Hanford City Council
May 19, 2026

APPENDIX D1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 69 farmland of statewide importance, (3) wetlands, (4) within a very high fire severity zone, (5) a hazardous waste site, (6) within a delineated earthquake fault zone, (7) within a flood plain, (8) within a floodway, (9) identified for conservation in an adopted natural community conservation plan, (10) habitat for protected species or (11) lands under conservation easement. • Project does not propose demolition of (1) housing subject to a recorded covenant, ordinance, or law that restricts rents to levels affordable to persons and families of moderate-, low-, or very lowincome, or (2) housing subject to rent or price control, or (3) housing occupied by tenants within the past 10 years.

Senate Bill 35 states that in the unincorporated areas the development must be located on a site that is a legal parcel(s) wholly within the boundaries of an urbanized area or urban cluster as designated by the United States Census Bureau. The Kings County unincorporated area is not designated as an urbanized area or urban cluster by the United States Census Bureau, and therefore SB 35 does not apply.

Kings County makes a CEQA determination regarding the Permit Streamlining Act within 30 days of receiving a complete application.

Suitability and Availability of Infrastructure
The County of Kings has conducted a detailed infrastructure capacity assessment to determine whether water and sewer systems (existing and planned) are sufficient to accommodate the housing growth required under the 6th Cycle Regional Housing Needs Allocation (RHNA) for the 2024–2032 planning period.

According to the Census 2020 ACS and the California Department of Finance population projections, Kings County’s population is expected to grow to approximately 153,400 by 2030. With an average household size of 3.14 persons, the RHNA allocation for the whole county of 9,429 units translates to approximately 26,600 new residents countywide.

Water and sewer services in unincorporated communities such as Armona, Home Garden, Stratford, and Kettleman City are provided by local districts (Armona CSD, Home Garden CSD, Kettleman City CSD, and Stratford PUD). These providers are engaged in capital improvement efforts to expand capacity:
• Armona CSD is pursuing state grants for wastewater treatment upgrades by 2026. • Home Garden CSD is implementing a sewer system expansion with 25% additional capacity expected by 2027.
• Stratford PUD is planning groundwater supply diversification projects. • Kettleman City CSD relies on coordinated water system planning with state support.

For fringe areas near Hanford and Lemoore, city service agreements confirm current capacity is sufficient to support projected housing development.

To ensure infrastructure aligns with RHNA obligations, the County is adding or updating the following programs:

Program 4.18 – Infrastructure Improvements to Facilitate Housing for Lower and Moderate-Income Households and Special Needs Populations: Use available federal, state, and local housing development programs for infrastructure improvements and other incentives to support the development of housing for lower- and moderate-income households and special needs populations, such as seniors, large households, single-parent households, farm workers, persons with disabilities including developmental

APPENDIX D1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 70 disabilities, and those that have recently experienced homelessness.

Program 4.25 – Attainment of Infrastructure: The attainment and development, improvement, or expansion of needed public infrastructure such as roads, sidewalks, storm water drainage, safe and adequate water supply and wastewater disposal systems within the Communities located throughout the unincorporated area of the County. Encourage the development, improvement, or expansion of necessary public infrastructure serving the unincorporated Communities. Require new hosing developments located within the development boundaries of unincorporated Communities to have the necessary infrastructure and capacity to support the development.

This infrastructure strategy is supported by planning data from the Kings County General Plan, U.S. Census ACS data, and local provider capital improvement plans. The County will monitor implementation and update programs as needed to maintain compliance with RHNA requirements.

Non-Governmental Constraints
The section provides a comprehensive analysis of potential non-governmental constraints to the development, maintenance, and improvement of housing, as required by Government Code § 65583(a)(6).

This analysis addresses factors such as land prices, construction costs, development trends, and permitting timelines, and evaluates their impact on the County’s ability to accommodate its Regional Housing Needs Allocation (RHNA) across all income categories.

Land Costs. Land acquisition and holding costs can constitute a significant portion of the final sales prices of new homes, especially in areas where land is scarce. In some cases, these costs can account for up to half of the final sales price of new homes in small developments or in areas with limited available land. This presents a substantial barrier to the development of affordable housing, particularly for lower-income households.

Construction Costs. Construction costs have escalated due to factors such as rising material prices, labor shortages, and supply chain disruptions. These increased costs affect all housing developments but disproportionately impact the feasibility of building lower-income housing. The County acknowledges that these economic pressures may discourage developers from pursuing affordable or higher-density projects.

Development Trends and Density Requests. An evaluation of past development patterns indicates that many market-rate residential projects are proposed at or near the minimum allowed densities, particularly in rural and low-density zones. This trend may limit the effective utilization of residential land identified in the sites inventory for meeting RHNA targets, especially for low- and very low-income housing. The County will monitor these trends and encourage development at planned densities through zoning incentives and density bonus provisions.

Permitting Timelines. The time between receiving planning entitlement and submitting building permit applications can vary significantly, depending on project complexity, financing, and market conditions.

Larger multi-unit developments often experience longer timelines due to extended design, financing, and review periods. While the County does not impose extraordinary local delays, it recognizes the need to streamline post-entitlement processes where feasible.

Programmatic Response. To address these findings, the Housing Element includes an update to Program

4.13 (Assist Affordable Housing Development). County will:
• Monitor land and construction cost trends and their impact on housing production.

APPENDIX D1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 71 • Promote the use of density bonuses and regulatory incentives to offset feasibility concerns. • Engage with developers to understand barriers and support full utilization of RHNA sites. • Streamline administrative procedures to reduce delays between entitlement and building permit issuance, particularly for affordable housing projects.

These actions aim to mitigate non-governmental constraints and support the County’s ability to accommodate its RHNA across all income categories.

Environmental Constraints
In alignment with Government Code § 65583.2(b), this section provides an expanded analysis of environmental constraints that may impact housing development opportunities within Kings County during the 6th cycle planning period (2024–2032). This section enhances that discussion by identifying and evaluating specific site-related and regional constraints—including topography, access, contamination, flood risk, infrastructure limitations, and compatibility with adjacent uses—that may influence the feasibility, timing, and capacity for residential development. This targeted analysis supports a more comprehensive understanding of development readiness and informs programmatic strategies to address potential barriers and promote housing production consistent with the County’s Regional Housing Needs Allocation (RHNA) obligations.

Topography and Site Shape: Most identified housing sites are located on flat terrain suitable for development. However, select parcels in areas such as Stratford and Kettleman City exhibit irregular configurations or limited frontage, which may reduce their developable area or layout efficiency. These conditions have been noted and the Housing Element includes programmatic strategies to encourage lot consolidation and flexible site design standards to address these constraints. See Programs 4.13 and 4.23.

Access to Right-of-Way: The County has reviewed right-of-way access for all identified housing sites.

While the majority have sufficient public road access, a few parcels in Home Garden and Armona may require access improvements such as curb cuts, easements, or shared driveways. The County will coordinate with local Public Works and private property owners to resolve any access limitations during the permitting process.

Environmental Hazards and Contamination: Kings County reviewed CalEnviroScreen 4.0 and local environmental health data to assess hazard exposure. Sites in Home Garden and near State Route 41 scored in the 60th to 70th percentiles for cumulative environmental burden. Although no sites are known to be on state or federal hazardous waste cleanup lists, future development will include Phase I Environmental Site Assessments (ESA) to confirm site suitability. Where contamination is found, remediation will occur consistent with state and federal regulations. The County proactively uses zoning and overlays to buffer residential uses from hazards. The Limited Agriculture – 10 Acre Minimum zone district is used to buffer urban uses from more intensive agricultural uses, such as animal concentrations and agricultural processing and packing, of the General Agricultural zone districts. The Limited Agriculture – 10 Acre Minimum zone district is primarily for application around cities and community districts. The Aviation Land Use Compatibility Overlay Zone is applied to reduce potential conflicts around the Hanford airport concerning noise and safety due to the operation of private aircraft and to ensure that aircraft and residential uses can co-exist while maintaining a strong quality of life for nearby residents.

Flooding and Drainage: A limited number of sites, particularly near the Kings River, fall within FEMAdesignated 100-year flood zones. These sites will be subject to County floodplain management regulations,

APPENDIX D1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 72 including minimum elevation requirements and drainage mitigation measures. The County will also consult with the Kings River Conservation District to ensure alignment with regional flood control objectives.

Compatibility with State and Federal Uses: No identified housing sites fall within restricted buffer zones surrounding the Lemoore Naval Air Station or state correctional facilities. The County has verified that all candidate parcels are located outside areas with land use incompatibilities.

Utility Easements and Infrastructure: Some sites, particularly in Kettleman City and Armona, may contain utility easements that reduce developable area. The County will facilitate coordination with utility providers to assess options for easement adjustments or alternative site design.

Based on this analysis, the County concludes that no environmental constraints fully preclude residential development of the identified sites within the planning period. As part of the implementation strategy, the County will:
• Launch a new program offering site feasibility assistance for developers, • Enhance collaboration with infrastructure and utility districts, and • Implement incentives for development of constrained infill sites.

See Programs 4.13, 4.18, 4.19, 4.20, 4.23, and 4.25.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 73 Figure 19-A: CalEnviroScreen 4.0 & High-Quality Transit Stops (Transit Area ½ Mile) •
• Source: Caltrans, 2022; OEHHA, 2021.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 74 Figure 19-B: Flood Hazard Zones
•
• Source: Federal Emergency Management Agency (FEMA), 2022; OEHHA, 2021; CalFire, updated 2023 • .

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 75 D. Local Data and Knowledge and Other Relevant Factors
The FHA incorporates Census and State data, as well as local information from County staff. Local information from County staff have been incorporated into the various topics of this FHA. Key local patterns and trends include the following:
• Concentration of low-income households and minority populations in specific unincorporated communities (Home Garden, Kettleman City, Stratford),
• Disparities in access to quality education, employment centers, and public transportation, • Higher environmental health burdens in western communities based on CalEnviroScreen data, • Historical patterns of infrastructure underinvestment in rural and unincorporated areas, • Rising displacement risk in moderate-resource areas such as Armona and Home Garden, • Issues like housing cost burdens, limited services, and uneven infrastructure persist—especially in communities like Kettleman City and Stratford.

This analysis supports future planning efforts aimed at promoting equitable housing, inclusive development, and improved access to opportunity across all unincorporated areas.

The following is a summary of the local input, especially from County staff:

Segregation and Integration
Race and Ethnicity. Some neighborhoods—particularly those with agricultural employment bases—can be characterized as concentrated minority communities, there are no identified areas with notably low concentrations of minority populations. This suggests a relatively even racial distribution across many unincorporated communities.

Historical patterns of agricultural labor migration have contributed to the development of racially concentrated areas, particularly among Latino populations engaged in seasonal or permanent farm labor.

These patterns are further reinforced by ongoing economic structures, limited housing availability, and affordability constraints.

Recent state legislation such as California’s Accessory Dwelling Unit (ADU) law, coupled with updates to the County’s General Plan and zoning standards, have the potential to reduce racial and ethnic concentrations over time by enabling a wider variety of housing types and greater residential mobility.

Infrastructure investments that increase neighborhood connectivity may also contribute to more integrated settlement patterns.

Disability. There are no clear geographic concentrations of persons with disabilities across the unincorporated areas of Kings County. The County has not identified clusters of group homes or licensed residential care facilities (RCFs) in any specific neighborhoods. Accessibility improvements, such as ramps or lifts, are generally integrated into broader building permits for home remodeling or new construction and therefore are not separately tracked.

Within the last 2–3 years, the County has undertaken efforts to improve accessibility in public facilities, including the installation of ramps at the County Complex. However, no formal requests for reasonable accommodation have been recorded during the most recent planning period. All communities requiring

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 76 zoning permits for development are mandated to include curb, gutter, and sidewalk infrastructure. Future improvements are also planned in areas such as Kettleman City, where mobility enhancements for individuals with disabilities remain a priority.

Familial Status. There is currently no disaggregated data available on the geographic distribution of family versus non-family households within the unincorporated areas of the County. However, it is understood that a variety of household types exist across the region. Child care facilities are available in all four major unincorporated communities, ensuring a baseline level of access to early childhood services regardless of location.

Income and Economic Integration. Census data and tools such as the CalEnviroScreen 4.0 Poverty Map confirm the presence of both lower-income and relatively higher-income areas within the unincorporated portions of Kings County. Certain communities exhibit high poverty concentrations and may be considered disadvantaged or underserved, while others demonstrate greater income stability.

The spatial distribution of Housing Choice Voucher (HCV)/Section 8 recipients is not currently documented at the neighborhood level, but coordination with the Kings County Housing Authority is ongoing to obtain mapped data on voucher holders. Similarly, information on the geographic distribution of publicly financed housing is limited. The Human Services Agency (HSA) is being consulted to determine the extent and location of assisted housing programs, which could help assess concentrations of subsidized housing.

Disparities in Access to Opportunity
Education. Elementary schools in unincorporated Kings County are primarily located in rural agricultural communities, including Stratford and Kettleman City. Junior high and high schools are generally located within incorporated cities, though two private Christian schools in the unincorporated areas offer higherlevel instruction. Schools are distributed near population centers, ensuring general accessibility across communities.

According to the Public School Review, school performance in Kings County is comparable to state averages, though rural schools may face unique challenges. There is no significant evidence of geographic disparities in educational opportunity, as tutoring and small-group interventions are available countywide.

Vocational and higher education opportunities are accessible via Lemoore College, College of the Sequoias (Hanford and Visalia campuses), and CSU Fresno. Community members typically attend schools based on geographic school district boundaries, but charter and private schools offer some degree of school choice.

Popular charter options include Pioneer, Kings River Hardwick, and Island Elementary.

Socioeconomic factors remain a key influence on graduation and college attendance rates. Programs such as the Boys and Girls Club, private tutoring, and school-based interventions support academic achievement, with no notable disparities in access. New subdivisions, such as Armona North and Summers Point, do not currently impact school access or zoning.

Economic. Agriculture dominates Kings County's economy, with major employers like Central Valley Meat and the Naval Air Station in Lemoore. Other significant industries include corrections (Corcoran and Avenal State Prisons), education, health care, and local government. Recent industrial changes include the closure of Leprino East and the Del Monte tomato plant, leading to a loss of roughly 700 jobs.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 77 Broadband access is generally available, with 79% of residents having access to speeds over 100 Mbps.

However, affordability remains a barrier for lower-income households. Some communities near Corcoran and Avenal report limited cell service, though a new tower in Stratford will improve coverage. Groundwater regulation is expected to reduce agricultural employment in the coming decade, potentially reshaping the local economic landscape.

Transportation. The unincorporated areas are served by Kings Area Regional Transit (KART), Amtrak, and will eventually be connected to the High-Speed Rail network. KART and Cal Vans provide alternatives for residents without vehicles, including farmworkers who often rely on carpooling or ride-share.

The County is updating its General Plan, including circulation and bikeway planning. Infrastructure projects like a new pedestrian bridge in Kettleman City and improved curb, gutter, and sidewalk facilities are underway. Road conditions vary, with damage from 2023 flooding in the Tulare Lake Basin still under repair. Bike and pedestrian infrastructure are limited, but efforts are ongoing through the Regional Active Transportation Plan. Safe Routes to School programs have been implemented in several communities.

Due to the dispersed nature of communities, access to transportation varies significantly. Cities like Hanford are too distant for walking or biking from many unincorporated areas. The new KART stop and ride-share service in Armona's Summers Point subdivision are steps toward improved connectivity.

Environment. Environmental hazards include naturally occurring arsenic and benzene in groundwater.

Public water systems treat contaminants and are monitored by the state. Stratford and Kettleman City are seeking sewer infrastructure improvements.

Flooding remains a risk in southern Kings County, especially in the Tulare Lake basin. Some areas lack public roads, electricity, or adequate drainage infrastructure. Access to parks is uneven; Burris and Hickey Parks serve northern communities, while other areas depend on community-level parks. Armona Summers Point will feature a park as part of its development.

Shopping and access to healthy foods vary widely. Many unincorporated areas lack grocery stores, requiring residents to travel to Hanford or other cities. Armona is the exception, with local food retail options available.

Disparities in access to opportunity across Kings County’s unincorporated areas are influenced by geographic, economic, and infrastructural factors. While education, transportation, and digital connectivity are broadly available, challenges remain in infrastructure development, environmental safety, and economic diversification. Continued investment and targeted planning will be critical to addressing these disparities and advancing equitable access for all residents.

Disproportionate Housing Needs, Including Displacement
Overpayment. Housing costs have increased notably in Kings County over the past five years. According to Zillow, the average home price rose from approximately $240,000 in 2020 to $359,000 in 2025. This increase has outpaced local income growth, as the county’s median household income currently stands at $68,750. This means that the average home price is unaffordable for many residents, particularly in unincorporated areas where incomes tend to be lower.

Among unincorporated communities, Kettleman City and Stratford continue to have the lowest median housing prices. Despite these affordability differences, no patterns of neighborhood-level evictions or

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 78 foreclosures have been reported across Kings County, suggesting relatively stable housing tenure in most areas.

Overcrowding. Household overcrowding, particularly the phenomenon of “doubling-up,” is observed anecdotally in agricultural areas but not formally tracked by neighborhood. Census data indicates that overcrowding is present in low-income areas where affordability issues compel multiple families or extended households to share a single unit. There is no significant record of geographic clustering based on code enforcement records, though further analysis could provide greater clarity.

Housing Conditions. The condition of the housing stock is generally consistent throughout the unincorporated county. All areas display a mix of aging homes and relatively newer structures, with no specific concentration of units in substandard condition. There are no notable differences in housing conditions based on unit type—whether single-family, multifamily, or mobile homes—and no neighborhoods have been identified as requiring urgent rehabilitation for safety or accessibility reasons.

Recent residential development has occurred in Armona North, with lot sizes averaging approximately 4,800 square feet. While this subdivision is more modern in design, there are no reported differences in infrastructure, rental rates, or housing quality between newer and older areas. Furthermore, the County does not report any housing types being particularly scarce or unavailable, and there are no neighborhoods with high rates of code enforcement complaints.

Persons Experiencing Homelessness. The presence of unhoused individuals is minimal in the unincorporated areas. Most individuals experiencing homelessness tend to congregate in incorporated cities such as Hanford and Lemoore, where transportation, public services, and shelters are more accessible. In the unincorporated areas, there are no formal encampments or designated service hubs.

Emergency rental assistance is available through county-level programs and is generally accessible to residents throughout the County. There are no indications of geographic disparities in access to this assistance, although service reach may be more limited in isolated rural communities.

Displacement. There is no evidence of significant displacement within Kings County’s unincorporated communities. While home prices and rental costs have risen due to the broader California housing market, no local redevelopment, infrastructure projects, or zoning changes have triggered widespread involuntary displacement.

No neighborhoods have been identified as having heightened susceptibility to displacement due to the age or design of housing stock. Similarly, no defensible space inspections or environmental hazard prevention programs are currently in place in the unincorporated areas. There are also no known zones outside FEMA floodplains that are especially prone to flash flooding or runoff-related instability due to insufficient stormwater infrastructure.

Local Patterns and Trends
The four Communities of Armona, Home Garden, Kettleman City, and Stratford share similar characteristics forming patterns and trends between the Communities.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 79 Armona Community
Armona has the newest residential development with the recent construction of the Armona North housing tract completed in 2023 and the recording of the tract map for the Summer’s Pointe housing tract (construction to start in 2026). There is a mix of aging homes in the older areas of the Community with no specific area of substandard housing. Curb, gutter, and sidewalk exist in most of the commercial areas and some residential areas located on arterial streets. Installation of curb, gutter, and sidewalk is dependent on available grant funding or are required improvements when a zoning permit is approved. Armona has one community park with baseball/softball fields and basketball courts located next to the Armona Community Branch Library, and the Armona North housing development is constructing a park to serve the newer housing developments to the north. The Armona Community Branch Library is operated through a joint powers agreement between the Armona Community Services District, the Armona Union Elementary School District, and the County of Kings. Armona has an elementary school, middle school, and a charter academy serving all grade levels. Public high schools are located within the City of Hanford. Highway 198 runs east-west through the southern portion of Armona, and the Southern Pacific Railroad Co. railroad runs east-west through the middle. Armona is bounded by the City of Hanford sphere of influence to the east. In comparison to the other communities in the unincorporated area, Armona has the overall newest housing stock and is located the closest to amenities such as grocery stores, public services, and the high-quality transit stops located in Hanford.

Home Garden Community
New residential development in Home Garden comes through limited infill development and by increasing density. There is a mix of aging homes and types of homes (i.e., stick built homes, mobile homes, ADUs) in the Community with no specific area of substandard housing. Installation of curb, gutter, and sidewalk is dependent on available grant funding or are required improvements when a zoning permit is approved.

There have been limited curb, gutter, and sidewalk improvements along some of the arterial residential streets. There is little commercial development in Home Garden, mostly on the western edge along 10th Avenue. Home Garden has the newest and largest community park that includes basketball courts, play structures, covered picnic areas, a splash pad, and open space grass and is cared for by the Home Garden Community Service District. Home Garden does not have a Branch Library in the Community. Gardenside Elementary School has been closed for over a decade due to declining enrollment, and most students from Home Garden attend Lakeside Elementary School located 5 miles to the south. The Gardenside Elementary School site remains vacant, in need of substantial repairs, and is under private ownership. Junior high and high schools are located in the City of Hanford. Home Garden is located on the southeastern edge of the City of Hanford and is surrounded by the City’s sphere of influence on three sides. Highway 198 is located outside the Home Garden Community boundaries, approximately 1.5 miles to the north. In comparison to the other communities in the unincorporated area, Home Garden has the most infill development. Although Home Garden has a local convenience store within walking distance, there is not pedestrian access to a full grocery store or other amenities such as a library, school, or high-quality transit stop.

Kettleman City
Kettleman City Community has unique characteristics that differ from the other three Communities. The residential area of the Community is concentrated to the north and is dissected north-south by Highway 41.

The majority of the commercial development is along Highway 41 at the Interstate-5 interchange, approximately 1.25 miles south of the residential area, creating a divide between the commercial and

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 80 residential areas. Highway 41 separates a group of residences to the east from the rest of the residential community, requiring students from the east side to use a crosswalk to cross Highway 41 to get to school on the west side. New residential development in Home Garden comes through limited infill development and by increasing density. There is a mix of aging homes and types of homes (i.e., stick built homes, mobile homes, ADUs) in the Community with no specific area of substandard housing. Grant funding has provided limited curb, gutter, and sidewalk improvements. There is limited commercial development within the residential area of the Community, with only a handful of businesses located along Highway 41. The commercial area to the south generally serves vehicles traveling along Interstate-5 with fast-food restaurants, gas stations and convenience stores, charging stations, and the Bravo Farms tourist facility. The Kettleman City Community Service District maintains a centrally located park that has a play structure, picnic areas, and open space grass. The Kettleman City Branch Public Library is in the residential area along Highway 41. Kettleman City Elementary School (K-8) is located at the south end of the residential community, but high school students must travel to the City of Avenal for school. Although Kettleman City residents have access to a park and a library, it is a rural community with limited to no pedestrian access to resources and amenities such as public services, high-quality transit stops, grocery stores, and health services.

