Cudahy City Council
March 18, 2025

STRATEGIC PLAN FOR A THRIVING COMMUNITY 89

LOCAL ECONOMY

HOUSING STABILITY & RENT BURDEN

TOTAL JOBS
9,743

EMPLOYMENT BY SECTOR
Private Sector 7,821
Public Sector 786
Self-Employed 685
Private Non-Profit 411
Unpaid Family Workers 40
LOCAL ECONOMY SNAPSHOT [2023]
Commercial Vacancy Rates 6.60%
Commercial Rents per SF $27.45
Sales Tax Revenue 0
TENURE
Owner-Occupied 688
Renter-Occupied 5,084

HOUSING BURDEN BY CENSUS TRACT
5344.03 24%
5344.04 26%
5344.05 32%
5344.06 31%
5343.02 32%
5343.01 25%

MEDIAN GROSS RENT
$1,619
CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN 89
Cudahy Available Housing Prices

90 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 91

3.3 COMMUNITY PRESERVATION

INDICATORS
Climate and Economic Justice
Former President Joe Biden issued Executive Order 14008 in 2021, directing the Council of Environmental Quality [CEQ] to develop a screening tool called the Climate and Economic Justice Screening. This tool features an interactive map that identifies census tracts that are overburdened or underserved using indicators such as climate change, energy, health, hous- ing, legacy pollution, transportation, water and wastewa- ter, and workforce development. Census tracts identified as “disadvantaged” communities [DACs] experience one or more of these indicators and are considered environmentally overburdened and underserved.

The Climate and Economic Justice methodology is deter-
mined if the census tracts meet the thresholds for at least one of the categories of environmental burden and if they are on land within the boundaries of Federally Recognized Tribes.

In addition, if a census tract is entirely surrounded by DACs and is above 50% of low-income, it is considered “disadvan- taged.” Federal agencies are utilizing this tool to help deter- mine where to focus mitigation and improvements, such as the Justice40 Initiative, which directs 40% of the overall bene- fits of certain Federal investments – including investments in clean energy and energy efficiency, clean transit, affordable and sustainable housing, training and workforce development, the remediation and reduction of legacy pollution, and the development of clean water infrastructure – to flow to DACs.

Through this screening tool, the City of Cudahy is identi- fied as a disadvantaged community [DAC] and qualifies to receive federal funding. Regarding census tract 5344.03, the closest census tract in Cudahy to the proposed Salt Lake/ Florence Station, this tract met six out of the possible eight indicators used to determine if a tract is “disadvantaged”.

In the “workforce development” category, this tract was in the 98th percentile for linguistic isolation, which means that a majority of households in Cudahy have no one over the age of 14 that speaks English very well. Additionally, 50% of Cudahy residents above the age of 25 possess less than a high school diploma. In the “transportation” category, this tract was identified as having higher-than-average traffic proximity and volume. This tract was also determined to be in the 90th percentile with regards to “green space”, which indicates this Census tract is severely lacking in green space.

Census tract 5343.01, the closest census tract in Cudahy to the proposed Firestone Station, was determined to be disad- vantaged in five out of eight possible categories. Most notable are in the “workforce development” and “housing” categories, where it was determined that the linguistic isolation rating was in the 96 percentile. It was also determined that 48% of the residents in this tract who are 25 years or older have less than a high school diploma. In the “housing” category, one indicator revealed that this tract lacks green space, with most of the land covered by artificial materials like concrete or pavement, ranking it in the 97th percentile.

Eviction Lab
The Eviction Lab at Princeton University has published the first-ever dataset of evictions in America, going back to 2000.

The Eviction Lab has now publicly released this data, allowing planners and policymakers to understand more about hous- ing, eviction, and poverty by studying evictions over time and comparing eviction rates of different neighborhoods, cities, and states. While the data is currently limited to 2000 to 2018, it provides a comprehensive understanding of how residential households are threatened by eviction. Aside from eviction rates, the Eviction Lab team combined these records with demographic information from the Census to help paint a better picture of which communities are most vulnerable and are experiencing the highest eviction rates.

According to Eviction Lab, in 2018 [which is the most recent data available], Cudahy experienced 37 eviction filings, which was 16 less than the previous year. With an average population of about 24,000, Cudahy had an annual average eviction rate of 0.8%, which is 1.04% below the national average. Similarly, in 2018, Los Angeles County had an eviction rate of 0.8% [a total of 14,900 eviction filings]. In Cudahy, there were a total of 0.1 evictions per day for about 24,000 residents, while Los Angeles County had an average of 39.2 evictions per day per 10 million residents.

Evictions are a crucial metric for measuring displacement, reflecting the vulnerability of individuals and businesses forced to relocate. In the City of Cudahy, there are currently robust anti-displacement policies that primarily safeguard residents, particularly renters, from the threat of eviction.

While residents benefit from these protective measures, the same cannot be said for businesses in the area. Businesses often face a distinct lack of tenant protections that exposes them to high displacement risks without the same safeguards provided to residential tenants. This disparity between the two groups shows the importance of extending anti-dis-
placement measures in Cudahy to encompass residential
and commercial tenants.

CalEnviroScreen 4.0
The public health of a community is deeply entwined with the preservation of that community, especially in Cudahy where environmental and socioeconomic challenges are signif- icant. The latest version of the CalEnviroScreen 4.0 tool, uses various environmental health, public health, and sociode- mographic indicators to assess and rank the environmental vulnerability of communities statewide. Each census tract receives a score determined by two categories – pollution burden and population characteristics – and includes 21 indi- cators of study. Using their methodology, the tool scores each California census tract and determines where the State will prioritize environmental mitigation strategies and investments.

Therefore, a higher CalEnviroScreen score indicates greater environmental and socioeconomic vulnerability and burden.

Environmental Burden

92 CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN STRATEGIC PLAN FOR A THRIVING COMMUNITY 93 Through this methodology, the California EPA determines eligibility and enforcement of State funding sources and promotes greater environmental justice. The State of California Office of Environmental Health Hazard Assessment developed the Disadvantaged Communities Index to identify communities that qualify for the California Climate Investments program. These specifically target investments that positively impact high-risk communities through the State’s Cap-and-Trade program, which aims to improve public health, quality of life, and economic opportunity in California’s most burdened communities. Communities categorized as “Disadvantaged” are census tracts among the highest 25% of overall scores as determined by CalEnviroScreen 4.0.

The City of Cudahy has six census tracts, and all are predominately above the 80% rating in the CalEnviroScreen scale, indicating significant risks and challenges associated with pollution, environmental hazards, and socioeconomic disparities. It is also important to note that the majority of residents who live in Cudahy are low-income people of color who are mostly renters. Regarding specific census tracts, 5344.03, the closest census tract in Cudahy to the proposed Salt Lake/ Florence Station, scored 84% overall. Both pollution burden and population characteristics contribute to this high rating.

When analyzing the census tract 5343.01, the closest census tract to the proposed Firestone Station, scored in the 99 percentile, one point off from the highest possible score on CalEnvironScreen. As among the most environmentally
burdened areas in the entire state, this census tract has a high pollution burden rating of 98% and a population characteristic rating of 93%.

One prominent environmental factor in Cudahy is the presence of the 710 Freeway, which serves as a critical highway for goods movement between the Port of Los Angeles and Port of Long Beach and the rest of the country. While this freeway facilitates essential commerce and trade, it also brings a range of environmental concerns, including air pollution from heavy truck traffic, noise pollution, and the fragmentation of wildlife habitats. Cudahy’s current built environment contains various industrial land uses and undesirable, nonconforming uses, including waste management sites, sited in close proximity to Cudahy’s residential neighborhoods, with little to no barriers or buffers separating them. Lastly, the development patterns of Cudahy are auto-oriented in design and character and contribute to the environmental health impacts in our community.

3.4 LITERATURE REVIEW
Cudahy Rent Stabilization Ordinance No. 736
The City of Cudahy introduced a Rent Stabilization Ordinance to address concerns about rising rents and potential residential displacement. With only 18% of residents owning homes, the city is predominantly renter-based. This Ordinance aims to curb excessive rent increases for covered residential units, regulate capital improvement cost recovery, and establish clear procedures to ensure landlords receive fair returns on their properties. It also includes administrative and enforcement measures, allows tenants to petition for fair rent adjustments, and outlines penalties for landlords who violate a tenants’ rights by imposing unjustified rent hikes. The Ordinance strives to protect tenants from excessive rent increases, promote long-term stability in the rental market, and maintain a balance that ensures landlords can sustain fair return on their investments.

Articles
Article II: General Provisions
→ Permitted Rent Increases for Covered Rental Units
→ Capital Improvement Pass-Through Cost Recovery
→ Landlord Fair Return Petition for Rent Increase
→ Tenant Petition for Adjustment
→ Security Deposits
→ Rental Unit Registration
→ Notices to Tenants
Article III: Administration and Enforcement
→ Enforcement
→ Administrative Review and Appeals
→ Administrative Citations
→ Remedies
→ Waiver
Ordinance Highlights
Permitted Rent Increases
→ Limits annual increases for “covered rental units” by no more than the change of CPI [inflation], or 3%, whichever is lower
→ Only one [1] increase in any 12-month period with a 30-day written notice
Covered Units/Exemptions
→ This applies to all residential rental units, except those expressly exempt, including, but not limited to, units built after February 1, 1995, single-family homes and condominiums, and properties with up to 2 units that are owner-occupied [owner lives in one of the units] Capital Improvement Pass-Through
→ Landlords may pass through [charge tenants] up to 50% of eligible capital improvement costs.
→ Eligible pass-through capital improvement costs include but are not limited to the replacement of electrical and plumbing systems that require a building permit.
→ The pass-through charge shall not exceed 5% of the
tenant’s rent.
→ The landlord must submit an application to the city and written notice to tenants before any capital improvement pass-through charge commences.

Fair Return Petition Process
→ Establishes a process for a landlord to request a fair return rent adjustment.
→ The landlord must provide tenants with written notice before charging an approved increase.

Rental Unit Registration
→ Requires Landlords to register rental.

Cudahy Tenant Protections Ordinance No. 737
The City of Cudahy implemented a Tenant Protections Ordinance aimed at safeguarding residents from unjust evictions following a minimum 12-month tenancy period. This Ordinance requires landlords to give proof of evictions with valid reasons, such as tenants’ non-payment of rent, breach of rental agreement, or engaging in nuisance or illegal activities.

The ordinance also requires landlords to provide relocation assistance and financial support equal to three months’ rent in cases where a tenant, lawfully residing in a rental unit for 12 months or more, faces non-renewal of their lease or eviction for reasons not caused by the tenant. Additionally, the ordinance imposes penalties and fines on both landlords and tenants who violate its provisions.

Articles
Article II: General Provisions
→ No Landlord shall terminate a Tenancy of an occupied
Rental Unit after a Tenant has continuously and lawfully occupied the Rental Unit for twelve [12] months or more unless the Landlord can demonstrate either a For Cause
or No-Fault termination as specified in Sections 5.14.050 and 5.14.060.
→ When terminating a Tenancy either For Cause or No-Fault,

94 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 95 a Landlord must comply with all of the following:

1. The Landlord must serve a written notice to the Tenant in accordance with California Civil Code sections 1946
through 1946.5 that states the Landlord will terminate the Tenancy, indicates at least one For Cause or No-Fault reason for termination in reasonable detail,
and includes any other information required by federal
or State law.

2. The Landlord has not accepted and will not accept Rent or any other consideration in return for the continued
use of the Rental Unit beyond the term of the terminated Tenancy in compliance with California Civil Code sections 1945 through 1946.5.

3. The Landlord qualifies the termination as For Cause
or No-Fault.

4. If the termination is a No-Fault termination, the Landlord has provided the Tenant with the notice of relocation
assistance required by Section 5.14.070.

5. The Landlord has submitted to the Department, within five [5] days after service of the notice of termination on the Tenant, a true and accurate copy of the Landlord’s
written notice of termination and proof of such service, signed under penalty of perjury, on the Tenant. The
Landlord shall maintain proof of service to the Department as evidence that the Landlord has complied with this Section.

Article III: Administration and Enforcement
→ Enforcement Authority. The Department is authorized to take appropriate steps it deems necessary to administer and enforce this chapter.
→ The Director of the Department or designee may develop and publish procedures and guidelines to aid in implementing this Chapter. → The Department may collect data regarding residential evictions in the City in an effort to help the City better understand rental housing and its impacts on renters and housing providers and inform the need to develop and
implement additional ordinances or policies regarding
residential housing.

Ordinance Highlights
“For Cause” and “No-Fault” Evictions
→ For-cause termination of tenancy. A Landlord is permitted to terminate tenancy for the following circumstances: the failure to pay rent, tenant violation of a material term of a rental agreement, illegal purpose of use of a unit, the failure to signal similar lease, assignment, or sublet in violation of the lease, refusing access for necessary repairs after the termination of employment, and the failure to vacate after providing landlord notice or intent to terminate lease. → No-fault termination of tenancy. A landlord is permitted to terminate a tenancy under the following circumstances:
demolition of the rental unit or permanent withdrawal of the rental unit from the rental market pursuant to the State law and/or use by the landlord or landlord’s family as their principal residence [this includes a spouse, domestic partner, child, grandchild, parent, grandparent].

Relocation Assistance
→ If there is no-fault eviction, the landlord must provide tenant[s] relocation assistance equal to 3x the rent in effect at the time of the termination notice plus 1 additional month’s rent for certain qualified tenants [low-income, seniors, disabled, families with minor children, tenancy 5 years or more]
→ Temporary relocation assistance be provided for tenant[s] who are temporarily displaced due to repairs, rehabilitation, and health and safety concerns Retaliatory Eviction and Anti-Harassment
→ Tenants are protected from retaliatory evictions and landlord harassment Cudahy Inclusionary Housing Program
The Cudahy Inclusionary Housing Program promotes the
growth and accessibility of affordable housing citywide. It ensures that new affordable housing units are proportionate to the overall expansion of housing in the city. The program establishes standards and procedures to incentivize affordable housing options at varying income levels. It outlines requirements for new residential and mixed-use projects, addressing market-rate units, construction timelines, and sale or rental unit provisions. Developers who fail to comply with the program may face penalties, including forfeiture of funds, legal action, and recovery costs. Notably, the program includes an environmental review component: qualifying inclusionary housing projects may be eligible for a streamlined Environmental Impact Report [EIR] or exemptions from CEQA review, facilitating faster approvals.

Inclusionary Unit Requirements
Number of Units Required
→ Fifteen percent [15%] of the total number of dwelling units in a residential or mixed-use project shall be developed, offered to, and sold or rented to households at eighty
percent [80%] or less of the area median income
Fractional Units
→ In calculating the required number of inclusionary units, any fractional unit shall be rounded-up to a whole unit Project Completeness
→ A residential or mixed-use project application will not be determined complete until the developer has submitted
a Housing Plan and Housing Agreement, which demonstrates the manner in which the requirements of this Chapter will be met Units for Sale
→ If a project consists of units for sale, fifteen percent [15%] CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN 95
of the total number of units in the project shall be sold to households at eighty percent [80%] or less of the area
median income
Rental Units
→ If the residential or mixed-use project consists of rental units, a minimum percent of the units shall be provided as follows:
→ A minimum of five percent [5%] of the units shall be
rented to very low-income households; and
→ A minimum of five percent [5%] of the units shall be
rented to very low-income or low-income households; and → The remaining five percent [5%] of the units shall be rented to very low-income, or low-income, or moderate-income households Displaced Households
→ On-site inclusionary units shall be required when very low, low, and/or moderate-income households are displaced.

Any other provisions of this Chapter, notwithstanding,
any project subject to this Chapter which results in the displacement of very low, low, and/or moderate-income
household[s] shall be required to provide on-site inclusionary units as required by this Chapter Priority Processing
→ All residential and mixed-use projects providing inclusionary housing on-site, pursuant to the provisions of this Chapter, shall receive priority building department plan check streamlining, to the extent authorized by law
Final Permit
→ The Final Construction Permit sign off, or Certificate of Occupancy, for the inclusionary units shall be issued prior to, or concurrently with, the proposed project

96 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 97 Concessions → By providing all the required inclusionary units on the project site, the developer may submit, and the City may consider granting, one or more of the following conces- sions: → Side Yard Setback → Distance Between Buildings → Parking → Open Space → Density Bonus The Program also provides sections/guidelines on the follow- ing: →
Alternatives to Providing On-Site Units
→Standards
→ Requirements for Housing Plans, Housing Agreements
and Livability Reports
→Enforcement of the Chapter
→Takings Determination
→Affordable Housing Trust Fund
→Administrative Fees
→Environmental Review
PLHA Rental Assistance Program
The Cudahy PLHA Rental Assistance Program is part of
California’s Permanent Local Housing Allocation [PLHA]
program, which provides funding to local governments
to address housing needs in their communities. The
program is designed to support the development and
maintenance of affordable housing, as well as provide
assistance to renters who are struggling to meet hous-
ing costs. Cudahy, like many cities in California, receives PLHA funds to support various housing initiatives,
including rental assistance for low-income residents.

The PLHA Rental Assistance Program in Cudahy aims to help low-income renters who may be facing challenges such as rising rent prices, job instability, or other financial burdens.

This assistance helps to prevent displacement, reduce hous- ing instability, and support community members who are
at risk of homelessness. By providing rental assistance, the program plays an important role in preserving the commu- nity’s diversity and socioeconomic stability. It helps ensure that long-term residents, many of whom may be low-income, are not priced out of their homes and can continue to live in Cudahy. This is especially important in areas like Cudahy, where housing affordability is a critical issue, and helps strengthen the overall health and resilience of the community.

CDBG Supportive Services
Cudahy’s CDBG [Community Development Block Grant]
Supportive Services program is part of a federally funded initiative aimed at enhancing the quality of life for low- and moderate-income residents in the city. The CDBG program is administered by the U.S. Department of Housing and Urban Development [HUD] and provides funding to local govern- ments for a variety of community development activities.

In Cudahy, the CDBG Supportive Services are focused on
providing essential services that support residents’ well-be- ing, particularly those facing economic hardship or other vulnerabilities. Programs like Cudahy’s monthly food drive and housing repairs are just a few of the many ways the city utilizes funding to support its residents.

Cudahy’s CDBG Supportive Services are crucial for address- ing the social and economic challenges many residents face, particularly in low-income communities. By offering access to these resources, the city helps residents overcome barriers to self-sufficiency, reduce poverty, and maintain stable housing.

CDBG Bus Shelter
Cudahy’s CDBG Bus Shelter project is an initiative funded through the Community Development Block Grant [CDBG]
program to improve public transportation infrastructure in the city. The project focuses on the installation or renovation of bus shelters throughout Cudahy, providing safer and more comfortable waiting areas for transit riders. These shelters help ensure that residents, particularly those who rely on public transportation, have access to basic amenities like protection from the elements, seating, and better overall conditions while waiting for buses.

By enhancing transit facilities, Cudahy can increase acces- sibility for residents, particularly low-income individuals, seniors, and people with disabilities who may rely on public transportation as their primary means of getting around. This also supports promoting greater connectivity, mobility, and quality of life, helping residents access jobs, healthcare, and other essential services while supporting the city’s broader efforts to improve livability and infrastructure.

98 CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN STRATEGIC PLAN FOR A THRIVING COMMUNITY 99

3.5 CASE STUDIES
As part of the Project Team, Fehr & Peers and City Fabrick selected three key case studies highlighted in the Commercial Gentrification and Displacement Case Studies section. These studies were chosen for their geographic or demographic similarity to Cudahy, infrastructure parallels to the South- east Gateway light rail, and focus on commercial gentrifica- tion. The LA Metro Anti-Gentrification Documents section features official Los Angeles County Metropolitan Trans- portation Authority documents exploring the relationship between transit development and gentrification within the Metro network. Finally, the Other Policy Case Studies section offers additional references and resources on the transit-gen- trification connection, both from California and beyond.

Commercial Gentrification and Displacement Case
Studies
This section, titled “Case Study Highlights” and “Ideas for Cudahy,” is designed to inform the development and engage- ment process for the Southeast Gateway Line-Cudahy Stra- tegic Plan for a Thriving Community [Cudahy Together]. The Case Study Highlights summarize the most relevant findings from the studies and literature, while the Ideas for Cudahy propose ways to adapt and apply those strategies to the city.

These ideas can be further refined and validated through input from City staff and the community.

Transit-Oriented Development Without Displacement:

Strategies to Help Pacoima Businesses Thrive
CASE STUDY 1
Author: UCLA Institute of Transportation Studies [2021] Location: Pacoima, Los Angeles
Key words: Light rail, Commercial gentrification, Small business, Latino neighborhood
Case Study Highlights
LA Metro aims to finish the East San Fernando Valley
Light Rail Project by 2030, which will traverse Pacoima's primary commercial corridor, Van Nuys Boulevard. This
study explores the potential risks of displacement, gentri- fication, and cultural erasure linked to rail expansion. This research asks: → How can community groups respond to displacement pressures from rail transit expansion to ensure thriving community businesses?
→ What are the concerns, experiences, and priorities
of Pacoima small businesses facing transit-related
displacement pressures?
Literature Review → Commercial community land trusts [CLT] • Example 1: Sawmill CLT, Albuquerque – mixed-use model that contains both commercial and residen-
tial developments
•Example 2: Crescent City CLT, New Orleans
→Cultural preservation as community asset-building
• The Calle 24 Latino Cultural District in San Francisco resulted in the establishment of a special use district, a zoning modification aimed at preserving cultural
and commercial assets. Additionally, a formal orga-
nization was formed to advocate for capital and tech-
nical support resources for small businesses.
→Recommendations for Pacoima • Consider rent-control ordinances, tax abatements or contract requirements with landlords with provi-
sions that they do not raise rents.
• Consider implementing tenant protection ordi-
nances [e.g., “just cause” eviction policies – ordi-
nances that limit the reasons landlords can evict
their tenants].
•
Consider supporting the development of a busi
-
ness association.
• Consider creating a temporary or permanent
resource center/counselor that offers one-on-one
technical assistance.
•
Explore community land ownership models.
• Develop lease-to-own opportunities for small busi-
ness owners.
•Explore shared-equity ownership structures.
• Partner with Inclusive Action and their Commu-
nity Owned Real Estate [CORE] initiative
Ideas for Cudahy → Conduct a small business survey to understand concerns and priorities of the Cudahy business commu-
nity regarding the Southeast Gateway Line. Consider
targeting corridors of particular concern [i.e., Atlantic Ave].
→ Refer to UCLA study survey and distribution strategy. → Partner with existing community-based organizations [CBO] that are active in Cudahy and/or surrounding
areas, using Southeast Gateway Line-Cudahy Strategic
Plan for a Thriving Community, Community Leadership
Circle [CLC] as a starting point.
→ Identify and meet with Metro to discuss business
support opportunities [e.g., business interruption fund, Little Tokyo business support during Regional Connec-
tor construction, etc.].
→ Consider outreach to meet businesses where they are
at, as opposed to hosting meetings which are often
infeasible for business owners to attend.
→ Review existing Rent Stabilization and Tenant Protection ordinances and policies and compare with recent case
studies for best practices and potential modifications. → Identify internal staff to allocate an initial amount of staff time [i.e., 20-30 hours] to research CLTs and other emerging strategies for alignment with local desires,
policies, and funding opportunities.

100 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 101 Transit-Oriented Development and Equity in Latino Neighborhoods:

A Comparative Case Study of MacArthur Park and Fruitvale CASE STUDY 2
Author: National Institute for Transportation and
Communities [2015]
Location: Los Angeles and Oakland
Key words: TOD, Latino neighborhood, Endogenous capital Case Study Highlights
This research focuses on Transit-Oriented Development
[TOD] projects in low-income Latino neighborhoods of
Fruitvale Transit Village in Oakland and the MacArthur
Park in Los Angeles.

The research discovered that the Fruitvale Transit Village and MacArthur Park deviated from the usual negative
impact of large-scale transportation projects, and instead played a role in revitalizing the respective neighborhoods.

The authors concluded that such projects could act as
catalysts for low-income neighborhoods by focusing on
and building upon three crucial factors:
→ Support the endogenous forms of cultural, political, financial, and built capital that exist in these neighborhoods. • Examples of endogenous capital could include any
operating informal economy [such as mercados or
street vendors], existing community-based organizations [CBOs], and the neighborhoods’ history of community activism.
→ Encourage more bottom-up participatory forms of
decision-making and activism in neighborhoods.
• Both the Fruitvale and MacArthur Park TOD projects began as top-down, before they were transitioned to bottom-up. → Incorporate and support increased access to
equity outcomes.
• Large-scale TOD projects should be evaluated regionally, in order to understand their health and mobility outcomes [such as regional accessibility from affordable housing and access to social services].

Ideas for Cudahy
→ Conduct an inventory of endogenous capital as
part of Cudahy Together development.
• Develop via a community engagement activity
with the CLC.
→ Identify core regional equitable mobility metrics
[currently being developed as part of Cudahy
Together], and continually evaluate the Southeast
Gateway Line for its effect on these metrics.
→ “Revitalization” of neighborhoods can have varied
meanings and impacts depending on the extent
to which that revitalization impacts housing costs,
displacement, and the ability of existing residents
to access resources and benefit from public and
private investment. As described in the prior
bullet, the City of Cudahy should work with local
residents and leaders to define relevant metrics
and potential tipping points such as rent increases,
number of evictions, and shifts from predominantly
lower-income residents to greater proportions of
substantially wealthier residents.

Transit-Oriented Development and Commercial Gentrification:

Exploring the Linkages
CASE STUDY 3
Author: UC Berkeley Center for Community Innovation
& UCLA Center for Neighborhood Knowledge [2017]
Location: Los Angeles and Bay Area
Key words: Commercial gentrification, Traffic safety,
Transit proximity
Case Study Highlights
This report provides a literature review on the topic of Transit-Oriented Development [TOD] and commercial
gentrification. It includes a literature review, development of quantitative gentrification metrics and examines four case studies: two in Los Angeles and two in the Bay Area. → Summary of Research Findings
• Commercially gentrified stations generally involve
an influx of eateries, cafés, and bars.
• Proximity to a transit station is likely unrelated to commercial gentrification. Demographic factors
like the percentage of non-Hispanic, Black, foreignborn, and renter residents, as well as overall population density, are more significant contributors to commercial gentrification in a neighborhood.
• Commercial gentrification may lead to increased
average annual crashes around rail transit stations,
involving cyclists and pedestrians. It’s unclear
whether this is directly caused by gentrification
or is linked to heightened traffic in these areas.
• Merchants commonly cited increasing rent as the
primary factor in neighborhood changes that negatively impact their businesses’ financial performance. → Recommendations to Empower TOD
• The study finds no clear link between transit proximity and commercial gentrification. Policymakers should avoid assuming transit neighborhoods are
immune and explore this issue further.
• The relationship between residential and commercial gentrification is complex and lacks a universal pattern. Policymakers need to investigate each neighborhood’s unique dynamics.
• Commercial gentrification is context-specific. Policymakers should consult local stakeholders like merchants and property owners for specific insights
rather than relying solely on aggregate data.
• Commercial gentrification in transit areas
correlates with more pedestrian and cyclist
crashes. Policymakers should prioritize resources
for traffic calming and proven safety improvements.

Ideas for Cudahy
→ Cudahy’s commercial corridor, Atlantic Avenue, relates to the first recommendation above, as it is not directly adjacent to either proposed Southeast Gateway
Line station. The corridor’s location may presumably
suggest it would be less susceptible to the pressures
of displacement. However, anti-commercial displacement activities should stretch citywide, not just within a certain buffer radius of the stations.
→ Multimodal accessibility improvements, both infrastructure and programmatic, should go hand-in-hand with anti-commercial gentrification policy and efforts.
→ While the literature has not identified a causal relationship between displacement and proximity to transit, the investment in public infrastructure and associated
changes in the built environment and local land values
can lead to local changes. The built environment may
change to better accommodate multimodal access and
the increase of people walking and biking who use the
transit facility. Local land values may change as the
public investment creates greater demand for housing
or services near transit. The City of Cudahy should
identify desired changes in the built environment,
potential negative outcomes, and potential strategies
to mitigate those outcomes.

