalled in August of 1907, “With its broad curving avenues sweeping from the [street] car line to the very crest of the foothills, it presents the spectacle of a magnificent park.” This master-planned layout is illustrated in an early map of the Cook Plan included as Figure A-74. As a result of this plan, the city continues to offer a variety in the size, scale, and typology of its housing stock.

The Cook Plan cemented the pre-planned and pre-plotted nature of the city of Beverly Hills over a century ago. The absence of any undeveloped tracts and larger re-developable parcels is a significant constraint on how and where redevelopment can occur in the city today. Working within this fixed urban layout, the City rezoned (by way of an overlay zone) entire commercial corridors to allow for adaptive reuse of existing buildings or redevelopment of sites to include housing all across the Mixed Use Overlay Zone. Additionally, expanded ADU regulations provide the opportunity to introduce additional housing units in residential zones within this contained context.

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Figure A-74. Cook Plan of Beverly Hills (1929)
b. Restrictive Covenants
Racially restrictive covenants were restrictions placed on the deed of properties to prohibit the sale to specified racial groups. The restrictions were presumed to be enforceable contacts between the selling and buying parties when this practice was first implemented. Many racially restrictive covenants precluded the sale or rental of property to Blacks, Jews, Asians, Hispanics, and others. In Shelley v. Kraemer in 1948, the United States Supreme Court held that racially restrictive covenants were not enforceable in a court of law. The federal Fair Housing Act of 1968 further struck down such agreements from being legal, and California law renders any such covenants unenforceable. Although illegal for more than 50 years, racially restrictive language remains visible in deed instruments. Restrictive clauses were included in early deeds which barred working-class African Americans and Asians from buying land or even occupying property except as live-in servants12. The presence of such racially restrictive language has been found in older deeds of Beverly Hills properties (the count of such covenants is unknown). The impact and legacy of such exclusions can be felt in the makeup of the community today.

12 Source: Historic Resources Group (HRG)
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Certain excluded racial groups were by some means able to overcome these prejudices and move into Beverly Hills in sizable numbers. For example, the presence of a Jewish population in Beverly Hills is documented as early as the 1920s, and continued to rise throughout the 20th century, to an estimated 20,500 population in 199713. The rise of the Jewish population in Beverly Hills follows the rise of the overall Jewish population in greater Los Angeles, as well as the group’s migration pattern after 1940 westward across the city from eastern Los Angeles neighborhoods to the Westside, including a strong enclave in Beverly Hills14.

Additionally, Iranian immigrants took up residence in Beverly Hills in large numbers following a mass exodus out of Iran in the late 1970s and 1980s (notably, an era after racially restrictive covenants were enforceable in America). Today the Iranian or Persian diaspora, including a large Persian Jewish community, constitute a significant and important population in Beverly Hills. One estimate placed the Iranian population in Beverly Hills at approximately 8,000 in 2007, constituting over 20% of the City’s population15. Had their era of migration been decades earlier, these populations might have been part of the racially excluded groups in the covenant restrictions that existed in the first half of the 20th century.

On the contrary, the lack of other racial minorities such as Blacks and Hispanics in significant numbers as reflected in the City’s population demographics may, in large part, be an enduring result of these types of historical restrictions in Beverly Hills and surrounding areas.
c. Redlining
The term “redlining” refers to the discriminatory policy instituted by the federal government to create color-coded maps of every metropolitan area in the country to indicate where it was a safer business decision to insure a mortgage. The Home Owners Loan Corporation (HOLC) was a federal agency created during the New Deal policy reforms that created this neighborhood ranking system. Local real estate developers and appraisers in over 200 cities across America then assigned grades to residential neighborhoods shown on color-coded maps. These grades were based on racial composition, quality of housing stock, access to amenities, etc. and were color coded to identify best (green “A” grade), still desirable (blue “B” grade), definitely declining (yellow “C” grade), and hazardous (red “D” grade) neighborhoods. Areas

13 American Jewish Year Book, 2008. Jewish Population in the United States. Table 1, p. 177. 14 City of Los Angeles, Department of City Planning. Survey LA: Citywide Historic Context Statement, Jewish History. December 2016.
15 Geis, Sonya. "Iran Native Becomes Mayor of Beverly Hills". The Washington Post, April 1, 2007.

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that were predominantly commercial/industrial were not color coded. Redlining as a practice was discriminatory in that it led to the systematic denial of mortgages, insurance, loans, and other financial services based on location and demographics rather than the creditworthiness and qualifications of an individual borrower.

The map provided as Figure A-75 shows that this was a practice employed across the Los Angeles region. Figure A-61 shows that no areas within the city of Beverly Hills were “redlined” or given a “D”/hazardous grade. All of the city north of Santa Monica Boulevard was given an “A”/best grade, while the southern portion of the city was graded “B”/still desirable and
“C”/declining. This means that areas in the City of Beverly Hills benefitted the most from these insurance/loaning practices, which may have resulted in the opposite effect of concentrating investment into desirable (mostly white) neighborhoods. These historical practices may be in part accredited for the entire city falling within the “highest resource area” status on the TCAC/HCD Opportunity Area Map.

Figure A-75. Home Owners Loan Corporation Redlining Map, Los Angeles and Vicinity Map
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Figure A-76. Home Owners Loan Corporation Redlining Grade Map (University of Richmond, 2021)
Sites Inventory
To ensure sites selected to meet the City’s RHNA affirmatively further fair housing, an analysis of the sites by AFFH variable and income level are described below. The following fair housing sites inventory analysis includes underutilized sites, conversion units, units with developer interest, approved projects, submitted projects, and City projects.

Approved and submitted projects include all proposed units. The total proposed units for approved and submitted projects may differ slightly from net units. However, this analysis uses proposed units for mathematical consistency (i.e., lower income units + moderate income units + above moderate-income units = total units).

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Segregation and Integration
As shown below, all tracts in the City have non-White populations of up to 40%. Most sites selected to meet the RHNA are in the southern area of the City where 20% to 40% of the population belongs to a racial or ethnic minority group.

More than 75% of RHNA units are in tracts where less than 10% of the population experiences a disability (Table A-18 and Figure A-60). A larger proportion of lower income units are in the tract where more than 40% of persons experience a disability compared to moderate and above moderate-income units.

Sites selected to meet the RHNA are distributed between tracts with populations of children residing in married couple households ranging from 40% to 60% and 60% to 80% (Table A-19). There are 333 above moderate income RHNA units in a tract where more than 80% of children reside in married couple households. Most units are in tracts where 60% to 80% of children reside in married couple households.

There are no RHNA units in tracts where more than 40% of children reside in single-parent female-headed households (Table A-20).

There are no LMI areas in the City. Therefore, none of the sites selected to meet the RHNA are in tracts that are considered LMI areas. Most sites selected to meet the RHNA are in tracts where 25% to 50% of households are low or moderate income (Table A-21).

Table A-26 Distribution of RHNA Units by Non-White Population Non-White
Population
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <20 0 0.0% 0 0.0% 333 33.9% 333 5.3%
20-40 1924 100.0% 3432 100.0% 649 66.1% 6005 94.7%
40-60 0 0.0% 0 0.0% 0 0.0% 0 0.0%
60-80 0 0.0% 0 0.0% 0 0.0% 0 0.0%
>80 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
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Table A-27 Distribution of RHNA Units by Population of Persons with Disabilities
Persons with
Disabilities
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <10% 1188 61.7% 2907 84.7% 755 76.9% 4850 76.5%
10-20% 319 16.6% 452 13.2% 96 9.8% 867 13.7%
20-30% 417 21.7% 73 2.1% 131 13.3% 621 9.8%
30-40% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
>40% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
Table A-28 Distribution of RHNA Units by Children in Married Couple Households
Children in
Married
Couple HHs
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <20% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
20-40% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
40-60% 736 38.3% 525 15.3% 227 23.1% 1488 23.5%
60-80% 1188 61.7% 2907 84.7% 422 43.0% 4517 71.3%
>80% 0 0.0% 0 0.0% 333 33.9% 333 5.3%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
Table A-29 Distribution of RHNA Units by Children in Female-Headed Households
Children in
Married
Couple HHs
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <20% 652 33.9% 1780 51.9% 520 53.0% 2952 46.6%
20-40% 1272 66.1% 1652 48.1% 462 47.0% 3386 53.4%
40-60% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
60-80% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
>80% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
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Table A-30 Distribution of RHNA Units by LMI Households Children in
Married
Couple HHs
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <25% 309 16.1% 406 11.8% 449 45.7% 1164 18.4%
25-50% 1615 83.9% 3026 88.2% 533 54.3% 5174 81.6%
50-75% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
75-100% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
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Figure A-77. Distribution of RHNA Units by Non-White Population (2019)
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Figure A-78. Distribution of RHNA Units by Disabled Population (2021)
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Figure A-79. Distribution of RHNA Units by Children in Married Couple Households (2021)
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Figure A-80. Distribution of RHNA Units by Children in FemaleHeaded Households (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Racially/Ethnically Concentrated Areas
There are no TCAC areas of high segregation and poverty in the City.

As discussed previously, the northern area of the City is considered an RCAA. The City has identified sites with a capacity of 333 above moderate-income units north of Santa Monica Boulevard in an RCAA area. The remaining units selected to meet the RHNA are not in RCAA communities. This excludes ADUs projected by the City. The City’s ADU program specifically encourages new housing units in the northern area of Beverly Hills to increase housing opportunities in this RCAA.

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Figure A-81. Distribution of RHNA Units RCAAs (2019)
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Access to Opportunities
All RHNA units are in tracts that are considered highest resource areas.

Figure A-82. Distribution of RHNA Units by TCAC Opportunity Area DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Disproportionate Housing Needs
Nearly 75% of units selected to meet the RHNA are in tracts where 40% to 60% of owners are cost burdened including 62% of lower income units, 85% of moderate-income units, and 43% above moderateincome units. An additional 17% of lower income units, 13% of moderate-income units, and 10% of above moderate-income units are in tracts where less than 20% of owners are cost burdened. The remaining units are in tracts where 60% to 80% of owners overpay for housing. Units are distributed throughout tracts where 20% to 80% of renters are cost burdened (Table A-23). Approximately 15% of RHNA units are in tracts where 20% to 40% of renters are cost burdened, 40% where 40% to 60% are cost burdened, and 45% where 60-80% are cost burdened.

There are no RHNA sites in tracts with populations of overcrowded households exceeding 5%.

Most RHNA units, including 72% of lower income units, 67% of moderate-income units, and 76% of above moderate-income units are in tracts that are not considered sensitive communities at risk of displacement. The City’s RHNA strategy does not disproportionately place lower income units in areas with sensitive communities.

Table A-31 Distribution of RHNA Units by Cost Burdened Owners Overpaying
Owners
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <20% 319 16.6% 452 13.2% 96 9.8% 867 13.7%
20-40% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
40-60% 1188 61.7% 2907 84.7% 422 43.0% 4517 71.3%
60-80% 417 21.7% 73 2.1% 464 47.3% 954 15.1%
>80% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
Table A-32 Distribution of RHNA Units by Cost Burdened Renters Overpaying
Renters
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent <20% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
20-40% 417 21.7% 73 2.1% 464 47.3% 954 15.1%
40-60% 791 41.1% 1466 42.7% 283 28.8% 2540 40.1%
60-80% 716 37.2% 1893 55.2% 235 23.9% 2844 44.9%
>80% 0 0.0% 0 0.0% 0 0.0% 0 0.0%
Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
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Table A-33 Distribution of RHNA Units by Sensitive Communities At Risk of Displacement
Overpaying
Renters
(Tract)
Lower Moderate Above Moderate Total
Units Percent Units Percent Units Percent Units Percent Sensitive 536 27.9% 1127 32.8% 235 23.9% 1898 29.9%
Not sensitive 1388 72.1% 2305 67.2% 747 76.1% 4440 70.1% Total 1924 100.0% 3432 100.0% 982 100.0% 6338 100.0%
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Figure A-83. Distribution of RHNA Units by Overpaying Owners (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-84. Distribution of RHNA Units by Overpaying Renters (2021) DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-85. Distribution of RHNA Units by Sensitive Communities At Risk of Displacement
Segregation and Integration
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Summary of Sites and AFFH Variables
Table A-34 shows the sites inventory by tract and AFFH variables. The sites inventory is shown geographically in Figure A-85. Figure A-72, presented above, shows the tracts in Beverly Hills.

Tract 7007. Tract 7007 encompasses the northwest side of Beverly Hills, north of Santa Monica Boulevard and west of Beverly Drive. This area of Beverly Hills is predominantly zoned for single-family residential uses.

This tract currently has 1,167 households with a non-White population of 13.8%, an LMI household population of 18%, and a population of overpaying renters of 30.3%. Tract 7007 is a highest-resource area and an RCAA. There are 333 above moderate income RHNA units allocated in this tract. Tract 7007 has the largest share of above moderate-income units compared to all other Beverly Hills tracts.

Tract 7008.01. Tract 7008.01 encompasses the area south of Santa Monica Boulevard, north of Wilshire Boulevard, and west of Doheny Drive. This section of the City is zoned for multi-family residential and commercial uses. According to recent ACS data, 2,202 households currently reside in this tract. Tract 7008.01 has a non-White population of 27.4%, a cost burdened renter population of 38.4%, and contains tracts with LMI populations ranging from 2% to 43%. Like all of Beverly Hills, this tract is a highest-resource area. A total of 621 RHNA units are allocated in this tract including 417 lower income units, 73 moderate income units, and 131 above moderate-income units.

Tract 7008.02. Tract 7008.02 is located north of Wilshire Boulevard and east of Doheny Drive and is zoned for single- and multi-family residential uses. Tract 7008.02 is a highest resource area with a nonWhite population of 31.4%, a cost burdened renter population of

52.2%, and contains block groups with LMI populations ranging from 27% to 37%. This tract is also considered a sensitive community at risk of displacement. A total of 1,898 RHNA units are allocated in this community, including 536 lower income units, 1,127 moderate income units, and 235 above moderate-income units. While this tract does have the largest allocation of lower income RHNA units compared to other tracts, the lower income units located in this tract only amount to 28% of the total lower income units allocated citywide.

Tract 7009.01. This tract is located along the southern City boundary and is bound by Wilshire Boulevard to the north and Doheny Drive to the west. Zoning designations in this section of Beverly Hills include single- and multi-family residential uses. Approximately 1,448 households reside in this tract where 26.1% of the population is nonWhite, 67.3% of renters are cost burdened, and 37% to 43% of households are LMI. Like all other tracts in the City, tract 7009.01 is a highest-resource area. This tract has the largest share of RHNA units DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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totaling 1,977 units (397 lower income units, 1,441 moderate income units, and 139 above moderate-income units).

Tract 7009.02. Tract 7009.02 is located along the southern boundary and encompasses the area south of Wilshire Boulevard, east of Beverly Drive, and west of Doheny Drive. Single- and multi-family residential zoning designations are the most prevalent in this tract. This tract has the largest household population of 3,256 households compared to other tracts containing RHNA units. Tract 7009.02 has a non-White population of 25.6%, a cost burdened renter population of 62%, and contains block groups with LMI populations ranging from 30% to 32%. There are 319 lower income RHNA units, 452 moderate income units, and 96 above moderate-income units, totaling 867 RHNA units, allocated in this tract.

Tract 7010. Tract 7010 is located in the southwest corner of the City and is bound by Wilshire Boulevard to the north and Beverly Drive to the east and is predominantly zoned for single- and multi-family residential uses. This tract has a population of 2,541 households with a non-White population of 20.3%, a cost burdened renter population of

46.1%, and LMI populations ranging from 16% to 23%. There are 642 RHNA units allocated in this tract (255 lower income, 339 moderate income, and 48 above moderate income).

In the southern area of Beverly Hills, the City distributes RHNA sites with the capacity for housing opportunities with a variety of affordability levels. Sites with capacity for lower income units are not concentrated in one southern tract alone. The City will implement additional strategies to increase housing opportunities in northern Beverly Hills. As discussed previously, the area north of Santa Monica Boulevard is considered an RCAA due, in part, to historical land use policies, restrictive covenants, and redlining. Strategies to increase housing opportunities in the northern RCAA area include, but are not limited to, promotion of ADUs through options beyond state allowances, homesharing opportunities, facilitation of affordable housing on religious institution site(s) through SB 4, and permittance of ancillary living quarters. The City’s sites inventory, in tandem with strategies to promote housing opportunities in northern Beverly Hills, will ensure new housing options are available citywide.

