Cudahy City Council
September 5, 2023

29 2021 HOUSING ELEMENT UPDATE AMENDMENT
will have to budget more for preservation assistance, home repair costs, and energy requirements.

Examining the age of the current housing stock is one way to determine how historical development patterns have contributed to a City’s form. The time period where the highest share of the City of Cudahy’s housing units was built is 1950-1959, while in the SCAG region more were built during 1970-1979 than any other period. Chart 2.5 identifies housing units by the year built.

Chart 2.5 - Housing Units by Year Structure Built
American Community Survey 2014-2018 5-year estimates.

A parcel specific housing condition survey was undertaken in February 2013. During the survey, housing conditions were evaluated according to the following criteria:

Category I: Good Condition. Housing units included in this category were considered to be in a good state of repair and no repairs were warranted.

Category II: Minor Fix-Up; Paint-Up. General housing improvement needed including paint and minor repairs. Typically, improvements can be and are usually made by the property owner.

Category III: Major Repairs. This category includes major repairs such as replacement of the roof. Typically, such repairs would be performed by a contractor.

Category IV: Beyond Repair. This housing condition category applies to those structures where the cost of repair is estimated to exceed the value of the structure. 0%
5%
10%
15%
20%
25%
30%
2014 &
Later
2010-
2013
2000-
2009
1990-
1999
1980-
1989
1970-
1979
1960-
1969
1950-
1959
1940-
1949
1939 &
Earlier
Cudahy (%) 0.0% 0.3% 5.2% 5.1% 8.7% 10.8% 15.5% 27.1% 18.1% 9.3% SCAG (%) 1.0% 1.5% 10.1% 9.5% 15.0% 16.3% 14.5% 15.9% 6.9% 9.3% Percent of Total Units Cudahy (%) SCAG (%)

30 2021 HOUSING ELEMENT UPDATE AMENDMENT
The 2018 Housing Element update indicated that there are 5,403 housing units in the City in a good state of repair and no repairs are warranted. There are 246 units that require paint and minor repairs, 18 units that require major repairs such as roof replacement, and three units where the cost of repair is estimated to exceed the value of the unit. A summary of the 2013 Housing Conditions Survey is provided in Table 2-8.

Table 2.8
Housing Conditions Survey 2013
Category of Housing Condition Number of Houses
Category I 5,403
Category II 246
Category III 118
Category IV 3
Total 5,770
Source: City Survey 2013
In 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.

The American Community Survey (ACS) includes surveys about three factors of what may be considered substandard housing. In Cudahy, 60 units (1.06%) lack telephone service, 0 units lack plumbing, and 34 units (.61%) lack complete kitchen facilities. Chart 2.6 identifies substandard housing in the City.

Chart 2.6 - Substandard Housing
American Community Survey 2014-2018 5-year estimates.

1.07%

0.00%

0.61%

1.95%

0.39%

1.29%
0%
1%
1%
2%
2%
3%
No Telephone Service Available Lacking Plumbing Facilities Lacking Complete Kitchen Facilities Percent of Total Units
Cudahy SCAG

31 2021 HOUSING ELEMENT UPDATE AMENDMENT
According to the most recent Department of Finance estimates, a total of 5,607 units were occupied while the remaining 163 units were vacant. This translated into a vacancy rate of 2.82% compared to a vacancy rate of 5.9% for Los Angeles County. In 2020 the vacancy rate for owneroccupied units was 2.9% and the vacancy rate for rental units was 1.5%. Compared to other cities in the county, Cudahy’s housing vacancy rate is among the lowest. This results in an increased demand for a limited supply of housing units, which in turn, could affect the cost of both rental and owner-occupied units. Chart 2.7 identifies vacant units by type.

Chart 2.7 - Vacant Units by Type
American Community Survey 2014-2018 5-year estimates.

Housing Costs and Affordability
The Department of Housing and Urban Development defines affordable housing as housing for which the owner or tenants pays less than 30 percent of the household income. The cost of housing vis-à-vis income directly impacts the degree of affordability. If housing costs are high relative to income, there will be a correspondingly higher prevalence of borrowing in the case of homeowners, and overpayment in the case of renters. Overcrowding also increases as people turn to sharing homes and apartments to reduce housing costs. This section summarizes the cost and affordability of Cudahy’s housing stock.

Between 2000 and 2020 median home sales prices in Cudahy increased 179% while prices in the SCAG region increased 151%. 2018 median home sales prices in Cudahy were $430,000 and the highest experienced since 2000 was $493,500 in 2007. Prices in Cudahy have ranged from a low of 62.2% of the SCAG region median in 2002 and a high of 93.2% in 2008. Chart 2.8 identifies the median sales of existing homes.

32.8%

0.0%

16.1%

0.0% 0.0% 0.0%

51.1%

20.7%

5.4% 7.9%

4.5%

33.5%

0.3%

27.7%
0%
10%
20%
30%
40%
50%
60%
For Rent Rented For Sale Sold Seasonal Migrant Other
Percent of Total Vacant Units
Cudahy SCAG

32 2021 HOUSING ELEMENT UPDATE AMENDMENT
Chart 2.8 - Median Sales Price of Existing Homes
A household is overpaying for housing if more than 30% of their net “take-home” income is used for paying rent or mortgages.

According to census figures for the year 2020, 255 households (45.2% of the total owneroccupied units) living in owner-occupied units paid more than 30% of their monthly income towards the mortgage. According to the same census figures, 2,624 renter households (56.3% of the total renter households) paid more than 30% of their monthly income towards the rent. For renters, the median gross rent per month significantly increased from $1,103 in 2011 to $1,306.

On a percentage basis, this increase in cost represents an 18.4 percent increase. This dollar amount refers to the contract rent (i.e., monthly rent agreed to, or contracted for) plus the estimated average cost of utilities and fuels if paid for by the renter. This definition was used by the census to eliminate differentials due to varying practices in rent structuring.

The HUD-formulated Fair Market Rent (FMR)schedule is a guideline to maximum rents allowable for units receiving Section 8 assistance. HUD uses the Consumer Price Index and the census data to calculate the FMRs for each Standard Metropolitan Statistical Area (SMSA).

Because HUD includes different criteria in its definition of rent, census data and FMRs are not directly comparable. While some vacant property is available for new residential development, most of the new residential construction will occur on land that is presently occupied by existing development. The demolition, removal, and clean-up of these existing properties contribute to the higher cost of development. During the latter part of the 1990s, interest rates were generally low. In 2000, interest rates were raised by the Federal Reserve though they were once again lowered in the years following 2000 in response to fears of recession and have continually dropped in response to avoiding a further recession. With the currently low interest rates in 2020, the prices of residential and commercial properties have skyrocketed. In general, the cost

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
$-
$100,000
$200,000
$300,000
$400,000
$500,000
$600,000
2000200120022003200420052006200720082009201020112012201320142015201620172018 Cudahy SCAG Cudahy Percentage of SCAG Price

33 2021 HOUSING ELEMENT UPDATE AMENDMENT
(market-rate) for new land in the City ranges from $100/square foot up to $150/square foot. The actual construction cost for residential development ranges from $300/square foot up to $530/square foot. The current average rent in the City is $1,624.00, and the average cost of a single-family residential property is approximately $450.00 per square-foot. Homes are not as affordable in the City as they were 10 years ago, following a similar regional and state-wide trend.

Chart 2.9 identifies the percentage of rent households are paying.

Rent/Ownership
Rent
Chart 2.9 - Spending on Rent by Renter (ACS -2020)
Across Cudahy's 4,811 renter households, 2,854 (59.3%) spend thirty percent or more of gross income on housing cost, compared to 55.3% in the SCAG region. Additionally, 1,457 renter households in Cudahy (30.3%) spend fifty percent or more of gross income on housing cost, compared to 28.9% in the SCAG region.

The ACS allows for the analysis of Cudahy's 4,733 renter households (for which income data are available) by spending on rent by income bracket (dollar amounts). As one might expect, the general trend is that low-income households spend a higher share of income on housing (e.g., over 50%) while high-income households are more likely to spend under 20% of income on housing. Chart 2.10 identifies spending on rent by income. 71 275
385
601 547
431 381
585
1,457
78 0
200
400
600
800
1,000
1,200
1,400
1,600
<10% 10-15% 15-20% 20-25% 25-30% 30-35% 35-40% 40-49% >50% Not Computed
Number of Households
Percent of Income Spent on Rent

34 2021 HOUSING ELEMENT UPDATE AMENDMENT
Chart 2.10 – Spending on Rent By Income
American Community Survey 2014-2018 5-year estimates.

Cudahy renter households' cash rent paid can be broken down by household incomes. As one might expect, the general trend is that lower-income households spend less on rent while higherincome households spend more on rent, though this may not be universally true. Rent categories range from <$500/month (3.6% of Cudahy renters) to >$2000/month (3% of Cudahy renters).

The most common rent category in Cudahy is $1000-1500/month with 57.6% of renters. Chart

2.11 identifies household income by cash rent.

Chart 2.11 - Household Income by Cash Rent
American Community Survey 2014-2018 5-year estimates.
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Less than
$20,000
$20,000 to
$34,999
$35,000 to
$49,999
$50,000 to
$74,999
$75,000 to
$99,999
$100,000 or
more
>50% 754 615 88 0 0 0
30-49% 86 419 660 232 0 0
20-29% 38 58 179 651 206 16
<20% 0 0 17 133 235 346
Number of Renter Households
Income Category
>50%
30-49%
20-29%
<20%
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Less
than
$20,000
$20,000
to
$34,999
$35,000
to
$49,999
$50,000
to
$74,999
$75,000
to
$99,999
$100,00
0 or
more
>$2000/mo. 0 19 36 39 0 47
$1500-2000/mo. 109 142 157 243 139 63
$1000-1500/mo. 443 637 557 589 265 252
$500-1000/mo. 225 269 177 145 37 0
<$500/mo. 129 25 17 0 0 0 Renter Households
Income
>$2000/mo.
$1500-2000/mo.
$1000-1500/mo.
$500-1000/mo.
<$500/mo.

35 2021 HOUSING ELEMENT UPDATE AMENDMENT
Ownership
While renter households receive much of the focus when it comes to housing cost analysis, owner households make up 14.1% of Cudahy and 52.5% of the SCAG region. The most commonly occurring mortgage payment in Cudahy is $1500-$2000/month and the most commonly occurring mortgage payment in the SCAG region is $2000-$3000/mo. 2020 Census data establishes $1,921 as the median mortgage payment in the City. Chart 2.12 identifies the monthly owner costs for mortgage holders.

Chart 2.12 - Monthly Owner Costs for Mortgage Holders
American Community Survey 2014-2018 5-year estimates
Mortgage-holding households in Cudahy can be broken down by income and the percentage of income spent on mortgage costs. As one might expect, the general trend is that lower-income households spend a higher share of income on housing costs, while high-income households may spend a lower share of income on housing. Chart 2.13 identifies the cost for mortgage holders by income.