102 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 103 LA Metro Anti-Gentrification Documents
Anti-Gentrification Document 1. Gentrification and
Displacement Policies [Ongoing]
→ This webpage summarizes Metro’s anti-gentrification
and anti-displacement policies and plans.
→ Key policies and plans related directly to local
commercial economic development include the Business Interruption Fund, and TOC Small Business Loan Fund.

Anti-Gentrification Document 2. Southeast Gateway
Line Transit Oriented Development Strategic Implementation Plan [2019] → The TOD SIP provides an overarching vision and strategic guidance for local Southeast Gateway Line jurisdictions to use as a reference as they develop and implement their own plans, policies and economic
development and mobility strategies in the 12 station
areas along the alignment. The report includes station
type and area summaries [Chapter 4], as well as a
strategies and actions toolkit [Chapter 5].
→ The following strategies and actions from the toolkit most directly support local commercial economic development and anti-commercial displacement • Action 1.1 – Corridor-wide economic development
corporation or modified joint powers authority
[JPA]
• Action 2.3 – Existing and new business support
Anti-Gentrification Document 3. Land Bank Pilot
[2022]
→ In 2022, the Metro Board directed Metro Staff to
develop a Land Bank Pilot. This link includes the
directive, though findings are still under development.

Other Policy Case Studies
Other Policy Case Study 1. The State of Anti-displacement Policies in LA County Author: UCLA Center for Neighborhood Knowledge
[2018]
Location: Los Angeles County
Document Highlights:
→ This document provides a high-level inventory of jurisdictions in LA County which have anti-displacement policies. Such policies include production and preservation of affordable housing, as well as asset building and local economic development, such as first source
hiring ordinances.

Other Policy Case Study 2. Transit Oriented Development, Gentrification and Displacement: Key Questions, Anti-Displacement Policies, and Case Studies Author: Twin Cities Metro [2021]
Location: Minnesota
Document Highlights:
→ This paper provides a comprehensive overview of
displacement and gentrification concepts and identifies anti-displacement policies related to the prevention of commercial displacement, preservation and production
of affordable housing, and neighborhood stabilization.
→ Commercial displacement strategies include the following:
• “Buy Your Building” Assistance
→ City provides a financing program and a
network of banks to assist businesses with the
down payment to buy their own building
• Commercial Space Set-Asides
→ Codified first-floor set-asides for local or
small businesses
• Business Incubators
→ City-run support programs for early stage or
displaced businesses, typically with below
market rate rent
• Community-Owned Cooperatives
→ Financing is provided by investors [customers and
neighbors] who buy a building and lease space to
businesses. Rent rates typically are below market
and based on a percentage of sales.

Barrio Logan Community Plan
CASE STUDY 4
San Diego, CA
Case Study Highlights
Chicano Park is a historic and culturally significant park located in the Barrio Logan neighborhood in San Diego.

It is renowned for its vibrant and colorful murals that celebrate Chicano and Mexican-American heritage,
culture, and history. Rooted in activism and protest,
the park was and still is a signal of cultural pride and activism for the Chicano community in the United
States. In the late 1960s, local residents protested the construction of a highway patrol substation on the site of what was promised to be a public park. The protests
led to a 12-day occupation of the land by community
members, which eventually led to the creation of
Chicano Park. The park is home to over 80 colorful
murals which depict various aspects of Chicano and
Mexican-American history, culture, and social justice
issues. These murals are not only works of art but also serve as important historical and political statements, reflecting the struggles and resilience of the Chicano
community in the United States. Likewise, Chicano
Park is not only a space for cultural expression and
community gatherings but also a symbol of resistance
and resilience for the Chicano community.

The Barrio Logan Community Plan was significant in
defining a community vision for the neighborhood,
which was adopted in 1978 by City Council. The Plan
presented a comprehensive land use and development strategy that guided the growth and rejuvenation of the Barrio Logan neighborhood while actively addressing the pressing concerns of gentrification and
displacement. In 2021, the City of San Diego undertook a significant initiative by updating and approving the Barrio Logan Community Plan and Local Coastal
Program to align with the evolving needs of Barrio
Logan’s expanding population. This Plan serves as a
blueprint for development that capitalizes on Barrios
Logan’s established character as a mixed-use working neighborhood. The Plan encompasses land use, public facilities, and development policies that are
specifically tailored for Barrio Logan and align with the City of San Diego’s General Plan. It outlines policies, specific actions, and implementing programs that aim
to guide and safeguard the community’s vision while
also accommodating new public and private projects.

With an emphasis on the importance of enriching
the community’s unique character, the Plan provides
guidance for projects that leverage the surrounding
amenities and includes specific zoning regulations
within the implementing programs. It overall serves
as a dynamic framework that ensures that the vision
of the community plan is effectively realized through
a thoughtful and strategic approach to development.

Key Takeaways
→ Grassroots activism and community mobilization can
shape policy. The park’s creation was a direct result of the Chicano community’s efforts to protect its interests and cultural heritage. → The park has had a positive impact on community
development, providing a safe and inclusive space
for gatherings, events, and community activities. This
in turn fosters a sense of unity and solidarity among
community members.
→ The 2021 updated Community Plan has continued
compliance with State and Local affordability requirements to help ensure that affordable housing will continue to be an integral component of overall housing production in Barrio Logan. → The 2021 Plan contains policies to provide relocation assistance to tenants of residential units that are proposed to be demolished or converted to condominiums.
→ The 2021 Plan supports anti-displacement initiatives, such as community acquisition, land trusts, and other
programs to increase homeownership opportunities
for residents in the community.

104
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 105 Street Vending

3.6 RELEVANT PUBLIC PROJECTS
Cudahy Sidewalk Vendor Map
City of Cudahy
The City of Cudahy has created a map for current and
future street vendors, identifying areas designated for stationary vending, roaming vending, or both. Vendors face certain restrictions, such as being prohibited from selling within 500 feet of school zones between 7 a.m. and 5 p.m. and in parks or recreational areas unless explicitly permit- ted through an agreement with the City. Over the past year, street vending has expanded significantly, prompt -
ing the adoption of ordinances aimed at reducing barriers in former “No-Vending” zones designated by Los Angeles County. As street vending continues to rise in popularity, the City has opportunities to expand vending zones and
establish itself as a regional attraction. Currently, roaming and stationary vending are permitted in the following areas:

Salt Lake Pedestrian Accessibility Project
City of Cudahy
The Salt Lake Pedestrian Accessibility project aims to
enhance pedestrian infrastructure along the east side of Salt Lake Avenue to meet ADA [Americans with Disabili-
ties Act] requirements and promote increased pedestrian activity. The primary objective is to provide safe, accessi- ble, and well-connected routes for the community, partic- ularly facilitating access to the Metro stations planned as part of the Southeast Gateway Line. These stations,
located just north and south of the Cudahy city limits, are set to be positioned at the intersection of Salt Lake Avenue and Florence Avenue in Huntington Park, and south of
Patata Street and east of Atlantic Avenue in South Gate.

The project will involve the removal and reconstruction of the existing narrow, non-ADA-compliant sidewalk and
wheelchair ramps, ensuring they meet accessibility stan- dards. New curb extensions of medium to large size will be added at key intersections to reduce pedestrian crossing distances and improve crossing angles, enhancing safety at skewed crossings. Pedestrian crosswalks will be installed to provide safer pedestrian routes and connect to the
upcoming Southeast Gateway Line stations. Additional
features include pedestrian lighting, wayfinding signage, traffic striping, and the installation of benches to provide rest points. New tree plantings will create shade cano- pies to improve comfort for pedestrians, along with other supplementary elements to enrich the walking experience.

Patata Street Industrial Development - 5037
Patata Street
City of South Gate
The Patata Street Industrial Development project is a
significant industrial project of over 450,000 square feet on an approximately 27-acre site in th City of South Gate which aims to attract businesses engaged in manufactur- ing, warehousing, and distribution.

The project promises economic growth for the City of
South Gate and job creation for the region; however, it also raises important concerns about community preservation.

Cudahy is already a densely industrialized area, and the addition of more industrial facilities in the surrounding area, including increased truck traffic, could further strain local infrastructure and exacerbate existing traffic conges- tion. The influx of trucks and additional industrial activity may negatively impact air quality, pedestrian safety, and the overall quality of life for residents, potentially displac- ing local businesses and homes.

It is important to recognize that the access point to this project site is located on Patata Street, which runs through Cudahy. Given this, it’s essential to consider the poten- tial impacts on Cudahy, as the development could affect traffic flow, infrastructure demands, and local services in both South Gate and the surrounding Cudahy commu-
nity. Increased vehicle activity from trucks and workers could put pressure on roadways, potentially necessitating improvements or modifications to accommodate the higher volume of traffic. Additionally, the development may raise concerns regarding noise, air quality, and other environ- mental factors that could affect nearby residential areas and businesses. It is crucial to address first and last mile transportation challenges while ensuring that pedestrian and bike connectivity are preserved and not disrupted by this potential development.

Roaming Vending Permitted

STREET IN BETWEEN STREETS
Flower Salt Lake and Otis
Clara Salt Lake and Otis
Olive Salt Lake and Otis
Hartle Otis and Atlantic
Clara Otis and Atlantic
Live Oak Atlantic and Wilcox
Live Oak Wilcox and River
Wilcox Live Oak and Florence
Atlantic Santa Ana and Cecilia
Atlantic Cecilia and Ardine
Atlantic Ardine and Patata
Stationary and Roaming Vending Permitted

STREET IN BETWEEN STREETS
Santa Ana Salt Lake and Atlantic

106 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 107 Community Voice The following engagement
data highlights key themes
specifically related to
community preservation,
derived from the feedback
gathered through various
outreach events and activities.

Listening Sessions
The listening sessions allowed for community members to share their concerns, priorities, and ideas early on in the engagement process. This information set the stage for all other outreach events.

Themes:
→ Residents prioritized the growth of diverse establishments and proper street vending as essential components for the future in Cudahy. They want to see more culturally diverse restaurants and more accessible parks for youth.
→ Having safe and clean neighborhoods were important to listening session participants. Residents emphasized the importance of maintaining clean, well-kept public spaces and ensuring that neighborhoods are safe.
→ Community members want to see an increase in public amenities and programs that are more suited for the demographic that lives in Cudahy. They would also like to see an increase in public amenities such as dog waste dispensers, bus stops, and local art.
→ There is a strong desire to preserve the Spanish language and cultural traditions for future generations, alongside a commitment to protecting the integrity of the neighborhoods.

Survey
In the public survey, the community was asked about what aspects of the community they love and what makes Cudahy unique to them. Participants provided valuable feedback, which is summarized below:

Themes:
→ Participants shared that access to community resources is very important, particularly when it comes to essential services such as healthcare, education, job training, and affordable housing. They emphasized the need for more community centers, public health programs, and local businesses that can provide these vital resources.
→ Participants highlighted the importance of a diversity of businesses in the community, expressing a strong desire for a mix of local, culturally reflective establishments, including restaurants, markets, and service-based businesses. → Participants emphasized the need for more community events and gathering spaces, expressing a desire for places where people can connect, celebrate, and engage with one another. → Participants expressed a strong desire for more natural elements in the community, including parks, green spaces, and trees. They emphasized the importance of having accessible areas where residents can enjoy nature, relax, and engage in community events.

Open House One
At the first public Open House, participants had the chance to engage in the Community Preservation section, sharing what aspects of the community are most important to them and offering their vision for the future.

Themes:
→ Participants want the City to host dance events and provide dedicated spaces with tables for seniors to gather and socialize. 100 150 Access to
Resources
Diversity of
Businesses
Community
Events and
Gathering Spaces
Sense of
Community
Cultural
Identity
Improvements and
Improve Cleanliness
Walkability
Safety
Overall Priorities
Low-Income
Renters Priorities
Youth Priorities
Active Transportation
Priorities
Senior Priorities
63 49
45 36
3 53
52 50
11 11
10 7
7 42
36 37
9 53
7 5
6 34
23 23
4 1
6 4
40 40
37 10
4 8
6 7
0 0
0 0
1 1
1 6
7 What are aspects of the community you love?
0 10 50

108 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 109 What aspects do you think can contribute most to Cudahy’s uniqueness and charm? 0 30 60 90 120 150
Highlight Cudahy's
Cultural Diversity
and Heritage
Architecture and
Neighborhood
Design
Access to Amenities
(shops, restaurants.
public transportation)
Natural Elements
(parks, trees, access
to nature)
Community
Events and
Activities
Overall Priorities
Low-Income
Renters Priorities
Youth Priorities
Active Transportation
Priorities
Senior Priorities
135
100
15 11
6 2
3 108
97 71
41 94
53 56
61 51
21 95
88 60
36 131
120
86 53
Overall Priorities
Low-Income
Renters Priorities
Youth Priorities
Active Transportation
Priorities
Senior Priorities
→ Participants expressed a strong desire to see the preservation of the Spanish language among youth, emphasizing the importance of cultural continuity and ensuring that future generations remain connected to their heritage.
→ Participants expressed a strong interest in expanding the variety of culturally diverse restaurants in the community. → Participants stressed the importance of making laundromats, retail stores, and essential services more affordable for residents, ensuring that all community members have access to basic necessities without financial hardship. → Participants called for improvements in street sweeping and overall cleanliness throughout the community, emphasizing the importance of maintaining clean, well-kept public spaces. → Participants expressed a strong desire to preserve the peaceful, small-town character of the community, emphasizing the importance of maintaining a quiet, close-knit atmosphere. → Participants suggested enhancing community cleanliness by adding more dog waste dispensers throughout the neighborhood.
→ Participants expressed a strong commitment to safeguarding the neighborhood’s traditions and cultural heritage, stressing the importance of preserving the unique identity that defines the community.
→ Participants emphasized the importance of supporting and promoting local vendors, particularly those selling fresh fruits and slushies, as they are integral to the community’s vibrant culture.
→ Participants strongly advocated for improved walkability and the creation of safe pedestrian pathways throughout the community. They emphasized the importance of ensuring that residents can easily and safely walk to essential services, parks, and local businesses.
→ Participants highlighted the need to ensure free access to CART for all residents, emphasizing the importance
of affordable mobility options for those who rely on
public transportation.
→ Participants suggested reevaluating and modernizing the city’s logo to better reflect the evolving identity of the community.

Roundtables
The roundtables provided a space for community leaders to thoughtfully prioritize their most important ideas mentioned in previous engagement, ensuring that ideas that were uplifted in previous rounds of engagement truly reflected community needs.

Key Takeaways:
→ Parking is a significant concern in the city due to its densely developed nature. While a bike lane would be a valuable addition to improve mobility and promote sustainable
transportation, the existing parking limitations present a challenge to its implementation.
→ Participants noted that the heavy rail project presents significant challenges and suggested considering the separation of tracks on the Cudahy side of Salt Lake Avenue. → Lack of overnight parking is a concern.
→ Participants advocated for the development of a regional bike master plan that would connect local communities
and stations.
→ Participants acknowledged the importance of housing
affordability but emphasized that walkability and safety, particularly near schools and residential areas, should be top priorities.
→ Participants stressed that access to green space and walking distance to essential amenities should be prioritized, ranking among the top three community goals.
→ Participants expressed that a close-knit, safe community should take precedence over affordable housing.
→ Participants suggested engaging students and youth
through community art contests, encouraging them to
depict what they love about Cudahy.
→ Participants emphasized that Atlantic Avenue should
be prioritized for improvements, given its role as a key commercial and retail corridor.

Open House Two
At the final Open House, residents had the opportunity to provide feedback on the recommendations that emerged
from an extensive community engagement process focused on preservation. The following themes directly reflect the input gathered during these discussions.

Themes:
→ Participants strongly supported the creation of a community hub that actively engages youth, schools, and local groups. → Participants expressed opposition to designated street vending, believing it works best when vendors can operate organically without government interference.
→ Participants advocated for supporting street vendors by providing resources like cleaning crews, rather than penalizing or exploiting them. → Participants highlighted the need to address challenges faced by street vendors, particularly around obtaining
health permits and ensuring access to safe washing facilities and food temperature practices. → Participants suggested developing a community hub and night market as a vibrant space for local vendors, entertainment, and cultural activities. → Participants expressed strong support for backyard
conversions as part of community development projects.
→ Participants emphasized the importance of providing small merchants with affordable, low-rent spaces to help foster local businesses.
→ Participants stressed the importance of ensuring that training and work opportunities are available for residents in neighboring cities and also is needed for Cudahy.
→ Participants advocated for allowing spontaneous street vending to enhance the community’s vibrant spirit, without the burden of heavy code enforcement.

110
CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN STRATEGIC PLAN FOR A THRIVING COMMUNITY 111 3.7 Community Preservation Recommendations Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Cudahy Chamber of Commerce
City of Cudahy - Public Works Department
Property Owners
Priority
Short-Term (0-2 years)

3.1.1. Support Emerging Chamber of Commerce
Overview
This initiative would
focus on fostering regular
communication between
the City of Cudahy and the
newly established Chamber
of Commerce regarding
new public programs and
resources available to local
businesses.

This initiative would focus on fostering regular communi- cation between the City of Cudahy and the newly estab-
lished Chamber of Commerce regarding new public
programs and resources available to local businesses.

By providing timely updates and information, the City
can ensure that the Chamber effectively disseminates
valuable resources to its members, helping them navi-
gate available support and opportunities. This collabo-

POLICIES
ration will strengthen the relationship between
the City and local businesses, promoting a unified
approach to economic development and commu-
nity engagement. These businesses are likely to
experience a positive impact once the transit
stations are built as the increased foot traffic can
boost customer volume and drive higher revenue.

Although the City of Cudahy and Cudahy Cham-
ber of Commerce can not directly support neigh-
boring cities financially, they can be a resource for
other opportunities that may arise.

Context
Established in 2024, the Cudahy Chamber of
Commerce initial focuses are on public safety,
economic development, and City-business part-
nerships. The Chamber would serve as a conduit
between the City and business owners and could
possibly be a resource for some of the business
assistance programs. The City could support the
Chamber of Commerce in the beginning support-
ing on outreach and business recruitment, while
providing logistical capacity as the organization is
still in its early stages of development.

112 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 113

3.1.2. Landlord/Tenant Mediation or Anti-Harassment

POLICIES
Overview
This initiative would establish a framework for mediation between landlords and tenants to resolve disputes
amicably, reducing the likelihood of harassment or
retaliatory actions.

It would provide tenants with access to legal resources and support services, ensuring they understand their rights and can advocate for themselves.

By promoting respectful communication and conflict resolution, the program aims to create a more equitable rental environment.

The City of Cudahy will establish a multilingual education and engagement strategy as part of this residential program to ensure the successful implementation of this strategy.

This will include public workshops to educate homeowners and landlords on design guidelines, a resource hub with technical assistance for property improvements, and collaborations with local organizations for ongoing feedback and collaboration.

Context
The development of the Metro Southeast Gateway rail line will likely lead to real estate speculation near the stations at varying scales, resulting in increased rents for businesses and residents. Many property owners, residents, and business owners are not aware of what tenant protections already exist. The City is committed to host community workshops and engage in additional marketing and outreach to increase awareness of existing tenant protections. At times arbitration is necessary when tenants and property owners cannot find a mutually beneficial solution, requiring an independent third party’s involvement.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
City of Cudahy - City Manager’s Office
Community Based Organizations
Priority
Medium-Term (2-5 years)

3.1.3. Commercial Eviction Restrictions

POLICIES
Overview
Eviction restrictions would
limit a property owner’s
ability to evict commercial
tenants without just
cause, providing greater
security for businesses.

This policy could include
requirements for
landlords to demonstrate
a legitimate reason
for eviction, such as
non-payment of rent or
lease violations.

By protecting tenants from arbitrary evictions,
the policy fosters a more stable business environment and encourages long-term investment in the community.

Context
The development of the Metro Southeast Gateway rail line presents significant opportunities for economic growth in the City of Cudahy but also raises
concerns about real estate speculation and rising
rents for businesses and residents near station areas.

These pressures could lead to increased commercial
evictions, particularly for small businesses, threatening the community’s economic stability and cultural identity. A Commercial Eviction Restriction Policy
would provide critical safeguards and assistance to
ensure that local businesses can remain in place and
benefit from the economic activity generated by the
new rail line. By combining such a policy
with community workshops, targeted
outreach, and, when necessary, arbitration services, the City can proactively protect its businesses from displacement.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Los Angeles Metropolitan Transit Authority
Cudahy Chamber of Commerce
Community Based Organizations
Priority
Medium-Term (2-5 years)

114 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 115

3.1.4. Cudahy Community Land Trust Study

POLICIES
Overview
Dedicate 20-30 hours
of City Staff time to
research community
land trusts (CLTs) and its
potential viability and
interest from the Cudahy
community. This initiative
will explore how these
approaches align with local
housing needs, policies,
and available funding
opportunities.

Staff will evaluate the feasibility of CLTs in preserving affordability, preventing displacement, and supporting long-term community stability for Cudahy. The findings will guide future discussions and inform
potential partnerships or a pilot program, ensuring
alignment with Cudahy’s goals for equitable and
sustainable housing solutions.

Context
As Cudahy continues to address housing challenges,
exploring emerging strategies like CLTs offers an
opportunity to expand affordability while maintaining local control of land use. Government-supported CLTs have been successfully implemented in other
communities to provide lasting affordable housing,
stabilize neighborhoods, and empower residents
through shared governance. By dedicating Staff time
to researching these models, the City can assess their
applicability to its unique context and proactively
position itself to leverage potential funding sources.

This effort to study the feasibility of CLTs ensures
that Cudahy remains innovative and intentional in
addressing its housing priorities.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Community Based Organizations
Priority
Medium-Term (2-5 years)

3.2.1. Cudahy Community Hub

PROJECTS
Overview
Construct a community
gathering space, business
incubator, and workforce
development that
provides a central location
for regular and special
community programs
and events.

The permitted space can host a wide range of community
events such as local farmers markets, cultural festivals, workshops, and performances, creating opportunities
for people of all ages to engage with one another. Additionally, the space should include a community hub that also engages youth, schools, or other groups, providing a platform for education, mentorship, and collaboration. The creation of art spaces for the youth, where they can learn martial arts, acrobatics, public art, and other creative outlets, is something the community
believes would further enrich the offerings and create a safe, productive environment for young people. Lastly,
community members expressed the desire to hire local
contractors for the eventual construction.

Context
The Cudahy Community Hub addresses a critical
need for a centralized, multi-functional space that
fosters community engagement, economic growth,
and cultural enrichment. As Cudahy experiences
ongoing development and population growth, the
lack of accessible, dedicated spaces for community
programs, workforce development, and business
incubation has limited opportunities for residents
and local businesses to thrive. A Community Hub
would serve as a vital resource for bringing people
together, promoting local entrepreneurship, and
hosting diverse events like farmers markets, cultural
festivals, and skill-building workshops. By providing
a space where residents of all ages can connect and
grow, the Hub would strengthen community ties,
support economic resilience, and celebrate Cudahy’s unique cultural identity.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
City of Cudahy - City Manager’s Office
City of Cudahy - Public Works Department
City of Cudahy - Community Services
Department
Cudahy Chamber of Commerce
Community Based Organizations
Local School Districts
Priority
Long-Term (5-10 years)

116 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 117

3.2.1 Cudahy Community Hub Potential Locations

1. Proximity to Metro Station - Supporting first/last mile connectivity

2. Vacant Land - Land close to residential communities and not serviced by parks

3. . City-owned parcels - Greatest opportunity for development Prioritization

3.2.2. Cudahy Night Market

PROJECTS
Overview
Develop a monthly night
market that showcases
local vendors, promotes
cultural exchange, and
brings together the
community. The monthly
night market will be a
vibrant gathering space
that highlights the best
of the local community,
offering a permitted
space for local businesses
to highlight their unique
products from street
food to handmade crafts.

Context
The Cudahy Night Market responds to the community’s expressed desire for more vibrant, family-friendly spaces that celebrate local culture and entrepreneurship. With an already thriving street vendor community, this initiative builds on existing strengths, providing a platform for vendors to showcase their
offerings and attract wider audiences. By featuring
local businesses, street food, and handmade crafts,
the market will not only promote cultural exchange
but also strengthen the local economy. This monthly
event will serve as a lively gathering space, fostering community pride and connection while supporting the
creative and entrepreneurial spirit of Cudahy.

Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
City of Cudahy - City Manager’s Office
City of Cudahy - Public Works Department
City of Cudahy - Community Services
Department
Cudahy Chamber of Commerce
Community Based Organizations
Property Owners
Priority
Short-Term (0-2 years)

118 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 119

3.2.3.Designated Street Vending

PROJECTS
Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
City of Cudahy - Public Works Department
Cudahy Chamber of Commerce
Priority
Medium-Term (2-5 years)
Overview
Create a structured program that allows for street
vending in designated areas, providing local and regional entrepreneurs with an opportunity to sell their goods in highly pedestrianized areas.

One key aspect of supporting street vendors is to help
them get health permits, including providing safe ways
to wash hands and ensure food temperature control.

This program will attract regional consumers to the
area and support the local business economy. It will
allow local vendors, entrepreneurs, and small businesses to provide a diverse range of food, products, and entertainment to visitors.

Working within the context of state law and the
County of Los Angeles Public Health licensing for
street vendors the City should develop place-based
strategies for supporting all local businesses, determining ways to support responsible street vending and developing synergies between street vendors
and brick and mortar businesses. Some residents
have shared that the spontaneity of street vending
adds to the vibrant spirit of the community, and would
not like to see these entrepreneurs penalized for
being in undesignated areas. Instead, some community members expressed that they can be engaged around maintaining cleanliness in their operations,
and connecting them to potential resources. Engaging with local businesses along Atlantic Avenue will be important to ensure that street vending complements,
rather than competes with, established businesses.

Context
Street vending has a long history across the region
that has exploded in popularity with the advancement
of state law allowing for certain types of street vending and cottage industries. There have been growing efforts to add back some layers of regulations as the
significant growth of street vending has led to unintended consequences including destabilizing brick and mortar businesses, compromising accessible
paths with encroaching vendor setups, and environmental degradation from improper disposal. It has decreased barriers to entry for new businesses and
many cases invigorated the public realm.

3.3.1. Commercial Rental Assistance Program

PROGRAMS
Overview
This program would
provide staff support
from the City of Cudahy
to assist small businesses
and merchants in meeting
rental obligations during
economic challenges or
disruptions from projects
like the Metro Southeast
Gateway rail line.

While Metro currently does not have a Business Interruption Fund for this project, the City would help connect businesses with available
financial resources, such as grants, low-interest
loans, and financial counseling. The City’s role
would focus on guiding businesses to potential funding opportunities, ensuring they have the support needed to stabilize operations
and prevent closures during the disruption.

If Metro were to establish a Business Interruption Fund for this project, it could provide direct financial assistance to businesses affected by the
rail line development. This fund would help businesses cover utilities, insurance, rent or mortgage, payroll, and other types of eligible documented
business-related expenses. Metro’s involvement in
funding this initiative would ensure that businesses
are not financially strained by the project, helping
them maintain operations and stay afloat. The City
would continue to assist in connecting businesses
to Metro’s funding, ensuring a streamlined process
for accessing support. For specific details on how
Metro works with local businesses during and after
rail construction, there are procedures that are
defined on Metro’s website related to financial
assistance, which can be found here: https://www.
metro.net/about/business-interruption-fund/
Context
With the development of the Metro Southeast
Gateway rail line, small businesses in Cudahy may
face increased rental pressures and financial challenges similar to those experienced by businesses near other major transit projects. Financial support
for this program could come from Metro, modeled
after the Business Interruption Fund established
for Little Tokyo, which provided grants to help businesses navigate disruptions caused by construction. In addition to advocating for Metro funding, the City of Cudahy can offer critical staff support
by connecting businesses to available resources,
assisting with applications for financial assistance,
and providing financial counseling services. This
combined approach would help stabilize local businesses while leveraging regional support for equitable economic development.

Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
Los Angeles Metropolitan Transit Authority
Cudahy Chamber of Commerce
Community Based Organizations
Priority
Long-Term (5-10 years)

120 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 121

3.3.2. Legacy Business Programs

PROGRAMS
Overview
Legacy Business programs are designed to protect and
support longstanding small businesses that have played a vital role in shaping the community’s culture and identity.

These programs may offer support in obtaining financial resources, such as grants or tax incentives, special
marketing strategies, to help these businesses maintain their operations, draw new patrons, and preserve their
unique character.

Encouraging legacy businesses to join the new Cudahy
Chamber can further enhance their support by connecting them with additional resources, networking opportunities, and advocacy. By recognizing and supporting these businesses, the program fosters community pride, preserves community identity, and encourages the continuation of
local traditions. These businesses are likely to experience a positive impact once the transit stations are built as the increased foot traffic can boost customer volume and drive higher revenue. Although the City of Cudahy and Cudahy
Chamber of Commerce can not directly support neighboring cities financially, they can be a resource for other opportunities that may arise.

Context
Cudahy is home to many small businesses - with
just a limited number of national chains, providing a
unique character for the community. Some of these
small businesses are staples of the community, having
existed for long periods of times, becoming associated with who Cudahy is, like landmark buildings or public art. They are also often civic leaders who give
back to the community, because they are invested in
their collective success. Preserving these legacy businesses serves what is special about Cudahy.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Cudahy Chamber of Commerce
Community Based Organizations
Property Owners
Priority
Short-Term (0-2 years)

3.3.3. Commercial Relocation Assistance

PROGRAMS
Overview
Relocation assistance
would provide staff
support to commercial
tenants who are forced
to vacate their leased
spaces, helping with the
business license/zoning
clearance process, finding
new tenant spaces, and
connecting businesses
with property ownership
opportunities.

This program could include guidance and resources
to ease the relocation process, ensuring that
displaced tenants can transition smoothly. By
offering this support, the initiative aims to minimize disruption and maintain stability within the community.

Additionally, Metro should assume the financial
responsibility for relocation assistance, as has
been done with other light rail transit projects.

Metro could help cover moving costs, securing
new accommodations, and potentially providing
financial assistance for security deposits and/or
build-out of the new space. This would ensure that
businesses impacted by the transit project are
able to relocate without undue financial burden,
maintaining the stability of local businesses and
preventing displacement. Metro’s involvement in
funding this relocation assistance would demonstrate a commitment to supporting the community during the transit development process. For specific details on how Metro works with local
businesses impacted by new transit development,
there are procedures that are defined on Metro’s
website related to Real Estate Services (Acquisitions), which can be found here: https://www. metro.net/about/property-acquisition/
Context
Relocating a business can be traumatic for its ongoing operation, everything from patrons familiarity with the current location to previous investment in
a space that can not be recuperated. There are also
substantial impacts during relocation that could
result in a business having to close. But assuming a
business has the ability to sustain itself after relocating, supporting the relocation is a short-term investment that can pay ongoing benefits by retaining that existing business.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Los Angeles Metropolitan Transit Authority
Cudahy Chamber of Commerce
Community Based Organizations
Priority
Long-Term (5-10 years)

122 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 123

3.3.4. Public Property for Local Entrepreneurs

PROGRAMS
Overview
The initiative would invite
specific communities
or businesses to utilize
publicly owned spaces
for vending purposes,
particularly those lacking
access to traditional brickand-mortar locations.

This could include designated areas for food trucks,
artisans, or pop-up shops, fostering entrepreneurship and community engagement. By activating these spaces, the program not only supports local businesses but also enhances the vibrancy of public areas.

Context
The initiative is crucial for Cudahy as it addresses
both economic and social challenges faced by its residents and small businesses. The city, like many urban areas, has a limited amount of commercial property
available for new businesses, especially those owned
by locals who may not have the financial means to
secure a traditional storefront. This initiative provides an alternative by utilizing underused public spaces,
making it easier for small-scale entrepreneurs, such as food vendors and artisans, to launch their businesses.

By activating these spaces, the program can help
strengthen the local economy, create job opportunities, and build a sense of community. It also supports the broader goal of revitalizing public areas, turning
them into dynamic, welcoming places where residents and visitors can gather, shop, and engage with local culture.

Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
City of Cudahy - City Manager’s Office
City of Cudahy - Public Works Department
City of Cudahy - Community
Services Department
Cudahy Chamber of Commerce
Community Based Organizations
Priority
Medium-Term (2-5 years)

3.3.5. Local Training and Hiring Program

PROGRAMS
Overview
This program would focus on developing the local
workforce by providing training and employment
opportunities tailored to the needs of local businesses in Cudahy. It could include partnerships with educational institutions to offer vocational training, apprenticeships, and job placement services.

A vital aspect of facilitating the development of a robust workforce would be to invest in the provision of supportive services such as childcare services and educational/vocational opportunities for youth. The City has identified potential growth and expansion areas in business categories such as service stations, grocery stores, building materials/supply dealers, clothing and apparel stores, and full-service restaurants. By investing in the skills of residents and those living in surrounding communities, the program aims to enhance employability and support economic growth within Cudahy.

Context
This program is key for the Cudahy community as it helps connect local residents with job opportunities through targeted training and apprenticeships. Many residents face employment barriers, and this program can bridge that gap by partnering with educational institutions to provide skills that match local business needs.

This initiative boosts employability, supports economic growth, and strengthens the community by creating a more skilled workforce that attracts and sustains businesses in the area.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Cudahy Chamber of Commerce
Community Based Organizations
Local School Districts
Priority
Short-Term (0-2 years)

124 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 125

3.3.6. Residential Backyard Developments

PROGRAMS
Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Community Based Organizations
Local School Districts
Priority
Medium-Term (2-5 years)
Overview
The City of Cudahy
proposes a Residential
Backyard Developments
Program to expand
affordable housing
opportunities by facilitating
the creation of accessory
dwelling units (ADUs) on
underutilized portions
of residential properties.

This program will promote ADU development to property owners, provide clear construction guidelines, and streamline the permitting process with tools like pre-approved designs to reduce costs and delays. Additional support, such as standardized easements or subdivisions, will further simplify development and encourage participation. By enabling incremental, context-sensitive housing growth, this program offers a sustainable approach to addressing the city’s housing needs while
preserving neighborhood character. The City of Cudahy
will establish a multilingual education and engagement
strategy as part of this residential program to ensure
the successful implementation of this strategy. This will include public workshops to educate homeowners and
landlords on design guidelines, a resource hub with
technical assistance for property improvements, and
collaborations with local organizations for ongoing feedback and collaboration.

Context
Cudahy’s deep residential parcels offer a valuable
opportunity to increase affordable housing through
the incremental development of accessory dwelling
units (ADUs) on underutilized portions of residential
properties. These surplus areas can be transformed
into functional living spaces, providing additional
housing options that are contextually appropriate for
the city’s neighborhoods. This approach maximizes
the efficient use of land, supports sustainable growth, and helps address the city’s housing needs while
maintaining neighborhood character. By encouraging
ADU development, Cudahy can expand its housing
supply in a way that benefits families and individuals
in need without requiring large-scale redevelopment.

3.3.6 Residential Backyard Development Opportunities

1. Proximity to Metro Station - Supporting first/last mile connectivity

2. Opportunity Sites - Supportive property owners

3. Opportunity Sites - Proximity to parks and schools Prioritization

126
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 127 Cultural
Placemaking
Study
The Cultural
Placemaking Study
evaluates the
City’s existing
infrastructure and
opportunities to
enhance local art
and placemaking by
implementing
Latino Urbanism into
public spaces that
can support in fostering
a sense of identity.

CHAPTER 4

4.1 CULTURAL PLACEMAKING STUDY ABSTRACT
The Study offers a detailed explanation of Cudahy’s
current built environment and ways to enhance and
preserve the unique latin heritage of the community, while also looking to address challenges that were identified through an extensive community engagement process.

This engagement has highlighted key priorities, such as the desire for more inclusive public spaces, the integration of local traditions and art, improved accessibility, and foster- ing a stronger sense of community identity. This feedback helped guide the integration of improvements to the built environment, ensuring that changes not only enhance the area aesthetically but also promote the well-being of current and future residents of Cudahy. This is particularly import- ant in light of upcoming transit investments in the city. As new transit infrastructure is introduced, it presents a unique opportunity to create more accessible and vibrant public spaces that reflect the values and heritage of the community.

Community involvement is central to this study, and a
specific focus is given to methods of soliciting and integrat- ing community voice in the design process for the transit stations but also the city overall. The Study analyzes key equity indicators such as the Parks Needs Assessment and Tree Equity to help identify and address disparities in access to essential public resources, ensuring that all communities in Cudahy benefit from improved environmental quality,
green spaces, and recreational opportunities. The Study then includes a Site Analysis overview to assess Cudahy’s current public realm inventory, identifying strengths and opportunities for improvement in both public art and future development opportunities. This analysis helps pinpoint areas where enhancements can be made that are reflective of community wants and desires. The Study then dives deep into relevant case studies that are applicable to Cudahy, the History of Cudahy and how the City got to where they are today, then an introduction to Latino Urbanism and how it has shaped the Cudahy built environment to what it is today.

Recommendations are made based on the findings, empha-
sizing the need for inclusive, context-sensitive designs that prioritize cultural expression, community collaboration, and enhancing Cudahy’s sense of place.

STRATEGIC PLAN FOR A THRIVING COMMUNITY 129

4.2 CULTURAL PLACEMAKING INDICATORS
Parks Needs Assessment
Parks and recreation play a crucial role in placemaking and cultural preservation, contributing to the community’s well-being.

Parks serve as central gathering spaces, becoming focal points for how residents often define their neighborhood and its assets.

They provide the Cudahy community with spaces for cultural events, celebrations, and other public programs, which help to foster a “sense of belonging” and allow for the continuation of cultural traditions and practices. Preserving and creating new opportunities to celebrate and uplift the cultural diversity of the community through the availability and access of public open spaces and recreational amenities will improve the quality of life for Cudahy residents, making the area more attractive and livable.

Like the concept of “transit-induced displacement,” “green gentrification” occurs when the investment of new public spaces contributes to the eventual displacement of existing residents.

Studies done by the National Recreation and Park Association have shown that proximity to well-maintained parks can increase property values in the surrounding area as people are often will- ing to pay more for homes near these neighborhood assets. As a result, rent-burdened and housing-insecure communities have experienced dramatic increases in their cost of living, affecting their ability to remain in their own home.

Parks and open spaces can also play a significant role in the local economy, contributing to economic growth, job creation, and tourism. Parks attract visitors and residents alike, contributing to increased foot traffic and economic activity in the surround- ing areas where they can access neighborhood services, dining, shopping, and recreational activities, boosting the local economy through increased patronage during park-related activities and events. The maintenance and operation of parks also create job opportunities, especially as many parks and recreation depart- ments prefer local hires who can better relate to the community members they serve. Parks also contribute to green infrastructure, helping manage stormwater, improve air quality, and mitigate the urban heat island effect. These environmental benefits can lead to cost savings for local governments and businesses in dealing with environmental challenges.

The Los Angeles County Board of Supervisors adopted the 2016 Countywide Parks Needs Assessment [PNA], which compre-
hensively analyzed and quantified the need for parks and recre- ational facilities in cities and unincorporated areas throughout the County, including Cudahy. Since its adoption, the PNA has guided the County in addressing inequities and funding alloca- tion for parks and recreation. The PNA has directly informed the development of Measure A, including dedicated funding for Very High and High park-need study areas. In 2022, the County of Los Angeles Department of Parks and Recreation released the 2022 Parks Needs Assessment Plus [PNA+], which builds upon the 2016 assessment and incorporates a study of conservation and restoration, regional recreation, and rural recreation. The PNA+ also provides mapping and analysis tools for studying population vulnerability, environmental benefits, environmental burdens, and priority areas for investment.

In the 2016 PNA, Cudahy was identified as a city with “Very High Park Need.” With 19.8 acres of park space, Cudahy has

0.8 acres of park space per 1,000 residents, which is signifi- cantly lower than the countywide average of 3.3 acres of park space per 1,000 residents [also below the recognized stan- dard of 4 acres of open space per 1,000 residents]. Park need is then determined by assessing this park acreage, the distance to the parks, and population density. In Cudahy, it was deter- mined that 67% of residents live in “Very High Park Need” areas, and the remaining 33% live in “High Park Need” areas. As the City of Cudahy considers opportunities for cultural preserva- tion, economic development, and transportation accessibil- ity, it will be important to consider opportunities to enhance the open space network and recreational programming.

Parks Needs Assessment

130

STRATEGIC PLAN FOR A THRIVING COMMUNITY
Tree Equity Score
Tree Equity Score
In Los Angeles County, there is a clear disparity in tree equity, with Southeast Los Angeles County showing some
of the highest levels of tree inequity. This discrepancy high- lights a lack of adequate tree canopies in communities with a high concentration of low-income people of color, further exacerbating environmental and social in equalities.

Urban forestry plays a vital role in combating the “urban heat island” effect by replacing pavement, buildings, and other heat-absorbing surfaces with natural shade canopies that can significantly lower neighborhood temperatures.

Beyond its environmental benefits, an expanded urban
forest can transform a community’s overall sense of place by creating inviting, vibrant spaces that foster social inter- action, pride, and identity. In Cudahy, where high popula- tion density and limited public space contribute to open space deficiencies, street trees and green corridors can become a cornerstone of the city’s open space network.

Strategically integrating trees into streetscapes, parks, and public spaces enhances the connectivity, accessibility, and usability of green spaces while encouraging walkability, bikeability, and transit use.

At a regional scale, urban forests mitigate climate change by capturing carbon dioxide, mitigating the effects of
heat waves, and improving air quality. Locally, street
trees near public spaces encourage residents to gather, interact, and engage with their surroundings, reinforc- ing a shared sense of belonging and community identity.

Thoughtful selection of tree species—prioritizing resil- ience, low maintenance, and maximum shade cover-
age—will ensure long-term success, creating cooler,
healthier, and more welcoming neighborhoods for
Cudahy residents. By prioritizing urban forestry, Cudahy can address environmental inequities while shaping
a more connected, livable, and inclusive community.

The Tree Equity Score, provided by American Forests,
assesses the extent to which the advantages of urban tree canopy reach individuals most in need. The scoring system sets an equity-first benchmark to direct investments in communities characterized by low-income, communities
of color, and all those disproportionately impacted by
factors such as extreme heat, pollution, and other envi- ronmental factors. The distribution of tree equity scores is categorized by highest priority [0-69], high priority [70-79], moderate priority [80-89], and lowest priority [90-99].

Cudahy has a tree equity score of 63, which puts the city in the “Highest Priority” category of communities in need of greater urban forestry. Out of the 12 census blocks
comprising Cudahy, nine were identified as the “Highest Priority,” two of the nine being the study area for Cudahy Together, and the other three were ranked as “High Prior- ity.” To achieve tree equity in Cudahy, around 11,636 trees must be planted citywide, particularly in areas of high- est priority. This will increase total canopy coverage by 20% and raise the total value of economic benefit by over $150,000, according to i-Tree Landscape, an application that uses tree cover maps and other data to estimate
ecosystem services of trees spatially.

132
CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN STRATEGIC PLAN FOR A THRIVING COMMUNITY 133

4.3 SITE ANALYSIS
Lynch Diagram Study
As part of the site analysis process, City Fabrick facilitated a Lynch diagramming exercise to examine how the community perceives and interacts with the two proposed Metro station areas and the Atlantic Avenue corridor in Cudahy. Based on urban planner Kevin Lynch’s seminal work, The Image of the City, a lynch diagram analyzes mental maps and urban experiences by identifying key elements—paths, edges, districts, nodes, and land- marks—that shape navigation and sense of place. In Cudahy, the exercise went beyond spatial analysis, incorporating cultural and social dimensions to capture the city’s rich heritage and identity.

The elements of Lynch Diagram are defined as follows: → Paths: The major circulation routes that people use to move through a space, such as streets, sidewalks, trails, or transit lines. These routes shape how individuals experience and navigate an area.
→ Edges: The boundaries or transitions between different areas, which can act as barriers or connectors. Examples include rivers, walls, highways, or abrupt shifts in land use. → Districts: The identifiable areas or zones within a community that share a common character or purpose, such as residen- tial neighborhoods, commercial corridors, or industrial areas. → Nodes: Centers of activity, intersections, or gathering points where people come together, often marked by increased
movement, interaction, or significance. Examples include transit stations, plazas, or market squares.
→ Landmarks: Distinct physical or symbolic features that stand out and serve as points of reference, such as buildings, monu- ments, public art, or natural features like hills and parks.

By examining these elements, the Lynch diagramming process reveals how communities perceive their environment and
identifies opportunities to strengthen physical, cultural, and social connections.

Lynch Diagram

134 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 135 Key Takeaways
Study Area One - Florence and Salt Lake Station
Nodes
→ The Salt Lake Market, located at Salt Lake Avenue and Live Oak Street, serves as a vibrant community hub and
gathering place for residents.
→ Otis Street is home to a variety of community-centered establishments, including a market, barbershop, community center, and church.

Paths
→ Major
• Otis Street is a key thoroughfare in the area, linking East and West streets while providing residents with
access to Lugo Park and other local community spaces.
• Florence Avenue is a major thoroughfare and the
economic backbone of Huntington Park, featuring
a diverse range of businesses along its commercial
corridor. However, the built environment along Florence Avenue prioritizes automobiles over pedestrians, creating challenges for walking and accessing businesses on foot. • Salt Lake Avenue serves as a key connector, linking
residents to the proposed Metro Transit Station and
providing easy access to Salt Lake Park.
→ Minor
• Flower Street, Walnut Street, and Live Oak Street are primarily residential streets within the community.
• Though small, Bear Street plays a vital role in
connecting residents to the Salt Lake Market and
Salt Lake Avenue.

Edges
→ Salt Lake Avenue presents a significant transportation barrier for cyclists and pedestrians, making access to the transit stations challenging.
→ Salt Lake Avenue is currently car-centric, with limited accessibility for pedestrians and cyclists. However, there is significant potential to enhance the street by prioritizing improvements for pedestrians and cyclists.
→ The wide intersections make it difficult for residents to cross the street and reduce visibility for drivers turning left. → Salt Lake Avenue restricts east-west connectivity, obstructing movement and accessibility between neighborhoods. → The rail tracks along Salt Lake Avenue obstruct connectivity between Cudahy and Huntington Park.

Districts
→ This study area is primarily residential, with only a small amount of light industrial activity.
→ Florence Avenue is a commercial corridor with small
businesses, auto-oriented establishments, and several
vacant storefronts.
→ This sector is characterized by long parcels, each housing multiple residential units.
→ Several corner markets embody the characteristics of
traditional urbanism.
→ Otis Street offers more neighborhood-serving commercial uses for residents.

Landmarks
→ A community-created mural at Lugo Park offers vibrant and meaningful artistic expression for residents.
→ Salt Lake Park is a key landmark in the community and will provide an ideal access point for Metro transit riders exiting the station.
→ The water storage tank in Huntington Park serves as a distinctive landmark for residents.
→ The Southern California Edison property is another recognizable landmark for Cudahy residents can easily recognize.

Study Area Two - Atlantic and Firestone Station
Nodes
→ Atlantic Avenue is the area’s primary commercial corridor, offering the greatest potential for improvement through artistic development and business growth.
→ Cudahy Plaza is a key attraction and central gathering place for the community due to its connection to the
Cudahy CART system.

Paths
→ Major
• Atlantic Avenue is the primary corridor in this sector, providing key access to the entire city and its most
prominent landmarks.
• Santa Ana Avenue provides the best east-west connectivity in the city, offering convenient access to City Hall and Cudahy Park.
• Wilcox Avenue is a key connector, linking the light
industrial area to the south with the residential
neighborhoods to the north, making it a vital route
in the community.
• Salt Lake Avenue is a key connector, linking residents to the proposed Metro Transit Station and providing
easy access to Salt Lake Park.
→ Minor
• Patata Street dead-ends to the east and does not
provide a significant connection to other areas.
• Cecilia Street serves as a boundary between the industrial and residential areas, connecting Atlantic Avenue and Wilcox Avenue.

Edges
→ Salt Lake Avenue poses a major transportation barrier CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN 135
for cyclists and pedestrians, hindering access to the
transit stations.
→ Salt Lake Avenue is currently car-centric, with limited accessibility for pedestrians and cyclists. However,
it serves as a crucial connection between Atlantic
Avenue,the South Gate Transit Station, and the Huntington Park Transit Station. → The rail tracks along Salt Lake Avenue disrupt connectivity between Cudahy and South Gate, extending further along Patata Street.

Districts
→ This study area is primarily industrial in character, with a mix of residential and commercial properties.
→ Patata Street is home to a vibrant food market, where vendors offer a variety of goods to the local community. → Atlantic Avenue serves as the area’s economic corridor, with vacant lots offering opportunities for community-led development.

Landmarks
→ Chris Burgers on Santa Ana and Atlantic is a beloved
landmark in the community, serving as a local staple for many years.
→ Castro Discount Tires, located at Atlantic and Santa Ana, is a key destination for local residents and occupies Cityowned land under lease. → The coin-operated laundry is another popular community spot.

Public Realm Inventory
The Project Team conducted a Public Realm Inventory study to document and evaluate public spaces within the city, including streets, sidewalks, parks, plazas, and other communal areas. This study focuses on assessing the design, quality, and functionality of these spaces to identify areas for improvePage 162 of 2485 136 CUDAHY STRATEGIC VISIONING IMPLEMENTATION PLAN STRATEGIC PLAN FOR A THRIVING COMMUNITY 137 ment, ensuring they are safe, welcoming, and conducive to public use.

A key aspect of this analysis is evaluating street and sidewalk widths, as they are critical for determining the feasibility of improvements like bike lanes or expanded street tree plantings. These improvements can enhance accessibility, providing more equitable opportunities for pedestrians and cyclists. By assessing available space, the study identifies ways to balance transportation needs with public amenities.

Additionally, the inventory highlights potential infrastructure challenges, such as utility poles, utility boxes, and other obstructions, that may impede pedestrian flow or hinder the development of continuous, safe trail networks. Identifying these barriers is essential for making informed decisions to improve connectivity and create more functional public spaces for all users.

Key Takeaways
Study Area One - Florence and Salt Lake Station
Salt Lake Avenue [Elizabeth Street to Cecilia Street]
→ This segment is predominantly residential and runs parallel to the train tracks. On the east side, intermittent street parking is available along the sidewalk. The opposite side of the street is bordered by a strip of unpaved private property adjacent to the tracks.
→ This segment features a roadway width of 32 feet, providing insufficient space for the addition of a bike lane or the expansion of the sidewalk. As it stands, it is currently a two way vehicular lane.
→ Sidewalk widths range from 4 to 7 feet, making some
areas more challenging to navigate than others. There is insufficient sidewalk width to accommodate a parkway
or street trees.
→ The sidewalk is narrow and not very pedestrian-friendly, often interrupted by driveways and entrances. There are 14 utility poles and 3 utility boxes on the sidewalk that impede travel for pedestrians.
→ The average block length in this area is 507 feet which exceeds the ideal distance for pedestrian comfort.
→ This area lacks shade trees, making it uncomfortable for pedestrians, especially during the day when direct sunlight can create a harsh walking environment.
→ The design of the intersections create more space than necessary for the pedestrian movement, which can be
repurposed for widening the sidewalk, adding landscaping, or creating seating or other pedestrian-friendly features. → This sector is classified as part of the freight zone in the circulation element, further exacerbating challenges for pedestrians and cyclists.

Clara Street [Salt Lake Avenue to Otis Street]
→ This segment is entirely residential, featuring a mix of single-story homes with front yards and driveways.
→ Intermittent street parking is available on both sides of the street.
→ The roadway width is 36 feet, insufficient for a dedicated bike lane. However there is the potential to add a shared lane for both bicyclists and vehicles.
→ The sidewalks are 9 to 10 feet, providing ample space for enhancements. This area could accommodate street
trees, adding shade and greenery to improve the pedestrian experience. → The sidewalk is lined with a mix of medium and large trees, many offering shade through their canopies. However, tree cover is inconsistent, with occasional shade provided by trees on private property that spill into the public space. → This segment is primarily made up of single-family homes, characterized by a predominately minimal traditional architectural style.

Otis Street [Walnut Street to Clara Street]
→ This segment is entirely residential, featuring a series of single-story homes with front yards and driveways.
→ Intermittent street parking is available on both sides of the street. Additionally, the presence of speed humps in the center of the street helps slow down traffic, enhancing pedestrian safety and creating a more walkable environment. → The roadway width is 37 feet, insufficient space for the addition of bike lanes.
→ The sidewalks range from 5 to 6 feet in width,sufficient space for pedestrians. However, the average block length in this area ranges between 230 and 500 feet, making
some sections pedestrian-friendly while others are less so. → This area lacks street trees, resulting in insufficient shade and reduced comfort for pedestrians.
→ This segment is primarily made up of single-family homes, primarily characterized by a minimal traditional architectural style.

Walnut Street [Salt Lake Avenue to Otis Street]
→ This segment is primarily residential, with single-story homes featuring front yards and driveways, alongside two large commercial establishments, including a truck dealership. → Intermittent street parking is available on both sides of the street. The southside sidewalk features a relatively consistent landscaping strategy, with parkways enhancing the streetscape. → The roadway width is 28 feet, insufficient for the addition of a bike lane.
→ The sidewalks are 9 to 10 feet wide, offering ample space for street trees. Additionally, the blocks are over 600 feet long, presenting an opportunity for further pedestrian-friendly enhancements. → This area has few street trees, and those present do not provide sufficient shade for pedestrians.
→ This segment is primarily made up of single-family homes, characterized by featuring a predominately minimal traditional architectural style.

Study Area Two - Atlantic and Firestone Station
[Patata Street [Salt Lake Avenue to Wilcox Avenue]
→ This street is predominately lined with light industrial and commercial businesses, along with vacant lots, and is defined by train tracks running the entire length of Patata. → The roadway width is 40 feet, sufficient space for a bike lane. However, with parking permitted on both sides, a
tradeoff would be necessary to accommodate both uses.
→ Patata Street has 5-foot-wide sidewalks and blocks averaging 1,200 feet in length. While the sidewalks offer sufficient space for walking, the long, uninterrupted stretches contribute to a car-centric environment, lacking opportunities for breaks or pedestrian-friendly pauses. → There are no street trees providing shade for pedestrians, and only one the northern side of the street has a usable sidewalk. The opposite side features an empty lot, limiting pedestrian access and comfort.
→ Its limited access from Atlantic Avenue makes it poorly connected to the surrounding neighborhood, creating
challenges for pedestrians.
→ A large street vending operation takes place here on weekends, increasing litter and creating potential safety hazards for pedestrians. The high volume of activity can make the area feel congested and uncomfortable for foot traffic.

Santa Ana Street [Atlantic Avenue to Wilcox Avenue]
→ The street is primarily residential, featuring a mix of single-family homes, apartment complexes, vacant lots,
and commercial retail at the corners.
→ The roadway width is 35 feet wide, insufficient space for a bike lane. However, tree extensions are feasible with minimal removal of parking.

