El Centro City Council
February 1, 2022

AGENDA

CITY OF EL CENTRO

CITY COUNCIL
TUESDAY, FEBRUARY 1, 2022
City Hall Regular Meeting 11:30 AM

CITY HALL

COUNCIL CHAMBERS
1275 MAIN STREET
EL CENTRO, CA 92243
City of El Centro Page 1

THIS MEETING WILL BE CONDUCTED VIRTUALLY ONLY PURSUANT TO THE PROVISIONS OF THE BROWN ACT (Govt. Code Section 54953(e)).

COUNCIL MEMBERS, STAFF AND THE PUBLIC WILL ATTEND BY TELECONFERENCE.

Any member of the public is invited to submit public comments AND may, but is not required, to do so in advance of the meeting to be answered at the meeting. Please email your questions to [email protected] or call 760-337-4515 by February 1, 2022.

Any member of the public wishing to address the City Council during the meeting may do so by using the conference number provided on the agenda. At the time the Mayor asks for comments, please raise your hand and your name will be called.

To participate and make a public comment:

Join Zoom Meeting:
https://us02web.zoom.us/j/86577556186?pwd=TFhyay9DTVhmOHRNWWhUMGx0OS9lQT09 Optional dial-in number: 1 (669) 900-6833
Meeting ID: 865 7755 6186 Passcode: 313747

PUBLIC COMMENTS AT THIS VIRTUAL MEETING ARE SUBJECT TO THE SAME TIME LIMITS ONCE THE PERSON COMMENTING BEGINS TO SPEAK.

Mayor & Council Members may be reached at (760) 336-8989 Mayor: Tomás Oliva City Manager: Marcela Piedra
Mayor Pro-Tem: Martha Cardenas-Singh City Attorney: Elizabeth Martyn Evans Council Members: Edgard Garcia City Clerk: Norma Wyles
Sylvia Marroquin
Cheryl Viegas-Walker
11:30 A.M CLOSED SESSION - CONFERENCE ROOM "A"
ROLL CALL (Open Session)
Agenda City Council of the City of El Centro February 1, 2022 City of El Centro Page 2
CLOSED SESSION PUBLIC COMMENT:

Any member of the public wishing to address the City Council on any matter appearing on the closed session may do so at this time. Unless the Mayor extends the time limit, remarks shall be limited to three (3) minutes. Additional opportunities for Public Comments will be given during and at the end of the meeting.

CITY COUNCIL ADJOURNS INTO CLOSED SESSION

CITY COUNCIL CLOSED SESSION

LABOR NEGOTIATIONS
The City Council will recess to closed session pursuant to Government Code 54957.6 to meet with Agency Representatives Marcela Piedra, City Manager, Dulce Bedolla, Human Resources Director and Patrick Clark, consulting negotiator, for the purpose of considering employee compensation in the form of fringe benefits, or, as applicable, other matters dealing with mandatory subjects within the scope of representation pursuant to Government Code 3504; negotiating with all bargaining units within the City.

POSSIBLE LITIGATION INITIATED BY THE CITY
A point has been reached where, in the opinion of the City Council upon the advice of its legal counsel, based upon existing facts and circumstances, there is a significant possibility of litigation initiated by the City regarding 1) unpaid sewer connection capacity charges; 2) uncollected water meter charges; and 2) a public agency's failure to obtain City grading approval.

PUBLIC SAFETY
Upon the advice of legal counsel, the City Council will recess to closed session pursuant to Govt. Code Section 54957(a) regarding matters that pose a threat to essential public services and the public's right of access to such services.

NOTICE TO THE PUBLIC
This is a public meeting. If there is an item on the agenda on which you wish to be heard, you are asked to complete a blue speaker slip and submit it to the City Clerk prior to the start of the meeting. Persons wishing to address the Council are not required to identify themselves (Gov’t Code § 54953.3); however, this information assists the Mayor by ensuring that all persons wishing to address the Council are recognized and also assists the City Clerk in preparing the City Council meeting minutes. When the item is announced and your name is called by the Mayor, please step to the podium and state your name for the record. Unless the Mayor extends the time, there is a three (3) minute time limit for each public presentation. If you wish to address the Council concerning any other matter not appearing on the agenda, you may do so during the public comment portion of the agenda.
* Any information provided on the “Speaker Slip” is voluntary and will be public record.

Agenda City Council of the City of El Centro February 1, 2022 City of El Centro Page 3
RECONVENE FOR OPEN SESSION 6:00 P.M.
6:00 P.M. OPEN SESSION

ALL TIMES ARE APPROXIMATE AND MAY VARY
CALL TO ORDER:

ROLL CALL BY CITY CLERK

PLEDGE OF ALLEGIANCE

INVOCATION
6:05-6:10 CITY ATTORNEY REPORT ON CLOSED SESSION
6:10-6:15 PRESENTATIONS AND ANNOUNCEMENTS BY MAYOR

1. 70th Anniversary Celebration - Central Baptist Church February 12, 2022 6:15-6:20 PUBLIC COMMENTS
6:20-6:25 CONSENT AGENDA
Consent agenda items are approved by one motion. Council members or members of the public may pull consent items to be considered separately at a time determined by the Mayor.

2. Approve City Council Minutes of December 21, 2021, January 4, 2022 and January 10, 2022.

3. Adopt Resolution No. 22- , RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF EL CENTRO CONFIRMING THE CONTINUATION OF THE

LOCAL STATE OF EMERGENCY AND THE STATE OF EMERGENCY
PROCLAIMED BY GOVERNOR NEWSOM ON MARCH 4, 2020 AND

AUTHORIZING REMOTE TELECONFERENCE MEETINGS OF THE CITY
COUNCIL FOR THE PERIOD FEBRUARY 3 THROUGH MARCH 4

PURSUANT TO NEWLY ENACTED BROWN ACT PROVISIONS

4. Adopt Resolution No. 22- , RESOLUTION OF THE CITY COUNCIL OF

THE CITY OF EL CENTRO, CALIFORNIA, APPROVING THE

DESTRUCTION OF EL CENTRO POLICE DEPARTMENT RECORDS FROM 2015-2019
Agenda City Council of the City of El Centro February 1, 2022 City of El Centro Page 4
6:25-6:45 PUBLIC HEARINGS

5. Public hearing to consider the recommendation of the Planning Commission to adopt an Addendum to the El Centro General Plan Final EIR (SCH #2020070349) for the 2021-2029 Housing Element Update
PRESENTATION: Angel Hernandez, Interim Community Development Director RECOMMENDATION:

Adopt Resolution No. 22 - , A RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF EL CENTRO, CALIFORNIA, APPROVING AN ADDENDUM TO THE EL

CENTRO GENERAL PLAN UPDATE FINAL ENVIRONMENTAL IMPACT
REPORT (SCH # 2020070349) FOR THE 2021-2029 HOUSING ELEMENT UPDATE

6. Public hearing to consider the recommendation of the Planning Commission to adopt the 2021-2029 Housing Element Update
PRESENTATION: Angel Hernandez, Interim Community Development Director RECOMMENDATION:

Adopt Resolution No. 22 - , RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF EL CENTRO, CALIFORNIA, APPROVING A GENERAL PLAN

AMENDMENT UPDATING THE CITY OF EL CENTRO HOUSING ELEMENT OF

THE GENERAL PLAN AND DECLARING THIS AMENDMENT TO BE THE FIRST GENERAL PLAN AMENDMENT FOR CALENDAR YEAR 2022
6:45-7:15 NEW BUSINESS

7. Discussion and necessary action related to proposals received for Community Development Block Grant (CDBG) Program year 2022-2023
PRESENTATION: Adriana Nava, Community Services Director RECOMMENDATION:

Discussion and necessary action related to proposals received for CDBG Program year 2022-2023.

LEGISLATIVE ACTION
Agenda City Council of the City of El Centro February 1, 2022 City of El Centro Page 5

INFORMATIONAL ITEMS

8. Received and referred to Community Development Department, Application for Alcoholic Beverage License - DPoly Taco Grill & Beer, 1573 W Main St, El Centro, CA 92243
7:15-7:25 TASK FORCE REPORTS AND MAYOR - COUNCIL MEMBER

REPORTS
7:25-7:35 CITY MANAGER REPORT

ADJOURNMENT
Materials related to an item on this Agenda submitted to the City Council after distribution of the agenda packet will be available for public inspection at the Office of the City Clerk, 1275 Main Street, El Centro, California 92243, Monday-Friday during normal business hours.

In compliance with the Americans with Disabilities Act, if you need special assistance to participate in this meeting, you should contact the office of the City Clerk at (760)337-4515. Notification at least 48 hours prior to the meeting will enable the City to make reasonable arrangement to assure accessibility to this meeting.

City Council of the City of El Centro Meeting: 02/01/22 11:30 AM 1275 Main Street Department: City Council
El Centro, CA 92243 Category: Proclamation
Prepared By: Cynthia De Zilwa
SCHEDULED Department Head: Tomás Oliva
PRESENTATION (ID # 5416) DOC ID: 5416
70th Anniversary Celebration - Central Baptist Church
February 12, 2022
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City Council of the City of El Centro Meeting: 02/01/22 11:30 AM 1275 Main Street Department: City Clerk's Office
El Centro, CA 92243 Category: Minutes
Prepared By: Norma Wyles
SCHEDULED Department Head: Norma Wyles
ACTION ITEM (ID # 5417) DOC ID: 5417
Approval of City Council Minutes of December 21, 2021,
January 4, 2022 and January 10, 2022.

CITY MANAGER’S RECOMMENDATION:

Approve City Council Minutes of December 21, 2021, January 4, 2022 and January 10, 2022.

ATTACHMENTS:
• 12-21-2021 Regular CC Minutes (PDF)
• 1-04-2022 Regular CC Minutes (PDF)
• 1-10-2022 Special CC Minutes (PDF)
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Book 36

REGULAR MEETING

EL CENTRO CITY COUNCIL

CITY HALL, COUNCIL CHAMBERS
1275 MAIN STREET, EL CENTRO, CA
TUESDAY, DECEMBER 21, 2021 11:30 A.M.

The El Centro City Council met in regular session on Tuesday, December 21, 2021 at 11:32 a.m. in RDA Conference Room, 1249 Main Street, El Centro, California for the purpose of closed session.

PRESENT: Council: Viegas-Walker, Oliva, Cardenas-Singh, Marroquin City Clerk Wyles, City Manager Piedra, City Attorney Martyn Evans ABSENT: Garcia
Closed Session Public Comment
None

CITY COUNCIL CLOSED SESSION
Moved by Marroquin, second by Cardenas-Singh, to adjourn into closed session for:

LABOR NEGOTIATIONS
The City Council will recess to closed session pursuant to Government Code §54957.6 to meet with Agency Representatives Marcela Piedra, City Manager, Dulce Bedolla, Human Resources Director and Patrick Clark, consulting negotiator, for the purpose of considering employee compensation in the form of fringe benefits, or, as applicable, other matters dealing with mandatory subjects within the scope of representation pursuant to Government Code §3504; negotiating with all bargaining units within the City.

POSSIBLE LITIGATION AGAINST THE CITY
A point has been reached where, in the opinion of the City Council upon the advice of its legal counsel, and based upon existing facts and circumstances, there is a significant possibility of initiation of litigation against the City under Govt. Code Section 54956.9(d)(2) based upon the following claims: (i) Guzman - damages sewer pipe; (ii) Robert Vera - pothole; (iii) Gregory Gelman - pothole; (iv) Juan Carlos Flores - pothole; (v) Lorena Soto - pothole; (vi) Claim of Kaleb Castillo (minor injured on his bike).

POSSIBLE LITIGATION INITIATED BY THE CITY
A point has been reached where, in the opinion of the City Council on the advice of its legal counsel, and based upon existing facts and circumstances, there is a significant possibility of initiation of litigation against the City under Govt. Code Section 54956.9(d)(4) based upon the following: (i) damage to the Aquatic Center.

EXISTING LITIGATION
Upon advice of its legal counsel, the City Council will recess to closed session pursuant to Government Code §54956.9(d)(1) regarding the following cases: (I) Kaleb Castillo v. City of El Centro.

Motion unanimously carried. Council Member Garcia absent.

Closed Session concluded at 1:50 p.m.

City Council recessed to 6:00 p.m.

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

OPEN SESSION
The El Centro City Council met in regular session on Tuesday, December 21, 2021 at 6:00 p.m. in Council Chambers, El Centro City Hall, 1275 Main Street, El Centro, California.

PRESENT: Council: Cardenas-Singh, Oliva, Viegas-Walker, Marroquin, Garcia City Clerk Wyles, City Manager Piedra, City Attorney Martyn Evans ABSENT: None
Pledge of Allegiance to the flag of the United States of America was led by Mayor Pro-Tem Cardenas-Singh, and Invocation was given by Mayor Oliva.

CITY ATTORNEY REPORT ON CLOSED SESSION
City Attorney Martyn reported that in closed session City Council discussed lengthy bargaining issues and litigation issues.

SCHEDULED PRESENTATIONS

1. Retirement Recognition for Norma Villicana, Community Development Director.

2. Retirement Recognition for Officer Mike Boston.

3. Retirement Recognition for Sergeant Victor Nunez.

PUBLIC COMMENTS
None

CONSENT AGENDA
Moved by Marroquin, second by Garcia, approving consent agenda items #4 – #11.

4. Approval of Warrant Registers for the Mont of November 2021.

5. Approval of Payroll Registers for the Month of November 2021.

6. Approval of Treasurer’s Report for the Month of November 2021.

7. Approval of City Council minutes of November 16, 2021 and November 19, 2021.

8. Acceptance of the annual Development Impact Fees and Water/Wastewater Capacity Fee information report for fiscal year June 30, 2021.

9. Adoption of Resolution No. 21-98, RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

EL CENTRO CONFIRMING THE CONTINUATION OF THE LOCAL STATE OF EMERGENCY AND STATE OF EMERGENCY PROCLAIMED BY GOVERNOR NEWSOM ON MARCH 4, 2020 AND AUTHORIZING REMOTE TELECONFERENCE MEETINGS OF THE CITY COUNCIL FOR THE PERIOD JANUARY 4 THROUGH FEBRUARY 2 PURSUANT TO NEWLY ENACTED BROWN ACT PROVISIONS.

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

10. Authorized the execution of the Utility Agreement between IID and the City of El Centro for the relocation of power poles between Danenberg Avenue and Manuel Ortiz Drive related to the Imperial Avenue Extension Project.

11. Adoption of Resolution No. 21-99, RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

EL CENTRO AWARDING THE BID AND AUTHORIZING THE EXECUTION OF A CONTRACT FOR THE 8TH STREET AND PLAZA DRIVE TRAFFIC SIGNAL SYNCHRONIZATION PROJECT FEDERAL PROJECT NO. CML-5169 (051).

AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ASTAINED: None

PUBLIC HEARINGS

12. This was the date and time set for a public hearing for the purpose of considering the recommendation of the Planning Commission regarding the Town Center Phase IV Mitigated Negative Declaration.

Presentation by Angel Hernandez, Associate Planner. Mayor Oliva declared the public hearing opened and asked if anyone wish to speak in favor or opposition to come forward. Seeing no one wishing to speak, the public hearing was closed.

Moved by Viegas-Walker, second by Cardenas-Singh, adopting Resolution No. 21-100,

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EL CENTRO ADOPTING MITIGATED NEGATIVE DECLARATION (SCH# 2021040547) WITH MITIGATION MONITORING & REPORTING PROGRAM FOR: PROJECT: Change of Zone 19-02, General Plan Amendment 19-02, and Tentative Subdivision Map 21-01, a proposed zone change from CG (General Commercial) to R3 (Multiple Family Residential), General Plan Amendment for consistency with the Zoning Map, and Tentative Subdivision Map consisting of approximately 19.33 acres of land, located at the northwest corner of North 8th Street and Bradshaw Drive, further identified by APN 044-620- 056 and APN 044-620-057
AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED: None

13. This was the date and time set for a public hearing for the purpose of considering issuing findings to overrule the Imperial County Airport Land Use Commission regarding the Town Center Phase IV Development Project (COZ 19-02, GPA 19-02). Presentation by Angel Hernandez, Associate Planner. Mayor Oliva declared the public hearing opened and asked if anyone wish to speak in favor or opposition to come forward. Seeing no one wishing to speak, the public hearing was closed.

Council member Viegas-Walker stated that the land use plan for the airport is outdated and needs to be updated. She has never received a noise complaint regarding that area. She also raised an issue with Imperial County Transportation Commission meeting, she raised an issue of updating the 1996 plan and other agencies were very supportive of the update of the land use plan. Mayor Pro-Tem Cardenas-Singh stated that the City of El Centro has done its due diligence in making sure we looked with outside entities to share with us the timelines and the discussions in regards to of the overruling of this outdated plan. She feels confident that City staff has diligent and done its due diligence to make sure we have no liability in this issue. Council member Marroquin stated the right thing to do was to move forward.

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

Moved by Garcia, second by Viegas-Walker, adoption of Resolution No. 21-101, RESOLUTION OF

THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA, ISSUING FINDINGS TO

OVERRULE THE IMPERIAL COUNTY AIRPORT LAND USE COMMISSION DECISION

ASSOCIATED WITH THE TOWN CENTER PHASE IV DEVELOPMENT PROJECT PROPOSED TO BE LOCATED AT THE NORTHWEST CORNER OF NORTH 8TH STREET AND BARDSHAW DRIVE.

AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED: None

14. This was the date and time set for a public hearing for the purpose of considering the recommendation of the Planning Commission regarding the Town Center Phase IV General Plan Amendment No. 19-

02. Presentation by Angel Hernandez, Associate Planner. Mayor Oliva declared the public hearing opened and asked if anyone wish to speak in favor or opposition to come forward. Seeing no one wishing to speak, the public hearing was closed.

Moved by Viegas-Walker, second by Garcia, adopting Resolution No. 21-102, A RESOLUTION OF

THE CITY COUNCIL OF THE CITY OF EL CENTRO APPROVING GENERAL PLAN AMENDMENT 19-02 CHANGING THE LAND USE DESIGNATION FROM GENERAL

COMMERCIAL TO HIGH-MEDIUM DENSITY RESIDENTIAL FOR PROPERTY WITH APN 044-620-056 AND LOCATED AT THE NORTHWEST CORNER OF NORTH 8TH STREET AND

BRADSHAW DRIVE, AND DECLARING SAME TO BE THE SECOND GENERAL PLAN AMENDMENT FOR CALENDAR YEAR 2021
AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED: None

15. This was the date and time set for a public hearing for the purpose of considering the recommendation of the Planning Commission regarding the Town Center Phase IV Change of Zone No. 19-02.

Presentation by Angel Hernandez, Associate Planner. Mayor Oliva declared the public hearing opened and asked if anyone wish to speak in favor or opposition to come forward. Seeing no one wishing to speak, the public hearing was closed.

Moved by Viegas-Walker, second by Marroquin, approve Ordinance No. 21-06, ORDINANCE OF

THE CITY COUNCIL OF THE CITY OF EL CENTRO AMENDING THE ZONING MAP OF THE CITY OF EL CENTRO PERTAINING TO CHANGE OF ZONE 19-02, waive reading and approve as a first reading and authority City Clerk to place on the agenda for second reading and adoption.

AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED: None

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

16. This was the date and time set for a public hearing for the purpose of considering the recommendation of the Planning Commission regarding the Town Center Phase IV Tentative Subdivision Map No. 21-

01. Presentation by Angel Hernandez, Associate Planner. Mayor Oliva declared the public hearing opened and asked if anyone wish to speak in favor or opposition to come forward. Seeing no one wishing to speak, the public hearing was closed.

Moved by Marroquin, second by Viegas-Walker, adopting Resolution No. 21-103, RESOLUTION

OF THE CITY COUNCIL OF THE CITY OF EL CENTRO APPROVING THE TOWN CENTER PHASE IV TENTATIVE SUBDIVISION MAP 21-01.

AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED: None

NEW BUSINESS

17. Presentation by Marcela Piedra, City Manager, reallocation of ARPA revenue loss expenses to Measure P funds.

ADA City Hall improvements $ 1,380,000
ADA Community Center Doors $ 12,864
ADA required signage $ 67,070
73 HP New Holland Tractor Loader $ 110,300
Automated License Plate Recognition cameras $ 615,000
New Type I Fire Pumper $ 750,000
New Type III/Fire Engine $ 650,000
Peterbilt 2 Axle 26,000 CVW Vehicle $ 140,000
Total amount to be reallocated to Measure P Funds $ 3,725,234 Moved by Garcia, second by Marroquin, approval of reallocation of $3,725,234 in ARPA funds to Measure P funds.

AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED:None

18. Presentation by Adriana Nava, Community Services Director, purchase of 2020 Freightliner 5-yard Load King Dump Truck.

Moved by Viegas-Walker, second by Garcia, adoption of Resolution No. 21-104, RESOLUTION OF

THE CITY COUNCIL OF THE CITY OF EL CENTRO COMMUNITY SERVICES DEPARTMENT TO PURCHASE ONE NEW 2020 FREIGHTLINER M2 W 5 YD LOAD KING DUMP TRUCK AYES: Cardenas-Singh, Oliva, Viegas-Walker, Marroquin, Garcia NOES: None
ABSENT: None
ABSTAIN: None

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

19. Moved by Cardenas-Singh, second by Marroquin, approval of the appointment by Mayor Tomás Oliva to the various City Council Committees:

SCAG (League Appointment): Walker
LAFCO (League Appointment 4-year term):City of Calexico AAA (Area Agency on Aging (League Appointment 2 year term): N/A ICTC: Representative: Viegas-Walker Alternate: Oliva
LTA Representative: Viegas-Walker Alternate: Oliva
SAFE Representative: Viegas-Walker Alternate: Oliva
IVRMA Representative: Viegas-Walker Alternate: Oliva
CJPIA Representative: Garcia Alternate: Marroquin
ECRMC Representatives: Oliva & Marroquin
Air Pollution Control: Representative: Marroquin Alternate: Cardenas-Singh Airport Advisory Committee: Representative: Viegas-Walker Alternate: Marroquin Imperial County Film Commission: Representative: Cardenas-Singh Alternate: Garcia Chamber of Commerce: Representative (Mayor Pro-Tem): Cardenas-Singh Alternate (Mayor): Oliva United Way–Emergency Food & Shelter Program: Representative: Marroquin Alternate: Cardenas-Singh
Mexicali Liaison Representatives: Oliva and Cardenas-Singh Citizen Advisory Committee (Centinela State Prison) (2-yr term): Representative: Viegas-Walker Alternate: Cardenas-Singh

AD HOC, COMMITEES AND TASK FORCES
Community Enhancement Task Force (CETF): Oliva/Viegas-Walker Friends of Community Service Foundation Board: Cardenas-Singh/ Alternate Garcia Taskforce to End Homelessness Marroquin/Viegas-Walker
COVID-19 Pandemic Response & Economic Recovery Force Oliva/Garcia Cannabis Task Force: Oliva/Garcia
Federal & State Funding Opportunities Task Force: Oliva/Viegas-Walker Public Safety Task Force: Oliva/Garcia
Measure P Working Groups:

IT & ADA Related Projects: Viegas-Walker/Garcia
Parks & Recreation Projects: Cardenas-Singh/Oliva
Operational Projects: Marroquin/Garcia
Strategic Planning Task Force 2020: Oliva/Viegas-Walker Downtown Ad Hoc Committee: Cardenas-Singh/Marroquin
Review Council Compensation 2021: Marroquin/Cardenas-Singh Evaluation Panels:

City Manager: Cardenas-Singh/Garcia
City Clerk: Oliva/Viegas-Walker
City Manager: Cardenas-Singh/Marroquin
AYES: Garcia, Viegas-Walker, Oliva, Cardenas-Singh, Marroquin NOES: None
ABSENT: None
ABSTAINED: None

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

20. Presentation by Mayor Tomás Oliva, discussion and any necessary action regarding the cancellation of the January 4, 2022 City Council meeting.

Moved by Garcia, second by Marroquin, to cancel the meeting of January 4, 2022.

AYES: Cardenas-Singh, Oliva, Viegas-Walker, Marroquin, Garcia NOES: None
ABSENT: None
ABSTAINED: None

DEPARTMENT REPORT

21. Update on Mandatory Commercial Organics Recycling Program (AB1826) by Abraham Campos, Director of Public Works/City Engineer.

LEGISLATIVE ACTION
None

INFORMATIONAL ITEMS

22. Water Treatment Plant Emergency Repairs Update.

23. Notification of Rejection of Claim for Juan Carlos Flores.

24. Claim filed with the City of El Centro by Lorena Soto on December 6, 2021.

25. Claim files with the City of El Centro by Gregory Gelman on November 30, 2021.

26. Received and referred to Community Development Department, Application for Alcoholic Beverage License – Fujisan Sushi, 1560 Ocotillo Dr., Suite o, El Centro, CA 92243

27. Received and referred to Community Development Department, Application for Alcoholic Beverage License – Hong Kong, 550 Wake Ave., El Centro, CA 92243

TASK FORCE AND MAYOR & COUNCIL MEMBERS REPORTS
Mayor and Council Members reported on their activities since last City Council meeting and upcoming events.

CITY MANAGER REPORT
City Manager reported on activities since last City Council meeting and upcoming events.

ADJOURNMENT
With no further business to come before City Council, Mayor Oliva adjourned the meeting at 8:00 p.m. __________________________
Norma Wyles, City Clerk
APPROVED BY:
________________________________
Tomás Oliva, Mayor

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Attachment: 12-21-2021 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

REGULAR MEETING

EL CENTRO CITY COUNCIL

CITY HALL, COUNCIL CHAMBERS
1275 MAIN STREET, EL CENTRO, CA
TUESDAY, JANUARY 4, 2022 11:30 A.M.

This being a regularly scheduled meeting date of the El Centro City Council, this date of January 4, 2022 at 11:30 a.m. and all Council Members were absent upon unanimous consent therefrom, and the undersigned City Clerk declared said meeting cancelled.

Next regular meeting to be held on Tuesday, January 18, 2022 at 11:30 a.m. __________________________________
Norma Wyles, City Clerk
APPROVED BY:
__________________________
Tomás Oliva, Mayor

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Attachment: 1-04-2022 Regular CC Minutes (5417 : Approval of City Council Minutes) Book 36

SPECIAL MEETING

EL CENTRO CITY COUNCIL

CITY HALL, COUNCIL CHAMBERS
1275 MAIN STREET, EL CENTRO, CA
MONDAY, APRIL 10, 2022 12:00 P.M. (NOON)
The El Centro City Council met in special session on Monday, April 10, 2022 at 12:00 p.m. in Council Chambers, El Centro City Hall, 1275 Main Street, El Centro, California for an English informational meeting.

Spanish informational meeting started at 1:14 p.m. Public and Staff in attendance inside and outside Council Chambers practiced social distancing. The meetings were also viewed by the public through Livestream and Facebook Live.

PRESENT: Council: Viegas-Walker, Oliva, Cardenas-Singh, Marroquin City Clerk Wyles, City Manager Piedra, City Attorney Evans ABSENT: Council: Garcia, Viegas-Walker (left meeting at 1:11 pm) Pledge of Allegiance to the flag of the United States of America was led by Mayor Pro-Tem Cardenas-Singh and Invocation was given by Mayor Oliva.

NEW BUSINESS

1. Informational updates on COVID 19 Coronavirus and services available were made by Janette Angulo, Director, Imperial County Public Health Department; Dr. Adolph Edward, CEO, El Centro Regional Medical Center; Cedric Ceseña; Interim Fire Chief, El Centro Fire Department; Brian Johnson, Chief of Police El Centro Police Department; Monica from El Centro Regional Medical Center; Ruben Martel, Records Supervisor, El Centro Police Department; Jesus Escobar, County Supervisor, County of Imperial.

All presentations were made in English and Spanish. Informational only. No action taken.

All Comments/concerns received through email, Facebook Live or Zoom were answered by City Council, Staff or Representatives.

PUBLIC COMMENTS:

Mr. Wiley – NBC, CBS
Mr. Hector Casillas

ADJOURNMENT
With no action coming from closed session and no further business to be discussed, the English meeting was adjourned at 1:11 p.m. Spanish meeting started at 1:11 p.m. and was adjourned at 2:12 p.m. ______________________________
APPROVED BY: Norma Wyles, City Clerk
________________________________
Tomás Oliva, Mayor

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Attachment: 1-10-2022 Special CC Minutes (5417 : Approval of City Council Minutes) City Council of the City of El Centro Meeting: 02/01/22 11:30 AM 1275 Main Street Department: City Clerk's Office
El Centro, CA 92243 Category: Resolution
Prepared By: Norma Wyles
SCHEDULED Department Head: Norma Wyles
ACTION ITEM (ID # 5363) DOC ID: 5363
Resolution Authorizing Remote Teleconference Meetings
CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 22- , RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO CONFIRMING THE CONTINUATION OF THE LOCAL STATE OF

EMERGENCY AND THE STATE OF EMERGENCY PROCLAIMED BY GOVERNOR NEWSOM ON MARCH 4, 2020 AND AUTHORIZING REMOTE TELECONFERENCE MEETINGS OF THE CITY COUNCIL FOR THE PERIOD FEBRUARY 3 THROUGH MARCH 4 PURSUANT TO NEWLY ENACTED BROWN ACT PROVISIONS
FISCAL IMPACT:

None
STRATEGIC PLANNING PROGRAM 2013-2018 RELATION:

N/A
DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

None
DISCUSSION:

If the City wishes to continue with virtual meetings, then the Council should consider and adopt this Resolution. It will apply to all Brown Act covered bodies within the City.

The previous teleconferencing provisions continue to apply but only for Council members on a trip or vacation do not change.

The bases for determining to continue virtual meeting participation are either the inability effectively to socially distance at public meetings (a health and safety issue) or a determination that a public meeting would present imminent danger to the participants. The inability to socially distance is set out in this Resolution.

In addition, AB 361 states requirements for virtual meetings (many of which were part of various Governor’s orders): requirements for clear noticing, allowing time for public comment during meetings, and observance of all statutory and constitutional rights of participants. The public may not be required to provide written comments in advance of the meeting. The legislation also provides that if the internet connection is lost, the meeting must stop until it is reacquired. Action taken without an internet connection is subject to challenge.

The ability to hold a virtual meeting lasts only as long as the Governor’s declaration of a statewide emergency. The Council may terminate virtual meetings at any time before that.

CONCLUSION:
3 Packet Pg. 17
Action Item (ID # 5363) Meeting of February 1, 2022
Adopt Resolution No. 22- , RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO CONFIRMING THE CONTINUATION OF THE LOCAL STATE OF

EMERGENCY AND THE STATE OF EMERGENCY PROCLAIMED BY GOVERNOR NEWSOM ON MARCH 4, 2020 AND AUTHORIZING REMOTE TELECONFERENCE MEETINGS OF THE CITY COUNCIL FOR THE PERIOD FEBRUARY 3 THROUGH MARCH 4 PURSUANT TO NEWLY ENACTED BROWN ACT PROVISIONS
ATTACHMENTS:
• Teleconference 2-3-2022(DOCX)
3 Packet Pg. 18
01/2022/liz/A22-0005/Reso
EmergDecTeleconferenceMeetings
RESOLUTION NO. 22-

RESOLUTION OF THE CITY COUNCIL OF THE CITY OF EL CENTRO CONFIRMING

THE CONTINUATION OF THE LOCAL STATE OF EMERGENCY AND THE STATE OF EMERGENCY PROCLAIMED BY GOVERNOR NEWSOM ON MARCH 4, 2020 AND

AUTHORIZING REMOTE TELECONFERENCE MEETINGS OF THE CITY COUNCIL FOR THE PERIOD FEBRUARY 3 THROUGH MARCH 2, 2022
WHEREAS, the City is committed to preserving and encouraging public access and participation in City Council meetings; and
WHEREAS, all meetings of the City’s legislative bodies are open and public, as required by the Ralph M. Brown Act (Cal. Gov. Code 54950 – 54963), so that any member of the public may attend, participate, and watch the City’s legislative bodies conduct their business; and
WHEREAS, Government Code section 54953(e) added to the Brown Act effective October 1, 2021, makes provisions for remote teleconferencing participation in meetings by members of a legislative body, without compliance with the requirements of Government Code section 54953(b)(3), subject to the existence of certain conditions; and WHEREAS, a required condition is that a state of emergency is declared by the Governor pursuant to Government Code section 8625, proclaiming the existence of conditions of disaster or of extreme peril to the safety of persons and property within the state caused by conditions as described in Government Code section 8558; and WHEREAS, a proclamation is made when there is an actual incident, threat of disaster, or extreme peril to the safety of persons and property within the jurisdictions that are within the City’s boundaries, caused by natural, technological, or human-caused disasters; and WHEREAS, it is further required that state or local officials have imposed or recommended measures to promote social distancing, or have determined that meeting in person would present imminent risks to the health and safety of attendees; and WHEREAS, such conditions now exist in the City, specifically, as the state of emergency declared by the City on March 17, 2020 and by Governor Newsom on March 4, 2020 each continues; and
WHEREAS, social distancing orders are in place at the state and County level for indoor public meetings and, given the size of the Council Chambers imposing such social distancing measures could present an imminent risk to the health and safety of attendees and enforcement of such rules could deter participation in a Board meeting; and WHEREAS, the City Council does hereby find that the combination of the emergency order and the requirement for social distancing has caused, and will continue to cause, conditions of peril to the safety of persons within the City that are likely to be beyond the control of services, personnel, equipment, and facilities of the City, and desires to rely upon

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Attachment: Teleconference 2-3-2022 (5363 : Resolution Authorizing Remote Teleconference Meetings) 01/2022/liz/A22-0005/Reso
EmergDecTeleconferenceMeetings
those orders to allow remote attendance at meetings subject to the requirements of the Brown Act; and
WHEREAS, City Council does hereby find that, commencing with the October 5, 2021 meeting, it is justified in conducting its meetings without compliance with paragraph (3) of subdivision (b) of Government Code section 54953, as authorized by subdivision (e) of section 54953, and that such the City shall comply with the requirements to provide the public with access to the meetings as prescribed in paragraph (2) of subdivision (e) of section 54953; and WHEREAS, the City has and will continue to comply with all other applicable health and safety orders.

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA DOES HEREBY RESOLVE AS FOLLOWS:

Section 1. Recitals. The Recitals set forth above are true and correct and are incorporated into this Resolution by this reference.

Section 2. Confirmation of Emergency. The City Council hereby proclaims that the state of emergency continues throughout the City, and meeting in person would be difficult due to the size of the Board room and therefore present imminent risk to those in attendance.

Section 3. Remote Teleconference Meetings. The City Manager, City Clerk and staff are hereby authorized and directed to take all actions necessary to carry out the intent and purpose of this Resolution including, conducting open and public meetings in accordance with Government Code section 54953(e) and other applicable provisions of the Brown Act.

Section 5. Effective Date of Resolution. This Resolution shall take effect immediately upon its adoption and supersedes Resolution No. 21-98. This Resolution shall be effective until the earlier of (i) 30 days from the date of its adoption, or February 2, 2022; (ii) or such time the City Council adopts a subsequent resolution in accordance with Government Code section 54953(e)(3) to extend the time during which all City bodies subject to the Brown Act may continue to teleconference without compliance with paragraph (3) of subdivision (b) of section 54953.

PASSED AND ADOPTED at a regular meeting of the City Council of the City of El Centro held on the day of , 2022.

CITY OF EL CENTRO
By ___________________________
Tomas Oliva, Mayor

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Attachment: Teleconference 2-3-2022 (5363 : Resolution Authorizing Remote Teleconference Meetings) 01/2022/liz/A22-0005/Reso
EmergDecTeleconferenceMeetings
ATTEST:

By _________________________
Norma Wyles, City Clerk
APPROVED TO FORM:

Office of the City Clerk
By__________________________
Elizabeth Martyn, City Attorney

STATE OF CALIFORNIA )
COUNTY OF IMPERIAL ) ss

CITY OF EL CENTRO )
I, Norma Wyles, City Clerk of the City of El Centro, California, do hereby certify that the foregoing Resolution No. 22- was duly and regularly adopted at a regular meeting of the City Council of the City of El Centro, California held on the day of , 2022, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

By ___________________________
Norma Wyles, City Clerk

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Attachment: Teleconference 2-3-2022 (5363 : Resolution Authorizing Remote Teleconference Meetings) City Council of the City of El Centro Meeting: 02/01/22 11:30 AM 1275 Main Street Department: Police
El Centro, CA 92243 Category: Resolution
Prepared By: Ruben Martel
SCHEDULED Department Head: Brian Johnson
RESOLUTION (ID # 5415) DOC ID: 5415
Destruction of Police Records from 2015-2019
CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 22- , RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO, CALIFORNIA, APPROVING THE DESTRUCTION OF EL CENTRO POLICE DEPARTMENT RECORDS FROM 2015-2019
FISCAL IMPACT:

No fiscal impact. The destruction of records will be conducted in house.

STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

N/A
DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

N/A
BACKGROUND:

Government Code Section 34090 allows the destruction of certain records, documents or instruments upon approval of the City Council by resolution and with written consent of the City Attorney, after the records are no longer required.

DISCUSSION:

The proposed list of records, documents, and instruments are no longer required and should be destroyed.

CONCLUSION:

Adopt Resolution No. 22- , RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO, CALIFORNIA, APPROVING THE DESTRUCTION OF EL CENTRO POLICE DEPARTMENT RECORDS FROM 2015-2019
ATTACHMENTS:
• Final Exhibit A (PDF)
• Final Resolution (DOCX)
4 Packet Pg. 22
1 Repossession of Vehicle notices 1/1/18-12/31/19
2 Subpoena service logs 1/1/18-12/31/19
3 Copies of citations maintained for records 1/1/18-12/31/19 4 "Original" parking citations 1/1/18-12/31/19
6 Taxi driver applications 1/1/18-12/31/19
7 Solicitor applications 1/1/18-12/31/19
8 Copies of ABC letters and permits 1/1/18-12/31/19
9 Telephone logs/message sheets 1/1/18-12/31/19
10 Applications for Public Address Use Permits 1/1/18-12/31/19 11 Ride-Along forms 1/1/18-12/31/19
12 Parking Officer reports 1/1/18-12/31/19
13 Citation adminstrative review forms and response letters 1/1/18-12/31/19 14 Vehicle maintenance logs/records 1/1/18-12/31/19
15 Copies of expired bicycle licenses 1/1/18-12/31/19
16 Field Interrogation cards 1/1/18-12/31/19
17 Stored vehicle reports 1/1/18-12/31/19
18 Department bulletins 1/1/18-12/31/19
19 Statistical reports 1/1/18-12/31/19
20 Dispatch radio logs (Press Logs) 1/1/18-12/31/19
21 Misdemeanor arrest reports (with exceptions) 1/1/15-12/31/15 including all related photos, index cards, and teletypes 22 Misdemeanor crime reports (with exceptions) 1/1/16-12/31/16 including all related photos, index cards, and teletypes 23 Felony crime reports (with exceptions) 1/1/16-12/31/16 including all related photos, index cards, and teletypes 24 Ex employee Personnel Files 1/1/16-12/31/16
*Police Officer files kept for 15 years as os 01/01/2022* 25 Citizen Complaint Forms Everything prior to 12/31/16 26 Background Files for ex employees Everything prior to 12/31/16 27 Disqualified applicants background files Everything prior to 12/31/16 28 Internal Affairs Investigations Everything prior to 12/31/16 29 Audio Recordings (Business and 911 Calls and Radio Traffic) 1/1/19-12/31/19 30 Digital Recordings (except those required by statute to be Everything prior to 12/31/19 retained for certain periods of time or indefinitely)
I hereby consent to the destruction of records hereinabove described. _________________________________________________
Elizabeth Martyn, City Attorney
EXHIBIT "A"

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Attachment: Final Exhibit A (5415 : Destruction of Police Records) 12/2021/liz/A21-0257/Reso
Destruction PD Records
RESOLUTION NO. 22-

RESOLUTION OF THE CITY COUNCIL OF THE

CITY OF EL CENTRO, CALIFORNIA, APPROVING

THE DESTRUCTION OF EL CENTRO POLICE
DEPARTMENT RECORDS FROM 2015-2019
WHEREAS, Government Code section 34090 provides that the head of a city department may destroy certain records, documents or instruments under his charge, without duplication thereof, with the approval of the City Council by resolution and with written consent of the City Attorney, after said records are no longer required; and WHEREAS, it has been determined that certain records are no longer required for retention and accumulation of El Centro Police Department records has become unduly cumbersome; and
WHEREAS, the City Attorney has reviewed and consented to the destruction of those documents listed in Exhibit “A.”

NOW, THEREFORE THE CITY COUNCIL OF THE CITY OF EL CENTRO, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

1. That the foregoing is true, correct and adopted.

2. That the video and audio records, documents, instruments, books or papers listed in Exhibit “A”, copy of which are on file at the Office of the City Clerk, on behalf of the City of El Centro, are no longer required.

3. That the City Council finds that the City Attorney has given his consent to the destruction of records described in Exhibit “A” and the Chief of Police, or his designee, is authorized to destroy the records described in Exhibit “A” without making a copy thereof.

PASSED AND ADOPTED at a regular meeting of the City Council of the City of El Centro held on the day of , 2022.

CITY OF EL CENTRO
By ___________________________
Tomas Oliva, Mayor
ATTEST:

By _______________________________
Norma Wyles, City Clerk

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Attachment: Final Resolution (5415 : Destruction of Police Records) 12/2021/liz/A21-0257/Reso
Destruction PD Records
APPROVED AS TO FORM:

Office of the City Attorney
By _______________________________
Elizabeth Martyn, City Attorney

STATE OF CALIFORNIA )
COUNTY OF IMPERIAL ) ss

CITY OF EL CENTRO )
I, Norma Wyles, City Clerk of the City of El Centro, California, do hereby certify that the foregoing Resolution No. 22- was duly and regularly adopted at a regular meeting of the City Council of the City of El Centro, California, held on the day of , 2022, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAINED:

By ___________________________
Norma Wyles, City Clerk

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Attachment: Final Resolution (5415 : Destruction of Police Records) City Council of the City of El Centro Meeting: 02/01/22 11:30 AM 1275 Main Street Department: Community Development
El Centro, CA 92243 Category: Public Hearing
Prepared By: Angel Hernandez
SCHEDULED Department Head: Angel Hernandez
RESOLUTION (ID # 5387) DOC ID: 5387
Public hearing to consider the recommendation of the
Planning Commission to adopt an Addendum to the El
Centro General Plan Final EIR (SCH #2020070349) for the 2021-2029 Housing Element Update
CITY MANAGER’S RECOMMENDATION:

Adopt Resolution No. 22 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO, CALIFORNIA, APPROVING AN ADDENDUM TO THE EL CENTRO GENERAL PLAN UPDATE FINAL ENVIRONMENTAL IMPACT REPORT (SCH # 2020070349) FOR THE 2021-2029 HOUSING ELEMENT UPDATE
FISCAL IMPACT:

Not Applicable
STRATEGIC PLANNING PROGRAM 2022-2027 RELATION:

Goal #6 - Strengthen El Centro’s resilience by diversifying the economy, recruiting new businesses, creating opportunities for business growth, retaining businesses, and maximizing efficiency.

DUE DILIGENCE CHECK FOR CONTRACTORS/CONSULTANTS: DID THE

DEPARTMENT VERIFY CURRENT EL CENTRO BUSINESS LICENSE,
CONTRACTORS LICENSE, REFERENCE CHECKS, INSURANCE, ETC:

Not Applicable
BACKGROUND:

The Housing Element is one of seven elements required to be included in the City’s General Plan. State law specifies that the Housing Element must assess housing needs and evaluate the current housing market in the City and then identify programs that will meet housing needs. The housing market evaluation includes a review of housing stock characteristics as well as housing cost, household incomes, special need households, availability of land and infrastructure and various other factors. Also included in this evaluation is the community’s “Regional Housing Needs Allocation” (RHNA) which provides an estimate of the number of housing units that should be provided in the community to meet its share of new households in the region. In addition to this information, the Housing Element document must evaluate and review its past housing programs and consider this review in planning future housing strategies. The Housing Element is unique, in that it is the only portion of the General Plan that requires regular updates by State Law and subject to review by the State though the Housing and Community Development Department (HCD).

The proposed Housing Element will cover the eight-year planning period of 2021-2029.

The Southern California Association of Governments (SCAG), is the regional agency responsible for distribution of RHNA within the Southern California region, except San 5 Packet Pg. 26
Resolution (ID # 5387) Meeting of February 1, 2022
Diego County. For this planning period SCAG assigned a RHNA of 3,442 Units, in the following income distribution:

Extremely Low/Very Low Income 1,001 units
Low Income 490 units
Moderate Income 462 units
Above Moderate Income 1,489 units
Through the Housing Element, the City must demonstrate its ability to accommodate the RHNA goals though available and appropriately zoned land for residential development for different income levels.

DISCUSSION:

Addendum to the El Centro General Plan Final EIR - To comply with the California Environmental Quality Act (CEQA), an Addendum to the El Centro General Plan Final EIR adopted in June 15, 2021 was prepared for the project. The draft Housing Element has determined that the City has adequate sites to comply with the RHNA consistent with the planned land uses identified in the Land Use Element of the General Plan.

Also, programs being recommended in the Housing Element will not result in an impact to the environment beyond those identified in the Final EIR prepared for the El Centro General Plan Update. The Addendum demonstrates that the proposed Housing Element Update involves only minor technical changes to the El Centro General Plan that was adopted in June 2021 and would not result in any new or increased severity significant environmental effects beyond those identified in the Final EIR. As such, an addendum is the appropriate environmental document under CEQA. The Addendum is attached for your review as Exhibit A.
2021-2029 Housing Element Update - The proposed Housing Element has been prepared in compliance with State law. Work on the update began in the fall of 2020 with the public participation phase and continued through 2021 with development of the plan and consultation with the State Housing and Community Development Department.

The City’s RHNA goal would be accommodated though existing vacant parcels and through greater flexibility for residential development in existing commercial areas though mixed-use districts identified in the Land Use Element recently updated in June 2021. The Housing Element reviewed the performance of existing housing programs and policies and calls for targeted marketing and outreach to residents of certain neighborhoods to increase participation in housing related programs operated by the City.

The draft 2021-2029 Housing Element has been reviewed by HCD. On November 4, 2021 the City received a letter from HCD (Exhibit B - November 4, 2021 HCD Letter) with results from their compliance review of the document with State Housing Element Law. In addition to the letter, meetings between HCD and the project team occurred on October 14, 2021 and November 10, 2021 to review earlier drafts of the document.

Based on this consultation revisions to the document were made that expanded discussion related fair housing issues, modifying the sites inventory for suitability, and explaining realistic capacity of housing sites among other comments in the HCD Letter. 5 Packet Pg. 27
Resolution (ID # 5387) Meeting of February 1, 2022
A public hearing before the Planning Commission was held on December 14, 2021. The Planning Commission voted unanimously to recommend adoption of the Addendum to the General Plan EIR and the 2021-2029 Housing Element. A draft of the Housing Element was posted on the City website prior to the meeting and interested parties were notified via email of the public hearing and of the draft available for review.

City staff received comments from California Rural Legal Assistance, Inc. (CRLA) and an attorney representing the Southwest Regional Council of Carpenters (SWRCC) (Exhibit C-Comment Letters). Comments from the CRLA were concerning HCD comments which have been since been addressed. SWRCC comments were concerning the environmental review of the project, specifically their letter argues how local skilled and trained workforce requirements would reduce environmental impacts.

The comment letter was not specific to the project. In addition, since the Housing Element does directly result in the construction.

The latest draft of the Housing Element is attached as Exhibit D. The project team has addressed all of the comments provided by HCD. Upon approval of the Housing Element by City Council, HCD has 60 days for an official review. It is expected that minor, if any changes will be required by HCD during their official review.

CONCLUSION:

Adopt Resolution No. 22 - A RESOLUTION OF THE CITY COUNCIL OF THE CITY

OF EL CENTRO, CALIFORNIA, APPROVING AN ADDENDUM TO THE EL CENTRO GENERAL PLAN UPDATE FINAL ENVIRONMENTAL IMPACT REPORT (SCH # 2020070349) FOR THE 2021-2029 HOUSING ELEMENT UPDATE
ATTACHMENTS:
• Exhibit A - El Centro GPU EIR addendum (PDF)
• Exhibit B - 11-4-2021_HCD Review Letter (PDF)
• Exhibit C - Comment Letters (PDF)
• Exhibit D - El Centro HE 2021-2029_Jan24 (PDF)
• Exhibit E - Resolution for EIR Addendum (PDF)
5 Packet Pg. 28
Addendum to the Final
Environmental Impact Report
for the City of El Centro
General Plan Update
Prepared by:

City of El Centro
1275 W. Main Street
El Centro, California 92243
Prepared with the assistance of:

Veronica Tam & Associates
107 S Fair Oaks Avenue #212
Pasadena, California 91105
October 2021

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Attachment: Exhibit A - El Centro GPU EIR addendum (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) General Plan Update
Addendum to the Final EIR
City of El Centro
i
City of El Centro General Plan Update
Addendum to the Final EIR
Table of Contents
Page
Introduction..................................................................................................................................... 1 Project Description.......................................................................................................................... 1 General Plan UPDATE EIR............................................................................................................ 2 Environmental IMpacts of the Housing element update................................................................. 3 Agriculture and Forestry Resources............................................................................................ 3 Biological Resources .................................................................................................................. 8 Cultural and Tribal Cultural Resources .................................................................................... 11 Greenhouse Gas Emissions....................................................................................................... 13 Noise ......................................................................................................................................... 14 Transportation........................................................................................................................... 16 Conclusion .................................................................................................................................... 18 rEFERENCES............................................................................................................................... 19 List of Tables
Table 1 Comparison of Sites Inventory with Regional Housing Growth Need (RHNA)............. 2

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Attachment: Exhibit A - El Centro GPU EIR addendum (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) General Plan Update
Addendum to the Final EIR
City of El Centro
1 INTRODUCTION
This document is an Addendum to the City of El Centro General Plan Update Final Environmental Impact Report (EIR - SCH# 2020070349, hereafter referred to as the Final EIR).

The Addendum analyzes the environmental effects of the proposed 2021-2029 Housing Element, which updates the City’s current 2014-2021 Housing Element. The Housing Element is a state-mandated element of the El Centro General Plan. The Addendum has been prepared in accordance with relevant provisions of the California Environmental Quality Act (CEQA) of 1970 (as amended) and the CEQA Guidelines.

According to Section 15164 of the CEQA Guidelines, an addendum to a previously certified EIR or Negative Declaration is the appropriate environmental document in instances when “only minor technical changes or additions are necessary” and when the new information does not involve new significant environmental effects beyond those identified in the previous EIR.

This Addendum describes the details of the City of El Centro 2021-2029 Housing Element (hereafter referred to as the Housing Element Update) and compares its impacts to those identified in the Final EIR. The analysis herein demonstrates that the proposed Housing Element Update involves only minor technical changes to the El Centro General Plan that was adopted in June 2021 and would not result in any new or increased severity significant environmental effects beyond those identified in the Final EIR. As such, an addendum is the appropriate environmental document under CEQA.

PROJECT DESCRIPTION
The City of El Centro proposes to update the Housing Element of its General Plan as mandated by Government Code Sections 65580-65589. The Housing Element Update is a policy document with programs intended to facilitate meeting the City's housing needs and accommodate the Southern California Association of Government's Regional Housing Needs Assessment (RHNA) during the 2021-2029 planning period (the sixth Housing Element cycle). As a policy document that is revised periodically, the Housing Element Update represents a fine-tuning process rather than a complete overhaul of the current Housing Element.

The Housing Element Update identifies strategies and programs that focus on preserving and improving housing and neighborhoods; providing adequate housing sites; assisting in the provision of affordable housing; removing governmental and other constraints to housing development; and promoting fair and equal housing opportunities.

El Centro’s 2021-2029 RHNA allocation is 3,442 units distributed among the following income groups: 1,491 low and very low income units; 462 moderate income units; and 1,489 above moderate income units. The housing unit totals specified by the RHNA are not quotas for development. Rather, the RHNA determines the number and affordability of housing units that jurisdictions need to plan for through land use policies, regulations, infrastructure plans, and housing assistance programs. In total, El Centro’s residential sites inventory accommodates 4,652 additional units, including sites suitable for development of 1,963 low/very income units,

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Attachment: Exhibit A - El Centro GPU EIR addendum (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) General Plan Update
Addendum to the Final EIR
City of El Centro
2 617 moderate income units, and 2,072 above moderate income units. This represents an overall surplus of 1,210 units above the RHNA. Table 1 shows El Centro’s residential unit potential by income category and compares the unit potential to the City’s 2021-2029 RHNA.

Table 1 Adequacy of Sites to Accommodate the 2021-2029 RHNA Income RHNA Entitled/
Pending
Pipeline
Projects Sites
Total
Unit
Potential
Surplus
compared
to RHNA
%
Surplus
Very Low (<50% AMI) 1,491 --- --- 1,963 1,963 472 32% Low (51-80% AMI) Moderate (81%-120% AMI) 462 --- 180 437 617 155 34%
Above Moderate (>120% AMI) 1,489 574 --- 1,498 2,072 583 39% Total 3,442 574 180 3,898 4,652 1,210 35%
Although programmatic changes included in the proposed Housing Element Update would influence the availability of affordable housing to El Centro residents, the Housing Element Update would not accommodate housing development beyond what is allowed under the current General Plan Update adopted in June 2021 and considered in the General Plan Update EIR. Accordingly, the 4,652 residential units accommodated for the 2021-2029 RHNA cycle would be within the housing accommodated by the land use designations in the General Plan Update, which forecasts future residential growth through 2050. The Final EIR considers overall housing growth of 20,761 units through 2050.