0.0%

3.7%

20.8%

29.7% 29.2%

12.3%

4.3%

0.5%

5.1%

13.7%

19.6%

33.4%

15.4%

12.3%
0%
5%
10%
15%
20%
25%
30%
35%
40%
<$500 $500-$1000 $1000-$1500 $1500-$2000 $2000-$3000 $3000-$4000 >$4000 Pct. of mortgage-holders
Mortgage - Monthly Payment
Cudahy SCAG

36 2021 HOUSING ELEMENT UPDATE AMENDMENT
Chart 2.13 - Cost for Mortgage Holders by Income
Another approach to evaluating the relationship between housing and income is to compare incomes and home values in Cudahy. Chart 2.14 identifies the household income by home value.

Chart 2.14 - Household Income by Home Value
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Less than
$20,000
$20,000 to
$34,999
$35,000 to
$49,999
$50,000 to
$74,999 $75,000 or more
Over 30% 19 90 58 71 79
20-29% 0 0 2 17 117
Under 20% 0 0 0 0 109
Mortgage-holding households
Household Income; Percent of income spent on mortgage costs 0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Less than
$20,000
$20,000 to
$34,999
$35,000 to
$49,999
$50,000 to
$74,999
$75,000 to
$99,999
$100,000
or more
Above $500,000 0 55 11 0 36 82
$200,000 to $500,000 18 44 72 112 45 220
$100,000 to $200,000 0 5 7 0 0 0
Below $100,000 70 8 27 3 0 0
Owner-occupied households
Household Income; Home Value

37 2021 HOUSING ELEMENT UPDATE AMENDMENT
Regional Housing Needs Assessment
The Southern California Association of Governments (SCAG) has identified a total of 393 housing units for Cudahy’s Regional Housing Needs Assessment. The units are broken down as follows:
80 very low-income units (40 of which are extremely low-income units), 36 low-income units, 53 moderate income units, and 224 above moderate-income units. Table 2.8 provides a breakdown of Cudahy’s regional housing needs allocation.

Table 2.8
Final 6th Cycle Regional Housing Needs Allocation
Although the extremely low-income category is not specifically identified, to calculate the projected housing needs, the City assumed 50% of its very low-income regional housing needs are extremely low households. As a result, from the very low income need of 80 units, the City has projected a need of 40 units for extremely low-income households. Extremely low-income is defined as households with income less than 30 percent of area median income. The County AMI is what this is based on. Households with extremely low incomes have a variety of housing situations and needs. For example, most families and individuals receiving public assistance, such as social security insurance (SSI) or disability insurance is considered extremely low-income households. At the same time, a minimum wage worker could be considered an extremely lowincome household with an annual income of approximately $17,000 or less.

Housing the extremely low-income population (below 30% of area median income) can be especially challenging. The race/ethnicity with the highest share of extremely low-income households in Cudahy is Black, non-Hispanic (40% compared to 31% of total population). In the SCAG region, the highest share of extremely low-income households is Black, non-Hispanic (27.1% compared to 17.7% of total households).

38 2021 HOUSING ELEMENT UPDATE AMENDMENT
Existing Needs
According to the 2020 Census data prepared by SCAG, of the City’s 5,690 households in 2020, 2,879 households were considered extremely low-income. Most extremely low-income households are renters and experience a high incidence of housing problems. For example, extremely low-income households faced housing problems (defined as cost burden greater than 30% of income and/or overcrowding and/or without complete kitchen or plumbing facilities).

Even further, extremely low-income households paid more than 50% of their income towards housing costs. Table 2.9 identifies the housing needs for extremely low-income households.

Table 2.9
Housing Needs for Extremely Low-Income Households
Renters Owners Total
Total Number of ELI
Households
2,624 255 2,879
Percentage with Any
Housing Problems

12.6% 12.6% 25.3%
Percent with Cost Burden
(30% of income)

56.3% 45.2% 50.3%
Percent with Severe Cost
Burden (50% of income)

10.2% 71% 12%
Total Number of Households 4,702 1,011 5,713
Source: Census.gov; Southern California Association of Governments Projected Needs
To calculate the projected housing needs, the City assumed 50% of its very low-income regional housing needs are extremely low-income households. As a result, from the very low-income need of 80 units, the City has a projected need of 40 units for extremely low-income households. Many extremely low-income households will be seeking rental housing and most likely facing an overpayment, overcrowding or substandard housing conditions. Some extremely low-income households could experience mental or other special needs.

The City previously adopted a number of programs as part of the City’s ongoing commitment to provide adequate housing for all residents. Amendments to several of these programs are included in this Housing Element. The amended programs include updates to the Zoning Code for accessory dwelling units and single room occupancy units. Program 3 has been amended as follows:

The City will update the accessory dwelling unit requirements within the Zoning Code, and update the Ordinance, to comply with statutory requirements (5th cycle Second Unit Ordinance changes to Accessory Dwelling Units Program in 6th cycle). 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

39 2021 HOUSING ELEMENT UPDATE AMENDMENT
homeowner/applicant assistance tools. Amendments to the Zoning Code will be completed in 2023.

The City will update the Housing Information Program to focus on the development of affordable housing and will create a residential database to identify vacant and underutilized sites for affordable housing developers. The City will update the Affordable Housing Incentives Program to include annual outreach to the development community and technical assistance/studies in support of the entitled senior housing project at 4610 Santa Ana Street. The City will continue the Housing Conversion Program, which will be split and combined into the sixth cycle’s At-Risk Preservation Housing Program and Replacement Housing Program. The City will update the Inclusionary Housing Program which will become the Implementation of the Inclusionary Housing Program in the sixth cycle.

The City will update the SRO Hotels Program which will become the Hotel and Motel Resources Program in the sixth cycle. This program will no longer focus on SROs and instead will focus on hotels and motels. The City will update the Emergency Shelters Program and Transitional and Supportive Housing Program which will combine to become the Emergency, Transitional, and Supportive Housing Program in the sixth cycle. During the sixth cycle the City commits to reducing City parking standards for emergency shelters for staff parking needs and to reviewing the City’s zoning districts to permit supportive housing where required in compliance with statutory requirements. The City will update the Fair Housing Program to promote the use of the Housing Rights Center during the sixth cycle, instead of the Fair Housing Council of Long Beach as in the fifth cycle.

To address the housing needs of extremely low-income households, the City will identify and meet with nonprofit builders who specialize in building housing for extremely low-income households and supportive housing. This effort is designed to:
• Build a long-term partnership in development,
• Gain access to specialized funding sources, including applying for funding sources that support deeper targeting,
• Identify the range of local resources and assistance needed to facilitate the development of housing for extremely low-income households, and
• Promote a variety of housing types, including higher density, multifamily supportive, single room occupancy, and shared housing.

As part of this effort, the City will develop an action plan with its nonprofit partners to develop housing for extremely low-income households. Activities include assisting with site identification and acquisition, local financial resources, assisting and streamlining entitlements and providing concessions and incentives.

40 2021 HOUSING ELEMENT UPDATE AMENDMENT
Overcrowding
Overcrowding its typically defined as more than one person per room, based on the Census Bureau’s definition of “room,” which excludes bathrooms, porches, balconies, foyers, halls, or half-rooms. Severe overcrowding occurs when there are more than 1.5 persons per room.

Overcrowding can result when there are not enough adequately sized units within a community, or when high housing cost relative to income forces too many individuals or families to share housing. Overcrowding can also accelerate deterioration of the housing stock.

In Cudahy, 93 owner-occupied and 1,518 renter-occupied households had more than 1.0 occupants per room, which meets the ACS definition for overcrowding. 7 owner-occupied households and 346 renter-occupied households had more than 1.5 occupants per room, which meets the ACS definition for severe overcrowding (see Table 2.10). Chart 2.15 identifies crowding by extent and tenure.

Chart 2.15 - Crowding by Extent and Tenure
American Community Survey 2014-2018 5-year estimates.

Table 2.10
Household Overcrowding
Owner Renter Total
Occupied Units 916 4733 5649
Overcrowded Units 180 1248 1428
Severely Overcrowded 83 451 534
Source: Census.gov; American Fact Finder
Overpayment
A household is overpaying for housing (or cost burdened) if it spends more than 30% of its gross income on housing. Severe housing cost burden occurs when a household pays more than 50%

11.8%

0.9%

31.6%

7.2% 4.9%

1.3%

15.6%

6.4%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

1.0+/room 1.5+/room 1.0+/room 1.5+/room
Owner Owner Renter Renter
Percent of Total Households
Cudahy SCAG

41 2021 HOUSING ELEMENT UPDATE AMENDMENT
of its income on housing. The prevalence of overpayment varies significantly by income, tenure, household type, and household size. Of the 2,879 households overpaying in Cudahy, 448 household were severely overpaying.

Table 2.11 identifies households overpaying, Table 2.12 identifies households severely overpaying, and Table 2.13 identifies households with lower incomes overpaying.

Table 2.11
Households Overpaying
Households Renter Owners TOTAL
All Households 4733 916 5649
Number of Households
Overpaying
2,624 255 2,879
Percent of All Households
Overpaying

56.3% 45.2% 50.9%
Source: Census.gov; American Fact Finder
Table 2.12
Households Severely Overpaying
Households Renter Owners TOTAL
Number of Households
Overpaying
2,624 255 2,879
Number of Households Severely
Overpaying
267 181 448
Percent of Households Severely
Overpaying

10.2% 71% 15.5%
Source: Census.gov; American Fact Finder
Table 2.13
Lower Income Households Overpaying
Households Renters Owners TOTAL
Total Households Overpaying 2,624 255 2,879

LOWER INCOME HOUSEHOLDS
Lower Income Households
Overpaying (30% of Income)
1,477 115 1,592
Lower Income Households
Severely Overpaying (50% of
Income)
267 181 448
Source: Census.gov; American Fact Finder
To address overpayment, Cudahy will pursue a variety of programs to expand affordability. With a strong prevalence of overpayment/overcrowding with large family renter households, the City will focus its new construction on multi-family units. The City adopted the Inclusionary Housing

42 2021 HOUSING ELEMENT UPDATE AMENDMENT
Ordinance in 2022 requiring the construction of affordable units with market rate projects.

Program 28 addresses implementation of the Inclusionary Housing Ordinance. Program 6 includes the City’s ongoing support and sharing of Section 8 information.

At Risk Housing
“Assisted housing units” are defined as units with rents subsidized by federal, State, or local governmental programs. California Government Code Section 65583 requires that housing elements include an inventory of all assisted rental housing units within the local jurisdiction that are at-risk of losing subsidies, mortgage prepayment, or being converted to other uses if the expiration date of their financing program is between 2021 and 2031 (i.e., 10 years from the beginning of the housing element planning period—2021). In all, there are a total of 142 units atrisk of conversion in Cudahy.

Conversion Risk
State law requires Housing Elements provide an inventory of all assisted housing units if the expiration date of their financing program is within the next ten years of the housing element planning period. These housing units are deemed to be “at-risk” of being converted to market rate units. Additionally, HCD recommends jurisdiction assess the overall potential conversion risk of all assisted housing units. However, there is no “official” or prescribed methodology to conduct the analysis. Jurisdictions, therefore, are free to decide how to conduct the analysis by choosing a method most appropriate to their jurisdiction.

