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The City of Cudahy’s library is located within Cudahy Park in the southeastern portion of the City.
The site located furthest away from the City’s library, Site 19, is still only a 6 minute drive north of the library and Cudahy Park. The rest of the lower income sites are located in closer proximity to the library, either within a comfortable walking distance or within a 5 minute drive or less.
Two of the eleven sites accommodating lower income housing are located within a ½ mile radius of Cudahy’s library.
The Los Angeles River Bikeway runs along the eastern portion of the City, along the Los Angeles River. Sites with lower income units located in the eastern portions of the City feature the best access to this Bikeway which connects Cudahy to Bell, Maywood, and Vernon to the north and South Gate, Compton, and Long Beach to the south. This Bikeway connection connects residents who bike to the services and employment opportunities available throughout the larger Los Angeles region. Additionally, travelling by bicycle is a low cost mode of transportation which is accessibile to Cudahy’s lower income residents. Site C4, which is located furthest away from the Bikeway, is only a seven minute bike ride away. Four of the eleven sites accommodating lower income housing are located within a ½ mile (4 minute bike ride) of the Los Angeles River Bikeway.
The City’s Post Office is located centrally in the City on Elizabeth Street, just off of Atlantic Avenue. The Post Office is located closest to Sites 25 and and P1 (approximately a 6 minute walk), which will accommodate 178 and 22 units of lower income housing respectably. However, due to the Post Office’s central location within the City it is incredibly convenient for all residents of Cudahy to access. Nine of the eleven sites accommodating lower income housing are located within a ½ mile radius of the Post Office.
The City of Cudahy features six pharmacies all of which are located on Atlantic Avenue or directly off of Atlantic Avenue, the City’s main commercial corridor. The majority of these pharmacies are clustered around the intersection of Atlantic Avenue and Clara Street, in the direct center of the City. However, two pharmacies are located in the central northern portion of the City, just to the east off of Atlantic Avenue. The sites with lower income units located within the central northern portion and northeastern portion of the City are located closest to the City’s pharmacies.
However, along the southern border of the City in South Gate is the Azalea Regional Shopping Center, which is the location of two pharmacies, including Walmart Pharmacy. These two pharmacies in South Gate are located in very close proximity to the sites in the southwestern portion, southeastern portion, and central southern portion of the City. Eleven of the sites accommodating lower income housing are located within a ½ mile radius of a pharmacy.
The City of Cudahy features one large grocery store, Superior Grocers at the intersection of Atlantic Avenue and Live Oak Street in the central northern portion of the City. A Sprouts Farmers Market is expected to open at Atlantic Avenue and Additionally, there is a Walmart Supercenter located within the Azalea Regional Shopping Center at the southern border of the City in South Gate. All but two of the sites accommodating lower income housing in the inventory are located within a ½ mile of a grocery store. These two sites are located in the northeastern and southeastern portions of the City. While these two sites may not be located within a ½ mile of a
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grocery store, they are located within a 4 minute and 7 minute drive of their closest respective grocery store. Additionally, Atlantic Avenue features a multitude of other local services such as restaurants, personal service salons, small scale commercial stores, and more that serve the local community. Atlantic Avenue runs directly north to south through the center of Cudahy, ensuring that all Cudahy residents have easy accessibility to commercial services along the main commercial corridor.
The City of Cudahy features five schools all of which are located in a different area of the City.
These five schools are located in the central northern portion, the northeastern portion, the southeastern portion, the central portion, and the central eastern portion of the City. This even distribution of the five schools means that all eleven sites accommodating lower income housing in the inventory are located within a ½ mile radius of a public school.
The City of Cudahy as well as the surrounding cities of South Gate and Bell feature a multitude of medical offices and clinics along Atlantic Avenue, including a Kaiser Permanente facility at the intersection of Atlantic Avenue and Elizabeth Street. All eleven sites accommodating lower income units are located within a ½ mile of a medical office or clinic.
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’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.
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. According to HCD’s AFFH Data Viewer, all eleven sites accommodating low income units in the inventory are located within high quality transit areas.
The future Metro West Santa Ana Branch Line will improve Cudahy residents’ affordable 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 and northwestern portion of the City, will have access to the north-south fixed rail service that will provide access to Artesia to the 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.
Through Program 14 of this Element the City will construct at least one mile of bicycle lanes connecting to the future Metro station by 2027. None of the eleven sites accommodating lower income housing are located within a half mile of either incoming Metro stop, however, all eleven
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sites are located within a reasonable drive or bike ride (as a lower cost alternative) of either incoming Metro stop.
During the 6th Cycle the City commits to pursuing Surplus Land Act compliant development on available Site 25. This publicly owned mixed-use site is located along Atlantic Avenue, the City’s central commercial corridor, is to be developed through the Surplus Land Act with lower income and above moderate income housing. Through Program 33 the City commits to choosing a developer for the sites included in the inventory by 2024 and entitling the projects by 2026.
Program 33 reiterates that the City will explore mixed-use development on publicly-owned sites within the mixed-use zones, ensuring the inclusion of affordable housing in mixed-use projects and adherence to all Surplus Land Act requirements.
The remaining available sites accommodate mixed income housing, including lower income units, moderate income units, and above moderate income units through the City’s Inclusionary Housing Ordinance. With the implementation of the City’s Inclusionary Zoning Ordinance the majority of new housing projects in the City will develop with a percentage of lower income units (or an in-lieu fee may be paid). All new residential and mixed-use projects with 4 or more units will qualify under the Inclusionary Zoning Ordinance. For for-sale units 15% of the total units in the project shall be sold to households at 80% or less of county median income. For rental units, 5% very-low income, 5% very-low or low, and 5% very-low, low, or moderate income units must be provided in the project. Since the Inclusionary Zoning Ordinance applies to projects throughout the City, lower income units will be developed in each Census tract along with moderate and/or above moderate units in the same projects, even beyond the City’s site inventory. The Inclusionary Housing Ordinance ensures the development of lower income units through the City of Cudahy within the 6th cycle.
In addition, two constructed sites (which count towards the 6th cycle RHNA) accommodate a mix of lower income housing and above moderate income housing. One of these two constructed sites is located in the central northern portion of the City and the other is located in the southwestern portion of the City close to Salt Lake Avenue.
Figure 2.4051 above illustrates the spatial distribution of all 31 inventory sites which are color coded to display their assumed income level. The inventory’s eleven sites which accommodate lower income housing are distributed throughout the City within each Census tract.
The 31 sites are distributed quite regularly throughout the City’s HDR, MDR, LDR zones, and mixed use zones. 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 four Housing Element sites, two of which accommodate moderate income housing, one
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of which accommodates above moderate income housing, and one of which accommodates mixed income housing. The income level distribution of housing within the City’s high segregation and poverty tract is similar to the income level distribution throughout the City. Lower income housing is not specifically targeted for development within the City’s high segregation and poverty tract.
In conclusion, this housing element site inventory does not contribute to maintaining current patterns of segregation and inequity. In fact, the site inventory serves to distribute housing for all income levels throughout the City, avoiding any concentrations. First, the City is quite uniformly lower income, and the City’s recently liberalized zoning is opening up opportunities in residential neighborhoods and on commercial corridors for development of housing for people at a variety of income levels. Second, the Inclusionary Housing Ordinance ensures lower income housing will be developed throughout the City during the 6th cycle in the same developments with moderate income housing and/or above moderate income housing. Third, the City is pursuing an affordable senior housing development and at least two further Surplus Land Act compliant developments with affordable units during the 6th cycle. This housing element site inventory promotes the development of housing for all income groups throughout the entire City.
Contributing Factors
Through the outreach program and discussions with community members; several factors were identified that contribute to fair housing issues in Cudahy. Figure 2.4053 identifies these factors.
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Figure 2.4053
Contributing Factors to Fair Housing Issues
AFFH Identified Fair
Housing Issues
Contributing Factors Meaningful Actions/Metrics
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 32 (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.
Fair Housing Metric: 120 new jobs created in Cudahy through economic development activities undertaken in the City’s mixed-use and transit-oriented development zones, in order to stimulate place-based revitalization in areas of high segregation and poverty such as in the southeastern tract in the City. The City’s high segregation and poverty tract is in close proximity to Atlantic Avenue, which will be the target for increased job opportunities and commercial amenities. Develop two new public open spaces, which may include public open spaces within new developments within the Entertainment Zone by the end of the sixth cycle.
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.
Fair Housing Metric: 3,567 households benefitted from upsized water lines in the Tract 180 Mutual Water Company service area, in order to improve water services to the eastern side of the City, including the City’s high segregation and poverty tract.
Fair Housing Metric: One mile of bicycle lanes, along Atlantic Avenue from Florence Avenue to Patata Street, constructed providing access to future Metro Rail stations. The bicycle lanes along Atlantic Avenue will create an affordable, safe way for residents of the City’s high segregation and poverty tract to access increased job opportunities and commercial amenities along Atlantic Avenue in addition to opportunities outside of Cudahy. In addition, all residents will benefit from the bicycle lanes along Atlantic Avenue.
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Fair Housing Metric: Construct three capital projects in areas of high need to improve transit or active transportation safety within the sixth cycle planning period.
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.
Fair Housing Metric: Two properties will be renovated per year. Number of properties served per year may change with results of the Housing Conditions Survey Program. The results of the Housing Conditions Survey will determine target areas for these two property renovations each year. Program 8 will implement place-based strategies to encourage community revitalization, including preservation of existing affordable housing.
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.
Fair Housing Metric: Increase staffing by two code enforcement officers. Increased level of staffing will be maintained throughout sixth cycle. The City commits to hosting two educational workshops per year to inform property owners and residents of code enforcement initiatives and opportunities. The City commits to ensuring a total of 40 participants for both sessions combined. This Program will prioritize place based strategies as necessary, following the results of the City’s annual Housing Conditions Survey. Specific high need areas of the City will be targeted for code enforcement activities as a result of this annual Housing Conditions survey.
Program 23 (Housing Conditions Survey). The City shall complete an annual Housing Conditions Survey to identify the number of units in need of rehabilitation and replacement. The surveys shall start in 2023, and housing maintenance and code enforcement strategies will be modified accordingly.
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Fair Housing Metric: Complete annual housing conditions survey to determine target areas for property renovations, as a part of the City’s place based strategies in this Housing Element. The results of the survey will target specific areas in the City that are in the most need of rehabilitation and replacement. As a result of this program and Program 8, two properties will be renovated per year in target areas.
Through Program 31 (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.
Fair Housing Metric: One training session in English and Spanish per year serving at least 25 total yearly participants. Pursue external funding sources annually, secure some level of funding. Program 31 will improve the ability of Cudahy residents to purchase homes, instead of rent, which increases the housing options available to residents.
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 28 (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.
Fair Housing Metric: Development of 34 lower income units through Inclusionary Housing Program. These 34 units will be developed outside of the City’s TCAC Area of High Poverty and Segregation tract. These 34 units will be developed throughout the rest of the City, spreading units available to lower income households throughout the City’s neighborhoods. This is a place-based strategy to distribute lower income units throughout the City, increasing housing options.
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 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.
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Fair Housing Metric: Construction of one affordable senior housing project at 4610 Santa Ana Street. Reduce permit processing time by 25% for future affordable projects compared to typical affordable housing processing time in the 5th cycle. The construction of a large senior affordable housing project in Cudahy greatly increases housing options for Cudahy’s seniors who are in need of affordable housing options. These affordable senior units may alleviate some of the overcrowding that currently exists in the majority of Cudahy’s households.
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).
Program 6 Fair Housing Metric: CDBG funds will apply towards multifamily, owner-occupied projects during the sixth cycle. One multifamily, owner-occupied project will be funded per year. Funds to rehabilitate multifamily units will improve the quality of multifamily housing and preserve existing affordable housing in the City.
Program 12 Fair Housing Metric: Completed Design Review Standards. Design Review Standards will improve the quality of new housing in Cudahy, improving the stock of quality housing options in the City. Program 12 will apply to and impact five housing types in Cudahy including single family homes, ADUs, 2 to 5 plexes, multifamily apartments, and townhomes.
Program 8 Fair Housing Metric: Two properties will be renovated per year. Number of properties served per year may change with results of the Housing Conditions Survey Program.
The results of the Housing Conditions Survey will determine target areas for these two property renovations each year. Program 8 will implement place-based strategies to encourage community revitalization, including preservation of existing affordable housing.
Program 13 Fair Housing Metric: Increase staffing by two code enforcement officers. Increased level of staffing will be maintained throughout sixth cycle. The City commits to hosting two educational workshops per year to inform property owners and residents of code enforcement initiatives and opportunities. The City commits to ensuring a total of 40 participants for both sessions combined. This Program will prioritize place based strategies as necessary, following the results of the City’s annual Housing Conditions Survey. Specific high need areas of the City will be targeted for code enforcement activities as a result of this annual Housing Conditions survey.
The City’s updating of ADU standards in Program 3 (Accessory Dwelling Units) should result in increased production of ADUs in Cudahy.
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Program 3 Fair Housing Metric: Two ADUs per year will be constructed. The construction of two ADUs per year will increase affordable housing options Cudahy residents.
As part of Program 26 (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.
Program 26 Metric: Complete review of density bonus standards annually to ensure compliance with State Density Bonus Law.
In Program 30 (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.
Fair Housing Metric: Ad-hoc committee presenting findings to City Council in May 2023. Ad-hoc committee will complete study and make recommendation to City Council by the end of 2023.
Rent increase moratorium has been extended until July 10, 2023. The adoption of rent control in Cudahy will provide increased protections for Cudahy’s renters, decreasing displacement pressure and risk.
Through Program 31 (First Time Homebuyers) the City will promote homeownership in the City, increasing housing stability. The City will partner with nonprofits that administer first time homebuyer funding and consider use of in-lieu fees from the Inclusionary Housing Ordinance to assist with first time homebuyer assistance.
Fair Housing Metric: One training session in English and Spanish per year serving at least 25 total yearly participants. Pursue external funding sources annually, secure some level of funding. Program 31 will improve the ability of Cudahy residents to purchase homes, instead of rent, which increases the housing options available to residents.
Through Program 33, the City will adjudicate the disposition of publicly-owned parcels included in the Sites Inventory. These publicly owned sites will develop with at least a portion of lower income housing, increasing the stock of affordable housing in different areas of the City.
Fair Housing Metric: The City will cooperate with the County to adjudicate the disposition of the City-owned and County-owned parcels on the southeastern corner of Santa Ana Street and
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Atlantic Avenue in the Sites Inventory in a manner consistent with the Surplus Land Act to develop 22 lower income units in addition to above moderate income units. The development of lower income units along Atlantic Avenue will connect lower income residents to the City’s commercial job center along with plentiful commercial amenities.
Through Program 34 the City will adjudicate the disposition of Site 25 in a manner consistent with the Surplus Land Act. Site 25 will develop at least 88 housing units of which 22 units would be lower-income units. The City will undertake Program 34 to ensure the cooperation of the County in making these seven parcels available at the same time for housing development through the Surplus Land Act.
Fair Housing Metric: Site 25 will develop at least 88 housing units of which 22 units would be lower-income units.
Low level of fair
housing complaints
among all
communities in the
Southeast Los
Angeles Cities
region. Low level of
participation in
government
processes.
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).
Additionally, the City will conduct targeted outreach to Cudahy’s unique populations to increase participation in housing decisions and opportunities, including residents from high need communities, residents who are renters, non-Latino residents, and residents from a wide array of age groups.
Fair Housing Metric: Public noticing prior to every scheduled public hearing to increase opportunities for residents to participate in local government and decision making for their City.
Fair Housing Metric: The City will target four unique Cudahy populations to improve their participation in City housing decisions and opportunities, including residents from high need communities, residents who are renters, non-Latino residents, and residents from a wide array of age groups.
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.
Program 6 Fair Housing Metric: CDBG funds will apply towards multifamily, owner-occupied projects during the sixth cycle. One multifamily, owner-occupied project will be funded per
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year. Funds to rehabilitate multifamily units will improve the quality of multifamily housing and preserve existing affordable housing in the City.
Program 16 Fair Housing Metric: 3 community activities per year to distribute fair housing information to residents to increase opportunities for residents to consult experts regarding their fair housing issues and provide assistance to residents at risk of displacement. The City will target four unique Cudahy populations to improve their knowledge of fair housing programs and opportunities, including residents from high need communities, residents who are renters, non-Latino residents, and residents from a wide array of age 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 30, 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.
Fair Housing Metric: Ad-hoc committee presenting findings to City Council in May 2023. Ad-hoc committee will complete study and make recommendation to City Council by the end of 2023.
Rent increase moratorium has been extended until July 10, 2023. The adoption of rent control in Cudahy will provide increased protections for Cudahy’s renters, decreasing displacement pressure and risk.
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
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 29 (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
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Angeles Cities
region. The
southeastern
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
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. The City also commits to connecting residents to the Los Angeles County Childhood Lead Poisoning Prevention Program and Low-Income Home Energy Assistance Program.
Fair Housing Metric: Locate one funding source to provide air filters. The place based strategy is to prioritize placement of the air filters within the City’s TCAC Area of High Segregation and Poverty tract in the southeastern portion of the City.
Fair Housing Metric: Through this Program the City will connect 40 households to the Los Angeles County Childhood Lead Poisoning Prevention Program and Low-Income Home Energy Assistance Program within the sixth cycle planning period.