The Housing Element Update includes policies and programs aimed at meeting the housing needs, including minor policy changes from the 2014-2021 Housing Element. Among the changes are new policies related to affirmatively furthering fair housing opportunities in the City. These policies have been added pursuant to AB 686, which was passed in 2017 and requires an analysis of barriers that restrict access to opportunity and a commitment to specific meaningful actions to affirmatively further fair housing.

Potential environmental impacts associated with development according to the General Plan were evaluated in the Final EIR, which is incorporated herein by reference and available at El Centro City Hall and on the City's website.

GENERAL PLAN UPDATE EIR
The City of El Centro prepared an EIR for the General Plan in accordance with the requirements of CEQA and the CEQA Guidelines. A Notice of Preparation (NOP) was filed with the California Office of Planning and Research and distributed to public agencies and interested parties for a 30-day public review period that began on July 17, 2020 and ended on August 16, 2020. The Draft EIR was circulated for a 45-day public review period that ran from March 9, 2021 to April 23, 2021. The Final EIR was certified in June 2021.

As noted previously, the EIR addresses the potential environmental effects of forecast growth under the General Plan Update through 2050. The scope of the EIR includes environmental

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Attachment: Exhibit A - El Centro GPU EIR addendum (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) General Plan Update
Addendum to the Final EIR
City of El Centro
3 issues determined to be potentially significant based on the Initial Study and responses to the NOP. The following issues are addressed in detail in the EIR:
• Agriculture and Forestry Resources
• Air Quality
• Biological Resources
• Cultural and Tribal Cultural
Resources
• Greenhouse Gas Emissions
• Noise
• Transportation
The Final EIR identifies significant and unavoidable impacts related to agriculture resources, air quality, cultural (historic) resources, greenhouse gas emissions, and noise.

ENVIRONMENTAL IMPACTS OF THE HOUSING ELEMENT
UPDATE
This section addresses each of the environmental issues discussed in the Final EIR to determine whether or not the proposed 2014-2021 Housing Element Update has the potential to create new significant impacts or a substantial increase in the significance of a previously identified significant impact as compared to what was identified in the Final EIR.

Agriculture and Forestry Resources
Conversion of Farmland
Table 3.1-3 of the Final EIR notes that up to 1,261.78 acres of designated important farmlands throughout the City’s Sphere of Influence (SOI) could be converted to non-agricultural uses with buildout of the General Plan Update. Although much of this land is considered fallow and unusable for agricultural purposes due to the lack of irrigation infrastructure, the Final EIR identifies this impact as significant. Mitigation Measure AG-1 requires a project-specific agricultural study, including project-specific mitigation as necessary, for any future development site that contains viable farmland. Nevertheless, the significant impact related to agricultural land conversion is identified as unavoidable.

Housing development under the Housing Element Update could contribute to the significant impact associated with the General Plan Update by converting sites containing designated farmlands to residential use. However, because the Housing Element Update does not include any land use designation changes beyond those included in the General Plan Update, it would not result in any new significant impact or increase the severity of the significant and unavoidable impact identified in the Final EIR. Mitigation Measure AG-1 from the Final EIR would apply to housing sites containing viable farmland and would reduce impacts associated with the Housing Element Update to the degree feasible.

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Attachment: Exhibit A - El Centro GPU EIR addendum (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) General Plan Update
Addendum to the Final EIR
City of El Centro
4 Conflict with Agricultural Zone or Williamson Act Contract As noted in the Final EIR, the County Board of Supervisors voted in 2010 to not accept any new Williamson Act contracts and to not renew existing contracts due to the elimination of the subvention funding from the state budget. All Williamson Act contracts in the County, including those in the City, were terminated on or before December 31, 2018. Therefore, no impacts Williamson Act contract lands were identified. Additionally, the Final EIR identifies no conflicts with existing agricultural zones because no designated agricultural zones are in the City or SOI.

Because the City and SOI include no Williamson Act contracts or agriculturally zoned land, the Housing Element Update would similarly have no conflict related to Williamson Act contracts or agricultural zones. Thus, it would not result in any new significant impact or increased severity significant impact in this regard.

Conflict with Zoning for Forest Land or Timberland
As noted in the Final EIR, no portion of the City or SOI is zoned as forest land or timberland and neither the City nor the SOI includes any forest land or timberland. Therefore, no impact related to conflicts with forest land or timberland zones is identified.

Because the City and SOI include no areas zoned as forest land or timberland, the Housing Element Update would similarly have no conflict related to forest or timberland zones or resources. Thus, it would not result in any new significant impact or increased severity significant impact in this regard.

Loss or Conversion of Forest Land
As noted in the Final EIR, neither the City nor the SOI includes any forest land. Thus, no impact to forest land is identified.

Because the City and SOI include no forest land, the Housing Element Update would similarly have no conflict related to forest land. Thus, it would not result in any new significant impact or increased severity significant impact in this regard.

Other Changes to the Existing Environment
As noted in the Final EIR, the General Plan Update includes changes in land use designations that could result in incompatibilities by placing residential or commercial development near agricultural uses. Buildout of the General Plan Update would increase development density/intensity in the vicinity of some agricultural operations. Although compliance with existing El Centro General Plan policies would partially mitigate potential impacts related to incompatible uses through buffering techniques, the potential for land use changes to adversely affect agricultural operations is identified as significant. Mitigation Measure AG-1 requires a project-specific agricultural study, including project-specific mitigation as necessary, for any

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City of El Centro
5 future development site that could adversely affect viable farmland. Nevertheless, this significant impact is identified as unavoidable.

Housing development under the Housing Element Update could contribute to the significant impact associated with the General Plan Update by adding residential development adjacent to existing farmland. However, because the Housing Element Update does not include any land use designation changes beyond those included in the General Plan Update, it would not result in any new significant impact or increase the severity of the significant and unavoidable impact identified in the Final EIR. Mitigation Measure AG-1 from the Final EIR would apply to housing sites with the potential to adversely affect viable farmland and would reduce impacts associated with the Housing Element Update to the degree feasible.

Air Quality
Consistency with Applicable Air Quality Plan
The Final EIR notes that future development under the General Plan Update would be required to comply with various mobility and environmental justice goals and policies that would reduce air pollutant emissions by reducing citywide vehicle miles traveled (VMT). Additionally, compared to the prior El Centro General Plan, the General Plan Update would have slightly less residential, commercial, industrial, and recreational development capacity. Based on these facts, the Final EIR concludes that the General Plan Update would not conflict with or obstruct implementation of the Imperial County Air Pollution Control District (ICAPCD) Clean Air Plans and that impacts would be less than significant.

The proposed Housing Element Update would not accommodate any housing development beyond that accommodated by the General Plan Update and all development under the Housing Element Update would be subject to the mobility and environmental justice policies included in the General Plan Update and cited in the Final EIR. Thus, as with the General Plan Update, the impacts of the Housing Element Update with respect to Clean Air Plan consistency would be less than significant. The Housing Element Update would not result in any new or increased severity significant impact related to Clean Air Plan consistency.

Cumulative Increase in Criteria Pollutants
With respect to future construction activity in El Centro, the Final EIR cites various ICAPCD requirements aimed at reducing construction emissions, but concludes that even with implementation of these standard measures, it cannot be guaranteed that future construction emissions would be below the ICAPCD thresholds. Therefore, the Final EIR concludes that implementation of the General Plan Update would result in potentially significant increases in criteria pollutant emissions from construction activities. The Final EIR includes Mitigation Measure AIR-1 to reduce criteria pollutant emissions from future construction activities by requiring future development to demonstrate compliance with ICAPCD thresholds and implement emissions reduction measures where feasible. However, even with this measure it cannot be guaranteed that compliance with the reduction measures

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City of El Centro
6 would fully reduce the impact; therefore, the significant temporary increase in criteria pollutant emissions associated with construction is found to be unavoidable.

With respect to long-term operational emissions, the Final EIR notes that net operational emissions associated with buildout of the General Plan Update would exceed the applicable ICAPCD Tier I thresholds for reactive organic gases (ROG), particulate matter (PM10 and PM2.5), and carbon monoxide (CO). Future development projects under the General Plan Update would be required to comply with standard measures for project operation in the ICAPCD Handbook as well as Mitigation Measure AIR-2, which requires future development to comply with the discretionary measures in the ICAPCD Handbook as applicable. Nevertheless, it cannot be guaranteed that compliance with the reduction measures would reduce emissions to below applicable thresholds so the Final EIR concludes that impacts related to project operation would be significant and unavoidable.

The proposed Housing Element Update would contribute to the significant and unavoidable air quality impacts identified in the Final EIR by accommodating additional housing throughout the City, but would not accommodate any housing development beyond that accommodated by the General Plan Update. Additionally, all development under the Housing Element Update would be subject to applicable ICAPCD requirements as well as Mitigation Measures AIR-1 and AIR-2 from the Final EIR. As such, both construction and operational emissions associated with development under the Housing Element would be within the total emissions identified in the Final EIR and the Housing Element Update would not result in any new or increased severity significant impact related to cumulative increases in criteria pollutants.

Sensitive Receptors
The Final EIR identifies two potential issues related to sensitive receptors: CO hotspots associated with vehicular traffic where CO concentrations exceed state or federal standards and diesel particulate (DPM) emissions from construction and operational activities. Each of these is discussed below.

With respect to CO hotspots, the Final EIR concludes that one roadway segment in El Centro (Imperial Avenue from Ocotillo Drive to the Interstate [I-8] westbound ramps) would have the potential for a hotspot because future average daily trips would exceed 30,000 and the level of service (LOS) would be E or lower under buildout conditions. Therefore, a potentially significant impact related to a CO hotspot is identified at the intersections of Imperial Avenue and Ocotillo Drive and Imperial Avenue and the I-8 westbound ramps. Mitigation Measure AIR-3 requires a CO hotspot analysis for future projects involving a new sensitive receptor within 500 feet of the intersections of Imperial Avenue and Ocotillo Drive or Imperial Avenue and the Interstate 8 westbound ramps or that would significantly increase traffic volumes at either intersection and implementation of actions to improve operations as necessary. With this measure, the Final EIR concludes that impacts related to CO hotspots would be reduced to a less than significant level.

With respect to DPM, the Final EIR notes that construction activities near any specific sensitive receptor would be temporary and short term. Additionally, with ongoing implementation of

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City of El Centro
7 USEPA and CARB requirements for cleaner fuels, off-road diesel engine retrofits, and new, lowemission diesel engine types, the DPM emissions of individual equipment would be substantially reduced over the year. Based on these facts, impacts associated with temporary DPM emissions are found to be less than significant.

The Final EIR analysis of operational impacts related to DPM is based on the California Air Resources Board’s (CARB’s) siting recommendations in the Air Quality and Land Use Handbook (CARB 2005), which recommends a detailed Health Risk Assessment for proposed sensitive receptors within 1,000 feet of a warehouse distribution center, 300 feet of a large gas station, 50 feet of a typical gas dispensing facilities, or 300 feet of a dry-cleaning facility that uses perchloroethylene (i.e., PCE), among other siting recommendations. Additionally, CARB recommends a Health Risk Assessment for any sensitive receptors proposed within 500 feet of a highway. The Final EIR also notes that emissions of toxic air contaminants (TACs) such as DPM are subject to new source review and regulated by the ICAPCD under Rule X, Air Toxic Control Measures, or Rule XI, New Source Performance Standards. Nevertheless, future facilities could potentially expose sensitive receptors to TACs and new sensitive receptors could potentially be sited within the CARB-recommended screening-level distance from a source of DPM. Thus, the Final EIR concludes that operational impacts would be significant. Mitigation Measure AIR-4 from the Final EIR requires a Health Risk Assessment for future development projects that would generate TACs (such as DPM) or that would locate a new sensitive receptor within the applicable screening-level distance identified in the ICAPCD CEQA Air Quality Handbook and identification of appropriate measures, such as upgrading building ventilation systems, to reduce the potential health risk to below a significant level if significant health risks are identified. Nevertheless, the significant impacts related to siting new receptors near existing facilities are identified as unavoidable because not all potential sources of TAC emissions would be subject to new source review.

The proposed Housing Element Update would not accommodate any housing development beyond that accommodated by the General Plan Update and would not involve any new residential development near the Imperial Avenue/Ocotillo Drive or Imperial Avenue/Interstate 8 westbound ramps intersections or that would be a source of TACs.

Additionally, all development under the Housing Element Update would be subject to Mitigation Measures AIR-3 and AIR-4 from the Final EIR. The Housing Element Update would not contribute to the impacts related to CO hotspots or new sources of TACs. It would contribute to the significant and unavoidable impact related to potential exposure of new sensitive receptors to existing sources of TACs. However, because it would not accommodate housing beyond that already planned for under the General Plan Update and analyzed in the Final EIR, the Housing Element Update would not result in any new or increased severity significant impact related to exposure of sensitive receptors to potential health risks from TACs such as DPM.

Odors
The Final EIR notes that construction activity under the General Plan Update could result in minor amounts of odor compounds associated with diesel heavy equipment exhaust, asphalt paving, and use of architectural coatings and solvents, but concludes that because such impacts

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City of El Centro
8 would be temporary, they would not be significant. With respect to operational impacts, the Final EIR cites the ICAPCD Handbook, which provides screening level distances for potential Odor sources. According to the Handbook, if a project is proposed within one mile of a wastewater treatment plant, sanitary landfill, composting station, feedlot, asphalt plant, painting and coating operation, or rendering plant, a potential odor problem may result.

Because the General Plan Update would have the potential to place sensitive receptors near an existing odor source, such as agricultural operations or the wastewater treatment plant, odor impacts are identified as potentially significant. However, Mitigation Measure AIR-5 from the Final EIR is determined to reduce odor impacts to a less than significant level by requiring proposed new odor sources or the placement of new receptors near an existing odor source to contact the ICAPCD and implement odor control techniques as necessary The proposed Housing Element Update would contribute to the potentially significant odor impact identified in the Final EIR since it would accommodate housing that could be exposed to odors from various sources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and development under the Housing Element Update would be subject to Mitigation Measure AIR-5 from the Final EIR. As such, the Housing Element Update would not result in any new or increased severity significant odor impact beyond that identified in the Final EIR. Odor impacts would remain less than significant with implementation of Mitigation Measure AIR-5.

Biological Resources
Candidate, Sensitive, or Special-Status Species
The Final EIR notes that the El Centro planning area consists primarily of urban/developed land surrounded by agricultural land where sensitive plant and animal species are limited due to the lack of preferred or required habitats. Nevertheless, the Final EIR concludes that the General Plan Update would have potentially significant direct and indirect impacts to plant and animal species identified as candidate, sensitive, or special-status species in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife (CDFW) or the U.S. Fish and Wildlife Service (USFWS). Potential impacts to nesting birds and raptors are also identified as potentially significant. However, mitigation measures BIO-1 through BIO-8 are found to reduce all such impacts to a less than significant level through project-specific plant, animal, and nesting bird surveys and avoidance, limitations on lighting, on other requirements.

The proposed Housing Element Update would contribute to potential impacts to sensitive plants, animals, and nesting birds identified in the Final EIR since it would accommodate housing with the potential to disturb such resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and development under the Housing Element Update would be subject to mitigation measures BIO1 through BIO-8 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant impact beyond that identified in the Final EIR and impacts to

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City of El Centro
9 sensitive plants, animals, and nesting birds would remain less than significant with implementation of measures BIO-1 through BIO-8.

Riparian Habitat or Other Sensitive Natural Communities As the Final EIR notes, the majority of the El Centro planning area is composed of agricultural and urban/developed lands, but portions of the planning area may have the potential to support small areas of sensitive vegetation communities, including non-native grassland, that may not have been previously identified. Therefore, direct and indirect impacts to sensitive vegetation communities are identified as potentially significant. With implementation of Mitigation Measures BIO-4, BIO-9, and BIO-10, the Final EIR concludes that impacts to sensitive natural communities would be reduced to a less than significant level.

The proposed Housing Element Update would contribute to the potentially significant impacts to sensitive communities identified in the Final EIR since it would accommodate housing with the potential to disturb grasslands and other resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and development under the Housing Element Update would be subject to mitigation measures BIO4, BIO-9, and BIO-10 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant impact beyond that identified in the Final EIR and impacts to sensitive natural communities would remain less than significant with implementation of measures BIO-4, BIO-9, and BIO-10.

Wetlands
The Final EIR identifies approximately 82.1 acres of open water and canals in the El Centro planning area that are associated with the surrounding agricultural industry and residential development. These open water areas are located in both the northern and southern portions of the planning area. The Final EIR states that it is unlikely that these aquatic resources areas would be impacted due to their function as essential water conveyance infrastructure for the agricultural industry. Nevertheless, potential disturbance of state and federal jurisdictional aquatic resources is identified as a potentially significant direct and indirect impact to jurisdictional aquatic resources. With implementation of Mitigation Measures BIO-11 and BIO12 requiring aquatic resources delineation and permitting as necessary, the Final EIR concludes that impacts to state or federally protected aquatic resources through direct removal, filling, hydrological interruption, or other means would be reduced to a less than significant level.

The proposed Housing Element Update would contribute to the potentially significant impacts to aquatic resources identified in the Final EIR by accommodating housing development with the potential to disturb such resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and development under the Housing Element Update would be subject to mitigation measures BIO-11 and BIO-12 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant

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City of El Centro
10 impact beyond that identified in the Final EIR and impacts to aquatic resources would remain less than significant with implementation of measures BIO-11 and BIO-12.

Native Resident or Migratory Fish or Wildlife Species
The Final EIR notes that the El Centro planning area falls within the Pacific Flyway migratory corridor and that although the planning area is primarily developed with agricultural and urban/developed lands, it has the potential to provide habitat for migratory birds traveling between nesting and wintering areas and overwintering birds. Implementation of the General Plan Update would result in potentially significant impacts to migratory birds. The planning area is not, however, likely to be used as a movement corridor by wildlife other than migratory birds because it lacks native vegetation communities, is primarily made up of urban/developed land uses, is surrounded by agricultural land, and is not connected to any other open space areas. Additionally, the Final EIR notes that no critical habitat is present in the planning area.

Therefore, no impacts to corridors or nursery sites for wildlife other than migratory birds are identified and the Final EIR concludes that the General Plan Update would have a less than significant impact to the movement of native resident or migratory fish or wildlife species.

The proposed Housing Element Update would not accommodate any housing development beyond that accommodated by the General Plan Update. As such, it would not result in any impact beyond that identified in the Final EIR or result in any new or increased severity significant impact related to migratory fish or wildlife. Impacts would remain less than significant.

Local Ordinances
As noted in the Final EIR, development projects in El Centro are required to comply with policies protecting biological resources identified in the Conservation/Open Space Element of the El Centro General Plan and the Conservation and Open Space Element of the Imperial County General Plan. The Final EIR concludes that with implementation of mitigation measures fully mitigating impacts to sensitive plant and animal species, sensitive vegetation communities, and jurisdictional aquatic resources, the General Plan would not conflict with the El Centro General Plan and impacts related to potential conflicts with applicable policies or ordinances protecting biological resources would be less than significant.

The proposed Housing Element Update would not accommodate any housing development beyond that accommodated by the General Plan Update and development under the Housing Element Update would be subject to mitigation measures included in the Final EIR. As such, the Housing Element Update would not result in any impact beyond that identified in the Final EIR or result in any new or increased severity significant impact related to local ordinances. Impacts would remain less than significant.

Habitat Conservation Plan
The Final EIR notes that no Habitat Conservation Plan or NCCP Plan has been adopted in or adjacent to the El Centro planning area and concludes that no impacts to local conservation

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City of El Centro
11 plans would occur as a result of the General Plan Update. Because no Habitat Conservation Plan or NCCP has been adopted, the proposed Housing Element Update similarly would have no impact related to habitat conservation plans.

Cultural and Tribal Cultural Resources
Historical Resources
The Final EIR identifies 12 historical resources in the El Centro planning area that are significant at the local, state, or federal level. Four of the resources have been listed or recommended eligible to be listed on the National Register of Historic Places (NRHP) or the California Register of Historic Resources (CRHR), two of the resources are listed as California Points of Interest, and the remaining six resources have been recommended as locally significant. Development under the General Plan Update could potentially impact any of these historical resources or previously unidentified, undesignated resources. The Final EIR notes a number of General Plan policies related to historical resource protection with which future development under the General Plan Update will be required to comply. Nevertheless, impacts to historical resources are identified as potentially significant. The Final EIR includes mitigation measures CUL-1 through CUL-3 to address this impact, but concludes that while measures CUL-1 and CUL-2 would reduce potential impacts associated with historical resources to the degree feasible, Measure CUL-3 would fully mitigate the effect of demolition or significant alteration of a historical resource. Therefore, the significant impact to historical resources is identified as unavoidable.

The proposed Housing Element Update could contribute to potential significant impacts to historical resources identified in the Final EIR since it could accommodate development involving modifications to or demolition of historical resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update. Development under the Housing Element Update would be subject to mitigation measures CUL-1, CUL-2, and CUL-3 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to the degree feasible, but impacts would remain potentially significant and unavoidable. The Housing Element Update would not, however, result in any new significant impact or increased the severity of the previously identified significant impact beyond that already identified in the Final EIR.

Archaeological Resources
The Final EIR notes that no prehistoric cultural resources have been previously recorded in the El Centro planning area and that during the prehistoric period the planning area was often submerged beneath Lake Cahuilla. Nevertheless, there is still a potential for prehistoric cultural resources to be identified in the planning area. Future development in the City under the General Plan Update would be required to comply with applicable provisions of the El Centro General Plan related to archaeological resource protection, but damage to or destruction of previously unknown subsurface cultural resources could still occur and impacts are identified as potentially significant. Mitigation Measures CUL-4 through CUL-6 from the Final EIR would

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City of El Centro
12 address this impact through archaeological resource investigation and avoidance and Native American monitoring as appropriate. With these measures, impacts are determined to be less than significant.

The proposed Housing Element Update would contribute to the potentially significant impact to archaeological resources identified in the Final EIR by accommodating housing development with the potential to disturb such resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and, as with the General Plan Update, development under the Housing Element Update would be subject to General Plan policies related to archaeological resource protection as well as mitigation measures CUL4, CUL-5, and CUL-6 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant impact beyond that identified in the Final EIR and impacts to archaeological resources would remain less than significant with implementation of measures CUL-4, CUL-5, and CUL-6.

Human Remains
The Final EIR notes that no prehistoric cultural resources have been previously recorded in the El Centro planning area, but that undiscovered surface and subsurface prehistoric cultural resources may be present. Therefore, the Final EIR concludes that ground disturbance associated with implementation of the General Plan Update would have the potential to disturb or destroy Native American human remains, including those interred outside of formal cemeteries. This potentially significant impact would be reduced to a less than significant level through implementation of mitigation measures CUL-4 through CUL-6 (described above) and CUL-7, which requires identification and treatment of human remains.

The proposed Housing Element Update would contribute to the potentially significant impact to human remains identified in the Final EIR by accommodating housing development with the potential to disturb such resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and, as with the General Plan Update, development under the Housing Element Update would be subject to mitigation measures CUL-4 through CUL-7 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant impact beyond that identified in the Final EIR and impacts to human remains would remain less than significant with implementation of measures CUL-4 through CUL-7.

Tribal Cultural Resources
The Final EIR indicates that future development as a result of the implementation of the General Plan Update could include grading in portions of the City and SOI with sensitivity to tribal cultural resources (TCRs) and that grading and construction activities in undeveloped areas or redevelopment that requires more intensive soil excavation than in the past could

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City of El Centro
13 potentially cause disturbance to TCRs. Additionally, indirect adverse effects may result from increased accessibility to TCRs, which could lead to resource looting or vandalism. Impacts to previously unknown/unrecorded TCRs are identified as potentially significant, but implementation of mitigation measures CUL-4, CUL-5, CUL-6, and CUL-7 are found to reduce potential impacts to a less than significant level.

The proposed Housing Element Update would contribute to the potential significant impact to TCRs identified in the Final EIR by accommodating housing development with the potential to disturb such resources. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and, as with the General Plan Update, development under the Housing Element Update would be subject to mitigation measures CUL-4 through CUL-7 from the Final EIR. As with the General Plan Update, these measures would reduce impacts related to development under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant impact beyond that identified in the Final EIR and impacts to TCRs would remain less than significant with implementation of measures CUL-4 through CUL-7.

Greenhouse Gas Emissions
Greenhouse Gas Emissions Generation and Conflict with Applicable Plan The Final EIR estimates that future citywide greenhouse gas (GHG) emissions would be approximately 1.9 million metric tons of carbon monoxide equivalents (MTCO2e) and that percapita emissions would be approximately 31.1 MTCO2e. This exceeds the per-capita targets recommended in the Air Resources Board’s 2017 Scoping Plan. Therefore, emissions would be potentially significant under the per-capita emissions criterion. Additionally, although the General Plan Update is consistent with some provisions of the 2017 Scoping Plan, it would not implement all applicable Scoping Plan reduction strategies. Thus, impacts are identified as potentially significant. The Final EIR includes mitigation measures GHG-1 through GHG-3 that would reduce GHG emissions compared to business-as-usual conditions to the degree feasible; however, because it cannot be ensured that proposed transportation demand management (TDM) and GHG sustainability measures would be effective in reducing GHG emissions to recommended per-capita thresholds, this significant impact is identified as unavoidable The proposed Housing Element Update would contribute to the potential significant impact related to GHG emissions identified in the Final EIR by accommodating housing development that would generate GHG emissions. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update; therefore, although the impact would remain significant and unavoidable, the proposed Housing Element Update would not increase the severity of this already identified significant impact or result in any new significant impact related to GHG emissions. Mitigation measures GHG-1 through GHG-3 from the Final EIR would apply to development under the Housing Element Update and would reduce emissions to the degree feasible.

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City of El Centro
14 Noise
Excessive Noise Levels
The Final EIR states that because construction noise would be temporary and would be regulated through the El Centro Noise Ordinance, its impact would be less than significant.

Similarly, long-term nuisance noise impacts associated with the various land uses accommodated under the General Plan Update are identified as less than significant with continued enforcement of the Noise Ordinance. With respect to permanent transportation noise, the Final EIR concludes that the highest volume roadways in the City would likely experience noise levels exceeding the 60 dBA CNEL1 threshold at 50 feet from the roadway centerline and that the increase in traffic associated with General Plan Update buildout would cause a noise increase of 3 dBA CNEL or greater. The Final EIR also notes that new sensitive receptor development planned under the General Plan Update, particularly in the opportunity areas, would have the potential to be exposed to vehicle noise above the existing General Plan Noise Element Noise Compatibility Standards. For these reasons, transportation noise impacts are identified as potentially significant. Mitigation Measure NOI-1 from the Final EIR would reduce the impact of increase traffic noise by requiring implementation of noise reduction techniques where feasible; however, because appropriate techniques may not be feasible in all cases, impacts are identified as significant and unavoidable. Mitigation Measure NOI-2 would reduce impacts to sensitive receptors to a less than significant level by requiring individual development projects to incorporate noise reduction features that reduce noise to within City standards.

The proposed Housing Element Update would involve construction and operational noise similar to that identified in the Final EIR. Impacts related to construction noise and nuisance noise from operation of individual housing developments would remain less than significant.

The proposed Housing Element Update would contribute to the potential significant impact related to transportation noise identified in the Final EIR by accommodating housing development that would generate traffic. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update; therefore, although the impact would remain significant, the proposed Housing Element Update would not increase the severity of this already identified significant impact or result in any new significant impact related to traffic noise. Mitigation measures NOI-1 and NOI-2 from the Final EIR would apply to development under the Housing Element Update. These measures would reduce impacts to sensitive receptors to a less than significant level. Similar to the General Plan Update, impacts related to traffic noise increases would remain significant and unavoidable, though the severity of this already identified significant impact would not increase as a result of the proposed Housing Element Update.
1 dBA is a-weighted decibels, the most commonly used metric for gauging human noise exposure. CNEL is the Community Noise Equivalent Level, a 24-hour sound level that adds a 5 dBA penalty for noise occurring from 7-10 PM and adds a 10-dBA penalty for noise occurring from 10 PM – 7 AM. The CNEL is a commonly used metric for gauging community noise.

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City of El Centro
15 Excessive Groundborne Vibration
The Final EIR concludes that typical vibration levels associated with construction equipment under the General Plan Update could exceed applicable thresholds at the nearest sensitive receptors. Temporary construction vibration impacts are therefore identified as potentially significant. In the long-term, new industrial land uses accommodated under the General Plan Update, primarily along the eastern boundary of the City and in the SOI, could generate groundborne vibration associated with heavy mechanical equipment. However, the El Centro Municipal Code limits displacement of the earth of 0.003 inch per second or less, which would not result in damage to even the most sensitive buildings; therefore, potential groundborne vibration impacts from industrial land uses are identified as less than significant. Mitigation Measure NOI-3 would reduce groundborne vibration impacts associated with construction to a less than significant level by requiring vibration best management practices for all vibration-generating construction activity.

Housing development accommodated by the proposed Housing Element Update would not generate any long-term vibration impacts. Construction activity under the Housing Element would contribute to the potential significant vibration impact identified in the Final EIR by accommodating construction of new housing throughout the City. However, it would not accommodate any housing development beyond that accommodated by the General Plan Update and, as with the General Plan Update, development under the Housing Element Update would be subject to Mitigation Measure NOI-3 from the Final EIR. As with the General Plan Update, this measure would reduce impacts related to construction under the Housing Element Update to a less than significant level. Therefore, the Housing Element Update would not result in any new or increased severity significant impact beyond that identified in the Final EIR and impacts associated with construction-related vibration would remain less than significant with implementation of Mitigation Measure NOI-3.

Aircraft Noise
The Final EIR notes that there are two airports in the vicinity of the City and SOI and that the Imperial County Airport Land Use Commission has established a set of land use compatibility criteria for lands surrounding the County’s airports. Portions of the City are in the Imperial County Land Use Compatibility Plan Area and a small portion of northern El Centro falls within the 55 CNEL noise contour of the Imperial County Airport Noise Impact Area.

Additionally, a small portion of the western planning area is within the 60 CNEL noise contour for Naval Air Facility El Centro. However, because the planning area is not within an airport noise contour for either airport that would exceed the City’s noise compatibility standard for the most sensitive land uses (60 dBA CNEL), implementation of the General Plan Update would not expose people residing or working in the planning area to excessive aircraft noise. Impacts are identified as less than significant.

The proposed Housing Element Update would not place any new housing in areas where exposure to aircraft-related noise exceeding the City’s noise compatibility standards for residences. As such, as identified in the Final EIR, the Housing Element Update would not

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City of El Centro
16 result in any exposure to excessive aircraft noise and impacts related to aircraft noise would remain less than significant.

Transportation
Conflict with Program, Plan, Ordinance, or Policy
The Final EIR notes that the previously adopted Active Transportation and Safe Routes to School Plan (ATP/SR2S), El Centro General Plan Circulation Element, Bicycle Master Plan, Vision 2050 Strategic Plan, and Imperial County Safe Routes to School Plan provide relevant goals and objectives related to mobility. These were used as a starting point for formulating the goals and policies for the proposed General Plan Update. Policies contained in the General Plan Update are found to be supportive of improvements to pedestrian, bicycle, transit, and roadway facilities. Therefore, the General Plan Update is found to be consistent with adopted programs, plans, ordinances, and policies and this impact is identified as less than significant.

The proposed Housing Element Update would not accommodate any housing not already accommodated by the General Plan Update and would not involve any changes to the City’s circulation system or otherwise conflict with the above adopted plans and policies.

Consequently, as with the General Plan Update, it would not conflict with programs, plans, ordinances, or policies related to mobility and impacts would remain less than significant.

Vehicle Miles Traveled
The Final EIR concludes that with implementation of the General Plan Update, the vehicle miles traveled (VMT) efficiency of the City would substantially improve due to the proposed land use and development patterns, policies, and practices that would be sustainable and consistent with Smart Growth principles as well as the balanced, interconnected, multimodal transportation network that would accommodate future growth in the City. With respect to future residential development specifically, the Final EIR projects that the City will have an average resident VMT per capita of 7.93 per resident and an average employee VMT per employee of 8, which are 58 percent and 43 percent, respectively, of the Base Year regional averages for these efficiency metrics. Because the VMT associated with residential and employment land uses would be more than 15 percent below the regional average VMT per capita and VMT per employee, impacts related to VMT for residential and employment land uses are found to be less than significant.

The proposed Housing Element Update would not accommodate any housing not already accommodated by the General Plan Update; therefore, the Housing Element Update would not alter the VMT projections identified in the Final EIR. As such, similar to the General Plan Update, implementation of the Housing Element would improve the VMT efficiency of the City and VMT associated with development under the Housing Element Update would be more than 15 percent below the regional average per capita VMT. Similar to the General Plan Update, impacts would remain less than significant.

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Addendum to the Final EIR
City of El Centro
17 Increase in Design Hazards
The Final EIR notes that new and upgraded roadways needed to accommodate new development under the General Plan Update would be designed according to applicable federal, state, and local design standards. Additionally, policies included in the General Plan Update would serve to reduce potential impacts from future development. The General Plan Update was developed with an emphasis on Complete Streets, which, by their nature, would improve compatibility between different transportation modes and between the transportation system and adjacent land uses. Relevant policies to improve the safety of all users of the transportation system include Policy ME-1.7 and ME-1.8, as discussed in Section 3.7.5.1. With adherence to these policies, the Final EIR concludes that the General Plan Update would not increase hazards due to a design feature or incompatible uses and that impacts would be less than significant.

The proposed Housing Element Update would not involve changes to roadways or other transportation features and, as with development under the General Plan Update, any transportation system improvements implemented in conjunction with housing development accommodated under the Housing Element Update would be designed in accordance with federal, state, and local design standards. Therefore, similar to the General Plan Update, the Housing Element Update would not increase design hazards and impacts would remain less than significant.

Inadequate Emergency Access
The Final EIR notes that buildout of the General Plan Update would enhance the capacity of the roadway system by upgrading roadways and intersections when necessary, ensuring that the future dedication and acquisitions of roadways are based on projected demand, and implementing paved crossover points through medians for emergency vehicles. The Final EIR also states that future development under the General Plan Update would be subject to City regulations regarding street design, site access, and internal emergency access and that the proposed Mobility Element Update includes policies in support of access for emergency vehicles and consideration of the needs for emergency access in transportation planning.

Therefore, implementation of the General Plan Update would not result in inadequate emergency access and impacts are identified as less than significant.

The proposed Housing Element Update would not involve changes to roadways or other transportation features and, as with development under the General Plan Update, transportation system improvements needed in conjunction with housing development accommodated under the Housing Element Update would be implemented on a project-byproject basis and would comply with applicable Mobility Element Update policies that support access for emergency vehicles. Therefore, as with the General Plan Update, the Housing Element Update would not result in inadequate emergency access and impacts would remain less than significant.

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City of El Centro
18 CONCLUSION
The proposed Housing Element Update is consistent with the General Plan Update that the City of El Centro adopted in June 2021 and would not result in any new significant impacts or increased severity significant impacts beyond those identified in the El Centro General Plan Update Final EIR. Therefore, this Addendum is the appropriate environmental document under CEQA.

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City of El Centro
19 REFERENCES
El Centro, City of, El Centro General Plan Update Draft Program Environmental Impact Report, March 2021.

El Centro, City of, El Centro General Plan Update Final Program Environmental Impact Report, June 2021.

El Centro, City of, El Centro General Plan Update, June 2021.

El Centro, City of, Draft El Centro Housing Element Update, September 2021.

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Attachment: Exhibit A - El Centro GPU EIR addendum (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
Norma M. Villacaña, Director
Community Development Department
City of El Centro
1274 W. Main Street
El Centro, CA 92243
Dear Norma M. Villacaña:

RE: City of El Centro’s 6th Cycle (2021-2029) Draft Housing Element Thank you for submitting the City of El Centro’s (City) draft housing element received for review on September 7, 2021, along with revisions received on October 22, 2021.

Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a conversation on October 14, 2021 with the City’s housing element team.

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code).

The enclosed Appendix describes the revisions needed to comply with State Housing Element Law.

The City’s statutory deadline to adopt a housing element was October 15, 2021. For your information, pursuant to Assembly Bill 1398 (Chapter 358, Statutes of 2021), if a local government fails to adopt a compliant housing element within 120 days of this statutory deadline, then any rezoning to accommodate the regional housing needs allocation (RHNA), including for lower-income households, shall be completed no later than one year from the statutory deadline. Otherwise, the local government’s housing element will no longer comply with State Housing Element Law, and HCD may revoke its finding of substantial compliance pursuant to Government Code section 65585, subdivision (i).

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

November 4, 2021

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Attachment: Exhibit B - 11-4-2021_HCD Review Letter (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) Norma M. Villacaña, Director

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City will meet housing element requirements for these and other funding sources.

For your information, some General Plan element updates are triggered by housing element adoption. HCD reminds the City to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf and
http://opr.ca.gov/docs/Final_6.26.15.pdf.

HCD appreciates the hard work and dedication of the City’s housing element team during the review. We are committed to assist the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Jose Ayala, of our staff, at [email protected].

Sincerely,
Paul McDougall
Enclosure

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APPENDIX

CITY OF EL CENTRO
The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element-memos.shtml.

Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources.

A. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A).) Racial/Ethnic Areas of Concentration of Poverty (R/ECAP): The element identified an area considered a R/ECAP and should include specific analysis such as trends, past and current efforts, including investment and their effectiveness, local data and knowledge, other relevant factors (as noted below), particularly relative to equitable quality of life, resources, and strategies to address any inequities in quality of life. The analysis should also consider any overlapping fair housing issues with other components of the assessment of fair housing (e.g., access to opportunity and disproportionate housing needs, including displacement).

Local Data and Knowledge: The element describes a variety of outreach efforts such as from the County and Inland Fair Housing and Mediation Board. However, the element should relate that input to the affirmatively furthering fair housing (AFFH) analysis to better inform the contributing factors to fair housing issues and goals and actions. The element should also consider other local data and knowledge to complete the AFFH analysis.

Examples include input from neighborhoods such as the identified R/E CAP, knowledge from local planners and city administrators and city records and reports.

Other Relevant Factors: The element includes some information on lending practices and housing choice vouchers, but it must still include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use, zoning and investment practices, presence of redlining, restrictive covenants, neighborhood investment or disinvestment, federal investment such as transportation infrastructure, demographic trends or any other information that supplements the reported data and assists in a complete analysis.

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Contributing Factors: Upon a full analysis of the AFFH section, the element should re-evaluate contributing factors to fair housing issues. In addition, the element lists several contributing factors, but it should also prioritize those contributing factors.

Goals, Actions, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have specific commitment, metrics, and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection. Additionally, the element should provide more specific commitment and concrete actions in existing programs. For instance, for housing mobility and new housing opportunities in high resource areas, the element should clarify what type of incentives will be provided, what collaboration will look like, and timing for these incentives and concessions. Additionally, for place-based strategies, the element should be more specific regarding City actions to support investments. Lastly, the element should look to add actions with respect to displacement risk.

2. Include an analysis of population and employment trends and documentation of projections and a quantification of the locality's existing and projected needs for all income levels, including extremely low-income households. (Gov. Code, § 65583, subd. (a)(1).) While the element provides information regarding extremely low-income (ELI) households, it must still analyze their existing housing needs. This is particularly important given the unique and disproportionate needs of ELI households. For example, the element should analyze tenure, cost burden, overcrowding and other household characteristics then examine trends and the availability of resources to determine the magnitude of gaps in housing needs.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov.

Code, § 65583, subd. (a)(3).)
Suitability of Sites: The element should include additional information to demonstrate the suitability of sites. For example, Site 6 does not appear to have road access, and absent additional information, the feasibility of development is unclear. Also, Site 15 should be evaluated for consistency with the City’s development standards.

Realistic Capacity: The element explains trends related to residential development in commercial areas. However, the element should also address the likelihood or 100 percent nonresidential uses occurring and account for that likelihood in residential capacity calculations. This analysis could explain anticipated residential performance standards for residential development as part of rezoning or could analyze all development activity in

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these nonresidential zones, how often residential development occurs and adjust residential capacity calculations, policies, and programs accordingly Small Sites: For your information, sites below 0.5 acres are not deemed adequate to meet the lower-income RHNA absent analysis that development below 0.5 acres is appropriate to accommodate the lower-income housing need. These sites were not utilized toward demonstrating adequate sites to accommodate the lower-income RHNA and should not be utilized for the purposes of meeting no net loss law pursuant to Government Code section 65863.

Zoning for a Variety of Housing Types (Employee Housing): Zoning must be consistent with the Employee Housing Act (Health and Safety Code, § 17000 et seq.) or add or modify programs. Specifically, section 17021.5 requires employee housing for six or fewer employees to be treated as a single-family structure and permitted in the same manner as other dwellings of the same type in the same zone. The element notes farm employee housing is allowed as accessory to a permitted use, but this housing is excluded from most residential zones and does not appear to be permitted similar to single family uses.

Further, the element states that employee housing for six or fewer people is not referenced in zoning. As a result, the element should add or modify programs to amend zoning and explicitly permit employee housing for six or fewer persons in compliance with the Employee Housing Act.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures… (Gov. Code, § 65583, subd. (a)(5).)
Processing and Permit Procedures: The element describes that most residential development is subject to a Site Plan Review which is completed by the Community Development Director, Planning Commission or City Council. While the element describes the purpose of the Site Plan Review, it must also analyze the procedure for impacts on housing cost, supply, timing, and approval certainty. For example, the analysis should analyze what parameters determine the level of review (Director, Commission or Council), number of public hearings, approval findings and discuss whether objective standards, guidelines or other processes improve development certainty and mitigate cost impacts.

The element must demonstrate this process is not a constraint or include a program to address the constraint as appropriate.

In addition, the element mentions processing timeframes for ministerial review and reviews with streamlined CEQA review, but it should also list and analyze typical timeframes for other entitlements, particularly including Site Plan Review subject to Planning Commission or City Council and other relevant entitlements (e.g., conditional use permits, variances, rezones, general plan amendments).

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Housing for Persons with Disabilities: The element shows (Table 39) residential care facilities for seven or more persons are excluded in some zones allowing residential uses (e.g., RAP zone) and subject to a conditional use permit. The element should analyze these requirements as potential constraints on housing for persons with disabilities and include programs as appropriate to address identified constraints.

On/Off-Site Improvements: While the element provides information regarding required on and off-site improvements for typical developments, the element should identify and analyze the actual standards. For example, the element mentions required streets, but it should also explain and analyze street widths that could impact the supply and cost of housing.

Codes and Their Enforcement: The element explains the City adopted the 2016 edition of the building codes; however, the City should be using the 2019 edition. The element should either clarify which version is used or include a program to adopt the most recent version of the building code.

B. Housing Programs

1. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) As noted in Finding A3, the element does not include a complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types.

In addition, Program 1 (Adequate Sites for RHNA) is intended to make zoning available to accommodate the RHNA for lower- and moderate-income households. With respect to lower-income households, the Program must address all by right requirements pursuant to Government Code section 65583.2, subdivisions (h) and (i). For example, the Program should clarify permitting multifamily development without discretionary review, minimum densities, permitting at least 16 units per site and performance standards to ensure residential development. In addition, the element should commit to rezone a minimum amount of acreage and ensure development standards will facilitate achieving maximum densities and will not constrain development.

2. The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income

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households. (Gov. Code, § 65583, subd. (c)(2).)
Farmworkers: The element states farmworker populations are significantly underestimated, including the Census and highlights the unique needs of farmworkers.

Then, the element concludes El Centro does not have a large farmworker population, seemingly based on Census data that underestimates need, and therefore, the housing needs can be addressed with other affordable housing programs. However, the element should address the significant housing needs of the broader region, including unique and disproportionate housing needs and include specific actions to assist in the development of housing for farmworkers. Actions could commit to be proactive and coordinate with nonprofit developers, employers, and other related organizations, to explore funding and incentives and to identify specific development opportunities.

3. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities.

The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding A4, the element requires a complete analysis of potential governmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

4. Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding A1, the element does not include a complete assessment of fair housing. Depending on a complete analysis, the element must add or revise programs as appropriate.

5. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).) Program Action 11 (Conservation of Existing and Future Affordable Units): In addition to providing technical assistance to qualified entities that can purchase development with units at-risk of conversion to market rate uses, the Program should commit to assist with funding or support applications for funding.

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C. Quantified Objectives
Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)
While the element includes quantified objectives for developments at-risk of conversion to market rate uses, the City is encouraged to consider, in its quantified objectives, the importance of conserving other existing affordable housing stock, such as housing choice vouchers (Program 10), efforts through code enforcement (Program 13) or place-based strategies toward community revitalization (Program 14).

D. Consistency with General Plan
The housing element shall describe the means by which consistency will be achieved with other general plan elements and community goals. (Gov. Code, § 65583, subd. (c)(7).)
While the element discusses how internal consistency within the general plan was achieved as part of the update of the housing element, it must also describe how consistency with the general plan is maintained. To meet this requirement, the City could consider an internal consistency review as part of its annual general plan implementation report required under Government Code section 65400.

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Attachment: Exhibit B - 11-4-2021_HCD Review Letter (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) P: (626) 381-9248
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101

VIA E-MAIL
December 14, 2021
El Centro Planning Commission
City Hall Council Chambers
1275 Main Street
El Centro, CA 92243
Em: [email protected]
RE: City of El Centro Draft 2021-2029 Housing Element Update Dear Chair Alvarez and Honorable Commissioners,
On behalf of the Southwest Regional Council of Carpenters (“Southwest Carpenters” or “SWRCC”), my Office is submitting these comments on Agenda Item No.2, the City of El Centro ’s (“City” or “Lead Agency”) draft 2021-2029 update to the City’s General Plan Housing Element (“Draft HEU” or “Project”).

The Southwest Carpenters is a labor union representing more than 50,000 union carpenters in six states and has a strong interest in well ordered land use planning and addressing the environmental impacts of development projects.

Individual members of the Southwest Carpenters live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.

SWRCC expressly reserve the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

SWRCC expressly reserve the right to supplement these comments at or prior to hearings on the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.

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SWRCC incorporate by reference all comments raising issues regarding the environmental documentation submitted prior to certification or adoption of the environmental documentation for the Project. Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App. 4th 173, 191 (finding that any party who has objected to the Project’s environmental documentation may assert any issue timely raised by other parties).

Moreover, SWRCC request that the Lead Agency provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (“CEQA”), Cal Public Resources Code (“PRC”) § 21000 et seq, and the California Planning and Zoning Law (“Planning and Zoning Law”), Cal. Gov’t Code §§ 65000–65010. California Public Resources Code Sections 21092.2, and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.

The City should require the use of a local skilled and trained workforce to benefit the community’s economic development and environment. The City should require the use of workers who have graduated from a Joint Labor Management apprenticeship training program approved by the State of California, or have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state approved apprenticeship training program or who are registered apprentices in an apprenticeship training program approved by the State of California.

Community benefits such as local hire and skilled and trained workforce requirements can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.

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March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.

Skilled and trained workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the UC Berkeley Center for Labor Research and Education concluded:
. . . labor should be considered an investment rather than a cost – and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Local skilled and trained workforce requirements and policies have significant environmental benefits since they improve an area’s jobs-housing balance, decreasing the amount of and length of job commutes and their associated greenhouse gas emissions. Recently, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program or a skilled and trained workforce with a local hire component” can result in air pollutant reductions.2
Cities are increasingly adopting local skilled and trained workforce policies and requirements into general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the City to “promote local hiring . . . to help achieve a more positive jobs-housing balance, and reduce regional commuting, gas consumption, and greenhouse gas emissions.”3
1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/defaultsource/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10. 3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-ca.gov/sites/default/files/documents/General_Plan_FINAL.pdf.

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In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the City “[c]ontribute to the stabilization of regional construction markets by spurring applicants of housing and nonresidential developments to require contractors to utilize apprentices from state-approved, joint labor-management training programs, . . .”4 In addition, the City of Hayward requires all projects 30,000 square feet or larger to “utilize apprentices from state-approved, joint labor-management training programs.”5
Locating jobs closer to residential areas can have significant environmental benefits. As the California Planning Roundtable noted in 2008:

People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.6
In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions since the skill requirements of available local jobs must be matched to those held by local residents.7 Some municipalities have tied local hire and skilled and trained workforce policies to local development permits to address transportation issues. As Cervero and Duncan note:

In nearly built-out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing.” The city’s First Source program encourages businesses to hire local residents, 4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-ca.gov/sites/default/files/Hayward%20Downtown% 20Specific%20Plan.pdf. 5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C). 6 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobshousing.pdf 7 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: JobsHousing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT825.pdf.

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especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment-ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.

The City should consider utilizing skilled and trained workforce policies and requirements to benefit the local area economically and mitigate greenhouse gas, air quality and transportation impacts.

I. CONCLUSION
Commenters request that the City consider the aforementioned issues raised. Please contact my Office if you have any questions or concerns.

Sincerely,
__________________________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attached:

March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).

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Attachment: Exhibit C - Comment Letters (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) CALIFORNIA RURAL LEGAL ASSISTANCE, INC.

FIGHTING FOR JUSTICE, CHANGING LIVES
El Centro Office
449 Broadway
El Centro, CA 92243
Tel: (760) 353-0220
Fax: (760) 353-8026
www.crla.org
Beatriz Garcia
Managing Attorney
(Health)
Adriane Bracciale
Staff Attorney
Jessica Moreno
Staff Attorney
Lupe Quintero
Director of Community
Workers
Diana Ponce
Administrative Legal
Secretary
Central Office
2201 Broadway Ste. 815
Oakland, CA 94612
Tel (415) 777-2752
Fax (415) 543-2752
www.crla.org
José R. Padilla
Executive Director
Ralph Santiago Abascal
General Counsel
(1934-1997)
William G. Hoerger
Ilene Jacobs
Michael Meuter
Cynthia Rice
Directors of Litigation,
Advocacy,
and Training
Regional Offices
Coachella
Delano
El Centro
Fresno
Gilroy
Lamont
Madera
Marysville
Modesto
Monterey
Oceanside
Oxnard
Paso Robles
Salinas
San Luis Obispo
Santa Barbara
Santa Cruz
Santa Maria
Santa Rosa
Stockton
Watsonville
January 14, 2022
Sent via email only [email protected]
Angel Hernandez, Associate Planner
Planning Division, City of El Centro
1275 W. Main Street
El Centro, CA 92243
Re: Comments on City of El Centro’s 6th Cycle 2021-2029 Draft Housing Element
Dear Mr. Hernandez:

California Rural Legal Assistance, Inc. (CRLA) represents low income individuals and families throughout rural California. The CRLA El Centro office addresses housing issues, including landlord-tenant disputes, habitability and fair housing complaints. We are writing on behalf of our client, to request that the City of El Centro comply with Housing Element Law.

This letter provides comments on the City of El Centro’s 6 th Cycle Housing Element
Draft to promote compliance with State Housing Element Law. CRLA raises the following concerns and reiterates the Department of Housing and Community Development (HCD) issues that were identified.

Please do not hesitate to contact us should you have any questions with respect to these comments. We can be reached at [email protected] and [email protected].

Sincerely,
CALIFORNIA RURAL LEGAL ASSISTANCE, INC.

Monica Sousa
Monica Sousa, Regional Director of Advocacy
145 E. Weber Avenue
Stockton, CA 95202
209-946-0605, Ext 2007
Patricia Fink
Patricia Fink, Legal Director – Rural Fair Housing and Foreclosure Prevention 141 N. A Street, Suite D
Arvin, CA 93203
cc: Ilene Jacobs, Director of Litigation and Advocacy & HCD

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Attachment: Exhibit C - Comment Letters (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) Comments on the City of El Centro’s 6th Cycle Draft Housing Element January 14, 2022

A. Housing Needs, Resources, and Constraints
Affirmatively Furthering Fair Housing Government Code section 65583 Affirmatively furthering fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction. (Gov. Code, § 65583, subd. (c)(10)(A)) In preparation for addressing this part of the Housing Element, the City held two Housing Element Workshop meetings to discuss the Housing Element process and solicit stakeholder and public comments. These meetings were followed by a Housing Element review community workshop. Notices of that meeting were advertised in English and Spanish on the City website, and flyers were distributed at public counters. However, the City failed to address fair housing issues by not making more meaningful outreach due to COVID-19 challenges, and failing to prepare outreach, presentation and materials more accessible to the indigenous and P’urepecha community.

1. Ensuring that Racial/Ethnic Areas of Concentration of Poverty (R/ECAP).

The element should relate input from the City’s various outreach efforts to the affirmatively furthering fair housing (AFFH) analysis, to better inform the contributing factors to fair housing issues, goals and actions.

The element includes some information on housing choice vouchers, but it must still include other relevant factors that contribute to fair housing issues in the jurisdiction. For instance, the element can analyze historical land use, zoning and investment practices, presence of redlining, restrictive covenants, neighborhood investment or disinvestment, federal investment such as transportation infrastructure, demographic trends or any other information that supplements the reported data and assists in complete analysis.

None of these sections describes how race or ethnicity factors into the special housing needs of each of the named groups and therefore this housing element is not able to comply with its obligations to affirmatively further fair housing.

2. Analysis of Population and Employment Trends
While the element provides information regarding extremely low-income (ELI) households, it must still analyze their existing housing needs. This is particularly important given the unique and disproportionate needs of ELI households. For example,

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the element should analyze tenure, cost burden, overcrowding and other household characteristics, then examine trends and the availability of resources to determine the magnitude of gaps in housing needs.