138 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 139 → Santa Ana Street’s sidewalks are seven feet wide, providing ample space for pedestrian access. However, the block lengths range between 1,900 and 1,950 feet, too long for comfortable pedestrian movement, making the area feel
less walkable and more car-dependent.
→ The area features numerous driveways, running through a residential neighborhood with commercial establishments at the corners. This mix of land uses creates both access points and potential challenges for pedestrians navigating the street.
→ This area lacks street trees providing shade for pedestrians, but the ample space available presents a significant opportunity to improve sidewalk conditions and enhance
the walking experience.
→ There are 15 utility poles and two utility boxes along the sidewalk, which can create obstacles and contribute to discomfort for pedestrians. → There is no access to public transportation along this street.

Wilcox Avenue [Elizabeth Street to Patata Street]
→ This stretch of Wilcox is primarily residential, with the exception of the segment between Cecilia and Patata, which is characterized by vacant lots and industrial factories.
→ The roadway width is 45 feet wide, sufficient space for a bike lane. However, with parking permitted on both sides, a tradeoff would be necessary to accommodate both uses. → The sidewalks on both sides of the street are seven feet wide, providing ample space. However, the 800-foot block length is more geared toward vehicular traffic, making the area feel car-centric rather than pedestrian-friendly.
→ There are very few street trees along the sidewalk, limiting shade and comfort for pedestrians. Additionally, utility poles along the sidewalk create obstacles that hinder pedestrian movement and safety.
→ This area has some commercial activity, but all crosswalks are unsignalized, making crossing the street more challenging for pedestrians. Additionally, various traffic signs along the street help manage vehicle flow.

Atlantic Avenue [Elizabeth Street to Patata Street]
→ The business corridor ends at Santa Ana Street, and from there to Patata Street, the area is predominantly characterized by vacant lots and car garages, with only a few remaining businesses. This stretch is shaped by auto-oriented development, prioritizing vehicles over pedestrians and cyclists, which diminishes the sense of place and limits the potential for a vibrant, walkable community.
→ The roadway width is 75 feet wide, sufficient space for a protected bike lane.
→ The streets along Atlantic Avenue have sidewalk widths ranging from eight to nine feet, with block lengths averaging between 670 and 900 feet.
→ There is a lack of trees along both sides of the street, with trees only present in the median. However,there is enough sidewalk space to add shade trees and improve
the urban greenery.
→ Utility boxes are adorned with mural art, and there is potential for further artistic expression on blank walls and storefronts throughout the area. → The area features a variety of businesses, including Sprouts, Chuze Fitness, McDonald’s, and Jim’s Burgers, offering a mix of retail, dining, and fitness options.

Study Area Three - Atlantic Avenue
→ Atlantic Avenue serves as Cudahy’s main business
corridor, including a dynamic mix of retail shops,
restaurants, and upscale marketplaces. This main
corridor is lined with strip malls, offering expansive
parking lots and on-street parking. These auto-oriented patterns prioritize vehicles over other modes of transportation, which can erode the community’s sense of place and hinder the development of a more walkable, inclusive environment. However,he blend of businesses creates a lively environment that caters to both local residents and visitors. → The roadway is 75 feet wide, sufficient space for a
protected bike lane.
→ The corridor has limited street tree coverage, with some medians featuring ficus trees. As a high-traffic corridor, enhancing greenery in this stretch could improve both
aesthetics and the overall pedestrian experience.
→ Cudahy’s sidewalks typically range from 8 to 9 feet wide, providing ample space for pedestrian movement and
accessibility. This width also offers opportunities for enhancements that could elevate the pedestrian experience, making the area more inviting and functional for residents and visitors alike.
→ The block lengths along the Atlantic Corridor are notably long, measuring 800 feet long poses challenges for pedestrians and reinforces a car-centric environment. The corridor is lined with many driveways, creating interruptions that further complicate pedestrian movement and safety. → The Atlantic corridor has two motels, two mobile home/ trailer parks, and two gas stations. These land uses are typically considered to be undesirable land uses non-conducive to pedestrian accessibility. → The Atlantic Corridor has several vacant lots, which present opportunities for potential improvements and development. However, these empty spaces can also contribute to challenges for pedestrians, such as uneven streetscapes and areas that may feel unsafe or neglected, impacting the overall walking experience.
→ The Atlantic Corridor is equipped with a range of
street furniture, including trash receptacles, street
pole banners, and bus benches with shelters, enhancing both functionality and the visual appeal of the area.

Public Space & First/Last Mile Study
Zoning Study
Zoning plays a crucial role in community preservation and cultural placemaking by shaping the physical environment and guiding long-term development. It can designate areas as historic or cultural districts to preserve the character, architectural heritage, or cultural institutions of a community. Zoning regulations in these historic and cultural districts often restrict building height, materials, and design to maintain the area’s historic and cultural integrity. Similarly, zoning regulations can also help to preserve a community’s unique identity by regulating building design, signage, and landscaping, creating a cohesive and visually appealing environment that reflects the community’s culture, values, and history.

Zoning can encourage mixed-use development, fostering
vibrant, walkable communities where residents can live, work, and shop in close proximity, enhancing the sense of place. When centered around public transportation hubs, this approach reduces reliance on vehicles, promoting a more sustainable and livable community. Zoning also supports affordable housing by permitting higher-density development, reducing minimum lot sizes, and offering incentives for affordable housing projects, helping to maintain diversity and accessibility to people of all income levels. Additionally, zoning can expand a city’s open space network by integrating plazas, parks, alleys, parkways, and other naturalized areas into a community fabric.

While zoning is a powerful tool for shaping the built environment, it has limitations in transforming and preserving communities. Zoning regulations are often static and can be slow to adapt to evolving needs and priorities, hindering efforts to address challenges like affordable housing, climate change, and economic development. Moreover, zoning is just one of many factors that influence community development, with its impact often constrained by market forces, political pressures, and infrastructure constraints. A holistic approach that integrates zoning with other planning tools and strategies is essential for creating lasting and meaningful change.

In adherence with the California Government Code, the City of Cudahy has a comprehensive zoning ordinance and development standards outlined in Title 20 of its Municipal Code.

Aligned with the City’s Land Use Element, the ordinance aims to promote orderly growth, preserve the character of residential neighborhoods, and ensure land use compatibility. Strategies proposed under Cudahy Together must account for the City’s existing zoning regulations, identifying how these rules may either support or constrain developments that address the planning needs of Cudahy Together target populations.

This summary highlights key provisions of Cudahy’s zoning ordinance and development standards.

Zoning Districts
Revisions to the zoning use table in the City of Cudahy offer a strategic opportunity to shape neighborhoods by prioritizing amenities residents value most. While it is not simple, by updating the use table to include specific categories for desired amenities– such as parks, community centers, libraries, and grocery stores– the city can demonstrate its commitment to fostering well-resourced communities. These changes could also enable mixed-use developments that seamlessly integrate these amenities, promoting vibrant, walkable neighborhoods that cater to the needs of residents. Involving the community in the process ensures that updates reflect local priorities, fostering more inclusive and responsive zoning policies. Table 20.16-1 of the zoning ordinance identifies the complete list of permitted and conditional uses within these residential designations.

Zoning in Cudahy plays a critical role in advancing– or hindering– transit, environmental, and social equity. Policies that prioritize mixed-use development and pedestrian-friendly infrastructure can strengthen the active transportation network, benefiting low-income residents who rely on walking, biking, or public transit. On the other hand, automobile-cenPage 164 of 2485 140
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 141 Zoning
tric design or restrictions on mixed-use development can create barriers, limiting access to jobs and essential services for underserved communities. To foster greater equity,
Cudahy should implement zoning policies that support active transportation, stimulate local economic development, and enhance placemaking efforts in the city’s most underserved areas, paving the way for a more inclusive and equitable community.

In certain cases, property owners in Cudahy may pursue a variance to deviate from the zoning ordinance. A CUP allows specific land uses that are not permitted without an additional review process and public hearing within a zoning district,and whose approval is accompanied by mandated conditions . A variance permits exceptions to zoning requirements, such as setbacks or building height, when unique circumstances justify the deviation.

The City of Cudahy is divided into several zoning districts, each with specific regulations guiding land use and develop- ment. These districts are governed by development stan- dards, including setbacks, building height, lot coverage, parking requirements, landscaping, and signage, all of which influence the built environment’s sense of place, accessibil- ity, and safety.

The primary zoning districts in Cudahy, along with their asso- ciated development standards, include: → Residential Zones These zones are designated primarily for single-family and multi-family residential uses, with regulations covering minimum lot size, setbacks, building height, and density.

Front yard setbacks allow space for creative landscaping, contributing to the neighborhood’s character. In Medium and High-Density Residential Zones [MDR & HDR], where
front yards are required, developments must also include a minimum of 280 square feet of common open space for
each dwelling unit. The City strongly encourages using this open space for tot lots, exercise areas, and other features that enhance the quality of life for residents.

Cudahy’s residential zoning permits home-based occu-
pations and businesses within dwelling units, subject
to reasonable restrictions. Notably, no more than 200
square feet of floor space can be used for such opera-
tions. Beyond residential uses, permitted by-right uses in these zones include child daycare homes, urban agricul- ture, public elementary schools, and group homes.

Section 20.16.130 of Cudahy’s residential zoning code
requires development to undergo a design review
process and comply with architectural standards to
ensure compatibility and visual appeal in new develop-
ments. The planning staff evaluates proposed buildings
for consistency with surrounding structures in terms of color, materials, and design. Both new and existing build- ings are subject to this review, and the City can require improvements or rehabilitation for existing structures
when new dwelling units are proposed.

To promote architectural variation, new buildings must
incorporate design elements such as articulation, varied roof forms, and staggered setbacks to avoid long, monot- onous walls and monotonous facades. While the City
possesses authority over the design of residential devel- opments, it has not yet established a distinct architectural style or vision that reflects the cultural diversity of the community. This absence leaves room for a more inclu-
sive and representative design framework that celebrates Cudahy’s unique identity.
→Commercial and Industrial Zones
There are four distinct commercial and industrial zones in Cudahy, each tailored to support specific types of busi- nesses and activities, ensuring balanced and sustainable development. These zones include the Neighborhood
Commercial Zone [NC], the Entertainment Zone [Ent],
the Innovative Industrial Zone [I-Ind], and the Light
Industrial Zone [LI]. Each zone is strategically designed to foster economic growth, job creation, and commu-
nity well-being, while maintaining compatibility with
surrounding land uses.

The NC zone in Cudahy is designed to provide conve-
nient commercial services to residents who are further
from the Atlantic Avenue District. It supports small-scale businesses like corner produce stores, mini-markets, and small business offices, promoting essential services within walking or biking distance and fostering local accessi- bility and promoting community cohesion. While the
NC zone is crucial for meeting the commercial needs of
the residential community, it is currently limited to a few parcels at key intersections away from Atlantic Avenue.

The Ent zone is intended for large-scale entertainment
venues that attract patrons from Cudahy and surround-
ing areas. Within this zone, design standards prioritize pedestrian accessibility and engagement along Atlantic
Avenue with vehicular access and parking situated at the rear of properties to minimize disruption to pedestrian flow and enhance the overall experience for visitors.

The I-Ind zone in Cudahy is a forward-thinking zoning desig- nation that allows for a flexible mix of uses to encourage job interactivity beyond traditional business hours, supporting start-ups, light industrial activities, office spaces, and live/ work arrangements, along with permitting the adaptive reuse of former industrial buildings or spaces, reflecting a commit- ment to sustainable development practices. Particularly suited for businesses in emerging industries such as “green” biotechnology, software development, and other innovative sectors, the I-Ind zone contributes to the city’s economic diversity and resilience. Cudahy’s LI zone allows space for a variety of light industrial activities that can operate in prox- imity to residential areas without posing significant health or safety risks, supporting job creation and economic growth while maintaining compatibility with nearby residential neighborhoods, creating a balanced and diverse economic environment benefiting both businesses and residents.

STRATEGIC PLAN FOR A THRIVING COMMUNITY 143
Commercial uses that are allowed and prohibited in the NC and Ent zones are described in Section 20.20.020 of the Municipal Code. The NC zone allows for several neighborhood-serving amenities [education centers, art and music studios, retail, and grocery stores permitted by-right], while prohibiting uses that can cause harmful impact to the existing residential and business community [drive-thrus, hotels, liquor stores, casinos, breweries, and autobody shops].

In Cudahy’s Ent zone, residential uses are only allowed in conjunction with mixed-use developments, with a restriction that residential units cannot occupy ground floor spaces, and such developments must ensure that less than two-thirds of the total floor area is dedicated to residential uses. Like the residential zones, the Ent zones require development to undergo design review, and includes development agreements and public benefits including on-site and off-site improvements such as public art, community facilities, pedestrian and bicyclist amenities, or monetary contributions to the City of Cudahy. None of these four zones currently define a specific architectural design style or vision that is reflective of the community’s cultural diversity.

Cudahy’s entertainment and commercial land uses are
primarily located along Atlantic Avenue. Firestone Station will be located along Atlantic Avenue, less than a quarter mile south of Cudahy’s border with South Gate. This station location is poised to be a catalytic public investment that will vastly improve mobility and access for local residents, visitors, and employees of the entertainment district.

The proximity of this station and proposed transit service suggests that there will be hundreds to thousands of people without a vehicle will be getting on and off the train every day. Employees will have greatly improved access to local jobs that would be within a 15-minute walk of the Firestone Station. Local residents will also benefit from expanded access to/from the entertainment district by being less reliant on private vehicles and the availability of parking in an area with relatively high parking demand. From a
development perspective, the proximity to this transit
station would allow for streamlined review of office, retail, and residential land uses, while residential land use could be constructed with little to no off-street parking.

The Florence/Salt Lake Station is just under a mile from the Atlantic Avenue corridor, which calls for commercial mixed uses along the corridor. While not as proximate
to the Atlantic Avenue corridor as Firestone Station, this location will also provide benefits of improved access and alleviate the need for transit patrons to find parking in the study area. The distance of this station would not allow streamlining of development review or reduced parking
supply, however, it is still anticipated to catalyze opportunities for local development along Florence Avenue that will offer additional opportunities for mixed-use development that can bring new job, retail, and housing opportunities for local residents. → Mixed-Use Zones
In Cudahy, two mixed-use zones are established to foster integrated residential and commercial development on
the same or adjacent parcels. The Commercial MixedUse Zone [CMU] allows a concentrated commercial hub, including retail, office space, limited automotive services, mixed-use, and residential uses. Development in this zone prioritizes pedestrian-friendly design with active street frontages, appropriately scaled buildings, and accessible spaces like plazas and courtyards. Transparent storefronts and offices that engage with the sidewalk are encouraged to enhance the pedestrian experience.

The Civic Mixed-Use Zone [CivicMU] accommodates
a mix of commercial, residential, and civic uses, incorporating public plazas, amphitheaters, and urban open spaces to create a vibrant community center. This zone
is designed to attract residents, employees, and visitors, fostering a dynamic, interactive space within Cudahy.

Commercial uses permitted and prohibited within the
CMU and CivicMU zones are described in Section

20.28.020 of the Municipal Code. Notably, the CMU
zone allows for various neighborhood-serving amenities, while prohibiting uses that can negatively impact the surrounding residential and business communities. However, with a CUP, certain uses such as drivethrus, hotels, and minor auto repair uses are allowed.

While these zones include design requirements aimed
at enhancing the overall pedestrian experience, they
do not encourage a specific architectural design style
or vision that reflects the cultural diversity of Cudahy’s residential and business communities.

Commercial uses permitted and prohibited within the
CMU and CivicMU zones are described in Section

20.28.020 of the Municipal Code. Notably, the CMU
zone allows for various neighborhood-serving amenities, while prohibiting uses that can negatively impact the surrounding residential and business communities. However, with a CUP, certain uses such as drivethrus, hotels, and minor auto repair uses are allowed.

While these zones include design requirements aimed
at enhancing the overall pedestrian experience, they
do not encourage a specific architectural design style
or vision that reflects the cultural diversity of Cudahy’s residential and business communities.

144
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 145 Building Height
How tall a building can be,
typically by number of stories
Development Districts
Unique overlays that help to achieve
and attract specific types of uses
Building Density
How many units are allowed in
a building based on the size of
the parcel
Frontage
Design requirements for how
the building interacts with the
public realm
Active Uses
Businesses and services that
attract pedestrian activity
Form
How tall a building can be,
typically by number of stories
What Does Zoning Influence?

146
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 147

4.4 LITERATURE REVIEW
Economic Development Strategic Plan
City of Cudahy
Recently adopted in 2023, the City of Cudahy Economic Develop- ment Strategic Plan [EDSP] outlines a comprehensive economic development strategy to revitalize the Atlantic Avenue corri- dor. Through a series of planning and engagement initiatives conducted between 2018 to 2022, Atlantic Avenue was identified as a key area for community and economic development efforts, revitalizing the corridor to serve as the City’s primary commer- cial tax generator. The EDSP will guide Cudahy’s community and economic development activities along Atlantic Avenue over the next five to ten years.

As part of the EDSP planning effort, a data-driven and stake- holder-informed market analysis was recently conducted to identify the real estate market opportunities for businesses and land uses that align with the City’s economic vision and better serve the existing community. Given that most Cudahy residents currently spend their money outside of the city, providing them with local access to commercial and enter- tainment options is important to keep their spending within the community. With community engagement at the forefront, the Project Team conducted various community and business outreach for over a year to help inform the EDSP recommen- dations. As part of this economic study, the following commer- cial market opportunities were explored according to existing policy and zoning standards:

The market study revealed that existing industrial businesses are not significantly contributing to the City’s economic base. The City’s rezoning of industrial land to Entertainment District uses is expected to drive greater redevelopment activity around these underutilized and disinvested industrial properties. As part of the EDSP, it is recommended that these existing businesses should be evaluated on a property-by-property basis for code and licens- ing violations, with special consideration given to non-conform- ing business operations to mitigate the threat of displacement.

The engagement feedback that was collected as part of the EDSP planning process is honored and has been incorporated into Cudahy Together’s planning process, including: → How Cudahy residents describe their community → Favorite Cudahy destinations → Local landmarks that are associated with the Cudahy identity
→Desirable community amenities
→Destinations outside of Cudahy
→City branding and identity
As part of the community engagement, Cudahy residents
and businesses shared their desires for particular qual- ity-of-life amenities in Cudahy. The findings revealed
that transportation and placemaking amenities such as
pedestrian walkability, retail/dining/family entertain- ment offerings, and other community gathering spaces
were identified as important needs to enhance Atlantic
Avenue. The following Community Quality-of-Life Goals
are presented in the EDSP and holds relevance to the
Cudahy Together planning efforts:

An important aspect of a thriving entertainment hub is having a community identity and branding that is reflective of the city. As part of the EDSP, one of the major goals is to create a unique brand and identity to enhance the corridor’s overall sense of place; this would be implemented through graphic collateral, such as signage, at future redevelopment sites and public infrastructure, and establishing architectural and place- making design guidelines. It was also recommended that this brand and identity involve a community outreach process and incorporate Latino Urbanism design elements [see page 166].

Through the EDSP, three key programs that the City of
Cudahy is looking to establish to revitalize Atlantic Avenue are the Business and Investment Attraction Program, Commu- nity Preservation Program, and Major Projects Accelerator Program. Metrics of success are also defined as part of these programs. Through the Business and Investment Attraction Program, the City is poised to strategically revitalize commer- cial properties along Atlantic Avenue, focusing particularly on areas that have been neglected or underutilized. The City identified various prime locations that would be beneficial for urban infill redevelopment that aligns with the goals and vision of bringing more job opportunities and increasing fiscal revenue through property and sales tax contributions. The following opportunity sites were identified as areas of focus for the Business and Investment Attraction Program:

The potential vision for these large development sites on Atlantic Avenue is geared towards more regional-serving commercial uses as well as multi-family residential uses, which current market conditions show demand for housing develop- ment due to a “chronic and critical lack of sufficient supply”. As part of the engagement for the EDSP, stakeholders from the private real estate development community are supportive of the Business and Investment Attraction Program and were engaged in advancing potential [and some now approved]

148 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 149 development approvals for regional-commercial uses such as Starbucks, Sprouts, a casino, hotels, and other commercial and mixed-use developments along Atlantic Avenue.

While serving as major sales tax generators for the City, these regional superstore developments led by corporations will likely result in commercial [and potentially residential] displacement without a comprehensive strategy to protect our most vulnerable communities. Cudahy’s City Council
has established an important goal of protecting existing businesses from the potential negative impacts of redevelopment such as displacement. As part of the Cudahy Together, it is important to complement the vision for these Investment Attraction Program opportunity sites with strategies to attract business to and support the preservation of existing small businesses, draw in neighborhood-serving uses and amenities, and promote local entrepreneurialism.

As part of the EDSP’s Community Preservation Program, the City of Cudahy seeks to launch a Small/Independent Industrial/Commercial Business Outreach Program to support in providing licensing, code violations, and relocation assistance. Responsible for business retention and attraction, a fulltime Economic Development Manager would have the role of implementing this Program, which includes the responsibility to collect data, monitor and report on business contacts, displacement risks, vacancies, and other small business needs. Cudahy Together is an important tool to prioritize and help implement this community preservation strategy by providing recommendations that expand the City’s ability to support local businesses.

The EDSP also takes into consideration the proposed Metro Southeast Gateway Line Firestone Station and proposes the Major Projects Accelerator Program to meet the existing and future demand for multifamily residential and family entertainment uses along Atlantic Avenue. This Program to implement the EDSP would help remove barriers to corridor revitalization and ensure that the City is capitalizing on these major investment opportunities and generating substantial sales and property tax revenues over time; this includes various policy recommendations presented below:

The EDSP also sets the foundation for its implementation in the Economic Development Funding Plan by providing guidance on strategies such as land banking, monetary and non-monetary developer incentives [expedited review, fee reductions and waivers], business improvement districts, adaptive zoning regulations [density bonuses, development standards, architectural and parking design requirements], public-private partnerships, and other various strategies for funding and implementation.

As the City of Cudahy plans for the economic future of Atlantic Avenue, it will be important that Cudahy Together incorporates both how existing residents will access these new amenities and how to retain and help existing businesses thrive. It is also important to consider the economic vitality and character of other parts of Cudahy, and consider how the strategies for Atlantic Avenue can also be contextually applied to these areas.

Cudahy General Plan - Economic
Development Element
Cudahy’s Economic Development Element within its General Plan aims to safeguard existing local businesses while attracting new industries that align with the community’s needs. This is important considering the potential for transit induced gentrification. The Element also focuses on supporting affordable housing, strengthening the tax base, and enhancing public services. Given Cudahy’s small size and dense population, it was important to be strategic and flexible when welcoming new businesses into the city. Through the engagement process, residents emphasized the importance of promoting stronger collaboration between the City and businesses to enhance Cudahy’s image of being a business-friendly community.

Through the Economic Development Element, it outlines strategies to achieve the community’s goals, including the establishment of chambers of commerce and business improvement districts. These initiatives are designed to promote economic growth and empower local business owners. The chamber
of commerce would provide businesses with a platform for networking, collaboration, and self-promotion within the city.

Additionally,the business improvement districts would facilitate collaboration among business and property owners to market opportunities, create a unified character for the area, and drive physical improvement projects.

Given Cudahy’s current socioeconomic factors, it is important that the City builds partnerships with local entities that would help provide workforce training, professional development, and entrepreneurial training for members of the community. Additionally, a vital aspect of facilitating the development of a robust workforce would be to invest in the provision of supportive services such as childcare services and educational/vocational opportunities for youth.

While residential properties constitute the majority of land use in Cudahy, the city is experiencing rapid expansion in its manufacturing and commercial sectors, specifically on the Atlantic corridor. Cudahy’s strategic location in the Gateway Cities region has allowed it to benefit from diverse employment sectors. The City has identified potential growth and expansion areas in business categories such as service stations, grocery stores, building materials/supply dealers, clothing and apparel stores, and full-service restaurants. As Cudahy continues prioritizing residential projects, new proposals, and transit-related initiatives are poised to stimulate the local economy and diversify job sectors.

Cudahy is cognizant of the impact of technology on various industries. In response the City has adopted flexible land use designations to position itself to adapt and accommodate the needs of future industries as they start to grow and thrive.

Cudahy General Plan - Land Use Element
City of Cudahy
The City of Cudahy Land Use Element [LUE] within its General Plan serves as the blueprint for future development in the city, delineating all pieces of land within Cudahy by land use designations, and shaping the urban landscape across the city’s diverse neighborhoods and districts. Each land use designation within the City has specific and unique development standards, and is further defined by the City’s zoning regulations and building codes. The map below shows the land use designations that cover each parcel within Cudahy. Additionally, the charts below define what the land use and urban form are for the residential, industrial, commercial/mixed use, and entertainment parts of the city.

Through data analysis and community engagement, residents identified that there is a lack of community gathering areas and open spaces, healthy food options and health-related activities, active transportation infrastructure, and underperforming or nonconforming land uses. Despite the limitations imposed by Cudahy’s existing built-out character, the Land Use Element, in alignment with the Open Space Element and Circulation Element, presents different strategies to address community needs with land use, like the creation of streetlets/cul-de-sacs, pocket parks, mini green spaces, and the promotion of urban agriculture. The LUE provides several planning implications to these and other land use challenges, including the fact that the socioeconomics of Cudahy’s residents needs to first be addressed by focusing on increasing property ownership and development. Leveraging the potential of City-owned properties to ensure that development aligns with the community’s housing needs and vision for better community health outcomes.

It also identifies the Atlantic Avenue corridor as having the most potential for commercial and entertainment uses that serve a local and regional audience. Lastly, expanding the types of uses and allowing for flexibility of land use regulations within Cudahy’s industrial areas could also attract new types of businesses and development, with consideration.

The urban design and architectural character of each land use designation is also described in the LUE. The northwest area of Cudahy near the Florence/Salt Lake Station [west of Otis Avenue] is nearly entirely classified as low-density residential, which “encourages and maintains single-family living” and is typically one to two stories tall, with front yards and backyards. The parcels that front Otis Avenue to the west change to the “medium-density residential” and the “neighborhood commercial” land use designations.

In contrast, the area of Cudahy nearest to the proposed Firestone Station is characterized by several land use designations with various districts and planning overlays. Bounded within the “urban agriculture overlay” this area consists of parcels designated under the “entertainment” land use along and directly adjacent to Atlantic Avenue, “innovative industrial” land use in the area to the west of Atlantic Avenue, and “light industrial” as well as “high-density residential” with an “industrial overlay” zone in the areas to the west of Atlantic Avenue. This is consistent with the City’s vision for the southern parts of Cudahy, and has the greatest potential for redevelopment along with the rest of the Atlantic Avenue corridor.

The “entertainment” land use designation defines a neighborhood character that accommodates large-scale entertainment uses, designed to provide pedestrian interest and accessibility along Atlantic Avenue, with vehicular access and parking located

150 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 151 to the rear of the parcels. It is also envisioned that this area would have active open spaces and paseos that link the entertainment uses together and enhance accessibility and sense of place.

Residential uses are allowed by-right in this area, but only in a mixed-use setting where residential units are on upper floors or do not face Atlantic Avenue. In addition to mixed-use residential, the types of development that the City of Cudahy is interested in attracting includes retail, theaters, restaurants, bowling alleys, skating rinks, gaming, dining, brew pubs and wineries, residential, hotels, and offices. Prohibited uses include standalone residential, automotive maintenance and garages, light industrial, manufacturing, warehousing, mini-storage, and trucking and transportation-related uses. Open spaces provided as part of new development would be designed to be public and urban in nature.

