Cudahy City Council
February 15, 2022

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning Existing Use
Max.

Density
(du/acre
)
Realistic
Capacity
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidation
Potential
Environmental
or
Infrastructure
Constraints
Unaccommodated 2008-2013 RHNA Sites
622400301
6 0.94
High Density
Residential
High
Density
Residential
4 Dwelling
Units 40 23
Very
Low/Low Yes No
622400401
5 0.70
High Density
Residential
High
Density
Residential
5 Dwelling
Units 40 17
Very
Low/Low Yes No
622400602
8 0.68
High Density
Residential
High
Density
Residential
4 Dwelling
Units 40 16
Very
Low/Low Yes No
622401701
7 0.94
High Density
Residential
High
Density
Residential
5 Dwelling
Units 40 23
Very
Low/Low Yes No
622501901
0 0.78
High Density
Residential
High
Density
Residential
5 Dwelling
Units 40 19
Very
Low/Low Yes No
622600900
4 0.93
High Density
Residential
High
Density
Residential
7 Dwelling
Units 40 22
Very
Low/Low Yes No
622600900
9 0.73
High Density
Residential
High
Density
Residential
5 Dwelling
Units 40 18
Very
Low/Low Yes No
622601001
5 0.74
High Density
Residential
High
Density
Residential 1 SFR 40 18
Very
Low/Low Yes No
622601401
5 0.81
High Density
Residential
High
Density
Residential
5 Dwelling
Units 40 20
Very
Low/Low No
622601403
0 0.65
High Density
Residential
High
Density
Residential 1 SFR 40 16
Very
Low/Low No
622601403
1 0.91
High Density
Residential
High
Density
Residential 1 SFR 40 22
Very
Low/Low No

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning Existing Use
Max.

Density
(du/acre
)
Realistic
Capacity
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidation
Potential
Environmental
or
Infrastructure
Constraints
622602001
5 0.93
High Density
Residential
High
Density
Residential 1 SFR 40 22
Very
Low/Low Yes No
622602100
6 0.75
High Density
Residential
High
Density
Residential
6 Dwelling
Units 40 18
Very
Low/Low Yes No
2014-2021 RHNA Sites
622400301
2 0.58
High Density
Residential
High
Density
Residential
2 Dwelling
Units 40 14
Very
Low/Low Yes No
622400400
9 0.94
High Density
Residential
High
Density
Residential
11 Dwelling
Units 40 23
Very
Low/Low Yes No
622400402
5 0.23
High Density
Residential
High
Density
Residential Vacant 40 6
Very
Low/Low Yes No
622401000
1 0.94
High Density
Residential
High
Density
Residential
11 Dwelling
Units 40 23
Very
Low/Low Yes No
622401701
0 0.23
High Density
Residential
High
Density
Residential Vacant 40 6
Very
Low/Low Yes No
622401805
4 1.22
High Density
Residential
High
Density
Residential
14 Dwelling
Units 40 29
Very
Low/Low Yes No
622501902
1 0.90
High Density
Residential
High
Density
Residential
10 Dwelling
Units 40 22
Very
Low/Low Yes No
622502805
4 0.93
High Density
Residential
High
Density
Residential
10 Dwelling
Units 40 22
Very
Low/Low Yes No
622600802
3 0.22
High Density
Residential
High
Density
Residential Vacant 40 5
Very
Low/Low Yes No
622601490
0 0.47
High Density
Residential
High
Density
Residential Vacant 40 11
Very
Low/Low No

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning Existing Use
Max.

Density
(du/acre
)
Realistic
Capacity
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidation
Potential
Environmental
or
Infrastructure
Constraints
622601490
1 0.46
High Density
Residential
High
Density
Residential Vacant 40 11
Very
Low/Low No
622602003
9 0.92
High Density
Residential
High
Density
Residential
10 Dwelling
Units 40 22
Very
Low/Low Yes No
622602101
2 0.93
High Density
Residential
High
Density
Residential
10 Dwelling
Units 40 22
Very
Low/Low Yes No
622602402
0 0.93
High Density
Residential
High
Density
Residential
10 Dwelling
Units 40 22
Very
Low/Low Yes No
622602500
6 0.52
High Density
Residential
High
Density
Residential
3 Dwelling
Units 40 13
Very
Low/Low Yes No
622603103
0 0.83
High Density
Residential
High
Density
Residential Vacant 40 20
Very
Low/Low Yes No
622400700
2 0.94
Med Density
Residential
Med
Density
Residential
7 Dwelling
Units 25 14
Very
Low/Low Yes No
622400700
9 0.59
Med Density
Residential
Med
Density
Residential
Commercial
Industrial Use 25 9
Very
Low/Low Yes No
622400780
0 0.78
Med Density
Residential
Med
Density
Residential
Commercial
Industrial Use 25 12
Very
Low/Low Yes No
622400780
1 0.93
Med Density
Residential
Med
Density
Residential
Commercial
Industrial Use 25 14
Very
Low/Low Yes No
622401390
2 0.10
Med Density
Residential
Med
Density
Residential Vacant 25 2
Very
Low/Low No
622600690
1 0.07
Med Density
Residential
Med
Density
Residential Vacant 25 1
Very
Low/Low No

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning Existing Use
Max.

Density
(du/acre
)
Realistic
Capacity
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidation
Potential
Environmental
or
Infrastructure
Constraints
622600700
3 0.18
Med Density
Residential
Med
Density
Residential Vacant 25 3
Very
Low/Low Yes No
622601701
0 0.93
Med Density
Residential
Med
Density
Residential
5 Dwelling
Units 25 14
Very
Low/Low Yes No
622601702
9 0.14
Med Density
Residential
Med
Density
Residential Vacant 25 2
Very
Low/Low Yes No
622601802
5 0.18
Med Density
Residential
Med
Density
Residential Vacant 25 3
Very
Low/Low Yes No
622602700
8 0.90
Med Density
Residential
Med
Density
Residential
5 Dwelling
Units 25 13
Very
Low/Low Yes No
622602700
9 0.80
Med Density
Residential
Med
Density
Residential
4 Dwelling
Units 25 12
Very
Low/Low Yes No
622602701
0 0.79
Med Density
Residential
Med
Density
Residential
2 Dwelling
Units 25 12
Very
Low/Low Yes No
622602701
1 0.78
Med Density
Residential
Med
Density
Residential
4 Dwelling
Units 25 12
Very
Low/Low Yes No
622602900
6 0.94
Med Density
Residential
Med
Density
Residential
5 Dwelling
Units 25 14
Very
Low/Low Yes No
622501800
9 0.08
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30
du/ac
(Res) 1
Very
Low/Low Yes No
622501801
0 0.26
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30
du/ac
(Res) 4
Very
Low/Low Yes No
622501801
1 0.39
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30 7
Very
Low/Low Yes No

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning Existing Use
Max.

Density
(du/acre
)
Realistic
Capacity
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidation
Potential
Environmental
or
Infrastructure
Constraints
du/ac
(Res)
622602290
0 0.03
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30
du/ac
(Res) 1
Very
Low/Low Yes No
622602290
1 0.20
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30
du/ac
(Res) 3
Very
Low/Low Yes No
622602290
2 0.17
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30
du/ac
(Res) 3
Very
Low/Low Yes No
622602290
3 0.19
Mixed Use/
Commercial
Mixed Use/
Commercia
l Vacant
40 du/ac
(MU)/30
du/ac
(Res) 3
Very
Low/Low Yes No
622401500
2 0.47
Single Family
Residential
Single
Family
Residential Vacant 15 4
Above
Moderate No
622403280
0 0.22
Single Family
Residential
Single
Family
Residential Vacant 15 2
Above
Moderate Yes No
622501002
5 0.22
Single Family
Residential
Single
Family
Residential Vacant 15 2
Above
Moderate No
622501100
6 0.22
Single Family
Residential
Single
Family
Residential Vacant 15 2
Above
Moderate No
622502501
4 0.13
Single Family
Residential
Single
Family
Residential Vacant 15 1
Above
Moderate No
622502600
2 0.44
Single Family
Residential
Single
Family
Residential Vacant 15 4
Above
Moderate Yes No

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning Existing Use
Max.

Density
(du/acre
)
Realistic
Capacity
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidation
Potential
Environmental
or
Infrastructure
Constraints
622502600
3 0.44
Single Family
Residential
Single
Family
Residential Vacant 15 4
Above
Moderate Yes No
622502600
9 0.08
Single Family
Residential
Single
Family
Residential Vacant 15 1
Above
Moderate Yes No
622502601
0 0.10
Single Family
Residential
Single
Family
Residential Vacant 15 1
Above
Moderate Yes No
622502601
3 0.54
Single Family
Residential
Single
Family
Residential
Commercial
Industrial Use 15 5
Above
Moderate Yes No
Notes:

Realistic Capacity: A realistic density calculation of 60 percent of the maximum density has been applied to the residential and mixed-use sites consistent with the realistic development scenario in the General Plan Land Use Element.

Mixed Use: Capacity calculations for Mixed Use – Commercial sites assumes 40% of site development with mixed uses (commercial and residential) and 40% of site development with exclusively residential uses all at 60 percent of the maximum density consistent with the realistic development scenario in the General Plan Land Use Element.

November 2020

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Figure 4-1 Sites Inventory Map

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

Unaccommodated RHNA Sites Summary
The 2013-2021 rollover RHNA sites inventory included in this Housing Element identifies capacity for 254 units, thus exceeding the required rollover of 154 units, and all sites are suitable for development of lower-income housing and comply with the unaccommodated RHNA requirements set forth in Government Code 65583.2(h). The 2013-2021 sites inventory is made up of 13 sites zoned for high-density residential development up to 40 units per acre. The sites range from approximately two-thirds of an acre to just under one acre in size. Total realistic capacity on these sites is 254 units, with individual site capacity ranging from 16 to 23 units. All sites have a realistic capacity of at least three times the existing use. Several sites are developed with one residential unit and provide the opportunity for at least a 16-fold increase in capacity.

If developed at the maximum density, these unaccommodated RHNA sites can provide significantly more housing units. There are no identified constraints on these sites that would prevent development or reuse during this Housing Element period.

RHNA (6th Cycle, 2021-2029)
The housing sites inventory for the current (2021-2029) RHNA consists of a mix of vacant and underutilized land, as detailed in Table 4.2 and Figure 4.1, and summarized in Table 4.3.

Table 4.3: 2014-2021 RHNA Sites Capacity (Units)
Site Affordability Level
Site Type Extremely
and Very
LowIncome (0-
50% AMI)
LowIncome
(51-80%
AMI)
ModerateIncome
(81- 120%
AMI)
Above
ModerateIncome
(121%+
AMI)
Total
Vacant 92 -- -- 21 113
Underutilized 338 -- -- 5 343
Total 430 -- -- 26 456
The inventory of vacant residential and mixed-use land in Cudahy totals 6.8 acres. Most vacant sites identified in the inventory allow densities above 20 units per acre and are credited towards the lower-income RHNA. These vacant properties, identified in Table 4.2, have the potential to yield 113 units, 92 of which can facilitate lower-income housing, as defined by state law.

The inventory of underutilized residential land in Cudahy totals 17.7 acres. Most underutilized sites identified in the inventory allow densities above 20 units per acre and are credited towards the lower-income RHNA. These properties, identified in Table 4.3, have the potential to yield 343 units, 338 of which can facilitate lower-income housing, as defined by state law. As stated previously, all underutilized sites in the inventory have a minimum size of one-half acre and are located adjacent to other underutilized or vacant sites to accommodate lot consolidation. All the

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

identified underutilized sites included in this inventory also have a realistic capacity of more than double the currently developed uses.

ADEQUACY OF SITES TO MEET THE RHNA
The sites inventory for both RHNA planning periods indicates a capacity for 710 units, 684 (96 percent) of which occur on sites suitable for development of lower-income housing. Overall, Cudahy can adequately accommodate and exceed the previous (2008-2013) and current (2013- 2023) RHNA. Table 4-4 summarizes the RHNA status.

Table 4.4: Comparison of Sites Inventory and RHNA
Affordability Level (Based on Density)
Extremely
and Very
LowIncome (0-
50% AMI)
LowIncome
(51-80%
AMI)
ModerateIncome
(81- 120%
AMI)
Above
ModerateIncome
(121%+
AMI)
Total
Previous (2008-2013) RHNA Sites (units)
Vacant Sites - - -
Underutilized Sites 254 - 254
Total Sites 254 - 254
RHNA 154 - 154
Redistributed Surplus/Shortfall of
Units (+/-)
+100 - +100
Previous (2014-2021) RHNA Sites (units)
Vacant Sites 92 - - 21 113
Underutilized Sites 338 - - 5 343
Total Sites 430 - - 26 456
RHNA 80 46 51 141 318
Redistributed Surplus/Shortfall of
Units (+/-)
+138 +138
Current (2021-2019) RHNA Sites (units)
Vacant Sites 92
Underutilized Sites 338
Total Sites 430
RHNA 80 36 53 224 393
Redistributed Surplus/Shortfall of
Units (+/-)
+119 +119

4.2 ENVIRONMENTAL AND INFRASTRUCTURE CONSTRAINTS
Environmental factors, such as topography, soils, landslides and seismic hazards, and noise, as well as the lack of infrastructure, such as roads, water, and sewer lines, are constraints to housing development in the city. However, most of the potential housing sites identified by the city are not constrained by environmental factors or by lack of adequate infrastructure, with the exceptions of earthquake, ground shaking which affects the entire region and poor water

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

infrastructure provided by Tract 180 Water Company. The General Plan has taken these environmental factors into account. Where development is planned, any site that remains can be mitigated through appropriate design and environmental planning.

ENVIRONMENTAL SETTING
The City of Cudahy is a relatively new city having only incorporated in the 1960s. At the time of incorporation, more than 80% of the city’s total land area was developed. In terms of land area, Cudahy is one of the smallest cities in Los Angeles County with only 1.07 square miles. Despite its relatively small land area, Cudahy is home to 23,805 residents according to the most recent DOF estimates. The City’s relatively large population given its small geographic area makes it one of the most densely populated communities in California.

A great majority of the city consists of residential land uses with residential neighborhoods accounting for approximately 394-acres of land or 51.5% of the total land area of Cudahy. An industrial area is in the southernmost portion of the city on both the west and east sides of Atlantic Avenue. Industrial land uses account for approximately 79-acres of land or 12.3% of the City’s total land area. Commercial land uses are located along the major roadways such as Atlantic Avenue and at key intersections and account for approximately 43-acres of land or 6.7% of the total City’s total land area.

NOISE
Cudahy is in an area where the ambient noise levels are relatively high. A citywide noise inventory performed in May 2013, found that virtually all the neighborhoods in Cudahy are in areas where noise levels exceed 65 dBA. The city’s noise environment is not expected to significantly change over time since the primary factors contributing to noise, namely the arterial roadway and freeway traffic and nearby industrial uses, will have a continued presence in the city. State noise guidelines recommend locating residential development in areas exposed to ambient outdoor noise levels no greater than 65 A-weighted decibels (dBA).

GEOLOGIC AND SEISMIC HAZARDS
No known earthquake faults traverse Cudahy and the City is not exposed to natural environmental hazards such as flooding, slope erosion and landslides. However, the city is located within an area that is subject to liquefaction hazards. The city is located within the dam inundation area of the Garvey Reservoir in Monterey Park.

The nearest major river is the Los Angeles River. This River does have a potential impact on the City of Cudahy. Normally this river channel is dry and only carries a significant water flow during a major rainstorm. The river channel is part of the County Flood Control District, and the City is

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

protected by a levee wall.

City of Cudahy, like most of the Los Angeles Basin, lie over the area of one or more known earthquake faults, and potentially many more unknown faults, particularly so-called lateral or blind thrust faults.

The major faults that have the potential to affect the greater Los Angeles Basin, and therefore the City of Cudahy are the:

Norwalk
Raymond Hill
Malibu Coast-Santa Monica-Hollywood
San Andreas
Newport-Inglewood
San Fernando
Sierra Madre
Whittier
The Los Angeles Basin has a history of powerful and relatively frequent earthquakes, dating back to the powerful 8.0+ 1857 San Andreas Earthquake which did substantial damage to the relatively few buildings that existed at the time. Paleoseismological research indicates that large (8.0+) earthquakes occur on the San Andreas fault at intervals between 45 and 332 years with an average interval of 140 years. Other lesser faults have also caused very damaging earthquakes since 1857. Notable earthquakes include the 1933 Long Beach Earthquake, the 1971 San Fernando Earthquake, the 1987 Whittier Earthquake, and the 1994 Northridge Earthquake. In addition, many areas in the Los Angeles Basin have sandy soils that are subject to liquefaction, including in the City of Cudahy.

ROADS
The transportation system in Cudahy consists of a roadway network dominated by Atlantic Avenue, collector streets, and local streets. The Long Beach Freeway (State Route-710) is located just east of Cudahy. Also, the City's central location in Los Angeles County provides Cudahy with easy access to most parts of the Southern California region. Local circulation within the city generally follows a grid pattern; except for Atlantic Avenue which extends in a north-south orientation at a slight angle and Salt Lake Avenue which follows the curve of the railroad tracks.

Atlantic Avenue is a regional highway that extends north to Alhambra and south to Long Beach.

Traffic volumes on most City streets are currently approaching or are at capacity.

Regional access to the city is provided by the Long Beach Freeway (I-710) that extends along the City's eastern border. Access to this freeway is provided by Florence Avenue (north of Cudahy) and Firestone Boulevard (south of Cudahy), both being major arterials located just outside the city. Florence Avenue is a major roadway that provides a connection to the Long Beach Freeway for the neighboring communities of Downey, Bell, and Bell Gardens. With local freeway access

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

largely dependent on Florence Avenue, the traffic on this roadway during peak hours is congested. Local access to Florence Avenue is provided by Wilcox Avenue and Atlantic Avenue and access to Firestone Boulevard is provided by Atlantic Avenue. The transportation system framework within Cudahy is largely defined by Atlantic Avenue which is a major north/south arterial that extends through the city. Other north/south roadways include Salt Lake Avenue, Wilcox Avenue, and Otis Avenue which also provide access to neighboring cities. Clara Street and Santa Ana Street are two primary east/west roadways. Aside from Atlantic Avenue and Santa Ana Street (west of Atlantic Avenue), all the streets in the city consist of two travel lanes.

All the potential housing sites identified are infill sites located in existing built-out areas of the city, and all have adequate road accesses (ingress and egress).

ASSESSMENT OF SEWER AND WATER
The City of Cudahy is served by three water agencies, including Tract 349 Mutual Water Company, Tract 180 Mutual Water Company, and Golden State Water Company. Tract 349 Mutual Water Company serves the west side of Atlantic; Tract 180 Mutual Water Company serves the east side of Atlantic, and Golden State Water Company serves the southeast portion of the city. Water for all three water companies comes from a series of groundwater wells throughout the Central Basin.

Tract 349 Mutual Water Company currently has plans to replace one of the existing groundwater wells. Although the location of the new well has not yet been determined, it will be located at one of the two existing well locations
Tract 180 Mutual Water Company has identified deficiencies within the water system along Clara Street, Elizabeth Street, Cecelia Street Park Avenue, and Atlantic Avenue, and along the east side of Live Oak Avenue. Proposed improvements include upsizing water lines throughout the service area. The water lines on Atlantic Avenue that range in size from 10” to 14” will be replaced with lines ranging in size from 10” to 12”. Tract 180 is currently addressing the deficiencies in the water system along Clara Street. Phase Two of the Clara Street Pipe Replacement Project is under construction. In addition, the Elizabeth Street Pipe Replacement Project is currently in the process of securing funds for the project.

Golden State Water Company (Golden State Water) provides water services to the east portion of the city east of Wilcox Avenue. Currently, no deficiencies exist within Golden State Water’s jurisdiction. Increases in land use density from new developments/redevelopments will require fire flow tests as mandated by the LA Fire Department. Golden State Water has since implemented the Unidirectional Flushing (UDF) program to mitigate iron and manganese levels within the water supply.

Water use would be expected to rise with the anticipated increase in population under the General Plan Update. However, the expansion in conservation practices such as low water use gardening and use of recycled water would likely dampen demand somewhat. Also, the increase in mixed-use and multi-family housing units typically results in lower household water use as

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

lawn and garden irrigation practices are less necessary than in single family homes. Low water use practices are common in the Southern California region and are consistent with the General Plan Update policies.

The sewer system is managed by the City’s Public Works Department. The local sewage is discharged into a larger system (County of Los Angeles Consolidated Sewer District) managed by the Los Angeles County Sanitation District (LACSD) which provides both primary and secondary treatment of all City of Cudahy sewage flows while Los Angeles County Department of Public Works (County DPW) maintains all city-owned collection systems. The field operation and maintenance services are fulfilled by utilizing the services provided by the Consolidated Sewer Maintenance District (CSMD) managed by the County DPW. Approximately 14.2 miles of sanitary sewer collection facilities serve customers in the city. The city is responsible for ensuring that the public sewer infrastructure is correctly designed, adequately sized, and easily maintainable. The CSMD also provides a supporting role in reviewing all proposed sewer plans for new developments in the city to ensure that they conform to County design standards and particularly to ensure that district’s requirements for acceptability for maintenance. Results from the inspection of 74,557 feet of the City’s sewer system determined that 88 percent of the system is free from structural defects. The remaining 12 percent of the pipe segments were placed on a priority list based on the severity and the need for action. Since the 2013 SCAR, all segments on the priority list have been repaired as of April 2016.

The anticipated population increase in Cudahy (because of General Plan land use policies) would likely increase the amount of wastewater delivered to the treatment facility. Given a projected Year 2040 population of 30,607, this would result in a generation of 2.26 million gallons per day (mgd) of wastewater (an increase of about 0.5 million gallons per day (gpd). This increase represents less than one percent of the remaining capacity at the Joint Water Pollution Control Plant in Carson.

Water Sewer Priority
In accordance with Government Code Section 65589.7, immediately following City Council adoption, the City must deliver to all public agencies or private entities that provide water or sewer services to properties within the City of Cudahy a copy of the 2021-2029 Housing Element.

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

5 Resources and Constraints
The availability of financing resources from federal, State, and local sources, as well as private lenders and non-profit organizations, is essential to the construction and rehabilitation of housing. The success of housing projects is also affected by governmental constraints (such as land use controls and development fees) and non-governmental constraints (such as housing market situation and environmental constraints). These factors will be discussed in this chapter.

Housing Constraints indicates those environmental factors, governmental factors, and market factors that could impede the development of new housing.

5.1 FINANCING AND SUBSIDY SOURCES
Federal, State, and local agencies provide a wide range of resources to help support the construction, acquisition, and rehabilitation of housing units for lower-income households in Cudahy. Many of these resources are made available to local tenants, owners, and developers of affordable housing through City and County programs and services. Although there is a wide range of programs, the availability of funding through these programs is typically inadequate to satisfy all needs. As a result, there is a fair amount of competition for program funds that are available, and any one development may need to draw upon multiple resources to be financially feasible.

FEDERAL RESOURCES
The federal government offers a wide variety of resource related housing assistance. The mortgage interest deduction and the real estate tax deduction are just two of the most common choices for homeowners provided through the income tax code. The deductions promote homeownership and reduce tax liabilities for home-owning taxpayers. Moreover, the deductions are used widely and expansively across the nation. Among the states, California has the highest amount of mortgage interest and real estate tax deducted every year.

Aside from tax of mortgage deductions, the federal government provided housing assistance to California jurisdictions through several programs. Like State programs, federal programs often change in terms of program details, application procedures, and amount of subsidy dollars available. For detailed descriptions, current subsidy levels, and up-to-date application procedures, refer to program literature available online from HUD at http://www.hud.gov.

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

Some of the largest programs, based on current funding levels include:

COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG)
The Community Development Block Grant (CDBG), a longstanding program of HUD funds local community development activities such as affordable housing, anti-poverty programs, and infrastructure development. Cities with populations over 50,000 receive CDBG funds directly from HUD while smaller cities apply directly to the County or State for a portion of the funding that is allocated and administered by those entities. HUD makes allocations based on a formula that takes population, poverty, and housing distress into account. CDBG funds can be used for a variety of housing efforts including activities aimed at reducing costs for private development (helping fund site acquisition, improvements, and other soft cost); housing acquisition and rehabilitation through short and long-term loans, grants, or loan guarantees; direct payment of rent or mortgage and housing counseling services; activities relating to energy conservation and renewable energy resources; and fair housing activities. CDBG funds are best used in combination with other subsidy sources or to provide predevelopment funding to initiate housing development.

The City shall continue housing programs on housing development, infrastructure, rehabilitation, and job development, as allowed by the CDBG program. The city currently uses its CDBG moneys for the Home Improvement program, Business assistance program, fair housing foundation services, code enforcement, senior nutrition program, food distribution programs and the development of public facilities. It shall coordinate with the County Housing Authority in implementing programs outlined in the Comprehensive Housing Affordability Strategy (CHAS) for Los Angeles County. The City shall prepare a brochure outlining available housing assistance and rehabilitation programs in the City. The city is not applying for other federal programs, although it has evaluated potential participation in the HOME, HOPE, and other housing loan programs of HUD. It shall distribute these to property owners and make them available at City Hall. The brochure shall encourage residents to participate in the Section 8 housing assistance payments program and the housing voucher program through the Los Angeles County Housing Authority.