Similar analysis should occur with respect to the impacts that the COVID-19 pandemic has had on overcrowded housing in the City and across all income levels, particularly the impacts that low wage workers, such as farmworkers, have faced.

3. Inventory of Land Suitable for Development
An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)
The element should include additional information to demonstrate suitability of sites including appropriate road access.

4. Analysis of Constraints
a. Housing for Persons with Disabilities
The element should include an analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified for persons with disabilities. b. Restrictions
The element should analyze the stated requirements for residential care facilities with zoning restrictions and subject to conditional use permit, as potential constraints on housing for persons with disabilities; and include programs as appropriate to address identified constraints.
c. Address and Remove Constraints
Element should address constraints on housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).

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B. Housing Programs

1. Actions to Make Sites Available
The element should identify appropriate zoning and development standards along with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 655584.09.

The element should include a variety of types of housing for all income levels including multifamily rental housing, factory-built housing, mobile homes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).)

2. Programs for Development of Low-Income Housing Needs The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderateincome level households. (Gov. Code, § 65583, subd. (c)(2).) The element states that farmworker populations are significantly underestimated, (including the Census) and highlights the unique needs of farmworkers. Then, the element concludes El Centro does not have a large farmworker population, seemingly based on Census data that underestimates need, and therefore, the housing needs can be addressed with other affordable housing programs. However, the element should address the significant housing needs of the broader region, including unique and disproportionate housing needs; and include specific actions to assist in the development of housing for farmworkers.

3. Promote and Affirmatively Further Fair Housing
Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code § 65583, subd. (c)(5).)

4. Preserve Identified Housing Developments

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The housing program shall preserve for low-income households the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov. Code, § 65583, subd. (c)(6).) C. Quantified Objectives
The element should establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1) & 2). The City must consider the importance of conserving other existing affordable housing stock, such as housing choice vouchers.

D. Consistency with General Plan
The element must describe how consistency with the general plan is maintained. To meet this requirement, the City could consider an internal consistency review as part of its annual general plan implementation report required under Government Code section 65400.

In conclusion, we appreciate your serious consideration to ensure that the City’s proposed draft includes all regulatory and fair housing requirements to comply with the State Housing Element Law.

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Attachment: Exhibit C - Comment Letters (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) City of El Centro
2021-2029 Housing Element
January 2022
City of El Centro
Community Development Department
1275 W. Main Street
El Centro, CA 92243

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Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) City of El Centro
2021-2029 Housing Element
City Council
Tomas Oliva, Mayor
Martha Cardenas-Singh, Mayor Pro Tem
Cheryl Viegas-Walker, Council Member
Edgard Garcia, Council Member
Sylvia Marroquin, Council Member
Planning Commission
Ashley Bertussi, Chairperson
Andy Alvarez, Vice-Chairperson
Param Maroke, Commissioner
Evelia Jimenez, Commissioner
Jack Dunnam, Commissioner
Sergio Lopez, Commissioner
Aaron Popejoy, Commissioner
City Staff
Norma M. Villicaña, Director of Community Development
Christian Rodriguez, Assistant Planner
Angel Hernandez, Associate Planner
Yvonne Cordero, Planning Staff Assistant
Consultants
Veronica Tam and Associates, Inc.

CityPlace Planning

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2021-2029 Housing ElementPage i

TABLE OF CONTENTS

1. INTRODUCTION.............................................................................................................................. 1

1.1. LEGISLATIVE REQUIREMENTS .........................................................................................................1

1.2. RELATIONSHIP WITH OTHER GENERAL PLAN ELEMENTS ...........................................................2

1.3. PUBLIC PARTICIPATION.....................................................................................................................2

2. COMMUNITY PROFILE .................................................................................................................. 5

2.1. DEMOGRAPHIC PROFILE...................................................................................................................5

2.2. ECONOMIC PROFILE..........................................................................................................................7

2.3. HOUSEHOLD CHARACTERISTICS...................................................................................................10

2.4. HOUSING PROBLEMS.......................................................................................................................13

2.5. SPECIAL NEEDS................................................................................................................................17

2.6. HOUSING STOCK CHARACTERISTICS ...........................................................................................29

2.7. HOUSING COST AND AFFORDABILITY...........................................................................................34

2.8. AFFORDABLE HOUSING...................................................................................................................39

3. HOUSING CONSTRAINTS.............................................................................................................45

3.1. MARKET CONSTRAINTS...................................................................................................................45

3.2. GOVERNMENTAL CONSTRAINTS ...................................................................................................50

3.3. PUBLIC POLICY CONSTRAINTS ......................................................................................................77

3.4. UTILITY AND PUBLIC SERVICE CONSTRAINTS.............................................................................77

3.5. ENVIRONMENTAL CONSTRAINTS...................................................................................................80

4. HOUSING RESOURCES................................................................................................................81

4.1. FUTURE HOUSING NEEDS...............................................................................................................81

4.2. FINANCIAL RESOURCES..................................................................................................................89

4.3. ADMINISTRATIVE RESOURCES ......................................................................................................89

4.4. OPPORTUNITIES FOR ENERGY CONSERVATION.........................................................................90

5. HOUSING PLAN.............................................................................................................................92

5.1 GOALS AND POLICIES......................................................................................................................92

5.2 HOUSING PROGRAMS......................................................................................................................96

5.3 SUMMARY OF QUANTIFIED OBJECTIVES....................................................................................108

6. APPENDIX A: OUTREACH EFFORTS ........................................................................................A-1

7. APPENDIX B: REVIEW OF PAST ACCOMPLISHMENTS..........................................................B-1

8. APPENDIX C: SITES INVENTORY..............................................................................................C-1

9. APPENDIX D: AFFIRMATIVELY FURTHERING FAIR HOUSING..............................................D-1

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List of Tables
Table 1: Population Trends – El Centro and Neighboring Cities (2000-2021) ...............................................................5 Table 2: Population by Age Trends (2010-2019) ...........................................................................................................6 Table 3: Population by Race and Ethnicity (2019) .........................................................................................................7 Table 4: Employment by Industry Type (2015-2019).....................................................................................................7 Table 5: Employment by Commuting Patterns (2015-2019) ..........................................................................................8 Table 6: Household Income (2000-2019).......................................................................................................................9 Table 7: Median Household Income Trends (2000-2019)............................................................................................10 Table 8: Households by Income Categories (2014-2018)............................................................................................10 Table 9: Household Trends (2000-2019) .....................................................................................................................11 Table 10: Average Persons-Per-Household Trends (2010-2019)................................................................................12 Table 11: Household Size Trends (2010-2019) ...........................................................................................................12 Table 12: Tenure (2010-2019) .....................................................................................................................................13 Table 13: Housing Type by Tenure (2015-2019) .........................................................................................................13 Table 14: Housing Assistance Needs of Lower Income Households (2013-2017) ......................................................15 Table 15: Overcrowded Units by Tenure (2015-2019).................................................................................................17 Table 16: Special Needs Groups (2015-2019).............................................................................................................18 Table 17: Senior Population Trends (65+) (2000-2019)...............................................................................................19 Table 18: Senior Household Trends (65+) (2010-2019) ..............................................................................................19 Table 19: Disabilities Tallied (2015- 2019)...................................................................................................................21 Table 20: Household Type and Presence of Children 18 Years Old and Under (2015-2019) .....................................23 Table 21: Households by Poverty Level (2015-2019) ..................................................................................................24 Table 22: Farm workers (2000-2019)...........................................................................................................................25 Table 23: Homeless Resources in El Centro ...............................................................................................................28 Table 24: Housing Unit Growth (2000-2021)................................................................................................................30 Table 25: Housing Age.................................................................................................................................................32 Table 26: Changes in Median Home Sale Prices (2011-2021)....................................................................................35 Table 27: Median and Average Rents by Number of Bedrooms (2021).......................................................................36 Table 28: Affordable Housing Costs by Household Size and Tenure (2021)...............................................................38 Table 29: Assisted Housing In El Centro (2021) ..........................................................................................................40 Table 30: Market Value of At-Risk Housing Units ........................................................................................................42 Table 31: Rental Subsidies Required...........................................................................................................................43 Table 32: Estimated New Construction Costs..............................................................................................................44 Table 33: Disposition of Home Loans (2017)...............................................................................................................48 Table 34: Land Use Designations that Allow Residential Uses....................................................................................51 Table 35: Zoning Districts that Allow Residential Uses................................................................................................55 Table 36: Development Standards by Zoning District (Residential Zones)..................................................................56 Table 37: Development Standards by Zoning District (Commercial Zones).................................................................57 Table 38: Off-Street Residential Parking Requirements ..............................................................................................59 Table 39: Provision for a Variety of Housing Types (Residential Zones ......................................................................59 Table 40: Provision for a Variety of Housing Types (Commercial Zones)....................................................................60 Table 41: Permit Processing Fees ...............................................................................................................................67 Table 42: Development Impact Fees ...........................................................................................................................68 Table 43: Development Fees for a Typical Unit ...........................................................................................................68 Table 44: Credits Toward RHNA..................................................................................................................................82 Table 45: El Centro General Plan Update Residential Development Capacity ............................................................83 Table 46: Average Density for Multi-Family Housing ...................................................................................................86 Table 47: Adequacy of Sites to Accommodate the 2021-2029 RHNA by Land Use Designation ................................88 Table 48: Adequacy of Sites to Accommodate the 2021-2029 RHNA .........................................................................89 Table 49: Fair Housing Issues and Actions................................................................................................................106 Table 50: Quantified Objectives .................................................................................................................................109

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2021-2029 Housing ElementPage iii
Table A- 1: Outreach List ...........................................................................................................................................A-1 Table A- 2: Service Provider Focus Group Comments ..............................................................................................A-2 Table A- 3: Developer Focus Group Comments and Responses ..............................................................................A-3 Table B- 1: Objectives and Accomplishments............................................................................................................ B-1 Table B- 2: Review of Past Program Accomplishments.............................................................................................B-2 Table C- 1: 2021-2029 Sites Inventory ......................................................................................................................C-1 Table D- 1: Race/Ethnicity Composition-Regional Comparison.................................................................................D-8 Table D- 2: Dissimilarity Indices for Imperial County (1990-2020).............................................................................D-8 Table D-3: Race/Ethnicity Composition Changes (2010-2019)................................................................................D-12 Table D-4: Dissimilarity Indices City of El Centro (1990-2020) ................................................................................D-12 Table D-5: RHNA Unit Distribution by % Minority Concentration .............................................................................D-15 Table D-6 RHNA Unit Distribution by % Population with Disabilities........................................................................D-17 Table D-7: Household (HH) Types with Children- Region........................................................................................D-19 Table D- 8: RHNA Unit Distribution by Percent Children in Married-Couple Households ........................................D-25 Table D- 9: RHNA Unit Distribution by Percent Children in Single Female-Headed Households ............................D-25 Table D- 10: RHNA Unit Distribution by LMI Population ..........................................................................................D-29 Table D-11: Domains and List of Indicators for Opportunity Maps...........................................................................D-38 Table D-12: TCAC Composite Scores- Region........................................................................................................D-39 Table D-13: RHNA Unit Distribution by TCAC Opportunity Area .............................................................................D-40 Table D- 14: Housing Problems and Cost Burden - Imperial County.......................................................................D-58 Table D- 15: Housing Problems, Elderly and Large Households, Imperial County ..................................................D-59 Table D-16: Housing Problems and Cost Burden- City of El Centro........................................................................D-62 Table D-17: Housing Problems, Elderly and Large Households, City of El Centro..................................................D-62 Table D- 18: RHNA Unit Distribution by Cost-Burdened Homeowner Households..................................................D-65 Table D-19: RHNA Unit Distribution by Cost-Burdened Owner Households............................................................D-65 Table D-20: Overcrowded Households- Imperial County.........................................................................................D-66 Table D-21: Overcrowded Households- City of El Centro........................................................................................D-68 Table D-22: RHNA Unit Distribution by Overcrowded Households..........................................................................D-68 Table D- 23: Loan Applications and Approvals by Race (2017)...............................................................................D-74

LIST OF FIGURES
Figure 1: Senior Households by Tenure (2010-2019)..................................................................................................19 Figure 2: Distribution of Housing Units (2000-2010-2019)...........................................................................................31 Figure 3: Vacant Units by Housing Type (2010-2019) .................................................................................................32 Figure 4: Median Home Sales Prices (2021) ...............................................................................................................36 Figure 5: Income Needed to Afford Housing Compared to Wages .............................................................................39 Figure 6: Imperial County Housing Building Permits (2001-2019) ...............................................................................46 Figure C- 1: Sites Inventory Quadrant Key ................................................................................................................C-0 Figure C- 2: Sites Inventory - Quadrant One..............................................................................................................C-1 Figure C- 3: Sites Inventory - Quadrant Two..............................................................................................................C-2 Figure C- 4: Sites Inventory - Quadrant Three...........................................................................................................C-3 Figure C- 5: Sites Inventory - Quadrant Four.............................................................................................................C-4 Figure D-1: Minority Concentration by Block Group – Imperial County......................................................................D-9 Figure D-2: Racial and Ethnic Majorities by Census Tract - Imperial County...........................................................D-10 Figure D-3: Racial and Ethnic Majorities by Census Tract- City of El Centro...........................................................D-12 Figure D-4: RHNA Unit Distribution by Minority Concentration - City of El Centro...................................................D-14 Figure D-5: Population with Disabilities- Region ......................................................................................................D-16 Figure D-6: RHNA Unit Distribution by Concentration of Persons with Disability.....................................................D-18 Figure D-7: Children in Married Households- Region ..............................................................................................D-20

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Figure D-8: Children in Single Female-Headed Households- Region......................................................................D-21 Figure D-9: Children in Married-Couple Households- City of El Centro ...................................................................D-23 Figure D-10: Children in Single Female-Headed Households- City of El Centro .....................................................D-24 Figure D-11: Low and Moderate Income Population – Region ................................................................................D-27 Figure D-12: Low and Moderate Income Population- City El Centro .......................................................................D-28 Figure D-13: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) - Region .....................................D-30 Figure D-14: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) - El Centro..................................D-33 Figure D-15: Median Income – Region ....................................................................................................................D-36 Figure D- 16: Median Income - City of El Centro .....................................................................................................D-37 Figure D-17: TCAC Opportunity Areas- City of El Centro ........................................................................................D-41 Figure D-18: TCAC Education Scores- Region........................................................................................................D-44 Figure D-19: GreatSchools Ratings .........................................................................................................................D-46 Figure D- 20: TCAC Education Score- City of El Centro..........................................................................................D-47 Figure D-21: AllTransit Score- City of El Centro.......................................................................................................D-49 Figure D-22: Transit Stops within ½ Mile – City of El Centro ...................................................................................D-49 Figure D-23: Jobs Proximity Index- Region..............................................................................................................D-51 Figure D-24: TCAC Economic Score- Region..........................................................................................................D-52 Figure D- 25: Jobs Proximity Index – City of El Centro............................................................................................D-54 Figure D- 26: TCAC Economic Score- City of El Centro..........................................................................................D-55 Figure D-27: TCAC Environmental Score- Region...................................................................................................D-56 Figure D-28: TCAC Environmental Score- City of El Centro....................................................................................D-57 Figure D-29: Cost Burdened Renters and Owners (2019) – Region........................................................................D-60 Figure D-30: Cost Burdened Owners and Renters (2019) - City of El Centro..........................................................D-63 Figure D-31: Overcrowded Households - Region ....................................................................................................D-67 Figure D-32: Overcrowded Households- City of El Centro.......................................................................................D-69 Figure D-33:Median Year Structure Built – City of El Centro ...................................................................................D-70 Figure D-34: Residential Parcels by 2009 Rehabilitation Need ...............................................................................D-71 Figure D-35: Sensitive Communities- Region ..........................................................................................................D-72 Figure D- 36: Sensitive Communities- City of El Centro ..........................................................................................D-73 Figure D-37: Disadvantaged Communities- City of El Centro..................................................................................D-76 Figure D-38: HCV Concentration- City of El Centro.................................................................................................D-77 Figure D-39: Median Gross Rent/ Affordability Index - City of El Centro..................................................................D-78

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2021-2029 Housing Element Page 1

1. Introduction

1.1. Legislative Requirements
The Housing Element is one of seven elements required to be included in the City’s General Plan.

State law identifies the subjects that must be addressed in a Housing Element. These guidelines are identified in Article 10.6 of the State of California Government Code (Sections 65580 et seq.).

State law specifies that the Housing Element must assess housing needs and evaluate the current housing market in the City and then identify programs that will meet housing needs. The housing market evaluation includes a review of housing stock characteristics as well as housing cost, household incomes, special need households, availability of land and infrastructure and various other factors. Also included in this evaluation is the community’s “Regional Housing Needs Allocation” (RHNA) which provides an estimate of the number of housing units that should be provided in the community to meet its share of new households in the region. In addition to this information, the Housing Element document must evaluate and review its past housing programs and consider this review in planning future housing strategies.

The City’s previous Housing Element was adopted in 2013. Until recently, Housing Elements have been required to be updated every five years, unless otherwise extended by State law. Senate Bill 375, enacted in 2008, established an eight-year cycle for housing element updates. The statutory planning period for this Housing Element begins on October 15, 2021 and extends through October 15, 2029. However, the RHNA period begins June 30, 2021, and extends through October 15, 2029.

The 2021-2029 Housing Element is subject to review by the California Department of Housing and Community Development (HCD) for compliance with applicable State laws. A critical component of HCD’s review of the Housing Element is the local jurisdiction’s ability in accommodating its RHNA through land use planning efforts. Compliance with this requirement is measured by the jurisdiction’s ability in providing adequate land with adequate density and appropriate development standards to accommodate the RHNA. The Southern California Association of Governments (SCAG), as the regional planning agency, is responsible for allocating the RHNA to individual jurisdictions within the region.

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For the 2021-2029 Housing Element update for the City of El Centro, SCAG has assigned a RHNA of 3,442 units, in the following income distribution:
▪ Extremely Low/Very Low Income:1 1,001 units
▪ Low Income: 490 units
▪ Moderate Income: 462 units
▪ Above Moderate Income: 1,489 units
The City must demonstrate its ability to accommodate the RHNA in this Housing Element.

1.2. Relationship with Other General Plan Elements
The General Plan for the City of El Centro has eight elements in addition to this Housing Element. In June 2021, the City adopted updated Land Use and Mobility Elements, and added a new Environmental Justice Element. The other General Plan elements include Economic Development, Conservation/Open Space, Public Facilities, Safety, and Noise, and were adopted in 2004. The General Plan includes both mandatory elements plus two optional elements, as permitted by State law. Internal consistency is required by State law among the various elements of the General Plan, including the Housing Element. This 2021-2029 Housing Element is consistent with the adopted General Plan.

California Senate Bill 1241 (SB 1241) was passed by the California legislature in 2012, which required jurisdictions to update their Safety Elements upon the next revision of the Housing Element, on or after January 1, 2014. The City will ensure compliance with this requirement by updating its Safety Element. To maintain internal consistency among all General Plan elements, the City will conduct a consistency review annually as part of its report on the General Plan implementation and identify necessary revisions.

1.3. Public Participation
The City of El Centro offers ample opportunities for the public to comment on housing-related issues and on the Draft 2021-2029 Housing Element. A list of agencies and organizations contacted to participate in the planning process and detailed summary of comments is contained in Appendix A. Due to the COVID-19 pandemic, public engagement was held virtually. 1 The City has a RHNA allocation of 1,001 very low income units (inclusive of extremely low income units). Pursuant to AB 2634, the City must project the number of extremely low income housing needs based on Census income distribution or assume 50 percent of the very low income units as extremely low. Assuming an even split, the City’s RHNA allocation of 1,001 very low income units may be divided into 501 very low and 500 extremely low income units. However, for purposes of identifying adequate sites for the RHNA, State law does not mandate the separate accounting for the extremely low income category.

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A. Housing Element Workshops
The City conducted two Housing Element Workshops on February 8, 2021 and May 19, 2021 to discuss the Housing Element update process and solicit stakeholder and public comments on housing issues and needs. The following topics were covered at each Workshop:
• February 8, 2021: Introduction to the Housing Element Update process, requirements, RHNA units, and possible strategies to meet RHNA.
• May 19, 2021: Review strategies to meet RHNA, including location of sites, and review Housing Programs.
• August 19, 2021: Review Draft Housing Element, including overview of Housing Element, strategies to meet RHNA, housing programs, AFFH findings, and next steps in the review and adoption process. Attendees were informed the draft would be available starting Monday August 23 for public review.

Notices of the meeting were published in English and Spanish in the Imperial Valley Press. The notices were also posted on City website and flyers were made available at public counters. In addition, special invitations were sent to housing developers, advocates, community stakeholders, and agencies that serve the housing and supportive service needs of lower and moderate income persons, as well as those with special housing needs. Agencies and organizations invited to attend the study session are listed in Appendix A. The meetings were attended by members of the public and representatives of the development community and nonprofit organizations.

B. Stakeholder Interviews
A number of developers and service providers that are active in El Centro were contacted by to discuss El Centro’s housing issues and needs. Three focus group interviews were held on:
• March 30, 2021 - service providers
• April 1, 2021 - developers
• April 21, 2021 - CLB, a nationwide mall developer that owns the Imperial Valley Mall (IVM) and additional property north of the IVM in El Centro The list of organizations interviewed, and a summary of each conversation is included in Appendix A.

C. Draft Housing Element Review

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The City conducted a community workshop on August 19, 2021 to review the draft Housing Element. To solicit input from supportive service and housing providers, the City sent special notices of the public meeting to housing developers and professionals, as well as agencies that serve or represent the interest of lower and moderate income households and persons with special housing needs. The City also advertised the availability of the Housing Element for public review in English and Spanish in the Imperial Valley Press and in Spanish in the Adelante Valle, a Spanish language newspaper. The Housing Element outreach list is presented in Appendix A.

The Draft Housing Element was then made available to the public for review beginning August 23, 2021.

D. Adoption Hearings
For the adoption of the 2021-2029 Housing Element, the City will conduct public hearings before the Planning Commission and City Council in November-December, 2021.

E. Summary of Public Comments and City Responses
Affordable housing, especially for lower income, seniors, large households, and persons with disabilities are among some of the key issues raised during the public participation process of this Housing Element update. Public service providers also brought up the need for more fair housing protection for special needs groups. Not only is there a need for more affordable housing, but housing of different types and other housing assistance like closing costs, rental assistance, neighborhood clean-up, habitability. On the other hand, developers expressed that long processing periods and high fees were a constraint for development in the City. A full summary of comments and City responses is found on Appendix A.

The Housing Element addresses these needs through a variety of programs targeted to conserve the existing affordable housing stock, facilitate construction of new affordable housing, and coordinate with and fund social service agencies, including organizations that support extremely low income seniors and persons with disabilities.

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2.Community Profile
The purpose of this section is to summarize and analyze the existing housing conditions in the City of El Centro. This section contains an analysis of population trends, employment trends, household trends and special needs groups within the City.

2.1. Demographic Profile
When evaluating housing needs, analysis of demographic variables such as population, employment, and households is essential in order to assess the present and future housing needs of a city or county. This section presents data gathered from the following sources: U.S. Census Bureau, American Community Survey (ACS), Comprehensive Housing Affordability Strategy (CHAS), U.S. Department of Housing and Urban Development (HUD), California Department of Housing and Community Development (HCD), California Employment Development Department, Southern California Association of Governments (SCAG), Imperial Valley Housing Authority (IVHA), DataQuick, and Craigslist.org.

A. Population Trends

Between 2000 and 2010, the population in El Centro increased by 4,763 residents (or 12.6 percent), from 37,835 to 42,598 residents, an increase of over one percent every year. As shown in Table 1, over the subsequent decade, from 2010 to 2021, the population increased by an additional 1,913 persons (or 5.6 percent) for a low annual growth rate of approximately 0.5 percent. El Centro is the largest City in Imperial County and the seat of County Government and its growth rate was similar to the County’s growth rate between 2010 and 2021 (6.6 percent). The City’s growth rate was also similar to most of the County’s incorporated cities. However, Imperial and Brawley both saw higher increases in population than the City of El Centro and the County overall.

Table 1: Population Trends – El Centro and Neighboring Cities (2000-2021) City 2000 2010 2021
Change
(2010-2021)
# of Persons % Change
El Centro 37,835 42,598 44,997 2,399 5.6%
Calexico 27,109 38,572 40,485 1,913 5.0%
Brawley 22,052 24,953 27,326 2,373 9.5%
Imperial 7,560 14,758 20,289 5,531 37.5%
Holtville 5,612 5,939 6,236 297 5.0%
Westmorland 2,131 2,225 2,305 80 3.6%
Imperial County 142,361 174,528 186,034 11,506 6.6%
Source: U.S. Bureau of the Census, 2000-2010, California Department of Finance, 2021 Population Estimates.

B. Age Trends

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As shown in Table 2, over the last ten years, the City of El Centro has experienced an increase in the number of persons in almost every age group. A 3.3 percent increase occurred in the middle age and older adult age groups (ages 50+), with one percent more residents being over 85. El Centro residents ages 30 and under continue to represent a large proportional share of the City’s population, although their share decreased 1.9 percentage points from 47.9 percent to 46 percent.

The largest share of residents in 2010 was between 10 and 14. In 2019 this was still the largest share of the population, but the percentage went down by a half percent. As of 2019, the median age in the City was 32.9 years of age, which is significantly older than the median age in 2010.

Table 2: Population by Age Trends (2010-2019)
Age Group 2010 2019
# of Persons % of Total # of Persons % of Total
Under 5 Years 3,368 8.1% 3,681 8.4%
5-9 Years 3,451 8.3% 3,490 7.9%
10-14 Years 3,784 9.1% 3,767 8.6%
15-19 Years 3,701 8.9% 3,311 7.5%
21-24 Years 2,869 6.9% 3,122 7.1%
25-29 Years 2,744 6.6% 2,870 6.5%
30-34 Years 2,453 5.9% 3,100 7.0%
35-39 Years 2,661 6.4% 2,263 5.1%
40-44 Years 2,453 5.9% 2,967 6.7%
45-49 Years 2,952 7.1% 2,187 5.0%
50-54 Years 2,952 7.1% 2,365 5.4%
55-59 Years 2,329 5.6% 2,635 6.0%
60-64 Years 1,580 3.8% 2,371 5.4%
65-69 Years 1,289 3.1% 2,038 4.6%
70-74 Years 1,123 2.7% 1,340 3.0%
75-79 Years 915 2.2% 1,098 2.5%
80-84 Years 582 1.4% 574 1.3%
85+ Years 374 0.9% 824 1.9%
Total 41,581 44,003
Median Age 29.9 32.9
Source: ACS 2005-2010 5-year estimates, ACS 2013-2019 5-year estimates

C. Race/Ethnicity
In 2019, the racial/ethnic composition of City residents was similar to that of County residents, however the City has a larger Hispanic or Latino population by 2.8 percent. As shown in Table 3, approximately 87 percent of the City’s population categorized themselves as Hispanic (of any race) with the remaining population identifying themselves as non-Hispanic (of one or more races). The County has a higher percentage of white people by 2.3 percent, while the County has a larger Black or African American population.

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Table 3: Population by Race and Ethnicity (2019)
Category City of El Centro Imperial County
# of Persons % of Total # of Persons % of Total
Not Hispanic or Latino 5,702 13.0% 28,529 15.8%
White 3,654 8.3% 19,228 10.6%
Black or African American 602 1.4% 3,882 2.1%
American Indian/Alaska Native 42 0.1% 1,104 0.6%
Asian 980 2.2% 2,367 1.3%
Native Hawaiian/Pacific Islander 79 0.2% 240 0.1%
Other Races or 2+ Races 345 0.8% 1,708 0.9%
Hispanic or Latino (any race) 38,301 87.0% 152,172 84.2% Total 44,003 100.0% 180,701 100.0%
Source: ACS 2013-2019 5-year estimates

2.2. Economic Profile
A. Employment
According to the 2015-2019 American Community Survey (ACS), the City’s labor force in 2019 consisted of 18,067 people and the unemployment rate was 13.1 percent. The occupational category employing the most El Centro residents was management, business, science, and arts, which employed 28.9 percent of the City’s workforce (see Table 4). In terms of total employment, service occupations were the second largest occupational category in El Centro.

Table 4: Employment by Industry Type (2015-2019)
Occupational Category
2015-2019
% of Employed
Persons
Management, Business, Science, and Arts Occupations 28.9% Service Occupations 22.6%
Sales and Office Occupations 23.5%
Natural Resources, Construction, and Maintenance Occupations 12.2% Production, Transportation, and Material Moving Occupations 12.9% Source: American Community Survey (ACS), 2015-2019
As shown in Table 5, between 2015 and 2019, most of the City’s labor force lived fairly near their place of employment. The mean travel time to work was 18 minutes; approximately 50.2 percent of commuters in the City traveled less than 15 minutes each way to work and 21.3 percent commuted less than 10 minutes.

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Table 5: Employment by Commuting Patterns (2015-2019)
Commute to Work % of Employed Persons
Less than 10 minutes 21.3%
10 to 14 minutes 28.9%
15 to 19 minutes 18.6%
20 to 24 minutes 11.9%
25 to 29 minutes 4.1%
30 to 34 minutes 6.8%
35 to 44 minutes 1.9%
45 to 59 minutes 2.5%
60 or more minutes 3.9%
Mean travel time to work (minutes) 18.0
Source: American Community Survey (ACS), 2015-2019
According to the 2015-2019 ACS, only 14 persons (or less than one percent of employed persons in the City) were classified as military personnel. However, Naval Air Facility (NAF) El Centro is a military airport and training facility located just outside city limits, approximately six miles northwest of the City. The facility was initially commissioned on May 1, 1946, as a Naval Air Station. Prior to that, the base was a Marine Corps Air Station. For the first 35 years of its existence, the mission of NAF El Centro was devoted to aeronautical escape system testing, evaluation, and design. Over time, the facility has developed into an integral part of Naval Aviation Training.

Today, NAF El Centro provides realistic training to active and reserve military units. Squadrons visit the installation and its associated ranges to practice gunnery, bombing, carrier landings and air combat.

According to the 2014 NAF-El Centro Joint Land Use Study, the installation provides employment for more than 597 government personnel (including 303 civilians) who live there year-round to serve the 1,600 military personnel in training at NAF in any given month. These military personnel come from Navy, Marine Corps, Army, and Air Force installations throughout the United States. Foreign military services also send personnel to train at NAF El Centro. Many of these training deployments extend over 30 days, and the military personnel are dependent on many local businesses and services during their training deployments.

NAF contributes over $105 million to the local economy each year ($24M in payroll, $4M in taxes and $77M in industrial output). It also provides Fleet and Family Support programs that assist with housing, social services, children’s programs and food.

B. Household Income

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In 1989, a significant percentage of households in the City (32.1 percent) had annual incomes less than $25,000 per year. In that same year, households with annual incomes over $75,000 accounted for 15.5 percent of total households. Between 1989 and 2000, the City’s households became increasingly stratified economically. There were noticeable increases in the overall number and proportion of households with lower (less than $25,000) and higher incomes ($75,000 and greater), while the proportion of households earning middle incomes ($25,000 to $74,999) decreased.

Between 2000 and 2011, the percentage of those earning less than $25,000 increased (from 15.9 to

17.5 percent), and between 2011 and 2019, it decreased to a level lower than in 2000 (from 17.5 back down to 13.9 percent). During this same time, the percentage of people earning in the middle of the range of income – from 25,000 to $75,000 – decreased significantly, by 9.5 percent. From 2011 to 2019, this income range regained some ground, but was still 6.3 percent less than in 2000.

Between 2000 and 2011, the percentage of those earning above $75,000 increased dramatically, by

11.5 percent. This trend continued through 2019 as the percentage of higher income residents increased by another 4.3 percent.

Although El Centro’s distribution of household income roughly mirrored the countywide distribution, the income profile of El Centro’s households differed significantly from households throughout the State. The 2015-2019 ACS reported that 14.9 percent of California households had incomes below $25,000 (compared to 29.6 percent in El Centro) and 40.5 percent of statewide households had incomes over $100,000 (compared to 20.3 percent in El Centro).

Table 6: Household Income (2000-2019)
Income Ranges
2000 2010 2019
# of
Households % of Total # of Households % of Total # of Households % of Total Less Than $10,000 1,586 13.9% 1,294 9.9% 673 5.8%
$10,000-$14,999 1,071 9.4% 1,268 9.7% 1,156 9.9%
$15,000-$24,999 1,818 15.9% 2,292 17.5% 1,614 13.9%
$25,000-$34,999 1,401 12.2% 1,349 10.3% 1,023 8.8%
$35,000-$49,999 1,789 15.6% 1,491 11.4% 1,643 14.1%
$50,000-$74,999 2,089 18.2% 1,935 14.8% 1,955 16.8%
$75,000-$99,999 842 7.4% 1,337 10.2% 1,213 10.4%
$100,000+ 853 7.5% 2,126 16.2% 2,348 20.3%
Total 11,449 100.0% 13,092 100.0% 11,625 100.0%
Source: U.S. Bureau of the Census, 2000-2010, American Community Survey (ACS), 2015-2019 In 2019, Imperial County’s median income was $53,424; the median income in the City of El Centro was higher than the County median (see Table 7). The City’s median income increased substantially - by 39.5 percent - between 2011 and 2019. The City of El Centro became more affluent relative to the County because of the larger number of higher income earners.

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Table 7: Median Household Income Trends (2000-2019)
Year Median Income $ Change % Change Annual % Change
City of El Centro
2000 $41,534
2011 $38,297 -$3,237 -7.8% -0.7%
2019 $53,424 $15,127 39.5% 4.9%
Imperial County
2000 $38,724
2011 $39,402 $678 1.8% 0.2%
2019 $47,622 $8,220 20.9% 2.4%
Sources: U.S. Bureau of the Census, 2000; American Community Survey (ACS), 2015-2019

For planning and funding purposes, the State Department of Housing and Community Development (HCD) categorizes households into five income groups based on the County Area Median Income (AMI):
▪ Extremely Low Income – up to 30 percent of AMI
▪ Very Low Income – 31 to 50 percent of AMI
▪ Low Income – 51 to 80 percent of AMI
▪ Moderate Income – 81 to 120 percent of AMI
▪ Above Moderate Income – greater than 120 percent of AMI Combined, extremely low, very low, and low income households are often referred to as lower income households.

The Southern California Association of Governments (SCAG) tabulated household income data by using the 2014-2018 ACS. As shown in Table 8, 43 percent of the City’s households earned lower incomes, similar to Imperial County households. SCAG data does not separately identify the extremely low income group.

Table 8: Households by Income Categories (2014-2018)
Income Group City of El Centro Imperial County
Very Low (31 to 50%) 27% 27%
Low (51 to 80%) 16% 15%
Moderate (81 to 120%) 15% 14%
Above Moderate (>120%) 42% 44%
Source: SCAG RHNA Calculator, March 2021

2.3. Household Characteristics

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A household is defined as all persons occupying a housing unit. Families are a subset of households, and include all persons living together who are related by blood, marriage, or adoption. Single households include persons living alone in housing units, but do not include persons in group quarters such as convalescent homes or dormitories. Other households are unrelated people living together, such as roommates. Household characteristics play an important role in defining community needs. Household type, income and tenure can help to identify special needs populations as well as other factors that affect the housing needs of a community.

A. Household Type and Size
Household types and sizes can change even in periods of static population growth as adult children leave home, married couples divorce, or with the general aging of the population. El Centro’s growth rate has been lower than the growth rate of the County.

According to data gathered from the Census and the ACS (see Table 9), between 2000 and 2010, the number of households in the County increased by 24.7 percent to 49,126 units. During the same time, the number of households in the City increased only by 14.6 percent. Between 2010 and 2019, the number of households in the City of El Centro decreased by 1,669 (or 11.3 percent), while the County’s decreased by 8.7 percent. These decreases, however, may partially be a result of the American Community Survey data that tends to have large margins of errors for small communities.

Table 9: Household Trends (2000-2019)
Year # of Households # Change % Change Annual % Change
City of El Centro
2000 11,439
2010 13,108 1,669 14.6% 1.5%
2019 11,625 -1,483 -11.3% -1.3%
Imperial County
2000 39,384
2010 49,126 9,742 24.7% 2.5%
2019 44,829 -4,297 -8.7% -1.0%
Source: U.S. Bureau of the Census, 2000-2010, American Community Survey (ACS), 2015-2019 Household size is a significant factor in housing demand. Often, household size can be used to predict the unit size that a household will select. For example, small households (one and two persons per household) traditionally can find suitable housing in units with up to two bedrooms while large households (five or more persons per household) can usually find suitable housing in units with three to four bedrooms. During the previous decade, the average household size in both El Centro and the County increased (see Table 10).

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Table 10: Average Persons-Per-Household Trends (2010-2019) Year City of El Centro County
2010 3.09 3.34
2019 3.74 3.81
Source: ACS 2006-2010, ACS 2015-2019
This is the case even though the number of two-person El Centro households increased the most (see Table 11). Four-person households in the City also increased, while the number of large households (those with five people or more) decreased in both the City and the County. One- and two-person households increased in the County between 2010 and 2019.

Table 11: Household Size Trends (2010-2019)
Household
Size
2010 2019
# of Households % of Total # of Households % of Total
City of El Centro
1-Person 2,156 18.8% 2,185 18.8%
2-Person 2,584 22.6% 3,272 28.1%
3-Person 2,013 17.6% 1,903 16.4%
4-Person 2,049 17.9% 2,233 19.2%
5-Person 1,445 12.6% 1,195 10.3%
6+ Person 1,192 10.4% 837 7.2%
Imperial County
1-Person 6,724 17.1% 9,235 20.6%
2-Person 9,067 23.0% 11,633 25.9%
3-Person 6,660 16.9% 7,847 17.5%
4-Person 7,161 18.2% 7,496 16.7%
5-Person 5,117 13.0% 4,618 10.3%
6+ Person 4,655 11.8% 4,000 8.9%
Source: U.S. Bureau of the Census, 2010, ACS 2015-2019
B. Housing Tenure
Housing tenure refers to whether a unit is owned or rented. Tenure is an important market characteristic because it is directly related to housing types and turnover rates. The tenure distribution of a community’s housing stock can be an indicator of several aspects of the housing market, including the affordability of units, household stability and residential mobility among others. In most communities, tenure distribution generally correlates with household income, composition and age of the householder.

Households in the City of El Centro in 2010 were almost equally split in terms of tenure, with slightly under one-half of the City’s households owning their homes and slightly over one-half renting their homes. The County, in 2010, had 11.8 percent more owners than renters. As of 2019, the City of El Centro continues to have a lower proportion of owner-households than Imperial

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County (see Table 12) by 4.7 percent, but the percentage of owner-households in El Centro has increased 1.6 percent since 2010.

Table 12: Tenure (2010-2019)
Household Size El Centro County
# of Households % of Total # of Households % of Total
2010
Owners 6,488 49.5% 27,465 55.9%
Renters 6,620 50.5% 21,661 44.1%
2019
Owners 5,909 50.8% 26,772 55.5%
Renters 5,716 49.2% 21,460 44.5%
Source: U.S. Bureau of the Census, 2010-2019.

As shown in Table 13, more (61.3 percent) of owner-households resided in single-family detached residences, compared to the 36.5 percent of renter-households residing in single-family residences. A much greater proportion of renter-occupied housing is in multi-family buildings consisting of 3 units or more (51.9 percent of rental units compared to 26.6 percent owned units).

Table 13: Housing Type by Tenure (2015-2019)
Units in Structure Total
Units
OwnerOccupied
OwnerOccupied
%
RenterOccupied
Renter -
Occupied
%
1, Detached 7,127 5,038 61.3% 2,089 36.5%
1, Attached 194 80 1.7% 114 2.0%
2 305 8 2.6% 297 5.2%
3 or 4 818 61 7.0% 757 13.2%
5 to 9 797 0 8.4% 979 17.1%
10 or More 1,255 21 10.8% 1,234 21.6%
Mobile Home 947 562 8.1% 246 4.3%
Total 11,625 6,489 100.0% 5,716 100.0%
Source: U.S. Bureau of the Census, American Community Survey (ACS), 2015-2019

2.4. Housing Problems

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While the SCAG data presented on in Table 8 estimates the number of households that fall within each income level, it does not provide any detail on the specific housing needs and problems faced by these households. The Comprehensive Housing Affordability Strategy (CHAS) developed by the Census Bureau for HUD, however, provides detailed information on housing needs by income level for different types of households in El Centro. Detailed CHAS data based on the 2013-2017 ACS data is displayed in Table 14. Housing problems considered by CHAS include:
▪ Units with physical defects (lacking complete kitchen or bathroom); ▪ Overcrowded conditions (housing units with more than one person per room); ▪ Housing cost burden, including utilities, exceeding 30 percent of gross income; or ▪ Severe housing cost burden, including utilities, exceeding 50 percent of gross income.

Most lower and moderate income households cope with housing cost issues either by assuming a cost burden, or by occupying a smaller-than-needed or substandard unit. Specifically, according to HUD, 70 percent of all of the City’s lower income households were experiencing one or more housing problems (e.g. cost burden, overcrowding, or substandard housing condition) between 2013 and 2017.
2 The types of housing problems experienced by El Centro households vary according to household income, type, and tenure. Some highlights include:
▪ In general, renter-households had a higher level of any housing problems (57.3 percent) compared to owner-households (32.1 percent).
▪ Large renter-families had the highest level of housing problems regardless of income level (68.4 percent).
▪ Approximately 84 percent of all extremely low income (households earning less than 30 percent of the AMI) and 83 percent of very low income households (households earning between 31 and 50 percent of the AMI) had housing problems. ▪ Over half of extremely low income elderly renters and owners (59 percent and 52 percent, respectively) experience a severe housing cost burden (i.e. spent more than 50 percent of their income on housing).
2 U.S. Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy (CHAS) data based on 2013-2017 ACS.

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Table 14: Housing Assistance Needs of Lower Income Households (2013-2017) Household by Type,
Income,
and Housing Problem
Renters Owners Total
House
holds Elderly Small
Families
Large
Families
Total
Renters Elderly LargeFamilies
Total
Owners
Extremely Low Income
(0-30% AMI) 615 505 205 1,460 210 30 435 1,895
With Any Housing Problem 72.4% 93.1% 100.0% 84.6% 76.2% 100.0% 80.5% 83.6% Cost Burden >30% 69.9% 93.1% 95.1% 82.9% 66.7% 100.0% 67.8% 79.4% Cost Burden > 50% 58.5% 70.3% 73.2% 65.1% 52.4% 66.7% 56.3% 63.1% Very Low Income
(31-50% AMI) 420 775 235 1,515 150 130 430 1,945
With Any Housing Problem 70.2% 89.7% 89.4% 83.8% 50.0% 92.3% 80.2% 83.0% Cost Burden >30% 60.7% 88.4% 48.9% 74.3% 50.0% 69.2% 74.4% 74.3% Cost Burden > 50% 19.0% 25.2% 8.5% 20.5% 26.7% 23.1% 43.0% 25.4% Low Income
(51-80% AMI) 230 475 190 1,030 245 150 910 1,940
With Any Housing Problem 60.9% 51.6% 78.9% 59.7% 26.5% 43.3% 47.3% 53.9% Cost Burden >30% 60.9% 43.2% 31.6% 47.1% 26.5% 20.0% 43.4% 45.4% Cost Burden > 50% 6.5% 3.2% 0.0% 2.9% 4.1% 0.0% 9.3% 5.9% Moderate & Above Income
(>80% AMI) 195 1,150 305 1,990 945 830 4,120 6,110
With Any Housing Problem 0.0% 16.1% 24.6% 15.8% 11.1% 30.7% 18.7% 17.8% Cost Burden >30% 0.0% 8.7% 0.0% 6.8% 8.3% 10.8% 12.8% 10.9% Cost Burden > 50% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Total Households 1,460 2,905 935 5,995 1,550 1,140 5,895 11,890 With Any Housing Problem 60.3% 54.9% 68.4% 57.3% 26.1% 41.2% 32.1% 44.8% Cost Burden >30% 56.5% 50.3% 39.6% 49.3% 23.1% 21.1% 26.1% 37.8% Cost Burden > 50% 31.2% 19.4% 18.2% 21.5% 10.3% 4.4% 8.7% 15.2% Note: Data presented in this table are based on special tabulations from the American Community Survey (ACS) data. Due to the small sample size, the margins are errors can be significant. Interpretations of these data should focus on the proportion of households in need of assistance rather than on precise numbers.

Source: HUD Comprehensive Housing Affordability Strategy (CHAS) tabulations of 2013-2017 ACS data A. Cost Burden

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Housing cost burden is defined as a housing cost that exceeds 30 percent of a household’s gross income. A severe cost burden is a housing cost that exceeds 50 percent of a household’s gross income.3 Housing cost burden is particularly problematic for low and moderate income households in that it leaves little resources for a household to pay for other living expenses.

The ACS calculated the percentage of income expended on housing costs for both renters and owners over a three-period of 2013-2017 and the estimates are considered an average for that time period. This five-year survey period includes the easing of the foreclosure crises and a decrease in unemployment. The estimates discussed below may, therefore, reflect a decrease from previous years’ estimates, reflecting an improvement for many households in the balance between housing costs and pay, except for extremely low income households.

Between 2013 and 2017, a total of 4,493 or 37.8 percent, of all households in the City of El Centro paid in excess of 30 percent of their income for shelter (see Table 14 above). Cost burden varies by tenure. About 26 percent (1,538) of the City’s owner-households overpaid for housing, while approximately 49 percent (2,955) of renter-households overpaid for housing. The cost burden situation is particularly critical for those households with the lowest annual incomes. Of extremely low income households, 79 percent (1,505) overpaid for housing. About 74 percent (1,445) of very low income households also experienced a housing cost burden. Lower income renter-households were also more affected by cost burden than lower income owners. About 1,210 (83 percent) of extremely low income renter-households experienced housing cost burdens (>30 percent) compared to 295 (68 percent) extremely low income owner-households. Very low income renter-households and owners experienced similar rates of cost burdens (74 percent; 1,125 renter households and 320 owner-households).

Severe housing cost burden is of even greater concern, particularly when those affected are lower income households. Approximately 435 owner-households are considered to be in the extremely low income category and over half (56 percent or 245) of these households experienced a severe housing cost burden between 2013 and 2017. Similarly, of all renter-households within the City, 1,460 are considered to be in the extremely low income category and a majority of these households (65 percent or 950) spend more than half of their net household income on housing.

As indicated in Table 14 as household income increases, cost burden generally decreases.

B. Overcrowding
3 A household spending more than 30 percent of its gross household income on housing is considered cost-burdened both by the State Department of Housing and Community Development (HCD) and the U.S. Department of Housing and Urban Development (HUD).

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An overcrowded unit is defined by the Census as having more than one person or more per room, excluding kitchens and bathrooms. A severely overcrowded unit has 1.5 or more persons per room. Generally, a room is defined as a living room, dining room, bedroom, or finished recreation room.

According to the 2015-2019 ACS, approximately 12.0 percent of all households in the City are considered to be overcrowded (see Table 15). Overcrowding was much more likely to affect renter-households (17.1 percent) than owner-households (7.0 percent). Severe overcrowding was also more prevalent among renter households than owner households (4.8 percent and 3.0 percent).

Table 15: Overcrowded Units by Tenure (2015-2019)
Persons per Room Owner Renter Total
# % # % # %

1.00 or less 5,495 93.0% 4,737 82.9% 10,232 88.0%

1.01 or to 1.50 235 4.0% 704 12.3% 939 8.1%

1.51 or more 179 3.0% 275 4.8% 454 3.9%
Total 5,909 5,716 11,625
% Overcrowded by Tenure 7.0% 17.1% 12.0%
Source: ACS 2015-2019

2.5. Special Needs

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As noted in Government Code Section 65583(a)(6), within the overall housing needs assessments there are segments of the population that have or require special housing. Generally, these are people who have lower incomes and less access to housing choices when compared to moderate and above moderate income households. Segments of the population that often have special housing needs include seniors, persons with disabilities, large households, single parents, people living in poverty, farm workers, and homeless individuals and families, and military personnel.

These groups are summarized in Table 16.

Table 16: Special Needs Groups (2015-2019)
Special Needs Group
# of Persons
or
Households
# of
Owners % Owner # of Renters % Renter
% of Total
Households
or Population
Senior Headed
Households 3,071 1,851 31.3% 1,220 21.3% 26.4%
Seniors Living Alone 1,116 485 8.2% 631 11.0% 9.6%
Large Households
(5 and more people) 2,032 1,228 10.6% 804 6.9% 17.5%
Single Parent
Households 1,238 10.6%
Persons with Disabilities 7,068 16.2%
Persons with
Developmental
Disabilities
886 2.0%
Female-Headed
Households 3,721 32.0%
Female Headed
Households w/ Children 1,072 9.2%
People Living in Poverty 9196 20.9%
Farm Workers 1330 8.5%
Homeless 92 0.2%
Military 14 <0.1%
Sources: American Community Survey 2015-2019
A. Seniors
Seniors, defined as persons over the age of 65 years, often age in-place, living in housing that is too expensive for their fixed incomes or that structurally does not accommodate specific needs for assistance. Even though senior citizens may have difficulty living in their own home, they often do not have the options or mobility afforded other segments of the population.

The number of seniors in El Centro has increased over the last two decades. In 2000, there were 3,529 seniors in the City (see Table 17). By 2019, the 5,874 seniors in El Centro represented 13.3 percent of the population. Between 2000 and 2010, the senior population increased at a rate of 2.9 percent annually; this pace increased to 3.2 percent between 2010 and 2019.

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Table 17: Senior Population Trends (65+) (2000-2019)
Year # of Persons # Change % Change Annual %
Change
2000 3,529
2010 4,556 1,027 29.1% 2.9%
2019 5,874 1,318 28.9% 3.2%
Source: U.S. Bureau of the Census, 2000-2010, ACS 2015-2019 Between 2010 and 2019, the number of senior-headed households in the City increased by 15.6 percent (see Table 18). In 2019, senior-headed households comprised approximately 26.4 percent of all households within the City. Since 1990, the proportion of senior households who owned their homes has slightly declined, while the proportion of senior households who rented their homes has increased (Figure 1). Nevertheless, as of 2019, senior households who owned their homes (60.3 percent) continued to outnumber their renter counterparts (39.7 percent) by 20.6 percent.

Table 18: Senior Household Trends (65+) (2010-2019)
Year # of Households # Change % Change Annual % Change
2010 2,657
2019 3,071 414 15.6% 1.7%
Source: U.S. Bureau of the Census, 2000-2010, ACS 2015-2019 As documented in Table 14, elderly households in the City (particularly those that rented their homes) were especially likely to experience a housing problem. Specifically, of all elderly renter households, around 60 percent reported experiencing a housing problem. Among elderly owner households, approximately 26 percent reported experiencing a housing problem.

Figure 1: Senior Households by Tenure (2010-2019)
Source: U.S. Bureau of the Census, 2000-2010, ACS 2015-2019 2000 2010 2019
Owner 62.6% 59.2% 60.3%
Renter 37.4% 40.8% 39.7%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

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Resources
The special needs of seniors can be met through a range of services, including congregate care, rent subsides, shared housing, and housing rehabilitation assistance. For the frail or disabled elderly, housing can be modified with features that help ensure continued independent living arrangements. Senior housing developments in the City include:
▪ Regency Park Apartment – 106 units
▪ El Centro Senior Villas – 72 units
▪ Plaza Senior Villas (now called Desert Villa Apartments) – 59 units There are also four Residential Care Facilities for the Elderly in the City:
• A&A Cottage View -14 units
• Heart & Hand – 14 units
• Parkside Villa Assisted Living – 15 units
• Majestic Villa Assisted Living- 18 units
And two Adult Residential Facilities in the City:
• Smoketree – 6 units
• Sunsent Homes - 18 units
Seniorresidents in the City can benefit from various services offered at the El Centro Adult Center managed by the City’s Parks and Recreation Department. Services offered at the Center include:
computer and sewing courses, bingo, movie screenings, a senior nutritional program, and adult and senior exercise days. Additionally, several local and regional programs provide housing and social services to assist the elderly in the City. These organizations include the Area Agency on Aging, Imperial County Work Training Center, United Way, and Catholic Charities.

As required by the Lanterman Developmental Disabilities Services Act, the City’s Zoning Ordinance treats state-licensed residential care facilities serving six or fewer individuals the same as any other residential use. Furthermore, larger residential care facilities that serve seven or more clients are allowed by-right in the RR, R1, R2, and R3 zones.

B. Persons with Disabilities (Including Developmental Disabilities) Three types of disabled persons are considered as having special housing needs: physically impaired, mentally disabled, and developmentally disabled. Each type is unique and requires specific attention in terms of access to housing, employment, social services, medical services, and accessibility of housing.

According to 2015-2019 ACS data, approximately 16.2 percent of El Centro residents had a disability. The ACS also tallied the number of disabilities by type for residents with one or more disabilities (see Table 19). Among the disabilities tallied, ambulatory (55.0 percent) and cognitive (34.1 percent) difficulties were the most prevalent. However, the types of disabilities experienced varied depending on the age of the disabled person. Specifically, vision difficulties were the most

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common disability affecting disabled person ages 5-7, afflicting 17.3 percent of the disabled persons in this age group. Meanwhile, ambulatory difficulties were the most likely to affect disabled persons over the age of 65.

