Agenda — Cudahy City Council, February 7, 2023 (part 2 of 4)

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park, a tennis court, trails, and baseball/softball diamonds. Additionally, the Cudahy Park complex includes community amenities such as City Hall, the Los Angeles County Public Library – Cudahy, Bedwell Hall (a public assembly/banquet hall available for rent by residents), and the City Council and Commission chambers.

Infrastructure
In terms of infrastructure, the entire City is well serviced, and no one census tract experiences a disadvantage in terms of access to infrastructure, such as water, sewage, gas, electrical, or telecommunication services.

Local Schools
There is one school located within the City’s high segregation and poverty tract, Park Avenue Elementary School. Park Avenue Elementary School and Dual Language Academy (Spanish) is a Los Angeles Unified School District (LAUSD) school serving 330 transitional kindergarten through sixth grade students. Ellen Ochoa Learning Center, which is approximately 0.35 miles from Park Avenue Elementary School, serves K-8 students in the City of Cudahy while Elizabeth Learning Center, which is approximately 0.47 miles from Park Avenue Elementary School, serves K-12 students in the City of Cudahy. Both Ellen Ochoa Learning Center and Elizabeth Learning Center are LAUSD schools. Accessing Ellen Ochoa Learning Center and Elizabeth Learning Center from the high segregation and poverty tract requires crossing residential streets and no major thoroughfares.

Environmental Conditions
The City of Cudahy’s high segregation and poverty tract in the southeast corner of the City along the I-710 freeway features a Healthy Places Index (HPI) score of 17.9, which indicates that the environment in the tract is slightly healthier than the average HPI score of 12.9 in Cudahy.

However, the HPI score of 17.9 in tract 5343.02 is significantly lower than the Los Angeles County average of 48.2. Census tract 5343.02 has healthier community conditions than 17.9% of other California tracts. Tract 5343.02 has a CalEnviroScreen pollution burden of 97. The only tract in Cudahy with a higher pollution burden is tract 5343.01, in the central southern portion of the City, with a burden of 98. The tracts along the eastern border of the City, such as the high segregation and poverty tract, are close to the I-710, which is a major diesel truck route in Los Angeles County.

Within the Southeast Los Angeles Cities region many Census tracts qualify as TCAC Areas of High Segregation and Poverty. These tracts within the Southeast Los Angeles Cities region fall within the cities of Huntington Park, Bell, Maywood, and Bell Gardens. Outside of the Southeast Los Angeles Cities region, many Census tracts to the North and West of Cudahy qualify as TCAC Areas of High Segregation and Poverty.

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Racially Concentrated Areas of Affluence
Racially concentrated areas of affluence are defined as Census tracts where: 1) 80% or more of the population is White and 2) the median household income is $125,000 or greater. No census tract in the Southeast Los Angeles Cities region features a dominant White population and no census tract in the region features a median household income equal to or greater than $125,000.

Conclusion
In conclusion, the racial and ethnically concentrated areas of poverty analysis found no R/ECAP tract in the City. However, the City does feature one TCAC high segregation and poverty tract in the southeastern portion of the City, close to the I-710 freeway, the heavy manufacturing area in South Gate, and the Los Angeles River. Notably, this high segregation and poverty tract features the highest poverty rate in the City and the lowest educational attainment rate. The southeastern portion of the City also features higher levels of environmental exposure compared to other areas of the City, according to Cal Enviro Screen. However, other environmental indicators find that the southeastern portion of the City does not stand out in terms of higher levels of exposure to environmental contaminants.

Access to Opportunity
Access to opportunity is a concept to approximate place-based characteristics linked to critical life outcomes. Access to opportunity oftentimes means both improving the quality of life for residents of low-income communities, as well as supporting mobility and access to ‘high resource’ neighborhoods. This encompasses education, employment, economic development, safe and decent housing, low rates of violent crime, transportation, and other opportunities including recreation, and food and healthy environment.

Educational Attainment, Access to Education
According to the US Census 42.7% of Cudahy’s residents have less than a high school education.

The percentage of high school graduates or higher of persons residing in Cudahy age 25 years or older is 50.7%. The percentage of residents with a bachelor’s degree or higher is 6.6%. Both the City of Cudahy and the Los Angeles Unified School District provide services in English and Spanish.

The School District also offers immersion programs for Cudahy students. The Los Angeles Unified School District provides bus transportation for students residing in the City of Cudahy. Cudahy residents are served by the City’s Dial-A-Ride program, Los Angeles Transportation Authority, and Cudahy Rapid Transit. All buses are wheelchair accessible. As part of the City’s ongoing efforts to update and improve infrastructure including bicycle, pedestrian, and vehicular access the City, through Program 14 Infrastructure Availability, will continue to upgrade facilities as identified in the City’s Annual Capital Improvement Program.

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Local Schools
There are five schools within the City of Cudahy. This includes elementary schools, middle schools, and high schools. All five schools within Cudahy are public LAUSD schools. According to Great Schools, the schools located within Cudahy’s borders have an average rating of 4/10, which is below average. The lowest rated schools (Elizabeth Learning Center, Park Avenue Elementary School, and Ellen Ochoa Learning Center) are located in the eastern portion of the City, east of Atlantic Avenue. One of these lowest rated schools, Park Avenue Elementary School, is located within the high segregation and poverty tract. In comparison to other schools within the region, the majority of which are also LAUSD schools, the schools in Cudahy are rated a bit lower than other schools in the Southeast Los Angeles Cities region. Access to more proficient schools does not appear to relate to protected characteristics within the City.

Youth Social Services
Related to Cudahy’s youth residents, the service organization Jovenes provided local data and knowledge regarding the Cudahy youth they serve. Jovenes provides services to youth experiencing housing instability, such as interim housing (bridge housing for 3-6 month stays), transitional housing (24 month stay), Time-Limited Subsidy (permanent housing), Permanent Supportive Services, Employment Services, Intensive Case Management Services, Transportation, and Linkage to Benefits. Jovenes SPA 7 Regional Coordinator estimates the organization serves approximately 2 to 5 young adults from Cudahy per year, most of whom are lower-income and experiencing homelessness with disabilities and substance abuse. The Coordinator identified areas along the Los Angeles riverbed/under bridges as hotspots where youth have sheltered prior to being referred to Jovenes. The Coordinator mentions housing is available for Cudahy youth, however, the available housing is far away from the City which sometimes presents a challenge in placing youth.

Outside of the Southeast Los Angeles Cities region, to the west of Cudahy there are more areas of segregation and racially and ethnically concentrated areas of poverty that correspond to lower quality LAUSD schools, the majority of which are rated either 2/10 or 3/10.

Accessibility to Jobs
Many of the jobs available in the Southeast Los Angeles Cities are blue-collar jobs. The blue collar jobs offered in the region are a great match for the skill set of the region’s population as well as the population of Cudahy. Cudahy is located in an area with high traffic congestion and job centers are not immediate to the community. According to HCD’s AFFH Data Viewer, HUD’s Job Proximity Index found that tracts in the western portion of the City are furthest in proximity from a concentration of jobs, tracts in the center of the City are locate closer in proximity to jobs, and tracts in the eastern portion of the City are located in even closer proximity to jobs. However, no tract in Cudahy qualifies as the closest in proximity or second closest in proximity to a concentration of jobs. To the north and east of Cudahy, census tracts are in closer proximity to a concentration of jobs in comparison to the City of Cudahy and the larger Southeast Los Angeles Cities region. Few high-income jobs are located in the Southeast Los Angeles Cities region; the closest major professional job center is Downtown Los Angeles.

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Most protected classes (such as race, color, religion, sex/gender, gender identity/expression, sexual orientation, marital status, medical condition, veteran status, national origin, ancestry, disability, age over 40, and more) do not live anywhere specific within the City of Cudahy. In fact, the City presents very similar population characteristics in each Census tract. Due to this, the City’s protected groups experience the same difficulties in access to jobs within the region.

While jobs in Cudahy are easy for Cudahy residents to access, jobs within the larger region are not as easy to access, especially by residents who do not have access to a car. Cudahy does have public transit in the form of buses. In 2019, 72.5 percent of Cudahy residents drove alone to work,

12.8 percent used carpools, 7.8 percent took public transit, 2.4 percent walked, 2.4 percent used other means to commute to work, and 2.2 percent worked from home. Between 2011 and 2019, there was a 5.8 percent increase in the number of Cudahy residents who drove to work.

In 2019, the mean travel time to work for Cudahy residents was 32.8 minutes. In a City of 1.2 square miles, nearly built out, this data indicates that Cudahy’s workers commute outside the City’s boundaries. The dominant mode of transportation for workers is a vehicle. In 2022 the City initiated the preparation of an Economic Development Strategic Plan to determine the needs of the City, programs to promote economic development to create more jobs in the City, and opportunities to increase revenues. Beginning in 2022 opportunities to address housing issues as part of economic development will be available through the City’s Economic Development Strategic Plan outreach efforts. Program 14 (Infrastructure Availability) has been amended to include a review of the outcomes of the economic development report as they relate to housing issues, including transportation opportunities, and the pursuit of funding sources for related infrastructure improvements.

Transit Accessibility
Cudahy is serviced by two Metro bus lines, the 260 and 611, which run along various thoroughfares throughout the city such as Santa Ana Street, Wilcox Avenue, Atlantic Avenue, and Cecilia Street. Additionally, the City of Cudahy runs the Cudahy Area Rapid Transit system, which runs daily throughout the City from 7 am to 5:45 pm, with a bus running every hour. The bulk of Cudahy residents are within ½ mile of public transit. Transit service exhibits a moderate frequency. For example, Metro route 260 provides north-south service along Atlantic Avenue at roughly 15-20 minute frequency. Metro provides local service to Huntington Park and its surrounding Southeast Los Angeles Cities region (such as Cudahy, Maywood, and Bell) with Route 611 every hour. The greatest transit accessibility is therefore located near the intersection of Atlantic Avenue and Santa Ana Street. Cudahy is considered “Somewhat Walkable”, scoring 62 of 100 by WalkScore.com. It is also considered “Bikeable”, scoring 61 of 100.

The future Metro West Santa Ana Branch Line will improve Cudahy residents’ access to regional transit with one station at Firestone and Atlantic Avenues and one station at Florence and Salt Lake Avenues. Residents, particularly those in the southern sand northwestern portion of the City, will have access to the north-south fixed rail service that will provide access to Artesia to the

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south and Downtown Los Angeles to the north, with connectivity to east-west rail service like the C Line in Paramount to the south and the L, B, D, and A Lines near Downtown Los Angeles.

Most protected groups who reside in the City have sufficient access to transportation options.

One exception is disabled residents. While some disabled residents in Cudahy are employed, many disabled residents are not employed. In some cases, these disabled residents are unable to work, but in others these residents may experience difficulty in accessing jobs. Generally, disabled residents have disproportionate transportation needs within the City of Cudahy; however, the majority of disabled residents live with their families who are able to assist them in their transportation needs. Additionally, the City’s Area Rapid Transit system provides free daily transportation to City residents from 7 am to 5:45 pm, with a bus running every hour. The transit system connects the entirety of the City with stops in every neighborhood. Additionally, residents have the option to flag the bus down anywhere along the route, meaning riders are not required to board only at set stops.

Disability
A full explanation of the needs of disabled residents in Cudahy is included in the Housing Needs Appendix of this Housing Element. However, a short summary is provided here. The most prevalent disabilities in Cudahy are ambulatory, independent living, and cognitive respectively.

These top disabilities are similar to those found in other cities throughout the Southeast Los Angeles Cities region. Ambulatory disabilities are of particular concern in regard to access to opportunity, specifically to transportation, as previously noted.

Disability by age groups is as follows: 205 disabled residents 18 years old and under, 1,159 disabled residents aged 19-64, and 610 disabled residents aged 65 and up. This reveals that a large portion of disabled residents exist within each age group in Cudahy, meaning that the needs of disabled residents must be addressed for young people, adults, and seniors. However, the demand for disabled services for adults and seniors is far larger than the demand for disabled services for minors. The Census tract to the north, directly in the center of Cudahy, features a higher concentration of disabled residents than the other Census tracts. However, this one tract is only 1.8 percent higher than the percent of the population with a disability in the tract which ranks second in terms of the concentration of disabled residents.

Approximately 10.6% of Cudahy’s housing stock was built after 1990, which is the year when many regulations went into place mandating the building and inclusion of accessible housing units. Therefore, there are a limited number of accessible units in Cudahy for disabled residents.

The Housing Needs Assessment includes an assessment of supportive housing stock. Additionally, Appendix the Housing Needs Assessment does include an assessment of accessibility of homelessness programs. In each of these cases, the City of Cudahy does have resources available.

Through this Element’s Program 19 (Disability Access) the City shall continue to enforce the American with Disabilities Act (ADA) and shall continue to require new development to comply with State disability access standards and the 2020 Los Angeles Building Code.

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Environmental Issues
The City of Cudahy is located in a region of significant environmental issues. These issues cause difficulties in accessing environmentally healthy neighborhoods for all, not only protected classes.

In 2021, the California Office for Environmental Health Hazard Assessment (COEHHA) released the fourth version of CalEnviroScreen, a tool that uses environmental health, and socioeconomic indicators to map and compare a community’s environmental scores. A community within the 75th percentile or above, is one with higher levels of pollution and other negative environmental indicators and is considered a disadvantaged community. According to the CalEnviroScreen 3.0 map, the City of Cudahy experiences a pollution burden ranging from 63 to 98 across Census tracts. The average pollution burden in the City is 89.17. This means the City of Cudahy has an overall pollution burden higher than up 89.17 percent of other communities within California.

The City’s high pollution burden percentile is similar to burdens throughout the Southeast Los Angeles Cities region. The pollution burden lessens the further southeast one moves from Cudahy; however, the burdens still remain high throughout most of Los Angeles County.

Two of the City’s census tracts with pollution burdens ranging from 63 to 80 are located on the west side of the City, while four of the census tracts with pollution burdens ranging from the 91 to 98 are located on the north, south, and east along the Interstate 710 corridor. The higher the percentile scores, the more a community is vulnerable to the potential effects of pollution.

Interstate 710 is an important regional/national freight corridor, and the associated traffic volumes and air quality impact Cudahy.

Overall, the City of Cudahy’s Census tract in the southeast corner of the City along the I-710 freeway experiences higher poverty and vulnerability in addition to worse environmental conditions. This tract in the southeast corner of the City is located directly adjacent to the I-710, which is a major source of air contamination in the Southeast Los Angeles Cities region, due to heavy truck traffic. Additionally, the southeast corner of the City is located directly across Wilcox Avenue from many of the larger industrial uses in Cudahy. South Gate’s M3 zone (Heavy Manufacturing) also directly abuts the southeasternmost Census tract in Cudahy. While this portion of South Gate is currently heavy industrial, in the future the City of South Gate plans to transition a portion of this M3 zoned area into a mixed-use Transit Oriented Development (TOD) area. A shift from heavy industrial to mixed-use TOD land uses will benefit residents of Cudahy’s southeastern Census tract, increasing the residents’ proximity to new commercial amenities and jobs and reducing the residents’ exposure to industrial contaminants.

Although there is not much the City can do regarding proximity to Interstate 710, the City’s implementation of the California Environmental Quality Act (CEQA) guidelines regarding construction and new development, can begin to mitigate some of the environmental impacts of pollution within the City.

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Through Program 30 (Environmental Enhancements) the City commits to reviewing a selection of environmental policies and regulations for adoption and implementation to reduce the amount that Cudahy residents are exposed to environmental contaminants. The City has already taken steps to reduce environmental contamination in the City, through a ban on trucking terminals in the City and a tree planting requirement for multifamily residential development.

Meaningful Actions
The southeastern and northwestern sides of the City will have improved access to transportation when the West Santa Ana Branch Transit Corridor (WSAB) opens at the intersection of Firestone Boulevard Atlantic Avenue as well as Salt Lake Avenue and Florence Avenue. The equitable TOD Plans (for the Florence/Salt Lake Station Area by the neighboring City of Huntington Park) promotes equitable development around the WSAB stations in an effort to prevent transit and investment driven displacement.

In anticipation of the new WSAB station at Firestone and Atlantic Avenues, the City of South Gate and Cudahy are both planning new TOD areas surrounding the station. The City of South Gate, which borders Cudahy to the south, has adopted the Gateway District Specific Plan. This area in South Gate, which is currently characterized by existing light to heavy-industrial uses and emerging retail uses, is intended to become a dense “transit village” designed to support a highlevel of pedestrian activity. South Gate also recently saw the development of the Azalea Regional Shopping Center abutting the southern boundary of Cudahy, close to the future WSAB station.

Some businesses which moved into this Shopping Center are Walmart, Ross Dress for Less, ULTA, Michael’s, and more. It thus provides significant new job opportunities and new commercial amenities to residents of South Gate and Cudahy.

Additionally, the City of Cudahy plans to turn their current Entertainment District along the southern portion of Atlantic into Transit Oriented Development area. The City of Cudahy has a similar vision to South Gate, which is to bring new commercial amenities to Atlantic Avenue while also ensuring a pedestrian friendly experience in support of the new transit stop. Last, the City of Cudahy is proud to have a new Sprouts grocery store moving into the City. Historically, the City has not been able to attract a high-quality, healthy grocery stores, so the City is excited for the future of commercial development for its residents. As with the Azalea Regional Shopping Center and the Gateway District Specific Plan, Cudahy’s TOD area will bring new job opportunities and commercial amenities into the City for its residents.

Conclusion
In conclusion, the access to opportunity analysis found that the City of Cudahy is similar to other cities in the Southeast Los Angeles Cities region in terms of accessibility to education opportunities, a wide variety of jobs, open spaces, healthy environments, and more. The analysis found low levels of educational attainment citywide. Additionally, the analysis found jobs are not easily accessible from the City, as the Southeast Los Angeles Cities region does not feature any job centers. Professional jobs are even more difficult to access from Cudahy. In terms of accessibility to healthy living conditions, the analysis found that some of the City’s housing stock

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is in need of major repairs. Lastly, the entire region cannot be considered a healthy environment, due to the industrial uses in the region along with the location of the I-710.

Disproportionate Housing Needs and Displacement Risk
Disproportionate housing needs refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing the category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, homelessness, and substandard housing conditions.

Cost Burden
Cost burden refers to the number of households for which housing cost burden is greater than 30% of their income. Severe cost burden refers to the number of households for which housing cost burden is greater than 50% of their income. According to overpayment data from the 2015- 2019 ACS 5-Year Survey, as included in HCD’s AFFH Data Viewer, the majority of homeowners in the City of Cudahy are cost burdened. For the City’s Census tracts, the tract with the lowest rate of cost burdened homeowners is located in the northeast corner of the City. The two tracts with the highest rate of cost burdened homeowners are located in the northern central portion of the City and the northwestern corner of the City.

Within the Southeast Los Angeles Cities region, the majority of Census tracts feature high percentages of cost burned homeowner households, just like in Cudahy. The percentage of cost burdened homeowner households decreases further South into Downey.

The HCD AFFH Data Viewer also finds that all Cudahy Census tracts feature a high percentage of renter households that are cost burdened. Based on SCAG Pre-Certified Data, 59.3% of renters in Cudahy spend more than 30% of their income on housing and 30.3% of renters spend more than 50% of their income on housing. The two census tracts with the highest percentage of cost burdened renter households were in the northern central portion of the City and the northeastern corner of the City, all east of Atlantic Avenue.

Within the Southeast Los Angeles Cities region, the majority of Census tracts feature high percentages of cost burned renter households, just like in Cudahy. The percentage of cost burdened renter households decreases further Southeast into Downey.

In response to overpayment, in 2022 the City adopted the Inclusionary Housing Program requiring inclusion of affordable units in market rate residential projects and the City has included Program 3 (Accessory Dwelling Units), Program 4 (Promote Lot Consolidation), and Program 5 (Affordable Housing Incentives). Currently, the City has a rent increase moratorium on multifamily housing, through January 18, 2023. This moratorium was put in to give the City’s Rent Control Ad Hoc Committee (Program 31) time to study and evaluate possible rent control and

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tenant protection programs, and the need to extend the moratorium. The moratorium will likely be extended until the committee is able to present its findings. It is likely this moratorium is resulting in less tenant harassment and evictions, which reduce the number of fair housing complaints received by the City.

Overcrowding
Overcrowding is defined as households having more than 1.01 to 1.5 persons per room. Severe overcrowding is defined as households having more than 1.51 persons per room. Overcrowding is an issue in the City of Cudahy, according to CHHS data from HCD’s AFFH Data Viewer. All Census tracts in Cudahy feature over 20% of households that are overcrowded. In fact, the Census tract with the lowest rate of overcrowding (28.18%) is located in the northwestern corner of the City.