The program is ongoing under the Community Development Department and is financed by the General Fund.

5.2 GOVERNMENT CONSTRAINTS ON HOUSING PRODUCTION
It is in the public interest for the government to regulate land use and building standards to protect the general welfare of the community. On the other hand, stringent regulations, processing fees and lengthy procedures can potentially deter private enterprises from developing housing. The City of Cudahy regulates the use of land within the city limits through General Plan, the Zoning Ordinance, and building codes and standards.

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GOVERNMENTAL CONSTRAINTS
Public constraints, such as land use and development controls, site improvement fees, and development permits, affect the supply, distribution, and cost of housing. Although often unpopular, these controls are necessary to protect the community's health, safety, and welfare.

Building codes and other development requirements can influence the cost of housing. Key development standards that could add to the cost of housing development and the City’s response include the following:

The City has adopted the 2013 California Building Code as amended by the 2014 Los Angeles County Building Code by reference that establishes minimum construction standards. The City’s existing development requirements included in the Zoning Ordinance and Building Code do not include any architectural standards that would add to the cost of new housing development. In addition, there are no unique open space, parking, or Mello-Roos fee requirements that are applicable to new developments outside of what is standard throughout the region. The only local amendment to the building code adopted by the City is in reference to identifying the Planning Commission as the building Board of Appeals.

Code Enforcement site visits are typically complaint driven. The City of Cudahy also maintains several programs that property owners may take advantage of if their units are found to be substandard. Code Enforcement officers have been very proactive in referring residential property owners to these programs.

All the residential areas where the residential zoning is applicable are well served by streets and other infrastructure. No street dedications or new infrastructure is required for the typical infill development. However, as properties are intensified, the existing water lines are becoming overtaxed, which will eventually require updating and improving water supply throughout the City which will add to the cost of future construction.

The California Energy Resources Conservation and Development Conservation have developed guidelines used by building code enforcement officials to implement energy conservation regulations established by the California Energy Commission. While serving as a mitigation tool to help reduce electricity and natural gas consumption, they do add to the cost of housing. State law also authorizes school districts to collect impact fees for all new residential, commercial, and industrial construction.

The school fees that are charged towards new residential development are State mandated and are beyond the City’s ability to control. The Los Angeles Unified School District (LAUSD) levies a school development fee for residential construction. Building inspection services such as plan checks, and permit issuance are contracted, and the fees charged to the developer for these services are typically less than the actual cost for review time though any increased administrative costs beyond the base fees for discretionary review are waived. The planning fees that are charged in the city do not make any distinction between rental housing and owneroccupied housing or the types of housing (single-family or multiple-family).

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The City of Cudahy has fully implemented the provisions of AB 884. The plan check review for new construction averages two to four weeks, which is considerably less than most surrounding cities. During a development's design and planning, the City staff is available to conduct pertinent reviews and issue permits related to engineering, drainage, grading, public works, electrical, and other aspects of new developments. Even with those infill projects that require some form of discretionary review, the City has taken advantage of recent legislation that calls for smaller infill projects to be categorically exempt through the referral of a Class 32 California Environmental Quality Act (CEQA) Categorical Exemption.

Residential infill projects are handled through the City’s streamlined review and entitlement process. The entire development process from land clearance through construction typically takes between six months to one year to complete, depending on the number of units. This includes the time required for plan check and construction.

CUDAHY GENERAL PLAN LAND USE POLICY
The Land Use Plan of the Cudahy General Plan has been developed to promote new residential development in the city. The Plan has several features which were developed to increase the availability of housing and maintain the existing housing stock. The Land Use Plan, illustrated in Exhibit LU-2 of the Land Use Element, preserves existing neighborhoods developed largely as single-family neighborhoods. The new General Plan increases the allowed density in the multifamily residential areas and intensity of nonresidential districts to encourage revitalization and lot consolidation, create new open spaces to enhance residents’ quality of life, and provide flexibility in land use policy to accommodate emerging land use trends. The General Plan land use categories allow residential development as follows:
• Low-Density Residential: 15 du/ac
• Medium-Density Residential: 25 du/ac
• High-Density Residential: 40 du/ac
• Mixed Use-Commercial: 40 du/ac if mixed use; 30 du/ac residential only • Mixed Use-Civic: 40 du/ac if mixed use; 30 du/ac residential only • Innovation Industrial: 1.5 FAR (allows live/work)
The updated Land Use Element significantly increased development maximums and encourages new housing types. The Land Use Element identifies a realistic buildout and a maximum theoretical buildout. Realistic buildout would assume a total of 7,222 gross dwelling units in the city and a population of 30,607 persons by 2040. The theoretical maximum buildout would allow 12,037 gross dwelling units and a total population of 51,012 persons by 2040.

Past residential development projects in the city have consisted primarily of land recycling, as lots with older single-family detached units are replaced with multi-family housing. This was the reason for the building moratorium in 1990. It is primarily due to the limited amount of vacant

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land in the city at that time (13.2 acres or 1.9 percent) and the economic advantages of multifamily projects on High Density Residential lots. Thus, it is expected that future development will continue this trend.

Most of the City of Cudahy consists of very low-income neighborhoods. According to the 2020 Census data prepared by SCAG, of the City's 5,770 households in 2010, 2,921 households or

52.9% were considered low-income. Of these, 1,029 households were overpaying for housing.

Thus, the other 1,892 low-income households (52.9% of low-income households) were not overpaying for housing. The units occupied by these households may be considered affordable because low-income households occupy them, and their rents are less than 30 percent of the occupying household's income. Census data indicated that for owner-occupied housing units, most of the monthly mortgage payments in the city ranged in 2020 was $2,000 or more with the median being $1,812 per month. A household was overpaying for housing if more than 30% of their net “take-home” income was used for paying rent or mortgages. According to census figures for the year 2020, 255 households (45.2% of the total owner-occupied units) living in owner-occupied units paid more than 30% of their monthly income towards the mortgage.

According to the same census figures, 2,624 renter households (56.3% of the total renter households) paid more than 30% of their monthly income towards the rent.

While it cannot be identified where these affordable housing units are located, the city may conclude that they include developments with 10 units per acre, as well as those with 14 units per acre (as allowed under the current zoning code). The current housing market and availability will continue to drive housing prices up within the city. However, new housing development is expected to meet some of the demand for affordable housing created by low-income households in the area, as a function of economic and market forces. These projects can be developed with densities of 10 to 14 dwelling units per acre, as found in the city; however, increasing the existing allowable density in the MDR Zone to 25 and HDR Zone to 40 dwelling units per acre will further facilitate meeting the demand for affordable housing. These increases will provide an additional 860 new housing units: going from the current 5,770 to a potential 6,630 housing units.

Additionally, increasing allowable density with a maximum of 35% density bonus; will encourage the redevelopment of existing properties at a higher density, resulting in additional housing stock.

Also, the application of a density bonus for low-income and senior residents housing projects and projects that provide or include early care and education or services for the needy or elderly, will increase the maximum allowable density to 20 dwelling units per acre in the HDR Zone, this can be done without taxing existing infrastructure.

Further increases in density beyond those allowed by the General Plan’s realistic buildout assumption will lead to demands on infrastructure and services which cannot be met by existing facilities (sewer, roads, water, storm drain, police, fire, etc.). This will be especially significant on traffic and local circulation, schools of the LAUSD, and police services. Future policies and goals should consider updating facilities including sewer, roads, water, storm drains, etc.

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DEVELOPMENT CODE REQUIREMENTS
The City of Cudahy Development Code includes development standards and requirements for existing and potential development within the Low Density Residential, Medium Density Residential and High-Density Residential zone districts, as well as three mixed-use districts (Civic Mixed Use, Commercial Mixed Use and Entertainment) and the Innovation Industrial district, which allows live/work units. The development standards do not appear to represent a constraint to development given the amount of rehabilitation that has occurred in recent years.

The minimum lot size and setback requirements are very liberal. For example, most communities in the area require between 5 to 10 feet for the side and rear yard setbacks.

Table 5.1 Development Standards
Zone
Dev.

Standard
Commercial/
Mixed Use
Civic/
Mixed Use
Innovation
Industrial
High Density
Residential
Medium
Density
Residential
Low Density
Residential
Density 30-40 du/ac 30-40 du/ac 30 du/ac 20-40 du/ac 25 du/ac 15 du/ac Yards Front: variable
Side and Rear: 10’
when adjoining Res.

Front: variable
Side and Rear: 10’
when adjoining Res.

Front: 10’
Side: none. 10’ on
corner lots
Rear: 10-30’ when
adjoining Res.

Front: variable
Side: 5’ (+2’ for
each
additional
story)
Rear: 10’
Front: variable
Side: 5’
Rear: 5’ (+2’
for each
additional
story)
Front: variable
Side: 5’
Rear: 10’
Lot
Coverage/
Open Space
50% 50% 60% Private: 150
sq. ft. /unit
Common: 280
sq. ft. /unit
Private: 150
sq. ft. /unit
Common: 280
sq. ft. /unit
250 sq. ft./unit or
25% of the lot
area/unit (exclusive
of the front yard
setback)
Building
Height
4 stories 4 stories 2-3 stories 4 stories 3 stories 2 stories or 35’ (whichever is less)
Distance
Between
Buildings
N/A N/A N/A 10 ft 10 ft 10 ft; 5 ft between
acc structure
Parking Single-family Detached, Duplex, Condominium and Townhouse: 2 garage spaces/dwelling unit, plus 1 additional garage or surface space where dwelling unit contains 5 or more bedrooms
Apartments: 2 spaces/dwelling unit, at least one space in a garage Efficiency Apartments and Senior Housing: 1 space/dwelling unit For all but single-family dwellings, Guest Parking shall be provided at .75 space/dwelling unit.

Fences,
Hedges, &
Walls
Front: 42” solid materials; 48” wrought iron
Side/Rear: 96”
Minimum
Living Area
1 bedroom: 700 sq.
ft.
2 bedrooms: 900
sq. ft.
3 bedrooms: 1,100
sq. ft.
4+ bedroom: 1,100
sq. ft. plus 150sq. ft.
for each additional
1 bedroom: 700 sq. ft.
2 bedrooms: 900 sq. ft.
3 bedrooms: 1,100 sq.
ft.
4+ bedroom: 1,100 sq.
ft. plus 150 sq. ft. for
each additional
1 bedroom: 700 sq.
ft.
2 bedrooms: 900 sq.
ft.
3 bedrooms: 1,100
sq. ft.
4+ bedroom: 1,100
sq. ft. plus 150 sq. ft.
for each additional
1 bedroom:
700 sq. ft.
2 bedrooms:
900 sq. ft.
3 bedrooms:
1,100 sq. ft.
4+ bedroom:
1,100 sq. ft.
plus 150 sq. ft.
for each
additional
1 bedroom:
700 sq. ft.
2 bedrooms:
900 sq. ft.
3 bedrooms:
1,100 sq. ft.
4+ bedroom:
1,100 sq. ft.
plus 150 sq. ft.
for each
additional
1,100 sq. ft.

Source: Cudahy’s Development Standards per Municipal Code Table 5.1 above indicates basic residential development standards for Cudahy; the table shows density, yard requirements (front, side, and rear), lot coverage, open space, building heights, distances between buildings (main and accessory buildings), parking, fences, hedges, walls, and

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minimum living area. Cudahy has three residentially based zone districts; Low-Density Residential, Medium-Density Residential; and High-Density Residential. The Development Code also allows stand-alone residential and mixed-use in the Commercial/Mixed Use, Civic/Mixed Use , and the Entertainment zone districts , as well as live/work units in the Innovation Industrial zone district.

PROCESSING AND PERMIT PROCEDURES
The Development Code stipulates the residential types permitted, conditionally permitted, development review permit, or prohibited in each zone allowing residential uses. Permitted Uses are those uses allowed without discretionary review, in designated areas, if the project complies with all development standards. Conditional Use Permits (CUP) are approved by the Planning Commission unless appealed to the City Council. Findings to approve a CUP include:

A. Consistency. The use shall be consistent with the general plan and consistent with the integrity and character of the zone in which it is to be located.

B. Site suitability. The site for a proposed conditional use is adequate in size and shape to accommodate the yards, walls and fences, parking and loading, landscaping, and other development standards prescribed in this zoning code, or required by the Planning Commission, City Council, or other authorized agent in order to integrate the conditional use with the land and uses in the neighborhood.

C. Neighborhood compatibility. The Planning Commission shall consider the nature, condition, and development of adjacent uses, buildings, and structures and the effect the proposed conditional use may have on such adjacent uses, buildings, and structures.

D. Access and circulation. The site for a proposed conditional use should relate to streets and highways adequate in width and pavement to carry the kind and quantity of traffic such use would generate. Adequate provisions for public access are available to serve the use.

E. Utilities and services. Adequate provisions for water, sewer, and public utilities and services are available to ensure that the use will not be detrimental to public health and safety.

F. Safety and welfare. The use will not be detrimental to the public interest, health, safety, convenience, or welfare.

Roughly 50% of the city is zoned for the highest density residential designation, with under 10% low density residential. The remaining commercial is focused on Atlantic Avenue (roughly 6%), with approximately 12% industrial, and the remaining is public/institutions/parks/streets.

Because of such high concentration of higher density zoning, new development under the permitted zoning densities is not found to be inconsistent with the nature, condition and development of adjacent uses, buildings, or structures.

Table 5.2 describes the housing types by permitted uses (*indicates a proposed Program).

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• In the Development Code, any employee housing providing accommodations for six or fewer employees shall be deemed a single-family structure pursuant to California Health & Safety Code Section 17021.5.
• State law also requires local governments to permit manufactured or mobile homes meeting federal safety and construction standards on a permanent foundation in all single-family residential zoning districts (Section 65852.3 of the California Government Code). In Cudahy, a manufactured/factory-built house is a single-family detached dwelling unit and is treated as such.
• Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone.
• The definition of “family” may limit access to housing for persons with disabilities when municipalities narrowly define the word, illegally limiting the development of group homes for persons with disabilities, but not for housing similar sized and situated families.

The City’s Development Code includes the following definition of family: “A group of persons, whether related or unrelated, who live together in a non-transient and interactive manner, including the joint use of common areas of the premises which they occupy and sharing household activities and responsibilities such as meals, chores, and expenses.

Notwithstanding the foregoing, any group of persons required to be considered as a “family” for zoning purposes pursuant to California Health & Safety Code Sections 1267.8, 1566.3, 1568.0831, 1569.85, 11834.23, or any other state law shall be deemed to be a family for purposes of this code.” This definition does not discriminate nor limit access to housing for persons with disabilities.

Table 5.2 Housing Types Permitted by Zoning District
Residential Use ZONE
LDR MDR HDR Civ MU Com MU I-I
1 DU P P P NP NP NP
2-4 DU P P P NP NP NP
5+ DU P P P P P CUP
Residential Care < 6P P P P NP NP NP
Residential Care > 6P NP CUP CUP NP CUP NP
Emergency Shelter NP NP NP P P NP
Single-Room Occupancy P
Manufactured Homes P P P NP NP NP
Mobile-Home Parks NP NP CUP NP NP NP
Transitional Housing P P P P P CUP
Supportive Housing P P P P P CUP
2 nd Unit P P P NP NP NP
P= Permitted; CUP= Conditional Use Permit; NP=Not Permitted Source: City of Cudahy Building & Planning Departments

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Permit Processing
The time required to process a project varies greatly from one project to another and is directly related to the size and complexity of the proposal and the number of actions or approvals needed to complete the process. Table 5.3 identifies the typical processing time most common in the entitlement process. It should be noted that each project does not necessarily have to complete each step in the process (i.e., small scale projects consistent with General Plan and Zoning designations do not generally require Environmental Impact Reports (EIR), General Plan Amendments, Rezones, or Variances). Also, certain review and approval procedures may run concurrently. For example, a ministerial review for a single-family home would be processed concurrently with the design review, typically taking 3-6 months. Similarly, entitlements for multiple family residential projects can be run concurrently, and typically takes 3-6 months to process. The city also encourages the joint processing of related applications for a single project.

As an example, a rezone petition may be reviewed in conjunction with the required site plan, tentative tract map, and any necessary variances. Such procedures save time, money, and effort for both the public and private sector.

Table 5.3 Timeliness for Permit Procedures
Type of Approval or Permit Typical Processing Time
Ministerial Review 2 weeks
Conditional Use Permit 3 months
Zone Change 3 – 6 months
General Plan Amendment 3-6 months
Site Plan Review 2 weeks
Architectural/Design Review 3 months
Tract Maps 3 months
Parcel Maps 3 months
Initial Environmental Study 1 month
Environmental Impact Report 3-6 months
Other
Source: City of Cudahy Building & Planning Departments
Table 5.4 lists the typical approval requirements by project type. After a project has been approved, the Building & Safety department then issues building permits through a plan check submittal/process. Throughout construction, the Building & Safety department will perform building inspections to monitor the progress of the project and ensure compliance with the plans and code.

Table 5.4 Processing Procedures by Project Type
List Typical Approval Requirements Single Family Unit Subdivision Multi-Family

DRP DRP DRP

CUP CUP

PARCEL TRACT
Source: City of Cudahy Building & Planning Departments

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ENTITLEMENT FEES
The City charges fees to process plans submitted for residential projects and to finance the provision of important services needed to accommodate housing and population growth. Fees and exactions are used to finance public facilities, roadways, water and sewer infrastructure, schools, and other community services. Nearly all these fees are assessed through a pro rata share system, based on the magnitude of the project’s impact or the extent of the benefit that will be derived. The fees have not been found to act as a constraint to the development of housing in Cudahy.

Two types of fees are charged and discussed below: planning and development fees and development impact fees. Planning and permitting fees are charged on an at-cost basis to cover staff services and administrative expenses for processing development applications.

Table 5-5: Planning and Development Fee Schedule as of December 14, 1987, Per City Ordinance No. 376 Minor Variance $630.00
CUP/Variance $2,660.00
Zone Change $4,225.00
*Sign Review Permanent/Temporary $135.00
Environmental Review
Negative Declaration & Exemption
County Registrar Document Handling Charge
$10,000 deposit
$75.00
Minor Project Review
Major Project Review
$630.00
$5,000.00 deposit
Subdivision Map Review (S-9)
$4,225.00
Tentative Map Consideration (S-10)
$4,225.00
Development & Appeal Processing
Administrative Appeal
Planning Commission Appeal
City Council Appeal
$630.00
$1,295.00
$1,295.00
Source: City of Cudahy Building & Planning Departments
Development impact fees are required to provide essential services and infrastructure to serve new residents. Development projects in Cudahy are subject to Development Impact Fees.

These include the following:

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ON-/OFF-SITE IMPROVEMENTS
If subdivision level improvements modify right of way street conditions, then the project must follow City standard guidelines such as: standard plans for public works construction, Cudahy’s Green Street Manual, Low Impact Guidelines, etc. All cost varies depending on the scope of work.

However, following the above-mentioned City standard guidelines is more cost effective than traditional Best Managements Practices (BMP).

CONSTRAINTS ON HOUSING FOR PERSONS WITH DISABILITIES
As noted in the Special Needs section of the Housing Needs Assessment Report, persons with disabilities have several housing needs related to accessibility of dwelling units; access to transportation; employment, and commercial services, and alternative living arrangements that include on-site or nearby supportive services.

The City ensures that new housing developments comply with California building standards (Title 24 of the California Code of Regulations) and federal requirements for accessibility.

PROCEDURE FOR ENSURING REASONABLE ACCOMODATIONS
In 2018, as part of the comprehensive update to the Development Code, the City established a formal procedure for individuals with disabilities seeking equal access to housing to request a reasonable accommodation to zoning regulations, as provided by the Federal Fair Housing Amendments Act of 1988 and California's Fair Employment and Housing Act, and to establish criteria to be used when considering these requests. The purpose of the reasonable

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accommodation process is to provide flexibility in the application of land use, zoning or building regulations, policies, or procedures for individuals with disabilities or developers of housing for persons with disabilities when it is necessary to eliminate barriers to equal housing opportunities.

DEVELOPMENT REVIEW PROCESS
Development Fee Review
The city is scheduled to regularly review its permit processing fees annually to ensure that they reflect the costs associated with the review process. The fee review will provide a basis for reducing fees which may be posing a constraint to housing production, and at the same time allow the city to recoup costs associated with individual developments.

Permitted Uses and Discretionary Approvals
Permitted uses are allowed by right in most Zoning Districts, with no action or approval required from the Planning Division. In some districts, a discretionary approval is required for certain permitted uses or occupancies. Discretionary actions are an approval letter with standard conditions, issued by the Planning Department. Conditions typically include applicable provisions of City codes or standards, such as Zoning requirements, building permit or code requirements, business license requirements, or permit requirements of other agencies, such as the Fire district or Water district.

Conditional Use Permits
Conditional Use Permits (CUP) are discretionary approvals subject to a public hearing. The planning department then reviews the application to deem it complete or incomplete; in either case the application will receive a letter with the status of their application stating whether more information is needed (incomplete application) or with a date to appear before Planning Commission (complete application). The CUP process (when complete) usually takes anywhere between 2-3 months. All CUPs are subject to specific findings contained within the City’s Municipal Code which make it easy to understand what the applicant must be able to comply with; this part of the process is not discretionary (findings).

Environmental Review
The city conducts environmental reviews for all development projects, consistent with the requirements of the California Environmental Quality Act (CEQA). CEQA requires an environmental analysis for all projects that are not exempt. Projects with potentially significant impacts typically require preparation of either a Mitigated Negative Declaration with special studies, or an Environmental Impact Report (EIR). Preparation of these reports adds time and costs to the development review process and may require additional expenses if additional measures are required to mitigate potential environmental impacts.

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Some projects are “categorically exempt” from CEQA because they comply with certain thresholds such as limited size or scope or because there is no reasonable possibility that they have the potential to significantly affect the environment. Article 19 of the CEQA Guidelines lists the types of projects that are normally exempt, including replacement or rehabilitation of existing facilities, construction, or conversion of small structures, and minor alterations to existing land.

Certain residential projects providing affordable urban, agriculture, or urban infill housing that meets specified acreage, affordability, and unit criteria are also exempt from CEQA by statutory law. The requirements for environmental review apply statewide and are not particular to Cudahy alone, so they represent little or no constraints to housing development in the city.

Applicable projects funded with CDBG or other sources of federal funding (depending on the administration of the funding source), are also subject to the requirements of the National Environmental Policy Act (NEPA).

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5.3 MARKET CONSTRAINTS ON HOUSING DEVELOPMENT
Market Constraints
Production cost factors such as land acquisition and improvement, construction material and labor, financing, overhead costs, and fees, are market constraints which impact the affordability of housing.

LAND COST / CONSTRUCTION COST
The cost of housing in Cudahy has increased in the last few years as land values, construction costs, and finance charges continue to increase. The diminishing supply of land available for residential construction has driven land and housing costs upward. The city typically has little control over the market fluctuations that affect housing costs. “Land values across the U.S. rose on average 8% in 2021, which is an increase over 2020 rates. This trend will affect the overall cost of developing new housing units in the city and the State in general.

Land, construction, and financing costs represent the most significant nongovernmental constraints in the production of housing for most income groups in Cudahy. Land costs in this City are generally high due to high demand and the limited supply found in a built-out City. Land cost are seldom less than $27,000 per unit (multifamily), and construction cost in the general Los Angeles area may range from $150 to $300 per square foot. A typical multi-family residential building lot in Cudahy sells for over $375,000.

Construction costs include both “hard” and “soft” costs such as labor and materials (hard), and soft costs such as architectural and engineering services, development fees, construction financing, and insurance.

Over the past 16 years, the City of Cudahy has not experienced any vacant land sales.

AVAILABILTIY OF FINANCING
An inventory of local lending institutions revealed that loans are available in the area to qualified clients.

HOUSING CRISIS
Residential vacancy rates and the location of the city within the Los Angeles basin are two market constraints that affect the affordability of housing. As Los Angeles development areas continue to expand, Cudahy and the surrounding cities are becoming an increasingly convenient area in which to live. Housing prices will continue to rise due to this demand. As previously mentioned, just over 1.9% of the housing stock within the Cudahy is vacant. This translates into a demand for housing in the region exceeding the available supply, which inflates both the rental and

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ownership housing prices. If land values, construction costs, and interest rates continue to increase in the long-term, the cost of all new housing will rise accordingly.

As indicated above, the city has no control over the market fluctuations that may affect housing costs because market conditions result from a complex interplay of national economic policies and general economic conditions. Inflation in the cost of goods and especially housing means that many families find themselves unable to afford suitable housing. The lack of sufficient income causes more working people to share the cost of a home. As a result, overcrowding is common, and the housing choice of many households is severely restricted. This situation is further aggravated in periods of high unemployment as experienced in the last two years due to the covid-19 pandemic and the threats of eviction of tenants and foreclosure on mortgaged properties.

Redlining practices have not been observed in Cudahy, as the City's housing market is not characterized by wide disparities in prices. The Long Beach Fair Housing Foundation monitors redlining practices in the Southern California region, including the city and has found that redlining practices do not appear to be a problem.

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6 Evaluation of the Previous Housing Element
The City of Cudahy’s prior Housing Element was adopted and certified by HCD in 2018. In keeping with State law requirements, the Housing Element must include an evaluation of previous program achievements, so there is an understanding of what worked well as well as what was not accomplished and the reasons why.