Persons with disabilities require housing that is adapted to their needs. Most older single-family homes are inaccessible to people with mobility and sensory limitations. Housing may not be adaptable to widened doorways and hallways, access ramps, larger bathrooms, lowered countertops, and other features necessary for accessibility. Location of housing is also an important factor for many persons with disabilities, as they often rely upon public transportation to travel to necessary services and shops.

Table 19: Disabilities Tallied (2015- 2019)
Disability Type % of Disabilities Tallied
Age 5 to 17 Age 18 to 64 Age 65+
With a hearing difficulty 0.6% 9.9% 13.1% 23.6%
With a vision difficulty 1.6% 6.4% 9.3% 17.3%
With a cognitive difficulty 19.1% 15.0% 34.1%
With an ambulatory difficulty 25.8% 29.2% 55.0%
With a self-care difficulty 8.7% 11.6% 20.3%
With an independent living
difficulty 16.1% 11.0% 27.1%
Total Disabled Persons 1; 2 630 3,475 2,917 7,022
Notes:

1. A person can have multiple disabilities.

2. Does not include people Age 0-4
Source: Bureau of the Census, American Community Survey (ACS), 2015-2019 Persons with Developmental Disabilities
A recent change in State law requires that the Housing Element discuss the housing needs of persons with developmental disabilities. Section 4512 of the Welfare and Institutions Code defines “a developmental disability as a disability that originates before an individual attains 18 years of age; continues, or can be expected to continue, indefinitely; and constitutes a substantial disability for that individual. This term shall include: intellectual disability, cerebral palsy , epilepsy, autism [and] shall also include disabling conditions found to be closely related to intellectual disability or to require treatment similar to that required for individuals with an intellectual disability, but shall not include other handicapping conditions that are solely physical in nature.” This term shall also reflect the individual’s need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.

The Census does not record developmental disabilities. According to the U.S. Administration on Developmental Disabilities, an accepted estimate of the percentage of the population that can be defined as developmentally disabled is 1.5 percent. This generally equates to 654 persons in the City of El Centro with developmental disabilities, based on the 2015-2019 Census population.

However, according to the State’s Department of Developmental Services, as of March 2021, approximately 886 El Centro residents with developmental disabilities were being assisted at the San Diego Regional Center for the Developmentally Disabled branch office located in the City of

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Imperial. Most of these individuals were residing in a private home with their parent of guardian and 13 of these persons with developmental disabilities were under the age of 18.

Many developmentally disabled persons can live and work independently within a conventional housing environment. More severely disabled individuals require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for the developmentally disabled is the transition from the person’s living situation as a child to an appropriate level of independence as an adult.

Resources
Various non-profit groups provide supportive services to the special needs population in El Centro, including persons with disabilities. Community Catalysts California has a center located at 354 E. Main Street in El Centro and offers various social services to City residents with the goal of empowering people with disabilities. Among other organizations, ARC of Imperial Valley offers dial-a-ride paratransit services to City residents and links them to additional health, employment, and residential services. The Arc Imperial Valley also operates Group Homes, Independent Living Services, an Adult Development Center, a Behavior Management Program, an Activity Center, a Work Activity Program, Supported Employment and Individual Placement, a Commercial Kitchen and a Recycling Program with a Car Wash. The Arc Imperial Valley is also one of the largest Federal Government contractors in the area through the AbilityOne Program.

According to the State Department of Social Services, six licensed residential care facilities, with a total capacity of 81 beds, are located within El Centro. These facilities have the capability to accommodate and serve persons with disabilities. The Zoning Ordinance treats residential care facilities in accordance with the Lanterman Developmental Disabilities Services Act.

State and federal legislation mandate that a percentage of units in new or substantially rehabilitated multi-family apartment complexes be made accessible to individuals with limited physical mobility.

C. Large Households
For the purposes of this section, large households are defined as households consisting of five or more persons. Generally, the needs of large families are not targeted in the housing market, especially in the multi-family market.

In 2010, 23 percent (or 2,637 households) of the City’s households were large households (see Table 11). By 2019, the number of large households in the City had decreased to 2,032 households, or 17.5 percent of all households. Two and three bedroom units are the most common housing unit type in the housing market; however, large households typically require dwelling units with four or more bedrooms in order to avoid overcrowding. According to 2015-2019 ACS data, the majority of owner-occupied housing in the City had three or fewer bedrooms (76.8 percent, occupied by 8,930 households). The proportion of renter-occupied housing with four or more bedrooms was low, at just 6.2 percent, accommodating 356 households.

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Housing options for large renter-households in the City are not sufficient to meet the needs of the 804 large renter-households in the ACS (2015-2019). Lower income large renter-households would have difficulty finding adequately sized and affordable housing in El Centro.

Large households are often more susceptible to housing problems, like overcrowding and cost burden. According to CHAS data, 67.4 percent of large-family renter-households and 25.5 percent of large-family owner-households had low incomes (see Table 14). CHAS also found that all (100.0 percent) of the City’s extremely low and 89.4 percent of very low income large renter households experienced at least one housing problem between 2013 and 2017.

Resources
In order to address the problem of overcrowding in large family households, the City has included, as part of this housing element, programs to increase opportunities for the development of suitably sized housing for these households. Large households can benefit from a variety of programs and services offered by different organizations in the City. Providers such as the Center for Family Solutions and House of Hope can aid households in need of emergency shelter and other services. Additional organizations that offer support services such as assistance with utilities, food, and housing referrals include the Imperial County Family Resource Center, Catholic Charities, Imperial Valley Food Bank, Imperial Valley Housing Authority, and the Salvation Army.

D. Single-Parent/Female-Headed Households
Single-person-heads of households, particularly female-headed families with children, often require special consideration and assistance because of their greater need for affordable housing and accessible day care, health care, and other supportive services. Female-headed families with children are a particularly vulnerable group because they must balance the needs of their children with work responsibilities, often while earning limited incomes. The 2015-2019 ACS found that there were 3,721 female-headed households in the City of El Centro. As shown in Table 20, of these households, 1,072 households (or 29 percent) had children under 18. Overall, single femaleheaded households make up 32 percent of all households in the City and single-female headed households with children make up about 9.2 percent of all households in the City.

Table 20: Household Type and Presence of Children 18 Years Old and Under (2015-2019) Household Type # of Households % of Total
Single-Person-Head of Household 6,678 57.4%
With Children Under 18 Years Old 1,238 10.7%
With No Children 5,440 46.8%
Female Householder, No Spouse Present 3,721 32.0%
Female Householder With Children Under 18 1,072 9.2%
Female Householder With No Children Under 18 2,649 22.8% Total Households 11,625
Source: ACS 2015-2019

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Resources
Various organizations located within El Centro offer family and youth services. The Imperial Valley Food Bank also supports the City’s families through its food distribution and emergency assistance programs. Womanhaven, Inc. offers shelter and a range of services to victims of domestic violence and their children, including counseling, education, advocacy, legal services, support groups, clothing, and case management. The agency also offers children and youth education and violence prevention programs to foster better life choices for the City’s young residents. Organizations offering programs and services beneficial to single-parent households include the Center for Family Solutions, Imperial County Family Resource Center, Catholic Charities, Imperial Valley Food Bank, Neighborhood House, and the Salvation Army.

E. Residents Living Below the Poverty Level
In the City of El Centro, in 2015-2019, an estimated 1,895 families (or 20.9 percent of all families) were living below the poverty level. Poverty thresholds vary depending on the size of the family and the age of family members; therefore, no specific income threshold can be specified.

Approximately 50.9 percent (964 families) of the 1,895 family households living below the poverty level were female-headed. Of the female-headed households living below the poverty level, 51.1 percent (492) of households had children under 18 years of age (see Table 21).

Table 21: Households by Poverty Level (2015-2019)
Family Households # Households % of Total
Total family households 9,066 100%
Total families with income below poverty level 1,895 20.9% Total families with children under 18 year of age
with incomes in below poverty level 2,557 28.2%
Total female-headed households 2, 564 28.3% total family households Female-headed households below the poverty
level 964 37.6% total female-headed households
Female-headed households with children under
18 years of age in below poverty level 492 51.1% female-headed households below the poverty level Source: Source: American Community Survey (ACS), 2015-2019 Resources
Households within the City living below the poverty level can benefit from programs and services offering assistance with utility bills, food supplies, and various other social services.

Organizations in the City offering these services include the Imperial County Family Resource Center, Catholic Charities, Imperial County Social Services, Imperial Valley Food Bank, Neighborhood House, and the Salvation Army. In addition to providing essential support services, the Center for Family Solutions and House of Hope provide emergency shelter to residents. The City promotes the maintenance and expansion of the Housing Choice Voucher program, which provides an important source of rental assistance for individuals and households living in poverty. Individuals living in poverty can also benefit from small units such as studios and single room occupancy units (SROs).

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F. Farm Workers
The farm worker population consists of two segments: permanent and migratory (seasonal) farm workers. The permanent population consists of farm workers who have settled in the region and maintain local residence and who are employed most of the year. The migratory farm worker population consists of those farm workers who typically migrate to the region during seasonal periods in search of farm labor employment and from the region during the off-season.

Traditional sources of population estimates, including the Census, have tended to significantly underestimate farm worker population. This conclusion is based upon subsequent farm worker data that conflicts with prior data. Moreover, different employment estimation techniques result in diverse estimates of local agricultural employment. The USDA’s 2017 Census of Agriculture reported that in Imperial County, 7,934 persons were hired farmworkers (fulltime), with 4,634 working more than 150 days and 3,300 working less than 150 days. Imperial County’s migrant farmworker population was 1,057.

According to 2015-2019 ACS data, shown in Table 22, 8.5 percent (1,330 persons) of the City’s labor force was employed in the farming, fishing and forestry industries. The proportion of El Centro’s labor force employed in agriculture is one percent lower than for the County (9.5 percent).

Table 22: Farm workers (2000-2019)
Industry
City of El Centro Imperial County
2000 2019 2019
#
% of Total
Employment #
% of Total
Employment #
% of Total
Employment
Farming, Fishing and Forestry 966 6.3% 1,330 8.5% 5,728 9.5% Total Labor Force 18,219 18,067 70,423
Source: U.S. Bureau of the Census, 2000; American Community Survey (ACS), 2015-2019 Farmers are at very high risk for fatal and nonfatal injuries. Additionally, farming is one of the few industries in which family members (who often share the work and live on the premises) are also at risk for fatal and nonfatal injuries. While no data specific for El Centro was available at the time of writing, a study published in the Journal of Agricultural Health and Safety found that the disability rate in the farm population was 12.9 percent based on U.S. Census Bureau’s American Community Survey (ACS) from 2008 to 2016.4 On average, nearly one out of ten farmworkers had a disability and one in 25 farm family children (ages 6 to 17) and slightly more than two in 25 farm family adults had a disability. The high risk of injury and disability has implications in the planning of housing for farmworkers and their families- both in terms of affordability and housing type needs.

Resources
Farmworker can benefit from programs for lower income households. The City also has a number of apartment complexes suitable for those in need of affordable housing (see Table 30). 4 Miller, Cristina & Aherin, Robert. (2018). The Prevalence of Disabilities in the U.S. Farm Population. Journal of Agricultural Safety and Health. 24. 243-260. 10.13031/jash.12934.

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G. Homeless Persons
The City of El Centro, with the assistance and participation of its local service providers, maintains a continuum of care for the homeless population and to those facing the possibility of homelessness. The continuum of care begins with the assessment of the homeless individual or family; then refers to appropriate housing where supportive services are provided to prepare them for independent living. The goal of a comprehensive homeless service system is to ensure that homeless individuals and families move from homelessness to self-sufficiency, permanent housing, and independent living.

Due to their transient nature, it is difficult to count the number of homeless in any one area. It should also be noted that there are generally two types of homeless - the permanent homeless, who are the transient and most visible homeless population, and the temporary homeless, who are homeless usually due to eviction and may stay with friends, family, at a shelter or motel until they can find a permanent residence.

The City of El Centro works with other county departments, mental health providers, homeless and transitional shelters, local jurisdictions and other service providers to identify the needs of the homeless, which have been identified in the Imperial Valley Continuum of Care (CoC) 2020 Homeless Point-in-Time Survey conducted on January 24-25, 2020. This updated count presents the most current data for the region. The Point-in-Time Survey reported that on a given day, there are 1,527 homeless in the County of Imperial. This includes 1,334 unsheltered and 193 sheltered homeless people. The exact population of those who are homeless within the City is difficult to estimate because of the transient nature of the homeless population.

Proportionally, El Centro’s population represents about 24 percent of the countywide population.

Therefore, it can be generally estimated that 322 unsheltered homeless persons in El Centro.

Given the basis of the calculation, the emergency need conditions and the transient nature of homeless people, these numbers will continue to fluctuate. This estimate is congruent with the most recent Point-In-Time (PIT) count that reported the number of homeless by community/ jurisdiction. According to the 2018 PIT report, El Centro’s homeless population was estimated account for 20.4 percent of the County’s homeless population, the largest homeless population in the County outside of Slab City.

Slab City is a World War II era U.S. Marine Corp training center formerly known as Camp Dunlap. In 1956, Camp Dunlap was determined to be no longer required by the Department of Defense. In October of 1961 and was given to the State of California by quitclaim deed. All of the former Camp Dunlap buildings were removed and all that remained were the concrete slabs used for the building foundations. Many began camping at the slabs and they continued to come and camp and many never left, even though there is no running water, sewage, electricity or garbage collection. In 2017, Imperial Valley began to include Slab City’s homeless population in its PIT counts. According to 2018’s PIT report (the last report to include data by community/jurisdictions), Slab City had the largest share of the County’s total homeless population. Homeless persons in Slab City include families with children, adults, transition-age youth, veterans, seniors, and all other subsets and demographics. Virtually all homeless persons in Slab City occupy vehicles, hand-built structures, or other makeshift accommodations. The report states that “homelessness in Slab City is unlike the type of homelessness most prevalent

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nationwide in urban and rural communities insofar as residents of the area are a more-or-less settled population, living in some cases for years on claimed lots with semi-permanent installations… a subset of Slab City residents denies being homeless, preferring instead to be defined as ‘living off the grid’ or some other alternative term.” In 2018, Slab City had the most homeless residents receiving Social Security, Veteran’s Assistance, Food Stamps, and disability income in the County. Slab City is located about 40 miles north of El Centro so its homeless population is not likely to have any effect on the needs and services provided in El Centro.

The 2018 PIT detailed that El Centro’s homeless population included a majority of unsheltered individuals with no makeshift accommodation of any type, unlike most other communities in the PIT count. El Centro’s homeless population cited Temporary Assistance for Needy Families (TANF), Food Stamps, and cash aid as their primary sources of supplementary income. The majority of El Centro’s homeless residents were 40 years old or younger while the majority of Slab City’s were 41 and older.

Though PIT Survey Reports after 2018 have not reported data by community, the data provided by the 2020 PIT count is still useful in identifying Countywide trends in the homeless population.

The 2020 Point-in-Time Survey reported the following about the homeless in Imperial County:
▪ There are 92 homeless children under the age of 18, of which 38 are sheltered while 54 are unsheltered.
▪ The largest subpopulation of unsheltered homeless are male; there is a total of 1,085 homeless males of which 965 are unsheltered.
▪ There are 750 chronically homeless individuals on any given day in Imperial County.

In Imperial County, 87 percent of those experiencing homeless are unsheltered. Factors contributing to homelessness include the lack of housing affordable to lower income persons, increases in the number of persons whose incomes fall below the poverty level, reductions in public subsidies to the poor, alcohol and substance abuse, domestic violence, and the deinstitutionalization of the mentally ill. Homeless people, victims of abuse, and other individuals often have housing needs that are not being met by the traditional housing stock. These people require temporary housing and assistance at little or no cost to the recipient.

Resources
The City amended the Zoning Ordinance in 2010 to allow emergency shelters by-right and with a ministerial permit process in the R3, CG, and CH zones and in April 2013 to allow transitional and supportive housing by-right in all zones that allow residential uses, pursuant to State law.

Additionally, as documented in Table 23, a number of organizations located within El Centro offer emergency shelter, transitional housing and supportive services to the region’s homeless or those at risk of becoming homeless.

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Table 23: Homeless Resources in El Centro
Organization Services
Catholic Charities/House of Hope Emergency Shelter, Supportive Services Employment Development Department Supportive Services
House of Hope Emergency Shelter, Supportive Services
Spread the Love Charity Transitional Housing
VCS – Community Catalyst Transitional Housing
Imperial County Health Department Supportive Services
Imperial County Social Services Supportive Services
Imperial Valley Behavioral Health Services Supportive Services Imperial Valley Food Bank Supportive Services
Imperial Valley College Supportive Services
I.V. Independent Living Center
(Empowering People with Disabilities)
Supportive Services
Salvation Army Supportive Services
IVROP Supportive Services
IVROP Foster Youth Services Supportive Services
Womanhaven (d.b.a. Center for Family Solutions) Emergency Shelter, Supportive Services, Transitional Housing
Source: Imperial County Homeless Resources, Imperial Valley Continuum of Care Council, 2021 H. Military Households
The military population’s influence on the demand for housing takes two forms: (1) existing military households trying to find housing; and (2) former military households trying to remain in the community. Often, the housing needs of military personnel are affected by lower incomes and an uncertain length of residency.

While the 2015-2019 ACS documented only 14 persons in the City employed in the Armed Forces, a far greater number of military personnel may actually be present in the City at any given time.

Naval Air Facility (NAF) El Centro is a short-term training facility for 1,600 members of the military at a time located about five miles from the City and base. There are also approximately 280 other full time military personnel working at NAF who are not included in the City’s ACS employment estimates.

Resources
Most special needs of military families are provided through on-base supportive programs and services. NAF El Centro has established Community Support Programs (CSP) (Fleet and Family Support or FFS), a regional team responsible for policy development, resourcing and oversight of quality of life programs for active-duty military, reservists, military retirees and their families.

FFS provides housing, morale/welfare/recreation, and family programs and services for military personnel and their families.

I. Extremely Low Income Households

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The category “extremely low-income households” is a subset of “very low-income households,” and is defined as 30 percent (or less) of the area median income. The housing element must quantify existing and projected extremely low-income households, analyze their housing needs, and assess the kind of housing available and suitable for extremely low-income households. Table 14 in the Housing Problems section of this assessment showed the disproportionate needs of ELI households compared to other lower income households and all households in the City. About 84 percent of all ELI households experience housing problems compared to 83 percent of very low income households, 54 percent low income households, and 45 percent of all households. ELI households also experience housing cost burdens at higher rates (79 percent) than all other households (74 percent VLI, 45 percent low income, and 38 percent of all households). ELI households also have high rates of overcrowding, compared to all households, but lower than VLI households (Table 24). ELI income renters are also more likely to live in overcrowded conditions than owners. However, all lower income renter households experience similarly high overcrowding rates (over 18 percent) compared to only nine percent of moderate and above moderate income households. Based on this analysis, ELI households are disproportionately affected by cost burdens and crowded conditions. Thus, affordable housing opportunities in units of various sizes are necessary it meet the needs of ELI residents in the City.

Table 24: Overcrowded Households by Income Level and Tenure Income Level Owners Renters
All
Households
Extremely Low Income (<30)=%) 12.6% 18.2% 16.9%
Very Low Income 18.6% 20.8% 20.3%
Low Income 6.0% 21.8% 14.4%
Moderate & Above Income (>80% AMI) 5.6% 8.5% 6.5%
Total Households 7.1% 16.3% 11.7%
Source: HUD Comprehensive Housing Affordability Strategy (CHAS) tabulations of 2013-2017 ACS data Resources
Extremely low-income households can also be any of the aforementioned special needs populations and can thus take advantage of the resources listed in the previous sections. In addition, the City will rely on the non-funding-related actions to encourage affordable and special needs housing production, including housing for extremely low income households, as detailed in Program 5.

2.6. Housing Stock Characteristics
The Census defines a housing unit as any of the following: a house, an apartment, a mobile home or trailer, a group of homes, or a single room intended for use as separate living quarters.

Separate living quarters are those in which the occupants live separately from any other individuals in the building, and which have direct access from outside the building or through a common hall.

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This section discusses various housing characteristics and trends that affect housing needs in El Centro. Important characteristics include housing growth, type, vacancy, and age and condition.

A. Housing Unit Growth
Perhaps due to the housing crisis of the late 2000s, the number housing units in the County increased from 2000-2010 (by 27.5 percent) and then only increase by 4.9 percent)in the decade that followed. This trend is amplified in El Centro, where there was a 17.5percent growth in the number of housing units between 2000 and 2010, followed by an increase of only 2.5 percent between 2010 and 2021 (see Table 25).

Table 25: Housing Unit Growth (2000-2021)
Jurisdiction 2000 2010 2021 % Change
2000-2010 2010-2019
Brawley 7,038 8,231 8,634 17.0% 4.9%
Calexico 6,983 10,651 10,999 52.5% 3.3%
Calipatria 961 1,121 1,122 16.6% 0.1%
El Centro 12,323 14,476 14,832 17.5% 2.5%
Holtville 1,617 1,937 1,982 19.8% 2.3%
Imperial 2,385 4,751 6,423 99.2% 35.2%
Imperial County 43,981 56,067 58,811 27.5% 4.9%
Sources: U.S. Bureau of the Census, 2000, ACS 2006-2010; 2010 and 2021 California Department of Finance Population and Housing Estimates.

B. Housing Type
Housing diversity is important for ensuring adequate housing opportunities for El Centro residents. A diverse housing stock helps ensure that all households, regardless of their income, age group, and/or household size, have the opportunity to find housing that is best suited to their needs.

According to the 2021 State Department of Finance Population and Housing Estimates, there were approximately 8,614 single-family residences located within the City, an increase of 5 percent since 2010 (see Figure 2). The City’s housing stock also includes 4,687 multi-family housing units.

Since 2010 the number of multi-family units decreased by 5 percent overall. Meanwhile, the number of mobile homes, boats, RV’s, vans, etc. in the City also decreased by 1 percent.

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Figure 2: Distribution of Housing Units (2000-2010-2019) Sources: U.S. Bureau of the Census, 2000; American Community Survey (ACS), 2006-2010; and 2021 DOF Population and Housing Estimates
C. Housing Vacancy
Vacancy rates are important indicators of the supply and cost of housing because they establish the relationship between housing supply and demand. For example, if the demand for housing is greater than the available supply, then the vacancy rate is low and the price of housing will most likely increase. Additionally, the vacancy rate indicates whether or not the City has an adequate housing supply to provide choice and mobility. General industry standards indicate that vacancy rates of five to six percent for rental housing and one to two percent of ownership housing is sufficient to provide choice and mobility.

In 2015 - 2019, the ACS estimated a vacancy rate of 15.9 percent for the City of El Centro. In 2006 - 2010, the ACS estimated the vacancy rate for El Centro to be 8.5 percent.

In both 2010 and 2019, the percentage of vacant rental units greatly exceeded the percentage of units for sale. Of the vacant units in the City in 2019, 6.2 percent were available for sale while 18 percent were available for rent. In 2010, there was a much higher percentage of both vacant housing for sale (21 percent) and vacant housing for rent (28.5 percent). A much large proportion of vacant units are being used for seasonal, recreational or occasional use in 2019 than in 2010.

Single-Family 2-4 Units 5+ Units MH/RV
2000 7,021 1,060 2,892 1,314
2010 8,180 2,027 2,888 1,549
2021 8,614 1,584 3,103 1,531
-
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000

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Figure 3: Vacant Units by Housing Type (2010-2019)
Source: American Community Survey (ACS), 2006-2010, ACS 2015-2019 D. Housing Age and Condition
Housing age can be an important indicator of
housing condition within a community. Like any
other tangible asset, housing is subject to gradual
physical or technological deterioration over time. If
not properly and regularly maintained, housing
can deteriorate and discourage reinvestment,
depress neighboring property values, and
eventually impact the quality of life in a
neighborhood. Many federal and state programs
also use the age of housing as one factor in
determining housing rehabilitation needs.

Generally, housing older than 30 years of age will
require minor repairs and modernization
improvements. Housing units over 50 years of age are more likely to require major rehabilitation such as roofing, plumbing, and electrical system repairs. Approximately 33 percent of the housing stock is over 50 years of age and may require substantial repairs.

Table 26 shows that 50.7 percent of the housing units in El Centro were built prior to 1980, meaning that more than one-half of the City’s housing stock is over 30 years old. Many of these older units could potentially require minor repairs.

Housing age is only a general indicator. It does not take into account private actions by property owners to maintain and upgrade their properties. In May of 2015, a comprehensive Housing Vacant
Housing Total
Vacant
Housing for
Sale
Vacant
Housing for
Rent
Seasonal,
Recreational
or Occasional
Use
For Migrant
Workers Other
2010 8.5% 21.0% 28.5% 12.1% 0% 27.5%
2019 15.9% 6.2% 18.0% 27.1% 0% 43.2%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%

30.0%

35.0%

40.0%

45.0%

50.0%
Table 26: Housing Age
Year Structure
Built Number Percentof Total
1939 or earlier 433 3.4%
1940-1959 2,542 18.4%
1960-1969 1,549 11.2%
1970-1979 2,463 17.7%
1980-1989 2,343 17.0%
1990-1999 1,865 13.4%
2000-2009 2,315 16.7%
Built 2010 or later 312 2.2%
Total 13,822 100.0%
Source: American Community Survey (ACS), 2015-2019

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Conditions Survey was conducted to estimate the total number of substandard units (e.g., those in need of rehabilitation/repair) and those in need of replacement/demolition. This is based upon the California Department of Housing and Community Development’s (HCD) – Housing Stock Characteristics definition:

Government Code Section 65583(a) requires an analysis and documentation of household characteristics, including level of payment compared to ability to pay housing characteristics, including overcrowding, and housing stock condition, [Section 65583(a)(2)].

In conducting a Housing Conditions Survey, compliant with the regulations set forth through the above referenced Government Code; the City conducted a representative sample survey, physically inspecting 2,180 of the units within the City boundary. As part of the 14,225 units constructed in the City approximately 13,908 are estimated to be occupied. Based upon construction timeframes and the age of units across the City, 10,461 units were identified as High Priority parcels. A High Priority parcel was defined as being located in an area of a high Rehab score (e.g., a score of 40 or more based upon the 2008 survey). During the survey, each residential housing unit was scored on a range of structural condition from “Good Condition” to “Repair Needed” to “Partial Replacement” to “Complete Replacement”. Each unit was provided a total Rehab Score that is identified below:
▪ Sound – 9 or less points; no repairs needed, or only one minor repair needed, such as exterior painting or window repair.
▪ Minor – 10 to 15 points; one or two repairs needed, or only one minor repair needed, such as patching and painting of siding or re‐roofing or window replacement. ▪ Moderate – 16 to 39 points; two or three minor repairs needed, such as those listed above. ▪ Substantial – 40 to 55 points; repairs needed to at least four of the five surveyed items (foundation, roof, siding/stucco, windows, and/or electrical) ▪ Dilapidated – 56 or more points; the cost of repairs would exceed the cost to replace the residential structure.

According to the 2015 survey data, the majority of units are classified as “Sound” (39 percent) or in need of “Minor” (47 percent) repair, which indicates a relatively healthy housing stock within the City. Approximately 12 percent of units were in need of moderate repairs. Only 0.9 percent of the units surveyed needed substantial repair, and less than one percent of housing units (0.3 percent) were dilapidated. Housing conditions in the City have not changed significantly since this survey was conducted. In summary, the survey showed that a majority housing units are in good condition and not in need of moderate to major repairs. Only 13 percent of units were estimated as classified as needing moderate or substantial repairs. As a proportion of the City’s 14,832 units in 2021, this equates about 1,920 units. Less than one percent of units (42 units) are estimated to need complete replacement.

As the majority of units surveyed are single‐unit, as well as the majority of units in the City, it is anticipated the greatest need to be derived from the Single‐Family Unit classification along with their corresponding need for repairs. The single‐most common repair identified was that of window replacement, as it was also identified in the 2008 Housing Conditions Survey. This indicates that even though the housing stock in El Centro has grown, a corresponding level of deterioration has not been identified.

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The survey also identified specific areas where poor housing conditions predominate, with greater than 60 percent of the units in need of some rehabilitation. These areas were located in the central, northern and western central portions of the City, where housing in need of rehabilitation was found to have the highest densities. The areas and their corresponding rehabilitation needs include:
▪ Area bounded by Wensley Ave on the south, Brighton Ave on the north, the Southern Pacific Railroad tracks on the east, and Waterman on the west (over 60 percent require rehabilitation).
▪ Area bounded by Bradshaw Drive on the north, the Date Canal on the South, the Southern Pacific tracks to the east.

Additional areas of the City were identified where slightly fewer (50 to 60 percent), of the housing units require some form of rehabilitation. These include:
▪ Area bounded by Main Street on the north, Dogwood Rd on the east, Hamilton Avenues on the south, and 2nd Street on the west.

Additional areas of the City were identified where 40 to 50 percent, of the housing units require some form of rehabilitation. These include:
▪ Area bounded by Ross Avenue on the south, Holt Avenue to the north, 4th St. to the east and 8th Street to the west.
▪ Area bounded by the Interstate 8 to the south, 5th Street to the east, Aurora Drive to the north, and 8th Street to the west.
▪ Area bounded by Ross Avenue on the south, Hamilton Avenue to the north, Imperial to the east and La Brucherie Avenue to the west.

2.7. Housing Cost and Affordability
One of the major barriers to housing availability is the cost of housing. In order to provide housing to all economic levels in the community, a wide variety of housing opportunities at various prices should be made available.

A. Ownership Housing

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As shown in Table 27, the median home price in El Centro decreased slightly, by 0.4 percent, from $123,500 in 2011 to $123,000 in 2012, when the Housing Element was last updated and also when the housing market was showing signs of recovery from the recession. Therefore, the median price increased significantly, to $299,500, or 143.5 percent, from 2012 to 2021. During this same time period, changes to median home prices in small neighboring jurisdictions were also significant. Calipatria had a large (206.7 percent) increase in median price. The largest increase occurred in the City of Holtville (249.7 percent) while the smallest increase was in Brawley (82.1 percent). The County’s median home price decreased by 0.8 percent between 2011 and 2012. After 2012, when home prices in the region were generally stagnant, the housing market in the cities of Imperial County experienced growth of around 16 percent a year.

Table 27: Changes in Median Home Sale Prices (2011-2021) Jurisdiction
2011 2012 2021 Percent Change in
Median Sale Price
Median
Price # Sold Median Price
#
Sold
Median
Price
2011-
2012
2012-
2021
Brawley $125,000 234 $123,000 23 $224,000 1.6% 82.1%
Calexico $135,000 302 $137,000 14 $284,000 1.5% 107.3%
Calipatria $72,000 26 $60,000 4 $184,000 -16.7% 206.7%
El Centro $123,500 391 $123,000 25 $299,500 -0.4% 143.5% Holtville $95,000 45 $95,000 3 $332,250 0.0% 249.7%
Imperial $160,000 351 $159,000 34 $305,000 -0.3% 91.8%
Imperial County $131,000 1,616 $130,000 132 $263,000 -0.8% 102.3% Source: CoreLogic, 2021.

Figure 4 compares median home prices in El Centro with home prices in neighboring jurisdictions during November 2021. El Centro had among the third highest median home prices among five neighboring jurisdictions. The median price of homes in the City was also $36,500 above the median price of homes in Imperial County.

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Figure 4: Median Home Sales Prices (2021)
Source: CoreLogic 2021
B. Rental Housing
According to a survey of rental listings on www.Craigslist.org and Zillow.com, the median rent in the City of El Centro was $1065 (see Table 28). Market rents in the City averaged approximately $1124, and ranged from $575 for a one-bedroom to $2,300 for a three-bedroom unit.

Table 28: Median and Average Rents by Number of Bedrooms (2021) # of Bedrooms # Listed Median Rent Average Rent Rent Range 0 1 $630 $630 $630 to $630
1 13 $840 $950 $575 to $1,150
2 4 $1,290 $1,300 $900 to $2,055
3 4 $1,650 $1,500 $1,000 to $2,300
4 0
5+ 0
Total 22 $1,065 $1,124 $630 to $2,300
Source: Craigslist.org, and Zillow, June 2, 2021 and July 1, 2021 C. Housing Affordability by Income
Brawley Calexico Calipatria El Centro Holtville Imperial Imperial County
Brawley $224,000 $284,000 $184,000 $299,500 $332,250 $305,000 $263,000 $0
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
$350,000

AXIS TITLE

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Housing affordability can be inferred by comparing the cost of renting or owning a home in the City with the maximum affordable housing costs for households at different income levels. Taken together, this information can generally show who can afford what size and type of housing and indicate the type of households most likely to experience overcrowding and overpayment.

Housing affordability is an important indicator of quality of life in El Centro. If residents pay too much for housing they will not have sufficient income for other necessities such as health care.

Households that spend a substantial portion of their income on housing may also be at risk of becoming homeless in the event of unexpected circumstances such as illness or loss of employment. State law requires that the City facilitate provision of housing opportunities that are affordable to all economic segments of the community.

The federal Department of Housing and Urban Development (HUD) conducts annual household income surveys nationwide to determine a household’s eligibility for federal housing assistance.

Based on this survey, the California Department of Housing and Community Development (HCD) developed income limits that can be used to determine the maximum price that could be affordable to households in the upper range of their respective income category. Households in the lower end of each category can afford less by comparison than those at the upper end.

Based on these income limits for Imperial County and current real estate prices documented in Table 27, homeownership in El Centro is within the reach of low to moderate income households, with the exception of single-person low income households. Housing options for extremely low and very low income households are virtually non-existent unless public assistance is involved.

As shown in Table 29, moderate and median income households can generally afford the market rents for apartments in El Centro. Low income households in El Centro may be able to rent housing in the City depending on household size; however, competition for appropriately sized rental homes may lead to a housing cost burden or overcrowding.

To afford the median-priced home of $299,500 in 2019, a household income of approximately $74,875 would be needed; more than that of the median-income for a four-person household in El Centro of $70,700 (see Table 29). Renting an average apartment, at $1124 per month, would require an annual income of approximately $54,829, an amount barely within reach of a medianincome four-person household in the County. The approximately half of City residents with higher income occupations could afford to rent housing based on these estimates, while ownership would be out of reach for most households. Lower wage occupations would struggle to find any affordable housing in the City.

The price of homes has increased approximately 16 percent a year since 2012, which saw the tapering of the housing crisis at the end of the prior decade. In addition to high costs, tight credit markets and high down-payment requirements may also have forced otherwise income-qualified households out of the ownership market. This, in turn, could have created higher demand for rental properties with associated rental price increases. Furthermore, a general shortage of ownership housing options may explain higher relative housing costs when compared to rental housing.

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Table 29: Affordable Housing Costs by Household Size and Tenure (2021) Household Annual
Income
Affordable Costs
(All Costs)
Utility Allowance,
Taxes & Insurance Affordable
Rent
Affordable
Rental Home Price
Costs
Ownership
Costs Renters Owners
Extremely Low Income (0-30% AMI)
1-Person $14,700 $368 $368 $163 $292 $204 $19,935
2-Person $17,420 $436 $436 $177 $329 $259 $28,034
3-Person $21,960 $549 $549 $202 $394 $347 $40,753
4-Person $26,500 $663 $663 $228 $460 $435 $53,401
5-Person $31,040 $776 $776 $257 $529 $519 $65,170
Very Low Income (31-50% AMI)
1-Person $24,500 $613 $613 $163 $378 $449 $61,904
2-Person $28,000 $700 $700 $177 $422 $523 $73,344
3-Person $31,500 $788 $788 $202 $478 $585 $81,609
4-Person $34,950 $874 $874 $228 $534 $646 $89,588
5-Person $37,750 $944 $944 $257 $587 $687 $93,906
Low Income (51-80% AMI)
1-Person $39,150 $979 $979 $163 $506 $816 $124,644
2-Person $44,750 $1,119 $1,119 $177 $568 $942 $145,078
3-Person $50,350 $1,259 $1,259 $202 $643 $1,057 $162,335 4-Person $55,900 $1,398 $1,398 $228 $717 $1,170 $179,309 5-Person $60,400 $1,510 $1,510 $257 $786 $1,253 $190,907 Median Income (80-100% AMI)
1-Person $49,500 $1,238 $1,238 $163 $596 $1,074 $168,969 2-Person $56,550 $1,414 $1,414 $177 $672 $1,237 $195,612 3-Person $63,650 $1,591 $1,591 $202 $759 $1,389 $219,294 4-Person $70,700 $1,768 $1,768 $228 $847 $1,540 $242,691 5-Person $76,350 $1,909 $1,909 $257 $925 $1,652 $259,214 Moderate Income (100-120% AMI)
1-Person $59,400 $1,485 $1,485 $163 $683 $1,322 $211,366 2-Person $67,900 $1,698 $1,698 $177 $771 $1,521 $244,219 3-Person $76,350 $1,909 $1,909 $202 $870 $1,707 $273,683 4-Person $84,850 $2,121 $2,121 $228 $970 $1,893 $303,289 5-Person $91,650 $2,291 $2,291 $257 $1,059 $2,034 $324,738 Source: California Department of Housing and Community Development, 2021 Income limits; and Veronica Tam and Associates Assumptions: 2021 HCD income limits; 30% gross household income as affordable housing cost; 35% of monthly affordable cost for taxes and insurance; 10% downpayment; and 3.0% interest rate for a 30-year fixed-rate mortgage loan. Utilities based on Imperial Valley Housing Authority Utility Allowance, 2019. For heating, cooking, and water heating utilities, for which multiple energy sources are available, the average for all energy sources was averaged.

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Figure 5: Income Needed to Afford Housing Compared to Wages Sources:

1. Average salary data State Employment Development Department, 2020

2. California Department of Housing and Community Development, 2021 Income limits; and Veronica Tam and Associates Assumptions: 2021 HCD income limits; 30% gross household income as affordable housing cost; 35% of monthly affordable cost for taxes and insurance; 10% downpayment; and 3.0% interest rate for a 30-year fixed-rate mortgage loan. Utilities based on Imperial Valley Housing Authority Utility Allowance, 2019. For heating, cooking, and water heating utilities, for which multiple energy sources are available, the average for all energy sources was averaged.

2.8. Affordable Housing
State law requires the City to identify, analyze, and propose programs to preserve existing multifamily rental units that are currently restricted to lower income housing use and that will become unrestricted and possibly be lost as lower income housing (i.e., “units at risk” or “at-risk units”).

The following discussion satisfies the first three requirements of State law listed above pertaining to the potential conversion of assisted housing units into market rate housing for the ten-year period between October 15, 2021 and October 15, 2031. The Housing Plan section includes a program for preserving the at-risk units, which meets the final requirement of State law. 0 20,000
40,000
60,000
80,000
100,000
120,000
Management Engineering Education Protective
Services
Sales Healthcare
Support
Food Prep
$70,700 income needed to own
median priced home
$54,829 income needed to rent
median priced home

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A. Inventory of At-Risk Rental Housing Units
Table 30 includes the inventory of assisted housing developments within the City of El Centro as of June 2021. The inventory includes 872 assisted units in deed-restricted affordable housing developments. Most of the properties and units are owned by the Imperial Valley Housing Authority.

Table 30: Assisted Housing In El Centro (2021)
Development Location Ownership
Type
# Assisted
Units
Expiration
Date
Non At-Risk
Fairfield Homes Hope, Holt, Heil & 1st IVHA 50 Perpetuity Green Gables Park Avenue IVHA 19 Perpetuity
Imperialwood Homes Holt & Heil IVHA 32 Perpetuity
Turnkey Units 680 Brighton IVHA 6 Perpetuity
Turnkey Units 580 Brighton IVHA 6 Perpetuity
Turnkey Units Commercial & Brighton IVHA 7 Perpetuity
Turnkey Units Barbara Worth Drive IVHA 9 Perpetuity
El Centro Homes 300 Block of Holt & 400
Block of Hamilton IVHA 21 Perpetuity
Casa de Anza 1690 W. Adams IVHA 36 Perpetuity
Tierra del Sol 1720 W. Adams IVHA 40 Perpetuity
El Centro Family Homes 6
th & Adams IVHA 8 Perpetuity
Cedar Homes Senior 650 Adams IVHA 19 Perpetuity
Boatwright Homes Senior 590 Holt Ave IVHA 20 Perpetuity Valley Apartments I, II, III & IV 970 Waterman Court IVHA 105 Perpetuity Casa de Pajas 402 Adams IVHA 3 Perpetuity
El Centro Senior Villas 515 Park Avenue LIHTC 80 2032
Countryside Apartments 1751 Adams Avenue LIHTC 72 2034
Plaza Senior Apartments 1755 W. Main Street LIHTC 171 2035 Imperial Gardens Family
Apartments 1798 W. Main Street LIHTC 76 2064
Las Brisas Apartments 2001 N. 8th St LIHTC 72 2064
El Centro Senior Villas II 579 Park Ave LIHTC 20 2067
Total Non At-Risk Units 872
At-Risk
Euclid Villas 1735 W Euclid Ave
Profit
Motivated –
Section 8
42 June 30, 2023
Total At-Risk Units 42
Total Housing Stock Within the City of El Centro 42
Source: HUD, 2021. Publichousing.com

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B. Preservation of At-Risk Housing Units
State Housing Element law requires the analysis of government-subsidized housing that may change from low-income housing to market-rate housing during the next ten years. Thus, this at-risk housing analysis covers the period from October 15, 2021 through October 15, 2031. This section evaluates affordable housing in El Centro that may be at-risk of converting to market rates and the estimated costs to preserve or replace the at-risk units.

Within the 2021-2031 “at-risk” housing analysis period, one of the City’s affordable housing projects is considered at low risk of being converted to market rate because the owners have continued to renew their HUD Section 8 contracts. While the HUD renewal process is periodic, the approval is fairly automatic. Though unlikely, it is possible 42 of the City’s affordable housing units could convert to market-rate at some point in the planning period.

According to California Government Code, owners of specified, federally assisted projects are required, unless exempted, to provide "notices of intent" to prepay a federally assisted mortgage, terminate mortgage insurance, or terminate rent subsidies or restrictions at twelve and six months to all affected households and to affected public agencies. However, recent changes in State law requires that the tenants are notified three years, one year, and six months before opting out of low income use restrictions.

Affected public agencies include the city or county where the development is located, the local public housing authority, and the California Department of Housing and Community Development (HCD). Owners of government-assisted developments cannot terminate subsidy contracts, prepay a federally assisted mortgage, or discontinue use restrictions without first providing an exclusive "notice of opportunity to submit an offer to purchase" to each identified qualified entity. The notices to qualified entities5 must be made by registered or certified mail, return receipt requested. The owner shall also post a copy of the notice in a conspicuous place in the common area of the development.

Preservation Options
Depending on the circumstances of the at-risk projects, different options may be used to preserve or replace the units. Preservation options typically include: 1) transfer of units to non-profit ownership; and 2) purchase of affordability covenants. In terms of replacement, the most direct option is the development of new assisted multi-family housing units. The following discussion highlights ways that the City’s at-risk project could be preserved as affordable housing. All of the presented alternatives are costly and beyond the ability of the City of El Centro to manage without large amounts of subsidy from federal and/or State resources. These options are described below.
5 List of current Qualified Entities is maintained and updated by HCD and is subject to change. - https://www.hcd.ca.gov/policyresearch/preserving-existing-affordable-housing.shtml).

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Transfer of Ownership
One preservation option is to transfer the ownership of the at-risk units to a nonprofit organization or purchase similar units by a nonprofit organization. This option is applicable to the Euclid Villas Apartments, as it is a for-profit housing project. By transferring property ownership to a non-profit organization, low income restrictions can be secure and the project would become potentially eligible for a greater range of governmental assistance. The cost of transferring ownership depends on a number of factors, including the market conditions at the time, occupancy rate, and physical conditions of the building and units. The estimated market value for the for-profit units at risk is provided in Table 31.

Current market value for the at-risk units is estimated on the basis of the units’ potential annual income, and operating and maintenance expenses. As indicated, the estimated market value of El Centro’s current stock of at-risk affordable housing is $5.3 million. This estimate is provided for the purpose of comparison and understanding the magnitude of costs involved and does not represent the precise market value of this project. The actual market value at time of sale would depend on market and property conditions, lease-out/turnover rates, among other factors.

Table 31: Market Value of At-Risk Housing Units
Unit Information Total
Two-Bedroom Units 14
Three-Bedroom Units 28
Annual Operating Cost $204,750
Gross Annual Income $630,100.80
Net Annual Income $425,350.80
Market Value $5,316,885.00
Market value for at-risk units is estimated with the following assumptions:

1. Average market rent based on Fair Market Rents air Market Rents (FY 2021) established by HUD (Two-bedroom unit = $1,060, and Three-bedroom unit = $1,444).

2. Average size is assumed to be: 850 square feet for a two-bedroom apartment, and 1,200 square feet for a three-bedroom apartment.

3. Annual income is calculated on a vacancy rate = 5%.

4. Annual operating expenses per square foot = $4.50.

5. Market value = Annual net project income*multiplication factor.

6. Multiplication factor for a building in good condition is 12.5.

Rental Assistance
Tenant-based rent subsidies could be used to preserve the affordability of housing. This option is applicable to all 42 units subsidized with Section 8. The level of the subsidy required to preserve the at-risk units is estimated to equal the Fair Market Rent (FMR) for a unit minus the housing cost affordable by a very low income household. Table 32 estimates the rent subsidies required to preserve the affordability of the 42 at-risk units. Based on the estimates and assumptions shown in this table, approximately $24,472 in rent subsidies would be required monthly (or $293,664 annually). Assuming a 20-year affordability, the total subsidy is about $5.9 million.

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Table 32: Rental Subsidies Required
Unit
Size
Total
Units
Fair
Market
Rent1
Household
Size
Very Low
Income (50%
AMI)2
Affordable
Cost –
Utilities3
Monthly
Per Unit
Subsidy
Total
Monthly
Subsidy
2-br 28 $1060 3 $31,500 $585 $475 $13,300
3-br 14 $1,444 4 $34,950 $646 $798 $11,172
Total 42 $24,472
Notes:

1. Final FY 2021 Fair Market Rent (FMR) is determined by HUD.

2. Imperial County 2021 Area Median Household Income (AMI) limits set by the California Department of Housing and Community Development (HCD).

3. Affordable cost = 30% of household income minus utility allowance.

Purchase of Affordability Covenants
Another option to preserve the affordability of at-risk projects is to provide an incentive package to the owners to maintain the projects as affordable housing. Incentives could include writing down the interest rate on the remaining loan balance, and/or supplementing the subsidy amount received to market levels.

To purchase the affordability covenant on these projects, an incentive package should include interest subsidies at or below what the property owners can obtain in the open market. To enhance the attractiveness of the incentive package, the interest subsidies may need to be combined with rent subsidies that supplement the HUD fair market rent levels.

Replacement Option
The construction of new lower income housing units is a means of replacing the at-risk units should they be converted to market rate. The cost of developing new housing depends on a variety of factors such as density, size of units, location and related land costs, and type of construction. Euclid Villas is comprised of two- and three-bedroom family apartment units.

Assuming an average development cost of $389,000 per unit for multi-family rental housing, replacement of the 42 at-risk units at Euclid Villas would require approximately $16.3 million, excluding land costs, which vary depending upon location.

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Table 33: Estimated New Construction Costs
Unit Size
(A) (B) (C) (D)
Total Units
Estimated
Average
Unit Size
(sq. ft.)
Estimated
Gross
Building
Size
Estimated
Gross
Building
Costs
2-BR 14 850 14,280 $4,270,937
3-BR 28 1,200 40,320 $12,059,115
Total 42 54,600 $16,330,052
Average Per Unit Cost: $388,810.76
(C) = (A) x (B) x 1.20 (i.e. 20% inflation to account for hallways and other common areas). (D) = (C) x $ 287 (per square foot construction costs) x 1.25 (i.e. 25% factor to account for parking and landscaping costs).

Note: City estimated construction costs ranged between $200-$250 for non-prevailing wage projects and $300 for prevailing wage projects. The $287 per square foot per construction cost based on a recent 56-unit project (45,000 sq ft).

Cost Comparison
The cost to build new housing to replace the 42 at-risk units is high, with an estimated total cost of more than $16.3 million. This cost estimate is substantially higher than the cost associated with transfer of ownership ($5.3 million) and providing rent subsidies similar to Housing Choice Vouchers for 20 years ($5.9 million).

Resources for Preservation of At-Risk Units
A variety of potential funding sources are available for the acquisition, replacement, or rent subsidies; however, due to the high costs of developing and preserving at-risk housing relative to the amount of available local funds, multi-layering of local and non-local sources may be required. A more thorough description of resources for the preservation of at-risk units is presented in Section 4, Housing Resources. The City will continue to monitor the 42 at-risk units located in Euclid Villas and should a notice of intent to convert to market rate be filed, work with potential purchasers to preserve the units, and ensure that tenants were properly notified of their rights under California law.

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3. Housing Constraints
Although El Centro strives to ensure the provision of adequate and affordable housing to meet the needs of the community, many factors can constrain the development, maintenance and improvement of housing. These include market mechanisms, government regulations, and physical as well as environmental constraints. This section addresses these potential constraints that affect the supply and cost of housing in El Centro.

3.1. Market Constraints
Several local and regional constraints hinder the ability to accommodate El Centro’s demand for affordable housing. The cost of land and development costs can make it expensive for developers to build housing. Historically, these constraints have resulted in housing that is often unaffordable to lower, and often moderate, income households, or may render some potential residential projects economically infeasible for developers. Subsidies are often necessary to bridge the gap between market rate and affordable housing costs by lower income households.

In fact, most affordable housing developments in El Centro today often require multiple subsidy sources in order to make a project financially feasible.

According to the United States Department of Housing and Urban Development, Imperial County experienced a building boom in the residential development market prior to the recession (2001 - 2007) with over 7,000 permits issued for single-family residences, peaking twice above 1,500 permits issued annually. The same period also saw permits issued for over 1,700 units of multi-family housing. Since then, the market has not recovered, never reaching 300 permits issued annually for single-family residences, and no multi-family permits issued at all in half of the years, as shown in the chart below.

In El Centro, the time lapse between project entitlement and building permit issuance varies depending on project type. Delays are attributed few local building plan drafters, civil engineers, and architects that located in the County resulting in high workload for them as well as projects requiring outside financing, public subsidies, or grant funding that delay project commencement.

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Figure 6: Imperial County Housing Building Permits (2001-2019) A. Land Costs
Land costs vary significantly in the City depending on zoning, location of the property, and proximity to services. As of October 2020, the market value of a subdivided and residentiallyzoned land served by infrastructure cost approximately $200,000 per acre (a multi-family zoned

5.91-acre parcel was valued at 1,1800,000).

Although restricted financing for construction and home purchases have reduced demand for new residential construction in recent years, the cost of raw, developable land still comprises a significant portion of overall housing costs. For this reason, developers often seek City approval for the largest number of single-family lots or multi-family units allowed on a given parcel. This allows the developer to distribute the costs for new infrastructure improvements (e.g., streets, sewer lines, water lines, drainage, etc.) over a larger number of units to be sold or rented.

B. Construction Costs
Construction cost is determined primarily by the cost of labor and materials. The relative importance of each is a function of the complexity of the construction job and the desired quality of the finished product. As a result, builders are under constant pressure to complete a job for as low a price as possible while still providing a quality product. This pressure has led (and is still leading) to an emphasis on labor-saving materials and construction techniques.

The price paid for material and labor at any one time will reflect short-term considerations of supply and demand. Between 2003 and 2008, residential construction costs rose in response to an extremely active housing market. Since 2008, construction costs have moderated due to the housing industry downturn. Future costs are difficult to predict given the cyclical fluctuations in demand and supply that in large part are created by fluctuations in the state and national

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economies. Such policies unilaterally impact construction in a region and therefore do not deter housing construction in any specific community.

For the average home, the cost of labor is generally two to three times the cost of materials and therefore represents a substantial component of the total cost of construction. Most relatively small residential construction jobs in Imperial County are performed with nonunion contractors; as a result, labor costs are responsive to changes in the residential market. The relative ease by which a skilled tradesperson can get a contractor’s license further moderates the pressures that force labor costs to rise. Construction costs in El Centro are about the same as in other parts of Imperial County. According to City estimates in 2020, costs may range between $75 and $85 per square foot for single-family residences depending on the level of amenities provided, and $230 to $300 (prevailing wage) per square foot for multi-family residential structure, depending on construction type and excluding parking. These estimates are based on a 1,300-square-foot singlefamily home and a 56-unit project with a cost per unit of $233,389.

A reduction in amenities and quality of building materials (above a minimum acceptability for health, safety, and adequate performance) could result in lower sale prices. Economy building techniques may reduce costs. In addition, prefabricated, factory-built housing may provide for lower priced housing by reducing construction and labor costs. Another factor related to construction costs is the number of units built at one time. As the number of units is increased, construction costs over the entire development are generally reduced based on economies of scale. This reduction in costs is of particular benefit when density bonuses are used for the provision of affordable housing.

C. Home Financing
The availability of financing can affect a person’s ability to purchase or improve a home. Under the Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications by the income, gender and race of the applicants. This applies to all loan applications for home purchases, improvements and refinancing, whether financed at market rate or with federal government assistance. Locally assisted mortgages (such as first-time homebuyer programs) are not subject to HMDA reporting.

Table 34Error! Reference source not found. summarizes the disposition of loan applications submitted to financial institutions for home purchase, refinance and home improvement loans within El Centro in 2017. Included is information on loan applications that were approved and originated (i.e. accepted by applicant and issued), approved but not accepted by the applicant, denied, withdrawn by the applicant or closed for incomplete information.