Program 35 (Open Space Developments) commits the City to the development of one new open space within the sixth cycle. Additionally, this program commits the City to creating cul-de-sacs at Olive and Elizabeth Streets, where they intersect with Salt Lake Avenue. The creation of these cul-de-sacs by the end of 2026 eliminates the use of these residential streets as shortcuts to bypass arterials.
Fair Housing Metric: Develop two new open spaces in Cudahy in the area of highest need within the sixth cycle. These new public open spaces may be developed in new developments in the Entertainment Zone. These two open spaces will be developed by the end of the sixth cycle.
Fair Housing Metric: Create cul-de-sacs at Olive and Elizabeth Streets at their intersections with Salt Lake Avenue to eliminate use of these residential streets as shortcuts to bypass arterials by the end of 2026.
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).
Fair Housing Metric: Public noticing prior to every scheduled public hearing to increase opportunities for residents to participate in local government and decision making for their City.
In Program 14 (Infrastructure Availability), the City will review transportation availability to promote access to educational opportunities located around Los Angeles County.
Fair Housing Metric: 3,567 households benefitted from upsized water lines in the Tract 180 Mutual Water Company service area, in order to improve water services to the eastern side of the City, including the City’s high segregation and poverty tract.
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Fair Housing Metric: One mile of bicycle lanes, along Atlantic Avenue from Florence Avenue to Patata Street, constructed providing access to future Metro Rail stations. The bicycle lanes along Atlantic Avenue will create an affordable, safe way for residents of the City’s high segregation and poverty tract to access increased job opportunities and commercial amenities along Atlantic Avenue in addition to opportunities outside of Cudahy. In addition, all residents will benefit from the bicycle lanes along Atlantic Avenue.
Fair Housing Metric: Construct three capital projects in areas of high need to improve transit or active transportation safety within the sixth cycle planning period.
High degree of racial
uniformity among
all communities in
the Southeast Los
Angeles Cities
region.
Priority Level: Low
Historic discrimination.
Restrictive zoning and lack of affordable housing
in more affluent communities.
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
3 Regional Housing Needs Assessment and Special Needs
3.1 REGIONAL HOUSING NEEDS ALLOCATION, 2014-2021
Every City 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 2021 to 2029 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.
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:
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 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, with higher-income jurisdictions receiving a greater share of lower-income housing and vice versa.
For a complete discussion of the methodology, see SCAG’s 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 City 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:
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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.
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
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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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 City will only receive credit towards the RHNA for the new housing that is entitled, under construction, or built beginning October 15, 2021.
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.
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Chart 3.1 – Disability by Type
American Community Survey 2014-2018 5-year estimates.
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 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 City is the Los Angeles County Sheriff’s Department, which serves Cudahy. Very few homeless persons have been observed in the City. Homeless persons (single males and females) have been found in the Cudahy area along the banks of the Los Angeles River in the City 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 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
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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Center, Human Services Association) in neighboring cities. The Salvation Army operates a shelter located at 1370 Alamitos Avenue in the City 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 Salvation Army Shelter, located in the City of Bell adjacent to Cudahy, hosts an emergency shelter, permanent supportive housing, and provides extensive transitional and supportive services to unhoused residents such as medical services, case management, and substance rehabilitation. The Bell Salvation Army typically provides transitional housing for 500 individuals; however, this capacity has been reduced to 250 individuals during the COVID-19 pandemic. The Salvation Army’s capacity is expected to increase as the COVID-19 pandemic lessens. 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 © zoning districts. Combined, these zone districts encompass 84.8 acres. The zoning districts identified are located along Atlantic Avenue, the City’s main north/south corridor. The central location of these districts puts potential shelters near the core services and transportation corridor within the City. 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 (City 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
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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. • 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.
• 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 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 131ells131p131“, “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 City may inspect the facility at any time for compliance with the facility operational plan and other applicable laws and standards.
• 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.
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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:
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 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.
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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.
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
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-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 City 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 City of Cudahy is located in SPA 7. On January 23, 2020, the number of homeless people processed in the City 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 Ci–y - 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 City 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 City’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 City 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 27 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 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 Accommodation
The most recent 2020 Census identified those residents that have one or more disabilities as well as the type of disability. Table 3.5 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
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) Mental Disabilities: Based on the most current Census information the City 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
Gender Male Female TOTAL
317 647 964
Percentage 33% 67% 100%
Source: U.S. Census. Bureau; 20–7 - 2021 American Community Survey Physical Disabilities: Based on the most current Census information the City 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.
Gender Male Female TOTAL
478 640 1,118
Percentage 43% 57% 100%
Source: U.S. Census. Bureau ;20–7 - 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 City 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 City 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 City’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 City’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 City’s total number of households in 2020. An estimated 15.8% of the households in the City (885 households) was female 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 identifies the female-headed households.
Chart 3–2 - 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 City contain one or two bedrooms. In addition, landlords may be reluctant to rent smaller units to larger families. Finally, many owner-occupied units are overcrowded (refer to 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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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 City 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 City 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 City) 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 rental units at 83%. Table 3.8 identifies tenure by large families.
Table 3.8
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. Bureau; 20–7 - 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 City identified in the 2020 Census, 1,428 units were identified as being overcrowded (25.3% of the City’s total number of occupied units) and 534 units (9.5% of the total occupied units in the City) were identified as being severely overcrowded.
Elderly Households
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
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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 City’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 elderly householders are predominately residing in rental units at 65%.
Table 3.9
Tenure by Elderly Households
Tenure Owner Renter TOTAL
208 388 596
Percentage 35% 65% 100%
Source: U.S. Census. Bureau ;2017-2021 American Community Survey Farmworkers
The special housing needs of many farmworkers 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 City 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.
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 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 (RHNA)
This Housing Element addresses the RHNA for the 6th cycle planning period (2021-2029).
The RHNA housing needs allocation is identified in the table below.
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Figure 4.1
Regional Housing Needs Allocation
Affordability Level
(AMI: Area Median Income)
RHNA
(2021-2029)
Extremely and Very Low-Income (0-
50% AMI)
801
Low-Income (51-80% AMI) 36
Moderate-Income (81- 120% AMI) 53
Above Moderate- Income (121%+
AMI)
224
Total 393
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). Through conversations with HCD, the State confirmed that the City satisfied its 5th cycle rezone requirement in 2018.
1 The extremely low income need can be calculated as 50% of the very-low income RHNA, or 40 units.
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Progress Toward the RHNA – Constructed Projects
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 received a Certificate of Occupancy since that time:
• 3827 Live Oak Street, 1 unrestricted unit (Site C1 in Figure 2.4051) • 3636-42 Walnut Avenue, 4 unrestricted units (Site C2 in Figure 2.4051) • 4848 Live Oak Street, 5 lower-income, 6 moderate-income and 9 above moderate income units (Site C3 in Figure 2.4051)
• 4302-4312 Elizabeth Street, 6 lower-income and 42 unrestricted units (Site C4 in Figure
2.4051)
• 4728 Live Oak Street, 4 unrestricted units (Site C5 in Figure 2.4051) 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 60 above moderate-income units.
Approved Projects
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 conditions of approval of the project require that all housing units other than manager’s units be covenanted as affordable to lower-income households. 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 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 communityserving commercial space.
The project is located on formerly City-owned land, which was sold to Prima Development for one dollar in order to assist Prima in financing this tax-credit affordable project. Prima has since brought on National Community Renaissance of California (National CORE), one of the state’s leading non-profit affordable housing developers, as co-developer and co-General Partner to build the project, with Prima leading the commercial build-out and National CORE leading the affordable housing. The developers are currently financing the project and are in constant communication with the City. The property does have some soil contamination issues, but the City worked with the developer to complete a successful application for $6.7 million in Infill Infrastructure Grant (IIG) funding to cover remediation cost, and other needed infrastructure costs for the project. The project has also secured $5 million from the Los Angeles County Development Authority Affordable Housing Trust Fund and $10 million from the 4th District of Los Angeles County. The final major piece of funding required is $10 million from HCD’s
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Multifamily Housing Program. Based on prior years’ NOFAs, the project would appear to score well; the only major barrier to receiving the funds is Housing Element certification, which is required to win funding. With these competitive funding sources in place, the project will easily qualify to obtain Low Income Housing Tax Credits and a small private bank construction loan to round out the needed financing for the project.
Program #5 (Affordable Housing Incentives) commits the City to supporting Prima and National CORE with the Multifamily Housing Program application or additional funding applications if necessary by the end of 2023, with the expectation that the project can be fully funded, with building permits extended by May 2024. Construction is anticipated to begin in July 2024 and be complete by September 2026. Dropout rates for affordable housing projects at this stage taken on by top-tier affordable housing developers are low. The riskiest parts of the process are entitlement, property acquisition and obtaining competitive financing; if Cudahy’s Housing Element can be certified and the project receives Multifamily Housing Program funds, the project will have passed all of these hurdles.
5132-5140 Live Oak Street
Three units are currently under construction at 5132-5140 Live Oak Street on a parcel which currently includes six residential units. The new units are being constructed on vacant portions of the site, meaning that no residential demolition is taking place. Figure 4.1 shows the site boundary (red outline) and the portions of the site being filled in with new residences (orange shade). Construction is estimated to be complete this year.
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Figure 4.1A
5210 Santa Ana Street
A similar residential project is under construction at 5210 Santa Ana Street, adjacent to Cudahy City Hall. This site was originally occupied by five units built during the 1950s. In 2021, one of the existing housing units was demolished and in its place four new multifamily housing units are being built (area on the left in the photo below). The 0.48-acre site will accommodate eight units, compared to only five units in the past. One unit is covenanted to lower-income households.
Other projects currently under construction include:
• 5017 Clara Street – eight unrestricted units
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• 8124 Wilcox Avenue – one ADU
• 4107 Clara Street – three unrestricted units including ADUs 4936-38 Live Oak Street
This 42-unit project including 4 very low income units received a building permit in 2022 and construction is expected to start immediately, with project completion anticipated for 2024.
Together, the three approved, not yet constructed projects total 184 lower-income units and 54 above moderate-income units, with the conservative assumption that all unrestricted units are credited to the above moderate-income category.
Sites Identified in Prior Planning Periods
Pursuant to Government Code Section 65583.2©, 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 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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Figure 4.2
Available Sites – Types of Sites, Demonstration of Likelihood of Development and Affordability Assumptions
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. Sites for the 6th cycle RHNA are mapped on Figure 4.2.
The available sites within the site inventory are each labeled in Figure 4.2 with their site number, corresponding to Appendix A. All sites are located in locations that are appropriately zoned and where existing uses do not constitute an impediment to development. All sites meet the following criteria:
• Site is vacant or if occupied by a residential use, it meets all of the following criteria:
o The residence has no more than two units
o The most recent building was constructed before 1975
o Buildings on the site are in poor condition, or the uses on the site do not meet current zoning code regulations
o If currently occupied by a residence, the ratio of realistic capacity to current units on the site is at least 12:1
• Site is zoned for by-right development of housing at a density greater than that assumed in realistic capacity
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• Site is located in a residential zone which does not allow commercial uses, with the exception of one mixed-use site which is subject to a commitment to pursue Surplus Land Act-compliant housing development on the site, ensuring that it will be developed with residential uses. • Site is under single ownership, with the exception of the mixed-use City/County owned site described below
This historical record of development (Appendix B) justifies the likely development of three types of sites, described below.
Entirely Vacant Sites
Entirely vacant sites are those with no existing structures or long-vacant structures ready for development; therefore, existing uses pose no impediment to development. Three projects approved since the City-wide rezoning took place have been built on completely vacant sites, as shown in Figure 4.3.
Figure 4.3
Realistic Capacity – LDR Zone
As shown in Figure 4.7, the record of approved projects since the City’s 2018 rezoning 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. Nevertheless, we conservatively assume that entirely vacant sites in the LDR zone will develop at a density of 13 du/ac (87% of maximum allowable).
Figure 4.7
Realistic Capacity – MDR Zone
Since the City completed its 2018 rezoning which increased allowable density in the MDR zone from 15 to 25 du/ac, five housing projects have been approved in this zone which consist of entirely new development on a site:
Address Zone Type DemoClass Acres # of Units
Bonus
Units
Existing
Units
Total
Units
Total
Density Affordabilty Allowable Density Prior Use
Planning
Application Approval
3636-42 Walnut LDR Multi-Family Completely Vacant 0.22 4 0.0 4.0 18.2 N/A 15.0 Vacant/Resid
ential, 0 2018 2018
3827 Live Oak Street LDR ADU Vac Portion 0.22 1 1.0 2.0 9.1 N/A 15.0 Residential, 1 2019 2019 8201 Crafton LDR ADU Vac Portion 0.14 1 1.0 2.0 14.3 N/A 15.0 Residential, 1 2019 2019 5249 Cecilia Street LDR ADU Vac Portion 0.12 1 1.0 2.0 16.7 N/A 15.0 Residential, 1 2021 2021 4107 Clara Street LDR ADU Vac Portion 0.27 3 3.0 6.0 22.2 N/A 15.0 Residential, 3 2022 2022 TOTALS/AVERAGES 0.97 16 16 du/ac 10 du/ac
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Figure 4.8
The average density of those projects, not including density bonus units, is 18 du/ac. Therefore, the Element assumes a density of 18 du/ac (72% of maximum allowable capacity) for these sites.
Realistic Capacity – HDR Zone
There are no entirely vacant parcels in the HDR zone in the sites inventory.
Vacant Portion of Larger Parcel
As shown in Figure 4.4, 12 of the 24 projects approved between 2018 and 2022 consisted of projects where new housing units are added to a site with housing units already on it, without demolishing those units. These sites contain areas that are unused, with the remainder of the parcel currently developed with far fewer units than are permitted for the entire site. This category includes but does not primarily consist of accessory dwelling units.
Figure 4.4
Address Zone Type DemoClass Acres # of Units
Bonus
Units
Base
Units
Base
Density Affordabilty Allowable Density Prior Use
Planning
Application Approval
4254 Elizabeth Street MDR Condominium Replacement 0.47 6 6.0 12.8 N/A 25.0 Residential, 3 2019 2019 4302-4312 Elizabeth
St. MDR Multi-Family Replacement 1.4 48 13.0 35.0 25.0
6 units
very low 25.0
Residential,
15 2018 2019
5252 Live Oak Street MDR Multi-Family Replacement 0.92 17 2.0 15.0 16.3 2 units
very low,
3 low, 6
moderate 25.0 Residential, 5 2018 2018
5112 Santa Ana MDR Multi-Family Completely Vacant 0.48 16 4.0 12.0 25.0 N/A 25.0 Residential, 0 2020 2020 5210 Santa Ana Street MDR Multi-Family Replacement 0.24 4 2.0 2.0 8.3 1 unit low
income 25.0 Residential, 5 2021 2021
5307 Live Oak Street MDR Multi-Family Replacement 0.90 20 20.0 22.1 N/A 25.0 Residential, 3 2019 2019 TOTALS/AVERAGES 4.41 90 20 du/ac
Address Zone Type DemoClass Acres # of Units Affordabilty Prior Use Planning
Application Approval
4935-37 Santa Ana
Street HDR Multi-Family Vac Portion 0.17 6 N/A Residential, 2 2019 2019 3827 Live Oak Street LDR ADU Vac Portion 0.22 1 N/A Residential, 1 2019 2019 8201 Crafton LDR ADU Vac Portion 0.14 1 N/A Residential, 1 2019 2019 5017 Clara Street MDR Multi-Family Vac Portion 0.24 8 N/A Residential, 1 2019 2019 5132-5140 Live Oak
Street MDR Single-Family Vac Portion 0.27 3 N/A Residential, 9 2019 2019 5306 Clara Street MDR Multi-Family Vac Portion 0.17 5 N/A Residential, 2 2020 2020 8124 Wilcox Avenue MDR ADU Vac Portion 0.17 1 N/A Residential, 1 2021 2021 5249 Cecilia Street LDR ADU Vac Portion 0.12 1 N/A Residential, 1 2021 2021 7929 Park Avenue MDR Multi-Family Vac Portion 0.09 2 N/A Residential, 1 2021 2021 4827 Santa Ana Street HDR Multi-Family Vac Portion 0.32 5 N/A Residential, 1 2021 2021 5103 Clara Street MDR Single-Family/ADUVac Portion 0.08 2 N/A Residential, 5 2021 2021 4107 Clara Street LDR ADU Vac Portion 0.27 3 N/A Residential, 3 2022 2022
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Among these 12 projects, 7 added units to lots occupied by single-family houses and 5 added units to multi-family properties. This demonstrates that neither use poses an impediment to development upon vacant portions of the parcel. Further, there are no other known contracts or conditions related to these uses which would preclude development on these sites during the 6th Cycle period.
A typical “vacant portion of larger parcel” project is 5132-5140 Santa Ana Street, described in more detail above.
Realistic Capacity – LDR Zone
There are no incremental sites in the LDR zone in the sites inventory.
Realistic Capacity – MDR Zone
Figure 4.5 shows the projects from Figure 4.4 which are located in the MDR zone.
Figure 4.5
As the average density of these projects was 21 du/ac, the realistic capacity of vacant portion of larger parcel sites in the MDR zone is assumed to be 21 du/ac (84% of the maximum allowable density).
Realistic Capacity – HDR Zone
Figure 4.6 shows the projects from Figure 4.4 which are located in the HDR zone.
Figure 4.6
As the average density of these projects was 25 du/ac, the realistic capacity of vacant portion of larger parcel sites in the HDR zone is assumed to be 25 du/ac (62.5% of the maximum allowable density).