The “innovative industrial” land use designation in the southwestern portion of the city re-envisions this area as a mix of highly flexible spaces for start-ups, light industrial, office, and live/work uses, allowing for the adaptive reuse of once industrial buildings/ spaces, accommodating young businesses in “green” biotechnical, health research, clean industrial, green technology, research/ development businesses, software, and other emerging and creative industries. Housing is also permitted in this innovative industrial zone, allowing for live/work units to be built, and uses such as brew pubs, coffee roasters, and small-scale restaurants.

Uses that are no longer permitted in this area include warehousing, trucking/truck lots, or freight/good storage. For future planning efforts, it will be important to consider how these potential uses can ultimately integrate with and buffer between the existing residential community to the north.

In the southwest portion of the city, east of Atlantic Avenue, the “light industrial” area of the Cudahy will accommodate greater employment opportunities for residents of all skills and education levels, create and support jobs in multiple other business sectors, and contribute to local tax revenues. Permitted uses include light industrial and manufacturing, biomedical, logistics, and creative industries. While automotive uses are permitted, their development should be discouraged as activities that involve a high volume of traffic, produce odors, involve fabrication or assembly, and operate during typical business hours are considered hazardous. Therefore, uses such as heavy manufacturing, new warehousing and storage, truck lots, and freight/ goods storage are prohibited from this area. Opportunities to increase Cudahy resident’s pedestrian and bicyclist accessibility to this area should be explored, as well as how this area can better integrate and buffer between the existing residential community to the north and northeast.

The Introduction of the General Plan describes the built environment of Cudahy embodying a distinctive architectural style reflective of the city’s rich cultural diversity, and promoting public art that celebrates this culture. Since the Land Use Element does not specify what this distinctive architectural style is or standards for its development, the Cudahy Together has the opportunity to help define what this might look like.

Overlay Zones
Urban Agriculture Overlay:

The Urban Agricultural Overlay encompasses multiple blocks south of Santa Ana Street and provides the opportunity for both indoor and outdoor agricultural activities. The Overlay allows for growth and cultivation of various plants, fruits, and vegetables through community gardens and also allows for commercial distribution and sale. The Urban Agriculture Overlay allows for the planting and cultivation of cannabis with a restriction to only indoor production and harvesting, although cannabis production is not allowed where the Overlay overlaps with residential designation until those parcels are rezoned to industrial.

The objective behind granting the City authority to oversee commercial cannabis production is multifaceted. It aims to bolster the well-being of residents and businesses by prioritizing health and safety while fostering a thriving urban agriculture scene. A key provision within the Overlay pertains to the prohibition of commercial cannabis production activities or retailers on Atlantic Avenue, unless their primary purpose aligns with entertainment to help catalyze the City’s economic growth.

Development standards are in place to ensure that all commercial cannabis facilities adhere to the City’s design and landscape guidelines. These standards will provide community beautification, parking reduction, and street enhancements, which all align with the overarching goals outlined in the General Plan.

Wilcox Commercial Overlay:

The Wilcox Commercial Overlay is situated at the intersections of Clara Street and Santa Ana Street on Wilcox Avenue where there is a cluster of parcels dedicated for neighborhood commercial use. The Overlay allows for parcels to undergo strengthening and/or expansion to support small commercial businesses that cater to the daily needs of residents’ everyday life, such as the addition of new shopping or dining. The City will review this Overlay every five years to potentially consider reclassifying areas from residential to neighborhood commercial use, not with the intent of transitioning parcels from residential to commercial.

Industrial Overlay:

The Industrial Overlay looks to extend the current industrial designations further north of Santa Ana Street if there is a strong demand for further industrial uses. If this Overlay is enacted, there will be strategies in place to protect residential buildings from harmful effects of industrial uses such as noise barriers, buffers, and landscape screening. Every 5 years, the City will review whether there is a need for redesignating and rezoning the Overlay from the current High-Density Residential to Light Industrial Use, although the intention is not for the parcels to transition from residential to industrial.

Riverfront Overlay:

With various regional planning efforts happening on the Los Angeles River, the City of Cudahy is seeking to capitalize on its proximity to the River and look for development opportunities on the riverfront. This Overlay within the Land Use Element would allow for high-density residential and introduce mixed-use commercial development along the river.

Application of this Overlay is only applicable if there is a strong demand for this type of development along the Los Angeles River. A functional mobility system and supportive infrastructure for residents to connect to this regional asset must also be in place before any potential development were to occur.

Cudahy General Plan - Open Space
and Conservation Element
The Open Space and Conservation Element within the
General Plan aims to forge improvements on existing open spaces and parks, details efforts to create greener public spaces, and addresses calls to action on conserving and sustainably maintaining natural resources and city infrastructure [sewage, water, storm drainage systems] with a long-term, community-centric focus. Cudahy faces unique challenges in terms of parkland availability due to its dense urbanization and limited open space. As of 2016, Cudahy had only five parks covering a total of 17.92 acres, resulting in a substantial deficit of over a hundred acres of open land, as outlined in the general plan [equating to just 4 acres per 1,000 residents].

The eastern border of Cudahy is marked by the Los Angeles River, which has suffered contamination from industrial and commercial activities. The City is committed to restoring this critical natural resource to function as habitat and flood control infrastructure. Given these limitations, a central focus is placed on sustainable landscape architecture and design for public spaces, parks, recreation centers, streets, and sidewalks. Integrating urban agriculture and gardens is seen as a pivotal strategy to promote sustainability, potentially providing fresh produce, and educational opportunities.

Cudahy developed a map focusing on improved access to
parks, which includes creating smaller parks, enhancing recreation services, and retrofitting existing public spaces to ensure that green areas are within walking distance for residents. This approach aims to maximize the utilization of limited space while enhancing aesthetics, reducing reliance on automobiles, and bolstering pedestrian safety. In partnership with the Circulation Element, proposing the introduction of cul-de-sacs along Salt Lake Avenue aims to establish new community hubs for residential interaction. Improvements to Salt Lake Avenue also include the implementation of new bike lanes and enhancements to the urban landscape seeking to elevate pedestrian and cyclist-focused infrastructure.

A strategic approach to enhance green spaces in Cudahy for the benefit of residents involves the introduction to community gardens. This not only seeks to provide fresh food to the neighborhood but also aims to build capacity for residents on the significance of sustainability, nutrition, and environmental stewardship.

152 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 153

4.5 RELEVANT PUBLIC PROJECTS
Cudahy Los Angeles River Area Improvement Project
The City of Cudahy will construct a gateway landmark sign in the triangular parcel of land on Salt Lake Avenue at the intersection of Elizabeth Street and Otis Avenue. This sign looks to be a connector between the cities of Huntington Park and Cudahy, and is strategically aligned with Salt Lake Avenue, which is a major street within Cudahy that divides the two cities. This sign will be accompanied by ornamental planting, large flowering shrubs, and new trees, which will all be native.

In cohesiveness with the Cudahy Circulation Element and Land Use Element, this Gateway Landmark project is a good first step to creating a sense of place for residents and visitors. As defined in other planning documents, there are further opportunities to expand and enhance this area,
specifically closing down Elizabeth Street and turning that area into a streetlet and pocket park.

Cudahy Complete Street Improvement Project
City of Cudahy
The City of Cudahy launched their Complete Streets
Improvement Project which is anticipated to begin construction in late 2024 and be completed in 2025. This Project looks to bring needed improvements to the Atlantic Avenue corridor [as identified in the previously mentioned planning documents], such as pedestrian safety improvements to
important intersections, and transit stop improvements at several locations.

The Atlantic Avenue Corridor Improvement Project, which will start on Patata Street and end on Florence Avenue, will introduce Class II buffer bike lanes, repairs to sidewalks, curb ramps, curb and gutter, asphalt resurfacing, and striping that includes high visibility ladder crosswalks.

Improvements to the Atlantic Avenue roadway includes
landscaped medians as shown above. By removing the existing decomposed granite in the existing medians, the City looks to plant new, low water-use shrubs and plants while also keeping the existing trees. It is important to note that all

154
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 155 Complete Streets Improvement Project
plants will be drip irrigated. As a key placemaking element, a new monument sign will also be installed to help welcome residents and visitors into the city and promote a sense of community pride.

Pedestrian safety enhancements at key intersections will include traffic signal countdown displays, pedestrian push buttons, and ADA curb ramps. Those intersections include Otis / Live Oak, Otis / Clara, Wilcox / Live Oak, Wilcox / Clara, and Clara / River.

The City is also looking to provide important transit stop improvements such as bus shelters where feasible, pedes- trian-scale lighting, bike racks and trash cans. The new bus stops on Atlantic Avenue will include improved lighting, a new and improved stainless steel bench, new trash recep- tacles that contain both trash and recycling, as well as bike racks that can hold two bikes for people who do not want to bring their bikes onto the bus.

156
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 157

4.6 CASE STUDIES
La Placita Cinco The Uptown

STRIP MALL CONVERSION STRIP MALL CONVERSION
Status: Completed
Location: Santa Ana, CA
The site of La Placita Cinco is a former auto-oriented strip mall that had not seen significant investments in 50 years. It has since been converted into a mixed-use, neighborhood-serving center that includes outdoor community areas, spaces for nonprofit partners, and affordable housing. Construction phasing was adjusted to ensure that businesses in the two commercial build- ings being retained were still able to operate. The developer worked with existing businesses to provide facade improve- ments as well as rent stabilization. A new structure was built on the former surface parking lot to create 51 affordable units and ground floor community space. A range of outdoor community spaces were added to the site, including a pedestrian plaza, urban farm, and mini park [La Placita Cinco, 2021].

Key Takeaways → Outdated zoning constraints required the team to work with City of Santa Ana Planning Staff to develop a specific zone plan tailored to the true conditions of the site and supported the desire for new affordable housing within
the future transit zone.
→ Clear, consistent communication between the develop-
ment team and on-site businesses resulted in effective
anti-displacement measures.
→ The site used urban design principles and repurposed
surface parking lots to create activated open spaces for both residents and visitors.

Status: Proposed
Location: Long Beach, CA
Located at the intersection of Atlantic Avenue and
Harding Street in North Long Beach, the Uptown was
a proposed redevelopment of a typical L-shaped strip
mall with a standalone drive-thru pad into a more
efficient design configuration that better activates
the public realm. Uptown is a 2.6-acre property that
currently hosts nine commercial businesses setback
behind 61 parking spaces. In 2018, the developer
Westland Real Estate Group conceptualized a design
that modernizes the site while increasing commercial
opportunity [28,660 SF], pedestrian accessibility and
outdoor gathering spaces, and parking stalls.

Key Takeaways → The redesign includes bringing the commer -
cial buildings forward towards the street, which
increases tenant visibility and activates the public
realm for pedestrians.
→ Interior and street-oriented landscaped pathways,
outdoor dining areas, and sidewalk extensions
improve the overall pedestrian experience.
→ Introduction of diagonal parking and one-way
drive aisle increase the availability of parking total- ing 137 spaces.

158 STRATEGIC PLAN FOR A THRIVING COMMUNITY
Calle 24 - Latino
Cultural District
Avenue 26 Night Market

LATINO URBANISM
Status: Complete
Location: San Francisco, CA
The Calle 24 Latino Cultural District in San Francisco is a culturally rich, historically significant area that serves as a vibrant epicenter for the city’s Latino community.

Located in the Mission District, the cultural district
spans 24th Street, which has long been a central hub
for Latino culture, commerce, and community life. The
establishment of the district was an effort to preserve and celebrate the cultural heritage of the area, amidst rapid gentrification and displacement that threatened
its identity and vibrancy. In 2014, after years of advocacy from community leaders, the City officially designated the Calle 24 Latino Cultural District to protect and promote Latino cultural expression through arts,
heritage, and commerce. This designation was pivotal in ensuring the district’s continued relevance and vibrancy in the face of urban transformation.

Status: Complete
Location: Los Angeles, CA
The Avenue 26 Night Market in Los Angeles is a great
example of a grassroots cultural placemaking initiative that combines food, community, and local cultural expression into a vibrant space for community members. Located in a predominantly Latino neighborhood of Lincoln Heights, the market takes place on Avenue 26, a street that transforms into a vibrant marketplace on the weekends. This market showcases the diversity and vibrancy of Latino street food culture and serves as a gathering point for residents from across Los Angeles, many of whom come from immigrant backgrounds.

The Avenue 26 Night Market emerged in 2015 as an informal food event but has since grown into one of the most popular night markets in the city. It brings together a wide range of local vendors, artists, musicians, and community members, creating a unique space where cultural traditions are celebrated, and new expressions of culture emerge. The market’s success highlights how cultural placemaking can activate underutilized spaces, provide economic opportunities for small businesses, and foster community pride.

Cudahy can draw inspiration from this grassroots cultural placemaking initiative to create similar vibrant spaces that celebrate local culture, support small businesses, and foster a sense of community. By activating underutilized spaces, such as vacant lots or streets, Cudahy can host cultural markets or events that highlight its own diverse heritage and provide opportunities for local entrepreneurs, artists, and vendors.

These initiatives not only promote economic growth but also create a strong sense of pride and belonging, especially for immigrant and marginalized communities.

LATINO URBANISM

160 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 161 Community Voice The following engagement
data highlights key themes
specifically related to
cultural placemaking,
derived from the feedback
gathered through various
outreach events and
activities. These insights
reflect the community's
collective values, concerns,
and aspirations, offering a
clear understanding of the
priorities that matter most
to residents.

Listening Sessions
The listening sessions allowed for community members to share their concerns, priorities, and ideas early in the engagement process. This information set the stage for all future outreach events, and the themes shared below were specific to cultural placemaking.
→ Participants emphasized the value of incorporating local art into placemaking efforts, noting that it helps to celebrate the unique culture and creativity of the community. → Participants underscored the importance of infrastructure improvements and additions as essential components of placemaking like more public plazas, murals, and wayfinding signage. → Participants emphasized the need for better wayfinding signage to improve navigation and connectivity within the community. The need for there to be Spanish wayfinding
signage is also as important.
→ Participants highlighted the potential of tactical urbanism as a powerful tool for quick, low-cost interventions that can improve public spaces and enhance the community’s
livability. Examples included pop-up parks, temporary bike lanes, and parklets on Atlantic.
→ Participants emphasized the importance of Transit-Oriented Development [TOD] improvements to create more connected, walkable, and sustainable communities. Examples included more mixed-use development, bike and pedestrian friendly infrastructure, and green spaces.
→ Participants emphasized the significance of community beautification as a key element in enhancing the overall livability and appeal of the neighborhood.

Survey
In the public survey, the community was asked about what aspects of the community they love and what makes Cudahy unique to them. This data in particular reflects participants' answers towards cultural placemaking. Participants provided valuable feedback, which is summarized below:
→ Participants highlighted the value of community events and activities as essential elements of placemaking.
→ Participants emphasized the importance of integrating natural elements, such as parks, trees, and access to
nature, into the community’s placemaking efforts.
→ Participants stressed the importance of thoughtful architecture and neighborhood design in shaping the community’s identity and livability. → Participants highlighted the importance of beautification and art presence as key elements of placemaking. Things such as trash cans, murals, statues were things the community would love to see more of. 100 150
Access to
Resources
Diversity of
Businesses
Community
Events and
Gathering Spaces
Sense of
Community
Cultural
Identity
Improvements and
Improve Cleanliness
Walkability
Safety
Overall Priorities
Low-Income
Renters Priorities
Youth Priorities
Active Transportation
Priorities
Senior Priorities
63 49
45 36
3 53
52 50
11 11
10 7
7 42
36 37
9 53
7 5
6 34
23 23
4 1
6 4
40 40
37 10
4 8
6 7
0 0
0 0
1 1
1 6
7 What are aspects of the community you love?
0 10 50

162 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 163 What aspects do you think can contribute most to Cudahy’s uniqueness and charm? 0 30 60 90 120 150
Highlight Cudahy's
Cultural Diversity
and Heritage
Architecture and
Neighborhood
Design
Access to Amenities
(shops, restaurants.
public transportation)
Natural Elements
(parks, trees, access
to nature)
Community
Events and
Activities
Overall Priorities
Low-Income
Renters Priorities
Youth Priorities
Active Transportation
Priorities
Senior Priorities
135
100
15 11
6 2
3 108
97 71
41 94
53 56
61 51
21 95
88 60
36 131
120
86 53
Overall Priorities
Low-Income
Renters Priorities
Youth Priorities
Active Transportation
Priorities
Senior Priorities
Open House One
At the first public Open House, participants were invited to engage in the Cultural Placemaking activity where they shared the cultural elements that are most important to them and offered their vision for how these aspects can be enhanced and used in the future.
→ Participants emphasized the importance of supporting
street vendors in the community and create a dedicated
space where they can legally sell items.
→ Participants highlighted the value of creating a community stage for performances and art that represents the local culture and identity.
→ Participants expressed the need for more local restaurants in the vicinity to enhance dining options and support small businesses.
→ Participants emphasized the need for more dining halls for senior citizens, recognizing that these spaces provide important social and nutritional benefits for older residents. → Participants suggested enhancing the little strip of green space across from Clara Park and expanding access to
more green spaces throughout the community.

Roundtables
The roundtables offered a platform for community members to carefully prioritize their key ideas from previous engagements, ensuring that the most important concepts that emerged genuinely aligned with the community’s best interests. These themes below represent the data pulled relevant to cultural placemaking.
→ Participants suggested adding murals throughout the
community to express local pride and showcase the area’s unique identity.
→ Participants proposed introducing artistic crosswalks to enhance both safety and the aesthetic vibrancy of the streets. → Participants suggested adding colorful bike racks or posts throughout the city, particularly in parks, to provide muchneeded bike parking options. → Participants recommended enhancing the Atlantic corridor by adding better vegetation to the median, with a focus on colorful plants, to create a more vibrant and
inviting atmosphere.
→ Participants suggested installing a prominent sign at the entrance to the city to strengthen its identity and foster community pride.
→ Participants recommended adding amenities such as
shade structures, water stations, and other bus stop-style features to improve walkability and comfort throughout
the community.
→ Participants emphasized the need for improvements to
pedestrian infrastructure along Salt Lake Avenue, particularly by incorporating the existing railroad right-of-way to enhance walkability and bicycle access.

Open House Two
At the final Open House, residents had the opportunity to provide feedback on the recommendations that emerged
from an extensive community engagement process focused on placemaking. The following themes directly reflect the input gathered during these discussions.
→ Participants stressed the need for stronger code enforcement targeting landlords who violate City laws, particularly those who allow the accumulation of trash or neglect property maintenance.
→ Participants advocated for allowing street vendors in the city, recognizing the important role they play in fostering local entrepreneurship and providing accessible, affordable goods and services. → Participants suggested that code enforcement should focus on addressing repeated violations with a more rehabilitative approach rather than relying solely on punishment.
→ Participants emphasized the importance of creating art spaces for youth where they can explore and develop various skills, including martial arts, urban arts, and acrobatics. → Participants strongly expressed the belief that education, rehabilitation, and better work opportunities should be prioritized over punitive measures for individuals who
violate codes or laws.

164 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 165

4.7 HISTORY OF GENTRIFICATION
& DISPLACEMENT
Note: This report contains limited data presenting the available information as of the time of analysis. It is essential to note that this summary may not encompass the entirety of the history and all available data.

The Project Team conducted historical research using online resources and by visiting the Cudahy Library, which revealed a collection of archived documents, articles, and photos that span from 1771 to 2010. Joseph Olvera, a City Librarian, had collected and archived this information from 2012 to 2013 on compact disks. As a consideration, many personal stories are missing or incomplete from this historical context study, and these stories can potentially refine or even redefine the greater community history of Cudahy development. Therefore, this document serves as a malleable record and foundation of the city’s development history that can be expanded upon through more archival information and interviews.

Housing, transportation, and open space developments were focal points in researching this information.

Early History
When thinking about race, place, and land, it is integral to recognize and highlight the histories of people that inhabited / and still inhabit the land we stand on. For centuries, The Tongva People inhabited Tovaangar: more than 4,000
square miles of ancestral land that encompassed the Santa Susanna Mountains to the North, Aliso Creek to the South, the San Bernardino Mountains to the East, the Pacific Ocean to the West, and the four channel islands of Santa Catalina, San Clemente, Santa Barbara, and San Nicolas. According to the document commemorating Cudahy's 25th anniversary [1960- 1985], historical documents detail two settlements that existed within the present-day City of Southgate: Tibahagna which was situated near Post Street and Victoria Avenue, and Ahau, which was located at the South Gate Municipal Recreation Park. Historical records from Downey reference the village Jaboneria, positioned south of Telegraph Road on the western bank of the Rio Hondo. Recognized as the Greater Los Angeles Basin today, Cudahy and other municipalities of Los Angeles and Orange County reside on stolen Tongva land.

Prior to Spanish colonization, both Juan Rodriguez Cabrillo and Captain Gaspar de Portolá encountered the Tongva
people in 1542 and 1769, respectively. However, in 1771, Spanish tendencies toward settler-colonialism led to the cultural genocide of Indigenous people in California; the Tongva were enslaved, murdered, and raped. The Spanish sought to forcibly convert Indigenous communities to Christian, Spanish citizens while also seeking wealth and resources from their land. Under forced labor, the Tongva people constructed the Misión de San Gabriel Arcángel [along with other forts and missions], which coined the Spanish Gabrieliño name for the Tongva people. Indigenous Californians faced forced displacement and assimilation, enduring centuries of exploitation and neglect from complicit entities like the United States government. People of the Tongva nation still face obstacles in accessing services/ resources from the federal government, and also in reclaiming their ancestral heritage.

Recent History
From the Tongva land, a land grant was gifted to cavalry corporal Don Antonio Maria Lugo in 1810 by King Carlos V of Spain as a form of compensation to the initial Californian colonizers; this land grant stretched from the San Gabriel River to current-day Huntington Park, West Vernon, South Lynwood, and approximately the Santa Ana Freeway, totalling a land area of 29,514 acres. Lugo named the land tract Rancho San Antonio after his birthplace [1775] in El Mission San Antonio de Padua. It included the vast ranchos of Chino, Cucamonga, San Antonio, and San Bernardino.

Numerous transactions and partitions during the time frame of 1855-1893 followed the initial acquisition. In 1855, after being sectioned and sold, Don Antionio was left with 4,239 acres of Rancho San Antonio. He retained 1/7 of the ranch, living on seven acres known as the Lugo Ranch, located three miles to the east of Bell. When Don Antonio Maria Lugo died in 1860, the remaining land was deeded to his son Vincent Lugo.

Flooding along the Los Angeles and San Gabriel Rivers
ensued in 1862, and the following two years [1863-64] were drought ridden, leading Vincent Lugo to renounce his land title. The droughts in the 1860s contributed to a considerable loss of herds and significantly affected the ability to continue to farm; as a result, this period saw a considerable amount of land being fragmented, subdivided and sold off.

A fragment of the ranch was later sold in 1864 at a public auction to Issac Heyman, a money lender, for 95 cents an acre. He then sold another fragment of the property to
Reme Nadeau who developed the land as Nadeau’s Ranch
Vineyards, which was later destroyed by sizable floods in 1889, causing Nadeau to sell the land to John W. Hinton.

Michael Cudahy, a meat packer and industrialist, obtained the land from Hinton in 1893 for $105.15 an acre. He was born in Ireland in 1841 and later immigrated to the United States, settling in Milwaukee, Wisconsin, in 1849. Incidentally, Michael Cudahy is part of the same family that founded and established the city of Cudahy in Milwaukee, Wisconsin.

Citywide Development/Cudahy Family
The development of the City of Cudahy is tied to the development of the state and the accompanying establishment of modern institutions, agencies, and industries. As a result, when it comes to examining the history of land use in Cudahy, it is important to acknowledge that regulations around land use at the time came up spontaneously and in immediate response to a growing number of manufacturers, industrialists, etc looking to establish businesses in Los Angeles.

Finding success in the meat industry, Michael Cudahy partnered with his brother Patrick Cudahy to establish the Cudahy Packing Company in Omaha, Nebraska. Looking to set-up and expand their entrepreneurial presence and services within the meat-packing industry in Los Angeles, Michael Cudahy acquired land in proximity to what is today Cudahy.

Michael Cudahy eventually sold his share of the company and purchased 2,777 acres of a ranch situated east of Los Angeles.

Initially intending to use the land for raising cattle and horses in stockyards, he later opted to sell tracts of it instead. The ranch was parceled into one acre tracts and continued to serve as grazing, agriculture, and dairying lands. Subsequent to his death [approximately in 1910] the Cudahy Ranch Company
was established and took over ownership of the land. The property boundaries at the time extended from Walnut Park to the southern and western parts of Atlantic Avenue, eastern parts of Walnut Park, and between what is now South Gate and Bell; this area was officially incorporated as Cudahy, California on November 10, 1960.

Establishing the meat-packing business and its facilities within City limits and in proximity to residential neighborhoods was unprecedented even at the time. By leveraging the prospect of economic growth, the Cudahys were able
to influence land use regulations, use of the LA River water, waste disposal, etc. In bringing meat-packing to the city, away from the outskirts, Michael Cudahy transformed the urban experience and perception.

The history of land use in Cudahy is, thus, one that went through multiple transformations from initially being an agriculturally conducive parcel of land to then being a hub for industrial use. Today, residing within the Southeast Los Angeles Gateway Cities and ranking as the second smallest municipality in Los Angeles County, the city is home to a population exceeding 20,000 residents, making it one of the most densely populated communities in the region. More than 95% of the working class community is Latinx.

Cudahy’s urban fabric is unique because of its rural and agricultural history; many of the residential lots are narrow and long because they were used for vegetable / fruit farming, chicken raising, and other uses for ranching / farming. These deep lots have multiple units and apartments that protrude out from the streets.

Transportation
Cudahy’s first iteration of local public transportation emerged in the form of a Model T Ford unlicensed bus,
helmed by Charles Burce Holbrook in 1918. This bus transported passengers in the cities of Bell, Huntington Park, and Cudahy. In 1934, Holbrook formed his own company,
the Holbrook Transit Company. The company later boasted a fleet of six buses, with two modern ones that could carry 25 passengers and serviced the cities of Huntington Park, Downey, Bell, Bell Gardens and Cudahy with ten employees]. In 1973, Cudahy established their own transit line named Cudahy Area Rapid Transit [CART. To equitably
plan for the future of Cudahy, it is important to consider its history of planning and development.

166
STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 167

4.8 LATINO URBANISM
Latino Urbanism is a
concept that explains the
impact Latinos have had
on the cultural landscape
in American cities.

It tells the story of how immigrants have reshaped the func- tionality of their communities by reconstructing their neigh- borhoods to resemble those they left behind. One of the main pioneers who coined the term Latino Urbanism is James Rojas, an Urban Planner, Community Activist, and Artist. Growing up in Southeast Los Angeles, a predominantly Latino community, Rojas witnessed the transformation of his surroundings in the 1970s as neighborhoods began accommodating more vehicles.

This has been an ongoing trend where consideration for cultural place has been disregarded and uniformed suburbias have taken the place of once lively neighborhoods.

In Latin culture, housing is typically designed to promote and embrace communal behavior within the neighborhood. For
instance, a Mexican vernacular house is positioned closer to the street, often extending the front porch or sharing fenc- ing. This design contrasts with suburban homes built with large front yards, which creates a sense of separation. In addi- tion, homes are characterized by personalized designs and constructions added by the owners. The term 'Rasquachismo' in Latino Urbanism describes the use of available materials, such as recycled items, repurposed into something new.

Latino Urbanism focuses on more than just house design; it also emphasizes public space utilization, such as parks, plazas, and street corners. All of these spaces serve as gathering locations in the Latino community. For example, street vendors and markets provide both economic opportunities and cultural enrichment within a community. The concept of the 15-minute city, which promotes designing neighborhoods with all amenities available within a 15-minute walk, originated from Latino Urbanism. The proximity to markets and vendors contributes to increased mobil- ity within the neighborhood, placing importance on walkabil- ity over vehicular travel. This strengthens the local economy by promoting small businesses, making them accessible to the community. This type of design also prevents sprawling devel- opment patterns. In order to preserve the cultural identity of these neighborhoods, Latinos are encouraged to become part of the planning process.