ASSESSMENT OF GOALS, POLICIES, PROGRAMS AND QUANTIFIED OBJECTIVES Table 6.1: Review and Revise (2021 Housing Element)
2021 Housing Element Program
Program Performance and Continued
Appropriateness
Housing Information Program
The City shall establish a promotional campaign to area developers.

The campaign shall promote the City of Cudahy and existing investment opportunities. The City shall work with local business groups (such as the Chamber of Commerce and Building Industry Association) on promoting available incentives to new development.

The city will work with local early care and education advocates to create an information handout to inform developers, business groups, and households about the available early care and education services.

The program will be managed by the Community Development Director and begin in 2013, promotional materials were developed by December 2014 for distribution, and is being updated on an ongoing basis.

The Housing information campaign was initiated
through the development of an economic
development informational flyer and
presentations by City staff to the Early Childhood
Education Coalition for SPA 7. The city is
continuing to work with local early care and
education advocates to distribute campaign
material.

This program is included in the updated Housing
Element.

Second Unit Ordinance
The City of Cudahy allows second units on single-family lots, as required by State law. This has led to second units on most lots in the Low Density Residential (LDR) Zone and has added to the current housing stock. This is an ongoing program by the Planning Department. Its implementation is funded by the General Fund. The Planning Department will monitor the construction of second units annually (coinciding with the fiscal year).

Single family neighborhoods represent a small
portion of the City’s residential land (23%) and
many of these existing neighborhoods have
second units on their lots. As such, additional
second unit development has been minimal. The
City will update accessory unit requirements and
regulations within the Development Code to
comply with State law (Assembly Bill 2299 and
Senate Bill 1069) in 2018.

An updated version of the program is included in
the updated Housing Element.

Development Monitoring Program
The City shall develop a system for assessing the potential impacts from new development. The city will require all new development to undergo an assessment to ensure that adequate infrastructure is available to serve the development. The feasibility of a Mello Roos fee for the upgrade of existing infrastructure (including roads, water lines, etc.) will be explored for future implementation. The program is ongoing and will be monitored annually (coinciding with the fiscal year) by the Public Works Department and is financed through the General Fund.

The study was completed by June 2014 and is included in the housing information program materials.

Infrastructure impacts from new developments
are addressed through the environmental review
process as required by the California
Environmental Quality Act and will be fully
assessed citywide through the General Plan
Environmental Impact Report (EIR).

Infrastructure availability is an integral part of
maintaining a high quality of life for residents.

This program and the provisions of ensuring
adequate infrastructure are included in Program
13: Infrastructure Availability program.

Manufactured Housing
The city allows manufactured homes and modular units on singlefamily lots. This permits the use of manufactured homes as affordable housing alternatives. This is an ongoing program, managed and State law requires local governments to permit
manufactured or mobile homes meeting federal
safety and construction standards on a
permanent foundation in all single-family
residential zoning districts (Section 65852.3 of

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monitored annually (coinciding with the fiscal year) by the Planning Department.
the California Government Code). In Cudahy, a
manufactured/ factory-built house is a singlefamily detached dwelling unit and is treated as such.

This program is implemented and is removed
from the updated Housing Element.

Affordable Housing Incentives
To encourage the development of affordable housing units, the City shall provide developers with incentives and shorten the permit process for low-income and senior citizen housing projects.

The City shall compile information on available financing mechanisms and federal, state, and local programs and agencies that provide funding assistance for housing projects. This information shall be made available to developers. Cooperative ventures with developers on housing projects may also be initiated by the city.

The program began in 2013 under the Community Development Department and was financed through the General Fund. An affordable housing ordinance to encourage development of affordable units and remove constraints was completed in December 2015, along with materials available for developers.

The provision of affordable housing for the
Cudahy community is important to the City.

An updated and expanded version of the
program is included in the updated Housing
Element. The new program includes an action
item to develop development incentives and a
community benefit permitting procedure that
incentivizes benefits and desired public
amenities provided by private development,
which include, but are not limited to, low Income
and/or affordable housing.

CDBG Information Programs
The City shall continue housing programs on housing development, infrastructure, rehabilitation, and job development, as allowed by the CDBG program. The city currently uses its CDBG moneys for the Home Improvement program, fair housing foundation services, code enforcement, senior nutrition program, food distribution program and the development of public facilities. It shall coordinate with the County Housing Authority in implementing programs outlined in the Comprehensive Housing Affordability Strategy (CHAS) for Los Angeles County. The city has prepared a brochure outlining available housing assistance and rehabilitation programs in the city. It has l distributed these to property owners and has made them available at City Hall. The brochure shall encourage residents to participate in the Section 8 housing assistance payments program and the housing voucher program through the Los Angeles County Housing Authority. (The city is not applying for other federal programs, although it has evaluated potential participation in the HOME, HOPE, and other housing loan programs of HUD). The program is ongoing and monitored annually (coinciding with the fiscal year) under the Community Development Department and is financed by the General Fund.

Since 2014, the City has used CDBG funds for
Code Enforcement, Single-unit Housing
Rehabilitation Program, Business Assistance
Program, Senior Activities Program, Food
Distribution Program, and two construction
projects at Clara Park and Cudahy Park.

CDBG funding is an important resource for the
city and the programs identified will continue.

This program is included in the updated Housing
Element.

Housing Conversion Program
The City shall take the lead in coordinating efforts for the preservation of subsidized housing projects in Cudahy. To help conserve the lowincome units at risk of conversion, the city may provide technical assistance to non-profit groups interested in buying the projects. It may aggressively look for an agency to buy the property or help the residents establish an association to buy the project.

Subsidized housing units in Cudahy are owned
by non-profit affordable housing developers that
have expressed a desire to continue renewing
their subsidies that allow for the provision of
affordable housing.

A program addressing affordable housing at risk
of conversion to market rate will be included in

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The Community Development Director shall monitor the status of all subsidized housing projects and shall work with the City Manager in developing strategies to preserve these projects. Specific projects shall be reviewed for consistency with the goals of the General Plan and other City policies prior to implementation. Public participation shall be encouraged throughout the process to reflect the needs and interests of Cudahy residents. Financing will come from CDBG funds, and the General Fund, to the extent funds are available. Other funding sources that may be available shall also be explored.
the updated Housing Element and will be
combined with a second existing program
related to at-risk housing.

Inclusionary Housing Program
The city is in the process of adopting an Inclusionary Housing Ordinance to encourage affordable housing units within new housing developments. The ordinance requires developers to provide a minimum percentage of affordable housing or pay fees, dedicate land, or establish agreements with other agencies for the construction of affordable units off site. To address Cudahy's overcrowding problems, the city included in the ordinance, the available options to requiring or encouraging large dwelling units (2 bedrooms or more) within new development. This may likewise be promoted by incentives to the allowable density and less stringent development standards. The inclusionary housing study was initiated by the Department of Community Development, with funding from the General Fund to the extent of available resources.

In addition to adopting an inclusionary housing
program, the City will establish development
incentives and community benefits permitting
procedure that incentivizes benefits and desired
public amenities provided by private
development, which include, but are not limited
to, low Income and/or affordable housing,
consistent with General Plan policy.

This program is included in the updated Housing
Element and directives pertaining to the
community befits program are added to several
programs.

Housing Maintenance and Conservation
The City of Cudahy has an ongoing program for the maintenance and conservation of the existing housing stock. There are programs aimed at the conservation of older housing units which are in good condition to maintain the units as affordable housing options. Rehabilitation and property maintenance programs ensure that living conditions are safe and decent for all households. By maintaining the existing housing stock and preventing the creation of substandard housing, the city improves the living environment for present residents. Implementation measures for housing maintenance and conservation are discussed below.

Approximately 25 housing units are anticipated to benefit from the City's rehabilitation programs by 2021. Also, approximately 400 mobile homes will be conserved. This program is managed by the Community Development Director.

Since 2014, 20 units have been assisted through
this program.

An updated version of the program is included
the updated Housing Element.

Tenant Minor Home Repair Program
The City shall continue to apply for Community Development Block Grants for housing rehabilitation programs in the City. These funds shall be used to offer technical assistance and loans under the Tenant Minor Home Repair program, as well as to implement housing rehabilitation programs which provide low interest loans, grants, and technical assistance to property owners. The program is ongoing and will continue to be managed and monitored annually (coinciding with the fiscal year) by the Community Development Department and financed through CDBG funds. The Tenant Minor Home Repair Program is complaint driven; complaints are filed with the City’s Code Enforcement department which then schedules follow up inspections and provides tenants with information to resources. Furthermore, the tenants may be referenced to the City’s Housing Department to seek Due to lack of funding, this program is no longer
available. Residents continue to have access to
improvement programs through the Housing
Maintenance and Conservation program.

This program is removed from the Housing
Element.

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possible financial assistance.

SRO Hotels
The City shall preserve single-room occupancy (SRO) hotels and strictly enforce ordinances regarding property maintenance and fire and safety standards to safeguard the public health, safety, and welfare of tenants.

To encourage the use of hotels by "homeless" individuals, the city continuously works with hotel managers on making rooms available for emergency/transitional housing and makes community service agencies in the area aware of the facilities. The city also refers persons in need to these facilities. Vouchers shall be solicited from the hotel, local businesses, charitable agencies, and other
organizations/individuals to provide short-term stays at the hotels. The 160 rooms available in local hotels are adequate to serve the temporary housing needs of homeless individuals in the area. This program is ongoing, implemented, and monitored annually (coinciding with the fiscal year) by the Community Development Department. It is funded by the General Fund, to the extent of available resources.

Vouchers and/or an allocated budget were developed in December 2015.

Two motels in the City provide short term
housing to homeless or at-risk individuals. City
strictly enforces ordinances regarding property
maintenance and fire and safety standards to
safeguard the public health, safety, and welfare
of tenants.

The program will be included in the updated
Housing Element.

Development Standards to Allow Uses
The City shall modify its Municipal Code to allow the development, maintenance, and improvement of Emergency Shelters, SRO’s, Transitional Housing, and Supportive Housing to address constraints and facilitate the development of low-income housing throughout the City. The City shall refer person in need to these facilities. This program is managed by the Planning Department, funded by the General Fund, and was completed in December 2015.

The city adopted a comprehensive update of the
Development Code in 2018 which addresses
Emergency Shelters, SROs, Transitional
Housing, and Supportive Housing consistent
with state law.

The city will monitor development of these
housing types and re-evaluate the effectiveness
of established development standards. The
program will be included in the updated Housing
Element.

Emergency Shelters
The city will amend the Zoning Ordinance so emergency shelters shall be a permitted use without a conditional use permit or other discretionary action in the High-Density Residential zone.

The city adopted a comprehensive update of the
Development Code in 2018 that addresses
Emergency Shelters consistent with state law.

Emergency shelters are allowed without
discretionary review in the Commercial Mixed
Use (C/MU), Civic Mixed Use (Civic/MU), and
Entertainment (E) zoning districts.

Development standard review and monitoring of
this development type is included in two other
programs. As the zoning ordinance amendment
is completed, this program is removed from the
updated Housing Element. The monitoring of
emergency shelter development is addressed in
the Emergency, Transitional and Supportive
Housing program.

Transitional and Supportive Housing
The city will continue to monitor the inventory of sites appropriate to accommodate transitional housing and supportive housing and will The city adopted a comprehensive update of the
Development Code in 2018 which addresses
Transitional and Supportive Housing consistent
with state law.

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work with the appropriate organizations to ensure the needs of homeless and extremely low-income residents are met. In compliance with Senate Bill 2, the City will amend the Zoning Code to allow transitional and supportive housing in all residential zones, subject only to those regulations that apply to other residential uses of the same type in the same zone. This program is funded by the General Fund and managed by the Community Development Department.

The city will continue to monitor the inventory of
sites appropriate to accommodate transitional
housing and supportive housing and will work
with the appropriate organizations to ensure the
needs of homeless and extremely low-income
residents are met. This program is renamed and
updated to also address emergency shelters.

Code Enforcement
The City shall continue code enforcement of nuisances such as inoperable vehicles, property maintenance, substandard units, and illegal garage conversions.

Code enforcement activities are an important
part of the City’s neighborhood preservation
programs. The program will be included in the
updated Housing Element.

Housing Cooperating Program
The City shall work with Los Angeles County to identify and coordinate water and sewer infrastructure on the provision of adequate infrastructure and public services in Cudahy, including monitoring for grant funding sources, to meet the City’s RHNA. The program will be financed through the General Fund. The CIP program was completed in December 2015 by the Public Works Department.

Infrastructure impacts from new developments
are addresses through the environmental review
process as required by the California
Environmental Quality Act and will be fully
assessed citywide through the General Plan
Environmental Impact Report (EIR).

Infrastructure availability is an integral part of
maintaining a high quality of life for residents. In
addition, consistent with the General Plan
Implementation program, the City will establish
permit tracking program by June 2019 that
monitors new development and the
redevelopment of existing uses that increase the
number of residential unit and/or nonresidential
square footage. This program is renamed and
updated to address continued coordination with
the County and ongoing development tracking.

Equal Access
The city intends to minimize difficulties of special needs households in finding adequate housing by providing programs to prevent discrimination or to encourage the production of housing specifically designed for these households. The city amended its definition of family in 2014.

The City shall refer discrimination complaints to the Fair Housing Network and ensure complaints are resolved. The city will participate and distribute fair housing materials at a variety of community activities such as food distribution, Easter egg hunt, national night out, and local carnivals/fairs to reach out to all segments of the community. The city will annually conduct fair housing press releases, directly contact interested groups for distributing fair housing materials, mail fair housing materials through utility billing and post fair housing information in a variety of community locations such as the library, bus stops, public counters, and post office. The program, managed by the Community Development Director, began in 2013, and promotional materials were developed in December 2014 for distribution, and will be updated on an ongoing basis. The program will be funded through the General Fund and staff time.

The city adopted a comprehensive update of the
Development Code in 2018 which includes a
definition of family consistent with state law.

This program is combined with the Fair Housing
Program in the updated Housing Element
Reasonable Accommodation Program The City adopted a comprehensive update of the Development Code in 2018 that includes a
formal procedure for individuals with disabilities

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The City has developed a policy pursuant to the Fair Housing Amendments Act of 1988, to provide people with disabilities reasonable accommodation in rules, policies, practices, and procedures that may be necessary to ensure equal access to housing.

This policy was developed by City Administration and completed in October 2014.
seeking equal access to housing to request a
reasonable accommodation to zoning
regulations, as provided by the Federal Fair
Housing Amendments Act of 1988 and
California's Fair Employment and Housing Act,
and to establish criteria to be used when
considering these requests. The purpose of the
reasonable accommodation process is to
provide flexibility in the application of land use,
zoning or building regulations, policies, or
procedures for individuals with disabilities or
developers of housing for persons with
disabilities when it is necessary to eliminate
barriers to equal housing opportunities.

This program is completed and removed.

Public Participation Program
The city encourages community participation in all city programs.

Noticing practices in the city include posting information on scheduled public hearings at City Hall, the Cudahy Library, and the Council Chambers at least two weeks prior to the hearing dates. The city also advertises these hearings, as well as other city programs, in the local newspaper (The Wave) and in the city newsletter. Both papers use English and Spanish in their articles to reach the primarily Hispanic Community of the area. An interpreter is also available during public hearings to facilitate communication between individuals who only speak Spanish. Brochures at City Hall are available in both English and Spanish versions. Spanish-speaking employees also facilitate the dissemination of information regarding city programs. It shall encourage residents to attend City Council and Planning Commission meetings by increased publicity practices. This will allow the city to get more input into its programs and tailor them to meet the needs expressed by residents.

Public workshops have been conducted in the General Plan's revised goals and policies and Draft Land Use Plan to solicit resident concerns.

Public hearings will continue to be held prior to adoption of the General Plan, including this Element. This will allow the city to better respond to the concerns and interests of Cudahy residents. This program is ongoing, to be monitored annually (coinciding with the fiscal year) and funded by the General Fund as services are contracted and staff time.

Public participation is a priority for the city. This
program is combined with the Bilingual program
in the updated Housing Element, as access for
Spanish speakers in Cudahy is crucial to
obtaining full participation.

Fair Housing Program
The city promotes the use of the Fair Housing Council of Long Beach through the City newsletter and local papers and informs all city employees of the available services for referral. The City shall prepare a list of referral agencies to serve low-income households, handicapped, elderly, homeless, and other special needs groups.

Information is given through Code Enforcement and City Housing Department. It shall make the list available at City Hall, the library and City parks for interested persons. Financing will be provided through the General Fund and CDBG funds. Referral information was completed in December 2015.

The city refers fair housing complaints to the
Housing Rights Center and advertises fair
housing services and information through the
city newsletter and local papers and informs all
city employees of the available services for
referral.

The program will be included in the updated
Housing Element and combined with the Equal
Access Program.

Food Distribution Program The city conducts hot meals and food distribution on the 4th Thursday of every month. The program
is important to the city and is a valuable resource

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The City shall continue the hot meals and food distribution programs.

Also, it shall assist public and non-profit agencies which provide support services to special needs populations (the homeless, the elderly, singleparent households, etc.). The food distribution program is ongoing, to be monitored annually (coinciding with the fiscal year) and financed through the CDBG.
for residents. The program will be included in the
updated Housing Element.

Homeless Assistance Program
The City shall continue to provide funds for the Human Services Association to serve the homeless and other special needs groups in the community. It shall also maintain a list of local social services to use as referral sources for residents in need. These services are discussed in the Housing Element Profile Report. This program is ongoing, to be monitored annually (coinciding with the fiscal year) and will continue to be financed through the CDBG.

Due to lack of funding, the City has not been able
to provide funds to the Human Services
Association. It does maintain a list of local social
services to use as referral sources for residents
in need and refers homeless individuals to local
and regional homeless resources. The program
will be included in the updated Housing Element.

Bilingual Programs
The City's will actively produce documents and publications that are in both English and Spanish. This is an ongoing program monitored annually (coinciding with the fiscal year) by the Community Services Department. It is funded by the General Fund, to the extent available, and staff time.

Public participation is a priority for the city. This
program is combined with the Public
Participation program.

Handicapped Access
The city currently requires new development to comply with State standards for handicapped access. It shall also enforce the recently adopted American with Disabilities Act. This program is implemented by the Department of Building and Public Services with funding from the General Fund. The city adopted the Los Angeles County Building Code in March 2013, which includes standards for ADA compliance.

The program is ongoing and will be included in
the updated Housing Element
Senior Shared Housing Program
The senior’s Center on Clara Park serves as an information center for senior programs and resources. This is an ongoing program monitored annually (coinciding with the fiscal year) by the Community Services Department with funding from the General Fund.

The program is ongoing and will be included in
the updated Housing Element
Housing for Extremely-Low-Income Households Program
The city will encourage the development of housing units for households earning 30 percent or less of the median Family income for Los Angeles County. Specific emphasis shall be placed on the provision of family housing and non-traditional housing types such as single-room occupancy units and transitional housing. The City will encourage development of housing for extremely low-income households through a variety of activities such as outreach to housing developers on at least an annual basis, providing financial or in-kind technical assistance or land-write downs, providing expedited processing, identifying grant and funding opportunities, applying for or supporting applications for funding on an ongoing basis, reviewing and prioritizing local funding at least twice during the planning period and/or offering additional incentives beyond the density bonus provision. This program, administered by the Planning Department, is ongoing.

Through its Inclusionary Housing Ordinance, the
City has established development incentives and
community benefits permitting procedure that
incentivizes benefits and desired public
amenities provided by private development,
which include, but are not limited to,
extremely/low Income and/or affordable housing.

This program is merged with the Affordable
Housing Incentives program.

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Persons with Disabilities, including Developmental Disabilities Program
The city shall seek State and Federal monies, as funding becomes available, in support of housing construction and rehabilitation targeted for persons with disabilities. The City shall provide regulatory incentives, such as expedited permit processing and fee waivers and deferrals, to projects targeted for persons with disabilities, including persons with developmental disabilities. The City shall reach out annually to developers of supportive housing to encourage development of projects targeted for persons with disabilities, including persons with developmental disabilities. The City shall work with the local Regional Center to implement an outreach program informing families within the City of housing and services available for persons with developmental disabilities. Information will be made available on the City’s website and at City Hall counter.

The program is ongoing and will be included in
the updated Housing Element
Preservation of At-Risk Units Program
The City will monitor every three months, the status of any HUD receipt/approval Notices of Intent and Plans of Action filled by property owners to convert to market-rate units. The city will annually identify and meet and pursue funding with non-profit organizations as potential purchasers/managers of at-risk housing units. As part of coordination with non-profit partners, the city will annually explore funding sources available to purchase affordability covenants on at-risk projects, transfer ownership of at-risk projects to public agencies, purchase existing buildings to replace at-risk units, or construct replacement units. Where feasible the city will provide technical assistance and support to these organizations with respect to financing. The city will update this list annually. The City will provide tenant education within 30 days of notice and assist tenants to obtain special Section 8 vouchers reserved for tenants of converted properties. HUD has set aside special Section 8 vouchers for existing tenants in Section 8 projects that are opting out of low-income use. Upon conversion, the units will stay affordable to the existing tenants if they stay. Once a unit is vacated and new tenants move in, the units will convert to marketrate housing. This is an ongoing program monitored (coinciding with the fiscal year) and managed by the Community Development Department with funding from CDBG funds.

Subsidized housing units in Cudahy are owned
by non-profit affordable housing developers that
have expressed a desire to continue renewing
their subsidies that allow for the provision of
affordable housing.

A program addressing affordable housing at risk
of conversion to market rate will be included in
the updated Housing Element. The details of this
program are merged with the At-Risk Housing
Preservation Program.

Consistency with General Plan
The City shall conduct an integral review as part of its General Plan implementation to achieve consistency with other general plan elements, policies, programs, and community goals to reflect the policy direction contained in other parts of the General Plan. As portions of the General plan are amended in the future, this Housing Element will be reviewed to ensure that internal consistency is maintained. This is an ongoing program monitored annually (coinciding with the fiscal year) and managed by the Community Development Director and Planning Departments.

The program is ongoing and will be included in
the updated Housing Element.

Zoning Update Program
To address a shortfall and un-accommodated need of 280 units at appropriate densities, the city will increase allowable zoning densities of the HDR and CC Zone’s city wide from 14.52 to allowing a minimum of 20 dwelling units per acre. Increasing the density to 20 dwelling units In 2016-2018, new General Plan Land Use
designations were developed, allowing for higher
density development in residential areas and
identifying new areas for mixed-use
development with higher residential densities.

The city completed a concurrent Development

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per acre will further facilitate meeting the demand for affordable housing. Pursuant to Government Code Section 65583(c)(1) and 65583.2(h) and (i), sites to accommodate the shortfall and unaccommodated need of 280 units will permit a minimum of 16 dwelling units per site and 50% will be zoned residential only. Candidate sites for rezoning include Site numbers 1, 2, 3, 4, and 11. In addition, the HDR and CC zones will be amended to permit owner-occupied or multifamily residential uses by right (without a conditional use permit, planned unit development permit, or other discretionary). This program was completed by October 2014 by the Community Development Department.

Code and Zoning Map update to provide zoning
districts consistent with the new General Plan.

These changes significantly increased allowable
densities in residential and mixed-use areas and
are expected to provide more incentive to
recycle underutilized and deteriorating property.

The updated sites inventory shows sufficient
capacity to address the City’s current and
previous (rollover) RHNA.

This program is completed and removed.

Affirmatively Furthering Fair Housing – AFFH – AB 686.

As of January 1, 2019, AB 686 extends the obligation to affirmatively further fair housing to all public agencies in the State of California.

Affirmatively furthering fair housing means taking meaningful actions to combat discrimination that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. The 6th Cycle Housing Element analysis has addressed the following: (1) Significant discrepancies in housing needs and in access to opportunities; (2) Replacing segregated living patterns with truly integrated and balanced living patterns; (3) Transforming racially and ethnically concentrated areas of poverty (R/ECAP) into areas of opportunity; (4) Fostering and maintaining compliance with civil rights and fair housing laws. The city’s Community Development Department, in conjunction with the State Department of Housing and Community Development (HUD) will administer and monitor this program.

Section 8 of this Housing Element includes an
analysis of AB 686, Affirmatively Furthering Fair
Housing. The City bears the responsibility of
monitoring and enforcing any rules and
regulations regarding Furthering Fair Housing by
understanding the root causes of housing
discrimination, who is being discriminated
against and why, and implement programs,
policies, and objectives in an affirmative fashion,
to address discrimination of the protected
classes in the City.

This is an ongoing program that must be
monitored and reported to the Department of
Housing and Community Development.

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7 Housing Goals, Policies, Programs and Quantified Objectives This section of the City of Cudahy Housing Element addresses the State's housing element requirements for a "statement of the community goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing" The goals, policies, and programs delineated in this Housing Element serve to support the State of California’s overarching goal of providing, “decent housing and a suitable living environment for every California” (Government Code Section 65580). This Housing Element proposes to add two programs that were not included in the previous Housing Element, and three programs will be deleted because they are no longer needed or may not be the best use of City resources.

The housing goals, policies, and programs that follow were created for the purpose of meeting the housing needs of the City throughout the 2021-2029 planning period given the limitations imposed by current political, economic, and social conditions, budget constraints and available local, State, and federal funding.