There are three general cases that can result in the conversion of public assisted units:

1. Prepayment of HUD Mortgages: Section 221(d)(3), Section 202 and Section 236 — Section 221 (d)(3) is a privately-owned project where the U.S. Department of Housing and Urban Development (HUD) provides either below market interest rate loans or marketrate loans with a subsidy to the tenants. With Section 236 assistance, HUD provides financing to the owner to reduce the costs for tenants by paying most of the interest on a market rate mortgage. Additional rental subsidy may be provided to the tenant. Section 202 assistance provides a direct loan to non-profit organizations for project development and rent subsidy for low-income elderly tenants. Section 202 provides assistance for the development of units for physically handicapped, developmentally disabled, and chronically mentally ill residents.

2. Opt-outs and Expirations of Project-Based Section 8 Contracts — Section 8 is a federally funded program that provides for subsidies to the owner of a pre-qualified project for the difference between the tenant’s ability to pay and the contract rent. Opt-outs occur when the owner of the project decides to opt-out of the contract with HUD by pre-paying the remainder of the mortgage. Usually, the likelihood of opt-outs increases as the market rents exceed the contract rents.
• Clara Park Commons Senior

43 2021 HOUSING ELEMENT UPDATE AMENDMENT

3. Other — Expiration of the low-income use period of various financing sources, such as Low-income Housing Tax Credit (LIHTC), bond financing, density bonuses, California Housing Finance Agency (CALHFA), Community Development Block Grant (CDBG) HOME and redevelopment funds. Generally, bond-financing properties expire according to a qualified project period or when the bonds mature.
• Clara Park Village
• Elizabeth Court
• Clara Court
• Live Oaks Garden
Federally Assisted “At Risk” Units
At-Risk Units includes a study of all low-income housing units, which may at some future time be lost to affordable inventory by the expiration of some type of affordability restrictions. The law requires that the analysis and study cover a ten-year period, and be divided into two periods, coinciding with updates of the housing elements. Table 2.14 provides a summary of the at-risk units.

Table 2.14
Summary of At-Risk Units
Cost Of Replacement Vs Preservation
The best ways to ensure that no assisted units convert to market rate within the planning period are either to acquire and preserve all at-risk units or to construct new housing to replace those units. Either of these methods will ensure affordable controls and price restriction are extended to at-risk households under current federal, State, and local programs. In Cudahy, the cost of preserving assisted units is estimated to be less than that required to replace the units through new construction. Land prices, land availability and construction costs are generally the limiting factors to development of new affordable housing.

Project Name Address Target
Group
Number
of Units
Type of
Assistance
Expiration
Date
Current Owner At-Risk
Clara Park Village 4805 Clara St Cudahy,
CA 90201
Elderly 49 Section 8 2060 National Church
Residents
Lower
Risk
Elizabeth Court 5225 Elizabeth St
Cudahy CA 90201
Low Income 25 Low-Income
Housing Tax
Credits
2051 Corp for Better
Housing
Lower
Risk
Clara Court 5159 Clara St Cudahy,
CA 90201
Low-Income 36 Low-Income
Housing Tax
Credits
2052 Corp for Better
Housing
Lower
Risk
Live Oaks Garden 5203 Live Oak St
Cudahy, CA 90201
Low-Income 32 Low-Income
Housing Tax
Credits
2053 Corp for Better
Housing
Lower
Risk
Las Brisas
Apartments
4339 Elizabeth St
Cudahy, CA 90201
Low-Income 99 Low-Income
Housing Tax
Credits
2069 Housing Corp of
America
Lower
Risk
Source: City of Cudahy Community Development Department

44 2021 HOUSING ELEMENT UPDATE AMENDMENT
To provide a cost analysis of preserving at-risk units, costs must be determined for rehabilitation, new construction, or tenant-based rental assistance.

1. Rehabilitation– The primary factors used to analyze the cost of preserving low- income housing include: acquisition, rehabilitation, and financing. Actual acquisition costs depend on several variables such as condition, size, location, existing financing, and availability of financing (governmental and market). The following (Table 2.15) are estimated per unit preservation costs for the City.

Table 2.15
Rehabilitation Costs
Fee/Cost Type Cost Per Unit
Acquisition $266,359
Total Estimated Cost Per Unit $266,359
Source: City of Cudahy Community Development Department

2. New Construction/Replacement – New construction implies construction of a new property with the same number of units and similar amenities as the one removed from the affordable housing stock. Cost estimates were prepared by using local information and data. The construction of new housing can vary greatly depend on factors such as location, density, unit sizes, construction materials and on-site and off-site improvements. The Table 2.16 describes new construction costs in Cudahy.

Table 2.16
New Construction/Replacement Costs
Fee/Cost Type Cost Per Unit
Acquisition $266,359
Construction $155,058.75
Financing/Other $55,000
Total Estimated Cost Per Unit $476,417.75
Source: City of Cudahy Community Development Department *Construction cost =$150/SF * 41,349SF (SF that can potentially be lost) = $6,202,350/40 units =$155,058.75 construction cost per unit.

The rehabilitation of existing units instead of new construction is the most cost-effective approach towards the preservation of at-risk units.

Qualified Entities
The California Department of Housing and Community Development (HCD) keeps a current list of all the qualified entities across the State. A “qualified entity” is a nonprofit or for-profit organization or individual that agrees to maintain the long-term affordability of housing projects.

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Efforts by the City to retain low-income housing must be able to draw upon two basic types of preservation resources: organizational and financial. Qualified, non-profit entities need to be made aware of the future possibilities of units becoming at risk. Groups with whom the City has an ongoing association are the logical entities for future participation. The qualified entities that HCD list for (Los Angeles County) are listed below:

Table 2.17
Organizations

1. A Community of Friends 28. Jamboree Housing Corporation

2. Abbey Road Inc. 29. Keller & Company

3. Access Community Housing, Inc. 30. Korean Youth & Community Center, Inc. (KYCC)

4. Affordable Homes 31. Latin American Civic Assoc.

5. Affordable Housing People 32. Long Beach Affordable Housing Coalition, Inc

6. Century Housing Corporation 33. Los Angeles Center for Affordable Tenant Housing

7. Century Pacific Equity Corporation 34. Los Angeles Community Design Center

8. City Housing Real Estate Services 35. Los Angeles Housing Department/ Policy Planning Unit

9. City of Pomona Housing Authority 36. Los Angeles Housing Partnership, Inc.

10. Coalition for Economic Survival 37. Los Angeles Low Income Housing Corp. (LALIH)

11. Community Partnership Dev. Corp 38. LTSC Community Development Corporation

12. Community Rehabilitation Services, Inc 39. Many Mansions, Inc.

13. CSI Support & Development Services 40. Menorah Housing Foundation

14. DML & Associates Foundation 41. Nehemiah Progressive Housing Dev. Corp.

15. Doty-Burton Associates 42. Nexus for Affordable Housing

16. Eden Housing, Inc. 43. Orange Housing Development Corporation

17. FAME Housing Corporation 44. PICO UNION HOUSING CORPORATION

18. Foundation for Quality Housing 45. Poker Flats LLC

19. Opportunities, Inc. 46. ROEM Development Corporation

20. Francis R. Hardy, Jr. 47. Shelter For The Homeless

21. Hart Community Homes 48. Skid Row Housing Trust

22. Hollywood Community Housing Corp. 49. Southern California Housing Development Corp

23. Home and Community 50. Southern California Presbyterian Homes

24. Hope - Net 51. The East Los Angeles Community Union (TELACU)

25. Housing Authority of the City of Los Angeles 52. The Long Beach Housing Development Co.

26. Housing Corporation of America 53. West Hollywood Community Housing Corp.

27. Irvine Housing Opportunities 54. Winnetka King, LLC Source: http://hcd.ca.gov/hpd/hrc/tech/presrv/
Opportunity for Energy Conservation
Under State law, the Housing Element must include an analysis of the opportunities for energy conservation in residential development (Government Code Section 65583 (a)(7)). Planning for energy conservation is important for several reasons, but mainly because of the environmental costs and financial costs involved in energy use. This section of the report will discuss both factors briefly before moving on to discuss City programs and strategies to reduce energy use.

Greenhouse Gas Emissions
Gases that trap heat in the atmosphere are known as Greenhouse Gases (GHG). GHG are emitted by both natural processes and human activities. GHG emissions that are produced both by natural and industrial processes include carbon dioxide (CO2), methane (CH4), and nitrous oxide (N20).

The accumulation of GHG in the atmosphere regulates the earth's temperature. Without these

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natural GHG, the Earth's surface would be about 61°F cooler. However, emissions from fossil fuel combustion by humans have elevated the concentration of GHG in the atmosphere to above natural levels. Scientific evidence indicates a correlation between increasing global temperatures/climate change over the past century and human induced levels of GHG. These and other environmental changes have potentially negative environmental, economic, and social consequences around the globe.

The California Natural Resources Agency is presently developing the State's Climate Adaptation Strategy. Currently, there are no federal standards for GHG emissions and federal regulations have not been promulgated. Recently, the U.S. Supreme Court ruled that the harm associated with climate change are serious and well recognized, that the EPA must regulate GHG as pollutants, and unless the agency determines that GHG do not contribute to climate change, it must promulgate regulations for GHG emissions from new motor vehicles. To date, 12 states, including California, have set State GHG emission targets. The passage of Assembly Bill (AB) 32, the California Global Warming Solutions Act of 2006, promulgated the California target to achieve reductions in GHG to 1990 GHG emission levels by the year 2020. The environmental impact report (EIR) includes an evaluation of the existing greenhouse gas emissions within the planning area, those anticipated local greenhouse gas emissions anticipated at build-out under the implementation of the General Plan’s land use policy, and those estimated greenhouse gas emissions for 1990.

Utility Costs
In addition to reducing GHG emissions, planning for energy conservation can reduce utility and maintenance costs, which in turn, leads to housing affordability. This is particularly important to lower income households with less disposable income to pay for utilities. Depending on the age and condition of the home and the number and type of appliances, energy costs can represent more than 25 percent of overall monthly housing costs. As such, the incorporation of energy saving features, energy saving materials and efficient systems in new as well as remodeled homes is an important consideration.

In the past 20 years, rapidly increasing energy costs have contributed to the deterioration of housing affordability. Since 1970, energy costs to consumers have increased over 100 percent above the price of inflation. More recently, crude oil prices have increased to over 40 dollars a barrel. It is therefore prudent for City government like Cudahy to find ways and means to reduce energy consumption to reduce energy costs.

Energy Conservation
The City shall consider the energy efficiency of new equipment when it purchases replacement equipment and shall purchase low energy replacements whenever feasible. Through the City's development review process, new construction shall be required to demonstrate that energy conservation measures beyond those required by Title 24 have been incorporated whenever

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feasible. To assist developers in knowing what options and special grants are available, the City shall work with the Southern California Edison Company and the Southern California Gas Company to identify new low-cost construction, heating and appliance techniques and equipment that can result in substantial energy and cost savings for future tenants and owners.

The City shall make information and utility company contacts available to all applicants for building permits. The City will utilize its Development Review Process to encourage the use of low-polluting building materials in new construction. It will also utilize the Development Review Process to assure that the exposure of sensitive receptors to toxic and hazardous pollutants, as well as dust and odors is minimized or, where feasible, eliminated. The City will revise its California Environmental Quality Act (CEQA) Guidelines to ensure uniform assessment of air quality impacts of projects and will incorporate the SCAQMD significance thresholds in these Guidelines or into EIR's and negative declarations prepared pursuant to these Guidelines.