Public art and architecture are used as a form of cultural expres- sion. Buildings and public spaces are designed to promote social interaction and a sense of place within the community. This is done by including vibrant colors, murals, and tile work [motifs] that all are reflective of latino culture. Latino urbanism in areas like East Los Angeles mixes cultural identity with architecture and design. In the 1970s, colorful murals became a way to share cultural pride and a way to stand up against injustice. Architects started to use Latino styles and symbols on purpose in their designs. Projects like El Mercado were made to reflect Chicano values, inspired by traditional Mexican buildings, while still provid- ing essential services to the community. Naming public places with words like “plaza” reminds the community of their cultural roots and the importance of coming together. This type of urban- ism is about celebrating culture while creating spaces where people feel safe and empowered within their community.

Urban Design: → Residential Development Layout: Reflect the cultural preferences of the community by designing houses based on the Mexican vernacular model which positions homes closer to the street, often extending the front porch or sharing fencing. → Cultural Connectivity: Integrating the 15-minute city design, which promotes designing neighborhoods with all amenities available within a 15-minute walk.
→ Plazas and Streets as Public Spaces: Creating gathering places like plazas or “mercados” which allows the commu- nity to socialize while still offering essential functions. → Mixed-Use Planning: Encouraging street vendors and local shops within residential areas.

Architecture: → Cultural Identity Building and Design: Adding elements of Latino architectural styles and motifs into buildings and design. → Space Design to reflect Latino Lifestyles: Designing exte- rior and interior spaces that accommodate Latino families and social gatherings.
→ Cohesive Cultural Landscape: Building design that compli- ments and matches the surrounding Latino community.

Art & Placemaking: → Cultural Expression through Color and Public Art: Using vibrant colors and murals to extend cultural pride.
→ Cultural Events: Using public spaces to host events that celebrate Latino traditions and customs like cultural
events and festivals.
→ Community Participation in Placemaking: Encouraging
local residents in placemaking initiatives to ensure that public spaces reflect the needs and desires of the Latino community. → Preservation of Art Installations: Establish ongoing main- tenance and preservation of public art installations that celebrate Latino heritage.

STRATEGIC PLAN FOR A THRIVING COMMUNITY 169

4.9 Cultural Placemaking Recommendations

4.1.1. Spanish Language Signage Policy
for Business Establishments
Overview
To foster an inclusive and
culturally sensitive business
environment, this policy
would support the use of
Spanish language signage by
businesses within city limits.

This policy aims to enhance
accessibility for Spanishspeaking residents and
visitors, promote economic
growth, and strengthen
community ties by making
local businesses more
accessible and welcoming to
Cudahy’s diverse population.

POLICIES
Spanish language signage may include, but is
not limited to, store names, hours of operation,
services offered, safety instructions, and promo-
tional materials. Businesses would be encouraged
to display information in both Spanish as well as
English to maximize accessibility for all residents
and visitors.

Context
Nearly 90% of Cudahy residents speak Spanish,
many are monolingual Spanish speakers. This
can result in language isolation if all public-fac-
ing signage is written in English. This compared
to 10% of residents who are monolingual English
speakers. Cudahy is amongst the communities
in Los Angeles County with the largest Latino
populations, at nearly 94%. Multilingual busi-
ness signage both reduces the potential for
language isolation while acknowledging the
unique identity of the community.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Cudahy Chamber of Commerce
Property Owners
Priority
Short-Term (0-2 years)

170 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 171

4.1.2. Bilingual Wayfinding Signage Policy
for Metro Station Access

POLICIES
Overview
To enhance accessibility and promote safe, efficient
navigation for all residents and visitors, this
recommendation involves the incorporation of bilingual
wayfinding signage in both Spanish and English for
pedestrian and bicycle routes to and from proposed
Metro stations. This policy aligns with the City’s
commitment to serving its predominantly Spanishspeaking community, ensuring public transit access is inclusive, welcoming, and easily understandable.

Context
Similarly, employing bilingual signage for Metro stations and for wayfinding helps addressing language isolation for community members while lifting up aspects of Cudahy’s unique identity.

Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
Los Angeles Metropolitan Transit Authority
City of Cudahy - Public Works Department
Priority
Medium-Term (2-5 years)

4.1.3. Community Benefits for New Development
Overview
To enhance the pedestrian environment along Atlantic
Avenue in Cudahy, new nonresidential developments
should be required to adhere to guidelines that improve accessibility and the pedestrian experience. This
guideline would require a minimum sidewalk width of
12 feet and compliance with ADA standards to ensure
accessibility and capacity for adding new street trees.

Developers should also provide an additional 5-foot
buffer on their property, which must be designed to
be pedestrian-friendly, either through a walking path
or landscaping that the property owner is responsible
for maintaining.

Landscaping elements such as trees and planters
should be included to create a welcoming atmosphere. Additionally, developments must feature clearly marked crosswalks and direct pathways to
the proposed Metro Stations if they are within close
proximity of one of the stations. Engaging local residents during the planning process will help tailor the public improvements to community needs.

Finally, a monitoring system should ensure compliance with these guidelines, allowing for regular assessments of the pedestrian enhancements. By
implementing these measures, Cudahy can create a
vibrant, pedestrian-friendly environment along Atlantic Avenue that improves connectivity and quality of life for residents and visitors.

Context
The sidewalks on Atlantic Avenue are currently 7-8
feet wide, not providing sufficient area to plant trees or landscaping while retaining enough remaining
width for a clear pedestrian path of travel. Widening the sidewalks will improve accessibility, allow for expansion of the urban tree canopy, and enhance the
overall pedestrian experience. The additional area
will permit improvements to bus stops along Atlantic
also enhancing the transit rider experience.

POLICIES
Lead Agency
City of Cudahy - Community Development
Department
Supporting Partners
City of Cudahy - Public Works Department
Priority
Medium-Term (2-5 years)

172 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 173

4.1.4.Amortization of Nonconforming Uses

POLICIES
Overview
An amortization policy
for nonconforming uses
is designed to gradually
phase out land uses
that do not comply with
current zoning regulations
while providing a fair
transition period for
property owners.

Amortization balances the rights and investment of
property owners with the public good as these nonconforming uses might be detrimental to community health or economic wellbeing. This progressive policy begins
by clearly defining what constitutes a nonconforming
use, including specific examples to guide stakeholders.

A reasonable amortization period would be determined
in consultation with property valuation experts to allow these uses to continue operating while giving owners
time to transition to conforming uses or recover their
investment into the property.

Additionally, the policy may offer compensation
options or financial assistance to affected property
owners, such as grants for relocation or incentives
for redevelopment. Clear pathways for transitioning
to conforming uses are provided, which may involve
zoning variances or special use permits. To ensure
effective implementation, a monitoring and reporting
system is established to track compliance and address
challenges. Community engagement is also emphasized, encouraging input through workshops and public forums to foster a sense of ownership in the transition process. By adopting this amortization policy, the City can promote orderly development while respecting
the interests of existing property owners, ultimately
enhancing the community’s character, and supporting
a more sustainable urban environment.

Context
As communities and development strategies evolve
over time, land use plans and zoning districts are
adapted in response. On occasion existing uses might
be longer be permitted on a property, leading to there
being a non-comforming use. In most cases jurisdictions allow the use to remain, but limit the amount of alterations, investments, or expansion of the use
on that property. In some cases when the non-conforming use has a substantial negative impact on the community, amortization is a tool used to terminate
that use. The rights and investment of the property
are then weighed against those public good.

Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
City of Cudahy - Public Works Department
Cudahy Chamber of Commerce
Community Based Organizations
Property Owners
Priority
Long-Term (5-10 years)

4.2.1. Facade Improvements for Businesses
Overview
To improve the visual
appeal and cultural
identity of local Cudahy
businesses a facade
improvement program
would support businesses
in updating their facades
to reflect the rich heritage
of the community,
creating a cohesive
cultural landscape.

Establishing a cohesive design language that incorporates traditional Hispanic and Latino architectural styles and motifs will ensure that building facades
harmonize with the surrounding environment. The
goal should be to balance the individual identity of
each of these businesses while demonstrating an
authentic, cohesive identity
To facilitate this effort, the City would collaborate
closely with the Cudahy Chamber of Commerce,
leveraging their local insights and resources to
promote participation among businesses. Financial
incentives, such as grants, low-interest loans. and/
or design support could support a more robust rollout of these renovations. This program can foster a vibrant, culturally rich atmosphere that celebrates
its heritage while supporting local economic growth
and community pride. Collaborating with businesses
and owners along Atlantic Avenue will be essential to
ensuring that the facade program is successful and
the improvements reflect the local community.

Context
Many local businesses may lack the resources to
update their facades, but this initiative can help them reflect the community’s cultural identity through
thoughtful design. By working with the Cudahy
Chamber of Commerce and offering incentives, the
program ensures that improvements are accessible
and impactful, promoting a cohesive cultural landscape. This effort will not only beautify the area but also attract more visitors, strengthen community
pride, and support local businesses by creating a
visually unified and culturally significant environment.

PROJECTS
Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
Cudahy Chamber of Commerce
Community Based Organizations
Property Owners
Priority
Medium-Term (2-5 years)

1 74 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 175

4.2.2. Pocket Parks
Overview
Create pedestrianfocused pocket parks at
key intersections along
Atlantic and Salt Lake
Avenues, specifically at
Florence Avenue, Live
Oak Street, Clara Street,
Elizabeth Street, Santa
Ana Street, Cecilia Street,
and Ardine Street.

These pocket parks will serve as vibrant public spaces
that reflect the unique character of the surrounding neighborhoods. The pocket parks can be created by installing curb extensions, reconfiguring irregular intersections, or partially closing surplus roadway. Collaborating with businesses and owners along Atlantic Avenue will be essential to ensuring that the development of a pocket park enhances and improves the success of businesses.

For the development of these pocket parks, the City
would like to create design guidelines that are driven
by community feedback. These design guidelines would
incorporate resident desires for open and inviting community spaces while considering Crime Prevention Through Environmental Design [CPTED] design principles. To
address resident’s concerns of safety, it will be important to activate the park with consistent community programming, security signage for community oversight, and high visibility [through lighting and design] to discourage improper use of any street furniture and structures.

The pocket parks along Atlantic Avenue should be
designed to complement the business context, featuring
elements that encourage social interaction while supporting local commerce. This could include outdoor seating, market stalls, and spaces for community events, creating a lively atmosphere that attracts both residents and visitors. In contrast, the pocket parks along Salt Lake Avenue should cater more to the residential community, providing tranquil gathering spots for families and social gatherings. Integrating urban agriculture and gardens is seen as a pivotal strategy to promote sustainability, potentially providing fresh produce and educational opportunities. These spaces can incorporate design elements that reflect Latino lifestyles, such as shaded seating areas, verdant landscaping, and areas for cultural activities.

Creating these inviting pocket parks can foster a sense of community, enhance social connections, and celebrate the cultural identity of Cudahy.

Context
This initiative aims to create vibrant, pedestrian-friendly spaces at key intersections along Atlantic and Salt Lake Avenues. The pocket parks will support local businesses on Atlantic Avenue with features like seating and market stalls, while offering tranquil gathering spots for families along Salt Lake Avenue. This reflects the surrounding uses of these two distinct corridors. This project will enhance community connections, celebrate Cudahy’s cultural identity, and improve the area’s livability.

PROJECTS
Lead Agency
City of Cudahy - Public Works Department
Supporting Partners
City of Cudahy - Community
Development Department
City of Cudahy - Community
Services Department
Cudahy Chamber of Commerce
Community Based Organizations
Property Owners
Priority
Long-Term (5-10 years)

4.2.2 Pocket Parks Potential Locations

1. Proximity to Metro Station - Supporting first/last mile connectivity

2. Salt Lake Avenue - Intersections as identified above

3. South Atlantic Avenue - Intersections as identified above Prioritization

176 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 177

4.2.3. Public Art Initiative
Overview
The Public Art Initiative
aims to transform blank
walls, utility boxes, and
underutilized spaces
along Atlantic Avenue
into vibrant canvases
that celebrate the unique
character of Cudahy.

By incorporating culturally relevant sculptures and murals, this initiative will uplift the community and extend cultural pride through colorful public art. These artistic expressions can reflect the rich Latino heritage of the neighborhood, creating a cohesive visual narrative that resonates with residents and visitors alike. It is also important that a part of this process engages Atlantic Avenue businesses and owners to ensure the public art is reflective of the community and enhances the beautification of businesses.

With this initiative, the creation of Public Art Guidelines will set the design standards for the development, selection, and installation of public artworks that are reflective of the Cudahy community. The creation of these Guidelines will involve an extensive community engagement process that will allow local artists, residents, and stakeholders in the creation of these design standards. This can include colors, designs, themes that are culturally relevant to the community.

Importantly, this initiative should be community-led,
encouraging local artists and residents to collaborate on design concepts that truly represent their experiences
and stories. Engaging the community in the creation of
these artworks fosters a sense of ownership and pride
in public spaces. Additionally, establishing a plan for the ongoing maintenance and preservation of these installations will ensure that art remains a lasting tribute to the cultural identity of Cudahy. This program not only beautifies the area but also strengthens community bonds and enhances the overall vibrancy of Atlantic Avenue.

Context
The Public Art Initiative is important for Cudahy as it will transform blank spaces along Atlantic Avenue into
vibrant murals and sculptures that celebrate the community’s Latino heritage. By engaging local artists and residents in the creation process, the initiative fosters pride and ownership while beautifying the area. This program
strengthens community ties, enhances the cultural identity of Cudahy, and creates lasting, colorful public art that resonates with both residents and visitors.

PROJECTS
Lead Agency
City of Cudahy - Community
Services Department
Supporting Partners
City of Cudahy - Community Development
Department
City of Cudahy - Public Works Department
Community Based Organizations
Local School Districts
Property Owners
Priority
Medium-Term (2-5 years)

4.2.3 Public Art Potential Locations

1. Proximity to Metro Station - Supporting first/last mile connectivity

2. Metro Sound Wall - Largest public art opportunity in the city

3. Utility Boxes - City-owned property

4. Blank Walls - In partnership with supportive property owners Prioritization

178 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 179

4.3.1. Enhanced Cultural Events Program
Overview
Establish a community-led Enhanced Cultural Events
program to address the challenges currently faced in
hosting City-sponsored events.

While the City of Cudahy has made efforts to celebrate Latino traditions and customs through cultural events and festivals, there is potential for improving their promotion and cultural relevance. By better marketing these events and ensuring they are held on a regular basis, we can foster greater community engagement and participation.

To achieve this, the City should formalize partnerships with local community organizations, arts groups, businesses, and youth organizations. Collaborating with these stakeholders will not only enhance the cultural authenticity of the events but also encourage diverse participation from all segments of the community. Creating a shared calendar of events that reflects the interests and traditions of residents can cultivate a stronger sense of community, improve safety through increased foot traffic, and create vibrant public spaces where people can gather, celebrate, and connect. This initiative will ultimately enrich the cultural fabric of Cudahy and promote a more inclusive environment for all residents.

Context
The Enhanced Cultural Events program stems from feedback gathered in the survey, where residents expressed the desire for more culturally relevant and regularly promoted events. While Cudahy already hosts cultural celebrations, there is an opportunity to improve their visibility, inclusivity, and engagement by partnering with local organizations. This initiative aims to foster a stronger sense of community, celebrate traditions, and create vibrant spaces for connection.

PROGRAMS
Lead Agency
City of Cudahy - Community
Services Department
Supporting Partners
Community Based Organizations
Cudahy Chamber of Commerce
City of Cudahy - Community
Development Department
Local School Districts
Priority
Long-Term (5-10 years)

4.3.2. Neighborhood Watch Initiative
Overview
Establish a community-led
Enhanced Cultural Events
program to address
the challenges currently
faced in hosting Citysponsored events.

While the City of Cudahy has made efforts to celebrate
Latino traditions and customs through cultural events and festivals, there is potential for improving their promotion and cultural relevance. By better marketing these events and ensuring they are held on a regular basis, we can foster greater community engagement and participation.

To achieve this, the City should formalize partnerships with local community organizations, arts groups, businesses, and youth organizations. Collaborating with these stakeholders will not only enhance the cultural authenticity of the events but also encourage diverse participation from all segments of the community. Creating a shared calendar of events that reflects the interests and traditions of residents can cultivate a stronger sense of community,
improve safety through increased foot traffic, and create vibrant public spaces where people can gather, celebrate, and connect. This initiative will ultimately enrich the cultural fabric of Cudahy and promote a more inclusive environment for all residents.

Context
The Enhanced Cultural Events program stems from feedback gathered in the survey, where residents expressed the desire for more culturally relevant and regularly
promoted events. While Cudahy already hosts cultural
celebrations, there is an opportunity to improve their visibility, inclusivity, and engagement by partnering with local organizations. This initiative aims to foster a stronger sense of community, celebrate traditions, and create vibrant
spaces for connection.

PROGRAMS
Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
Community Based Organizations
Cudahy Chamber of Commerce
City of Cudahy - Community
Development Department
Local School Districts
Priority
Long-Term (5-10 years)

180 STRATEGIC PLAN FOR A THRIVING COMMUNITY STRATEGIC PLAN FOR A THRIVING COMMUNITY 181

4.3.3. Community Placemaking Program
Overview
The City can develop a Community Placemaking
Program designed to foster a vibrant and inclusive
environment.

This initiative will actively encourage local residents to participate in placemaking efforts, ensuring that public spaces authentically reflect the needs and desires of the Latino community. By engaging residents in the design and enhancement of their surroundings, the program aims to create welcoming and functional spaces that promote social interaction and cultural expression.

In addition to placemaking, this program will incorporate an educational campaign aimed at establishing a strong identity for the City. By collaborating with resident leaders, community groups, and local artists, the campaign will highlight Cudahy’s unique cultural heritage and foster a sense of pride among residents. Community workshops and events will provide platforms for residents to share their ideas and collaborate on projects, such as murals, community gardens, and gathering spaces that celebrate local traditions.

Through this dual approach of placemaking and education, the City will empower residents to take ownership of their public spaces, strengthening community ties and enhancing the overall quality of life. This initiative not only beautifies Cudahy but also cultivates a shared identity that reflects the rich diversity of its residents.

Context
This initiative encourages active participation from the local Latino community in designing public spaces that reflect their needs and cultural identity. By engaging residents in placemaking and supporting educational campaigns, the program fosters pride, strengthens community ties, and enhances the overall quality of life in Cudahy. It creates welcoming spaces for social interaction and cultural expression, while celebrating local traditions and building a shared identity

PROGRAMS
Lead Agency
City of Cudahy - Community
Services Department
Supporting Partners
Community Based Organizations
City of Cudahy - Community Development
Department
Local School Districts
Priority
Short-Term (1-2 years)

4.3.4. Front Yard Activation
Overview
Creative incentives
for Cudahy residents
to participate in the
standardization of materials
and design elements for
front yards, reflecting the
cultural preferences of
the community through
the principles of Latino
Urbanism, particularly the
Mexican vernacular model.

This would involve establishing guidelines for material and aesthetics that aim to promote the use of culturally relevant outdoor furniture, emphasizing
brightly colored materials, string lights, decorative
fountains, and the use of drought-resistant native
plants that honor the local ecosystem and cultural
heritage. Locations of where to prioritize implementation of the front yard activation program will be based on various factors including proximity to the
proposed Metro stations, willingness of residents
and property owners, and areas where ample space
is provided for front yard space. The City of Cudahy
will establish a multilingual education and engagement strategy as part of this residential program to ensure the successful implementation of this strategy. This will include public workshops to educate homeowners and landlords on design guidelines, a
resource hub with technical assistance for property
improvements, and collaborations with local organizations for ongoing feedback and collaboration.

Context
This initiative is important because it aims to foster
a sense of pride and cultural connection in Cudahy’s residential areas, enhancing the visual appeal and community identity. However, it must be recognized that the majority of Cudahy residents are renters, which can limit their ability to make permanent changes to their front yards. Given this context, the
program’s success would depend on offering flexible,
temporary solutions that allow residents to engage
with the initiative while accommodating the transient
nature of rental properties. Encouraging participation
through creative incentives could empower renters
to express their cultural identity and contribute to
the community’s visual and cultural richness.

PROGRAMS
Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
City of Cudahy - Public Works Department
Property Owners
Priority
Long-Term (5-10 years)

182 STRATEGIC PLAN FOR A THRIVING COMMUNITY

4.3.5. Enhanced Code Enforcement
Overview
To improve community standards and address persistent
code violations, the City of Cudahy would enhance
its code enforcement powers. Key strategies include
adopting a tiered fine structure to escalate penalties
for repeat offenders and allowing officers to issue
citations for minor infractions directly.

A public registry of these landlords and property owners will promote accountability, while educational programs will encourage compliance. The program also emphasizes collaboration with local law enforcement to address root causes, such as economic challenges, and regular evaluations to ensure enforcement strategies remain effective. These measures aim to create a safer, more orderly, and vibrant community.

Context
Cudahy faces ongoing challenges with repeat code violations that can disrupt neighborhood harmony and diminish the overall quality of life. Existing enforcement mechanisms often lack the tools needed to deter habitual offenders, leaving unresolved issues that frustrate residents and delay progress. By enhancing enforcement capabilities and incorporating educational and support programs, the City of Cudahy can address both the symptoms and underlying causes of non-compliance. This approach not only ensures fairness and accountability but also fosters a more collaborative relationship between residents and enforcement agencies, supporting a healthier and more cohesive community. Some community members have expressed concern that repeat offenders should not be punished, but should be given educational resources and opportunities that they need to implement such changes.

PROGRAMS
Lead Agency
City of Cudahy - Community
Development Department
Supporting Partners
Property Owners
Community Based Organizations
Cudahy Chamber of Commerce
Priority
Medium-Term (2-5 years)

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 1 of 17

STAFF REPORT
Date: March 18, 2025
To: Honorable Mayor/Chair and City Council/Agency Members From: Alfonso Noyola, City Manager/Executive Director
By: Juan Arauz, AICP, Assistant City Manager/Community Development Director Prepared By: Cecilia Madrigal-Gonzalez, Senior Planner
Concurrence: Paloma McEvoy, Assistant City Attorney.

Subject: Introduction and Adoption by First Reading of Ordinance No. 759 Repealing Ordinance No. 697, Terminating Development Agreement No. 18-011C between the City of Cudahy and Aqua Tergere, LLC

RECOMMENDATION
The City Council is requested to:

1. Open the public hearing and receive public comment and testimony; and

2. Make a determination that Aqua Tergere, LLC (“Operator”) is not in compliance with the terms and conditions of Development Agreement (“DA”) No. 18-011C with the City of Cudahy (“City”) and find the Operator is in default of contractual obligations set forth in the DA; and

3. Introduce and adopt by first reading Ordinance No. 759 (Attachment A) repealing Ordinance No. 697 terminating DA No. 18-011C between the City and Aqua Tergere, LLC; and

4. Schedule the second reading of Ordinance No. 759 at the next regularly scheduled meeting on April 1, 2025; and

5. Determine that these actions are exempt from the California Environmental Quality Act (“CEQA”) pursuant to CEQA Guidelines Section 15321 (Enforcement Actions by Regulatory Agencies).

Item Number
13B

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 2 of 17

SUMMARY
Pursuant to the terms and conditions of DA No. 18-011C and Commercial Cannabis Permit (“CCP”) No. 18-0011, it is the City’s purpose and intent to regulate cannabis activities within the City in a responsible manner to protect the health, safety, and welfare of the residents of Cudahy and to enforce rules and regulations consistent with California’s cannabis laws.

Cannabis operators with development agreements are obligated to comply with all provisions of the Cudahy Municipal Code (“CMC”), obligations of the DA, and conditions of approval under the CCP, and applicable state and local laws and related regulations. This report provides a summary of the unrefuted evidence offered at an administrative review hearing; a decision by a third-party hearing officer (“Hearing Officer”) finding the Operator in default of the DA and out of compliance with the CCP; the public hearing by the Planning Commission determining that the Operator has failed to comply with the terms and conditions of its DA, despite being provided with ample notice and several opportunities to achieve compliance, thereby recommending to the City Council that it repeal Ordinance No. 697 and DA No. 18-011C through the adoption of Planning Commission Resolution No. 2024-18. Therefore, City staff recommends the City Council adopt Ordinance No. 759 repealing Ordinance No. 697 terminating DA No. 18-011C.

BACKGROUND

1. On September 11, 2017, the City adopted Ordinance No. 673 (Attachment B) establishing the City’s commercial cannabis production activity regulations codified in Chapter 5.20 of the Cudahy Municipal Code (“CMC”). CMC Section 5.20.040 authorizes medicinal commercial cannabis activities within a designated overlay zone, pursuant to a development agreement adopted in accordance with the Development Agreement Law (Gov. Code § 65864 et seq.) and Chapter 20.28 of the CMC.

2. On September 17, 2018, after conducting a duly noticed hearing, in conjunction with CMC Section 20.28.030, the Planning Commission reviewed, considered, and recommended disapproval of an ordinance to enter into and approve a Development Agreement (“DA”) and denial of CCP No. 18-0011 to permit cannabis manufacturing activities with accessory general business offices at 8210 Atlantic Avenue, Cudahy, CA (“Site”). The Agenda, Staff Report, and Draft Minutes are provided in Attachment E, pp. 56-229.

3. On or around August 14, 2018, Operator submitted a tenant improvement (“TI”) plan check application for cannabis activities at the Site to the City’s third-party plan checker (Plan Check #PC18-0011) (Attachment E, pp. 734-789). Plan Check #PC18-0011 was disapproved and waiting for Operator to resubmit as of September 4, 2019 (Attachment E, pp. 790-793). Due to inactivity, Plan Check #PC18-0011 automatically expired 180-days afterwards, on March 2, 2020. The City has no record of a request for a time extension on the plan check application from the Operator.

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 3 of 17

4. On October 1, 2018, the City Clerk’s Office received the Operator’s appeal of the Planning Commission’s disapproval of the CCP and recommendation not to approve a development agreement between the City and the Operator (Attachment E, pp. 230-232), pursuant to CMC Section 20.84.160 (Appeals). Operator claimed the Planning Commission “failed to articulate findings and provide supporting evidence identifying specifics in the record that are reasons for the denial.”

5. On November 6, 2018, the City Council, after conducting a duly noticed hearing, in conjunction with CMC Section 20.28.060, and after independent consideration and de novo review on appeal, approved the execution of DA No. 18-011C (Attachment E, pp. 443-491) by first reading of Ordinance No. 697 and issuance of CCP No. 18-0011 through the approval of City Council Resolution No. 18-49 (Attachment E, pp. 704-708). The Agenda, Minutes, and Staff Report are provided in Attachment E, pp. 245-436.

6. On November 20, 2018, the City Council conducted a second reading and adopted Ordinance No. 697 (Attachment C) authorizing the execution of DA No. 18-011C (Attachment E, pp. 443-491), inclusive of Exhibits A-F (Attachment E, pp. 492-542), between Operator and the City authorizing commercial cannabis manufacturing activities and office at the Site as illustrated in Figures 1 and 2, below. The Site Plan and Floor Plan are incorporated by reference in Article 3(a) of DA No. 18-011C. Recital I of DA No. 18- 011C permits the Operator to operate in an approximately 2,665 square foot (“sf”) building, inclusive of 1,084 sf of cannabis manufacturing space (Attachment E, pp. 447- 448). The Agenda, Minutes, and Staff Report for the November 20, 2018, City Council Meeting are provided in Attachment E, pp. 543-668.