7.1 HOUSING GOALS, POLICIES, AND PROGRAMS
The City's housing goals have been developed to respond to the key housing related issues facing the City. As summarized in the Profile Report, Cudahy is experiencing a very high demand for housing. This is manifested by the low vacancy rate, the creation of unpermitted housing units, and the doubling-up of households in individual units resulting in overcrowding. The lack of housing has led to increases in rents and prices, which go beyond the affordability of its lowincome residents.

Housing Element Policies indicates those policies that will be applicable over the course of the planning period governed by this Element;
Housing Element Programsindicates those specific programs that will be effective in assisting in the conservation of affordable housing, the development of new affordable housing, the identification and provision of new sites for residential development, and the removal of governmental constraints.

Goals
Housing Element Goal 1: The City of Cudahy will improve the housing supply and the choice of housing opportunities through private investment and, where necessary, through public action and financing.

Housing Element Goal 2: The City of Cudahy will promote affordable housing and shelter for all economic segments of the community.

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

Housing Element Goal 3: The City of Cudahy will support and provide incentives for the maintenance and rehabilitation of the existing housing stock.

Housing Element Goal 4: The City of Cudahy will encourage development of a viable urban community consistent with orderly growth and environmental conservation to provide suitable living environments, with access to employment, community facilities, and services.

Housing Element Goal 5: The City of Cudahy will promote equal access and opportunity to housing regardless of race, religion, sex, marital status, ancestry, national origin, or color.

Housing Element Goal 6: The City of Cudahy will identify and address significant discrepancies in housing needs and in access to housing opportunities.

Housing Element Goal 7: The City of Cudahy will identify and replace segregated living patterns with truly integrated and balanced living patterns.

Housing Element Goal 8: The City of Cudahy will identify and transform racially and ethnically concentrated areas of poverty (R/ECAP) into areas of opportunity.

Housing Element Goal 9: The City of Cudahy will foster and maintain compliance with civil rights and fair housing laws.

Issue: Housing Availability
Although there has been an overall population decline in Cudahy, due to over-crowding and housing cost, there is an increasing need for housing in the city. Low vacancy rates and second units on single-family lots reflect this high demand. New housing development coupled with the City’s new Inclusionary Housing Ordinance will help meet this need and provide residents with greater opportunities to find appropriate and adequate housing.

HOUSING ELEMENT GOAL 1:

The City of Cudahy will improve the housing supply and the choice of housing opportunities through private investment and, where necessary, through public action and financing.

Housing Element Policy 1.1: The City of Cudahy will encourage future investment in the City's housing stock.1
Housing Element Policy 1.2: The City of Cudahy will evaluate the factors affecting housing costs and examine ways to reduce housing costs where governmental action is appropriate.

Housing Element Policy 1.3: The City of Cudahy will support the development and use of new techniques in housing design, construction, and development. 1 This symbol indicates a goal, policy, or program that addresses environmental justice issues.

CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE

Housing Element Policy 1.4: The City of Cudahy will promote the development of attractive and safe housing to meet the community's needs.

Housing Element Policy 1.5: The City of Cudahy will provide prompt processing of housing construction applications through standardized development requirements and centralized processing.

Housing Element Policy 1.6: The City of Cudahy will encourage the assemblage and consolidation of existing small parcels in areas which permit higher density development.

Larger parcels can better accommodate increased density housing, through a more efficient use of space resulting in more on-site amenities and greater use of open space.

Housing Element Policy 1.7: The City of Cudahy will recognize the changing trends and patterns in the community and encourage a broad range of housing types to meet these needs.

Housing Element Policy 1.8: The City of Cudahy will work with the appropriate service providers to develop and coordinate programs to assist in the conservation of affordable housing and to serve the homeless population.

Issue: Housing Affordability
Low-income households comprise a major segment of the City’s population. Coupled with high demand and market rate housing, it has led to overpaying, overcrowding, and unpermitted housing units. Affordability is a major concern in Cudahy.

HOUSING ELEMENT GOAL 2:

The City of Cudahy will promote affordable housing and shelter for all economic segments of the community.

Housing Element Policy 2.1: The City of Cudahy will promote all State, regional and local practices and plans that support housing availability for all economic segments of the population.

Housing Element Policy 2.2: The City of Cudahy will promote local housing services to ensure federal, state, and local housing programs are available to assist the private sector in obtaining funds for housing development.

Housing Element Policy 2.3: The City of Cudahy will utilize Community Development Block Grant funds to develop housing, expand economic opportunities through commercial development, improve community facilities and services, prevent deterioration of the housing stock, and redevelop residential areas.

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Housing Element Policy 2.4: The City of Cudahy will inform residents of the availability of housing assistance programs and community services available in the area (such as Section 8 certificates and vouchers).

Housing Element Policy 2.5: The City of Cudahy will encourage variety in the supply of housing at costs affordable to the various income levels of the population.

Housing Element Policy 2.6: The City of Cudahy will solicit State and Federal funds for new housing development.

Housing Element Policy 2.7: The City of Cudahy will work towards the conservation of existing subsidized housing for low and moderate-income families.

Housing Element Policy 2.8: The City of Cudahy will seek funding opportunities and promote rental assistance for low and moderate-income families.

Issue: Housing Maintenance and Conservation
The City of Cudahy is primarily a residential community and has provided housing to the County's very low, low, and moderate-income households. Without maintenance and conservation, the City's housing stock can go into disrepair or be replaced with more expensive housing. To prevent displacement and the deterioration of housing and neighborhood quality, the city needs to promote the rehabilitation of existing housing units.

HOUSING ELEMENT GOAL 3:

The City of Cudahy will support and provide incentives for the maintenance and rehabilitation of the existing housing stock.

Housing Element Policy 3.1: The City of Cudahy will encourage, support, and provide incentives for the maintenance, conservation, and revitalization of existing residential units.

Housing Element Policy 3.2: The City of Cudahy will explore strategies and programs that will be effective in reducing the costs incurred by the homeowner for rehabilitation.

Housing Element Policy 3.3: The City of Cudahy will encourage relocation assistance for displaced persons living in rentals undergoing rehabilitation and/or reconstruction.

Housing Element Policy 3.4: The City of Cudahy will continue residential rehabilitation programs and provide technical assistance to property owners as needed.

Housing Element Policy 3.5: The City of Cudahy will encourage prompt rehabilitation or demolition and replacement of vacant and abandoned properties.

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Housing Element Policy 3.6: The City of Cudahy will actively engage in identifying substandard and deteriorating housing in Cudahy and take appropriate actions to correct these deficiencies, such as initiating rehabilitation, maintenance, or replacement programs.

Housing Element Policy 3.7: The City of Cudahy will promote housing rehabilitation and conservation through public education and awareness programs.

Housing Element Policy 3.8: The City of Cudahy will encourage property maintenance to promote quality design, public safety, and to promote energy conservation.

Housing Element Policy 3.9: The City of Cudahy will work with the County or non-profit agencies in conserving existing low-income housing units and subsidized housing projects.

Housing Element Policy 3.10: The City of Cudahy will preserve existing single-family, lower density residential neighborhoods.

Issue: Neighborhood Preservation
Neighborhood quality is dependent on street and property maintenance, the availability of services and infrastructure and the residents' sense of community. By improving neighborhood quality, the City of Cudahy can create stability in the resident population and pride in its people.

HOUSING ELEMENT GOAL 4:

The City of Cudahy will encourage development of a viable urban community consistent with orderly growth and environmental conservation to provide suitable living environments, with access to employment, community facilities, and services.

Housing Element Policy 4.1: The City of Cudahy will reserve the existing residential neighborhoods and provide areas to accommodate new residential development.

Housing Element Policy 4.2: The City of Cudahy will coordinate regional and local public works and capital improvement programs in declining neighborhoods and in neighborhoods experiencing increased population due to redevelopment or land conversion activities.

Housing Element Policy 4.3: The City of Cudahy will provide the necessary public services and infrastructure, including encouraging early care and education facilities, to residential areas and locate new housing developments where availability of public facilities and services is assured.

Housing Element Policy 4.4: The City of Cudahy will encourage the application of high-quality urban design standards to create safe, attractive, functional housing units and neighborhoods.

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Housing Element Policy 4.5: The City of Cudahy will conserve existing residential areas and prevent the intrusion of incompatible uses into the neighborhoods.

Housing Element Policy 4.6: The City of Cudahy will encourage continued and new investment in the established residential neighborhoods in Cudahy.

Housing Element Policy 4.7: The City of Cudahy will increase property maintenance efforts by code enforcement to improve the overall appearance of the residential neighborhoods, thus maintaining property values in the City.

Housing Element Policy 4.8: The City of Cudahy will identify the best possible locations and development standards for residential development and encourage a high-quality environment for family life.

Issue: Equal Access to Housing
Discrimination can prevent households with special needs or certain characteristics from obtaining appropriate housing. The City of Cudahy seeks to eliminate all forms of housing discrimination to allow residents to find adequate housing.

HOUSING ELEMENT GOAL 5:

The City of Cudahy will promote equal access and opportunity to housing regardless of race, religion, sex, marital status, ancestry, national origin, or color.

Housing Element Policy 5.1: The City of Cudahy will promote equal access and opportunities to housing through the provision of consumer information, assistance, and protection and through citizen involvement in the design and implementation of housing programs.

Housing Element Policy 5.2: The City of Cudahy will explore procedures for fair and equitable treatment of the parties in housing contracts, such as buyer-seller and landlord-tenant agreements.

Housing Element Policy 5.3: The City of Cudahy will encourage citizen participation and community involvement in the development and implementation of housing assistance and housing programs in the City. Actively pursue participation on housing issues by the City's elderly and minority populations.

Housing Element Policy 5.4: The City of Cudahy will establish referral agencies to serve lowincome households, the homeless, handicapped, elderly households and residents with special housing needs.

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Housing Element Policy 5.5: The City of Cudahy will enforce fair housing laws and encourage the use of fair housing council services.

Housing Element Policy 5.6: The City of Cudahy will encourage and promote accessible housing for the handicapped. This includes the retrofitting of existing units and the enforcement of the State accessibility standards for new residential construction.

Housing Element Policy 5.7: The City of Cudahy will provide continued cooperation between the City and adjacent cities in the development of regional housing programs and homeless services.

Housing Element Policy 5.8: The City of Cudahy will provide density bonuses for low-income housing projects and senior citizen housing projects.

HOUSING ELEMENT GOAL 6:

Housing Element Policy 6.1: The City of Cudahy will identify paras of the city where significant discrepancies in housing needs and in access to opportunities exist and address them.

Housing Element Policy 6.2: The City of Cudahy shall convene a task force consisting of city staff from the Community Development Department to implement this policy and make perioding reports to the City Manager and the City Council.

HOUSING ELEMENT GOAL 7:

Housing Element Policy 7.1: Through its zoning and land use policies, the City of Cudahy shall systematically replace segregated living patterns with truly integrated and balanced living patterns.

Housing Element Policy 7.2: The Community Development Director shall study and advise the City Manager, the Planning Commission, and the City Council on the best practices available to replace segregated living patterns in the City with truly integrated and balanced living patterns.

The Community Development Director shall define “segregated living patterns” based on guidance and policies of the State Department of Housing and Community Development Department.

HOUSING ELEMENT GOAL 8:

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Housing Element Policy 8.1: The City of Cudahy, in compliance with State Assembly Bill 686 (AB 686), shall identify and systematically transform racially and ethnically concentrated areas of poverty (R/ECAP) into areas of opportunity.

Housing Element Policy 8.2: The City of Cudahy shall establish a critical racially and ethnically concentrated areas of poverty within its boundaries and implement policies to transform those areas into areas of opportunity. This policy may require coordination with the HCD as most of the City of Cudahy is predominantly Hispanic/Latino and the predominantly low income.

HOUSING ELEMENT GOAL 9:

Housing Element Policy 9.1: The City of Cudahy shall establish and maintain policies that foster and maintain compliance with all civil rights and fair housing laws by training its Community Development staff in the details of the civil rights and fair housing laws.

Housing Element Policy 9.2: The City of Cudahy, in addition to establishing and maintain compliance with all civil rights and fair housing laws shall employ, where vacancies exist, those who are familiar with, or have worked specifically with fair housing and civil rights laws.

HOUSING PROGRAMS
The quality of housing in the City of Cudahy is a major concern. The Housing Program has been designed to address these needs and to help provide adequate housing to all residents. The housing program revolves around the key issues and housing goals of the City which have been discussed previously.

Housing Availability - the policies address the existing and future housing needs.

Housing Affordability - the policies provide housing for the City's lower income households and reduce overpayment.

Housing Maintenance and Conservation - the policies preserve the existing housing stock and conserve affordable housing units.

Neighborhood Preservation - the policies are designed to bring stability to the residential neighborhoods and promote community pride.

Equal Access - the policies are designed to assist special group’s find appropriate housing.

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Early care and Education Program Availability – the policies support the availability of quality, affordable early care, and education services for families.

Through the policies and programs in this Element, the City of Cudahy will be able to improve the quality of the environment for all residents. By addressing these interdependent issues at the same time, the City hopes to eliminate or slowly reduce its housing problems. The identification of funding sources for individual programs does not exclude the use of other funding sources which may be available.

SUMMARY OF PROGRAMS
Table 7.1 Summary of Programs
Program # Name Responsible Department Completion Date
1 Adequate Sites Program Community Development Re-zoning completed in 2018; Ongoing (monitored annually)
2 Housing Information Program Community Development December 2018 3 Second Unit Ordinance Planning 2018, Ongoing (monitored annually) 4 Promote Lot Consolidation Planning Ongoing, Community Benefits program by June 2019
5 Affordable Housing Incentives Community Development Ongoing, Community Benefits program by June 2019
6 CDBG Information Program Community Development Distribute brochure in December 2018. Ongoing (monitored annually)
7 At-Risk Housing Preservation Community Development Ongoing (monitored annually) 8 Housing Maintenance and
Conservation
Community Development Ongoing
9 Hotel and Motel Resources Community Development Ongoing (monitored annually) 10 Development Standards to Allow
Uses
Planning January 2020
11 Emergency, Transitional and
Supportive Housing
Community Development Ongoing (monitored annually)
12 Code Enforcement Code Enforcement Ongoing (monitored annually as part of the CDBG program)
13 Infrastructure Availability Community Development June/December 2019 14 Public Participation Program City Clerk Ongoing (monitored annually) 15 Fair Housing Program Code Enforcement / Housing December 2018; Ongoing 16 Food Distribution Program Community Development Ongoing (monitored annually) 17 Homeless Assistance Program Community Development Ongoing (monitored annually) 18 Handicapped Access Building & Safety Ongoing (monitored annually) 19 Senior Shared Housing Program Community Services Ongoing (monitored annually) 20 Persons with Disabilities, including
Developmental Disabilities Program
Community Development December 2018/2019
21 Consistency with General Plan
Program
Community Development /
Planning
Ongoing (monitored annually)
Source: City of Cudahy; Community Development Department

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Housing Availability
Housing availability refers to the development and provision of housing units to meet existing and future needs of area residents. Housing development can be initiated by the city, private developers, or other agencies. Most new residential development will be initiated by the private sector because of limited financial resources on the part of the City, State, and Federal governments. Developers will generally provide market rate housing because they see housing development as a financially profitable activity. Housing projects funded by local state and federal agencies are likely to be reserved for low and moderate-income households. Specific programs designed to promote new residential development in the city are described in the following section.

Program 1: Adequate Sites
The residential sites inventory consists of vacant and underutilized residential land with the capacity to yield at least 710 units. The sites and RHNA comparison indicate that there are adequate sites to accommodate and exceed the total RHNA (including both the 2021 RHNA and 2014 unaccommodated RHNA) under the City’s 2018 General Plan and Development Code standards.

The City of Cudahy has an unaccommodated RHNA from 2014 of 154 units in addition to the current RHNA (2021-2029). Within the current (2021) RHNA, there is a shortfall identified from the 2014 adopted Housing Element of 126 units. To satisfy the total unaccommodated (rollover) RHNA of 280 units, the city will re-zone at least 14 acres at a minimum density of 20 units per acre as part of the new General Plan and Development Code update. Per housing element law (Government Code 65583.2[h]), the sites re-zoned to address the lower-income, unaccommodated (rollover) RHNA units will be on sites that are zoned to permit owner-occupied and rental multifamily residential use by right (as defined in Government Code 65583.2[i]) during the planning period. These sites will permit at least 16 units per site at a density of at least 20 units per acre. The sites inventory presented in Table 4.2 includes sufficient sites to address these requirements.

The City will maintain an inventory of available sites for residential development and provide it to prospective residential developers upon request. The city will also conduct ongoing implementation and annual assessment of status of housing sites inventory as part of the annual reporting process.

Government Code §65863 states that no jurisdiction shall “reduce, or require, or permit the reduction of, the residential density for any parcel to, or allow development of any parcel at, a lower residential density, than projected” for sites identified in the Housing Element sites inventory unless the jurisdiction makes written findings that the reduction is consistent with the General Plan, and that the remaining sites identified in the Housing Element are adequate to accommodate the jurisdiction’s need. The City will evaluate residential development proposals

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for consistency with goals and policies of the General Plan specifically as they relate to the housing needs of the community.

Program 2: Housing Information Program
To encourage the development of high-quality housing on vacant and underutilized lots, the City shall establish a promotional campaign to area developers. The campaign shall promote the City of Cudahy and existing investment opportunities. The City shall work with local business groups (such as the Chamber of Commerce and Building Industry Association) on promoting available incentives to new development. This may be accomplished through networking, formal presentations, brochures, ads, and other promotional materials and activities. Staff will also keep informed of state and federal housing programs and provide information to interested residents and groups. The city will work with local early care and education advocates to create an information handout to inform developers, business groups, and households about the available early care and education services. The program will be managed by the Community Development Director and will be updated on an ongoing basis. The program will be funded through the General Fund.

Program 3: Second Unit Ordinance
As part of the comprehensive update to the Development Code, the City will update accessory dwelling unit requirements and regulations within the Development Code to comply with State law – Assembly Bill 2299 and Senate Bill 1069 – in 2018. The Planning Department will monitor the construction of second units annually (coinciding with the fiscal year).

Program 4: Promote Lot Consolidation
Although long-time policy encourages residential lot consolidation to achieve higher quality development, lot consolidation rarely occurs. As part of the comprehensive update to the General plan, the city increased the allowed density in the multi-family residential areas and intensity of nonresidential districts to encourage revitalization and lot consolidation. Within 3 years, the City will establish development incentives and a community benefit permitting procedure that incentivizes benefits and desired public amenities provided by private development, which include, but are not limited to, lot consolidation. In the interim, City staff will provide technical assistance and information to interested developers and post (at the Planning Department and on the city website) the Housing Element Sites Inventory table that identifies lot consolidation potential for residential sites.

Program 5: Affordable Housing Incentives
To encourage the development of affordable housing units, the City shall provide developers with incentives and shorten the permit process for low-income and senior citizen housing projects.

These incentives may be like those awarded for high quality housing projects or developments on larger lots. Or they may involve a different set of parking, open space and density standards

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which lower the cost of development. By expediting the review process, developers also save money and housing costs can be reduced. Within 3 years, the City will establish development incentives and a community benefit permitting procedure that incentivizes benefits and desired public amenities provided by private development, which include, but are not limited to, extremely low-Income and/or affordable housing. In addition, the city provides information on available financing mechanisms and federal, state, and local programs and agencies that provide funding assistance for housing projects. This information shall be made available to developers.

The City will also provide technical assistance and information to interested affordable housing developers and post (at the Planning Department and on the City website) the Housing Element Sites Inventory table that identifies residential development sites and a technical assistance memo on the use of the State’s Density Bonus provisions.

Program 6: CDBG Information Programs
The City shall continue housing programs on housing development, infrastructure, rehabilitation, and job development, as allowed by the CDBG program. The city currently uses its CDBG moneys for the Single Unit Home Improvement program, fair housing foundation services, code enforcement, business assistance program, senior activities/nutrition program, food distribution program and the development of public facilities. It shall coordinate with the County Housing Authority in implementing programs outlined in the Comprehensive Housing Affordability Strategy (CHAS) for Los Angeles County. The city also provides informational brochures outlining available housing assistance and rehabilitation programs in the city. The brochure encourages residents to participate in the housing assistance payments program and the housing voucher program through the Los Angeles County Housing Authority. The program is ongoing, contingent on federal funding availability, and monitored annually (coinciding with the fiscal year) under the Community Development Department and is financed by the General Fund. The city will distribute the information brochure to every City facility.

Program 7: At-Risk Housing Preservation
Subsidized housing units in Cudahy are owned by non-profit affordable housing developers that have expressed a desire to continue renewing their subsidies that allow for the provision of affordable housing. The City shall take the lead in coordinating efforts for the preservation of subsidized housing projects in Cudahy. Every three months, the City will monitor the status of any HUD receipt/approval Notices of Intent and Plans of Action filled by property owners to convert to market-rate units. To help conserve the low-income units at risk of conversion, the city will provide technical assistance to non-profit groups interested in buying the projects. If any of the non-profit affordable housing providers decide to let their subsidized housing contracts lapse, the City will aggressively look for an agency to buy the property or help the residents establish an association to buy the project. the City will also notify all organizations listed on Table 2-15 (page 41) of the availability of property to ensure continued low-income housing. HUD has stated that they generally evaluate projects that apply for conversion and offer incentives to property owners to preserve these units. The California Housing Partnership Corporation (CHPC) has indicated that it will assist Cudahy in looking for a suitable organization who would take over

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the subsidized projects in the city. The City will also provide tenant education within 30 days of notice and assist tenants to obtain special Section 8 vouchers reserved for tenants of converted properties. Public participation shall be encouraged throughout the process to reflect the needs and interests of Cudahy residents. Financing will come from CDBG funds, and the General Fund, to the extent funds are available. Other funding sources that may be available shall be explored, as well. This is an ongoing program monitored (coinciding with the fiscal year) and managed by the Community Development.

Program 8: Housing Maintenance and Conservation
The City of Cudahy has an ongoing program for the maintenance and conservation of the existing housing stock. There are programs aimed at the conservation of older housing units which are in good condition to maintain the units as affordable housing options. Rehabilitation and property maintenance programs ensure that living conditions are safe and decent for all households. By maintaining the existing housing stock and preventing the creation of substandard housing, the city improves the living environment for present residents. Implementation measures for housing maintenance and conservation are discussed below.

Approximately 5 housing units are anticipated to benefit from the City's rehabilitation programs annually. This program is managed by the Community Development Director.

Program 9: Hotel and Motel Resources
The City shall preserve hotels and motels as an emergency housing resource and strictly enforce ordinances regarding property maintenance and fire and safety standards to safeguard the public health, safety, and welfare of tenants. Code enforcement efforts on hotels and motels in the city have led to the upgrading and renovation of two local motels. The city does not allow SRO hotels to be used as permanent housing but will encourage their use as emergency and transitional shelter for the homeless. To encourage the use of hotels by "homeless" individuals, the city continuously works with hotel managers on making rooms available for emergency/transitional housing and makes community service agencies in the area aware of the facilities. The city also refers persons in need to these facilities. Vouchers shall be solicited from the hotel, local businesses, charitable agencies, and other organizations/individuals to provide short-term stays at the hotels. The 160 rooms available in local hotels are adequate to serve the temporary housing needs of homeless individuals in the area. This program is ongoing, implemented, and monitored annually (coinciding with the fiscal year) by the Community Development Department. It is funded by the General Fund, to the extent of available resources. Vouchers and/or allocated funds are searched for on an ongoing basis.

Program 10: Development Standards to Allow Uses
The city has modified its Municipal Code to allow the development, maintenance, and improvement of Emergency Shelters, Transitional Housing, and Supportive Housing to address constraints and facilitate the development of low-income housing throughout the city. The City

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will monitor development of these housing types and re-evaluate the effectiveness or constraints posed by established development standards every two years starting in January 2020.

Program 11: Emergency, Transitional and Supportive Housing The city will continue to monitor the inventory of sites appropriate to accommodate transitional housing and supportive housing and will work with the appropriate organizations to ensure the needs of homeless and extremely low-income residents are met. The city is committed to prioritizing funding and other available incentives for projects that provide housing for homeless and extremely low-income residents whenever possible. This program is funded by the General Fund and managed by the Community Development Department.

Neighborhood Preservation
Neighborhood preservation is seen as a mechanism to increase homeownership in the City, to promote property maintenance, and to maintain a more stable resident population. By improving public services and infrastructure in existing neighborhoods, including available early care and education, the city hopes to provide a more attractive residential environment.

Implementation measures that will help achieve this goal are provided below.

Program 12: Code Enforcement
The City shall continue code enforcement of nuisances such as inoperable vehicles, property maintenance, substandard units, and illegal garage conversions. It shall identify substandard dwelling units and encourage rehabilitation through the provision of technical support and incentives such as streamlined permit processing, variances to development standards on a caseby-case basis, waiver of fees or fines if rehabilitation is undertaken within the next three months, etc. Also, it shall actively work towards the rehabilitation of structures which do not meet seismic safety standards and current electrical code requirements. The City shall coordinate with homeowner's associations in the enforcement of CC&R's regarding property maintenance. This program is ongoing, to be monitored annually (coinciding with the fiscal year) and will continue to be financed through CDBG funds. The Code Enforcement Program is complaint driven; complains are filed with the City’s Code Enforcement department which then schedules follow up inspections and provides tenants with information to resources.