Citywide Strategies
The City works to promote energy conservation in a number of ways. The Cudahy General Plan provides policy direction under which City regulations, programs, and projects work in unison to ensure land use, transportation, and other aspects of City operations conform to energy conservation goals. Especially for housing development, the issue of energy conservation is addressed at two levels: for new construction and rehabilitation of existing structures.

2.4 FAIR HOUSING ASSESSMENT
This portion of the Housing Needs Analysis is focused on assessing the state of fair housing in the City of Cudahy, in keeping with AB 686. California jurisdictions are required to affirmatively further fair housing (AFFH) through meaningful actions “that, taken together, address significant disparities in housing needs and in access to opportunity for all groups protected by state and federal law by:
i. Replacing segregated living patterns with integrated and balanced living patterns ii. Transforming racially and ethnically concentrated areas of poverty into areas of opportunity (without displacement)
iii. Fostering and maintaining compliance with civil rights and fair housing laws iv. Note: meaningful actions include actions that will promote fair housing opportunities for low- and moderate-income tenants and tenants of affordable housing, including subsidized housing.” (Government Code 8899.50 (a)(1))
This analysis analyzes five housing issue areas:

1. Fair housing enforcement and outreach capacity

2. Segregation and integration

3. Racially or ethnically concentrated areas of poverty

4. Access to opportunity

5. Disproportionate housing needs within the jurisdiction, including displacement risk

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Outreach
Outreach Efforts
The Housing Element was prepared with public outreach and participation to the extent permissible under the restrictions of Covid 19. All public outreach activities and materials, verbal, written, Zoom meetings, and participation at community events are provided in both English and Spanish. To ensure the broadest community involvement, particularly among low-income and special needs groups, the City used several strategies, including public workshops, public hearings, focused stakeholder meeting, dedicated website, article in the City’s monthly newsletter, and community survey. Additional information on the outreach efforts is discussed in more detail in Section 1.6 Public Outreach of this Housing Element.

The City held a public workshop in August 2021, a stakeholder meeting in August 2021, Planning Commission public hearing in January 2022, and two City Council public hearings, one in February 2022 and one in March 2022. Due to the COVID-19 pandemic, all public workshops, hearings, and stake holder meeting were held virtually, which enabled community members and interested parties to attend regardless of their location. The City established a format that provided the option to call in the meeting from a landline or cell phone to participate regardless of their access to the internet to view the meeting live. The power point presentations and meeting recordings were posted on the City’s website following the workshop and public hearings.

The City conducted a virtual meeting to engage with service providers, community organizations, and local businesses. The purpose of the meeting was to solicit direct feedback on housing needs, barriers to fair and affordable housing, and opportunities for development from all community groups, not just those who are able to attend the public workshop and public hearings. The participants included several interested parties including the owner of a local bakery, a residential developer, a representative from the East Yard Communities for Economic Justice, a local school principal, and an executive from a utility company.

Additional efforts to engage the community in the preparation of the Housing Element included an article in the City’s monthly newsletter and a Housing Element community survey. The Housing Element Community Survey was conducted to engage the community at the beginning of the Housing Element update process, to provide input, and to be a part of the preparation of the update. The questions were formulated to get an understanding of who was participating in the survey, identification of the housing issues facing the City, and options to address the housing issues. Interested parties could complete the Survey online, at the City’s website. To further efforts to reach as many citizens as possible, hard copies of the survey were provided at all City facilities including: the Senior Center, City Hall, Parks & Recreation facilities, National Night Out, and Food Distribution events. Through the Housing Element Community Survey, the following two housing issues were identified as concerns of residents: the need for more affordable housing and homelessness in Cudahy.

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Local Data and Knowledge
Additionally, in 2021 the City distributed a community survey regarding the potential adoption of an Inclusionary Housing Ordinance. While most of the survey did not pertain to fair housing issues, a couple of the survey’s questions revealed concerns of residents related to AFFH issues.

These concerns include a need for affordable housing in Cudahy, a need to rehabilitate existing housing in Cudahy, and a need to integrate affordable housing throughout the City to create mixed income neighborhoods.

The City understands the concerns of residents identified through the two community surveys.

Through the programs of this Housing Element, the City addresses the community’s housing concerns.

Generally, residents expressed a great need for affordable housing in Cudahy. This Element includes several programs addressing the production of affordable housing in the City. Through Program 28 (Implementation of the Inclusionary Housing Program), the City shall begin implementation of the Inclusionary Housing Program to include a requirement that all residential and mixed-use projects throughout the City with a residential component include affordable housing units. 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. 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.

A series of programs in this Housing Element address the need to rehabilitate housing. Through Program 8 (Housing Maintenance and Conservation) of the City will continue the program for the maintenance and conservation of the existing housing stock through the sixth cycle. Program 8 specifically targets the conservation of older housing units which are in good condition to maintain the units as affordable housing options. Through Program 13 (Code Enforcement) the City shall continue code enforcement each year of the sixth cycle, focusing on property maintenance, substandard units, and illegal garage conversions. Program 23 (Housing Conditions Survey) of this Element shall conduct an annual survey starting in 2023 to identify the number of units in need to rehabilitation and replacement. Lastly, the Element’s Program 31 (First Time Homebuyers) will promote homeownership in the City, which should improve conditions of housing in Cudahy as owner occupied units are more likely to well-maintained as owners wish to maintain the value of their investment.

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Residents also identified homelessness in the City as a key concern. This Element includes several programs addressing homelessness. Through Program 9 (Hotel and Motel Resources) the City shall preserve 160 hotel and motel rooms as an emergency housing resource for homeless residents. To encourage the use of hotels by "homeless" individuals, the City continuously works with hotel managers on making rooms available for emergency/transitional housing and makes community service agencies in the area aware of the facilities. With Program 11 (Emergency, Transitional, and Supportive Housing) 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. Through Program 24 (Low Barrier Navigation Centers) 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. Lastly, Program 17 (Food Distribution) and Program 18 (Homeless Assistance) both provide City assistance to homeless residents in the form of free meals and referrals to service providers.

Additionally, for the purpose of this AFFH analysis, the City conducted outreach in the form of a set of questions to various stakeholders, including supportive services City staff and supportive service organizations to which the City refers residents (including The Whole Child, Jovenes, PATH and SHARE Housing). The City and consultant obtained answers to the AFFH questions from the City’s Supportive Services Coordinator along with Jovenes’ SPA 7 Regional Coordinator. Through Program 15, City will continue to conduct annual outreach starting in 2023 to stakeholders in an effort to obtain information regarding affirmatively furthering fair housing in Cudahy. As the City receives feedback from stakeholders, the City will annually examine and implement changes to City policies that might address and alleviate fair housing issues. Throughout this AFFH analysis, the local data and knowledge gained from the City’s Supportive Services Coordinator and Jovenes’ SPA 7 Regional Coordinator will be included where applicable.

The City maintains a distribution list of stakeholder organizations, interested private citizens and public agencies, posts public information on the City’s website and at the physical location of the meetings, and issues press releases. The venues for the public meetings were ADA accessible and served by public transportation. The City also advertised meetings, public hearings, and availability of the Housing Element in the City’s monthly newsletter. The main concerns expressed by the community were the City’s ability to provide the units identified in the RHNA for the various household income categories, provide more affordable housing, increase opportunities for homeownership, provide more diverse housing opportunities, housing for homeless individuals, and residential properties are not being maintained.

Fair Housing Enforcement and Capacity
Local Data and Knowledge
The City of Cudahy’s Supportive Service Coordinator provided information on fair housing complaints the City receives. The Coordinator found that typical fair housing complaints received by the City revolved around either rent increases or substandard housing conditions. For

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substandard complaints the Coordinator stated these complaints occur because homeowners will not make repairs for renters or the owner requests that the renter pay for repairs. The Coordinator estimates that the City receives around 156 fair housing complaints per year. The Supportive Services Coordinator found that the majority of fair housing complainants are low income, and some are seniors. No specific neighborhood was found to be the origin of a disproportionate number of fair housing complaints.

Fair Housing Complaints
Between 2013 and 2021, there was one (1) Fair Housing and Equal Opportunity inquiry in the City of Cudahy. There is a similar rate of fair housing inquiries in the surrounding region. In 2010, the number of Fair Housing and Equal Opportunity inquiries in Los Angeles County was 291. 80 of those cases, or 25% were with a racial bias, 106 of the cases or 36.4% had a disability bias. 58 of the cases, or 20% had a familial status bias. In 2020, there were 130 total cases reported. 27, or

20.7% of the cases had a racial bias, 86, or 66% had a disability bias, and 9, or 7% had a familial status bias. Figure 2.4002 depicts the comparison between 2010 and 2020.

Figure 2.400
Fair Housing and Equal Opportunity Inquiries by City (2013-2021)

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Figure 2.4001
Fair Housing and Equal Opportunity Cases – Total (2010) County Figure 2.4002
Fair Housing and Equal Opportunity Inquiry
County Data Year Total
Cases
Cases with Racial
Bias and %
Cases with
Disability Bias and %
Cases with Familial
Bias and %
Los Angeles
County 2020
130 27 or 20.7% 86 or 66% 9 or 7%
Los Angeles
County 2010
291 80 or 25% 106 or 36.4% 58 or 20%

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Figure 2.4003
Percentage of FHEO case reported in county 2010 based on race Figure 2.4004
FHEO Cases with racial bias by County 2020

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Figure 2.4005
FHEO Cases with Disability Bias 2010
Figure 2.4006
FHEO Cases with Disability Bias – 2020 – County

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One reason for the low number of fair housing complaints in Cudahy is the ethnic homogeneity of the community, which provides less opportunities for housing discrimination. Another reason may be the high level of non-English speakers and persons with low educational level who are not aware of fair housing protections. Cudahy has a large immigrant population, and according to local sources, a large undocumented immigrant population. Cudahy continues to provide City services in English and Spanish and will continue this practice through Program 15 Public Participation. According to the 2015-2019 American Community Survey (ACS), 7,190 persons (30% of the population) are foreign born and have not been naturalized as U.S. citizens. A large proportion of these people may have no legal status in the country and may be afraid to file complaints against landlords, realtors, or other people in positions of power.

The City enforces fair housing and complies with fair housing laws and regulation through a twofold process: review of City policies and code for compliance with State law and referring fair housing complaints to appropriate agencies. The City will continue to review the Zoning Code to ensure compliance with fair housing law, and continue to examine land use policies, permitting practices, and building codes to comply with state and federal fair housing laws through Program 27 (Zoning Code Review).

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

The number of fair housing complaints is small and are no discernable patterns when it comes to the impacts on protected characteristics and geographic trends. The entirety of Cudahy is predominantly occupied by lower-income Latino families.

Within the Southeast Los Angeles Cities region, the frequency of fair housing complaints is similar to the frequency in Cudahy. The surrounding cities of Bell, Bell Gardens, Downey, South Gate, and Huntington Park feature higher frequencies of fair housing complaints that the City of Cudahy.

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

Public housing comes in all sizes and types from scattered single-family houses to high-rise apartments for elderly families. In the State of California, there are approximately 1.2 million households living in public housing units, managed by about 3,300 housing agencies (HAs) In the County of Los Angeles, the Los Angeles County Development Authority manages public housing programs for the City of Cudahy and some of the Gateway Cities. As indicated on Figure 2.4007, there are no recognized public housing buildings in the City of Cudahy.