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Table A-34 Distribution of RHNA Units by Tract and AFFH Variable Tract # of HHs
in Tract
Total
Capacity
(Units)
Income Distribution % NonWhite% LMI
HHs
RCAA? TCAC
Opp.

Cat.
%
Overpay
Renter
Sensitive
Comm.?
Lower Moderate Above
Moderate
7007 1167 333 0 0 333 13.80% 18% Yes Highest 30.30% No
7008.01 2202 621 417 73 131 27.40% 2%-43% No Highest 38.40% No 7008.02 2036 1898 536 1127 235 31.40% 27%-37% No Highest 52.20% Yes 7009.01 1448 1977 397 1441 139 26.10% 37%-43% No Highest 67.30% No 7009.02 3256 867 319 452 96 25.60% 30%-32% No Highest 62% No 7010 2541 642 255 339 48 20.30% 16%-23% No Highest 46.10% No DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Figure A-86. Sites Inventory
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Summary of Fair Housing Issues and Local Conditions
An analysis of the research and outreach conducted on local housing conditions has identified the following fair housing themes and issues.

The top themes identified are:

1. Affordability

2. Accessibility

3. Preservation of existing households

4. Integration of new households into the city.

Within these themes, the specific issues identified are:

1. High housing costs

2. Aging housing stock

3. Large senior population, who are most vulnerable to housing issues

4. Displacement

5. Covert discrimination
Table A-35 Summary of Fair Housing Issues
Fair Housing
Issue
Theme Contributing Factors
High housing
costs
Affordability The overarching issue that pervades all
other housing issues in Beverly Hills is the
extremely high cost of housing, at all
levels and within all housing types, which
leads to lower levels of affordability and
higher rates of rent burden.

Aging housing
stock
Accessibility The majority of the housing stock in
Beverly Hills was developed in the 1920s1930s and is maturing to an age of nearly 100 years. Most properties were
developed prior to the 1990 Americans
with Disabilities Act (ADA) and therefore
may not contain the standards for
accessibility as would be required under
current codes.

Large senior
population
Accessibility As shown in Figure A-2, Beverly Hills’
population distribution skews older, with
a below-average share of young persons
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(under 18), with the senior (65+)
population constituting more than 21% of
the city’s population. Senior households
are identified as a special needs
population in section B.1 of the
Demographic Profile. Additionally, all of
the local experts interviewed identified
seniors as the most vulnerable population
in the city who can face numerous
housing and fair housing issues. Issues
facing seniors include fixed incomes,
limited mobility, and higher disability
rates.

Displacement Preservation
and
Integration
All of the local experts noted that once a
household in Beverly Hills is displaced due
to eviction or other factors, relocation
within the city is nearly impossible due to
lack of affordability.

Covert
discrimination
Preservation
and
Integration
Federal, state, and local laws strictly
prohibit discrimination in the sale, rental,
and financing of housing (private or
public) based on race, religion, national
origin, sex, handicap and family
status. However, local housing experts
have indicated that covert discrimination
on the part of landlords when reviewing
prospective tenants may be playing a
role in preventing certain groups or
populations from rightfully seeking
residence in the city. Figures A-41 and A42 show that the majority of Fair Housing and Outreach Cases were based on
disability bias, and less than half were
based on racial bias.

2. Future Programs and Policies to Affirmatively Further Fair Housing To address the impact of the fair housing issues identified, the City is committing to a series of programs intended to increase access to housing opportunities in Beverly Hills, as detailed in Implementation Measure 11.1. When a household is able to secure housing and become residents of the City of Beverly Hills (regardless of ownership status), the institutional opportunities of this high resource area become availed to them. These opportunities include, but are not limited to, access to education in the top-rated Beverly Hills Unified School District (BHUSD); infrastructure, DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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public parks, and city services, including police and fire protection, through the City of Beverly Hills; proximity to multi-modal transit routes connecting throughout the Los Angeles region; and close proximity to jobs (as shown in Figure A-40, Jobs Proximity Index Map).

In addition to policies and programs, the capacity for new housing growth in the Housing Element Land Inventory and Identification of Sites shows the wide opportunity for new residential populations to be accommodated in the city. Almost all of the housing growth is expected to be produced through widened regulations allowing for redevelopment of commercial properties or the conversion of existing commercial structures in a newly-created Mixed Use Overlay Zone. The Mixed Use Overlay Zone spans the entire breadth of the city, from its east to west borders, and partially north to south, along its largest commercial corridors including Wilshire Boulevard, Robertson Boulevard, Olympic Boulevard, South Doheny Drive, and South Beverly Drive. This wide-scale rezoning allows for the creation or conversion of nonresidential space into residential units, and therefore will create all net new housing, since it does not involve the displacement of any existing occupied housing/residents. Therefore, all of this new housing is intended to promote mobility within and into the City of Beverly Hills.

Additionally, in response to several of the fair housing issues identified during the Housing Element process, the City has prioritized the creation of Accessory Dwelling Units (ADUs) as a permitted housing type throughout the city. The socioeconomic benefits of ADUs as a housing type respond directly to mitigate some of the fair housing issues identified. According to the UC Berkeley Terner Center for Housing Innovation ADUs provide the following advantages16:

1. Construction is less expensive and faster than construction of other traditional forms of housing;

2. Provide independent living for disabled family members, elderly parents, and adult children;

3. Meet the cultural needs of some communities for multigenerational living;

4. Increases socioeconomic integration;

5. Typically face less opposition from neighbors than larger developments; and

6. Allow jurisdictions to increase housing supply through urban infill.

ADUs are a low-barrier housing strategy that will increase housing density and introduce new populations into existing single-family residential neighborhoods, within a fully built-out urban context that exists in Beverly Hills. The City is currently in the process of public outreach and ordinance creation to craft generous regulations and incentives to help spur the creation of ADUs to contribute towards the City’s RHNA allocation. Implementation Program 11.1 contains a more detailed matrix of programs intended to address the specific fair housing issues identified in the Analysis of Fair Housing.

16 Terner Center and Center for Community Innovation Report, August 2022, “ADUs for All: Breaking Down Barriers to Racial and Economic Equity in Accessory Dwelling Unit Construction.” DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Appendix B: Potential Constraints on Housing
Production and Conservation
A. Market Constraints................................................................................. 2

1. Construction Costs.............................................................................. 2

2. The Cost and Availability of Land..................................................... 3

3. The Cost and Availability of Financing............................................. 3 B. Governmental Constraints .................................................................... 4

1. Land Use Controls and Zoning Standards........................................ 4 Figure B-1 .................................................................................................. 5

2. Historic Preservation Program.......................................................... 24

3. Development Review Process......................................................... 25

4. Environmental Review Process........................................................ 32

5. Building Codes and Enforcement................................................... 33

6. Fees ..................................................................................................... 34

7. Housing for Persons with Special Needs......................................... 43 C. Environment and Infrastructure ......................................................... 56

1. Environmental Constraints ............................................................... 57

2. Infrastructure Constraints.................................................................. 61 Several factors can limit production or conservation of housing. These factors include potential, market-driven or governmental influences that could affect the market’s ability to meet the community’s future housing needs, especially in regard to adequate and affordable housing for very low-, low-, and moderate-income households. This “Potential Constraints on Housing Production and Conservation” section includes discussion of market constraints, governmental constraints, environmental and infrastructure constraints, and City efforts to limit potential constraints and to encourage the development and conservation of a variety of housing types.

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A. Market Constraints
State law defines nongovernmental constraints as “market factors which may hinder the development, improvement, and
maintenance of housing.” Market factors can constrain production of a variety of housing forms which can have a negative effect on the availability and affordability of housing and supportive services, thereby potentially reducing the City’s ability to achieve its housing objectives.

This section describes market factors that constrain housing production, including:
• Economic factors,
• Construction costs,
• Cost of acquiring land, and
• Availability of financing.

Given that these factors are market-driven, they are outside of the direct control of the City; however, through programs and policies, the City of Beverly Hills has the ability to influence and offset some market factors and thereby increase production of affordable housing.

1. Construction Costs
Construction factors such as the type of construction, custom versus tract development, materials, site conditions, finishing details, amenities, square footage, and structural configuration can increase the cost of housing. In general, multi-family housing is less expensive to construct than single-family housing. However, construction costs vary significantly, depending on the size of the unit and the number and quality of amenities offered. This includes items such as fountains, swimming pools, underground parking, gyms, and other less obvious decisions based on the type of flooring, types of appliances, light fixtures, and quality of cabinetry and woodwork.

A major cost associated with the development of housing is the cost of building materials, which has risen dramatically in recent years.

According to the Terner Center for Housing Innovation at UC Berkeley, in 2008-2009, construction hard costs averaged $177 per square foot but by 2018 that average had risen to $222 per square foot—a 25 percent increase. Construction cost is also affected by construction type. “Type I” projects, which are typically over 5-7 stories and constructed with steel and concrete, cost an average of $65 more per square foot than other types of construction, like Type V over I (i.e., wood frame floors over a concrete platform). Type I projects use more expensive components in order to build higher, and are more likely to DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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be found in infill locations, such as San Francisco or Los Angeles, where zoning allows higher density construction.1
Though construction costs comprise a large portion of the total development cost of a project, these costs are fairly consistent throughout the Los Angeles metro area and therefore would not constitute a constraint on housing production in Beverly Hills as compared to other cities in the same general vicinity.

2. The Cost and Availability of Land
Land costs include the cost of raw land, site improvements, and all costs associated with obtaining government approvals. Land costs typically account for a large share of the total housing production costs. All other things being equal, very high land costs may make housing development infeasible unless expected rents or sales prices are high enough to recuperate the additional land costs. In Beverly Hills one of the primary market constraints to producing affordable housing is land cost. This is directly attributable to the City’s desirable location and limited availability of vacant and developable land for residential development. Review of current market data for multifamily properties indicate land costs ranging from $500 to 1000 per square foot, with land costs for commercial properties averaging from $1,000 to $1,500 per square foot.

3. The Cost and Availability of Financing
The cost and availability of financing affects the provision of housing both at the construction financing phase and mortgages for individual home purchasers. Although the mortgage crisis that began in 2008 affected the availability of real estate loans, interest rates have declined to historically low levels, which reduces the cost of both construction loans and home mortgages. For buyers with good credit, the current low interest rates significantly reduce the cost of housing.

1 https://ternercenter.berkeley.edu/wpcontent/uploads/pdfs/Hard_Construction_Costs_March_2020.pdf DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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B. Governmental Constraints
Local government can affect the production of housing in a variety of ways through its police powers as generally expressed in its land use and development regulations. Some commonly used practices include limiting the land designated for residential development and/or the densities at which that development can occur, imposing fees or exactions, and requiring review periods prior to approval of a project. Local land use regulations can also help to define residential character and facilitate housing production.

It is important to recognize that the goal of producing housing may at times conflict with other City goals, such as the desire to provide open space and recreation facilities, the desire to protect environmental features and historic resources, and the desire to ensure the health and safety of residents by maintaining the current level of community services and infrastructure. This section evaluates the extent to which government regulation in Beverly Hills acts as a constraint to the production, maintenance, or improvement of housing for all income groups, and whether such constraints would prevent the City from achieving its assigned share of the regional housing need.

1. Land Use Controls and Zoning Standards
General Plan
The Beverly Hills General Plan establishes maximum residential densities throughout the community based upon the availability of public services, circulation capacities, and the desire to maintain the character of existing neighborhoods. The City has three single-family land use districts, ranging in density from one to six units per acre, and five multi-family districts, accommodating densities from 22 up to 50 units per acre. As indicated in Table B-1 (General Plan Land Use Categories for Residential Areas), the General Plan also designates certain areas that have been approved for Planned Development, providing greater flexibility by regulating development density/intensity through floor area ratios (FAR) rather than units per acre. Specific Plans have been adopted for each of the three Planned Developments.

In 2020 the General Plan Land Use Element was amended to create a Mixed-Use Overlay designation on properties shown in Figure B-1, which allows a maximum density of 79.2 dwelling units per acre (or 1 dwelling unit per 550 square feet of lot area). As is discussed below in the analysis of zoning regulations and also in the sites inventory analysis in Appendix C, this amendment created significant additional opportunities for residential development.

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Figure B-1
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Table B-1 General Plan Land Use Categories for Residential Areas Category Uses Density/ Intensity
Residential Land Use Designations (General Plan)
Single
Family
Low Single-family detached dwelling units on a single legal lot; with second units in accordance with state law.
1 du/ac
Medium Single family detached dwelling units on a single legal lot; with second units in accordance with state law.
4 du/ac
High Single family detached dwelling units on a single legal lot; with second units in accordance with state law.
6 du/ac
Multi
family
Very Low Multi-family residential development containing attached or detached residential units.
22 du/ac
Low Multi-family residential development containing attached or detached residential units.
40 du/ac
Low-Medium Multi-family residential development containing attached or detached residential units.
40 du/ac
Medium Multi-family residential development containing attached or detached residential units.
45 du/ac
High Multi-family residential development containing attached or detached residential units.
50 du/ac
Mixed Use Overlay Zone
Mixed Use Overlay Zone Commercial and multi-family residential (with some restrictions related to the location of commercial uses within a mixed-use building)

79.2 du/ac
Planned Development
Robinsons-May Residential, with supporting retail and services 31 du/ac : 2.6 FAR Hilton Hotel, with residences, retail and supporting restaurant and commercial

2.5 FAR
Beverly Hills Garden/Maybourne Hotel Hotel, with residential, retail and supporting restaurant and commercial, and public plaza
Max. 76,500 SF for
condo/hotel; max. 214
hotel rooms
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Category Uses Density/ Intensity
a. Incentives specified in Table LU 1 for additional development density and height exceeding existing baseline standards, as indicated by an asterisk (*), shall not be applied “by right” and considered only in very limited and special circumstances for the specific purpose of accommodating “key industries” that provide substantial community benefit, including, but not limited to: (a) support and enhance Beverly Hills key business sectors (such as entertainment Class-A offices, high-end retail, hotel, technology, and comparable uses); (b) provide high-paying employment opportunities; (c) contribute significant revenue for City services; (d) exhibit a high level of architectural design excellence; and (e) are scaled and massed to complement and “fit” with adjoining residential neighborhoods. Criteria shall be established in the Municipal Code for the types of uses that qualify and the process to be used in considering additional density and height, which, at a minimum, shall require public comments regarding their appropriateness. Developer obligations and community benefits shall be confirmed by a Development Agreement with the City.

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Zoning
Zoning is an implementation tool that establishes districts to control the physical development of land consistent with the General Plan.

Zoning regulations identify land uses and activities that are permitted, prohibited, or are permitted only with a conditional use permit or other discretionary permit within the zoning designations. In addition to permitted uses, zoning establishes development standards relating to intensity, lot coverage, setbacks, and height requirements. As shown in Table B-2 (Zoning Designations), Beverly Hills has seven single-family and five multi-family residential zoning designations, with 86 percent of all land devoted to residential uses.

Table B-2 Zoning Designations
Zoning Parcels Acres
Percent of City’s Land
Area
Single-Family Residential 76.84
R-1 1373 492.7 17.64
R-1.5X 451 76.3 2.73
R-1.5X2 359 49.0 1.76
R-1.6X 451 62.6 2.24
R-1.7X 162 21.5 0.77
R-1.8X 426 70.8 2.54
R-1.X 2,968 1,372.8 49.16
Multiple Family Residential 9.20
R-3 6 1.0 0.04
R-4 1,410 222.9 7.98
R-4-P 10 1.0 0.04
R-4X1 116 18.0 0.65
R-4X2 79 14.0 0.50
Commercial2 8.37
Other (Parks, Public Facilities, etc…) 5.59
Total 2,792.2 100%
SOURCE: General Plan Technical Background Report, October, 2005 The City’s zoning regulations establish standards for residential development including minimum lot sizes, density (based on amount of site area), unit size, height, setback and parking standards, as well as additional standards related to hillside areas. The City’s residential development standards are presented in the following tables:
• Table B-3 (City of Beverly Hills Residential Zoning
Requirements—Single Family)

2 The Mixed Use (MU) Overlay Zone now applies to a significant area of the commercial zones, which allows multi-family residential uses.