Program 13: Infrastructure Availability
The City shall work with Los Angeles County to identify and coordinate water and sewer infrastructure on the provision of adequate infrastructure and public services in Cudahy, Consistent with the General Plan Implementation program, the City will establish a permit tracking program by June 2019 that monitors new development and the redevelopment of existing uses that increase the number of residential unit and/or nonresidential square footage.

The City will annually review the permit tracking data to determine levels of infrastructure need to ensure appropriate levels of circulation, water, sewer, storm drainage, and other utilities’

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availability and capacity. In addition, the City will establish specific procedures and require that priority is given to developments with units affordable to lower-income households.

The city will pursue a study to evaluate current and potential impact fees from new development for infrastructure improvements and other public facilities to offset the impact of new development.

Program 14: Public Participation Program
The city encourages community participation in all city programs. Noticing practices in the city include posting information on scheduled public hearings at City Hall, the Cudahy Library, and the Council Chambers at least two weeks prior to the hearing dates. The city also advertises these hearings, as well as other city programs, in the local newspaper (The Wave) and in the city newsletter. Both papers use English and Spanish in their articles to reach the primarily Hispanic Community of the area. An interpreter is also available during public hearings to facilitate communication between individuals who only speak Spanish. Brochures at City Hall are available in both English and Spanish versions. Spanish-speaking employees also facilitate the dissemination of information regarding city programs. It shall encourage residents to attend City Council and Planning Commission meetings by increased publicity practices. This will allow the city to get more input into its programs and tailor them to meet the needs expressed by residents. Public workshops have been conducted in the General Plan's revised goals and policies and Draft Land Use Plan to solicit resident concerns. Public hearings will continue to be held prior to adoption of the General Plan, including this Element. This will allow the city to better respond to the concerns and interests of Cudahy residents. This program is ongoing, to be monitored annually (coinciding with the fiscal year) and funded by the General Fund as services are contracted and staff time.

The City will also actively produce documents and publications that are in both English and Spanish. This is an ongoing program monitored annually (coinciding with the fiscal year) by the Community Services Department. It is funded by the General Fund, to the extent available, and staff time.
*The Housing Element Update Draft was made available online October 10, 2021.

Program 15: Fair Housing Program
There are many special needs households in Cudahy that will benefit from programs designed to promote equal access and opportunity to housing. The city intends to minimize difficulties of special needs households in finding adequate housing by providing programs to prevent discrimination or to encourage the production of housing specifically designed for these households.

The city promotes the use of the Housing Rights Center through the City newsletter and local papers and informs all city employees of the available services for referral. The city will participate and distribute fair housing materials at a variety of community activities such as food

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distribution, Easter egg hunt, national night out, and local carnivals/fairs to reach out to all segments of the community. The city will annually conduct fair housing press releases, directly contact interested groups for distributing fair housing materials, mail fair housing materials through utility billing and post fair housing information in a variety of community locations such as the library, bus stops, public counters, and post office. The City shall prepare a list of referral agencies to serve low-income households, handicapped, elderly, homeless, and other special needs groups. Information is given through Code Enforcement and City Housing Department. It shall make the list available at City Hall, the library and City parks for interested persons.

Financing will be provided through the General Fund and CDBG funds.

Program 16: Food Distribution Program
The City shall continue the hot meals and food distribution programs the 4th Thursday of every month. Also, it shall assist public and non-profit agencies which provide support services to special needs populations (the homeless, the elderly, single-parent households, etc.). The food distribution program is ongoing, to be monitored annually (coinciding with the fiscal year) and financed through the CDBG program.

Program 17: Homeless Assistance Program
The City shall maintain a list of local social services to use as referral sources for residents in need.

The information will be distributed to City departments that interface with homeless persons or persons at risk of being homeless.

Program 18: Handicapped Access
The city currently requires new development to comply with State standards for handicapped access. It shall also enforce the recently adopted American with Disabilities Act. This program is implemented by the Department of Building and Public Services with funding from the General Fund. The city adopted the Los Angeles County Building Code in March 2013, which includes standards for ADA compliance.

Program 19: Senior Shared Housing Program
The senior’s Center on Clara Park serves as an information center for senior programs and resources. This is an ongoing program monitored annually (coinciding with the fiscal year) by the Community Services Department with funding from the General Fund.

Program 20: Persons with Disabilities, including Developmental Disabilities Program The city shall seek State and Federal monies, as funding becomes available, in support of housing construction and rehabilitation targeted for persons with disabilities. The City shall provide regulatory incentives, such as expedited permit processing and fee waivers and deferrals, to projects targeted for persons with disabilities, including persons with developmental disabilities.

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The City shall reach out annually to developers of supportive housing to encourage development of projects targeted for persons with disabilities, including persons with developmental disabilities. The City shall work with the local Regional Center to implement an outreach program informing families within the City of housing and services available for persons with developmental disabilities. Information will be made available on the City’s website and at City Hall counter. Specific regulatory incentives shall be established by 2019 and initiation of cooperative outreach program with the local Regional Center by December 2018, with funding from the General Fund and other sources available.

Program 21: Consistency with General Plan
The City shall conduct an integral review as part of its General Plan implementation to achieve consistency with other general plan elements, policies, programs, and community goals to reflect the policy direction contained in other parts of the General Plan. As portions of the General plan are amended in the future, this Housing Element will be reviewed to ensure that internal consistency is maintained. This is an ongoing program monitored annually (coinciding with the fiscal year) and managed by the Community Development Director and Planning Departments.

7.2 PROPOSED QUANTIFIED OBJECTIVES FOR 2021-2029
Local jurisdictions are required under section 65583 of the California Government Code to propose quantified housing objectives and seek to meet them through Housing Element goals, policies, and programs. The quantified objectives do not represent a ceiling on development, but rather set a target goal for the jurisdiction to achieve based on needs, resources, or constraints.

The quantified objectives of the city by income category are provided in table below. The City’s objective is to allow the construction of at least 339 new units; from very low to above moderateincome levels. And to rehabilitate 8 very low and 8 low-income level properties, totaling in 56 rehab units over the seven-year implementation phase.

7.2 Proposed Qualified Objectives for 2021-2029
Income Category
New Construction Rehabilitation
Conservation/Preservation
Extremely Low 117 10 10
Very low 117 9 9
Low 46 9 9
Moderate 51 0 0
Above Moderate 141 0 0
TOTALS 472 28 28
Source: City of Cudahy Community Development Department

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8 Affirmatively Furthering Fair Housing (AFFH) AB 686
List of Charts, Tables, and Maps
Map 8.1 Public Housing Buildings – Regional Page...................................................................138 Map 8.2 Public Housing Buildings – Cudahy Page...................................................................139 Map 8.3 Percentage of FHEO Case Reported in County 2010 Based on Race Page .................141 Map 8.4 Percent White Population Page.....................................................................................142 Map 8.5 Predominant Population Hispanic Majority Page...........................................................143 Map 8.6 Fair Housing Vouchers by Tract – Cudahy Page .........................................................144 Map 8.7 Fair Housing and Equal Opportunity Inquiries by City Page ........................................145 Map 8.8 Fair Housing and Equal Opportunity Cases – Total (2010) County Page ......................146 Map 8.9 FHEO Cases with Disability Bias 2010 Page...................................................................147 Map 8.10 FHEO Total Cases 2010 by County Page........................................................................148 Map 8.11 FHEO Cases with Racial Bias by County 2020 Page.......................................................149 Map 8.12 FHEO Cases with Disability Bias – 2020 – County Page ................................................150 Map 8.13 Population with Disability – 2015-2019 by Tract Page .................................................151 Map 8.14 Percent of Population Below the Poverty Level – 2015-2019 by Census Tract Page ...152 Map 8.15 Median Income 2015-2019 by Block Group Page.........................................................153 Map 8.16 Percent of Children in Female Householder, No Spouse / Partner Present Households (ACS, 2015-2019) Tract Page.....................................................................154 Map 8.17A Percent of Population 18 Years and Over in Households Living with Spouse (ACS, 2015-2019) Tract Page.........................................................................................155 Map 8.17B Percent of Population 18 Years and Over in Households Living Alone 2015-2019 Page 156
Map 8.18 Children in Married – Couple Households (ACS, 2015-2019) Tract Page .....................157 Map 8.19 Neighborhood Segregation (US Berkeley, 2019) Tract Page ........................................158 Map 8.20 Diversity Index (2010) Block Group Page......................................................................159 Map 8.21 Diversity Index 2018 (ESRI) Page..................................................................................160 Map 8.22 Racial Demographic 2010 Block Group Page ................................................................161 Map 8.23 TCAC Opportunity Areas 2021 – Composite Score – Tract Page ..................................162 Map 8.24 TCAC Opportunity Score Areas 2021 – Economic Score – Tract Page ..........................163 Map 8.25 TCAC Opportunity Areas 2021 Environmental Score by Tract Page.............................167 Map 8.26 TCAC Opportunity Areas 2021 Education Score – Tract Page ......................................168 Map 8.27 Overcrowded Households (CHHS) Tract Page...............................................................169 Map 8.28 Overpayment by Homeowners (ACS, 2015-2019) Tract Page ......................................170 Map 8.29 Overpayment by Renters (ACS, 2010-2014) Tract Page .................................................171 Map 8.30 Location Affordability Index (HUD) Tract Page .............................................................172 Map 8.31 Sensitive Communities (UCB, Urban Displacement Project) Page ...............................173 Map 8.32 Areas of High Segregation and Poverty (2021) Tract Page...........................................174 Map 8.33 Social Vulnerability Index (CDC, 2018) Tract Page........................................................175 Map 8.34 Mobil Home Parks (HIFLD, 2018) Page .........................................................................176 Map 8.35 CalEnviroScreen 4.0, 2021 – Tract Page........................................................................177 Map 8.36 SB 535 Disadvantaged Communities Page....................................................................179 Map 8.37 Healthy Places Index (PHASC, 2021) Tract Page ...........................................................180

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Table 8.1 Housing Choice Vouchers by Census Tract Page...........................................................140 Table 8.2 Fair Housing and Equal Opportunity Inquiry (FHCO) Page ...........................................140 Chart 8.1 Percent of Households in Renter – Occupied Housing Units (HUD) Tract Page ..........170

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As stated earlier, as of January 1, 2019, AB 686 extends the obligation to affirmatively further fair housing to all public agencies in the State of California. Affirmatively furthering fair housing means taking meaningful actions to combat discrimination that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. The Bill added an assessment of fair housing to the Housing Element which includes the following components:
(1) a summary of fair housing issues and assessment of the City’s fair housing enforcement and outreach capacity,
(2) an analysis of segregation patterns and disparities in access to opportunities, (3) an assessment of contributing factors, and
(4) an identification of fair housing goals and actions.

This Housing Element analysis, therefore, must address the following:
(1) Significant discrepancies in housing needs and in access to opportunities, (2) Replacing segregated living patterns with truly integrated and balanced living patterns, (3) Transforming racially and ethnically concentrated areas of poverty (R/ECAP) into areas of opportunity,
(4) Fostering and maintaining compliance with civil rights and fair h housing laws.

Public Housing Program
According to HUD’s Public Housing Program, public housing was established to provide decent and safe rental housing for eligible low-income families, the elderly, and persons with disability.

Public housing comes in all sizes and types from scattered single-family houses to high-rise apartments for elderly families. In the State of California, there are approximately 1.2 million households living in public housing units, managed by about 3,300 housing agencies (HAs) In the County of Los Angeles, the Los Angeles County Development Authority manages public housing programs for the City of Cudahy and some of the Gateway Cities. As indicated on Map 8.1 and Map 8.2, there are no recognized public housing buildings in the City of Cudahy.

Map 8.1 – Public Housing Buildings – Regional

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Map 8.1 above, indicates that there are public housing buildings located within the Los Angeles County area and regionally. However, Map 8.2, below shows there are no recognized public housing buildings in the City of Cudahy.

Map 8.2- Public Housing Buildings Cudahy

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As indicated on Map 8.2, there are no recognized public housing buildings in the City of Cudahy.

However, this does not preclude the residents of the city from access to building housing as the city is enrolled in the Section 8 program offered through the State of California and the county of Los Angeles.Housing Choice Vouchers
The U.S. Department of Housing and Urban Development’s (HUD) Housing Choice Voucher (HCV) Program assists very low-income families, the elderly, and the disabled in obtaining decent, safe, and sanitary housing in the private market. Public Housing Authorities (PHAs) receive federal funds from HUD to administer the voucher program, and housing subsidies are paid to the landlord directly by the PHA on behalf of the participating family. The voucher recipient remains responsible for paying any difference that exists between the actual rent charged by the landlord and the amount subsidized by the program. Voucher recipients are responsible for finding a suitable housing unit where the owner agrees to rent under the program. Because housing assistance is provided on behalf of the family or individual, participants are free to choose their own housing, including single-family homes, townhouses, and apartments provided that the chosen housing meets the requirements of the program, and is not limited to units located in subsidized housing projects. Qualified housing may also include the family's present residence.

Furthermore, under certain circumstances, and if authorized by the PHA, a family may use its voucher to purchase a modest home. To protect the confidentiality of those receiving Housing Choice Voucher Program assistance, tracts containing 10 or fewer voucher holders have been

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omitted from this service. This dataset includes both tenant-based vouchers and project-based vouchers.

There are six Census Tracts in the City of Cudahy, namely: 6037534401, 6037534302, 60375344403, 6037534404, 6037534405, and 6037534406. In all the census tracts, there were 168 Housing Choice vouchers reported. Table 8.1, provides a breakdown by Census Tract and percentage of population by Census Tract:

Table 8.1 – Housing Choice Vouchers by Census Tract
Census Tract # Of Housing Choice Vouchers Percentage % of Population 6037534301 24 2.65
6037534302 29 4.30
6037534403 59 8.44
6037534404 12 1.38
6037544405 44 4.78
6037534406 0 0
Table 8.1 indicates that the highest utilization rate for Housing Choice Vouchers occurs in Census Tract 603754403 with 59, representing 8.44% of the Census Tract population. There are no apparent policy implications for the city of Cudahy other than to continue to understand and provide necessary assistance to the members of its community that need housing assistance. The city’s department of community development is aware of these discrepancies and will monitor and support the population in need of housing assistance.

Fair Housing and Equal Opportunity (FHEO) Inquiries 2013-2021 Between 2013 and 2021, there was one (1) Fair Housing and Equal Opportunity inquiry in the City of Cudahy. In 2010, the number of Fair Housing and Equal Opportunity inquiries in Los Angeles County was 291. 80 of those cases, or 25% were with a racial bias, 106 of the cases or 36.4% had a disability bias. 58 of the cases, or 20% had a familial status bias. In 2020, there were 130 total cases reported. 27, or 20.7% of the cases had a racial bias, 86, or 66% had a disability bias, and 9, or 7% had a familial status bias. Table 8.2 depicts the comparison between 2010 and 2020.

Because there was only one (1) Fair Housing and Equal Opportunity inquiry in the city of Cudahy in 2021 does not necessarily indicate that there were no intentions to file such inquiry. The population demographics of the city (almost 100%) Latino/Hispanic could be indicative of need to not file at least at the racial bias level. However, there are disabled persons in the city and there were no filings based on disability. The city will continue to provide resources and access to information through the Community Development Department and other non-city and nonprofit organizations who have championed this cause.

Table 8.2 Fair Housing and Equal Opportunity Inquiry

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County Data
Year
Total
Cases
Cases with Racial Bias
and %
Cases with Disability
Bias and %
Cases with Familial
Bias and %
Los Angeles
County 2020
130 27 or 20.7% 86 or 66% 9 or 7%
Los Angeles
County 2010
291 80 or 25% 106 or 36.4% 58 or 20%
Map 8.3 – Percentage of FHEO case reported in county 2010 based on race Map 8.3 above is a map of the county of Los Angeles showing the percentage of Federal Housing and Equal Opportunity cases based on race. Looking at the geographical location of the city of Cudahy from the county map, it appears that the cases reported in the city fall within the 20.% to 30% range, which is low compared to the rest of the county.

Segregation and Integration
The population of some areas in the United States is dominated heavily by one racial or ethnic group. In the City of Cudahy, the predominant racial or ethnic group is Hispanic or Latino,

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comprising of over 96% of the population. The while population percentage (%) was 1.47% and the black population percentage (%) was 1.28%.

Map 8.4 – Percent Non-White Population
Map 8.4 indicates that the city of Cudahy is within the 81% to 100% bracket of the county and region’s non-white population. As stated earlier, the city of Cudahy is predominantly Latino/Hispanic with 96% of its residents being Latino/Hispanic. The population makeup of the city of Cudahy is not based on a particular policy of the city to intentionally attract Latino/Hispanic people into its boundaries. What the city is experiencing with its population is indicative of the historical migration patterns and opportunities available to people of Latino/Hispanic origins.

Cities like Cudahy, without sound economic and fiscal practices could end up with gentrification of its residents. The city is aware of this and the fact that gentrification is a market-driven phenomenon which cannot be excluded through legislation.

Map 8.5 – Predominant Population Hispanic Majority

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Map 8.5 supports map 8.4 in identifying the city of Cudahy as a predominantly Latino/Hispanic community. The percentage of Latino/Hispanic residents in the city is above the state of California Latino/Hispanic population of 39.4%. The percentage of Latino/Hispanic population in the county of Los Angeles is 48%. Based on the city’s socio-economic profile, Cudahy may benefit from county and state programs to help Latino/Hispanic communities.

Map 8.6– Fair Housing Vouchers by Tract - Cudahy

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Based on Map 8.6, Fair Housing by Tract Cudahy, indicates that majority of the city is within the 0% to 5% category, which a smaller portion of the city is within the 16% to 30% category. This indicates that compared to the region, about 30% of the city’s residents file for Housing Vouchers compared to 70% that do not. Again, the city of Cudahy has policies in place to help residents with housing needs.

Map 8.7 – Fair Housing and Equal Opportunity Inquiries by City

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Map 8.7 above, indicates that there were less than 0.25 Fair Housing and Equal Opportunity inquiries per thousand population in the City of Cudahy between 2013 and 2021. With a population of approximately 14,000 residents, the number of inquiries is as low as zero and as high as 3.5. This number is extremely low compared to communities where the number of fair Housing and Equal Opportunity inquiries as are high as 1 per thousand population. The number of inquiries by population is not necessarily indicative of a fair Housing and Equal Opportunity issue that needs to be addressed. Rather, it could be indicative of the availability of resources and information regarding the Fair Housing and Equal Opportunity issues.

Map 8.8 – Fair Housing and Equal Opportunity Cases – Total (2010) County

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According to map 8.8, the number of Fair Housing and Equal Opportunity cases in the county of Los Angeles in 2010 ranged from zero cases to 291 cases. The discussions under Map 8.7 already addresses the cases in the city of Cudahy and the accompanying policy implications.

Map 8.9 – FHEO Cases with Disability Bias 2010

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Map 8.9 shows the FHEO cases with disability implications filed in 2010 in the county of Los Angeles. The map indicates that the number of cases filed range from 0% to 100% with the city of Cudahy represented within the 45% to 80% range. This indicates that more residents of Cudahy filed FHEO disability cases than they filed for racial bias. This is not surprising because most of the residents of Cudahy represent as Latino/Hispanic which would reduce the number of racial bias cases. Because of the moderate to high percentage of disability bias cases filed in 2010, the city implemented policies to address housing issues faced by people with disability.

Looking at the FHEO disability bias cases filed in 2020 (Map 8.11), it does not appear that any of the city’s policies have yielded a decrease in the number of disability bias cases filed. Therefore, the city is encouraged to enforce its existing policies or implement new policies with identifiable goals to reduce the FHEO disability cased filed in the city.

Map 8.10 – FHEO Total cases 2010 by County

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Map 8.10 – FHEO Cases with racial bias by County 2020
From Map 8.10, FHEO Cases with Racial Bias – 2020 – County, there is no discernible difference between the number of cases filed in 2010 and 2020. This is indicative of the soci0-demographic makeup of the city and does not require any imminent policy changes.

Map 8.11 – FHEO Cases with Disability Bias – 2020 – County

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In assessing the number of disability bias cases filed in 2020 as indicated in Map 8.11, compared to 2010 cases filed in the same category (Map 8.9), we see no discernable difference. This might indicate that the population of disabled residents in the city has not changed, or that the city’s policy(ies) addressing the issue have not affected the expected outcome.

Map 8.12 – Population with a Disability – 2015 - 2019 By Tract

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In Map 8.12, Population With a Disability by Tract – 2015 – 2019, it is observed that most of the residents of Cudahy report disability in the range of 0% to 10%. Only one census tract reports disability within the 11% to 20% range. Compared to the county overall population of people with disability, the occurrence reported in Cudahy is low. The 2020 percentage of disabled population in the United States is 26%, and in the state of California, the percentage is 10.4%. In the county of Los Angeles, the percentage of disabled population is higher with the county reporting that 32.5% of residents in the county with a Bachelor’s degree or people aged 25+ report a disability. This number is significantly higher (79.1%) with population with high school diploma. The implication for Cudahy is that the community is not significantly different from the state of California in this category, but the city must address any housing-related issues affecting the population with disability within the community.

Map 8.13 – Percent of Population Below the Poverty Level- 2015 – 2019 By Census Tract

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Map 8.13, Percent of Population Below the Poverty Level- 2015 – 2019 By Census Tract, indicates most of the city is reported to be within the 21% to 30% below poverty level range. There is only one census tract that reports at the 41% to 100% below poverty level range. This indicates that for most of the city, 21% to 30% of residents live below the poverty level, and 70% to 89% live above the poverty level compared to the region. There are no discernible policy changes to be made other than stating the fact that a changing population educational achievement will decrease the poverty rate in the city. In comparison, the poverty rate among adults in Los Angeles county is 14.9%. In the state of California, the poverty rate is 16.4%. The poverty rate in the city of Cudahy is higher than the county of Los Angeles and the state of California.

The Economic security programs such as social security food assistant, tax credits, and housing assistance can help provide opportunity by ameliorating short-term poverty and hardship and, by doing so, reduce children’s long-term outcomes.

Map 8.14 - Median Income 2015 2019 By Block Group

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Map 8.14, Median Income 2015 2019 By Block Group indicates that most of the city of Cudahy is within the less than $55,000.00 median household income bracket. This figure is low compared to the county because the county median income includes very affluent cities like Beverly Hills and Los Angeles where the median incomes are very high. The policy implication for the city of Cudahy is that the city must ensure that information on social services for residents with low incomes must be made available to residents who need them. The city must also ensure that existing government programs for low-income residents are not discontinued, and if discontinued, replaced with similar or better programs.

Map 8.15 – Percent of Children in Female Householder, No Spouse/Partner Present Households (ACS, 2015-2019) – Tract

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Map 8.15, Percent of Children in Female Householder, No Spouse/Partner Present Households (ACS, 2015-2019) – Tract identifies two census tracts with 14% to 18% of its residents within the category, and two other census tracts within 21% to 40% category. The policy implication for the city is that programs must be enhanced for early child education and care to ensure that children in these households do not fall behind socially or in their educational achievements later in life.

Map 8.16 – Percent of Population 18 years and Over in Households Living with Spouse (ACS, 2015-2019) Tract

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In Map 8.17, Percent of Population 18 years and Over in Households Living with Spouse (ACS, 2015-2019) Tract, we observed that one of the six tracts in the city falls within the 41% to 60% range, while the five other census tracts were in the 21% to 40% range. Cumulatively, between 21% and 60% of the city’s population 18 years and over live in households with their spouses.

The policy implications for the city are that programs needs to be implemented to address the needs of the city’s population with spouses.

Map 8.17 – Percent of Population 18 years and over in Households Living Alone 2015 – 2019

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Map 8.17, Percent of Population 18 years and over in Households Living Alone 2015 – 2019, is very similar demographically to the data in Map 8.16 which is the percent of population 18 years and over in households living with a spouse. It indicates that the city is split almost equally between those living alone and those 18 years old and over living with a spouse. The policy implications for the city are that programs need to be implemented to address the needs of single people 18 years old and over and those 18 years old and over living with a spouse.

Map 8.18 – Neighborhood Segregation (UC Berkeley, 2019) – Tract

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Map 8.19, Neighborhood Segregation (UC Berkeley, 2019) – Tract, indicates that the city of Cudahy is mostly Latino/Hispanic.

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Map 8.19 – Diversity Index (2010) Block Group
In Map 8.19, Diversity Index (2010) Block Group, Diversity Index prepared by the Environmental Systems Research Institute (ESRI) shows 100% of the city is within the higher diversity category.

ESRI’s diversity index captures the racial and ethnic diversity of a geographical area in a single number ranging from 0 to 100. The Diversity Index allows for efficient analysis and mapping of seven race groups that can be either of Hispanic or non-Hispanic origin. The Diversity Index from ESRI represents the likelihood that two persons, chosen at random from the same area, belong to different race or ethnic groups. Ethnic diversity, as well as racial diversity, is included in the definition of the Diversity Index. ESRI's diversity calculations accommodate up to seven race groups: six single-race groups (White, Black, American Indian, Asian, Pacific Islander, Some Other Race) and one multiple-race group (two or more races). Each race group is divided into two ethnic origins, Hispanic and non-Hispanic. If an area is ethnically diverse, the racial diversity is compounded. The Diversity Index is available down to the block group level geography and ranges from 0 (no diversity) to 100 (complete diversity). If an area's entire population belongs to one race group and one ethnic group, then an area has zero diversity. An area's diversity index increases to 100 when the population is evenly divided into two or more race/ethnic groups. The

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United States had a 2010 Diversity Index of 60.6, based on census counts. Based on ESRI’s diversity index, the City of Cudahy is considered diverse even though it has limited White population because of the number of Latino/Hispanic groups within its population.