Figure 2.4006
Public Housing Buildings – Regional

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Figure 2.4007
Public Housing Buildings – Cudahy
Housing Choice Vouchers
The U.S. Department of Housing and Urban Development’s (HUD) Housing Choice Voucher (HCV) Program assists very low-income families, the elderly, and the disabled in obtaining decent, safe, and sanitary housing in the private market. Public Housing Authorities (PHAs) receive federal funds from HUD to administer the voucher program, and housing subsidies are paid to the landlord directly by the PHA on behalf of the participating family. The voucher recipient remains responsible for paying any difference that exists between the actual rent charged by the landlord and the amount subsidized by the program. Voucher recipients are responsible for finding a suitable housing unit where the owner agrees to rent under the program. Because housing assistance is provided on behalf of the family or individual, participants are free to choose their own housing, including single-family homes, townhouses, and apartments provided that the chosen housing meets the requirements of the program, and is not limited to units located in subsidized housing projects. Qualified housing may also include the family's present residence.

Furthermore, under certain circumstances, and if authorized by the PHA, a family may use its voucher to purchase a modest home. To protect the confidentiality of those receiving Housing Choice Voucher Program assistance, tracts containing 10 or fewer voucher holders have been omitted from this service. This dataset includes both tenant-based vouchers and project-based vouchers.

There are six Census Tracts in the City of Cudahy, namely: 6037534401, 6037534302, 60375344403, 6037534404, 6037534405, and 6037534406. In all the census tracts, there were

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168 Housing Choice vouchers reported. Figure 2.4008, provides a breakdown by Census Tract and percentage of population by Census Tract:

Figure 2.4008
Housing Choice Vouchers by Census Tract
Census Tract # Of Housing Choice Vouchers Percentage % of Population 6037534301 24 2.65
6037534302 29 4.30
6037534403 59 8.44
6037534404 12 1.38
6037544405 44 4.78
6037534406 0 0
Figure 2.4009 indicates that the highest utilization rate for Housing Choice Vouchers occurs in Census Tract 603754403 with 59, representing 8.44% of the Census Tract population.

Figure 2.4009
Fair Housing Vouchers by Tract - Cudahy

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Segregation and Integration
According to HCD’s AFFH Guidance segregation “means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a type of disability in a particular geographic area when compared to a broader geographic status.” Integration means a condition in which there is not a concentration of any type of persons.

Race
Cudahy is a predominately Latino community with Latinos comprising 95.2% of the City’s residents. The City’s White population is 3.1% and the Black/African American population is 0.7%.

According to HCD’s AFFH Data Viewer, all Census tracts within the City feature a strong Latino majority.

Figure 2.4010
Predominately Hispanic/Latino Population - Cudahy
The majority of Census tracts within the Southeast Los Angeles Cities region also feature a strong Latino majority. Directly surrounding the City of Cudahy, the predominance of the Latino majority is strongest. Moving South, West, and East of Cudahy the predominance of the Latino majority lessens; however, it remains significant.

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Figure 2.4011
Predominately Hispanic/Latino Population - Southeast Los Angeles Cities region History of the City of Cudahy/Local Data and Knowledge
The reasons for this pattern are many, and stem from historical and regional factors. The City of Cudahy was incorporated in November 1960. Prior to its incorporation, the City was known as Rancho San Antonio. Rancho San Antonio was purchased by Michael Cudahy, an Irish American meatpacking baron, in 1908. Michael Cudahy split Rancho San Antonio into one acre lots and sold them. These one acre lots were incredibly narrow, often measuring 50 to 100 feet in width and. 600 to 800 feet in depth. Interestingly, this narrow parcel typology remains prevalent in Cudahy, though on a much smaller scale. In most cases, these one acre lots were the size of a city block in most American towns. The size of these lots was optimal for small scale agriculture as well as raising chickens and horses. Up until World War II, Cudahy retained a rural feel in an increasingly urban region.

After World War II, blue collar White Americans settled in Cudahy due to its proximity to steel and automobile plants in the region. However, by the late 1970s the industrial plants closed down and the White population of Cudahy left the City. When jobs left, the White population left as the Southeast Los Angeles Cities region was generally disfavored due to its close proximity to industrial contaminants. Following this exodus of the White population, the Latino population moved into Cudahy.

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Local Data and Knowledge
As noted earlier, today Cudahy features a majority Latino population, which falls in line with how most community members perceive their City. Most community members, including City staff, understand Cudahy as a low income, Latino community.

Figure 2.4012
Redlining - Cudahy

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Figure 2.4013
Redlining - Southeast Los Angeles Cities region
Since the City of Cudahy was only incorporated in 1960, redlining would not have been based on the City as we now recognize. Because the area was rural during the 1930’s, most of it was unclassified by the Home Owners Loan Corporation (HOLC), except for the northwest area of the City (with a grade of Class C – “Definitely Declining”). The surrounding Southeast Los Angeles Cities region is either unclassified, or classified as either Class B – “Still Desirable” or Class C – “Definitely Declining”, with Class C being far more prevalent. Moving further west of Cudahy, the prevalence of Class C – “Definitely Declining” and Class D – “Hazardous” areas increases.

In the decades following World War II, the White population, particularly those of means, began to decamp the Southeast Los Angeles Cities region for Orange County and other more suburban jurisdictions. During the 1970s, a large, sustained wave of immigration from Latin America began and filled in the neighborhoods in central Los Angeles County that had been abandoned by the White population. More affluent cities and neighborhoods of the metropolitan area enacted stringent zoning regulations to stop population growth and severely curtail the opportunities for residents of Cudahy and similar cities to move into attainable housing in those jurisdictions. Thus, the population of Cudahy has remained highly segregated to the present day.

Median Household Income and Poverty
The entire City of Cudahy features a medium household income (ACS 2015-2019) above $30,000 and below $50,000. There is little difference in median household income when comparing the City’s block groups. Cudahy is significantly poorer than the Los Angeles County region as a whole, with a median household income of $46,642 compared to the County at $68,044 (ACS 2015-

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2019). According to 2015-2019 ACS 5-Year data, in the Southeast Los Angeles Cities region the median household income ranges from under $30,000 to $125,000. Closest to Cudahy the median household incomes are lower, ranging from under $30,000 to $87,100. As one moves further Southeast towards Downey the median household income increases, with the majority block groups featuring a median household income of over $87,100.

Figure 2.4014
Median Household Income – Cudahy

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Figure 2.4015
Median Household Income - Southeast Los Angeles Cities region According to 2015-2019 ACS 5-Year data the rates of poverty within Cudahy Census tracts range from 20% to 40% of the population. The two tracts with the highest rates of poverty are located on the eastern end of the City, along the I-710. Within the Southeast Los Angeles Cities region, the cities of Bell, Bell Gardens, and Huntington Park have similar rates of poverty. However, in the cities of Downey, South Gate, and Lynwood the poverty rates are lower, ranging from under 10% to 30%. Based on the City’s high poverty rate the City has updated Program 6 (CDBG Information) which includes coordination with the County Housing Authority and the housing voucher program. The Food Distribution event is very popular and during the COVID-19 pandemic the City adjusted distribution methods to be in compliance with State and Federal regulations.

The City has included continuation of Program 17 (Food Distribution) to ensure that low-income residents receive meals and healthy choices.

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Figure 2.4016
Poverty - Cudahy

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Figure 2.4017
Poverty - Southeast Los Angeles Cities region
Based on HUD’s Low to Moderate Income Population Census Tract Data from the AFFH Data Viewer, Census tracts in the City of Cudahy feature a population that is 61.92 to 91.17% low- and moderate-income. All but two census tracts in Cudahy feature a population which is over 75% low and moderate income. The two census tracts in the City which feature a population which is

61.92 to 75% low and moderate income are located in the northwestern corner of the City, bordering Bell and Huntington Park. Based on the same data, within the Southeast Los Angeles Cities region many cities feature similarly high concentrations of low- and moderate-income households. However, towards the City of Downey the percent of low income and moderate populations does decline.

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Figure 2.4018
Low to Moderate Income Population – Cudahy

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Figure 2.4019
Low to Moderate Income Population - Southeast Los Angeles Cities region Demographics reveal that the majority of residents in the City of Cudahy would benefit from affordable housing development in the City. Based on information from the Los Angeles County Development Authority there are no recognized public housing buildings in the City of Cudahy.

However, eligible City residents are able to access affordable housing through the Section 8 Program. It is up to eligible residents to locate participating housing units owned by landlord who will accept Section 8 vouchers. The locations of voucher recipients are identified by Census Tract; however, tracts with 10 or fewer voucher holders are not identified. Citywide there are 168 voucher recipients. There are six Census Tracts in the City of Cudahy, and in five of the Tracts there are more than 10 voucher recipients.

The City’s efforts to increase housing opportunity and improve the quality of existing housing units and neighborhoods are therefore Citywide in nature. Within this Housing Element, programs 27 and 29 include efforts to increase housing opportunity. As part of Program 26 (State Density Bonus Law) the City commits to reviewing City’s density bonus standards and amending the Zoning Code as necessary to comply with State Density Bonus Law. State Density Bonus law would impact the entirety of the City, with no particular concentrations. Through Program 28 (Implementation of the Inclusionary Housing Program and Economic Development Strategic Plan), the City commits to implementing the Inclusionary Housing Program adopted in 2022 which will create affordable housing throughout the City, and not create concentrated areas of poverty. This Housing Element’s Program 8 (Housing Maintenance and Conservation) commits to improving the quality of existing housing units and neighborhoods. Specifically, Program 8 is an

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effort to conserve older housing units throughout the City which are typically more affordable housing options.

Household Composition
The City of Cudahy’s southeastern and northwestern tracts have a higher rate of children living in households headed by a single mother. These rates are similar to rates experienced by the surrounding region.

Map 2.4020
Percent of Children in Female Householder, No Spouse/Partner Present Households (ACS, 2015-2019) – Tract
d
The majority of Cudahy’s tracts have between 21 to 40% of their adult residents living with a spouse. The westernmost tract in Cudahy features slightly high rates of adults living with a spouse, at 41 to 60%.

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Map 2.4021
Percent of Population 18 years and Over in Households Living with Spouse (ACS, 2015-2019) Tract
The majority of Cudahy’s tracts have between 21 to 40% of their adult residents living alone. The westernmost tract in Cudahy features slightly high rates of adults living alone, at 41 to 60%.

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Map 2.4022
Percent of Population 18 years and over in Households Living Alone 2015 – 2019 Mobile Homes
The City of Cudahy features 13 mobile home parks within its boundaries, with more existing outside of the City in the surrounding region.

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Map 2.4023
Mobile Home Parks (HIFLD, 2018)
Disability
According to 2015-2019 ACS 5-Year data from HCD’s AFFH Data Viewer, all but one Census tract within the City of Cudahy contains less than 10% of residents who are disabled. The Census tract which has over 10%, 11.3% specifically, of residents who are disabled is located in the middle of the City to the North, bordering the City of Bell. Based on 2015-2019 ACS 5-Year data, the City of Cudahy’s population is approximately 7.8% disabled. Within the Southeast Los Angeles Cities region, the percent of each city’s population with a disability remained low, ranging from 0% to 20%. Census tracts with higher percentages of disabled residents only existed to the North, in and around Downtown Los Angeles.