Address Zone Type DemoClass Acres # of Units Density
Bonus
Units
Base
Units
Base
Density Affordabilty
Planning
Application Approval
5017 Clara Street MDR Multi-Family Vac Portion 0.24 8 33.3 8.0 33.3 N/A 2019 2019 5132-5140 Live Oak
Street MDR Single-Family Vac Portion 0.27 3 11.1 3.0 11.1 N/A 2019 2019 5306 Clara Street MDR Multi-Family Vac Portion 0.17 5 29.4 5.0 29.4 N/A 2020 2020 8124 Wilcox Avenue MDR ADU Vac Portion 0.17 1 5.9 1.0 5.9 N/A 2021 2021 7929 Park Avenue MDR Multi-Family Vac Portion 0.09 2 22.2 2.0 22.2 N/A 2021 2021 5103 Clara Street MDR Single-Family/ADUVac Portion 0.08 2 25.0 2.0 25.0 N/A 2021 2021 TOTALS/AVERAGES 1.02 21 21 du/ac
Address Zone Type DemoClass Acres # of Units Density
Bonus
Units
Base
Units
Base
Density Affordabilty
Planning
Application Approval
4935-37 Santa Ana
Street HDR Multi-Family Vac Portion 0.17 6 35.3 6.0 35.3 N/A 2019 2019 4827 Santa Ana Street HDR Multi-Family Vac Portion 0.32 5 15.6 5.0 15.6 N/A 2021 2021 TOTALS/AVERAGES 0.49 11 22 du/ac
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Replacement
As shown in Figure 4.7, the historical record of approved projects since the City’s rezoning supports the finding that lower density residential uses can also be replaced by higher density residential uses. All ‘replacement’ sites meet the following criteria:
o The property is a residential use
o The residence has no more than two units
o The most recent building was constructed before 1975
o Buildings on the site are in poor condition, or the uses on the site do not meet current zoning code regulations
o The current density of development is less than 6 units per acre o If currently occupied by a residence, the ratio of realistic capacity to current units on the site is at least 12
o There are no other known contracts or conditions related to these uses which would preclude development on these sites during the 6th Cycle period.
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Figure 4.7
Note: Number of units demolished may differ from the number of units in the prior use, because some projects only involved partial replacement of units/demolition of the site.
Each of these criteria is justified below.
o The property is a residential use. As shown in Figure 4.7, the historical record of approved projects since the City’s rezoning showed that 9 of 24 projects demolished a pre-existing use. All of these prior uses were residential in nature. o The most recent building was constructed before 1975. While there is precedent for 30-45 year old housing units to be demolished in Cudahy, seven of the nine projects demolished only homes that were constructed prior to 1975. o Buildings on the site are in poor condition, or the uses on the site do not meet current zoning code regulations. Four of the nine projects were constructed on sites with previously deteriorating housing, as recorded in City records. Other Address Zone Type DemoClass Acres # of Units Affordabilty Prior Use # of Units
Demolished
Pre-Demo
Density
Constructed:
Demolished
Ratio
Date Built of
Demolished
Structure (s)
Condition of
Demolished
Structure(s)
4302-4312 Elizabeth
St. MDR Multi-Family Replacement 1.4 48
6 units
very low
Single-Family
and MultiFamily
Residential,
15 15 10.7 3.2
Four units built
in 1962, one
unit built in
1938, two units
built in 1950,
one unit built in
1923, one unit
built in 1925. Fair
5252 Live Oak Street MDR Multi-Family Replacement 0.92 17 2 units
very low,
3 low, 6
moderate
Residential,
5. 3 SingleFamily and 2
Duplex. 5 5.4 3.4
Two units built
in 1956, two
units built in
1959, one unit
built in 1932. Fair
4936-38 Live Oak Street HDR Multi-Family Replacement 0.81 42 4 units
low
income
Residential
Multi-Family,
5 5 6.2 8.4
5 units.
Four units built
in 1963, one
unit built in
1925. Deteriorating
4942-4938 Clara St. HDR Multi-Family Replacement 0.93 44 4 units
very low
Residential
Single-Family,
4 4 4.3 11.0
One unit built in
1937, one unit
built in 1959,
one unit built in
1945, one unit
built in 1952. Deteriorating
4254 Elizabeth Street MDR Condominium Replacement 0.47 6 N/A Residential
Single-Family,
3 3 6.4 2.0
One before
1975, and
maybe 1 or 2
after 1975. Deteriorating
7919 Wilcox Avenue HDR Multi-Family Replacement 0.36 9
1 unit very
low
income
Residential
Single-Family,
2 2 5.6 4.5
2 single family
units.
One unit built in
1938, one unit
built in 1953. Deteriorating
4728 Live Oak Street HDR Single-Family Replacement 0.17 4 N/A Multi-Family
Residential, 3 1 5.9 4.0
One built in
1935, one built
in 1932, one
built in 1912. Fair
5210 Santa Ana Street MDR Multi-Family Replacement 0.24 4 1 unit low
income
Residential
Multi-Family,
5 1 4.2 4.0
5 single family
units.
Three units built
in 1950, one
unit built in
1940, one unit
built in 1919. Fair
5307 Live Oak Street MDR Multi-Family Replacement 0.90 20 N/A Residential
Single-Family,
3 1 1.1 20.0
3 single family
units.
One built in
1915, one built
in 1989, one
built in 1918. Fair
TOTALS/AVERAGES 6.2 37 6.0 du/ac
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projects entitled before 2018 were constructed on sites with uses that did not meet current zoning code regulations, such as legal nonconforming single-family homes.
o The current density of development is less than three units per acre. The average density of entitled project sites prior to their demolition was 6.0 dwelling units per acre, although densities ranged as high as 10.7 units per acre. The Element conservatively elects only those properties whose density is less than 3.0 units per acre, reflecting a high degree of underutilization.
o The residence has no more than two units. As illustrated in Figure 4.7, the City has a track record of replacing both single-family and multi-family units with denser multifamily development. Four of the nine projects demolished only one or two units to build housing.
o The ratio of realistic capacity to current units on the site is at least 12:1. Projects in the City which created higher-density residential units demolished up to fifteen units. Projects resulted in demolition of residential units even when the ratio of constructed to demolished units was as low as 2:1. To be extremely conservative, however, this Element restricts available sites in this category to those that would result in at least a 12:1 ratio between realistic capacity and current developed capacity. This criterion is relevant because it is indicative of a site which possesses a lot of developable area and higher density zoning, with few existing units. Also, since these sites may be subject to Replacement Housing requirements (Program #4), this criterion accounts for ensuring that housing element sites contain sufficient capacity to produce sufficient income-generating units to potentially cross-subsidize Replacement Housing units.
o There are no other known contracts or conditions related to these uses which would preclude development on these sites during the 6th Cycle period.
In general, the City of Cudahy has had a long track record of converting vacant land, single-family housing and duplexes into higher-density multifamily housing. This can be seen from the City’s existing land uses (Figure 4.8), which consists almost entirely of multifamily housing except in the small LDR-zoned areas in the northwestern and southeastern corners of the City. Originally, the City consisted of entirely single-family housing, but those homes have been replaced with higherdensity multifamily housing over decades. Over this time, the presence of owner- or renteroccupied housing, if it is significantly below the maximum density permitted on the parcel, has not posed an impediment to development; with the 2018 rezoning, many more opportunities have become available to convert existing uses into more efficient residential.
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Figure 4.8
Realistic Capacity – LDR Zone
There are no replacement sites in the LDR zone in the sites inventory.
Realistic Capacity – MDR Zone
There are no replacement sites in the MDR zone in the sites inventory.
Realistic Capacity – HDR Zone
Figure 4.9 shows the projects from Figure 4.7 which are located in the HDR zone.
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Figure 4.9
As the average density of these projects was 30 du/ac, excluding density bonus units, the realistic capacity of vacant portion of larger parcel sites in the HDR zone is assumed to be 30 du/ac (75% of the maximum allowable density).
The narrative below provides more detail regarding 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.
Affordability Assumptions
For available sites, units are credited to the lower, moderate and above moderate income levels based on the following assumptions:
• For publicly-owned, mixed-use zoned projects, 25% of units are credited to the lowerincome category and 75% of units are credited to the above-moderate income category.
The Surplus Land Act provides an exemption for projects that are 300 units or greater, mixed-use and include 25% lower-income units.
• New construction projects (projects on completely vacant sites, or replacement sites) on privately-owned land are credited to the above moderate-income category. These projects would likely generate the highest rents in the City. • However, new construction projects on privately-owned sites in which each parcel is at least ½ acre in size also include lower- and moderate-income units subject to the City’s inclusionary zoning ordinance (Program #28), adopted in 2022. This ordinance requires that all projects with more than four units dedicate 10% of units to lower-income households and 5% of units to moderate-income households. These percentages are assumed in the affordability assumptions for these sites. • Units located on vacant portions of larger parcels are credited to the moderate-income category. However, these units are likely to be cheaper than units constructed within a brand-new development; they will function more like ADUs, smaller ground-level units with a relationship to older existing units. According to SCAG’s Regional ADU Affordability Analysis, ADUs are rented at a variety of rates, with the majority (60%) affordable to lower-income households. Therefore, we view the assumption of moderate-income households to be a conservative assumption.
Address Zone Type DemoClass Acres # of Units
Bonus
Units
Base
Units
Base
Density Affordabilty Allowable Density Prior Use
Planning
Application Approval
4728 Live Oak Street HDR Single-Family Replacement 0.17 4 4.0 23.5 N/A 40.0 Residential, 3 2021 2021 7919 Wilcox Avenue HDR Multi-Family Replacement 0.36 9 3.0 6.0 16.7 1 unit very
low
income 40.0 Residential, 2 2020 2020
4936-38 Live Oak Street HDR Multi-Family Replacement 0.81 42 9.0 33.0 40.7 4 units
low
income 40.0 Residential, 5 2020 2020
4942-4938 Clara St. HDR Multi-Family Replacement 0.93 44 7.0 37.0 39.8 4 units
very low 40.0 Residential, 4 2021 2021
TOTALS/AVERAGES 2.27 80 35 du/ac
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• Publicly-owned, residentially zoned parcels are also credited to the moderate-income level. This corresponds to the City’s strong policy of encouraging housing at a variety of income levels.
• All projects with units credited to the lower-income level are at least ½ acre in size and possess a realistic capacity of more than 16 units.
Available Sites – Descriptions
See Appendix A.
Mixed-Use Site
Site #25 is a publicly-owned site in the Entertainment zone wrapping the southeast corner of Atlantic Avenue and Santa Ana Street. The site is completely vacant, consisting of raw land and a long-ago abandoned foundation owned by the City of Cudahy, and a now-closed Department of Public Social Services building with a large parking lot owned by the County of Los Angeles. The City and County are planning to pursue a unified development in order to maximize public benefit and affordable housing. The process of developing Site 25 will be facilitated by this Element’s Targeted Lot Consolidation Program (Program 34).
Primestor, a private developer with a track record of commercial and mixed-use development in the Southeast Los Angeles and Gateway Cities area, has acquired a privately-owned parcel contiguous to Site #25 and is in discussions with the City and County to develop a mixed-use, mixed-income project on the combined site.
The total size of the site is 2.96 acres and the realistic capacity of the site is 88 units assuming a density of 30 du/ac. The Entertainment zone has no maximum density. While the only recent ground-up development project approved in the City’s mixed-use zones was a residential project of 135 du/ac, the City is conservatively assuming a 30 du/ac realistic capacity to reflect the realistic capacity resulting from City’s current mixed-use development standards, which are analyzed in Figure 5.9, showing a capacity of 31 du/ac. However, Program #27 (Zoning Code Review) commits the City to making multiple modifications to development standards in order to ensure that mixed-use sites can achieve higher densities, such as increasing FAR in the CMU zone, reducing private open space requirements, reducing guest parking requirements, and eliminating parking enclosure requirements.
The site allows 100% nonresidential development; however, there have been no ground-up nonresidential development projects in Cudahy during the 5th Cycle period. Nevertheless, in Program #33 (Surplus Land Act Compliance) the City is committing to issuing an RFP, entitling and constructing a development on the site that includes a minimum 88 housing units and 22 units for lower-income households.
Completely Vacant Sites – LDR Zone
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Sites #1, 2, and 3, located in the LDR zone, are completely devoid of structures and thus considered to be vacant.
Based on the 13 du/ac realistic capacity density, the three sites total 2.56 acres and the realistic capacity is 31 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.
Completely Vacant Sites – MDR Zone
Site #13 is a 0.93-acre parcel in the MDR zone which is completely vacant and available for development. Based on the 18 du/ac realistic capacity, the site has a realistic capacity of 16 units.
As this project will result in brand-new, site wide development, 85% of units are credited to the above moderate income category, 5% to moderate, and 10% to lower income.
Additionally, Site #24 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). Although there are two single-family homes on the property, both have been abandoned for many years, and the homes are likely not habitable. Given that this site will be targeted for affordable housing development subject to the Surplus Land Act, the units are allocated to the moderate-income category.
Vacant Portions of Larger Parcels – MDR Zone
Sites #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; therefore, existing uses do not constitute an impediment to development of the site. Based on the 21 du/ac realistic capacity density assumption, the developable portions total 0.29 acres and have a realistic capacity of 5 units. As with the LDR zone, units on these types of sites are credited to the moderate-income category.
Vacant Portions of Larger Parcels – HDR Zone
Sites #7 to 12 are located in the HDR zone and have single-family or multifamily 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. Based on the 25 du/ac realistic capacity density assumption, the developable portions total 2.02 acres and have a realistic capacity of 39 units. As with the LDR and MDR zone, units on these sites are credited to the moderate-income category.
Replacement Sites – HDR Zone
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Sites #17, 18, 19, 21, 22, and 23 are sites of greater than ½ acre located in the HDR zone with single-family homes or duplexes (development of less than 5 du/ac). As discussed above, the City has a long track record of replacing single-family homes and duplexes with higher-density multifamily development. As detailed in more depth in Appendix A, each site (except Site 18) meets the following criteria:
o The property is a residential use
o The residence has no more than two units
o The most recent building was constructed before 1975
o Buildings on the site are in poor condition, or the uses on the site do not meet current zoning code regulations
o The current density of development is less than 6 units per acre o If currently occupied by a residence, the ratio of realistic capacity to current units on the site is at least 10.5:1
o There are no other known contracts or conditions related to these uses which would preclude development on these sites during the 6th Cycle period.
Site 18 is a unique case, as described in Appendix B. Due to the conditions described in Appendix B, the City expects Site 18 to develop with housing within the 6th cycle.
It is assumed that these replacement HDR sites will be replaced in their entirety by new development. Units are allocated 85% to above-moderate, 5% to moderate and 10% to lower income.
Based on the 30 du/ac realistic capacity density assumption described above, the sites total 4.63 acres and have a realistic capacity of 137 units. As discussed above, all replacement sites would result in at least a 10.5:1 ratio between constructed and demolished units.
For property owners of such low-density residential uses, a sale to a development partner typically makes financial sense. With land prices running around $2 million per acre, and the majority of sites being greater than ½ acre, owners will net over $1 million for sale of the property, while the value of a single-family home or duplex in Cudahy will be no more than $750,000.
To support projects achieving maximum densities, the City is undertaking Program #27 (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. Units on these replacement sites are assigned to the above moderate-income category.
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.
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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 shows sufficient capacity to address the City’s 6th cycle RHNA without need of rezoning.
Figure 4.10 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 4.10
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 60 77
Approved Projects 184 -- 57 241
Mixed-Use Site 22 -- 66 88
Completely Vacant - LDR -- 4 27 31
Completely Vacant - MDR 1 17 14 32
Vacant Portions of Larger
Parcels – MDR
-- 5 -- 5
Vacant Portions of Larger
Parcels – HDR
-- 39 -- 39
Replacement - HDR 8 10 119 137
Total 226 81 343 650
6th Cycle RHNA 116 53 224 393
Buffer +110 +28 +119 +257
4.2 ENVIRONMENTAL AND INFRASTRUCTURE CONSTRAINTS
Environmental factors, such as topography, soils, landslides and seismic hazards, and noise, as well as the lack of infrastructure, such as roads, water, and sewer lines, are constraints to housing development in the City. However, most of the potential housing sites identified by the City are not constrained by environmental factors or by lack of adequate infrastructure, with the exceptions of earthquake, ground shaking which affects the entire region and poor water infrastructure provided by Tract 180 Water Company. The General Plan has taken these environmental factors into account. Where development is planned, any site that remains can be mitigated through appropriate design and environmental planning.
Environmental Setting
The City of Cudahy is a relatively new City having only incorporated in the 1960s. At the time of incorporation, more than 80% of the City’s total land area was developed. In terms of land area, Cudahy is one of the smallest cities in Los Angeles County with only 1.07 square miles. Despite its relatively small land area, Cudahy is home to 23,805 residents according to the most recent DOF estimates. The City’s relatively large population given its small geographic area makes it one of the most densely populated communities in California.
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A great majority of the City consists of residential land uses with residential neighborhoods accounting for approximately 394-acres of land or 51.5% of the total land area of Cudahy. An industrial area is in the southernmost portion of the City on both the west and east sides of Atlantic Avenue. Industrial land uses account for approximately 79-acres of land or 12.3% of the City’s total land area. Commercial land uses are located along the major roadways such as Atlantic Avenue and at key intersections and account for approximately 43-acres of land or 6.7% of the total City’s total land area.