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Table 34: Disposition of Home Loans (2017)
Disposition
Home Purchase
Refinances Home
Improvement Government
Backed Conventional
# of
Appl’n %
# of
Appl’n %
# of
Appl’n %
# of
Appl’n %
Approved,
Originated 289 74.3% 267 66.9% 485 45.5% 51 45.5%
Approved, Not
Accepted 16 4.1% 24 6.0% 33 3.1% 2 1.8%
Denied 38 9.8% 45 11.3% 206 19.3% 43 38.4%
Withdrawn/Incomplet
e
46 11.8% 63 15.8% 342 32.1% 16 14.3%
Total 389 100.0% 399 100.0% 1,066 100.0% 112 100.0%
Appl’n = Applications
Note: Due to a change in report formatting, the FFIEC and LendingPatterns had delayed release of more recent data after the reformatting.

Source: Lendingpatterns,com, 2020.

Home Purchase Loans
In 2017, a total of 389 households applied for government backed loans (e.g. FHA, VA) in El Centro. The overall loan approval rate was 78 percent and 10 percent of applicants were denied.

The same year, 399 households applied for conventional home purchase loans and 73 percent of these applications were approved while 16 percent were denied.

To be eligible for government-backed loans, residents must meet the established income standards and the price of the home is capped according to the specific funding program regulations. For calendar year 2017, the FHA home price limit for Imperial County was $484,350, well above the median home price in El Centro. FHA loans typically require a lower downpayment and people with less than stellar credit history may still qualify. Therefore, use of FHA in El Centro is popular when lending in the conventional market has tightened.

Refinance Loans
The conversion of introductory low-interest rate loans prevalent until about 2007 into high interest rates and subsequent changes in the housing market overall led El Centro residents to file 1,066 refinance loan applications in 2017. Approximately than half of the applications (49 percent) of the refinance loans were approved.

Home Improvement Loans
Only 112 El Centro residents applied for home improvement loans in 2017. Of these applicants, 47 percent were approved and 38 percent were denied. The large proportion of home improvement loan denials may be explained by the nature of these loans. These loans are usually second loans and therefore, many households may have already carried a high debt-to-income

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ratio to qualify for additional financing. This pattern is also similar to the experience of residents living in other parts of California.

Foreclosures
Between 2000 and 2005, with low interest rates, “creative” financing (e.g., zero down, interest only, adjustable loans), and predatory lending practices (e.g. aggressive marketing, hidden fees, negative amortization), many households purchased homes that were beyond their financial means. Under the false assumptions that refinancing to lower interest rates would always be an option and home prices would continue to rise at double-digit rates, many households were (and still are) unprepared for the hikes in interest rates, expiration of short-term fixed rates, and decline in sales prices that set off in 2006. Suddenly faced with significantly inflated mortgage payments, and mortgage loans that are larger than the worth of the homes, many had to resort to foreclosing their homes. The City was hard hit by the 2008 foreclosure crisis. From January 2008 to March 2009, Imperial County had 4,122 foreclosures. Out of the 4,122 foreclosures, 1,026 were in El Centro. From July 2010 to April 2011, the City had 308 foreclosures which represented a 70 percent drop from the 2008 foreclosures. In July 2021, only 18 residential properties in El Centro were listed as foreclosures for sale (http://www.homes.com, accessed July 26, 2021\.). However, the full economic impact of the COVID-19 pandemic may present a different picture when State and Federal relief measures expire in the future.

D. Timing and Density
Non-governmental market constraints can also include timing between project approval and requests for building permits. In most cases, this may be due to developers’ inability to secure financing for construction. Developers at stakeholder interviews expressed that timing between project approval and issuance of building permits is critical since market can change quickly and may lead to changes in pricing. Increased costs are then added to the cost of the units. Timing varies from project to project - there are projects that submit to the Building Department within a month and are approved within four weeks, while other recent projects have taken from four months to five years. For example, Phase I El Dorado Family Apartments, which is currently under construction, took five years between the project approval and issuance of a building permit. The original planning approval for Phase I was given in 2015 but since it is an affordable housing development, the developer had to get funding and credits to line up. It took five years to secure all the funding and tax credits for Phase I. However, the developer was able to secure funding for Phase II of the project at the same time and resubmitted a Site Plan Review with Phase II in early 2020 that was approved on 3/9/2020. The developer started working on structural plans and civil plans to submit for both phases together and during that time the City met with the project developer to provide comments prior to building permit submittal.

In the example of Girasol Apartments (another affordable housing development), the project had some funding available. Therefore, the project developer able to submit for a building permit on December 9, 2019 – four months after planning approval on August 16, 2019.

The Town Center development (market rate development) that was recently completed was originally approved by Planning in 2017 but did not submit for building permit until November 17, 2019. The building permits were approved in late December 2019 but since it was a large

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project, the developer decided to pull permits in three phases. This means that the approved building permits for Phase II and Phase III sat for some time. The last of Phase III buildings were pulled in June, July, and August of 2019 and they were “finaled” and issued certificates of occupancy in July of 2020.

As described in the Housing Resources section of this Housing Element, development projects proposed in El Centro are generally below the maximum density allowed. For all zones for which recent examples were available, developments reached between 50 and 76 percent the maximum allowable density. This is due primarily to the availability of vacant and relatively inexpensive land in El Centro, not due to the City’s development standards. Nevertheless, as part of the General Plan update, the City created a mixed use overlay to offer opportunities for different product types at more densely configured developments.

E. Efforts to Address Nongovernmental Constraints
The City has taken into consideration the nongovernmental constraints in the development of this Housing Element and its Land Use Element. Developers at the stakeholder meeting expressed that timing was the most critical non-governmental constraint since future materials prices, residential demand, mortgage rates are hard to predict and can change quickly. The City is committed to helping developers process their applications quickly. The City’s turnaround time for approval is relatively fast compared to other cities. A Site Plan Review (SPR) has a turnaround of five to six weeks for approval. If a project requires Planning Commission approval due to a CUP or parcel map, the turn-around time is six to eight weeks. Building Plan Check approvals are relatively quick, a multi-family development is usually approved within six to eight weeks while a single-family home and ADU can be approved within two weeks. The time consuming portion is taken by the applicant while they address redlines/corrections. The City offers many avenues to help developers address the changes needed. If the building plan check is kept in house, the City’s building inspectors and building officials will, at the request of the applicant (or their architect/structural engineer), meet to review redlines/corrections. The City’s building department also receives phone calls to clarify the redlines/corrections and its building inspectors make time for those calls.

In addition, the City has committed to assisting and support developers of housing for lower income households, especially housing for extremely low income households and the disabled (including the developmentally disabled), by conducting pre-application meetings, assisting with design and site requirements, and providing regulatory incentives and concessions (Program 5).

3.2. Governmental Constraints

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Housing affordability is affected by factors in both the private and public sectors. Actions by the City can have an impact on the price and availability of housing in El Centro. Land use controls, site improvement requirements, building codes, fees, and other local programs intended to improve the overall quality of housing may serve as a constraint to housing development. These governmental constraints can limit the operations of the public, private, and nonprofit sectors, making it difficult to meet the demand for affordable housing and limiting supply in a region.

A. Land Use Controls
Local land use policies and regulations impact the price and availability of housing, including affordable housing. The following discussion of land use controls demonstrates that El Centro encourages the provision of residential land uses at various densities to facilitate the provision of housing for all economic segments of the community.

General Plan Land Use Designations
The El Centro General Plan was updated in 2021, including a comprehensive update to the Land Use Element and Mobility Element (formerly Circulation Element), and the preparation of a new Environmental Justice Element. The General Plan Land Use Element establishes policies to designate the general distribution and intensity of residential, commercial, industrial, and community facilities uses of the land in the City. As summarized in Table 35Error! Reference source not found., the Land Use Element accommodates a wide range of housing types in the following land use designations.

Table 35: Land Use Designations that Allow Residential Uses Land Use Element
Designation Max. Density/ FAR Summary of Allowable Residential Uses Rural Residential 2 du/ac
Single-family detached dwelling units and ADUs; small
agricultural operations & rural-oriented residences and out-buildings.

Low Density Residential 6 du/ac Single-family detached dwelling units, ADUs, & accessory buildings.

Medium Density
Residential 12 du/ac Single-family detached dwelling units, ADUs, mobile home parks, duplexes, or multiple-family units.

High-Medium Density
Residential 25 du/ac Variety of multi-family dwelling units.

Tourist Commercial 1.0:1 FAR
Motels, resort hotels, related commercial & tourist
oriented uses, retail & freeway-oriented uses; multiplefamily residential may be permitted.

Mixed Use 1

1.0:1 FAR (mixed use)
min. 12 du/acre
max. 25 du/acre, or 32
du/acre for senior
projects
Multiple-family residential, live/work, & retail & serviceoriented uses serving the needs of local neighborhoods; allows mixed use, stand-alone residential, stand-alone
commercial developments.

Source: City of El Centro General Plan Land Use Element, 2021

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Overlay Designations
Single-Family Neighborhood Overlay
The Single-Family Neighborhood Overlay is intended to recognize and preserve the historical character of El Centro’s older residential neighborhoods that were developed in the early 1920s.

As infill development occurs, the character of these neighborhoods has the potential to change as older, smaller bungalows are replaced with larger, modern homes or multi-family housing. The overlay will help facilitate the preservation of unique examples of single-family architecture that contribute to the City’s heritage. In the event that an older single-family unit within the overlay needs to be replaced, such as in the event of a fire, owners are encouraged – but not required – to reconstruct in a similar style and scale as the original home.

Medical Office Overlay
The Medical Office Overlay allows properties within the overlay designation to transition to medical office, remain single-family residential, or allow a combination of both uses in a live/work project. Parcels that are redeveloped to medical office and live/work (medical office use) are encouraged to take access from the alley to the east of the overlay area and to close existing driveways that take access from Imperial Avenue to improve traffic flow and safety. The maximum FAR for live/work development in this overlay designation is 1.0:1, with a maximum density for live/work or residential development of 6 du/acre.

Mixed Use 2 Overlay
The Mixed Use 2 Overlay provides for a mix of Missing Middle, multi-family residential, and non-commercial uses to support an active, community- or regional-serving corridor, area, or activity center. A variety of housing options along a continuum of high-medium to higher densities are encouraged to provide affordable housing for a range of household types. This overlay encourages, but does not require, an integrated mix of residential and commercial uses on the same parcel. Stand-alone multi-family residential development is permitted, as is standalone non-residential development. The maximum FAR for mixed use (including live/work) is

1.2:1. The minimum residential density is 21 du/acre, and the maximum is 30 du/acre, with a maximum of 38 du/acre for senior projects.

Opportunity Areas
Opportunity Areas (OAs) identify locations where the City of El Centro desires or anticipates land use change or growth to occur. Several OAs are areas of existing development that can benefit from targeted plans and policies to help guide transformation, while others are proposed for property that either has not yet been developed and/or where growth is expected or proposed to occur. Each OA has a vision and policies to guide future planning. A key element of each OA is the correlation of land use and site design with proposed improvements to the mobility infrastructure. The following reflects the vision for each of the five OAs.

OA-1: Adams Avenue Mixed Use Village District
The Adams Avenue Opportunity Area is a compact, walkable and bikeable, transit-accessible, mixed-use area that provides a variety of new housing options and neighborhood commercial uses and services for existing and new residents.

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OA-2: Downtown El Centro
Downtown El Centro is the cultural and social activity center for El Centro. It serves as a destination for arts, culture, creative industries, community-serving businesses, entertainment, and festivals, offering products, services, and fun for locals and visitors alike.

OA-3: North Dogwood Opportunity Area
The North Dogwood Opportunity Area is designated for Tourist Commercial land use. Coupled with its size and proximity to the I-8 freeway, offers many opportunities for a variety of largerscale uses to attract locals and tourists alike. Big-box retail, indoor and/or outdoor recreational, entertainment, and amusement venues, and other tourist-supporting uses would benefit from the area and the location.

OA-4: South Dogwood Opportunity Area
The South Dogwood OA is a mixed-use activity center that continues to be a regional shopping destination within a walkable village of higher density residential, recreational, and other compatible uses that attract locals and visitors alike. The area provides a variety of housing choices that appeal to seniors.

OA-5: South Imperial Avenue
The vision for OA-5 promotes implementation of the mixed-use village concept both for individual projects and for the area as a whole as El Centro expands to the south. The interchange at Imperial Avenue and I-8 and the extension of Imperial Avenue south to McCabe will open hundreds of acres of vacant property within both the City and the SOI to development as residential and commercial use.

Master Planned Mixed Use Special Planning Area
The General Plan Land Use Element includes a Special Planning Area that is proposed for an area within the City’s Sphere of Influence in the vicinity of the future extension of Imperial Avenue.

The intent of this Master Planned Mixed Use Special Planning Area is to provide guidance for how future development should occur if the area is annexed, with an emphasis on sustainability and Smart Growth principles. While actual density and intensity standards will be established for this area if it is annexed, it was assumed that approximately 60 percent of net area will develop with an average density of 8.5 du/ac across the entire area. The expectation is that a full range of residential types and densities will be provided, including but not limited to attached and detached single-family residential, small-lot single-family residential, cottage/court style housing, townhouses, duplexes, triplexes, quads, stacked flats (apartments), accessory dwellings, live/work units, and senior housing.

Urban Development Program
The General Plan incorporates an Urban Development Program, which was adopted to direct and control growth in the City and sphere of influence (SOI). The goal of the program is to create a community that is compact and pedestrian and transit-oriented development, avoids removing more agricultural land from production than necessary, and can meet the public service and infrastructure needs of existing and future residents. Development “tiers” are established for the

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SOI and implementation of the program will ensure that a variety of growth locations are available and timed to maintain reasonable housing costs and promote economic development.

To identify those areas that will require more extensive planning, ensuring the provision of adequate levels of public services and facilities, the undeveloped portion of the planning area for the Urban Development Program has been divided into three development tier areas, as described below. Designation of an area in one of the three tiers does not determine the sequence of development within the planning area, but rather, delineates those areas that, due to a lack of public facilities, may require more detailed planning prior to development. For example, development in Development Tier II and III may require a greater cost for infrastructure improvements than would the same development if located within the Development Tier 1 area, since Tier 1 has greater access to existing public services and facilities. Tier II and III areas also may require that facilities be sized, at developer expense, to accommodate additional development within an entire Tier Subarea (described below), or such larger area as may be required by the City. Reimbursement agreements, improvement districts, and other public finance strategies may be used to cost-effectively provide needed public infrastructure, as deemed necessary by the City Council.

Specific Plans
The General Plan anticipates and encourages the use of specific plans when designing new projects, especially those that will include large areas of land. For example, future development proposed within Urban Development Program Tiers II/III may benefit most from the specific planning process. The specific plan process allows for a more comprehensive planning process for the target area and can be a mechanism to allow for flexibility in the design and location of future land uses.

Airport Land Use Plan
Due to the close proximity of the Imperial County Airport, land use options are limited in a portion of northern El Centro. The Imperial County Airport Land Use Commission is responsible for maintaining an Airport Land Use Plan (ALUP), which includes a set of land use compatibility criteria for lands surrounding the Imperial County Airport. Portions of northern El Centro are located within the D zone, representing negligible risk from airport activity, whereas other areas are in the approach and departure zones (B1/B2) and are subjected to risk and noise exposure.

The ALUCP for the Imperial County airports was approved in 1982 and last revised in 1996. The California Department of Transportation (Caltrans) Airport Land Use Planning Handbook (Caltrans Handbook) was revised in 2011, and identifies modified geometrics, naming conventions, and evaluation criteria for ALUCP map zones. Until the ALUCP is revised to reflect the most current Caltrans Handbook, applicable proposed actions are analyzed pursuant to the Caltrans Handbook to enable the Imperial County Airport Land Use Commission to determine if they comply with current Caltrans regulations.

The City’s Zoning Ordinance includes a Residential Airport Zone (RAP) that regulates development to ensure consistency with the ALUP. The Residential Sites Inventory does not

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include any parcels within the RAP zone. The ALUP is not considered a significant constraint in El Centro.

B. Residential Development Standards
The City’s Zoning Ordinance (Chapter 29 of the El Centro Municipal Code) regulates the type, location, density and scale of residential development for areas of the City. Zoning regulations are designed to protect and promote the health, safety and general welfare of residents as well as implement the policies of the General Plan. Table 36 Error! Reference source not found. below provides a summary of the range of residential land uses and associated densities and FloorArea-Ratio (FAR) allowed in the City pursuant to the Zoning Ordinance. New residential construction and alterations to existing structures and sites must conform to the development standards summarized in Table 37.

Table 36: Zoning Districts that Allow Residential Uses
Zoning Category Max.

Density/FAR Notes
Residential Airport
(RAP) 1 du/ac
Allows for the development of residential uses within areas designated as "extended approach/departure zone" under the Imperial County Airport Land Use Compatibility Plan where risk factors have been identified resulting in the need for restricting density. A conditional use permit (CUP) is required for residential development in this zone.

Rural Residential (RR) 2 du/ac Provides for large lot rural residential uses and is intended to implement the Rural Residential general plan land use designation.

Low Density (R1) 7 du/ac
Provides for the development of a single-family home (or mobile home on a permanent foundation) and the protection of these dwellings from incompatible uses. Intended to implement the Low Density Residential general plan land use designation.

Medium Density (R2) 12 du/ac
Permits the development of medium density, single-family, duplex, or multi-family dwellings and is intended to implement the Medium Density Residential general plan land use designation.

High-Medium Density
(R3) 25 du/ac
Permits the development of medium high density apartment and condominium dwellings and is intended to implement the High Medium Density Residential general plan land use designation.

Tourist Commercial
(CT) 1:1 FAR
Allows for some types of multi-family and mixed-use residential by CUP and is intended to implement the Tourist Commercial general plan land use designation.

Office Commercial (CO) 0.40:1 FAR
This zone is intended for establishment of professional and administrative offices, medical care centers and ancillary services with appropriate landscaping and development standards which provide relative compatibility for such uses near residential areas.

The CO zone is intended to implement the office commercial general plan land use designation.

Neighborhood
Commercial (CN) 0.25:1 FAR
This zone is intended for retail uses serving principally the convenience shopping needs of the neighborhood in which it is located. Caretaker’s residences are permitted in this zone. The CN

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Table 36: Zoning Districts that Allow Residential Uses
Zoning Category Max.

Density/FAR Notes
zone is intended to implement the neighborhood commercial general plan land use designation.

General Commercial
(CG) 0.50:1 FAR
This zone is intended for general business, light service and retail uses, as well as large-scale planned shopping districts and, where appropriate, hotel and public assembly uses. Caretaker’s residences, homeless shelters, and group care facilities are permitted/conditionally permitted in this zone. The CG zone is intended to implement the general commercial general plan land use designation.

Heavy Commercial
(CH) 0.50:1 FAR
This zone is intended for general commercial uses, business and consumer services, and light manufacturing. Caretaker’s residences and homeless shelters are permitted in this zone. The CH zone is intended to implement the heavy commercial general plan land use designation.

Source: City of El Centro Municipal Code, 2021
The zoning code is consistent with General Plan densities, and allows development at up to 25 du/acre in the most dense residential zones (R3). Maximum density in commercial zones is regulated by cumulative application of the development standards, including maximum height, lot coverage, FAR, parking, and setbacks. Up to 45 feet (or 3 stories) and 60 percent lot coverage is allowed within the R3 zone.

The recently updated General Plan adds a new Mixed-Use 1 land use category, which promotes mixed use development with 1.0:1 FAR (mixed use), yet allows the flexibility for stand-alone commercial or stand-alone residential at densities of a minimum 12/du/acre, up to 25 du/ac, or up to 32 du/acre for senior housing developments. A new Mixed-Use 2 overlay is added for which the minimum residential density is 21 du/acre, and the maximum is 30 du/acre, with a maximum of 38 du/acre for senior projects. Because the updated Land Use Element of the General Plan was adopted in June 2021, a program has been developed to update the zoning code to allow mixed use development at these densities.

Table 37: Development Standards by Zoning District (Residential Zones) Standard RAP RR R1 R2 R3
Min. Lot Size:

Single-family 1 acre1 ½ acre 6,000 sf 3,600 sf 3,600 sf Multi-family N/A N/A N/A 7,200 sf 7,200 sf
Max. Lot Coverage 35% 25% 50% 50% 60%
Min. Lot Width 150 ft 100 ft 50-60 ft 60-65 ft 60-65 ft Min. Lot Depth 150-200 ft 100-200 ft 60-150 ft 65-150 ft 65-150 ft Max. Building Height2 35 ft 35 ft 35 ft 35 ft 45 ft
Open Space3
2 units on a lot 400 sf 400 sf 400 sf 400 sf 400 sf4
>2 units on a lot 150 sf 150 sf 150 sf 150 sf 150 sf4

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Table 37: Development Standards by Zoning District (Residential Zones) Standard RAP RR R1 R2 R3
Setbacks:

Front 60 ft 40 ft 20 ft 20 ft 20 ft
Rear5 20-50 ft 10-50 ft 5-50 ft 5-50 ft 5-50 ft
Side 0-30 ft 0-20 ft 0-15 ft 5-20 ft 5-20 ft
Source: El Centro Municipal Code, 2021.

Notes:
1 Density of one du/acre is required per the General Plan; however, densities consistent with the R1 zone may be allowed as a cluster development, subject to CUP and so long as the average densities within the designated “extended approach/departure” areas do not exceed one du/acre.
2 A CUP may be granted to authorize additional exceptions to height limits in any zone. 3 When a private open space area greater than ninety-six (96) square feet with a minimum width of eight (8) feet is provided for each dwelling unit, the total common open space requirements may be reduced by twenty-five (25) percent. 4 In addition, a minimum of 50 square feet of private of private open space required contiguous to each dwelling unit. 5 The top end of setback range applies to lots abutting a freeway.

Table 38: Development Standards by Zoning District (Commercial Zones) Standard CT CO CN CG CH
Min. Lot Size: 7,200 sf 6,000 sf N/A N/A N/A
Max. Lot Coverage 60% 40% N/A N/A N/A
Min. Lot Width 60-65 ft 60-65 ft N/A N/A N/A
Min. Lot Depth 100-150 ft 100-135 ft N/A N/A N/A
Max. Building Height1 65 ft 65 ft 45 ft 65 ft 45 ft
Setbacks:

Front 20 ft 20 ft 20 ft 0 ft 0 ft
Rear5 5-25 ft 5-25 ft 0-25 ft 0-25 ft 0-25 ft
Side 5-15 ft 5-15 ft 0-15 ft 0-10 ft 0-10 ft
1 A CUP may be granted to authorize additional exceptions to height limits in any zone.

The maximum height of residential buildings in the RAP, RR, R1 and R2 zones is 35 feet, which is sufficient to accommodate two-story buildings. Maximum lot coverage ranges from 25 percent in the RR zone to 50 percent in the R1 and R2 zones.

Open space requirements apply within all residential zones. At least 400 square feet of common open space is required per unit when two units are proposed on a lot and 150 square feet per unit is required when more than two units are proposed. In the R3 zone, a minimum of 50 square feet of private of private open space required contiguous to each dwelling unit. The Zoning Ordinance allows a 25 percent reduction in total common open space when a development provides more than 96 square feet of private open space per unit with a minimum width of eight feet. This Housing Element includes a program to update the City’s open space requirements to allow a reduction in open space when high-quality community amenities, such as play structures or covered seating and food preparation areas, are provided. The City will also evaluate incentives to encourage developers to design required stormwater systems to accommodate passive recreational areas to increase available common open space.

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Overall, El Centro’s development standards are typical for the region and have not been a constraint on residential development. In the past four years there have been six larger singlefamily and multi-family developments, creating a total of 109 single-family dwellings and 243 multi-family dwellings. However, only 22 of these have been developed as affordable units.

Density Bonus Ordinance
Density bonuses, together with the incentives and/or concessions, allow residential projects to exceed maximum densities within a zone, and result in a lower average cost of land per dwelling unit thereby making the provision of affordable housing more feasible. The City’s density bonus regulations were most recently updated in 2013. Since then, there have been a number of changes to density bonus requirements in state law. AB 1763 (enacted in 2019) requires a density bonus to be granted for projects that include 100 percent lower income units, but allows up to 20 percent of total units in a project that qualifies for a density bonus to be for moderate-income households.

Density bonus projects must be allowed four incentives or concessions and, for developments within ½ mile of a major transit stop, a height increase of up to three additional stories or 33 feet.

A density bonus of 80 percent is required for most projects, with no limitations on density placed on projects within ½ mile of a major transit stop. The bill also allows developers to request the elimination of minimum parking requirements for rental units affordable to lower-income families that are either supportive housing or special needs housing, as defined. AB 2345 (enacted in September 2020) further incentivizes the production of affordable housing by increasing the maximum available density bonus from 35 percent to 50 percent for qualifying projects not composed exclusively of affordable housing.

The Housing Plan includes a program to update the City’s zoning ordinance to bring density bonus regulations into compliance with currently adopted state law. The City will also continue to work with developers on a case-by-case basis to provide regulatory concessions and incentives to assist them with the development of affordable and senior housing. Working alongside developers on a case-by-case basis is the most effective method of providing technical assistance as each individual project can be analyzed to determine which concessions and incentives would be the most beneficial to the project’s feasibility.

Parking Requirements
Parking requirements for different types of residential uses in El Centro are summarized in Table 39Error! Reference source not found.. The requirements are in line with typical off-street parking required for residential uses throughout the region. The requirements for multi-family apartment developments are reasonably adjusted for unit size and the requirements for multi-family and senior apartments are lower than ratios available to affordable housing developers pursuant to State density bonus law. Off-street parking requirements do not pose a constraint on housing development in El Centro. The Housing Plan includes a program to establish an accessory dwelling unit ordinance with parking requirements conforming with state law. As part of this program, the City will also evaluate reductions to off-street parking requirements for multifamily residential uses.

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Table 39: Off-Street Residential Parking Requirements
Use Parking Spaces Required
Single-family 2.0 / du
Duplex 2.0 / du
Multi-family
Studio 1.0 / du + 0.25 / du (guest)
1 BR 1.5 / du + 0.25 / du (guest)
2 BR 2.0 / du + 0.25 / du (guest)
3+ BR 2.0 / du + 0.50 / br over 3, plus 0.25 / du (guest) Condos or Townhomes 2.0 / du + 0.25 / du (guest)
Second Dwelling Unit 1.0 / du + 0.50 / br over 2
Senior Apartments 1.0 / du + 0.25 / du (guest)
Mobile homes in parks or
planned developments

1.0 / du + 1.0 / 6 du (guest) + 1.0 / 10 du used for
recreation center parking
Rest homes 1.0 / 1,000 sf
Source: City of El Centro Zoning Ordinance, 2021
C. Provisions for a Variety of Housing Types
State Housing Element law specifies that jurisdictions identify adequate sites to be made available through appropriate zoning and development standards to encourage the development of various types of housing for all economic segments of the population. This includes single-family housing, multi-family housing, mobile homes, farm employee housing, emergency shelters, transitional and supportive housing, among others. Table 40 and Table 41Error! Reference source not found. summarize the various housing types permitted and conditionally permitted under the City’s Zoning Ordinance.

Table 40: Provision for a Variety of Housing Types (Residential Zones Housing Type RAP RR R1 R2 R3
Single-Family P P P P P
Mobile Home1 P P P P P
Duplex and Two-Family Dwelling X X X P P
Multi-Family Dwellings X X X P P
Group Dwellings X X X X P
Mobile Home Park C C C C C
Senior Apartments X X X C C
Retirement Homes X X X C C
Rest Homes, Convalescent Homes and Nursing Homes X X X X C Second Dwelling Unit P P P P P
Homeless Shelters, Emergency Shelters X X X X P
Guest Dwellings P P P X X
Accessory Unit P P P P X

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Table 40: Provision for a Variety of Housing Types (Residential Zones Housing Type RAP RR R1 R2 R3
Small Residential Care Facilities, Group Homes,
Supportive Housing, Transitional Housing P P P P P
Large Residential Care Facility X P P P P
Farm Employee Housing (Incidental to Ag Use) X P X X X
Table 41: Provision for a Variety of Housing Types (Commercial Zones) Housing Type CT CO CN CG CH
Caretaker’s Residence X X P P P
Convalescent Homes X C X C C
Group Care Facilities and
Residential Retirement Hotels C C X C X
Multi-Family Residential or
Residential Units on 2nd Floor and
Above Commercial Uses, Including
Residential Care Facilities,
Transitional Housing and Supportive
Housing

C X X X X
Homeless Shelters, Emergency
Shelters X X X P P
Single Room Occupancy Buildings C X X X X
Detached Single-Family Accessory
Residential Unit1, 2 P P P P P
Mixed Use X X X C X
1 In any commercial or manufacturing zone, a single accessory residential unit may be established when it is located within and occupies not more than 20 percent of the floor area of a commercial or industrial building, and is occupied exclusively by the owner, caretaker, superintendent, or security personnel and his/her family 2 Within the ML (Light Manufacturing) or MG (General Manufacturing) zones only, a detached single-family accessory residential unit is permitted, provided that it occupies not more than 20 percent of the floor area occupied by the principal manufacturing use and is screened from view from any public street in a manner satisfactory to the city Single-Family
The term “dwelling, single-family” is defined in the Zoning Ordinance as a detached building or mobile home designed primarily for the use of a single family and no portion of which is to be rented separately. The Housing Plan includes a program to update to zoning ordinance to ensure regulations for single-family dwellings conform to state law allowing Accessory Dwelling Units (ADUs) and Junior Accessory Dwelling Units (JADUs), and to facilitate the development of ADUs/JADUs. Single-family units are permitted by-right in all residential zones.

Mobile Homes and Manufactured Housing
The El Centro Zoning Ordinance defines mobile home as a structure designed as a permanent dwelling unit to be used with or without a permanent foundation, and which is in excess of eight feet in width or in excess of 40 feet in length. This definition includes “manufactured home” as defined in the California Health and Safety Code.

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A mobile home that was constructed after September 15, 1971, and was issued an insignia of approval by the state Department of Housing and Community Development or a mobile home that has been certified under the National Mobile Home Construction and Safety Standards Act of 1974 (42 U.S.C. § 5401 et seq.), and located on a permanent foundation is permitted in all residential zones on lots where no other mobile home on a permanent foundation, single-family dwelling or multi-family dwellings are located, regardless of the lot size and the number of dwelling units otherwise permitted by the Zoning Ordinance.

Mobile Home Parks
Mobile home parks include an “area or tract of land where two (2) or more mobile home lots are rented or leased or held out for rent or lease to accommodate mobile homes for human habitation.” Mobile home parks are permitted in all residential zones with approval of a CUP.

Accessory Dwelling Units
An Accessory Dwelling Unit (ADU) is a dwelling unit with complete independent living facilities for one or more persons. A Junior Accessory Dwelling Unit (JADU) is a type of ADU that is 500 square feet or less and located within a primary residence. The Zoning Ordinance currently includes two different types of dwellings that can be classified as ADUs. These include a “second dwelling unit”, defined as “a separate residential unit containing sleeping quarters, kitchen and bathroom facilities independent of the main dwelling on the site,” as well as an “accessory unit”, defined as a dwelling unit, attached to a primary residence by roofline, providing complete, independent living facilities for no more than two (2) persons including permanent provisions for living, sleeping, eating, cooking and sanitation, and having only one (1) kitchen. While the current definition of “accessory unit” specifies that these units should not be considered ADUs as defined in state law, effectively they function as ADUs. The City currently reviews ADUs in accordance with State legislation. As long as the lot is zoned residential then it is allowed to construct an ADU and a JADU via an administrative review. The turn-around time for an administrative review is one to two weeks. The City is currently drafting an ADU ordinance to mirror State legislation and is expected to be adopted in early 2022. The Housing Plan includes a program to update the zoning ordinance to bring this definition into compliance with state law.

The Zoning Ordinance also includes “guest dwellings,” defined as “living quarters within an accessory building, for use exclusively by temporary, non-paying guests of the resident family, such quarters having no cooking or plumbing facilities except plumbing facilities for a bathroom.” Because these dwellings do not include complete independent living facilities, they do not qualify as ADUs.

The Zoning Ordinance allows ADUs by right in all residential zones, and in most commercial and industrial zones. They are permitted in accordance with California Government Code section 65852.2. Between 2013 and 2019, 33 building permits were issued for ADUs.

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Duplexes
Duplexes are a multi-family dwelling “in which two (2) dwelling units are attached and located together on a lot or building site.” Duplex buildings are allowed by-right in the R2 and R3 zones, subject to ministerial Site Plan Review.

Multi-Family
El Centro’s Zoning Ordinance defines “dwelling, multiple-family” as “a building or buildings designed and used for occupancy by two (2) or more families, all living independently of each other and having separate kitchen and toilet facilities for each family.” Multi-family dwellings are allowed by-right in the R2 and R3 zones, subject to ministerial Site Plan Review. Multi-family dwellings are also allowed in the CT zone with approval of a CUP by the Planning Commission.

A new Mixed Use land use designation and overlay were adopted into the Land Use Element as part of the General Plan update in June 2021, which allow multi-family residential uses. A program has been developed to update the zoning code to implement the new land use designations.

Mixed-Use
Mixed-use buildings and developments are allowed with approval of a CUP by the Planning Commission in the CT zone. A mixed-use building is defined by the City as a “structure or project with both residential and pedestrian-oriented commercial uses (including retail, restaurants, offices, services and similar uses deemed compatible with residential uses). The commercial use or uses are typically located on the ground floor of the structure with the residential dwellings predominantly located on the second or higher floors.” The Zoning Ordinance draws a distinction between mixed-use buildings and mixed-use developments. A mixed-use development is defined as a “project with both residential and non-residential uses located on the same lot or site. With this type of development, there is no requirement that the residential and the non-residential uses be located in the same building.” Group Dwellings
The City allows “group dwellings” by-right in the R3 zone, subject to ministerial Site Plan Review.

Per the Zoning Ordinance definition, this use includes “apartment hotels, boarding, rooming or lodging houses consisting mainly of living units without individual kitchens which are rented on a weekly basis or longer. Also includes student dormitories and retirement homes providing congregate dining facilities.” Group dwellings can provide a valuable form of affordable private housing for seniors, persons with disabilities, and lower income households, including extremely low income households, and can serve as an entry point into the housing market for formerly homeless people.

Single Room Occupancy (SRO) Buildings
The City revised the Zoning Ordinance in April 2013 to define SRO buildings and allow the use with approval of a CUP by the Planning Commission in the CT zone. The Zoning Ordinance defines SRO buildings as “a building providing single-room units for one or more persons with or without shared kitchen and bath facilities, including efficiency units per Health and Safety

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Code Section 17958.1.” Like group dwellings, SROs can be another source of affordable housing for lower-income households, including extremely low income households.

Residential Care Facilities
The City of El Centro defines “residential care facility” to include “various types of facilities operated by licensed staff that provide twenty-four (24) hour non-medical supportive and custodial care for children, adults, and the elderly who need general assistance for everyday living. The facilities are licensed by the state department of social services and are not considered to be health facilities. The facilities are referred to by a variety of terms, including: group homes, family care homes, foster family homes, small family homes, special needs housing, adult residential facilities, social rehabilitation facilities, residential board and care facilities, assisted living facilities, residential care facilities for the chronically ill, and residential care facilities for the elderly. See California Health and Safety Code § 1502(a).” The Zoning Ordinance distinguishes between small and large residential care facilities. The Lanterman Developmental Disabilities Services Act provides that state-licensed residential care facilities serving six or fewer individuals must be treated no differently than any other residential use. Consistent with State law, the City allows small residential care facilities that serve six or fewer clients in all residential zones, subject to the same development standards and permit processing requirements as other types of housing in the same zone.

Large residential care facilities serving seven or more clients are allowed by right in the RR, R1, R2, and R3 zones. Residential care facilities are also allowed with approval of a CUP by the Planning Commission in the CT zone, the same as multi-family residential developments in these zones. Large residential care facilities serving seven or more clients are allowed by right in the RR, R1, R2, and R3 zones. Large residential care facilities are also allowed with a CUP in the CT zone. Allowable zoning and permit requirements may constrain the development of some larger facilities. A program has been added to this Housing Element for the City to evaluate the provisions for permitting large residential care facilities ensure that permitting requirements and zoning do not unduly constrain development of these facilities, and to review the Development Code as necessary.

Transitional and Supportive Housing
Transitional and supportive housing are allowed by-right in all residential zones, and with a conditional use permit in the CT zone, where multi-family housing is also similarly permitted.

The City has not adopted any special or unique development standards, findings, or other criteria for either use.

Pursuant to SB 745 (2013), transitional housing is defined as “rental housing developments, but operated under program requirements that require the termination of assistance and recirculating of the assisted unit to another eligible program recipient at a predetermined future point in time that shall be no less than six months from the beginning of the assistance. Transitional housing that is provided in single-family, duplex, manufactured housing, multi-family, mixed-use units, or group dwellings shall be permitted, conditionally permitted or prohibited in the same manner

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as the other single-family, duplex, manufactured housing, multi-family, mixed-use units, or group dwellings. See Government Code 65582.

Supportive housing is defined as means housing with no limit on length of stay, that is occupied by the target population, and that is linked to an onsite or offsite service that assists the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. “Target population” means persons with low incomes who have one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health condition, or individuals eligible for services provided pursuant to the Lanterman Developmental Disabilities Services Act (Division 4.5 (commencing with Section 4500) of the Welfare and Institutions Code) and may include, among other populations, adults, emancipated minors, families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, and homeless people.

Furthermore, AB 2162 (September 2018) requires that supportive housing meeting specific criteria to be permitted by right in zones where multi-family and mixed-use developments are permitted.

Specific criteria include the size of the project and percentage set aside for target population, and specified amount of floor area for supportive services, among others. The Housing Plan includes a program to update the Zoning Ordinance to comply with AB 2162.

Emergency Shelters
State law requires that local jurisdictions identify a zone or zones where emergency shelters are allowed with a non-discretionary (i.e., ministerial) review. The Zoning Ordinance defines “emergency shelter” as “a housing facility that provides temporary overnight shelter for persons with no permanent housing with minimal support services in which residency is limited to six (6) months or less and is not related to the person's ability to pay. Such facilities may offer services to meet basic needs such as food, clothing, and limited medical care. See California Health and Safety Code § 50801(e).” The 2017 Point in Time Count, the most recent year for which data was available for individual jurisdictions, identified 286 homeless individuals living in El Centro. The 2020 Point in Time County by the Imperial Valley Continuum of Care estimates an unsheltered homeless population of 1,334 countywide. Proportionally, the homeless population in El Centro can be generally estimated at 332 persons (24 percent of County population).

Emergency shelters are allowed by right in the R3, CG and CH zones, subject to ministerial building permit review. The City has not adopted unique development standards or criteria for this use. The City has more than 60 acres of vacant land within the R3 zone, as well as nearly 17 acres of vacant land use in the CH zone. The R3 and CH zones are located primarily along the City’s transportation corridors and/or are located closes to public transportation and services.

With no limit on the number of beds allowable per shelter, and no distance requirements between shelters, the vacant land within the City is adequate to accommodate emergency shelters for the City’s unsheltered homeless population.

Low Barrier Navigation Center (LBNC)
Adopted in 2019, AB 101 requires cities to permit Low Barrier Navigation Centers by right in areas zoned for mixed-use and nonresidential zones that permit multi-family uses, if the center

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meets certain requirements. AB 101 defines a Low Barrier Navigation Center as “a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing.” AB 101 is effective through the end of 2026, at which point its provisions are repealed. The Housing Plan includes a program to address this new requirement.

Farm Employee Housing
Pursuant to the California Employee Housing Act (Section 17000 of the California Health and Safety Code), any employee housing providing accommodations for six or fewer employees shall be deemed a single-family structure within a residential land use designation. Employee housing for six or fewer people must be permitted wherever a single-family residence is permitted. To comply with state law, no conditional use permit or variance can be required for employee housing. The zoning ordinance does not reference employee housing, or define it as a distinct use. When employee housing for six or fewer people is provided in a single-family residence it is regulated in the same way as comparable single-family residences.

The Zoning Ordinance defines “farm employee housing” as “Housing that is incidental or accessory to a permitted agricultural use and provides accommodations for six or fewer employees within a single-family structure. See Section 17021.5 of the California Health and Safety Code.” Incidental farm employee housing is allowed by right within the RR, rural residential zone.

The California Employee Housing Act further requires housing for agricultural workers consisting of no more than 36 beds in a group quarters or 12 units or spaces designed for use by a single-family or household be considered an agricultural land use, and permitted in the same way as other agricultural uses. Although the General Plan does not include an agriculture land use designation, commercial agricultural operations are allowed by right with in the RR zone. The Housing Plan includes a program to update the zoning ordinance to allow housing for agricultural workers as defined by the California Employee Housing Act in the RR zone as required by state law.

D. Site Improvements, Exactions and Development Fees
Site Improvements
The City requires on- and off-site improvements for all new residential projects, including singlefamily, multi-family, and mixed-use developments. Projects are typically required to provide offstreet parking with adequate lighting on site, internal driveways and access roads as needed, as well as common open space, on-site landscaping, appropriate irrigation and drainage facilities, fire hydrants and fire prevention systems, and at least one ADA accessible pathway between the right-of-way and a project entrance. Perimeter fencing, lighting, and decorative paving may also be required.

Typical off-site improvements include sidewalk construction and/or repair adjacent to the property, water, sewer, and stormwater facilities, street landscaping, restriping or other improvements in the right-of-way to allow project access, dedication of easements and/or rightof-way for future use by the City, and roadway construction. The Mobility Element includes roadway classifications for key existing and future roadways in the City. The design of each

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roadway varies by type, and the Mobility Element allows flexibility in design to accommodate multiple transportation modes. These minimal improvements are necessary to promote the health, safety, and general welfare of the public. The costs of improvements are the responsibility of developers and are applied uniformly to all projects within the City.

As a mostly built-out city, the infrastructure, including streets and other infrastructure, is in place in the majority of El Centro that is designated to allow moderate- and lower-income households.

Areas that are yet to be developed with residential uses are almost exclusively designated for lower density residential development, with the majority being single-family subdivisions, many of which have already been approved but are not yet built. Street widths have never been identified as a constraint to residential development in El Cento. However, the City works with developers on a project-by-project basis regarding infrastructure for new SFR subdivisions and accommodations can be made if and when necessary. For three recently-approved housing projects in the City, the following improvements were required:
▪ Paved off-street parking spaces
▪ Removal of old access driveways and replacement with new driveways, including colored or textured paving
▪ Landscaping and irrigation within parking areas and the project site, including both trees and other landscaping plants
▪ ADA accessible pathway between the right-of-way and project entrance ▪ Common usable open space serving project residents
▪ Private open space for resident use
▪ Outdoor lighting, including lighting for parking areas ▪ Laundry facilities for residents
▪ Screened trash and recycling collection areas
▪ Decorative perimeter fencing and sound walls
▪ Irrigation, building, and fire backflow preventers
▪ Fire alarms, hydrants, and sprinkler systems
▪ Curb and gutter improvements on streets fronting the project property ▪ Sidewalk repair and/or construction on streets fronting the project property ▪ Right-of-way dedication to allow for roadway improvements in the project vicinity, and/or construction of roadway improvements including curb, gutter, sidewalk, streetlight, striping, and paved roadways
▪ Easements for stormwater improvements
▪ Storm drain facilities
Development Fees and Exactions
In addition to improvements and dedications of land for public purposes, housing developers are subject to variety of fees and exactions to cover the cost of processing permits and providing necessary services and facilities. In general, these fees can be a constraint on housing development and compromise project feasibility because the additional cost borne by developers contributes to overall increased housing unit cost. However, the fees are necessary to maintain adequate planning services and other public services and facilities in the City.

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For new residential projects, developers in El Centro may be required to pay one or more of the following fees depending on the location, type, and size of the project:
▪ Planning, Building, and Environmental Fees: The City of El Centro charges developers standard plan check fees, fees for processing applications, building permits, subdivision maps, environmental initial study, variance, conditional use permit, or other permits to pay for the cost of processing applications and conducting inspections for specific projects.

This does not include additional fees paid by the developer for project-specific environmental impact reports (EIRs); however, a Program EIR was prepared for the General Plan Update adopted in June 2021, so new projects will be able to use that document to substantially reduce future environmental review costs and timeframes within the 6th Cycle.

Table 42: Permit Processing Fees
Type Amount
Planning Permits
Variance $1,076.81
Conditional Use Permit $2,907.40
General Plan Amendment $3,768.85
Zone Change $3,015.08
Site Plan Review $753.77
Specific Plan $9,745.16
Development Agreement $3,445.80
Administrative Committee Review $753.77
Subdivisions
Lot Line Adjustment $753.77
Parcel Map (<5 lots) $753.77
Subdivision Map (5+ lots) $4,845.66
Environmental
Initial Study $2,153.63
Negative Declaration $1,399.86
Environmental Impact Report (Review) $5,599.43
Sources: City of El Centro, User Fee Schedule, 2021.
▪ City Impact Fees: The City charges impact fees to finance new or expanded infrastructure and public facilities required to serve residents. The fee must have a reasonable relationship to the infrastructure costs and represent the marginal cost of improvements required to serve residents of the new residential projects. The City charges fees to offset impacts to parks, libraries, police, fire, sewer, streets, and general government facilities. ▪ School Impact Fees: Impact fees are collected by school districts as allowed by State law to finance the construction and expansion of schools to accommodate student enrollment.

The City of El Centro does not set these fees and does not have discretion to waive, reduce, or defer these fees.

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A summary of the City’s permit processing and development impact fee schedules are included in Table 42Error! Reference source not found. and Table 43Error! Reference source not found..

Table 43: Development Impact Fees
Type SingleFamily
Mobile
Home Multi-Family
City Impact Fees1
Parks $1,288 $1,037 $921
Library $714 $575 $510
Police $377 $303 $269
General Government $932 $750 $666
Fire $621 $500 $444
Streets $283 - $383 $267 $160 - $240
Sewer $4,304 - $7,174
Water $3,689 - $6,149
School Impact Fees
El Centro Elementary School District $2.62/sf
McCabe Union School District $4.08/sf
Meadows Union School District $2.62/sf
Central Union High School District $1.17/sf
Sources: City of El Centro2021; El Centro Elementary School District, 2021; McCabe Union School District, 2021; Meadows Union School District, 2021; and Central Union High School District, 2021.

Notes:
1 Fees for residential use vary by the type of use and number of bedrooms.

Table 44Error! Reference source not found. provides a fee worksheet for two prototypical housing projects based on applications processed in the City. Altogether, developer fees for a prototypical single-family dwelling total $20,466 (approximately 8 percent of the total development cost). Fees for a prototypical multi-family project are somewhat lower on a per-unit basis at $9,775 (approximately 10 percent of the total development cost).

Table 44: Development Fees for a Typical Unit
Fee Type Single-Family Multi-Family
Permit Processing Fees $2,895 $574
Impact Fees $17,571 $9,201
Total estimated fees per unit $20,466 $9,775
Typical estimated cost of development per unit $262,266 $94,061 Estimated proportion of fee cost to overall
development cost per unit

7.80% 10.39%
Sources: City of El Centro, 2021.

Notes: Single-family prototype is a 3-bedroom, 1,810 square-foot home with 400 square-foot attached garage. Multi-family prototype is based on a 28-unit apartment complex with an average unit size is 966 square feet.

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Planning and permitting fees are charged on an at-cost basis to cover staff services and administrative expenses for processing development applications. Development impact fees are required to provide essential services and infrastructure to serve new residents. Impact fees are governed by State law to demonstrate a nexus between development and potential impacts. State law also requires the proportionality test to ensure the pro rata share of costs to provide services and infrastructure by individual developments is reasonable.

The City recognizes that planning/permitting and development fees add to the cost of residential development. To mitigate the impact of permitting and impact fees on the cost of residential development, the City will consider deferment of fees for affordable housing projects on a caseby-case basis.

E. Development Permit Procedures
The City reviews all applications for development to ensure the construction of projects that contribute in a positive manner to the community and improve quality of life. This section describes the permitting requirements, procedures, and timeframes for Site Plan Review, Conditional Use Permits (CUP), and Subdivisions. The City’s permit processing procedures and processing times are in line with industry standards, provide development certainty, and do not unduly constrain the development of housing.

Site Plan Review
Site Plan Review applies to all projects involving two or more dwelling units on the same lot, second dwelling units, and developments that require a CUP or rezone. Site Plan Review does not apply to individual single-family dwellings proposed on existing legal lots. The purpose of Site Plan Review is to:
▪ Provide a process for the reviewing official or body to verify a proposed project's compliance with Zoning Ordinance development, design, and use standards; ▪ Assure land owners, business owners and developers that proposed uses, structures, and site improvements comply with the Zoning Ordinance provisions before preparation of plans for building permits; and
▪ Provide a means of streamlining the development review process through administrative review of development proposals.

As part of the Site Review Plan process (Figure 7), sites are evaluated by staff to ensure:
• Compliance with all provisions of the zoning code
• The following are arranged to avoid traffic congestion, protect pedestrian and vehicular safety, and avoid adverse effects on surrounding property:
o Buildings, structures and improvements
o Vehicular ingress, egress and internal circulation
o Setbacks
o Height of buildings
o Location of service access
o Walls

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o Landscaping
• Proposed lighting is arranged as to reflect the light away from adjoining properties • Proposed signs will not interfere with traffic or limit visibility • Compliance with state environmental laws
No findings are required as part of the Site Plan Review process.

Depending on the project and type of permit required, Site Plan Review is completed by the Community Development Director, Planning Commission, or City Council. The Community Development Director has authority to complete Site Plan Review for uses including two or more dwellings on a lot, structures and outdoor uses in all commercial zones except the civic center (CC) zone, within the CC zone new structures and additions of less than 3,000 sf, accessory dwellings, guest dwellings, and second dwelling units. The Community Development Director’s Site Plan Review is ministerial, and no noticing or public hearing is required.

The Planning Commission has the authority to approve, approve with conditions, or deny site plans for new structures and additions of greater than 3,000 square feet in the civic center (CC) zone, for variances, and conditional use permits. The City Council has the authority to approve, approve with conditions, or deny site plans for projects involving a change of zone when no other discretionary approvals or permits are required.

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Figure 7: Site Plan Review Procedure

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Conditional Use Permits
Land uses that require a CUP generally have a unique and distinct impact on the area in which they are located or are capable of impacts to adjacent properties unless given special review and conditions. There have been seven CUP applications to construct new housing over the past seven years, and all have been approved. Depending on the use, CUP requests are heard by the Planning Commission and, where required by the zoning ordinance, the City Council. The City Council has final authority to approve conditional use permits for buildings or structures with heights greater than permitted by the zone, density bonuses, mobile home parks, planned unit developments, recreational vehicle parks, clustered single family development within the RAP zone at the maximum density permitted in the R1 zone so long as the average density within the portion(s) of the site designated "extended approach/departure zone" does not exceed one dwelling unit per net acre, and uses in the civic center zone that require a conditional use permit.

The Planning Commission has the authority to approve conditional use permits for all other uses, although its decision may be appealed to the City Council.

The Planning Commission or City Council must make the following findings prior to approval of a CUP:
▪ The use applied for at the location set forth in the application is properly one for which a conditional use permit is authorized by the Zoning Ordinance; ▪ Said use is necessary or desirable for the development of the community, is in harmony with the various elements or objectives of the general plan, and is not detrimental to existing uses or uses specifically permitted in the zone in which the proposed use is to be located;
▪ The site for the intended use is adequate in size and shape to accommodate said use, and all yards, setbacks, walls or fences, landscaping and other features are required in order to adjust said use to those existing or permitted future uses on land in the neighborhood; and
▪ The site for the proposed use relates properly to streets and highways which are designed and improved to carry the type and quantity of traffic generated or to be generated by the proposed use.

The findings apply uniformly to all uses that require a CUP and conditions of approval must be deemed necessary to protect the public health, safety, and general welfare.

Lot Line Adjustments
The City allows for ministerial lot line adjustments to facilitate the development of multi-family and mixed-use buildings across property lines, so long as the adjustment does not lead to an increase in the number of legal lots. The Community Development Director has authority to approve, conditionally approve, or deny the lot line adjustment within 15 days of receipt of a complete application. A lot line adjustment will be approved upon determination that the adjustment plat meets the requirements of the Subdivision Ordinance and complies with the General Plan and Zoning Ordinance.

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Subdivisions
The subdivision of land into multiple lots pursuant to the California Subdivision Map Act requires discretionary approval by the City. The Planning Commission can review and approve or recommend denial of tentative maps of four or fewer parcels. The Planning Commission also recommends approval, conditional approval, or denial of tentative maps of five or more parcels.

The City Council has final authority to approve, conditionally approve, or deny all tentative maps of five or more lots or parcels; and to approve, conditionally approve or deny any tentative map of four or fewer parcels for which the Planning Commission recommended denial or an appeal has been made.

The reviewing and approving body must deny approval of a tentative map if it makes any of the following findings:
▪ That the proposed map is not consistent with the General Plan and applicable specific plans;
▪ That the design or improvement of the proposed subdivision is not consistent with the General Plan and applicable specific plans;
▪ That the site is not physically suitable for the type of development; ▪ That the site is not physically suitable for the proposed density of development; ▪ That the design of the subdivision or the proposed improvements is likely to cause substantial environmental damage or substantially and avoidably injure fish or wildlife or their habitat;
▪ That the design of the subdivision or type of improvements is likely to cause serious public health problems; and
▪ That the design of the subdivision or the type of improvements will conflict with easements, acquired by the public at large, for access through or use of property within the proposed subdivision; provided, however, the city council may approve a map if it finds that alternate easements, for access or for use, will be provided, and that these will be substantially equivalent to ones previously acquired by the public.