The tracts with the highest rate of overcrowding (36%) in Cudahy are located on the eastern side of the City. Two of Cudahy’s Census tracts feature severely overcrowded households. Most significantly, the Census tract in the southeastern corner of the City features the highest percentage of severely overcrowded households, at 5%.

Overcrowding is also an issue within the larger Southeast Los Angeles Cities region. Within the City of Bell, all census tracts except one feature overcrowding rates over 20%. Additionally, all Bell census tracts but two feature severely overcrowded households. All but one census tract in the City of South Gate feature overcrowding rates over 20%. The one remaining census tract is an almost exclusively industrial area. In the City of South Gate approximately half of the cities census tracts feature severely overcrowded households. All but one census tract in the City of Huntington Park feature overcrowding rates over 20%. In the City of Huntington Park, seven of the City’s sixteen census tracts featured severely overcrowded households.

Outside of Cudahy within the Southeast Los Angeles Cities region, the majority of Census tracts feature over 20% of households that are overcrowded. Severe overcrowding ranges from less than 5% to over 65% in different tracts in the region. The percentage of overcrowding decreases as one moves further Southeast within the region, towards Downey and Santa Fe Springs.

In response to overcrowding in the City, in 2018, as part of the City’s comprehensive General Plan and Zoning Code update, the City rezoned properties, increasing densities to encourage higher density residential development. The City adopted the Inclusionary Housing Program in 2022 to require the construction of affordable units within market rate projects and has amended Program 3 (Accessory Dwelling Units) and added Program 25 (Single Room Occupancy Units) to further affordable housing opportunities.

Substandard Housing Problems and Housing Stock Quality
Substandard housing problems include: 1) Lacking a complete kitchen, 2) lacking complete plumbing, 3) severe overcrowding, and 4) severe cost-burden. According to ACS and CHAS data included in HCD’s AFFH Data Viewer, the majority of cities within the Southeast Los Angeles Cities region feature 40 to 60% of households that have any of the four severe housing problems. Fiftytwo percent of households in the City of Cudahy feature any of the four severe housing problems.

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Severe housing problems are also less prominent to the southeast, south of Lynwood, in the cities of Downey, Paramount, and Bellflower. In these cities, the percentage of households facing severe housing problems are 29.9%, 38.9%, and 35% respectively.

Over half of the City’s housing stock was built prior to 1960. A citywide housing condition survey conducted in 2013 found that the majority of the housing units (5,403 units) in the City are in “Good” Condition, meaning no repairs were warranted. The same survey found 246 units in the City in “Minor Fix-Up/Paint-Up” condition, meaning only a new paint job or minor repairs were needed. Approximately 118 housing units were found to need “Major Repairs”, such as replacement of roof. Lastly, 3 housing units were found to be “Beyond Repair”.

The City has an active code enforcement division which responds to complaints, including maintenance and safety concerns. Through these code enforcement efforts, the City will continue to follow up with landlords to ensure repairs are made so the unit can be occupied, and the City will continue to assist homeowners to apply for rehabilitation funding; Program 8 (Housing Maintenance and Conservation), Program 12 (Neighborhood Preservation), Program 13 (Code Enforcement), and Program 23 (Housing Conditions Survey) also address housing quality.

Homelessness
Homelessness is an issue in the Southeast Los Angeles Cities region; however, it is less acute than in communities to the North and East of the Southeast Los Angeles Cities region. The City of Cudahy has an unhoused population of 47 people (according to the 2022 LAHSA count), 45 of which are unsheltered. Within the greater Southeast Los Angeles Cities region, the City of Cudahy has a relatively small unhoused population. Within Service Planning Area (SPA) 7, the total unhoused count in 2022 was 4,781.

Program 9 (Hotel and Motel Resources) says that there are 160 hotel rooms which are sufficient to accommodate the local demand for shelter. The City works with these hotel operators to place homeless residents in the City into these 160 hotel rooms.

Displacement Risk
UC Berkeley’s Urban Displacement Project classifies Census tracts in terms of their “displacement typology.” According to the data, Cudahy ranks in the middle of its severity classification.

Cudahy’s neighborhoods are classified as “low-income/susceptible to displacement,” “ongoing displacement,” and “early/ongoing gentrification”. The contribution of new development to gentrification is probably minor, perhaps being limited to direct displacement of people affected by demolition of older housing in order to construct new housing. The City’s recently adopted Inclusionary Zoning Ordinance, as well as Program 26 (Replacement Housing) will ensure that new affordable housing is created where ever older housing is demolished to construct new units, and will give those displaced opportunities to occupy new units.

New development in Cudahy has not significantly altered the desirability of the broader community to the point where widespread gentrification is evident. Rather, displacement in

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Cudahy is driven by rising regional housing prices. Prices for housing have been rising throughout the Los Angeles region and the City of Cudahy is no exception. Thus while Cudahy might not be experiencing disinvestment-driven displacement, investment-driven displacement, or disasterdriven displacement, the City is still experiencing significant levels of displacement pressure due to high housing costs.

The greater Southeast Los Angeles Cities region does feature displacement risk, ranging from early/ongoing gentrification, low-income/susceptible to displacement, ongoing displacement, advanced gentrification, and at risk or becoming exclusive. Those cities actively experiencing some level of gentrification are located closest to Cudahy within the region and they include cities such as South Gate, Bell Gardens, Bell, Maywood, and Huntington Park. Communities such as Lynwood, Bellflower, Downey, and Paramount, on the other hand have a lower gentrification risk, as these communities are more stable moderate/mixed income and at risk of becoming exclusive. However, gentrification is much less pronounced in these communities than in other parts of the Los Angeles region such as Mid-City, South Los Angeles (Crenshaw area), or Boyle Heights.

According to SCAG, between 2000 and 2020 median home sales prices in Cudahy increased 179% while prices in the SCAG region increased 151%. The rising cost of housing in Cudahy is reflective of trends in the SCAG region and throughout California, and increases the risk of displacement for residents, particularly lower-income households. While housing costs have risen in recent years, wages have not kept pace. The 2000 median income in Cudahy was $28,957 and the median income in 2020 was $46,642, which is a 61% increase. The difference in these trends indicates growing unaffordability of housing in Cudahy that may prevent low-income households from remaining in their homes over time. To address affordability challenges, the City adopted the Inclusionary Housing Program in 2022 and includes Program 3 (Accessory Dwelling Units), Program 6 (CDBG), and Program 25 (Single Room Occupancy Units).

The Urban Displacement Project classifies Cudahy’s renter vulnerability as very high at 7-10 on a 10-point scale due to the population’s high rent burden, overcrowding, and concentration of employment in low-wage sectors. The Urban Displacement Project classifies the Southeast Los Angeles Cities region’s renter vulnerability as 3-10 on a 10-point scale. However, most Census tracts within the region rank from 7-10, due to the population’s high rent burden, overcrowding, and concentration of employment in low-wage sectors.

Conclusion
In conclusion, the disproportionate housing needs and displacement risk analysis found many similarities between the City of Cudahy and the larger Southeast Los Angeles Cities region. The City suffers from severe cost burdening, not dissimilar to the region and larger county. The City also features a high rate of overcrowding, similar to the region yet significantly higher than the County’s overcrowding rate. The overcrowding rate is highest in the southeastern portion of Cudahy. Additionally, the analysis found that a small portion of the City’s housing is in need of

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major repairs. Lastly, the analysis found that the City is impacted by rising housing prices and high renter vulnerability, which is common in the region and county.

According to the US Census 42.7% of Cudahy’s residents have less than a high school education.

The 2020 Census notes that Cudahy workers 16 years of age and older have a travel time of 32.6 minutes to work. In a City of 1.2 square miles, nearly built out, this data indicates that Cudahy’s workers commute outside the City’s boundaries. The dominant mode of transportation for workers is a vehicle. In 2022 the City initiated the preparation of an Economic Development Strategic Plan to determine the needs of the City, programs to promote economic development to create more jobs in the City, and opportunities to increase revenues. Beginning in 2022 opportunities to address housing issues as part of economic development will be available through the City’s Economic Development Strategic Plan outreach efforts. Program 14 has been amended to include a review of the outcomes of the economic development report as they relate to housing issues, including transportation opportunities, and the pursuit of funding sources for related infrastructure improvements.

In 2021, the California Office for Environmental Health Hazard Assessment (COEHHA) released the fourth version of CalEnviroScreen, a tool that uses environmental health, and socioeconomic indicators to map and compare a community’s environmental scores. A community within the 75th percentile or above, is one with higher levels of pollution and other negative environmental indicators and is considered a disadvantaged community. 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 located on the west side of town, while four of the census tracts are within the 91% to 100% percentile located on the north, south, and east side of town along the Interstate 710 corridor. The higher the percentile scores, the more a community is vulnerable to the potential effects of pollution.

Interstate 710 is an important regional freight corridor, and the associated traffic volumes and air quality impact Cudahy. Although there is not much the City can do regarding proximity to Interstate 710, the City’s implementation of the California Environmental Quality Act (CEQA) guidelines regarding construction and new development, can begin to mitigate some of the environmental impacts of pollution within the City. To ensure residents throughout the City have access to positive environmental conditions, the City will review open space requirements for

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new developments and will revise requirements as necessary to ensure all residents have access to healthy outdoor spaces (Program 12 Neighborhood Preservation).

Disproportionate Housing Need and Displacement Risk
Overcrowding in the City of Cudahy is a significant issue. In Cudahy, 93 owner-occupied and 1,518 renter-occupied households had more than 1.0 occupants per room, which meets the definition for overcrowding. Seven owner-occupied households and 346 renter-occupied households had more than 1.5 occupants per room, which meets the definition for severe overcrowding. In 2018, as part of the City’s comprehensive General Plan and Zoning Code update, the City rezoned properties, increasing densities to encourage higher density residential development. The City adopted the Inclusionary Housing Program in 2022 to require the construction of affordable units within market rate projects and has amended Program 3 Accessory Dwelling Units and added Program 25 Single Room Occupancy Units to further affordable housing opportunities.

As shown in the Tables in Chapter 2, renters and homeowners are overpaying for housing throughout the City. According to the 2020 Census data, 50.9% of the City's households are severely overpaying for housing. Of the 50.9%, there are 15.5% severely overpaying for housing.

In 2022 the City adopted the Inclusionary Housing Program requiring inclusion of affordable units in market rate residential projects and the City has included Program 3 Accessory Dwelling Units, Program 4 Promote Lot Consolidation, and Program 5 Affordable Housing Incentives.

In addition to the issues of overcrowding and overpaying, housing condition can present a safety concern for residents living in substandard housing in need of repairs. Over half of the City’s housing stock was built prior to 1960. Because of the age of the homes and apartments, it can be assumed that at least some low-income households in the City are living in substandard conditions. The City has an active code enforcement division which responds to complaints, including maintenance and safety concerns. Through these code enforcement efforts, the City will continue to follow up with landlords to ensure repairs are made so the unit can be occupied, and the City will continue to assist homeowners to apply for rehabilitation funding; Program 8 Housing Maintenance and Conservation, Program 12 Neighborhood Preservation, Program 13 Code Enforcement, and Program 23 Housing Conditions Survey.

Displacement occurs when a household is no longer able to remain in their home for any number of reasons. There are several indicators of displacement risk that include overcrowding, overpayment, and substandard housing conditions. Other key indicators include an increase in home prices and rents, low vacancy rates, and wage increase that are less than home price increases. According to SCAG, between 2000 and 2020 median home sales prices in Cudahy increased 179% while prices in the SCAG region increased 151%. Cudahy census data for the year 2020 indicates that 45.2% of owner-occupied units and 56.3% of renter occupied units paid more than 30% of their monthly income towards housing. The rising cost of housing in Cudahy is reflective of trends in the SCAG region and throughout California, and increases the risk of displacement for residents, particularly lower-income households. While housing costs have

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risen in recent years, wages have not kept pace. The 2010 median income in Cudahy was $39,388 and the median income in 2020 was $46,642.00. The difference in these trends indicates growing unaffordability of housing in Cudahy that may prevent low-income households from remaining in their homes over time. To address affordability challenges, the City adopted the Inclusionary Housing Program in 2022 and includes Program 3 Accessory Dwelling Units, Program 6 CDBG, and Program 25 Single Room Occupancy Units.

Enforcement and Outreach Capacity
The City enforces fair housing and complies with fair housing laws and regulation through a twofold process: review of City policies and code for compliance with State law and referring fair housing complaints to appropriate agencies. The City will continue to review the Zoning Code to ensure compliance with fair housing law, and continue to examine land use policies, permitting practices, and building codes to comply with state and federal fair housing laws, Program 28 Zoning Code Review.

In addition to assessing fair housing issues related to development standards, fair housing issues can also include discriminatory behaviors by landlords such as refusal to grant reasonable accommodation requests, not allowing service animals, discrimination against familial status, sex, religion, or other protected class, and more. The City manages a Citizens Complaint Log on the Cities website https://www.Cityofcudahy.com/FormCenter/Public-Safety-Services6/Complaint-Violation-Reporting-Form-48 The “other” category on the log can be used to file fair housing complaints. The City reviews the complaints and refers the complaint to the appropriate City Department or service agency. The City would refer any complaints, depending on the nature of the complaint to one or more of the following service agencies: the Department of Fair Housing and Employment, Fair Housing Foundation, Department of Consumer Affairs, and Legal Aid. The City will continue Program 16 Fair Housing which includes posting and providing fair housing information in the City.

Sites Inventory
The opportunity map prepared the California Tax Credit Allocation Committee (TCAC) and the California Department of Housing and Community Development were reviewed by the City. The opportunity map identifies areas in every region of the state whose characteristics have been shown by research to support positive economic, educational, and health outcomes for lowincome families. The TCAC data indicates that the City of Cudahy is divided into two composite scores, “high segregation and poverty” and “low resources.” These scores are used to determine the amount of federal and state tax credits that would be allocated to developers of affordable projects. Based on Cudahy’s scores, the developers of affordable housing in Cudahy could receive federal and state tax dollars for the development of affordable housing in the City.

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Using the statewide opportunity area map and indicators of segregation, displacement risk, and access to opportunity as overlays to the City’s site inventory, the City was able to identify if the sites identified in the inventory to accommodate the lower-income RHNA disproportionately concentrate these units or increase patterns of segregation. Although the entire City of Cudahy is characteristic of low income, low education levels, overcrowding, overpayment, and vulnerable to the potential effects of pollution, a review was still completed to identify if there was any indication that the RHNA sites were concentrated in one specific area of the City or not. This Housing Element features 33 sites within its site inventory. The review concluded that there are no clusters of RHNA sites in the City. The 33 sites are spread throughout the City. Additionally, sites with lower income capacity are not concentrated in any area of the City. Sites with moderate income capacity area also not concentrated in a any area of the City and instead are spread throughout the City. Sites with above moderate income housing are not concentrated in any area of the City and are spread throughout.

The majority of the 33 sites are located in the City’s HDR and MDR zones. A small number of these sites are located within the City’s mixed use zones (1 site), commercial zones (2 sites), and LDR zone (6 sites). The low and medium residential zoned vacant sites are generally located on the east and west sides of the City, while the high density zoned vacant sites are generally located on the north side of the City and within the center of the City flanking the Atlantic Avenue Mixed Use Corridor.

The southeastern corner of the City, identified as a TCAC area of high segregation and poverty, features six Housing Element sites, only one of which has a low income capacity of 21 multifamily units on Elizabeth Street, north of Park Avenue Elementary School. The rest of the City’s 13 sites with low income capacity are spread throughout the City. The TCAC area of high segregation and poverty features three sites with moderate income capacity. Only one site with above moderate income housing is located within the TCAC area of high segregation and poverty. Since the housing element sites for all three income levels are dispersed throughout the City, this housing element site inventory does not contribute to maintaining current patterns of segregation and inequity. Instead, this housing element site inventory promotes the development of housing for all three income groups throughout the entire City. The vacant commercial zoned sites are located in the north portion of the City along Atlantic Avenue. The underutilized sites are generally located in the center of the City, west of the Atlantic Avenue corridor. Although the sites are dispersed throughout the City,Additionally, the City furthered efforts to provide affordable housing Citywide with the adoption of the Inclusionary Housing Program in 2022.

Contributing Factors
Through the outreach program and discussions with community members; several factors were identified that contribute to fair housing issues in Cudahy. Table 22.2016 identifies these factors.

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Table 2.20
Contributing Factors to Fair Housing Issues
Table 2.16
Contributing Factors to Fair Housing Issues
AFH Identified Fair Housing
Issues
Contributing Factors Meaningful Actions
Disproportionate access to
services.

Predominate Hispanic
population.

Low education levels.

Jobs located outside of the City.

Continue bilingual programs for
all City services and
communications. Program 15
Public Participation.

Continue working with the local
schools to support bilingual
programs. Program 15 Public
Participation.

Identify transit services. Include
business development and
transit opportunities in the
2022 City Economic
Development Strategic Plan.

Program 14 Infrastructure
Availability.

Displacement risk for residents
due to economic pressures.

Limited affordable ownership
and rental options.

High cost of housing.

Implement Inclusionary Housing
Program 5 Affordable Housing
Incentives.

Provide lot consolidation
assistance, Program 4 Promote

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Lot Consolidation and other
incentives Program 5 Affordable
Housing Incentives for
affordable housing.

Condition of housing. Majority of units constructed
prior to 1960. Cost of
rehabilitation and repairs.

Continue providing
rehabilitation and repair
services, including funding.

Program 6 CDBG (which
includes the Housing
Rehabilitation Program)
Program 8 Housing
Maintenance and Conservation,
Program 12 Neighborhood
Preservation, and Program 13
Code Enforcement.

AFFH Identified Fair
Housing Issues
Contributing Factors Meaningful Actions
Disproportionately
low access to jobs
and commercial
amenities.

Priority Level:

Medium
Lack of professional and service job centers in
Cudahy and the Southeast Los Angeles Cities
region.

High traffic congestion making it difficult to access
jobs.

Lack of high quality transit access for residents
without cars to be able to access jobs.

Lack of high quality commercial amenities in the
City. Residents often have to leave the City of
Cudahy to make purchases and receive services.

In Program 33 (Economic Development Strategic Plan and Transit-Oriented Development), the City embarks on a coordinated strategy to increase job opportunities and commercial amenities through transit-oriented mixed-use development in the City’s Entertainment zone. Specific commitments include adoption of the Economic Development Strategic Plan, annual outreach to developers, and development of publicly-owned sites in keeping with the Surplus Land Act.

Through Program 14 (Infrastructure Availability) and the 2023 Economic Development Strategic Plan, the City commits to reviewing transportation opportunities to increase access to opportunity, and pursuing funding sources for improvements if necessary. The City also commits to further reviewing and adopting specific standards for streets, including bicycle facilities and ADA accessibility.

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Additionally, the City of South Gate recently built the Azalea Regional Shopping Center abutting the southeast corner of Cudahy. This new shopping center has increased access to jobs for Cudahy residents. Some businesses which moved into the Shopping Center are Walmart, Ross Dress for Less, ULTA, Michael’s, and more.

Older Housing Stock
with some signs of
disrepair
Priority Level:

Medium
Older housing stock; high cost for rehabilitation
and repairs.

Substandard housing which does not meet
building code requirements.

Unusual lot sizes which do not accommodate
single family homes well. As a result, there are few
single family neighborhoods in Cudahy and the
number of owner occupied housing units is low.

Single family homes tend to be occupied by the
owner, meaning upkeep on the home is a priority
as owners wish to maintain the value of their
home.

With Program 8 (Housing Maintenance and Conservation), the City will continue the program for the maintenance and conservation of the existing housing stock through the sixth cycle. The Program specifically targets the conservation of older housing units which are in good condition to maintain the units as affordable housing options. By maintaining the existing housing stock and preventing the creation of substandard housing, the City improves the living environment for present and future residents.

Through Program 13 (Code Enforcement), the City shall continue code enforcement each year 2021-2029, focusing on property maintenance, substandard units, and illegal garage conversions. Substandard dwelling units shall be identified, and rehabilitation shall be encouraged through the provision of technical support and incentives.

Program 23 (Housing Conditions Survey). The City shall complete a Housing Conditions Survey to identify the number of units in need of rehabilitation and replacement. The Survey shall be completed in 2023, and housing maintenance and code enforcement strategies will be modified accordingly
Through Program 32 (First Time Homebuyers) the City will promote homeownership in the City.

The City will partner with nonprofits that administer first time homebuyer funding and use inlieu fees from the Inclusionary Housing Ordinance to assist with first time homebuyer assistance.

High cost burdens
and overcrowding
for renters and
homeowners
resulting in
displacement risk.

Priority Level: High
Supply constraints and general lack of affordable
housing in the Southern California region.

Lack of affordable housing in Cudahy.