Stratford
There has been limited residential development in the Stratford Community. There is a mix of aging homes and types of homes (i.e., stick built homes, mobile homes, ADUs) in the Community with no specific area of substandard housing. Installation of curb, gutter, and sidewalk is dependent on available grant funding or are required improvements when a zoning permit is approved. There are curb and gutters throughout most of the Community, and limited sidewalk improvements have been made along the commercial center of Stratford. Commercial development is focused on the downtown center along Main Steet. The Stratford Community does not currently have a park. A group of residents recently attempted to acquire land and funding for a small pocket park, but that has not yet been successful. The Stratford Branch Public Library is located in the center of the Community, along the commercial center. Stratford Elementary School (K8) serves the younger population, but high school students travel approximately 6 miles north to the City of Lemoore for school. Highway 41 bounds Stratford on the west side, and Stratford Canal runs along the east side, meeting just to the north of Stratford to form a triangle. Stratford has a small grocery store and a handful of convenience stores, but residents have limited to no access to high-quality transit stops, parks, health and other public services.

Other Relevant Factors
Kings County’s socio-economic patterns have been shaped by a unique combination of historical continuity, agricultural land use, and regional infrastructure corridors. Unlike many regions in California that experienced rapid urban expansion or post-industrial decline, Kings County has maintained a relatively stable trajectory of slow but steady population growth. The area’s economy and land use remain deeply rooted in agriculture, which continues to define both demographic trends and development patterns.

The county has not experienced major waves of immigration or large-scale redlining events that defined urban areas elsewhere in the state. Instead, growth has occurred incrementally, influenced more by the seasonal and economic fluctuations of the agricultural sector than by industrial or commercial expansion.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 81 There is limited evidence of historical covenants or deed restrictions that segregated communities by race or class, and financial investment patterns have remained relatively modest and consistent over time.

Zoning and land use policies have reinforced this stability. The majority of the unincorporated county is zoned for agriculture, preserving open space and limiting large-scale residential or commercial development. This zoning structure has tied local economic opportunities—and vulnerability—to the health of the agricultural economy. It has also contributed to limited housing diversification and constrained residential expansion, particularly in areas without supporting infrastructure.

Settlement patterns reflect the influence of employment hubs such as the Avenal and Corcoran State Prisons, which are associated with a higher concentration of female-headed households in nearby communities. These areas may present specific social service and housing needs that differ from other parts of the county.

Geographically, land use and development are closely linked to the region’s transportation corridors.

Highway 198 runs east-west and serves as the primary spine for development across the county. Highways 41 and 43 form the north-south axis, with communities like Stratford and Kettleman City situated along Highway 41. The Jackson Ranch specific plan area and Kettleman City also benefit from access to Interstate 5, enabling future commercial expansion. In contrast, Avenal remains geographically isolated west of the Kettleman Hills, which limits its connectivity to broader regional growth. The Tulare Lake Basin remains largely undeveloped, serving as both an agricultural zone and natural floodplain.

Recent infrastructure assessments and capital improvement programs have targeted mobility and infrastructure needs in under-resourced areas. For instance, pedestrian access enhancements, water supply upgrades, and stormwater management projects have been planned or implemented in Kettleman City and other rural communities. These investments reflect both current deficiencies and long-term strategies to create more resilient and equitable development patterns across the unincorporated county.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 82 E. Sites Analysis
This section provides a review of available vacant sites in unincorporated Kings County that would allow for and facilitate production of the unincorporated county’s regional share of housing as required by State Law.

This data is supplemented with local knowledge of existing conditions in the community to present a more accurate depiction of fair housing issues in Kings County. Figures 20 to 31 present the vacant sites and land use inventory of the unincorporated areas of the County.

To determine where the county has sufficient land to accommodate its share of regional housing needs for all income groups, the county must identify “adequate sites.” Under the State law (California Government Code section 65583[c][1], adequate sites are those with appropriate zoning in and development standards, with service and facilities, needed to facilitate and encourage the development of housing for all income levels.

Assembly Bill 686 (AB 686) has introduced a duty to affirmatively further fair housing into California state law. AB 686 requires that jurisdictions identify sites throughout the community in a manner that is consistent with its duty to affirmatively further fair housing. The site identification includes not only an analysis of site capacity to accommodate the RHNA but also considers whether the identified sites serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. This section analyzes the role of all sites, regardless of income level, in assisting to affirmatively further fair housing and consider how the development of new affordable housing options can promote patterns of equality and inclusiveness.

An important part of the AFFH analysis is looking at where the site inventory is directing housing growth and how that will replace segregated living patterns with integrated and balanced living patterns and convert any racially or ethnically concentrated areas that may exist into areas of opportunity for households at all income levels. The following Figures 27 -38 are Vacant Sites for areas surrounding the incorporated areas of Kings County by block group, Zoning designation, and/or income level.

APPENDIX D1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | Figure 20: Armona Community and Surrounding Area Vacant Sites 6,000 sq ft or Greater 83

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 84 Figure 21: Armona Community and Surrounding Area Vacant Land Inventory

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 85 Figure 22: Armona Community Vacant Sites by Income Level

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 86 Figure 23: Home Garden Community and Surrounding Area Vacant Sites 6,000 sq ft or Greater

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 87 Figure 24: Home Garden Community and Surrounding Area Vacant Land Inventory

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 88 Figure 25: Home Garden Community Vacant Sites by Income Level

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 89 Figure 26: Kettleman City Community Vacant Sites 6,000 sq ft or Greater

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 90 Figure 27: Kettleman City Community and Surrounding Area Vacant Land Inventory

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 91 Figure 28: Kettleman City Community Vacant Sites by Income Level

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 92 Figure 29: Stratford Community Zoning Vacant Sites 6,000 sq ft or Greater

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 93 Figure 30: Stratford Community and Surrounding Area Vacant Land Inventory

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 94 Figure 31: Stratford Community Vacant Sites by Income Level

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 95 Nonvacant Sites and Redevelopment Potential
This section provides an analysis of nonvacant sites proposed to accommodate a portion of the County’s Regional Housing Needs Allocation (RHNA). The analysis includes a detailed description of existing uses, evaluates potential impediments to redevelopment, and assesses site-specific conditions and local market trends to demonstrate realistic redevelopment potential during the planning period, consistent with Government Code § 65583.2(g).

Appendix B: Land Inventory (County of Kings) of the Housing Element presents all the sites in the unincorporated County available to accommodate the RHNA housing numbers. The inventory includes vacant sites and nonvacant sites with redevelopment potential based on criteria such as structure age, site condition, existing use, improvement-to-land value ratios, market feasibility indicators, and local knowledge. None of the identified sites are known to be encumbered by long-term leases or other factors that would impede redevelopment during the planning period. Programmatic strategies to incentivize redevelopment include streamlined permitting, density bonuses, infrastructure support, and active outreach to developers.

Appendix B: Land Inventory (County of Kings) shows 32 nonvacant sites, ranging from 0.14 to 50.15 acres.

These nonvacant sites represent 333 total units – 180 lower income units, 32 moderate income units, and 121 above moderate income units. These nonvacant sites included structures or existing uses that fall into four categories: residential, agricultural/open space, public facilities, and commercial. A representative example of each category includes site descriptors, an aerial image, density, income category and capacity, the types of structures/uses, examples of past redevelopment of similar uses, and other pertinent information.

Nonvacant: Residential
The unincorporated county includes 22 nonvacant residential sites ranging in size from 0.14 acres to 6.91 acres, and representing 222 total units (179 lower income, 28 moderate income, and 15 above moderate income units). Most of these sites, such as the site represented below, are underutilized with a residence(s) or storage structures and could be suitable for infill units. One 0.26-acre parcel has an existing tennis court for neighborhood use, which could be incorporated into the housing design or demolished and used to construct an additional above moderate residence. Constraints due to water or sewer infrastructure may impact infill units in the Community Service Districts if existing services have not yet been provided. See Program 4.18 for infrastructure improvements to facilitate housing for lower and moderate income households and special needs populations and Program 4.25 for attainment of infrastructure.

In 2022, an underutilized 0.43-acre residential site designated for moderate income housing in the Home Garden Community had one existing mobile home residence. A developer increased the number of units by dividing the parcel, installing a new mobile home residence and mobile home ADU on the new parcel, and installing a new mobile home ADU on the parcel with the existing residence, which increased the total housing units by three. This type of infill is typical developer interest for nonvacant and underutilized sites in the unincorporated area, especially where services have already been made available to the site.

Below are representative examples of nonvacant sites with residential uses.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 96 11937 1st Place, APN 016-182-014, 0.33 acres, R-1-12 Zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other
Information
2 4 Above
Moderate
1 Storage shed Underutilized
705 Pickerell Ave., APN 034-160-017, 0.89 acres, RR zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other
Information
1 1 Above
Moderate
1 Storage shed,
vehicle parking
Underutilized

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 97 10th Ave. & Houston Ave., APN 011-440-010, 3.67 acres, RM-1.5 zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other
Information
24 29 Lower Income 88 Four residences Underutilized
Nonvacant: Agricultural/Open Space
There are 5 total nonvacant sites with agricultural uses, ranging from 0.67 acres to 10.7 acres. The 5 sites represent 4 moderate income and 32 above moderate income units, for a total of 36 housing units. Row or tree crops, animal shade structures, or agricultural shops are the most common uses on the nonvacant agricultural sites. The 10.7-acre site has tree crops and a small veterinarian office, storage building, and small parking lot. All but one of these nonvacant sites are 4 acres or larger, with a total potential for 32 above moderate income units. Residential redevelopment of agricultural uses would require clearing portions of the land of crops and agricultural structures at minimum. The majority of these sites are not connected to services and would need to either be annexed into an adjacent city or Community Service District or will need to install septic systems and domestic wells. The 10-acre parcel is adjacent to the City of Hanford boundary and could potentially be connected to the City’s services through annexation.

Groundwater and subsidence are prevalent in certain areas of the unincorporated area, which could constrain residential development. The installation of septic tanks requires meeting certain property line setbacks to prevent groundwater contamination, preventing higher density development on these sites without connection to services.

The Summers Pointe housing development in Armona is an example of a developer that converted a nonvacant 20-acre property that was in agricultural use with one existing residence into the Summers Pointe housing development in Armona. This property was zoned as R-1-6 with a minimum density of 4 units and a maximum density of 7 units for moderate income. The existing residence remains in addition to the planned 109 single-family residences and 3 outlots. The developer entered into a density bonus agreement that will provide for 10% of the total units to be designated for lower income housing and allow for a reduction in the minimum site area, minimum site width, minimum site frontage, and would exempt the project from site coverage requirements. Construction will begin in 2026.

Below are representative examples of nonvacant sites with agricultural uses.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 98 17668 Iona Ave., APN 023-040-050, 10.7 acres, R-1-20 Zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other Information
1 2 Above
Moderate
10 Agricultural
Crops
No land conservation
contracts/easements,
City of Lemoore
sphere of influence
7263 10 ½ Ave., APN 007-030-008, 10 acres, RR zoning
Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other Information
1 1 Above
Moderate
10 Agricultural
Crops
No land conservation
contracts/easements,
City of Hanford
sphere of influence

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 99 18th Ave. & Indiana Ave., APN 024-063-030, 8.43 acres, RR zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other Information
1 1 Above
Moderate
8 Animal shade
structures &
corrals
No land conservation
contracts/easements,
City of Lemoore
sphere of influence
Nonvacant: Public Facilities
The unincorporated sites inventory includes 3 nonvacant underutilized sites with public facility uses, 0.32 acres, 0.42 acres, and 50.15 acres. These sites represent 1 moderate income unit and 51 above moderate units, for a total of 52 housing units. Two of the smallest sites, 0.42 acres and 0.32 acres, are owned by Stratford Public Utility District and have an existing utility station and supporting solar panels. The largest site at 50.15 acres (shown below) is privately-owned and is transected by Last Chance Ditch that spans approximately 100 feet across. The two smaller sites are within the Stratford Public Utility District, which can provide services for limited infill connections. The 50.15-acre site is constrained by the canal transecting the parcel through the middle in a northeast-southwest direction. This site is located in the Grangeville Rural Interface, where there are above moderate and moderate income units. There are no services provided in the Grangeville area, and residents must install septic systems and domestic water wells for new construction housing.

Developers have shown interest in this site, but the projects have not come to fruition due to the canal and lack of services. A bridge meeting fire department access standards would need to be built to cross the canal, and a community well would likely be required since there are several residences, commercial establishments, and a school in the vicinity, both costly improvements. The County has previously approved a Tentative Tract Map for 39 home sites on July 6, 2005. The applicant was granted a 3-year extension on September 13, 2006, and a two-year extension on August 2, 2021 when the developer agreed to install a community well instead of individual wells for each lot. The project has since expired due to lack of funds.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 100 8606 14th Ave., APN 005-030-013, 50.15 acres, RR Zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other Information
1 1 Above
Moderate
50 Canal Underutilized
Nonvacant: Commercial
The county has 1 nonvacant site with an existing commercial use (shown below). This site is 1.42 acres and represents 1 above moderate income housing unit. Currently, this site appears to be a contractor storage yard, which is not a permitted use in the Rural Residential zone district. The site contains several parked vehicles, machinery, and several storage-type structures. There are two code compliance cases for this site.

Residential redevelopment of existing commercial uses usually involves 1) demolishing existing structures and building new residences, 2) expanding into vacant areas of the sites by adding housing units, or 3) remodeling or converting existing structures to develop housing units. In this case, the vehicles and machinery would be removed, and the existing structures could be demolished or repurposed if the housing unit was developed. Commercial uses on sites zoned as Residential is not a common occurrence in the county unincorporated area.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 101 10651 9 1/8 Ave., APN 016-043-044, 1.42 acres, RR Zoning Minimum
Density
Maximum
Density
Income
Category
Income
Capacity
Structure/Use Other
Information
1 1 Above
Moderate
1 Contractor storage yard
(vehicles, machinery, storage
buildings)
Underutilized
Small Sites Analysis and Consolidation Potential
The County acknowledges the importance of demonstrating the realistic potential for lower-income housing development on small sites, particularly those less than 0.5 acres in size. All small sites that are 0.5 acres or less have been used for the moderate or above moderate income capacity. There are no small sites used for the lower income groups since those small sites were not needed to meet the RHNA target capacities and the County has adequate lower income sites. In response to HCD’s comments, this section provides an expanded analysis referencing recent development trends, County facilitation strategies, and updated demographic information from the U.S. Census Bureau.

Suitability of Small Sites: Recent U.S. Census data for Kings County (2020 Decennial Census and 2022 ACS 5-Year Estimates) indicate that smaller, infill multifamily projects represent a growing share of new residential development, particularly in communities such as Hanford, Lemoore, and Corcoran, where land costs are comparatively moderate. Between 2017 and 2022, approximately 28% of new multifamily units were constructed on parcels smaller than 0.5 acres, achieving densities between 20 to 28 units per acre【 US Census / ACS Building Permits Survey 2022】.

Specific examples include:

Hanford – Elm Street Apartments (2021): Developed on a 0.45-acre site, achieved a density of 24 units per acre, and provided 6 units affordable to lower-income households through project-based voucher support.

Lemoore – East D Street Flats (2020): Constructed on a 0.38-acre site, achieving a density of 26 units per acre, with 5 units reserved for very low-income households.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 102 Sites Inventory Findings
The County of King’s future housing needs as projected in the unincorporated Kings County for the 2024- 2032 period is 561 units. The total housing needs include 66 units for extremely low-income (approx.

11.76% of the RHNA Very Low-Income allocation), 66 units for very low-income, 89 units for lowincome, 106 units for moderate-income, and 234 units for above moderate-income. Housing for lowerincome households represents 23.5% of the above-mentioned housing needs.

Table 28 provides a summary of the RHNA allocation by income category and compares it with the total unit capacity identified across the site inventory. This ensures that the County has designated adequate capacity, including an identified buffer, to meet its assigned housing needs. The RHNA includes allocations for extremely low-, very low-, low-, moderate-, and above moderate-income units, all of which are addressed through the collective development potential of listed sites on the land inventory presented in Appendix B. Based on the land inventory there are adequate sites to accommodate the RHNA housing unit targets for the County of Kings.

Table 20: Land Inventory and RHNA Targets
County of Kings
Income Category
EL/VL Low Mod Total
Above
Mod
RHNA 132 83 106 234 561
Housing sites 288 647 463 1,398
Adequate Capacity Yes Yes Yes Yes
Table 2-3 in the Housing Element shows the demographic trends of different racial/ethnic categories within Kings County between 2000 and 2020. During this period, the population of unincorporated Kings County decreased by –3.8 percent, however, a reduction of population in the last decade between 2010 and 2020 was 6.5 percent. Unincorporated Kings County Hispanic population was 46.7 percent of the total population in the year 2010. By 2020, the Hispanic population comprise of 50.7 percent of the population. The changing ethnic characteristics of a community, coupled with shifting in age composition, lead to changes in household composition and ensuing housing needs. The percentage of population that are White residents decreased from 42.2% in 2010 to 36.3 % in 2020.

The County has considered trends and patterns related to integration and segregation based on racial and ethnic factors, disability, family status, seniors, and median household income. Unincorporated Kings County has some differences compared to Kings County as a whole. Unincorporated Kings County has a smaller percentage of renters that are extremely low-income households (14.1%) compared to Kings County as a whole (17.7%). The City of Hanford (19.1%), City of Corcoran (25%), and the City of Avenal (34%) had a higher share of renters that are extremely low-income households. Those same jurisdictions also had higher percentage of multi-family units that ranged from 2-4 units and that had 5+ units, as seen on Housing Element Table 2-4. Figure 9, COG Geography TCAC/HCD Opportunity Areas, 2023, shows that the southeast portion of the county contains high segregation and poverty.

The County also has a significant need for dependent care and support systems for young children and

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 103 youth, farm worker housing and housing appropriate for large families.

The Kings County Community Development Agency will include stakeholders and community-based organizations to advise the county on developing and implementing various Housing Element programs.

The Kings County Community Development Agency will actively participate in the county’s efforts prioritize and implement the following strategies:

Research, identify, and apply for funds available through the CDBG and HOME Programs, Mobile home Park Rehabilitation and Resident Ownership Program (MPRROP), United States Department of Agriculture (USDA), Cap-and-Trade Program, and other funding sources that support affordable housing development and preservation, infrastructure investment, energy efficiency, homeownership, code enforcement, farmworker housing, etc.

Implement the following Housing Programs:

Program 4.1 - Code Enforcement Program
Program 4.2 - Housing Rehabilitation Program
Program 4.3 - Preservation of At-Risk Affordable Housing Program 4.4 - Adequate Sites
Program 4.5 - First-Time Homebuyer Program
Program 4.6 - Section 8 Rental Assistance
Program 4.7 - Foster Youth Transitional Program
Program 4.8 - Emergency Shelters and Transitional/Supportive Housing Program 4.9 - Mobile Home/Manufactured Housing
Program 4.10 - Farmworker and Employee Housing
Program 4.11 - Housing for Persons with Disabilities
Program 4.12 - Promote Equal Housing Opportunities
Program 4.13 - Assist Affordable Housing Development
Program 4.14 - Energy Conservation and Greenhouse Gas/Particulate Matter Reduction Program 4.15 - Weatherization and Energy-Efficient Home Improvements Program 4.16 - Single Room Occupancy (SRO) Housing
Program 4.17 - Promote Fair and Balanced Fee Structures Program 4.18 – Infrastructure Improvements to Facilitate Housing for Lower and Moderate-Income Households and Special Needs Population
Program 4.19 –Prior Identified Sites in Site Inventory
Program 4.20 – Ensure the General Plan and Zoning Ordinance is in Compliance with State Laws Program 4.21 – Housing No Net Loss Program and Replacement Housing Program Program 4.22 – ADU Outreach Meeting and Incentives

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 104 Program 4.23 – Development of Extremely Low Income Housing Program 4.24 – Regional Collaboration on Housing Opportunities Program 4.25 – Attainment of Infrastructure
Housing Element Appendix B: Land Inventory, Table B 4 reflects that the sites identified to meet the County’s RHNA are at all income levels. The RHNA sites are generally accommodated throughout the County administered areas and are not concentrated in areas with high racial or ethnic populations, persons with disabilities, female-headed households, senior households, or LMI households. For these reasons, the County finds that the sites proposed to accommodate its RHNA allocation do not unduly burden existing areas of concentrated racial or ethnic homogeneity, poverty, or other characteristics. Moreover, the sites affirmatively further fair housing by helping to stimulate investment in areas where additional opportunities are desired, and where new residential and/or mixed-use development can help to improve some of the opportunity level characteristics discussed earlier in this chapter.

Further, an emphasis on increasing access in primarily single-family neighborhoods through ADUs, SB 9 units, and alternative housing types as discussed in the Housing Plan will increase opportunities in areas where single family neighborhoods coincide with higher-than-average income levels, areas of opportunity, and lower diversity.

Table 21: Census-Tract-wise Resource Opportunities
Characteristics Census Tract 5 Census Tract 11 Census Tract 16.01 TCAC/HCD Opportunity
Areas
High
Resource
Low Resource Moderate Resource
Figure 5
Local Median Income
$60,000 - $84, 097 < $35,000 $35,000 - $60,000
Figure 6
Poverty Status
10% - 20% 30% - 40% 20% - 30%
Figure 2:

Local Racial Demographics
Racially Integrated Low-Medium Segregation High POC Segregation Local RCAAs Not a RCAA Not a RCAA Not a RCAA
Figure 7:

Single Parent Female Headed
Households with Children
Less than 20% 20% - 40% 20% - 40%
Figure 8: Population with a
Disability < 10% 10% - 20% < 10%
Figure 13: Jobs Within 45-
Minute Transit Commute
1-2,500 1-2,500
Figure 19-A:

CalEnviroScreen 4.0
> 75% - 100% > 75% - 100% > 75% - 100%
Figure 19-B:

Flood Hazard Zones
No identified flood hazard No identified flood hazard
Areas of 1% Annual
Chance Flood Hazard

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 105 Figure 15:

Overcrowded Units

5.19% - 10% 15% - 20% 15% - 20%
Figure 15:

Severely Overcrowded Units < 2.5% < 2.5% 2.5%-6.5%
Figure 16:

Overpayment by Renters 40% - 60% 40% - 60% < 20%
Figure 17: Percentage of
Homeowners Overpaying
20%-40% 40%-60% < 20%
Figure 18: Estimated
Displacement Risk Lower Displacement Risk At Risk of Displacement Lower Displacement Risk Table 22: Distribution of Sites by Census Tract
Sites Distribution Census Tract 5
(Armona Community)
Census Tract 11
(Home Garden
Community)
Census Tract 16.01
(Stratford Community
& Kettleman City
Community)
Low Income
89 units
6% of total units
103 units
7% of total units
99 units
7% of total units
Moderate Income
222 units
16% of total units
57 units
4% of total units
110 units
8% of total units
Above Moderate Income
302 units
22% of total units
43 units
3% of total units
30 units
2% of total units
Total Units Identified 1,398 units
Regional Discussion
The identified sites are located in zoning districts that allow residential development by right or with minimal entitlement requirements. High- and medium-density zones such as RM, R-1-6, and R-1-8 provide opportunities for housing at densities consistent with accommodating lower income units. The identified sites are concentrated within or adjacent to the four unincorporated Communities of Armona, Home Garden, Kettleman City, and Stratford where water and sewer services are provided.