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• Table B-4 (City of Beverly Hills Residential Zoning
Requirements—Multiple Family)
• Table B-5 (Site Area Standards)
• Table B-6 (General Plan Density)
In general, rehabilitation or reconstruction of older units does not require conformance with current zoning standards unless over 50% of the replacement value of the structure is involved or over 50% of the structure is being reconstructed. In order to address the potential loss of units on properties developed with more units than are currently permitted under zoning, the City is currently allowing at least the same number of units to be rebuilt as currently exist as part of program Imp.

12.3 in the adopted Housing Element, and due to state law provisions in SB 330. This density is based upon the General Plan Land Use map, rather than the Multi-Family Density regulations in the Zoning Code. In addition, program Imp. 12.3 has been expanded to address transparency and accessibility regarding zoning requirements, development standards, and fees.

Single-Family Residential Development Standards
The City has development standards that apply to all single-family housing in the community and those that are unique to four different single-family areas of the City:
• Hillside Area (generally north of Sunset Boulevard, but varies in some locations)
• Trousdale Estates (north of Doheny Road)
• Central Area of the City, north of Santa Monica (north of North Santa Monica Boulevard, south of Sunset Boulevard but varies in some locations)
• Central Area of the City, south of Santa Monica (all areas south of North Santa Monica Boulevard)
Single-family dwellings must be a minimum of 1,600 square feet in size.

There is no universal maximum size for single-family dwellings.

Maximum size is a function of the lot size, setback, height limit, size of buildable pad, etc. Projects in excess of 1,500 square feet plus 40 percent of lot size (or over 15,000 square feet in the Hillside Area) must be first reviewed by the Planning Commission, which has the authority to establish a maximum size. The maximum floor area is further regulated in the Hillside and Trousdale Estates Areas by the topography and buildable area.

The maximum allowable height for single-family homes varies from 14 to 32 feet depending on the location, slope, roof style and other conditions. These standards are further identified in Table B-3.

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Table B-3 City of Beverly Hills Residential Zoning Requirements—Single Family Central, North of Santa Monica Central, South of Santa
Monica Hillside Trousdale Estates
Minimum Area of Primary
Residence (sf) 1,600 sf 1,600 sf 1,600 sf 1,600 sf
Density Range (units/acre) 4.0 du/acre 6.0 du/acre 1.0 du/acre 1.0 du/acre Minimum Lot Size 13,000 sf 7,500 sf 43,560 sf 43,560 sf Minimum Front Yard Setback As established in the records for each property a As established in the records for each property 15 ft.

Minimum Side Yard Setback
Min. 7.5 ft. on each side; for
lots wider than 70 ft. the sum
is 15 ft. plus 30% of lot wide in
excess of 70 ft.

If width of a site area
exceeds 100 ft., then the
side setback shall be
increased by 10% of the
width in excess of 100 ft.
5 feet on one side; 9 ft. on
the other side
South of Olympic Blvd. west
of Roxbury Dr.: 5 ft. on each
side: sum min. 20% of lot
width
South of Olympic Blvd. east
of Doheny Dr.: 5 feet on
each side
10 ft. or 12% of the lot width
for each setback,
whichever is greater
5 ft. Exception: For buildings on
sites consisting of two or more
lots as subdivided on July 3,
1984, side setback shall be
20 ft.

If width of a site area exceeds
100 ft., then the side setback
shall be increased by 10% of
the width in excess of 100 ft.

Minimum Rear Yard Setback 30% of lot depth minus 9 ft. b 15% of the lot depth or 20 ft., whichever is greater 10 ft.

Height Limit (dwellings)
Flat roof: 28 ft.

Sloped roof: 28 ft.

Sloped roof with ridgeline: 32
ft.

Flat roof: 25 ft.

Sloped roof: 28 ft.

Sloped roof with ridgeline:
32 ft.
30 ft. c 14 ft.

Maximum Lot Width and Depth Maximum width and depth shall not exceed the average depth of the lots in the same block —
SOURCE: City of Beverly Hills May 2013.
a. If no record exists, the distance between the front lot line and the closest element of the existing primary residence; or the average of the front setbacks of the other site areas on the same side of the street in the same block. b. Doheny Drive and Olympic Boulevard: Lots located easterly of Doheny Drive and southerly of Olympic Boulevard; a maximum of four hundred fifty (450) sf of floor area of the principal residential building may encroach into the rear yard provided that a 10' rear setback is provided. c. A structure may exceed this height if the structure is constructed within a height envelope that begins at 22' in height at the front setback line and increases toward the rear of the site at a 33° slope to a maximum height of 30'.

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Multi-Family Residential Development Standards
The number of dwelling units that may be constructed on any individual multi-family residential property is determined by applying a combination of standards to the specific site, summarized in Tables B-5, B-6 and B-7. The development standards for condominiums and multi-family apartments are the same. The City’s multi-family development standards permit densities ranging from 26 units per acre to 48 units per acre. However, due to state law provisions adopted via SB 330, the City now allows at least the same number of units to be rebuilt as currently exist on a multi-family site. This density is based upon the General Plan Land Use map, rather than the Multi-Family Density regulations in the Zoning Code. The General Plan Land Use densities range from 22 to 50 dwelling units per acre, but if this calculation results in a lower number of units than currently exist on site, the existing number of units is permitted.

Minimum front and rear yard setbacks are generally 15 feet although there are site-specific exceptions, as well as certain blocks that have a 25-foot front setback. Minimum side yard setbacks are calculated at a rate of 8 feet on each side and a sum of 17 feet for buildings of no more than 3 stories; 8 feet on each side and a sum of 19 feet for buildings of 4 stories; and 9 feet on each side and a sum of 23 feet for buildings of 5 stories. No structure may exceed 175 feet in width. A minimum of 200 square feet of outdoor living area is required for each unit.

Dwelling Unit Size
The City of Beverly Hills Zoning Code requires the following minimum individual dwelling unit sizes:
• 0 Bedroom: 600 square feet
• 1 Bedroom: 1,000 square feet
• 2 Bedrooms: 1,300 square feet
• 3 or more Bedrooms: 1,500 square feet
In some cases these minimum unit sizes can act to limit the achievable densities to less than that otherwise permitted under zoning. As a means of better facilitating the provision of smaller, and more affordable units, the City has included a program in the proposed Housing Element (Imp 12.1) to decrease the minimum unit size for projects with affordable units that utilize the State Density Bonus. This is an initial step towards considering potentially reducing the minimum unit size for all multifamily units in the City. The City already provides for reduced dwelling unit sizes for senior and disabled housing, for adaptive reuse of existing buildings, and for the mixed use zone.

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Table B-4 City of Beverly Hills Residential Zoning Requirements—Multiple Family R-3b R-4b R-4X1c R-4X2c R-4-P
Minimum Front
Setbacka As established in the records for each site area. If not established, then 15 ft.b Minimum Side Yard
Setback
Three stories or 33 feet or less: sum of side setback from the two longest side lot lines must be at least 17 feet In addition, each side setback shall be at least 8 feet
Four stories or 33 feet to 45 feet: sum of side setback from the two longest side lot lines must be at least 19 feet. In addition, each side setback shall be at least 8 feet
More than four stories or greater than 45 feet: sum of side setback from the two longest side lot lines must be at least 23 feet In addition, each side setback shall be at least 9 feet Modulation
Requirementc,d. e
Three stories or less: the area of modulation shall be
3 percent of the aggregate principal building or
1,500 sf
Four stories: the area of modulation shall be

3.5 percent of the aggregate principal building or
1,500 sf
Five stories: the area of modulation shall be
4 percent of the aggregate principal building or
1,500 sf
For lots that do not exceed 50 feet in width: The front façade shall be modulated so that a portion of the building are set back at least 5 feet from the front setback line.

For lots that exceed 50 feet in width: The front façade shall be modulated so that a portion of the building are set back at least 10 feet from the front setback line.

Minimum Rear Yard
Setback 15 feet from the rear lot line or 22½ feet from the centerline of the abutting alley, whichever is greater Height Limit
(dwellings)
No building or structure located on a site that is less than or equal to sixty feet (60') in width shall exceed 3 stories or 33 in height. In addition, no building or structure shall exceed the relevant height limitation imposed by Height districts (refer to Tables B-8 and B-9)
Minimum Unit Size 0 Bedroom: 600 sf Note: These standards are reduced for senior and disabled housing. 1 Bedroom: 1,000 sf
2 Bedrooms: 1,300 sf
3 or more Bedrooms: 1,500 sf
Structure Width Maximum of 175 feet
Outdoor Living
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R-3b R-4b R-4X1c R-4X2c R-4-P
a. Large scale multi-family developments (width of 100 feet or more) shall have a minimum of 60% and maximum of 70% of the front façade of the first two stories built back to the front setback line.
b. Exceptions are properties previously zoned R1.5: Not withstanding any other provision, the front sent back is 15 feet. c. Modulation is requirement that intends to create variation and articulation of a building façade by requiring that there are portions of the façade that are recessed or otherwise articulated so that the exterior is not a continuous flat surface. d. A reduction of the modulation requirement may be permitted if the development does not adversely impact on the scale and massing of the streetscape. e. Large scale multi-family developments (width of 100 feet or more) must provide an additional area of front modulation based on the following formula: Area of Modulation= Width of the principle buildable area x 5 feet x the number of stories.

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Maximum Zoning Unit Density / Site Area Standards
Each area zoned for multi-family residential use is subject to one of three possible minimum site area requirements for each dwelling unit, depending on the number of contiguous lots comprising the site, the proximity of the block to single-family zoned areas, and the street width (referred to as “conditions”). The City’s standards provide increased densities for parcel assembly, thereby reducing the number of driveway curb cuts, decreasing the cost of parking by increasing the number of parking spaces possible on each subterranean level and decreasing the percentage of garage area devoted to ramps and aisles. The standards are listed in Table B-5 (Site Area Standards).

Table B-5 Maximum Zoning Unit Density / Site Area Standards3 Condition
(this is not
height
district)
Number of Lots on Site
(assuming a lot width
along the street of up to
60-feet) Minimum Site Area per Unit
Resulting Density (units/acre)
A
1 1,700 sf 26
2 1,450 sf 30
3 1,200 sf. 36
B
1 1,500 sf 29
2 1,200 sf. 36
3 1,000 sf 44
C
1 1,300 sf. 34
2 1,100 sf 40
3 900 sf 48
The City’s Zoning Code further refines the unit densities allowable in the General Plan. The intention of this refinement is to provide decreased densities near single-family residences and on narrower streets. Conditions A, B, and C, as included in the chart above are used to refine the allowable General Plan density. These conditions are defined as follows:

Condition A: All multiple-family properties within 170 feet of a single-family property.

Condition B: All multiple-family properties on streets less than 34-feet wide.

Condition C: All other multiple-family properties which do not meet the previous two criteria.

The above information demonstrates the zoning density calculation for multi-family properties. However, as previously noted, due to state law provisions adopted via SB 330, the City now allows at least the

3 An exception of these site area requirements is a small R-3 zoned area on North Doheny Drive where a minimum of 1,700 square feet of site area is required for each additional unit.

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same number of units to be rebuilt as currently exist on a multi-family site. This density is based upon the General Plan Land Use map, rather than the Multi-Family Density regulations in the Zoning Code. The General Plan Land Use densities range from 22 to 50 dwelling units per acre, but if this calculation results in a lower number of units than currently exist on site, the existing number of units is permitted. The General Plan Land Use density categories are:

Table B-6 General Plan Density
Category Dwelling Units/Acre
SingleFamily
Residential
Low Density 1
Medium Density 4
High Density 6
Multi-Family
Residential
Very Low Density 22
Low Density 40
Low Medium Density 40
Medium Density 45
High Density 50
Other
Residential
Designations
Multi-Family ResidentialCommercial Parking
50 Mixed Use Overlay 1
(9200 Wilshire Blvd)

4.0 FAR
Mixed Use Overlay 2
(8600 Wilshire Blvd)

2.0 FAR
Mixed Use Overlay Zone 79.2
Height Limits
No building or structure located on a site that is less than or equal to 60 feet in width may be more than three stories or 33 feet in height.

In addition, there are maximum heights for multi-family development depending on the designated Height District. Maximum heights are the lesser of the indicated number of stories or height in feet:

Table B-7 Building Height Districts with Maximum Buildings Height (to Ceiling Plate)^
District A: Three stories, and 33 feet
District B: Four stories, and 45 feet
District C: Five stories, and 55 feet
^ All properties with less than 60’feet of width along the street are limited to three stories and 33 feet in height regardless of district.

The Building Height Districts are described in the City’s Zoning Code and modify the maximum height allowances given in the City’s General Plan. District A, which allows three stories and 33 feet in height, is located adjacent to single-family residential properties and DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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is intended as a graduated buffer between the maximum height allowed in the single-family districts (two stories and 30 feet for a pitched roof, 25 feet for a flat roof) and the heights in District B and District C. District B is an intermediary buffer, providing greater height than is allowed in District A, but not as much height as allowed in District C. The City’s multiple-family height districts are not related to the City’s zoning unit density conditions. Unit density is calculated by the City zoning unit density conditions (10-3-2801). The height districts are defined in the City’s Zoning Code (10-3-2804) and identified on the City’s Multi-Family Height District Map.

Similar to the density calculations, the zoning height limitations have been affected by state law provisions in SB 330, and the above no longer apply in the majority of cases. In order to allow at least the same number of existing units to be constructed on a multi-family property, the City allows the use of General Plan height limits, which are tied to the density category of the property. These height limits are shown below:

Table B-8 General Plan Height Limits
Category Height Limit (Feet)
Multi-Family
Residential
Very Low Density 33-45
Low Density 30
Low Medium Density 40
Medium Density 60
High Density 60
Other
Residential
Designations
Multi-Family ResidentialCommercial Parking
40 Mixed Use Overlay 1
(9200 Wilshire Blvd)
60 Mixed Use Overlay 2
(8600 Wilshire Blvd)
61 Mixed Use Overlay Zone 45-55
Deviations from Multi-Family Development Standards
The City has established an “R-4 Permit” to accommodate projects that deviate from the basic development standards within specified criteria. The R-4 permit allows for modifications to building height, length, setbacks and articulation, depth of garages that encroach into the front yard setback, and permitted paving in the front yard.

The R-4 permit also allows for “bonus units” to be developed above existing carports or garages where the rear property line abuts an alley. One-bedroom units ranging between 400 to 999 square feet in size are permitted, with heights of up to 28 feet, or the height of the principal building.

Affordable Housing Requirements
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The City currently has an inclusionary housing requirement for a minimum of 10% of the units in a development meeting certain criteria to be rented to very-low, low- or moderate-income households, with some provisions for the payment of an in-lieu fee for projects that contain at least 5, but less than 10 residential units. In addition, recent state law changes contained in SB 330 require the replacement of “protected units” on a project site and require that a portion of those protected units be replaced as deed restricted affordable units. The City fully complies with this state law, which has resulted in housing applications with a number of deed restricted units being proposed (often in excess of the number of units resulting from the local requirement of 10%). The local and state requirements to provide affordable housing do not appear to be a constraint on housing production at this time, as evidenced by the substantial increase in the number of housing project applications that City is currently processing (see Table B-11).

Mixed Use Development Standards
In 2020 the City adopted a Mixed Use Overlay Zone that encompasses the area shown in Figure C-1 on page C-5. The overlay zone adds mixed use developments as a permitted use within the designated areas. Maximum residential density within the overlay zone is 79.2 units per acre and height limits range from three to five stories depending on location. Minimum unit size is 500 square feet for efficiency and 1- bedroom units and 800 square feet for units with 2 or more bedrooms.

The average size of all units in a mixed-use development may not exceed 1,750 square feet. To assist interested property owners, developers and other interested parties in understanding the new mixed-use regulations, a summary is posted on the City’s website.4 Accessory Dwelling Units
Accessory dwelling units (ADUs) provide an important source of affordable housing for seniors, young adults, care-givers and other low- and moderate-income segments of the population. In recent years, the State Legislature has adopted extensive changes to ADU law in order to encourage housing production. Among the most significant changes is the requirement for cities to allow one ADU plus one “junior ADU” on any property zoned for residential uses by-right subject to limited development standards. Program Imp 10.4 in the Housing Plan includes a commitment to update the City’s ADU regulations in order to meet and exceed the requirements of State Law for the purpose of further encouraging ADUs as a source of housing in the City. In addition, the Housing Plan includes additional commitments from the City related to ADUs including the

4 http://www.beverlyhills.org/cbhfiles/storage/files/1108659042674523311/BeverlyHillsMixed UseGuideFeb2021.pdf
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development of “off-the-shelf” plans and proactive outreach to property owners to educate the community about ADUs.