Through Program 29 (Implementation of the Inclusionary Housing Program), the City shall begin implementation of the Inclusionary Housing Program adopted in 2022 to include a requirement that all residential and mixed-use projects with a residential component include affordable housing units. This Inclusionary Housing Program should increase the affordable housing supply in the City of Cudahy, reducing the high housing cost burden for some residents. Additionally, the construction of additional units should alleviate overcrowding in Cudahy.

With Program 5 (Affordable Housing Incentives), the City commits to encouraging the development of affordable housing units in Cudahy. The City will accomplish this by conducting

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outreach to developers (both market rate and affordable), streamlining the permit process to low-income and senior housing projects, streamlining environmental review for eligible Inclusionary Housing projects, providing technical assistance to affordable housing developers, and providing developers with a list of affordable housing financing sources.

As part of Program 4 (Promote Lot Consolidation), the City commits to establishing development incentives including a list of potential consolidation sites, a review to streamline lot consolidations, provide assistance with compliance with the state’s Subdivision Map Act requirements, fee reductions, ADA compliance, and infrastructure support. Lot consolidation is important for the production of new housing in Cudahy due to the unique lot sizes and shapes which exist in the City. In some cases, lot consolidation is necessary to make a development feasible in the City.

The City will continue providing rehabilitation and repair services, including funding, to preserve the existing housing units in Cudahy. Programs that apply here are Program 6 (CDBG), Program 8 (Housing Maintenance and Conservation), Program 12 (Neighborhood Preservation), and Program 13 (Code Enforcement).

The City’s updating of ADU standards in Program 3 (Accessory Dwelling Units) should result in increased production of ADUs in Cudahy.

As part of Program 27 (State Density Bonus Law) the City commits to reviewing the City’s density bonus standards and amending the Zoning Code as necessary to comply with State Density Bonus Law.

In Program 31 (Rent Control Ad Hoc Committee), a Committee of the City Council will study adoption of rent stabilization and tenant protection ordinances for the City of Cudahy. The City has currently enacted a rent increase moratorium on multifamily housing, through April 2023 to give the Rent Control Ad Hoc Committee time to complete its study and for the City Council to take appropriate action.

Through Program 32 (First Time Homebuyers) the City will promote homeownership in the City, increasing housing stability. The City will partner with nonprofits that administer first time

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homebuyer funding and consider use of in-lieu fees from the Inclusionary Housing Ordinance to assist with first time homebuyer assistance.

Low level of fair
housing complaints
among all
communities in the
Southeast Los
Angeles Cities
region.

Priority Level: Low
Lack of knowledge of fair housing laws.

Limited local government capacity.

Linguistic isolation.

Fear among undocumented residents.

Continue bilingual programs for all City services and communications and continue working with the local schools to support and prioritize bilingual services, bilingual noticing/communication, and ESL classes through Program 15 (Public Participation).

Through Program 6 (CDBG Information) and Program 16 (Fair Housing), the City funds its relationship with the Housing Rights Center, which receives all fair housing complaints issued by Cudahy residents. Additionally, the City prepares and distributes fair housing information, including the services of the Housing Rights Foundation, through community events, utility bill mailers, posting in public places and working with interested groups.

Currently, the City has a rent increase moratorium on multifamily housing, through April 17, 2023. This moratorium was put in to give the City’s Rent Control Ad Hoc Committee, Program 31, time to study and evaluate possible rent control and tenant protection programs, and the need to extend the moratorium. The moratorium will likely be extended until the committee is able to present its findings. It is likely this moratorium is reducing the number of complaints, including harassment complaints, received by the City due to a lack of rent increases.

Additionally, just cause evictions have likely decreased in the City due to a lack of rent increases in Cudahy.

Generally, the entire
City of Cudahy
experiences high
pollution burdens
and high levels of
exposure to
environmental
contaminants due
to the City’s
positioning in the
Southeast Los
Angeles Cities
region. The
southeastern
Proximity to the I-710 and Los Angeles River.

Proximity to Heavy Manufacturing (M3) zone in
the City of South Gate. Historically, this area of
South Gate abutting the southeastern corner of
Cudahy housed heavy industrial uses, large
manufacturing plants.

Close proximity to industrial contamination
decreases the desirability of the southeastern
corner of the City.

The City of South Gate is planning on transitioning a portion of their M3 Heavy Manufacturing zone (close to the southeastern corner of Cudahy) into a mixed-use TOD district. This shift from heavy manufacturing to mixed-use TOD land uses will benefit residents of Cudahy’s southeastern Census tract, increasing the residents’ proximity to new commercial amenities and reducing the residents’ exposure to industrial contaminants. New commercial amenities located close to the southeastern corner of Cudahy and decreased exposure to contaminants could increase the desirability of the neighborhood.

Through Program 30 (Environmental Enhancements) the City commits to reviewing a selection of environmental policies and regulations for adoption and implementation to reduce the amount that Cudahy residents are exposed to environmental contaminants. The City has already taken steps to reduce environmental contamination in the City, through a ban on trucking terminals in the City and a tree planting requirement for multifamily residential development.

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portion of the City,
near the I-710, is
considered a TCAC
area of high
segregation and
poverty. In addition,
this TCAC area of
high segregation
and poverty is
slightly worse of in
terms of exposure
to environmental
contaminants,
compared to the
rest of Cudahy.

Priority Level:

Medium
Low rates of
education
attainment
throughout City,
with the lowest
rates occurring in
the TCAC area of
high segregation
and poverty.

Priority Level: Low
Low quality K-12 schools in Cudahy.

High foreign-born population.

Linguistic isolation.

Continue working with the local schools to support and prioritize bilingual services, bilingual noticing/communication, and ESL programs through Program 15 (Public Participation).

In Program 14 (Infrastructure Availability), the City will review transportation availability to promote access to educational opportunities located around Los Angeles County.

High degree of racial
uniformity among
all communities in
the Southeast Los
Historic discrimination.

Restrictive zoning and lack of affordable housing
in more affluent communities.

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Angeles Cities
region.

Priority Level: Low

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3 Regional Housing Needs Assessment and Special Needs
List of Charts, Tables, and Maps
Chart 3.1 – …………………………………………………………..Disability by Type - Page 67 Chart 3.2 - ……………………………Disability by Type (Seniors 65 and Over) - Page 67 Chart 3.3 – ………………………..Disability by Type – Seniors 65 Years and Older - Page 73 Chart 3.4 – ……………………………………………………Disability by Type – Page 74 Chart 3.5 – ……………………………………Female-Headed Households - Page 75 Chart 3.6 - …………………………………. ….. Households by Household Size - Page 76 Table 3.1 - ……………………………………………………..……….RHNA 6th Cycle – Page 65 Table 3.2 ……………………………………………Disability by Employment Status – Page 71 Table 3.3 …………………………………………………Farmworkers by Occupation – Page 77 Table 3.4 ………………………………… Employment in the agricultural Industry – Page 77

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3.1 REGIONAL HOUSING NEEDS ALLOCATION, 2014-2021
Every cityCity and county in the State of 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 and other Southern California jurisdictions, the regional housing need is determined by the Southern California Association of Governments (SCAG), based upon an overall regional housing need number established by the State. In accordance with State law, SCAG has determined the fair share of the regional housing need that must be planned for by each jurisdiction during the 2013 to 2021 planning period. That need is divided into four income categories of housing affordability (in accordance with State law).

Methodology
The RHNA methodology assigns each jurisdiction a share of the region’s total housing need. The methodology includes an allocation tool that is a mathematical equation that consists of weighted factors. For example, if one of the factors, e.g., household growth, is determined to be more important that another factor, e.g., transit. The methodology can give household growth a higher weight than transit in the formula. The methodology may also equally weight the factors, therefore ensuring that all the factors are of equal priority. • The factors and weights (expressed in parenthesis) are:
• Household growth (45%)
• Existing employment (22.5%)
• Employment growth (22.5%)
• Household growth near existing transit (5%)
Employment growth near existing transit, Household growth, existing employment, and employment growth are estimated in SCAG’s regional household and employment forecasts. A jurisdiction’s share of the Regional Housing need is assigned accordingly to its percentage share of regional household growth, employment growth, existing employment, and household and employment growth near transit:
(Household Growth x 0.45) + (Employment Growth x 0.225) + (Existing Employment x 0.225) + (Household Growth near Transit x

0.05) + (Employment Growth near Transit x 0.05)
After determining the housing need, a number of “rules” are established by SCAG to determine the allocation of units by income. The broad concept is that local jurisdictions must plan for

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income-based housing relative to the regional average. The income allocations scenarios give each jurisdiction 175 percent of the difference between their 2020 household income distribution and the 2020 regional household income distribution. An “adjustment factor” is then applied to determine housing unit allocation in each income category.

For a complete discussion of the methodology, see SCAGS website at: http://www.scag.ca.gov/ Cudahy’s ‘Fair Share’ Of The Regional Housing Need
Regional Housing Needs Assessment provides a discussion of the Regional Housing Needs Assessment and how the cityCity intends to accommodate its identified housing need.

The authority to determine housing needs for the various income groups for cities within the Southern California region has been delegated to the Southern California Association of Governments (SCAG), pursuant to Section 65584 of the Government Code. The housing needs are categorized according to the following income groups:

The Extremely Low-Income households are those whose income is 30% or less than that of the median household income for the greater Los Angeles area; The Very Low-Income households are those whose income does not exceed 50% of the median household income for the greater Los Angeles area; The Low-Income households earn from 51% to 80% of the median; The Moderate-Income groups earn from 81% to 120% of the median; and, The Above Moderate households earn over 120% of the median income.

The various housing categories and the income thresholds for each are discussed above. SCAG’s Regional Housing Needs Assessment (RHNA) estimated the eight-year future housing construction need for Cudahy at 393 units. Tables 3.1, 3.2, and 3.3 identify the 4th, 5th, and 6th RHNA cycles respectively.

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Table 3.1 RHNA 4th Cycle and Table 3.2 RHNA 5th Cycle
Table 3.1 RHNA 4th Cycle and Table 3.2 RHNA 5th Cycle
Table 3.3
RHNA 6th Cycle
Table 3.3
RHNA 6th Cycle
October 2021 – October 2029
Number of Units Number Percentages
Very Low-Income Households 80 20.35%
Low-Income Households 36 9.16%
Moderate Income Households 53 13.48%
Above Moderate-Income Households 224 56.9%
Total Needed-Future Housing 393 100%
Southern California Association of Governments
As indicated previously, those households that have incomes of 30% of the County median would fall into the extremely low-income category. Based on the 2020 income limits, an extremely lowincome household would have the following household incomes: a one-person household with an annual income of $17,400 or less; a two-person household with an annual income of $19,900 or less; a three-person household with an annual income of $22,400 or less; and a four-person household with an annual income of $24,850 or less.

The planning period governed by the RHNA extends from 2021 to 2029. As a result, the cityCity will only receive credit towards the RHNA for the new housing that is entitled, under construction, or built beginning in 2021.

As indicated in Table 3.2 the CityCity's remaining unmet need for the planning period is 393 units.

There is a remaining unmet need for above moderate-income units (141 units are still needed), moderate-income units (51 units are still needed), low-income units (46 units are still needed), and very low-income units (80 units are still needed).

Table 3.1 RHNA 4th Cycle
January 2006 – June 2014
Table 3.2
RHNA 5th Cycle
January 2014 – October 2021
Number of Units Number Percentages Number of Units Number Percentages Very Low-Income Households 94 23% Very Low-Income Households 80 25% Low-Income Households 60 15% Low-Income Households 46 15% Moderate Income Households 67 17% Moderate Income Households 51 16% Above Moderate-Income
Households
180 45% Above Moderate-Income
Households
141 44%
Total Needed-Future Housing 401 100% Total Needed-Future Housing 318 100% Source: Southern California Association of Governments

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What The Numbers Mean
The primary goal of the RHNA numbers is to act as targets for jurisdictions to achieve during the planning period. Because local jurisdictions are rarely if ever involved in the actual construction of housing units, sometimes it is not possible for these targets to be met. HCD does not penalize jurisdictions for not meeting RHNA targets, if they have allocated enough land for the construction of units and have made a good effort through the implementation of housing policies and programs to help meet the RHNA targets.

3.2 SPECIAL HOUSING NEEDS
In addition to the general housing needs of the population, cities and counties must plan for the special housing needs of certain groups. For the Housing Element, Government Code (65583(a)(6)) requires that several populations with special needs be addressed: people who are homeless; persons with disabilities; female-headed households; large households; seniors; overcrowded households; farmworker households. To meet the needs of these groups; Cudahy must be creative and look to new ways of increasing the supply, diversity, and affordability of this specialized housing stock. The charts below identify disability by type and disability by type of seniors 65 and over.

Chart 3.1 - Disability by Type
American Community Survey 2014-2018 5-year estimates.
397
291
718
939
491
733
0 100 200 300 400 500 600 700 800 900 1,000
Hearing
Vision
Cognitive
Ambulatory
Self-care
Independent Living

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Chart 3.2 - Disability by Type (Seniors 65 and Over)
American Community Survey 2014-2018 5-year estimates.

Understanding the employment status of people with special needs disabilities may also be an important component in evaluating specialized housing needs. In Cudahy, 27.8% of the population with a disability is employed, compared to 69.8% of the non-disabled population.

EMERGENCY SHELTER & TRANSITIONAL HOUSING
The primary agency that deals with the issue of homelessness in the cityCity is the Los Angeles County Sheriff’s Department, which serves Cudahy. Very few homeless persons have been observed in the cityCity. Homeless persons (single males and females) have been found in the Cudahy area along the banks of the Los Angeles River in the CityCity of Bell Gardens and the trash bins at local supermarkets. Homeless persons are encouraged to seek assistance from the Department of Public Social Services on Atlantic Avenue and local community services (Chicana Service Action Center, Human Services Association) in neighboring cities. The Salvation Army operates a shelter located at 1370 Alamitos Avenue in the CityCity of Long Beach. This Salvation Army shelter provides services to an average of 73 people per day. Of this number, approximately 10% are homeless. The Bell Shelter, located in the CityCity of Bell adjacent to Cudahy, provides transitional housing for women with dependent children. The focus of the shelter’s services is to provide women who are victims of domestic violence with housing while they are making a transition to independent living; the shelter has a 24-bed capacitycityCity. The Los Angeles Homeless Service Authority is also a good resource; their mission is “to support, create and sustain solutions to homelessness in Los Angeles County by providing leadership, advocacy, planning, and management of program funding” (http://www.lahsa.org).

Emergency Shelters
Emergency shelters are allowed without discretionary review in the Commercial Mixed Use (C/MU), Civic Mixed Use (Civic/MU), and Entertainment (E) zoning districts. Combined, these zone districts encompass 84.8 acres. The zoning districts identified are located along Atlantic

10.7%

3.9%

8.9%

20.8%

10.4%

19.8%

13.1%

6.6%

10.1%

22.9%

10.5%

17.5%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%
Hearing Vision Cognitive Ambulatory Self-care Independent Living
Percent of Senior Population
Cudahy Percent SCAG Region Percent

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Avenue, the CityCity’s main north/south corridor. The central location of these districts puts potential shelters near the core services and transportation corridor within the cityCity. Services in the immediate area include a large dialysis facility, Kaiser Permanente (non-emergency) medical treatment facility, six clinics or medical facilities, and the County of Los Angeles Department of Public Social Services.

Additionally, within the immediate area are seven main Metropolitan Transportation Authority bus lines including routes 111, 260, 315, 361, 611, 612, and 711, as well as the Cudahy Area Rapid Transit (CityCity fixed route). Among the 84.8 acres of land in the three zoning districts, 11.5 acres are vacant. There are 6 large vacant sites (made up of various vacant lots) that range from 5 acres to 0.6 acres. North of Santa Ana Street, the predominant use in these districts is commercial (mostly in the form of large to small shopping centers, individual commercial uses, and motels) and residential (multi-family). South of Santa Ana Street, most buildings in the districts identified are vacant or have older, light industrial uses. As the southern area has transitioned slightly away from its industrial roots, several industrial uses have been repurposed, for example, for a church.

The Los Angeles Department of Public Social Services maintains a large office location in this area from which they administer various social service programs for the public.

In addition to the same land use regulations and development standards that apply to all development within the identified districts (e.g., lot size, setbacks, building height, etc.), an emergency shelter proposed in these districts must comply with the following operational use regulations/standards:
• Occupancy. A maximum of 15 beds or persons may be served nightly, with associated support service not open to the public. Any emergency shelter for homeless with greater than 15 beds shall be subject to approval of a conditional use permit consistent with Chapter 20.84 PART 5.
• Hours of Operation. Emergency shelters for homeless providing less than 15 beds are not required to be open 24 hours a day but may be open 24 hours. Clients for emergency shelters for homeless shall have a specified check out time as detailed in the management and operation plan but may remain on the premises to utilize on-site services offered. • Length of Stay. The length of stay of an individual client shall not exceed six months within a 12-month period; days of stay need not be consecutive. • Management and Operation Plan. The applicant or operator shall submit a management and operation plan for the emergency shelter for review during the over-the-counter approval process for review and feedback by the Community Development Director or designee in consultation with law enforcement at the time the project is proposed, prior to issuance of permits. If site plan review applies, then the management and operational plan should be submitted and reviewed concurrently with those applications. The plan shall remain active throughout the life of the facility, with any changes subject to review and approval by the Community Development Director or designee in consultation with

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the chief of police. The plan should be based on "best practices" and include, but not limited to, a security plan, procedures, lists of services, staff training, "good neighbor" communication plan, client transportation and active transportation plan, ratio of staff to clients, client eligibility and intake and check out process, detailed hours of operation, and an ongoing outreach plan to Cudahy homeless population. The cityCity may inspect the facility at any time for compliance with the facility operational plan and other applicable laws and standards.
• Parking. One vehicle parking space shall be provided per five beds. A covered and secured area for bicycle parking shall be provided for use by staff and clients, commensurate with demonstrated need, but no less than a minimum of eight bike parking spaces. • Waiting and Intake Area. A client waiting and intake area shall be provided and contain a minimum of 10 square feet per bed provided at the facility. The client waiting and intake area shall be screened from the public right-of-way by a solid wall of at least six feet in height and shall be sufficient in size to accommodate all persons waiting to enter the facility.
• Support Services. Emergency shelters may also provide the following support services:
o Food preparation and dining areas.;
o Laundry facilities.;
o Restrooms and showers.;
o Areas to secure and store client belongings.;
o Indoor and/or outdoor recreational facilities and open space. o A private area providing referral services to assist shelter clients in entering programs aimed at obtaining permanent shelter and income. Referral services refers to the initial assessment of a homeless client to identify the areas in which assistance is needed and connecting clients with appropriate off-site programs and services depending on their need.
• Restrooms. The number of toilets and showers shall comply with applicable building codes and plumbing codes.
• Trash Enclosure and Loading Zone. Each facility shall have a trash enclosure and loading zone as provided in Chapters 20.20 and 20.28.

Currently the parking standards for emergency shelters are not in compliance with statutory requirements. Therefore, Program 11 has been amended to include the following:

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In 2023 the City will review City parking standards and complete required amendments to the City’s Zoning Code, in accordance with state law.

Low Barrier Navigation Centers
A “Low Barrier Navigation Center” is a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefitspublic benefits, health services, shelter, and housing “Low Barrier” means best practices to reduce barriers to entry such as allowing pets; storage of possessions; and privacy. Government Code Section 65560 et.seq. requires that local jurisdictions all “low barrier navigation centers” by right in areas zoned for mixed use and in non-residential zones permitting multifamily residential uses, if they meet the requirements specified in Government Code Section 65662.

In order to comply with these statutory requirements a new Program 23, has been added as follows:

The City shall review the City’s mixed use and non-residential zones that permit multifamily residential uses and amend the permitted uses sections of the appropriate zone districts to include low barrier navigation centers, in compliance with statutory requirements. These zoning code amendments will be completed in 2023.

Transitional and Supportive Housing
State law (AB 2634 and SB 2) requires local jurisdictions to address the provisions for transitional and supportive housing. Pursuant to Government Code Section 65651 supportive housing shall be a permitted use in zones where multifamily and mixed uses are permitted. Nonresidential zones that permit multifamily housing are also subject to allowing supportive housing as a permitted use. Transitional and supportive housing facilities meeting the Government Code Section 65582 definition are considered a residential use and allowed by right in all zones that allow residential uses of the same type, consistent with State law. These facilities are subject to the same development standards and permit processing criteria required for similar uses in the same zones.

In order to comply with these statutory requirements a new Program 24, has been added as follows:

The City shall review the City’s zone districts, including the mixed use and commercial zone districts, and amend the permitted uses sections of the appropriate zone districts to include supportive housing, in compliance with statutory requirements These zoning code amendments, will be completed in 2023.