There are no discernable policy implications for the city in this category.

Map 8.20- Diversity Index 2018 (ESRI)
Map 8.20, Diversity Index 2018 (ESRI), which is an update to Map 8.19 prepared in 2010, it is clear that the city of Cudahy’s diversity status has not changed.

Map 8.21 – Racial Demographic 2010 Block Group

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Map 8.22, Racial Demographic 2010 Block Group, shows the city is in the 0% to 20% non-white population category, which supports the predominantly Latino/Hispanic character of the city’s population.

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Map 8.22 – TCAC Opportunity Areas 2021 – Composite Score – Tract TCAT refers to the California Tax Credit Allocation Committee map. Map 8.22, TCAC Opportunity Areas 2021 – Composite Score – Tract, indicates that the City of Cudahy is divided into two composite scores, “high segregation and poverty”, and “low resources”. The California Tax Credit Allocation Committee (TCAC) facilitates the investment of private capital into the development of affordable rental housing for low-income Californians. TCAC allocates federal and state tax credits to the developers of these projects. The composite score is an indication of the amount of federal and state tax credits that would be allocated to developers of projects.

Areas with low resources scores get more tax dollar assistance than areas with high resource scores. Based on this definition, the developers of affordable housing in the City of Cudahy will receive federal and state tax dollars for the development of affordable housing.

Opportunity mapping is a way to measure and visualize place-based characteristics linked to critical life outcomes, such as educational attainment, earnings from employment, and economic mobility. Opportunity maps can be used to inform how to target investments and policies in a way that is conscious of the independent and inter-related effects that research has shown places have on economic, educational, and health outcomes. Opportunity mapping also has limitations.

For example, the accuracy of maps is dependent on the accuracy of the data behind them. Data

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may be derived from self-reported surveys of subsets of an area’s population, and sometimes may not be recorded or reliable in some areas. Further, even the most recent publicly available datasets typically lag by two years, meaning they may not adequately capture conditions in areas undergoing rapid change.

TCAC and HCD charged the Task Force with creating an opportunity map to identify areas in every region of the state whose characteristics have been shown by research to support positive economic, educational, and health outcomes for low-income families—particularly long-term outcomes for children. TCAC intended to adopt this map into its regulations, which it eventually 2 did in December 2017, to accompany new policies aimed at increasing access to high opportunity areas for families with children in housing financed with 9% Low Income Housing Tax Credits (LIHTCs). For this reason, the Task Force designed this map and the methodology behind it with the funding infrastructure for the 9% LIHTC program (e.g., geographic competition, a separate funding pool for rural applicants), as well as that of key HCD funding programs such as the Multifamily Housing Program, in mind.

Map 8.24 – TCAC Opportunity Score Areas 2021 – Economic Score – Tract

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Map 8.23 identifies the economic score for the City of Cudahy based on tract. One tract, located south of the city, has a 0.51 – 0.75 economic demand score, two tracts to the north and northeast of the city have a less than 0.25 score, while two tracts located west, and northwest of the city have a 0.25 – 0.50 score. In this category, not all the City of Cudahy is the same.

On the issue of environmental health, Map 8.24 identifies three distinct categories for the City of Cudahy: 0.74 – 1.00, 0.25 – 0.50, and 0.01 – 0.25.

Indicators used in the TCAC/HCD Opportunity Map index were selected based on the following criteria:
● Evidence from peer-reviewed research that the indicator is linked to improved life outcomes for low-income families, particularly children
● Reliable data
● Publicly available data
Each census tract or rural block group receives a score for each indicator, except where data is missing. To account for the fact that each indicator is measured differently (e.g., percent versus dollar amount), a unit-less “z-score” is calculated for each indicator within each region. These tract level z-scores are averaged together by domain (with each indicator’s score receiving an equal weighting), and the three domain scores are then averaged together to create an index score.

ECONOMIC DOMAIN
Poverty Indicators
Tract-level poverty rates have been shown through numerous studies to be a strong indicator of an area’s level of resources, risk, and opportunity, and predictor of key life outcomes for lowincome children in particular. Living in high-poverty areas increases exposure to localized risks— such as violent crime, low-quality and underfunded schools, and pollution—that have been shown to contribute to toxic stress, poor physical and mental health, low educational attainment, and impaired cognitive development in children. On the other hand, living in low poverty areas has been shown to generate significant benefits such as higher educational attainment and longterm earnings increases for low-income children, as well as improved mental and physical health for both children and adults.

The Task Force chose to use 200 percent of the poverty line to reflect the higher cost of living in California. Because each indicator in this domain is designed to measure opportunity in a positive sense, this indicator is measured as the percent of a tract’s or rural block group’s residents who live above 200 percent of the federal poverty line.

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The tract-level share of adults that have earned a bachelor’s degree has been shown to be highly correlated with rates of upward economic mobility for low-income children. Adult unemployment is commonly considered to be an indicator of neighborhood disadvantage that affects not just the individuals who do not have jobs, but members of the entire community.

Areas with low levels of employment see outcomes like those with high poverty rates, including poor health outcomes, low birthweight babies, and violent crime. The employment rate was calculated as the percent of individuals in each tract and rural block group age 20-64 who are employed in either the civilian labor force or the armed forces. The Task Force opted to use the employment rate because the unemployment rate does not account for individuals who have dropped out of the labor force due to disillusionment with their job prospects.

Proximity to Jobs Indicator
Proximity to jobs—particularly to jobs that may be accessible to a low-wage or low- to moderateskill worker—is an important place-based attribute according to the “spatial mismatch hypothesis,” which maintains that communities can experience poor labor market outcomes because of the lack of nearby jobs with skill-levels and qualifications appropriate for those community members. According to this literature, the labor market, and the jobs that they can potentially fill are geographically “mismatched.”,
Accounting for proximity to low- and mid-skill jobs in the construction of the overall opportunity index helps avoid this spatial mismatch in the location of affordable housing. This indicator was calculated in two stages. The first stage uses Longitudinal Employer-Household Dynamics OriginDestination Employment Statistics (LEHD-LODES) data from 2017 to calculate the populationweighted median distance traveled by workers earning $1,250 a month or less (or the equivalent of $15,000 a year). In non-rural areas, the median distance is calculated by region. For rural areas, the median distance is calculated based on all rural areas in the state, to reflect their greater typical travel distances. The Task Force chose this benchmark in recognition that low-wage workers tend to commute shorter distances than higher-wage employees due to constraints on mode and cost of travel. (Note, this is not the same as saying low-wage workers spend less time commuting. The same limitations that constrain commute distances--for example, reliance on public transit--may lead to longer travel times for the working poor.)

ENVIRONMENTAL DOMAIN
The environmental domain relies on twelve of the indicators that are used in the California Office of Environmental Health Hazard Assessment (OEHHA)’s CalEnviroScreen 3.0 tool under the “exposures” and “environmental effect” subcomponents of the “pollution burden” domain. To mirror the CalEnviroScreen 3.0 approach to calculating pollution burden scores, the exposure indicators are weighed twice as heavily as the environmental effects burden indicators because they are considered to have more of an impact on pollution burden.

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The indicators for each category are listed below: Exposure indicators:

1. Ozone Concentrations

2. PM2.5 Concentrations

3. Diesel PM Emissions

4. Drinking Water Contaminants

5. Pesticide Use

6. Toxic Releases from Facilities

7. Traffic Density Environmental effects indicators:

8. Cleanup Sites

9. Groundwater Threats

10. Hazardous Waste Generators and Facilities

11. Impaired Water Bodies

12. Solid Waste Sites and Facilities
The indicators were selected based on scientific literature that confirms their detrimental effects on human, and especially child, health; the completeness, accuracy, and currency of the data; and the widespread concerns about each indicator in California. CalEnviroScreen 3.0 was developed to support the Affordable Housing and Sustainable Communities program and other programs that allocate funding from sale of cap and-trade revenue, but it is explicitly acknowledged as a tool that can be used for a variety of policy and planning purposes.

One limitation of the environmental quality indicators is that the levels of a pollutant are generally measured at a limited number of points statewide; the levels of the pollutant are then estimated for other areas that are not immediately adjacent to the measurement site.

Additionally, there are some indicators which may have a large impact in one area of a census tract, but which could have only a marginal effect at another location in the same census tract.

This is particularly true of stationary polluting sources (for example, impaired water bodies like lakes), where the impact decreases as the distance from the site decreases. Note that, because this set of indicators moves in the opposite direction compared to the other two domains (i.e., larger shares on these indicators would reflect a negative outcome for the tract whereas larger shares for other measures—adults with at least a bachelor’s degree, for example—indicate a positive outcome), the additive inverse of this domain score is calculating the final index score.

EDUCATION DOMAIN
Math and Reading Proficiency Indicators
Elementary school test scores from 3rd and 4th grade are considered in the literature to be strong proxies for the level of resources and opportunity during early childhood both in local schools and more broadly in communities. Indeed, studies have shown that test scores should be understood as an output of students’ neighborhood conditions—such as whether they live in a high-poverty or high-crime area—and not only of students’ individual abilities and family backgrounds, or the quality of the schools they attend. Further, test scores and other measures

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of school quality are highly correlated with upward mobility for low-income children. Proficiency on elementary school-age standardized tests is also a strong predictor of whether individual children will eventually graduate high school, which itself is associated with higher long-term earnings and other social benefits compared to dropping out. “Proficiency” is defined as the percent of students that are performing at grade-level in the 4th grade in each school. Math and reading proficiency scores are calculated as the enrollment weighted average proficiency level of students at the three closest schools, within the same county, to each census tract’s centroid.

The Task Force utilized the average value from three schools because our methodology does not account for school assignment boundaries, which are different from census tract boundaries. This approach does have limitations, including that student will attend only one of the three closest schools, so the quality of the school they attend may differ somewhat from the average score that is calculated in each census tract. In addition, it does not account for non-neighborhood school district assignment policies. However, the academic literature suggests that low-income students are more likely to attend their neighborhood schools even when they have a choice to go elsewhere—and that choice-based assignment policies can have the effect of worsening school segregation. High School Graduation Rate Indicator Low graduation rates indicate that schools are not preparing students for the workforce. Students who do not graduate from high school face a variety of challenges later in life, including an increased risk of going to prison and lower wages than their classmates who graduate. In addition, high schools with lower graduation rates have also been found to have disciplinary practices that negatively impact low-income and minority youth as well as lower levels of teacher engagement. The high school graduation rate indicator is calculated based on the cohort-weighted average of the three high schools nearest to the tract or rural block group centroid, using California Department of Education data on the percent of students who graduate in four years.

Student Poverty Indicator Studies have consistently shown that attending low-poverty and economically integrated schools boosts educational achievement for low-income students, when compared to attending higher poverty schools. Recent studies have found that the disparity in school poverty rates that Black and white children experience is the primary mechanism through which racial segregation in schools translates to Black-white academic achievement gaps.

However, racial integration in schools provides benefits to low-income students and students of color that both overlap and complement the benefits of economic integration in the classroom— including higher levels of educational attainment, reductions in prejudice and negative attitudes across racial groups, and long-term improvements in earnings, health, and rates of incarceration—all while producing no detrimental effects for white children. As with the math and reading proficiency indicators, the Task Force averaged the attributes, weighted by school enrollment, from the three closest schools to the centroid of each census tract to develop the tract level score. And similar to the poverty indicator in the economic domain, school poverty rates are measured as the percent of students that do not receive free and reduced-price lunch, to better align with the opportunity-oriented constructions of the other variables in this domain.

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Map 8.24 – TCAC Opportunity Areas 2021 Environmental Score by Tract Map 8.25, TCAC Opportunity Areas 2021 Environmental Score by Tract, we deduce that the city’s six census tracts fall within three environmental scores namely 0.01 to 0.25, 0.26 to 0.50, and

0.51 to 0.73. The Environmental Score in an indication of general environmental well-being based on exposure to the 12 exposure indicators identified above. The higher the score, the lower the environmental health of the community. With the city of Cudahy having an environmental score of 0.51 to 0.73 in some of its census tracts, those census tracts are considered less healthy than the SCAG region and the state.

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Map 8.25 – TCAC Opportunity Areas (2021) Education Score – Tract With Map 8.25 – TCAC Opportunity Areas by Education Score – Tract, we deduce that there are three distinct education score categories encompassing the city’s six census tracts. They are the

0.01 to 0.25 Educational Score Domain, the 0.25 to 0.50 Educational Score Domain, and the 0.51 to 0.73 Education Score Domain. Compared to the State, most of the Census Tracts in the City of Cudahy score less than the state. The Education Score Domain is an indication of educational achievement and potential, with the higher score indicating more educational accomplishment and, therefore, success.

There is no discernable policy strategy that the city can implement to address the educational attainment of its residents. However, it is important to mention that a combination of low educational attainment coupled with a low economic and environmental score could be detrimental to the economic and health outlook for the city.

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Overcrowded Households Data
Residential crowding has been linked to an increased risk of infection from communicable diseases, a higher prevalence of respiratory ailments, and greater vulnerability to homelessness among the poor. Residential crowding reflects demographic and socioeconomic conditions.

Older-adult immigrant and recent immigrant communities, families with low income and renteroccupied households are more likely to experience household crowding. A form of residential overcrowding known as "doubling up"—co-residence with family members or friends for economic reasons—is the most reported prior living situation for families and individuals before the onset of homelessness. The household crowding table is part of a series of indicators in the Healthy Communities Data and Indicators Project (HCI) of the Office of Health Equity. The goal of HCI is to enhance public health by providing data, a standardized set of statistical measures, and tools that a broad array of sectors can use for planning healthy communities and evaluating the impact of plans, projects, policy, and environmental changes on community health. The creation of healthy social, economic, and physical environments that promote healthy behaviors and healthy outcomes requires coordination and collaboration across multiple sectors, including transportation, housing, education, agriculture, and others. Statistical metrics, or indicators, are needed to help local, regional, and state public health and partner agencies assess community environments and plan for healthy communities that optimize public health.

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Map 8.26 – Overcrowded Households (CHHS) – Tract
Map 8.26 indicates that all the City of Cudahy is in highest category of overcrowded households.

This narrative is consistent with the analysis in prior sections of this document that identify the city as densely populated, and with a high number of household members. Based on Map 8.26, the percentage of overcrowded households in the city is in the 20.0001% – 100% range. This is highest category in the SCAG region. Some of the reasons for overcrowding of households have been identified as cultural, social, and economic. There are several policy implications for the city, which include the need for the provision of more affordable housing, and the relaxation of some of the city’s regulations regarding garage conversions, SROs, and other housing assistance programs for the different economic strata of the city.

Chart 8.1– Percent of Households in Renter- Occupied Housing Units (HUD) Tract

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Chart 8.1, Percent of Households in Renter- Occupied Housing Units (HUD) Tract, indicates that 12% of the 22.7% of the households in poverty in the city are female-headed households. The next category, which is 9.7% is female-headed households with children, and the last category (3.4%) is female-headed households with three of more children. The implications are that there are more female-headed households in poverty than any other population demographic. Policy implications are that the city must address the issue of poverty with workable goals and objectives, some of which have been identified in other sections of this report.

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Map 8.27 – Overpayment by Homeowners (ACS, 2015 – 2019) Tract Map 8.27, Overpayment by Homeowners (ACS, 2015 – 2019) Tract, indicates that homeowners in two of the city’s six census tracts paid between 61% to 80% of their income on mortgages, and four of the six census tracts paid between 41% to 60% of their income on mortgages. These percentages are high especially since the recommended guidelines for the payment of mortgages is between 25% to 33% of household income. The policy implications for the city would include ensuring that more housing units are built for all economic segments of the city including very low, low, moderate, and above moderate-income households.

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Map 8.28 – Overpayment by Renters (ACS, 2010 -2014) Tract Map 8.28, Overpayment by Renters (ACS, 2010 -2014) Tract, indicates that most of the renters in the city of Cudahy pay between 81% to 100% of their income on rent, while the renters in one census tract pay between 41% to 60% of their income on rent. This indicates that the city is almost not affordable for renters in the city either due to insufficient income or high rent. The city of Cudahy does not have rent control, but the cost of rental housing can be reduced through the provision of more housing in all economic categories.

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Map 8.29– Sensitive Communities (UCB, Urban Displacement Project) Map 8.29, Sensitive Communities (UCB, Urban Displacement Project), displays the result of the Urban Displacement Project (UDP) conducted by the University of California at Berkely and the University of Toronto. UDP conducts community-centered, data-driven, applied research toward more equitable and inclusive futures for cities. The research aims to understand and describe the nature of gentrification, displacement, and exclusion, and to generate knowledge on how policy interventions and investment can support more equitable development. The map indicates that Cudahy is in the vulnerable category of sensitive communities indicating that most of the city is prone to gentrification.

The policy implication for the city is both economic and social.

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Map 8.30 – Areas of High Segregation and Poverty (2021) – Tract Map 8.30, Areas of High Segregation and Poverty (2021) – Tract, indicates that all of the six census tracts in the city of Cudahy are designated as “high segregations and poverty”. There are policy changes that could reduce the city’s poverty status, but the high segregation may change due to future gentrification.

Racially or Ethnically Concentrated Areas of Poverty R/ECAPs 2009 – 2013 To assist communities in identifying racially/ethnically concentrated areas of poverty (R/ECAPs), HUD has developed a census tract-based definition of R/ECAPs. The definition involves a racial/ethnic concentration threshold and a poverty test. The racial/ethnic concentration threshold is straightforward: R/ECAPs must have a non-white population of 50 percent or more.

Regarding the poverty threshold, Wilson (1980) defines neighborhoods of extreme poverty as census tracts with 40 percent or more of individuals living at or below the poverty line. Because overall poverty levels are substantially lower in many parts of the county, HUD supplements this with an alternate criterion. Thus, a neighborhood can be a R/ECAP if it has a poverty rate that exceeds 40% or is three or more times the average tract poverty rate for the

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metropolitan/micropolitan area, whichever threshold is lower. Census tracts with this extreme poverty that satisfy the racial/ethnic concentration threshold are deemed R/ECAPs.

One of the mandates of AB 686, Affirmatively furthering Fair Housing is to identify and transform racially and ethnically concentrated areas of poverty (R/ECAP) into areas of opportunity. It appears from Map 8.31that the city needs to set achievable goals designed to transform all its census tracts into areas of opportunities.

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Map 8.31 – Racially and Ethnically Concentrated Areas of Poverty “R/ECAP’S” (HUD, 2009 – 2013) Tract
In the City of Cudahy, the R/ECAP score is 0, while there are pockets in the county of Los Angeles with R/ECAP scores of 1.

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Map 8.32 - TCAC Area of High Segregation and Poverty (2020) – Block Group Map 8.32, TCAC Area of High Segregation and Poverty (2020) – Block Group, indicates that the city of Cudahy is in an area of high segregation and poverty. This phenomenon has been discussed and described earlier in this section.

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Map 8.33 – Social Vulnerability Index (CDC, 2018) – Tract Map 8.34, Social Vulnerability Index (CDC, 2018) – Tract, indicates that five of the six census tracts in the city of Cudahy is in the higher vulnerability category, and one census tract is in the 0.25 to

0.50 category. This indicates that the city of Cudahy is in a high social vulnerability category.

Social vulnerability refers to the potential negative effects on communities caused by external stresses on human health. Such stresses include natural or human-caused disasters, or disease outbreaks. Reducing social vulnerability can decrease both human suffering and economic loss.

The city of Cudahy must set economic goals to strengthen its economic based and wellbeing because the social vulnerability can result in significant economic loss. When that happens, the city of Cudahy could be significantly impacted.

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Map 8.34 – Mobile Home Parks (HIFLD, 2018)
Map 8.35, Mobile Home Parks (HIFLD, 2018), identifies several mobile home parks in the city of Cudahy. They are: A & A mobile home park, located at 7722 Atlantic Avenue; Capri mobile home park, located at 4513 Clara Street; ABC mobile home park, located at 8006 Atlantic Avenue; and Atlantic Trailer Village, located at 7735 Atlantic Avenue. The presence of mobile home parks in the city of Cudahy is not unique to the city. Mobile home parks have historically provided housing to the elderly, poor, and disabled because they are of affordable construction and value. Both the city and the state of California have policies in place to protect mobile home parks because they provide housing for a specific segment of the city’s population.

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Map 8.35 – CalEnviroScreen 4.0, 2021 – Tract
Map 8.35, CalEnviroScreen 4.0, 2021 – Tract, indicates that the city of Cudahy is within the 71% to 100% percentile. Two of the city’s census tracts are within the 71% to 80% percentile, while four of the census tracts are within the 91% to 100% percentile. The higher the percentile scores, the more a community is vulnerable to the potential effects of pollution.

CalEnviroScreen scores represent a combined measure of pollution and the potential vulnerability of a population to the effects of pollution. CalEnviroScreen 4.0 does not include indicators of race/ethnicity or age. However, the distribution of the CalEnviroScreen 4.0 cumulative impact scores by race or ethnicity is important. This information can be used to better understand issues related to environmental justice and racial equity in California.

CalEnviroScreen 4.0 results provide an analysis of the relationship between pollution, the potential vulnerability of a population to the effects of pollution, and race/ethnicity. It also shows clear disparities with respect to the racial makeup of the communities with the highest pollution burdens and vulnerabilities. People of color, especially Latino and Black people, disproportionately reside in highly impacted communities in California. One of the potential sources of environmental pollution could be proximity of the communities of color to freeways

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and/or industries and other land uses that are perennial environmental polluters. The policy implications for the city are numerous as well as limited. For example, there is not a lot a city can do regarding its location adjacent to a freeway. However, with the implementation and adherence to the California Environmental Quality Act (CEQA) guidelines regarding construction and new development, the city can begin to mitigate some of the environmental impacts of pollution within its community.

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SB 535
Disadvantaged communities refer to the areas throughout California which most suffer from a combination of economic, health, and environmental burdens. These burdens include poverty, high unemployment, air and water pollution, presence of hazardous wastes as well as high incidence of asthma and heart disease.

Disadvantaged communities in California are specifically targeted for investment of proceeds from the State’s cap-and-trade program. These investments are aimed at improving public health, quality of life and economic opportunity in California’s most burdened communities at the same time reducing pollution that causes climate change.

Authorized by the California Global Warming Solutions Act of 2006 (AB 32), the cap-and-trade program is one of several strategies that California uses to reduce greenhouse gas emissions that cause climate change. The funds must be used for programs that further reduce emissions of greenhouse gases.

In 2012, the Legislature passed Senate Bill 535 (de Leon), directing that 25 percent of the proceeds from the Greenhouse Gas Reduction Fund go to projects that provide a benefit to disadvantaged communities. The legislation gave CalEPA responsibility for identifying those communities. In 2016, the Legislature passed AB 1550 (Gomez), which now requires that 25 percent of proceeds from the fund be spent on projects located in disadvantaged communities.

As indicated in Map 8.31, the City of Cudahy is a disadvantaged community based on SB 535.

What this means for the City of Cudahy is that in the areas of environmental and social justice, a history of unfair treatment of communities, predominantly communities of people of color and/or low-income residents can be remedied. These communities have been subjected to disproportionate impacts from one or more environmental hazards, socio-economic burdens, or both. Residents have been excluded in policy setting or decision-making processes and have lacked protections and benefits afforded to other communities by the implementation of environmental and other regulations, such as those enacted to control polluting activities.

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Map 8.36 – SB 535 Disadvantaged Communities
Map 8.36, SB 535 Disadvantaged Communities, indicates that the city of Cudahy is classified as a disadvantaged community. What this means for the City of Cudahy is that in the areas of environmental and social justice, a history of unfair treatment of communities, predominantly communities of people of color and/or low-income residents can be remedied. These communities have been subjected to disproportionate impacts from one or more environmental hazards, socio-economic burdens, or both. Residents have been excluded in policy setting or decision-making processes and have lacked protections and benefits afforded to other communities by the implementation of environmental and other regulations, such as those enacted to control polluting activities.

Disadvantaged communities refer to the areas throughout California which most suffer from a combination of economic, health, and environmental burdens. These burdens include poverty, high unemployment, air and water pollution, presence of hazardous wastes as well as high incidence of asthma and heart disease.

Disadvantaged communities in California are specifically targeted for investment of proceeds from the State’s cap-and-trade program. These investments are aimed at improving public

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health, quality of life and economic opportunity in California’s most burdened communities at the same time reducing pollution that causes climate change.

Authorized by the California Global Warming Solutions Act of 2006 (AB 32), the cap-and-trade program is one of several strategies that California uses to reduce greenhouse gas emissions that cause climate change. The funds must be used for programs that further reduce emissions of greenhouse gases.

In 2012, the Legislature passed Senate Bill 535 (de Leon), directing that 25 percent of the proceeds from the Greenhouse Gas Reduction Fund go to projects that provide a benefit to disadvantaged communities. The legislation gave CalEPA responsibility for identifying those communities. In 2016, the Legislature passed AB 1550 (Gomez), which now requires that 25 percent of proceeds from the fund be spent on projects located in disadvantaged communities.

The policy implications for the city of Cudahy are that the city must participate in programs that qualify Cudahy for some of the benefits available under prescribed legislations.