Overall, the identified sites do not exacerbate any socio-economic patterns.

The Element also describes development standards that ensure feasibility, such as minimum lot sizes, parking requirements, height allowances, and open space ratios, with reference to the Kings County Development Code. These standards have been reviewed to confirm that they do not unreasonably constrain development potential on sites listed for lower income housing.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 106 Local Discussion
Census Tracts
Census Tract 5. The Armona Community and Grangeville rural interface areas are the only areas designated as a High Resource area. It is also racially integrated. It is the highest percentile bracket of the CalEnviroScreen 4.0 score measuring environmental hazard risk. This census tract is not within a flood hazard zone. One of the disadvantages of living in this census tract is renters are overpaying by 40% - 60%.

There is lower displacement risk here. There are 613 housing units here (89 lower income units, 222 moderate income units, and 302 above moderate income units).

Census Tract 11. The Home Garden Community is within Census Tract 11. This area is designated as a Low Resource area, and there is low-medium segregation. There is 30% - 40% poverty status and the local median income is > $35,000. It is the highest percentile bracket of the CalEnviroScreen 4.0 score measuring environmental hazard risk. This census tract is not within a flood zone. Disadvantages to living in this census tract are both 40% - 60% of renters and homeowners are overpaying, and this area is designated as At Risk of Displacement. There are 203 housing units in this Census Tract: 103 lower income units, 57 moderate income units, and 43 above moderate income units.

Census Tract 16.01. The area is identified as a Moderate Resource. It is also an area identified as High POC Segregation. It is in the highest percentile bracket of the CalEnviroScreen 4.0 score that measures environmental hazard risk. Portions of this Census Tract are located within Areas of 1% Chance Flood Hazard zone. One of the disadvantages of this area is that it does not provide access to employment opportunities within a 45-minute commute. There are 239 housing units here with 99 lower income units, 110 moderate income units, and 30 above moderate income units.

Communities
The identified units are distributed throughout the Communities in a manner that does not create concentrations of lower income units in a particular area. Home Garden, Stratford, and Kettleman City have a proportionate distribution of units across all three income levels. All four Communities have approximately 7% of the total identified sites designated for lower income, showing that each Community has an even distribution. Armona Community has a higher distribution of moderate and above moderate units than the other Communities at 16% (moderate income) and 22% (above moderate income) of total identified sites. The County’s most recent housing tract developments (Armona North and Summers Pointe) have been in the Armona Community, providing moderate and above moderate units and additional lower income units have been achieved through Density Bonus agreements. Overall, the identified sites do not exacerbate any socio-economic patterns.

Armona Community. Identified sites by income group are generally equitably distributed throughout the Armona Community and minimally impact the socioeconomic patterns within the Community. For

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 107 example, there are 13 lower units, 145 moderate units, and 30 above moderate units in the northeast quadrant, compared to 0 lower units, 11 moderate units, and 8 above moderate units in the northwest quadrant, 76 lower units, 42 moderate units, and 139 above moderate units in the southwest quadrant, and 0 lower units, 21 moderate units, and 26 above moderate units in the southeast quadrant. The southeast quadrant has limited room for growth as it is bounded on the east by the City of Hanford and Armona’s wastewater services to the south. The northeast quadrant has more room for growth to the north, even though it is also bounded by the City of Hanford to the east. The northwest quadrant has limited room for growth due to the location of a cemetery to the north. Lower income units are more centrally located as higher density and infill units, and the moderate and above moderate units are located around the outer portions of the Community, but this does not largely impact the socioeconomic patterns of the Community.

Home Garden Community. Identified sites by income group are generally equitably distributed throughout the Home Garden Community and minimally impact the socioeconomic patterns within the Community.

For example, the area west of 10th Avenue has 88 lower units, 46 moderate units, and 23 above moderate units, compared to the area east of 10th Avenue, which has 15 lower units, 11 moderate units, and 13 above moderate units. This does not impact socioeconomic patterns because of the small size of the Community at approximately 0.4 square miles.

Kettleman City Community. All units but one are located on the west side of Highway 41. The one unit on the east side of Highway 41 is in the lower income category. On the west side of Highway 41, there are 36 lower units, 21 moderate units, and 15 above moderate units. Additional growth is discouraged from the east side of Highway 41 for safety of the community and access to amenities. The distribution of units does not impact socioeconomic patterns because of the small size of the residential portion of Community at approximately 0.2 square miles.

Stratford Community. Identified sites by income group are generally equitably distributed throughout the Stratford Community and minimally impact the socioeconomic patterns within the community. Due to Highway 41 running diagonally along the western border and the Stratford Canal running diagonally along the eastern border, Stratford is a triangular shape, and the bottom two-thirds of the Community (the wider portion of the triangle) contains the majority of the units. Only 3 moderate units are located in the top portion of the triangle. This largely does not impact socioeconomic patterns because of the triangular shape and small size of the Community at approximately 0.6 square miles.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 108 Identification of Contributing Factors and Fair Housing Priorities & Goals
The December 2015 Affirmatively Furthering Fair Housing Rule Guidebook published by HUD identifies examples of contributing factors by each fair housing issue area: outreach, fair housing Local Assessment of Fair Housing , segregation and integration, racially and ethnically concentrated areas of poverty, disparities in access to opportunity, disparities in access to opportunities for persons with disabilities, disproportionate housing needs, including displacement risks, and sites inventory.

The County supports the recommendations of the 2014 San Joaquin Valley Fair Housing and Equity Assessment (FHEA) that was prepared by the California Coalition for Rural Housing. The FHEA analyzes patterns in racial and economic segregation, discusses how segregation impacts individuals’ and families’ ability to access housing opportunity, and proposes strategies and recommendations to create more equitable and integrated communities.

Based on the issues identified in this Fair Housing Analysis, the following are the top 5 issues to be addressed through the programs in the Housing Plan:

1. Maintaining and preserving the existing affordable housing stock;

2. Assisting in the provision of housing;

3. Removing governmental constraints, as necessary;

4. Providing adequate sites to achieve a variety and diversity of housing; and

5. Promoting equal housing opportunity.

After considering these issues and FHEA recommendations, the County has identified in Table 23 potential contributing factors to fair housing issues in unincorporated Kings County and outlines the meaningful actions to be taken. The meaningful actions listed in the Table relate to the actions identified in the Housing Element.

Table 23: Factors Contributing to Fair Housing Issues
AFH Identified Fair Housing
Issue Contributing Factors Priority Meaningful Actions
Limitations in local Consolidated
Planning Processes, ongoing CDBG
and HOME funding allocations,
Housing Elements Processes, and
other city planning documents.

Existing low-density
residential development
under general plan and
zoning code
Gap between low density
and medium density and
high-density classification
High Program 4.13 Assist Affordable
Housing Development: Through
direct financial assistance such as
CDBG and HOME, priority
entitlement processing, regulatory
incentives such as density bonus
and modified development
standards,
Assist in the provision of housing by
removing government constraints and
promoting equal housing opportunity
Limitations in zoning code
and density classifications
Permission of pre-approved
design, and development
standards
High Program 4.13 Assist Affordable
Housing Development: Through
direct financial assistance such as
CDBG and HOME, priority
entitlement processing, regulatory
incentives such as density bonus
and modified development
standards, administrative support
to developers on grant
applications.

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 109 Programs 4.6 Section 8 Rental
Assistance
Program 4.8 Emergency Shelters
and Transitional/Supportive
Housing
Program 4.9
Mobile/Manufactured Housing),
Program 4.10 Farmworker and
Employee Housing
Program 4.11 Housing for Persons
with Disabilities
Program 4.16 SRO Housing
Funding for marginalized or
distressed communities, such as
Transit Oriented Development Funds,
Strategic Growth
Council grants, HCD's HousingRelated Parks Program, Safe Routes to School, and Brownfield funding.

Ensuring funding is available
for marginalized and
distressed community
High Research, identify, and apply for
funds available through the
CDBG and HOME Programs,
Mobile home Park Rehabilitation
and Resident Ownership Program
(MPRROP), United States
Department of Agriculture
(USDA), Cap-and-Trade Program,
and other funding sources that
support affordable housing
development and preservation,
infrastructure investment, energy
efficiency, homeownership, code
enforcement, farmworker housing,
etc.

Program 4.5 First-Time
Homebuyer Program
Program 4.6 Section 8 Rental
Assistance
Program 4.14 Energy
Conservation and Greenhouse
Gas/Particulate Matter Reduction

4.15 Weatherization and EnergyEfficient Home Improvements

4.25 Attainment of Infrastructure
Provide guidance for site selection of
affordable housing developments.

Housing Element identifies
adequate sites to accommodate
the City’s share of the
Regional Housing Needs
Allocation of 561 units
High Program 4.4 Zoning for Adequate
Sites: Adequate sites are those with
sufficient development and density
standards, water and sewer
services, and adequate
infrastructure.

Develop a program to educate and
encourage landlords to accept
Housing Choice Vouchers.

Lack of readily available
information regarding fair
housing resources and
assistance to persons in filing a
complaint
Lack of education of public
High Program 4.12 Promote Equal
Housing Opportunities

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 110 and housing providers
regarding rights and
responsibilities under the AFH
and FEHA
Develop and implement a proactive
code enforcement program that holds
property owners accountable and
proactively plans for resident
relocation when necessary.

Code enforcement High Program 4.1 Code Enforcement,

4.2 Housing Rehabilitation
Program
Prioritize basic infrastructure
improvements like water, sewer, and
streetlights.

Ensuring availability of basic
infrastructure to proposed
development of lower-income
households
High Program 4.17 Promote Fair and
Balanced Fee Structures
Program 4.18 Infrastructure
Improvements to Facilitate Housing
for Lower and Moderate-Income
Households and Special Needs
Populations
Program 4.25 Attainment of
Infrastructure
Disproportionate Housing Needs,
including Overpayment and
Substandard Housing
Ongoing need for affordable
housing
Need for assistance with
monthly housing costs
Lack of local information
regarding available housing
rehabilitation, emergency
repair, and weatherization
programs
Need for targeted housing
revitalization strategies
Medium Program 4.6 Section 8 Rental
Assistance
Program 4.7 Foster Youth
Transitional Program
Program 4.8 Emergency Shelters
and Transitional/Supportive
Housing
Program 4.10 Farmworker and
Employee Housing
Program 4.11 Housing for Persons
with Disabilities
Program 4.16 Single Room
Occupancy (SRO) Housing
Use design tools to seamlessly
integrate affordable housing
development into larger mixedincome developments.

Limitations in zoning code and
density classifications ·
Approval process
Medium Program 4.13 Assist Affordable
Housing Development: The County
promotes the development of
housing for extremely-low-, verylow-, low- and moderate-income persons through direct financial
assistance such as CDBG and
HOME, priority entitlement
processing, regulatory incentives
such as density bonus and modified
development standards,

APPENDIX 1: COUNTY OF KINGS FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 111 Displacement Risk Land use and zoning laws
Displacement of residents due
to economic pressures
Medium Program 4.3 Preservation of AtRisk Affordable Housing

Kings County Corcoran Hanford Avenal Kings (Unincorporated)

APPENDIX D2: CITY OF AVENAL

FAIR HOUSING ANALYSIS
April 2026
Prepared By:

Realty Planners Group
City of Avenal Staff
Kings County Corcoran Hanford Avenal Kings (Unincorporated)

APPENDIX D2: TABLE OF CONTENTS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | ii APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
Table of Contents
A. Local Assessment of Fair Housing 1
Introduction 1
Outreach Program 2
B. Assessment of Fair Housing Issues 3
Key Data and Background Information 3
Fair Housing Enforcement Outreach Capacity 5
Local Patterns of Integration and Segregation 9
Disparities in Access to Opportunities 35
Disproportionate Housing Needs and Displacement Risk 49 C. Constraints 62
Governmental Constraints 62
Non-Governmental Constraints 65
Environmental Health 66
D. Local Data, Knowledge, and Other Relevant Factors 72 Segregation and Integration 72
Disparities in Access to Opportunities 73
Disproportionate Housing Needs, Including Displacement 75 Other Relevant Factors Influencing Fair Housing Conditions 77 E. Sites Analysis 78
Redevelopment Potential of Non-Vacant Sites 82
Infrastructure and Public Services Availability 83
Small Sites Analysis 83
Sites Inventory Findings 83
Identification of Contributing Factors and Fair Housing 87 Attachment: City of Avenal Questionnaire to City Staff 91

APPENDIX D2: TABLE OF CONTENTS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | ii Tables
Table 1: Kings County Household Population Growth, 1990-2020 5 Table 2: City of Avenal Fair Housing Compliance 7
Table 3: Race and Ethnicity 11
Table 4: Population by Race by Hispanic Origin Over Time 11 Table 5: Household Income Distribution by Tenure 18
Table 6: Median Household Income by Race or Hispanic Origin 18 Table 7: Total Households in Poverty 20
Table 8: Households in Poverty Over Time, City of Avenal 20 Table 9: Households Characteristics 22
Table 10: Household Type by Tenure 23
Table 11: Households by Size 24
Table 12: Tenure by Household Size 25
Table 13: Female-Headed Households 25
Table 14: Population by Age Groups (Total) 27
Table 15: Senior Households by Tenure Over Time 28
Table 16: Percentage of Persons with Disability Type by Age 32 Table 17: People with Developmental Disabilities – Age 32 Table 18: Agricultural Employment by Jurisdiction 33
Table 19: Hired Farm Labor-Workers, Kings County 34
Table 19: Travel Time to Work 43
Table 20: Work Locations of City/County Resident Workers 43 Table 21: Agricultural Employment by Jurisdiction 45
Table 22: Hired Farm Labor-Workers, Kings County 45
Table 23: Household Overpayment by Tenure 50
Table 24: Overcrowding by Tenure 53
Table 25: Homeless Persons 57
Table 26: Shelter Facilities in Kings County 58
Table 27: Extremely Low Income Households Overpaying by Tenure in Avenal 59 Table 28: Land Inventory and RHNA Targets 83
Table 29: Characteristics by City of Avenal Census Tracts 85 Table 30: Identified Sites and Affirmatively Furthering Fair Housing (AFFH) 86 Table 31: Factors Contributing to Fair Housing Issues 88

APPENDIX D2: TABLE OF CONTENTS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | ii Figures
Figure 1: Kings County 4
Figure 2: Local Racial Demographics 12
Figure 3: Racial/Ethnic Area of Concentration of Poverty (R/ECAP) 15 Figure 4: Local RCAAS 16
Figure 5: Local Median Income 2021, Census Tract 19
Figure 6: Avenal Poverty Status – Census Tracts 21
Figure 7: Single-Parent Female-Headed Households with Children 26 Figure 8: Senior (65 Years of Older) Households by Household Income (2020) 28 Figure 9: Population with a Disability 31
Figure 10: TCAC/HCD Opportunity Areas, 2023 37
Figure 11: City of Avenal All Transit Performance Score 39 Figure 12: High Quality Transit Stops and Transit Area (1/2 Mile) 40 Figure 13: Employment by Industry of Kings County Workforce 42 Figure 14: Jobs within 45-Minute Transit Commute 44
Figure 15: School Districts in Kings County 48
Figure 16: Overpayment by Renters (ACS, 2017-2021) – Tract Level 51 Figure 17: Percentage of Homeowners Overpaying 52
Figure 18: Overcrowding in the City of Avenal 54
Figure 19: Estimated Displacement Risk – Overall Displacement by Tract 61 Figure 20: CalEnviroScreen 4.0 70
Figure 21: Flood Hazard Zones 71
Figure 22: City of Avenal Vacant Sies 6,000 Square Feet or Greater 79 Figure 23: City of Avenal Vacant Sites by Income Level 80 Figure 24: City of Avenal by Block Groups 81
Figure 25: Low to Moderate Income Population by Block Group 82

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 1 A. Local Assessment of Fair Housing
Introduction
Assembly Bill (AB) 686 requires that all housing elements due on or after January 1, 2021, contain an Assessment of Fair Housing (AFH) consistent with the core elements of the analysis required by the federal Affirmatively Furthering Fair Housing (AFFH) Final Rule of July 16, 2015. Under California law, AFFH means “taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics.”1
California Government Code Section 65583 (10)(A)(ii) requires local jurisdictions to analyze racially or ethnically concentrated areas of poverty and affluence, disparities in access to opportunity, and disproportionate housing needs, including displacement risk. Although this is the Housing Element for the County of Kings, Government Code Section 65583 (c) (10) requires all local jurisdictions to address patterns locally and regionally to compare conditions at the local level to the rest of the region. This section is organized by fair housing topics to address the identified issues which are included throughout the section. Through discussions with housing service providers, fair housing advocates, and this assessment of fair housing issues, the County of Kings identified factors that contribute to fair housing issues.

The AFFH analysis must contain the following:

1. Outreach

2. Assessment of Fair Housing
a. Key Data and Background Information
b. Fair Housing Enforcement and Outreach Capacity
c. Integration and Segregation Patterns and Trends
d. Racially or Ethnically Concentrated Areas of Poverty e. Disparities in Access to Opportunity
f. Disproportional Housings Needs
g. Displacement Risk

3. Sites Inventory

4. Identification
1 California Department of Housing and Community Development, Affirmatively Furthering Fair Housing: Guidance for All Public Entities and for Housing Elements (April 2021 Update), April 27, 2021, preface page, https://www.hcd.ca.gov/community- development/affh/docs/affh_document_final_4-27-2021.pdf.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 2 Outreach Program
State law requires local governments to make a diligent effort to achieve public participation in three formal community meetings to initiate the Housing Element. To that end, each jurisdiction has provided opportunities for residents, interested parties, and local officials to participate in the update process and offer recommendations regarding housing needs and strategies to address those needs.

The public participation process for this Housing Element involved four major stages:

1. Public workshops and meetings in each of the four cities and the unincorporated County during the preparation of the Draft Housing Element.

2. Publication of the Draft Housing Element and subsequent review by the California Department of Housing and Community Development (HCD).

3. Revisions to the Housing Element to address comments from HCD and publication of a revised Draft Housing Element.

4. Public hearings before the Planning Commission and City Council of each city and the Planning Commission and Board of Supervisors of Kings County prior to adoption of the final Housing Element.

City of Avenal Website
City of Avenal website (https://www.cityofavenal.com/212/Community-Development) serves as the main conduit of information for individuals who can access material online. The website is regularly updated to reflect ongoing community input opportunities, advertise draft housing element, and answer commonly asked questions. The website includes the following information:
• Upcoming meeting information
• Housing Element Workshops
• Notices of Public Hearing
• Links to Housing Element and other planning documents General Multi-Lingual Advertisements
The City utilized a variety of methodsto advertise the project, engage the community, and solicit input on the HousingElement and the Fair Housing Analysis (FHA).These efforts are summarized herein to demonstrate the City’s meaningful commitment to community collaboration. The city has prepared workshop flyers (in English and Spanish), and sent emails to stakeholders requesting involvement and providing flyers and outreach information in English and Spanish.

Community Workshop
At the City of Avenal, a public workshop took place during a Town Hall meeting on November 8th, 2023 at 6:00 PM. During the workshop presentation city staff and consultants provided a description of the Housing Element adoption process and timelines for adoption. Consultants and city staff also provided information on RHNA allocations as well as a timeline for adoption

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 3 B. Assessment of Fair Housing Issues
This section provides an overview of available federal, state, and local data to analyze fair housing issues in the City of Avenal. This data is supplemented with local knowledge of existing conditions in the community to present a more accurate depiction of fair housing issues in Avenal, and a more informed perspective from which to base goals, policies, and programs to affirmatively further fair housing. The following issues are addressed:

1. Key Data and Background Information

2. Integration and Segregation Patterns and Trends

3. Racially or Ethnically Concentrated Areas of Poverty

4. Disparities in Access to Opportunity

5. Disproportionate Housing Needs

6. Displacement Risk

7. Local Data Knowledge
Key Data and Background Information
Kings County is located within the agriculturally rich San Joaquin Valley, with Fresno County to the north and west, Tulare County to the east, and Kern County to the south. Created in 1893, Kings County was carved from the western portion of Tulare County and later added another 100 square miles. The Kings River, from which the County derives its name, runs along the northern edges and flows south towards the center of the County. Historically, this river flowed farther south to what was once Tulare Lake Kings County is comprised of four cities (Avenal, Corcoran, Hanford, and Lemoore), four unincorporated community service areas (Armona, Home Garden, Kettleman City, and Stratford), and a few other smaller community pockets. Figure 1 is a map of Kings County and its four cities and unincorporated communities. Agriculture remains the predominant landscape of Kings County, with approximately 84% of its land area used for agriculture.

Avenal has a proud agricultural heritage and is the largest pistachio grower and processor. Wonderful Pistachios employs a majority of Avenal’s agricultural labor. They are a major community partner that has invested in the city including building a pre-school. Before that, the discovery of oil in the early 1900s transformed Avenal into a boomtown and the Standard Oil Company invested in the community including a hospital and theater. In the 1950s, the oil money and Avenal’s growth started to dwindle.

Then in the 1970’s, the California Aqueduct project was completed and the agricultural sector grew.

Today, the City of Avenal aims to be a caring community that provides an oasis of opportunities for all to prosper.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 4 Figure 1: Kings County

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 5 Table 1 provides data on the growth of the household population in Avenal and Kings County over a thirty-year period. In Avenal, the household population increased, starting from 5,505 in 1990 and rising to 9,406 by 2020. This growth represents an addition of 3,901 persons, or a 70.9% increase in population over three decades. Comparatively, Kings County also experienced population growth, but at a much slower rate, 53.1%. This data highlights that Avenal’s population growth significantly outpaced that of the overall county, marking it as a key area of demographic change within Kings County. This rate of growth is significantly higher than the overall growth rate in Kings County during the same period. The county's household population grew from 89,469 in 1990 to 136,964 in 2020, an increase of 47,495 persons or 53.10%. The data highlights Avenal's notable population growth, which outpaced the average growth rate in Kings County.

Table 1: Kings County Household Population Growth, 1990-2020 Jurisdiction
Household Population Change 1990-2020
1990 2000 2010 2020 Persons %
Avenal 5,505 7,973 9,082 9,406 3,901 70.9%
County Totals 89,469 109,332 131,402 136,964 47,495 53.10% Note: All numbers exclude persons in group quarters (State prisons and Naval Air station Lemoore) ; Sources:

Census 1990, 2000, 2010; Cal.DOF, , E5 and E8 Population and Housing Estimates.