Homelessness

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The results of the 2020 Greater Los Angeles homeless count showed 66,436 people in Los Angeles County experiencing homelessness. This represents a 12.7% rise from last year’s point-in-time count. Three years into the 10-year investment from Measure H, LA County’s homeless services system has doubled the number of annual housing placements. Improvements in coordination across agencies through the LAHSA based Housing Central Command have increased the speed of placements. And efforts to protect the most vulnerable people from COVID-19COVID-19 led to the rapid sheltering of 6,010 people since the March Safer at Home order (4,056 through Project Roomkey, 1,708 in Rec and Parks shelters, and 246 in trailers)—and a goal to move 15,000 of the most vulnerable people experiencing homelessness into housing.

Most of the people experiencing homelessness that the homeless system helps house stay housed. Eighty-eight percent of the people placed in permanent housing through the system in 2018 have not returned to homelessness. In 2019, the rehousing system helped 22,769 people move into permanent housing. And many more people occupy interim housing this year: 18,395 people experiencing homelessness in L.A. County were sheltered, up from 14,722 the previous year, a 25% increase.

Meanwhile, county-wide, 732 new permanent supportive housing units opened in 2019, and thousands more are expected soon, including 2,360 scheduled to open in the next 12 months of a total construction pipeline of 10,638 homes.

The LAHSA point-in-time homeless data count for the CityCity of Cudahy, indicates that on January 23, 2019, 76 homeless persons were processed, representing only 1% of the total in the Service Planning Area (SPA). The CityCity of Cudahy is located in SPA 7. On January 23, 2020, the number of homeless people processed in the cityCity decreased to 23, which still represents 1% of the total in SPA 7. Table 3.4 provides homeless statistics for Cudahy.

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Table 3.4
Homeless Statistics by City - Cudahy
Persons With Disabilities
Disabled persons have special needs when it comes to housing and many of the households in the category are occupied by elderly persons. Door frames must be wider to accommodate wheelchairs, ramps instead of stairs are needed, handrails in bathrooms need to be installed, cabinet doors must be accessible, and light switches and other devices also need to be within easy reach. The cost for retrofitting an existing structure may be thousands of dollars and be

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beyond the reach of those households with lower incomes. The lack of such housing is even more pronounced when it comes to market-rate rental units.

Unless such provisions are made for disabled persons during original construction, such facilities will not likely be provided in a typical rental unit. Senior housing (both owner and rental) generally has many of the features outlined above. The real constraints are associated with the housing for families and working-aged adults. The results of this analysis are summarized below according to three general categories of potential constraints: 1. zoning and land use, 2. permits and processing procedures, and 3. building codes.

Zoning and Land Use: The zoning ordinance does not preclude or restrict the construction of exterior ramps or other improvements (exterior or interior) for disabled persons. The CcityCity treats residential care facilities with six or fewer persons as a single-family use. These facilities are allowed in any zone where single-family homes are permitted under state law. The zoning ordinance does identify these facilities as a permitted use. The CcityCity’s zoning ordinance also permits reduced off-street parking space requirements for seniors though no such allowance is specifically identified for persons with disabilities.

Permits and Processing Procedures: There are no permit requirements for residential care facilities serving six or fewer persons. Furthermore, there are no special designs or permitting standards that have been established for residential care facilities. The ityCity has no occupancy standards that specifically apply to unrelated adults. Requests to retrofit homes for disabled accessibility or for reasonable accommodation are handled as any other building permit or variance application.

The City requires a conditional use permit for residential care facilities of seven or more persons located in the MDR, HDR, and Com MU zones. Given the zone district changes completed in 2018 as part of the 2040 General Plan Update and the City’s commitment to providing affordable housing and a variety of housing opportunities for all City residents, Program 28 includes the following: Additionally, the review will include consideration of the entitlement process for residential care facilities with seven or more persons. The consideration for residential care facilities with seven or more persons shall include review of the not permitted use category in the single-family residential zone district; and eliminating and/or changing the conditional use permit requirement in the medium and high density residential zone districts, and commercial mixed-use zone district.

Building Code: Cudahy has adopted the most recent 2020 Los Angeles County Building Code which includes provisions of the Americans with Disabilities Act. One provision is that a number of the residential units in new multi-family construction of three or more apartments, or four or more condominiums, must be accessible or adaptable.

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Households In Need Of Reasonable AccomodationAccommodation The most recent 2020 Census identified those residents that have one or more disabilities as well as the type of disability. Table 3.5-4 indicates the number of disabilities by three major age groupings (under 17 years of age. 18 to 64 years of age, and 65 years of age or older). In addition, the table summarizes the types of disabilities for each major age grouping. A single individual within each age grouping may be counted numerous times depending on the types of disability.

Table 3.5
Estimates Residents with Disabilities 2020
Table 3.5
Estimates Residents with Disabilities 2020
Category and Type of Disability Number of People Percentage of People Persons Under the Age of 17 535 7.9%
Hearing Difficulty 79 1.2%
Vision Difficulty 101 1.5%
Cognitive Difficulty 496 7.3%
Ambulatory Difficulty 311 4.6%
Self-Care Difficulty 333 4.9%
Persons Between Ages 18-64 1,064 7.8%
Hearing Difficulty 179 1.3%
Vision Difficulty 274 2.0%
Cognitive Difficulty 309 2.3%
Ambulatory Difficulty 562 4.1%
Self-Care Difficulty 337 2.5%
Independent Living Difficulty 382 2.8%
Persons 65 years and older 618 58.7%
Hearing Difficulty 198 18.8%
Vision Difficulty 181 17.2%
Cognitive Difficulty 236 22.4%
Ambulatory Difficulty 413 39.3%
Self-Care Difficulty 257 24.4%
Independent Living Difficulty 315 29.9%
Sources: U.S. Census Bureau (2020)
Developmental Disabilities
Persons with disabilities in Cudahy face unique problems in obtaining affordable and adequate housing. This segment of the population, which includes individuals with mental, physical, and developmental disabilities need affordable, conveniently located housing which, where necessary, has been specially adapted for wheelchair accessibility, along with other physical needs. The living arrangements for persons with disabilities depend on the severity of the disability. Many persons live at home in an independent environment with the help of other family members. To maintain independent living, disabled persons may require assistance. This can include special housing design features for the physically disabled, income support for those who are unable to work, and in-home supportive services for persons with medical conditions.

Accessible housing can also be provided via senior housing developments. Most persons with disabilities live on an income that is significantly lower than the non-disabled population. Many disabled individuals live on a small, fixed income which severely limits their ability to pay for housing.

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The Task Force on Family Diversity estimates that at least one-third of all persons with disabilities in the United States live in poverty. Persons with disabilities have the highest rate of unemployment relative to other groups. For most, their only source of income is a small, fixed pension afforded by Social Security Disability Insurance (SDI), Social Security Insurance (SSI), or Social Security Old Age and Survivor's Insurance (SSA), which will not adequately cover the cost of rent and living expenses even when shared with a roommate. In addition, persons with disabilities oftentimes experience discrimination in hiring and training. When they find work, it tends to be unstable and at low wages.

The term developmental disability refers to a severe and chronic disability attributable to a mental or physical impairment, such as cerebral palsy (a disability resulting from damage to the brain before, during, or shortly after birth and outwardly manifested by muscular in- coordination and speech disturbances); epilepsy (any of various disorders marked by abnormal electrical discharges in the brain and typically manifested by sudden brief episodes of altered or diminished consciousness, involuntary movements, or convulsions); or autism (a developmental disorder that appears by age three and that is variable in expression but is recognized and diagnosed by impairment of the ability to form normal social relationships, by impairment of the ability to communicate with others, and by stereotyped behavior patterns especially as exhibited by a preoccupation with repetitive activities of restricted focus rather than with flexible and imaginative ones that begins before individuals reach adulthood (http://www.nlm.nih.gov/medlineplus/mplusdictionary.html) Table 3.6 Active Consumers by Age Group
Zip Code Age Group 00-17 yrs. Age Group 18-21 yrs. Age Group 22-64 yrs. Age Group 65+ Grand Total 90201 449 75 226 3 753
Job 9001 - Active Consumers In LA, Ventura, San Diego, Orange, Riverside & San Bernardino Counties by Age Group. (based upon CMF created 9/4/13) Mental Disabilities: Based on the most current Census information the cityCity has a total of 964 residents with mental disabilities; 33% are male and 67% are females, as identified in Table 3.6 below.

Table 3.6
Mental Disability by Gender
Table 3.7 Mental Disability by Gender
Gender Male Female TOTAL
317 647 964
Percentage 33% 67% 100%
Source: U.S. Census. Bureau; 2017 - 2021 American Community Survey Physical Disabilities: Based on the most current Census information the cityCity has a total of 1,118 residents with physical disabilities; 43% are male and 57% are females, as identified in Table 3.7 below..

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Table 3.7
Physical Disability by Gender.

Table 3.8 Physical Disability by Gender
Gender Male Female TOTAL
478 640 1,118
Percentage 43% 57% 100%
Source: U.S. Census. Bureau ;2017 - 2021 American Community Survey Strategies And Programmatic Responses To Meet Need
Appropriate housing for persons with mental or physical disabilities include very low-cost units in large group home settings (near retail services and public transit), supervised apartment settings with on- or off-site support services, outpatient/day treatment programs, and inpatient/day treatment programs, crisis shelters and transitional housing.

In 1984, Title 24 of the State Uniform Building Code mandated that all multiple-family residential construction projects containing more than five units under construction after September 15, 1985, would conform to specific disabled adaptability/accessibility regulations. In 1988, the Federal government enacted the U.S. Fair Housing Amendment Act; in part with the intent of increasing the number of rental units being built that would be accessible to handicapped individuals. In July 1993, the State of California issued “California Multifamily Access Requirements” based upon the Act. Unfortunately, the actual increase in the number of handicapped-accessible units available on the current rental market has been small.

The cityCity does not require special building codes or onerous project review to construct, improve, or convert housing for persons with disabilities. Both the federal Fair Housing Act and the California Fair Employment and Housing Act impose an affirmative duty on local governments to make reasonable accommodations (i.e., modifications or exceptions) in their zoning and other land-use regulations when such accommodations may be necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling.

The CityCity also makes rehabilitation funds available to income qualified households for accessibility improvements through its CDBG Program; CDBG funds can be used for a variety of housing efforts including activities aimed at reducing costs, housing acquisition and rehabilitation through short and long-term loans, grants, or loan guarantees; direct payment of rent or mortgage and housing counseling services and fair housing activities.

The housing needs of several other categories of disabled persons, including developmentally disabled persons and the mentally ill are typically not addressed by Title 24 Regulations. The housing needs of persons with these types of disabilities, in addition to basic affordability, range from needing slight modifications of existing units to the need for a variety of supportive housing arrangements. Some of this population can only live successfully in housing which provides a semi-sheltered, semi-independent living state, such as clustered group housing or other groupliving quarters; others can live independently if affordable units are available.

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Based on a review of the cityCity's development procedures and policies, no specific constraints were identified other than consideration of reduce parking requirements for group care housing and streamlined review for applications that involve the retrofit of existing units to accommodate reasonable access. In summary, the cityCity's zoning ordinance does not contain any provisions that would preclude the development of housing for handicapped persons. There are no zoning restrictions that would limit the use of ramps, wider doorways, or other features that would be desirable in such units. No additional review or development standards are required for handicapped units beyond that required for all units.

Female-Headed Households
Female headed households generally refers to those households with a female that is a single parent. Female-headed households tend to have low-incomes, thus limiting housing availability for this group. Female-headed households accounted for 24.5% (1,372 households) of the cityCity's total number of households in 2020. An estimated 15.8% of the households in the CcityCity (885 households) wasfemale headed with dependent children less than 18 years of age.

More significantly, the same census figures for 2020 indicated that 45.1% of the female headed households with dependent children had incomes that were below the poverty level. Thus, providing housing opportunities for this group relates both to affordability and services related to the care of children. This number bares importance in relation to social service needs, such as childcare, recreation programs, and health care, which are of special concern to these households. The chart below idenfiesidentifies the female-headed households.

Chart 3.23 - Female-Headed Households (ACS 2020)
Large Family Households
According to the HCD’s definition, the term "large family" refers to a family containing five or more persons. Large family households, containing five or more persons, frequently experience a greater incidence of overcrowding, especially in older units and rental housing. Most rental units in the cityCity contain one or two bedrooms. In addition, landlords may be reluctant to rent 5601

24.5%; 1372

15.8%; 885

1.4%; 76
0 1000 2000 3000 4000 5000 6000
Total Households
Total FHH
FHH w/children
FHH w/children under 6
Percent of total househods; Number of households

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smaller units to larger families. Finally, many owner-occupied units are overcrowded (refer to the previous section) due to extended families sharing housing to reduce mortgage or rental costs.

Large families are identified as a group with special housing needs based on the limited availability of adequately sized, affordable housing units. With a median household income of $41,805 (35% lower than the State average), a total of 24.3% of CityCity of Cudahy residents live below the poverty line, almost twice the State average of 13.7%. Taking into consideration the previous statistics, large families often face these conditions, frequently resulting in the overcrowding of smaller dwelling units and in turn accelerating unit deterioration.

Most of the market rate owner-occupied housing constructed during the past ten years had three or more bedrooms. In recent years, few rental units have been constructed in the cityCity with even fewer new rental units containing three or more bedrooms. According to the most recent census, 1,259 units (21.4% of the total housing units in the CityCity) contained five rooms, 397 units (6.8%) contained six rooms, and 181 units (3.1%) have seven or more rooms.

Large Families (those containing five or more persons) are overwhelmingly residing in renter units at 83%. Table 3.8 identifies tenure by large families.

Table 3.8
Tenure by Large Families
Table 3.9 Tenure by Large Families
Tenure Owner Renter TOTAL
Family with >5 persons 364 1,723 2,087
Percentage 17% 83% 100%
Source: U.S. Census.BureauCensus. Bureau; 2017 - 2021 American Community Survey Overcrowding
Overcrowded housing is defined by the U.S. Census as units with more than one inhabitant per room, excluding kitchen and bathrooms. Overcrowding usually occurs because of high housing costs, such that families double-up or reside in smaller units to devote income to other basic necessities such as food and medical fees.

Of the occupied housing units in the cityCity identified in the 2020 Census, 1,428 units were identified as being overcrowded (25.3% of the CityCity’s total number of occupied units) and 534 units (9.5% of the total occupied units in the cityCity) were identified as being severely overcrowded.

Elderly Households

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Escalating housing costs, particularly in the rental market, severely impact housing affordability for the elderly who usually have fixed incomes. The housing needs of the elderly can be addressed through the provision of smaller units, congregate housing, and rental and rehabilitation assistance programs. The special needs of many elderly households often are a result of lower (and fixed) incomes, physical disabilities, and dependence needs. As indicated in a previous section, approximately 5.1% of the CityCity’s population was 65 years of age or older. In 2010, there were 909 households (16.8%) with individuals 65 years of age or olde r.

Within those 909 elderly households, 217 of those households contained a single individual while 692 households contained two or more persons.

As identified in Table 3.9, the Eelderly householders are predominately residing in renter units at 65%.

Table 3.9
Tenure by Elderly Households
Table 3.10 Tenure by Elderly Households
Tenure Owner Renter TOTAL
208 388 596
Percentage 35% 65% 100%
Source: U.S. Census.BureauCensus. Bureau ;2017-2021 American Community Survey Farmworkers
The special housing needs of many farm workers stem from their low wages and the seasonal nature of their employment. Most of the Cudahy residents work in the Los Angeles-Long Beach Metropolitan area in non-agricultural occupations. The 2020 census identified 37 persons employed in the agricultural, forestry, and fishing sector. These persons are likely to be employed in nurseries, stables, and not in traditional agricultural production. The demand for housing generated by farm workers in the CcityCity is thus estimated to be extremely low.

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4 Land Inventory
This section assesses the housing development potential in Cudahy during the 2021-2029 Housing Element planning period. The purpose is to determine the quantity of land available to accommodate the City’s RHNA. The RHNA is broken down by income group into four categories:

Very Low (less than 50% of the Area Median income (AMI)), Low (50-80% of AMI), Moderate (80- 120% of AMI), and High (over 120% of AMI). While a jurisdiction must show that it has adequate sites in total to meet its RHNA, it must also show that it can meet the allocation at each of these income categories. This section assesses the housing development potential in Cudahy during the 2021-2029 Housing Element planning period. The purpose is to determine the quantity of land available to accommodate the CityCity’s RHNA. The RHNA is broken down by income group into four categories: Very Low (less than 50% of the Area Median income (AMI)), Low (50-80% of AMI), Moderate (80-120% of AMI), and High (over 120% of AMI). While a jurisdiction must show that it has adequate sites in total to meet its RHNA, it must also show that it can meet the allocation at each of these income categories.

List of Charts, Tables, and Maps
Map 4.1 …………………………………………CityCity of Cudhy Zoning Map – Page 78 Table 4.1- ………………………………..Zoning Summary - CityCity of Cudahy – Page 79 Table 4.2- ……………………………………………….….Current 6th Cycle Vacant Sites – Page 84 Table 4.3- ……………………………………..………………… …5th Cycle Vacant Sites – Page 84 Table 4.4 - …………………………………………… …….Land Sales in – October 2021 – Page 91 Table 4.5 - ……… .Construction Costs per Square-Foot for Residential Construction – Page 92 Table 4.6 - ………………………………………………..………Average Mortgage Rates – Page 92

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4.1 HOUSING INVENTORY
The State requires that a Housing Element identify how much housing can be constructed to accommodate the community’s RHNA. Section 65583(a)(3) of the California Government Code states that this inventory must be site specific to help localities determine the appropriate zoning, development standards, and infrastructure capacity to accommodate the new construction needed. The Code also requires that all land identified must be available for residential use in the planning period. Sites that require rezoning may be included in the inventory if actions are taken to address the rezoning early in the planning period.The State requires that a Housing Element identify how much housing can be constructed to accommodate the community’s RHNA. Section 65583(a)(3) of the California Government Code states that this inventory must be site specific to help localities determine the appropriate zoning, development standards, and infrastructure capacityCity to accommodate the new construction needed. The Code also requires that all land identified must be available for residential use in the planning period. Sites that require rezoning may be included in the inventory if actions are taken to address the rezoning early in the planning period.

The types of sites that are appropriate for residential development include:
• Vacant residentially zoned sites.
• Vacant non-residentially zoned sites that allow residential development. • Underutilized residentially zoned sites capable of being developed at a higher density or with greater intensity; and
• Non-residentially zoned sites that can be redeveloped for, and/or rezoned for, residential use (via program actions, such as rezoning).

Regional Housing Needs Allocation (RHNAhna)
This Housing Element addresses the RHNA for two three planning periods:
• The current RHNA (6th Cycle) planning period which spans 2021-2029 • The lower-income RHNA (referred to as the unaccommodated RHNA or rollover RHNA) from the previous (5th Cycle) planning period (2014-2021) • The lower-income RHNA (referred to as the unaccommodated RHNA or rollover RHNA) from the 4th Cycle planning period (2008-2014)

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The unaccommodated 5th cycle RHNA from previous planning periods rolled over and is added to the current planning period because HCD found that the City did not make adequate sites available to accommodate the RHNA during the 5th cycle RHNA planning period. The RHNA housing needs allocation is identified in the table below.The unaccommodated 5th cycle RHNA from 2014-2021 rolled over and is added to the current planning period because HCD found that the cityCity did not make adequate sites available to accommodate the RHNA during the 5th cycle RHNA planning period. The RHNA housing needs allocation is identified in the table below.

Table 4.1
Regional Housing Needs Allocation
Affordability Level
(AMI: Area Median Income)
RHNA
(2021-2029)
Unaccommodated
RHNA
(2014-2021)
Unaccommodated
RHNA
(2008-2013)
Total
Extremely and Very Low-Income (0-
50% AMI)
801
80 154 234
Low-Income (51-80% AMI) 36 46 - 82
Moderate-Income (81- 120% AMI) 53 51 - 104
Above Moderate- Income (121%+
AMI)
224
141
- 365
Total 393 318 154 865
In 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 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 have provided more incentive to recycle underutilized and deteriorating property. In single-family residential areas, allowable density has been increased from nine units per acre to 15 units per acre. In the Medium Density and High-Density Residential areas, allowable densities have more than doubled (from 12 units per acre to 25 units per acre and from 16 units per acre to 40 units per acre, respectively).

The RHNA, even accounting for unaccommodated 4th and 5th Cycle RHNAs, represents but a small portion of the realistic potential increase in housing Citywide under current General Plan and zoning standards. Table LU-4 below is an excerpt from the City of Cudahy 2040 General Plan, identifying the Realistic Buildout (2040) for the City at 7,222 dwelling units, an increase of 1,448 units over baseline. General Plan Table LU4 Capacity for Development is included below. 1 The extremely low income need can be calculated as 50% of the very-low income RHNA, or 40 units.