Noise
Cudahy is in an area where the ambient noise levels are relatively high. A Citywide noise inventory performed in May 2013, found that virtually all the neighborhoods in Cudahy are in areas where noise levels exceed 65 dBA. The City’s noise environment is not expected to significantly change over time since the primary factors contributing to noise, namely the arterial roadway and freeway traffic and nearby industrial uses, will have a continued presence in the City. State noise guidelines recommend locating residential development in areas exposed to ambient outdoor noise levels no greater than 65 A-weighted decibels (dBA).
Nevertheless, even in areas with higher noise levels, California Building Code requirements establish that interior noise levels be mitigated to 45 dBA. Therefore, noise levels are not a constraint to the production of housing.
Geologic And Seismic Hazards
No known earthquake faults traverse Cudahy and the City is not exposed to natural environmental hazards such as flooding, slope erosion and landslides. However, the City is located within an area that is subject to liquefaction hazards. The City is located within the dam inundation area of the Garvey Reservoir in Monterey Park.
The nearest major river is the Los Angeles River. This River does have a potential impact on the City of Cudahy. Normally this river channel is dry and only carries a significant water flow during a major rainstorm. The river channel is part of the County Flood Control District, and the City is protected by a levee wall.
City of Cudahy, like most of the Los Angeles Basin, lie over the area of one or more known earthquake faults, and potentially many more unknown faults, particularly so-called lateral or blind thrust faults.
The major faults that have the potential to affect the greater Los Angeles Basin, and therefore the City of Cudahy are the:
• Norwalk
• Raymond Hill
• Malibu Coast-Santa Monica-Hollywood
• San Andreas
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• Newport-Inglewood
• San Fernando
• Sierra Madre
• Whittier
The Los Angeles Basin has a history of powerful and relatively frequent earthquakes, dating back to the powerful 8.0+ 1857 San Andreas Earthquake which did substantial damage to the relatively few buildings that existed at the time. Paleoseismological research indicates that large (8.0+) earthquakes occur on the San Andreas fault at intervals between 45 and 332 years with an average interval of 140 years. Other lesser faults have also caused very damaging earthquakes since 1857. Notable earthquakes include the 1933 Long Beach Earthquake, the 1971 San Fernando Earthquake, the 1987 Whittier Earthquake, and the 1994 Northridge Earthquake. In addition, many areas in the Los Angeles Basin have sandy soils that are subject to liquefaction, including in the City of Cudahy.
Roads
The transportation system in Cudahy consists of a roadway network dominated by Atlantic Avenue, collector streets, and local streets. The Long Beach Freeway (State Route-710) is located just east of Cudahy. Also, the ’City’s central location in Los Angeles County provides Cudahy with easy access to most parts of the Southern California region. Local circulation within the City generally follows a grid pattern; except for Atlantic Avenue which extends in a north-south orientation at a slight angle and Salt Lake Avenue which follows the curve of the railroad tracks.
Atlantic Avenue is a regional highway that extends north to Alhambra and south to Long Beach.
Traffic volumes on most City streets are currently approaching or are at capacity.
Regional access to the City is provided by the Long Beach Freeway (I-710) that extends along the City’s eastern border. Access to this freeway is provided by Florence Avenue (north of Cudahy) and Firestone Boulevard (south of Cudahy), both being major arterials located just outside the City. Florence Avenue is a major roadway that provides a connection to the Long Beach Freeway for the neighboring communities of Downey, Bell, and Bell Gardens. With local freeway access largely dependent on Florence Avenue, the traffic on this roadway during peak hours is congested. Local access to Florence Avenue is provided by Wilcox Avenue and Atlantic Avenue and access to Firestone Boulevard is provided by Atlantic Avenue. The transportation system framework within Cudahy is largely defined by Atlantic Avenue which is a major north/south arterial that extends through the City. Other north/south roadways include Salt Lake Avenue, Wilcox Avenue, and Otis Avenue which also provide access to neighboring cities. Clara Street and Santa Ana Street are two primary east/west roadways. Aside from Atlantic Avenue and Santa Ana Street (west of Atlantic Avenue), all the streets in the City consist of two travel lanes.
All the potential housing sites identified are infill sites located in existing built-out areas of the City, and all have adequate road accesses (ingress and egress).
Water and Sewer
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The City of Cudahy is served by three water agencies, including Tract 349 Mutual Water Company, Tract 180 Mutual Water Company, and Golden State Water Company. Tract 349 Mutual Water Company serves the west side of Atlantic; Tract 180 Mutual Water Company serves the east side of Atlantic, and Golden State Water Company serves the southeast portion of the City. Water for all three water companies comes from a series of groundwater wells throughout the Central Basin.
Tract 349 Mutual Water Company currently has plans to replace one of the existing groundwater wells. Although the location of the new well has not yet been determined, it will be located at one of the two existing well locations.
Tract 180 Mutual Water Company states there is no deficit in water availability for the areas they serve. Tract 180 currently has enough water to supply current uses and future developments in their service area, including new residential developments. The company is currently upsizing water lines to be more efficient and to create more pressure. These improvements to the water lines will solve issues within the Cudahy service area more efficiently. These improvements should be completed by the end of 2025.
Golden State Water Company (Golden State Water) provides water services to the east portion of the City east of Wilcox Avenue. Currently, no deficiencies exist within Golden State Water’s jurisdiction. Increases in land use density from new developments/redevelopments will require fire flow tests as mandated by the LA Fire Department. Golden State Water has since implemented the Unidirectional Flushing (UDF) program to mitigate iron and manganese levels within the water supply.
Water use would be expected to rise with the anticipated increase in population under the General Plan Update. However, the expansion in conservation practices such as low water use gardening and use of recycled water would likely dampen demand somewhat. Also, the increase in mixed-use and multi-family housing units typically results in lower household water use as lawn and garden irrigation practices are less necessary than in single family homes. Low water use practices are common in the Southern California region and are consistent with the General Plan Update policies.
The sewer system is managed by the City’s Public Works Department. The local sewage is discharged into a larger system (County of Los Angeles Consolidated Sewer District) managed by the Los Angeles County Sanitation District (LACSD) which provides both primary and secondary treatment of all City of Cudahy sewage flows while Los Angeles County Department of Public Works (County DPW) maintains all City-owned collection systems. The field operation and maintenance services are fulfilled by utilizing the services provided by the Consolidated Sewer Maintenance District (CSMD) managed by the County DPW. Approximately 14.2 miles of sanitary sewer collection facilities serve customers in the City. The City is responsible for ensuring that the public sewer infrastructure is correctly designed, adequately sized, and easily maintainable.
The CSMD also provides a supporting role in reviewing all proposed sewer plans for new
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developments in the City to ensure that they conform to County design standards and particularly to ensure that district’s requirements for acceptability for maintenance. Results from the inspection of 74,557 feet of the City’s sewer system determined that 88 percent of the system is free from structural defects. The remaining 12 percent of the pipe segments were placed on a priority list based on the severity and the need for action. Since the 2013 SCAR, all segments on the priority list have been repaired as of April 2016.
The anticipated population increase in Cudahy (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 capacity 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 capacity. 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.
In accordance with Government Code Section 65589.7, immediately following City Council adoption, the City must deliver to all public agencies or private entities that provide water or sewer services to properties within the City of Cudahy a copy of the 2021-2029 Housing Element.
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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.
5.1 FINANCING AND SUBSIDY SOURCES
Federal, State, and local agencies provide a wide range of resources to help support the construction, acquisition, and rehabilitation of housing units for lower-income households in Cudahy. Many of these resources are made available to local tenants, owners, and developers of affordable housing through City and County programs and services. Although there is a wide range of programs, the availability of funding through these programs is typically inadequate to satisfy all needs. As a result, there is a fair amount of competition for program funds that are available, and any one development may need to draw upon multiple resources to be financially feasible.
Federal Resources
The federal government offers a wide variety of resource related housing assistance. The mortgage interest deduction and the real estate tax deduction are just two of the most common choices for homeowners provided through the income tax code. The deductions promote homeownership and reduce tax liabilities for home-owning taxpayers. Moreover, the deductions are used widely and expansively across the nation. Among the states, California has the highest amount of mortgage interest and real estate tax deducted every year.
Aside from tax of mortgage deductions, the federal government provided housing assistance to California jurisdictions through several programs. Like State programs, federal programs often change in terms of program details, application procedures, and amount of subsidy dollars available. For detailed descriptions, current subsidy levels, and up-to-date application procedures, refer to program literature available online from HUD at http://www.hud.gov.
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 City shall continue housing programs on housing development, infrastructure, rehabilitation, and job development, as allowed by the CDBG program. The City currently uses its CDBG moneys for the Home Improvement program, Business assistance program, fair housing foundation services, code enforcement, senior nutrition program, food distribution programs and the development of public facilities. It shall coordinate with the County Housing Authority in implementing programs outlined in the Comprehensive Housing Affordability Strategy (CHAS) for Los Angeles County. The City shall prepare a brochure outlining available housing assistance and rehabilitation programs in the City. The City is not applying for other federal programs, although it has evaluated potential participation in the HOME, HOPE, and other housing loan programs of HUD. It shall distribute these to property owners and make them available at City Hall. The brochure shall encourage residents to participate in the Section 8 housing assistance payments program and the housing voucher program through the Los Angeles County Housing Authority.
The program is ongoing under the Community Development Department and is financed by the General Fund.
5.2 GOVERNMENT CONSTRAINTS ON HOUSING PRODUCTION
It is in the public interest for the government to regulate land use and building standards to protect the general welfare of the community. On the other hand, stringent regulations, processing fees and lengthy procedures can potentially deter private enterprises from developing housing. The City of Cudahy regulates the use of land within the City limits through General Plan, the Zoning Ordinance, and building codes and standards.
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 standards that could add to the cost of housing development and the City’s response include the following:
Building Code
The City has adopted the Los Angeles County 2020 Building Code that establishes minimum construction standards. The City’s existing development requirements included in the Zoning Ordinance and Building Code do not include any architectural standards that would add to the cost of new housing development. In addition, there are no unique open space, parking, or MelloRoos fee requirements that are applicable to new developments outside of what is standard throughout the region. The only local amendment to the building code adopted by the City is in reference to identifying the Planning Commission as the building Board of Appeals.
Infrastructure
All the residential areas where the residential zoning is applicable are well served by streets and other infrastructure. No street dedications or new infrastructure is required for the typical infill development. However, as properties are intensified, the existing water lines are becoming overtaxed, which will eventually require updating and improving water supply throughout the City which will add to the cost of future construction.
Energy Conservation
The California Energy Resources Conservation and Development Conservation have developed guidelines used by building code enforcement officials to implement energy conservation regulations established by the California Energy Commission. While serving as a mitigation tool to help reduce electricity and natural gas consumption, they do add to the cost of housing. State law also authorizes school districts to collect impact fees for all new residential, commercial, and industrial construction.
School Fees for New Residential Development
The school fees that are charged towards new residential development are State mandated and are beyond the City’s ability to control. The Los Angeles Unified School District (LAUSD) levies a school development fee for residential construction. Building inspection services such as plan checks, and permit issuance are contracted, and the fees charged to the developer for these services are typically less than the actual cost for review time though any increased administrative costs beyond the base fees for discretionary review are waived. The planning fees that are charged in the City do not make any distinction between rental housing and owneroccupied housing or the types of housing (single-family or multiple-family).
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AB 884
The City of Cudahy has fully implemented the provisions of AB 884. The plan check review for new construction averages two to four weeks, which is considerably less than most surrounding cities. During a 169development’s design and planning, the City staff is available to conduct pertinent reviews and issue permits related to engineering, drainage, grading, public works, electrical, and other aspects of new developments. Even with those infill projects that require some form of discretionary review, the City has taken advantage of recent legislation that calls for smaller infill projects to be categorically exempt through the referral of a Class 32 California Environmental Quality Act (CEQA) Categorical Exemption.
Residential Infill
Residential infill projects are handled through the City’s streamlined review and entitlement process. The entire development process from land clearance through construction typically takes between six months to one year to complete, depending on the number of units. This includes the time required for plan check and construction.
Cudahy General Plan Land Use Policy
The Land Use Plan of the Cudahy General Plan has been developed to promote new residential development in the City. The Plan has several features which were developed to increase the availability of housing and maintain the existing housing stock. The Land Use Plan, illustrated in Exhibit LU-2 of the Land Use Element, preserves existing neighborhoods developed largely as single-family neighborhoods. The new General Plan increases the allowed density in the multifamily residential areas and intensity of nonresidential districts to encourage revitalization and lot consolidation, create new open spaces to enhance residents’ quality of life, and provide flexibility in land use policy to accommodate emerging land use trends. The General Plan land use categories allow residential development as follows:
• Low-Density Residential: 15 du/ac
• Medium-Density Residential: 25 du/ac
• High-Density Residential: 40 du/ac
• Mixed Use-Commercial: 40 du/ac if mixed use; 30 du/ac residential only • Mixed Use-Civic: 40 du/ac if mixed use; 30 du/ac residential only • Innovation Industrial: 1.5 FAR (allows live/work)
• Entertainment: NA, but in Housing Element we assume 30 du/ac The updated Land Use Element significantly increased development maximums and encourages new housing types. The Land Use Element identifies a realistic buildout and a maximum theoretical buildout. Realistic buildout would assume a total of 7,222 gross dwelling units in the City and a population of 30,607 persons by 2040. The theoretical maximum buildout would allow 12,037 gross dwelling units and a total population of 51,012 persons by 2040.
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As discussed in Section 4, the record of applications and constructed projects from 2018 to 2022 (33 projects/481 units) demonstrates that the updated Land Use Element and Development Code are being effective in encouraging development.
Development Code Requirements
The City of Cudahy Development Code includes development standards and requirements for existing and potential development within the Low Density Residential, Medium Density Residential and High-Density Residential zone districts, as well as three mixed-use districts (Civic Mixed Use, Commercial Mixed Use and Entertainment) and the Innovation Industrial district, which allows live/work units. Table 5.1 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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Table 5.1
Development Standards
Zone
Dev.
Standard
Commercial/
Mixed Use
Civic/
Mixed Use
Entertainment 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)
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: none
Side: none. 10’
adjacent to Res.
Rear: none. 10’
adjacent to 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: 200 sq. ft.
/unit
Common: 280 sq. ft.
/unit
Private: 200 sq. ft. /unit
Common: 280 sq. ft.
/unit
Subject to
Development
Agreement
Private: 200
sq. ft. /unit
Common: 280
sq. ft. /unit
Private: 200
sq. ft. /unit
Common: 280
sq. ft. /unit
250 sq. ft./unit or
25% of the lot
area/unit (exclusive
of the front yard
setback)
Building
Height
4 stories 4 stories 4 +4 stories with
Development
Agreement
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: 1.5 spaces/ 1-2 bed, 2 spaces per 3+ bed.
Efficiency Apartments and Senior Housing: 1 space/dwelling unit For all but single-family dwellings, Guest Parking shall be provided at .5 space/dwelling unit.
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 Cumulative Effect of Development Standards
The 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. Within multi-family residential zones, townhome and rental developments were studied upon a typical lot for the City (0.46 ac, 385’ x 50’). The most
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restrictive zoning standards were studied when considering the mixed-use development to propose the most effective changes to be made.
Additionally, 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, the City will reduce the guest parking requirements as discussed in the following study.
The first study consisted of a residential townhome development under current zoning standards (see Figures 5.1 and 5.2) 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 a required 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, with one in a garage + 0.5 guest spaces).
Figure 5.1
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Figure 5.2
There is potential for density increases through modifications to the current constraints that effect a typical residential townhome development. Shown below in Figure 5.3 and 5.4 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 of private open space, the density 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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Figure 5.3
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Figure 5.4
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 balcony 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)). See Figures 5.5 and 5.6 for the current code’s standards.
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Figure 5.5
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Figure 5.6
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 a portion of 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 from 30 to 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)). See Figures 5.7 and 5.8 to see results of the modified standards.
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Figure 5.7
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Figure 5.8
The mixed-use scenario was studied by taking the most restrictive zoning standards among the City’s mixed-use districts. See these standards in Figures 5.9 and 5.10. 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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Figure 5.9
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Figure 5.10
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Figure 5.11
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)). The adjustments result 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. See Figures 5.12, 5.13, and 5.14 to see results of the modified standards.
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Figure 5.12
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Figure 5.13
Figure 5.14
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As a result of these studies, the City is committing to the following changes in Program 27:
• Amend the definition of “family” in the zoning code
• Eliminate the 15 dwelling units per acre limit on sites that are less than half an acre • Increase the FAR limit to 1.5 in the CMU zone
• Eliminate the one acre minimum for mixed-use projects • Eliminate the 15 feet by 15 feet required open space for ownership projects • Count fire turnaround within the open space area
• Allow permeable, porous materials in the driveway right of way • Reduce private open space requirement to 100 square feet per unit. The City shall require a total of 280 square feet of open space per unit.
• Allow building that are two stories or higher to have balconies projecting into the side setback approximately 3 feet, leaving a minimum balcony setback from the side property line of 4
• Reduce guest parking to 0.25 spaces per unit
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. The City permits various residential uses by right in their respective zones, as identified in Table 5.2.