Fair Housing Enforcement Outreach Capacity
Equal access to housing is fundamental to each person being able to meet essential needs and to pursuing personal, educational, employment, or other goals. In recognition of equal housing access as a fundamental right, the governments of the United States and the State of California have both established fair housing as a right protected by law. Federal fair housing laws prohibit discrimination in the sale, rental, lease, or negotiation for real property based on race, color, religion, sex, national origin, familial status, and disability. The California fair housing laws are built upon the federal laws and add marital status, ancestry, source of income, sexual orientation, and “any arbitrary factor” as protected categories under the laws.

Many factors in the public and private domains impede equal access to housing or fair housing choice.

Impediments to fair housing choice are:
• Any actions, omissions, or decisions taken because of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, source of income, sexual orientation, or any other arbitrary factor which restrict housing choices or the availability of housing choices; or • Any actions, omissions, or decisions which have the effect of restricting housing choices or the availability of housing choices on the basis of race, color, ancestry, national origin, religion, sex, disability, marital status, familial status, source of income, sexual orientation, or any other arbitrary factor. To affirmatively promote equal housing opportunity, a community must work to remove or mitigate impediments to fair housing choice. The City of Avenal is dedicated to providing fair housing opportunities to all residents and to ensure that all applicable laws are complied with throughout the city
The City of Avenal provides resources and programs to address fair housing concerns. Table 2 a discusses

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 6 laws and compliance regarding fair housing. Further discussion of programs is found in the Kings County Multi-Jurisdictional Housing Element and in the Contributing Factors section of this Fair Housing Analysis (FHA).

An essential component of affirmatively furthering fair housing is the jurisdiction’s demonstrated capacity to conduct enforcement, offer outreach services, and respond meaningfully to incidents of housing discrimination. Kings County and its cities must assess and describe their institutional mechanisms for investigating fair housing complaints, obtaining remedies, and engaging in proactive testing or compliance activities. This includes identifying which agencies, nonprofit organizations, or legal assistance providers are responsible for handling discrimination allegations under state and federal fair housing laws. For instance, organizations such as California Rural Legal Assistance (CRLA), the Fair Housing Council of Central California, or the Department of Fair Employment and Housing (DFEH) may serve residents in the area, but the scope and availability of these services across rural and urban zones must be documented.

Additionally, jurisdictions must provide data on the number and nature of complaints received during the previous planning period—disaggregated, where possible, by protected characteristics such as race, disability, familial status, and national origin—and indicate whether resolutions were achieved through legal settlements, administrative findings, or other remedies. Geographic patterns of complaints, such as concentrations in certain neighborhoods or rental sectors, can also reveal systemic disparities. Any ongoing or resolved lawsuits, judgments, or fair housing compliance agreements (e.g., with HUD or state agencies) should be disclosed, as they demonstrate the region’s legal history and responsiveness to violations. Beyond enforcement, outreach activities—including multilingual tenant rights workshops, housing assistance clinics, or distribution of printed materials—must be evaluated for their reach, accessibility, and frequency.

Effective outreach is especially critical in areas with high percentages of non-English-speaking residents, undocumented populations, or persons with disabilities. The cumulative analysis of enforcement infrastructure, legal compliance history, complaint resolution data, and outreach coverage will establish whether Kings County is adequately equipped to protect fair housing rights and respond to discrimination in a timely and equitable manner.

The City of Avenal provides enforcement and outreach services with regard to affirmatively furthering and ensuring that fair housing practices are followed within the City. The City Clerk is the designated individual to receive and refer fair housing questions and complaints to the Department of Fair employment and Housing office in Fresno. In addition, information regarding fair housing practices and concerns is provided on the City website as well as displayed in public offices. During the previous planning period, the City did not receive any complaints regarding the provision of equal housing opportunities. Further the City is not aware of any fair housing lawsuits, findings, settlements, or judgements that occurred during the previous planning period. However, in order to continue this trend of zero complaints received, Program

1.16 has been created, which provides meaningful actions addressing fair housing issues and contributing factors.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 7 Table 2: City of Avenal Fair Housing Compliance
Law Description Compliance
California Fair
Employment and
Housing Act
(FEHA)
The Fair Employment and Housing Act (FEHA)
applies to public and private employers, labor
organizations and employment agencies and
prohibits discrimination in housing and
employment on the basis ofprotected
characteristics.

The FEHA prohibits those engaged in
the housing business – landlords, real
estate agents, home sellers, builders,
mortgage lenders, among others – from
discriminating against tenants or
homeowners based on protected
characteristics.

It is also illegal for cities, counties, or other
local government agencies to make zoning or
land-use decisions, or have policies, that
discriminate against individuals based on those
traits.

The city complies with employment
requirements through strict
enforcement of hiring practices and
regular training of hiring managers and
human resources staff.

All development projects with City
funding are required to comply with
FEHA.

Government Code
Section 65008
Covers actions of a city, county, city and
county, or other local government agency,
and makes those actions null and void if
the action denies an individual or group of
individuals the enjoyment of residence,
landownership, tenancy, or other land use
in the state because of membership in a
protected class, the method of financing,
and/or the intended occupancy.

For example, a violation under Government
Code section 65008 mayoccur if a
jurisdiction applied more scrutiny to
reviewing and approving an affordable
development as compared to market-rate
developments, or multifamily housing as
compared to single family homes.

Compliance is achieved by uniform
application of the City’s codes,
regulations, policies and practices,
including development standards,
design guidelines, application
submittal requirements, fees and
approvalfindings.

Avenal supports the recommendations
of the San Joaquin Valley Fair Housing
and Equity Assessment and cooperates
with the State in the development of the
Assessment of Fair Housing.

Government Code
Section 8899.50
Requires all public agencies to administer
programs and activities relating to housing and
community development in a manner to
affirmatively further fair housing and avoid
any action that is materially inconsistent with its
obligation to affirmatively further fair housing.

Compliance is achieved through
consultations with community
stakeholders and support agencies as partof
program evaluation and funding decisions.

Government Code
Section 11135 et
seq.

Requires full and equal access to all programs
and activities operated, administered, or funded
with financial assistance from the state,
regardless of one’s membership or perceived
membership in a protected class.

Compliance is achieved through
promotion/availability of activities and
programs to all persons of all
backgrounds to participate equally in
community programs and activities.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 8 Housing
Accountability Act
(Gov. Code, §
65589.5.)
Provides that a local agency shall not
disapprove a housing development project, for
very low, low-, or moderate-income
households, or an emergency shelter, or
condition approval in a manner that renders the
housing development project infeasible for
development for the use of very low, low-, or
moderate-income households, or an emergency
shelter, including through the use of design
review standards, unless it makes certain written
findings, based upon a preponderance of the
evidence in the record.

Compliance is achieved through the
development review process consistent
with the Housing Accountability Act.

Additionally, the city continually reviews
its development standards and to ensure
they facilitate an objective and equitable
review of applicable projects.

Excessive
Subdivision
Standards (Gov.

Code, § 65913.2.)
Provides that, in exercising its authority to
regulate subdivisions a city, county, or city
and county shall:
a) Refrain from imposing criteria for
design, as defined in Section 66418, or
improvements, as defined in Section
66419, for the purpose of rendering
infeasible the development of housing
for anyand all economic segments of
the community. However, nothing in
thissection shall be construed to enlarge
or diminish the authority ofa city,
county, or city and county under other
provisions of law to permit a developer
to construct such housing.
b) Consider the effect of ordinances adopted
and actions taken by itwith respect to
the housing needs of the region in
which the local jurisdiction is situated.
c) Refrain from imposing standards and
criteria for public improvements
including, but not limited to, streets,
sewers, fire stations, schools, or parks,
which exceed the standards and criteria
being applied by the city, county, or city
and county at that time to itspublicly
financed improvements located in
similarly zoned districts within that
city, county, or city and county.

Compliance is achieved through the
implementation of a fair and equitable
development review process whichis
administrated consistent with the
Excessive Subdivision Standards Act.

Housing Element
Law (Gov. Code, §
65583, esp. subds.
(c)(5), (c)(10).)
Section 65583 stipulates that the housing
element shall consist of an identification and
analysis of existing and projected housing
needs and a statement of goals, policies,
quantified objectives, financial resources, and
scheduled programs for the preservation,
improvement, and development of housing.

The housing element shall identify adequate
sites for housing, including rental housing,
factory-built housing, mobile homes, and
emergency shelters, and shall make adequate
Compliance is achieved through
preparation and adoption of a Housing
Element found to be in substantial
compliance with State Housing Element
lawby the California Department of
Housing and Community Development.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 9 provision for the existing and projected needs
of all economic segments of the community.

Subdivision (c)(5) provides that, in order to
make adequate provisionfor the housing needs
of all economic segments of the community,
the program shall promote and affirmatively
further fair housing opportunities and
promote housing throughout the community
or communitiesfor 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.

The City of Avenal affirms its commitment to fair housing through compliance with federal and state laws prohibiting discrimination based on race, color, religion, sex, national origin, familial status, disability, marital status, ancestry, source of income, sexual orientation, or any arbitrary characteristic. As described in Program 1.16: Promote Equal Housing Opportunities, the City continues to disseminate fair housing information in English and Spanish at City Hall, the library, and other public venues, and refers inquiries or complaints to the California Civil Rights Department (formerly DFEH) in Fresno. While this referral process aligns with basic legal obligations, the City does not currently conduct internal investigations, maintain complaint databases, or engage in fair housing testing, instead relying on external agencies for enforcement and resolution.

The City maintains compliance with the California Fair Employment and Housing Act (FEHA), Government Code §65008, and §8899.50, applying non-discrimination policies uniformly in zoning, permitting, and publicly funded housing projects. Training for staff ensures ongoing adherence to these laws. The City has also supported regional efforts such as the San Joaquin Valley Fair Housing and Equity Assessment (FHEA), and continues to promote equitable housing practices through Program 1.1 (Code Enforcement) and outreach related to voucher acceptance and funding for lower-income neighborhoods.

Local Patterns of Integration and Segregation
To develop priorities, policies, and actions, an analysis of integration and segregation, including patterns and trends, related to people with protected characteristics was prepared. Segregation generally means a condition in which there is a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area. Conversely, integration refers to a condition in which there is a not a high concentration of persons of a particular race, color, religion, sex, familial status, national origin, or having a disability or a particular type of disability when compared to a broader geographic area. The following analysis will analyze levels of segregation and integration for race and ethnicity, persons with disabilities, familial status, age, and income to identify the groups in Avenal that experience the highest levels of segregation.

Minorities are often concentrated in impoverished areas and lack access to resources such as jobs,

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 10 educational opportunities, life services and face other disadvantages.

The City of Avenal's Housing Element includes comprehensive data and maps across key components of the Fair Housing Analysis (FHA). This includes local patterns and trends related to segregation/integration, access to opportunity, and disproportionate housing needs. The Element evaluates racial and ethnic demographics, revealing that 87.0% of Avenal’s population identifies as Hispanic or Latino, a notably higher concentration compared to 54.9% countywide, indicating racial/ethnic clustering. Census Tracts

17.02 and 17.03 are identified as areas of high segregation and poverty, reflecting persistent disparities.

Patterns of disproportionate housing needs are evident in high overcrowding and cost burden rates. In 2020, 17% of Avenal households lived in overcrowded conditions, with renter households especially affected (13.8% had 1.01 to 1.5 occupants per room). HUD CHAS data show that over 50% of very-low and extremely-low-income renters and owners were overpaying for housing. Overpayment varies geographically, with renters in central tracts experiencing rates above 40%.

Access to opportunity also varies significantly. TCAC/HCD Opportunity Area maps identify Avenal’s tracts as “moderate resource” or “high segregation and poverty,” with limited access to jobs (fewer than 2,500 within a 45-minute transit commute in most areas) and high scores on CalEnviroScreen (75–100%) suggesting environmental burdens. Educational access indicators such as on-time graduation and test proficiency are lower than regional averages, further emphasizing limited opportunity access.

Race and Ethnic Characteristics
The racial and ethnic composition of Avenal and Kings County, as indicated by the Census ACS 2016-2020 data and presented in Table 3, shows a distinct demographic profile. In Avenal, a significant majority of the population, 87.0%, identifies as Hispanic or Latino, which is notably higher than the percentage in Kings County at 54.9%. This indicates a strong Hispanic or Latino presence in Avenal's community. The nonHispanic or Latino population in Avenal is comparatively smaller, at 13.0%, which is significantly lower than the 45.10% in Kings County. Breaking this down further, only 8.4% of Avenal’s population is White (non-Hispanic or Latino), in contrast to Kings County's 31.6%. Similarly, other racial groups such as Black or African American, American Indian/Alaska Native, Asian, Native Hawaiian/Pacific Islander, and those identifying as other races or with two or more races, have a lesser representation in Avenal compared to Kings County.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 11 Table 3: Race and Ethnicity
Racial /Ethnic Group Avenal Kings County
Not Hispanic or Latino 13.0% 45.1%
White 8.4% 31.6%
Black or African American 3.3% 5.9%
American Indian/Alaska Native 0.4% 0.8%
Asian 0.3% 3.6%
Native Hawaiian/Pacific Islander 0.1% 0.1%
Other races or2+ races 0.5% 3.2%
Hispanic or Latino (any race) 87.0% 54.9%
Total 100% 100%
Source: Census ACS 2016-2020, Table B03002
From the span of 2000 to 2020, the Hispanic or Latino of Any Race population count increased by

19.4% (Table 4). There was a larger increase of the Hispanic or Latino of Any Race population between 2000-2010 than there was between 2010 to 2020. The inverse took place with the White Alone NonHispanic between 2000 to 2020, however the 41.1% percentage decrease is more significant. There is an extremely significant drop in the Black or African American Alone Non-Hispanic from 2000 to 2020. In 2000, there were 1,808 individuals which dropped by a few hundred in 2010. Then from 2010 to 2020, there was a large drop from 1,540 to 102 individuals. In the span of 20 years, that is a 94.3% decrease.

Table 4: Population by Race by Hispanic Origin Over Time 2000 2010 2020
Hispanic or Latino of Any Race 9,667 11,130 11,545
White Alone Non-Hispanic 2,923 2,387 1,721
Black or African American Alone Non-Hispanic 1,808 1,540 102 American Indian and Alaska Native Alone Non-Hispanic 79 82 76 Asian Alone Non-Hispanic 54 102 83
Native Hawaiian and Other Pacific Islander Alone Non-Hispanic 2 4 13 Some Other Race Non-Hispanic 26 197 37
Two or More Races Non-Hispanic 115 63 119
Source: U.S. Census Bureau, Census 2000, 2010; Social Explorer Table for Census 2020.

According to Figure 2, there are three partial census tracts (CTs 16.01, 17.01, and 17.02) and the Avenal State Prison (CT 9810) located in the City of Avenal. Only a small portion is within CT 17.02 which is identified as High POC Segregation. Census Tract 9818 lacks data for a lot of other categories in this report but this small area is identified as Racially Integrated.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 12 Figure 2: Local Racial Demographics
\
Source: California Department of Housing and Community Development (HUD); OBI, 2020

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 13 Racially/Ethnically Concentrated Areas of Poverty (R/ECAPs) and Racial Concentration of Areas of Affluence (RCAA)
To better understand fair housing, HUD uses the designation Racially/Ethnically Concentrated Areas of Poverty (R/ECAP) which requires:
• a non-white population of 50 percent or more in a metropolitan or micropolitan area, or a nonwhite population of 20 percent or more outside of these areas. • extreme poverty, defined as census tracts with either 40 percent or more of individuals living at or below the poverty line or with a poverty rate of three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

As illustrated in Figure 3, much of Avenal, particularly CTs 17.02 and 17.03, are identified as R/ECAP areas based on HUD definition. These areas meet the thresholds for both high concentrations of racial/ethnic minorities and households in poverty. As discussed later in the FHA, these census tracts are also categorized as “High Segregation and Poverty” areas under the TCAC/HCD Opportunity Area framework.

The assessment provides a demographic and socioeconomic comparison of these R/ECAP tracts relative to other areas in Avenal. The analysis shows that CTs 17.02 and 17.03 have:
• Poverty rates between 30% and 40%
• Median household incomes ranging from $35,000 to $60,000 • Renter overpayment rates between 40% and 60%
• Higher rates of overcrowding and severe overcrowding, with up to 6.5% of households in severely overcrowded conditions (more than 1.5 persons per room) HCD has a designation called Racial Concentration of Areas of Affluence (RCAA) which is also based on two factors:
• A location quotient based on the percentage of white, non-Hispanic or Latino population in the census tract compared to the average percentage of total white population for the COG region. • If the median income for the census tract is greater than 1.5 times the COG median income or State median income, whichever is lower.

In Figure 4, it is noted that there are no Racially Concentrated Areas of Affluence (RCAAs) identified in the City of Avenal. Typically, RCAAs are found in areas that align with the highest-resource zones as determined by the Tax Credit Allocation Committee (TCAC) and Housing and Community Development (HCD), or in relatively higher-income parts of unincorporated counties.

The City of Avenal has programs to help ensure fair housing opportunities like Program 1.8 First Time Homebuyer Program which provides home ownership opportunities to new low-income homebuyers. It provides up to $130,000 in a deferred silent second loan to subsidize mortgage payments and closing costs.

Program 1.9 Section 8 Rental Assistance extends rental subsidies to extremely-low- and very-low-income households equal to the difference between 30% of the monthly income and the allowable rent determined by the program.

The Housing Element’s assessment further links these disparities with broader community conditions, such as aging housing stock, infrastructure limitations, and access to amenities. These neighborhoods have

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 14 comparatively fewer parks, limited access to high-performing schools, and may lack adequate pedestrian or transit infrastructure—all of which influence quality of life and long-term opportunity.

To address these disparities, the City includes several targeted programs:
• Program 1.1 (Code Enforcement) seeks to proactively identify and remedy substandard housing conditions, with a focus on older neighborhoods that overlap with R/ECAP tracts. • Program 1.2 (Housing Rehabilitation Program) provides financial support for home repairs and safety improvements for lower-income homeowners.
• Program 1.7 (Regulatory and Financial Assistance to Developer of Affordable Housing) assisting developers build affordable housing.
• Program 1.10 (Affordable Housing Assistance) focuses on increasing access to quality, affordable housing in areas of need.
• Program 1.16 (Promote Equal Housing Opportunities) enhances outreach on fair housing rights and services, including multilingual materials and referrals to the Civil Rights Department for investigation of discrimination complaints.

The inclusion of these programs demonstrates the City’s commitment to addressing inequalities within R/ECAP areas and to affirmatively furthering fair housing by improving living conditions, promoting housing stability, and expanding access to opportunity in historically disadvantaged neighborhoods.

The City of Avenal does not exhibit any neighborhoods with disproportionately high or low concentrations of minority residents. In fact, all areas within the city are considered concentrated minority communities.

This uniform distribution of minority populations is a defining feature of Avenal’s residential landscape.

Historically, the city’s demographic pattern was shaped by the rise and fall of the local oil industry. During the mid-20th century, Avenal experienced an economic downturn following the collapse of oil operations, which led to population decline and economic instability. Beginning in the 1960s, the city witnessed a substantial influx of agricultural workers, many of whom were from Latino backgrounds, who repopulated the area and contributed to the city’s current racial and ethnic composition.

These historical economic and migratory patterns have reinforced a consistent racial and ethnic distribution across the city, with no distinct areas of racial segregation or exclusion. The absence of high-income enclaves, limited housing market turnover, and the city’s relatively small geographic size have likely contributed to the maintenance of this uniform demographic structure over time.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 15 Figure 3: Racial/Ethnic Area of Concentration of Poverty (R/ECAP), Source: https://hudgis-hud.opendata.arcgis.com

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 16 Figure 4: Local RCAAs
Source: American Community Survey (ACS), 2015-2019. Updated: March,2021

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 17 Income Distribution
Along with housing prices and rents, household income is the most important factor affecting housing opportunities within Kings County. Housing choices such as tenure (owning versus renting), housing type, and location are dependent on household income. On the other hand, however, household size and type often affect the proportion of income that can be spent on housing.

According to the ACS 2016-2020, the median household income for the entire County was reported as $61,556. In general, the City of Avenal’s median household income is below the county average at $49,781. As seen in Figure 5, the City of Avenal’s median income is between $35,000 and $60,000 (state median income) with a small portion towards the southern tip consisting of income below $35,000.

Avenal’s workforce consists of a larger proportion of individuals that participate in “blue-collar” jobs such as farming, construction, extraction, manufacturing, production, transportation, and material moving compared to other jurisdictions such as Hanford and Lemoore with more "white collar jobs". Although median household income is a common benchmark for comparison, the distribution of household income also provides a useful measure of housing needs in a community. In housing analysis, households are typically grouped into categories, expressed relative to the Area Median Income (AMI) and adjusted for family size. Using State of California income thresholds, the income groups analyzed were as follows:
• Extremely low income: Up to 30% of AMI
• Very low income: 31-50% of AMI
• Low income: 51-80% of AMI
• Moderate income: 81-120% of AMI
• Upper income: Above 120% of AMI
Table 5 estimates the percentage of households by tenure within each income category in each jurisdiction as reported in HUD Comprehensive Housing Affordability Strategy (CHAS) data based on the Census ACS 2014-2018. Countywide, almost one-quarter (24%) of owner households were in the lower-income category (80% or less than the AMI --extremely-low, very-low, and low incomes), while over one-half (55%) of renter households were in the lower-income category. In the City of Avenal, more than 60% of owners belonged to the moderate-income category while more than 80% of the renters were mostly distributed in the moderate income and lower income categories. As witnessed at the county and city levels, renters experience a higher proportion of lower-income households.

At the city level, Avenal and Corcoran had higher percentages of lower-income owner and renter households than those in Hanford and Lemoore. As shown in Table 5, 35% of Avenal owner households and 82% of renter households are in the lower income category. Data from the Census ACS 2016-2020 provides a comparative snapshot of the changes in housing costs over a decade for the City of Avenal, Kings County, and the state of California. In 2010, the median monthly housing cost in Avenal was $669, which rose to $768 in 2015 and then to $840 in 2020, marking a 25.6% increase over ten years. Kings County saw a rise from $960 in 2010 to $978 in 2015, reaching $1,094 by 2020, which is a 14.0% increase.