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Figure 2.4024
Disabled Residents – Cudahy

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Figure 2.4025
Disabled Residents - Southeast Los Angeles Cities region Statute requires analysis of specialized housing needs, including housing needs for seniors.

Federal housing data define a household type as 'elderly family' if it consists of two persons with either or both age 62 or over. Of Cudahy's 396 such households, 61.9% earn less than 30% of the surrounding area income, (compared to 24.2% in the SCAG region), 82.1% earn less than 50% of the surrounding area income (compared to 30.9% in the SCAG region). According to the 2020 Census, the median age of City residents was 23.8 years of age compared to 33.7 years of age for Los Angeles County. Currently the median age is 27, showing a shifting trend from a predominantly younger age group of 23.8 in 2000 to the current 2020 age group of 27. Program 20 (Senior Program Resources) and Program 21 (Persons with Special Needs) are incorporated into this element to provide housing information and assistance with locating housing in the City.

Additional Programs addressing special needs include Program 9 (Hotel and Motel Resources), Program 10 (Development Standards to All Uses) (this includes development, maintenance, and improvement of Emergency Shelters, Transitional Housing, and Supportive Housing), Program 11 (Emergency, Transitional and Supportive Housing), Program 16 (Fair Housing), Program 18 (Homeless Assistance), Program 19 (Disability Access), and Program 25 (Single Room Occupancy Units).

Supportive Services and Organizations
The City’s Supportive Services Coordinator assists many of Cudahy’s low income residents and senior residents. The City assists these residents in need by referring them out to service providers and other service organizations. The City refers residents out to the Department of

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Social Services (DPSS), People Assisting The Homeless (PATH), The Whole Child, Salvation Army, Catholic Charities of L.A., Jovenes, L.A. County Department of Mental Health, Housing Rights Center (HRC), Exodus Recovery, and Maravilla Foundation. These organizations all have different focuses in terms of the types of residents they serve, such as families, residents in need of mental health services, homeless residents, low-income residents, homeless youth, tenants, residents experiencing addiction, and more.

Local Data and Knowledge
The Supportive Services Coordinator refers about 180 residents to social service providers and organizations per year. The Coordinator notes the most prevalent issues faced by residents who are referred out include rental arrears, utility arrears, evictions, homelessness, and mental or substance abuse issues. The majority (80%) of residents referred out to service provides are lowincome, while 10% are seniors and the other 10% are residents experiencing homelessness.

Conclusion
In conclusion, this segregation and integration analysis found that Cudahy is remarkably similar to other cities in the Southeast Los Angeles Cities region. The surrounding region is significantly less well-off compared to the larger County. Within the City of Cudahy, the only segregation and integration indicator which isolates a portion of the City is the poverty indicator, which found that the eastern portion of the City (next to the Los Angeles River and I-710) features higher rates of poverty than the rest of the City.

Racially and Ethnically Concentrated Areas of Poverty
Racially and ethnically concentrated areas of poverty, also known as R/ECAPs, must meet the following definitions: 1) The area must have a non-White population of 50% or more and 2) The area must have 40% or more of the population living below the federal poverty line, or those where the poverty rate is three times the average poverty rate in the metropolitan area, whichever is less. In the surrounding Southeast Los Angeles Cities region, the cities of Bell and Huntington Park have one and two R/ECAP tracts, respectively. The number of R/ECAP tracts increases markedly to the west, in City of Los Angeles along the I-110 freeway corridor.

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Figure 2.4026
R/ECAP Tracts - Southeast Los Angeles Cities region
Based on HUD’s R/ECAP data from HCD’s AFFH Data Viewer, no Census tract in the City of Cudahy qualifies as a racially and ethnically concentrated area of poverty. According to 2015-2019 ACS (5-Year Estimates) data, 26.2% of Cudahy residents are experiencing poverty. The poverty rate in Cudahy is significantly higher than in the County of Los Angeles, wherein 14.9% of County residents are experiencing poverty according to the same data set.

In the City of Cudahy, the R/ECAP score is 0, however, there are pockets in the County of Los Angeles with R/ECAP scores of 1.

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Map 2.4027
TCAC Area of High Segregation and Poverty (2020) – Block Group High Segregation and Poverty Tracts
Despite the absence of R/ECAPS in the City, the Fair Housing Task Force, made up of the California Tax Allocation Committee (TCAC) and HCD, has identified tracts of high segregation and poverty in Cudahy. These two tracts are located in the eastern portion of the City, closest to the I-710 freeway. Tract 5338.06 is located on the easternmost end of the City. This tract includes the right of way in Cudahy which borders the I-710 freeway, the I-710 freeway, and residential areas in the City of Bell. Therefore, since this tract does not include any residences in Cudahy, this high segregation and poverty analysis will only evaluate Tract 5343.02. Tract 5343.02 is located in the southeastern portion of the City, close to the I-710 freeway and abutting the City of South Gate.

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Figure 2.4028
TCAC High Segregation and Poverty Tracts - Cudahy
According to high segregation and poverty measurement, the threshold for poverty is 30% of the population living below the poverty line and the location quotient is essentially a measure of the concentration of race in a small area compared to a county level. Tract 5343.02 has a Latino population with a strong majority, at 96.6%, which is common throughout the entire City. The poverty rate for this tract is 31.2%, which is the highest poverty rate for a Census tract in the City.

It also features low levels of educational attainment; it ranks the lowest of all six tracts in residents with a high school diploma or higher and in residents with a bachelor’s degree or higher.

There are also TCAC maps rating the economic score, environmental score, and education score of Cudahy Census tracts. These maps are included within this AFFH analysis.

Median Household Income, Household Size, Familial Status, and Disability In most other respects, however, Tract 5343.02 resembles the City at large. It has a median household income of $49,833 which is higher than the City’s median household income of $46,642 (although much lower than the County’s median household income of $68,044). It ranks 5th among the City’s six Census tracts, in terms of the number of foreign born non-naturalized residents. Tract 5343.02 ranks 3rd among the City’s six Census tracts, in terms of the largest average household size, with an average household size of 4.46 people. This average household

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size is similar to the City average household size of 4.2 people and far larger than the Los Angeles County average household size of 2.99 people. In regard to female headed households (no spouse/partner present) with children, tract 5343.02 ranks third highest compared to all six City Census tracts. Tract 5343.02 ranks fifth highest in the City with 175 households with one or more persons 65 years of age and over. The high segregation and poverty tract ranks 4th out of the six tracts (1 meaning the highest percentage of disabled residents and 6 meaning the lowest percentage of disabled residents) in terms in the percentage of disabled residents among the six Census tracts in the City.

Housing Quality, Park Need
Based on a windshield survey, the condition of residential buildings within the City’s high segregation and poverty tract is similar to the condition of residential buildings in non-high segregation and poverty tracts throughout the City of Cudahy. Generally, access to parks and open spaces within the City of Cudahy is low for residents. According to the Parks Needs Assessment for the City of Cudahy there are four parks in the City: Lugo Park on the western side of the City, Clara Park in the northern central portion of the City, River Pocket Park in the far eastern portion of the City, and Cudahy Park in the southeastern corner of the City (located within high segregation and poverty tract 5343.02). These four parks amount in 19.8 park acres in the City, which amounts to 0.8 park acres per 1,000 residents in Cudahy. This 0.8 park acres to 1,000 residents ratio is extremely low compared to the County average of 3.3 park acres per 1,000 residents. However, since the City is relatively small, approximately 82% of Cudahy residents live within a half mile of a park. The countywide average is 49% of County residents living within a half mile of park.

The same Parks Needs Assessment found the park need across the City. The assessment calculates park need by taking into account park acre need, distance to parks, and population density. According to the park need map, the entire City of Cudahy features either a very high park need or high park need. The City’s one high segregation and poverty tracts features very high park need (even though this tract contains Cudahy Park), as do the areas around most of the edges of the City. The central portion of the City features high park need. Generally, within the Southeast Los Angeles Cities region park need is high and very high, while areas outside of the Southeast Los Angeles Cities region feature lower rates of park need.

Local Data and Knowledge
Cudahy Park, located within the high segregation and poverty tract, serves as a hub for community events and activities. The park features the following amenities: a playground, basketball courts, meeting rooms, a multipurpose grass field, open space, picnic tables, a skate park, a tennis court, trails, and baseball/softball diamonds. Additionally, the Cudahy Park complex includes community amenities such as City Hall, the Los Angeles County Public Library – Cudahy, Bedwell Hall (a public assembly/banquet hall available for rent by residents), and the City Council and Commission chambers.

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

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

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

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

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

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

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

What this means for the City of Cudahy is that in the areas of environmental and social justice, a history of unfair treatment of communities, predominantly communities of people of color and/or low-income residents can be remedied. These communities have been subjected to disproportionate impacts from one or more environmental hazards, socio-economic burdens, or

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both. Residents have been excluded in policy setting or decision-making processes and have lacked protections and benefits afforded to other communities by the implementation of environmental and other regulations, such as those enacted to control polluting activities.

Map 2.4029
SB 535 Disadvantaged Communities
Environmental Conditions
The City of Cudahy’s high segregation and poverty tract in the southeast corner of the City along the I-710 freeway features a Healthy Places Index (HPI) score of 17.9, which indicates that the environment in the tract is slightly healthier than the average HPI score of 12.9 in Cudahy.

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

The Healthy Places Index is structured to highlight the community conditions shaping health outcomes in neighborhoods across California. It is designed to showcase extraordinary data that properly frames and recognizes equity issues communities are experiencing, while also offering policy solutions to improve health for all. To ensure that everyone can live a healthy life, the HPI

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is a crucial resource for guiding informed prioritization of public and private investments, resource allocations, program planning and service delivery.

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

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

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

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

Figure 2.4030
Healthy Places Index Map - Cudahy

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Figure 2.4031
CalEnviroScreen Pollution Burden Map – Cudahy
Figure 2.4032
TCAC Opportunity Areas 2021 Environmental Score by Tract

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The TCAC Opportunity Area Environmental Score map finds that the tracts in the south and east of the City feature worse environmental conditions, compared to the tracts in the center and west of the City, which feature more favorable environmental conditions.

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.

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

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

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

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

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Educational Attainment, Access to Education
Figure 2.4033 illustrates the educational outcome disparity within the Southeast Los Angeles Cities region. According to the US Census 42.7% of Cudahy’s residents have less than a high school education. The percentage of high school graduates or higher of persons residing in Cudahy age 25 years or older is 50.7%. The percentage of residents with a bachelor’s degree or higher is

6.6%. Both the City of Cudahy and the Los Angeles Unified School District provide services in English and Spanish.

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

Figure 2.4033
Education Score Map (More Positive Outcome versus Less Positive Outcome) – Southeast Los Angeles Cities region

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Figure 2.4034
TCAC Opportunity Areas (2021) Education Score – Tract
The TCAC Opportunity Areas Education Score map reveals that the City’s northwesternmost tract features the most favorable education outcomes. Since this map challenges the findings of the prior map both maps are presented for consideration.