Parking Requirements
The number of parking spaces required per dwelling unit is dependent upon the type of residential use, number of bedrooms, and, for singlefamily dwellings, location in the community. Table B-9 (Residential Parking Requirements) presents the required parking spaces necessary for residential development. It should be noted that the majority of projects now utilize state density bonus, which provides alternative parking requirements (reduced) for multifamily projects.

Further, frequent changes in state law (such as AB 2097) now allow projects with no parking.

The City requires multi-family housing to provide structured parking and to screen all parking spaces from view of public streets. These requirements have resulted in most multi-family projects providing subterranean parking. The City will evaluate revisions to its standards to allow greater flexibility in the type and location of multi-family parking as part of Program 12.1 in the adopted Housing Element in order to reduce development costs.

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Table B-9 Residential Parking Requirements
Use Type Required Parking Spaces
Covered
Spaces
Single-Family Central Area
No more than 4 Bedrooms 3
None
5 or 6 Bedrooms 4
7 Bedrooms 5
8 Bedrooms 6
9 or more Bedrooms 7
Single-Family Hillside Area
<6,000 sfe 3 2
>6,000 sfe 4 2
Single-Family Trousdale Estates
No more than 4 Bedrooms 2
5 Bedrooms 3 None
6 or more Bedrooms 4
Multiple-Family and Mixed Use a,b
Efficiency Unit (<1,000 sf) 1
All spaces to
be enclosed
within a
structure
1 Bedroom 2
2 Bedrooms 2.5
3 Bedrooms 3
4 Bedrooms 3
5 or more Bedrooms 4
Congregate Housing for
Elderly and Disabled
Studio or 1bdrm – 1 space
2 bdrm - 1½ space
(May be reduced to 1/2 a
space per unit)
Multi-family Housing for
Elderly and Disabled
(Affordable)
1 space per unit
(May be reduced to 4/10th
of a space per unit)
SOURCE: City of Beverly Hills, Municipal Code, December 2006. a One guest space for each four units.
b Up to 20% of multi-family units may have tandem parking. The Planning Commission may increase the percentage of tandem parking spaces as part of an application for an R-4 permit.

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Cumulative Impact of Development Standards
Multifamily
To evaluate the cumulative impact of the City’s development standards on achievable densities, the City reviewed multi-family projects built in the R-4 zone. Table B-10 below summarizes the characteristics of multi-family projects, and compares the maximum densities permitted under the General Plan, and zoning code, with the actual built project.

Table B-10 Comparison of R-4 Units Approved Or Applied For to the Allowable Densities in the General Plan
Year Address # of
lots
Max units
per
General
Plan
Proposed/
Approved
Units
Units
Built/Proposed
as % of
Allowed
Approved
2016
250 N.

Crescent Dr.
1 7 8 114%
Approved
2019
340 S. Rexford
Dr.
1 3 3 100%
Approved
2020
457 N.

Oakhurst Dr.
1 10 6 60%
Approved
2022
425-429 N.

Palm Dr.
3 25 20 80%
Approved
2022
149-159 S.

Maple Dr.
3 19 29 153%
Approved
2023
208 N.

Crescent Dr.
1 7 10 142%
Approved
2023
332 S. Doheny
Dr.
1 6 9 150%
Approved
2023
55 La
Cienega Blvd
70 105 150%
Approved
2023
227 Tower Dr. 1 8 10 125%
In process 8800 Burton
Way
1 20 25 125%
In process 244-256 N.

Clark Dr.
3 19 for
standards
units, 70 for
senior units
55 senior
units
290% over
standard
zoning
78% for senior
housing zoning
In process 232 S. Doheny
Dr
1 6 9 150%
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In process 412 N
Oakhurst Dr5
2 6 9 150%
In process 444-446
Oakhurst Dr.
3 17 27 158%
In process 227-231 N.

Swall Dr.
2 12 18 150%
In process 9600 Wilshire
Blvd6
4 (west)
7 (east)
50 54
38 30
76%
56%
Table B-10 illustrates that multi-family buildings that are recently constructed, approved, and proposed typically are proposed and/or approved at 100 percent or more of the maximum zoning code and/or General Plan density, indicating that the density provided in the code is not necessarily an impediment to development. Further, recent state and local law changes are ensuring that existing units on a site are replaced when multi-family buildings are demolished for the purpose of a new project and that all new projects include affordable units. In addition, the table above illustrates how the City’s zoning density incentive for assemblage of properties incentivizes greater unit density, but is not essential for development, as some projects have been developed on single lots.

In order to further analyze whether current regulations are a constraint on housing production, the City also reviewed the number of development projects and units that were proposed and approved over time. The results of the analysis (see Table B-11 below) indicate that the current standards are not inhibiting development of housing, and that the amount of housing units that are currently in the pipeline for approval far outpaces any development of multi-family housing in the City in the last decade (including provision of affordable units).

Table B-11 Housing Projects Submitted for Entitlement
Year Proposed multi-family project submitted
for entitlement
Total Number of
Units
2018 • 340 S. Rexford Dr. – 3 units 3 units
2019 • 149 S. Reeves Dr. – 1 unit 1 unit

5 This project is a multi-jurisdictional project located within both the City of Beverly Hills and the City of Los Angeles, with 9 units proposed to be located in Beverly Hills boundaries.
6 This project has applied for a Specific Plan, which would allow up to 70 multi-family units within the plan; however, currently submitted plans show a total of 68 units proposed.

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2020 • 9384 Olympic Blvd. – 1 unit
• 457 N. Oakhurst Dr. – 6 units
• 9908 S. Santa Monica Blvd. – 25 units
32 units
2021 • 149-159 S. Maple Dr. – 29 units 29 units
2022 • 9900 Wilshire Blvd. (One Beverly Hills
Project) – 340 units
• 332 S. Doheny Dr. – 9 units
• 55 La Cienega Blvd. – 105 units
• 412 N. Oakhurst Dr. – 42 units7
• 457 N. Oakhurst Dr. – 6 units
• 227 Tower Dr. – 10 units
• 9600 Wilshire Blvd. – 70 units8
582 units
Grand Total 647 units
The R-4 projects presented in Table B-11 also illustrate the feasibility of developing on small parcels (<0.5 acre). However, given the fact that only one multi-family projects that has been proposed in recent years utilizes either Beverly Hills zoning code section 12.5 or 12.8 (specific standards for multi-family housing for the elderly and disabled and multi-family congregate care housing), the Housing Plan has been updated to include an action item in Program 12.1 that requires that the City update these zoning regulations to ensure they are up-todate and encourage the provision of this type of housing. Further, it has been identified that the complexity of existing multi-family residential regulations is not ideal for developers. Due to this, the City is committing to several actions with a goal of simplifying multi-family residential development standards to provide greater transparency for those who may be interested in providing new housing in the City.

Given the steps that will be taken through the programs in the Housing Plan, the City will further encourage the development of housing for a wider range of populations.

Mixed Use Development Projects
As stated above, in 2020, the City adopted mixed use zoning that applies to approximately 388 parcels in the City totaling more than 100 acres along major commercial corridors, where housing was previously not an allowed use. This zoning change has spurred interest in the development of mixed use projects along these transit and amenity-rich corridors. In addition, it should be noted that the mixed

7 This project is a multi-jurisdictional project located within both the City of Beverly Hills and the City of Los Angeles, with 9 units proposed to be located in Beverly Hills boundaries.
8 This project has applied for a Specific Plan, which would allow up to 70 multi-family units within the plan; however, currently submitted plans show a total of 68 units proposed.

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use provisions in the code allow the conversion of existing buildings (even if they are legally nonconforming) into housing units. Under this provision, the Planning Commission can waive otherwise required zoning requirements in order to accommodate housing units in existing buildings without major changes to the building. In addition, the City Council recently reviewed the implementation of the Mixed Use Overlay Zone at their meeting of July 18, 2023. During this discussion, staff reported that there had been one project approved under the Mixed Use Overlay Zone requirements, and three projects currently submitted for review. At the meeting, the City Council indicated support to change the mixed use regulations to allow the calculation of density for adaptive reuse projects with the use of a minimum unit size, rather than a lot size calculation. This change to the calculation of density has the potential to substantially increase residential density on mixed-use sites with an existing structure that exceeds the City’s current maximum commercial building height limit.

The Planning Commission reviewed this proposed change in September 2023, and the City Council will review this by the end of 2023. The City Council also expressed general interest in looking at ways to update and possibly expand or modify the mixed use regulations to further encourage development in the Mixed Use Overlay Zone, and this effort will begin in 2023 and continue into 2024.

The City’s specific commitments related to improving the Mixed Use Overlay Zone are noted in Imp. Program 12.1.

As shown in the Sites Inventory exhibit to Appendix C, there are several mixed use projects in the Mixed Use Overlay Zone that are either under review for an entitlement approval, or have submitted for “concept review” (meaning that they are receiving preliminaty comments from the City prior to formal submittal). Due to the fact that this is a newer code provision, staff has identified the need to proactively provide information to property owners regarding the new mixed use zoning. Programs related to proactive outreach and consultation with property owners regarding mixed use provisions have been included in the housing plan in order to address the identified barrier of lack of information/knowledge regarding the mixed use regulations. As noted in Imp. Program 12.1, staff plans to hold several outreach meetings starting in 2023 (both community meetings and Planning Commission study sessions) to discuss what kinds of changes might be needed to encourage the utilization of the regulations.

Accessory Dwelling Unit (ADU) Production
In terms of ADU production, the City’s current requirements do not appear to be inhibiting the production of ADUs. The production of ADUs has substantially increased over the past several years, from 9 in 2020, to 19 units in 2021, and to 25 units in 2022. However, the City is DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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committed to further encouraging the provision of ADUs as a viable housing option in the City. Implementation Program 10.4 includes a number of actions that the City will undertake to address identified barriers to the further production of ADUs in the City.

2. Historic Preservation Program
In 2012, the City established a Historic Preservation program to maintain and preserve its unique heritage and neighborhoods. The program was established to preserve specific properties that demonstrate the unique cultural, architectural and historic sense of Beverly Hills. Examples of listed properties follow below.

The program was most recently updated in 2015 and outlines procedures and criteria for landmark and historic district designation, and establishes penalties for unauthorized demolition or alteration of historic resources. The Ordinance only allows the City Council and Cultural Heritage Commission to nominate properties as potential landmarks and historic districts (districts are not allowed in singlefamily zones). In order to form a historic district, 70% or more of the properties within the potential district boundaries must qualify as contributors and 50% of the property owners must support the district’s formation.

Since the inception of the Historic Preservation Program, the City has established a Cultural Heritage Commission and compiled a Master Architect List of notable individuals who have designed buildings in the City. The City has also designated a number of buildings as local landmarks, including but not limited to:
• Beverly Hills Hotel
• Virginia Robinson Estate and Garden
• Beverly Hills Women’s Club
• Greystone Mansion
• Beverly Hills Post Office
• Anderton Court
• Karasik House
• The Witch’s House
• Waverly Mansion
• Hilton Office Building
• Locke House
• Fox Wilshire – Saban Theatre
• Beverly Hills City Hall
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The City previously started a comprehensive historic survey of all properties, including multi-family properties. However, this survey was halted due to changes to the Historic Preservation ordinance that took place in 2015. The next step will be to determine which of these properties might merit placement on an inventory and further consideration as a landmark. The City has established a Mills Act Program (the pilot program was started in 2011, and the permanent program was established in 2020) to provide property tax incentives for preservation. The Mills Act Program specifically encourages the preservation of multi-family properties in the City. In addition, the Historic Incentive Program was established in 2015, which allows the Planning Commission to modify or waive development standards that would otherwise apply to locally designated historic landmarks.

Because the historic preservation program was recently updated in 2015, and a comprehensive survey of all properties in the City has not yet been completed, it is difficult to assess exactly how it will impact housing development potential. However, the purpose of the program is to protect historic and cultural resources that are especially unique and contribute to the cultural, historic and architectural sense of the City. For this reason, the City does not believe that the program will be a constraint to housing development.

The City will continue to monitor the program as it develops and has included Imp. 9.4 in the Housing Plan. In 2023, the City initiated work on a new multi-family residential historic survey.

3. Development Review Process
All residential development is reviewed by City staff for zoning, building, and fire code compliance prior to issuance of construction permits.

Single-Family Housing Review Process
New single-family homes that overpower the general local neighborhood scale "lot to house size" ratio ("mansionization") are a concern to the community. To address this issue, all single-family residential development located in the “Central Area of the City” (basically all areas south of Sunset Blvd.) must be first reviewed and approved by the Director of the Community Development
Department, or the Design Review Commission, based on whether the project complies with the City’s published design guidelines.

Director Review (Track 1)
A proposed residential development is reviewed to determine whether it substantially adheres to an architectural style as outlined in the Single-Family Design Review Catalogue. If the required review determines that the proposed development adheres to the architectural style within the catalogue, is designed by a licensed architect, and meets all of the applicable development standards, DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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the development may be granted a design review entitlement by the Director of Community Development without further design review.

Commission Review of Single Family Projects (Track 2)
Projects that do not comply with a style in the City’s guidelines, or are not designed by a licensed architect, are reviewed by the Design Review Commission. The Design Review Commission reviews proposed single-family residential development and its impact on the streetscape by controlling the mansionization of the City's residential neighborhoods, which would degrade and depreciate the
character, image, beauty, and reputation of the City's residential neighborhoods with adverse consequences for the quality of life of all residents. Design Review Commission decisions involve a noticed public hearing, and decisions are appealable to the Planning Commission and ultimately to the City Council.

Design Guidelines
The City provides guidelines to the public on what would constitute acceptable design. This City’s design guidelines, titled the “Residential Design Style Catalog”, are available for reviewing and download on the City’s website9. The catalogue includes explanations of the different design styles, including the defining architectural features, materials, and proportions present for each style, as well as various sub-categories of styles. The guide also includes picture examples for the styles. The catalogue includes the following housing design categories, each with various subtypes:
• American Colonial
• Rural European Revival
• Spanish Colonial
• Contemporary
• Period Revival
Other design styles can be considered if the design is architecturally true to textbook definitions.

Review Process
The City has a dedicated staff person who works with applicants on single-family related design. The City provides an application packet that includes a process flowchart and instructions for submitting a complete set of plans. Decisions made by City staff or the Design Review Commission are rarely appealed.

9 The City’s Residential Design Style Catalog is available at:
<http://www.beverlyhills.org/cbhfiles/storage/files/4702978971337846787/StyleCatalogRevis edMarch2008.pdf>
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1. The first step in the process is for City staff to determine if the proposed project can be reviewed by the Director, or if it warrants review by the Design Review Commission.

2. Once a determination is made, the applicant is informed in writing and they are invited to submit either a “Track 1”, or a “Track 2” application. Track 1 applications are reviewed by City staff and, ultimately, the director. Track 2 applications are reviewed by the Design Review Commission.

3. Staff-level project reviews are typically processed within 30 days.

4. Commission reviewed projects are typically processed within 60 days.

5. The Design Review Commission process includes a public hearing. The Commission considers the following findings in their review:
a. The proposed development's design exhibits an
internally compatible design scheme;
b. The proposed development's design appropriately
minimizes the appearance of scale and mass and
enhances the garden like quality of the city and
appropriately maximizes the use of required open
space within the proposed architectural style;
c. The proposed development will enhance the
appearance of the neighborhood;
d. The proposed development is designed to balance the
reasonable expectation of development for the owner
with the reasonable expectation of privacy of
neighbors; and
e. The proposed development respects prevailing site
design patterns, carefully analyzing the characteristics of the surrounding group of homes, and integrates
appropriate features that will ensure harmony between
old and new.

Multi-Family Housing Review Process
Development Plan Review Entitlement Required
All multi-family residential projects are subject to the City’s Development Plan Review (DPR) process. Projects with five or more units are reviewed by the Planning Commission; projects with four or fewer units may be reviewed at the staff-level. Development Plan Review involves evaluating the proposed development for General Plan consistency and compatibility to the area in which the development is proposed to be located. The review focuses on site plan, building layout, and building amenities. Use of multi-family properties are considered to be for multi-family residential purposes and therefore, use is not part of the review.