Table 5.2
Housing Types Permitted by Zone District
Residential Use ZONE
LDR MDR HDR Civ MU Com MU I-I
1 DU P P P NP NP NP
2-4 DU CUP P P NP NP NP
5+ DU CUP P P P P P
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 NP
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: City of Cudahy Building & Planning Departments
Permitted Uses are those uses allowed without discretionary review, in designated areas, if the project complies with all development standards. Roughly 50% of the City is zoned for the highest density residential designation, with under 10% low density residential. The remaining commercial is focused on Atlantic Avenue (roughly 6%), with approximately 12% industrial, and the remaining is public/institutions/parks/streets. Because of such high concentration of higher
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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.
Cudahy’s municipal code complies with many major stipulations of state law:
• In the Development Code, any employee housing providing accommodations for six or fewer employees shall be deemed a single-family structure pursuant to California Health & Safety Code Section 17021.5.
• State law also requires local governments to permit manufactured or mobile homes meeting federal safety and construction standards on a permanent foundation in all single-family residential zoning districts (Section 65852.3 of the California Government Code). In Cudahy, a manufactured/factory-built house is a single-family detached dwelling unit and is treated as such.
• Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. 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 City’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. This definition does not discriminate nor limit access to housing for persons with disabilities.
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, typically taking 3-6 months. Similarly, entitlements for multiple family residential projects can be
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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
Zoning Clearance 1-2 weeks
Minor Development Review Permit 2-3 weeks
Conditional Use Permit 3 months
Major Development Review
Permit/Design Review
3-6 months
Zone Change 3 – 6 months
General Plan Amendment 3-6 months
Site Plan Review 2 weeks
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
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 have 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.
Zoning Clearance
The City has a zoning clearance process which is an administrative review undertaken by the Community Development Director. Currently, the review takes approximately 2 weeks. While the zoning clearance process has not affected housing cost, supply, timing or approval certainty to date, the code currently describes this review as discretionary. To rectify this classification, within Program 27 the City commits to classify review of the Director of Community Development as ministerial in nature, removing requirements for CEQA analysis.
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
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through a zoning clearance. If the developer/owner wishes to appeal, the appeal will be heard by the Planning Commission.
Development Review Permit
The City approves minor and major residential projects through a development review process.
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.
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. Projects with 2 units or less 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.
In the City of Cudahy, according to CMC 20.16.130 and CMC 20.16.130, design review is conducted as a part of the development review permit process. CMC 20.15.130 states “to ensure architectural compatibility of new buildings and structures, design review shall be performed by the director of community development, or his or her designee, or by the planning commission as part of the development review permit procedures.” According to this code section, “design review shall focus on the color, material, and design of proposed buildings or structures.” The Director of Community Development, or his or her designee, or Planning Commission shall have the authority to request an existing building or structure to be improved or rehabilitated if one or more dwelling units are proposed on a lot. The City’s current design review standards through the development review permit process include both objective and non-objective standards.
The development review findings in CMC 20.16.130 (which do not apply to zoning clearances) 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.
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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.
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.
The zoning code provides the only set of guidelines that promote certainty in the evaluation of these findings. However, the code is not explicit in giving objective development and design review standards with which to evaluate all of these findings. Through Program 12 (Neighborhood Preservation) the City commits to establish objective design standards for residential and commercial development to assist the City’s development review processes in maintaining and creating safe, attractive, healthy neighborhoods. These objective design standards will be utilized during hearings and they will be developed by 2025.
Among 18 projects subject to major development review permits, 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. Given the relatively quick timelines associated with review procedures in Cudahy (especially as compared to neighboring Los Angeles), these processes have not markedly affected housing cost, supply, timing or approval certainty. Nevertheless, the City recognizes that some procedures do not comply with best practices and/or State laws, and as a result will address these issues:
• Since not all approval findings are objective, the City commits to revising these findings to be objective through Program 27.
• Since design review approval findings are not all objective, the City will develop objective design standards in Program 12.
• Additionally, in Program 27, the City commits to increasing the number of units that trigger Planning Commission development review from 3 units to at least 5 units.
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• In Program 27, the City shall classify development review by the Director of Community Development as ministerial in nature.
Conditional Use Permits
As described in Table 5.2, 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 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 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 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 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 of the zone in which it is to be located.
B. Site suitability. The site for a proposed conditional use is adequate in size and shape to accommodate the yards, walls and fences, parking and loading, landscaping, and other development standards prescribed in this zoning code, or required by the Planning Commission, City Council, or other authorized agent in order to integrate the conditional use with the land and uses in the neighborhood.
C. Neighborhood compatibility. The Planning Commission shall consider the nature, condition, and development of adjacent uses, buildings, and structures and the effect the proposed conditional use may have on such adjacent uses, buildings, and structures.
D. Access and circulation. The site for a proposed conditional use should relate to streets and highways adequate in width and pavement to carry the kind and quantity of traffic such use would generate. Adequate provisions for public access are available to serve the use.
E. Utilities and services. Adequate provisionsfor 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. The Planning Commission may apply such conditions to a
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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.
Through Program 27 (Zoning Code Review) the City commits to removing the CUP requirement for multifamily development in the LDR zone. The removal of this CUP requirement reduces housing cost, as developers no longer have to pay the $2,660 fee for the City to process their application for a CUP. Additionally, developers will be more likely to pursue the development of multifamily housing within an additional zone of the City, in addition to the MDR and HDR zones.
The removal of a CUP requirement in the LDR zone opens more of the City up to multifamily development, without the added step and cost of a CUP. Additionally, developers will not have to wait on their CUP to be processed through City systems, reducing the time developers must spend during the entitlement process. Lastly, multifamily development in LDR zones is more certain, without the CUP requirement which allows the City more power to apply conditions to the approval of multifamily development in the LDR zone. The City commits to removing this requirement in Program 27.
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Development Agreement
Development agreements are required for certain new development projects in the Mixed-Use, Entertainment, and HDR zones. Development agreements in the City must contain information regarding the duration of the agreement, permitted use of the property, density and intensity of the use, maximum height and size of proposed buildings, any provisions for the reservation or dedication of land for public purposes, and a provision for periodic review of the applicant’s compliance with the terms of the agreement. Development agreements shall be approved by resolution through the City Council.
According to the City, rather than viewing the development agreement requirement as a hurdle to development, developers of multifamily housing in the HDR and Mixed-use zones have generally appreciated the development agreement process. Developers may view this requirement favorably because they are able to gain more concessions through a development agreement process. City code allows for height bonuses of up to three stories to be granted through a development agreement in some areas. Additionally, financial assistance may be available through a development review process. And last, developers have been able to identify community needs throughout the public development review process.
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. The projects that required two hearings were subject to the HDR zone development agreement requirement. 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.
Thus, although the development agreement requirement is generally benign or even favorable to development, the requirement has impacted the timing and approval certainty of some new housing developments. As a result, in Program 27, the City commits to removing this development agreement requirement for new development in the HDR and Mixed-Use zones.
Development agreements will still be permitted for applicants which want to seek bonuses beyond those offered by State law, financial assistance or other City assistance.
Subdivisions
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 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
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Council. This process takes approximately three months and can include an additional month due to scheduling the final map for City Council action.
Density Bonus
The City’s code complies with State density bonus law, and the City has a consistent recent track record of processing applications for density bonuses, concessions and waivers. Approximately half of recent projects have included bonus units, concessions or waivers.
Accessory Dwelling Units
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:
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.
Compliance with the State’s Public Resources Code 21080.1 and 21080.2 The City of Cudahy’s Municipal Code does not include language in compliance with the State’s Public Resources Code 21080.1 and 21080.2. Program 27 addresses this constraint.
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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 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 development 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. 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.
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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 for the provision of low-income 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 27). The City will also make information available to developers of eligible projects.
Summary
Despite some of the constraints noted above, the City has a very aggressive schedule for reviewing, processing, and taking action on projects. Housing cost and timing for development have generally both not been greatly impacted as the City’s approval processes are quite quick and will become quicker through the changes in Program 27. 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 and mixed-use zones is likely the reason that developers are sometimes uncertain about the certainty that their development will be approved. Therefore, in Program 27, the City commits to removing this development agreement for new development in the HDR and Mixed-Use zones.
As discussed above, Program 27 (Zoning Code Review) commits to several other development review process changes as stated previously in this section and directly in Program 27.
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.
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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.
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.
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• 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 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 #28 (Implementation of the Inclusionary Housing Ordinance), 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 Ordinance 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. Therefore, in Program #28, the City commits to modifying concessions to be ministerial in nature and to expanding the number of potential incentives.
Environmental Review
The City conducts environmental reviews for all development projects, consistent with the requirements of the California Environmental Quality Act (CEQA). CEQA requires an environmental analysis for all projects that are not exempt. Projects with potentially significant impacts typically require preparation of either a Mitigated Negative Declaration with special studies, or an Environmental Impact Report (EIR). Preparation of these reports adds time and costs to the development review process and may require additional expenses if additional measures are required to mitigate potential environmental impacts.
Some projects are “categorically exempt” from CEQA because they comply with certain thresholds such as limited size or scope or because there is no reasonable possibility that they have the potential to significantly affect the environment. Article 19 of the CEQA Guidelines lists the types of projects that are normally exempt, including replacement or rehabilitation of existing facilities, construction, or conversion of small structures, and minor alterations to existing land.
Certain residential projects providing affordable urban, agriculture, or urban infill housing that meets specified acreage, affordability, and unit criteria are also exempt from CEQA by statutory
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law. The requirements for environmental review apply statewide and are not particular to Cudahy alone, so they represent little or no constraints to housing development in the City.
Applicable projects funded with CDBG or other sources of federal funding (depending on the administration of the funding source), are also subject to the requirements of the National Environmental Policy Act (NEPA).
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 Development Fees
The City charges two types of fees, planning entitlement fees (Table 5.5) 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,
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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:
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.
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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
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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
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
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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. The Program states that beginning in 2024 the City will establish development incentives including providing 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 “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. Due to the builtout 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 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 capacity to support the development. If the test comes back not meeting the minimum threshold, then the developer works with the City on facility upgrades.
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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 General Plan recognizes that street right-of-way is basically fixed in Cudahy and does not recommend any widening of collector or local roadways.
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.
The required street width construction for a typical subdivision would include 20-foot driveways and 60-foot rights-of-way for local streets. However, few properties in the City are large enough to require local streets. 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.
Constraints On Housing For Persons With Disabilities
As noted in the Special Needs section of the Housing Needs Assessment Report, persons with disabilities have several housing needs related to accessibility of dwelling units; access to transportation; employment, and commercial services, and alternative living arrangements that include on-site or nearby supportive services.
The City ensures that new housing developments comply with California building standards (Title 24 of the California Code of Regulations) and federal requirements for accessibility.
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Procedure For Ensuring Reasonable Accommodations
In 2018, as part of the comprehensive update to the Development Code, the City established a formal procedure for individuals with disabilities seeking equal access to housing to request a reasonable accommodation to zoning regulations, as provided by the Federal Fair Housing Amendments Act of 1988 and California’s Fair Employment and Housing Act, and to establish criteria to be used when considering these requests. The purpose of the reasonable 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, or a representative ofsuch 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 determine:
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 of the 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.
5.3 MARKET CONSTRAINTS ON HOUSING DEVELOPMENT
Market Constraints
Production cost factors such as land acquisition and improvement, construction material and labor, financing, overhead costs, and fees, are market constraints which impact the affordability of housing.
Land Cost / Construction Cost
The cost of housing in Cudahy has increased in the last few years as land values, construction costs, and finance charges continue to increase. The diminishing supply of land available for residential construction has driven land and housing costs upward. The City typically has little control over the market fluctuations that affect housing costs. Land values across the U.S. rose on average 8% in 2021, which is an increase over 2020 rates. This trend will affect the overall cost of developing new housing units in the City and the State in general.
Land, construction, and financing costs represent the most significant nongovernmental constraints in the production of housing for most income groups in Cudahy. Land costs in Cudahy are generally high due to high demand and the limited supply found in a built-out City. 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 multi-family residential building lot in Cudahy sells for over $375,000.
Construction costs include both “hard” and “soft” costs such as labor and materials (hard), and soft costs such as architectural and engineering services, development fees, construction financing, and insurance.
Sales of land that is developable for multi-family residential uses in Cudahy over the past five years average about $2 million per acre, or $50,000 to 80,000 per developable unit.
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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, and 5 Affordable Housing Incentives.
Availability Of Financing
An inventory of local lending institutions revealed that loans are available in the area to qualified clients.
Housing Crisis
Residential vacancy rates and the location of the City within the Los Angeles basin are two market constraints that affect the affordability of housing. As Los Angeles development areas continue to expand, Cudahy and the surrounding cities are becoming an increasingly convenient area in which to live. Housing prices will continue to rise due to this demand. As previously mentioned, just over 1.9% of the housing stock within the Cudahy is vacant. This translates into a demand for housing in the region exceeding the available supply, which inflates both the rental and ownership housing prices. If land values, construction costs, and interest rates continue to increase in the long-term, the cost of all new housing will rise accordingly.
As indicated above, the City has no control over the market fluctuations that may affect housing costs because market conditions result from a complex interplay of national economic policies and general economic conditions. Inflation in the cost of goods and especially housing means that many families find themselves unable to afford suitable housing. The lack of sufficient income causes more working people to share the cost of a home. As a result, overcrowding is common, and the housing choice of many households is severely restricted. This situation is further aggravated in periods of high unemployment as experienced in the last two years due to the COVID-19 pandemic and the threats of eviction of tenants and foreclosure on mortgaged properties.
Redlining practices have not been observed in Cudahy, as the City’s housing market is not characterized by wide disparities in prices. The Long Beach Fair Housing Foundation monitors redlining practices in the Southern California region, including the City and has found that redlining practices do not appear to be a problem.
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6 Evaluation of the Previous Housing Element
The City of Cudahy’s prior Housing Element was adopted and certified by HCD in 2018. 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.
Cudahy’s estimated RHNA allocation for 2014 -2021 was 318 units. The estimated RHNA allocation for 2021-2029 is 393 units. Between 2015 and 2021 119 building permits were issued for residential construction. Additionally, in 2021 the City approved a 179 unit project with 100% of the units affordable for seniors.
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 Local Roadway Safety Plan (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.
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
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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.
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 available early
care and education
services.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
funding sources
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)
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
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.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
The Study was
completed in 2014.
The City initiated
and adopted a
Development
Impact Fee Study in
2021/2022.
Delete
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Measure Implementation
Status
Continue/Modify/Delete
The feasibility of a Mello
Roos fee for the upgrade of
existing infrastructure
(including roads, water
lines, etc.) will be explored
for future implementation.
funding sources
as available.
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 lowincome 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
made available to
developers. Cooperative
ventures with developers
on housing projects may
also be initiated by the
City.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund
The program
began 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
Incentives)
CDBG
Information
Programs
The City shall continue
housing programs on
housing development,
infrastructure,
rehabilitation and job
development, as allowed
by the CDBG program. It
shall coordinate with the
County Housing Authority
in implementing programs
outlined in the
Comprehensive Housing
Affordability Strategy
(CHAS) for Los Angeles
County. The City shall
prepare a brochure
outlining available housing
assistance and
rehabilitation programs in
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
Continue
(Program 6 CDBG
Information)
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Measure Implementation
Status
Continue/Modify/Delete
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 Housing Authority.
(The City is not applying
for other federal
programs, although it has
evaluated potential
participation in the HOME,
HOPE and other housing
loan programs of HUD).
Park and Cudahy
Park.
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 low-income
units at risk of conversion,
the City may provide
technical assistance to nonprofit groups interested in buying the projects. It may
aggressively look for an
agency to buy the property
or help the residents
establish an association to
buy the project.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund CDBG
funds, and
other funding
sources as
available.
The City continued
to provide services
as needed. In 2022
the City adopted
the Inclusionary
Housing Program.
Options to on-site
development of
affordable units
included an option
to purchase at-risk
units and retain
affordability.
Another option
included payment
of in-lieu fees.
These fees could be
combined with
other funding
sources to
purchase sites for
affordable housing
and/or assist with
construction costs.
Modify. Combined with
Program 7 At-Risk
Preservation and Program 4
Replacement Housing
2024
Inclusionary
Housing
Program
The City shall explore the
feasibility of requiring
affordable housing units
within new housing
developments. This may be
promoted by density
bonuses and other
incentives, coupled with a
use restriction on the
affordable units. The City
may also require
developers to provide a
minimum percentage of
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
funding sources
as available.
The City initiated
the Inclusionary
Housing Program in
2021 and adopted
the Program in
2022.
Delete (program was
adopted; however,
implementation will begin in
2022 and will be ongoing).
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Measure Implementation
Status
Continue/Modify/Delete
affordable housing or pay
fees, dedicate land or
establish agreements with
other agencies for the
construction of affordable
units off site. To address
Cudahy’s overcrowding
problems, the City shall
include in this study, the
available options to
requiring or encouraging
large dwelling units (2
bedrooms or more) within
new development. This
may likewise be promoted
by incentives to the
allowable density and less
stringent development
standards. The
inclusionary housing study
shall be initiated by the
Department of Community
Development, with funding
from the General Fund to
the extent of available
resources. The study and
associated ordinance or
program will be completed
by December 2015.
Housing
Maintenance
and
Conservation
The City of Cudahy has an
ongoing program for the
maintenance and
conservation of the existing
housing stock. There are
programs aimed at the
conservation of older
housing units which are in
good condition to maintain
the units as affordable
housing options.