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Table 4.1Regional Housing Needs Allocation
Affordability Level
(AMI: Area Median Income)
RHNA
(2014-2021)
Unaccommodated
RHNA (2008-2013)
Total
Extremely and Very Low-Income (0-50% AMI) 80 154 234
Low-Income (51-80% AMI) 46 - 46
Moderate-Income (81- 120% AMI) 51 - 51
Above Moderate- Income (121%+ AMI) 141 - 141
Total 318 154 472
Progress Toward the RHNA
The City may credit any units constructed after the 6th Cycle planning period began on June 30, 2021 toward the RHNA. The following projects have been constructed since that time:
• 3827 Live Oak Street, 1 unrestricted unit
• 3636-42 Walnut Avenue, 4 unrestricted units
• 4848 Live Oak Street, 5 lower-income, 6 moderate-income and 9 above moderate income units
• 4302-4312 Elizabeth Street, 6 lower-income and 42 unrestricted units • 4728 Live Oak Street, 4 unrestricted units
The City conservatively credits all unrestricted constructed units to the above moderate income category. Therefore, the constructed sites total 11 lower-income, 6 moderate-income and 51 above moderate-income units.

Senior Housing Project – 4610 Santa Ana Street
In 2022, the City Council approved a senior housing project at 4610 Santa Ana Street in the City’s Entertainment zone with 179 lower-income units and 1 above moderate-income manager’s unit.

The project, shown below, consists of a six-story structure with podium and underground parking; the achieved density is 135 dwelling units per acre. The project used the Cudahy

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Municipal Code’s provisions which allow the City Council to grant extra height and other concessions to developers in exchange for public benefits through a development agreement.

Public benefits from this project will arise not only from the affordable housing units, but also public open space and 20,000 square feet of community-serving commercial space.

The project is located on formerly City-owned land, which was sold to Prima Development for an extremely low cost in order to assist Prima in financing this tax-credit affordable project. The property does have some soil contamination issues, but the City has been working closely with the developer to complete an application for Infill Infrastructure Grant (IIG) funding which would cover the remediation cost, as well as provide other needed infrastructure for the project.

Program #5 (Affordable Housing Incentives) commits the City to supporting Prima with grant and other funding applications by the end of 2023, with the expectation that the project can be fully funded by the end of this calendar year.

Sites Identified in Prior Planning Periods
Pursuant to Government Code Section 65583.2(c), a non-vacant site identified in the prior planning period and a vacant site that has been included in two or more prior consecutive planning periods cannot be used to accommodate the lower income RHNA unless the site is subject to a program in the Housing Element. This program would require rezoning within three years of the beginning of the sixth cycle planning period to allow residential use by right for

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housing developments in which at least 20% of the units are affordable to lower income households.

The sixth cycle site inventory does not include any sites in common with the fifth cycle site inventory or the fourth cycle site inventory.

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Available Sites – Types of Sites
All assumptions made for this sites inventory are based on the City’s experience with development since the 2018 adoption of the General Plan and Development Code. The planning team undertook an analysis of all project applications submitted to the City between 2018 and 2022 to determine historical patterns and averages which inform this analysis. In total, 33 project applications have been submitted to the City since 2018, totaling 481 units, a number higher than both the 5th and 6th Cycle RHNA. 18 of these 33 projects are multi-family rental in nature, with four condominium projects, three single-family projects and eight ADUs.

The analysis found that “incremental” development, where new housing units are added to a site with housing units already on it without demolishing those units, comprises a majority of the development in the City (20 projects/239 units). Therefore we identified sites appropriate for this type of incremental development in addition to vacant sites and those sites which were sufficiently underutilized for the historical record to justify an assumption of replacement of lower-density housing with higher-density housing.

The narrative below identifies the assumptions and characteristics of each type of site for each zoning district. Each individual site is mapped and described in Appendix A to this Element.

Completely Vacant Sites – LDR Zone
Sites #1, 2, and 3, located in the LDR zone, are completely devoid of structures and thus considered to be vacant. The historical development record indicates that most projects that have been constructed in the LDR zone have been ADUs, leading to sites being developed at total densities (including ADUs) of greater than the density maximum of 15 du/ac. With this in mind, these sites are assumed to have a realistic capacity equal to the maximum.

The three sites total 2.49 acres and the realistic capacity is 37 units. Because these properties are located in the lowest-density zone of the City, with a density below the minimum required density for lower-income households per Government Code 65583.2(c)(3)(B) and 65583.2(f), these units are credited to the above moderate income category.

Incremental Sites – LDR Zone
Sites #4, 5, and 6 are located in the LDR zone and have single-family homes on the property arranged in such a way that a significant developable portion of the site remains. The developable portions of these lots are raw, vacant land and do not appear to be used as parking or manicured yards or gardens. The developable portions total 0.33 acres and have a realistic capacity of 6 units.

These units are credited to the moderate-income category. Densities are below the minimum required for lower-income households per Government Code 65583.2(c)(3)(B) and 65583.2(f).

However, these units are likely to be cheaper than units constructed within a brand-new

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development; they will function more like ADUs, smaller ground-level units with a relationship to an older single-family home structure. According to SCAG’s Regional ADU Affordability Analysis, ADUs are rented at a variety of rates, with the majority (60%) affordable to lowerincome households. Therefore we view the assumption of moderate-income households to be a conservative assumption.

Completely Vacant Sites – MDR Zone
Sites #13, 17 and 31 are parcels in the MDR zone which are completely vacant and available for development. Site #13 is publicly-owned and will be adjudicated for development subject to the Surplus Land Act, as described in Program #33. The total acreage is 1.1 acres and the realistic capacity is 24 units.

The historical record of development shows that seven applications have been submitted for housing projects in the MDR zone which consist of entirely new development on a site. The average density of those projects is 22 du/ac. Therefore, the Element assumes a density of 22 du/ac for these sites. As these projects will result in brand-new, site wide development, the units are credited to the above moderate-income category.

Site #13 is credited to the lower-income category based on its public ownership. The Surplus Land Act process will give first priority to developers of 100% affordable housing. The other sites are credited to the above moderate-income category, as they will result in brand-new, site wide development.

Incremental Sites – MDR Zone
Sites #14, 15, and 16 are located in the MDR zone and have single-family homes on the property arranged in such a way that a significant developable portion of the site remains. The developable portions of these lots are raw, vacant land and do not appear to be used as parking or manicured yards or gardens. The developable portions total 0.57 acres and have a realistic capacity of 12 units.

The historical record of development shows that the 20 incremental development projects in the City created 239 units with an average density within the newly constructed areas of 22 du/ac.

Therefore, the Element assumes a density of 22 du/ac upon the developable portion of these sites for development. As with the LDR zone, units on these incremental sites are credited to the moderate-income category.

Replacement Sites – MDR Zoning
Sites #29 and 30 are sites of greater than ½ acre located in the MDR zone with single-family or small multifamily (development of less than 5 du/ac). It is assumed that these sites will be

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replaced in their entirety by new development. The developable portions total 1.88 acres and have a realistic capacity of 41 units.

Site #30 is a publicly owned (Successor Agency) site and will be adjudicated for development subject to the Surplus Land Act, as described in Program #35 (Public Land Development). This site holds two single-family homes, but both of these homes are abandoned.

The historical record supports the finding that lower density residential uses can be replaced by higher density residential uses. Projects in the City which created higher-density residential units demolished up to six units. The majority of projects (7 of 12) resulted in a 4:1 ratio between the new units constructed and the old units demolished, although instances were recorded where the ratio was as low as 2:1. All of the sites in this category would result in a gain of at least 4:1 between realistic capacity and current developed capacity. There are no other known contracts or conditions which would preclude development during the 6th Cycle period.

New construction projects in the MDR zone since 2017 have demonstrated an average density of 22 du/ac, 88% of the maximum capacity of the zone. For this reason, a 22 du/ac density has been used to derive the realistic capacity of the sites.

Incremental Sites – HDR Zone
Sites #7 to 12 are located in the HDR zone and have single-family homes on the property arranged in such a way that a significant developable portion of the site remains. The developable portions of these lots are raw, vacant land and do not appear to be used as parking or manicured yards or gardens. The developable portions total 1.88 acres and have a realistic capacity of 40 units.

The historical record of development shows that the 20 incremental development projects in the City created 239 units with an average density within the newly constructed areas of 22 du/ac.

Therefore, the Element assumes a density of 22 du/ac upon the developable portion of these sites for development. As with the LDR and MDR zone, units on these incremental sites are credited to the moderate-income category.

Replacement Sites – HDR Zoning
Sites #21,22 and 24 to 28 are sites of greater than ½ acre located in the HDR zone with singlefamily homes or duplexes (development of less than 5 du/ac). It is assumed that these sites will be replaced in their entirety by new development. The developable portions total 6.4 acres and have a realistic capacity of 213 units.

All sites are at least one-half acre in size, except for Site #23. Site #23 is assigned to the above moderate-income category, while all remaining sites are credited to the lower-income category.

As discussed above, all replacement sites would result in at least a 4:1 ratio between constructed and demolished units.

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New construction projects in the MDR zone since 2017 have demonstrated an average density of 33 du/ac, 85% of the maximum capacity of the zone. For this reason, a 33 du/ac density has been used to derive the realistic capacity of the sites. Additionally, the City is undertaking Program #28 (Zoning Code Review) which will address barriers identified in the Constraints Analysis (Chapter 5) which have been making higher-density development more difficult in the City.

A few sites in this category are composed of two or three separately owned parcels. Two parcels, each with a single-family home, has been assumed to have a high possibility of consolidation due to the high land value realized from redevelopment. The City has a strong track record of lot consolidation, which will be strengthened through the application of Program #4 (Lot Consolidation).

Publicly Owned Mixed-Use Sites
The 2.92-acre site at 8110 Atlantic Avenue (APN 6224018900, 6224018901, 6224018902, 6224018912, 6224018913, and 6224018915) is a largely vacant publicly owned parcel. The city of Cudahy Successor Agency owns the corner portion, and the County of Los Angeles owns the larger facility (closed) to the south. Other uses of this site consist of auto repair services with a large portion of the site occupied by parking surface or simply vacant land in poor condition, the Successor Agency is negotiating with the County to consolidate the site. The Successor Agency plans to redevelop this site through a partnership with a developer per Surplus Land Act guidelines. This site is zoned Entertainment, which is a commercial zone in the City which allows upper-floor residential units with a density maximum of 30 units per acre. Maintaining this density to calculate the site’s capacity the total residential capacity estimated for this site is 88 units. While any development that would proceed on the property would include affordable units, the units are assigned to the Above Moderate Income category.

This 2.33-acre site at 7660 Atlantic Avenue (APN 6226022904, 6226022905, 6226022906, 6226022907, 6226022908, 6226022909, 6226022910, 6226022017 and 6226022018) is a largely vacant publicly (successor agency) owned parcel. The uses occupying this site are a motel, a liquor store, and a restaurant (now permanently closed), all in poor condition. The Successor Agency plans to redevelop this site through a partnership with a developer per Surplus Land Act guidelines. This site is zoned Entertainment, which is a commercial zone in the City which allows upper-floor residential units with a density maximum of 40 units per acre. However, for the purposes of this site inventory, the density used to calculate the site’s capacity is 30 units per acre. According to this methodology, the residential capacity estimated for this site is 70 units.

While any development that would proceed on the property would include affordable units, the units are assigned to the Above Moderate Income category.

Program #35 (Public Land Development) commits the City to adjudicating at least one of these site to a developer by 2024, with the project entitled by 2025. The other site should also be entitled by the end of the 6th Cycle period.

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Public Resources and Infrastructure Availability
All of the housing sites identified in the Sites Inventory have basic utility services including water, sewer, storm drain, electrical service, gas, and broadband internet. These housing sites have sufficient existing infrastructure capacity to accommodate the City’s RHNA and site inventory.

The City is unaware of any utility infrastructure deficits which would prevent the construction of housing in the areas listed in the sites inventory. Because this Housing Element’s site inventory is based on the City’s General Plan land use designations, the site inventory only lists housing sites in areas which already have existing infrastructure for housing.

SITES INVENTORY AND ANALYSIS
The sites inventory included in this section is divided into two parts. The first part presents sites to address the City’s unaccommodated RHNA from the 4th and 5th cycle planning period (2014- 2021) consistent with State law (Government Code Section 65584.09). The second part of the inventory presents sites to address the City’s current 6th cycle (2021-2029) RHNA. The inventories are presented separately to facilitate tracking of sites throughout the planning period and due to the different criteria each inventory must address under housing element law. The requirement to identify sites for the unaccommodated RHNA is in addition to the requirement to identify sites for the current cycle RHNA. The City may not count capacity on the same sites for both planning periods (RHNA cycles) (Government Code 65584.09[b]). Together, the inventories show sufficient capacity to address the City’s current and previous RHNA.

The City’s land inventory was developed by a combination of methods, among them, utilizing data available from the City and the LA County Assessor’s Parcel Maps, a review of aerial maps, and most importantly, through field work. The Sites Inventory and Analysis lists properties by parcel number or other unique reference, showing for each parcel: size, zone, General Plan and zoning designation, existing use, maximum allowable density, and number of units that can be accommodated in each site (realistic capacity). In addition, the lot consolidation potential and any constraints to development are also listed. As part of the City’s efforts to promote lot consolidation, Program 4 has been amended to include the following:

Beginning in 2024 the City will establish development incentives including a list of potential consolidation sites, a review to streamline lot consolidations, provide assistance with compliance with the state’s Subdivision Map Act requirements, fee reductions, ADA compliance, and infrastructure support. The City will work with the development community and property owners to develop information that will assist with consolidating lots.

Sites for the current and unaccommodated previous cycle RHNA are shown on Table 4.2 and Figure 4.1.

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UNACCOMODATED RHNA (5th and 4TH Cycle)
Because HCD found that the City did not make adequate sites available to accommodate the RHNA in the previous planning period, Government Code Section 65584.09 requires the identification or, if necessary, rezoning of sites to address the unaccommodated lower-income RHNA from the previous planning period. The City of Cudahy must carry over 154 lower-income units from the 2008-2013 RHNA and 126 lower-income units from the 2013-2021 RHNA.

Unaccommodated RHNA Site Requirements
Housing Element Law (Government Code 65583.2[h]) requires that jurisdictions accommodate all the lower-income, unaccommodated RHNA 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 must permit at least 16 units per site at a density of at least 20 units per acre. At least half of the very low- and low-income housing must be accommodated on sites designated for residential use and for which nonresidential uses or mixed-uses are not permitted, except that a City or county may accommodate all the very low- and low-income housing need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.

All available sites identified in the inventory for lower-income units meet this criteria and are assigned to the unaccommodated RHNA inventory. All sites in the unaccommodated RHNA inventory are zoned for Medium or High Density Residential, which allows residential uses by right, and allows between 25 and 40 units per acre. The minimum site capacity is 16 units per acre (based on realistic capacity, not maximum capacity, which is higher).

Unaccommodated RHNA Sites Summary
The 2013-2021 and 2008-2013 rollover RHNA sites inventory included in this Housing Element identifies capacity for 292 units, thus exceeding the required rollover of 280 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 rollover RHNA sites inventory is made up of replacement MDR and HDR sites, all above ½ acre. All sites have a realistic capacity of at least four 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)
Table 4.3 tabulates the housing sites inventory for the current (2021-2029) RHNA, which consists of constructed projects, approved projects and available sites in the categories described above.

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Table 4.3
2021-2029 RHNA Sites Capacity (Units)
Site Affordability Level
Site Type
Lower-Income (0-
80% AMI)
ModerateIncome
(81- 120%
AMI)
Above
ModerateIncome (121%+
AMI)
Total
Constructed Projects 11 6 51 68
Approved Project
(4610 Santa Ana St)
178 -- 1 179
Completely Vacant - LDR -- -- 37 37
Incremental - LDR -- 6 -- 6
Completely Vacant - MDR -- -- 4 4
Incremental - MDR -- 12 -- 12
Replacement - MDR Assigned to unaccommodated RHNA
Incremental - HDR -- 40 -- 40
Replacement - HDR -- -- 12 12
Publicly-Owned Mixed-Use -- -- 158 158
Total 189 64 263 516
6th Cycle RHNA 116 53 224 393
Buffer +73 +11 +39 +123
The City has sufficient sites to accommodate the RHNA without need of rezoning.

Sites Inventory Assumptions
Realistic CapacityCapacity
Consistent with HCD Guidelines, the methodology for determining realistic capacitycapacity on each identified site must account for land use controls and site improvements. The Cudahy General Plan and Development Code establish three residential and two mixed-use land use categories to provide housing opportunities for all household income ranges. A realistic density calculation of 60 percent of the maximum density has been applied to the residential and mixeduse sites. The 60 percent realistic capacitycapacity figure is consistent with the realistic development scenario in the General Plan Land Use Element. Overall, the use of expected densities provides a very realistic, and perhaps somewhat conservative approach, as developments in Cudahy can achieve much higher densities through development at maximum density.

Table LU-4 below is an excerpt from the CityCity of Cudahy 2040 General Plan, identifying the Realistic Buildout (2040) for the CcityCity at 7,222 dwelling units, a population of 30,607, and nonresidentalnon residential square feet of 5,172,540. Based on the current declining population trend, attaining a population of 30,607 persons is unlikely to be achieved if additional housing units are constructed. Additionally, the cityCity is currently conducting actual Realistic Analysis based on the projects that have been approved between 2013 and now. The results of

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that analysis will be published shortly. General Plan Table LU4 Capacity for Development is included below.

Zoning Appropriate To Accommodate Housing For Lower-Income Households Higher density residential and mixed-use zones provide the potential for lower construction cost because of economies of scale created and are therefore most suitable for development of housing affordable to very low-income and low-income households. The California Government Code states that if a local government has adopted density standards consistent with the population-based criteria set by State law (at least 20 units/acre for the CityCity of Cudahy), State HCD is obligated to accept sites with those density standards (20 units/acre or higher) as appropriate for accommodating the jurisdiction’s share of regional housing need for lowerincome households. The capacityCity of sites that allow development densities of at least 20 units/acre are credited toward the lower-income RHNA, pursuant to State law. Per Government Code Section 65583.2(c)(3)(B), the Medium Density Residential (MDR), High Density Residential (HDR), and mixed-use designations are consistent with the default density standard for Cudahy.

Therefore, capacityCity on sites with these designations is credited towards the lower-income RHNA categories. Sites designated for single-family uses (15 units/acre) are credited towards the above moderate-income RHNA.

General Plan Table LU 3: General Development Standards, Mixed Use, of the Cudahy 2040 General Plan allocates for the use of non-residential zones for residential purposes at a density of 30 dwelling units to the acre in both the Mixed Use-Commercial and Mixed-Use-Civic designations of the Land Use Code. As indicated below from excerpts of the Cudahy 2040 Land Use Element, residential development is allowed in mixed-use zones Cudahy has experienced very little growth since the 1990s.

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“What residential development has occurred results from single-family structures on large lots being torn down and replaced with higher-density residential development where zoning permits.

Factors that limit potential development include the challengingly long and narrow lot sizes and the high rate of absentee property ownership, which create little financial incentive for redevelopment because rental housing demands remains high”.

The above quotation is from the Cudahy 2040 General Plan Land Use Element, page LUE 30. The Housing Element is one of the mandatory elements of the General Plan and is required to be consistent with the General Plan. However, the Housing Element is the only Element of the General Plan that requires approval by an agency outside the cityCity. The intent of the Housing Element, its goals, and objectives, is to be consistent with the General Plan. General Plan Table LU-3 is included below.

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Site Suitability
Site identification criteria were used to ensure the inclusion of sites with a high potential for redevelopment based on size, location, current uses, and allowed densities. • CapacityCapacity: The Sites Inventory includes both vacant and underutilized sites.

Underutilized sites are parcels that are currently developed at less than the maximum permitted density. Many of these sites are in areas intended for high-density development, yet the sites are developed at significantly lower densities. Identified underutilized sites included in this inventory have a realistic capacitycapacity of at least two times the existing use.
• Size and location: Development of parcels of at least one-half acre in size is desirable in terms of construction economies and effective use of State or federal grants. However, in older cities, the subdivision pattern has resulted in many lots less than one-half acre in size. Vacant sites of all sizes are included in the inventory as they present opportunities for consolidation into larger developments. Underutilized sites in the inventory are limited to a minimum size of one-half acre and a location adjacent to other underutilized or vacant sites to accommodate lot consolidation.
• Potential for redevelopment: In 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 cityCity completed a concurrent Development 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 is expected to provide more incentive to recycle underutilized and deteriorating property. In single-family residential areas, allowable density has been increased from nine units per acre to 15 units per acre.