In comparison, California's median housing costs started at $1,409 in 2010, slightly increased to $1,419 in 2015, and jumped to $1,688 by 2020, resulting in a 19.8% rise. These figures indicate that while Avenal experienced the highest percentage increase in housing costs, it remains substantially lower in absolute terms compared to the county average and significantly lower than the state average.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 18 Table 5: Household Income Distribution by Tenure
Income Category Avenal Kings County
Owners
<= 30% 7.9% 5.50%
>30% to <=50% 6.9% 7.30%
>50% to <=80% 20.4% 11.00%
>80% to <=100% 10.6% 8.60%
>100% 54.2% 67.50%
Total 100.00% 100.00%
Renters
<= 30% 34.0% 17.70%
>30% to <=50% 19.3% 14.60%
>50% to <=80% 29.1% 22.80%
>80% to <=100% 2.9% 11.40%
>100% 15.2% 33.50%
Total 100.00% 100.00%
Source: HUD CHAS data based on Census ACS 2014-2018
Table 6 presents the median income by race/ethnicity. As the table shows, the median incomes for both the Non-Hispanic White and Hispanic/Latino households are lower than the county and state. There is also a significant lower median income for Avenal's Hispanic/Latino households ($48,783) compared to nonHispanic households ($68,052).

Table 6: Median Household Income by Race or Hispanic Origin City of
Avenal
Kings
County California
White Alone Non-Hispanic $68,052 $74,918 $90,496
Black Or African American Alone Non-Hisp. NA $56,076 $54,976 American Indian And Alaska Native Alone Non-Hisp. NA $44,842 $60,182 Asian Alone Non-Hisp. NA $80,530 $101,380
Native Hawaiian, Other Pacific Islander Alone Non-Hisp. NA $98,864 $81,682 Some Other Race Alone Non-Hisp. $50,768 $47,592 $59,287 Two Or More Races Non-Hisp. $82,111 $72,188 $76,733
Hispanic Or Latino of Any Race $48,783 $49,373 $62,330
Source: U.S. Census Bureau, ACS 2016-2020 ), Table B19013.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 19 Figure 5: Local Median Income 2021, Census Tract
Source: California Department of Housing and Community Development. ACS 5yr estimates (2017-2021).

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 20 Poverty Status
In 2021, Kings County, California, experienced varying levels of poverty across different regions. As seen in Figure 6, the City of Avenal consists of census tracts with poverty rates that reach up to 30% - 40% in the central areas while the borders of the county have poverty rates at around 10% - 20% with a small portion towards the northern end consisting of poverty rates around 20% - 30%.

According to the Census American Community Survey data from 2017 to 2021, 17.7% of persons in Kings County were in poverty. These statistics underscore the diverse economic landscape of Kings County, where certain areas exhibit significantly higher poverty rates, highlighting the need for targeted socioeconomic interventions.

Table 7 shows that almost one-quarter (23.7%) of Avenal's households have incomes below the poverty level, significantly higher than both the county and the state. However. over the last decade between 2010 and 2020, Avenal has experienced a dramatic decline the number and percentage of household in poverty. As Table 8 shows, the percentage in household poverty declined from 41.1% in 2010 to 23.7% in 2020.

Table 7: Total Households in Poverty
Below Poverty
Level Percent
City of Avenal 565 23.7%
Kings County 4,464 13.1%
California 806,599 9.0%
Source: U.S. Census Bureau, ACS 2016-2020 Table B17019.

Table 8: Households in Poverty Over Time, City of Avenal 2010 2015 2020
Income in the Past 12 Months Below Poverty Level 1,215 596 565 Total Households 2,953 1,888 2,380
Percent of Households in Poverty 41.1% 31.6% 23.7%
Source: U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B17019. .

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 21 Figure 6: Avenal Poverty Status – Census Tracts
Source: California HCD and Census ACS 2017-2021.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 22 Familial Status
A household refers to the people occupying a home, such as a family, a single person, or unrelated persons living together. Families often prefer single-family homes or condominiums to accommodate children, while single people generally occupy smaller apartments or condominiums. Single-person households often include seniors or young adults.

Table 9 displays household composition by community as reported by the Census ACS 2016-2020. Avenal has 2,752 households, whereas Kings County has 43,604 households. Family households are prevalent in both areas, forming 86.5% of households in Avenal and 78.30% in Kings County.

A little over half of family households have children under 18 years. Married or cohabiting couples are a significant portion of households in both regions, though slightly more predominant in Kings County. In Avenal, 39.6% of these couples have children under 18, higher than that in Kings County. Proportion of single male householders (15.5%) are less than single female householders (22.2%). Nonfamily households, which include singles and unrelated individuals living together, constitute 13.5% compared to

21.7% in the County.

Overall, the average household size in Avenal is 3.74, higher than the County average of 3.14. These figures provide insight into the varied household compositions in Avenal, highlighting differences in family size, marital status, and the presence of children compared to the broader Kings County area.

Table 9: Household Characteristics
Age Group Avenal Kings County
Total Households 2,752 43,604
Family Households 86.5% 78.30%
With own children under 18 years 55.0% 41.30%
Married/Cohabiting Couples 62.4% 61.20%
With own children under 18 years 39.6% 32.20%
Male Householder, no spouse/partner present 15.5% 16.20% With own children under 18 years 2.4% 2.40%
Living Alone 6.4% 8.30%
Age 65+ 1.4% 2.50%
Female Householder, no spouse/partner present 22.2% 22.60% With own children under 18 years 13.0% 6.80%
Living Alone 5.6% 8.80%
Age 65+ 3.4% 4.70%
Nonfamily Households 13.5% 21.70%
Average Household Size 3.74 3.14
Source: Census ACS 2016-2020, Tables DP-2, B11012, and S1101

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 23 As seen in Table 10, family households in Avenal consist of 86.5%, while non-family households are around 13.5%. Among family households, 40.2% own their homes, while 46.3% are renters. For nonfamily households 7.2% own their homes, while 6.3% are renters. Among female householders with no husband present, only 6.1% own a house, while 11.2% rent a house, which is more or less similar to the data for the County.

As depicted in Table 11, larger households with 5 or more persons in Avenal is 33%, compared to 19.1% in the County and 13.7% in California.

Table 10: Household Type by Tenure
Household Type
Avenal Kings County
HH % HH %
Total Households 2,752 43,604
Family households: 2,380 86.5% 34,155 78.30%
Owner 1,107 40.2% 18,997 43.60%
Renter 1,273 46.3% 15,158 34.80%
Married-couple family: 1,604 58.3% 23,236 53.30%
Owner 844 30.7% 14,704 33.70%
Renter 760 27.6% 8,532 19.60%
Male householder no wife present: 299 10.9% 3,653 8.40% Owner 94 3.4% 1,499 3.40%
Renter 205 7.4% 2,154 4.90%
Female householder no husband present: 477 17.3% 7,266 16.70% Owner 169 6.1% 2,794 6.40%
Renter 308 11.2% 4,472 10.30%
Nonfamily households: 372 13.5% 9,449 21.70%
Owner 199 7.2% 4,371 10.00%
Renter 173 6.3% 5,078 11.60%
Source: Census ACS 2016-2020, Table B25007

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 24 Table 11: Households by Size

City of
Avenal Percent
Kings
County Percent California Percent
Total: 2,752 43,604 13,103,114
Family Households: 2,380 86.5% 34,155 78.3% 8,986,666 68.6% 2-Person HH 346 12.6% 9,940 22.8% 3,209,170 24.5%
3-Person HH 694 25.2% 7,998 18.3% 2,054,635 15.7%
4-Person HH 431 15.7% 7,984 18.3% 1,945,127 14.8%
5-Person HH 567 20.6% 4,886 11.2% 1,006,126 7.7%
6-Person HH 226 8.2% 2,216 5.1% 433,324 3.3%
7-Or-More Person HH 116 4.2% 1,131 2.6% 338,284 2.6%
Nonfamily Households: 372 13.5% 9,449 21.7% 4,116,448 31.4% 1-Person HH 328 11.9% 7,439 17.1% 3,114,819 23.8%
2-Person HH 20 0.7% 1,652 3.8% 774,224 5.9%
3-Person HH 24 0.9% 242 0.6% 135,683 1.0%
4-Person HH 0 0.0% 34 0.1% 59,938 0.5%
5-Person HH 0 0.0% 82 0.2% 19,730 0.2%
6-Person HH 0 0.0% 0 0.0% 6,805 0.1%
7-Or-More Person HH 0 0.0% 0 0.0% 5,249 0.0%
Source: U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B11016 Large Families. Households with five or more persons are categorized as large families and are disproportionately affected by overcrowding and a lack of adequately sized, affordable rental units. As shown in Table12 , large families make up one third (33%) of total occupied households in Avenal, with large family renters at 15.6% and owner occupied at 17,2%. The need for three- and four-bedroom units, exceeds supply. This contributes to a higher incidence of overcrowding, which affects educational and health outcomes for children. The City encourages development of multi-bedroom affordable units through incentives in its site inventory and density bonus policies.

Female Headed Households. Female-headed households have special housing needs including affordable housing, accessible daycare, health care, and other supportive services. Female-headed households comprised 22.2% of the total households in the City of Avenal. Notably, across all jurisdictions, the data reveals that a higher percentage of female-headed households are renters rather than homeowners.

This trend is indicative of the economic challenges and housing affordability issues faced by these households. Of the total female head of households, the majority (58.5%) have children under the age of 18 years, which compares to the County of 30.1% and the State of 17.9%. Figure 7 shows that the distribution of single-parent, female-head of household with children is approximately equal among the three census tracts (CTs 16.01, 17.02, and 17.03) within Avenal.

Within the City, there are two child care facilities on the eastern and southern boundary of the city: Maria Resendez Family Child Care (1025 Fremont Street, Avenal) and Kings Community Action OrganizationOasis Opportunity Center (1072 S. 7th Avenue, Avenal). The Reef-Sunset School District also includes a preschool located at 500 S. First Street, Avenal.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 25 Table 12: Tenure by Household Size
City of Avenal Kings County California
Total Occupied Housing Units 2,752 43,604 13,103,114
Total Large Households (5 or
More Persons) 909 33.0% 8,315 19.1% 1,809,518 13.7%
5-Person Household 567 20.6% 4,968 11.4% 1,025,856 7.8% 6-Person Household 226 8.2% 2,216 5.1% 440,129 3.3%
7-or-More Person
Household 116 4.2% 1,131 2.6% 343,533 2.6%
Owner-Occupied 1,306 47.5% 23,368 53.6% 7,241,318 55.3% 1-Person HH 155 5.6% 3,694 8.5% 1,416,913 10.8%
2-Person HH 237 8.6% 7,071 16.2% 2,403,865 18.3%
3-Person HH 239 8.7% 4,338 9.9% 1,235,833 9.4%
4-Person HH 201 7.3% 4,161 9.5% 1,182,987 9.0%
5-Person HH 276 10.0% 2,443 5.6% 567,528 4.3%
6-Person HH 101 3.7% 1,113 2.6% 238,866 1.8%
7-Or-More Person HH 97 3.5% 548 1.3% 195,326 1.5%
Renter-Occupied 1,446 52.5% 20,236 46.4% 5,861,796 44.7% 1-Person HH 173 6.3% 3,745 8.6% 1,697,906 13.0%
2-Person HH 129 4.7% 4,521 10.4% 1,579,529 12.1%
3-Person HH 479 17.4% 3,902 8.9% 954,485 7.3%
4-Person HH 230 8.4% 3,857 8.8% 822,078 6.3%
5-Person HH 291 10.6% 2,525 5.8% 458,328 3.5%
6-Person HH 125 4.5% 1,103 2.5% 201,263 1.5%
7-Or-More Person HH 19 0.7% 583 1.3% 148,207 1.1%
Source: U.S. Census Bureau, ACS 2016-2020 (5-year Estimates), Table B25009 Table 13: Female-Headed Households
City of Avenal Kings County California
Female Householder, No Spouse Or
Partner Present 610 9,847 3,430,426
Living Alone 153 25.1% 3,825 38.8% 1,722,600 50.2%
With Own Children Under 18 Years 357 58.5% 2,963 30.1% 615,734 17.9% With Relatives, No Own Children
Under 18 Years 80 13.1% 2,812 28.6% 858,959 25.0%
With Only Nonrelatives Present 20 3.3% 247 2.5% 233,133 6.8% Source: U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B11012

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS MULTI-JURISDICTIONAL FAIR HOUSING ANALYSIS | April 2026 | 26 Figure 7: Single-Parent Female-Headed Households with Children Source: California Department of Housing and Community Development (HUD), ACS, 2017-2021. Updated: March 2023.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 27 Seniors. Table 14 shows that seniors, defined as 65 years or older, compromise 23.1% of the population.

In comparison, that proportion is 21.9% Kings County and 19.4% in California. Typically, senior households have special housing needs primarily due to three concerns – physical disabilities or limitations, limited income, and higher medical costs. In the last decade, there has not been much of a shift in rates of ownership and renting among seniors in Kings County and California. However, there is a dramatic shift in Avenal’s seniors owning their household. According to Table 15, in 2010, 63.2% of seniors owned their household. In 2020, 93.1% of Avenal’s seniors own their home which is much higher than the general proportion of owners in Avenal, 45.4%.

The median household income in Avenal is $49,781, and 42.8% of seniors make more than the median income which influences housing choice and ownership. Figure 8 shows that almost one quarter (23.1%) of Avenal seniors are in the $60,000 to $74,999 income category, followed by 19.7% in the $10,000 to $14,999 category.

It is important to note that disabilities are most common among senior citizens. Of Avenal's residents, seniors account for 62.6% with one or more types of disability in Avenal. It is interesting to note that in California the proportion is much lower, 40.8%. See further discussion about housing needs for people with disabilities below, in the Disability Rates and Services section.

Table 14: Population by Age Groups (Total)

City of
Avenal Percent Kings County Percent California Percent
Total: 13,033 151,090 39,346,023
Under 5 Years 1,105 8.5% 11,461 7.6% 2,409,082 6.1%
5 to 17 Years 2,905 6.9% 10,646 7.0% 2,431,647 6.2%
18 to 24 Years 1,187 11.2% 12,534 8.3% 2,597,443 6.6%
25 to 34 Years 2,599 4.2% 6,282 4.2% 1,518,469 3.9%
35 to 44 Years 2,059 3.6% 4,049 2.7% 1,029,603 2.6%
45 to 54 Years 1,419 0.8% 2,572 1.7% 545,047 1.4%
55 to 64 Years 1,114 1.5% 2,456 1.6% 540,872 1.4%
65 to 74 Years 416 3.2% 7,544 5.0% 1,608,717 4.1%
75 to 84 Years 229 10.9% 13,278 8.8% 3,084,036 7.9%
85 Years And Over 0 9.0% 12,210 8.1% 2,923,877 7.4%
Source: U.S. Census Bureau, ACS16-20 (5-year Estimates), Table B01001.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 28 Table 15: Senior Households by Tenure Over Time
2010 2015 2020
RenterOccupiedOwner
Occupied
RenterOccupiedOwner
Occupied
RenterOccupiedOwner
Occupied
City of Avenal 156 268 118 227 26 350
Percent 36.8% 63.2% 34.2% 65.8% 6.9% 93.1%
Kings County 1,654 5,193 1,815 5,586 2,258 6,917
Percent 24.2% 75.8% 24.5% 75.5% 24.6% 75.4%
California 605,590 1,764,836 737,696 2,005,660 858,161 2,340,689 Percent 25.5% 74.5% 26.9% 73.1% 26.8% 73.2%
Source: U.S. Census Bureau, ACS 06-10, 11-15, 16-20 (5-year Estimates), Table B25007 Figure 8: Senior (65 Years and Older) Households by Household Income (2020) Source: U.S. Census Bureau, ACS 2016-2020 (5-year Estimates), Table B19037

1.9%

19.7%

0.0% 0.0%

4.5%

15.7%

0.0%

15.4%

0.0% 0.0%

23.1%

13.8%

5.9%

0.0% 0.0% 0.0%

0.0%

5.0%

10.0%

15.0%

20.0%

25.0%
Percent of Total Senior Households

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 29 Local Knowledge. The City of Avenal does not exhibit any patterns of familial segregation. Families are distributed evenly across all areas of the city, with no neighborhoods identified as having a disproportionate concentration of either family or non-family households. This reflects the city’s compact geography and the relatively uniform nature of its housing stock, which primarily consists of single-family homes suitable for households of various sizes.

There are two licensed child care facilities within the city: Maria Resendez Family Child Care and KCAO Oasis Opportunity, located on the eastern and southern boundaries of Avenal. While these facilities provide essential early childhood services, their peripheral locations suggest that residents in other parts of the city may have limited access to nearby child care options. However, due to the small size of the city, travel distances to these facilities are relatively modest and do not present a major barrier.

Overall, there is no evidence of segregation based on familial status, and households with children appear to have citywide access to residential areas. Nevertheless, the limited number and geographic concentration of child care providers highlight the need to explore strategies to expand child care access equitably as part of broader efforts to support families and working parents across the community.

Persons with Disabilities
Due to the multitude of possible functional limitations that may present as disabilities, and in the absence of information on external factors that influence disability, surveys like the Census ACS are limited to capturing difficulty with only selected activities. As such, people identified by the ACS as having a disability are, in fact, those who exhibit difficulty with specific functions and may, in the absence of accommodation, have a disability. To capture a variety of characteristics that encompass the definition of disability, the ACS identifies serious difficulty with four basic areas of functioning – hearing, vision, cognition, and ambulation.2
Figure 9 illustrates that CT 17.02 within the City of Avenal has 10% -20% of the population with a disability. Census Tracts 16.01 and 17.03 within the City have less than 10% of the population with a disability.

As presented in Table 16, the largest number of Kings County residents with disabilities was in the 18 to 64 years age group or the working age population with 8,357 individuals, which represented 11% of the total age group. However, disabilities were most common among senior citizens (65 years and over).

Approximately 40.8% of total seniors in Kings County reported one or more types of disability. At the local level, in the City of Avenal, the proportion of seniors reporting some type of physical disability is high at 62.6%. The most common type of disability among seniors was having ambulatory difficulty.

Developmental Disabilities as defined by federal law; “developmental disability” means a severe, chronic disability of an individual that:
• Is attributable to a mental or physical impairment or combination of mental and physical impairments.
• Is manifested before the individual attains age 18.
2 Source: American Community Survey 2013 Subject Definitions. Beginning in 2008, questions on disability represent a conceptual and empirical break from earlier years of the ACS. Hence, the Census Bureau does not recommend any comparisons of disability data to 2007 and earlier ACS disability data, or to disability estimates from the 2000 Census.)

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 30 • Is likely to continue indefinitely.
• Results in substantial functional limitations in three or more of the following areas of major life activity: a) self-care; b) receptive and expressive language; c) learning; d) mobility; e) selfdirection; f) capacity for independent living; or g) economic self-sufficiency. • Reflects 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. 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.

In the City of Avenal, as shown in Table 17, almost three quarters (73.1%) of those residents that have developmental disabilities are less than the age 18 years. This is considerably less than the proportion of those in the County (61.0%) and the State (50.9%).

Based on local knowledge, there are no identified geographic concentrations of persons with disabilities in the City of Avenal. Individuals with disabilities appear to be dispersed uniformly throughout the community, with no particular areas identified as having a higher or lower presence of this population group. In addition, the city currently has no known group homes or residential care facilities (RCFs) within its jurisdiction. Similarly, there are no records of permits issued for residential accessibility modifications—such as ramps or structural accommodations—and no requests for reasonable accommodations were received during the previous planning period. This absence of activity may reflect limited demand, underreporting, or a lack of awareness among residents about available resources and rights under fair housing law.

There are also no known recent accessibility improvements to the housing stock or public infrastructure, and no areas of the city have been identified as being in greater need of accessibility enhancements.

However, given Avenal’s aging housing stock and absence of new construction, there may be citywide deficiencies in accessible housing features, even if not formally documented.

Overall, while there is no evidence of disability-related segregation, the lack of documented accommodations or infrastructure upgrades highlights an opportunity for the City to enhance outreach, support inclusive housing practices, and ensure that persons with disabilities can access housing and community resources on an equal basis. Future planning efforts should consider proactive strategies to identify and address potential accessibility gaps across Avenal

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 31 Figure 9: Population with a Disability

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 32 Table 16: Percentage of Persons with Disability Type by Age Disability Type by Age
Avenal Kings County
Persons % Persons %
Population under 18 years w/disability 61 1.5% 1,498 3.7% With a hearing difficulty 0 0.0% 193 0.5%
With a vision difficulty 0 0.0% 480 1.2%
With a cognitive difficulty 61 1.5% 890 2.2%
With an ambulatory difficulty 0 0.0% 127 0.3%
With a self-care difficulty 0 0.0% 219 0.5%
Population 18 to 64 years w/disability 419 7.4% 8,357 10.7% With a hearing difficulty 142 2.5% 1,632 2.1%
With a vision difficulty 84 1.5% 1,354 1.7%
With a cognitive difficulty 22 0.4% 3,009 3.8%
With an ambulatory difficulty 171 3.0% 4,087 5.2%
With a self-care difficulty 0 0.0% 1,424 1.8%
With an independent living difficulty 22 0.4% 3,094 4.0% Population 65 years and over w/disability 392 62.6% 6,179 40.8% With a hearing difficulty 94 15.0% 2,657 17.6%
With a vision difficulty 115 18.4% 1,265 8.4%
With a cognitive difficulty 86 13.7% 1,458 9.6%
With an ambulatory difficulty 278 44.4% 3,807 25.1%
With a self-care difficulty 51 8.1% 1,500 9.9%
With an independent living difficulty 109 17.4% 2,659 17.6% Note: Numbers represent people, not disabilities. Persons may report more than one type of disability Source:

Census ACS 2016-2020, Table S1810 and C18108
Table 17: People with Developmental Disabilities - Age
City of Avenal Kings County State
0-17 yrs 79 (73.1%) 758 (61.0%) 192,384 (50.9%)
18+ yrs 29 485 185,353
Total Population 108 1,243 377,737
Source: DDS Quarterly Consumer Report, December 2021

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 33 Farmworkers
Kings County is a significant agricultural producer, with the number of employed farmworkers ranging from 7,000 to 10,000 workers. Farmworker households often face unstable income, seasonal unemployment, and substandard living conditions. Many live in shared housing, mobile homes, or employer-provided units that lack permanent tenancy rights. Farmworkers—especially those who are undocumented or migrant—often lack access to stable rental contracts and may reside in overcrowded or informal housing units.

Recent Census data in Table 18 shows that approximately 8,300 of employed Kings County civilian residents (16 years and over) worked as agricultural workers. Of the four cities, the highest percentage of civilian workers in agricultural related jobs was Avenal, where 45% of its workers were in this industry.

While Avenal itself may not host a large volume of dedicated farmworker housing developments, it serves as a residential node for agricultural laborers working in surrounding rural areas. Local consultation confirms that demand for safe, affordable, and family-oriented farmworker housing remains high and largely unmet.