Rehabilitation and property
maintenance programs
ensure that living
conditions are safe and
decent for all households.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and CDBG
funds.
In 2020 two homes
received funding
through the CDBG
program.
There have been
no demolitions or
removal of mobile
homes.
Continue (Program 8 Housing
Maintenance and
Conservation)
Tenant Minor
Home Repair
Program
The City shall continue to
apply for Community
Development Block Grants
for housing rehabilitation
programs in the City. These
funds shall be used to offer
technical assistance and
loans under the Tenant
Minor Home Repair
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
This is an ongoing
program.
Two homes
received repair
assistance in 2020.
Delete (Combined with
Program 8 Housing
Maintenance and
Conservation)
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
program, as well as to
implement housing
rehabilitation programs
which provide low interest
loans, grants, and technical
assistance to property
owners. The program is
ongoing and will continue
to be managed and
monitored annually
(coinciding with the fiscal
year) by the Community
Development Department
and financed through CDBG
funds. The Tenant Minor
Home Repair Program is
complaint driven;
complaints are filed with
the City’s Code
Enforcement department
which then schedules
follow up inspections and
provides tenants with
information to resources.
Furthermore, the tenants
may be referenced to the
City’s Housing Department
to seek possible financial
assistance.
funding sources
as available.
SRO Hotels The City shall preserve
single-room occupancy
(SRO) hotels and strictly
enforce ordinances
regarding property
maintenance and fire and
safety standards to
safeguard the public
health, safety, and welfare
of tenants. Code
enforcement efforts on
hotels and motels in the
City have led to the
upgrading and renovation
of two local motels. The
City does not allow SRO
hotels to be used as
permanent housing but will
encourage their use as
emergency and transitional
shelter for the homeless.
The regulation on the
maximum stay of 30 days
by motel guests has abated
the use of SRO hotels are
permanent housing. The
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund
This program is
ongoing,
implemented, and
monitored annually
(coinciding with the
fiscal year).
Homeless persons
in the City
decreased from 76
in 2019 to 23 in
2020. In 2020 seven
homeless persons
were placed in
permanent
housing, six in
interim housing,
and 23 in rapid
housing.
Modify. Program 9 Hotel and
Motel Resources, and
New Program 25 Single Room
Occupancy Units
2023
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
City regularly checks hotel
records to ensure that this
regulation is followed. To
encourage the use
213ells”213ells by
”homeless” individuals, the
City continuously works
with hotel managers on
making rooms available for
emergency/transitional
housing and makes
community service
agencies in the area aware
of the facilities. The City
also refers persons in need
to these facilities. Vouchers
shall be solicited from the
hotel, local businesses,
charitable agencies, and
other
organizations/individuals
to provide short-term stays
at the hotels. The 160
rooms available in local
hotels are adequate to
serve the temporary
housing needs of homeless
individuals in the area.
Development
Standards to
Allow uses
The City shall modify its
Municipal Code to allow
the development,
maintenance, and
improvement of Emergency
Shelters, SRO’s,
Transitional Housing, and
Supportive Housing to
address constraints and
facilitate the development
of low income housing
throughout the City. The
City shall refer person in
need to these facilities.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
funding sources
as available.
Zoning Code
Amendments
completed in 2018.
Modify: Update, statutory
compliance. Program 10
Development Standards to
Allow Uses and Program 11
Emergency, Transitional and
Supportive Housing.
2023
Emergency
Shelters
The City will amend the
Zoning Ordinance so
emergency shelters shall be
a permitted use without a
conditional use permit or
other discretionary action
in the High Density
Residential zone.
Emergency shelters shall be
subject to the same
development and
management standards as
other permitted uses in the
Time Frame:
2014
Responsibility:
Community
Development
Funding Source:
City General
Fund
Zoning Code
Amendments
completed in 2018.
Modify. Update, statutory
compliance. Program 11
Emergency, Transitional, and
Supportive Housing
2023
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
High Density Residential
Zone, except for any
written, objective
standards for emergency
shelters the City may
develop as prescribed in SB
2. Transitional and
Supportive
Housing
The City will continue to
monitor the inventory of
sites appropriate to
accommodate transitional
housing and supportive
housing and will work with
the appropriate
organizations to ensure the
needs of homeless and
extremely low-income
residents are met. The City
is committed to prioritizing
funding and other
available incentives for
projects that provide
housing for homeless and
extremely low-income
residents whenever
possible. In compliance
with Senate Bill 2, the City
will amend the Zoning
Code to allow transitional
and supportive housing in
all residential zones,
subject only to those
regulations that apply to
other residential uses of
the same type in the same
zone. This program is
funded by the General
Fund and managed by the
Community Development
Department. Transitional
and Supportive Housing are
to be permitted and
implemented within 120
days of the adoption of the
Housing Element Update,
no later than March 2014.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
funding sources
as available.
The City began
review of state
laws to amend
Zoning Code.
Modify. Program 11
Emergency, Transitional and
Supportive Housing. Update,
statutory compliance. 2023
Neighborhood
Preservation
Neighborhood preservation
is seen as a mechanism to
increase homeownership in
the City, to promote
property maintenance, and
to maintain a more stable
resident population.
Time Frame:
Ongoing
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
In 2020 the City
issued 109
violation notices
regarding housing
and property
maintenance
issues. Two units
received
Modify. To include Citywide
Design Review Program
(Program 12 Neighborhood
Preservation)
2023
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
funding sources
as available.
rehabilitation
assistance in 2020.
Code
Enforcement
The City shall continue
code enforcement of
nuisances such as
inoperable vehicles,
property maintenance,
substandard units, and
illegal garage conversions.
It shall identify
substandard dwelling units
and encourage
rehabilitation through the
provision of technical
support and incentives
such as streamlined permit
processing, variances to
development standards on
a case by case basis, waiver
of fees or fines if
rehabilitation is
undertaken within the next
three months, etc. Also, it
shall actively work towards
the rehabilitation of
structures which do not
meet seismic safety
standards and current
electrical code
requirements. The City
shall coordinate with
homeowner’s associations
in the enforcement of
CC&R’s regarding property
maintenance.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund, and other
funding sources
as available.
This program is
ongoing,
monitored annually
(coinciding with the
fiscal year). The
Code Enforcement
Program is
complaint driven;
complaints are
filed with the City’s
Code Enforcement
Division which then
schedules follow
up inspections and
provides tenants
with resource
information.
Continue (Program 13 Code
Enforcement)
Housing
Cooperation
Program
The City shall work with Los
Angeles County to identify
and coordinate water and
sewer infrastructure on the
provision of adequate
infrastructure and public
services in Cudahy,
including monitoring for
grant funding sources, to
meet the City’s RHNA. It
shall coordinate County
and City capital
improvement projects
(CIP). This includes setting
priorities for infrastructure
and public service projects
through the City’s capital
improvement program.
The City shall coordinate
with state and regional
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund and other
funding sources
as available.
The CIP program is
completed
annually. The
continues to work
with surrounding
agencies on
regional issues and
compliance with
statutory
compliance.
Modify. Combined with
Program 14 Infrastructure
Availability
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
agencies on addressing
planning and
environmental issues that
affect Cudahy. It shall
initiate talks with adjacent
cities on potential areawide strategies to promote
jobs/housing balance.
Equal Access There are many special
needs households in
Cudahy that will benefit
from programs designed to
promote equal access and
opportunity to housing.
The City intends to
minimize difficulties of
special needs households
in finding adequate
housing by providing
programs to prevent
discrimination or to
encourage the production
of housing specifically
designed for these
households.
Time Frame:
2013, 2014
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund
City Zoning Code
Amended in 2018
with updated
definitions. City
works with the Fair
Housing Network
on any
discrimination
complaints.
Modify. Combine with other
Programs. Program 16 Fair
Housing
Program 19 Disability Access
Program 21 Persons with
Special Needs
New Program 27 Zoning Code
Review (includes new
definition of Family, statutory
compliance).
Reasonable
Accommodation
The City shall develop a
policy pursuant to the Fair
Housing Amendments Act
of 1988, to provide people
with disabilities reasonable
accommodation in rules,
policies, practices, and
procedures that may be
necessary to ensure equal
access to housing.
Time Frame:
2014
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund.
City Zoning Code
Amended in 2018
to include formal
procedure for
individuals with
disabilities seeking
equal access to
housing to request
a reasonable
accommodation to
zoning regulations.
Delete (program was
completed; however, services
continue through Program 16
Fair Housing).
Public
Participation
The City encourages
community participation in
all City programs. Noticing
practices in the City include
posting information on
scheduled public hearings
at City Hall, the Cudahy
Library, and the Council
Chambers at least two
weeks prior to the hearing
dates. The City also
advertises these hearings,
as well as other City
programs, in the local
newspaper (The Wave) and
in the City newsletter.
Both papers use English
and Spanish in their articles
to reach the primarily
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund
This program is
ongoing,
monitored annually
(coinciding with the
fiscal year).
Continue (Program 15 Public
Participation)
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
Hispanic Community of the
area. An interpreter is
also available during
public hearings to
facilitate communication
between individuals who
only speak Spanish.
Brochures at City Hall are
available in both English
and Spanish versions.
Spanish-speaking
employees also facilitate
the dissemination of
information regarding City
programs. It shall
encourage residents to
attend City Council and
Planning Commission
meetings by increased
publicity practices. This
will allow the City to get
more input into its
programs and tailor them
to meet the needs
expressed by residents.
Public workshops have
been conducted in the
General Plan’s revised
goals and policies and Draft
Land Use Plan to solicit
resident concerns. Public
hearings will continue to be
held prior to adoption of
the General Plan, including
this Element. This will
allow the City to better
respond to the concerns
and interests of Cudahy
residents.
Fair Housing
Program
The City promotes the
use of the Fair Housing
Council of Long Beach
through the City
newsletter and local
papers, and informs all City
employees of the available
services for referral. The
City shall prepare a list of
referral agencies to serve
low-income households,
handicapped, elderly,
homeless, and other
special needs groups.
Time Frame:
2013
Responsibility:
Community
Development
Director
Funding Source:
City General
Fund
Information is
provided by the
Code Enforcement
Division and the
Community
Development
Department.
Continue (Program 16 Fair
Housing)
Homeless
Assistance
The City shall continue to
provide funds for the
Time Frame:
2013
This program is
ongoing,
Continue (Program 18
Homeless Assistance)
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
Human Services
Association to serve the
homeless and other special
needs groups in the
community. It shall also
maintain a list of local
social services to use as
referral sources for
residents in need.
Responsibility:
Community
Development
Director
Funding Source:
General Fund,
CDBG Funds
monitored annually
(coinciding with the
fiscal year).
Bilingual The City will actively
produce documents and
publications that are in
both English and Spanish.
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund
This is an ongoing
program monitored
annually
(coinciding with the
fiscal year)
Delete. This Program has
been combined with Program
15 Public Participation)
Ongoing
Handicapped
Access
The City currently requires
new development to
comply with State
standards for handicapped
access. It shall also enforce
the recently adopted
American with Disabilities
Act.
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund
The City adopted
the Los Angeles
County 2020
Building Code
which includes
standards for ADA
compliance. The
City continues to
update current
codes, per
statutory
compliance.
Continue (Program 19
Disability Access)
Senior Shared
Housing
The senior’s Center on
Clara Park serves as an
information center for
senior programs and
resources.
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund
This is an ongoing
program monitored
annually
(coinciding with the
fiscal year).
Continue (Program 20 Senior
Program Resources)
Housing for
Extremely Low
Income
Households
Program
The City will encourage the
development of housing
units for households
earning 30 percent or less
of the median Family
income for Los Angeles
County. Specific emphasis
shall be placed on the
provision of family
housing and nontraditional housing types
such as single-room
occupancy units and
transitional housing. The
City will encourage
development of housing for
extremely-low income
households through a
Time Frame:
2015
Responsibility:
Community
Development
Funding Source:
City General
Fund and other
funding
sources.
In 2018 the City
rezoned 14 acres to
higher densities in
the HDR and CC
zone districts from
14.52 du/acre to 20
du/acre to meet
the RHNA. In 2022
the City adopted an
Inclusionary
Housing Program
with specific
requirements for
construction of
units affordable to
low and extremelylow income
households.
Delete (however, actions
continue to be provided
through other Programs 11
Emergency, Transitional and
Supportive Housing, 18
Homeless Assistance, 25
Single Room Occupancy, and
with implementation of the
2022 Inclusionary Housing
Program).
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
variety of activities such as
outreach to housing
developers on at least an
annual basis, providing
financial or in-kind
technical assistance or
land-write downs,
providing expedited
processing, identifying
grant and funding
opportunities, applying for
or supporting applications
for funding on an ongoing
basis, reviewing and
prioritizing local funding at
least twice during the
planning period and/or
offering additional
incentives beyond the
density bonus provision.
Persons with
Disabilities,
including
Developmental
Disabilities
The City shall seek State
and Federal monies, as
funding becomes available,
in support of housing
construction and
rehabilitation targeted for
persons with disabilities.
The City shall provide
regulatory incentives, such
as expedited permit
processing and fee waivers
and deferrals, to projects
targeted for persons with
disabilities, including
persons with
developmental disabilities.
The City shall reach out
annually to developers of
supportive housing to
encourage development of
projects targeted for
persons with disabilities,
including persons with
developmental disabilities.
The City shall work with
the local Regional Center to
implement an outreach
program informing families
within the City of housing
and services available for
persons with
developmental disabilities.
Information will be made
available on the City’s
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund
The City continued
to work with the
local Regional
Center. The City
adopted an
Inclusionary
Housing Program in
2022, which will
further
opportunities for
low income
persons with
disabilities.
Modify
(Program 21 Persons with
Special Needs)
2024, 2025
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
website and at City Hall
counter.
Preservation of
At-Risk Units
The City will monitor every
three months, the status of
any HUD receipt/approval
Notices of Intent and Plans
of Action filled by property
owners to convert to
market-rate units. The City
will annually identify and
meet and pursue funding
with non-profit
organizations as potential
purchasers/managers of atrisk housing units. As part
of coordination with nonprofit partners, the City will annually explore funding
sources available to
purchase affordability
covenants on at-risk
projects, transfer
ownership of at-risk
projects to public agencies,
purchase existing buildings
to replace at-risk units, or
construct replacement
units.
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund, CDBG
Funds
The City continued
to provide services
as needed. In 2022
the City adopted
the Inclusionary
Housing Program.
Options to on-site
development of
affordable units
included:
an option to
purchase at-risk
units and retain
affordability.
Payment of in-lieu
fees; and
conversion of
market rate units
to affordable units.
Continue. Program 7 At-Risk
Housing Preservation,
Program 4 Replacement
Housing
Consistency
with General
Plan
The City shall conduct an
integral review as part of
its General Plan
implementation to achieve
consistency with other
general plan elements,
policies, programs, and
community goals to reflect
the policy direction
contained in other parts of
the General Plan. As
portions of the General
plan are amended in the
future, this Housing
Element will be reviewed
to ensure that internal
consistency is maintained.
Time Frame:
2013
Responsibility:
Community
Development
Funding Source:
City General
Fund
This is an ongoing
program monitored
annually
(coinciding with the
fiscal year)
Continue. (Program 22
Consistency with General
Plan).
Zoning Update
Program
To address a shortfall and
un-accommodated need of
280 units at appropriate
densities, the City will
increase allowable zoning
densities of the HDR and CC
Zone’s City wide from
14.52 to allowing a
minimum of 20 dwelling
units per acre. Increasing
Time Frame:
2014
Responsibility:
Community
Development
Funding Source:
City General
Fund
In 2018 the City
Amended the
Zoning Code and
Zoning Map to
rezone 14 acres to
meet the RHNA
requirements.
Delete (Rezones completed;
however, a new Program 27
Additional Zoning Code
Amendments is included in
the 2021-2029 Housing
Element Update to maintain
updates and address
statutory compliance).
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Measure Implementation
Status
Continue/Modify/Delete
the density to 20 dwelling
units per acre will further
facilitate meeting the
demand for affordable
housing. Pursuant to
Government Code Section
65583I(1) and 65583.2(h)
and (i), sites to
accommodate the shortfall
and un-accommodated
need of 280 units will
permit a minimum of 16
dwelling units per site and
50% will be zoned
residential only.
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Effectiveness of Past Goals, Policies, and Actions for Special Needs Populations Seniors
The City of Cudahy’s 5th Cycle Housing Element included many successful goals, policies, and actions for the City’s senior population. During the 5th Cycle, the City’s Second Unit Ordinance allowed second units on single-family lots, leading to new second units on many lots in the LDR zone. These additional second units are often inhabited by family members, allowing for more comfortable multigenerational family living on LDR lots. Additionally, second units can often be more affordable than primary units, which is beneficial for Cudahy’s senior population who are often limited by their monthly budget. This Second Unit Ordinance has been renamed to the Accessory Dwelling Units Program (Program 3) within the 6th cycle Housing Element and will continue throughout the 6th cycle. The 5th cycle’s Affordable Housing Incentives Program encouraged the development of affordable housing units, provided developers with incentives, and shortened the permit process for low-income and senior citizen housing projects. Through this program, the City adopted an Inclusionary Housing Ordinance in 2022. This program will continue during the sixth cycle.