In the Medium Density and High-Density Residential areas, allowable densities have more than doubled (from 12 units per acre to 25 units per acre and from 16 units per acre to 40 units per acre, respectively). The density increases reflect development trends in the residential areas and are expected to produce additional housing to address severe deficiency between the number of residents and number of available housing units in the cityCity. Recent residential development in the cityCity consists of the construction of additional dwelling units, ADU’s, and recycling of single-family structures on large lots to higher-density residential developments. With allowable density increases across all residential land use categories and with most of the cityCity zoned for high density residential uses, the recycling of land to higher uses is expected to continue.

SITES INVENTORY AND ANALYSIS

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The sites inventory included in this section is divided into two parts. The first part presents sites to address the cityCity’s unaccommodated RHNA from the 5th cycle planning period (2014-2021) consistent with State law (Government Code Section 65584.09). The second part of the inventory presents sites to address the CityCity’s current 6th cycle (2021-2029) RHNA. The inventories are presented separately to facilitate tracking of sites throughout the planning period and due to the different criteria each inventory must address under housing element law. The requirement to identify sites for the unaccommodated RHNA is in addition to the requirement to identify sites for the current cycle RHNA. The CityCity may not count capacityCity on the same sites for both planning periods (RHNA cycles) (Government Code 65584.09[b]). Together, the inventories show sufficient capacityCity to address the CityCity’s current and previous RHNA.

The CityCity’s land inventory was developed by a combination of methods, among them, utilizing data available from the cityCity and the LA County Assessor’s Parcel Maps, a review of aerial maps, and most importantly, through field work. The Sites Inventory and Analysis lists properties by parcel number or other unique reference, showing for each parcel: size, zone, General Plan and zoning designation, existing use, maximum allowable density, and number of units that can be accommodated in each site (realistic capacityCity). In addition, the lot consolidation potential and any constraints to development are also listed. As part of the City’s efforts to promote lot consolidation, Program 4 has been amended to include the following:

Sites for the current and unaccommodated previous cycle RHNA are shown on Table 4.32 and Figure 4.1.

UNACCOMODATED RHNA (5th Cycle, 2013-2021)
Because HCD found that the cityCity did not make adequate sites available to accommodate the RHNA in the previous planning period, Government Code Section 65584.09 requires the identification or, if necessary, rezoning of sites to address the unaccommodated lower-income RHNA from the previous planning period. The CityCity of Cudahy must carry over 154 lowerincome units from the 2013-2021 RHNA.

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permitted, except that a cityCity or county may accommodate all the very low- and low-income housing need on sites designated for mixed uses if those sites allow 100 percent residential use and require that residential use occupy 50 percent of the total floor area of a mixed-use project.

The unaccommodated RHNA (2013-2021) sites inventory is limited to sites that meet these criteria. All sites in the unaccommodated RHNA inventory are zoned for High Density Residential, which allows residential uses by right, and allow a minimum density of 20 units per acre and a maximum density of 40 units per acre. The minimum site capacityCity is 16 units units per acre (based on realistic capacityCity, not maximum capacityCity, which is much higher).

Actual Units Constructed Since 2015
Table 4.2 – Housing Units by Construction Year
2015 2016 2017 2018 2019 2020 2021
Unit Type 2 2 11
ADUs
Condominiums
Townhomes 20 6
Apartments 6 48
Residential
Conversions 5 8 2 3
Single-Family
Residential 4 1 1
TOTAL 9 9 0 26 53 11 11
GRAND TOTAL 119
Between 2015 and 2021, the CityCity of Cudahy issueds 119 building permits for residential construction /conversion. The 53 units constructed in 2019 was the largest over the seven-year period, and apartments (48) was the highest category. In contrast, there were zero building

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permits issued for residential construction in 2017, and the largest number of townhomes built (20) was in 2018.

Table 4.2
Sites Inventory Table

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Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning
Existing
Use
Max.

Density
(du/acre
)
Realistic
CapacityCapacit
y
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidatio
n Potential
Environmenta
l 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

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Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning
Existing
Use
Max.

Density
(du/acre
)
Realistic
CapacityCapacit
y
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidatio
n Potential
Environmenta
l 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

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Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning
Existing
Use
Max.

Density
(du/acre
)
Realistic
CapacityCapacit
y
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidatio
n Potential
Environmenta
l 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

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Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning
Existing
Use
Max.

Density
(du/acre
)
Realistic
CapacityCapacit
y
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidatio
n Potential
Environmenta
l 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/
Commerci
al Vacant
40 du/ac
(MU)/30
du/ac
(Res) 1
Very
Low/Low Yes No
622501801
0 0.26
Mixed Use/
Commercial
Mixed Use/
Commerci
al Vacant
40 du/ac
(MU)/30
du/ac
(Res) 4
Very
Low/Low Yes No
622501801
1 0.39
Mixed Use/
Commercial
Mixed Use/
Commerci
al Vacant
40 du/ac
(MU)/30 7
Very
Low/Low Yes No

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Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning
Existing
Use
Max.

Density
(du/acre
)
Realistic
CapacityCapacit
y
(units)
Affordabilit
y Level
(based on
density)
Lot
Consolidatio
n Potential
Environmenta
l or
Infrastructure
Constraints
du/ac
(Res)
622602290
0 0.03
Mixed Use/
Commercial
Mixed Use/
Commerci
al Vacant
40 du/ac
(MU)/30
du/ac
(Res) 1
Very
Low/Low Yes No
622602290
1 0.20
Mixed Use/
Commercial
Mixed Use/
Commerci
al Vacant
40 du/ac
(MU)/30
du/ac
(Res) 3
Very
Low/Low Yes No
622602290
2 0.17
Mixed Use/
Commercial
Mixed Use/
Commerci
al Vacant
40 du/ac
(MU)/30
du/ac
(Res) 3
Very
Low/Low Yes No
622602290
3 0.19
Mixed Use/
Commercial
Mixed Use/
Commerci
al 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

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Table 4.2 Sites Inventory Table
Parcel
Number Size (acres)
General Plan
Designation Zoning
Existing
Use
Max.

Realistic CapacityCapacity: 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: Capacitycity 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

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Figure 4-1 Sites Inventory Map

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Unaccommodated RHNA Sites Summary
The 2013-2021 rollover RHNA sites inventory included in this Housing Element identifies capacitycapacity 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 capacitycapacity on these sites is 254 units, with individual site capacitycapacity ranging from 16 to 23 units. All sites have a realistic capacitycapacity 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 capacitycapacity. 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)
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

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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 identified underutilized sites included in this inventory also have a realistic capacitycapacity 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 capacitycapacity 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
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
Inclusionary Housing Ordinance
The CityCity of Cudahy, to foster the development of additional housing units to satisfy the mandated RHNA units, has begun an amendment to Cudahy Municipal Code Chapter 20.88, definitions, and Chapter 20.30 – Inclusionary Housing Program. Section 20.88.100 I.

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Section 20.88.100 I defines an inclusionary unit as a dwelling unit that will be offered for sale or rent to very low, low, or moderate-income households, at an affordable housing cost in compliance with Chapter 20.30.

The Inclusionary Housing Ordinance is designed to encourage the development and availability of affordable housing by ensuring that the addition of the affordable housing units to the CityCity’s housing stock is proportional with the overall increase in new housing units.

All residential and mixed-use projects are required to incorporate the standards as part of an onsite Inclusionary Housing project.

A. Minimum number of units required. A minimum of 20 percent of the total number of dwelling units in a residential or mixed-use project shall be developed, offered to, and sold or rented to households of very low, low, and moderate-income, at an affordable housing cost.

B. Fractional Units. In calculating the required number of inclusionary units, any fractional unit shall be rounded-up to a whole unit.

C. Project Completeness. A residential or mixed-use project application will not be determined complete until the developer has submitted a Housing Plan and Housing Agreement, which demonstrates the manner in which the requirements of this Chapter will be met.

D. Units for Sale. If a project consists of units for sale, a minimum of 20 percent of the total number of units in the project shall be sold to very low, low, or moderate-income households.

E. Rental Units. If the residential or mixed-use project consists of rental units, a minimum percent of the units shall be provided as follows:

1. A minimum of five percent of the units shall be rented to very low-income households; and

1. A minimum of five percent of the units shall be rented to very low-income or lowincome households; and

2. A minimum of 10 percent of the units shall be rented to very low-income, or lowincome, or moderate-income households.

F. Displaced Households. On-site inclusionary units shall be required when very low, low, and/or moderate-income households are displaced. Any other provisions of this Chapter, notwithstanding, any project subject to this Chapter which results in the displacement of very low, low, and/or moderate-income household(s) shall be required to provide on-site inclusionary units as required by this Chapter.

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G. Priority Processing. All residential and mixed-use projects providing inclusionary housing on-sit e, pursuant to the provisions of this Chapter, shall receive priority building department plan check streamlining, to the extent authorized by law.

H. Final Permit. The Final Construction Permit sign off, or Certificate of Occupancy, for the inclusionary units shall be issued prior to, or concurrently with, the proposed project.

Alternatives to Providing On-Site Units.

As an alternative to developing required inclusionary units within an affected residential or mixed-use project in compliance with Section 20.30.040 (Inclusionary Unit Requirements), the requirements of this Chapter may be satisfied through one or more of the following alternatives, in compliance with this Chapter and Title 20 (Zoning Code).

A. Off-Site Units. Inclusionary units required by Section 20.30.040 (Inclusionary Unit Requirements), may be provided offsite, pursuant to Section 20.30.040 (Inclusionary Unit Requirements), if the inclusionary units are owned in whole or part, and operated, by a non-profit housing provider for the life of the project. The following requirements must be met to satisfy the off-site option of this Chapter:

1. Units for Sale or Rent. The developer shall agree to construct 25 percent more inclusionary units than the number of inclusionary units required by Section

20.30.040 A (Inclusionary Unit Requirements, Minimum Number of Units Required).

2. The developer shall identify an alternate site suitable for residential housing, which the developer either owns or has site control over (i.e., purchase agreement, option to purchase, lease) subject to CityCity review to ensure that the proposed development is consistent with the CityCity’s housing objectives and projects.

2. The off-site units shall be located within a one-quarter mile radius of the marketrate units.

3. The off-site units shall satisfy the requirements of Section 20.30.040 C, D, and E (Inclusionary Unit Requirements, Project Completeness, Units for Sale, and Rental Units).

4. The off-site units shall not count towards satisfaction of any affordable, or inclusionary housing obligation, that development of the alternative site with market-rate units would otherwise be subject to, pursuant to this Chapter.

Exceptions to the location of the off-site units specified in this Section may be granted by the CityCity Council on a case-by-case basis.

B. Land Donation. A developer of a residential or mixed-use project may satisfy the Inclusionary Housing Requirement by dedicating land in-lieu of constructing restricted affordable units within the residential or mixed-use project if the CityCity Council determines that all the following criteria have been met:

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1. The dedicated site is transferred to the cityCity prior to commencement of construction of the residential or mixed-use project or is subject to an agreement between the developer and the cityCity that sets forth a date certain for transfer of the dedicated site and such agreement is in the best interests of the cityCity; and

1. The value of the dedicated site at the date of dedication or the date such agreement to dedicate is executed, as applicable, is greater than the in-lieu fee in effect at the date of dedication or the date such agreement to dedicate is executed, as applicable, multiplied by the number of otherwise required affordable units within the residential or mixed-use project; and

2. The dedicated site could accommodate at least the number of otherwise required affordable units within the residential or mixed-use project. Notwithstanding the above, the CityCity shall not be required to construct restricted affordable units on the dedicated site, but may sell, transfer, lease or otherwise dispose of the dedicated site as necessary in furtherance of its inclusionary affordable housing goals.

C. Purchasing Affordable Housing Covenants. A developer may purchase affordable housing covenants for units in an existing residential or mixed-use project within the cityCity. All such units shall be:

1. Reasonably dispersed throughout the residential or mixed-use project; and

1. Located in an area or areas of the CityCity, as approved by the CityCity Manager, or designee; and

2. Proportional in the number of bedrooms and location to the market rate units included in the developer's residential or mixed-use project; and

3. Comparable to the market rate units included in the residential or mixed-use project in terms of design, materials, finished quality, and appearance.

D. Substantially Rehabilitating Existing Housing. A developer may purchase and substantially rehabilitate existing market rate units, for conversion to affordable units.

Substantially rehabilitating means:

1. Rehabilitating a dwelling unit that has substantial building and/or other code violations; and

1. Has been vacant for at least ninety days; and

2. The unit is returned to the CityCity's housing supply as decent, safe, and sanitary housing; and

3. The cost of the rehabilitation work exceeds twenty-five percent of the market value of the unit after rehabilitation.

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E. In-Lieu Fee. The developer may choose to pay a fee in lieu of providing all or some of the inclusionary units as follows:

1. Amount of Fee. The amount of the fee shall be as required by the Council’s Fee Resolution.

1. Timing of Payment. One-half of the in-lieu fee shall be paid (or a letter of credit posted) before issuance of a building permit for any part of the residential or mixed-use project. The remainder of the fee shall be paid before a Certificate of Occupancy is issued for any unit in the project.

2. Housing Trust Fund. Fees collected in compliance with this Section shall be deposited in the Affordable Housing Trust Fund.

With these policies in place, the CityCity of Cudahy anticipated using its Land Use plan to meet the RHNA numbers, with the understanding that there may be other obstacles to satisfying the RHNA requirements.

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 cityCity. However, most of the potential housing sites identified by the cityCity 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 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 CityCity of Cudahy is a relatively new CcityCity having only incorporated in the 1960s. At the time of incorporation, more than 80% of the CcityCity’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 CityCity’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 CcityCity 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 CcityCity 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 CityCity’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 CityCity’s total land area.

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Noise
Cudahy is in an area where the ambient noise levels are relatively high. A cityCitywide noise inventory performed in May 2013, found that virtually all the neighborhoods in Cudahy are in areas where noise levels exceed 65 dBA. The cityCity’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 cityCity. 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 CityCity is not exposed to natural environmental hazards such as flooding, slope erosion and landslides. However, the cityCity is located within an area that is subject to liquefaction hazards. The cityCity 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 CityCity 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 DistrictDistrict, and the CityCity is protected by a levee wall.

CityCity 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 CityCity 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

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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 CityCity 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 CityCity's central location in Los Angeles County provides Cudahy with easy access to most parts of the Southern California region. Local circulation within the cityCity generally follows a grid pattern; except for Atlantic Avenue which extends in a northsouth 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 CityCity streets are currently approaching or are at capacitycityCity.

Regional access to the cityCity is provided by the Long Beach Freeway (I-710) that extends along the CityCity'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 cityCity. 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 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 cityCity. 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 cityCity consist of two travel lanes.

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

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ASSESSMENT OF SEWER AND Water, And Sewer
The CityCity 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 cityCity. 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 cityCity 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 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 CityCity’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 CityCity of Cudahy sewage flows while Los Angeles County Department of Public Works (County DPW) maintains all cityCity-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

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sewer collection facilities serve customers in the cityCity. The cityCity 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 cityCity 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 CityCity’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 per 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 capacityCitycapacity at the Joint Water Pollution Control Plant in Carson. Program 14 Infrastructure Availability has been updated: 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 2024 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 needed to ensure appropriate levels of circulation, water, sewer, storm drainage, and other utilities’ availability and capaCitycapacity. The City will review the 2022 Economic Development Strategic Plan as it relates to housing issues, including transportation opportunities, and pursue funding sources for related infrastructure improvements. In addition, the City will establish specific procedures, in 2024, and require that priority is given to developments with units affordable to lower-income households. Responsibility: Community Development Department. Funding: City General Fund and other funding sources as available.

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

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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.

List of Charts, Tables, and Maps
Table 5.1- Development Standards ……………………………....– Page
Table 5.2- R-1 – Single-Family Residential development Standards ………………………………...- Page 84 Table 5.3- R-2- Medium Density Development Residential Standards…………………………….. – Page 84 Table 5.4 - R-3 – Intermediate Density Residential Development Standards …………………….– Page 91 Table 5.5 - R-4 – High Density Residential Development Standards ……………………………….– Page 92 Table 5.6 - Mobile Home Park Development Standards …………………………………………….– Page 92 Table 5.7 -Individual Mobile Home Lot/Space Standards …………………………………………..– Page

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Map 4.1- CityCity of Hawaiian Gardens Zoning Map …………………………………………………....– Page 78

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 CityCity 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.

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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.

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

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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 CityCity shall continue housing programs on housing development, infrastructure, rehabilitation, and job development, as allowed by the CDBG program. The cityCity 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 CityCity shall prepare a brochure outlining available housing assistance and rehabilitation programs in the CityCity. The cityCity 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 CityCity 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 CityCity of Cudahy regulates the use of land within the cityCity limits through General Plan, the Zoning Ordinance, and building codes and standards.

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

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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 CityCity’s response include the following:

The CityCity has adopted the Los Angeles County 2020 2019 California Building Code that establishes minimum construction standards. The CityCity’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 CityCity is in reference to identifying the Planning Commission as the building Board of Appeals.

The CityCity 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 CityCity’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 CityCity is in reference to identifying the Planning Commission as the building Board of Appeals.

Code Enforcement site visits are typically complaint driven. The CityCity 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 CityCity 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 electricityCityelectricity 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 CityCity’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

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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 cityCity do not make any distinction between rental housing and owneroccupied housing or the types of housing (single-family or multiple-family).

The CityCity 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 CityCity 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 CityCity 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 CityCity’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 cityCity. 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

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

Most of the CityCity of Cudahy consists of very low-income neighborhoods. According to the 2020 Census data prepared by SCAG, of the CityCity'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 cityCity 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 cityCity 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 cityCity. 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 cityCity; 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

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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.

Development Code Requirements
The CityCity 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 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 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.

Table 5.1
Development Standards
Table 5.1 Development Standards
Zone
Dev.

Standard
Commercial/
Mixed Use
Civic/
Mixed Use
Innovation
IndustrialEntertainment
High Density
Residential
Medium
Density
Residential
Low Density
Residential
Density 30-40 du/ac 30-40 du/ac N/A (in Housing Element we assume 30 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: none10’
Side: none. 10’ adjacent
to Res. 10’ on corner
lots
Rear: none. 10’ adjacent
to Res.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
Private: 150 sq. ft.
/unit
Common: 280 sq.
ft. /unit 50%
Private: 150 sq. ft.
/unit
Common: 280 sq. ft.
/unit 50%
Private: 150 sq. ft. /unit
Common: 280 sq. ft.
/unit 60%
Private: 200
150 sq. ft.
/unit
Private:
200150 sq. ft.
/unit
250 sq. ft./unit or
25% of the lot
area/unit (exclusive
of the front yard
setback)

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Table 5.1 Development Standards
Zone
Dev.

Standard
Commercial/
Mixed Use
Civic/
Mixed Use
Innovation
IndustrialEntertainment
High Density
Residential
Medium
Density
Residential
Low Density
Residential
Common: 280
sq. ft. /unit
Common: 280
sq. ft. /unit
Building
Height
4 stories 4 stories 42-3 +4 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: 1.52 spaces/ 1-2 bed, 2 spaces per 3+ bed. 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 .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 Development Standards Study
City conducted a test to determine if any current development standards constituted constraints to developing new housing at the densities permitted by the zoning code.

The analysis developed below studied a series of housing types under current zoning regulations applying to typical lot sizes located within the area. The studies sought to identify any development standards which provide significant constraints to the development of housing at densities permitted in the City. Housing in the area consisting of multi-family residential zones were studied, such as townhome and rental developments upon a lot size of 0.46 acres with typical site dimensions to the city. The most restrictive zoning standards were studied when considering the mixed-use development to propose the most effective changes to be made.

Additionally, dDuring the preparation of the Inclusionary Housing Program the City reviewed the parking standards for all residential zones. Following public input, including public hearings, the City incorporated an option for a different parking standard as one of the incentives to construct affordable units onsite. The option included elimination of the garage requirement, while still maintaining the space requirement. Throughout the public outreach process for the Inclusionary Housing Program, the community and elected officials expressed concerns over the lack of adequate parking in the City and did not want to see the space requirements changed. However, to ensure that impediments to medium and high-density residential development are minimized,

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the City will include considerationreconsider the guest parking requirements through the following study. of eliminating the garage parking requirements in the medium and high-density residential zone districts, while still maintaining the number of spaces required. Program 28 Zoning Code Review.

The first study consisted of a residential townhome development under current zoning standards applying to a typical lot size and shape within the city. The study showed the current development standards on a lot size of 0.46 acres with typical site dimensions to the city can accommodate 7 units (15 du/ac, 38% max density of the highest-density residential zone (HDR)).

Each three Bedroom unit is three stories. The common open space required is 280 SF per unit and private open space (including the 15’x15’ area) is 365 SF per unit. The vehicular aisle dimensions for this site are to be 24’ (two way) and the current standards require a minimum of 18 spaces (2 spaces/du, one in a garage + 0.5 guest spaces).