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Other Entitlements that May Be Required
In addition to the Development Plan Review requirements, if a building does not meet all of the basic R-4 Zone standards, the applicant may apply for an R-4 permit. If the deviation from the basic standards meets specific criteria, an R-4 Permit allows for the reduction in development standards for setbacks, building height, articulation of the building façade, building length, depth of garages that encroach into the front yard setback and the amount of paving in the front yard. An R-4 permit is also required to allow residential units to be constructed above existing detached garages. The reviewing authority typically reviews the R-4 permit at the same time as the development plan and the tentative map.

Incentives for Development of Assisted Living or Independent Living for the Elderly or Disabled Housing
The City’s municipal code allows for the development of senior and disabled housing anywhere housing is allowed in the City. In the City’s multi-family districts, senior and disabled housing can be constructed at a unit density greater than would be allowed for other types of housing (up to 165 units/ acre), provided that the project obtains a Conditional Use Permit and units are deed-restricted as affordable. In select areas of the City’s multi-family districts, Congregate Care Facilities for the elderly and persons with disabilities can also be constructed at unit densities greater than would otherwise be allowed (up to 165 units/acre) with a Conditional Use Permit. Furthermore, the City’s Code provides for significant reductions in parking and minimum unit sizes for senior and disabled housing.

Commission Review of Multi-Family Projects
Most multi-family residential and some single-family residential developments require review by the Planning Commission. The Community Development Department offers a “one-step” process where the formal Planning Commission review application will be made through the City’s Permit Center and routed to all applicable departments such as Fire and Engineering. If there are no revisions to the plans, a hearing is scheduled before the Planning Commission.

Planning Commission Review
The Planning Commission reviews development plans for all multifamily projects with more than four units, second unit use permits, condominium conversions, and all requests for modifications to the City’s development standards. As required for all entitlements, public notification procedures for Planning Commission hearings are also followed, which can include a notice sent within 45 days of the application filing date, and a notice sent at least 20 days before the hearing date, as well as newspaper notices and on-site posted signs.

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findings, resolution, and covenant. Typically, projects move through the process, from initial submittal to approval in 90-180 days.

The findings used by the Planning Commission in the Development Plan Review process are:

A. The proposed plan is consistent with the general plan and any specific plans adopted for the area.

B. The proposed plan will not adversely affect existing and anticipated development in the vicinity and will promote harmonious development of the area.

For those proposed plans to be located in the C-5 zone that are reviewed by the planning commission, the commission shall consider the factors set forth in section 10-3-2021 of this chapter as part of the commission's determination regarding whether a project will promote harmonious development of the area.

C. The nature, configuration, location, density, height and manner of operation of any commercial development
proposed by the plan will not significantly and adversely interfere with the use and enjoyment of residential properties in the vicinity of the subject property.

D. The proposed plan will not create any significantly adverse traffic impacts, traffic safety hazards, pedestrian-vehicle conflicts, or pedestrian safety hazards.

E. The proposed plan will not be detrimental to the public health, safety or general welfare.

The Planning Commission reviews the tract map and site plan, and confirms that the project conforms to the general plan and zoning code. This includes a review of vehicle flow and pedestrian access.

In areas served by alleys, the Planning Commission encourages new projects to orient vehicle access off the alley to limit the number of vehicles crossing the sidewalk. The Planning Commission also encourages new projects to be designed with a main entrance facing the street to continue the existing pedestrian-orientation of buildings to the sidewalk.

The Planning Commission was established more than 50 years ago and the Commission’s review is based on site planning and land use compatibility. Potential uncertainty in the City’s review process related to meeting the finding of “…[promoting] harmonious development of the area” is addressed through a focused review of site plan orientation and traffic generation, and a reliance on past precedence. The findings used by the Planning Commission to evaluate applications for Development Plan Review entitlements have been in place since the early 1990s and constitute a substantial body of cases to reference in determining the appropriateness of future applications.

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same professional staff also work the City’s public counter and are a resource made available to assist applicants with zoning conformity and entitlement submittal requirements in advance of submitting a project.

The City’s current system includes the public counter zoning services, entitlement processing services, informational materials, and application submittal requirements. The current system will be evaluated annually in conjunction with the Annual Housing Element Report to HCD and any uncertainty in the development review process will be identified and procedures will be modified as needed to increase certainty (Imp. 12.3 Efficient Development Permit Review).

This ensures that an applicant will be able to use the City’s available informational resources, meet with public counter staff and entitlement case management staff, submit an application with all necessary supporting materials, and with certainty be assured their project will proceed through the review process in an efficient manner.

Architectural Review
Architectural Review is required for the erection, construction, alteration, or remodeling of the exterior of any non-single family residential zoned properties (e.g. multi-family residential and mixeduse), pursuant to Beverly Hills Municipal Code Title 10, Chapter 3, Article 30. Architectural Review and the Architectural Commission of the City of Beverly Hills were established in 1966. The approval criteria are intended to compel a standard for high quality housing production in the City. The Architectural Commission application form sets forth a transparent, standardized list of submittal requirements available in advance to all applicants. The application form includes an opportunity for a project applicant to provide rationale on how their project meets the approval criteria. The criteria relate to the quality of the façade treatments and finishes only and the Architectural Commission has no purview over the approval or denial of the underlying multi-family housing project. The criteria are then applied evenly by the Architectural Commission in a public hearing and are cited evenly in the approval resolution, which follows a regularized template for all projects. Nearly all minor (staff-level review) Architectural Review applications are approved at the staff level or over-the-counter on the day of application. The average processing time for Architectural Commission-level architectural review projects is 3 weeks from the date of receipt of a formal application to the date a project is agendized and heard by the Architectural Commission. The majority of projects are approved in a single meeting before the Commission. The existing Architectural Review process for multi-family residential projects in Beverly Hills is a streamlined, standardized procedure that does not appear to be a barrier to the approval of housing projects. Regardless, DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Implementation Measure 12.1 (Development Standards) in the Housing Plan includes policies to 1) adopt objective design standards for multi-family housing projects, and 2) to consider an ordinance to streamline the approval process to allow Director-level approvals for Architectural Review of multi-family housing projects with affordable housing.

The Architectural Commission reviews the architectural qualities of all multi-family projects, and all commercial or mixed-use projects. The Architectural Commission’s review focuses only on the outside of the building and the building’s landscaping and includes a review of architectural features, final finishes and colors.

Typically, a project is scheduled for review by the Architectural Commission as soon as it is approved by the Planning Commission.

From start to finish, the Architectural Commission’s review typically takes a maximum of 60 days. The Commission’s review includes a public hearing and approval is provided in a letter to the applicant.

The findings used by the Architectural Commission in the Architectural Review process are:

A. The plan for the proposed building or structure is in conformity with good taste and good design and, in general, contributes to the image of Beverly Hills as a place of beauty, spaciousness, balance, taste, fitness, broad vistas, and high quality; B. The plan for the proposed building or structure indicates the manner in which the structure is reasonably protected against external and internal noise, vibrations, and other factors which may tend to make the environment less desirable;
C. The proposed building or structure is not, in its exterior design and appearance, of inferior quality such as to cause the nature of the local environment to materially depreciate in appearance and value;
D. The proposed building or structure is in harmony with the proposed developments on land in the general area, with the general plan for Beverly Hills, and with any precise plans adopted pursuant to the general plan; and
E. The proposed development is in conformity with the standards of this code and other applicable laws insofar as the location and appearance of the buildings and structures are involved.

The Architectural Commission was established more than 50 years ago and over the course of its existence a methodology to objectively reviewing applications has been developed based on precedent.

The process includes the following:

The City has a planner and urban designer dedicated to working with project applicants on architectural submittals and the City takes measures to assure that applicants are informed of submittal requirements at the time the application is initially submitted to the DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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City. The City keeps a collection of sample review materials, such as material boards and renderings. The City also awards projects semiannually which possess exemplary architecture and those awarded projects are photographed and made available to the public on the City’s website. By reviewing the City’s examples of exemplary architecture and submittal samples, and meeting with the City’s dedicated planner, a project applicant can be assured their project will proceed through the review process in an efficient manner.

Expedited Plan Check
At this time, the Planning Division does not provide an expedited review process for multi-family projects; however, plans are underway to establish an expedited review process for planning permits, provided that needed funds for staffing are available. The Building and Safety Division does provide an expedited plan check option which can reduce plan check times from six to three weeks.

SB 35 Streamlined Review Process
Under certain circumstances, SB 35 (Government Code Sec. 65913.4) requires cities to conduct “streamlined review” of housing development applications. To address this requirement,
Implementation Measure 12.3 in the Housing Plan includes a commitment to establish written procedures for the SB 35 Streamlined Ministerial Approval Process when applicable.

4. Environmental Review Process
Residential projects developed consistent with the General Plan and Zoning Code in most cases are categorically exempt from environmental review. Only when the new project would demolish a building determined to be of historic significance would additional environmental review be performed (additional environmental review would also be required in some instances for projects that disrupt natural habitats; however, Beverly Hills is located in a dense urbanized area and there is very little to no natural habitat remaining in the City that would warrant additional review).

Typical timeframes for the environmental review is as follows:

Table B-12 Environmental Review – Processing Times
Type of Review Processing Time
Categorical Exemption 2 months
Negative Declaration/ Mitigated Negative Declaration 6 months Environmental Impact Report 18 months
SOURCE: City of Beverly Hills, May 2021
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5. Building Codes and Enforcement
Building Codes regulate the physical construction of dwellings and include plumbing, electrical, and mechanical divisions. The purpose of the Building Code and its enforcement is to protect the public from unsafe conditions associated with construction. The City of Beverly Hills enforces the California Building Code standards (Title 24) for existing units, new construction, and residential rehabilitation. State law affords local government some flexibility when adopting the uniform codes; the building codes can be amended based on geographical, topographical, or climate considerations. Further, State housing law provides that local building departments can authorize the use of materials and construction methods other than those specified in the uniform code if the proposed design is found to be satisfactory and the materials or methods are at least equivalent to that prescribed by the building codes.

The Beverly Hills City Council finds that certain changes and modifications are necessary in the adoption of the California Building Code because specific local conditions in the City involve climatic conditions which present severe fire hazards to buildings, structures and occupants because of the semiarid climate; the City's location which is partially in a hillside and mountainous area and partially on an alluvial plain; topographical conditions which create a hazard because of steep hillsides and the proximity of hills and canyons; and because of soil conditions in some areas which require testing prior to construction. Modifications to the Building Code are designed to meet the requirements of local needs, and can be summarized as follows:
• Re-adoption of current amendments to the State Building Code requiring additional seismic standards
• Amendments to the State’s 2019 Green Building Standards Code (CALGreen) and the State’s 2019 California Residential Code establishing a tiered set of requirements for new
development
The City doesn’t believe these amendments to the State building codes will affect the cost and supply of housing in the City for the following reasons:
• Past development activity (both entitlement and construction) has demonstrated sufficient interest and ability within the building industry to continue development of housing units at amounts desired by the State through the RHNA process.
• The City offers unit size and parking reductions, and unit density incentives for the development of senior and congregate housing projects. It is expected these incentives should counter-balance additional project costs associated with meeting the City’s added requirements. Additionally, the City DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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is in the process of carrying out the following programs to further incentivize the production of affordable housing:
o 10.1 Density Bonus – modify the City’s existing program to include specific waivers and incentives
o 10.2 Inclusionary Housing – implementation of the City’s inclusionary housing program to require affordable units within market rate developments
o 10.3 Housing Trust Fund – set aside money to be used in the development of affordable housing
o 10.4 Accessory Dwelling Units – promote accessory
dwelling units (ADUs) as a means to provide lower-cost
housing
o 10.6 Partnerships with Affordable Housing Developers – increase the power of the City’s investment in
affordable housing by partnering with NGO’s able to
compete for other funding sources, such as affordable
housing grants
o 11.2 Senior Housing Development – further incentivize the development of affordable senior housing
o 12.1 Adjust Development Standards – modify the City’s multi-family development standards to incentivize a
broader range of housing options
o 12.2 Reduced Fees for Affordable Housing – provide
additional incentives for affordable housing in the form of fee reductions for projects with a certain percentage of affordable housing

6. Fees
As in most cities, the City of Beverly Hills requires all new residential projects to go through a zoning review for entitlements, and a plan review for building permits. The Community Development
Department oversees both review processes in coordination with the City’s Public Works Department (Engineering, and Public Services).

Entitlement Processing Fees
The following charts identify the fees associated with the entitlement of a new housing project. Tables B-13 and B-14 include fees associated with multiple-family projects. Table B-15 includes fees associated with single-family projects. The City conducted a comprehensive fee study in FY 2019-20, and subsidized certain fees (effective February 1, 2020) related to entitlement projects that provide benefits to the greater community. These subsidized fees include the Open Air Dining fee for restaurants, the Design Review fee for single-family homes in the Central Area, and several fees related to historic preservation review (Landmark Designations, etc). All fee DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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information was provided by the Community Development
Department in April 2021.

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Multi-Family Housing Projects – Fees10
Table B-13 Planning Fees for New Multi-Family Residential Projects (2020)
Project Type/ Entitlement Cost
New Apartment Projects
Development Plan Review (10-3-2570)
Commission-level (Planning Commission) $16,400
Architecture/ Landscape Plan Review (10-3-3016)
Commission-level (Architectural Commission) $4,485
Environmental Review $291
Covenant Processing (upon entitlement) $578
Total Fees $24,666
Mixed Use Project
Development Plan Review (10-3-2570)
Commission-level (Planning Commission) $16,400
Architecture/ Landscape Plan Review (10-3-3016)
Commission-level (Architectural Commission) $4,485
Environmental Review $291
Covenant Processing (upon entitlement) $578
Total Fees $21,754
New Condominium Projects
Tentative Parcel/ Tract Map Review (Vesting and Non-Vesting) $20,247 Development Plan Review (10-3-2570)
Commission-level (Planning Commission)
(Multiple Application Fee Applied) $2,632
Architecture/ Landscape Plan Review (10-3-3016)
Commission-level (Architectural Commission) $4,485
Environmental Review $291
Covenant Processing (upon entitlement) $578
Total Fees $28,413
Conversion Projects (Apartments to Condominiums)
Tentative Parcel/ Tract Map Review (Vesting and Non-Vesting) $20,247 Common Interest Development Review (includes conversions) (Multiple Application Fee Applied) $2,632
Environmental Review $291
Covenant Processing (upon entitlement) $578
Total Fees $23,748
Note: The following fees also apply
• a 3.7% technology fee and 10% document maintenance fee on all development permits, plan checks, and planning applications

10 The entitlements listed here are those that would typically be required for a multi-family residential development, while other entitlements that would rarely or never used (such as a Conditional Use Permit) have not been included.

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Table B-14 Multi-Family Residential Projects Requiring Additional Discretionary Review
Entitlement (Potential Entitlements and Fees in Addition to the Base Entitlements and Fees for projects not complying with the General Plan and Zoning Code) Cost
Character Contributing Structural Review (07-R-12338) (To request an Apartment to Condominium Conversion without upgrading the existing building to all current zoning, and building and safety code requirements.

Evaluates an existing multi-family residential building’s structure and identifies necessary upgrades for safety/ seismic safety.)
$8,068
Density Bonus Permit (10-3.1524) $6,649
R-4 Permit
Commission Level (w/o another application)
Staff Level (w/o another application)
$8,254
$6,095
Variance (10-3.2804) (Reduction in parking, or set-backs based on irregularity of the site) $14,954
General Plan Amendment (Cal. Gov. Code) (plus full costs of processing the application) Deposit
Zone Change (10-3.3904) (plus full costs of processing the application) Deposit Environmental Assessment (Negative Declaration) Actual
Cost
Environmental Impact Reporta Actual
Cost
a. Plus a deposit for staff time to be determined by staff with charges at the fully allocated hourly rates for the project for contract planner/engineer plus any outside costs. This fee would include any mitigation monitoring programs that are required.