FIGURE 1 – AERIAL OF SITE
Site
8210 Atlantic Ave.

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 4 of 17

FIGURE 2 – FLOOR PLAN

7. On March 18, 2019, the City received a plan check application (Plan Check #440) submittal for interior tenant improvements (“TI”) for a cannabis facility at the Site (Attachment E, pp. 675-684).

8. On October 2, 2019, the City provided Operator with a Notice of Delinquency (Attachment E, pp. 669-671) prior to placing the Operator in default status due to payment noncompliance with the Development Agreement and Commercial Cannabis Permit, inclusive of the non-payment of Community Benefit Fees, Cost Recovery Fees, and Non-Operating Fees1 in the amount of sixty-four thousand two hundred sixty-seven dollars and ninetythree cents ($64,267.93). The Operator was given no later than October 17, 2019 to pay the past due amounts, however, the default was not timely cured.

9. On December 12, 2019, the City’s third-party plan checker approved Plan Check #440 for interior tenant improvements as noted in the record log (Attachment E, pp. 732-733). No building permit was issued pursuant to Plan Check #440, therefore the plan check 1 As used herein, the terms Operating Fees and Non-Operating Fees are used interchangeably.

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 5 of 17

approval expired one-hundred and eighty (180) days after the approval date on June 12, 2020. The City has no record of a time extension request by the Operator.

10. On May 4, 2021, the City provided Operator with a Notice of Default (Attachment E, pp. 672-674) due to the Operator’s non-compliance with payment of fees and associated penalties in the amount of two hundred eight thousand three hundred nine dollars and nine cents ($208,309.09). The Operator was given no later than thirty (30) days to cure the default, however, the default was not timely cured.

11. On August 17, 2022, City staff and the Los Angeles County Sheriff’s Department conducted an inspection of the Site and observed multiple Building, Mechanical, Electrical, and Plumbing Code violations. As such, the City issued a stop work notice due to unpermitted construction (Attachment E, pp. 685-686). During the inspection, the following building, mechanical, fire, electrical, and plumbing code violations were observed:
• installation of insulated panel walls;
• installation of cannabis extraction room;
• installation of fire suppression system;
• installation of HVAC ducts;
• installation of an upgraded electrical panel; and
• installation of plumbing throughout the facility.

12. All violations observed were constructed without obtaining proper Zoning Clearance, engineered drawings, plan check approval, building permit issuance, and inspections. The Operator failed to take necessary actions to correct the stop work notice. To correct the actions, the Operator was required to obtain requisite approvals and permits from the City Planning Division and Building & Safety Division. As of the writing of this report, the Operator has not obtained requisite approvals and permits from the City Planning Division and Building & Safety Division.

13. On September 13, 2022, the City proceeded to declare the structure unsafe and dangerous for occupancy, commonly referred to as “red-tag,” and issued a letter (Attachment E, pp. 687-693) to Operator to clear all violations within 10 days. The notice was also placed at the Site as shown in Attachment E, pp. 690-693. However, as detailed below, Vladimir Calderon (“Property Owner”) pulled a demolition permit to remove the unpermitted improvements and the Site’s red-tag status was removed on May 9, 2023.

14. On September 20, 2022, Operator appeared at City Hall to discuss the Site’s red-tag status. City staff spoke with Operator and answered questions on the unpermitted improvements and financial obligations. Operator also verbally requested a time extension, City staff advised Operator to submit formal extension in writing.

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 6 of 17

15. On September 21, 2022, the City received an email (Attachment E, pp. 694-696) from Vince Sanchez memorializing the conversation with City staff on September 20, 2022, and acknowledging the red-tag status, and informing the City of hardships with their previous contractors, requesting to amend the DA to allow a different license type and requesting an extension to complete the list of corrections detailed in Attachment E, pp. 687-689.

16. On September 22, 2022, the City received an email from Cheryl Montanez (Attachment E, pp. 794-795) from MO+RE Design Solutions in which Ms. Montanez stated that the unpermitted improvements did not match the plans she had reviewed and requested additional information and guidance to understand the City’s building permit process.

City staff advised Ms. Montanez regarding the City’s records and building permit process.

No further correspondence or inquiries were received from Ms. Montanez.

17. On December 6, 2022, the City Manager presented the City Council with a proposed Cannabis Deferment and Payment Program to assist cannabis operators with the accumulated Community Benefits, Cost Recovery and Non-Operating Fees by deferring and providing additional time for payment without penalty. The City Council directed the City Manager to offer the Payment Agreement to Operators who have defaulted on their payment obligations, which was approved by the City Council. Under the program:
a. Unpaid Non-Operating Fees would be deferred (without penalty) until six (6) months after the Operator was issued a Certificate of Occupancy; and then repay accumulated Non-Operating Fees within twelve (12) months; and b. Operators would continue to be responsible for the timely payment of Community Benefit Fees and Cost Recovery Fees as they accumulated; and c. Previously incurred Community Benefit Fees and Cost Recovery Fees would be subject to a payment plan and require timely payments.

18. On December 7, 2022, the City presented the terms of the Cannabis Deferment and Payment Program to the Operator (Attachment E, pp. 697-699). All cannabis operators interested in participating in this program were given no later than January 31, 2023 to execute a payment agreement with the City. The City Manager did not receive a request from the Operator to participate in the Cannabis Deferment and Payment Program.

19. On March 20, 2023, the City sent a Final Demand Letter (Attachment D) demanding Operator to respond to the following demands: 1) An updated project description; 2) Approvable plans for the Operator’s cannabis operation; and 3) Forwarding payment for the total past due amounts. The Operator did not respond in a timely manner and failed to make any attempt to cure the defaults within the thirty (30) day period.

20. On April 24, 2023, the City received an unsolicited email from "[email protected]" claiming to provide notice of Aqua Tergere, LLC, informing the City that it had (1) “officially shut down;” (2) the company had gone bankrupt; and (3) the company was no longer able

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 7 of 17

to continue operations (Attachment E, pp. 709-714). The email also informed the City that the building lease had expired and the Operator returned the keys to the landlord.

Lastly, the email informed the City that the Operator was withdrawing its “submission application” (Attachment E, p. 711).

21. On May 2, 2023, the City responded to the Operator's email communication, which informed the Owner that the notice was insufficient to terminate the DA and provided the correct process in order to terminate the DA which requires the written notice to “be signed, by an authorized party, and given personally or by registered or certified mail (return receipt requested), or by Federal Express, UPS or similar couriers” (Attachment E, pp. 709-714). The Operator was given no later than (10) days from the date of the letter to submit the requisite documentation.

22. On May 9, 2023, the City issued the Property Owner a demolition permit (Permit #820) to demolish all unpermitted work (Attachment E, pp. 730-731). The Site’s red tag-status was subsequently removed.

23. On May 18, 2023, the City received formal written notification dated May 8, 2023 from Mr. Charles Arden, representing the Operator, informing the City of their decision to terminate the lease agreement for the Site and requesting that the letter serve as official confirmation of the voluntary termination of their cannabis operation in the City (Attachment E, pp. 715-717).

24. According to the lease terms, the Operator’s leasehold interest in the Site expired on May 31, 2023 (Attachment E, pp. 715-717). The lease did not provide any options to extend the lease term.

25. On August 22, 2023, the City provided Operator a letter (Attachment E, pp. 718-726) acknowledging the May 8, 2023 Notice of Termination was received by the City pursuant to DA Article 14(d) and effective upon the date of the written notice. The letter confirmed that the Operator had “ceased all cannabis operations within the City.” Proper notice of termination of the Development Agreement has been given by Aqua Tergere, LLC and such termination is effective upon the date written notice was given to the City.

Therefore, the City is prepared to process documents terminating Development Agreement No. 18-0011C [as] of May 18, 2023, except as set forth in the Agreement (Attachment E, pp. 718-726, emphasis original). The City advised that it had prepared documents to formally terminate the DA pursuant to Article 11(c), which states “Termination of this Agreement shall not, however, eliminate the rights of the City to seek any applicable and available remedies or damages based upon acts or omissions occurring before termination.” As of May 18, 2023, the outstanding fees due to the City, inclusive of Operating Fees, Community Benefit Fees, and Cost Recovery Fees, is $334,921.56. The City prepared an “Agreement Re: Aqua Tergere, LLC’s Notice of Termination of Development Agreement No. 18-011C and Voluntary Surrender of Commercial Cannabis Permit No. 18-0011” (Attachment E, pp. 723-726) and a “Memorandum of Termination” (Attachment E, pp. 721-722) for Operator’s review and signature. The Operator

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 8 of 17

responded to the City by asking for an extension of time, until September 15, 2023 to respond to the City’s Notice of Termination (Attachment E, pp. 727-729).

26. October 26, 2023, more than a month after the Operator’s requested extension (Attachment E, pp. 910-912) to respond, an attorney for the Operator contacted the City with an offer to settle the outstanding amount owed to the City, under the following terms:
a. Termination of DA No. 18-011C; and
b. Waiver of all fees, penalties, and/or other sums, including but not limited to any and all guarantees by the Company and/or individual members, allegedly owned by the Operator and/or its members; and
c. Waiver of all fees, penalties, sums, and/or claims, including but not limited to, any personal guarantees, allegedly due and/or owed by the Operator and/or individual member(s); and
d. Mutual waiver of all fees, penalties, sums, and/or claims arising out of or under DA No. 18-011C.

27. The Operator’s legal counsel did not dispute the amount of the fees accumulated or the fact that fees were due, but objected to payment on the basis that the Operator was “unable to secure timely reviews and/or approval of plans or specifications during “most of 2020 and 2021” (Attachment E, p. 911). Operator’s counsel further argued that the “City is precluded from collecting any fees or penalties due to State and Federal emergency orders in place preventing or precluding timely construction and/or development, that the City’s failure to treat all applicants/licensees equitably during this time of extreme emergency was a denial of due process, and the alleged Community Benefit Payments (CBD) presuppose a ‘going concern’ – a fully operational business” (Attachment E, pp. 911-912). Operator’s legal counsel did not offer any explanation as to the Operator’s non-compliance in 2019, 2022, and 2023. Nor did Operator’s counsel demonstrate how the Operator had been treated inequitably by the City or how the Operator had been denied due process.

28. Due to the characterization of the statements made by Operator’s counsel and an offer to “settle claims” the City Council conferred regarding the foregoing settlement terms in a Closed Session hearing pursuant to Government Code Section 54956.6(d)(2), which permits a closed session discussion due to anticipated litigation. The City Council did not accept the Operator’s proposed settlement terms and directed the City Attorney’s Office to communicate this decision to the Operator’s counsel. The City’s letter noted the number of unfounded and unsupported assertions made by the Operator’s counsel including the fact that governmental orders during the COVID-19 pandemic did not preclude commercial construction or cannabis activities such as cultivation, manufacture, and sales; the lack of substantiation regarding unfair or inequitable treatment; a

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 9 of 17

Constitutional prohibition of a gift of public funds; and a lack of due process (Attachment E, pp. 913-922).

29. On July 11, 2024, the City issued to the Operator a Notice of Review Hearing with the hearing date, time, and place via certified mail (Attachment E, pp. 805-808).

30. On July 24, 2024, the City received email correspondence from F. Araiza-Kasama, the Operator’s counsel, requesting the August 12, 2024 hearing date be continued, stating she was unable to attend the hearing (Attachment E, p. 929).

31. On July 30, 2024, the City granted a one-time request to Operator to reschedule the Review Hearing to August 27, 2024, at 9:00 AM (Attachment E, pp.930-935) pursuant to Ms. Araiza-Kasama’s availability. The revised Notice of Review Hearing with the hearing date, time and place was sent via certified mail and email (Attachment E, p. 930-931, 935).

32. As of July 25, 2024, the website for the California Department of Cannabis Control shows no record of a cannabis license issued to Aqua Tergere, LLC (Attachment E, p. 924).

33. As of July 25, 2024, the Operator’s status with the Secretary of State and the Franchise Tax Board is suspended (Attachment E, p. 924), meaning the Operator’s powers, rights and privileges are suspended in the state of California. As of the writing of this report, the Operator’s status remains suspended.

34. On August 26, 2024, the day prior to the Review Hearing, the City received a letter (Attachment E, pp. 936-938) from Marshall L. Hogan, new counsel retained by the Operator, requesting the City to continue the Review Hearing by one month on the basis that Mr. Hogan could not attend the Review Hearing and the continuance would allow additional time “to understand the allegations so that it can be in a position to respond to those allegations on behalf of [Operator].” The letter was admitted into the City’s Administrative Record during the Review Hearing held on August 27, 2024 (Attachment E, pp. 936-938). The City notes that at the time it received the verbal request, Operator had not submitted evidence of compliance ten (10) days in advance of the Review Hearing nor paid the estimated cost for the Review Hearing, as required by the DA and CCP (see also, Attachment E, pp. 805-807). Additionally, the City already stipulated a one-time continuance pursuant to a request from the Operator’s previous attorney to continue the Review Hearing by two (2) weeks (Attachment E, pp. 929-934), and therefore the City advised the Operator’s counsel to send a representative to the Review Hearing to ask the Hearing Officer for a continuance, and if there was no one available to send to the hearing, that Operator’s counsel request that the Hearing Officer grant the request for a continuance through a letter.

35. On September 24, 2024, the Hearing Officer issued a written decision and order (the “Decision”) (Attachment F) finding evidence showing the Operator, despite considerable notice and opportunities to cure outstanding issues, has breached the terms and conditions of the DA and CCP and recommended the Planning Commission and City

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 10 of 17

Council repeal Ordinance No. 697 terminating DA No. 18-011C and revoke CCP No. 18- 0011.

36. On November 18, 2024, pursuant to State law and the CMC, the Planning Commission held a duly noticed public hearing to consider the Hearing Officer’s recommendation to repeal Ordinance No. 697 and terminate DA No. 18-011C. The Planning Commission considered all public comments received before and during the public hearing, the presentation by City staff, the relevant staff report, administrative record, and all other pertinent documents. No representation from the Operator was present at the hearing.

After closing the public hearing, the Planning Commission adopted Resolution No. 2024- 18 (Attachment L), recommending the City Council repeal Ordinance No. 697 and terminate DA No. 18-011C.

ANALYSIS
During a review of the Operator’s compliance with the Development Agreement, the burden is upon the Operator to demonstrate good faith compliance with the terms of the Development Agreement under Article 19. Pursuant to Government Code Section 65868.1 and Articles 19 and 19(d) of the Development Agreement, if the City Council determines, based on substantial evidence, that the Operator has not complied in good faith with the terms of the conditions of the Development Agreement, the City Council may terminate the Development Agreement or alternatively may choose to modify and impose conditions reasonably necessary to protect the interests of the City. Conversely, if the Operator is found to be in compliance with the Development Agreement, the Operator may request the City to issue a Certificate of Compliance pursuant to Article 19(e). Any decision to terminate a development agreement must be reviewed by the Planning Commission prior to review by the City Council, Gov. Code § 65867. Under Article 19(d), the decision to terminate a development agreement by the City Council is final and only subject to appeal pursuant to Civil Code Section 1094.5.

As it relates to the CCP, pursuant to CMC Sections 5.20.080(6) and 5.20.080(7), any material violations of Chapter 5.20, any other relevant city law or state law, condition of approval, or any other required agreement or covenant, such as a development agreement, by a cannabis permittee, or cannabis permittee’s agent, is ground for suspending or revoking the relevant cannabis permit. The decision to suspend or revoke a cannabis permit is with the City Manager or his designee. Furthermore, pursuant to CMC Section 5.20.080, any decision regarding the suspension or revocation may be appealed to the City Council.

The City Manager has appointed a third-party hearing officer (“Hearing Officer”) to conduct a review of the Operator’s compliance with CCP No. 18-0011 and DA No. 18-011C. The findings and determinations made by the Hearing Officer inform any subsequent action to terminate or modify the Development Agreement and suspension or revocation of the CCP. As stated above, and further described in Attachment F, the Hearing Officer issued a written decision making

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 11 of 17

several findings of fact and conclusions and determined that the Operator breached the terms and conditions pursuant to DA No. 18-011C and CCP No. 18-0011, based on a preponderance of the evidence, in the following material aspects:

1. Violation #1. Breach of Payment Obligations. Pursuant to DA Article 5(b) (Community Benefit Fees), Article 7(c) (Operating Fees) and Article 8 (Cost Recovery Fees), the Operator must pay the City an annual Community Benefit Fee in the amount of $66,667.00 ($13,333.40 down payment and monthly payments in the amount of $5,333.36), a Cost Recovery Fee, and an Operating [or Non-Operating] Fee since 2018.

The Operator is also obliged to make payments for Cost Recovery Fees within 30 days of receipt of a City invoice pursuant to Condition of Approval Nos. 1(a) and 1(b) of the CCP; pay all Operating Fees under the DA pursuant to Condition of Approval No. 8; and all fees due under the DA pursuant to Condition of Approval No. 17. In December 2022, the City offered a Payment Agreement to the Operator but the City did not receive any interest from the Operator.

The Operator’s duty to comply with the CCP conditions of approval are incorporated into DA No. 18-011C2 under Section 18, Conditions 1(a) and 1(b) require the Operator to pay all City-issued invoices within 30 days of receipt. Conditions 8 and 17 all require timely payment of fees due under the Development Agreement. The City has regularly sent monthly invoices for Community Benefits Fees, Cost Recovery Fees, Non-Operating Fees, and appliable late penalties since 2018 (Attachment E, pp. 813-891).

On May 18, 2023, the City was provided notice by the Operator stating they had ceased cannabis operations, and as such the termination began effective upon the date of written notice received. However, pursuant to DA Article 11(c), the termination of the DA does not eliminate the City from seeking any applicable and available remedies or damages based upon acts or omissions occurring before termination. Operator is not relieved of obligations already incurred. As of May 18, 2023, the City reported the Operator had incurred $334,921.56 of past-due payments, including late payment penalties.

City staff brought forth the Operator request to waive all fees and penalties due to the “COVID-19 pandemic emergency shut down,” but failed to provide evidence how the waived of accrued fees under a contractual agreement is permitted under the DA.

Based on the evidence submitted by the City, Hearing Officer found that “a preponderance of the evidence shows that the [Operator] has materially breached the terms of DA No. 18-011C by failing to make all required payments to the City…despite 2 Section 18 of DA No. 18-011C states “Owner shall comply with all conditions of approval of the Regulatory Permit approved by City Council.” The Regulatory Permit is CCP No. 18-0011.

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 12 of 17

demand and after proper notice of default and opportunity to cure.” Further, “the [Operator] non-payment of [fees] under the [DA], respectively in violation of Condition Nos. 8 and 17 consistent grounds for termination of the DA and revocation of the [Operator] interest in the CCP” (Attachment F, pp. 8-9). The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find the Operator is in default of the terms set forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

2. Violation #2. Breach of Conditions of Approval No. 23 (Time Limits) under CCP No. 18- 0011. The Operator’s duty to comply with the CCP’s conditions of approval are incorporated into DA No. 18-011C under Section 18. CCP Condition of Approval No. 23(A)(i) sets a 90-day time frame in which the Operator needed to obtain a Zoning Clearance. Condition of Approval No. 23(A)(ii) sets a 90-day time frame in which the Operator must complete construction of Phase I as indicated in the approved Floor Plan.

CCP Condition of Approval 23(A)(iii) sets a 180-day time limitation from the effective date of the CCP to complete all tenant improvements, construction, and obtain a certificate of occupancy from the Building & Safety Division. Failure to obtain a Zoning Clearance within 90 days of the effective date of the CCP, renders the CCP to “expire and become null and void” (Attachment E, p. 541). The City Manager’s ability to grant an extension of time for a Zoning Clearance if the Operator has made diligent efforts to implement the project is stated in Conditions of Approval 23(A)(i), (ii), and (iii). The effective date of the CCP is November 22, 2018.

The Operator submitted two (2) TI plans to the City’s third-party plan checker in August 2018 and March 2019. As further described above, Plan Check Nos. #18-0011 was disapproved and expired on March 2, 2020, and #440 was approved on December 12, 2019, however, Operator failed to obtain the building permit which subsequently expired on June 12, 2020. The City’s Planning Division has no record of the Operator applying for a Zoning Clearance for either Plan Check #18-0011 or #440, which were ultimately disapproved. The City has no record of any requests by the Operator to the City Manager for a time extension. Without the extensions, the deadlines to complete any phase set forth in CCP Condition of Approval No. 23 expired in 2019.

Based on the evidence submitted by the City, the Hearing Officer found “a preponderance of the evidence shows [Operator] remains in breach of conditions of approval by failing to implement the Project within the time limits set forth in Conditions of Approval No. 23.A, despite the [Operator] submittal for building plan check” (Attachment F, pp. 10-11). As previously stated, the CCP conditions of approval are incorporated into the DA through Section 18. The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find that Operator is in default of the terms set

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 13 of 17

forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

3. Violation #3. Breach of Conditions of Approval No. 21 (Construction Activities) under CCP 18-0011. The Operator’s duty to comply with the CCP’s conditions of approval are incorporated into DA No. 18-011C under Section 18. Condition of Approval No. 21 states “prior to any construction, the [Operator] shall obtain a Zoning Clearance for construction from the Planning Division and a Building Permit from the Building and Safety Division.” The City has no record of any Zoning Clearance application or issuance of a building permit to complete or perform any construction at the Site. Yet on August 17, 2022, City staff entered the Site and observed the installation of insulated panel walls; a cannabis extraction room; a fire suppression system; HVAC duct; upgraded electrical panels; and plumbing throughout the facility.

Based on the evidence submitted by the City, the Hearing Officer found that “based on a preponderance of the evidence…the [Operator] is in violation of Conditions of Approval No. 21” (Attachment F, p. 10). As previously stated, the CCP conditions of approval are incorporated into the DA through Section 18. The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find that Operator is in default of the terms set forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

4. Violation #4. Breach of Conditions of Approval No. 20 (Modification Procedures) under CCP 18-0011. The Operator’s duty to comply with the CCP’s conditions of approval are incorporated into DA No. 18-011C under Section 18. Condition of Approval No. 20 states “prior to undertaking any operational or construction-related activity which is not expressly described in these [CCP Conditions], the [Operator] shall first contact the City Manager to determine if the proposed activity requires a modification. The City Manager may, at his sole discretion, require the [Operator] to file a written and/or mapped description of the proposed activity in order to determine if a permit modification is required.” Article 7(c) of DA No. 18-011C also provides that the Operator was limited to a 1,084-sf space to conduct any cannabis manufacturing activities. Any proposed deviation from the permitted square footage must be approved by the City Manager.

On August 17, 2022, City staff conducted an inspection and observed several violations of the Building, Mechanical, Electrical, and Plumbing code which did not conform to the originally approved Site Plan and Floor Plan, inclusive of a cannabis extraction room, which is not an approved commercial cannabis activity. The Operator was required to formally submit a written or mapped description of the proposed design changes for the City Manager’s approval. The City has no record of the Operator submitting nor obtaining prior approval to deviate from the original Site Plan and Floor Plan. The Operator not only modified the Project by engaging in unpermitted construction, but the scope of the

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 14 of 17

unpermitted construction supported cannabis extraction activities, which is outside of the scope of the City’s approvals.

Based on the evidence submitted by the City, the Hearing Officer found “a preponderance of the evidence shows the [Operator] breached its conditions of approval….by failing to receive City Manager approval for the design changes made to the facility set forth in [COA] No. 20.” Further, that Operators “project changes were outside of the scope of approved commercial cannabis activities” (Attachment F, pp. 10-12). As previously stated, the CCP conditions of approval are incorporated into the DA through Section 18. The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find that Operator is in default of the terms set forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

5. Violation #5. Failure to Obtain State-Issued Cannabis Licenses for Cultivation and Manufacturing. Recital I of the DA states the Owner has applied for one (1) license:
manufacturing. Article 21 of the DA states that the facility shall not operate unless the Operator is the holder of a State-issued Cannabis license for the type of commercial cannabis facility or business operation that is the subject of the DA. The DA also requires the Operator to be a lawful entity capable of operating in accordance with a state-issued cannabis license.

The Operator breached the DA because the Owner does not hold a state-issued Cannabis license for the facility. As of July 25, 2024, search of the term “Aqua Tergere” on the Cal Cannabis website shows no record of an active cannabis license issued to Operator (Attachment E, pp. 925-927). As of the writing of this report March 5, 2025, the Operator still does not hold a state-issued cannabis license (Attachment H).

Based on the evidence submitted by the City, the Hearing Officer found that based “on the preponderance of the evidence [which] shows that [Operator] breached the DA because the [Operator] has not obtained a State issued Cannabis license for the [Site]” (Attachment F, p. 11). The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find that Operator is in default of the terms set forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

6. Violation #6 Failure to Maintain a Legal Business Entity. The DA sets forth standard operating procedures as mentioned in DA No. 18-011C Article 4(a) (Facility Operations).

Article 4(a) requires the Owner to “lawfully operate in accordance with all state and local laws.” In addition, CCP No. 18-0011 Condition of Approval No. 3 requires the Operator to implement the Project in “compliance with all applicable requirements and enactment of federal, state, and local authorities.” Condition of Approval No. 22 also states that the

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 15 of 17

Operator is “responsible for being aware of and complying with the CCP conditions and all applicable federal, state, and local laws and regulations.” As shown in a Certificate of Status dated July 25, 2024, the Operators legal status of a California limited liability company, Aqua Tergere, LLC, with the Secretary of State and Franchise Tax Board is suspended and all powers, rights and privileges are suspended in California (Attachment E, p. 924) (See, Rev. & Tax Code § 23301). Despite notice of default and opportunity to cure, the Operator’s status remained “suspended” at the time of the Review Hearing. As of the writing of this report March 5, 2025, the Operator’s legal status remains suspended (Attachment G).

Based on the evidence submitted by the City, the Hearing Officer found that a “suspended business entity is essentially prohibiting the entity from legally operating within the State unless and until the suspended status is withdrawn. A preponderance of the evidence shows the [Operator] breached the DA and is in violation of the CCP” (Attachment F, pp. 12). The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find that Operator is in default of the terms set forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

7. Violation #7 Failure to Maintain Legal or Equitable Interest Over Real Property.

Development Agreement Law permits a city, county, or city and county to enter into a development agreement with a person having a legal or equitable interest in real property (Gov. Code § 65865(a)).

On May 18, 2023, the Operator informed the City that it no longer had an equitable or legal interest in the Site because it no longer held a lease with the Site’s landlord (Attachment E, pp. 715-717). Further, the leasehold interest in the Site ended on May 31, 2023, and the lease did not offer any options for a lease extension. The Operator no longer has any legal interest in the Site and therefore, has no right to maintain a development agreement with the City for rights at the Site.

Based on the evidence submitted by the City, the Hearing Officer found “a preponderance of the evidence [showing] that [Operator] no longer has a leasehold interest in the Site and therefore has no legal standing to be a party to a development agreement with the City” (Attachment F, p. 12). The Hearing Officer’s determination was ratified by the Planning Commission through the adoption of Resolution No. 2024-18 which recommends that the City Council find that Operator is in default of the terms set forth in DA No. 18-011C and repeal Ordinance No. 697 and terminate the related DA.

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 16 of 17

PUBLIC NOTICE AND COMMENTS
This item was noticed in accordance with the City’s public notice requirements, which involved mailed notices to property owners and tenants within 300 feet of the Site (Attachment I) and publication in the local paper (Attachment J). As of the writing of this report, City staff have not received any public comments. Further, pursuant to Section 22 of the Development Agreement, the City sent a public hearing notice via certified mail to all concerned parties in Attachment K.