Permit Processing Time Frames
Permit processing time frames vary depending on the type, location and environmental review requirements of the proposed development. Permits are generally processed more quickly than in other cities. A Site Plan Review has a typical processing time of five to six weeks. Projects that requires Planning Commission approval due to a CUP or parcel map, typically take six to eight weeks for processing. Building Plan Check approvals are relatively quick, with multi-family developments typically processed within six to eight weeks, and single-family homes and ADUs processed in as little as two weeks.

Projects that require only a Negative Declaration under CEQA can typically be processed in a six month time frame. Large subdivisions may require a longer processing time frame due to the information required and public comments received. Projects requiring an Environmental Impact Report (EIR) will be able to use the General Plan EIR for tiering, which should reduce processing time. Processing time may vary due to the volume of applications, the type and number of

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changes made to the project by the applicant to address impacts, and the size and complexity of the projects.

F. Building Codes
The City of El Centro adopted the 2016 edition of the following California Building Standards Codes, which is a compilation of specialty codes: Building Code, Residential Code, Electrical Code, Mechanical Code, Plumbing Code, Energy Code, Historical Building Code, Existing Building Code, and Green Building Standards Code. The City also adopted the 2010 edition of the Uniform Administration Code and Uniform Housing Code. These codes establish minimum standards for residential construction and are structured to be the minimum necessary to protect the public health, safety, and welfare, while not unduly constraining the development of housing.

The codes are determined by the International Conference of Building Officials and the state.

Some of the codes have been adopted with minor administrative amendments; no local amendment to the code has either been initiated or approved that directly impacts housing standards or processes. The City will adopt the 2019 version of the building codes.

Code enforcement is conducted by the Code Enforcement Division of the Community Development Department and is based upon systematic enforcement in areas of concern and on a complaint basis throughout the City. The Code Enforcement Division works with property owners and renters to assist in meeting state health and safety codes. If a violation relates to residential rehabilitation, CDBG funds are available to help defer the cost of housing rehabilitation.

G. Transparency in Development Process
To increase transparency and certainty in the development application process as required by law, the City has links to its zoning and development standards and fee schedule posted on its website. Currently, the City has no inclusionary requirements. ▪ Links to the zoning maps can be found here:
http://www.cityofelcentro.org/communitydevelopment/index.asp?m=1&page=67&su bpage=26.
▪ Links to development standards and allowed uses can be found here:
https://library.municode.com/ca/el_centro/codes/code_of_ordinances?nodeId=CHC OTA_CH29ZO_ARTIIZO_DIV2REZO
▪ Fee schedule can be found here:
http://www.cityofelcentro.org/communitydevelopment/index.asp?m=1&page=67&su bpage=24
H. Housing for People with Disabilities
Persons with disabilities have a number of specific housing needs, including those related to design and location. Design needs generally include the removal of architectural barriers that limit the accessibility of dwelling units and construction of wheelchair ramps, railings, etc.

Location needs include accessibility to public transportation, commercial services, healthcare,

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and supportive services. Some persons with disabilities need group housing opportunities, especially those who are lower income or homeless.

California statutes require that the Housing Element include an analysis of the Zoning Ordinance, permitting procedures, development standards, building codes, and permit processing fees to identify potential constraints for housing for persons with disabilities. The following discussion addresses these issues and determines that no specific City policy or regulation serves to impede the access that persons with disabilities have to housing that suits their specific needs.

Zoning and Land Use
The Lanterman Development Disabilities Service Act (Sections 5115 and 5116) of the California Welfare and Institutions Code declares that mentally and physically disabled persons are entitled to live in normal residential surroundings. The use of property for the care of six or fewer people with disabilities is a residential use for the purposes of zoning. As discussed earlier in this Chapter, State-authorized or certified residential care facilities, family care home, foster home, or group home serving six or fewer people with disabilities or dependent and neglected children on a 24-hour-a-day basis is considered a residential use that is permitted in all zones that allow residential uses, subject to the same application process and development standards as other types of housing in the same zones.

In addition to residential care facilities, the City encourages and facilitates group dwellings and supportive housing. Group dwellings are permitted in the R3 zone and supportive housing is permitted in all residential zones. Group dwellings and supportive housing can be important sources of affordable housing for persons with disabilities. Supportive housing is permitted with a conditional use permit in the CT zone. Group care facilities are permitted with a conditional use permit in the CT, CO, and CH zones.

Building Codes
The City enforces Title 24 of the California Code of Regulations that regulates the access and adaptability of buildings to accommodate people with disabilities. Government Code Section 12955.1 requires that ten percent of the total dwelling units in multi-family buildings without elevators consisting of three or more rental units or four or more condominium units be subject to the following building standards for people with disabilities:
▪ The primary entry to the dwelling unit shall be on an accessible route unless exempted by site impracticality tests.
▪ At least one powder room or bathroom shall be located on the primary entry level served by an accessible route.
▪ All rooms or spaces located on the primary entry level shall be served by an accessible route. Rooms and spaces located on the primary entry level and subject to this chapter may include but are not limited to kitchens, powder rooms, bathrooms or hallways. ▪ Common use areas shall be accessible.
▪ In common tenant parking is provided, accessible parking spaces are required.

No unique Building Code restrictions are in place that would constrain the development of housing for people with disabilities. Compliance with provisions of the City’s Municipal Code,

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California Code of Regulations, California Building Standards Code, and federal Americans with Disabilities Act (ADA) is assessed and enforced by the Building & Safety Division of the Community Development as part of the building permit submittal.

Definition of Family
Local governments may restrict access to housing for households failing to qualify as a “family” by the definition specified in the Zoning Ordinance. Specifically, a restrictive definition of “family” that could be interpreted to limit the number of or differentiates between related and unrelated individuals living together may illegally limit the development and siting of group homes for people with disabilities, but not for housing families that are similarly sized or situated.

Another potentially restrictive definition could limit use of residential land uses for facilities that serve special needs populations, including people with disabilities.

The City defines “family” as “two or more individuals related by birth, marriage, adoption or convenience who occupy the same dwelling unit. A family also includes the residents of residential care facilities and group homes for people with disabilities. A family does not include larger institutional group living situations such as dormitories, fraternities, sororities, monasteries or nunneries, nor does it include such commercial group living arrangements as boardinghouses, lodging houses and farm labor camps.” The City’s definition does not constrain or limit housing opportunities for the disabled because this definition explicitly includes residential care facilities and group homes for people with disabilities.

Reasonable Accommodation
Both the Federal Fair Housing Act and the California Fair Employment and Housing Act direct local governments to make reasonable accommodation (i.e., modifications or exceptions) in their zoning laws and other land use regulations to allow disabled persons an equal opportunity to use and enjoy a dwelling. For example, it may be a reasonable accommodation to waive a setback requirement so that elevated ramping can be constructed to provide access to a dwelling unit for a resident who has mobility impairments. Whether a particular modification is reasonable depends on the circumstances and must be decided on a case-by-case basis.

Reasonable accommodation refers to flexibility in standards and policies to accommodate the needs of persons with disabilities. The City’s Reasonable Accommodation Ordinance grants the City’s Administrative Committee authority to review and decide applications for reasonable accommodation as provided by the federal Fair Housing Amendments Act and California’s Fair Employment and Housing Act to allow reasonable remedy from zoning standards for individuals with physical or mental impairment. A request for reasonable accommodation may include a modification or exception to the rules, standards, and practices for the siting, development, and use of housing or housing-related facilities that would eliminate regulatory barriers and provide a person with a disability equal opportunity to housing of their choice.

The Ordinance directs the Administrative Committee to approve the accommodation if it is necessary to make housing available to an individual in accordance with the fair housing acts, unless the Committee can present evidence that doing so would either create an undue financial or administrative burden or result in a fundamental alteration of the Zoning Ordinance. The

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Zoning Ordinance defines “fundamental alteration” as an alteration so far reaching that it would change the essential scheme of the Zoning Ordinance. Requests for reasonable accommodation are approved administratively with no required fee. There has been one reasonable accommodation request since 2015.

3.3. Public Policy Constraints
State and Federal requirements may act as a barrier to the development or rehabilitation of housing, and affordable housing in particular.

A. State Prevailing Wage Requirements
The State Department of Industrial Relations (DIR) expanded the kinds of projects that require the payment of prevailing wages. Labor Code Section 1720, which applies prevailing wage rates to public works of over $1,000, now defines public works to mean construction, alteration, installation, demolition, or repair work done under contract and paid for in whole or in part out of public funds. For example, public transfer of an asset for less than fair market value, such as a land write-down, would now be construed to be paid for, in part, out of public funds and trigger prevailing wage requirements.

While the cost differential in prevailing and standard wages varies based on the skill level of the occupation, prevailing wages tend to add to the overall cost of development. In the case of affordable housing projects, prevailing wage requirements could effectively reduce the number of affordable units that can be achieved with public subsidies. The following types of projects are exempt from the prevailing wage requirement:
▪ Residential projects financed through issuance of bonds that receive an allocation through the State; and
▪ Single-family projects financed through issuance of qualified mortgage revenue bonds or mortgage credit certificates.

B. Environmental Protection
State law (California Environmental Quality Act, California Endangered Species Act) and federal law (National Environmental Protection Act, Federal Endangered Species Act) regulations require environmental review of proposed discretionary projects (e.g., subdivision maps, use permits, etc.). Costs resulting from the environmental review process are also added to the cost of housing and are passed on to the consumer to the extent that the market can bear. These costs include fees charged by local government and private consultants needed to complete the environmental analysis, costs to mitigate impacts, and costs from delays caused by the mandated public review periods. However, the presence of these regulations helps preserve the environment and ensure environmental safety to El Centro residents.

3.4. Utility and Public Service Constraints

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The provision of utilities such as water and sewer as well as public services including police, fire, and schools is costly to local governments and special districts providing municipal services.

New development must pay for much of these costs thereby increasing the overall cost of housing. This section provides an overview of potential utility and public service constraints in El Centro.

A. Water Supply
The City Public Works Department receives and distributes potable water from the Imperial Irrigation District (IID). The IID has senior water rights to the Colorado River water and ranks urban supply higher than the agricultural supply. The City’s draft 2020 Urban Water Management Plan reviewed the overall supply and demand of water for the City of El Centro determined that “[g]iven that 100 percent of the City’s demand is met through Colorado River water purchased from IID, and given the extreme reliability of that water source, IID will be able to meet El Centro’s demands in all projected years through 2045.” The water demand projected in the Urban Water Management Plan included development pursuant to the City’s General Plan and there is adequate water supply and filtration capacity to accommodate 3,433 new residential dwellings during the 2021-2029 RHNA period. The City charges a water capacity fee that goes toward improvement/expansion of potable water filtration and distribution facilities maintained by the Public Works Department.

Senate Bill 1087 (enacted 2006) requires that water providers develop written policies that grant priority to proposed development that includes housing affordable to lower-income households.

The legislation also prohibits water providers from denying or conditioning the approval of development that includes housing affordable to lower income households, unless specific written findings are made. Although the City relies on the IID for its water supply, the Public Works Department is responsible for providing local service to existing and new development.

Therefore, the City is responsible for complying with Senate Bill 1087 requirements should supply rationing or limited filtration capacity occur. To ensure compliance, the City will develop and establish a formal procedure to grant water priority to developments with units affordable to lower-income households pursuant to Government Code Section 65589.7 B. Wastewater Treatment
The City owns and operates a wastewater collection system and treatment facility that receives wastewater from the entire city and a few entities outside of the City Limits. The facility underwent a significant upgrade in the mid-1990s, increasing its capacity to eight million gallons per day (mgd).

The City’s Public Works Department is planning large wastewater capital improvements over the next five fiscal years. These improvements will both increase the capacity of the collection and treatment systems to support the City's growth and to repair, replace, and improve existing facilities to continue to reliably serve existing customers. A portion of the City’s wastewater connection and monthly service fees is allocated to a Wastewater Capacity Fee Fund, which is used to finance capital projects associated with growth anticipated in the 2008 Wastewater Master

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Plan and Capital Improvements Plan. These plans were developed and are implemented based on General Plan Land Uses and in conjunction with the Urban Development Program.

Implementation of these plans and programs will ensure that adequate wastewater collection and treatment facilities are in place to serve existing and planned growth, including the City’s 2021- 2029 RHNA of 3,433 units. The City charges a sewer capacity fee to offset the cost of improving and expanding wastewater collection and treatment facilities.

Senate Bill 1087 described above also mandates priority wastewater collection and treatment service to housing developments providing units affordable to lower income households. The City is responsible for complying with Senate Bill 1087 requirements should limited wastewater treatment capacity force a moratorium on new development or rationing new sewer connections.

To ensure compliance, the City will develop and establish a formal procedure to grant wastewater service priority to developments with units affordable to lower-income households pursuant to Government Code Section 65589.7
C. Urban Development Program
El Centro has adopted an Urban Development Program to facilitate residential, industrial, and business growth in areas where public services are available and to provide a variety of growth locations so that an adequate supply of developable land will maintain reasonable housing costs and promote economic development. Specific geographic areas (referred to as “Development Tiers”) have been delineated for new development based on existing or planned public facilities, existing land use, and transportation corridors or other physical barriers:
▪ Development Tier I - Current Urban Service Area: Includes land within and adjacent to the present City limits. In most cases, new development within this area can be served by gravity sewer lines to existing trunk sewers. Generally, water lines and reservoirs are also adequate to serve new development; however, easements and financial contributions to improve the ultimate sewer and water systems may be required. Fire, police, schools, parks, library, medical, roads, and other City services are also in proximity to these areas, though service capacities are likely to be limited and improvements to existing facilities and/or new facilities may be needed to adequately accommodate new development.

Subdivisions of land and commercial or industrial development within this area would generally follow standard zoning, subdivision, and environmental review procedures and would not require a Community Facilities Study.
▪ Development Tier II - Planned Urban Service Area: Includes land both within and adjacent to the City limits, but differs from Development Tier I in that public infrastructure to serve new development is more limited. Essential required improvements may include sewer and water pump stations, water storage reservoirs, and sewer trunk lines or force mains. New schools, parks, roadway improvements, and fire stations may also be required to adequately serve development of Development Tier II areas. As with Development Tier I areas, additional service capacity for police, library, medical, and other City services may also be needed to accommodate new development.

Preparation of a Community Facilities Study may be required for development projects within Development Tier II areas.

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▪ Development Tier III - Future Urban Service Area: Encompasses unincorporated lands that are not anticipated to be developed for at least ten years.

All of but one site included in the Residential Sites Inventory ( Appendix C: Sites Inventory) are located within Development Tier I - Current Urban Service Area. A large single-family tract is in Development Tier II and will require the installation of infrastructure to serve new development.

However, this is consistent with the majority of single-family tract development in the City. The Urban Development Program is designed and implemented to encourage and facilitate the orderly and efficient provision of utilities and public services concurrent with anticipated growth and is therefore not considered a constraint on residential development.

3.5. Environmental Constraints
A community’s environmental setting affects the feasibility and cost of developing housing.

Environmental issues range from the conservation of biological resources to the suitability of land for development due to potential exposure to environmental hazards. This section summarizes potential biological and seismic constraints on residential development in El Centro. None of the properties identified in the residential sites inventory are known to be constrained by steep slopes, floodplains, or hazardous materials.

A. Biological Resources
The irrigation and drainage canals network within some portions of the City provides habitat for saline adapted plant species. Populations of a number of fish species live in the canals. The mosquito fish has been introduced by the Imperial County Health Department for mosquito control, and species of Tilapia have been introduced to control aquatic weeds. The canal system has created an aquatic habitat within a naturally arid environment and provides opportunities for people to fish and observe wild species in a unique manmade “natural” environment.

Although the City must assess development proposals for potential impacts to significant natural resources and habitat pursuant to the California Environmental Quality Act (CEQA), the canal system right-of-way is well defined and related biological resources will not be a significant constraint on residential development within the 2021-2029 RHNA period.

B. Seismic Hazards
The Imperial Valley is one of the most tectonically active regions in the United States. Branches of the San Andreas Fault form the eastern boundary of the basin (Salton Trough) and the western edge is defined by the San Jacinto-Coyote Creek and the Elsinore-Laguna Salada Faults. More small to moderate earthquakes have occurred in the area than along any other section of the San Andreas Fault System. Since the City is generally flat, landslides are not considered a major hazard. However, bluff failure and mudslides may occur along slopes and embankments of the rivers and canals. Standard engineering practices, including soils investigation and compaction techniques, are sufficient to mitigate most seismic hazards in the City. Seismic hazards should not be a significant constraint to the development of housing in El Centro.

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4. Housing Resources
This section of the Housing Element addresses the resources available to the City in implementing the goals, policies, and programs contained in this Housing Element, specifically regarding the potential for future residential development. Resources covered in this section include potential development sites, financial resources, and administrative resources.

4.1. Future Housing Needs
State law requires each community to play a role in meeting the region’s housing needs. As such, the Southern California Association of Governments (SCAG), as the regional planning agency, is responsible for allocating the Regional Housing Needs Allocation (RHNA) to individual jurisdictions within the region. SCAG has allocated the City of El Centro housing production goals for the 6th cycle Housing Element update. This section discusses how El Centro has adequate existing residential site capacity to accommodate its share of regional housing needs during the planning period.

A. Regional Housing Needs Allocation (RHNA)
State Housing Element law requires that a local jurisdiction accommodate a share of the region’s projected housing needs for the planning period. This share, called the RHNA, is important because State law mandates that a jurisdiction provide sufficient land to accommodate a variety of housing opportunities for all economic segments of the community. Compliance with this requirement is measured by the jurisdiction’s ability in providing adequate land with adequate density and appropriate development standards to accommodate the RHNA.

SCAG assigned a RHNA of 3,442 units to the City of El Centro for the 2021-2029 RHNA period.

This allocation is distributed into four income categories, as shown below, in the following income distribution:
▪ Extremely Low/Very Low Income: 1,001 units
▪ Low Income: 490 units
▪ Moderate Income: 462 units
▪ Above Moderate Income: 1,489 units
The City has a RHNA allocation of 1,001 very low income units (inclusive of extremely low income units). Pursuant to AB 2634, the City must project the number of extremely low income housing needs based on Census income distribution or assume 50 percent of the very low income units as extremely low. Assuming an even split, the City’s RHNA allocation of 1,001 very low income units may be divided into 501 very low and 500 extremely low income units. However, for purposes of identifying adequate sites for the RHNA, State law does not mandate the separate accounting for the extremely low income category.

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The RHNA includes a fair share adjustment which allocates future (construction) need by each income category in a way that meets the State mandate to reduce over-concentration of lower income households in historically lower income communities or areas within the region. The City must ensure the availability of residential sites at adequate densities and appropriate development standards to accommodate these units by income category.

B. Credits Toward the RHNA
The 6th cycle RHNA covers a planning period that starts on June 30, 2021. Housing units built, under construction, or approved June 30, 2021 onward, can be credited toward meeting the City’s RHNA. These units can be subtracted from the City’s share of regional housing needs. The City must demonstrate in this Housing Element its ability to meet the remaining housing needs, through the provision of sites, after subtracting units under construction or anticipated (pipeline projects). These projects are identified in Table 45.

Units Approved
As of July 1, 2021, the City has entitled a total of 574 single-family lots in one subdivision; building permits have not been issued. Single-family lots are only considered affordable to abovemoderate households.

Units Pending Approval
As of July 1, 2021, a total of 180 units (the fourth phase of an apartment development) were in the approval process. Apartment units are considered affordable to moderate income households based on rent levels in the City (see discussions in previous sections).

Remaining Housing Need to be Accommodated
After accounting for units approved and pending approval, a remaining need of 2,688 units exists.

The City must demonstrate the availability of sites with appropriate zoning and development standards that can facilitate and encourage the development of such units by October 15, 2029.

Table 45: Credits Toward RHNA
Unit Type Very Low Low Moderate Above
Moderate Total
RHNA 1,001 490 462 1,489 3,442
Net Units Entitled (Building Permits Not Issued) as of 7/1/2021 S. La Broucherie Rd./Wake Ave.
– Approved subdivision with 574
SFR lots; no permits issued
SF --- --- --- 574 574
Subtotal: 0 0 0 574 574
Net Units Pending Approval as of 7/1/2021
Bradshaw Ave./10th Ave. Apartments --- --- 180 --- 180
Subtotal: 0 0 180 0 180
Remaining RHNA 1,001 490 282 915 2,688

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The 180 units from the Bradshaw Avenue Apartments are considered moderate based on the rent information provided by the developer. Rental rates for a two-bedroom two-bathroom apartment ranges from $1,500 to $1,600, which is considered within the moderate affordability range for a three-person household (see Table 29).

C. Future Residential Development Potential
The City of El Centro has adequate land capacity to meet the needs of all income groups through the 2021-2029 RHNA period. The City recently completed a comprehensive update of its Land Use Element as part of a General Plan update, that also included updating the Mobility Element and preparing a new Environmental justice Element, which was adopted by the City Council on June 15, 2021. Consideration was given to accommodating the City’s required 6th Cycle RHNA as a part of the update process. According to the Program Environmental Impact Report (PEIR) that was prepared for the General Plan update, the residential development capacity of the updated Land Use Element is estimated at 20,770 at build-out (as shown in Table 46).

Table 46: El Centro General Plan Update Residential Development Capacity Land Use Designations Number of Dwelling Units (within the City)
Rural Residential 12
Low Density Residential 9,083
Medium Density Residential 2,509
High Density Residential 6,552
Mixed Use 1 995
Mixed Use 2 Overlay 1,619
Total: 20,770
Source: El Centro General Plan EIR, June 2021, SCH No. 2020070349 The Mixed Use 1 (MU-1) and Mixed Use 2 (MU-2) Overlay land use designations are new designations created for the Land Use Element update. Both of these designations provide new opportunities for new multi-family residential opportunities, either as stand-alone residential developments or as part of mixed use projects, in areas that are on or near key commercial corridors in proximity to transit, existing and proposed pedestrian and bicycle paths, and shopping and other services. These two new mixed use designations were applied to former commercial land use designations to facilitate the trend the City has experienced, whereby developers have been applying and receiving approval for discretionary permits to change commercially designated/zoned property to the High-Medium Residential land use designation/R-3 zone to allow multi-family residential projects. In fact, the City has not had a request for a new commercial project in nearly 15 years in the Adams Avenue proposed mixed use area. The planned mixed use area around the IV Mall has had only two commercial new development in the last 15 years; a hotel in 2015 and medical office building in 2019..

The updated Land Use Element also redesignates the majority of Rural Residential properties to Low density and Medium density residential land use designations to provide increased opportunities for moderate and above moderate income households. Descriptions of the land use designations are provided in the Realistic Capacity Assumptions section below.

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The total residential capacity shown in Table 46 (above) represents buildout of the General Plan over the course of 20+ years. The capacity identified in the Residential Sites Inventory (Table 48, below), identifies the sites with near-term development potential through the City’s newly adopted policy of expanding the range of housing types within El Centro to accommodate a wider range of household types and income levels.

The following is a summary of the detailed parcel data included in Appendix C: Sites Inventory.

Realistic Capacity Assumptions
Consistent with the regional trends shown earlier in the Housing Constraints section, multifamily construction has been relatively limited in El Centro. For purposes of calculating the realistic capacity of sites in Appendix C: Sites Inventory, the following density factors were used to determine the realistic capacity of sites identified to meet the City’s RHNA:
▪ High-Medium Density Residential/R3 (maximum 25.0 units per acre): A density factor of 19.0 units per acre represents the realistic capacity of development within this land use designation/zone. This factor is only 76 percent of the maximum allowable density and is consistent with recent development applications. Four recent projects demonstrate that this is a realistic capacity assumption. Girasol Apartments, a 56-unit project, is currently under construction at a density of 23.5 du/ac. Amigo Ent. Apartments, a four-unit project, was constructed at 20 du/ac, while RSG Capital Apartments, a six-unit project, was recently constructed at 30 du/ac. Finally, Vaszques Apartments, a three-unit project, was recently constructed at 23 du/ac. This demonstrates that the density factor of 19 du/ac is not only achievable, but is a conservative estimate and is applicable to both small and medium sized lots.
▪ Tourist Commercial/CT (maximum density set by FAR): A density factor of 19.0 units per acre is reasonable given the City’s demonstrated High-Medium Density Residential/R3 sites identified above, which is typical of residential developments constructed in the CT zone.
▪ Medium Density Residential/R2 (maximum 12.0 units per acre): A density factor of 8.0 units per acre represents 67 percent of the maximum allowable density and is consistent with historic development patterns, including a five-unit project at 12 du/ac that is currently under construction, and a 240-unit project (Town Center Village III) at 12 du/ac, that was recently constructed.
▪ Low Density Residential/R1 (maximum 6.0 units per acre): A density factor of 3.5 units per acre represents 58 percent of the maximum allowable density and is consistent with historic development patterns, including a 23-unit subdivision (Santa Fe subdivision, currently under construction), which was developed at 6.38 du/ac, and a 22-unit subdivision (Lotus Ranch subdivision, currently under construction), that was developed at four du/ac.
▪ Rural Residential/RR (maximum 2.0 units per acre): A density factor of 1.0 unit per acre represents 50 percent of the maximum allowable density and is consistent with historic development patterns. There is very little RR land left in the city, and the recently updated

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Land Use Element redesigned the majority to land use designations with higher densities, so this 50 percent capacity assumption is assumed to reasonable. ▪ Mixed Use 1 (MU-1)/Zone to be created (minimum 12.0 units per acre to maximum 25.0 units per acre; maximum 32 units per acre for senior projects): Mixed Use 1 is a new land use designation in the recently updated Land Use Element (June 2021). It allows mixed use, stand-alone multi-family residential, and stand-alone commercial. Since this is a new land use designation and the zone has not been created yet, there are no representative projects to demonstrate actual capacity; therefore, the City proposes to use the density factor of 19, which is consistent with the High-Medium Density Residential/R3 land use designation and zone and has the same maximum density. The MU-1 designated sites in the 2021-2029 Sites Inventory are located on Adams Avenue. The portion of Adams Avenue that has been redesignated to MU-1 was identified as an Opportunity Area (OA1) in the Land Use Element. As a corridor with many older commercial properties, it was identified as a corridor both in need of revitalization and an area that offers significant opportunities to provide a variety of new housing types and neighborhood commercial uses. This corridor has recently experienced redevelopment of several older motels into affordable dwelling units, a trend that the new MU-1 designation acknowledges and promotes. The MU-1 land designation and proposed zone allow both mixed use and stand-alone residential. The trend in the city over the past several years has been for developers to redesignate and rezone property from commercial to multi-family residential; because of this trend, the City assumes these vacant properties identified in the sites inventory will develop as 100 percent residential. Another demonstration of this trend is that several properties within the MU-1 designation have recycled from 100 percent commercial to 100 percent residential uses in the past several years. City staff indicate that developers typically express interest in developing 100 percent housing rather than mixed use, and one developer who constructed a traditional vertical mixed use on a large lot in another city has indicated to staff that it did not perform well and therefore he is now interested in building 100 percent residential use, particularly apartments in this area.

Other large parcels to the north of the MU-1 designation have been rezoned from commercial to residential uses. The reason the sites were redesignated mixed use and not strictly residential is to retain legal conforming status of the existing commercial uses. The decision to redesignate the Adams Avenue corridor to mixed use instead of multi-family residential was to preserve existing commercial uses as legal conforming and retain a mixed use corridor to provide goods and services within proximity to existing and new households. The MU-1 designation also applies to an area of the City that is not within the Sites Inventory because it currently lacks infrastructure; however, the City expects this area to become available for development within the 6th Cycle planning period. ▪ Mixed Use 2 Overlay (MU-2 Overlay)/Overlay Zone to be created (minimum 21.0 units per acre to maximum 30.0 units per acre; maximum 38 units per acre for senior projects):

The Mixed Use 2 Overlay is a new land use designation in the recently updated Land Use Element (June 2021). It allows mixed use, stand-alone multi-family residential, and standalone commercial. The density is the highest allowed in El Centro, which provides enhanced opportunities for multi-family housing that is affordable to lower income households. Since this is a new land use designation and the zone has not been created yet, there are no representative projects to demonstrate actual capacity; therefore, the City proposes to use the density factor of 21, which is the lowest density allowed by the land

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use designation. The MU-2 Overlay land designation and proposed zone allow mixed use allows stand-alone residential. This supports the trend in the City over the past several years for developers to redesignate and rezone property from commercial to multi-family residential; therefore the City assumes these vacant properties identified in the sites inventory will develop as 100 percent residential. This assumption was corroborated by talking to a representative of the Imperial Valley Mall. The IV Mall currently has vacancies within the mall and vacant pads adjacent to the mall. The property owner indicated that a mixed use overlay that would allow stand-alone (100 percent) residential would be beneficial because demand for commercial “brick-and-mortar” stores is declining and adding residential to commercial projects provides new shoppers who will support the existing retailers. The property owner indicated that other malls that are owned by the IV Mall parent company have already added stand-alone residential projects on mall sites in Texas.

The MU-2 Overlay designated sites in the 2021-2029 Sites Inventory are located in two areas. The first area includes two vacant parcels in the northwest corner of El Centro, located within proximity to the City’s main commercial area and near Imperial Avenue (SR 78), which is served by transit and a proposed pedestrian/bikeway path.

The second area is located in the southeast corner of El Centro, at and around the Imperial Valley Mall (IVM) and nearby shopping areas, in an area designated as Opportunity Area 4 (OA-4) in the Land Use Element. The intent of OA-4 is to promote an integrated mixed use activity center by introducing and encouraging multi-family residential units to locate within and near the established commercial area. This could occur on vacant pads around the mall and on vacant portions of adjacent property also owned by the IVM. Discussions with a representative for the IVM indicate that this is a desirable addition to the land use mix and that other mall properties owned by the IVM are already incorporating multifamily residential units into their developments. This area is also served by transit and by a proposed pedestrian/bicycle pathway.

Table 47: Average Density for Multi-Family Housing
Project Max Allowed
Density Acreage Units Density Achieved
% Density
Realized
Density
Assumed
R3 Project 25 2.2 48 21.8 87.2%
Las Brisas 25 4.0 72 18.0 72.0%
R3 Trends/Average 6.2 120 19.4 77.6% 19
Stakeholder meetings with market-rate and non-profit developers did not indicate any concern over the City’s existing development standards, nor the ability to achieve maximum densities.

The City is not constraining maximum density—developers often choose to develop at a lower density, but it is not because of governmental constraints. The City is already initiating the implementation plan for the Housing Element program, including the preparation of the MU-1 zone and MU-2 overlay zone and associated development standards. The standards will be formulated such that developers can achieve the maximum allowable density.

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Affordability, Suitability, and Availability Analysis
This subsection describes the assumptions applied to each parcel in Appendix C: Sites Inventory to determine affordability level and establish the suitability and availability for development within the 2021-2029 RHNA period.

Lower Income
Zones in El Centro that allow at least 20 dwelling units per acre are considered sufficient to accommodate housing that is affordable to lower income households “by default” per Government Code Section 65583.2(c)(3)(B). The City’s R3 zone allows up to 25 units per acre and therefore meets this default affordability density threshold. The City’s CT zone, which allows mixed use and multi-family residential with a Conditional Use Permit, also meets this default affordability density threshold because at least 20 units per acre are achievable given the maximum allowable FAR of 1.0 and development history. As described in the previous section, the City has added a new MU-2 Overlay designation to the Land Use Element since the last Housing Element update, which requires the creation of a new zone to implement it (see Program 1). The zone created to implement the MU-2 Overlay will allow a minimum of 21 dwelling units per acre with a maximum density of up to 30 dwelling units per acre, which meets the default density—in fact, the minimum allowed density exceeds the default density.

The City has identified 36 High-Medium Density Residential, Tourist Commercial, and Mixed Use 2 Overlay parcels or properties covering 105.25 acres that are vacant and available for development in the planning period. These parcels can accommodate at least 1,883 lower income units assuming a density factor of between 19.0 and 21.0 dwelling units per acre. Each site is larger than 0.50 acre and the average parcel size is 2.92 acres. Although two sites are larger than 10 acres, there has been expressed interest from developers for residential development.

Moderate Income
As described previously, the City has added the MU-1 designation to the Land Use Element since the last Housing Element update, which requires the creation of a new zone to implement it. A total of 2.47 acres on five parcels that are designated MU-1 are vacant and available to accommodate at least 47 moderate income units within the RHNA period. Another 25.57 acres on 50 parcels in the R3 and R2 zones (including two City-owned parcels) are vacant and available to accommodate at least 396 moderate income units within the RHNA period. The average size of the parcels identified to accommodate the moderate income RHNA is 0.51 acre. Based on the real estate market data presented in Section 2.7 of this Housing Element, it is reasonable to assume that new multi-family construction on relatively smaller R3, R2, CD, CT, and MU-1 sites will be offered at market prices that are affordable to moderate income households.

Above Moderate Income
El Centro’s remaining RHNA for above moderate income households will be accommodated on 386.5 acres consisting of 72 parcels zoned for lower density residential (R1 and RR). These sites are suitable to accommodate at least 1,529 single-family units. This is in addition to the already approved projects that did not have permits issued prior to July 1, 2021. New construction on these sites is assumed to produce units that are affordable to above moderate income households.

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Public Services and Infrastructure Availability
El Centro has adopted an Urban Development Program to facilitate residential, industrial, and business growth in those areas where public services are available and to provide a variety of growth locations so that an adequate supply of developable land will maintain reasonable housing costs and promote economic development. While the majority of property within the City boundary has access to utilities, there are exceptions. To identify those areas that will require more extensive planning, ensuring the provision of adequate levels of public services and facilities, the undeveloped portion of the Planning Area has been divided into three development tier areas—Tier I, Tier II, and Tier III.

All lower income and moderate income sites are served by utilities. Several of the above-moderate income sites are located in the Tier I Growth Area. New development within the Tier I Growth Area can be served by gravity sewer lines to existing trunk sewers. Generally, water lines and reservoirs are also adequate to serve new development; however, easements and financial contributions to improve the ultimate sewer and water systems may be required. Fire, police, schools, parks, library, medical, roads, and other City facilities and services also are in proximity to these areas, though service capacities are likely to be limited and improvements to existing facilities and/or new facilities may be needed to adequately accommodate new development.

Subdivisions of land and commercial, industrial, and mixed use development within Tier I generally would follow standard zoning, subdivision, and environmental review procedures. As discussed in detail in Section 3.4.C of this Housing Element, Tier I is the “Current Urban Service Area” and no significant public service or infrastructure constraints have been identified.

Adequacy of Sites to Meet the City’s RHNA
Table 48 summarizes the City’s accommodation of the RHNA for all income groups by General Plan Land Use Designation.

Table 48: Adequacy of Sites to Accommodate the 2021-2029 RHNA by Land Use Designation General Plan Land Use
Designation Lower Income Moderate Income Above Moderate Income Total Low Density Residential --- --- 1,061 1,061
Medium Density Residential --- 61 437 498
High-Medium Density Residential 633 331 --- 964
Mixed Use 1 --- 45 --- 45
Mixed Use 2 Overlay 874 --- --- 874
Tourist Commercial 375 --- --- 375
Neighborhood Commercial 21 --- --- 21
Total 1,963 437 1,498 3,838
Table 49 summarizes the City’s accommodation of the RHNA for all income groups during the 2021-2029 RHNA period. After accounting for the realistic capacity of vacant sites, the City has identified capacity of at 3,838 units for the RHNA period, including a surplus of 1,150 units.

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Table 49: Adequacy of Sites to Accommodate the 2021-2029 RHNA Income RHNA Entitled/
Pending
Pipeline
Projects Sites Surplus %Surplus
Very Low (<50% AMI) 1,491 --- --- 1,883 392 26%
Low (51-80% AMI)
Moderate (81%-120% AMI) 462 --- 180 443 161 35%
Above Moderate (>120% AMI) 1,489 574 --- 1,498 583 39%
Total 3,442 574 180 3,924 1,136 33%

4.2. Financial Resources
The State’s dissolution of the El Centro’s redevelopment agency in 2012 eliminated the City’s primary source of affordable housing funding. Other funding resources available for affordable housing development are highly limited. These other financial resources include private contributions (including foundations or trusts), semi-public agencies and federal and state agencies. Listed below are some typical sources of funds used for affordable housing:
▪ State of California, Department of Housing and Community Development loan and grant programs
▪ California Housing Finance Agency financial assistance programs ▪ Federal/State Low Income Housing Tax Credits (LIHTC)
▪ Rural Housing Administration (Farmers Home Administration or FHA) Programs ▪ U.S. Department of Housing and Urban Development (HUD) Programs The City of El Centro is an entitlement jurisdiction under the HUD Community Development Block Grant (CDBG) program. For FY 2021, the City received an allocation of approximately $558,074 for a range of housing and community development activities. Specifically, the City has used CDBG funds to address lead-based paint and asbestos hazard abatements, as to provide public services in the areas of fair housing, senior services, families affected by domestic violence through visitation assistance, homeless shelter, and homeless assistance through local non-profit agencies. The City also used CDBG funds for Code Enforcement program, which consists of conducting inspections for code violations and enforcement of state and/or local codes.

4.3. Administrative Resources
The City collaborates with various agencies, developers, and organizations to provide affordable housing and supportive services for lower and moderate income households and households with special needs. Key agencies, developers, and organizations include:
▪ Imperial Valley Housing Authority: The Housing Authority administers the Housing Choice Voucher program in the Imperial Valley, including El Centro. The Housing Authority also owns and operates public housing located throughout the County, with units for seniors, farm workers, and the disabled in El Centro. ▪ Imperial County Regional Task Force on Homelessness: The Task Force serves as the lead agency for Imperial County homeless issues. The City will continue to participate in activities and outreach conducted by the Task Force.

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▪ California Coalition for Rural Housing: The California Coalition for Rural Housing (CCRH) is a statewide nonprofit organization that works to ensure affordable housing opportunities for low-income households in California. CCRH supports the production and preservation of decent, safe, and low-cost housing for rural and low-income Californians. Supporters include nonprofit housing agencies, lending institutions, community advocacy organizations, consumer members, and local government officials.

The Coalition advocates for housing at all levels of government before legislative and regulatory bodies. It also provides technical and organizational assistance to community groups and nonprofit agencies and educates the public on housing issues. ▪ Affordable Housing Developers: The City collaborates with a number of affordable housing developers and service providers to accommodate the housing needs of El Centro residents. The following are some of the housing developers and service providers active in southern California; several are included in the State’s list of entities with the legal and managerial capacity to acquire and manage at-risk projects: AMG, Affirmed Housing Group, Bridge Housing, Jamboree Housing, and Chelsea Investment Group. ▪ Supportive Services: Various non-profit groups that provide supportive services to the special needs population in El Centro. Some of the key groups operating in Imperial Valley include the Center for Family Solutions, Imperial County Family Resource Center, Campesinos Unidos, Catholic Charities, Independent Living Center, Neighborhood House, and Veteran Services.

4.4. Opportunities for Energy Conservation
Two basic and interrelated approaches to creating energy conservation opportunities in residences are conservation and development:
▪ Conservation: Conservation can be accomplished by reducing the use of energyconsuming items, or by physically modifying existing structures and land uses. The California Energy Commission first adopted energy conservation standards for new construction in 1978. These standards, contained in Title 24 of the California Administrative Code, contain specifications relating to insulation, glazing, heating and cooling systems, water heaters, swimming pool heaters, and several other items. ▪ Development: Solar energy is a viable alternate energy source for the City of El Centro.

Two basic types of solar systems exist: active and passive. In passive solar systems, the structure itself is designed to collect the sun’s energy, then store and circulate the resulting heat similar to a greenhouse. Active solar systems typically collect and store energy in panels attached to the exterior of a house. This type of system utilizes mechanical fans or pumps to circulate the warm/cool air, while heated water can flow directly into a home’s hot water system.

Additional conservation opportunities are found in new construction. Residential construction techniques for conservation and sustainability have been gaining in popularity and acceptance in recent years. The most widely recognized certifying agency with respect to such construction is LEED, the Leadership in Energy and Environmental Design (LEED) Green Building System. The intent of LEED is to encourage widespread

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implementation of development practices that further the concept of sustainability and environmental friendliness in the built environment.

The City strictly enforces Title 24 Energy Requirements. In addition, the local energy company, the Imperial Irrigation District (IID), offers incentives to homeowners with rebates to buy energy efficient air conditioners, appliances and thermostats. IDD income-qualifying costumers can also enroll in the Residential Energy Assistance Program (REAP) which provides them with a 20 percent discount on their electric bill. IID also offers a 30 percent REAP discount to qualifying customers age 62 or older. IID also partners with the Citizens Energy Corporation for the Imperial Solar/E-Green and Solar Homes Programs. The Imperial Solar/E-green Program, the nation's largest low-income community solar program generates 30 megawatts of power for the IID grid under a 23-year purchase power agreement. IID directly passes on these savings to all of its qualified low-income electric customers enrolled in the REAP program in the form of an additional monthly discount on their electric bills. Through the Solar Homes Program, using proceeds from their partnership on the Sunrise Powerlink transmission line, Citizens Energy works to install solar rooftop systems for low income residents in Imperial Valley.

Also, air pollution control measures from the Imperial Air Pollution Control District require new construction and development to include energy conservation measures (Imperial County Air Pollution Control District rule 310).

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5.Housing Plan
This section of the Housing Element contains the goals, policies, and programs the City of El Centro intends to implement to meet its quantified objectives and address a number of important housing-related issues through the 2021-2029 planning period. The Housing Plan considers accomplishments under the 2013-2021 Housing Element (see Appendix B: Review of Past Accomplishments) and builds upon the identified City’s housing needs, constraints on residential development, and resources available to address El Centro’s existing and future housing needs, as well as changes to the Housing Element requirements. To make adequate provision for the housing needs of all economic segments of the City and consistent with statutory requirements, the Housing Plan aims to:
▪ Conserve, preserve, and improve the condition of the existing affordable housing stock [Government Code Section 65583(c)(4 & 6)];
▪ Assist in the development of housing for extremely low, very low, low, and moderate income households [Government Code Section 65583(c)(2)]; ▪ Identify adequate sites to encourage the development of a variety of types of housing for all income levels [Government Code Section 65583(c)(1)]; ▪ Address and, where appropriate and legally possible, remove governmental constraints to the maintenance, improvement, and development of housing [Government Code Section 65583(c)(3)]; and
▪ Promote housing opportunities for all persons [Government Code Section 65583(c)(5)].

5.1 Goals and Policies
Goals are statements of community desires, which are broad in both purpose and aim, but are designed specifically to establish direction. Policies provide specific standards and/or end statements for achieving a goal. Essentially, goals represent desired outcomes the City seeks to achieve through the implementation of policies. The goals and policies that guide the City’s housing programs and activities are as follows:

A. Housing Diversity and Opportunities
Striving to provide a balanced inventory of housing in terms of unit type, tenure, cost, and style will allow the City to fulfill a variety of housing needs.

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GOAL 1.0: Adequate housing to meet the existing and future needs of El Centro residents.

Policy 1.1: Maintain land use controls and development standards that can accommodate a variety of housing opportunities, including single-family homes, townhomes, apartments, condominiums, mixed-use development, accessory dwelling units, and mobile homes to fulfill regional housing needs.

Policy 1.2: Facilitate the development of affordable housing by offering development incentives on a case-by-case basis.

Policy 1.3: Encourage the development of residential units intended to meet the needs of extremely low income households, seniors, persons with disabilities (including persons with developmental disabilities), farm workers, and those experiencing homelessness.

Policy 1.4: Work with developers to identify and, when feasible, remove or reduce governmental constraints on affordable housing development.

Policy 1.5: Encourage the development of new housing units in close proximity to public transportation and community services, including mixed-use development.

Policy 1.6: Identify and pursue State and federal programs and funding to facilitate development of housing that is suitable for lower income (including extremely low income) households, including farmworkers.

Policy 1.7: Support the provision of housing services in meeting the housing needs of El Centro residents, including extremely low income households, the homeless and near-homeless, farmworkers, and persons with disabilities.

Policy 1.8: Encourage the development of affordable homeownership housing for first-time homebuyers.

Policy 1.9: Pursue state and federal funding sources to provide favorable home purchase options to lower and moderate income households.

Policy 1.10: Process permits concurrently as a means of streamlining development review.

Policy 1.11: Support efforts of non-profits, private developers, and the Imperial Valley Housing Authority to expand the City’s supply of affordable housing.

Policy 1.12: Encourage developers of multi-family rental housing to include units with three or more bedrooms to accommodate the needs of large households.

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B. Maintenance, Preservation, and Conservation of Housing The majority of El Centro’s housing stock is in good condition. However, some older single-family neighborhoods and multi-family structures show evidence of deferred maintenance and deterioration. As the City's housing stock continues to age, on-going maintenance is vital to prevent further deterioration. Other housing conservation needs of the City include existing affordable housing stock and rental units at risk of converting to market-rents or condominiums, and the Housing Choice Voucher Program.

GOAL 2.0: Maintenance and enhancement of the quality of residential neighborhoods and living environments.

Policy 2.1: Improve the overall quality and conditions of existing housing in El Centro.

Policy 2.2: Advocate and facilitate the conservation and rehabilitation of substandard residential properties by homeowners.

Policy 2.3: As funds allow, continue to offer rehabilitation and home improvement assistance to lower income homeowners.

Policy 2.4: Work to preserve restricted lower income housing in the City that is at risk of converting to market rate use.

Policy 2.5: Continue to support Imperial Valley Housing Authority efforts to preserve and expand rental assistance programs for extremely low income households, including the Housing Choice Voucher Program.

Policy 2.6: Discourage smoking in homes that are occupied by children, the elderly, and others with health issues to enhance living environment quality.

Policy 2.7: Avoid displacement of residents in carrying out City programs, whenever possible, or provide relocation assistance subject to available funds.

Policy 2.8: Conduct a Housing Conditions Survey during the planning period, subject to available funds.

Policy 2.9: Preserve and maintain existing and future neighborhoods through continued enforcement of City codes.

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C. Affirmatively Further Fair Housing
Promotion of equal housing opportunities for all existing and future El Centro residents is necessary to make adequate provision for the housing needs of all socioeconomic segments of the community.

GOAL 3.0: Equal opportunity for all residents to reside in housing of their choice.

Policy 3.1: Prohibit discrimination in the sale, rental, or financing of housing based characteristics protected under State and Federal fair housing laws.

Policy 3.2: Accommodate persons with disabilities (including persons with developmental disabilities) who seek reasonable waiver or modification of land use controls and/or development standards pursuant to procedures and criteria set forth in the Zoning Ordinance.

Policy 3.3: Encourage the provision of designs that support aging in place (such as universal design) in new development.

Policy 3.4: Continue to support and participate with a fair housing service provider that can receive and investigate fair housing allegations, monitor compliance with fair housing laws, and refer possible violations to enforcing agencies.

Policy 3.5: Work to mitigate impacts of economic displacement of existing residents.

Policy 3.6: Employ place-based strategies to implement neighborhood improvements.

Policy 3.7: Expand housing options in the City and promote housing mobility and choices.

D. Energy Conservation in Housing Development
Conserving energy helps reduce household costs and enable households to allocate more disposable income to housing costs, which can reduce the incidence of housing problems such as cost burden and overcrowding.

GOAL 4.0: Housing that maximizes opportunities for energy conservation.

Policy 4.1: Promote passive energy conservation measures through site planning and landscaping techniques.

Policy 4.2: Encourage developers to exceed minimum Title 24 energy conservation requirements.

Policy 4.3: Educate the public regarding simple energy conservation measures that can be implemented in the home.

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Policy 4.4: Encourage weatherization improvements, roofing repairs, window replacement, and appliance upgrades to conserve energy.

5.2 Housing Programs
Programs identify specific actions the City will undertake toward putting each goal and policy into action. Each program relates to one or more goals and policies and may overlap the various issue areas.

El Centro offers a variety of housing opportunities to meet the needs of the community. This section of the Housing Plan addresses the issues identified in the previous sections of the Element and provides a strategy to achieve the City’s housing goals. The housing programs designed to implement the City’s strategy are discussed in detail below.

A. Facilitate the Provision of a Variety of Housing Types, Densities, and Opportunities
A key element in satisfying the housing needs of all segments of the community is the provision for a variety of housing types and densities for renters and owners. This is an important function of both the General Plan and zoning.

Program 1: Adequate Sites for RHNA
The City of El Centro has been assigned a Regional Housing Needs Assessment (RHNA) of 3,442 units for the 2021-2029 planning period. With projected ADUs and entitle/pipeline projects, the City has the ability to provide 754 units, with a remaining RHNA of 2,688 units (1,001 very low income, 490 low income, 282 moderate income, and 915 above moderate income units).

The remaining RHNA will be accommodate entirely on vacant land designated for various residential and mixed use development through the City’s newly adopted Land Use Element (June 2021). The City will be updating its Zoning Ordinance to implement the Mixed Use 1 (MU-1) and Mixed Use 2 Overlay (MU-2 Overlay) – two new land use designations created in the new Land Use Element. An estimated 45 moderate income units will be accommodated in MU-1 (12-25 du/ac) and 875 lower income units will be accommodated in the MU-2 Overlay (21-30 du/ac). The rezoned sites will meet the requirements of Government Code 65583.2, including but not limited to a minimum density of 20 units per acre, minimum site size to permit at least 16 units on site, and zoned to allow ownership and rental housing by right in which at least 20 percent of the units are affordable to lower income households. Specifically for MU-2 Overlay, the Zoning Ordinance update will allow standalone multi-family housing, and projects with 20 percent affordable units for lower income households will be eligible for by-right approval, pursuant to State law (see Program 3).

Development on nonvacant sites with existing residential units is subject to replacement requirement, pursuant to AB 1397. The City will amend the Zoning Code to require the

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replacement of units affordable to the same or lower income level as a condition of any development on a nonvacant site consistent with those requirements set forth in State Law.

Responsible Agency: Community Development Department
Financing: Department budget
2021-2029 Objectives:
▪ Update the Zoning Ordinance to address the replacement requirements within one year of Housing Element adoption.
▪ Update the Zoning Ordinance to implement the MU-1 and MU-2 Overlay designations of the Land Use Element by October 15, 2024.
▪ Maintain and monitor the residential sites inventory to ensure adequate sites remain to accommodate the RHNA throughout the RHNA period.
▪ Provide sites inventory information online and update at least annually.

Program 2: Monitor Residential Capacity (SB 166 No Net Loss) City staff will monitor the consumption of residential acreage to ensure an adequate inventory is available to meet the City’s RHNA obligations. To ensure sufficient residential capacity is maintained to accommodate the RHNA, the City will develop and implement a formal ongoing (project-by-project) evaluation procedure pursuant to Government Code Section 65863. The City’s development application tracking software will notify staff when an application has been submitted for development of a property included in the residential sites inventory (Appendix C). Should an approval of development result in a reduction of capacity below the residential capacity needed to accommodate the remaining need for lower income households, the City will identify and, if necessary, rezone sufficient sites to accommodate the shortfall and ensure “no net loss” in capacity to accommodate the RHNA.

Responsible Agency: Community Development Department; Community Services Department
Financing: Department budget
2021-2029 Objectives:
▪ Develop and implement a formal evaluation procedure pursuant to Government Code Section 65863 by 2022.

Program 3: By-Right Approval of Projects with 20 Percent Affordable (AB 1397) Pursuant to AB 1397, the following categories of sites in the sites inventory of this Housing Element are subject to by-right approval if 20 percent of the units are set aside as affordable housing for lower income households:
▪ Reuse sites - Vacant R3 and CT sites previously identified in the 4th and 5th cycle Housing Element for lower income RHNA
▪ Rezone sites – MU-2 Overlay sites for lower income RHNA

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Responsible Agency: Community Development Department; Community Services Department
Financing: Department budget
2021-2029 Objectives:
▪ Develop and implement a formal evaluation procedure pursuant to Government Code Section 65863 by 2022.

Program 4: Accessory Dwelling Units
Accessory Dwelling Units (ADUs) represent an alternative source of affordable housing. While the City’s Zoning Ordinance complies with State law regarding the provision of ADUs, the Zoning definition of accessory unit is unclear and the parking requirement is not consistent with State law. The City will amend the Zoning Ordinance to bring the definition into compliance with State law. Furthermore, the City will develop incentives to facilitate the construction of ADUs.

Responsible Agency: Community Development Department; Community Services Department
Financing: Department budget
2021-2029 Objectives:
▪ Amend the Zoning Ordinance by the end of 2022 to:
o Clarify definition of ADUs
o Establish parking standards in consistent with State law o Ensure regulations for single-family dwellings conform to State law allowing ADUs and Junior ADUs (JADUs)
▪ By 2023, develop incentives to facilitate ADU production. Incentives may include preapproved plans, expedited review, and increased allowable size, etc. ▪ Facilitate the construction of 40 ADUs over eight years.

Program 5: Facilitate Affordable and Special Needs Housing Production Developers of affordable and special needs housing face a number of hurdles, including financing, development codes and standards, and in some cases, public opposition. The City can encourage and facilitate affordable and special needs housing through financial assistance, removal of regulatory constraints, and administrative support. El Centro does not have a large farmworker population. Countywide, migrant farmworkers are estimated at about 1,057 persons, according to the USDA. Most farmworkers in the County were hired full time.

Therefore, housing needs for farmworkers and farmworker families in El Centro can be addressed with affordable housing for lower income households.