During the 5th cycle, through the CDBG Information Programs, the City used CDBG funds towards code enforcement, single-unit housing rehabilitation, senior activities, food distribution and two construction projects in two City parks. Many of these CDBG funded programs benefitted Cudahy’s seniors, and will continue in the sixth cycle. During the 5th cycle, the Housing Conversion Program and Preservation of At-Risk Units Program both supported the preservation of subsidized housing programs in Cudahy, many of which house Cudahy’s seniors. These Programs have been integrated into the At-Risk Preservation Program and the Replacement Housing Program of the sixth cycle. Through the 5th cycle’s Equal Access Program, the City worked with the Fair Housing Network on discrimination complaints in an effort to minimize difficulties special needs households face in finding adequate housing. This program will continue in the 6th cycle and has been integrated into Program 16 (Fair Housing), 19 (Disability Access), 21 (Persons with Special Needs), and 28 (Zoning Code Review).
Through the 5th cycle’s Reasonable Accommodation Program, the City amended its zoning code in 2018 to include formal procedure for individuals with disabilities seeking equal access to housing to request a reasonable accommodation to zoning regulations. Due to the link between the senior and disabled populations, this program benefits the City’s senior population with disabilities. This program has been deleted in the 6th cycle; however, these services will continue through the Fair Housing Program (Program 16). The 5th cycle’s Handicapped Access Program also serves the City’s senior disabled population and will be continued in the 6th cycle. Through the 5th cycle’s Fair Housing Program, the City connected residents to referral agencies, including residents from special needs groups such as seniors. The Fair Housing Program (Program 16) will continue in the 6th cycle. The 5th cycle’s Senior Program Resources Program allows the City to provide senior programs and resources at the Senior Center in Clara Park. This program will continue in the 6th cycle.
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Persons with Disabilities
The City of Cudahy’s 5th Cycle Housing Element included many successful goals, policies, and actions for the City’s disabled population. Through the 5th cycle’s Equal Access Program, the City worked with the Fair Housing Network on discrimination complaints in an effort to minimize difficulties special needs households, including disabled households, face in finding adequate housing. This program will continue in the 6th cycle and has been integrated into Program 16 (Fair Housing), 19 (Disability Access), 21 (Persons with Special Needs), and 28 (Zoning Code Review). Through the 5th cycle’s Reasonable Accommodation Program, the City amended its zoning code in 2018 to include formal procedure for individuals with disabilities seeking equal access to housing to request a reasonable accommodation to zoning regulations. This program has been deleted in the 6th cycle; however, these services will continue through the Fair Housing Program (Program 16). The 5th cycle’s Handicapped Access Program also serves the City’s disabled population and will be continued in the 6th cycle.
Through the 5th cycle’s Fair Housing Program, the City connected residents to referral agencies, including residents from special needs groups such as disabled residents. The Fair Housing Program (Program 16) will continue in the 6th cycle. The 5th cycle’s Persons with Disabilities, including Developmental Disabilities Program resulted in the adoption of the City’s Inclusionary Housing Ordinance in 2022 which will improve future housing opportunities for low income persons with disabilities during the 6th cycle. This Program will continue with the modified name, Persons with Special Needs (Program 21).
Large Households
The City of Cudahy’s 5th Cycle Housing Element included many successful goals, policies, and actions for the City’s large family population. During the 5th Cycle, the City’s Second Unit Ordinance allowed second units on single-family lots, leading to new second units on many lots in the LDR zone. These additional second units are often inhabited by family members, allowing for more comfortable multigenerational family living on LDR lots. Additionally, second units can often be more affordable than primary units, which benefits low income large families. This Second Unit Ordinance has been renamed the Accessory Dwelling Units Program (Program 3) within the 6th cycle Housing Element and will continue throughout the 6th cycle. The 5th cycle’s Affordable Housing Incentives Program encouraged the development of affordable housing units, provided developers with incentives, and shortened the permit process for low-income and senior citizen housing projects. Sometimes low-income housing developments include three to four bedroom units, which would house Cudahy’s low income large families. Through this program, the City adopted an Inclusionary Housing Ordinance in 2022. This program will continue during the sixth cycle.
During the 5th cycle, through the CDBG Information Programs, the City used CDBG funds towards code enforcement, single-unit housing rehabilitation, senior activities, food distribution and two construction projects in two City parks. Many of these CDBG funded programs benefit Cudahy’s low income large families. This program will continue in the sixth cycle. During the 5th cycle, the
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
Housing Conversion Program and Preservation of At-Risk Units Program both supported the preservation of subsidized housing programs in Cudahy, some of which provide large units which house Cudahy’s large families. These Program have been combined into the At-Risk Preservation Program and the Replacement Housing Program of the sixth cycle. The 5th cycle’s Development Standards to Allow Uses Program resulted in the modification of the City’s zoning code in 2018 to address constraints and facilitate the development of supportive and low income housing.
Supportive housing can include low income family housing developments in Cudahy. This program has been modified and will continue in the 6th cycle, through the program of the same name (Program 10) as well as the Emergency, Transitional, and Supportive Housing Program (Program 11). Through the 5th cycle’s Transitional and Supportive Housing Program, the City began review of state laws to amend the City’s zoning code in support of supportive housing for extremely low income households, including extremely low large family households. This program will continue in the 6th cycle.
Through the 5th cycle’s Equal Access Program, the City worked with the Fair Housing Network on discrimination complaints in an effort to minimize difficulties special needs households (including large family households) face in finding adequate housing. This program will continue in the 6th cycle and has been integrated into Program 16 (Fair Housing), 19 (Disability Access), 21 (Persons with Special Needs), and 28 (Zoning Code Review).
Female Headed Households
The City of Cudahy’s 5th Cycle Housing Element included many successful goals, policies, and actions for the City’s female headed households. During the 5th Cycle, the City’s Second Unit Ordinance allowed second units on single-family lots, leading to second units on most lots in the LDR zone. These additional second units are often inhabited by family members, allowing for more comfortable multigenerational family living on LDR lots. Additionally, second units can often be more affordable than primary units, which benefits low income female headed households. This Second Unit Ordinance has been renamed the Accessory Dwelling Units Program (Program 3) within the 6th cycle Housing Element and will continue throughout the 6th cycle. The 5th cycle’s Affordable Housing Incentives Program encouraged the development of affordable housing units, provided developers with incentives, and shortened the permit process for low-income and senior citizen housing projects. Many female headed households could potentially qualify as low-income and therefore would be able to qualify for low-income housing.
Through this program, the City adopted an Inclusionary Housing Ordinance in 2022. This program will continue during the sixth cycle.
During the 5th cycle, through the CDBG Information Programs, the City used CDBG funds towards code enforcement, single-unit housing rehabilitation, senior activities, food distribution and two construction projects in two City parks. Many of these CDBG funded programs benefit Cudahy’s low income female headed households. This program will continue in the sixth cycle. During the 5th cycle, the Housing Conversion Program and Preservation of At-Risk Units Program both supported the preservation of subsidized housing programs in Cudahy, some of which provide units which house Cudahy’s low income female headed households. These Program have been
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
combined into the At-Risk Preservation Program and the Replacement Housing Program of the sixth cycle.
The 5th cycle’s Development Standards to Allow Uses Program resulted in the modification of the City’s zoning code in 2018 to address constraints and facilitate the development of supportive and low income housing. Supportive housing can include low income housing developments in Cudahy which low income female headed households would qualify to live in. This program has been modified and will continue in the 6th cycle, as it has been integrated into the program of the same name (Program 10) as well as the Emergency, Transitional, and Supportive Housing Program (Program 11). Through the 5th cycle’s Transitional and Supportive Housing Program, the City began review of state laws to amend the City’s zoning code in support of supportive housing for extremely low income households, including female headed households. This program will continue in the 6th cycle.
Through the 5th cycle’s Equal Access Program, the City worked with the Fair Housing Network on discrimination complaints in an effort to minimize difficulties special needs households (including female headed households) face in finding adequate housing. This program will continue in the 6th cycle and has been combined with Program 16 (Fair Housing), 19 (Disability Access), 21 (Persons with Special Needs), and 28 (Zoning Code Review). Through the 5th cycle’s Fair Housing Program, the City connected residents to referral agencies, including residents from special needs groups such as female headed households. The Fair Housing Program (Program 16) will continue in the 6th cycle.
Persons Experiencing Homelessness
The City of Cudahy’s 5th Cycle Housing Element included many successful goals, policies, and actions for the City’s homeless population. The 5th cycle’s Affordable Housing Incentives Program encouraged the development of affordable housing units, provided developers with incentives, and shortened the permit process for low-income and senior citizen housing projects. Lowincome housing projects have the potential to house Cudahy’s homeless population, depending on the targeted population of the project. Through this program, the City adopted an Inclusionary Housing Ordinance in 2022. This program will continue during the sixth cycle. During the 5th cycle, through the CDBG Information Programs, the City used CDBG funds towards code enforcement, single-unit housing rehabilitation, senior activities, food distribution and two construction projects in two City parks. Many of these CDBG funded programs benefits Cudahy’s homeless residents. This program will continue in the sixth cycle.
During the 5th cycle, the Housing Conversion Program and Preservation of At-Risk Units Program both supported the preservation of subsidized housing programs in Cudahy, some of which house Cudahy’s formerly homeless residents. These Program have been combined into the At-Risk Preservation Program and the Replacement Housing Program of the sixth cycle. The 5th cycle’s SRO Hotel Program implementation coincided with a decrease in the homeless population in Cudahy, from 76 in 2019 to 23 in 2020. In 2020, seven homeless residents were placed in permanent housing, six in interim housing, and 23 in rapid housing. This program will continue
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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
through two programs in the sixth cycle, the Hotel and Motel Resources Program (Program 9) and the Single Room Occupancy Program (Program 25).
The 5th cycle’s Development Standards to Allow Uses Program resulted in the modification of the City’s zoning code in 2018 to address constraints and facilitate the development of supportive and low income housing. Supportive housing includes housing for homeless residents. This program has been modified and will continue in the 6th cycle, as it has been integrated into the program of the same name (Program 10) as well as the Emergency, Transitional, and Supportive Housing Program (Program 11). Through the 5th cycle’s Transitional and Supportive Housing Program, the City began review of state laws to amend the City’s zoning code in support of supportive housing for extremely low income households, including homeless residents. This program will continue in the 6th cycle. During the 5th cycle, the Emergency Shelters Program amended the zoning code so emergency shelters for homeless residents would be a permitted use without a conditional use permit or other discretionary action in the High Density Residential zone. This program will continue as the Emergency, Transitional, and Supportive Housing Program (Program 11) in the 6th cycle.
Through the 5th cycle’s Equal Access Program, the City worked with the Fair Housing Network on discrimination complaints in an effort to minimize difficulties special needs households (including homeless residents) face in finding adequate housing. This program will continue in the 6th cycle and has been integrated into Program 16 (Fair Housing), 19 (Disability Access), 21 (Persons with Special Needs), and 28 (Zoning Code Review).
Through the 5th cycle’s Fair Housing Program, the City connected residents to referral agencies, including residents from special needs groups such as homeless residents. The Fair Housing Program (Program 16) will continue in the 6th cycle. Through the 5th cycle’s Homeless Assistance Program, the City continued to provide funds for the Human Services Association to serve the homeless and other special needs groups in the community. The City also maintained a list of local social services to use as referral sources for residents in need. This program will be continued in the 6th cycle.
Extremely Low Income Households
The City of Cudahy’s 5th Cycle Housing Element included many successful goals, policies, and actions for the City’s extremely low income households. During the 5th Cycle, the City’s Second Unit Ordinance allowed second units on single-family lots, leading to second units on most lots in the LDR zone. These additional second units are often inhabited by family members, allowing for more comfortable multigenerational family living on LDR lots. Additionally, second units can often be more affordable than primary units, which is beneficial for Cudahy’s extremely low income households. This Second Unit Ordinance has been renamed to the Accessory Dwelling Units Program (Program 3) within the 6th cycle Housing Element and will continue throughout the 6th cycle. The 5th cycle’s Affordable Housing Incentives Program encouraged the development of affordable housing units, provided developers with incentives, and shortened the permit process for low-income and senior citizen housing projects. Through this program, the
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City adopted an Inclusionary Housing Ordinance in 2022. This program will continue during the sixth cycle.
During the 5th cycle, through the CDBG Information Programs, the City used CDBG funds towards code enforcement, single-unit housing rehabilitation, senior activities, food distribution and two construction projects in two City parks. Many of these CDBG funded programs benefit Cudahy’s extremely low income households. This program will continue in the sixth cycle. During the 5th cycle, the Housing Conversion Program and Preservation of At-Risk Units Program both supported the preservation of subsidized housing programs in Cudahy, many of which house Cudahy’s extremely low income households. These programs have been combined into the AtRisk Preservation Program and the Replacement Housing Program of the sixth cycle.
The 5th cycle’s SRO Hotel Program implementation coincided with a decrease in the homeless population (whom are all likely extremely low income) in Cudahy, from 76 in 2019 to 23 in 2020.
In 2020, seven homeless residents were placed in permanent housing, six in interim housing, and 23 in rapid housing. This program has been integrated into two programs in the sixth cycle, the Hotel and Motel Resources Program (Program 9) and the Single Room Occupancy Program (Program 25). The 5th cycle’s Development Standards to Allow Uses Program resulted in the modification of the City’s zoning code in 2018 to address constraints and facilitate the development of supportive and low income housing. Supportive and low income housing includes housing extremely low income households. This program has been modified and will continue in the 6th cycle, as it has been integrated into Program 10 as well as the Emergency, Transitional, and Supportive Housing Program (Program 11). Through the 5th cycle’s Transitional and Supportive Housing Program, the City began review of state laws to amend the City’s zoning code in support of supportive housing for extremely low income households. This program will continue in the 6th cycle. During the 5th cycle, the Emergency Shelters Program amended the zoning code so emergency shelters for homeless residents (whom are almost all extremely low income) would be a permitted use without a conditional use permit or other discretionary action in the High Density Residential zone. This program will be integrated into Emergency, Transitional, and Supportive Housing Program (Program 11) in the 6th cycle.
Through the 5th cycle’s Equal Access Program, the City worked with the Fair Housing Network on discrimination complaints in an effort to minimize difficulties special needs households (including extremely low income households) face in finding adequate housing. This program will continue in the 6th cycle and has been combined with Program 16 (Fair Housing), 19 (Disability Access), 21 (Persons with Special Needs), and 28 (Zoning Code Review).
Through the 5th cycle’s Fair Housing Program, the City connected residents to referral agencies, including residents from special needs groups such as extremely low income households. The Fair Housing Program (Program 16) will continue in the 6th cycle. Through the 5th cycle’s Homeless Assistance Program, the City continued to provide funds for the Human Services Association to serve the homeless and other special needs groups (including extremely low income households)
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in the community. The City also maintained a list of local social services to use as referral sources for residents in need. This program will be continued in the 6th cycle.
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7 Housing Goals, Policies, Programs, and Quantified Objectives This section of the City of Cudahy Housing Element address’s the State's housing element requirements or a "statement of the community goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing." The goals, policies, and programs identified in this Housing Element serve to support the State of California’s overarching goal of providing, “decent housing and a suitable living environment for every Californian” (Government Code Section 65580). The programs have been reviewed, in relationship to the General Plan, updated analysis, and state housing laws, and amended accordingly. City
The housing goals, policies, and programs that follow were created for the purpose of meeting the housing needs of the City throughout the 2021-2029 planning period given the limitations imposed by current political, economic, and social conditions, budget constraints and available local, state, and Federal funding.
7.1 HOUSING GOALS, POLICIES, AND PROGRA’S
The City's housing goals have been developed to respond to the key housing related issues facing the City. As summarized in the Profile Report, Cudahy is experiencing a very high demand for housing. This is manifested by the low vacancy rate, the creation of unpermitted housing units, and the doubling-up of households in individual units resulting in overcrowding. The lack of housing has led to increases in rents and prices, which go beyond the affordability of its lowincome residents.
Housing Element Goals
The Housing Element Goals are those goals applicable to the City’s housing related issues.
Housing Element Goal 1: The City of Cudahy will improve the housing supply and the choice of housing opportunities through private investment and, where necessary, through public action and financing.
Housing Element Goal 2: The City of Cudahy will promote affordable housing and shelter for all economic segments of the community.
Housing Element Goal 3: The City of Cudahy will support and provide incentives for the maintenance and rehabilitation of the existing housing stock.
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Housing Element Goal 4: The City of Cudahy will encourage development of a viable urban community consistent with orderly growth and environmental conservation to provide suitable living environments, with access to employment, community facilities, and services.
Housing Element Goal 5: The City of Cudahy will foster opportunities for Cudahy residents to become homeowners.
Housing Element Goal 6: The City of Cudahy will promote equal access and opportunity to housing regardless of race, religion, sex, marital status, ancestry, national origin, or color.
Housing Element Goal 7: The City of Cudahy will foster and maintain compliance with civil rights and fair housing laws.
Housing Element Policies
The Housing Element Policies are those policies that will be applicable over the course of the planning period governed by this Housing Element. The policies are listed under their respective goal.
Housing Element Goal 1: The City of Cudahy will improve the housing supply and the choice of housing opportunities through private investment and, where necessary, through public action and financing.
Housing Element Policy 1.1: The City of Cudahy will encourage future investment in the City's housing stock.4
Housing Element Policy 1.2: The City of Cudahy will evaluate the factors affecting housing costs and examine ways to reduce housing costs where governmental action is appropriate.
Housing Element Policy 1.3: The City of Cudahy will support the development and use of new techniques in housing design, construction, and development.