ENVIRONMENTAL ANALYSIS
The action(s) have been assessed in accordance with the California Environmental Quality Act (“CEQA”) and the environmental regulations of the City. The action(s) are categorically exempt from the requirements to prepare additional environmental documentation per CEQA Section 15321. Class 21 (Enforcement Actions by Regulatory Agencies) applies to “Actions by regulatory agencies to enforce or revoke a lease, permit, license, certificate, or other entitlement for use issues, adopted, or prescribed by the regulatory agency or enforcement or a law, general rule, standard, or objective, administered or adopted by the regulatory agency.” If the City Council terminates DA No 18-011C and the City Manager revokes CCP No 18-0011, those actions would be enforcement actions. Therefore, the action(s) are categorically exempt from the provisions of CEQA.

CONCLUSION
As discussed above and based on the preponderance of unrefuted evidence offered at the administrative Review Hearing; the public hearing by the Planning Commission finding that the Operator has failed to comply with the terms and conditions of its DA, despite being provided with ample notice and several opportunities to achieve compliance, thereby recommending to the City Council that it repeal Ordinance No. 697 and DA No. 18-011C through the adoption of Planning Commission Resolution No. 2024-18. As stated above, the Operator has failed to comply with their obligations under the DA, despite being provided with ample notice and several opportunities to achieve compliance. Therefore, City staff recommends the City Council adopt Ordinance No. 759 repealing Ordinance No. 697 and terminating DA No. 18-011C.

STRATEGIC PLAN CORRELATION
Not applicable.

FINANCIAL IMPACT
As already stated above, Operator is not relieved of obligations already incurred pursuant to the DA. As of May 18, 2023, the City reported the Operator had incurred $334,921.56 of past-due payments, including late payment penalties. Further, pursuant to Section 19 of the DA, Operator

“Serving The People” "Sirviendo A La Comunidad"
Staff Report
03/18/2025 Page 17 of 17

is responsible for the cost of the Review Hearing. On July 11, 2024, and July 30, 2024, the City requested (Attachment E, pp. 930-934) the Operator to make a $12,695.00 deposit, however, Operator failed to make the deposit. The City utilized the General Fund to cover all costs incurred related to this matter.

ATTACHMENTS
A. Draft Ordinance No. 759
B. City of Cudahy Ordinance No. 673
C. City of Cudahy Ordinance No. 697
D. Final Demand Letter, dated March 20, 2024
E. Administrative Record for Aqua Tergere, LLC
F. Decision and Order for Aqua Tergere, LLC
G. Secretary of State Status for Aqua Tergere, LLC, dated March 5, 2025 H. Department of Cannabis Control Records Search for Aqua Tergere, LLC, dated March 5, 2025 I. 300-foot Tenant and Property Owner Notice of Public Hearing J. Newspaper Publication posted on February 24, 2025
K. Proof of Notice to Operator dated sent on February 24, 2025 L. City of Cudahy Planning Commission Resolution No. 2024-18

ORDINANCE NO. 759

AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
CUDAHY REPEALING ORDINANCE NO. 697 AND

TERMINATING RELATED DEVELOPMENT AGREEMENT
NO. 18-011C BETWEEN AQUA TERGERE, LLC AND THE
CITY OF CUDAHY.

WHEREAS, the City of Cudahy (the “City”) is a general law city, incorporated under the laws of the State of California; and
WHEREAS, pursuant to its police power, the City may enact and enforce laws within its boundaries that promote the public health, safety, or general welfare of the community, and are not in conflict with general laws; and WHEREAS, on September 11, 2017, the City Council adopted Ordinance No. 673 establishing regulations for commercial cannabis activities, in a specified Overlay Zone through an acquisition of a Commercial Cannabis Permit and execution of a development agreement with the City; and
WHEREAS, to strengthen the public planning process, encourage private participation in comprehensive planning and reduce the economic risk of development, the California State Legislature adopted Section 65864 et seq. of the California Government Code (the “Development Agreement Statute"); and
WHEREAS, the Development Agreement Statute authorizes the City to enter into a development agreement with a person having legal or equitable interest in real property for the development of such property in order to establish certain development rights in exchange for public benefits; and
WHEREAS, in accordance with the Development Agreement Statute, the City Council adopted Ordinance No. 690 in 2018 establishing the procedures and requirements for the consideration of development agreements with the City and are contained within Cudahy Municipal Code (“CMC”) Sections 20.84.530 through 20.84.640; and WHEREAS, on September 17, 2018, the City Planning Commission (“Planning Commission”) conducted a properly noticed public hearing to consider an application by Aqua Tergere, LLC (“Operator”) for approval of a Commercial Cannabis Permit to allow non-store front commercial cannabis manufacturing activities at 8210 Atlantic Avenue (“Site”); and
WHEREAS, at this hearing, at this hearing, the Planning Commission heard and considered verbal and written testimony and evidence, and on a 3-1 vote, the Planning Commission recommended denial or an ordinance to enter into and approved a development agreement (“DA”) and denial of CCP No. 18-011 to allow cannabis manufacturing activities with accessory general business offices at the Site; and WHEREAS, on October 1, 2018, pursuant to CMC Section 20.84.160 (Appeals) the Attachment APage 204 of 2485
Ordinance No. 759

Operator submitted an appeal to the City Clerk appealing the Planning Commission recommendation of a DA and denial of CCP No. 18-011; and WHEREAS, on November 6, 2018, in conjunction with CMC Section 20.28.060, and after independent consideration and de novo review on an appeal, the City Council conducted a properly noticed public hearing to consider the issuance of the Commercial Cannabis Permit (“CCP”) No. 18-0011 and Development Agreement (“DA”) No. 18-011C at which the City Council heard and considered both written and oral testimony and evidence; and
WHEREAS, at the same hearing the City Council considered and approved CCP No. 18-011 and conducted the first reading of Ordinance No. 697 which authorized the execution of DA No. 18-011C between the Operator and the City; and WHEREAS, on November 20, 2018, the City Council conducted a second reading and adopted Ordinance No. 697, approving DA No. 18-011C and authorizing the Mayor to execute the DA on behalf of the City; and
WHEREAS, the effective date of the Development Agreement is December 20, 2018 (“Effective Date”); and
WHEREAS, upon the Effective Date of Ordinance No. 697, the Operator was granted the permission to conduct commercial cannabis manufacturing activities with accessory general business offices at the Site provided, among other things, it received State licensing approval and complied with the terms outlined in the DA and conditions of approval under the CCP; and
WHEREAS, the Operator has not complied with the terms and conditions of the DA and CCP despite notices and opportunity to cure and remains in material breach of thereof; and
WHEREAS, on July 11, 2024, the City provided notice to the Operator that it would be conducting a Special Review Hearing (“Review Hearing”) under Article 19.c of the Development Agreement which informed the Operator of the burden to prove compliance with the DA and CCP; and
WHEREAS, on July 24, 2024, the City received correspondence from the Operator stating they would not be able to attend the scheduled Review Hearing; and WHEREAS, on July 30, 2024, the City granted a one-time request to Operator to reschedule the Review Hearing; and
WHEREAS, on August 26, 2024, the City received correspondence from the Operator requesting the City continue the Review Hearing by one (1) month; and WHEREAS, on August 27, 2024, Steve Napolitano, Esq., a duly appointed third-party hearing officer for the City (“Hearing Officer”) conducted a properly noticed Review Hearing; and

Ordinance No. 759

WHEREAS, the Operator did not participate at the Review Hearing, was not present at the hearing and did not present any evidence for consideration and the Hearing Officer heard and considered information and evidence by City staff, which a true and correct copy of the staff report and supporting evidence (the “Administrative Record”) incorporated by reference and attached hereto as Exhibit “A” ; and
WHEREAS, the Hearing Officer heard and considered information and evidence presented by City staff; and
WHEREAS, on September 24, 2024, the Hearing Officer issued a written decision and order (the “Decision”) incorporated by reference and attached hereto as Exhibit “B”, making several findings of fact and conclusions of law with respect to the Operators noncompliance with the DA and CCP based on a preponderance of the evidence; and WHEREAS, the Hearing Officer determined that Operator breached the DA and CCP in seven (7) material respects: (1) of Payment Obligations – Non-payment of fees and costs owing to the City totaling $334,921.56; (2) Breach of Condition of Approval No. 23 (Time Limits) – Failure to implement the Project within the time limits; (3) Breach of Condition of Approval No. 20 (Construction Activities) – Operator failed to obtain any requisite approvals from the City’s Planning Division and Building & Safety Division prior to construction; (4) Failure to comply with Article 7(c) of DA 18-011C and breach of Condition of Approval No. 20 – Operator failed to receive City Manager approval for the design changes made to the Site prior to construction; (5) Failure to comply with Article 21 of DA No. 18-011C – Operator failed to obtain a State-issued cannabis license for manufacturing; (6) Failure to Comply with Article 4(a) of DA18-001C and breach of Conditions of Approval No. 3 and 22 – Operator failed to maintain a legal business entity; and (7) Failure to maintain a legal or equitable interest over real property; and
WHEREAS, the Hearing Officer has recommended that the City Council adopt an ordinance repealing Ordinance No. 697 terminating DA18-011C and revoking the related interest in CCP18-0011; and
WHEREAS, pursuant to state law and the CMC, the Planning Commission duly noticed, agendized, and conducted a public hearing on this matter; and WHEREAS, on November 18, 2024, the Planning Commission considered all public comments received before and during the public hearing, the presentation by City staff, the relevant staff report, administrative record, and all other pertinent documents relating to the repeal of Ordinance No. 697; and
WHEREAS, after the closing of such public hearing, the Planning Commission adopted Resolution No. 2024-18, recommending the City Council repeal Ordinance No. 697 and terminate related DA No. 18-011C; and
WHEREAS, pursuant to state law and the CMC, the City Council duly noticed, agendized, and conducted a public hearing on this matter; and WHEREAS, the City Council considered all public comments received before and

Ordinance No. 759

during the public hearing, the presentation by City staff, the relevant staff report, administrative record, and all other pertinent documents relating to the repeal of Ordinance No. 697; and
WHEREAS, after the close of such public hearing, the City Council introduced and adopted by first reading Ordinance No. 759, repealing Ordinance No. 697 and terminating related DA No. 18-011C.

NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF CUDAHY DOES HEREBY ORDAIN AS FOLLOWS:

SECTION 1. RECITALS
That the above Recitals are true and correct and are incorporated as though fully set forth herein.

SECTION 2. ADOPTION OF HEARING OFFICER’S FINDINGS OF FACT AND

CONCLUSIONS OF LAW
The City Council has reviewed and considered the Decision by the Hearing Officer (Exhibit “B”) issued on September 24, 2024, on this matter. For the reasons stated in the Decision and as recommended by the Planning Commission (Exhibit “C”), the City Council adopts the Hearing Officer’s findings of fact and conclusions of law as its own and determines that Aqua Tergere, LLC is not in compliance with the terms and conditions of the Development Agreement No. 18-011C and finds that Aqua Tergere, LLC is in default of its contractual obligations set forth in said Development Agreement and has breached its Conditions of Approval for CCP No. 18-0011 by a showing of the preponderance of the evidence.

SECTION 3. TERMINATION OF DEVELOPMENT AGREEMENT
Pursuant to Article 19(d) of the Development Agreement, the City Council may terminate Development Agreement No.18-011C in its entirety. For the reasons stated in the Decision and as recommended by the Planning Commission, the City Council hereby adopts this Ordinance repealing Ordinance No. 697 terminating DA No. 18-011C in its entirety.

SECTION 4. SEVERABILITY
If any section, subsection, sentence, clause, phrase, or portion of this Ordinance is for any reason held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Ordinance. The City Council hereby declares that it would have adopted this Ordinance, and each section, subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more sections, subsections, subdivisions, sentences, clauses, phrases, or portions might subsequently be declared invalid or unconstitutional.

Ordinance No. 759

SECTION 5. CALIFORNIA ENVIRONMENTAL QUALITY ACT
The City Council has determined that this Ordinance is categorically exempt from the California Environmental Quality Act (“CEQA”) (Pub. Res. Code § 21000 et seq.) and CEQA Guidelines (Cal. Code Regs., tit. 14, § 21000 et seq.) pursuant to CEQA Guidelines Section 15321 (Class 21) because the repeal of Ordinance No. 697 and termination of DA No. 18-011C is an enforcement action to revoke an entitlement interest.

SECTION 6. PUBLICATION
The City Clerk shall certify the passage and adoption of this Ordinance and shall cause this Ordinance to be published and/or posted as required by law, which shall take full force and effect thirty days from its adoption.

PASSED, APPROVED, AND ADOPTED by the City Council of the City of Cudahy at the regular meeting of this 18th day of March 2025.
______________________________
Elizabeth Alcantar Loza
Mayor
ATTEST:
____________________________
Richard Iglesias
City Clerk

Ordinance No. 759

CERTIFICATION

STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES ) SS:

CITY OF CUDAHY )
I, Richard Iglesias, City Clerk of the City of Cudahy, hereby certify that the foregoing Ordinance No. 759 was introduced for a first reading on the 18th day of March 2025 and approved for a second reading and adopted by said Council at its regular meeting held on the 18th day of March 2025 by the following vote, to-wit:

AYES:

NOES:

ABSENT:

ABSTAIN:

Richard Iglesias
City Clerk

Ordinance No. 759

EXHIBIT “A”
EVIDENCE SUBMITTED BY THE CITY (“ADMINISTRATIVE RECORD”)

ADMINISTRATIVE RECORD FOR

REVIEW HEARING
Aqua Tergere , LLC
August 27, 2024

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

REVIEW HEARING STAFF REPORT
Date: August 27, 2024
1 To: Hearing Officer, Steve Napolitano
From: Juan Arauz, AICP, Community Development Director
Prepared By: Cecilia Madrigal-Gonzalez, Senior Planner
Concurrence: Joshua Calhoun, Finance Director, Raul Diaz, Building Official and Paloma McEvoy, Assistant City Attorney.

Subject: Compliance Review Hearing relating to Commercial Cannabis Permit (“CCP”) No. 18-0011 and Development Agreement (“DA”) No. 18-011C between Aqua Tergere, LLC (“Operator”) and the City of Cudahy (“City”).

RECOMMENDATION
City staff recommends that the Hearing Officer take the following action(s):

1. Hear the evidence presented by the City and the Operator; and

2. Make a determination that the Operator is not in compliance with the terms and conditions of DA No. 18-011C with the City and find that the Operator is in default of contractual obligations set forth in the DA; and

3. Make a determination that the Operator is not in compliance with the conditions of approval of CCP No. 18-0011; and

4. Make a recommendation to the Planning Commission and City Council to adopt an ordinance repealing Ordinance No. 697 to terminate DA No. 18-011C and to the City Manager to revoke the Operator’s interest under CCP No. 18-0011.

BACKGROUND/TIMELINE
On September 11, 2017, the City adopted Ordinance No. 673 (Attachment A) establishing the City’s commercial cannabis production activity regulations codified in Chapter 5.20 of the Cudahy Municipal Code (“CMC”). CMC Section 5.20.040 authorizes medicinal 1 On August 15, 2024, the City finalized the Administrative Record including attachments A through SS. On August 27, 2024, the City amended pg. 8 of the Review Hearing Staff Report and added Attachment TT.

The amendments in the report are shown underlined and italicized.

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

commercial cannabis activities within a designated overlay zone, pursuant to a development agreement adopted in accordance with the Development Agreement Law (Gov. Code § 65864 et seq.) and Chapter 20.28 of the CMC.

On September 17, 2018, after conducting a duly noticed hearing, in conjunction with CMC Section 20.28.030, the Planning Commission reviewed, considered, and recommended disapproval of an ordinance to enter into and approve a Development Agreement (“DA”) and denial of a CCP No. 18-0011 to permit cannabis manufacturing activities with accessory general business offices at 8210 Atlantic Avenue, Cudahy, CA (“Site”). The Agenda, Staff Report, and Draft Minutes are provided in Attachments B, C, and D.

On or around August 14, 2018, Operator submitted a tenant improvement (“TI”) plan check application for cannabis activities at the Site to the City’s third-party plan checker (Plan Check #PC18-0011) (Attachment EE). Plan Check #PC18-0011 was disapproved and waiting for Operator to resubmit as of September 4, 2019 (Attachment FF). Due to inactivity, Plan Check # PC 18-0011 automatically expired 180-days afterwards, on March 2, 2020. The City has no record of a request for a time extension on the plan check application from the Operator.

On October 1, 2018, the City Clerk’s Office received the Operator’s appeal of the Planning Commission’s disapproval of the CCP and recommendation not to approve a development agreement between the City and the Operator (Attachment E), pursuant to CMC Section 20.84.160 (Appeals). Operator claimed the Planning Commission “failed to articulate findings and provide supporting evidence identifying specific in the record that are reasons for the denial.”
On November 6, 2018, the City Council, after conducting a duly noticed hearing, in conjunction with CMC Section 20.28.060, and after independent consideration and de novo review on appeal, the City Council approved the execution of DA No. 18-0011C (Attachment F) by first reading of Ordinance No. 697 and issuance of CCP No. 18-0011 through the approval of City Council Resolution No. 18-49 (Attachment X). The Agenda, Minutes, and Staff Report are provided in Attachments G, H, and I respectively.

On November 20, 2018, the City Council conducted a second reading and adopted Ordinance No. 697 (Attachment J), authorizing the execution of DA No. 18-011C (Attachment K) inclusive of Exhibits A-F (Attachment L) between Operator and the City authorizing commercial cannabis manufacturing activities and office at the Site as illustrated in Figures 1 and 2 below. The Site Plan and Floor Plan are incorporated by reference in Article 3(a) of DA No. 18-011C. Recital I of DA No. 18-011C permits the Operator to operate in an approximately 2,665 square foot(“sf”) building, inclusive of 1,084 sf of cannabis manufacturing space (Attachment K). The Agenda, Minutes, and Staff Report for the November 20, 2018 City Council Meeting are provided in Attachments M, N, O, respectively.

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

FIGURE 1 – AERIAL OF SITE
FIGURE 2 – FLOOR PLAN
On March 18, 2019, the City received a plan check application (Plan Check #440) submittal for interior tenant improvements (“TI”) for a cannabis facility at the Site (Attachment R).

Site
8210 Atlantic Ave.

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

On October 2, 2019, the City provided Operator with a Notice of Delinquency (Attachment P) prior to placing the Operator in default status due to payment non-compliance with the Development Agreement and Commercial Cannabis Permit, inclusive of the non-payment of Community Benefit Fees, Cost Recovery Fees, and Non-Operating Fees2in the amount of sixty-four thousand two hundred sixty-seven dollars and ninety-three cents ($64,267.93). The Operator was given no later than October 17, 2019, to pay the past due amounts, however, the default was not timely cured.

On December 12, 2019, the City’s third-party plan checker approved Plan Check #440 for interior tenant improvements as noted in the record log (Attachment DD). No building permit was issued pursuant to Plan Check #440, therefore the plan check approval expired one-hundred and eighty (180) days after the approval date on June 12, 2020. The City has no record of a time extension request by the Operator.

On May 4, 2021, the City provided Operator with a Notice of Default (Attachment Q) due to the Operator’s non-compliance with payment of fees and associated penalties in the amount of two hundred eight thousand three hundred nine dollars and nine cents ($208,309.09). The Operator was given no later than thirty (30) days to cure the default, however, the default was not timely cured.

On August 17, 2022, City staff and the Los Angeles County Sheriff’s Department conducted an inspection of the Site and observed multiple Building, Mechanical, Electrical, and Plumbing Code violations. As such, the City issued a stop work notice due to unpermitted construction (Attachment S). During the inspection, the following building, mechanical, fire, electrical, and plumbing code violations were observed:
1) installation of insulated panel walls;
2) installation of cannabis extraction room;
3) installation of fire suppression system;
4) installation of HVAC ducts;
5) installation of an upgraded electrical panel; and
6) installation of plumbing throughout the facility.

All violations observed were constructed without obtaining proper Zoning Clearance, engineered drawings, plan check approval, building permit issuance, and inspections.

The Operator failed to take necessary actions to correct the stop work notice. To correct the actions, the Operator was required to obtain requisite approvals and permits from the City Planning Division and Building & Safety Division. As of the writing of this report, the Operator has not obtained requisite approvals and permits from the City Planning Division, Building & Safety Division.

On September 13, 2022, the City proceeded to declare the structure unsafe and dangerous for occupancy, commonly referred to as “red-tag” and issued a letter (Attachment T) to Operator to clear all violations within 10 days. The notice was also placed at the Site as shown in Attachment T. However, as detailed below, Vladimir 2 As used herein, the terms Operating Fees and Non-Operating Fees are used interchangeably.

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

Calderon (“Property Owner”) pulled a demolition permit to remove the unpermitted improvements and the Site’s red-tag status was removed on May 9, 2023.

On September 20, 2022, Operator appeared at City Hall to discuss the Site’s red-tag status. City staff spoke with Operator and answered questions on the unpermitted improvements and financial obligations. Operator also verbally requested a time extension, City staff advised Operator to submit formal extension in writing. No such written request was ever received.

On September 21, 2022, the City received an email (Attachment U) from Vince Sanchez memorializing the conversation with City staff on September 20, 2022, and acknowledging the red tag status, and informing the City of hardships with their previous contractors, requesting to amend the DA to allow a different license type and requesting an extension to complete the list of corrections detailed in Attachment T.

On September 22, 2022, the City received an email from Cheryl Montanez (Attachment GG) from MO+RE Design Solutions in which Ms. Montanez stated that the unpermitted improvements did not match the plans she had reviewed and requested additional information and guidance to understand the City’s building permit process. City staff advised Ms. Montenez regarding the City’s records and building permit process. No further correspondence or inquiries were received from Ms. Montanez.

On December 6, 2022, the City Manager presented the City Council with a proposed Cannabis Deferment and Payment Program to assist cannabis operators with the accumulated Community Benefits, Cost Recovery and Non-Operating Fees by deferring and providing additional time for payment without penalty. The City Council directed the City Manager to offer the Payment Agreement to Operators who have defaulted on their payment obligations, which was approved by the City Council. Under the program:
(a) Unpaid Non-Operating Fees would be deferred (without penalty) until six (6) months after the Operator was issued a Certificate of Occupancy; and then repay accumulated Non-Operating Fees within twelve (12) months; and (b) Operators would continue to be responsible for the timely payment of Community Benefit Fees and Cost Recovery Fees as they accumulated; and (c) Previously incurred Community Benefit Fees and Cost Recovery Fees would be subject to a payment plan and require timely payments.

On December 7, 2022, the City presented the terms of the Cannabis Deferment and Payment Program to the Operator (Attachment V). All cannabis operators interested in participating in this program were given no later than January 31, 2023, to execute a payment agreement with the City. The City Manager did not receive a request from the Operator to participate in the Cannabis Deferment and Payment Plan.

On March 20, 2023, the City sent a Final Demand Letter (Attachment W) demanding Operator to respond to the following demands: 1) An updated project description; 2)

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

Approvable plans for the Operator’s cannabis operation; and 3) Forwarding payment for the total past due amounts. The Operator did not respond in a timely manner and failed to make any attempt to cure the defaults within the thirty (30) day period.

On April 24, 2023, the City received an unsolicited email from "[email protected]," claiming to provide notice of Aqua Tergere, LLC's informing the City that it had (1) “officially shut down;” (2) the company had gone bankrupt; and (3) the company was no longer able to continue operations (Attachment Y). The email also informed the City that the building lease had expired and the Operator returned the keys to the landlord. Lastly, the email informed the City that the Operator was withdrawing its “submission application” (Attachment Y).

On May 2, 2023, the City responded to the Operator's email communication, which informed the Owner that the notice was insufficient to terminate the DA and provided the correct process in order to terminate the DA which requires the written notice to “be signed, by an authorized party, and given personally or by registered or certified mail (return receipt requested), or by Federal Express, UPS or similar couriers” (Attachment Y). The Operator was given no later than (10) days from the date of the letter to submit the requisite documentation (Attachment Y).

On May 9, 2023, the City issued the Property Owner a demolition permit (Permit #820) to demolish all unpermitted work (Attachment CC). The Site’s red tag-status was subsequently removed.

On May 18, 2023, the City received formal written notification dated May 8, 2023, from Mr. Charles Arden, representing the Operator, informing the City of their decision to terminate the lease agreement for the Site and requesting that the letter serve as official confirmation of the voluntary termination of their cannabis operation in the City (Attachment Z).

According to the lease terms, the Operator’s leasehold interest in the Site expired on May 31, 2023 (Attachment L). The lease did not provide any options to extend the lease term.

On August 22, 2023, the City provided Operator a letter (Attachment HH) acknowledging the May 8, 2023, Notice of Termination was received by the City pursuant to DA Article 14(d) and effective upon the date of the written notice. The letter confirmed that the Operator had “ceased all cannabis operations within the City. Proper notice of termination of the Development Agreement has been given by Aqua Tergere, LLC and such termination is effective upon the date written notice was given to the City. Therefore, the City is prepared to process documents terminating Development Agreement No. DA18- 0011 [as] of May 18, 2023, except as set forth in the Agreement” (Attachment HH, emphasis original). The City advised that it had prepared documents to formally terminate the DA pursuant to Article 11(c), which states “Termination of this Agreement shall not, however, eliminate the rights of the City to seek any applicable and available remedies or damages based upon acts or omissions occurring before termination.” As of May 18,

Administrative Review Record - Aqua Tergere, LLC

“Serving The People” "Sirviendo A La Comunidad"

2023, the outstanding fees due to the City, inclusive of Operating Fees, Community Benefit Fees, and Cost Recovery Fees, is $334,921.56. The City prepared an “Agreement Re: Aqua Tergere, LLC’s Notice of Termination of Development Agreement No. DA18- 011C and Voluntary Surrender of Commercial Cannabis Permit No. 18-0011” (Attachment HH – pp. 3-6) and a “Memorandum of Termination” (Attachment HH – pp. 7- 8) for Operator’s review and signature. The Operator responded to the City by asking for an extension of time, until September 15, 2023, to respond to the City’s Notice of Termination (Attachment LL).

On October 26, 2023, more than a month after the Operator’s requested extension (Attachment O) to respond, an attorney for the Operator contacted the City with an offer to settle the outstanding amount owed to the City, under the following terms:
(1) termination of DA No. 18-011C;
(2) waiver of all fees, penalties, and/or other sums, including but not limited to any and all guarantees by the Company and/or individual members, allegedly owned by the Operator and/or its members;
(3) waiver of all fees, penalties, sums, and/or claims, including but not limited to, any personal guarantees, allegedly due and/or owed by the Operator and/or individual member(s); and
(4) mutual waiver of all fees, penalties, sums, and/or claims arising out of or from under DA No. 18-011C.

The Operator’s legal counsel did not dispute the amount of the fees accumulated or the fact that fees were due, but objected to payment on the basis that the Operator was “unable to secure timely reviews and/or approval of plans or specifications” during “most of 2020 and 2021” (Attachment OO). Operator’s counsel further argued that the “City is precluded from collecting any fees or penalties due to State and Federal emergency orders in place preventing or precluding timely construction and/or development, that the City’s failure to treat all applicants/licensees equitably during this time of extreme emergency was a denial of due process, and the alleged Community Benefit Payments (CBD) presuppose a ‘going concern’ – a fully operational business” (Attachment OO).

Operator’s legal counsel did not offer any explanation as to the Operator’s noncompliance in 2019, 2022, and 2023. Nor did Operator’s counsel demonstrate how the Operator had been treated inequitably by the City or how the Operator had been denied due process.

Due to the characterization of the statements made by Operator’s counsel and an offer to “settle claims” the City Council conferred regarding the foregoing settlement terms in a Closed Session hearing pursuant to Government Code Section 54956.6(d)(2), which permits a closed session discussion due to anticipated litigation. The City Council did not accept the Operator’s proposed settlement terms and directed the City Attorney’s Office