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There are potential for density improvements through modifications to the current constraints that effect a typical residential townhome development. Shown below are development adjustments made to this townhome study that increase the site density to 9 units (20 du/ac, 50% max density of the highest-density residential zone (HDR)). This is possible by the elimination of the 15 du/ac limit on sites less than 0.5 acre. The townhomes remain 3 Bedroom units at three stories tall. By allowing the fire turn around to be counted towards the common open space requirement of 280 SF per unit and eliminating the required 15’x15’ area within the private open space of 365 SF per unit to a total of 200 SF per unit the site area can be maximized in the typical lot condition. Parking standards in this study remain the same requiring a minimum 22.5 spaces (2 spaces/du, one in a garage + 0.5 guest spaces).

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The residential rental under current constraints within a lot size of 0.46 acres produces a scenario with 11 Units (24 du/ac, 52% max density of the highest-density residential zone (HDR)), three stories with first level parking and two levels of mixed family residential above consisting of (6) 2 Bedroom, (4) 1 bedroom, and (1) studio units. The required common open space is 280 SF per unit with a private open space of 200 SF per unit. A 24’ (two way) vehicular aisle dimension is required, this scenario requires a minimum of 22 parking spaces ((1,2 beds): 1.5 spaces/dwelling unit, one in a garage + 0.5 guest spaces) and ((studio): 1 space/du, not garaged + 0.5 guest spaces)).

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The modifications to current zoning constraints to the residential rental study allows for a substantial gain in site performance. The scenario increases density to 15 Units (33 du/ac, 82% max density of the highest-density residential zone (HDR)), consisting of (8) 2 Bedroom, (5) 1 bedroom, and (2) studio units. The required common open space is adjusted to 180 SF per unit, with allowance for the common space to be used as fire turnaround. The private open space is reduced to 100 SF per unit, with the balconies allowed to project into the 7’ side setback up to 3’. The guest parking standards have been reduced from 0.5 guest spaces per unit to 0.25 guest spaces per unit, lowering the parking requirement for this scenario to reflect 26 spaces ((1,2 beds): 1.5 spaces/dwelling unit, one in a garage + 0.25 guest spaces) and ((studio): 1 space/du, not garaged + 0.25 guest spaces)).

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The mixed-use scenario was studied by taking the most restrictive zoning standards. With a current FAR of 1.0 this provides a site with 78 Units (31 du/ac, 78% max density) consisting of (42) 2 Bedroom, (21) 1 bedroom, and (15) studio units and 30,500 SF of retail space, on a site of

2.5 acres. Common open space requirements are 280 SF per unit and private open spaces are to be 200 SF per unit. Parking under current standards require retail spaces to provide 1 space per 300 SF, additionally residential parking standards reflect the typical ((1,2 beds): 1.5 spaces/dwelling unit, one in a garage + 0.5 guest spaces) and ((studio): 1 space/du, not garaged + 0.5 guest spaces)). This results in 275 spaces in this scenario which are split between 81 surface and 194 structured in 2 levels or single level with parking lifts to accommodate both parking requirements.

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The modifications to this mixed-use development scenario increase performance and density of the site by increasing FAR limits to 1.5, resulting in a site with 100 Units (40 du/ac, 100% max density) consisting of (42) 2 Bedroom, (34) 1 bedroom, and (24) studio units and an increased retail space of 39,600 SF. The common open space has been adjusted to 180 SF per unit and the private open space reduced to 100 SF per unit. In this scenario retail parking standards have been reduced by 20% and residential guest parking standards reduced to 0.25 per unit ((1,2 beds): 1.5 spaces/dwelling unit, one in a garage + 0.25 guest spaces) and ((studio): 1 space/du, not garaged + 0.25 guest spaces)). Resulting in 277 spaces which are split between 40 surface and 237 structured in 2 levels or single level with parking lifts to accommodate both parking requirements.

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Through these study modifications provided the city is committing to the following zoning changes regarding the highest-density residential zone (HDR), to Eliminate the 15 du/ac limits on sites less than 0.5 acres, eliminate 15’x15’ required private open space for residential townhomes and reduce private open space applying to residential rental units to 100 SF. Allowing both townhome and residential unit developments to count fire turnaround to within the common open space area. The reduction of guest parking requirements to be 0.25 per unit will further increase site needs. The allowance of balconies to project into side setback measuring 7’ will optimize unit space. These changes in standard will greatly increase performance and density demands within the city.

Mixed-use developments will benefit from increasing the FAR limit to 1.5 and eliminating the one-acre minimum requirement. Residential open space reductions, common open space to 180 SF per unit and private open space to 100 SF per unit will also increase unit density within the site. Parking requirements for commercial use by 20% and residential guest parking requirements reduced to 0.25 per unit will also stimulate site performance.

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 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.

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During the preparation of the Inclusionary Housing Program the City reviewed the parking standards for all residential zones. Following public input, including public hearings, the City incorporated an option for a different parking standard as one of the incentives to construct affordable units onsite. The option included elimination of the garage requirement, while still maintaining the space requirement. Throughout the public outreach process for the Inclusionary Housing Program, the community and elected officials expressed concerns over the lack of adequate parking in the City and did not want to see the space requirements changed. However, to ensure that impediments to medium and high-density residential development are minimized, the City will include consideration of eliminating the garage parking requirements in the medium and high-density residential zone districts, while still maintaining the number of spaces required.

Program 28 Zoning Code Review.

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 CityCity Council. Findings to approve a CUP include:

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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, CityCity 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 CcityCity 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).

• 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

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dwellings of the same type in the same zone. Transitional housing and supportive housing shall be approved by right in all residential zones.
• 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 CityCity’s Development Code will be amended to include the following definition of Family: means one or more persons living together in a dwelling unit, with common access to, and common use of all living, kitchen, and eating areas within the dwelling unit. 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
2nd Unit P P P NP NP NP
P= Permitted; CUP= Conditional Use Permit; NP=Not Permitted Source: CityCity of Cudahy Building & Planning Departments The “2nd Unit” or Accessory Dwelling Unit is identified in Table 5.2 as not permitted in the mixeduse zones. This regulation is not in compliance with statutory requirements. Additionally, the City will review development standards and make amendments as necessary to provide incentives and promote development of accessory dwelling units for very low-, low-, and moderate-income households. Review could include exploring and pursuing available state funding, fee reductions, pre-approved plans, and homeowner/applicant assistance tools. Program 3 is amended to include the following:

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The City will update the accessory dwelling unit requirements within the Zoning Code, and update the Ordinance, to comply with statutory requirements. The City will review development standards and make amendments as necessary to provide incentives and promote development of accessory dwelling units for very low-, low-, and moderate-income households. Review could include exploring and pursuing available state funding, fee reductions, pre-approved plans, and homeowner/applicant assistance tools. Amendments to the Zoning Code will be completed in 2023.

Permit Processing
Residential development review and permit processing are necessary steps to ensure that development proceeds in an orderly manner consistent with the policies of the General Plan. The City permits various residential uses by right in their respective zones, as identified in Table 5.2.

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 cityCity 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 5.2
Housing Types Permitted by Zone District
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 CUPP P P NP NP NP
5+ DU CUPP 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 NCUP
Supportive Housing P P P P P CUP
2nd Unit P P P NP NP NP
P= Permitted; CUP= Conditional Use Permit; NP=Not Permitted

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Source: CityCity of Cudahy Building & Planning Departments 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: CityCity of Cudahy Building & Planning Departments Discretionary permits are required for some residential projects. Most discretionary projects can be approved by the Planning Commission. This process includes the following: an application, Planning Commission hearing, action (approval or denial). The City does have an appeal process if an applicant does not agree with a condition or does not agree with a denial action. The applicant would then file an appeal, and the project would be considered by the City Council for final action. If the application includes a General Plan amendment, rezone, and/or a development agreement then the project would go to the Planning Commission who makes a recommendation to the City Council, and the City Council is the final hearing body.

The City has a zoning clearance process which is an ministerial, administrative review undertaken by the Community Development Director. Currently, the review takes approximately 2 weeks.

The code describes this review as discretionary, however, within Program 28 the City commits to making the review of the Director of Community Development ministerial in nature. The review is to ensure that all proposed new and modified uses and structures that do not require any discretionary actions comply with applicable provisions of the City’s Zoning Code. The review takes approximately 2 weeks.

The City approves minor and major residential projects through a development review process.

Applications for development review are all subject to CEQA. If a minor development review permit triggers a negative declaration, mitigated negative declaration, or environmental impact report, the project shall be referred to the planning commission for review and approval.

Generally, major development review approval is by the Planning Commission and minor development review approval is by the Director of Community Development.

Single family residential projects, including new construction, expansions over 50% of the existing floor area, expansions under 50%, façade improvements, and accessory structures visible from the public street, all second story additions, and accessory dwelling units, are subject to approval or denial from the Director of Community Development. If the developer/owner wishes to appeal, the appeal will be heard by the Planning Commission.

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Single family residential projects, including expansions less than 50% of existing floor area, façade improvements, and accessory structures not visible from the public street and conversions of existing living areas into existing structures to an accessory dwelling unit, are subject to approval through a zoning clearance. If the developer/owner wishes to appeal, the appeal will be heard by the Planning Commission.

Multifamily residential projects, including new construction (including second stories, proposing 3 or more dwelling units), expansion (including accessory structures and second stories over 50% of the existing gross floor area), and fences or walls with 3 or more dwelling units, proposing a fence within the front yard setback over 42 inches in height, are subject to approval by the Planning Commission. If the developer/owner wishes to appeal, the appeal will be heard by the City Council.

Multifamily residential projects, including expansion (including accessory structures and second stories up to a maximum of 50 percent of the existing gross floor area, but no additional dwelling units), second stories proposing up to a maximum of 2 dwelling units, fences or walls on projects with up to 2 dwelling units, proposing a fence within the front yard setback over 42 inches in height, and façade improvements, are subject to approval by the Director of Community Development. If the developer/owner wishes to appeal, the appeal will be heard by the Planning Commission.

The City reports that according to the 18 most recent residential project approvals, approximately half of the projects were approved through one Planning Commission and the other half were approved through one Planning Commission meeting and one City Council meeting. It is likely that projects required two hearings due to a development agreement requirement for new development in the HDR zone that the City commits to removing in Program

28. Additionally, one project 48 unit project required 3 hearings. The first and second hearings were with the Planning Commission, who needed more time and eventually denied the project.

The developer/owner appealed to the City Council and the City Council approved the project during the third hearing.

The development review findings are as follows:

1. Consistency. The project is consistent with the general plan, any applicable specific plan, all applicable provisions of this zoning code, all other city ordinances and regulations, and any plan of another governmental agency made applicable by statute or ordinance.

2. Proportionality. The height, bulk, and other design features of structures are in proportion to the building site, and external features are balanced and unified so as to present a harmonious appearance.

3. Design. The project design contributes to the physical character of the community, relates harmoniously to existing and anticipated development in the vicinity, and is not monotonously repetitive in and of itself or in conjunction with neighboring uses, and does not contribute to excessive variety among neighboring uses.

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4. Site Layout. The site layout and the orientation and location of structures and their relationship to one another and to open spaces, parking areas, pedestrian walks, signs, illumination, and landscaping achieve safe, efficient, and harmonious development.

5. Site Development. The grading and site development show due regard for the qualities of the natural terrain and landscape and do not call for the indiscriminate destruction of trees, shrubs, and other natural features.

6. Signs. The design, lighting, and placement of signs are appropriately related to the structure and grounds and are in harmony with the general development of the site.

7. Equipment and Service Areas. Mechanical equipment, machinery, trash, and other exterior service areas are screened or treated in a manner that is in harmony with the design of the structures and grounds.

8. Compatibility. The project shows proper consideration for adjacent residentially zoned or occupied property and does not adversely affect the character of such property.

Upon review the City found that the development review findings are not objective, therefore, the City commits to revising these findings to be objective through Program 28. Additionally, in Program 28, the City commits to increasing the number of units that trigger Planning Commission review from 3 units to 5 units. In Program 28, the City shall commit to considering development review by the Director of Community Development to be ministerial in nature. Discretionary permits are required for some residential projects. Most discretionary projects can be approved by the Planning Commission. This process includes the following: an application, Planning Commission hearing, action (approval or denial). The City does have an appeal process if an applicant does not agree with a condition or does not agree with a denial action. The applicant would then file an appeal, and the project would be considered by the City Council for final action.

If the application includes a General Plan amendment, rezone, and/or a development agreement then the project would go to the Planning Commission who makes a recommendation to the City Council, and the City Council is the final hearing body.

Some uses may require a Conditional Use Permit. The City recognizes that certain uses, due to the nature of the use, intensity, or size, require special review to determine if the use proposed, or the location of that use; is com compatible with surrounding uses; or if through the imposition of conditions on the development and use, it can be made compatible with surrounding uses.

The conditional use permit is provided for this purpose and to ensure compatibility with zoning regulations and with surrounding properties. The code currently requires a CUP for multifamily development in the LDR zone. The City commits to removing this requirement in Program 28.

The Planning Commission shall consider applications for a Conditional Use Permit and may, with or without conditions, approve any application that is in general accord with the followingthe following principles and standards based on findings and conclusions drawn from information and evidence presented at a public hearing. Conditional Use Permits shall be granted only when

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the Planning Commission determines that the proposed development or activity complies with all of the following findings:

A. Consistency. The use shall be consistent with the general plan and consistent with the integrity and character ofthe 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.

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 oftraffic 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.

G. The Planning Commission may apply such conditions to a proposed conditional use as it deems necessary to protect the public health, safety, and general welfare, The process for a Conditional Use Permit, application through one Planning Commission hearing takes approximately three months.

The City currently has a requirement for a development agreement for new development within the HDR zone. This requirement is the reason why approximately half of the 18 most recent development projects had to go through two hearings, one Planning Commission hearing and one City Council hearing. In Program 28, the City commits to removing this development agreement requirement for new development in the HDR zone.

The subdivision of land is regulated by Title 19 of the Cudahy Municipal Code and by the State of California Subdivision Map Act. Tentative parcel maps are required when a project proposes to subdivide land into four or fewer parcels. Tentative parcel maps require a public hearing and approval of the Planning Commission. This process takes approximately three months. Projects

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proposing the creation of more than four parcels require a tentative tract map. Tentative tract maps require a public hearing before the Planning Commission with final action by the City Council. This process takes approximately three months and can include an additional month due to scheduling the final map for City Council action.

As noted below the City has a very aggressive schedule for reviewing, processing, and taking action on projects. Because of this, the City’s requirement as noted above, for applications and the associated timelines have not majorly impacted the cost of housing, the supply of housing, timing for development, or approval certainty. Housing cost and timing for development have both not been greatly impacted as the City’s approval processes are quite quick and will become quicker through the changes in Program 28. Approval certainty in the City may impact the supply of housing when we consider larger housing projects, as developers might not be willing to take risk if they are not confident their project will be approved. The development agreement requirement for new development in the HDR zone is likely the reason that developers are sometimes uncertain about the certainty that their development will be approved. Therefore, in Program 28, the City commits to removing this development agreement for new development in the HDR zone.

The City has included a new program in this Element,Additionally, Program 28 (Zoning Code Review) commits to several other development review process changes as stated previously in this section and directly in Program 28., which requires a review of the Zoning Code including such reviews of use categories, development standards (including parking), processing, and updates required due to statutory regulations. Additionally with the adoption of the Inclusionary Housing Program in 2022, the City is also aggressively pursuing the development of affordable housing, as part of a residential project and a mixed-use with a residential component project.

This includes incentives for constructing the affordable units on-site and eligibility for an environmental review permit streamlining process. A new program has been added to this Element, Program 29 Implementation of the Inclusionary Housing Program and Economic Development Strategic Plan which will further the City’s priority to develop affordable housing and jobs.

Processing Time
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 the General Plan and Zoning standards 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,

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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 application may be reviewed in conjunction with the required site plan and tentative tract map. 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
The City has not received any requests to develop housing at densities below those identified in Chapter 4, sites inventory. Rather, the City has received density bonus requests, most recently for the affordable senior project approved in 2021. Following approval of a planning entitlement the typical processing time for an applicant to submit a residential building permit (plan check) request has been four to six weeks. Review and issuance of a typical residential building permit request averages 2-4 weeks, depending on the complexity of the project. The challenges of meeting the City’s share of the regional housing need has not been hindered by the City’s development application nor building permit processes. During the COVID-19 pandemic, even with closure of some City offices, the City still provided planning and building services, remotely and onsite in accordance with state and federal regulations. Additionally, the City continues to offer electronic plan check.

SB 330 Streamlining
The City’s timelines are consistent with those contained in SB 330 Housing Crisis Act of 2019. For example, SB 330 limits the number of public hearings on a housing development to five. In 2021 the City approved a 179 unit affordable housing project for seniors which included one Planning

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Commission hearing and two City Council hearings. The State law also reduces the time that the City has to approve or disapprove an application under the permit streamlining act. Further, the City is prohibited from downsizing (reducing density) unless an equivalent acreage is upsized (increasing density). The City has not downzoned properties and in fact during 2018 the City significantly increased the densities for the residential zones.

The City’s Zoning Code includes provisions that allow the Community Development Director to approve a design review application for minor projects. The Planning Commission includes the design review process when considering a development review permit. Both levels of review shorten the review time by allowing administrative approval in one case and combining entitlements in the other case. Additionally, the City’s Zoning Code includes provisions that allow the Community Development Director to approve a minor modification or amendment to a project. This allows a project to continue through the building permit and constructions phases without going back through a hearing process which would add time to project development. In 2022 the City adopted the Inclusionary Housing Program which included an environmental review streamlining process for eligible projects.

SB 35 Processing Procedure
Senate Bill (SB) 35 requires cities and counties to streamline review and approval of eligible affordable housing projects by providing a written process for ministerial approval, exempting qualifying projects from CEQA review. SB 35 can be utilized in a City when the State determines the City has made insufficient process towards their lower-income RHNA. In Cities where the State has made this determination SB 35 allows for streamlined ministerial approval of proposed developments with at least 50% affordability. If the City is also determined to have made insufficient progress towards their moderate-income RHNA, the City is subject to the more inclusive streamlining for developments with at least 10% affordability.

The City of Cudahy is subject to SB 35 streamlining at this time, specifically the more inclusive streamlining for developments with at least 10% affordability.

Effective January 1, 2018. If the City does not meet the Regional Housing Needs Assessments (RHNA) a developer can request a streamlined process. Provided the development meets specific state requirements, then the City has: 60 days to approve the project if it contains less than 150 housing units, or 90 days if the project contains more than 150 housing units.

SB 35 applies only to the specific income levels not being built for. For example, if a City is building enough market-rate units to meet its RHNA but not enough low-income units, the project can only add low-income units to qualify for quickened approval.

According to SCAG the City has not met the RHNA targets and has a remaining unmet need for all income categories. However, the City recently approved the “Prima” Development for 177 affordable units for low-income seniors. This approval will exceed the City’s 6th Cycle RHNA target

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for the provision of low-income units. These units were not included in this Housing Element because state law only allows units that have received a building permit to be counted. Once a building permit has been issued, then the units will be credited to the City as meeting the respective RHNA target. The RHNA targets may also be met in the future, with the implementation of the Inclusionary Housing Ordinance, and subsequent construction of affordable units.

As noted previously, the City’s Zoning Code includes provisions for streamlining. Examples included the design review process, combining applications allowing for one hearing for all entitlements rather than separate hearings for each entitlement, and the recently approved environmental review streamlining process for Inclusionary Housing projects. The City’s development codes are generally permissive of development; therefore, there is no need to circumvent and streamline. However, the City of Cudahy commits to creating a SB 35 checklist and written procedure for processing SB 35 applications (Program 28). The City will also make information available to developers of eligible projects.

Local Ordinances – Analysis of Adopted Ordinances that Directly Impact the Cost and Supply of Housing
The City of Cudahy is surrounded by the incorporated cities of South Gate, Bell, Bell Gardens, and Huntington Park; therefore, the City does not have the ability to expand the City’s boundaries and has not adopted any growth control policies. The City has imposed no moratoria or prohibitions against multifamily housing developments. In 2020 the City issued 119 residential permits, which included six new homes, and permits for electrical, plumbing, and mechanical improvements. In 2020 the City approved projects totaling 221 units, of which 184 were for very low-income households. The City has not adopted any ordinances pertaining to rent control, short term rentals or crime-free rental housing.

In 2022 the City adopted an Inclusionary Housing Ordinance furthering the City’s commitment to providing a variety of affordable housing opportunities throughout the City. Below is a summary of some of the requirements/regulations included in the Inclusionary Housing Program (adopted as an Ordinance, Zoning Code Amendment):

Applicability
• All new residential and mixed-use projects with 4 or more units to provide affordable units.
• For sale units: 15% of total units in the project shall be sold to households at 80% or less of county median income; 45-year affordability. • Rental units: 5% very-low income, 5% very-low or low, 5% very-low, low, or moderate income; 55-year affordability.
• Fractional Units. In calculating the required number of inclusionary units, any fractional unit shall be rounded-up to a whole unit.