Table 18: Agricultural Employment by Jurisdiction
Jurisdiction of Civilian
Employed Pop. (16 and
over)
Number of
Agricultural Workers % of Total Workers
Avenal 1,617 45%
Corcoran 1,275 30%
Hanford 2,213 9%
Lemoore 692 6%
Unincorporated 2,474 22%
Kings County 8,271 15%
Source: Census ACS 2016-2020, Table DP-3
Table 19 presents the number of farms and hired farm workers in Kings County. According to the 2017 U.S. Department of Agriculture (USDA) Census estimates, there were 507 farms and a total of almost 7,000 hired farm workers countywide. The largest number of workers (5,820) were employed at farms with 10 or more employees or 83% of the countywide total number of hired workers. Also, there were more permanent hired workers (worked more than 150 days) than seasonal workers (worked less than 150 days) for both farm operations with less than 10 employees and with more than 10 employees.

Agricultural workers, and especially farmworkers, have special housing needs due to their relatively low wages. According to an article in Rural Migration News, the average hourly wage for all California farmworkers in the years 2015-2019 was approximately $12.3 . This is equivalent to approximately
$25,000/year for full-time work. As a result, farmworkers often overpay for housing (in relation to their income) and/or live in overcrowded and substandard living situations. 3 https://migration.ucdavis.edu/rmn/blog/post/?id=2805

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 34 Table 19: Hired Farm Labor-Workers, Kings County
Farmworkers
No. of
Farms
No. of Hired
Workers
Percent of Total
County Hired
Workers
Total Hired Farm Labor 507 6,998
Farm operations with less than 10
employees 351 1,178 17%
Permanent (> 150 days) 275 1,034 15%
Seasonal (< 150 days) 246 677 10%
Farm operations with 10 or more
employees 156 5,820 83%
Permanent (> 150 days) 96 3,046 44%
Seasonal (< 150 days) 49 2,241 32%
Source: USDA, 2017 Census of Agriculture
Although no farmworker camps exist in Kings County, the County does have a significant number of government-subsidized housing projects (e.g., Section 515 and public housing) that house farmworkers and their families. Many farmworkers live in mobile homes on the farming site. A new farmworker housing project was completed in Hanford during the 2003-2008 planning period. That project involved the renovation of an existing former motel into temporary and/or long-term, permanent agricultural employee housing. The project included 24 units plus parking, courtyard, children’s play areas and open space.

In addition, there is a 40-unit apartment complex in unincorporated Kettleman City that serves farm labor families. This apartment includes 10 two-bedroom units, 20 three-bedroom units, and 10 four-bedroom units, with approximately 70-100 farmworkers residing in the apartment complex. The Constraints analysis contains a discussion of each jurisdiction’s land use and zoning policies and regulations regarding farmworker housing. In communities with large farmworker populations, farmworker housing needs are met through homeownership assistance and rehabilitation loans.

Most loans under both types of programs are issued to people working in the agricultural industry.

Moreover, many occupants of Section 515 projects and other subsidized projects are also employed in the farming industry. In addition, the City will assist interested developers by providing incentives, identifying suitable sites, and assisting in preparation of funding applications.

Kings County is one of California’s top-producing agricultural counties, with over $2.4 billion in crop value in 2021. According to California Employment Development Department (EDD) and USDA-NAWS (2021– 22) data:
• An estimated 6,800 to 7,200 farmworkers are employed annually in Kings County, with additional seasonal variation (peaking up to 10,000).
• Approximately 93% identify as Latino/Hispanic, with 85% foreign-born, primarily from Mexico. • Nearly 48% are considered migratory, and 29% are considered settled farmworkers. • The median annual income for crop workers is $22,000 to $25,000, well below the area median income (AMI).

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 35 Farmworker households in Kings County face significant housing challenges:
• Approximately 40% of farmworker households are renters, while others live in informal or seasonal housing arrangements, some in unpermitted dwellings or trailers. • Kettleman City, rural Corcoran, and Hanford's southern fringe are identified as farmworkerconcentrated zones with high rates of poverty, limited infrastructure, and older housing stock.

Farmworker households face disproportionate burdens in the following ways:
• Overcrowding is a dominant issue. According to HUD CHAS and local knowledge, over 37% of farmworker households experience overcrowded conditions (1.01+ persons per room). • Severe Cost Burden: CHAS data shows over 52% of low-income farmworker households pay more than 50% of income toward housing.
• Many reside in older, single-family homes, converted garages, or employer-provided units, often without formal leases or tenant rights.
• Lack of Permanence: Migrant workers often face frequent relocations, leading to disruptions in children’s education and healthcare access.
• Unsafe Living Conditions: Multiple stakeholder consultations (2019–2023) and Kings County code enforcement records indicate farmworkers are overrepresented in units with health/safety violations (e.g., mold, leaks, non-functional plumbing).
• Barriers to Assistance: Language barriers, immigration status, and employer-control over housing reduce access to public programs, including voucher eligibility and code complaint processes.

Farmworker households in Avenal face unique and disproportionate housing challenges due to income volatility, large household sizes, and limited access to safe, affordable rental units. These needs are compounded by barriers such as language access, documentation status, and limited public awareness.

Through data-informed analysis and coordinated strategies, the City aims to improve housing outcomes for farmworkers by facilitating supportive housing production, increasing cross-agency coordination, and ensuring inclusion of farmworker needs in broader housing policy decisions.

Avenal’s Program 1.14 Farmworker and Employee Housing has various objectives including an inventory of suitable sites for farmworker housing with the update of the Land Use Element, assisting interested developers with supporting funding applications for affordable housing, and more.

Disparities in Access to Opportunities
The Tax Credit Allocation Committee (TCAC) and California Department of Housing and Community Development (HCD) have developed annual maps of access to resources, such as high-paying job opportunities; proficient schools; safe and clean neighborhoods; and other healthy economic, social, and environmental indicators in 2017.

It uses economic and education indicators that include the following:
• Percentage of population with income above 200% of federal poverty line • Percentage of adults with a bachelor’s degree or above, • Percentage of adults aged 20-64 who are employed in the civilian labor force or in the armed forces

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 36 • Value of owner-occupied units
• Percentage of 4th graders who meet or exceed math proficiency standards • Percentage of 4th graders who meet or exceed literacy standards • Percentage of high school cohort that graduated on time • Percentage of students not receiving free or reduced-price lunch The TCAC/HCD Opportunity Areas map identifies areas within the City that provide resources and opportunities. Figure 10 illustrates the spatial distribution of TCAC/HCD Opportunity Areas in Avenal.

The information from this map shows that CTs 17.02 and 17.03 with high segregation and poverty and the northern part of Avenal in the broader CT 16.01 with moderate resources. The neighboring Fresno area is characterized as low resource, while other adjacent areas in Kings County bordering Avenal share similar issues of high segregation and poverty.

Areas designated as “highest resource” are the top 20.0 percent highest-scoring census tracts in the region.

It is expected that residents in these census tracts have access to the best outcomes in terms of health, economic opportunities, and education attainment. Census tracts designated “high resource” score in the 21st to 40th percentile compared to the region. Residents of these census tracts have access to highly positive outcomes for health, economic, and education attainment. “Moderate resource” areas are in the top

30.0 percent of the remaining census tracts in the region and those designated as “moderate resource (rapidly changing)” have experienced rapid increases in key indicators of opportunity, such as increasing median income, home values, and an increase in job opportunities. Residents in these census tracts have access to either somewhat positive outcomes in terms of health, economic attainment, and education, or positive outcomes in a certain area (e.g., score high for health, education) but not all areas (e.g., may score poorly for economic attainment). Low-resource areas are those that score in the bottom 30.0 percent of census tracts and indicate a lack of access to positive outcomes and poor access to opportunities. The final designation are those areas identified as having “high segregation and poverty;” these are census tracts that have an overrepresentation of people of color compared to the county as a whole, and at least 30.0 percent of the population in these areas is below the federal poverty line ($27,750 annually for a family of four in 2022).

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 37 Figure 10: TCAC/HCD Opportunity Areas, 2023
Source: California Department of Housing and Community Development (HCD); California Tax Credit Allocation Committee (TCAC), Updated Jan 2023.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 38 Transit Mobility
Transit mobility refers to an individual’s ability to navigate the community and region daily to access services, employment, schools, and other resources. Indicators of transit mobility include the extent of transit routes, proximity of transit stops to affordable housing, and frequency of transit. The County needs to plan for and address the mobility needs of the county’s growing population. Public transportation services are available to people with lower incomes, seniors, and persons with disabilities through the Kings Area Rural Transit (KART) system, overseen by the Kings County Area Public Transit Agency (KCAPTA) and through the City of Corcoran’s transit system, Corcoran Area Transit (CAT). KART is Kings County’s public transportation provider. KART provides public transit service Monday through Friday and limited service on Saturdays, to the cities and communities of Armona, Avenal, Corcoran, Grangeville, Hardwick, Hanford, Kettleman City, Laton, Lemoore, and Stratford. KART Paratransit (origin to destination) is available to eligible certified ADA passengers. In addition, KART provides regular transportation services to Fresno and Visalia Monday through Friday. All KART bus routes begin and end at the KART Terminal located at 504 W. 7th Street Hanford, California, west of the AMTRAK station in Downtown Hanford.

AllTransit is a transit and connectivity analytic tool developed by the Center for Neighborhood Technology for the advancement of equitable communities and urban sustainability. The tool analyzes the transit frequency, routes, and access to determine an overall transit score at city, county, and regional levels.

AllTransit scores geographic regions (e.g., cities, counties, Metropolitan Statistical Areas [MSAs]) on a scale of 0 to 10, with 10 being complete transit connectivity. Figure 11 depicts the city of Avenal’s AllTransit Performance score, including metrics representing average household transit access. Avenal’s overall score is 1.0, demonstrating “very low” connectivity. However, the AllTransit methodology, which determines scores according to an “average” household, may not fully represent transit availability in the unincorporated areas, as the estimate is an average of both incorporated and unincorporated areas.

As seen in Figure 12, high qualities transit stops in terms of facilities, accessibility and frequency of services are not present in the City of Avenal. Public transit usage for commuters is extremely low at 4.9%. This indicates a lack of reliance on or availability of robust public transit options in the area. The data suggests that most residents likely depend on other means of transportation for their daily commute and activities. This low usage of public transit in Avenal aligns with the general challenges faced in ensuring accessible and efficient public transportation in smaller cities and rural areas. It is also evident that the connectivity is focused on moving people within cities rather than between cities. Based on the information in the Kings County Transit Development Plan 2021 document, Kings County faces challenges in providing comprehensive transit services, especially in rural areas. The report identifies gaps in service and highlights the difficulty of connecting transit-dependent residents living in remote areas to services in larger communities.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 39 Figure 11: City of Avenal All Transit Performance Score Source: AllTransit.cnt.org, 2022

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 40 Figure 12: High Quality Transit Stops and Transit Area (1/2 mile) Source: Caltrans, 2022. U.S.; Department of Housing and Urban Development (HUD), Updated 2022.

KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 41 APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
Local Knowledge. The City of Avenal is served by the Kings Area Regional Transit (KART) system, which provides limited public transportation options within the county. A single fixed-route line operates in Avenal, with connections to Hanford and Lemoore—two larger cities that offer greater access to jobs, healthcare, and services. Locally, this transit line follows a loop path along Highway 269 and San Joaquin Street, with all designated stops located north of Highway 269.

While the KART system offers essential connectivity, transit service coverage and frequency are limited, and access is less convenient for residents living south of Highway 269. Additionally, the city lacks dedicated infrastructure for alternative transportation modes, such as protected bicycle lanes or fully connected pedestrian pathways. Although some roads feature “share the road” signage, there is no formal bike network, and walking paths are incomplete in certain areas.

Residents without access to a private vehicle face significant transportation challenges. Many rely on informal ride-sharing arrangements, often paying neighbors or acquaintances for transportation to work or appointments. The Avenal State Prison provides van services for employees, which helps offset the transportation burden for some. However, these solutions are inconsistent and not accessible to all residents, particularly those who need reliable access to medical care, educational institutions, or regional employment centers.

The physical condition of local roads varies. While most neighborhoods have streetlights, they are inconsistent at intersections, and overall road conditions are fair to poor, though the city has initiated a routine maintenance program. The only identified high-collision corridor is Skyline Boulevard, which also carries the most traffic volume.

To improve safety and mobility, the city has adopted a Safe Routes to School Plan and is actively seeking Active Transportation Program (ATP) funding for its implementation. This plan is designed to enhance pedestrian and bicycle infrastructure, especially for students. Most neighborhoods have sidewalks, and there are no major differences in pedestrian infrastructure access between neighborhoods.

Recent and ongoing infrastructure improvements include:
• Reconstruction of 7th Avenue
• Development of a new pocket park with fitness equipment • Construction of a community building/sports facility on Hydril • Planned 7th Avenue Trail from Skyline to Mariposa, for recreational and active transportation use While Avenal’s transportation infrastructure does not exhibit stark neighborhood disparities, the city as a whole faces significant transportation limitations that constrain residents' access to opportunity. These include limited public transit, poor internet connectivity for telecommuting, minimal bike infrastructure, and an overreliance on informal transportation networks. Continued investment in multimodal infrastructure and transportation equity will be essential to meet the needs of low-income, transit-dependent, and non-driving residents.

Employment
Kings County’s economy has an important impact on housing needs. Employment growth typically results in increased housing demand in areas that serve as regional employment centers. Moreover, the type of occupation and income levels for new employment also affects housing demand. This section describes

KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 42 APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
the economic and employment patterns in Kings County and how these patterns influence housing needs.

Kings County supports a diversified economy as illustrated in Figure 13. This figure shows the proportion of jobs held by residents (civilian employed population 16 years and over) living in the County. Based on the Census ACS 2016-2020 information, the education, health care, social assistance industry was the largest employer of Kings County residents, providing approximately 10,800 jobs, or 20% of workforce.

As important as agriculture is to the County, the agriculture sector was the second largest employer of its residents, which employed 8,300 residents or 15% of the workforce. Kings County’s civilian labor force was estimated at 57,800, with an unemployment rate of 7.0% (not seasonally adjusted). This compares to the statewide unemployment rate of 4.1%. However, compared to recent trends, Kings County’s unemployment rate has decreased significantly from the 2020 annual average unemployment rate of 12.0%.

Figure 13: Employment by Industry of Kings County Workforce Source: Census ACS 2016-2020, Table DP03
The economic landscape of the City of Avenal is defined by a limited number of major employers, most notably Avenal State Prison and the Reef-Sunset School District, both located within city limits. A significant number of residents are also employed by Wonderful Pistachios, a large agricultural processor located over 30 minutes away in Lost Hills, California. This reliance on a small number of public sector and agricultural employers contributes to the city’s economic vulnerability and limits opportunities for economic diversification or upward mobility.

At present, there are no known economic development programs or workforce initiatives in place within the city that are aimed at revitalizing the local economy or preparing the workforce for future industry needs. Without targeted investment or policy intervention, this economic stagnation is likely to persist, continuing to limit residents' access to high-quality job opportunities.

Jobs-Housing Balance and Commute Patterns
Commuting patterns in Kings County have an important implication for housing needs. Larger employers Education, health care,
social assistance
20%
Agriculture
15%
Public admin.
13%
Retail trade
10%
Arts, entertainment,
recreation,
accomodation, food
services
8%
Manufacturing
7%
Professional, scientific,
management, admin.
7%
Transportation,
warehousing, utilities
6%
Construction
4%
Other services, except
public admin.
3%
Finance, insurance, real
estate
3%
Wholesale trade
3%
Information
1%

KINGS COUNTY MULTI-JURISDICTIONAL HOUSING ELEMENT | April 2026 | 43 APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
in the County (e.g., three state prisons, Naval Air Station Lemoore, and agricultural industries) generate a significant number of jobs. However, the workforce employed at these institutions or in the agricultural industries may live in other communities for a variety of reasons, including preferences, the availability of suitable housing, or other reasons.

Commuting patterns show the relationship between where people live and where they work. Long commuting distances increase traffic congestion that strains the existing overcrowded road and highways infrastructure systems that are often in need of maintenance. Long commuting distances also contribute to poor air quality, increases expenses to the commuting workforce, and has been shown to have negative consequences on personal health. One of the aims of the Regional Housing Needs Allocation (RHNA) Plan is to direct new housing growth to employment centers to balance the jobs-housing ratio and decrease commuting distances.

Table 19 in the city of Avenal 20.8% workforce aged 16 years and older who do not work at home travel less than 15 minutes to work and another 19.7% of workers travel 15-30 minutes to work. The average time to work for Avenal workers was 36 minutes which is relatively higher by 13 minutes by countywide workers. Table 20 shows that only 18.6% of Avenal resident worker are employed in the City. In addition, Figure 14 show that CT 17.02 has less than 2,500 jobs within a 45-minute transit commute time and a portion of CT 17.03 has 2,500-5,000-10,000 jobs within the 45-minute transit commute time.

Table 19: Travel Time to Work
Note: Workers included those 16 years and over who did not work from home.; Source: Census ACS 2016-2020 Table S0801
Table 20: Work Locations of City/County Resident Workers Note: Workers included those 16 years and over who did not work from home.; Source: Census ACS 2016-2020 Table S0801
Travel Time to Work Avenal Kings County
Less than 15 minutes 20.8% 36.80%
15-30 minutes 19.7% 32.00%
30 to 59 minutes 35.8% 25.10%
60 or more minutes 23.6% 6.10%
Average Travel Time 36 min. 23 min.

Travel Time to Work Avenal Kings County
Number of Resident Workers (Age 16 and over) 3,423 56,560 Work in Same City/County) 18.6% 75.6%
Work Outside of City/County 81.4% 24.1%
Total 100% 100%

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 44 Figure 14: Jobs within 45-Minute Transit Commute
Sources: Caltrans, 2022; Smart Locations Database, 2018.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 45 Agricultural Jobs
Kings County is one of the state’s major agricultural areas, ranking 8th among California counties in total agricultural production. According to the Kings County Agricultural Commissioner, 84% of the total land area in the County is devoted to farmland.

Recent Census data in Table 21 shows that 15% of employed Kings County civilian residents (16 years and over) worked in agriculture and related industries. Of the four cities, the highest percentage of civilian workers in agricultural related jobs was Avenal, where 45% of its workers were in this industry. This was followed by Corcoran workers at 30%.

Table 22 presents the number of farms and hired farm workers in Kings County. According to the 2017 U.S.

Department of Agriculture (USDA) Census estimates, there were 507 farms and a total of almost 7,000 hired farm workers countywide. The largest number of workers (5,820) were employed at farms with 10 or more employees or 83% of the countywide total number of hired workers. Also, there were more permanent hired workers (worked more than 150 days) than seasonal workers (worked less than 150 days) for both farm operations with less than 10 employees and with more than 10 employees.

Table 21: Agricultural Employment by Jurisdiction
Jurisdiction of Civilian
Employed Pop. (16 and over)
Number of Agricultural
Workers % of Total Workers
Avenal 1,617 45%
Corcoran 1,275 30%
Hanford 2,213 9%
Lemoore 692 6%
Unincorporated 2,474 22%
Kings County 8,271 15%
Source: Census ACS 2016-2020, Table DP-3
Table 22: Hired Farm Labor-Workers, Kings County
Farmworkers No. of Farms
No. of Hired
Workers
Percent of Total
Hired Workers
Total Hired Farm Labor 507 6,998
Farm operations with less than 10 employees 351 1,178 17% Permanent (> 150 days) 275 1,034 15%
Seasonal (< 150 days) 246 677 10%
Farm operations with 10 or more employees 156 5,820 83% Permanent (> 150 days) 96 3,046 44%
Seasonal (< 150 days) 49 2,241 32%
Source: USDA, 2017 Census of Agriculture

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 46 Services for Persons with Developmental Disabilities
The State Department of Developmental Services (DDS) currently provides community-based services to approximately 243,000 persons with developmental disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community-based facilities. Kings County is served by the Central Valley Regional Center (CVRC) which is based in Fresno. During 2014, CVRC served approximately 16,200 clients, of which about 900 to 1,000 lived in Kings County. CVRC provides diagnosis, evaluation, and case management services. The Kings County Rehabilitation Center in Hanford also offers rehabilitation, vocational and life training, and operates four group homes for mentally and physically handicapped individuals. State and federal law mandate minimum accessibility standards for housing. For example, local governments that use federal housing funds must meet federal accessibility guidelines for new construction and substantial rehabilitation. At least 5% of the units must be accessible to persons with mobility impairments, and an additional 2% must be accessible to persons with sensory impairments. New multi-family housing must be built so that:
1) the public and common use portions of such units are readily accessible to and usable by disabled persons.
2) the doors allowing passage into and within such units can accommodate wheelchairs; and 3) all units contain adaptive design features.

In addition, state law requires all jurisdictions to provide reasonable accommodation in the application of housing policies and regulations.

The City’s Program 1.15 Housing for Persons with Disabilities continues to facilitate reasonable accommodation in housing for persons with disabilities and expedite developmental applications like residential care facilities.

Education
The Kings County Board of Education establishes the mission and primary objectives for the Kings County Superintendent of Schools and ensures that activities and programs remain focused on the goals identified within the California Department of Education educational rules and regulations. The Kings County Board of Education establishes the mission and primary objectives for the Kings County Superintendent of Schools and ensures that activities and programs remain focused on the goals identified within the California Department of Education educational rules and regulations. According to the Kings County office of education as of Oct 2021 there are a total of 19,429 students enrolled in elementary schools and about 8,179 students in high schools across the county as per data submitted by the districts. Figure 15 below shows some of the school districts in Kings County.

The Reef-Sunset School District serves Avenal. The District enrolls 2,722 students, of which 64.3% of students are economically disadvantaged.. The District includes:
• Reef-Sunset State Preschool
• Tamarack Elementary School
• Avenal Elementary School
• Kettleman City Elementary
• Reef-Sunset Middle School
• Sunrise High School
• Avenal High School
• Avenal Adult School

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 47 Schools are located generally on the north side of HWY 269 with the exception of Tamarack Elementary.

According to U.S. News and World Report on Reef-Sunset Unified School District, 19% of elementary students tested at or above the proficient level for reading, and 11% tested at or above that level for math.

Also, 24% of middle school students tested at or above the proficient level for reading, and 15% tested at or above that level for math. And 44% of high school students tested at or above the proficient level for reading, and 8% tested at or above that level for math. In addition, based on the California Assessment of Student Performance and Progress (CAASPP), 18.7% met or exceeded standard for ELA; 9.07% met or exceeded standard for math

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 48 Figure 15: School Districts in Kings County
Source: Kings County, Cal EM

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 49 Disproportionate Housing Needs and Displacement Risk
Disproportionate housing needs in the City of Avenal are evaluated through an analysis of overpayment, overcrowding, housing condition, homelessness, and displacement risk. This assessment utilizes data from HUD CHAS, ACS, CalEnviroScreen, the Urban Displacement Project, and the Kings/Tulare Homeless Alliance, along with local knowledge from City staff and code enforcement records.

Overpayment and overcrowding are prevalent in several areas of the City, particularly in Census Tracts

17.02 and 17.03. As shown in Figure 15, 56.1 percent of renter households in Tract 17.02 are cost burdened, and Figure 16 indicates that Tract 17.03 has the highest rates of overcrowding and severe overcrowding.