Housing Element Policy 1.4: The City of Cudahy will promote the development of attractive and safe housing to meet the community's needs.
Housing Element Policy 1.5: The City of Cudahy will provide prompt processing of housing construction applications through standardized development requirements and centralized processing.
Housing Element Policy 1.6: The City of Cudahy will encourage the assemblage and consolidation of existing small parcels in areas which permit higher density development. 4 This symbol indicates a policy or program that addresses environmental justice issues.
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Larger parcels can better accommodate increased density housing, through a more efficient use of space resulting in more on-site amenities and greater use of open space.
Housing Element Policy 1.7: The City of Cudahy will recognize the changing trends and patterns in the community and encourage a broad range of housing types to meet these needs.
Housing Element Policy 1.8: The City of Cudahy will work with the appropriate service providers to develop and coordinate programs to assist in the conservation of affordable housing and to serve the homeless population.
Housing Element Goal 2: The City of Cudahy will promote affordable housing and shelter for all economic segments of the community.
Housing Element Policy 2.1: The City of Cudahy will promote all State, regional and local practices and plans that support housing availability for all economic segments of the population.
Housing Element Policy 2.2: The City of Cudahy will promote local housing services to ensure federal, state, and local housing programs are available to assist the private sector in obtaining funds for housing development.
Housing Element Policy 2.3: The City of Cudahy will utilize Community Development Block Grant funds to develop housing, expand economic opportunities through commercial development, improve community facilities and services, prevent deterioration of the housing stock, and redevelop residential areas.
Housing Element Policy 2.4: The City of Cudahy will inform residents of the availability of housing assistance programs and community services available in the area (such as Section 8 certificates and vouchers).
Housing Element Policy 2.5: The City of Cudahy will encourage variety in the supply of housing at costs affordable to the various income levels of the population.
Housing Element Policy 2.6: The City of Cudahy will solicit State and Federal funds for new housing development.
Housing Element Policy 2.7: The City of Cudahy will work towards the conservation of existing subsidized housing for low and moderate-income families.
Housing Element Policy 2.8: The City of Cudahy will seek funding opportunities and promote rental assistance for low and moderate-income families.
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Housing Element Goal 3: The City of Cudahy will support and provide incentives for the maintenance and rehabilitation of the existing housing stock.
Housing Element Policy 3.1: The City of Cudahy will encourage, support, and provide incentives for the maintenance, conservation, and revitalization of existing residential units.
Housing Element Policy 3.2: The City of Cudahy will explore strategies and programs that will be effective in reducing the costs incurred by the homeowner for rehabilitation.
Housing Element Policy 3.3: The City of Cudahy will encourage relocation assistance for displaced persons living in rentals undergoing rehabilitation and/or reconstruction.
Housing Element Policy 3.4: The City of Cudahy will continue residential rehabilitation programs and provide technical assistance to property owners as needed.
Housing Element Policy 3.5: The City of Cudahy will encourage prompt rehabilitation or demolition and replacement of vacant and abandoned properties.
Housing Element Policy 3.6: The City of Cudahy will actively engage in identifying substandard and deteriorating housing in Cudahy and take appropriate actions to correct these deficiencies, such as initiating rehabilitation, maintenance, or replacement programs.
Housing Element Policy 3.7: The City of Cudahy will promote housing rehabilitation and conservation through public education and awareness programs.
Housing Element Policy 3.8: The City of Cudahy will encourage property maintenance to promote quality design, public safety, and to promote energy conservation.
Housing Element Policy 3.9: The City of Cudahy will work with the County or non-profit agencies in conserving existing low-income housing units and subsidized housing projects.
Housing Element Policy 3.10: The City of Cudahy will preserve existing single-family, lower density residential neighborhoods.
Housing Element Goal 4: The City of Cudahy will encourage development of a viable urban community consistent with orderly growth and environmental conservation to provide suitable living environments, with access to employment, community facilities, and services.
Housing Element Policy 4.1: The City of Cudahy will reserve the existing residential neighborhoods and provide areas to accommodate new residential development.
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Housing Element Policy 4.2: The City of Cudahy will coordinate regional and local public works and capital improvement programs in declining neighborhoods and in neighborhoods experiencing increased population due to redevelopment or land conversion activities.
Housing Element Policy 4.3: The City of Cudahy will provide the necessary public services and infrastructure, including encouraging early care and education facilities, to residential areas and locate new housing developments where availability of public facilities and services is assured.
Housing Element Policy 4.4: The City of Cudahy will encourage the application of high-quality urban design standards to create safe, attractive, functional housing units and neighborhoods.
Housing Element Policy 4.5: The City of Cudahy will conserve existing residential areas and prevent the intrusion of incompatible uses into the neighborhoods.
Housing Element Policy 4.6: The City of Cudahy will encourage continued and new investment in the established residential neighborhoods in Cudahy.
Housing Element Policy 4.7: The City of Cudahy will increase property maintenance efforts by code enforcement to improve the overall appearance of the residential neighborhoods, thus maintaining property values in the City.
Housing Element Policy 4.8: The City of Cudahy will identify the best possible locations and development standards for residential development and encourage a high-quality environment for family life.
Housing Element Goal 5: The City of Cudahy will foster opportunities for Cudahy residents to become homeowners.
Housing Element Policy 5.1: The City of Cudahy will remove locally imposed barriers to the development of new owner-occupied housing.
Housing Element Policy 5.2: The City of Cudahy will provide financial assistance to residents who seek to purchase a home for the first time and cannot qualify on the private market alone.
Housing Element Policy 5.3: The City of Cudahy will seek the creation of a long-term affordable ownership housing stock, to ensure that financial subsidies result in long-term affordability.
Housing Element Goal 6: The City of Cudahy will promote equal access and opportunity to housing regardless of race, religion, sex, marital status, ancestry, national origin, or color.
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Housing Element Policy 6.1: The City of Cudahy will promote equal access and opportunities to housing through the provision of consumer information, assistance, and protection and through citizen involvement in the design and implementation of housing programs.
Housing Element Policy 6.2: The City of Cudahy will explore procedures for fair and equitable treatment of the parties in housing contracts, such as buyer-seller and landlord-tenant agreements.
Housing Element Policy 6.3: The City of Cudahy will encourage citizen participation and community involvement in the development and implementation of housing assistance and housing programs in the City. Actively pursue participation on housing issues by the City's elderly and minority populations.
Housing Element Policy 6.4: The City of Cudahy will establish referral agencies to serve lowincome households, the homeless, handicapped, elderly households and residents with special housing needs.
Housing Element Policy 6.5: The City of Cudahy will enforce fair housing laws and encourage the use of fair housing council services.
Housing Element Policy 6.6: The City of Cudahy will encourage and promote accessible housing for the handicapped. This includes the retrofitting of existing units and the enforcement of the State accessibility standards for new residential construction.
Housing Element Policy 6.7: The City of Cudahy will provide continued cooperation between the City and adjacent cities in the development of regional housing programs and homeless services.
Housing Element Policy 6.8: The City of Cudahy will provide density bonuses for low-income housing projects and senior citizen housing projects.
Housing Element Goal 7: The City of Cudahy will foster and maintain compliance with civil rights and fair housing laws.
Housing Element Policy 7.1: The City of Cudahy shall establish and maintain policies that foster and maintain compliance with all civil rights and fair housing laws by training its Community Development staff in the details of the civil rights and fair housing laws.
Housing Element Policy 7.2: The City of Cudahy, in addition to establishing and maintain compliance with all civil rights and fair housing laws shall employ, where vacancies exist, those who are familiar with, or have worked specifically with fair housing and civil rights laws.
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Housing Element Programs
The housing programs were developed to address the City’s housing needs and help provide adequate housing for all residents. Quantified objectives and metrics are identified in accordance with AB 686.
The programs and quantified objectives are identified on Table 7.1 and a description of each program is provided on the following pages. Fair housing metrics are given within the program descriptions and in Table 2.20.
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Table 7.1
2021-2029 Housing Element Programs and Quantified Objectives Program # Program Name/Objective Responsible Department Completion Date 1 Adequate Sites Community Development
• Prepare an annual monitoring report for vacant and
underutilized sites
Each year 2021-2029.
• Maintain an inventory of available sites for residential development
Each year 2021-2029.
• Evaluate residential development proposals for consistency with statutory requirements and the City’s General Plan goals and policies
Ongoing
2 Housing Information Community Development
• Creation of a residential database for vacant and
underutilized sites
2023
3 Accessory Dwelling Units Community Development
• Update ADU requirements in Zoning Code and update ADU Ordinance, to comply with State law.
2023
4 Replacement Housing Community Development 2024
• Update the Municipal Code to specify replacement housing requirements on nonvacant sites consistent with State law. 2024
5 Affordable Housing Incentives Community Development
• Outreach to development community Each year 2021-2029 • Technical assistance memo on State Density Bonus Law 2024 • One grant application to close funding gap for 4610 Santa Ana Street
2023
6 CDBG Information Community Development
• Provide information on programs and services to residents. Ongoing 7 At-Risk Housing Preservation Community Development
• Monitor the status of any HUD receipt/approval Notices of Intent and Plans of Action filled by property owners to convert to market-rate units.
Ongoing
• Notify all appropriate organizations and interested parties of the availability of property to ensure continued low-income housing.
Ongoing
8 Housing Maintenance and
Conservation
Community Development
• Renovate two properties per year. Each year 2021-2029 9 Hotel and Motel Resources Community Development
• Make 160 rooms available in local hotels which are adequate to serve the temporary housing needs of homeless individual in the area.
Each year 2021-2029
10 Development Standards to Allow
Uses
Community Development
• Amend the zoning code to allow the development,
maintenance, and improvement of Emergency Shelters,
Transitional Housing, and Supportive Housing.
2023
11 Emergency, Transitional and
Supportive Housing
Community Development
• Reduce parking standards for emergency shelters to
accommodate staff parking
2023
12 Neighborhood Preservation Community Development
• Develop objective design standards. 2025
13 Code Enforcement Community Development
• Continue code enforcement of nuisances such as inoperable vehicles, property maintenance, substandard units, and
illegal garage conversions.
Ongoing
14 Infrastructure Availability Community Development
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• Establish a permit tracking program. 2024
• Construct at least one mile of bicycle lanes connecting to a future Metro station.
2027
• Establish specific procedures for water and sewer
connections.
2024
• Tract 180 Mutual Water Company to upsize water lines 2025 15 Public Participation Community Development
• City will notice at least two weeks prior to public hearings. Ongoing • Annual outreach to AFFH stakeholders. Each year 2023-2029 • Produce documents in English and Spanish. Ongoing
16 Fair Housing Community Development
• Annual fair housing press releases Each year 2021-2029 17 Food Distribution Community Development
• Continue the hot meals and food distribution programs once a month.
Ongoing
18 Homeless Assistance Community Development
• Maintain a list of local social services to use as referral sources for residents in need.
Ongoing
19 Disability Access Community Development
• Enforce the Americans with Disabilities Act Ongoing
20 Senior Program Resources Community Development
• Continue the use of the Senior Center as an information center for senior programs and resources.
Ongoing
21 Persons with Special Needs Community Development
• Provide regulatory incentives, such as expedited permit processing and fee waivers and deferrals, to projects
targeted for persons with special needs.
2024
• Work with the local Regional Center to implement an
outreach program informing families within the City of
housing and services available for persons with special needs.
2025
22 Consistency with General Plan Community Development
• Conduct an integral review as part of its General Plan implementation to achieve consistency with other General Plan elements, policies, programs, and community goals.
Each year 2021-2029
23 Housing Conditions Survey Community Development
• Complete Housing Conditions Survey. 2023
24 Low Barrier Navigation Centers Community Development • 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.
2023
25 Single Room Occupancy Units Community Development
• Review and amend the Zoning Code to include single room occupancy units in the appropriate zones.
2023
26 State Density Bonus Law Community Development
Department
• Review the City’s density bonus standards and amend the Zoning Code as necessary to comply with State Density
Bonus Law.
2024
27 Zoning Code Review Community Development
• Several changes to the City’s zoning code, relating to complying with State law, updating development standards, and streamlining the City’s permit processes.
2023
28 Implementation of the Inclusionary
Housing Program
Community Development
• Monitor the effect of the Ordinance on housing production and report progress in the General Plan Implementation
Report.
Each year 2021-2029
29 Environmental Enhancements Community Development
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• Provide land write-downs where possible to assist in the cleanup of contaminated sites.
Ongoing
• Identify funding sources and partners to install and help residents access air filters
• City will amend the municipal code and other regulations to require mitigation measures such as increased indoor air filtration to increase the protection of sensitive receptors near major emission sources.
Ongoing
End of 2026
30 Rent Control Ad Hoc Committee Community Development
• Study and recommendation to City Council from Ad-hoc
committee.
2023
31 First Time Homebuyers Community Development
• One training session in the City per year. Each year 2023-2029 • Identify local or external funding source for incentivizing homeownership.
2029
32 Economic Development Strategic
Plan and Transit Oriented
Development
Community Development
• Economic Development Strategic Plan 2023
• WSAB Cudahy Strategic Implementation Plan 2025
• One sidewalk improvement plan 2025
33 Surplus Land Act Compliance Community Development
• Choose developer for publicly owned parcel in Inventory 2024 • Entitle project on parcel by 2026. 2026
34 Promote Lot Consolidation of Site 25 Community Development • Meet with County leadership once a month until the
County and City reach an agreement to adjudicate the
disposition of Site 25 in a manner consistent with the
Surplus Land Act.
Each month 2023-2024.
35 Open Space Development Community Development
• Develop one new open space in Cudahy in the area of
highest need within the sixth cycle.
• Create cul-de-sacs at Olive and Elizabeth Streets at their intersections with Salt Lake Avenue to eliminate use of these residential streets as shortcuts to bypass arterials by the end of 2026.
• Completion of Parks Long Range Plan
2029
2026
2026
Source: City of Cudahy; Community Development Department 2022
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Program 1: Adequate Sites
The City will prepare an annual monitoring report for vacant and underutilized sites. This report shall identify any changes to use, potential environmental concerns, and site development that occurs in each fiscal year beginning in 2021/2022 through 2029. The City will also maintain an inventory of available sites for residential development and provide it to prospective residential developers upon request.
Government Code §65863 states that no jurisdiction shall “reduce, or require, or permit the reduction of, the residential density for any parcel to, or allow development of any parcel at, a lower residential density, than projected” for sites identified in the Housing Element sites inventory unless the jurisdiction makes written findings that the reduction is consistent with the General Plan, and that the remaining sites identified in the Housing Element are adequate to accommodate the jurisdiction’s need. The City will evaluate residential development proposals for consistency with statutory requirements, and the City’s General Plan goals and policies; as they relate to the housing needs of the community.
Responsibility: Community Development Department.
Funding: City General Fund and other funding sources as available.
Program 2: Housing Information
To encourage the development of quality affordable housing on vacant and underutilized sites, the City shall prepare a residential data base. The data base shall include identification of the vacant and underutilized sites, City investment opportunities, development incentives, and early care and education services. The data base shall be prepared in 2023 and updated annually.
Responsibility: Community Development Department.
Funding: City General Fund and other funding sources as available.
Program 3: Accessory Dwelling Units
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.
Fair Housing Metric: Two ADUs per year will be constructed. The construction of two ADUs per year will increase affordable housing options Cudahy residents.
Responsibility: Community Development Department.
Funding: City General Fund and other funding sources as available.
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Program 4: Replacement Housing
Pursuant to Government Code 65583.2(g)(3), the Housing Element must include a program requiring the replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site consistent with those requirements set forth in Density Bonus Law (Government Code 65915(c)(3). Replacement requirements shall be required for sites identified in the inventory that currently have residential uses, or within the last five years have had residential uses that have been vacated or demolished, and were either rent or price restricted, or were occupied by low or very low income households. The 2021-2019 objective for this program is to update the City’s Municipal Code to specify replacement housing requirements on nonvacant sites consistent with Government Code 65583.2(g)(3). The Municipal Code will be updated by the end of 2024.
Responsibility: Community Development Department.
Funding: City General Fund
Program 5: Affordable Housing Incentives
To encourage the development of affordable housing units, the City shall annually conduct proactive outreach to the development community to inform them of City affordable housing incentives and funding potentials starting in 2024. This task will occur annually starting in 2024.
The permit process shall be expedited for low-income and senior citizen housing projects.
Additionally, the Inclusionary Housing Ordinance also included an environmental review streamlining process for eligible Inclusionary Housing projects. The City shall also update the list of local, state, and federal financing sources, and assist developers in obtaining grant funds to support the construction of affordable housing, housing related infrastructure, or environmental remediation. The activities will be completed by 2024.
The City will also provide technical assistance and information to interested affordable housing developers and post (at the Planning Department and on the City website) the Housing Element Sites Inventory table that identifies residential development sites and a technical assistance memo on the use of the State’s Density Bonus provisions. This task will occur annually starting in 2023.
In particular, the City will support the developer of the entitled senior housing project at 4610 Santa Ana Street by providing technical assistance and studies, where possible, to support grant applications intended to close any funding gap for this project. The City and developer will submit at least one grant application by the end of 2023.
Fair Housing Metric: Construction of affordable senior housing project at 4610 Santa Ana Street.
Reduce permit processing time by 25% for future affordable projects compared to typical affordable housing processing time in the 5th cycle. The construction of a large senior affordable housing project in Cudahy greatly increases housing options for Cudahy’s seniors who are in need