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With limited funding, the City will rely on the following non-funding-related actions to encourage affordable and special needs housing production (including housing for extremely low income households, farmworkers, and the developmentally disabled) during the planning period:
▪ Collaborate with Affordable and Special Needs Housing Developers: Affordable housing developers work to develop, conserve and promote rental and ownership affordable housing. Particularly in relation to farmworker housing, senior housing, and housing for persons with disabilities (including persons with developmental disabilities), the affordable housing developer is often, but not always, a local organization interested in developing affordable housing. The affordable housing developer is often involved with what is called "assisted housing", where some type of government assistance (such as Section 8 or Tax Credits) is provided to the individual household to keep rents affordable. An affordable or special needs housing developer can help meet the goals for additional housing by implementing or assisting with the implementation of programs described in this Element. The City will continue to collaborate with affordable and special needs housing developers to identify potential sites, write letters of support to help secure governmental and private-sector funding, and offer technical assistance related to the application of City incentive programs (e.g., density bonus).
▪ Regulatory Concessions and Incentives: The City will continue to work with developers on a case-by-case basis to provide regulatory concessions and incentives to assist them with the development of affordable and senior housing. The newly adopted General Plan Land Use Element provides for increased base density in MU1 and MU-2 Overlay for senior housing. In a relatively small city like El Centro, this is the most effective method of assisting developers, as each individual project can be analyzed to determine which concessions and incentives would be the most beneficial to the project’s feasibility. Regulatory concessions and incentives could include, but are not limited to, density bonuses, parking reductions, fee reductions or deferral, expedited permit processing, and modified or waived development standards.

Responsible Agency: Community Development Department
Financing: Department budget
2021-2029 Objectives:
▪ Maintain contact information for affordable housing developers special needs service providers for the purposes of soliciting their involvement in development projects in El Centro. Annually, the City will contact local and regional affordable housing developers, especially those that focus on housing for the disabled, seniors, and farmworker households to explore opportunities for affordable housing. ▪ Participate with affordable and special needs housing developers to review available federal and State financing subsidies and apply as feasible on an annual basis. Provide letters of support to applications of nonprofit developers for affordable housing financing.
▪ Assist and support developers of housing for lower income households, especially housing for extremely low income households, farmworker households, and the disabled (including the developmentally disabled), with site identification,

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supporting applications, conducting pre-application meetings, assisting with design and site requirements, and providing regulatory incentives and concessions. ▪ Collaborate with developers of affordable housing over the planning period to facilitate the construction of 200 affordable units over the planning period (20 extremely low income, 80 very low income, and 100 low income units).

Program 6: First-Time Homebuyer Program
The City will pursue affordable ownership housing opportunities for lower and moderate income households. Specifically, the City will provide information on homebuyer assistance programs available to El Centro residents through the California Housing Finance Agency (CalHFA):
▪ Mortgage Credit Certificate (MCC) – The MCC program offers qualified first-time homebuyers a Federal income tax credit. The credit can reduce potential Federal income tax liability, creating additional net spendable income for qualified first-time homebuyers to possibly use toward their monthly mortgage payment. This MCC Program enables qualified first-time homebuyers to convert a portion of their annual mortgage interest into a direct dollar-for-dollar tax credit on their U.S. individual income tax returns.
▪ Homebuyer Loan Programs – El Centro residents can access homebuyer assistance programs available from CalHFA. These include first mortgage programs and downpayment assistance programs.

Responsible Agency: Community Development Department
Financing: Department budget
2021-2029 Objectives:
▪ Provide links to CalHFA programs on City website by the end of 2022. ▪ Annually pursue available funding programs to deliver homebuyer assistance.

B. Removal of Constraints
State law requires the Housing Element to address, and where appropriate and legally possible, remove constraints affecting the maintenance, improvement, and development of housing.

Program 7: Zoning Code Amendments
To facilitate the development of affordable and special needs housing, the State has passed numerous new requirements that necessitate the City of El Centro to amend its Zoning Ordinance. In addition, the City has identified additional changes to its development regulations to facilitate housing development. These changes include:
▪ Density Bonus: The State Density Bonus Law has been amended numerous times in recent years. Key changes include:

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o AB 1763 (Density Bonus for 100 Percent Affordable Housing) - Density bonus and increased incentives for 100 percent affordable housing projects for lower income households.
o SB 1227 (Density Bonus for Student Housing) - Density bonus for student housing development for students enrolled at a full-time college, and to establish prioritization for students experiencing homelessness.
o AB 2345 (Increase Maximum Allowable Density) - Revised the requirements for receiving concessions and incentives, and the maximum density bonus provided. ▪ Emergency and Transitional Housing (AB 139): Local governments may include parking requirements for emergency shelters specifying that adequate parking must be provided for shelter staff, but overall parking requirements for shelters may not exceed the requirements for residential and commercial uses in the same zone. ▪ Low Barrier Navigation Center (AB 101): AB 101 requires cities to permit Low Barrier Navigation Centers by right in areas zoned for mixed-use and nonresidential zones that permit multi-family uses, if the center meets certain requirements. AB 101 defines a Low Barrier Navigation Center as “a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing.”
▪ Supportive Housing (AB 2162): AB 2162 requires supportive housing projects of 50 units or fewer to be permitted by right in zones where multi-family and mixed-use developments are permitted, when the development meets certain conditions. The bill also prohibits minimum parking requirements for supportive housing within ½ mile of a public transit stop.
▪ Farmworker Housing: The California Employee Housing Act requires housing for agricultural workers consisting of no more than 36 beds in a group quarters or 12 units or spaces designed for use by a single-family or household be considered an agricultural land use, and permitted in the same way as other agricultural uses. Update the Zoning Ordinance to allow housing for agricultural workers as defined by the California Employee Housing Act in the RR zone as required by State law.
▪ Employee Housing: The California Employee Housing Act further requires housing for six of fewer employees be considered a single-family residential use. Update the Zoning Ordinance to comply with State law.
▪ Open Space Requirements: Update open space requirement to allow a reduction in open space when high-quality community amenities, such as play structures or covered seating and food preparation areas, are provided.
▪ SB 35 Streamlined Approval: Establish a formal procedure for streamlining, including a pre-application checklist.
▪ Residential Care Facilities for Seven or More Persons: Amend the Zoning Code to address the provision of residential care facilities for seven or more persons as similar uses in the same zone.

Responsible Agency: Community Development Department

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Financing: Department budget
2021-2029 Objectives:
▪ Amend Zoning Ordinance as outlined above by the end of 2022.

Program 8: Water and Sewer Service Priority for Affordable Housing Senate Bill 1087 (enacted 2006) requires that water and sewer providers develop written policies that grant priority to proposed development that includes housing affordable to lower income households. The legislation also prohibits water providers from denying or conditioning the approval of development that includes housing affordable to lower income households, unless specific written findings are made. The City will develop and establish a formal procedure to grant water and sewer priority to developments with units affordable to lower income households pursuant to Government Code Section 65589.7.

Responsible Agency: Public Works Department
Financing: Department budget
2021-2029 Objectives:
▪ Develop and establish a formal procedure to grant water and sewer priority to developments with units affordable to lower-income households within one year of adoption of the 2021-2029 Housing Element.

C. Provide Supportive Housing Assistance for Special Needs Population Where there is a need for affordable housing, often there is also a need for supportive services for lower income households, including extremely low income households. The City assists service providers in meeting the immediate needs of persons with special needs, including the homeless, near-homeless, and extremely low income households. Immediate need includes the provision of food, temporary shelter, health care, and other social services. The following programs intend to address the overall need for affordable housing and supportive services in El Centro.

Program 9: Coordination with Social Service Agencies
A variety of social services agencies provide housing and supportive services to special needs groups in El Centro. Several of these social service agencies receive CDBG funds from the City to help administer these programs. The City determines its CDBG allocations to social service agencies annually based upon applications received, whether the agency provides a priority need in the City’s five-year Consolidated Plan, and if the agency meets Federal HUD regulations. In a typical program year, funding is allocated to nonprofits that serve the following needs of lower income individuals and households (i.e., those earning up to 80 percent AMI): food distribution, housing assistance, services and programs for the elderly and youth, before and after school care programs, services for the disabled (including the developmentally disabled), primary health care services, and fair housing advocacy and counseling.

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Similar to the Housing Element update, the Consolidated Plan involves comprehensive outreach, citizen participation workshops, and assessment of community needs to develop a road map for programs and activities to be pursued in the ensuing five years. The variety of social service agencies that may be awarded CDBG are guided by priority needs articulated in the Consolidated Plan. All CDBG-contracted and funded programs (emergency housing/shelter, food distribution, primary health care services to the indigent or non-insured, senior case-management services and home-delivered meals, and before-and-after school youth programs for lower income families) address and assist the needs of lower income and special needs persons and households of our community.

Responsible Agency: Community Services Department
Financing: CDBG
2021-2029 Objectives:
▪ Continue to evaluate on an annual basis allocation of CDBG funds to social service agencies to benefit El Centro residents.
▪ Assist 250 special needs and lower income residents annually.

D. Maintain and Conserve the Existing and Future Housing Stock Market rents in El Centro are at a level which significantly limits the supply of housing affordable to very low income households. Rental subsidies are necessary to prevent many of the City's very low income residents from spending upwards of 30 percent of their incomes on housing costs, and over-extending themselves financially. In addition to rent subsidies, actions to conserve the 42 atrisk units at the Euclid Villas apartments will be necessary to maintain affordability. Furthermore, although the majority of the City’s housing stock is in good condition, the City seeks the continued maintenance and improvement of housing during the planning period.

Program 10: Rental Assistance
The Housing Choice Voucher (HCV) rental assistance program extends rental subsidies to extremely low and very low income families and elderly (i.e., those earning up to 50 percent AMI) who spend more than 30 percent of their income on rent. The subsidy represents the difference between the excess of 30 percent of their monthly income and the actual rent. The Imperial Valley Housing Authority (IVHA) administers the HCV Program in the City of El Centro.

California legislature passed SB 329, which redefines source of income as “lawful, verifiable income paid directly to a tenant or to a representative of a tenant, or paid to a housing owner or landlord on behalf of a tenant, including federal, state or local public assistance, and federal, state, or local housing subsidies, including, but not limited to, federal housing assistance vouchers issues under Section 8 of the United States Housing Act of 1937.” SB 222 passed in 2019 also extends the same protection to VASH (Veterans Affairs Supportive Housing) voucher recipients.

Responsible Agency: Imperial Valley Housing Authority
Financing: U.S. Department of Housing and Urban Development (HUD) 2021-2029 Objectives:

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▪ Continue to contract with the IVHA to administer the Housing Choice Vouchers Program and assist an average of approximately 900 extremely low and very low income households annually during the planning period.
▪ Promote the Housing Choice Vouchers program on City website. ▪ Partner with its fair housing service provider to educate the community on the new source of income protection.

Program 11: Conservation of Existing and Future Affordable Units In order to meet the housing needs of all economic groups in El Centro, the City must guard against the loss of housing units available to lower income households. As of June 2021, the City’s affordable housing inventory consisted of 914 units, of which 42 units were at risk of converting to market rate rents (see Table 30).

Responsible Agency: Community Services Department; Imperial Valley Housing Authority.

Financing: Section 8 vouchers; PHLA; CalHome
2021-2029 Objectives:
▪ Monitor Units at Risk: Maintain contact with providers and owners to monitor the status of existing and future affordable units, including the 42 at-risk units at Euclid Villas since they may lose their subsidies due to discontinuation of the Section 8 program at the federal level or opting out by the property owner. ▪ Work with Potential Purchasers: Where feasible, provide technical assistance to public and non-profit agencies interested in purchasing and/or managing units at risk. As funding permits, provide assistance to leverage the acquisition/preservation of at-risk housing, and/or support the funding applications of nonprofit housing providers to pursue the preservation of at-risk housing. ▪ Tenant Education: The California legislature extended the noticing requirement of atrisk units opting out of low income use restrictions to three years, requiring notifications three years, one year, and six months prior to conversion. Should a property owner pursue conversion of the units to market rate, the City will ensure that tenants were properly noticed and informed of their rights and that they are eligible to receive Section 8 vouchers that would enable them to stay in their units. ▪ Assist Tenants of Existing Rent Restricted Units to Obtain Section 8 Voucher Assistance: Tenants of housing units with expired Section 8 contracts are eligible to receive special Section 8 vouchers that can be used only at the same property. The City will assist tenants of "at-risk" units to obtain these Section 8 vouchers through the Imperial Valley Housing Authority.

Program 12: Housing Rehabilitation Loan Program
The City offers a low interest rate loan to lower income owner-occupants to rehabilitate their single family dwelling, address lead-based paint, and conduct asbestos testing. Eligible improvements

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include, but are not limited to, kitchen cabinetry, roofing, air conditioning, windows/doors, plumbing, electrical, insulation/weather proofing, paint, floor covering, additions to alleviate overcrowding, and total reconstruction (in certain circumstances). Loans amortized at a three percent interest rate are secured with a deed of trust for a maximum term of 15 years. The program also offers deferred loans at zero percent interest, subject to review every 36 months (non-seniors) or 84 months (seniors). The loan-to-value ratio of the property must not exceed 100 percent.

Responsible Agency: Community Services Department
Financing: CDBG
2021-2029 Objectives:
▪ Assist two low income homeowners annually with rehabilitation loans. ▪ Assist one low income homeowner annually with lead-based paint reduction. ▪ Assist one low income homeowner annually with asbestos testing and removal. ▪ Annually pursue other funding sources (e.g., CalHome) to expand housing rehabilitation assistance.

Program 13: Code Enforcement
Code Enforcement officers respond to complaints related to substandard housing, property maintenance, overgrown vegetation, trash and debris, illegal conversions, improper occupancy and other nuisance and zoning complaints. Code enforcement staff will to inform owner-occupants about the City’s Housing Rehabilitation Loan Program (see Program 12).

Responsible Agency: Community Development Department
Financing: CDBG and Department budget
2021-2029 Objectives:
▪ Continue to implement the applicable sections of the El Centro Municipal Code.

Inform eligible owners about the City’s Home Improvement Loan Program. ▪ Conduct code enforcement on 150 units annually.
▪ Adopt the most recent version of the California Building Code by 2022 and update every three years according to the State Building Code update schedule.

E. Affirmatively Further Fair Housing
Promoting equal housing opportunities for all persons is an important City goal. The following program is intended to help ensure El Centro residents have equal opportunity to obtain and maintain decent and safe housing
Program 14: Fair Housing Services
The City currently contracts with the Inland Fair Housing and Mediation Board (IFHMB) to provide fair housing services and landlord/tenant counseling to City residents. Typically, fair housing services include the investigation and resolution of housing discrimination complaints,

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discrimination auditing/testing, and education and outreach including the dissemination of fair housing information such as written material, workshops, and seminars. Landlord/tenant counseling services involves informing landlords and tenants of their rights and responsibilities under the California Civil Code and mediating conflicts between tenants and landlords.

The City monitors and attempts to minimize discriminatory housing practices with the assistance of the IFHMB that is annually funded by the City’s CDBG. The City advertises the availability of fair housing services by posting IFHMB posters and provides IFHMB informational flyers at public counters at City Hall and the Community Services Department offices. The City’s website also provides a link to IFHMB resources. Furthermore, the City accommodates IFHMB meetings and workshops at Council Chambers and distributes information at tabling events and includes articles about fair housing in a bi-annual newsletter and period newspaper advertisements published in English and Spanish.

As part of this Housing Element update, the City conducted an affirmatively furthering fair housing analysis (Appendix D), pursuant to AB 686. To address the fair housing issues, the City has developed a set of meaning actions to address issues identified (Table 50) Responsible Agency: Community Services Department; Inland Fair Housing and Mediation Board
Financing: CDBG
2021-2029 Objectives:

Table 50: Fair Housing Issues and Actions
Contributing Factor Meaningful Actions
Issue #1: Insufficient fair housing testing and limited outreach capacity ▪ Lack of fair housing testing services2
▪ Lack of targeted outreach 1
▪ Lack of variety of outreach meeting times2
▪ Lack of transportation to services
▪ Lack of awareness of services1
▪ By the end of 2022, meet with the fair housing service provider to revise the scope of work and explore their capability to accommodate the following outreach efforts:
o Plan to hold in-person meetings in various locations in the central census tracts.
o Seek sites that are transit-accessible and/or consider options to assist residents without vehicle access with transportation.
o Hold meeting at a variety of times
o Testing
▪ Increase community awareness of the IFHMB services
through postings on the City’s web pages, publication of newspaper display ads, and Community Newsletter articles, as stated in the 2019 AI. Based on findings from this
assessment, the City will also utilize non-traditional media (i.e. social media, City website) in outreach and education efforts, in addition to print media and notices.
▪ Targeted outreach of fair housing services and improvement programs (Home Rehabilitation and Façade Improvement
Program for neighborhood serving businesses on Main Street) in R/ECAPs, specifically Census Tract 115. Targeted outreach plan will include:

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Table 50: Fair Housing Issues and Actions
Contributing Factor Meaningful Actions
▪ Application Workshop - City staff will host a yearly
application workshop at the M.L. King Jr. Sports
Pavilion or another City facility in Census Tract 115.

The workshop will assist residents in completing
applications for the City Housing Rehabilitation Loan
Program and First-Time Homebuyer Program. The
workshop will also provide an opportunity for City
staff to gain valuable input from residents on the City housing programs. Assistance will be provided in
English and Spanish.
▪ Direct Mailing Campaign - City staff will coordinate a yearly direct mail campaign to addresses within
Census Tract 115 informing residents about City
housing programs. Additional mailings within
Census Tract 115 will also announce application
workshops. Letters will be in English and Spanish to
meet the language needs of residents.
▪ Postings – Flyers and posters will be posted at
neighborhood businesses within Census Tract 115
informing residents of the availability of city housing programs and workshops. Possible locations for
postings include Coin-O-Matic (laundromat), Euclid
Market (market), Raspados Cuchies (restaurant),
Los Compadres (market), or Antonio’s Meat Market
(market). Postings will be in English and Spanish.
▪ Develop list contact list for apartment managers to which to invite to workshops and send fair housing information by 2022, as stated in the 2019 AI. On an ongoing basis, contact interest list with updates.
▪ Request the Imperial County Association of REALTORS
update its website to include information regarding fair housing by the end of 2022, as stated in the 2019 AI.
▪ Request the Imperial Valley press Imperial Valley Press to publish notice regarding no pets policy and reasonable
accommodation by end of 2022, as stated in the 2019 AI. ▪ Ensure the IFBMB is enacting the new actions regarding steering and homebuyer services as stated in the 2019 AI.

Issue #2: Patterns of concentration as well as disparate access to opportunities/ resources for communities in the center of the City.
▪ Lack of access to local jobs
▪ Lack of high quality schools
▪ Low home values/old housing stock 1
▪ Lack of private investment1
▪ Lack of public investments in specific
neighborhoods, including services or
amenities1
▪ Location and type of affordable housingHCV use concentrated2 ▪ Developing multifamily and mixed-income housing
opportunities through the sites inventory - located close to 50 percent of lower income RHNA units in moderate and high resource areas.
▪ Require an Affirmative Marketing Plan (AMP) a condition for approval for density bonuses.
▪ Request that the fair housing service provider (IFHMB) inform tenants and landlords of the State’s new Source of Income Protection (SB 329 and SB 222).

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Table 50: Fair Housing Issues and Actions
Contributing Factor Meaningful Actions
▪ The availability of affordable units in a
range of sizes2
▪ Continue targeted improvements in CDBG eligible areas, which overlap with areas with low resources/high poverty and segregation. Improvements thus far have included a sports complex and aquatic center. In FY 2021, the City provided CDBG funds to perform upgrades to existing playground at Swarthout Park (located in the center of the City, in an area of high segregation and poverty).
▪ Support the construction of the El Centro Public Library, located in a low resource tract. Construction is expected to be complete by July 2022.
▪ Support the planned improvement projects in Census Tract 115- undergrounding the Date Canal, the north/south
connection of N. 12th Street from Oleander Avenue to Pico Avenue (curbs, gutter, and asphalt), and building a parking lot at Frazier Field, all of which will improve the health and safety of the community.
▪ Annually, coordinate with Public Works to prioritize areas identified as Disadvantaged Communities (SB 535) for actions and improvements. The City has invested in public works improvements on Adams Ave through investments on gyms,
skate parks, new aquatic center, Caltrans improvements and beatification., and conversions of SRO and hotels to new housing.
▪ The City provided $14 million in funds for water, sewer, and broadband projects.

Issue #3: Communities with disproportionate housing needs, like cost burdens, overcrowding, and substandard housing conditions, are concentrated in the census tracts in the center of the City. ▪ Age of housing stock 1
▪ The availability of affordable units in a
range of sizes 1
▪ Expand outreach to the central census tracts, especially parcels identified in the 2015 Housing Conditions Report, about the City’s Home Rehabilitation Program, through
targeted outreach efforts in Census Tract 115.
▪ Annually conduct outreach meetings regarding the Home Rehabilitation program at the Community Center
▪ Require an Affirmative Marketing Plan (AMP) a condition for approval for density bonuses

5.3 Summary of Quantified Objectives
Table 51 summarizes the City’s objectives in housing production, rehabilitation, and conservation/preservation based on the level of financial and administrative resources anticipated during the 2021-2029 Housing Element planning period. The RHNA is a planning goal; actual new construction of housing may not reach the RHNA due to development trends and funding availability. Program objectives are not cumulative as some overlap between programs can be expected given limited funding.

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Table 51: Quantified Objectives
Objective Category Extremely
Low
Very
Low Low Moderate Above Moderate Total
RHNA 500 501 490 462 1,489 3,442
New Construction 20 80 100 200 800 1,200
Rehabilitation 0 16 16 0 0 32
Conservation/Preservation
Affordable (including at-risk housing) 914 0 0 0
Housing Choice Vouchers 900 0 0 0 0

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6. Appendix A: Outreach Efforts
A.1. Housing Workshops
Outreach List
In addition to municipal, regional, and state agencies, including school districts and utilities, the following organizations and agencies were sent invitations - to attend the Housing Element Workshops held on February 8, 2021, May 19, 2021, and August 19, 2021.

Table A- 1: Outreach List
Organization Category
Desert Valley Builder's Association Developer
Southern California Gas Company Utility
Imperial Valley Housing Authority Housing Services
Inland Fair Housing and Mediation Board Housing Services California Rural Legal Assistance Housing Services
Chelsea Investment Corporation (Housing
Developer-Multifamily)
Developer
AMG & Associates (Housing Developer-Multifamily) Developer Materra (land development) Developer
YK America (Housing Developer-Multifamily) Developer
Dubose Design Group (Engineering/planning firm) Developer Galey Homes (Housing Developer) Developer
Comite Civico de Valle Housing Services
Imperial Valley Continuum of Care Housing Services
Coachella Valley Housing Coalition Housing Services
Imperial Valley Rentals (Housing Developer) Developer
CRP Affordable Housing and Community
Development
Developer
Imperial Valley Association of Realtors Developer
Roben Real Estate (Housing Developer) Developer
Imperial Valley Association of Realtors Developer
Methodist Church (Partnered w/affordable housing
developer)
Housing Services
Dubose Design Group (Engineering/planning firm)
Mitchell M. Tsai, Attorney At Law

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Comments Received
The key comments received at the meetings include:
• Concerns over the adequacy of water services from the Imperial Irrigation District (IID) to enable development.
• Concerns over costs associated with constructing or upgrading electrical power services provided by the IID.
• Concerns over impacts on existing school capacity to serve the new housing units. • Opportunity for affordable homeownership was emphasized.

The 2021-2029 Housing Element includes a program to pursue homeownership assistance. In addition, facilitating multi-family housing can increase the opportunity for affordable homeownership.

A.2. Focus Group Interviews
Public Service Providers
Date: March 30, 2021
Attendees: Coachella Valley Housing Coalition (CVHC), Blaz Gutierrez: CA Rural Legal Assistance (CRLA), Inland Fair Housing and Mediation Board, Molina HealthCare Expanding housing options, especially urban style options, addressing the housing needs of special needs groups, and affirmatively furthering fair housing are some of the key issues identified. The Housing Element implements the new General Plan Land Use Element to expand the range of housing choices in the City. The Housing Element identifies housing sites located throughout the City, with new opportunities being located in areas near services and amenities.

Table A- 2: Service Provider Focus Group Comments
Housing Needs
▪ Should consider the correlation between ag industry and rates of injury and their influence with physical disabilities. Ag workers experience high rates of injury, so that population has more disabilities, and higher rates of disabilities among older ag workers, predominantly Hispanic. Also mental health issues. ▪ The City’s high population does not meet the USDA Rural Funding requirements. So is suggesting a more urban style of housing provision. Need land donation to make housing affordable. ▪ Other types of needs include assistance with closing costs, rental assistance, neighborhood clean-up, habitability, and low income housing assistance including access to fair housing information, mobile home trade-in program.

Underserved Groups
▪ Issues with elderly and disabled persons having access to housing, and farmworkers are being taking advantage by landlords, long wait times for formal farm workers, unlawful evictions and defaults, high rate of unemployment and poverty.
▪ Concerns about affirmatively furthering fair housing, would like to see many different housing options, same options for everyone.

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Table A- 2: Service Provider Focus Group Comments
Housing Needs
▪ Discrimination against persons with disabilities, families with children, COVID has exacerbated the issues, problems accessing the courts. Need more access to safe and affordable housing. Not enough housing to fill the need.

Housing Obstacles
▪ Lack of availability of subsidized housing results in them going to private market and put tenants at risk. ▪ Affordable housing shouldn’t be restricted to only multifamily. To help alleviate the connotation of multifamily with affordable housing, affordable housing should be open to other types of housing stock. Large families need single-family homes.
▪ Affordable land with infrastructure for low income projects needed, partnerships with municipalities are very important. Worked on a semi-developed single-family subdivision in Imperial that was left over from the housing crises in 2008. Infrastructure was already in place so that saved a lot of time and cost - Morningside. ▪ Capacity fees for affordable housing is a constraint. For affordable housing, recommend defer fees.

Housing Location
▪ New housing should be placed in close proximately to basic services (employment, schools, grocery stores, medical care, etc.) transportation is very important on the siting of housing. ▪ Not siting places that are near negative environmental factors, the siting of affordable housing should consider potential health impacts.

Developers
Date: April 1, 2021
Attendees: Capital Real Estate Broker, Imperial Valley Home Rentals, YK America The key obstacle to development is timing. Lengthy process adds to the cost of development.

The Housing Element includes a by-right program if projects include 20 percent affordable units in certain locations. Infill development in mixed use areas is an important land use strategy for providing additional opportunities for housing.

Table A- 3: Developer Focus Group Comments and Responses Housing Needs
▪ The only new inventory is out of the price range of most- $250Ks to 350Ks is the target price range for single-family
▪ Repurposing existing commercial buildings that are vacant and unused should be considered, example of motels on Adams Avenue
▪ ADUs: Calexico has the triplex initiative where you can have an ADU, House, and converted garage to stimulate housing.
▪ Buyers without cash on hand find it difficult winning competitive bidding situations ▪ More multi-family needed, affordable housing needed
Underserved Groups
▪ All groups are underserved, affordable, entry-level housing needed most, 70%. 20% mid-level prices homes needed, 5% high level needed. Estimates that 70% of single family housing is for mid-level income demand.

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Table A- 3: Developer Focus Group Comments and Responses Housing Needs
Housing Obstacles
▪ Obstacles can include long time to get a project approved ▪ Time it takes to get approvals for housing is obstacle ▪ Hard to plan out for future materials prices, residential demand, mortgage rates ▪ Infrastructure cost is an obstacle, cost of CFDs.
▪ Power capacity is an issue with new developments. Costs to upgrade/construct new power facilities are pricy
▪ Mello Roos helps the builder but not the buyer
▪ Timing is everything with the market (market can change quickly, leads to changes to pricing) ▪ Is difficult when city expresses no-sense of urgency, 12 – 18 months to process a development is way too long, especially if no EIR
▪ Ideal entitlement period of 90 to 180 days, less than 90 days for smaller projects. ▪ Costs are going up, ex. Building materials, interest rates, oil prices. ▪ Cooperation with staff needed not just in Planning, but also Public Works ▪ Builder-friendly city needed
▪ City of Imperial has an advantage with lower impact fees and water and sewer rates were double in El Centro. ▪ Recommends reduced impact or building fees by 50% such as in 2000s. The overbuilt infrastructure costs being imposed on the project reduces demand to develop. ▪ Sometimes conditions imposed by the City are not feasible, deal killers ▪ School districts carry a lot of clout, high fees.
▪ Timing between project approval and issuance of building permits critical ▪ Delays are super expensive. Cost gets added to the cost of the home. ▪ Profit on single-family is really tight in El Centro
▪ Fees are high, especially school fees, connection fees, increasing materials costs ▪ CEQA slows down the process.

Housing Location and Opportunities
▪ Need infill low-income, multifamily and lofts. Infill development is concentrated on multi-family housing while greenfield development is attractive to single family builders ▪ The phase 1 and phase 2 annexation areas (Urban development plan) influences the costs of the homes and direction of growth.
▪ Make areas that are specific plans to entice smaller lot development without having the developer apply for that.
▪ Important for development to be close to day-to-day services ▪ Horizontal mixed use might be successful

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Mall Developer (CBL)
Date: April 21, 2021
CBL is a nationwide mall developer. They own 66 malls, including the Imperial Valley Mall (IVM) and additional property north of the IVM in El Centro (see Opportunity Area 4 in the newly adopted Land Use Element).
▪ Very much in favor of adding multifamily (especially senior living) housing near malls.

Highly beneficial for both mall properties and the residents of multifamily units. Built-in customers for the mall. CBL is not apartment developer so they would need a mult-ifamily developer partner. This could be to sell mall land, lease parcel(s), or partnership to build. CBL asked if there are multifamily developers that they should be talking to for a partnership. ▪ COVID turned retail upside down
▪ CBL thinks it will be hard to get multifamily inside the ring road at malls ▪ Example of housing near mall is Leighton, UT, 2 ½ acres, 196 apartments, 6 stories, 2 levels of parking
▪ City staff asked if CBL liked being in close proximity to Industrial Development, such as distribution centers. CBL prefers proximity to multifamily housing and hotels. ▪ Looking at the El Centro mall and parking lot configuration, CBL would be interested in creating better walkways to connect future housing and the mall. A possible future connection from an “outer parcel” to Macy’s was discussed. ▪ Parking ratios and landscape requirements would need to be adjusted ▪ CBL does not own the Sears store (now vacant). Estimated cost to demolish a Sears store is $2 million.
▪ CBL’s experience has been that subsidized housing near mall tends to lead to lower rents and stores closing. They have had better success with developers working in the market (marketrate housing). ▪ CBL is also interested in the idea of including schools, medical uses, office, grocery stores, amenities, etc., in and around their properties as part of the MU overlay. In favor of creating a mixed-use environment that offers a lot of things to a lot of people. Would like to create a “suburban town center.”
▪ CBL asked if the City has any kind of government aid to help with economic development near mall that might be a catalyst
▪ City staff also asked about whether governmental uses would be appropriate near the mall? County of Imperial may need more office space.
▪ In other areas, to spur mall activity, entertainment uses are being added (pre-COVID), Dick’s Sporting Goods, Main Event, hotels, restaurant pads, furniture store, fitness centers, climbing fitness centers (CBL doesn’t add these uses, rather partners with developers.)

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A.3. Incorporation of Comments
The City already addressed many of the comments through the Land Use Element. Feedback relating to the location and type of housing needed is addressed through changes in land use designations. The Mixed Use 1 and Mixed Use 2 Overlay land use designations are new designations created for the Land Use Element update. Both of these designations provide for new multi-family residential opportunities in areas that are on or near key commercial corridors in proximity to transit, existing and proposed pedestrian and bicycle paths, and shopping and other services. The updated Land Use Element also redesignates the majority of Rural Residential properties to Low density and Medium density residential land use designations to provide increased opportunities for moderate and above moderate income households. Stakeholder feedback was also used in determining the location of the sites in the inventory by identifying sites with near-term development.

In terms of the needs assessments, the City incorporated the feedback received from the City regarding an examination of the correlation between farmworkers and injuries and how this affects their housing type needs (p.25). Some residents also expressed the need for affordable and safe housing and for the City to affirmatively further fair housing. In response, the City has developed an extensive Fair Housing Plan (Table 50). The City also conducted a survey specifically related to AFFH and used the results, mainly that while services are available, the public is not aware of them, to improve its outreach actions in the Fair Housing Program.

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7. Appendix B: Review of Past Accomplishments
Government Code Section 65588(a) requires each jurisdiction to review its housing element as frequently as appropriate to evaluate:
• The appropriateness of the housing goals, objectives, and policies in contributing to the attainment of the state housing goal;
• The effectiveness of the housing element in attainment of the community’s housing goals and objectives; and
• The progress of the city, county or city and county in implementation of the housing element.

This section documents the City’s achievements under the 2013-2021 Housing Element with respect to the actions and objectives contained therein. This section describes the relative success of the City’s efforts to implement the 2013 programs, and contains recommendations for program retention, revision, deletion or addition to address current and projected needs and state requirements for the 2021-2029 planning period. The Housing Element planning period covers from October 15, 2013 through October 15, 2021. However, the RHNA planning period did not commence until January 1, 2014 and extended through October 31, 2021. Therefore, residential units permitted prior to January 1, 2014, although fall within the Housing Element planning period, will not receive RHNA credits for this Housing Element.

Table B- 1 compares quantified objectives and accomplishments during the 2014-2021 (through end of 2020). Table B- 2 lists these housing programs and provides a summary of accomplishments during the prior period.

Table B- 1: Objectives and Accomplishments
Income
Category
RHNA
Objective
New Construction Rehabilitation Conservation/
Preservation
Objective Accomplishment Objective Accomplishment Objective Accomplishment Extremely Low 487 5
195 0 0
Very Low 20 8 10 42 42
Low 300 35 131 16 1
Moderate 297 340 271 0 0 0 0
Above Moderate 840 500 83 0 0 0 0
Total 1,924 900 680 24 11 42 42
Effectiveness in Addressing Special Needs
The City of El Centro was successful in addressing the housing needs of special needs populations. Specifically, the City was able to facilitate the construction of special needs and affordable housing by activities that are not funding related:

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▪ Rezoning a 4.33-acre site to high density residential for senior and affordable housing ▪ Amending the Zoning code to facilitate the establishment of residential care facilities and group homes in the residential zones.
▪ Processing requests for reasonable accommodation.

In addition, the City was able to provide a range of supportive services for special needs groups using CDBG funds. For the 2021-2029 Housing Element, the City will pursue state funding for affordable and special needs housing.

Table B- 2: Review of Past Program Accomplishments
Goal and Associated Programs Accomplishments
Facilitate the Provision of a Variety of Housing Types, Densities, and Opportunities Program 1: Land
Use Controls and
Development
Capacity
Maintain and monitor the residential sites
inventory to ensure adequate sites
remain to accommodate the RHNA
throughout the RHNA period. Provide
sites inventory information to interested
developers.

Site inventory was available for developers at the customer service counter for review.

Continued Appropriateness: This program will be
updated to reflect the new RHNA and the new
requirements pursuant to AB 1397.

Program 2: Monitor
Residential Capacity
(No Net Loss)
Develop and implement a formal
evaluation procedure pursuant to
Government Code Section 65863 by
January 2014.

Between 2013 and 2020, 115 single family units were built on vacant lots, nine (9) single family homes were built as the first phase of the Lotus Ranch subdivision, 49
accessory dwelling units were built on existing single
family dwelling lots, 162 multi-family units were built (72 of them as part of an affordable housing project) and a total of 174 former hotel rooms were converted to studio units, resulting in no net loss in housing capacity during the planning period.

Continued Appropriateness: This program continues to
be appropriate pursuant to SB 166.

Program 3: Facilitate
Affordable and
Special Needs
Housing Production
Encourage and facilitate affordable and
special needs housing through financial
assistance removal of regular
constraints, and administrative support.

During the planning period, the Community Development
Department facilitated affordable housing and provided
administrative support to the by:
▪ Facilitating the rezone of a 4.33-acre property to
multiple-family residential for the proposed
construction on high-density senior and affordable
housing (2013).
▪ Approving the site plan for a 73-unit Multiple Family residential development proposed by AMG &
Associates (2014).
▪ Assisting Chelsea Development in completing an
Environmental Assessment for possible funding for
the affordable housing project Countryside II/Girasol
Apartments project at 1776 W. Adams Avenue
(2017). In 2020, the City processed the application
for the construction of the development.
▪ Working with AMG & Associates, LLC to prepare two
phases of the El Dorado Affordable Housing
Development (2019), both of which are under
construction.

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Table B- 2: Review of Past Program Accomplishments
Goal and Associated Programs Accomplishments
In 2013, the City also amended the Zoning code to
facilitate the establishment of residential care facilities and group homes in the residential zones. The Community
Development continues to be in contact with local
developers of affordable housing.

Program 4: FirstTime Homebuyer
Program
Continue to pursue CalHFA and other
available funding programs to deliver the
First Time Homebuyer Program. Assist
three low income and seven moderate
income first-time homebuyers annually
during the planning period.

Between 2013 and 2020, no applicant homebuyers
applied for the first time homebuyer program.

Continued Appropriateness: The 2021-2029 Housing
Element includes a program to provide outside resources for homebuyer assistance and to pursue funding in the
future.

Program 5:

Farmland Mitigation
Fee
Study farmland mitigation fund options
and present to the Planning Commission
and City Council for initial consideration.

The Community Development Department initiated
research on establishing a farmland mitigation fee
program in 2015 and initiated discussions with the
Community Services Department in developing a program.

The program was not pursued as it was viewed as a
hindrance to housing development.

Continued Appropriateness: This program is removed
from the 2021-2029 Housing Element.

Removal of Constraints
Program 6:

Reasonable
Accommodation
Modify the Reasonable Accommodation
Ordinance to
establish a ministerial review procedure.

Reduce or eliminate the $428 application
fee.

An amendment to the City's Zoning Ordinance that
established a ministerial review procedure for reasonable accommodation requests and that eliminated the
application fee was adopted by the City Council in April 2015. No applications for reasonable accommodation
were requested in 2016, 2017, 2018, 2019, or 2020.

Continued Appropriateness: The City amended the
ordinance to provide a formal process for reasonable
accommodation. Ongoing implementation of the Zoning
Ordinance is not included in the 2021-2029 Housing
Element as a program.

Program 7: Monitor
Changes in Federal
and State Housing,
Planning, and
Zoning Laws
Monitor State and federal legislation as
well as City development process and
zoning regulations to identify and remove
housing constraints.

The Community Development Department monitored
legislative change to State and Federal laws and
recommended pertinent updates to the City Code at such
a time that they became necessary. In 2016, the
Community Development Department began the process
to amend the zoning code to increase the opportunity for the construction of accessory dwelling units in compliance with Senate Bill 1069 and Assembly Bill 2406 in 2016 and Senate Bill 229 and Assembly Bill 494 in 2018. The ADU
ordinance is expected to go to City Council in December 2021.

Continued Appropriateness: The 2021-2029 Housing
Element includes a program to specifically identify
changes to Zoning Ordinance to comply with State laws.

Program 8: Water
and Sewer Service
Priority for
Affordable Housing
Develop and establish a formal procedure
to grant water and sewer priority to
developments with units affordable to
lower income households within one year
The City provides water and sewer services. Since there is no scarcity in sewer or water capacity, this has not been a priority.

5.d
Packet Pg. 191 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) City of El Centro
2021-2029 Housing Element Page B-4
Table B- 2: Review of Past Program Accomplishments
Goal and Associated Programs Accomplishments
of adoption of the 2013-2021 Housing
Element.

Continued Appropriateness: The adoption of policy to
prioritize water and sewer services is required by State law. This program is included in the 2021-2029 Housing
Element.

Provide Supportive Housing Assistance for Special Needs Populations Program 9:

Coordination with
Social Service
Agencies
Continue to evaluate on an annual basis
allocation of CDBG funds to social service
agencies to benefit El Centro residents.

Between 2013 and 2020, approximately $3,646,602
CDBG funds were programmed to be disbursed to public
service agencies. Public service agencies assisted with CDBG funds include Catholic Charities Senior Nutrition
Program, Catholic Charities House of Hope, the El Centro Police Athletic League, Woman Haven, and the Child
Abuse Prevention Council.

Continued Appropriateness: The City continue to
provide a range of services for special needs groups. This program is included in the 2021-2029 Housing Element.

Maintain and Conserve the Existing and Future Housing Stock Program 10: Rental
Assistance
Continue to contract with the Imperial
Valley Housing Authority to administer the
Housing Choice Vouchers Program and
assist an average of approximately 900
extremely low and very low income
households annually during the planning
period.

The Imperial Valley Housing Authority counted 933 very
low and low income households in El Centro assisted with Housing Choice Vouchers as of the 2020. The waitlist
period is approximately 22 months as of 2020.

Continued Appropriateness: This program remains
relevant and is modified in the 2021-2029 Housing
Element to include outreach and education on source of
income protection.

Program 11:

Conservation of
Existing and Future
Affordable Units
Work with property owners interest groups
and the State and Federal governments to
implement actions on an ongoing basis to
conserve its affordable housing stock.

The City did not lose any affordable housing due to
conversion to market rate during the planning period.

Continued Appropriateness: This program is updated
and included in the 2021-2029 Housing Element.

Program 12:

Housing
Rehabilitation Loan
Program
Assist two low-income homeowners and
one very low-income homeowner
annually.

The City intended to assist 16 low income and eight (8) very-low income homeowners through the Housing
Rehabilitation Loan Program. One (1) low income
household and 10 vey-low income households were
assisted between 2013 and 2020.

Continued Appropriateness: This program continues to
be relevant and is included in the 2021-2029 Housing
Element.

Program 13: Code
Enforcement
Continue to implement the applicable
sections of the El Centro Municipal Code.

Inform eligible owners about the City’s
Home Improvement Loan Program.

During the planning period, 1,048, Code Enforcement
cases were closed on housing related complaints. Code
Enforcement Officer also distributed information
pamphlets to potentially eligible homeowners about the
City's Housing Rehabilitation Loan Program.

Continued Appropriateness: This program continues to
be relevant and is included in the 2021-2029 Housing
Element.

Program 14: Fair
Housing Services
Continue to contract with a fair housing
service provider to provide fair housing
services. Maintain the link on the City
website providing information about fair
housing services.

Since 2007 the City of El Centro has contracted with the Inland Fair Housing and Mediation Board (IFHMB) to
conduct the necessary community outreach as it relates to fair housing laws and discrimination. During the planning period, outreach material was primarily provided by the

5.d
Packet Pg. 192 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) City of El Centro
2021-2029 Housing Element Page B-5
Table B- 2: Review of Past Program Accomplishments
Goal and Associated Programs Accomplishments
IFHMB. The City also distributes information at tabling events and includes articles about fair housing in a biannual newsletter. The IFHMB has its own outreach efforts they provide, such as public service announcements,
distribution of brochures at various sites within El Centro, fair housing community events. The City maintained
pamphlets on fair housing at the Community Development
Department and Community Services Department public
service counters.

Continued Appropriateness: This program is expanded
to address the affirmatively furthering fair housing
requirements.

5.d
Packet Pg. 193 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - Addendum to General Plan Final EIR) City of El Centro
2021-2029 Housing Element Page C-1

8. Appendix C: Sites Inventory
Table C- 1: 2021-2029 Sites Inventory
Site
#
APN Address GP Designation Zoning Acres
Consolidation
Potential
(A – W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
13 053-136-007 153 W STATE High-Medium Density Residential R3 0.17 12.1-25.0 19 3 Moderate Yes Y 13 053-136-023 156 W OLIVE High-Medium Density Residential R3 0.17 12.1-25.0 19 3 Moderate Yes Y 20 044-392-016 1464 W ADAMS AVE Mixed Use 1 CT* 1.85 F 12.1-25.0 19 35 Moderate Yes Y 20 044-392-005 1464 W ADAMS AVE Mixed Use 1 CT* 0.15 F 12.1-25.0 19 2 Moderate Yes Y 25 052-062-018 W BARBARA WORTH DR High-Medium Density Residential R3 0.23 G 12.1-25.0 19 4 Moderate Yes Y 25 052-062-017 W BARBARA WORTH DR High-Medium Density Residential R3 0.22 G 12.1-25.0 19 4 Moderate Yes Y 26 053-215-030 W OLIVE DR/N 1ST ST High-Medium Density Residential R3 0.43 12.1-25.0 19 8 Moderate Yes Y 27 053-136-020 134 W OLIVE AVE High-Medium Density Residential R3 0.27 H 12.1-25.0 19 5 Moderate Yes Y 27 053-136-019 W OLIVE DR/N 1ST ST High-Medium Density Residential R3 0.17 H 12.1-25.0 19 3 Moderate Yes Y 28 053-135-018 132 W STATE ST High-Medium Density Residential R3 0.17 12.1-25.0 19 3 Moderate Yes Y 29 053-292-006 151 W ORANGE AVE High-Medium Density Residential R3 0.16 12.1-25.0 19 3 Moderate Yes Y 30 053-283-005 257 W HOLT High-Medium Density Residential R3 0.19 12.1-25.0 19 3 Moderate Yes Y 31 044-351-004 1438 WOODWARD AVE High-Medium Density Residential R3 0.38 12.1-25.0 19 7 Moderate Yes Y 32 053-293-022 W HOLT AVE/S 2ND ST High-Medium Density Residential R3 0.16 I 12.1-25.0 19 3 Moderate Yes Y 32 053-293-021 W HOLT AVE/S 2ND ST High-Medium Density Residential R3 0.15 I 12.1-25.0 19 2 Moderate Yes Y 33 053-291-008 528 S 2ND DR High-Medium Density Residential R3 0.09 J 12.1-25.0 19 1 Moderate Yes Y 33 053-291-009 532 S 2ND DR High-Medium Density Residential R3 0.17 J 12.1-25.0 19 3 Moderate Yes Y 34 053-762-026 E HAMILTON AVE High-Medium Density Residential R3 0.25 12.1-25.0 19 4 Moderate Yes Y 35 053-043-035 517 W COMERCIAL ST High-Medium Density Residential R3 0.24 12.1-25.0 19 4 Moderate Yes Y 36 044-371-005 N 7TH ST High-Medium Density Residential R3 0.23 12.1-25.0 19 4 Moderate Yes Y 38 053-404-009 201 HAMILTON High-Medium Density Residential R3 0.2 12.1-25.0 19 3 Moderate Yes Y 39 053-136-015 W STATE ST/S 1ST ST High-Medium Density Residential R3 0.19 12.1-25.0 19 3 Moderate Yes Y 40 053-271-002 473 W BRIGHTON High-Medium Density Residential R3 0.19 12.1-25.0 19 3 Moderate Yes Y 41 053-263-004 W BRIGHTON/S 6TH ST High-Medium Density Residential R3 0.19 12.1-25.0 19 3 Moderate Yes Y 42 053-341-003 W HOLT AVE/S 8TH ST High-Medium Density Residential R3 0.19 12.1-25.0 19 3 Moderate Yes Y 44 044-381-022 N 7TH ST High-Medium Density Residential R3 0.19 12.1-25.0 19 3 Moderate Yes Y 45 053-214-024 W ORANGE AVE/2ND ST High-Medium Density Residential R3 0.18 12.1-25.0 19 3 Moderate Yes Y 46 044-402-005 1051 EL CENTRO AVE High-Medium Density Residential R3 0.17 12.1-25.0 19 3 Moderate Yes Y 47 044-402-007 1025 EL CENTRO AVE High-Medium Density Residential R3 0.17 12.1-25.0 19 3 Moderate Yes Y 48 053-213-003 W OLIVE AVE/2ND ST High-Medium Density Residential R3 0.17 12.1-25.0 19 3 Moderate Yes Y 49 053-046-034 PARK AVE/N 4TH ST High-Medium Density Residential R3 0.16 12.1-25.0 19 3 Moderate Yes Y

5.d
Packet Pg. 194 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - City of El Centro
2021-2029 Housing Element Page C-2
Table C- 1: 2021-2029 Sites Inventory
Site
#
APN Address GP Designation Zoning Acres
Consolidation
Potential
(A – W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
50 053-292-002 181 W ORANGE High-Medium Density Residential R3 0.16 12.1-25.0 19 3 Moderate Yes Y 51 053-412-048 713 S 2ND AVE High-Medium Density Residential R3 0.16 12.1-25.0 19 3 Moderate Yes Y 52 053-134-002 W STATE ST/NEW ST High-Medium Density Residential R3 0.15 12.1-25.0 19 2 Moderate Yes Y 54 053-262-019 692 W HOLT LN High-Medium Density Residential R3 0.1 12.1-25.0 19 1 Moderate Yes Y 55 053-213-019 W OLIVE AVE/NEW ST High-Medium Density Residential R3 0.08 12.1-25.0 19 1 Moderate Yes Y 58 044-402-011 1014 W ADAMS AVE Mixed Use 1 CT* 0.16 12.1-25.0 19 3 Moderate Yes Y 59 044-404-024 832 W ADAMS AVE Mixed Use 1 CT* 0.16 12.1-25.0 19 3 Moderate Yes Y 60 044-414-029 652 W ADAMS AVE Mixed Use 1 CT* 0.15 12.1-25.0 19 2 Moderate Yes Y 79 054-573-006 SMOKETREE DR/2ND ST Medium Density Residential R2 5.2 6.1-12.0 8 41 Moderate Yes Y 81 052-456-003 1703 S 21ST ST Medium Density Residential R2 0.27 K 6.1-12.0 8 2 Moderate Yes Y 81 052-456-001 1657 S 21ST ST Medium Density Residential R2 0.26 K 6.1-12.0 8 2 Moderate Yes Y 81 052-456-002 1699 S 21ST ST Medium Density Residential R2 0.27 K 6.1-12.0 8 2 Moderate Yes Y 82 052-453-047 S 2ND ST/PEPPER CT Medium Density Residential R2 0.25 L 6.1-12.0 8 2 Moderate Yes Y 82 052-453-049 S 2ND ST/PEPPER CT Medium Density Residential R2 0.25 L 6.1-12.0 8 2 Moderate Yes Y 82 052-453-048 S 2ND ST/AURORA CT Medium Density Residential R2 0.25 L 6.1-12.0 8 2 Moderate Yes Y 83 044-580-004 N 8TH ST/W PICO AVE Medium Density Residential R2 0.19 6.1-12.0 8 1 Moderate Yes Y 84 053-282-009 305 W HOLT AVE Medium Density Residential R2 0.19 6.1-12.0 8 1 Moderate Yes Y 85 053-216-009 111 W BRIGHTON AVE Medium Density Residential R2 0.19 6.1-12.0 8 1 Moderate Yes Y 86 044-362-021 1080 EUCLID AVE Medium Density Residential R2 0.18 6.1-12.0 8 1 Moderate Yes Y 88 053-401-011 304 W HAMILTON Medium Density Residential R2 0.16 6.1-12.0 8 1 Moderate Yes Y 91 044-401-019 W EUCLID AVE/N 12TH ST Medium Density Residential R2 0.14 6.1-12.0 8 1 Moderate Yes Y 92 053-394-021 452 W VINE Medium Density Residential R2 0.13 6.1-12.0 8 1 Moderate Yes Y 93 053-281-011 324 W HOLT AVE Medium Density Residential R2 0.1 I 6.1-12.0 8 1 Moderate Yes Y 146 No APN
(Property
being
annexed)
S DOGWOOD/E McCABE High-Medium Density Residential R3 11.27 12.1-25.0 19 227 Moderate Yes Y 1 064-470-103 N WATERMAN AVE/W

LINCOLN AVE
High-Medium Density Residential R3 6.41 12.1-25.0 19 121 Lower Yes Y 2 053-740-048 THOMAS DR/6TH ST High-Medium Density Residential R3 1.19 A 12.1-25.0 19 22 Lower Yes Y 2 053-740-049 THOMAS DR/6TH ST High-Medium Density Residential R3 1.72 A 12.1-25.0 19 32 Lower Yes Y 3 052-070-065 303 S LA BRUCHERIE RD High-Medium Density Residential R3 2.81 12.1-25.0 19 53 Lower Yes Y 4 064-560-002 436 W EUCLID AVE High-Medium Density Residential R3 1.61 B 12.1-25.0 19 30 Lower Yes Y 4 064-560-003 1630 EUCLID AVE High-Medium Density Residential R3 0.81 B 12.1-25.0 19 15 Lower Yes Y 7 052-061-041 1998 W BARBARA WORHTH High-Medium Density Residential R3 0.9 C 12.1-25.0 19 17 Lower Yes Y

5.d
Packet Pg. 195 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - City of El Centro
2021-2029 Housing Element Page C-3
Table C- 1: 2021-2029 Sites Inventory
Site
#
APN Address GP Designation Zoning Acres
Consolidation
Potential
(A – W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
7 052-061-079 W BARBARA WORTH DR/S LA

BROUCHERIE RD
High-Medium Density Residential R3 0.43 C 12.1-25.0 19 8 Lower Yes Y 8 053-552-002 4TH ST (CA 86)/DESERT