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Map 8.37 – Healthy Places Index (PHASC, 2021) - Tract
Map 8.37, Healthy Places Index (PHASC, 2021) – Tract, identifies the city of Cudahy with a Healthy Places Index score of 0% to 20%. The higher the HPI score, the healthier a community is. This means that the city of Cudahy is one of the unhealthy communities, based on the HPI index, in the county of Los Angeles and the SCAG region.

The Healthy Places Index is structured to highlight the community conditions shaping health outcomes in neighborhoods across California. It is designed to showcase extraordinary data that properly frames and recognizes equity issues communities are experiencing, while also offering policy solutions to improve health for all. To ensure that everyone can live a healthy life, the HPI is a crucial resource for guiding informed prioritization of public and private investments, resource allocations, program planning and service delivery.

The HPI applies a positive, asset-based frame for community conditions that influence health while simultaneously offering a unique granularity of detailed data down to the census tract level across California. The methodology of the HPI score is also unique, as its eight Policy Action Area containing a total of 25 individual indicators are weighted to maximize the overall score’s association with life expectancy at birth. Additionally, the HPI offers detailed information on

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specific and actionable policy solutions to address community conditions across eight policy action areas.

The HPI score is the sum of its eight weighted Policy Action Areas: Economic, Education, Transportation, Social, Neighborhood, Housing, Clean Environment, and Healthcare Access. The final HPI scores are then assigned a percentile rank, with ranks closer to 100 indicating healthier community conditions, and ranks closer to 0 indicating less healthy community conditions.

As a city, Cudahy falls within the 0% to 20% percentile of all cities in the county of Los Angeles.

What this means is that 80% of the communities in the county exceed the city’s health potential value. Therefore, the City of Cudahy is not considered a city with high health potential. This can be due to a variety of factors such as: economy, education, transportation, social, neighborhood, housing, clean environment, and healthcare and healthy food access.

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CITY OF CUDAHY

ENVIRONMENTAL CHECKLIST FORM AND INITIAL STUDY FOR AN
ADDENDUM TO THE 2040 CUDAHY GENERAL PLAN PROGRAM ENVIRONMENTAL IMPACT REPORT

PROJECT INFORMATION

1. Project Title:
2021 Housing Element Update to the Cudahy 2040 General Plan

2. State Clearinghouse Number:

3. Lead Agency Name and Address:

City of Cudahy
5220 Santa Ana Street
Cudahy, CA 90201
https://www.cityofcudahy.com/

4. Contact Person, Phone, Email:

Salvador Lopez,
Contract Planning Manager
(323) 773-5143, ext. 242
[email protected]

5. Project Location:
4610 Santa Ana Street, Cudahy, CA
APN 6224-019-014

6. Property Owner:

Not Applicable

7. Project Sponsor's Name and Address:

City of Cudahy

8. General Plan Designation:

Not Applicable

9. Zoning:

Not Applicable
Attachment B

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10. Purpose and Authority
The California Environmental Quality Act (CEQA) requires that all State and local agencies consider the environmental consequences of projects over which they have discretionary authority through documentation, analysis, and review.

This document is an Initial Study and Addendum (Initial Study/Addendum or “Addendum”) to the City of Cudahy’s General Plan Update and General Plan Program EIR (GPPEIR). The City Council of the City of Cudahy certified the Program Environmental Impact Report for the General Plan Update and adopted the General Plan 2040 in 2018. The purpose of this document is to evaluate the environmental impacts of the proposed HE Update which consists of the 2021 update to the Housing Element (Housing Element Update).

The City of Cudahy is the Lead Agency under the California Environmental Quality Act (CEQA), and is responsible for preparing and adopting this document.

This Addendum has been prepared in conformance with CEQA (California Public Resources Code § 21000 et seq.), California CEQA Guidelines (California Code of Regulations, Title 14, § 15000 et seq.), and the rules, regulations, and procedures for implementation of CEQA, as adopted by the City of Cudahy. The principal CEQA and CEQA Guidelines sections governing content of this document are § 21157.1 (Review of Subsequent Projects Described in Report; Requirements); § 15162 (Subsequent Documents and Negative Declarations) and § 15164 (Addendum to an EIR or Negative Declaration).

11. Documents Incorporated by Reference
The discussion in this document incorporates by reference the 2040 GPPEIR (SCH #2017071071), the 2040 General Plan Update, the 2040 General Plan Update Findings of Fact and Statement of Overriding Considerations (Resolution No. 18-07, March 18, 2018), and all technical studies prepared for the analysis of the proposed HE Update as listed below. The GPPEIR, Resolution No. 18-07 and accompanying staff reports are available for public review at the City of Cudahy City Hall, 5220 Santa Ana Street, Cudahy, CA 90201. References in this document to the GPPEIR are inline; all other references are in footnotes, with internet links when appropriate.

12. Intended Uses of This Initial Study/Negative Declaration The City of Cudahy, as the Lead Agency for this proposed project, will use this Initial Study/Negative Declaration in considering whether to approve the Housing Element Update and associated discretionary actions. This document will also provide environmental information to other agencies affected by the proposed project, or which are likely to have an interest in the proposed project. Various State and Federal agencies exercise control over certain aspects. The various public, private, and political agencies and jurisdictions with a particular interest in the proposed project, may include but are not limited to the following:
• California Air Resources Board (CARB)
• California Department of Housing and Community Development • California Department of Toxic Substances Control
• California Department of Transportation (Caltrans)
• California Emergency Management Agency
• California Energy Commission
• California Environmental Protection Agency (CalEPA)
• California Office of Emergency Services
• California Regional Water Quality Control Board (CRWQB) • County of Los Angeles Library

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• County of Los Angeles Public Works
• County Sanitation Districts of Los Angeles County
• Golden State Water Company
• Tract 349 Water Company
• Los Angeles County Department of Public Works
• Los Angeles County Fire Department
• Los Angeles County Health Department
• Los Angeles County Metropolitan Transit Authority
• Los Angeles County Sheriff’s Department
• South Coast Air Quality Management District (SCAQMD)
• Southern California Association of Governments (SCAG) • U.S. Environmental Protection Agency
• Water Replenishment District of Southern California (WRD)

13. Project Description:

The proposed project includes the following actions:

1. Adoption of the 6th Cycle Housing Element Update for the 2021-2029 period (“ the proposed Housing Element Update”)

2. Amendment of the General Plan to add the proposed Housing Element Update The Housing Element is one of the seven (7) required elements of the General Plan. State Housing Element law mandates that local governments plan to meet the existing and projected housing needs of all segments of the population and to be consistent with all parts of the General Plan. The 6th Cycle Housing Element Update covers the time period from October 15, 2021 to October 15, 2029, an eight-year period. It includes extensive background information on demographics, population, employment, and housing to establish housing needs.

State law requires every updated Housing Element be submitted to California’s Housing and Community Development (HCD) Department to ensure compliance with the minimum requirements. This “certification” process is unique to the Housing Element versus the other required elements. The City’s prior Housing Element was adopted and certified by HCD in 2018.

State law requires that the Housing Element include the following:
-Analysis of the City’s population, household, and employment base, and the characteristics of the housing stock -Summary of the present and projected housing needs of the City’s households - Review of potential constraints to meeting the City’s identified housing needs - Evaluation of opportunities that will further the development of new housing -Community outreach plan
-Statement of the Housing Plan to address identified housing needs -Analysis on Affirmatively Furthering Fair Housing
This is the first Housing Element cycle to implement the requirements of Assembly Bill 686 (AB 686). As of January 1, 2019, AB 686 extends the obligation to affirmatively further fair housing to all public agencies in

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California, to combat discrimination, overcome patterns of segregation, foster inclusive communities, and free barriers to housing that restrict access to opportunity based on protected status.

The Housing Element Update does not propose specific housing development projects. It is a planning, policy, and program document that provides for future housing construction and improved housing conditions. These future actions are expected to result in direct changes to the physical environment of the City of Cudahy.

Although potential development sites are identified in the Housing Element Update, they are included to realize future housing production goals.

Adoption of the proposed HE Update alone does not directly result in development of residential units, but future housing development is expected. As specific projects are proposed, project review against Federal, State, and local rules and regulations, including compliance with the Municipal Code and the California Environmental Quality Act will be undertaken. Future proposed HE Update impacts will be evaluated on a project- by-project basis given specific site boundaries and environments. Appropriate environmental review documentation and public participation would be a part of those future proposed projects. Mitigation measures would be adopted to reduce any significant impacts, if identified.

HOUSING NEEDS
Each city and county in California has a legal obligation to respond to its “fair share” of the projected future housing need in the region in which it is located. For Cudahy, the regional housing need is determined by the Southern California Association of Governments (SCAG). SCAG has identified a total of 393 housing units for Cudahy’s Regional Housing Needs Assessment (RHNA). The units are broken down by average monthly income (AMI) as: 80 very-low-income (50 percent of AMI or less), 36 low-income units (50 to 80 percent of AMI), 53 moderate-income units (80 to 120 percent of AMI), and 224 above moderate-income units (120 percent of AMI or greater). The jurisdiction must show that it has adequate land inventory and sites to meet its RHNA obligations for each income category.

Cudahy RHNA 6th Cycle, October 2021 to October 2029
Affordability Category Number of
Units
Percentage
of Total
Very Low-Income 80 20.35%
Low-Income 36 09.16%
Moderate-Income 53 13.49%
Above Moderate-Income 224 57.00 %
TOTAL 393 100.00%
Source: Table 3.3, proposed HE Update
The primary goals of the RHNA numbers are to act as targets for jurisdictions to achieve during the planning period.

The proposed HE Update includes both the 6th cycle RHNA allocation and the unaccommodated 5th cycle RHNA allocation from the 2014-2021 period which are rolled over into the current cycle. These units include 154 Extremely and Very Low-Income housing units.

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CUDAHY GENERAL PLAN HOUSING SCENARIOS
The Cudahy General Plan provides three scenarios for future development across all land uses. The scenarios include: the Baseline (2015) scenario, the Realistic Buildout (2040), and Theoretical Maximum Buildout (2040).

The General Plan eliminates the Theoretical Maximum Buildout (2040) as unlikely. The following two capacity scenarios form the basis for the General Plan projections of new dwelling units and future population, and the General Plan EIR analysis.

Cudahy General Plan Capacity for Development (2017-2040) Scenario Number of Dwelling Units Population
Baseline (2015) 5,775 24,470
Realistic Buildout (2040) 7,222 30,607
Source: Table LU4, Cudahy General Plan
The General Plan would potentially result in an increase in the number of residential units from 5,774 to 7,222 by 2040. This is an increase of 1,448 units or roughly 25%. The increase in population anticipated from implementation of the General Plan is estimated at 6,138 persons, resulting in a 2040 population of 30,607. The General Plan assumes re-development of parcels throughout the city with mixed-use development being a significant part of this re-development.

The proposed HE Update does not propose development that would exceed GP buildout and is substantially smaller than the growth that the 2040 General Plan projects, even considering the shorter horizon period of 2029. The RHNA obligation of 393 units by 2029 is 27 percent of the General Plan realistic 2040 buildout 1,448 additional units by 2040.

POPULATION AND HOUSING CHARACTERISTICS
The City of Cudahy has a 2020 population of 22,811, a decrease from 2010 when the city had a population of 23,805. The population has been stable over the past few decades. The city has a high population density given its small geographic size. According to data from SCAG, Cudahy’s current household size is 5 persons per household, 32 percent higher than the State average. The average household income is $55,752 and the poverty rate is 26.16 percent. People of Hispanic/Latino origin comprise 95.2 percent of the population. Among residents over 25 years old, 50.7 percent are high school graduates. The median age of city residents was 23.8 according to the 2020 Census, while the County of Los Angeles had a median age of 33.7.

According to the 2020 California Department of Finance data, there were 5,780 housing units in Cudahy with

36.8 percent single family detached units, 23.1 percent single family attached unit, and the remainder multifamily units including mobile home units. The median rental cost is $1,306 per month and the median home value is $420,700. More than one-half of the city’s housing stock (57.4 percent) was built prior to 1960.

LAND AND SITES INVENTORY
The City of Cudahy has over 1,600 parcels occupying roughly 670 acres (not including the right-of-way for streets).

Residential development accounts for 61% of the total land area based on the General Plan. Commercial land use accounts for about 7% while industrial land uses account for about 10% of the total land area. Public and institutional land uses account for 16% and the remainder of the City is recreational, right-of-way, or vacant. The

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City is largely built out; however, there are opportunities for increased residential development on underutilized parcels, development of remaining vacant parcels, and expansion of uses on existing developed parcels.

The proposed HE update includes an inventory of sites currently vacant, underutilized, and zoned for nonresidential used that could be rezoned to residential use. The sites inventory for both RHNA planning periods, 5 th cycle, and 6th cycle indicates a capacity for 710 units, 684 (96 percent) on sites suitable for lower-income housing development. Overall, Cudahy can adequately accommodate and exceed the previous and current RHNA.

Most of the potential housing sites identified are not constrained by environmental factors except for ground shaking during earthquakes, or by a lack of adequate infrastructure, such as limited water infrastructure provided by Tract 180 Water Company. The General Plan has taken these environmental factors into account.

Where development is planned, any environmental issues that remain can generally be mitigated through appropriate design, engineering, and environmental planning.

GOALS, PROGRAMS, AND INCENTIVES
The proposed Housing Element Update includes a list of goals, available programs, and incentives to provide housing in all income categories. It describes federal and State resources for particularly low-income housing.

The City is also preparing an inclusionary housing ordinance to provide for low-income units as a part of new housing development.

Cudahy 6
th Cycle, October 2021 to October 2029 Goals:

1. The City of Cudahy will improve the housing supply and the choice of housing opportunities through private investment and, where necessary, through public action and financing.

2. The City of Cudahy will promote affordable housing and shelter for all economic segments of the community.

3. The City of Cudahy will support and provide incentives for the maintenance and rehabilitation of the existing housing stock.

4. The City of Cudahy will encourage development of a viable urban community consistent with orderly growth and environmental conservation to provide suitable living environments, with access to employment, community facilities, and services.

5. The City of Cudahy will promote equal access and opportunity to housing regardless of race, religion, sex, marital status, ancestry, national origin, or color.

6. The City of Cudahy will identify and address significant discrepancies in housing needs and in access to housing opportunities.

7. The City of Cudahy will identify and replace segregated living patterns with truly integrated and balanced living patterns.

8. The City of Cudahy will identify and transform racially and ethnically concentrated areas of poverty (R/ECAP) into areas of opportunity.

9. The City of Cudahy will foster and maintain compliance with civil rights and fair housing laws.

COMMUNITY OUTREACH AND PUBLIC ENGAGEMENT
The City of Cudahy has been able to proceed with community outreach effort surrounding the preparation of the proposed Housing Element Update considering restrictions due to Covid-19. Outreach was conducted in

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both English and Spanish and included workshops, stakeholder interviews, and staff consultations, to the extent feasible given public health regulations, as follows:
*August 1, 2021 – Planning Commission Workshop on the proposed Housing Element Update *August 26, 2021 – focused stakeholder interviews (11 community members) *July 14, 2021 to September 14, 2021 - Community Outreach Survey with 52 respondents In addition, printed and online information out the proposed Housing Element Update was made available and posted in public facilities.

Survey responses included issues surrounding affordable housing, homelessness, gentrification/displacement, use of vacant and underutilized properties for housing, city regulatory height restrictions, parking, regulatory size of units, density bonuses, homeless shelters, homeownership, high rental rates, property maintenance, and providing diverse housing opportunities.

14. Discretionary Action
Discretionary actions surrounding the 6th cycle Housing Element Update, include adoption by the City Council, certification by the State Housing and Community Development Department, completion of CEQA review, and amendment to the Cudahy General Plan.

15. Surrounding Land Uses and Setting
The General Plan describes the City of Cudahy as a largely built-out urban community within Los Angeles County and is one of the smallest cities in the county based on population and size. The City incorporated in 1960 and at that time, more than 80 percent of the land area was developed. Cudahy is one of the smallest cities in Los Angeles County with only 1.0 square miles of land area. It is home to 22,811 residents according to the 2020 Census and is one of the most densely populated communities in Los Angeles County. A great majority of the city consists of residential land uses. Residential neighborhoods account for about 394 acres of land or 51.5 percent of the total land area. The southern portion of the city includes an industrial area along Atlantic Avenue.

Industrial land uses account for about 79 acres or 12.3 percent of the city’s land area. Cudahy is boarded by Bell on the north, Bell Garden on the east, south Gate on the south and southwest, and Huntington Par on the west.

The 710 freeway and the Los Angeles River are located near the west edge of the city.

16. Other Agency Approvals
California Department of Housing and Community Development

17. 17. Tribal Consultation
Tribal consultation was conducted as part of the 2040 General Plan Update process. CEQA does not require additional tribal notification or consultation for addenda (CEQA § 21080.3.1) to existing environmental documents.

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ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact,” as indicated by the checklist on the following pages. ☐ Aesthetics ☐
Agriculture/Forestry
Resources ☐ Air Quality
☐ Biological Resources ☐ Cultural Resources ☐ Energy
☐ Geology/Soils ☐ Greenhouse Gas Emissions ☐
Hazards and Hazardous
Materials
☐ Hydrology/Water Quality ☐ Land Use/Planning ☐ Mineral Resources ☐ Noise ☐ Population/Housing ☐ Public Services
☐ Recreation ☐ Transportation ☐ Tribal Cultural Resources ☐ Utilities/Service Systems ☐ Wildfire ☐
Mandatory Findings of
Significance

DETERMINATION
On the basis of this initial evaluation:
☐ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
☐ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared. ☐ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
☐ I find that the proposed project MAY have a “potentially significant impact” or “potentially significant unless mitigated” impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. ☒ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date

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EVALUATION OF ENVIRONMENTAL IMPACTS

1. A brief explanation is required for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question. A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors, as well as general standards (e.g., the project would not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

2. All answers must take account of the whole action involved, including off-site as well as onsite, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that an effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level.

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration. § 15063(c)(3)(D). In this case, a brief discussion should identify the following:
a) Earlier Analyses Used. Identify and state where they are available for review. b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.

9. The explanation of each issue should identify:
a) The significance criteria or threshold, if any, used to evaluate each question; and b) the mitigation measure identified, if any, to reduce the impact to less than significant.

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I. AESTHETICS
Except as provided in Public Resources Code § 21099(d) (which prohibits a significance determination regarding aesthetics impacts for transit-oriented infill projects within transit priority areas), Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect on a scenic vista? ☐ ☐ ☐ ☒ b) Substantially damage scenic resources, including,
but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway?
☐ ☐ ☐ ☒
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views
of the site and its surroundings? (Public views are
those that are experienced from publicly accessible
vantage points.) If the project is in an urbanized
area, would the project conflict with applicable
zoning and other regulations governing scenic
quality?
☐ ☐ ☒ ☐
d) Create a new source of substantial light or glare
that would adversely affect day or nighttime views
in the area?
☐ ☐ ☒ ☐
Impact Discussion:
a, b) No Impact. The proposed HE Update would not affect scenic vistas or scenic resources, because none exist within the City or its surroundings. The City of Cudahy GPPEIR concluded that there are no scenic resources or scenic highways in the City, and that vistas, when perceptible, are of the San Gabriel Mountains as viewed from the Los Angeles River bridge at Clara Street and along the Los Angeles River bike path. c) Less than Significant Impact. The proposed HE Update covers an urbanized area and is consistent with the goals and policies of the General Plan for scenic quality. Cudahy Municipal Code (CMC) Sections

20.16.28 and 20.28 require that new construction in residential and mixed-use zones undergo a design review process which is intended to reduce any potential impacts to visual character or quality of public views.
d) Less Than Significant Impact. The proposed HE Update is not anticipated to create substantial new light and glare affecting day or night-time views. Exterior lighting is regulated by CMC § 20.28.080(B), which requires light fixtures to be shielded so that the emitted light does not negatively impact existing residential uses. This requirement would be applied during the project application review and building plan-check process.

II. AGRICULTURE AND FORESTRY RESOURCES.

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects,

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lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest Protocols adopted by the California Air Resources Board.

Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps
prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency, to non-agricultural use?
☐ ☐ ☐ ☒
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract? ☐ ☐ ☐ ☒
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code §
12220(g)), timberland (as defined by Public Resources Code § 4526), or timberland zoned Timberland Production (as
defined by Government Code § 51104(g))?
☐ ☐ ☐ ☒
d) Result in the loss of forest land or conversion of forest land to non-forest use? ☐ ☐ ☐ ☒
e) Involve other changes in the existing environment which, due to their location or nature, could result in conversion of farmland to non-agricultural use or conversion of forest land to non-forest use?
☐ ☐ ☐ ☒
Impact Discussion:
a-e) No Impact. The proposed HE Update would not affect farmland or forest land because the City is located entirely within an urbanized environment. Chapter Six, Agriculture and Forestry Resources, of the GPPEIR describes Cudahy’s agricultural setting as not within a designated farmland area, not zoned for agricultural use, not having land under Williamson Act contracts. No forestlands are within the City. Since there are no agricultural or forest resources in the City of Cudahy, no impacts to such resources are anticipated.

III. AIR QUALITY
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations.

Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Conflict with or obstruct implementation of the applicable air quality plan? ☐ ☐ ☒ ☐

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Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
☒ ☐ ☐ ☐
c) Expose sensitive receptors to substantial pollutant
concentrations? ☐ ☐ ☒ ☐
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people? ☐ ☐ ☒ ☐ Background and Regulatory Setting
The City is located within the South Coast Air Basin. The South Coast Air Quality Management District (SCAQMD) has jurisdictional and regulatory authority within the Air Basin, and is responsible for the region’s Air Quality Management Plan (AQMP), which sets forth regulations and various control measures to reduce air pollution and bring the region into compliance with federal Clean Air Act (CAA) and California Clean Air Act (CCAA) standards by various target years. The 2016 AQMP includes control measures for both stationary and mobile sources of air pollutants; the control measures are further codified into Rules or set forth as policies for jurisdictions within the Air Basin. Rules set specific limits for emissions from various stationary sources, including specific types of equipment, industrial processes, paints, solvents, and consumer products. Limits on airborne “fugitive” dust from construction and particulates from diesel engines are also set forth and enforceable. To measure ongoing AQMP progress, the SCAQMD monitors air quality at 38 locations throughout the Air Basin, and has enforcement authority over a four-county area (Los Angeles, Orange, Riverside and San Bernardino Counties). See the SCAQMD website, http://www.aqmd.gov/, for comprehensive information regarding the AQMP and the SCAQMD’s overall responsibilities.

As of 2020, the South Coast Air Basin is considered to be in “non-attainment” for three criteria pollutants:
ozone; particulate matter(PM10); and respirable particulate matter (PM2.5) (See SCAQMD National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS), available at http://www.aqmd.gov/docs/default-source/clean-air-plans/air-quality-management-plans/naaqs-caaqsfeb2016.pdf?sfvrsn=14 (accessed August 14, 2020). To moderate the effects of public and private development projects on non-attainment, the SCAQMD sets regional and local emissions significance thresholds for CEQA compliance for reactive organic gases/ozone precursors (ROG), carbon monoxide (CO), nitrogen oxides (NOx), PM10 and PM2.5 (see Tables AQ-1 and AQ-2 below for threshold values). Generally, if a project’s construction and operational emissions do not exceed these thresholds, they are assumed to be “less-than-significant;” moreover, if the estimated emissions exceed thresholds but can be reduced to below thresholds by applying mitigation measures, emissions levels may be deemed less than significant with mitigation incorporated. Figure AQ-1 below shows the region’s overall attainment status.

The SCAQMD’s local, or “localized,” emissions thresholds are a means of assessing NOx, CO, PM10 and PM2.5 emission concentration at various distances from emission sources at projects that occupy less than five acres in area (see http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook/localizedsignificance-thresholds (accessed August 12, 2020)). These thresholds consider the baseline (ambient) pollutant concentrations for 38 source receptor areas within the South Coast basin, and assign threshold values based on distances from the pollution source to the nearest sensitive receptor, e.g., 25m, 50m, 100m, 200m and 500m (82’, 164’, 328’, 656’, and 1640’). The City of Cudahy is in Sensitive Receptor Area 12. For comprehensive information specific to the City, see also Cudahy General Plan FEIR, Chapter 7, Air Quality (2017).

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Calculating localized emission concentration is most critical when there are sensitive receptors nearby (homes, hospitals, schools, etc.) and when a project involves a significant grading and excavation construction phase where heavy non-road equipment is used, such as graders, excavators or other diesel-powered machines.

AQMP implementation also encompasses the Southern California Association of Governments (SCAG) Regional Transportation Plan/Sustainable Communities Strategy and Transportation Control Measures (RTP/SCS). SCAG develops the RTP/SCS every four years. The RTP/SCS is a long-range regional transportation plan that provides for the development and integrated management and operation of transportation systems and facilities that will function as an intermodal transportation network for the SCAG region. The RTP/SCS also outlines land use growth strategies that provide for more integrated land use and transportation planning, and that maximize transportation investments to achieve the California Air Resources Board (CARB) regional greenhouse-gas (GHG)-reduction targets.

SCAG also develops the biennial Federal Transportation Improvement Program (FTIP). The FTIP is a multimodal program of capital improvement projects to be implemented over a six-year period. The FTIP implements the programs and projects in the RTP/SCS, which must be consistent with achieving air quality goals.