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

Youth Social Services/Local Data and Knowledge
Related to Cudahy’s youth residents, the service organization Jovenes provided local data and knowledge regarding the Cudahy youth they serve. Jovenes provides services to youth experiencing housing instability, such as interim housing (bridge housing for 3-6 month stays), transitional housing (24 month stay), Time-Limited Subsidy (permanent housing), Permanent Supportive Services, Employment Services, Intensive Case Management Services, Transportation, and Linkage to Benefits. Jovenes SPA 7 Regional Coordinator estimates the organization serves approximately 2 to 5 young adults from Cudahy per year, most of whom are lower-income and

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experiencing homelessness with disabilities and substance abuse. The Coordinator identified areas along the Los Angeles riverbed/under bridges as hotspots where youth have sheltered prior to being referred to Jovenes. The Coordinator mentions housing is available for Cudahy youth, however, the available housing is far away from the City which sometimes presents a challenge in placing youth.

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

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

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Figure 2.4035
Job Proximity Map – Southeast Los Angeles Cities region Most protected classes (such as race, color, religion, sex/gender, gender identity/expression, sexual orientation, marital status, medical condition, veteran status, national origin, ancestry, disability, age over 40, and more) do not live anywhere specific within the City of Cudahy. In fact, the City presents very similar population characteristics in each Census tract. Due to this, the City’s protected groups experience the same difficulties in access to jobs within the region.

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

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

According to HCD’s AFFH Data Viewer (Smart Locations Database, 2018), the majority of Cudahy is located within a 45-minute transit commute of 100,001 to 250,000 jobs. The only area with reduced accessibility is located in the eastern portion of the City, bordering the I-710 and Los Angeles River. Within the surrounding area, the accessibility is similar to that in Cudahy. However, accessibility by transit greatly increases to the north and northwest of Cudahy. According to the same data set, the entire City of Cudahy is located within a 45-minute drive of 345,000 to 515,000

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jobs. The region features the same accessibility to jobs by car. The accessibility by car significantly increases for residents of Downtown Los Angeles.

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

Economy
Figure 2.4036 identifies the economic scores for the City of Cudahy by Census tract. One tract, located south of the city, has an economic demand score between 0.51 and 0.75. Two tracts in the north and northeastern portions of the city have a score below 0.25. The tracts located in the southern and western portions of the City have scores between 0.25 and 0.50.

Figure 2.4036
TCAC Opportunity Score Areas 2021 – Economic Score – Tract Transit Accessibility
Cudahy is serviced by two Metro bus lines, the 260 and 611, which run along various thoroughfares throughout the city such as Santa Ana Street, Wilcox Avenue, Atlantic Avenue, and Cecilia Street. Additionally, the City of Cudahy runs the Cudahy Area Rapid Transit system, which runs daily throughout the City from 7 am to 5:45 pm, with a bus running every hour. The bulk of

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Cudahy residents are within ½ mile of public transit. Transit service exhibits a moderate frequency. For example, Metro route 260 provides north-south service along Atlantic Avenue at roughly 15-20 minute frequency. Metro provides local service to Huntington Park and its surrounding Southeast Los Angeles Cities region (such as Cudahy, Maywood, and Bell) with Route 611 every hour. The greatest transit accessibility is therefore located near the intersection of Atlantic Avenue and Santa Ana Street. Cudahy is considered “Somewhat Walkable”, scoring 62 of 100 by WalkScore.com. It is also considered “Bikeable”, scoring 61 of 100.

The future Metro West Santa Ana Branch Line will improve Cudahy residents’ access to regional transit with one station at Firestone and Atlantic Avenues and one station at Florence and Salt Lake Avenues. Residents, particularly those in the southern 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.

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

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

Additionally, according to HCD’s AFFH Data Viewer (Caltrans 2022 data), the majority of the City of Cudahy is located within a ½ mile of a high quality transit area and there are multiple high quality transit stops along Atlantic Avenue and Wilcox Avenue in the City.

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

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

Disability by age groups is as follows: 205 disabled residents 18 years old and under, 1,159 disabled residents aged 19-64, and 610 disabled residents aged 65 and up. This reveals that a

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large portion of disabled residents exist within each age group in Cudahy, meaning that the needs of disabled residents must be addressed for young people, adults, and seniors. However, the demand for disabled services for adults and seniors is far larger than the demand for disabled services for minors. The Census tract to the north, directly in the center of Cudahy, features a higher concentration of disabled residents than the other Census tracts. However, this one tract is only 1.8 percent higher than the percent of the population with a disability in the tract which ranks second in terms of the concentration of disabled residents.

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

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

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

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

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

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

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

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

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

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

Local Data and Knowledge
City staff and community members recognize that the southeastern portion of the City is located in greater proximity to environmental hazards, compared to the rest of the City. Due to this knowledge, the City is sensitive to issues relating to industrial uses in South Gate and is working with city of South Gate to address issues. The City has already taken steps to reduce environmental contamination in the City, through a ban on trucking terminals in the City and a tree planting requirement for multifamily residential development. 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.

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

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

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Shopping Center abutting the southern boundary of Cudahy, close to the future WSAB station.

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

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

Conclusion
In conclusion, the access to opportunity analysis found that the City of Cudahy is similar to other cities in the Southeast Los Angeles Cities region in terms of accessibility to education opportunities, a wide variety of jobs, open spaces, healthy environments, and more. The analysis found low levels of educational attainment citywide. Additionally, the analysis found jobs are not easily accessible from the City, as the Southeast Los Angeles Cities region does not feature any job centers. Professional jobs are even more difficult to access from Cudahy. In terms of accessibility to healthy living conditions, the analysis found that some of the City’s housing stock is in need of major repairs. Lastly, the entire region cannot be considered a healthy environment, due to the industrial uses in the region along with the location of the I-710.

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

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

Figure 2.4037
Homeowner Cost Burden – Cudahy

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Figure 2.4038
Homeowner Cost Burden – Southeast Los Angeles Cities region Within the Southeast Los Angeles Cities region, the majority of Census tracts feature high percentages of cost burned homeowner households, just like in Cudahy. The percentage of cost burdened homeowner households decreases further South into Downey.

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

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Figure 2.4039
Renter Cost Burden – Cudahy

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Figure 2.4040
Renter Cost Burden – Southeast Los Angeles Cities region Within the Southeast Los Angeles Cities region, the majority of Census tracts feature high percentages of cost burned renter households, just like in Cudahy. The percentage of cost burdened renter households decreases further Southeast into Downey.

In response to overpayment, in 2022 the City adopted the Inclusionary Housing Program requiring inclusion of affordable units in market rate residential projects and the City has included Program 3 (Accessory Dwelling Units), and Program 5 (Affordable Housing Incentives). Currently, the City has a rent increase moratorium on multifamily housing, through January 18, 2023. This moratorium was put in to give the City’s Rent Control Ad Hoc Committee (Program 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 resulting in less tenant harassment and evictions, which reduce the number of fair housing complaints received by the City.

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

The tracts with the highest rate of overcrowding (36%) in Cudahy are located on the eastern side of the City. Two of Cudahy’s Census tracts feature severely overcrowded households. Most

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significantly, the Census tract in the southeastern corner of the City features the highest percentage of severely overcrowded households, at 5%.

Figure 2.4041
Overcrowding – Cudahy

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Figure 2.4042
Overcrowding – Southeast Los Angeles Cities region
Overcrowding is also an issue within the larger Southeast Los Angeles Cities region. Within the City of Bell, all census tracts except one feature overcrowding rates over 20%. Additionally, all Bell census tracts but two feature severely overcrowded households. All but one census tract in the City of South Gate feature overcrowding rates over 20%. The one remaining census tract is an almost exclusively industrial area. In the City of South Gate approximately half of the cities census tracts feature severely overcrowded households. All but one census tract in the City of Huntington Park feature overcrowding rates over 20%. In the City of Huntington Park, seven of the City’s sixteen census tracts featured severely overcrowded households.

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

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Figure 2.4043
Severe Overcrowding – Cudahy

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Figure 2.4044
Severe Overcrowding – Southeast Los Angeles Cities region In response to overcrowding in the City, in 2018, as part of the City’s comprehensive General Plan and Zoning Code update, the City rezoned properties, increasing densities to encourage higher density residential development. The City adopted the Inclusionary Housing Program in 2022 to require the construction of affordable units within market rate projects and has amended Program 3 (Accessory Dwelling Units) and added Program 25 (Single Room Occupancy Units) to further affordable housing opportunities.

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

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

Local Data and Knowledge
Over half of the City’s housing stock was built prior to 1960. A citywide housing condition survey conducted in 2013 found that the majority of the housing units (5,403 units) in the City are in

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“Good” Condition, meaning no repairs were warranted. The same survey found 246 units in the City in “Minor Fix-Up/Paint-Up” condition, meaning only a new paint job or minor repairs were needed. Approximately 118 housing units were found to need “Major Repairs”, such as replacement of roof. Lastly, 3 housing units were found to be “Beyond Repair”. In addition, the survey conducted for the Housing Element found the “need to rehabilitate existing housing in Cudahy” to be a major concern of residents. Community members along with City staff recognize that the condition of housing in the City is not optimal. It is a priority of this Housing Element to improve the condition of existing housing throughout the 6th cycle.

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

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

As far as protected classes and the homeless population goes, this data is available at the Special Planning Area level. Service Planning Area 7 features 3,343 male homeless residents, 1,417 female homeless residents, 21 gender non-binary homeless residents, and 32 transgender homeless residents. Clearly, males make up the majority of homeless residents in SPA 7. As for sexual identity, the majority of homeless residents in SPA 7 identify as straight. Approximately 4,440 homeless residents identify as straight, 83 homeless residents identify as gay or lesbian, 134 homeless residents identify as bisexual, and 124 homeless residents identify as questioning.

As for race, the majority of SPA 7 homeless residents are Hispanic/Latino. Approximately 3,487 homeless residents are Hispanic/Latino, 618 homeless residents are Black/African American, 623 homeless residents are White, 3 homeless residents are American Indian, 24 homeless residents are Mixed-race, 14 homeless residents are Asian, and 12 homeless residents are Native Hawaiian.

As for medical conditions, the two most prevalent conditions are substance abuse disorders and serious mental illness. Approximately 589 homeless residents have physical disabilities, 1,192 homeless residents have substance abuse disorders, 637 homeless residents have a serious mental illness, 255 homeless residents have a developmental disability, and 21 homeless residents have HIV or AIDS. Approximately 110 homeless residents in SPA 7 are veterans. Lastly, approximately 50% of all SPA 7 homeless residents are over 40 years of age.

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The demographics of the homeless population in SPA 7 reflect most of the demographics of the typical homeless population or the population at risk of homelessness in Los Angeles County. The only difference is that SPA 7’s homeless population is majority Latino, which matches the majority Latino population of the Southeast Los Angeles Cities region. Aside from race, there are no remarkable characteristics that SPA 7’s homeless population has that the county’s homeless population does not. There is an overlap between the City’s homeless population and the following protected class group, extremely low income households. The majority of homeless residents are unable to afford market rate housing due to their status as extremely low income households. Homeless residents and extremely low income households both are in need of affordable housing, the production of which is a priority within this Housing Element.