Single-Family Housing Projects – Fees
Table B-15 Planning Fees for Single-Family Residential Projects Project Type/ Fees Cost
New Single-Family Residence Projects using an architectural type listed in the City’s architectural design guidelines
Staff Level Plan Review (Development, Design, Landscape) (10-3.4612) $724 Environmental Review $291
Total Fees $1,015
New Single-Family Residence Projects not using an architectural type listed in the City’s architectural design guidelines
Commission Level Plan Review (Development, Design, Landscape) (10-

3.4612) $5,420
Environmental Review $291
Total Fees $5,711
Single-Family Residential Projects Requiring Discretionary Review R-1 Permits (Single Family Review, Central R-1, Hillside, Trousdale) $11,278 Note: The following fees also apply
• a 3.7% technology fee and 10% document maintenance fee on all development permits, plan checks, and planning applications
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Development Plan Review/ Building Permits – Multi-Family and Single-Family Housing Projects - Fees
Development review and building permit fees are summarized in the following table. The City’s fee structure is based on total valuation and the same fees are applied to multi-family and single-family projects.

Table B-16 Development Fees for Multi-Family and Single-Family Residential Projects (2020)
Zoning Conformance Letter $379
Conceptual Review (Zoning Review) $2,912
Building and Shoring and Grading Permit (Percent of total project valuation)
$0 - $500
Each additional $100 over the first $500, up to $1,000
Each additional $1,000 over the first $1,000, up to $20,000 Each additional $1,000 over the first $20,000 up to $50,000 Each additional $1,000 over the first $50,000 up to $100,000 Each additional $1,000 over the first $100,000 up to $500,000 Each additional $1,000 over the first $500,000
$62
$10
$41
$24
$17
$16
$14
Building Permit Plan Check (Percent of total permit) 80% Mechanical Permit
Issuance of permit (minimum)
Plus 1.55% of Building Permit Fee
$41
Mechanical Permit Plan Check (Percent of permit valuation) %100 Plumbing Permit
Issuance of permit (minimum)
Plus 1.55% of Building Permit Fee
$41
Plumbing Permit Plan Check (Percent of permit valuation) %100 Electrical Permit
Issuance of permit (minimum)
Plus 1.55% of Building Permit Fee
$41
Electrical Permit Plan Check (Percent of permit valuation) %100 Water Meter Connection Fee (not including replacement of sewer lateral – for new meters)
1”

1.5” – 2”
3”
4”
6”
$11,428
$13,033
$23,072
$26,038
$33,739
Water Meter Capacity Fee
1”

1.5”
2”
3”
4”
6”
$14,912
$29,824
$47,719
$89,473
$149.121
$298,243
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Water Meter Supply Fee
5/8” x ¾”
¾”
1”

1.5”
2”
3”
4”
6”
8”
10”
12”
$3,488
$5,231
$8,719
$17,438
$27,901
$55,802
$87,190
$174,380
$279,008
$732,396
$924,214
Off Site Improvements
Replacement of Sewer Lateral
Sidewalk Replacement Inspection (up to 250 SF)
Each additional 250 SF
Curb and Gutter Permit (first 100 linear feet)
Curb Drain Use Permit
Paving Replacement Inspection
Construction Barricade Permit
Utility Permit (plus $1.50 per square foot)
Hauling/ Street Use (Heavy Haul)
$1,177
$597
$148
$597
$398
$5/sq ft
$1,764
$200
Set by
statute
Note: The following fees also apply:
• Training and Education Fee of 1.2% of all building, mechanical, electrical and plumbing permits
• Accessibility Expert Fee of 4% on plan check and 3% on permit fees for new and greater than 50% remodel of Multi- Family properties
• 3.7% technology fee and 10% document maintenance fee on all development permits, plan checks, and planning applications
• General Plan Maintenance fee of 0.00151 per each $1 of all development Impact Fees and Exactions
Cities use exactions and impact fees to assure that a desired standard for public services and facilities is maintained. The City of Beverly Hills charges impact fees and exactions on all new residential development in the City to offset increased use of public infrastructure, public spaces, and services from future residents.

The effect that exactions and impact fees have on the cost of housing is proportional to the amenities and services provided by the exactions and impact fees. Exactions and impact fees do increase the cost of housing; however, when implemented well the increased cost results in higher property values and greater public desirability for the housing. The public’s desire results from the quality of the housing product, and from the public services and amenities available to the residents.

For housing sold at market rate, exaction and impact fees are a cost that is factored into the overall cost of the project. A market rate housing developer covers the increase in costs due to exactions and impact fees by building a higher quality product which in turn can be sold at a higher price. A person is more willing to pay the higher price for the housing because it is higher quality, and because of the DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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services and amenities provided by the exactions and impact fees.

Therefore, the cost of maintaining the City’s standards for public amenities and services is shared in part by the future residents.

Table B-17 Exactions & Impact Fees – Fiscal Year 2020-21 Type of Fee Fee
Dwelling Unit Tax
$1,181.05/unit +
$235.15/bedroom
Condo Conversion Fee $8,061.10/unit
School Fee—Residential $4.08/sq ft
Parks and Recreation Construction Tax $7.35/sq ft
SOURCE: City of Beverly Hills, April 2021
Exactions and impact fees can present a challenge in the development of affordable housing, since these costs cannot easily be passed on to the potential future resident as is the case with market rate housing. The City currently exempts dwelling units for very low, low and moderate income households from the dwelling unit tax and parks and recreation construction tax. The City will conduct a fee study to evaluate the economic benefit of providing additional waivers or reductions of certain fees for projects containing affordable units.

Total Fees and Exactions for a Typical Multi-Family Project The City adopts a schedule of taxes, fees and charges annually. In order to illustrate the total fees and exactions for a typical multi-family project, Table B-18 illustrates the fees that were charged on a recently permitted multi-family residential project under the applicable fee schedule. The City feels this project is a typical multi-family project based on the number of units and the lot size. The total fees that would be charged by the City would amount to approximately $1,964,531.42 equating to $98,226.57 per unit. The listing price for the condominium units in this building is not known at this time, since the project construction has not yet been completed. However, it would be reasonable to state that the City’s entitlement fees would be a nominal amount compared to the sales price, given that
condominiums in the City typically list for $800,000 to $2 million, depending on the location, size, and year built.

In summary, given the modest percentage that fees represent of unit sales prices, combined with the fact that affordable units are exempt from the dwelling unit tax and parks & recreation (QUIMBY) construction tax, it can be concluded that the City’s permit fees do not impose an undue constraint on the production of new housing.

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insignificant amount, and the City wishes to incentivize the production of affordable housing units, the Housing Plan includes Policy H 4.3, which requires that the City conduct a future fee study to assess the possibility of providing fee waivers for entitlement and permitting costs to help facilitate the production of affordable, senior, and workforce housing. In addition, the Housing Plan includes Imp. 12.2, which requires that the City conduct a housing development fee study, and commits the City to adopting modified development fees for projects with a certain percentage of affordable housing by 2026.

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Table B-18 Total Fees for a Typical Multi-Family Project Project Description – 425 N. Palm Drive, 20 Condominium Units Total Project Fees
Fees Per Unit
$1,964531.42
$98,226.57
Description Cost
Tentative Parcel/ Tract Map Review (Vesting and Non-Vesting) $14,744 Development Plan Review (10-3-2570)
Commission-level (Planning Commission) – Multiple Application Fee $3,577
R-4 Permit (10-3-2850) $2,632
Architecture/ Landscape Plan Review (10-3-3016)
Commission-level (Architectural Commission) $ 3,904.77
Environmental Review $4,000
Newspaper Noticing $2,415
Public Noticing – (Mailed Notice) $3,295
Public Noticing (On-site Signage) $314
Covenant Processing (upon entitlement) $466
Final Parcel/ Tract Map Review (Vesting and Non-Vesting) Zoning Review $706.20
Engineering Review $2,439
Building Permit and Plan Check $225,488.80
Shoring Permit $14,461
Grading Permit $25,617.35
Mechanical Permit and Plan Check $51,255.48
Plumbing Permit and Plan Check $51,255.48
Electrical Permit and Plan Check $50,231.85
Energy Permit and Energy Plan Review $84,558.10
Water Efficient Landscape Permit $738.30
Off Site Improvements
Sewer Charge
Sidewalk Replacement Use Permit
Curb and Gutter Permit
Curb Drain Use Permit
Paving Replacement Inspection ($3.00/square foot x 2,000 sq ft) Construction Barricade Permit
Utility Permit
Hauling/ Street Use (Heavy Haul Permit)
$6,803
$405.00
$1,439.00
$807.00
$6,000
$981.00
$155.30
$90.00
AB717 Fee $3,382,33
Seismic SB861 Residential $2,000
School Fees $135,358.08
Dwelling Unit Tax $22,800
Bedroom Tax $10,442
Parks and Recreation (QUIMBY) Fee $453,271.10
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On and Off-Site Improvements
Site improvements encompass the range of water, sewer, circulation, and other infrastructure needed to support development. In Beverly Hills, site improvements include water and sewer and storm drain laterals, streets, curbs, gutters, parkway, street trees, sidewalks and alleyways. The City uses a standard street width of 46-feet curb-tocurb within a 70-foot right-of-way for local residential (multi-family) streets and secondary arterial streets, and a standard street width of 36-feet curb-to-curb within a 60-foot right-of-way for local residential (single-family) streets. All residential streets are improved with 6-foot parkways and 6-foot sidewalks on both sides of the street.

To ensure that adequate improvements are in place, Beverly Hills requires pro-rata payments for off-site extension of the water, sewer and storm drain systems, and pro-rata payments for transportation improvements. In larger projects, the City requires developers to construct internal streets, sidewalks, curbs, gutters, and affected portions of off-site arterials. However, development in Beverly Hills typically occurs on small infill parcels where infrastructure is already in place.

While on and off-site improvements add to the cost of development and thus impact affordability, it is standard for jurisdictions to require development to “pay its own way.” Beverly Hills site improvement requirements are deemed necessary to maintain the quality of life desired by residents, and are consistent with General Plan goals to ensure that public services and facilities are in place at the time of need, thus avoiding the overloading of existing urban service systems.

7. Housing for Persons with Special Needs
Special Needs Housing Overlay Zone
In order to encourage a variety of housing, the City has established a Special Needs Housing Overlay Zone to encourage the construction of housing for persons with special needs in certain areas of the City and locate such housing close to appropriate amenities and services.

The Special Needs Housing Overlay Zone allows increased residential density, small housing units, and reduced parking requirements.

Emergency Shelters are permitted by-right in the Special Needs Housing Overlay zone, and SROs and multi-family congregate housing for elderly or disabled are permitted with a Conditional Use Permit (CUP).

The Special Needs Housing Overlay Zone applies to R-4 zones on sites which meet the following criteria:
• Site is located in area with 4 or 5 story height limits • Site is located adjacent to commercial zoned areas, and is separated by an alley from commercial uses
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A total of 37.8 acres on 172 parcels within the R-4 zone meets these criteria for special needs housing. A map of the Special Needs Housing Overlay Zone is provided at the end of this Appendix.

This ordinance also added the following definitions to the Municipal Code:
• Bona Fide Housekeeping Unit: Shall have the same meaning as Single Housekeeping Unit
• Community Care Facility, Large: Any State licensed facility, place, or structure that is maintained and operated to provide non-medical residential care, day treatment, adult day care, or foster agency services for seven or more adults, children, or adults and children, as defined in California Health and Safety Code Section 1502. However, as noted in Imp. 11.5, the City has committed to revise the regulations related to group homes or community care facilities to ensure that these regulations do not create constraints on persons with
disabilities and to allow group homes for 7 or more persons in all residential zones and other housing types of the same form • Community Care Facility, Small: Any State licensed facility, place, or structure that is maintained and operated to provide non-medical residential care, day treatment, adult day care, or foster agency services for six or fewer adults, children, or adults and children, as defined in California Health and Safety Code Section 1502.
• Emergency Shelter: A facility that provides immediate and short-term housing with minimal support services for homeless persons or families on a first-come, first-served basis, and that is limited to occupancy of no more than six months.
• Family: Two or more persons living together as a single housekeeping unit in a single dwelling unit. Family also means the persons living together in a licensed residential facility, as that term is defined in California Health & Safety Code Section 1502(a)(1) serving six or fewer persons, excluding the licensee, the members of the licensee’s family, and persons employed as facility staff who reside at the facility. However, as noted in Imp. 11.5, the City has committed to review and amend the zoning code to revise the definition of “family” to ensure that this does not create constraints on persons with disabilities. • Single-Family Residence: Shall have the same meaning as One-family or Single-family Residence or Dwelling.
• Single Housekeeping Unit: The functional equivalent of a traditional family, whose members are a non-transient
interactive group of two or more persons, where such persons jointly occupy a single dwelling unit, jointly use common areas, DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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and share household activities and responsibilities (e.g., meals, chores, and expenses).
• Single Room Occupancy Housing (SRO): A residential facility where individual secure rooms are rented to a one- or twoperson household. Rooms are generally 150 to 375 square feet in size and include a sink, closet and toilet, with shower and kitchen facilities typically shared. SRO units are rented on a weekly or monthly basis.
• Supportive Housing: Permanent affordable housing with no limit on length of stay, that is occupied by the target population as identified in State law, and that is linked to onsite or offsite services that assist the supportive housing residents in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community.
• Target Population: Persons with disabilities, homeless families, and homeless youth.
• Transitional Housing: Temporary rental housing intended for occupancy by homeless individuals or families transitioning to permanent housing that is operated under program
requirements calling for the termination of assistance and recirculation of the dwelling unit to another eligible program recipient at a predetermined future time, which shall be no less than six months. Transitional housing often includes a supportive services component, such as job skills training or rehabilitation counseling to allow individuals to gain the necessary life skills to support independent living.

Table B-19 and Table B-20 show allowable types of special needs housing in single-family and multi-family zones, respectively. In order to address any non-intended constraints to the provision of housing for disabled individuals, the City has actions outlined in its Housing Plan (Implementation Program 11.5) to commit to periodically reviewing the zoning code definitions related to housing for persons with disabilities to ensure the definitions maintain compliance with state law.

Table B-19 City of Beverly Hills Residential Allowable Residential Development Land Use Regulations for Single Family Residential Zoning Districts and Zoning District Overlays
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R-1 R-1X R-1.5 R-1.5X R-1.5X2 R-1.6X R1.7X R-1.8X
Single-family dwelling P P P P P P P P
Accessory Dwelling units P P P P P P P P
Transitional and supportive housing1
Single-family structure P P P P P P P P
Family daycare home
Small P P P P P P P P
Large UP UP UP UP UP UP UP UP
Community care facility2
Small (serving 6 or fewer) P P P P P P P P
Manufactured/Mobile home P P P P P P P P
Notes: P: Permitted use UP: Use Permit CUP: Conditional Use Permit

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a single-family residence, it is regulated as such and is subject to all regulations applied to residences in the single family residential zone where it is located.

2. For the purposes of this table, residential care facilities for the elderly, as defined in state law, shall be treated the same as community care facilities.

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Table B-20 City of Beverly Hills Residential Allowable Residential Development Land Use Regulations for Multi-Family Residential Zoning Districts and Zoning District Overlays R-4
RMC
P
Special Needs
Housing
Overlay3 R4X1 R-4X2 R-3 R-4-P
Single-Family dwelling P P P P P
Duplex P P P P P P
Accessory Dwelling units P P P P P P
Multi-family dwelling P P P P P P
Transitional and supportive housing1
Single-family structure P P P P
Multi-family structure P P P P P
Emergency shelters P
Single room occupancy housing (SRO) CUP
Community care facilities2 (state licensed)
Small (6 or fewer) P P P P
Large (7 or more) CUP CUP CUP CUP CUP
Childcare uses licensed pursuant to state law CUP CUP CUP CUP Multiple-family congregate housing for the elderly or disabled pursuant to article 12.8 of zoning code4 CUP
Multiple-family housing for the elderly or disabled pursuant to article 12.5 of the zoning code5 CUP CUP CUP CUP
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R-4
RMC
P
Special Needs
Housing
Overlay3 R4X1 R-4X2 R-3 R-4-P
Notes: P: Permitted use UP: Use Permit CUP: Conditional Use Permit

1. Transitional or supportive housing is permitted in residential zones subject to the same standards as similar residential uses; therefore, if such housing is configured as a multi-family residence, it is regulated as such and is subject to all regulations applied to residences in the multi-family residential zone where it is located.

2. For the purposes of this table, residential care facilities for the elderly, as defined in state law, shall be treated the same as community care facilities.

3. Uses allowed in the special needs housing overlay zone are in addition to any use allowed in the underlying zoning district.