Impact Discussion:
a) No New Impacts. The proposed HE Update would in part accomplish buildout under the City of Cudahy General Plan 2040, which according to the GPPEIR, was found to exceed the RTP/SCS growth forecasts that were used in preparing the SCAQMD 2016 AQMP (GPPEIR, p. 7-19); associated impacts were considered to be significant and unavoidable. As such, the proposed HE Update could contribute to the cumulative population growth in the City in excess of the 2016 RTP/SCS growth forecasts. Because of this exceedance, impacts would remain significant and unavoidable. b) No New Impacts. As was projected in the GPPEIR, future projects and construction work would generate air pollutants from equipment/vehicle exhaust, paint, solvents, and dust, including the criteria pollutants listed in the discussion above, specifically particulate matter (PM10), fine particulate matter (PM2.5) and ozone (O3). Heavy equipment would generate carbon monoxide (CO), reactive organic gases (ROG), nitrogen oxides (NOx), and sulfur dioxide (SO2). Future project operational air pollutants would be generated directly from passenger vehicles and freight trucks, and indirectly from building heating, cooling, and periodic re-application of structure and parking lot coatings. The GPPEIR found that the general plan buildout’s net operational emissions (barring future changes in technology, electrification of the vehicle fleet, etc.) would exceed maximum daily NOx emissions thresholds, and that impacts would be significant and unavoidable (GPPEIR, p. 7-29). Future projects proposed under the Housing Element Update will be evaluated for emissions; these would be mitigated to the extent feasible by adherence to General Plan policies (GPPEIR, Table 7-11) and SCAQMD rules for construction particulate emissions. Despite mitigation efforts, however, some projects might not be capable of fully reducing emissions below significance thresholds; thus, impacts associated with NOx emissions would remain significant and unavoidable.
c) Less Than Significant Impact. Construction resulting from future development consistent with the Housing Element Update may expose “sensitive receptors” to excessive concentrations of the shortterm pollutants described in III(b) above, particularly to toxic air contaminants (TACs). 1 Sensitive
receptors are those individuals or land uses which are particularly sensitive to air pollution - the very young, the elderly and those suffering from certain illnesses or respiratory disabilities. Outdoor exercisers are also considered sensitive receptors due to their increased breathing rates. Land uses 1 TACs are defined by the California Health and Safety Code as air pollutants which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.

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characterized as sensitive receptors include homes, medical facilities, rest homes, convalescent care facilities, schools, day care centers, parks, and recreational areas. Residents of homes and long-term care facilities may be subject to both long-term/chronic and acute exposures to poor air quality, whereas park users are primarily at risk from acute exposure to air quality.

The GPPEIR noted that Plan implementation could result in new sensitive receptors being exposed to significant TAC emissions, but that General Plan Policies AQE-1, AQE-5, LU-10.1, OSCE-1, and SE-5 would prevent this exposure and would reduce TAC emissions citywide.

Future projects’ emissions would be estimated and mitigated through numerous measures on a projectspecific basis (including measures such as requiring low-emission diesel engines during construction, low-VOC architectural coatings, compliance with SCAQMD rules for dust suppression, etc.) consistent with General Plan policies. The GPPEIR concluded that these measures were sufficient to reduce impacts to sensitive receptors to less-than-significant levels (GPPEIR, p. 7-36). Because development under the HE Update would be consistent with General Plan growth projections, impacts would not exceed those estimated by the GPPEIR, and would remain less than significant. d) Less Than Significant Impact. The GPPEIR found that implementation of the General Plan would not result in significant odor impacts to sensitive receptors because Policies AQE-1.1 to AQE 1.5 require the City to (1) create buffer zones between industrial uses and sensitive land uses, (2) require development of projects with sensitive receptors to include design features and equipment to mitigate any significant negative air quality impact on the proposed receptors, and (3) enforce air quality standards such as proposed General Plan policies and code requirements pertaining to odors. The proposed HE Update provides for increased housing development; however, such land uses are generally not odorgenerating. Although residential construction could expose workers and nearby residents to temporary odors from construction equipment engine exhaust and asphalt application, those effects would be short-term; moreover, project-specific mitigation measures and SCAQMD rules to reduce construction impacts would apply. Impacts would remain less than significant.

IV. BIOLOGICAL RESOURCES.

Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a
candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
☐ ☐ ☐ ☒
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
☐ ☐ ☐ ☒

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Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede of native wildlife nursery sites?
☐ ☐ ☒ ☐
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
☐ ☐ ☐ ☒
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
☐ ☐ ☐ ☒
Impact Discussion:
a-f) Less Than Significant Impact & No Impact. The GPPEIR notes that the City of Cudahy is completely developed with urban land uses, that the primary public vegetated areas consist of City parks and street trees, that there are no local policies or ordinances protecting biological resources, and that there are no applicable conservation plans within the City (GPPEIR, Chapter 8, Biological Resources). However, the GPPEIR also notes that construction could affect nesting birds protected under the federal Migratory Bird Treaty Act – crows, house finches, etc., which could be nesting in mature trees near proposed development. The City is otherwise fully urbanized and devoid of habitat except for street trees, urban parks, and areas around the Los Angeles River. Adoption of the Housing Element Update would not directly affect biological resources, because it would not authorize or permit any specific development project. Future projects as a result of the Housing Element Update would be subject to environmental review once project specifics are known and proposed. The following GPPEIR mitigation measures would serve to mitigate any impacts to less-than-significant levels:

GPPEIR Mitigation Measures
BIO MM-1: Pre-Construction Nesting Surveys. To avoid impacts to nesting birds, construction activities and construction noise should occur outside the avian nesting season (prior to February 1 or after September 1). If construction and construction noise occur within the avian nesting season (during the period from February 1 to September 1), all suitable habitats within 100 feet of the Project Site shall be thoroughly surveyed by a qualified biologist for the presence of nests no more than five (5) days before commencement of any vegetation removal. If it is determined that the Project Site is occupied by nesting birds covered under the MBTA , MM BIO-2 shall apply.

BIO MM-2: Construction Monitoring and Buffer Zones for Nesting Birds. If pre-construction nesting bird surveys result in the location of active nests, no grading, vegetation removal, or heavy equipment activity shall take place within an appropriate setback from occupied nests as determined by a qualified biologist. Protective measures (e.g., established setbacks) shall be required to ensure compliance with the MBTA and California Fish and Game Code requirements.

The qualified biologist shall serve as a construction monitor during those periods when construction activities occur near active nest areas to ensure that no inadvertent impacts occur.

A report of the findings, prepared by a qualified biologist, shall be submitted to the CDFW prior

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to construction-related activities that have the potential to disturb any active nests during the nesting season.

V. CULTURAL RESOURCES
Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Cause a substantial adverse change in the significance of a historical resource pursuant to § 15064.5? ☐ ☐ ☒ ☐
b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to § 15064.5? ☐ ☐ ☒ ☐
c) Disturb any human remains, including those interred
outside of dedicated cemeteries? ☐ ☐ ☒ ☐
Impact Discussion:
a) Less Than Significant Impact:. The Cudahy GPPEIR identifies several historic period houses and commercial buildings within the City (Cudahy GPPEIR, Chapter 9, Historic and Cultural and Tribal Resources, p. 9-1). An up-to-date historic resource inventory of the City has not been conducted. The GPPEIR calls for resource surveys associated with specific proposed projects as they are conceptualized. . Adoption of the proposed Housing Element Update would not directly affect historic resources, because it would not authorize or permit any specific development project. Future projects as a result of the proposed HE Update would be subject to environmental review once project specifics are known and proposed. The following GPPEIR mitigation measure would serve to reduce impacts to less-thansignificant:

GPPEIR Mitigation Measure:

CULT MM-1: Historic Resource Assessment. Prior to issuing any permit for demolition or redevelopment of a building that is 50 years old or greater , an assessment of the building must take place by a person who meets the Secretary of the Interior’s Professional Qualifications and Standards for history, architectural history, architecture, or historic architecture to assess if it meets the criteria for inclusion on a historic register. If a building meets the criteria for inclusion on the California or National registers, the City will have prepared and filed a completed DPR 523 form with the South Central coastal Information Center and the California Office of Historic Preservation, and the building will be treated as a historic resource under CEQA, subject to all regulations that relate to the treatment of historic resources.
b) Less Than Significant Impact: Adoption of the proposed Housing Element Update would not directly affect archaeological resources, because it would not authorize or permit any specific project. The GPPEIR recognized, however, that although almost all of the City is developed, the possibility remains that as-yet unrecorded prehistoric archaeological resources (including human remains) could exist in undisturbed areas or beneath existing foundations. Current cultural resource analysis practice discourages assuming that all resources have been destroyed by prior development, and it is possible that archaeological resources exist beneath the ground surface. . Future development projects proposed pursuant to the HE Update would undergo environmental review, and would be subject to State and federal law regarding archaeological resources, and to GPPEIR mitigation measures CULT

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MM 3 and CULT MM-3 as set forth below. These measures were considered to reduce impacts to historical and cultural resources to less-than-significant levels (GPPEIR, p. 9-14).

GPPEIR Mitigation Measures:

CULT MM-2: Pre-construction Briefing. Prior to the commencement of grading or demolition of subsurface structures, a professional archaeologist who meets U.S. Secretary of the Interior’s Professional Qualifications and Standards, shall conduct a brief archaeological and paleontological informational session for construction personnel. The training session may consist of in-person meeting or a written handout describing: (1) how to identify archaeological and paleontological resources that may be encountered during earth-moving activities and (2) the procedures to be followed in such an event, including contact information for the appropriate entities if archaeological or paleontological resources are discovered.

CULT MM-3: Treatment and Evaluation of Discovered Resources: In the event that archaeological or paleontological resources are unearthed during ground-disturbing activities, the ground-disturbing activities shall be halted or diverted away from the vicinity of the find so that the find can be evaluated.

A buffer area of at least 50 feet shall be established around the find, where construction activities will not be allowed to continue until a qualified archaeologist or paleontologist has examined the newly discovered artifact(s) and has evaluated the area of the find. Work shall be allowed to continue outside the buffer area. If the archaeologist identifies the find as a tribal cultural resource or suspects it to be a tribal cultural resource, the City will contact the Native American Heritage Commission (NAHC) to report the discovery, and will contact local Native American tribal representatives as directed by the NAHC.

Should the newly discovered artifact(s) be determined to be a tribal cultural resource, Native American construction monitoring will be initiated. The City shall coordinate with the archaeologist and tribal representative(s) to develop an appropriate treatment plan for the resources. c) Less Than Significant Impact: As set forth in the GPPEIR, in the event human remains are encountered, the discovery is required to comply with State of California Public Resources Health and Safety Code § 7050.5-7055. Specifically, Health and Safety Code § 7050.5 describes the requirements if any human remains are discovered during excavation of a site. As required by California law, the requirements and procedures set forth in § 5097.98 of the California Public Resources Code would be implemented, including notification of the County Coroner, notification of the Native American Heritage Commission, and consultation with the individual identified by the Native American Heritage Commission to be the “most likely descendant.” If human remains are found during excavation, excavation must stop in the vicinity of the find and any area that is reasonably suspected to overlie adjacent remains until the County Coroner has been contacted, the remains investigated, and appropriate recommendations made for the treatment and disposition of the remains. Given required compliance with state regulations that detail the appropriate actions necessary in the event human remains are encountered, potential impacts would be less than significant (GPPEIR p. 9-10). Moreover, adoption of the proposed HE Update would not authorize any development. Future projects as a result of the proposed HE Update would be subject to environmental review. GPPEIR mitigate measures CULT MM-2 and CULT MM-3 listed above would also apply.

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VI. ENERGY
Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
☐ ☐ ☒ ☐
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency? ☐ ☐ ☒ ☐
Impact Discussion:
a, b) Less Than Significant Impact. The GPPEIR evaluated the City’s overall energy use in Chapter 11, Greenhouse Gas Emissions and Energy. GPPEIR Table 11-5 summarizes General Plan policies that address energy through land use, mobility, and emissions-reduction policies. With these policies in place, in addition to compliance with existing state and local regulations for increasing energyefficiency and reducing overall vehicle miles traveled, impacts associated with wasteful energy consumption were less than significant (GPPEIR p. 11-36). The proposed HE Update is intended to facilitate housing development and rehabilitation at all income levels with a target of 393 residential units within the 2029 horizon period which is substantially less than the planned 1,447 units within the 2040 horizon period included in the GPPEIR. Adoption of the Housing Element Update would not directly affect energy consumption or conflict with a local plan, because it would not authorize or permit a specific development project. Future projects as a result of the HE Update would be subject to environmental mitigation measures would serve to mitigate any impacts.

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VII. GEOLOGY AND SOILS
Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i. Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map, issued by the State Geologist for the area
or based on other substantial evidence of a known
fault? Refer to Division of Mines and Geology Special
Publication 42.
☐ ☐ ☒ ☐
ii. Strong seismic ground shaking? ☐ ☐ ☒ ☐
iii. Seismic-related ground failure, including liquefaction? ☐ ☐ ☒ ☐ iv. Landslides? ☐ ☐ ☐ ☒
b) Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☒ ☐ c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and
potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
☐ ☐ ☒ ☐
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial
direct or indirect risks to life or property?
☐ ☐ ☒ ☐
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
☐ ☐ ☐ ☒
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature? ☐ ☐ ☒ ☐
Impact Discussion:
a) (i, ii, iii) Less Than Significant Impact. The GPPEIR explains that surface rupture is not a significant hazard in the City of Cudahy, because the nearest fault trace lies more than six miles from the City (GPPEIR, Chapter 10, p. 10-1, Table 10-1). However, as are all southern California communities, the City is subject to seismic effects from many known faults in the region (GPPEIR, Table 10-1). In particular, the Puente Hills thrust fault lies in the northern portion of the City (see GPPEIR Ex. 11-1 and 11-2). As such, development within the City, such as provided for through the proposed project, would expose people and structures to potential earthquake hazards, including fault rupture (GPPEIR Chapter 10, p. 10-7), strong seismic ground shaking, and liquefaction. However, the GPPEIR also lists numerous state and local regulations, as well as General Plan policies, that work together to reduce this exposure to less than significant levels. Specifically, GPPEIR Table 10-2 references the following regulations and policies, which would apply to the future projects developed under the HE Update:

1. California Building Standards Code, (Cal. Code Regs. Title 24), as adopted by the Cudahy Municipal Code § 15.04.010, which prescribes minimum standards for building construction, and

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ensures that structures are properly designed and constructed to withstand seismic hazards, soil erosion, unstable soils or other unstable geologic units (such as those subject to liquefaction), and expansive soils.

2. City of Cudahy Local Natural Hazard Mitigation Plan EGH-2, which requires geologic/geotechnical studies for large-scale residential development projects that identify a project site’s individual characteristics and set forth construction requirements that would protect future residents from seismic-related hazards, soil erosion, unstable soils or geologic units, and expansive soils.

3. City of Cudahy Local Natural Hazard Mitigation Plan EGH-6, which requires liquefaction assessment studies as part of a project’s geotechnical evaluation, and requires mitigation as conditions warrant.

With these regulations governing future projects consistent with the Housing Element Update, the proposed HE Update impacts associated with seismic effects would be less than significant. (iv.) No Impact. The GPPEIR notes that the City of Cudahy lies on relatively flat terrain, and that no impacts associated with landslides would be expected in the City (GPPEIR, p. 10-8). Accordingly, the project could not cause adverse effects involving landslides, directly or indirectly. No impacts are anticipated.
b) Less Than Significant Impact. The GPPEIR acknowledges that future development under the General Plan could cause erosion and topsoil loss (GPPEIR p. 10-8). Future projects under the proposed Housing Element Update are not expected to result in a substantial loss of topsoil, because new development would be subject to numerous regulations designed to minimize erosion. For example (see also the impact discussion below in Part X, Hydrology and Water Quality), Chapter 13.08 of the Cudahy Municipal Code sets various requirements for stormwater and urban runoff pollution control and water conservation, including: prohibiting activities that would cause runoff; setting requirements for existing properties; requiring standard urban storm water mitigation plans for new developments; establishing requirements on construction projects; and implementing a program for public education about stormwater runoff. In addition, as discussed in Part X, State and federal laws apply for erosion and runoff.
c) Less Than Significant Impact. As noted under (a)(iv.) above, the GPPEIR states that the City is in a “mostly flat” area (GPPEIR, p. 10-8). City lands are relatively level. Future projects are subject to the General Plan Policy EGH-2, which requires a construction-specific geotechnical study and compliance with that study’s recommendations for site excavation, stabilization, and construction. Such compliance, in addition to compliance with the California Building Standards Code cited above, would reduce associated impacts to less than significant levels.
d) Less Than Significant Impact. The GPPEIR notes that the City is underlain by sand, loam, silt, or a combination of these soil types, which are not characteristically expansive (GPPEIR, p. 10-8). However, as noted in (c) above, future development projects would be subject to the recommendations of a sitespecific geotechnical study regarding expansive soils and would be required to comply with those recommendations as part of the building permit process. Impacts related to expansive soils are expected to be less than significant.
e) No Impact. The GPPEIR notes that the City is served by a “comprehensive, integrated, wastewater collection, treatment and disposal system” (GPPEIR p. 10-17). No septic or alternative wastewater systems would be constructed under the HE Update; thus, no related impacts would occur. f) Less Than Significant Impact. The GPPEIR indicates that while discovery of paleontological resources is unlikely where sites have been previously developed, if a site will be subject to additional excavation,

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the potential for discovering previously unknown resources exists. Future development projects resulting from the proposed HE Update would be evaluated against the amount of excavation. Future projects as a result of the proposed HE Update would be subject to environmental review. GPPEIR mitigation measures CULT MM-2 and CULT MM-3 listed above under “Cultural Resources” would apply.

VIII. GREENHOUSE GAS EMISSIONS
Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
☐ ☐ ☒ ☐
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
☐ ☐ ☒ ☐
Background and Regulatory Setting
The GPPEIR provides substantial background into the current state of understanding of greenhouse gas (GHG) emissions, their contribution to global climate change (GPPEIR, Chapter 11, Greenhouse Gas Emissions and Energy), the regulatory setting and the California Air Resources Board (CARB) draft 2017 Climate Change Scoping Plan’s guidance for countering GHG emissions. The GPPEIR estimated the City’s current and projected emissions, and set forth all General Plan 2040 policies that would collectively reduce emissions, but ultimately concluded that despite the City’s best efforts, emissions resulting from General Plan buildout would likely exceed the CARB GHG-reduction goals, and that impacts were significant and unavoidable (GPPEIR p. 11-31, Table 11-4, p 11-24). Still, individual development projects’ emissions still must be estimated and, to the extent feasible, mitigated so that the City approaches CARB goals.

To date, the City has not established a quantified GHG emissions threshold for individual projects, and the SCAQMD’s recommended thresholds as discussed in the GPPEIR (GPPEIR p. 11-22) have not been adopted by that agency. However, since the GPPEIR was certified, the CARB’s 2017 Climate Change Scoping plan was finalized and adopted. It sets forth a “reference scenario” as a baseline for measuring how much GHG emissions can be reduced in several economic sectors. This scenario illustrates the level of GHG emissions that would be generated statewide through 2030 under existing policies and programs, but without any further action to reduce GHGs, i.e., what would be generated by doing “business as usual” without efforts to reduce emissions. This level is estimated to be approximately 400 million metric tons (MMTs) of carbon dioxide equivalents (CO2e) from all sources in 2030. The CARB’s statewide 2030 target level of emissions is approximately 260 MMTs. The Scoping Plan estimates that the change from 1990 levels in the residential and commercial sectors must be from 44 MMT of CO2e to 38-40 MMT of CO2e by 2030, a four to eight percent reduction. Where a project can demonstrate consistency with this percentage reduction, a finding of “less than significant” may be appropriate.

Impact Discussion:
a) Significant and Unavoidable. Development constructed under the proposed HE Update would generate GHG emissions during both construction and operation. The GPPEIR determined that General Plan 2040 buildout would result in significant and unavoidable GHG impacts (GPPEIR, p. 11-31) because despite incorporating feasible mitigation measures and public infrastructure, GHG-reduction targets could not be achieved. Although development consistent with the HE Element would not exceed buildout totals,

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and individual projects’ GHG emissions may not exceed Scoping Plan reduction goals, such development must still be considered to result in cumulative significant and unavoidable impacts. The degree of impact would not change from that concluded in the GPPEIR. b) Less than Significant Impact. The GPPEIR concluded that General Plan buildout would not conflict with plans, policies or regulations adopted for the purpose of reducing the emissions of greenhouse gases, and components of future projects would be required to be consistent with those plans (GPPEIR, p. 11- 31). Development under the HE Update would not exceed General Plan buildout totals, and future projects are expected to incorporate the strategies listed in the General Plan for emissions and vehicle trip reduction.

IX. HAZARDS AND HAZARDOUS MATERIALS
Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
☐ ☐ ☒ ☐
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?
☐ ☐ ☒ ☐
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school? ☐ ☐ ☒ ☐
d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code §
65962.5 and, as a result, would it create a significant hazard to the public or the environment?
☐ ☐ ☒ ☐
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
☐ ☐ ☐ ☒
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
☐ ☐ ☒ ☐
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
☐ ☐ ☐ ☒
Impact Discussion:
a-d) Less Than Significant Impact. The proposed HE Update would not authorize or permit any specific development project and thus would not result in hazards related to transport, use, or disposal of hazardous materials. Future development conforming to the proposed HE Update policies could involve hazardous materials, but would not be expected to use, transport or dispose of such materials

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routinely. Individual project sites may require excavation and disposal of contaminated soils, but these activities are controlled by existing federal and state regulations (GPPEIR, Ch. 12, pp.8-12).

The GPPEIR describes four Comprehensive Environmental Response, Compensation, and Liability Act2 (CERCLA) Sites, or Superfund Sites, within the City (GPPEIR, p. 12-5, Table 12-1). None of these sites are on the National Priorities List (NPL). Two sites were being investigated when the GPPEIR was prepared, at 8420 and 8427 Atlantic Avenue, including two sites, at 5310 Elizabeth Street and 5240 East Santa Ana Street. Because of the known history of industrial land uses within the City, project specific investigation will be conducted for future development consistent with the Housing Element Update.

Since the GPPEIR’s certification, the California Department of Toxic Substances Control has continued to develop guidance for site mitigation from soil vapor intrusion.3 Although this guidance is not a regulatory document itself, it informs the DTSC in its exercise of jurisdiction over contaminated properties, particularly about state-of-the-art remediation strategies. e) No Impact. The GPPEIR indicated that there are no airports or private airstrips within two miles of the City limits, and that no mitigation associated with General Plan implementation was required. This condition has not changed since the General Plan was adopted. The proposed HE Update does not authorize development and would not result in a safety hazard or excessive airport-related noise for people residing or working in the area (GPPEIR p. 12-22). f) Less Than Significant Impact. The GPPEIR indicated that the implementation of the General Plan would not significantly interfere with emergency response or evacuation plans. As described in Part XI, Land Use and Planning below, the proposed HE Update is consistent with and partially implements the General Plan. As such, impacts related to emergency/evacuation plans would be less than significant (GPPEIR p. 12-22).
g) No Impact. The GPPEIR notes that the City of Cudahy is completely developed and is not adjacent to wildlands (GPPEIR p. 12-22). The proposed HE Update covers the City of Cudahy limits, in part would implement the General Plan, and as such, would not result in impacts related to wildland fires. 2 For additional information about CERCLA and the NPL, and additional references, see GPPEIR p. 12-8, See also U.S.

Environmental Protection Agency, Regulatory Information by Topic: Land and Cleanup, available at https://www.epa.gov/regulatory-information-topic/regulatory-information-topic-land-and-cleanup#rcra (accessed January 14, 2022)).
3 California Department of Toxic Substances Control, Site Mitigation and Restoration Program, available at https://dtsc.ca.gov/vapor-intrusion/ (accessed January 14, 2022).

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X. HYDROLOGY AND WATER QUALITY
Would the project: Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
☐ ☐ ☒ ☐
b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the
project may impede sustainable groundwater management
of the basin?
☐ ☐ ☒ ☐
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious
surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or offsite? ☐ ☐ ☒ ☐ ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor off-site? ☐ ☐ ☒ ☐
iii. Create or contribute runoff water which would
exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional
sources of polluted runoff; or
☐ ☐ ☒ ☐
iv. Impede or redirect flood flows? ☐ ☐ ☒ ☐
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation? ☐ ☐ ☐ ☒
e) Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management
plan?
☐ ☐ ☐ ☒
Impact Discussion:
a) Less Than Significant Impact. The GPPEIR concluded that buildout of the General Plan would not result in significant impacts related to hydrology and water quality, including violations of water quality standards or waste discharge requirements (GPPEIR, p. 13-15). GPPEIR Table 13-1 sets forth the comprehensive set of statutes, regulations and policies that govern General Plan implementation, including physical construction of new development. New construction is subject to Cudahy Municipal Code, §§ 13.08, the Stormwater Management and Discharge Control Ordinance. Subsections 110-120 require a standard urban storm water mitigation plan (SUSMP), a storm water pollution prevention plan (SWPPP) and specific construction methods to prevent runoff from the site and contamination of storm drainage systems with construction waste. New construction is also subject to the City’s Low Impact Development (LID) ordinance, as codified in the Zoning Code (Cudahy Municipal Code, § 20.68). This Code section establishes minimum requirements for mitigating storm water pollution, and provides