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Concessions – Incentives to Provide Units On-Site
• Reduced side yard setbacks.
• Decrease distance between buildings.
• Include private open space in front yard as part of open space requirement. • Eliminate parking garage requirement, maintain number of parking spaces. • Maintain City’s density bonus provisions.

Standards
• The affordable units shall be dispersed throughout the project. • The affordable units shall be comparable in design, appearance, and size. • The affordable units shall be constructed concurrently with the market rate units.

Housing Plan, Housing Agreement, Livability Report
• Housing Plan: Required with project application. Identifies for-sale and rental units, location of units, and income levels.
• Housing Agreement: Recorded document that goes with the land. Identifies affordability requirements, resale restrictions, and monitoring ongoing affordability.
• Livability Report: Required to be submitted to City annually.

This Housing Element includes amendments to existing programs, such as State Density Bonus Law which contributes to land cost reductions. Additionally, this Housing Element includes new programs such as the Single Room Occupancy, Implementation of the Inclusionary Housing Program and Economic Development Strategic Plan, and Zoning Code Review (parking standards for medium and high-density residential projects and use category for residential care facilities) which will contribute to increasing the supply of housing.

Effects of the Inclusionary Housing Ordinance
The City does not anticipate effects on housing supply resulting from the inclusionary housing ordinance; a 15% affordable requirement is typical and within the threshold that does not require special review from HCD. However, in Program #29 (Inclusionary Housing), the City commits to monitoring housing production. Should negative effects be observed, the City will revise the ordinance to remove the constraint.

The development standard concessions, or incentives, identified in the Element, which can be allocated on a discretionary basis by the City Council. However, State Density Bonus Law already allows developers to pursue affordable housing concessions to be processed on a ministerial basis. In Program #29, the City also commits to expanding the number of potential incentives and modifying them to be ministerial in nature.

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Development Fee Review
The cityCity 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 cityCity 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 CityCity 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 CityCity’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 CcityCity 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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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 cityCity.

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).

In 2022 the City adopted an Inclusionary Housing Program with an environmental review permit streamlining process. The Inclusionary Housing Program requires residential and mixed-use with a residential component project to include affordable units as part of the project. An inclusionary housing project, may be eligible for a streamlined environmental review process, and can be determined to be exempt from CEQA review as a Class 32 “In-fill Development Projects” exemption pursuant to CEQA Guidelines Section 15332 if the project meets all the conditions of an in-fill development project, and the City’s Inclusionary Housing Ordinance, as follows:

1. The project is consistent with the applicable General Plan designation and all applicable General Plan policies; and

2. The project will implement all applicable General Plan Environmental Impact Report mitigation measures; and

3. The project is consistent with all applicable zoning designations and regulations; and

4. The project is consistent with the City’s Inclusionary Housing Ordinance regulations; and

5. The proposed development occurs within the City of Cudahy City limits, on a project site of no more than five (5) acres substantially surrounded by urban uses; and

6. The project site has no value as habitat for endangered, rare, or threatened species; and

7. Approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and

8. The project site can be adequately served by all required utilities and public services; and
The City reserves the right to require special studies including but not limited to hazardous wastes, soils analysis, traffic impacts, and any other analysis/studies as deemed necessary to adequately identify potential environmental impacts and resulting mitigation measures

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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: CityCity of Cudahy Building & Planning Departments Zoning Development Standards and Fees
Standards ENTITLEMENT FEES
The development standards are identified in the City’s Municipal Code, Title 20: City of Cudahy Zoning Code. The standards are included in Table 5.1 of this Housing Element and posted on the City’s website:
https://www.Cityofcudahy.com/DocumentCenter/View/218/Cudahy-Zoning-Code-PDF Fees
The CityCity charges two types of fees, planning entitlement fees (Table 5.5) and) and development impact fees (Table 5.6) 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. 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. The City currently posts all planning entitlement fees the maximum justified impact fees on the City’s website:

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Planning Entitlement Fee Schedule
https://www.Cityofcudahy.com/DocumentCenter/View/221/Planning-Fee-Schedule-PDF Maximum Justified Impact Fee Summary
https://www.Cityofcudahy.com/DocumentCenter/View/774/Development-Impact-Fees The following tables identify the planning and development schedule, and the maximum justified impact fees.

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.

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Table 5.4
Planning and Development Fee Schedule
(as amended May 3, 2022)
Application Fee $
Conditional Use Permit (CUP) 5,000.00
Variance (VAR) 5,000.00
Zoning Change 7,500.00
Sign Permit 240.00
Environmental Impact Report/Negative
Declaration
10,000.00 Deposit
County Registrar 75.00
Minor Development Review 1,200.00
Subdivision Map Review (TM) 7,500.00
Tentative Map Consideration (TPM) 4,225.00
Admin Appeal 1,100.00
Planning Commission/City Council Appeal 2,300.00
Rebuild Letter/Zoning Verification 225.00
Temporary Use Permit Admin 562.50
Code Amendment 7,500.00
Lot Line Adjustment 2,000.00
Development Review Permit 5,000.00
Development Agreement 10,000.00 Deposit
Source: City of Cudahy July 2022
Table 5-5: Planning and Development Fee Schedule as of December 14, 1987, Per CityCity 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

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Tentative Map Consideration (S-10)
$4,225.00
Development & Appeal Processing
Administrative Appeal
Planning Commission Appeal
CityCity Council Appeal
$630.00
$1,295.00
$1,295.00
Source: CityCity 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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Table 5.5
Maximum Justified Impact Fee Summary
Land Use $ Traffic Facilities $ Parks and
Recreation
Facilities2
$ General
Government
Facilities
$ Total (Onsite
parking)3
Residential Fee
per Dwelling Unit
Single Family 2,037.00 11,624.00 1,395.00 15,056.00
Multifamily 1,365.00 10,303.00 1,237.00 12,905.00
Nonresidential –
Fee per 1,000 Sq.

Ft.

Commercial 3,174.00 - 196.00 3,370.00
Office 3,174.00 - 233.00 3,407.00
Industrial 1,945.00 - 110.00 2,055.00 1 Mitigation Fee Act fee shown n. Quimby fees in lieu of parkland dedication only apply to development occurring in subdivisions.

Quimby in-lieu fees are $37,884 per single family unit and $33,579 per multifamily unit. 2Assumes that development project provides parking onsite. Maximum justified fee of $29,170 in-lieu of providing one space onsite. Refer to City’s municipal code parking standards for detailed parking requirements. Source: City of Cudahy, July 2022 ON-/OFF-SITE IMPROVEMENTS
2 3

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The guidance from HCD indicates:

The element must also describe and analyze the impact of on-and off-site improvement standards including street widths, curb, gutter, and sidewalk requirements, landscaping, circulation improvement requirements and any generally applicable level of service standards or mitigation thresholds.

Developers of residential subdivisions in Cudahy are required to construct streets, curbs, gutters, sidewalks, sewer and water lines, street lighting, and trees located in the public rights-of-way within and adjacent to a subdivision. These facilities are then dedicated to the City, which is responsible for maintenance. On- and off-site improvements add to the total cost of developing housing, but are costs associated with the provision of infrastructure and services necessary for the health and safety of the public, including new residents of the subdivision. Because residential development cannot take place without the addition of adequate infrastructure, site improvement requirements are not seen as a constraint to the development of housing.

The City’s review of two recently approved projects, a 5 unit development at 5306 Clara Street and a 42 unit development at 4936-38 Live Oak Street, did not find that the City requires any significant on-site or off-site improvements from developers. As the City does not ask for significant improvements, the cost and supply of housing is not impacted.

The majority of the residential areas in Cudahy are built out. The vacant sites are dispersed throughout the City and are fairly small in size. For this reasonreason, the City promotes lot consolidation and included Program 4 Promote Lot Consolidation. The Program states that beginning in 2024 the City will establish development incentives including a list of potential consolidation sites, a review to streamline lot consolidations, provide assistance with compliance with the state’s Subdivision Map Act requirements, fee reductions, ADA compliance, and infrastructure support. The City will work with the development community and property owners to develop information that will assist with consolidating lots. Consolidating the vacant sites will also eliminate the “the “hop scotch” effect of improvements on one site, with no improvements on a middle site, then improvements on the other adjacent site. The City has been successful in acquiring state and federal funding to upgrade roadways and other infrastructure. This includes safe routes to schools which provide safe pedestrian access by improving the frontages and providing safe access for students and all of Cudahy’s citizens. Caltrans Active Transportation Program (ATP) funding providing non-motorized active and active transportation improvements for all users, and other HSIP funding.

The ability to widen streets to accommodate additional auto volumes is extraordinarily limited.

Most streets are classified and built as two-lane streets with on-street parking. Therefore, site improvement requirements vary depending on the existing condition of each project site. Due to the built-out nature of Cudahy, all developed and vacant sites in the City are already served by infrastructure including roads, sewer, water, storm drains, and utilities. There are no septic

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systems or wells located in the City. The specific requirements for public works improvements, underground utilities, water, sanitation, and streets are described below:

Public Works Improvements: Projects must dedicate land for street widening and construct or repair curb, gutter, sidewalks, pave to the centerline of all streets adjacent to the development parcel if they exceed the valuation level. In addition, developers are responsible for construction or upgrading of sewer and water mains, storm drains, streetlights, fire hydrants, street trees, and street signs. Construction is required concurrent with project development and a performance bond for the construction must be obtained before the issuance of building permits. In certain situations where construction is infeasible, the City may accept an in-lieu fee equal to the cost of construction.

Underground Utilities: Although the City does not have an established underground utility district, the City still requires that existing overhead and new lines be underground.

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. Through the Development Review Permit (DRP) the Los Angeles Consolidated Fire District (LACFD) requires a water flow test to be conducted (with the respective water company) for any new development to ensure capaCitycapacity to support the development. If the test comes back not meeting the minimum threshold, then the developer works with the City on facility upgrades.

Sanitation: Projects that require a new connection to the public sewer must pay a sewer connection fee to the Los Angeles County Sanitation District. Permits must be obtained before the issuance of City building permits.

Streets: The 2040 General Plan Circulation Element identifies the City’s circulation system, including the following streets and their respective classification:
• Arterial - Atlantic Avenue is the only major highway in Cudahy. • Collector - Otis Avenue, Salt Lake Avenue, Wilcox Avenue, Clara Street, and Santa Ana Street.
• Local - Patata Street, Live Oak Street, and Cecelia Street, while they carry high volumes of cross-town traffic, are classified as local streets.

The Circulation Element also includes a plan for incorporating bicycle facilities as part of the City’s overall circulation network. The only Class 1 bikeway (trail dedicated exclusively for the use of bicyclists) in Cudahy extends along the banks of the Los Angeles River channel, on the east side of the City and is under the jurisdiction of Los Angeles County. Depending on the scope of the development project and existing conditions, bicycle facilities could also be required as part of the street improvements.

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The required street width construction for a typical subdivision would most likely range from 60- foot rights-of-way for local streets up to 110-foot rights-of-way for an arterial (Atlantic Avenue).

Flexibility on street widths can be allowed with a specific project application taking into consideration the potential impacts of the project and existing conditions. The City is reviewing adoption of specific street standards. This Element includes an amendment to Program 14 Infrastructure Availability, as follows: The City will further review and adopt specific standards for streets, including bicycle facilities and ADA accessibility.

If subdivision level improvements modify right of way street conditions, then the project must follow CityCity 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 CityCity 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 CityCity ensures that new housing developments comply with California building standards (Title 24 of the California Code of Regulations) and federal requirements for accessibility.

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Procedure For Ensuring Reasonable AccomodationsAccommodations In 2018, as part of the comprehensive update to the Development Code, the CityCity 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 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.

A request for reasonable accommodation may be made by any person with a disability, ordisability, or a representative of such person, when the application of a zoning, land use, or building regulation, policy, or practice acts as a barrier to equal housing opportunity. If a reasonable accommodation request is approved, the request shall be granted to an individual and shall not run with the land unless the Director of Community Development determines that:

1. The modification is physically integrated into the residential structure and cannot easily be removed or altered to comply with applicable codes; or

2. The accommodation is to be used by another disabled person.

The Community Development Director or Building Official, as appropriate, shall have the authority to consider and act on requests for reasonable accommodation consistent with the California Fair Employment and Housing Act, the Federal Fair Housing Act, Section 504 of the Rehabilitation Act, and the Americans with Disabilities Act. The following findings must be analyzed, and adopted before any action is taken to approve or deny a request for reasonable accommodation:

A. The housing that is subject to the request will be used by an individual with a disability, as defined under California Fair Employment and Housing Act, the Federal Fair Housing Act, Section 504 ofthe Rehabilitation Act, and the Americans with Disabilities Act.

B. The request for reasonable accommodation is necessary to make specific housing available to an individual with a disability.

C. The requested reasonable accommodation would not impose an undue financial or administrative burden on the City.

D. The requested reasonable accommodation would not require a fundamental alteration in the nature of a City program or law, including but not limited to land use and zoning.

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E. There are no other alternative reasonable accommodations that may provide an equivalent level of benefit at a similar cost while providing greater consistency with the City's laws and regulations.

The Community Development Director shall issue a written determination within 30 days of receipt of a completed application that either grants, grants with modifications or denies a request for reasonable accommodation There have not been negative impacts imposed by this process or the findings. Rather, it has been beneficial to the City and community that the City established a formal procedure for individuals with disabilities seeking equal access to housing to request a reasonable accommodation.

DEVELOPMENT REVIEW PROCESS
Development Fee Review
The cityCity 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 cityCity to recoup costs associated with individual developments.

Environmental Review

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The cityCity 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.

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.

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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 CcityCity 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 cityCity 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 Cudahythis CityCity are generally high due to high demand and the limited supply found in a builtout CityCity. Land costs 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 multifamily 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 CityCity of Cudahy has not experienced any vacant land sales.

This Housing Element includes the following amendments to the existing programs, amended proposed to minimize, where feasible, the nongovernmental constraints impacting housing in Cudahy: Program 1 Adequate Sites, 2 Housing Information, 4, Promote Lot Consolidation, and 5 Affordable Housing Incentives.

AvailabiltiyAvailability Of Financing
An inventory of local lending institutions revealed that loans are available in the area to qualified clients.

Housing Crisis

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Residential vacancy rates and the location of the cityCity 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 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 cityCity 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-19COVID-19 pandemic and the threats of eviction of tenants and foreclosure on mortgaged properties.

Redlining practices have not been observed in Cudahy, as the CityCity'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 cityCity 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 CityCity of Cudahy’s prior Housing Element was adopted and certified by HCD in 2018. The City must assess the effectiveness of its existing housing goals, policies, and programs (adopted in the 2013-2021 Housing Element). Since adoption of the previous Housing Element the City experienced a slight reduction in population from 24,076 persons in 2017 to 23,937 in 2020. 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.

Cudahy’s estimated RHNA allocation for 2014 -2021 was 318 units. The estimated RHNA allocation for 2021-2029 is 393 units. The unaccommodated 2014-2021 allocation rolled over and was added to the 2021-2029 allocation because HCD found that the City did not make adequate sites available to accommodate the 2014-2021 allocation.

The 2021-2029 Housing Element includes an inventory of vacant and underutilized land. There are 6.8 acres of vacant land which have the potential to yield 113 units. There are 17.7 acres of underutilized land which have the potential to yield 343 units. Based on this review the City can adequately accommodate the RHNA allocations.

As part of the City’s update to the General Plan, in 2018 the City increased densities for single family residential from nine to 15 dwelling units per acre, for medium density residential from 12 to 25 dwelling units per acres, and for high density residential from 20 to 40 dwelling units per acre. Additionally, in 2018, 2019 the City rezoned 14 acres to higher densities in the high density residential and commercial zone districts from 14.52 dwelling units/acre to 20 dwelling units/acre to meet the RHNA allocation.

During the 2013-2021 planning period the City did not receive any building permit requests for ADU’s; therefore, no ADU’s were constructed.

In 2020 the City provided funding, through the CDBG Rehabilitation Program, for two single family homes.

The City successfully continued to provide updated infrastructure with the LRSP for traffic safety analysis, HSIP Cycles 6 and 7 funding for pedestrian, bicycle, and vehicular traffic safety improvements, and ATP Cycle 2 funding for 12 crossing locations near schools, mid-block, and across major arterials.

The City continued to adjust the Building Department and Code Enforcement procedures to be in compliance with changing Federal and State COVID-19 regulations, while still maintaining high levels of service for the community.

Between 2015 and 2021 119 building permits were issued for residential construction.

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In 2021 the City approved a 179 unit project with 100% of the units affordable for seniors.

Due to Federal and State mandated COVID-19 restrictions, the City temporarily suspended the provision of hot meals. However, the City did institute an interim food services program until such time as the previous hot meal program could be reinstated. This interim program included the facilitation of frozen meals to seniors provided by the Human Services Association (HAS). The City also provided bi-weekly and monthly units of groceries to residents via the Community Development Block Grant (CDBG)-funded Food Distribution project.

The goals and policies adopted in the City’s 2040 General Plan and included in the 2013-2021 Housing Element are appropriate to carry forward to the 2021-2020 planning period. A list of the goals and policies is included in Chapter 7. The program evaluation is included in this Chapter.

The evaluation included the accomplishments of each program against the objectives established in the 2013-2021 Housing Element, explains any discrepancy in program achievements, and recommends programmatic changes for inclusion in the 2021-2029 Housing Element. The status of each action item and the effectiveness of implementing that item are discussed in Table 6.1.

List of Charts, Tables, and Maps
Table 6.1- Review and revise 2021 Housing Element …………………………………………….. – Page 117 ASSESSMENT OF GOALS, POLICIES, PROGRAMS AND QUANTIFIED OBJECTIVES Table 6.1
Review of 2013-2021 Housing Element Programs
Measure Implementation
Status
Continue/Modify/Delete
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
Time Frame:
2013
Responsibility:

Community
Development
Director
Funding Source:

City General
Fund and other
funding sources
assources as
available.

Promotional
materials were
developed and
distributed in 2014;
updated on an
ongoing basis.

Modify: to include updated
terminology, and preparation
of a residential data base in
2023.
(Program 2 Housing
Information)

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Measure Implementation
Status
Continue/Modify/Delete
available early care and
education services.

Second Unit
Ordinance
The City of Cudahy allows
second units on singlefamily 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.

Time Frame:

Ongoing 2013
Responsibility:

Community
Development
Director
Funding
Source:

City General
Fund
During 2013-2021
the City did not
receive any
buildingany
building permit
requests for second
units; therefore,
there were no
second units
constructed.

Modify:

Renamed Program 3
Accessory Dwelling Units:

Update, statutory compliance.
2023
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.

Time Frame:
2013
Responsibility:

Community
Development
Director
Funding
Source:

City General
Fund and other
funding sources
as available.

The Study was
completed in 2014.

The City initiated
and adopted a
Development
Impact Fee Study in
2021/2022.

Delete
Manufactured
Housing
The City allows
manufactured homes and
modular units on singlefamily lots. This permits
the use of manufactured
homes as affordable
housing alternatives.

Time Frame:
2013
Responsibility:

Community
Development
Director
Funding
Source:

City General
Fund
Program was
implemented in
2013/2014.

Delete
Affordable
Housing
Incentives
In order 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 shall be
Time Frame:
2013
Responsibility:

Community
Development
Director
Funding
Source:

City General
Fund
The program
began inbegan in
2013 and is
ongoing.

The City adopted
an Inclusionary
Housing Ordinance
in 2022 including
incentives related
to parking, height,
design review, and
open space.

Modify: to include updated
terminology; and provide
specifics. 2024 (Program 5
Affordable Housing
IncentiviesIncentives)

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Measure Implementation
Status
Continue/Modify/Delete
made available to
developers. Cooperative
ventures with developers
on housing projects may
also be initiated by the
City.

CDBG
Information
Programs
The City shall continue
housing programs on
housing development,
development,
infrastructure,
rehabilitation and job
development, as allowed
by the CDBG program. It
shallIt 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
prepareshall prepare a
brochure outlining
available housing
assistance and
rehabilitation programs in
the City. 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
HousingCounty Housing
Authority. (The CityThe
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).

Time Frame:
2013
Responsibility:

Community
Development
Director
Funding
Source:

City General
Fund
The program is
ongoing and
monitored annually
(coinciding with the
fiscal year). 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.

Continue
(Program 6 CDBG
Information)
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
Time Frame:
2013
Responsibility:

Community
Development
Director
The City continued
to provide services
as needed. In 2022
the City adopted
the Inclusionary
Housing Program.

Options to on-site
Modify. Combined with
Program 7 At-Risk
PerservationPreservation and
Program 26 Replacement
Housing
2024

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Cudahy City CouncilFebruary 7, 2023

Cudahy City Council
February 7, 2023