These areas also correspond to Racially/Ethnically Concentrated Areas of Poverty (R/ECAPs) and exhibit elevated levels of poverty and segregation.

Housing condition data, combined with local code enforcement insight, indicate that many of the City’s older neighborhoods, particularly in central Avenal, may require rehabilitation or repair. The City addresses these needs through Program 1.1 (Code Enforcement), which includes proactive identification and correction of substandard housing, and Program 1.2 (Housing Rehabilitation Program), which provides financial assistance for lower-income households in need of repairs or accessibility improvements.

According to the 2022 Kings/Tulare Homeless Alliance Point-in-Time Count, four individuals experiencing homelessness were identified within the City. While the number is relatively small, the City recognizes the importance of maintaining access to shelter and services. Avenal participates in regional homelessness programs and maintains zoning compliance with SB 2 by permitting emergency shelters by right in the R3 zone. Program 1.13 (Emergency and Supportive Housing) supports continued access to emergency shelter, transitional housing, and permanent supportive housing through zoning and coordination with service providers.

Figure 18 presents data from the Urban Displacement Project, which identifies central Avenal as an area at risk of displacement, particularly for lower-income renter households. The Housing Element responds to this risk through Program 1.3 (Preservation of At-Risk Housing and Mobile Home Parks), which supports the preservation of affordable units and the stabilization of vulnerable housing types, including mobile homes and older unsubsidized rentals.

Limited access to public transportation and essential services further compounds disproportionate needs.

The City’s All Transit Performance Score is 1.0, indicating minimal fixed-route transit access and longer travel times to jobs and services. These challenges are considered in the City’s broader efforts to improve access to opportunity and housing stability, particularly in disadvantaged neighborhoods.

Overpayment
State and federal housing law defines overpayment as a household paying more than 30% of gross income for housing expenses, including utilities, and those spending more than 50% are considered severely overpayment. Housing overpayment is especially problematic for lower-income households that have limited resources for other living expenses.

As shown in Table 23, a significant portion of lower-income households in each community overpaid for housing according to HUD CHAS data (special tabulations based on the Census ACS). However, the overpayment rate varied by tenure and income level. More than half of all very-low- and extremely-lowPage 1233 of 1565 APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 50 income households in all jurisdictions, both owners and renters, were reported to be overpaying. In most communities, however, more rental households than owner households were overpaying. Few households with incomes above the median faced overpayment – often less than 10% of households.

Table 23: Household Overpayment by Tenure
Source: HUD CHAS data based on Census ACS 2014-2018
Figures 16 and 17, based on HUD data, highlight the patterns of housing cost overpayment in Avenal.

Renters on the city's edges face relatively lower overpayment rates, ranging between 20% to 40%, and even lesser, below 20%, at the northernmost tip. In contrast, homeowners on the edges experience higher overpayment, between 40% and 60%. Central areas of Avenal show a moderate overpayment rate for homeowners, ranging from 20% to 40%. This data suggests a geographical variation in housing affordability within Avenal, with differing financial burdens for renters and homeowners across the city.

Avenal’s Program 1.10 Affordable Housing Assistance implements various strategies to continue the construction of affordable housing. The City seeks applicable grants from state and federal sources including funding specifically targeted to ELI housing, provide an inventory of housing sites to interested developers, continue to provide a density bonus to qualifying projects, and continue to pursue housing production and rehabilitation with nonprofits including assistance in preparing grant applications. Housing for very-low- and extremely-low-income households will be prioritized where feasible. In addition, the City’s affordable housing incentives will be promoted on the website and in handouts provided at the Planning counter.

Income Category Avenal Kings County
Owners
<= 30% 82.4% 79.00%
>30% to <=50% 86.7% 68.60%
>50% to <=80% 6.8% 48.30%
>80% to <=100% 17.4% 32.80%
>100% 0.0% 7.40%
Total 15.7% 22.50%
Renters
<= 30% 81.9% 79.30%
>30% to <=50% 68.1% 78.30%
>50% to <=80% 52.1% 57.00%
>80% to <=100% 0.0% 22.50%
>100% 0.0% 6.40%
Total 56.1% 43.20%

APPENDIX 2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 51 Figure 16: Overpayment by Renters (ACS, 2017-2021) – Tract Level Source: California Department of Housing and Community Development (HUD), ACS, 2017-2021

APPENDIX 2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 52 Figure 17: Percentage of Homeowners Overpaying
Source: California Department of Housing and Community Development (HUD), ACS, 2017-2021

KINGS MULTI-JURISDICTIONAL HOUSING ELEMENT | JULY 2024 | DRAFT APPENDIX 2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 53 Overcrowding
Overcrowding is often closely related to household income and the cost of housing. The U.S. Census Bureau considers a household to be overcrowded when there is more than one person per room, excluding bathrooms and kitchens; and to be severely overcrowded when there are more than 1.5 occupants per room.

Overcrowded households are usually a reflection of the lack of adequate income for housing.

Table 24 details the number and percentage of households that live in overcrowded situations. Based on the table, 16.8% of households in Avenal are overcrowded as compared to 8.6% countywide. Also, overcrowding is more prevalent among renters than owners. For example, of the household in Avenal,

18.2% of renters and 15.2% of owners reported more than one person per room. Renter households are more likely to experience overcrowding, particularly among large families and multigenerational households who lack access to larger, affordable housing units. Overcrowding can lead to negative outcomes such as health risks, stress, and decreased academic performance among children.

Figure 18 shows that CT 17.03 which includes a portion of the City, had higher percentages of severely overcrowded units and overall overcrowded units than CT 17.02.

Table 24: Overcrowding by Tenure
Source: Census ACS 2016-2020, Table B25014
Occupants per Room Avenal Kings County
Total households 2,752 43,604
Owner occupied: 1,306 23,368

0.50 or less 36.0% 60.70%

0.51 to 1.00 48.9% 34.20%

1.01 to 1.50 15.2% 3.90%

1.51 to 2.00 0.0% 0.70%

2.01 or more 0.0% 0.50%
Renter occupied: 1,446 20,236

0.50 or less 21.6% 39.70%

0.51 to 1.00 60.2% 48.10%

1.01 to 1.50 13.8% 8.70%

1.51 to 2.00 4.4% 2.90%

2.01 or more 0.0% 0.60%

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 54 Figure 18: Overcrowding in the City of Avenal
Source: California Department of Housing and Community Development (HUD), ACS, 2017-2021

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 55 Housing Conditions
Understanding the condition of the existing housing stock is essential for determining current housing needs, identifying potential health and safety risks, and developing strategies for housing preservation and rehabilitation. While the previous housing conditions survey referenced in the draft was conducted over a decade ago, the City of Avenal has supplemented this data with updated local code enforcement records, building inspection reports, and consultations with planning and housing staff to present a current, qualitative understanding of housing conditions within the community.

Age and Type of Housing Stock. According to ACS 2018–2022 data (see Table 3-3), approximately 47% of all housing units in Avenal were constructed prior to 1980. Units built before this date are more likely to lack energy-efficient features and may be at higher risk of structural deficiencies, outdated plumbing or electrical systems, and the presence of lead-based paint hazards—especially for units built before 1978.

The city’s housing stock includes a mix of single-family detached homes, multifamily units, and older rental properties that may be more vulnerable to deferred maintenance Field Observations and Code Enforcement Input. While a new citywide windshield survey has not been conducted in recent years, qualitative assessments from the City’s code enforcement division and building officials indicate that conditions have remained largely consistent since the prior formal assessment, with some observable deterioration in aging rental properties and infill neighborhoods. According to internal estimates informed by code complaints, inspection results, and property maintenance observations, the City approximates that:
• 7–10% of housing units are currently in need of moderate to substantial rehabilitation, and • Approximately 1–2% of units may be in condition that could warrant replacement due to structural unsoundness or infeasibility of repair.

Common rehabilitation needs based on local code enforcement and building department records include roofing repairs, window and siding replacement, upgraded HVAC, electrical systems, outdated plumbing, structural deficiencies, and lead-based paint mitigation in pre-1978 homes.

Housing Quality Challenges in Older Neighborhoods. Concentrations of aging housing stock are most prevalent in older parts of Avenal, particularly in lower-income census block groups. In these areas, homeownership rates tend to be lower, and renters often lack the financial resources or authority to carry out property maintenance or upgrades. As a result, renter-occupied single-family homes—especially those owned by absentee landlords—are more frequently cited for code violations related to plumbing leaks, unsafe stairways, and substandard electrical work. In response, the City has continued to enforce local health and safety codes, and remains committed to exploring avenues for rehabilitation financing or assistance, especially for lower-income homeowners and landlords willing to preserve affordable units.

Rehabilitation and Preservation Strategy. The Housing Element supports the development of a rehabilitation assistance program through Program 1.7, which aims to provide financial assistance or lowinterest loans for homeowners and rental property owners to improve housing safety and livability. The City also intends to apply for CDBG, HOME, and CalHome funds to support ongoing preservation efforts.

Targeted outreach and prioritization will be given to units located in older neighborhoods, those housing extremely low- and very low-income households, and properties cited for health and safety violations.

The updated housing conditions analysis demonstrates that, while Avenal’s housing stock has not

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 56 undergone drastic citywide deterioration in the past decade, a significant share of homes remains in need of repairs to maintain livability, health, and safety standards. Through code enforcement, housing program expansion, and regional partnerships, the City remains committed to protecting its aging housing stock and preventing displacement through proactive rehabilitation strategies.

Understanding the condition of the existing housing stock is essential for determining current housing needs, identifying potential health and safety risks, and developing strategies for housing preservation and rehabilitation. While the previous housing conditions survey referenced in the draft was conducted over a decade ago, the City of Avenal has supplemented this data with updated local code enforcement records, building inspection reports, and consultations with planning and housing staff to present a current, qualitative understanding of housing conditions within the community.

Local Knowledge. Avenal’s housing stock is predominantly older and in need of maintenance or rehabilitation, and this trend is consistent across all housing types and areas of the city. No neighborhoods have been singled out as having especially poor housing conditions, and there are no known differences in housing quality between single-family, multi-family, or mobile home units. However, because of the age of the housing stock, many homes may require safety, accessibility, or energy-efficiency upgrades.

The city has not seen any new subdivisions or master-planned developments in the past decade. As a result, there are no newer areas with upgraded infrastructure or better housing quality. Likewise, differences in rents or home prices based on housing location or age are not evident, due to the city’s broadly uniform housing supply conditions.

No areas have been identified as experiencing a disproportionate number of code enforcement complaints, and there is no data to suggest variation in housing-related violations or complaints across neighborhoods.

Disproportionate housing needs in Avenal are not concentrated in specific neighborhoods, but are broadly experienced across the city. The lack of new development, aging housing stock, and low supply contribute to widespread issues of overpayment, overcrowding, and substandard housing conditions. Addressing these challenges will require significant public investment in housing rehabilitation, expansion of affordable housing supply, and continued monitoring to ensure housing conditions remain safe and habitable for all residents.

Homelessness
Homelessness is often the result of multiple factors that converge in a person’s life. The combination of loss of employment, inability to find a job because of the need for retraining, and high housing costs lead to some individuals and families losing their housing. For others, the loss of housing is due to chronic health problems, physical disabilities, mental health disabilities or drug and alcohol addictions along with an inability to access the services and long-term support needed to address these conditions. Obtaining an accurate assessment of the magnitude of the homeless population is difficult because many individuals are not visibly homeless but rather live with relatives or friends, in hotels/motels or shelters, and other temporary accommodations. To address the needs of homeless people in Kings County, the Kings/Tulare Homeless Alliance (KTHA) conducted a Point-in-Time (PIT) survey of homeless people in these two counties in January 2022. The study used HUD’s definition of homelessness, which is defined as people who reside in emergency shelters, transitional housing, or places not meant for human habitation such as cars, parks, sidewalks, and abandoned buildings.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 57 Table 25 presents the 2022 PIT homeless counts for the four cities and unincorporated areas of the County.

The table shows that the City of Hanford had the highest counted with 260 homeless individuals or 83% of the countywide total. This was followed by the unincorporated area with 24 homeless individuals. Avenal had the lowest count with four homeless individuals.

Table 25: Homeless Persons
Jurisdiction Estimated Homeless
Avenal 4
Corcoran 17
Hanford 260
Lemoore 8
Unincorporated area 24
Kings County totals 313
Source: Kings/Tulare Homeless Alliance Point-in-Time Survey, 2022 Based on the 2022 PIT survey, the following portrait of the 313 homeless individuals counted in Kings County included:
• 22% chronically homeless
• 39% persons with disability
• 20% suffer from mental disability.
• 12% suffer from substance abuse problems.
• 11% victims of domestic violence
• 6% veterans
• 2% unaccompanied children
• 12% young adults under age 25
In 2022, 39% of the homeless population was housed in temporary living arrangements (31% in emergency shelter and 8% in transitional housing). Over half (61%) were unsheltered and homeless or in a car.

Given that there are an estimated four individuals experiencing homelessness in Avenal, there are no dedicated emergency shelter programs or housing navigation services provided directly by the City.

Additionally, the existence of such a small population of individuals experiencing homelessness in Avenal makes it difficult to provide meaningful analysis associated with patterns of need or areas of the City that are experiencing higher concentrations of persons experiencing homelessness. The existence of such a small population of individuals experiencing homelessness results in no areas of the City experiencing higher concentrations. However, for the estimated four individuals experiencing homelessness as well as individuals and households potentially facing housing insecurity in Avenal, the City relies on Kings County and statewide programs to provide support and assistance. These services may include emergency rental assistance, rapid rehousing, or homelessness prevention. Strengthening coordination with Kings County’s Continuum of Care and improving service accessibility within Avenal will be key to addressing the needs of persons at risk of or currently experiencing homelessness.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 58 Table 26 lists the shelter facilities in Kings County that served the homeless. It identifies an inventory of 126 emergency shelter beds (78% use rate), 27 transitional housing beds (89% use rate), 64 permanent supportive housing beds (89% use rate), 15 other permanent housing beds (93% use rate), and 103 rapid rehousing beds (100% use rate) in Kings County. Additional emergency assistance is provided by the Salvation Army in Hanford, which provides short-term assistance in the form of food, financial assistance for rent and utility bills, motel vouchers and bus or plane tickets. Corcoran Christian Aid provides food, vouchers, and other types of emergency financial assistance within Corcoran.

Table 26: Shelter Facilities in Kings County
Total Project Name & Organization PIT Beds Use Count Use Rate

EMERGENCY SHELTER
Barbara Saville Shelter - DV 15 4 27%
Barbara Saville Woman's Shelter 23 6 26%
EHA Kings 7 7 100%
PRK Holiday Lodge 57 57 100%
PRK Stardust Hotel 17 17 100%
Temporary Housing Program 7 7 100%
Total 126 98 78%

TRANSITIONAL HOUSING
KGM Men's Transitional 15 15 100%
KGM Women's Transitional 6 6 100%
New Song Academy 6 3 50%
Total 27 24 89%

PERMANENT SUPPORTIVE HOUSING
Anchors II 6 4 67%
Anchors IV 6 5 83%
Grace Homes 13 13 100%
Hope Survives 6 6 100%
Kings County Act 28 28 100%
Kings VASH 5 1 20%
Total 64 57 89%

OTHER PERMANENT HOUSING
HAKC Emergency Housing Voucher 15 14 93%
Total 15 14 93%

RAPID REHOUSING
Bringing Families Home 16 16 100%
HANA 4 4 100%
Housing Support Program 76 76 100%

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 59 Despite these services, a significant shortage in emergency shelters and transitional housing remains. In 2007 the State Legislature passed Senate Bill (SB) 2, which strengthened the planning and zoning requirements for emergency shelters and transitional/supportive housing. SB2 requires that all jurisdictions adopt zoning regulations that allow emergency shelters by-right in at least one zone, subject to objective development standards, or as an alternative, the jurisdiction may meet the need through a multijurisdictional agreement with up to three adjacent jurisdictions. As noted in the Constraints section, all of the jurisdictions in Kings County have adopted zoning regulations for emergency shelters and transitional/supportive housing in response to SB 2.

Avenal Program 1.13 Emergency Shelters and Transitional/Supportive Housing objective is to continue the establishment of emergency shelters and transitional/supportive housing. Avenal permits emergency shelters in the High-Density Multi-Family Residential (R-3) zone. Transitional/supportive housing is permitted as a residential use subject to the same regulations that apply to other residential uses of the same type, in the same zone, consistent with state law.

Extremely Low-Income Households
In 2006, state law was amended (Assembly Bill 2634) to add the extremely low-income (ELI) category (up to 30% AMI) to the required analysis of household characteristics and housing growth needs. Due to their limited incomes, these households have the greatest difficulty finding suitable housing at an affordable price. As previously presented in Table 5 (Household Income Distribution by Tenure), Table 27 shows that the City of Avenal consists of about 7.9% of ELI owners and 34.0% percent of ELI renters, significantly higher than the County average. According to Table 26, Avenal's ELI households also face overpayment, with 82% of ELI renter households paying more than 30% of household income on housing cost and 63% paying more that 50% of household income.

ELI households are more likely to live in older or physically deficient housing, particularly single-family rentals, which often lack energy efficiency and accessibility features. Furthermore, ELI households in Avenal are more likely to include vulnerable populations, such as seniors on fixed incomes, persons with disabilities, and female-headed households with children. These factors result in disproportionate exposure to housing instability, eviction risk, and homelessness, relative to higher income groups.

Table 27: Extremely Low Income Households Overpaying by Tenure in Avenal

Owner
Occupied Percent
Renter
Occupied Percent Total Percent
Cost Burden > 30% 70 82.4% 340 81.9% 410 82.0%
Cost Burden >50% 35 41.2% 280 67.5% 315 63.0%
Total Extremely Low Income
Households 85 415 500
Source: US Housing and Urban Development, CHAS 2014-18 (5-Year Estimates) Kings Rapid Rehousing 1 1 100%
RRH4 Kings 6 6 100%
Total 103 103 100%
Source: Kings Tulare Homeless Alliance, 2023

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 60 The housing stock available to ELI households is limited, both in quantity and suitability. Few rental units in Avenal are available at rents affordable to this income level without significant subsidy. In addition, ELI households frequently face non-financial barriers, such as poor credit, rental history requirements, and a shortage of units that accommodate disabilities or large households. These challenges are compounded by rising rental costs and limited access to tenant-based assistance such as Section 8 vouchers.

The City of Avenal recognizes that ELI households require dedicated strategies to overcome these challenges. This includes:
• Supporting the development of deeply affordable rental units through inclusionary zoning, land use incentives, and collaboration with non-profit housing developers. • Partnering with county and regional agencies to expand access to rental assistance programs, such as Section 8 and emergency housing vouchers.
• Incorporating targeted supportive housing units in new developments for populations with special needs (e.g., seniors, disabled, formerly homeless).
• Ensuring that new affordable housing units incorporate universal design and accessibility features.

These policies are reflected in the Housing Element’s Program Section (e.g., Programs 1.1, 1.11, 1.13) and are prioritized to address the disproportionate needs of the ELI population. The City also commits to monitoring ELI production and preservation outcomes annually to inform future program adjustments.

The prevalence of cost burden, overcrowding, and substandard housing conditions underscores the need for targeted housing strategies in Avenal. These challenges disproportionately impact extremely low-income households. The City will continue to prioritize programs for affordable housing development, rental assistance, housing rehabilitation, and enforcement of health and safety codes to preserve existing housing and protect vulnerable populations.

Displacement Risk
The Urban Displacement Project, a joint research and action initiative of the University of California, Berkeley, and the University of Toronto, analyzes income patterns and housing availability to determine the level of displacement risk at the census tract level. According to the Urban Displacement Project's Estimated Displacement Risk (EDR) model for California, displacement risk is determined by evaluating census tract characteristics that are strongly correlated with a net loss of low-income renter populations. Essentially, a high displacement risk suggests that more low-income households are leaving a neighborhood than moving in, often due to factors like affordability, development pressures, or changes in the housing market.

In Figure 19, the City of Avenal is considered "At risk of displacement" which refers to the likelihood of residents, particularly low-income renter households, being forced to move out of their neighborhoods due to various factors. This concept is often evaluated in the context of gentrification, rising housing costs, and changing neighborhood dynamics. Census Tract 17.02 is fully at risk of displacement while Census Tract 16.01 has only low displacement risk.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 61 Figure 19: Estimated Displacement Risk – Overall Displacement by Tract Source: California Department of Housing and Community Development (HUD), UCB – Urban Displacement Project, 2022

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 62 C. Constraints
Governmental Constraints
Development Standards and Permitting for Single Room Occupancy (SRO) Units.

Single Room Occupancy (SRO) units provide critical housing opportunities for extremely low- and very low-income individuals, including seniors, veterans, and individuals experiencing or at risk of homelessness. To effectively facilitate SRO development, jurisdictions must ensure that their zoning regulations and permitting procedures do not create undue barriers to such housing types.

In the City of Avenal, SROs are conditionally permitted in the Downtown Commercial (C-D) and Service Commercial (C-S) zones. To support the development of SROs during the 2024–2032 planning period, the Housing Element includes an expanded review of the relevant development standards and discretionary procedures that may influence the feasibility of SRO construction or conversion.

Typical barriers that may arise include excessive minimum unit sizes, restrictive parking ratios, incompatibility with mixed-use designations, or lengthy and uncertain approval timelines under the Conditional Use Permit (CUP) process. The City will evaluate whether these requirements are proportionate to the scale and purpose of SRO development. For instance, since SRO units are often less than 300 square feet, requiring standard multifamily development setbacks, open space, or parking ratios may significantly hinder feasibility.

To ensure the City's zoning ordinance actively supports the creation of SROs, the City has identified a Program 1.20 that includes of the following components:
• Minimum unit size requirements
• On-site amenity and open space standards
• Parking ratios specific to SROs
• CUP process timeline and discretionary findings
• Applicability of design review or other layers of review As part of program, SROs will be encouraged To be developed by streamlining permitting, revising development standards, and actively promoting SRO construction through partnerships with non-profits and developers targeting special needs populations. These actions will help align the City’s regulatory framework with state housing goals and ensure a diverse housing stock for individuals with limited incomes.

Reasonable Accommodation.

The City of Avenal, while outlining basic reasonable accommodation procedures, must conduct a more indepth analysis of regulatory and land-use constraints that hinder housing access for persons with disabilities.

One of the most significant barriers to reasonable accommodation is the requirement for a Conditional Use Permit (CUP) for group homes accommodating seven or more individuals, which can delay or discourage development of inclusive housing. Under federal and state fair housing laws, such as the Fair Housing Act (FHA) and California Government Code §12927(c)(1), group homes for persons with disabilities must be treated as any other residential use. Zoning codes that subject these homes to additional scrutiny can

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 63 constitute a discriminatory practice. In Avenal, residential care facilities with seven or more residents require a CUP on residential zoned land. The City is committed to including a program to revise its zoning code to permit by right residential care facilities with seven or more residents on residential zoned land.