GARDENS DR
Neighborhood Commercial CN 1.12 12.1-25.0 19 21 Lower Yes Y 10 053-211-009 265 W OLIVE High-Medium Density Residential R3 0.52 D 12.1-25.0 19 9 Lower Yes Y 10 053-211-010 265 W OLIVE High-Medium Density Residential R3 0.53 D 12.1-25.0 19 10 Lower Yes Y 11 052-061-082 1761 ADAMS High-Medium Density Residential R3 0.68 12.1-25.0 19 12 Lower Yes Y 12 053-291-012 S 2ND ST/W HOLT ST High-Medium Density Residential R3 0.6 12.1-25.0 19 11 Lower Yes Y 14 053-740-041 2502 S 4TH ST Tourist Commercial CT 1.25 12.1-25.0 19 23 Lower Yes Y 16 053-740-042 2502 S 4TH ST Tourist Commercial CT 1.11 12.1-25.0 19 21 Lower Yes Y 18 053-740-043 2502 S 4TH ST Tourist Commercial CT 1.07 12.1-25.0 19 20 Lower Yes Y 100 053-740-040 2502 S 4TH ST Tourist Commercial CT 9.74 12.1-25.0 19 185 Lower Yes Y 17 053-810-004 2380 S 4TH Tourist Commercial CT 1.28 12.1-25.0 19 24 Lower Yes Y 19 053-810-010 W WAKE AVE/6TH ST Tourist Commercial CT 0.7 E 12.1-25.0 19 13 Lower Yes Y 19 053-810-011 W WAKE AVE/6TH ST Tourist Commercial CT 0.7 E 12.1-25.0 19 13 Lower Yes Y 19 053-810-012 W WAKE AVE/6TH ST Tourist Commercial CT 0.7 E 12.1-25.0 19 13 Lower Yes Y 21 054-571-014 DRIFTWOOD

DR/SMOKETREE DR
Tourist Commercial CT 1.08 12.1-25.0 19 20 Lower Yes Y
23 044-391-066 W EUCLID/EL CENTRO AVE Tourist Commercial CT 0.82 12.1-25.0 19 15 Lower Yes Y 24 054-573-005 SMOKETREE DR/S 3RD ST Tourist Commercial CT 0.77 12.1-25.0 19 14 Lower Yes Y 140 064-450-076 2204 2208 LA BRUCHERIE General Commercial/MU-2 Overlay
CG** 20.13 21-.0-30.0 21 210
10 acres
assumed to be
developed with
lower income=
210 units;

10.13 acres
assumed to be
developed with
commercial
Lower No Y
141 064-442-007 N WATERMAN

AVE/CRUICKSHANK
High-Medium Density Residential R3 3.64 12.1-25.0 19 69 Lower No Y

5.d
Packet Pg. 196 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - City of El Centro
2021-2029 Housing Element Page C-4
Table C- 1: 2021-2029 Sites Inventory
Site
#
APN Address GP Designation Zoning Acres
Consolidation
Potential
(A – W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
143 NO APN YET WAKE AVE/S CYPRESS DR High-Medium Density Residential R3 5.59 12.1-25.0 19 106 Lower Yes Y 151 054-530-009 IV Mall (1560 1558 DOGWOOD
BLVD)
General Commercial/MU-2
Overlay
CG** 1.49 21-.0-30.0 21 31 Lower No Y
152 054-530-050 IV Mall General Commercial/MU-2
Overlay
CG** 3.47 21-.0-30.0 21 72 Lower No Y
153 054-530-007 IV Mall (1560 1558 DOGWOOD
BLVD)
General Commercial/MU-2
Overlay
CG** 2.69 21-.0-30.0 21 56 Lower No Y
154 054-530-049 IV Mall General Commercial/MU-2
Overlay
CG** 2.25 21-.0-30.0 21 47 Lower No Y
155 054-430-041 The Commons Property General Commercial/MU-2 Overlay
CG** 6.42 21-.0-30.0 21 134 Lower No Y
156 054-430-069 The Commons Property General Commercial/MU-2 Overlay
CG** 5.17 21-.0-30.0 21 108 Lower No Y
157 054-430-069 The Commons Property General Commercial/MU-2 Overlay
CG** 5.17 21-.0-30.0 21 108 Lower No Y
158 054-430-069 The Commons Property General Commercial/MU-2 Overlay
CG** 5.17 21-.0-30.0 21 108 Lower No Y
161 052-070-108 SEC La Brucherie and Main High-Medium Density Residential R3 5.51 12.1-25.0 21 112 Lower No Y 78 054-530-056 S/E portion of Imperial Valley
Mall
Medium Density Residential R2 21.18 1.0-6.0 8 169 Above Moderate
Income
No Y
95 052-270-026 AUSTIN RD, N OF VINE CT Low Density Residential R1 19.46 L 1.0-6.0 3.5 68 Above Moderate
Income
Yes Tier I
95 052-270-029 W. ORANGE AVE/SANTA

ROSA RD
Low Density Residential R1 7.77 L 1.0-6.0 3.5 27 Above
Moderate
Income
Yes Tier I
95 052-270-002 W ORANGE AVE E OF SANTA

ROSA RD
Low Density Residential R1 27.06 L 1.0-6.0 3.5 86 Above Moderate
Income
Yes Tier I
96 064-450-014 N LA

BROOUCHERIE/BRADSHAW
RD
Low Density Residential R1 55.73 1.0-6.0 3.5 195 Above
Moderate
Income
Yes Tier I
98 044-440-001 N 8TH ST BETWEEN

BRADSHAW AVE & W EL

DORADO AVE
Low Density Residential R3 14.23 1.0-6.0 3.5 49 Above
Moderate
Income
Yes Y

5.d
Packet Pg. 197 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - City of El Centro
2021-2029 Housing Element Page C-5
Table C-1: 2021-2029 Sites Inventory
Site #
APN Address GP Designation Zoning Acres
Consoli-
dation
Potential
(A –W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
99 052-793-011 W ORANGE AVE/SOLANO
AVE
Low Density Residential R1 3.06 1.0-6.0 3.5 10 Above
Moderate
Income
YesY
102 044-254-024 1001 W EL DORADO PL Low Density Residential R1 1.5N 1.0-6.0 3.55 Above Moderate
Income
YesY
102 044-254-026 1003 W EL DORADO DR Low Density Residential R1 2.83N 1.0-6.0 3.59 Above Moderate
Income
YesY
102 044-254-031 877 W EL DORADO AVE Low Density Residential R1 0.6N1.0-6.0 3.52 Above Moderate
Income
YesY
103 052-776-002 W MAIN ST/LOTUS AVE Low Density Residential R1 4.61 1.0-6.0 3.5 16 Above Moderate
Income
YesY
104 052-794-035 223RD BETWEEN MOIOLA AVE
& W BRIGHTON AVE
Low Density Residential R1 0.17O 1.0-6.0 3.51 Above
Moderate
Income
YesY
104 052-794-034 MOIOLA AVE E OF 23RD ST Low Density Residential R1 0.15O 1.0-6.0 3.51 Above Moderate
Income
YesY
104 052-794-033 MOIOLA AVE E OF 23RD ST Low Density Residential R1 0.16O 1.0-6.0 3.51 Above Moderate
Income
YesY
104 052-794-027 MOIOLA AVE E OF 23RD ST Low Density Residential R1 0.17O 1.0-6.0 3.51 Above Moderate
Income
YesY
104 052-794-023 W BRIGHTON AVE E OF 23RD
ST
Low Density Residential R1 0.15O 1.0-6.0 3.51 Above
Moderate
Income
YesY
104 052-794-024 W BRIGHTON AVE E OF 23RD
ST
Low Density Residential R1 0.14O 1.0-6.0 3.51 Above
Moderate
Income
YesY
104 052-794-026 W BRIGHTON AVE E OF 23RD
ST
Low Density Residential R1 0.16O 1.0-6.0 3.51 Above
Moderate
Income
YesY
104 052-794-012 W ORANGE AVE/23RD ST Low Density Residential R1 0.16O 1.0-6.0 3.51 Above Moderate
Income
YesY

5.d
Packet Pg. 198 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - City of El Centro
2021-2029 Housing Element Page C-6
Table C-1: 2021-2029 Sites Inventory
Site #
APN Address GP Designation Zoning Acres
Consoli-
dation
Potential
(A –W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
104 052-794-032 MOIOLA AVE E OF 23RD ST Low Density Residential R1 0.25O 1.0-6.0 3.51 Above Moderate
Income
YesY
105 052-270-028 646 S GLENWOOD DR Low Density Residential R1 0.93P 1.0-6.0 3.53 Above Moderate
Income
YesY
105 052-270-035 1852 A AUSTIN DR Low Density Residential R1 1.16P 1.0-6.0 3.54 Above Moderate
Income
YesY
105 052-270-034 1852 A AUSTIN DR Low Density Residential R1 1.17P1.0-6.0 3.54 Above Moderate
Income
YesY
107 044-252-027 1475 W EL DORADO DR Low Density Residential R1 0.48Q 1.0-6.0 3.51 Above Moderate
Income
YesY
107 044-252-009 1651 N IMPERIAL DR Low Density Residential R1 0.13Q 1.0-6.0 3.51 Above Moderate Income
YesY
107 044-252-008 1427 W EL DORADO Low Density Residential R1 0.81Q 1.0-6.0 3.52 Above Moderate
Income
YesY
107 044-252-007 1451 W EL DORADO Low Density Residential R1 0.67Q 1.0-6.0 3.52 Above Moderate
Income
YesY
107 044-252-028 1675 N IMPERIAL Low Density Residential R1 0.19Q 1.0-6.0 3.51 Above Moderate
Income
YesY
108 044-251-016 1902 N 12TH Low Density Residential R1 1.03R 1.0-6.0 3.53 Above Moderate
Income
YesY
108 044-251-017 1898 N 12TH Low Density Residential R1 1.03R 1.0-6.0 3.53 Above Moderate
Income
YesY
109 044-252-018 1602 N 12TH DR Low Density Residential R1 1.44 1.0-6.0 3.55 Above Moderate
Income
YesY
111 053-807-007 W OF JACARANDA DR &

DANENBERG DR
Low Density Residential R1 1.3 1.0-6.0 3.54 Above
Moderate
Income
YesY

5.d
Packet Pg. 199 Attachment: Exhibit D - El Centro HE 2021-2029_Jan24 (5387 : 2021-2029 Housing Element Update - City of El Centro
2021-2029 Housing Element Page C-7
Table C-1: 2021-2029 Sites Inventory
Site #
APN Address GP Designation Zoning Acres
Consoli-
dation
Potential
(A –W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
112 044-252-020 W EL DORADO AVE W OF N
12TH ST
Low Density Residential R1 0.14 1.0-6.0 3.51 Above
Moderate
Income
YesY
113 053-752-080 E HOLT AVE BETWEEN S

HOPE ST & DOGWOOD RD
Low Density Residential R1 0.16S 1.0-6.0 3.51 Above
Moderate
Income
YesY
113 053-752-079 E HOLT AVE BETWEEN S

HOPE ST & DOGWOOD RD
Low Density Residential R1 0.16S 1.0-6.0 3.51 Above
Moderate
Income
YesY
113 053-752-078 E HOLT AVE BETWEEN S

HOPE ST & DOGWOOD RD
Low Density Residential R1 0.16S 1.0-6.0 3.51 Above
Moderate
Income
YesY
113 053-752-077 E HEIL AVE BETWEEN S

HOPE ST & S DOGWOOD RD
Low Density Residential R1 0.16S 1.0-6.0 3.51 Above
Moderate
Income
YesY
113 053-752-076 E HEIL AVE BETWEEN S

HOPE ST & S DOGWOOD RD
Low Density Residential R1 0.16S 1.0-6.0 3.51 Above
Moderate
Income
YesY
113 053-752-075 E HEIL AVE BETWEEN S

HOPE ST & S DOGWOOD RD
Low Density Residential R1 0.16S 1.0-6.0 3.51 Above
Moderate
Income
YesY
115 052-044-018 467 S HASKELL DR Low Density Residential R1 0.34T 1.0-6.0 3.51 Above Moderate
Income
YesY
115 052-044-016 HASKELL ST Low Density Residential R1 0.4T 1.0-6.0 3.51 Above Moderate
Income
YesY
116 053-761-017 E HEIL AVE BETWEEN S

HOPE ST & S DOGWOOD RD
Low Density Residential R1 0.05 1.0-6.0 3.50 Above
Moderate
Income
YesY
117 052-791-008 195 S 23RD ST Low Density Residential R1 0.19U 1.0-6.0 3.51 Above Moderate
Income
YesY
117 052-791-016 23RD ST BETWEEN W STATE

ST & W OLIVE AVE
Low Density Residential R1 0.17U 1.0-6.0 3.51 Above
Moderate
Income
YesY
117 052-791-017 23RD ST BETWEEN W STATE

ST & W OLIVE AVE
Low Density Residential R1 0.17U 1.0-6.0 3.51 Above
Moderate
Income
YesY

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Table C-1: 2021-2029 Sites Inventory
Site #
APN Address GP Designation Zoning Acres
Consoli-
dation
Potential
(A –W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
119 052-732-006 1230 GLENWOOD DR Low Density Residential R1 0.22 1.0-6.0 3.51 Above Moderate
Income
YesY
120 052-452-032 2451 W ROSS AVE Low Density Residential R1 0.4 1.0-6.0 3.51 Above Moderate
Income
YesY
122 044-272-014 798 W PICO DR Low Density Residential R1 0.33 1.0-6.0 3.51 Above Moderate
Income
YesY
123 053-231-011 396 E BRIGHTON AVE Low Density Residential R1 0.16V 1.0-6.0 3.51 Above Moderate
Income
YesY
123 053-231-010 398 E BRIGHTON Low Density Residential R1 0.16V 1.0-6.0 3.51 Above Moderate
Income
YesY
124 044-280-009 N 6TH ST BETWEEN SANDY

AVE & VILLA AVE
Low Density Residential R1 0.29 1.0-6.0 3.51 Above
Moderate
Income
YesY
125 053-761-022 E HAMILTON AVE BETWEEN

S DOGWOOD RD & S HOPE
ST
Low Density Residential R1 0.29 1.0-6.0 3.51 Above
Moderate
Income
YesY
126 044-261-015 1402 N 12TH ST Low Density Residential R1 0.25 1.0-6.0 3.51 Above Moderate
Income
YesY
127 053-752-061 E HEIL AVE BETWEEN S

DOGWOOD RD & S HOPE ST
Low Density Residential R1 0.21 1.0-6.0 3.51 Above
Moderate
Income
Yes
128 044-273-004 603 W LINCOLN AVE Low Density Residential R1 0.19 1.0-6.0 3.51 Above Moderate
Income
YesY
129 053-143-012 E OLIVE AVE/S HOPE AVE Low Density Residential R1 0.17 1.0-6.0 3.51 Above Moderate
Income
YesY
130 053-233-028 395 MC CULLOM WAY Low Density Residential R1 0.16 1.0-6.0 3.51 Above Moderate
Income
YesY
131 053-231-014 E BRIGHTON AVE BETWEEN
S HOPE ST & McCULLOM ST.

Low Density Residential R1 0.16 1.0-6.0 3.51 Above
Moderate
Income
YesY

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Table C- 1: 2021-2029 Sites Inventory
Site
#
APN Address GP Designation Zoning Acres
Consolidation
Potential
(A – W)
Density
Range
(du/ac)
Density
Factor Unit Potential Income Level
5 th
Cycle
Infras
truct
ure
132 053-143-007 253 E STATE AVE Low Density Residential R1 0.16 1.0-6.0 3.5 1 Above Moderate
Income
Yes Y
133 053-143-005 E STATE ST BETWEEN S

FAIRFIELD DR & S HOPE ST
Low Density Residential R1 0.16 1.0-6.0 3.5 1 Above
Moderate
Income
Yes Y
134 053-223-023 208 E BRIGHTON AVE Low Density Residential R1 0.16 1.0-6.0 3.5 1 Above Moderate
Income
Yes Y
135 053-152-022 E STATE ST BETWEEN S
HOPE ST & McCULLOM ST
Low Density Residential R1 0.16 1.0-6.0 3.5 1 Above
Moderate
Income
Yes Y
136 053-423-003 221 E HEIL AVE Low Density Residential R1 0.16 1.0-6.0 3.5 1 Above Moderate
Income
Yes Y
137 054-360-008 241 W DANENBERG DR Medium Density Residential R2 10.62 W 1.0-6.0 8 84 Above Moderate
Income
Yes Y
137 054-360-007 299 W DANENBERG DR Medium Density Residential R2 15.37 W 1.0-6.0 8 122 Above Moderate
Income
Yes Tier I
137 054-360-038 W DANENBERG DR W OF

FARNSWORTH LN
Medium Density Residential R2 7.84 W 1.0-6.0 8 62 Above Moderate
Income
Yes Tier I
138 054-360-067 3056 BELL LN Low Density Residential R1 0.5 1.0-6.0 3.5 1 Above Moderate
Income
Yes Tier I
159 052-280-008 AUSTIN RD/ROSS AVE Low Density Residential R1 153.98 1.0-6.0 3.5 485 Above Moderate
Income
No Tier I
160 052-042-023 W MAIN ST BETWEEN SANTA

ROSA RD & SUNSET RD
Low Density Residential R1 9.9 1.0-6.0 3.5 34 Above
Moderate
Income
No Tier I
163 052-791-012 23RD ST/W OLIVE RD Low Density Residential R1 0.25 1.0-6.0 3.5 1 Above Moderate
Income
No Y
164 052-791-014 23RD ST BETWEEN W OLIVE

RD & MOIOLA AVE
Low Density Residential R1 0.22 1.0-6.0 3.5 1 Above
Moderate
Income
No Y

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*Requires a new zone to implement the new MU-1 land use designation as approved in the Land Use Element (updated June 2021) ** Requires a new zone to implement the new MU-2 Overlay land use designation as approved in the Land Use Element (updated June 2021)

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Figure C-1: Sites Inventory Quadrant Key

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Figure C-2: Sites Inventory - Quadrant One

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Figure C-3: Sites Inventory - Quadrant Two

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Figure C-4: Sites Inventory - Quadrant Three

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Figure C-5: Sites Inventory - Quadrant Four

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9. Appendix D: Affirmatively Furthering Fair
Housing
D.1 Introduction and Overview of AB 686
AB 686 passed in 2017 requires the inclusion in the Housing Element an analysis of barriers that restrict access to opportunity and a commitment to specific meaningful actions to affirmatively further fair housing. The Bill added an assessment of fair housing to the Housing Element which includes the following components: a summary of fair housing issues and assessment of the City’s fair housing enforcement and outreach capacity; an analysis of segregation patterns and disparities in access to opportunities, an assessment of contributing factors, and an identification of fair housing goals and actions.

The City’s Economic Development Division prepared the 2019-2024 Analysis of Impediments to Fair Housing Choice and Fair Housing Action Plan (2019 AI) with valuable input from the Community Development Department, Inland Fair Housing and Mediation Board, Imperial County Association of Realtors, Access to Independent, Imperial Valley Transit, Imperial Valley Housing Authority, and the community. As appropriate, data and discussions from the 2019 AI are incorporated here. Imperial County does not prepare Analysis of Impediments to Fair Housing Choice. Regional data for this analysis uses HCD’s 2020 AI for regional comparisons.

D.2 Assessment of Fair Housing Issues
A. Fair Housing Enforcement and Outreach
Housing discrimination complaints can be filed directly with HUD. In California the housing discrimination complaints are processed by HUD’s San Francisco Office of Fair Housing and Equal Opportunity (FHEO). El Centro’s residents may also file complaints with the State Department of Fair Employment and Housing (DFEH), and local fair housing providers such as the Inland Fair Housing and Mediation Board.

As outlined in El Centro’s 2019 AI, the City has committed to complying with applicable federal and state fair housing laws including, but not limited to, the Fair Housing Act of 1968, the Fair Housing Amendments Act of 1988, and the Fair Housing Employment and Housing Act (FEHA).

The City currently contracts with the Inland Fair Housing and Mediation Board (IFHMB) to provide fair housing services and landlord/tenant counseling to City residents. Typically, fair housing services include the investigation and resolution of housing discrimination complaints, discrimination auditing/testing, and education and outreach including the dissemination of fair housing information such as written material, workshops, and seminars. Landlord/tenant counseling services involves informing landlords and tenants of their rights and responsibilities under the California Civil Code and mediating conflicts between tenants and landlords.

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The City monitors and attempts to minimize discriminatory housing practices with the assistance of the IFHMB that is annually funded by the City’s CDBG. The City advertises the availability of fair housing services by posting IFHMB posters and provides IFHMB informational flyers at public counters at City Hall and the Community Services Department offices. The City’s website also provides a link to IFHMB resources. Furthermore, the City accommodates IFHMB meetings and workshops at Council Chambers and distributes information at tabling events and includes articles about fair housing in a bi-annual newsletter and period newspaper advertisements published in English and Spanish.

Fair Housing Enforcement
Regional Trends
HUD’s Office of Fair Housing and Equal Opportunity (FHEO) works to eliminate housing discrimination, promote economic opportunity, and achieve diverse, inclusive communities.

FHEO investigates fair housing complaints, conducts compliance reviews, ensures civil rights in HUD programs, and manages fair housing grants. According to HCD’s 2020 Analysis of Impediments to Fair Housing, 4,198 fair housing complaints were filed in California between January 1, 2015 and November 14, 2019, with the number of complaints decreasing from 1,158 in 2015 to 327 in 2019. Based on a Community Needs Assessment Survey and stakeholder consultations conducted as part the of 2020 AI, HCD concluded that people are choosing not to report complaints due to a limited understanding of fair housing protections and a lack of resources to support fair housing claims at the local level.

The California Department of Fair Employment and Housing (DFEH), in partnership with HCD, is also responsible for enforcing California’s state fair housing laws. The department handles fair housing complaints, provides resources to the community, and cooperates with HUD if the matter falls into HUD’s jurisdiction. According to the DFEH Annual Reports, 12 housing complaints were filed by complainants in Imperial County between 2013 and 2019. The Annual Reports did not include details for the basis for discrimination of these complaints. However, HCD’s 2020 AI reported that statewide, between 2015 and 2019, the primary basis of fair housing complaints filed with DFEH was disability (51 percent), followed by race, color, or ancestry, 16 percent, and familial status, 10 percent.

Local Trends
Housing discrimination complaint data was compiled by the Inland Fair Housing and Mediation Board (IFHMB) for the period from 2015 through 2018. During this four-year period, 32 housing discrimination complaint cases were filed with the IFHMB. The 32 cases were filed on the following basis: disability (19), familial status (4), national origin (3), race (3), arbitrary (2), religion (1).

The San Francisco Regional Office of HUD provided the City with housing discrimination complaint data for calendar years 2000 through 2012 and no complaints from 2013 to 2018. During the 13-year period, 10 cases were filed with HUD. The bases were as follows: disability (6), national origin (4), familial status (3), sex (3), retaliation (1). The number of bases (17) exceeds the number of cases (10) because a case can have more than one basis. Both the IFHMB and HUD

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data indicate that the most frequent bases for a housing discrimination complaint include disability, familial status, and national origin. El Centro’s 2019 AI demonstrates that the City is in compliance with fair housing requirements. The City has a program to process housing discrimination complaints; has not been subject to a HUD-initiated complaint; has not been subject to a compliance review; and has not been subject to a fair housing lawsuit.

Fair Housing Testing
Initiated by the Department of Justice’s Civil Rights Division in 1991, fair housing testing involves the use of an individual or individuals who pose as prospective renters for the purpose of determining whether a landlord is complying with local, state, and federal fair housing laws.

Regional Trends
HCD’s 2020 AI did not include any data related to for housing testing at a statewide or regional level. However, it did find Limited community awareness of fair housing protections and enforcement resource (impediment #4). Comments to the 2020 AI suggested that the AI should include concrete actions to increase fair housing testing such as developing and funding a fair housing testing program at DFEH similar to the United States Department of Justice’s fair housing testing program. A testing program at DFEH is likely to be similarly effective in identifying and counteracting housing discrimination in California. The state could also consider providing direct funding for fair housing organizations to conduct testing. The 2020 AI recommends supporting the increase of fair housing testing to identify housing discrimination.

Local Trends
El Centro did not report any results from Fair Housing testing. According to the 2019 AI, Inland Fair Housing and Mediation Board's (IFHMB) scope of services does not include fair housing testing. As such, it does not appear that the City actively and routinely conducts fair housing testing. As found in HCD’s 2020 AI, a fair housing testing program and funding is necessary.

Fair Housing Education and Outreach
Regional Trends
The 2021-2021 Imperial County Housing Element contained a review of the County’s housing outreach program (Program 4.1.1) for the 5th Cycle that “encourage[d] the development and implementation of housing outreach and education programs to inform the public of available housing opportunities, as well as various assistance programs available to eligible households, by continuing to provide information about the County’s housing programs by posting flyers on community boards and at gas stations, schools, and other public places.” The review of the program reported that while the County discusses strategies to encourage housing outreach and education programs at all Board of Supervisor meetings, there has been no interest in such a program. The County’s 2021-2029 Element includes a new Fair Housing Outreach Program which commits the County to:
• Develop bilingual outreach materials to inform the public of available housing opportunities, as well as various assistance programs available to eligible households, to

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be posted on the County’s website and community boards and at gas stations, schools, and other public places and;
• Coordinate with local fair housing providers to conduct a public workshop on tenant and landlord rights and responsibilities.

Local Trends
The City contracts with Inland Fair Housing and Mediation Board's (IFHMB) to provide residents with fair housing services. IFHMB scope of services provides the City with a comprehensive program committed to Fair Housing Education, Outreach, and Enforcement.

Community awareness of IFHMB services have been through monthly community outreach, community events and social media. IFHMB attends a monthly Imperial Valley Continuum of Care Council Meetings. The monthly meetings are to engage individuals and organizations of the Imperial Valley in a community-based process that works to eradicate homelessness in the region.

The monthly collaborative meeting is attended by many City of El Centro community organizations and provides a great opportunity to collaborate with other community organizations.

IFHMB also accomplished the following:
• Monthly outreach throughout the City to inform El Centro residents of programs and services the agency provides.
• Attend community events/meetings – e.g., Point in Time Count • Transitional Fair – Resource Fair
• Radio ads – Fair Housing Month
• Social media – Facebook, Twitter, Eventbrite, Google AdWords, Mailchimp • Agency Workshops (flyers) – are promoted using various social media platforms such as (Facebook, Twitter, Eventbrite, and Mailchimp), IFHMB website, City of Centro City Hall community board
• Average annual agency programs and services outreach distributed 10,000 • First Time Homebuyer workshop conducted in El Centro – 19 workshops • Fair Housing Workshops – 13 workshops (FY-14-18)
• Attendees received information on California landlord-tenant laws, and state and federal fair housing laws, including information about the protected classes under the Fair Housing Act, with an emphasis on the reasonable accommodation and reasonable modification process for persons with disabilities
Fair housing outreach capacity relates to the ability of a locality and fair housing entities to disseminate information related to fair housing and provide outreach and education to assure community members are aware of fair housing laws and rights. Despite extensive outreach activities, these efforts have limited effectiveness.

As part of the 2019 AI, the City posted a Resident Fair Housing Survey in the English and Spanish languages on its website for a 4-month period. However, there were no responses to the online survey. A short survey related to Fair Housing was also conducted during the May 19, 2021 Community Fair Housing Workshop. The survey had five respondents, only one of which was

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aware of the City’s fair housing services. The respondents also selected social media as the best medium to receive information about Fair Housing services. In addition, the respondents said that the following would improve access to services:
• Information about the services,
• More services,
• Services in Spanish,
• Evening services, and
• Transportation to services
The City already uses social media to post information about Fair Housing services. Due to COVID-19, the City relied primarily on zoom webinars to discuss the Housing Element with the public. These meetings were all held in the evenings during the week. City chambers were open to the public to attend in person for the meetings. Interpreter services were available at all three community workshops. As described in Appendix A, municipal, regional, and state agencies, including school districts and utilities, housing developers, and housing services providers were directly notified of the meetings.

The 2019-2024 AI for the City also reported that a survey of on-site property managers revealed that impediments to fair housing choice because of ill-informed property management practices.

Therefore, subject to funding availability, the City would implement the following actions:
• Invite the apartment managers to one or more workshops; the topics could include: Fair housing laws in general, fair housing laws regarding occupancy limits, fair housing laws regarding reasonable accommodations and modifications, sample written policies regarding service and companion animals;
• Distribute information on the above and other topics and distribute it to the apartment managers of all small, medium and large apartment complexes.

The 2019-2024 AI also listed the following activities actions to affirmatively further fair housing to improve outreach and education of fair housing laws and resources:
• The City will request in FY 2019/2021 that the Imperial County Association of REALTORS:
o Revise the Resources tab on its web site to:
o Add a Fair Housing Information button (e.g., include information on steering, link to the Inland Fair Housing and Mediation Board, etc.)
o Add information to the current Insurance button such as the value of a C.L.U.E.

Report (Comprehensive Loss Underwriting Exchange) when purchasing a home • During the five-year period from FY 2019-2020 through FY 2023-2024, the City’s fair housing provider – Inland Fair Housing & Mediation Board – will:
o Offer as part of its home buyer counseling services examples of how to detect “steering” during the home search process and how to detect “loan steering.” o Provide information to renters attending workshops on how to detect steering behavior by resident property managers.
o Continue to include “steering” as a category of alleged housing discriminatory acts.

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o Continue to provide information on homeowners insurance and C.L.U.E. Report (Comprehensive Loss Underwriting Exchange) during homebuyer counseling service
o If funding allows, annually review ads published in newspapers, on-line apartment search sites, and craigslist. Ads with discriminatory words or phrases should be investigated in more detail with follow-up enforcement actions, if necessary
o Offer a 3-hour Fair Housing course for brokers and sales persons. Every four years, when renewing their license, all brokers and sales persons are required to complete a course on fair housing. Currently, most renewals are accomplished through online courses.
• Encourage the Imperial Valley Press to publish a concise “no pets” notice that indicates rental housing owners must provide reasonable accommodations for “service animals” and “companion animals” for disabled persons.

B. Integration and Segregation
Race/Ethnicity
Ethnic and racial composition of a region is useful in analyzing housing demand and any related fair housing concerns, as it tends to demonstrate a relationship with other characteristics such as household size, locational preferences and mobility.

To measure segregation in a given jurisdiction, the US Department of Housing and Urban Development (HUD) provides racial or ethnic dissimilarity trends. Dissimilarity indices can be used to are used to measure how evenly two groups are distributed throughout a jurisdiction.

The following shows how HUD views various levels of the index:
• <40: Low Segregation
• 40-54: Moderate Segregation
• >55: High Segregation
Regional Trends
Imperial County is unique in southern California and the state in that its Hispanic population is significantly higher (more than twice) the proportion observed stated wide (39 percent) and in the Los Angeles and San Diego Counties (46 percent and 34 percent, respectively, Table D- 1). In Imperial County, 84 percent of the population identifies as Hispanic or Latino. Most cities within the county have similar share of Hispanic population, ranging from 75 percent in Calipatria to 98 percent in Calexico. Because Hispanic population is predominant in Imperial County, the share of White population is also significantly lower than statewide and in other Southern California counties. Only 10 percent of the population is White, with all other races having shares of less than two percent of the entire population.

Between 2000 and 2017, Imperial County’s Hispanic population increased by almost 51,241 persons and its share of the total population increased from 72 percent in 2000 to 84 in 2017.

During the 18-year period, the Asian, Black, and White populations decreased in both absolute

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and relative terms. That means that Hispanics accounted for all the population increase in Imperial County between 2000 and 2017.

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Table D- 1: Race/Ethnicity Composition-Regional Comparison California Los Angeles County San Diego County Imperial County El Centro Brawley CalexicoCalipatriaHoltvilleImperial Westmorland
White 37.2% 26.2% 45.6% 10.6% 8.3% 12.2% 1.0% 5.8% 16.8% 17.1% 10.8% Black or
African Am 5.5% 7.8% 4.7% 2.1% 1.4% 1.2% 0.2% 15.0% 0.7% 1.7% 2.5% Am. Ind/
Alaska Native 0.4% 0.2% 0.4% 0.6% 0.1% 0.3% 0.1% 0.6% 0.0% 0.3% 1.4% Asian 14.3% 14.4% 11.6% 1.3% 2.2% 0.4% 0.9% 0.7% 0.0% 2.3% 0.4% Native
Hawaiian/Paci
fic Islander

0.4% 0.2% 0.4% 0.1% 0.2% 0.3% 0.0% 0.6% 0.0% 0.0% 0.0%
Other Races 3.3% 2.6% 3.6% 0.9% 0.8% 1.8% 0.1% 1.6% 0.4% 0.6% 2.2% Hispanic or
Latino 39.0% 48.5% 33.7% 84.2% 87.0% 83.7% 97.8% 75.7% 82.1% 78.0% 82.6% Source: ACS 2013-2019 5-year estimates
As explained above, dissimilarity indices are measures of segregation, with higher indices meaning higher degree of segregation. In Imperial County, all minority (non-white) residents combined are considered moderately segregated from White residents (index is 41.76 in 2020).

However, the dissimilarity index between Black and White residents is considered a high degree of segregation (61.18). All dissimilarity indices have decreased in the past 30 years in the County, except for Blacks/Whites, for which the dissimilarity index increased by close to 20 points, indicating increasing segregation among residents of non-White races from Whites. Given that the population of all races decreased between 2000 and 2017, the increase in the dissimilarity index for Blacks/Whites indicates blacks are disproportionately segregated.

Table D- 2: Dissimilarity Indices for Imperial County (1990-2020) 1990 Trend 2000 Trend 2010 Trend Current
Non-White/White 43.79 40.2 38.4 41.76
Black/White 43.49 55.26 54.97 61.18
Hispanic/White 45.39 43.45 40.91 44.3
Asian or Pacific Islander/White 38.26 40.53 28.4 36.98
Sources: HUD Dissimilarity Index, 2020.

Figure D-1 below shows the concentration of minority population in the County is widespread across Imperial County. Figure D-2 shows census tracts in Imperial by the racial or ethnic groups that make up the majority of the population. The categories show the percentage population gap between the majority racial/ethnic group and the next largest racial/ethnic group. The more intense the color, the higher the percentage gap between the predominant racial/ethnic group

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and the next largest racial/ethnic group. As expected based on the high percentage of Hispanic population (Table D- 1), all Imperial County cities have a high concentration of Hispanic majority census tracts. Overall, Hispanic population predominates the County.

Figure D-1: Minority Concentration by Block Group - Imperial County

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Figure D-2: Racial and Ethnic Majorities by Census Tract - Imperial County

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Local Trends
Like the County, El Centro’s population is mostly Hispanic (87 percent, Table D- 1). As shown in Table D-3, White population has decreased by almost eight percent between 2010 and 2019, while the Hispanic/Latino has grown by a nine percent. The percentage of black population also decreased by two percent in the past decade while most other races did not change in their share of the population.

From 1990 to 2020, while the White and non-White communities in Imperial County have been considered moderately segregated, the White/non-While community in El Centro has scored as low levels of segregation (less than 40). Like the County, segregation between Blacks and Whites is the highest, though the level of segregation in El Centro is considered moderate and has decreased in the past 30 years (compared to the high levels in the County and the increasing trend). The level of segregation between Asian/Pacific Islander residents and White has increased by 20 points during the 30-year period.

Figure D-3 shows that the Hispanic majority population is widespread throughout the entire City.

Only once census tracts in the west of the City (bounded by Interstate Highway 8 and Main Street) has a slightly lower concentration of Hispanic population.

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Figure D-4 shows that minority concentrations make up more than 81 percent of most census tracts in the City.

Table D-3: Race/Ethnicity Composition Changes (2010-2019) 2010 2019 % change
White alone 16.2% 8.3% -7.9%
Black or African American alone 3.1% 1.4% -1.7%
American Indian and Alaska Native alone 0.1% 0.1% 0.0%
Asian alone 2.1% 2.2% 0.1%
Native Hawaiian and Other Pacific Islander alone 0.1% 0.2% 0.0% Other 0.7% 0.8% 0.1%
Hispanic or Latino: 77.7% 87.0% 9.3%
Total Population 41,581 44,003 5.8%
Source: ACS 2010-2014, 2013-2019 5-year estimates
Table D-4: Dissimilarity Indices City of El Centro (1990-2020) 1990 Trend 2000 Trend 2010 Trend Current
Non-White/White 29.84 30.82 25.42 29.66
Black/White 54.99 46.83 32.96 44.63
Hispanic/White 30.04 31.79 26.12 30.21
Asian or Pacific Islander/White 19.67 17.94 19.43 31.38 Sources: HUD Dissimilarity Indices, 2020.

Figure D-3: Racial and Ethnic Majorities by Census Tract- City of El Centro

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Figure D-4: RHNA Unit Distribution by Minority Concentration - City of El Centro

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Distribution of RHNA Units by Percent Minority Concentration As part of the AFFH analysis, the City must show sites identified in the inventory were selected a manner that is consistent with its duty to affirmatively further fair housing (AFFH). This involves an analysis of whether the identified sites serve the purpose of replacing segregated living patterns with integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity.

As shown in

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Figure D-4, the minority population in most census block groups of the City is over 81 percent.

A few block groups along the City’s western boundaries north of Interstate Highway 8 have a lower minority concentration. About 20 percent of all RHNA sites were located in these areas, comprising 49 percent of the City’s above moderate RHNA units and three percent of moderate units. Since most the City’s census block groups have a minority concentration over 81 percent, the majority of RHNA units are in census block groups with these concentrations of minorities (Table D-5). Approximately 80 percent of all RHNA units are located in these census tracts, with 100 percent of lower income units, 97 percent of moderate income units, and 51 percent of above moderate income units in block groups with over 81 percent racial/ethnic minorities.

Table D-5: RHNA Unit Distribution by % Minority Concentration Lower Income
RHNA
Moderate Income
RHNA
Above Moderate
Income RHNA Total RHNA Units
21 - 40% 0.0% 0.0% 0.0% 0.0%
41 - 60% 0.0% 0.0% 0.0% 0.0%
61 - 80% 0.0% 2.7% 49.3% 19.6%
> 81% 100.0% 97.3% 50.7% 80.4%
Total 1,903 437 1,498 3,838
Persons with Disabilities
Persons with disabilities have special housing needs because of their fixed income, the lack of accessible and affordable housing, and the higher health costs associated with their disability.

Regional Trends
Imperial County has a higher share of population with disabilities (14.4 percent) compared to the state (10.6 percent) and the nearby Los Angeles and San Diego counties (10 percent). According to the 2015-2019 ACS, jurisdictions in the County have proportions of population with disability ranging from 7.8 percent in Imperial to 17 percent in Brawley.

Figure D-5 shows the population with disabilities census tracts in Calipatria (where over 40 percent of the population has a disability) followed by one census tract in Brawley and El Centro each (where between 20 and 30 percent of the population has a disability). For most census tracts in the region, about 10 to 20 percent of the population has a disability. Only a few census tracts in the region, in Imperial and surrounding El Centro, have a population with disability less than 10 percent.

Figure D-5: Population with Disabilities- Region

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Local Trends
El Centro the third highest proportion of population with a disability (16.2 percent) in the County after Brawley (17.4 percent) and Holtville (16.2 percent). The City also has a has a higher

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population of persons with disabilities than the County (14.4 percent. Within the City, the population with disabilities is concentrated in the census tract in the center of the City, bounded by W Main Street to the north, W Ross Avenue to the south, S Imperial Avenue to the west, and 4th Street to the east. In this census tract, between 20 and 30 percent of the population has a disability.

Distribution of RHNA by % Population with Disabilities
Most census tracts in the City have a population between 10 and 20 percent of persons with disabilities. Since this concentrated of persons with disabilities is most common, most RHNA units (72 percent) are in tracts where the population of persons with disabilities is between 10 and

20. About 28 percent of all RHNA units are located in tracts with a population of less than 10 persons with disabilities. Lower income RHNA units also have a similar distribution as all RHNA units, with 65 percent of lower income units are located in census tracts with a population with a disability between 10 and 20 percent and a 35 percent in tracts with the lower concentration of persons with disabilities. Less than one percent of units (11 units) are located in the tract with the highest concentration of persons with disabilities. These units are moderate income.

Table D-6 RHNA Unit Distribution by % Population with Disabilities Lower Income
RHNA
Moderate Income
RHNA
Above Moderate
Income RHNA Total RHNA Units
< 10% 34.9% 51.9% 11.3% 27.6%
10% - 20% 65.1% 45.5% 88.7% 72.1%
20% - 30% 0.0% 2.5% 0.0% 0.3%
Total Units 1,903 437 1,498 3,838

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Figure D-6: RHNA Unit Distribution by Concentration of Persons with Disability

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Familial Status
Familial status refers to the presence of children under the age of 18, whether the child is biologically related to the head of household, and the marital status of the head of household.

Families with children may face housing discrimination by landlords who fear that children will cause property damage. Some landlords may have cultural biases against children of the opposite sex sharing a bedroom. Differential treatments such as limiting the number of children in an apartment complex or confining children to a specific location are also fair housing concerns.

Single parent households are also protected by fair housing law.

Regional Trends
According to the 2015-2019 ACS (Table D-7), 41 percent of households in Imperial County have children under the age of 18. This share is higher than the share of households with children observed in the state (34 percent) and in Los Angeles and San Diego County (33 percent for both).

The percentage of households with children in Imperial County range from 41 in Westmorland to 51 percent in Imperial. Imperial County also has a higher percentage of female-headed households with children (62 percent) compared to the state (59 percent)and neighboring counties (55 percent in Los Angeles and 58 percent in San Diego County). Within Imperial County, over 75 percent of households have children in the cities of Brawley, Imperial, and Westmorland.

Table D-7: Household (HH) Types with Children- Region California Los Angeles County San Diego County Imperial County El Centro Brawley CalexicoCalipatriaHoltvilleImperialWestmorland
All HH 34.4% 33.0% 33.1% 41.6% 42.0% 45.0% 46.4% 43.2% 46.6% 50.5% 41.3% Married HH 47.0% 47.4% 46.2% 52.0% 51.5% 53.3% 56.0% 51.8% 67.9% 58.2% 48.9% Single MaleHeaded HH 53.0% 48.8% 53.4% 50.3% 46.4% 41.1% 58.9% 54.5% 84.5% 66.4% 72.7% Single
femaleheaded HH58.5% 54.8% 58.5% 61.9% 59.3% 75.4% 61.1% 62.1% 51.0% 79.6% 75.6% Nonfamily 0.8% 0.6% 0.7% 1.1% 1.9% 0.0% 2.6% 0.0% 0.0% 0.0% 0.0% all HH 34.4% 33.0% 33.1% 41.6% 42.0% 45.0% 46.4% 43.2% 46.6% 50.5% 41.3% Source: ACS 2015-2019 5-year estimates

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Figure D-7 and Figure D-8 shows the distribution of children in married households and single female headed households in the region. Darker colors indicate a higher percentage of children in married-couple households or single female-headed households per tract. Most census tracts in major jurisdictions like Imperial, Holtville, and Calexico have between 20 and 40 percent of the children population in married-couple households. The highest concentration of children in married people households is found in a few tracts in El Centro. Many census tracts in the eastern and western county appear to have a high concentration of children in married households. It is likely that low population in these areas (which are mainly rural plots) skew the percentages.

While children in married-households appear to be uniform across most of the County’s jurisdictions, children in female headed households are more notably concentrated in El Centro and Brawley (Figure D-8).

Figure D-7: Children in Married Households- Region

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Figure D-8: Children in Single Female-Headed Households- Region

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Local Trends
Approximately 42 percent of households in El Centro have children, fewer than the surrounding jurisdictions of Imperial (51 percent), Calexico (46 percent), and Brawley (45 percent). According to the HCD AFFH map in Figure D-9, children in married households are most concentrated in a single census tract in the City, north of Interstate Highway 8 and bounded by S. Imperial Avenue to the west and the railroad tracks on the east. In this census tract, over 80 percent of children are in married couple households.

Figure D-10 shows children in single female-headed households are concentrated in the central tracts of the City. In these tracts, between 20 and 40 percent of children are living with a single female householder. The highest concentration of children in female headed households is found along the western city limits of the City, in the tract bound by N. La Brucherie Avenue, Bradshaw Avenue, N. Imperial Avenue, and W. Main Street.

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Figure D-9: Children in Married-Couple Households- City of El Centro

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Figure D-10: Children in Single Female-Headed Households- City of El Centro Distribution of RHNA Units by Familial Status
RHNA units are distributed throughout the City, with smaller mixed-income units in the center and larger mixed-income sites in the southeastern and northwestern parts of the City. In terms of familial status, most RHNA units (82 percent) are in tracts that have between 60 and 80 percent of its children population in married households. Lower income units are distributed similarly, with 75 percent of lower income units in tracts where 60 to 80 percent of children live in marriedcouple households (Table D- 8).

About 85 percent of all RHNA units are located in tracts with the lowest concentration of children in single female-headed households similar to the 78 percent of lower income RHNA units (Table D- 9). A higher proportion of moderate income RHNA units (34 percent) are located in areas with

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a higher concentration of children in female headed households compared to lower income and all RHNA units (11 and 10 percent).

Table D- 8: RHNA Unit Distribution by Percent Children in Married-Couple Households Lower Income
RHNA
Moderate Income
RHNA
Above Moderate
Income RHNA Total RHNA Units
< 20 % 0.0% 0.0% 0.0% 0.0%
20% - 40% 0.0% 0.0% 0.0% 0.0%
40% - 60% 22.0% 33.4% 1.3% 15.2%
60% - 80% 75.1% 57.2% 98.7% 82.3%
> 80% 2.9% 9.4% 0.0% 2.5%
Total Units 1,903 437 1,498 3,838
Table D- 9: RHNA Unit Distribution by Percent Children in Single Female-Headed Households Lower
Income
RHNA
Moderate
Income
RHNA
Above
Moderate
Income RHNA
Total RHNA
Units
< 20 % 78.0% 64.1% 98.7% 84.5%
20% - 40% 11.4% 34.1% 1.3% 10.0%
40% - 60% 10.7% 1.8% 0.0% 5.5%
60% - 80% 0.0% 0.0% 0.0% 0.0%
> 80% 0.0% 0.0% 0.0% 0.0%
Total Units 1,903 437 1,498 3,838

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Income Level
Household income is the key determinant of ability to pay for housing. For many households, their income is too limited to afford existing housing. A larger number of households have incomes too low to afford new housing, as new housing is usually more expensive than existing housing.

Identifying low or moderate income (LMI) geographies and individuals is important to overcome patterns of segregation. HUD defines a LMI area as a Census tract or block group where over 51 percent of the population is LMI (based on HUD income definition of up to 80 percent of the AMI).

Regional Trends
According to 2013-2017 CHAS data, 49 percent of Imperial County’s households earn low and moderate income. This is a higher percentage than observed in San Diego County (43 percent) and statewide (44 percent) but lower than Los Angeles County (52 percent). Figure D-11 shows that LMI population is concentrated in tracts within the major jurisdictions of the County.

However, in the cities of Westmorland, Calipatria, and Holtville, between 50 and 75 percent of the population earns low and moderate incomes in all their tracts. In Brawley, El Centro, and Calexico, the percentage of LMI population per block group varies within the city boundaries, with the percentage of LMI populating ranging from less than 25 to over 80 percent.

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Figure D-11: Low and Moderate Income Population – Region

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Local Trends
The City’s LMI population (48.7 percent) is similar to the County’s (48.8 percent). As seen in Figure D-12, the City of El Centro has many census tracts with a high percentage of LMI population in the center of the City. In these tracts, between 50 and 75 percent of the population is LMI. Census tracts with the second highest concentration of LMI population (where 25 to 50 percent of the population earns low and moderate incomes) are concentrated in the southeastern tracts of the city, east of La Brucherie Avenue.

Figure D-12: Low and Moderate Income Population- City El Centro

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Distribution of RHNA Units by % Low and Moderate Income Population RHNA units mostly distributed in census tracts that have less than 25 percent LMI population (52 percent of units) and tracts that have 50 to 75 percent LMI population (39 percent of units).

This makes sense given that most census tracts fall into either one of these two categories. In an effort to encourage mixed-income neighborhoods, about 40 percent of lower income units are located in census tracts with the lowest percent of LMI persons (less than 25 percent). However, given the prevalence of tracts with higher LMI concentration, 53 percent of lower income units are also located in tracts with 50 to 75 percent LMI persons. Only six percent of lower income units are sited in tracts with the highest concentration of LMI persons.

Table D- 10: RHNA Unit Distribution by LMI Population
Lower Income
RHNA
Moderate Income
RHNA
Above Moderate
Income RHNA
Total RHNA Units
< 25% 40.2% 2.7% 81.6% 52.1%
25% - 50% 0.8% 13.5% 5.9% 4.2%
50% - 75% 53.4% 68.9% 12.5% 39.2%
75% - 100% 5.6% 14.9% 0.0% 4.5%
Total Units 1,903 437 1,498 3,838
C. Racially and Ethnically Concentrated Areas
Racially and Ethnically Concentrated Areas of Poverty (R/ECAP) In an effort to identify racially/ethnically-concentrated areas of poverty (R/ECAPs), HUD has identified census tracts with a majority non-White population (greater than 50 percent) and a poverty rate that exceeds 40 percent or is three times the average tract poverty rate for the metro/micro area, whichever threshold is lower.

Regional Trends
There are two R/ECAPs located within the County- in Calexico and El Centro (Figure D-13).

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Figure D-13: Racially and Ethnically Concentrated Areas of Poverty (R/ECAPs) - Region

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Local Trends
There is one R/ECAP identified in the City of El Centro, in the northern part of the City (Figure D-14). This tract (Census Tract 115) is bounded by bounded by Main Street to the South, N.

Imperial Avenue to the west, Villa Avenue (unimproved) and Pico Avenue to the North, and the Union Pacific Railroad to the west. While the area is aggregated as single census tract, it consists of four separate residential neighborhoods separated by major roadways, railroads, and public facilities. Below is a list of distinct areas within the R/ECAP area based on time of development and residential structure composition.
• South of Adams Avenue Area – This residential area consists of parcels located on Park Avenue and Commercial Avenue between N. 12th Street and N. 4th Street. According to subdivision maps, development of this area occurred in the 1900s and 1910s. Residential development in this area is a mixture of single family residences and two to four unit multifamily buildings.
• North of Adams Avenue Area – This residential area consists of properties north of Adams Avenue and south of the Union Pacific Railroad. Parcels are located on El Centro Avenue, Euclid Avenue, and Woodward Avenue. Development of this area began in the 1910s. Residential development in this area is a mixture of single family residences and two to four unit multifamily buildings.
• West of 8th Street Area – This residential area consists of properties north of the Union Pacific Railroad and west of 8th Street. Parcels are located on Oleander Avenue, Rose Avenue, Scott Avenue, and Stacy Avenue. Development in this area began in 1950s for the area between 8th Street and 12th Street thought the late 1970s for the area west of 12th Street. Residential development in this area consists substantially of single family residences.
• Kennedy Middle School Area – This residential area includes the properties to the north and east of Kennedy Middle School. It is consists of several mobile home parks along 8th street between the Union Pacific Railroad and Villa Avenue, a single family and condominium neighborhood north of Villa Avenue and south of Pico Avenue. Mobile home developments were established before the 1960s while the single family development and condominium areas were constructed in the 1980s.

An important geographic quality of Census Tract 115 is that only about 44 percent of the tract allows residential uses while the remaining is a mix of commercial and manufacturing. Despite limited residential area, the tract’s population has one of the highest concentrations per square mile among neighboring census tracts (Table D- 11).

Table D- 11: Persons per Square Mile in R/ECAP and Neighboring Tracts Census Tract Population Size (mi2) Persons per mi2
115 6,227 0.8 7,859
112.01 6,221 5.6 1,116
112.02 5,626 0.6 8,861
114 4,570 1.5 2,984
116 5,728 0.8 7,248
Source: ACS 2013-2019 5-year estimates

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As expected due to the nature of beig identified as a R/ECAP, census tract 115 is located among the central area of the City that disproportionate concentration of lower and moderate income population, the lowest economic outcomes, and low educational outcomes (see Figure D-12, Figure D- 21, Figure D- 26 in the next sections). Census tract 115 also has disproportionate needs compared to the rest of the City with the highest rates of overcrowding (17 percent), the highest concentration of the renter population (Figure D- 15) and the highest concentration of cost burdened renters (59 percent), and is considered a vulnerable community to displacement (see Figure D-31, Figure D-33, Figure D-35, Figure D- 37 in the sections below).

According to the ACS, median income in this area has increased by about $8,000 from $24,000 (2019 inflation adjusted dollars) in 2013 to $32,480 in 2019. Poverty rates have decreased in the census tract in the same time period with 41.6 percent of the population under the federal poverty line in 2013 compared to 39.3 percent in 2019. Along with slight improvements in median income and poverty rates, the percent of cost-burdened renter population has decreased between 2014 and 2019. In 2014, 63.7 percent of the renter population was experiencing cost burdens compared to 59.4 percent in 2019.

While these income and cost burden improvements may be outside City control, the City has invested many resources to improve the quality of life of residents in Census Tract 115 over the past 5 years through the construction and renovation of community facilities. In September 2019, the City held the grand opening to the Aquatic Center at 540 Park Avenue that consists of an 8- lane competition pool, a warm-up/instructional pool, a beach activity pool, a lazy river, and the Aquatic Center building all over a 3.5-acre site. The Aquatic Center represents a $18 million investment within one of the main corridors of Tract 115. Adjacent to the Aquatic Center, the City had invested a total of $5.7 million with the construction of Sidewinder Skate Park and the Martin Luther King Jr. Pavilion along Park Avenue within Tract 115. In November of 2017, the City acquired Center Point, a 14.07-acre abandoned shopping center at 1140 Imperial Avenue. This will be the home of the new El Centro Public Library that is currently under construction, representing an investment of $17.4 million by the City and while it is not inside of Tract 115, it is right across the street from it. The City also installed bike lanes on 8th Avenue throughout the entire census tract providing active transportation options.