4. A Conditional use Permit (CUP) is required to utilize the reduced development standards offered for this type of development. Intended to reduce development costs for assisted living facilities. Specific requirements apply. The project site must be located in an area with four- or five-story height limits; located adjacent to commercially zoned areas; separated from adjacent commercial areas by an alley; and located on a street greater than thirty feet (30’) in width. Unit density up to 165 units/acre. Reduced minimum unit sizes and parking requirements apply (450 square feet minimum unit size, unit must have private bathroom) (BHMC 10-3-12.8).

5. Multiple-family housing for the elderly or disabled is a permitted use in any zone permitting multiple-family residential uses. Conditional Use Permit (CUP) required to utilize the reduced development standards offered for this type of development. Intended to reduce development costs of housing for seniors and persons with disabilities. Specific requirements apply. Housing limited to households with head of household 62 years and older and families with handicapped member. Maximum unit density 150 units/acre. Minimum unit size as defined by HUD. Maximum number of bedrooms per unit is 2. Only 5% of the units can be 2-bedroom units (BHMC 10-3-12.5).

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Elderly and Disabled Housing
Beverly Hills has established modified standards to specifically encourage the provision of higher density rental housing for seniors and persons with disabilities at costs lower than could otherwise be achieved. While housing which serves the elderly and persons with disabilities is permitted in any residential zone district subject to the same standards as other residential uses, for such housing to take advantage of a potential doubling in density and other modified standards, a Conditional Use Permit is required. The Municipal Code specifies the following two distinct types of housing: 1) Multiple-Family Congregate Housing for Elderly and Disabled Persons (Article 12.8); and 2) Multiple-Family Housing for Elderly and Disabled Persons (Article 12.5).

Multiple-Family Congregate Housing for Elderly and Disabled Persons and Community Care Facilities
Congregate housing provides a range of support services for residents, including all meals, housekeeping and laundry service, private transportation, planned activity programs, and 24-hour emergency inhouse call system. Emergency shelters, transitional and supportive housing programs and community care facilities for seven or more persons, offer similar amenities and support networks. Currently, to use the City’s incentives to develop an elderly or disabled congregate care facility the City requires at least one household member to be 65 years of age or older, or to have a substantial physical impairment. The City may study fee reductions for certain types of housing in this zone, as outlined in program

12.3 of the adopted Housing Element.

The City’s modified development standards for congregate housing for the elderly or disabled provide for densities of up to 165 units per acre, with up to 113 units permitted on any one site. In addition, the City provides significant reductions in the minimum unit size for congregate housing:
• 450 square feet for an efficiency unit
• 500 square feet for a one-bedroom unit
• 800 square feet for a two-bedroom unit
As presented in Table B-9, the City has adopted a reduced parking ratio for congregate housing of one space for one-bedroom units and 1.5 spaces for two bedroom units. The Planning Commission is authorized to provide further reductions of one-half space per unit.

The City is committed to providing opportunities for special needs housing and realizes that such housing forms typically require additional incentives to be viable. The incentives offered in the City’s Special Needs Housing Overlay zone offer greater density and reduced parking and unit size requirements as compared to normal R-4 standards. Additionally, the City may study the viability of reducing or waiving the cost for the Conditional DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Use Permit for these projects in the future. A map of the overlay area is provided in the back of this document and shows that the overlay zone properties are in close proximity to public transportation and businesses that support daily needs and services. The overlay zone is residential and so provides the look and feel of living in a neighborhood, as opposed to alternative locations in the commercial zones. For these reasons this overlay zone, in concert with the incentives offered, is a viable location for special needs housing. Specific implementation programs (Imp. 11.1 and Imp. 12.1) in the Housing Plan have been added to further fair housing practices and analyze how zoning regulations may be amended to help provide more housing for special needs populations (such as the congregate care facility regulations).

Multiple-Family Housing for Elderly and Handicapped Persons (DeedRestricted Affordable) Affordable independent multi-family housing for the elderly (age 62+) and disabled persons is permitted by Conditional Use Permit in any zone allowing multiple-family residential uses. Densities of up to 165 units per acre are permitted, with a maximum project size of 150 units. Minimum unit sizes are not less than the maximum allowable under HUDs Section 202 Senior Housing Program, with no more than five percent of project units permitted to be two-bedrooms. Building height must be consistent with the prevailing height of surrounding buildings, and not greater than 60 feet. A reduced parking ratio of one space per unit is allowed, with further reductions to 0.4 space per unit permitted at the discretion of the Planning Commission.

If the rental rates for any such senior or disabled housing are not under the provision of a federal, state, or other public agency, then the rental rates will be set by the Planning Commission at affordable levels as a condition of approval.

Housing for Persons with Disabilities
The following analysis addresses Beverly Hills’ regulations and procedures for housing for persons with disabilities with regard to: 1) zoning and development standards; 2) building codes; and 3) processing procedures.

Zoning and Development Standards
The City’s Zoning Code facilitates housing for persons with disabilities in several ways, including:
• Allowances for property owners to build handicapped ramps into residential structures which encroach into the front, or side yard setbacks to allow first floor access for physically disabled residents. • Allowances for elevators to encroach in the side yard setbacks on single-family properties to allow persons no longer able to climb stairs to remain in their homes.

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• Reduced parking and unit size standards for multi-family congregate housing for elderly and disabled persons, and for affordable multifamily residences for elderly and handicapped persons.

The City permits housing for special needs groups in residential zones, including for individuals with disabilities, without regard to distances between such uses or the number of uses in any part of the City.

Building Codes
The City of Beverly Hills ensures that new housing developments comply with California building standards (Title 24 of the California Code of Regulations) and federal requirements for accessibility. For example, any new apartment development is subject to requirements under the Americans with Disabilities Act (ADA) for unit “adaptability” on ground floor units. Adaptable units are built for easy conversion to disabled access, such as doorway and hallway widths, and added structural support in the bathroom to allow the addition of handrails.

The City also allows residential retrofitting to increase the suitability of homes for persons with disabilities in compliance with accessibility requirements.

Further, the City works with applicants who need special accommodations in their homes to ensure that application of building code requirements does not create a constraint.

Permits and Processing
The City does not impose special permit procedures or requirements that could impede the retrofitting of homes for accessibility. The City’s requirements for building permits and inspections are the same as for other residential projects and are straightforward and not burdensome. City officials are not aware of any instances in which an applicant experienced delays or rejection of a retrofitting proposal for accessibility to persons with disabilities.

Reasonable Accommodation
In 2012, the City adopted Ordinance No. 12-O-2634 to establish specific written procedures for persons with a disability to request reasonable accommodation from the zoning and land use regulations. This ordinance codifies the process through which a request for a modification to building codes, land use regulations, policies, or procedures needed to enable a person affected by a disability to use and enjoy a housing unit. A request for a Reasonable Accommodation is reviewed by the Community Development Director (or Designee), unless it is related to a discretionary land use application that requires review by the Planning Commission, in which case the Planning Commission is the reviewing authority. The applicant must provide information pertaining to the regulation, procedure, or policy from which relief is sought, the nature of the property and the relief sought, and explanation of why the accommodation is DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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reasonable and necessary. No application fee is associated with the Reasonable Accommodation, and if an improvement or modification is requested that would normally require a variance, a variance is not required. Given the process, the specific criteria set forth for qualification, and the no-fee application, the City’s current regulations related to reasonable accommodations does not appear to act as a constraint for persons with disabilities.

Transitional and Supportive Housing
Transitional housing is defined as temporary (typically six months to two years) housing for a homeless individual or family who is transitioning to permanent housing or for youth who are moving out of the foster care system. Supportive housing is generally defined as permanent, affordable housing linked to on- or off-site services and occupied by a target population (i.e., persons with disabilities, suffering from mental illness or chronic health conditions). Services typically include assistance designed to meet the needs of the target population in retaining the housing, living and working in the community, and/or improving health.

State law requires that transitional and supportive housing be treated as residential uses that are subject only to those restrictions that apply to other residential uses of the same type in the same zone. In addition, supportive housing shall be a use by-right in zones where multifamily and mixed uses are permitted, including nonresidential zones permitting multifamily uses pursuant to Government Code section 65651. Implementation Measure

11.5 includes a commitment to review and update the Zoning Ordinance to ensure conformance with current State definitions and requirements.

Emergency Shelters
Emergency shelters are facilities that provide shelter to homeless families and/or individuals on a short-term basis.

Jurisdictions with an unmet need for emergency shelters for the homeless must identify at least one zone where emergency shelters will be allowed as a permitted use without a Conditional Use Permit or other discretionary approval. The identified zone must have sufficient capacity to accommodate the unmet shelter need, and at a minimum provide capacity for at least one year-round shelter. Permit processing, development and management standards for emergency shelters must be objective and facilitate the development of, or conversion to, emergency shelters.

As noted in Appendix A, the most recent homeless survey estimated that there are 17 unsheltered persons experiencing homelessness in Beverly Hills.

Beverly Hills has no emergency shelters within its City limits; however, the City has provided funds for the construction and ongoing operation of DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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emergency shelters operated by People Assisting the Homeless (PATH), and by Network of Care for Veterans and Service Members.

The Zoning Ordinance allows emergency shelters by-right in the R-4 multifamily residential zoning overlay district. This district is characterized as a high-density multi-family zone consisting of a variety of existing apartment buildings and condominiums. Within the approximately 37.8-acre area there are numerous older and/or underutilized residential properties that could be converted or redeveloped for use as emergency shelters.

Additionally, the overlay zone provides close access to needs and services such as grocery stores, pharmacies, and transportation. A map of this zone is provided at the end of this document.

Development standards within the district located in the Southerly Zone of the City (BHMC 10-2-303: LOTS: A.) are appropriate to facilitate emergency shelters, and can be summarized as follows:
• Height: up to 60 feet, or five stories
• Minimum Lot Size: 7,500 square feet
• Minimum Public Street Frontage: 55 feet
• Setbacks:
o Front – 15 feet
o Side (total) 19 – 23 feet
Pursuant to State law, the City has also established development standards for Emergency Shelters regulating the following aspects:
• The maximum number of beds or persons permitted to be served nightly by the facility;
• A minimum of one parking space for every 10 beds, plus one-half space for each bedroom designated for families with children, plus one parking space for each employee/volunteer on duty. The number of parking spaces may be reduced by 25% if the shelter is located within 1,000 feet of a public transit stop. Bicycle rack parking shall also be provided.
• The size and location of exterior and interior onsite waiting and client intake areas;
• The provision of onsite management;
• The proximity of other emergency shelters, provided that shelters are not required to be more than 300 feet apart;
• The length of stay;
• Lighting; and
• Security during hours that the emergency shelter is in operation.

To address recent changes to State law, Implementation Measure 11.7 includes a commitment to process a Municipal Code amendment regarding required parking for emergency shelters consistent with Government Code Sec. 65583(a)(4)(A)(2).

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Low Barrier Navigation Centers
In 2019, the State Legislature adopted AB 101 establishing requirements related to local regulation of low barrier navigation centers, which are defined as “Housing first, low-barrier, service-enriched shelters focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing.” Low barrier means best practices to reduce barriers to entry, and may include, but is not limited to:
(1) The presence of partners if it is not a population-specific site, such as for survivors of domestic violence or sexual assault, women, or youth
(2) Accommodation of residents’ pets
(3) The storage of possessions
(4) Privacy, such as partitions around beds in a dormitory setting or in larger rooms containing more than two beds, or private rooms”
Low barrier navigation centers meeting specified standards must be allowed by-right in areas zoned for mixed use and in nonresidential zones permitting multi-family uses. Program Imp 11.7 in the Housing Plan includes a commitment to process an amendment to the Zoning Code in compliance with this requirement.

Single Room Occupancy (SRO)
Single Room Occupancy (SRO) residences are small, one-room units occupied by a single individual, and may either have shared or private kitchen and bathroom facilities. SROs are rented on a monthly basis typically without rental deposit, and can provide an entry point into the housing market for extremely-low-income individuals, formerly homeless and disabled persons.

Ordinance No. 12-O-2633 established a definition for “Single Room Occupancy Housing” (SRO) and incorporated this definition into the zoning code. SROs are allowed in the Special Needs Housing Overlay Zone by Conditional Use Permit. Additionally, the ordinance established development standards for SROs including unit size and occupancy, common area, management, parking, kitchen facilities and bathroom facilities to ensure high standards for development.

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Mobile Homes
No mobile homes or mobile home parks are located in the community.

Pursuant to State law, the City permits manufactured housing placed on a permanent foundation in all residential zones.

Farm Employee Housing
Beverly Hills is located within the highly urbanized Los Angeles metropolitan area, and no agricultural land remains in the City. Given these conditions, no specialized regulations have been adopted for farmworker housing. Any agricultural employees who may happen to live in the City would be eligible to participate in any affordable housing programs that are offered to other lower-income persons. To address the requirements of Health & Safety Code Sec. 17021.5 Implementation Measure 11.1 includes a commitment to process an amendment to the Municipal Code to allow employee housing for six or fewer employees as a single-family structure that is permitted in the same manner as other dwellings of the same type in the same zone.

Inclusionary Housing
In 2019, the City Council established an inclusionary housing program with the following provisions:
• Applies to projects with five or more housing units.
• For projects with five or more but fewer than 10 units, the developer must provide one affordable unit for low-income households. There is an option for the developer to pay a fee in-lieu of providing the affordable housing unit.
• For rental projects with 10 or more units, a minimum of 10% of all the units in the development must be rented to and occupied by verylow-, low-, or moderate-income households. • For new condominium projects or condominium conversion projects with 10 or more units, a minimum of 10% of all the units in the development must be sold to and occupied by very-low-, low-, or moderate-income households.
• When only one affordable unit is constructed as part of a development it may be allocated for a very-low-, low-, or moderateincome household. When two or more affordable units are constructed, the units shall be allocated alternately with the first unit for low- or very-low-income and the second for moderate-income and so forth.
• The inclusionary housing regulations do not apply to projects that enter into a development agreement with the City.

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Rent Control
Most non-condominium multi-family properties in Beverly Hills built before 1995 are subject to rent control. Rent control of apartment units first went into effect March 31, 1979. On January 24, 2017, the City’s rent control ordinance was amended to establish the requirement to pay relocation fees to tenants who were evicted for no-cause or non-just cause from Chapter 6 units. This Ordinance also increased the relocation fees that must be paid to tenants for Chapter 5 units, and established an annual increase in the relocation fees tied to the CPI to be conducted on July 1st of each year for both Chapter 5 and Chapter 6 units. The ordinance decreased the allowable rent increase for Chapter 6 to the greater of; 3% or the percentage equal to the percentage increase in the CPI. It also established a rent increase application process and the requirement for property owners to annually register their rental units.

On October 18, 2018, the City further updated the rent control regulations to eliminate no cause evictions. In addition it added a new grounds for a just-cause eviction of a disruptive tenant and a new procedure pertaining to the termination of a tenancy of a disruptive tenant to Chapters 5 and 6.

On April 2, 2019, an Ordinance was adopted establishing the Rent Stabilization Commission. The Commission is to be composed of the following: two (2) landlords who own one or more residential rental properties with the City; two (2) tenants who reside in the City; and two (2) at large members who are not landlords, tenants or managers of an apartment building. The Commission will also have three alternates, one from each of the categories (1 landlord, 1 tenant and 1 at large member).

The Rent Stabilization Commission, as established by the Ordinance has the power to: a) make recommendations to the City Council concerning amendments to Chapter 5 and 6 of Title 4 that have not been resolved by the City Council; and b) to perform any other functions that may be designated by resolution or motion of the City Council.

All Ordinances are closely monitored by the Rent Stabilization Division in an attempt to assure the rent stabilization guidelines are properly followed and there is no abuse or misinterpretation of the City Council’s intent.

C. Environment and Infrastructure
Environmental and infrastructure constraints can limit or affect the type and density of housing development in a community. These constraints can include natural resources such as topography and flood areas, hazards/safety concerns, or lack of sufficient infrastructure capacity.

However, as discussed in greater detail below, Beverly Hills is a built-out community with little remaining vacant land, with the majority of the City’s infrastructure systems already in place. Environmental and infrastructure concerns do not compose a significant constraint to housing production.

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1. Environmental Constraints
Seismic Hazards
The City of Beverly Hills contains both active and potentially active faults.