Program 9 (Hotel and Motel Resources) says that there are 160 hotel rooms which are sufficient to accommodate the local demand for shelter. When necessary, the City works with these hotel operators to place homeless residents in the City into these 160 hotel rooms. City staff states that the current demand for shelter is met by the Bell Salvation Army Shelter, in the neighboring City of Bell. The City of Cudahy works with the Bell Salvation Army Shelter to house Cudahy residents when the demand arises. At this time, there is not a demand to house homeless residents in local hotel rooms.

Local Data and Knowledge
The City of Cudahy employs a Homeless Services Liaison and a Supportive Services Coordinator.

Together these employees partner up with service providers, nonprofit agencies, and local businesses to offer and connect the homeless population or anyone that could experience homeless the appropriate services. They are also providing continuous information on available resources, workshops, and training. While there are no service providers or non-profit agencies focused on the homeless located in Cudahy proper, there are many providers and agencies that serve the City of Cudahy. These include the Salvation Army, which operates two local shelters in Long Beach and Bell which serve Cudahy residents. In addition, The Whole Child located in Whittier serves homeless families in Cudahy. Jovenes, located in Boyle Heights, serves homeless youth in Cudahy. These are just a few of the service providers and nonprofit agencies which serve Cudahy. Others include the LA County Department of Mental Health, LAHSA, SHARE Housing, and PATH.

According to City staff, Cudahy’s unsheltered homeless residents concentrate in and around the City’s parks. The majority of the contact that City staff has with unsheltered homeless residents occurs in the City’s parks. The City has four parks, Cudahy Park, Clara Street Park, River Pocket Park, and Lugo Park. These three parks are distributed throughout the City. Cudahy Park is located in the southeastern portion of the City, Clara Street Park is located in the northern central portion of the City, and Lugo Park is located in the western portion of the City. Additionally, the City’s Code Enforcement Department and Supportive Services Coordinator collaboratively do Homeless Outreach at local parks a minimum of 4 times a month.

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Social Vulnerability
According to the Centers for Disease Control, social vulnerability “refers to the resilience of communities (the ability to survive and thrive) when confronted by external stresses on human health, stresses such as natural or human-caused disasters, or disease outbreaks. Reducing social vulnerability can decrease both human suffering and economic loss.” “Socially Vulnerable Populations include those who have special needs, such as, but not limited to, people without vehicles, people with disabilities, older adults, and people with limited English proficiency.” “The CDC/ATSDR SVI ranks each tract on 16 social factors, including poverty, lack of vehicle access, and crowded housing, and groups them into four related themes. Each tract receives a separate ranking for each of the four themes, as well as an overall ranking.” According to the map below, the majority of the City of Cudahy features a high level of social vulnerability, as proven by the higher vulnerability classification (a rating over 0.75). The only portion of the City with a lower level of social vulnerability is the westernmost tract in the City, which features a social vulnerability rating between 0.5 and 0.75.

Figure 2.4045
Social Vulnerability Index (CDC, 2018) – Tract
Displacement Risk/Local Data and Knowledge
UC Berkeley’s Urban Displacement Project classifies Census tracts in terms of their “displacement typology.” According to the data, Cudahy ranks in the middle of its severity classification.

Cudahy’s neighborhoods are classified as “low-income/susceptible to displacement,” “ongoing displacement,” and “early/ongoing gentrification”. The contribution of new development to gentrification is probably minor, perhaps being limited to direct displacement of people affected by demolition of older housing in order to construct new housing. The survey conducted for this Housing Element found housing affordability to be a major concern of residents. Concerns regarding housing affordability are often accompanied by concerns of displacement in the event that residents can no longer afford the rent or home prices in Cudahy. The City’s recently adopted

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Inclusionary Zoning Ordinance, as well as Program 4 (Replacement Housing) will ensure that new affordable housing is created where ever older housing is demolished to construct new units, and will give those displaced opportunities to occupy new units.

Figure 2.4046
Displacement Risk – Cudahy
New development in Cudahy has not significantly altered the desirability of the broader community to the point where widespread gentrification is evident. Rather, displacement in Cudahy is driven by rising regional housing prices. Prices for housing have been rising throughout the Los Angeles region and the City of Cudahy is no exception. Thus, while Cudahy might not be experiencing disinvestment-driven displacement, investment-driven displacement, or disasterdriven displacement, the City is still experiencing significant levels of displacement pressure due to high housing costs.

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Figure 2.4047
Displacement Risk – Southeast Los Angeles Cities region The greater Southeast Los Angeles Cities region does feature displacement risk, ranging from early/ongoing gentrification, low-income/susceptible to displacement, ongoing displacement, advanced gentrification, and at risk or becoming exclusive. Those cities actively experiencing some level of gentrification are located closest to Cudahy within the region and they include cities such as South Gate, Bell Gardens, Bell, Maywood, and Huntington Park. Communities such as Lynwood, Bellflower, Downey, and Paramount, on the other hand have a lower gentrification risk, as these communities are more stable moderate/mixed income and at risk of becoming exclusive. However, gentrification is much less pronounced in these communities than in other parts of the Los Angeles region such as Mid-City, South Los Angeles (Crenshaw area), or Boyle Heights.

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

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Figure 2.4048
Renter Vulnerability – Cudahy

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Figure 2.4049
Renter Vulnerability – Southeast Los Angeles Cities region The Urban Displacement Project classifies Cudahy’s renter vulnerability as very high at 7-10 on a 10-point scale due to the population’s high rent burden, overcrowding, and concentration of employment in low-wage sectors. The Urban Displacement Project classifies the Southeast Los Angeles Cities region’s renter vulnerability as 3-10 on a 10-point scale. However, most Census tracts within the region rank from 7-10, due to the population’s high rent burden, overcrowding, and concentration of employment in low-wage sectors.

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Figure 2.4050
Sensitive Communities (UCB, Urban Displacement Project) Additionally, according to UC Berkeley’s Urban Displacement Project the City of Cudahy is considered a community vulnerable to displacement, as are most communities in the surrounding region.

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

Sites Inventory
The opportunity map prepared the California Tax Credit Allocation Committee (TCAC) and the California Department of Housing and Community Development were reviewed by the City. The

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

Using the statewide opportunity area map and indicators of segregation, displacement risk, and access to opportunity as overlays to the City’s site inventory, the City was able to identify if the sites identified in the inventory to accommodate the lower-income RHNA disproportionately concentrate these units or increase patterns of segregation. Although the entire City of Cudahy is characteristic of low income, low education levels, overcrowding, overpayment, and vulnerable to the potential effects of pollution, a review was still completed to identify if there was any indication that the RHNA sites were concentrated in one specific area of the City or not. This Housing Element features 31 sites within its site inventory, including available sites (labeled with a site number corresponding to Appendix A on the map below), pending sites (labeled P# on the map below), and constructed sites (labeled C# on the map below).

Figure 2.4051
Cudahy Site Inventory by Income Level

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Figure 2.4052
Cudahy Site Inventory Split by Three Income Levels
Eleven of the 31 inventory sites accommodate or are expected to accommodate lower income housing. Three of these eleven sites are pending sites, two sites are constructed sites, and the remaining six sites are available sites.

One of the eleven sites will accommodate 100% affordable housing, except for one above moderate income manager’s unit. This 100% affordable development is the pending 179 unit senior affordable housing project (4610 Santa Ana Street). The progress towards the development of this senior housing project is detailed within Chapter 4 of this Element. This 100% affordable pending development (P1) is located in the southwestern corner of the City.

The two other pending sites which accommodate lower income housing (P3 and P7) are located in the southeastern corner of the City and the central northern portion of the City respectively.

The two constructed sites which accommodate lower income housing (C3 and C4) are located in the central northern portion of the City and the southwestern corner of the City respectively.

Site Number Lower Income Units Moderate Income Units Above Moderate Income Units Total Units P1 179 0 1 180
P2 0 0 3 3
P3 1 0 3 4
P4 0 0 8 8
P5 0 0 1 1
P6 0 0 3 3
P7 4 0 38 42
C1 0 0 1 1
C2 0 0 4 4
C3 5 6 9 20
C4 6 0 42 48
C5 0 0 4 4
1 0 4 24 28
2 0 0 2 2
3 0 0 1 1
7 0 10 0 10
9 0 7 0 7
10 0 6 0 6
11 0 10 0 10
12 0 6 0 6
13 1 1 14 16
15 0 3 0 3
16 0 2 0 2
17 2 1 24 27
18 2 1 24 27
19 2 1 19 22
21 0 3 18 21
22 0 3 18 21
23 2 1 16 19
24 0 16 0 16
25 22 0 66 88
Total 226 81 343 650

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The six available sites which accommodate lower income housing are sites 13, 17, 18, 19, 23, and

25. Site 13 is located in the northeastern corner of the City. Sites 17, 18, 19, and 23 are located in the central northern portion of the City. Site 25 is located in the central southern portion of the City along Atlantic Avenue.

This analysis of all eleven sites which accommodate lower income housing found that inventory sites with lower income housing units are located throughout the City, including 3 of the City’s 4 corners as well as the northern and southern center of the City. Two sites accommodating 185 lower income units are located in the southwestern corner of the City. One site accommodating 1 lower income unit is located in the southeastern corner of the City. Six sites which accommodate 17 lower income units are located in the central northern portion of the City. One site accommodating 1 lower income unit is located in the northeastern corner of the City and one site accommodating 22 lower income units is located in the central southern portion of the City. The southwestern corner of the City accommodates the majority of the inventory’s lower income units due to the pending development of 179 lower income senior units. However, it remains true that the inventory includes lower income units throughout the City, including 3 of the City’s 4 corners and the northern and southern center of the City.

The inventory’s eleven sites which include lower income housing are located in close proximity to a variety of services and connections which are utilized by Cudahy’s lower income residents.

The City of Cudahy provides several services and connections utilized by lower income residents.

The City’s Senior Center is located within Clara Park’s Turner Hall, located in the central northern portion of the City. The Senior Center is located in close proximity to 17 lower income units within the inventory accommodated within six sites. The Senior Center is located within a 15 minute walk of the the remaining five sites accommodating lower income units, including the 179 unit lower income senior development. Eight of the eleven sites accommodating lower income units are located within a ½ mile radius of the Senior Center.

The City of Cudahy has four parks located in the central western portion, southeastern portion, central northern, and northeastern portion of the City. All sites accommodating lower income housing except two are located within a 5 minute walk of one of Cudahy’s parks. Site P1 and 25, located in the southwestern corner and central southern portion of the City are located within a 10 minute walk of Cudahy’s Lugo Park. Through Program 35 (Open Space Development), during the sixth cycle the City will encourage new developments within the Entertainment Zone to provide public open space for the benefit of Cudahy’s residents. The Entertainment Zone is located in the central southern portion of the City, which happens to be an area of high park need in Cudahy and includes sites P1 and 25.

Most of Cudahy’s parks feature plentiful free and low-cost amenities and services for residents, including community centers, senior centers, picnic areas, playgrounds, facility rentals, baseball diamonds, soccer fields, basketball courts, and more. All eleven sites accommodating lower income housing are located within a ½ mile radius of one of Cudahy’s parks.

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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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2021 HOUSING ELEMENT UPDATE AMENDMENT
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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2021 HOUSING ELEMENT UPDATE AMENDMENT
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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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
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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CITY OF CUDAHY 2021 HOUSING ELEMENT UPDATE
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 improvementsthrough 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.