Specifically, three active or potentially active faults are located within the City limits, including: the Hollywood Fault, the Santa Monica Fault, and the Newport-Inglewood Zone of Deformation. (Woodward-Clyde 1987) Since the 1987 Study was completed, work completed by Dolan, et al and the California Division of Mines and Geology maps show the Hollywood and Santa Monica faults as converging within the City, and the NewportInglewood fault located approximately two miles south of the City.

The City of Beverly Hills implements the most recent California Building Code. In addition, the City’s Seismic Safety Program promotes public safety and welfare by reducing the risk of death or injury that may result from the effects of earthquakes on existing unreinforced masonry bearing wall buildings. In addition, the City adopted a mandatory seismic retrofit ordinance in 2018 that requires existing soft-story multi-family buildings to be reinforced. The City is also exploring the adoption of a mandatory retrofit program for non-ductile concrete buildings and pre-Northridge earthquake moment frame buildings.

Landslides and Slope Hazards
The hillside areas of Beverly Hills pose the greatest hazard of landslides.

Surface movements in the hillside area could be triggered by heavy rain, a reservoir breach, pumping facilities or an earthquake. Hillside development has placed additional loads on the subsurface bedrock. Additionally, improper site grading, steep slopes, and loss of vegetation can increase the potential for localized landslides. In the canyon areas, the presence of subsurface water and geology composition provides the potential for liquefaction during earthquakes. Any significant hillside movement along canyon streets would potentially isolate populations in those areas due to limited ingress egress routes. Potential damage to underground utilities and fire hydrants could also result from landslide movement. Future growth in the canyon areas of the City may be limited due to safety factors.

Flooding Hazards
There are no Federal Emergency Management Agency (FEMA) designated flood zones in the City of Beverly Hills. The City is located within the Ballona Creek Watershed; however most of the drainage is controlled by structural flood control measures along a mostly channelized watershed.

Approximately 40 percent of the watershed within the City is covered by impervious surfaces leading to greater surface area for storm runoff and the potential for flooding.

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FEMA, as part of its statutory responsibilities to carry out the National Flood Insurance Program, has mapped most of the flood risk areas within the United States. The City of Beverly Hills is located in a FEMA Zone “X” which does not require mandatory flood mitigation enforcement.11 Properties are not required to carry flood insurance (Hazard Mitigation Action Plan 2017, pg. 59). However, Beverly Hills is highly urbanized and as a result of increased paving, can lead to an increase in volume and velocity of runoff after a rainfall event, exacerbating the potential flood hazards. The City’s steep hillside areas are also more susceptible to runoff and slope failures, and new development in these areas will require careful adherence to current grading, soil compaction, maximum slope, and drainage regulations.

The City of Beverly Hills also lies in the inundation path of the Lower Franklin Canyon Dam, which is located north of the City. The reservoir has a 200 acre-feet capacity and can be drained to half capacity in 72 hours and completely emptied in 216 hours. The National Inventory of Dams characterizes this dam with significant hazard potential. Dams with significant hazard potential are those in which failure or incorrect operation would result in no probable loss of human life but can cause economic loss, environmental damage, and disruption of lifeline facilities. In the event of a breach of the Lower Franklin Reservoir, the residential area north of Carmelita Avenue would be exposed to immediate and severe danger.

Below that point, the danger diminishes rapidly although flooding of most structures in this section of the inundation path would occur. Approximately 1,200 people live in the sector of the inundation area subject to severe danger and provision for evacuation of this population is required in the event of a breach in the structure. This reservoir, as well as others in California, are continually monitored by various governmental agencies (such as the State of California Division of Safety of Dams and the U.S. Army Corps of Engineers) to guard against the threat of dam failure.

The possibility of dam failures during an earthquake has been addressed by the California Division of Mines and Geology in the earthquake planning scenarios for a magnitude 8.3 earthquake on the San Andreas Fault zone and a magnitude 7.0 earthquake on the Newport-Inglewood fault zone (Davis 1982). These studies found that catastrophic failure of a major dam as a result of a scenario earthquake is regarded as unlikely (Davis 1982).

Current design and construction practices and ongoing programs of review, modification, or total reconstruction of existing dams are intended to ensure that all dams are capable of withstanding the maximum credible earthquake (MCE) for the Incentive Area. FEMA requires that all reservoir owners develop Emergency Action Plans (EAP) for warning, evacuation,

11 City of Beverly Hills Hazard Mitigation Plan 2017-2022. http://www.beverlyhills.org/citymanager/emergencymanagement/hazardmitigationplan DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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and post-flood actions. Although there may be coordination with county officials in the development of the EAP, the responsibility for developing potential flood inundation maps and facilitation of emergency response is the responsibility of the reservoir owner.

The City’s Safety Element and hazard mitigation plan address flood hazard mitigation, including dam or reservoir failure inundation hazards.

Furthermore, any project would be required to undergo project-specific environmental review, at which time specific mitigation or design changes would be required to reduce the exposure of people or structures to flooding. Therefore, potential impacts associated with flooding were found to be less-than-significant in the General Plan environmental review and are not considered a constraint to new housing production. 12 Wildland Fire Hazard
Beverly Hills is bounded on the north by hillside and canyon areas. Canyons that empty into the City's boundaries are Benedict, Franklin, Coldwater, and Trousdale Canyons. Benedict, Coldwater, and Trousdale Canyons are densely populated, with Franklin Canyon the least developed of the four.

The dense wild brush of Franklin Canyon extends to the boundaries of the City. Due to the extensive hazards originating in the hills north of Sunset Boulevard, the area has been designated a Very High Fire Hazard Severity Zone (VHFHSZ). Approximately 36 percent of the City is located in the VHFHSZ. The City’s Fire Department has implemented programs13 to help educate the community located in the VHFHSZ area, and encourage them to take steps to reduce the risk of wildfire in the VHFHSZ area. These include the “Ready, Set, Go!” program which emphasizes homeowner preparation for fire events, the Brush Clearance and Fuel Modification Programs, which focus on reducing vegetation that can contribute to fire events, and the Public Tree Program, which seeks to provide greater defensible space from public trees with higher flammability characteristics.

Urban Fire Hazard
In the built-out areas of the community, the primary fire hazard risks are man-made. Beverly Hills is home to three very large hotels having occupancies in excess of 500 persons per day, 36 high-rise buildings, and a densely populated retail and commercial district. Of particular concern are two high-rise buildings that are residential occupancies and did not fall under the 1998 retrofit sprinkler mandate imposed on buildings 55 feet or

12Beverly Hills General Plan EIR, 2008
13 http://www.beverlyhills.org/departments/firedepartment/vegetationprograms/ DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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higher. These are the only two high-rise buildings in the City that are not equipped with sprinkler systems.

New housing development within the City is expected to occur through the infill of existing sites and mixed-use development in commercial areas.

Limited future development is expected to occur in the hillside areas.

Wildland fire risks for new development are mitigated by various City programs described below.

Fire Prevention and Suppression Programs
In 1998, the Beverly Hills Fire Department (BHFD) installed a Remote Automated Weather Station (RAWS) in the hillside area just outside the City in Franklin Canyon. Data from the RAWS assists fire officials in determining the need for augmenting or redeploying fire resources depending on current and anticipated weather conditions.

For the VHFHSZ, the BHFD has also developed “Pre-Attack Plans” that enable the fire department to predetermine required resource deployment, resources to locate combustible roofs, evacuation routes, safe refuge areas, and resident assemblage locations. These planning resources help firefighting forces make critical decisions during emergency situations. Pre-Attack Plans are also made available to outside agencies who are called for Mutual Aid assistance and that may not be familiar with the area.

In addition, in 2004 the BHFD and residents within the VHFHSZ initiated the FireWise Communities/USA Program, which is designed to enable communities to achieve a high level of protection against wildland/urban interface fire loss while maintaining a sustainable ecosystem balance.

Biological Resources
The City of Beverly Hills is fully developed with urban uses and has little undisturbed open space areas. Review of GIS databases and aerial photographs indicate that there is little native terrestrial vegetation within the City. The only relatively undisturbed areas include those located near the foothills of the Santa Monica Mountains and the few open space areas located in the area north of Sunset Boulevard. The remaining open space within the City is located in public parks, which typically do not contain natural or native vegetation.

As discussed in the Beverly Hills General Plan Amendments Environmental Review (2009), there are no riparian or sensitive habitats that are known to occur in the City of Beverly Hills. As no riparian or sensitive habitats are DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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known to exist within the City, biological resources do not present a constraint to future housing development within the community.14 In summary, while environmental constraints will require development to incorporate measures to mitigate potential hazards, the City’s development review process already includes standard processes and requirements to address such constraints. For example, the plan check process requires a seismic study for any development that may be affected by a seismic hazard. In addition, the housing units included in the Sites Inventory are not located within the Very High Fire Hazard Severity Zone (VHFHSZ), and the City’s Safety Element was recently updated (in 2022) to address potential climate change issues and assess any safety issues related to an increase in development and population over the next planning period. Furthermore, the City has experienced housing development, including single-family, multi-family, and mixed use residential projects, in recent years, which demonstrates that such constraints have not precluded development in the past. As such, the identified constraints are not expected to preclude housing development on the sites identified to satisfy the RHNA.

2. Infrastructure Constraints
Infrastructure needed to maintain and develop new housing includes water facilities, sewer facilities, streets, storm drains, street lights, and sidewalks. The provision and maintenance of these facilities in a community enhances not only the character of the neighborhoods but also serves as an incentive to homeowners to routinely maintain the condition of their homes. In contrast, when public improvements are left to deteriorate or are overextended in use, the neighborhoods in which they are located become neglected and show early signs of deterioration.

Very little undeveloped residential land remains in the City. Most of the community’s infrastructure is currently in place and adequately serves existing development. Future housing growth will occur within in-fill areas and construction of multi-family or mixed-use development within commercial areas. Therefore, the provision of infrastructure does not constitute a constraint to housing production.15
Water System
The City of Beverly Hills provides water service to all of the City’s residents and to some residential parts of the City of West Hollywood. The City of Beverly Hills will be importing about 70% of its water from the Metropolitan Water district (MWD) to approximately 9,400 customers. The remaining

14 Beverly Hills General Plan Amendments Environmental Review (2009) 15 Ibid.

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30% of water need is met by the four groundwater wells in the City. Three groundwater Hollywood wells are located in the Beverly Gardens Park, one in the Burton Way median, two shallow groundwater wells (Maple yard wells) at the City’s yard, and one is currently being developed in the unadjudicated portion of the Central Basin in the City of Los Angeles. All existing and proposed wells will be pumped to the City’s treatment plant through a transmission main owned and maintained by the City. The proposed Central Basin well is drilled and the transmission main construction completed. The well-equipping construction phase of the project is currently underway. About 80 percent of the water service area use is residential in nature. 16
As described in the Urban Water Management Plan (UWMP), the current and projected water supply and demand indicates that in average precipitation years, the City has sufficient water to meet its customer’s needs through 2030. Beverly Hills’ water supply is anticipated to meet the demand for future population growth up to 2030. As per State Law (Gov Code Sec. 65589.7), the City will give priority for service hook-ups to projects that include affordable housing.

Sewer System
The Beverly Hills Department of Public Works maintains a sewer collection system within the community. The existing sanitary sewer system consists of over 95 miles of sewer main. More than half of the existing sewer system within Beverly Hills is over 50 years old. To address this issue, the City of Beverly Hills has a rehabilitation program in place to repair, reline, and/or replace the existing wastewater infrastructure. The City of Beverly Hills sewer flows come from the City of Los Angeles from its north and northwestern border and then comingles flows within the city limits until it connects to the City of Los Angeles sewer facilities at the southeastern border of the City.

All of the City’s wastewater flow is treated at the City of Los Angeles Hyperion Treatment Plant in El Segundo.17 Wastewater treatment capacity is expected to be adequate to accommodate projected housing development during the planning period. 18As per State Law (Gov Code Sec. 65589.7), the City will give priority for service hook-ups to projects that include affordable housing.

16 Ibid.
17 City of Beverly Hills General Plan Update Technical Background Report, October 2005. 18 City of Los Angeles, Citywide Housing Element 2021-2029 and Safety Element Updates Draft EIR, p.

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Storm Drainage
There are approximately 47 miles of improved storm drains within and adjacent to the boundaries of the City of Beverly Hills, approximately twothirds of which are owned and maintained by the City. The remaining onethird are under the jurisdiction of the Los Angeles County Department of Public Works. Roughly one-third of the storm drain system was built before 1940 with the earliest construction taking place in the 1920s and the most recent in the 1970s. The 1999 Storm Drain System Master Plan identified 18 percent of the City’s drainage links as insufficient to convey the runoff for the 10-year or 25-year storm. However, approximately 72 percent of the deficient links require a 1-foot diameter or less upgrade to the existing pipe size.

The 2020 Integrated Water Resources Master Plan (IWRMP) included the evaluation of the storm drain system which includes capacity and system integrity. Overall, the City’s storm drain system has sufficient capacity and significant flooding areas are not expected due to the Hollyhills Storm Drain improvement project. The Hollyhills project increased the capacity of the regional system that addressed upstream flooding conditions. The Los Angeles County Department of Public Works and Flood Control System were the project leads of this regional project.

To verify the City’s storm drain pipe conditions, the IWRMP is recommending a 5-year storm drain inspection program that would investigate the integrity of the system and assess potential capacity issues. Results of the CCTV assessments will provide a list of future projects for replacement or rehabilitation.

Street System
The City is located along the densely developed Wilshire Corridor and is regionally situated in the middle of a variety of regional traffic generators that include Westwood, the University of California, Los Angeles (UCLA), Century City, Los Angeles International Airport (LAX), Culver City to the west, and West Hollywood, the Wilshire Miracle Mile, and downtown Los Angeles to the east. There are only two major facilities that provide regional transportation service for through traffic to bypass the City: the I-405 freeway in the north-south direction and the I-10 freeway in the east-west direction. This results in many of the roadways in the City being used by through traffic to get to and from the various activity centers in the area.

The City promotes walking as a viable means of transportation. Recently, upgrades in urban design and pedestrian amenities have been completed in the Business Triangle, including mid-block signalized crosswalks and widened sidewalks. In addition, several more enhanced pedestrian crossings are in the design phase for use throughout the City. The City's DocuSign Envelope ID: E0A8EBFF-E849-4C07-9990-720DA9F26FEB City of Beverly Hills General Plan
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Complete Streets Plan (discussed below) includes a crosswalk policy for non-controlled intersections so that all future crosswalks are of the highest quality possible to improve pedestrian safety and visibility. The Business Triangle also features some diagonal pedestrian intersection crossings (with an exclusive pedestrian crossing phase) and an ordinance limiting ground floor street frontage of businesses not considered to be pedestrianfriendly. The City’s pedestrian facilities include sidewalks, crosswalks, stairs, pedestrian promenades, and paths in the City’s parks.

Four separate transit agencies provide bus service in the City. The Los Angeles County Metropolitan Transportation Authority (Metro or MTA) operates the majority of the fixed-route bus transit service. The City of Santa Monica Big Blue Bus (SM), the Antelope Valley Transit Authority (AV), and the Los Angeles Department of Transportation (LADOT) also provide limited transit routes within and through the City. Metro has also planned two underground rail stations in the City that will extend the Purple Line subway route through Beverly Hills. The stations are currently under construction in two sections: The first section of the Purple Line Extension will extend the subway from the Wilshire/ Western station in Los Angeles to Wilshire/La Cienega in Beverly Hills. Section 2 extends from the Wilshire/ La Cienega station to the Wilshire/ Rodeo station in Beverly Hills and then on to the Century City / Constellation station.

In 2021, the City Council adopted a Complete Streets Plan, which aims to consider access to the public right-of-way for all road users of all ages and abilities. The plan works to accommodate those who are walking or biking, as well as those using public transit and vehicles. As part of the plan’s development, the City comprehensively evaluated and updated existing policies and programs to relieve traffic congestion, including policies to encourage non-driving modes.

As outlined in the Complete Streets Plan, the City has started to implement its holistic bikeway network. Currently there are bike lanes on Burton Way east of Rexford Drive, on Santa Monica Boulevard from west to east City limits, and on Crescent Drive north of Santa Monica Boulevard. There are also bike routes with shared lane markings on South Santa Monica Boulevard between Moreno Drive and Roxbury Drive, and Crescent Drive between Santa Monica Boulevard and Wilshire Boulevard. The City continues to expand end-of-trip facilities through short-term and long-term bike parking at key destinations.
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