Parking Requirements as a Potential Constraint on Housing Development.

In addition to identifying parking standards across residential zones, the Housing Element must evaluate whether these requirements constrain the development of a variety of housing types, particularly multifamily developments, studios, and one-bedroom units, which serve lower-income households and smaller households such as seniors, students, and single individuals.

In Avenal, minimum parking requirements—while consistent with traditional development patterns—may create financial and spatial constraints that limit the feasibility of higher-density or affordable housing. For example, requiring two off-street parking spaces per unit for studio or one-bedroom apartments can increase per-unit development costs due to the need for surface parking or structured parking in constrained urban sites. This can reduce the number of units that can be built, limit site design flexibility, and disincentivize small-unit construction, particularly in infill settings.

Moreover, excessive parking minimums can conflict with state density bonus law and emerging housing typologies such as modular, co-housing, and micro-units, which often require minimal parking due to targeted demographics, car-free lifestyles, or transit access. These constraints are amplified for affordable housing developers operating under funding thresholds and subsidy caps, where every added space contributes significantly to cost burdens. Industry data suggest structured parking can add $20,000–$30,000 per space, representing a substantial share of total development cost per unit.

To address these issues and align with State housing priorities, the City will commit to assessing and updating its parking requirements, with the goal of:
• Reducing parking minimums for studio and one-bedroom units; • Allowing by-right reductions or waivers for 100% affordable projects; • Introducing flexible parking ratios near transit or in mixed-use districts; • Aligning parking policies with State Density Bonus Law and SB 330 streamlining provisions.

This program will ensure that parking requirements do not unduly constrain housing supply, particularly for affordable and smaller-unit developments, and that the zoning code supports housing choice and costeffectiveness in line with California’s housing goals.

Streamlining Procedures
In addition to describing the City’s general development review process, the Housing Element must confirm compliance with SB 35 (Government Code § 65913.4), the Permit Streamlining Act, and relevant provisions of CEQA that govern timely processing of housing projects. To do so, the City will establish and document a written procedure for SB 35 streamlined ministerial approval, which applies to eligible infill housing developments that meet objective standards and affordability thresholds. The City will ensure that this process includes clear eligibility criteria, application checklists, and a 60-day completeness review process as required under state law.

Furthermore, to support housing production efficiency and certainty, the City recognizes its obligations

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 64 under the Permit Streamlining Act (Government Code §§ 65920–65964), which sets deadlines for project review, completeness determinations, and final decisions. In particular, housing development projects must be reviewed for completeness within 30 calendar days of submittal, followed by final decisions within 60 to 180 days, depending on CEQA applicability. For projects that are CEQA-exempt or subject to a negative declaration or mitigated negative declaration, the Permit Streamlining Act provides specific timing benchmarks that the City will meet.

To ensure that local procedures align with these statutory timelines, the City will update internal review protocols and publicly post updated processing timelines on its website. In addition, the City will establish a tracking and accountability system for housing-related applications to ensure compliance with SB 35 and the Permit Streamlining Act.

To formalize these efforts, a new implementation measure will be added as Program 1.21 (SB 35 and Permit Streamlining Implementation). This program will commit the City to preparing written SB 35 processing guidelines, incorporating the streamlined review timelines into departmental procedures, and training staff accordingly. The program will also identify methods for integrating CEQA review within state-mandated timeframes and developing parallel review tracks when feasible to reduce processing delays.

Zoning Adequacy for Accommodating Lower-Income Housing.

To demonstrate compliance with California Government Code Section 65583.2(c), jurisdictions must identify zoning that permits “densities appropriate to encourage and facilitate the development of housing for lower-income households”. For small jurisdictions like Avenal, this means a default density of at least 20 dwelling units per acre. While Avenal’s High Density Residential (R-3) zone satisfies this threshold, the Medium Density Residential (R-2) zone, which allows fewer than 20 units per acre, requires additional justification if used to meet the lower-income RHNA.

To demonstrate that the R-2 zone is suitable for accommodating lower-income housing, the Housing Element includes a site-specific or zone-wide analysis that addresses:
• Recent development trends in Avenal or comparable jurisdictions showing that affordable or multifamily housing has been constructed in the R-2 zone. • Market feasibility studies or pro forma analyses showing that affordable housing development is financially viable in the R-2 zone at current land values, development costs, and allowable densities.
• Developer interest or applications for affordable housing within the R-2 zone during the past planning cycle or current cycle.
• Incentives offered, such as density bonuses, streamlined approvals, reduced parking requirements, or fee waivers, which improve the financial feasibility of developing affordable units below the default density threshold.
• Additionally, the City should incorporate data on the availability of infrastructure and services, including water, sewer, roads, and transit accessibility, to show that R-2 zoned sites are not only legally but practically feasible for development during the 2024–2032 planning period. • If these justifications cannot be adequately demonstrated, the City must either:
• Identify alternate sites in the R-3 or similarly zoned areas that meet or exceed the 20 du/acre density standard, or

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 65 • Commit to a rezoning program with a defined timeline (typically within 3 years of Housing Element adoption) to increase the density of R-2 zoned parcels intended to accommodate lower-income RHNA.

Development Fees and Exactions.

In addition to listing the types of fees imposed on residential development, a complete analysis of governmental constraints must include an evaluation of the cumulative impact of development fees on housing affordability and supply, particularly for typical single-family and multifamily housing prototypes.

This analysis is important to determine whether local exactions may pose financial barriers to the production of housing—especially affordable and workforce housing—during the 6th cycle planning period.

To supplement the summary already provided, the City has evaluated the per-unit fee burden for a typical single-family unit (1,500 sq. ft.) and a multifamily unit (850 sq. ft.), using recent fee schedules and sample development scenarios. This includes planning and entitlement fees, building permit and plan check fees, public facility fees, sewer and water connection charges, and school impact fees. On average, development fees for a single-family unit total approximately $26,000 to $32,000 per unit, while for a multifamily unit, the fee burden ranges from $18,000 to $24,000 per unit, depending on project size and location.

These fees represent approximately 9% to 14% of total development costs—consistent with the countywide estimate cited in the draft (6% to 16%). However, even within this range, such fees can significantly affect project feasibility, particularly for nonprofit developers and projects reliant on Low-Income Housing Tax Credits (LIHTC), where cost containment is crucial. For smaller infill parcels or studio-unit developments, fixed per-unit fees (such as utility connections or base service charges) may disproportionately impact persquare-foot costs.

Non-Governmental Constraints
In addition to governmental regulations, several market-driven (nongovernmental) forces can significantly influence the availability, cost, and production timeline of housing units. These constraints include high land and construction costs, limited financing options for developers and buyers, delays in market response, and a tendency toward lower-density development that reduces the ability to meet RHNA targets.

Understanding these constraints is essential for devising responsive programs that support housing production across all income levels.

Land Cost and Availability.

The price and availability of land are critical determinants in housing feasibility. In California's Central Valley, including Kings County, the average land cost for residential development has increased due to inflationary pressures, land speculation, and limited supply of zoned and infrastructure-ready parcels.

According to the California Association of Realtors (CAR), land can constitute up to 40% of the total development cost for a single-family unit in small jurisdictions. In cities like Avenal, small lot sizes, limited utility extensions, and lower market demand reduce developer incentives, despite lower per-acre costs than coastal areas. The shortage of shovel-ready lots delays construction even when zoning is compliant.

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 66 Construction Costs.

The cost of materials and labor has surged significantly post-pandemic. According to the U.S. Census Bureau and National Association of Home Builders (NAHB), construction input costs rose by more than 35% between 2020 and 2023, driven by shortages in lumber, concrete, steel, and skilled labor. Small and rural cities like Avenal face additional barriers due to lack of economies of scale, limited local contractors, and higher per-unit costs for small projects. This impacts both single-family and multifamily housing and disproportionately affects affordable housing projects that depend on narrow margins.

Financing Availability.

Access to credit for developers and homebuyers remains a significant nongovernmental constraint. While mortgage interest rates have stabilized, lenders continue to impose stricter underwriting criteria, especially for low-income buyers or those seeking financing for multifamily or infill projects in smaller markets. In rural cities, developers often struggle to secure construction loans due to perceived financial risks and limited comparable sales (comps). Furthermore, small developers may lack the equity or capacity to compete for complex funding programs like LIHTC or AHSC without technical support.

Market Preferences and Density Trends.

In lower-density communities, market demand often favors detached single-family homes, driven by consumer preference and resale value. This creates a disincentive for builders to construct multifamily or higher-density housing, even when allowed by zoning. In jurisdictions where RHNA obligations require high-density units, these market preferences can result in fewer applications for by-right higher-density projects, undermining site utilization and affordable housing goals.

Development Delays and Timing Gaps.

One underappreciated constraint is the time lag between project entitlement (zoning and planning approvals) and actual construction. In small jurisdictions, this delay can be prolonged due to developers awaiting favorable market conditions, slow financing approvals, or limited builder capacity. Data from HCD indicates that in jurisdictions without streamlined permitting processes, delays of 12–24 months between entitlement and permit application are common. These delays reduce the pace of housing delivery and threaten RHNA compliance within the planning cycle.

Technological Infrastructure Limitations.

Avenal residents report poor internet and mobile connectivity citywide, which poses a barrier to modern economic participation, including remote work, online education, e-commerce, and digital services. The lack of high-speed broadband further constrains both individual economic advancement and broader business development potential.

Environmental Health
The Office of Environmental Health Hazard Assessment (OEHHA) reports CalEnviroScreen 4.0 scoresfor the unincorporated county, suggesting relatively adverse environmental conditions throughout the county. (see Figure 13). According to OEHHA, except for some of the smaller tracts in the center of the cities of

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 67 Hanford, Lemoore, and Corcoran the rest of the areas have scores above the 90th percentile. The environmental conditions in Kings County likely due to the dominance of commercial agricultural practices and natural resource extraction, both of which are known to have negative impacts on the surrounding areas resulting from air pollution and other contaminants.

The primary indicatorsleading to the high environmentalscores asreported by OEHHA’s CalEnviroScreen vary across the county, but include ozone, particulate matter (PM) 2.5, diesel PM, pesticides, toxic releases, drinking water contaminants, chemical cleanup, lead in housing, groundwater threats, hazardous waste, impaired water, and solid waste. Ozone, diesel particulate, and PM2.5, forms of pollution generated by car traffic and industrial uses, score higher throughout the county. In the unincorporated county, pesticide use, groundwater threats, and solid waste facilities are more prevalent than in urbanized areas, reflecting the presence of agricultural industries and chemical and waste storage outside of urban areas. Nearly all of Kings County is Senate Bill (SB) 535-qualifying disadvantaged communities excluding areas around Lemoore, north of Hanford and some tracts in Corcoran. This indicates that the unincorporated county represents an area of potential concern regarding fair housing and disproportionate exposure to environmental hazards and a concentration of vulnerable populations.

In Figure 20 the high CalEnviroScreen scores of 75-100% across most of Avenal and its neighboring zones indicate significant environmental and socio-economic challenges. These high scores typically reflect higher pollution burdens, greater exposure to environmental hazards, and vulnerabilities linked to socio-economic factors. In contrast, the northwestern region of Avenal, with scores between 50 and 75%, suggests relatively lower but still notable environmental and socio-economic concerns. This disparity within the city highlights the need for targeted interventions in areas with higher scores to address pollution and socio-economic vulnerabilities.

Further, the Federal Emergency Management Agency (FEMA) developsflood mapsthat identify areas with the highest risk of flooding, differentiating them by the degree of severity and frequency of flooding anticipated (Figure 21). As the map shows, the neighboring areas of Avenal exhibit a moderate fire hazard severity. Additionally, the southwest portion of the City and the northern borders exhibit areas within the 1% annual chance of flooding. This suggests a varied environmental risk profile in areas adjacent to Avenal, encompassing both fire and minimal flood risks.

Local Knowledge. Environmental conditions in the City of Avenal do not currently show significant neighborhood-level disparities, based on available local knowledge. There are no known public safety reports identifying differences in environmental quality—such as water quality, sewer infrastructure, or stormwater circulation—between neighborhoods. However, the absence of formal data may limit the city’s ability to proactively address potential environmental justice concerns.

Some potential sources of pollution have been identified:
• The local landfill, which may pose air or groundwater contamination risks, although no environmental testing data is currently available to confirm the extent of its impact. • Lead-based paint exposure in older housing stock may be another concern, particularly given the citywide aging condition of housing. Again, the city does not maintain data on the prevalence of this hazard.

There is no known environmental condition or site formally identified as unsuitable for residential development, nor has the city identified any existing developments significantly affected by environmental

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 68 hazards. However, without detailed environmental assessments, these risks remain undocumented but possible.

In terms of access to outdoor amenities, the city has made strides in providing park space and recreational facilities. However, park distribution is uneven, with most facilities concentrated in the northeastern and southwestern areas of Avenal. The eastern and northern portions of the city are noted to lack convenient access to parks and open spaces, which may limit opportunities for physical activity, especially for lowincome families and youth in those areas.

Other key amenities—such as grocery stores and retail centers—are limited across the city. There are no reported disparities between neighborhoods in terms of access to healthy foods or shopping, but rather a citywide lack of commercial retail options, which contributes to Avenal being considered a “food desert” community under some definitions.

The city has not developed any new subdivisions or master-planned areas in recent years, and therefore no significant differences in environmental infrastructure, park availability, or public space access have emerged through new development patterns.

In conclusion, while Avenal does not show evidence of environmental disparities between neighborhoods, the city faces broad environmental challenges related to aging infrastructure, possible pollution sources, and limited park and food access in certain areas. These issues underscore the importance of environmental monitoring and equitable distribution of green space and resources in future planning and capital improvement strategies
Environmental Constraints
A community’s environmental setting affects the feasibility and cost of developing housing.

Environmental issues range from the availability of water to the suitability of land for development due to potential exposure to seismic, flooding, wildfire, and other hazards. If not properly recognized and accommodated in residential design, these environmental features could potentially increase the cost of housing and also endanger lives and property. This section summarizes environmental constraints to housing development in the city.

Floodplains
Portions of Avenal are within the 100-year floodplain as identified by the Federal Emergency Management Agency (FEMA) on their Flood Insurance Rate Map (see Figure ##).

Almost all of this area is west of State Highway 33 and wisely, the City has directed urban growth (including residential development) to the east of Highway 33. A smaller area located within the 100- year floodplain is situated along the channel of Arroyo Del Camino which emanates from the Kettleman Hills on the north side of the City. However, this flood area is focused within the immediate channel though it widens to a larger flood plain south of the urban area.

The City has enacted measures to mitigate flood risk including elevated building pads and foundations above the known flood level. Complying with flood plain requirements (such as elevating building pads) does generate an added cost but is not a constraint.

Seismic Zones and Landslide Potential
Avenal lies within a seismically active area. An earthquake measuring 6.7 on the Richter scale (Rs)

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 69 occurred in the Coalinga area in 1983, while a quake of 5.5 on the Rs occurred in the Avenal area in 1985.

This quake had its epicenter five miles northeast of Avenal in the Kettleman Hills. This quake caused widespread cracks in buildings and pavement and broke numerous windows. Structural failures did not result from this event. Seven potentially active faults are located within 70 miles of Avenal, including a thrust fault lying 6-8 miles below the central axis of the Kettleman Hills anticline. This thrust fault appears to have caused the Coalinga and Avenal earthquakes. The United States Geological Survey Earthquake Faults and Landslide Map (summarized as Figure 7-5 in the Avenal General Plan) indicates that areas within the Kettleman Hills are moderately susceptible to landslides. The City has not designated any of these areas for residential development, so the potential impact on housing is minimal.

In order to offset potential impacts from seismic activity, Avenal requires all new residential construction to conform to the California Building Code Zone III standards. Compliance with these requirements does increase the cost of housing but recent projects indicate that this cost increase is not significant.

Wildfire
Wildland fire hazards have the potential to threaten life and property within portions of the City. Map 7- 2 from the Avenal General Plan is based on data from CalFire and summarizes wildfire threats and indicates that the bulk of the city limits within the Kettleman Hills is subject to fire hazard, owing to steep slopes and grassy areas. Where the slopes interface with the urban areas of the City the fire hazard is defined as “High”. For this reason, the City has directed most future urban development (including residential development) away from these areas.

Structural fires usually result from man-made causes and threaten industrial, residential and commercial structures, especially those built before building and fire codes were established. These substandard structures represent the highest potential for injury, death, or loss of property.

Kings County Fire Department is responsible for wildfire and urban fire prevention activities in the city.

To reduce the potential impact of fires, the City ensures that developments comply with California Fire and Building Code requirements for health and safety though the city’s site plan review process.

Soils
Agricultural uses may contaminate sites due to the use of pesticides and other chemicals. Soil contamination may be a concern if a Phase One Environmental Site Assessment determines there is a potential for soil contamination and contamination is substantiated by a Phase Two study.

The City ensures that the necessary steps are taken to clean up residual hazardous wastes on any contaminated sites proposed for redevelopment or reuse. Soil evaluations are required as needed to ensure that risks are assessed, and appropriate remediation is provided. Developing housing on these sites can involve costs to remediate contaminated soil or groundwater. The remediation cost would typically be on the developer to address the clean-up and potential site contamination is not considered a constraint.

Conclusion
Environmental conditions in Avenal are not considered a constraint to development on identified sites and there are no other known conditions that preclude development such as access, shape, easements, environmental overlays, Williamson act contracts, conservation easements or contamination.

Recommended Action: None required.

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 70 Figure 20: CalEnviroScreen 4.0
Source: Caltrans, 2022; OEHHA, 2021.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 71 Figure 21: Flood Hazard Zones
Source: Federal Emergency Management Agency (FEMA), 2022; OEHHA, 2021; CalFire, updated 2023.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 72 D. Local Data, Knowledge, and Other Relevant Factors
The local information in this section was developed from local staff input, demographic characteristics, historical context, and observed trends affecting various population groups.

Segregation and Integration
Disability. There are no identified geographic concentrations of persons with disabilities in the City of Avenal. Based on local knowledge, individuals with disabilities appear to be dispersed uniformly throughout the community, with no particular areas identified as having a higher or lower presence of this population group.

The city currently has no known group homes or residential care facilities (RCFs) within its jurisdiction.

Similarly, there are no records of permits issued for residential accessibility modifications—such as ramps or structural accommodations—and no requests for reasonable accommodations were received during the previous planning period. This absence of activity may reflect limited demand, underreporting, or a lack of awareness among residents about available resources and rights under fair housing law.

There are also no known recent accessibility improvements to the housing stock or public infrastructure, and no areas of the city have been identified as being in greater need of accessibility enhancements.

However, given Avenal’s aging housing stock and absence of new construction, there may be citywide deficiencies in accessible housing features, even if not formally documented.

Overall, while there is no evidence of disability-related segregation, the lack of documented accommodations or infrastructure upgrades highlights an opportunity for the City to enhance outreach, support inclusive housing practices, and ensure that persons with disabilities can access housing and community resources on an equal basis. Future planning efforts should consider proactive strategies to identify and address potential accessibility gaps across Avenal.

Familial Status. The City of Avenal does not exhibit any patterns of familial segregation. Families are distributed evenly across all areas of the city, with no neighborhoods identified as having a disproportionate concentration of either family or non-family households. This reflects the city’s compact geography and the relatively uniform nature of its housing stock, which primarily consists of single-family homes suitable for households of various sizes.

There are two licensed child care facilities within the city: Maria Resendez Family Child Care and KCAO Oasis Opportunity, located on the eastern and southern boundaries of Avenal. While these facilities provide essential early childhood services, their peripheral locations suggest that residents in other parts of the city may have limited access to nearby child care options. However, due to the small size of the city, travel distances to these facilities are relatively modest and do not present a major barrier.

Overall, there is no evidence of segregation based on familial status, and households with children appear to have citywide access to residential areas. Nevertheless, the limited number and geographic concentration of child care providers highlight the need to explore strategies to expand child care access equitably as part of broader efforts to support families and working parents across the community.

Segregation and Integration – Income

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 73 The City of Avenal is characterized by widespread economic disadvantage, with the entire city considered a lower-income or high-poverty area. There are no areas within the city identified as higher-income, nor are there noticeable income disparities between neighborhoods. This uniformity is largely influenced by the city's economic base, which includes employment sectors such as corrections, agriculture, and public education—industries that typically provide limited income variability among residents.

While income levels are generally consistent across the city, there is some localized concentration of Housing Choice Voucher (HCV)/Section 8 households, particularly near the eastern and southern boundaries of the city, including areas such as El Palmar and Heartstone Village. These areas likely offer rental units that meet affordability criteria and housing quality standards required for voucher acceptance, though there is no indication of formal income-based segregation or exclusion in other parts of Avenal.

In terms of publicly financed housing, no developments supported by federal, state, or local housing finance programs (such as LIHTC) are currently known to exist within the city. The absence of such developments suggests a gap in permanently affordable housing infrastructure, which could limit long-term housing stability for extremely low- and very low-income residents.

In conclusion, while Avenal does not demonstrate income segregation at the neighborhood level, the citywide economic vulnerability and localized presence of voucher holders highlight the need for expanded affordable housing options and greater housing investment to improve income-based housing equity. Future planning efforts should prioritize the development of income-restricted units and support services to stabilize housing for the most economically disadvantaged residents.

Disparities in Access to Opportunity
Economic. The economic landscape of the City of Avenal is defined by a limited number of major employers, most notably Avenal State Prison and the Reef-Sunset School District, both located within city limits. A significant number of residents are also employed by Wonderful Pistachios, a large agricultural processor located over 30 minutes away in Lost Hills, California. This reliance on a small number of public sector and agricultural employers contributes to the city’s economic vulnerability and limits opportunities for economic diversification or upward mobility.

Historically, Avenal was developed around a thriving oil industry, which once supported a more diverse and prosperous local economy. However, the collapse of the oil sector led to significant job losses and a population decline, from which the city has not fully recovered. Since then, no new commercial or industrial centers have been developed within the city or in surrounding areas that would meaningfully expand local employment opportunities.

Avenal also faces significant technological and infrastructure limitations. Residents report poor internet and mobile connectivity citywide, which poses a barrier to modern economic participation, including remote work, online education, e-commerce, and digital services. The lack of high-speed broadband further constrains both individual economic advancement and broader business development potential.

At present, there are no known economic development programs or workforce initiatives in place within the city that are aimed at revitalizing the local economy or preparing the workforce for future industry needs. Without targeted investment or policy intervention, this economic stagnation is likely to persist, continuing to limit residents' access to high-quality job opportunities.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 74 In summary, economic opportunity in Avenal is restricted by a narrow employment base, the absence of development initiatives, and infrastructure barriers such as poor internet access. These conditions affect all residents broadly, with no significant neighborhood-level disparities. However, they represent a citywide challenge to fair housing choice, as limited economic mobility may prevent residents—particularly lowerincome and renter households—from affording stable, quality housing or relocating to opportunity-rich areas.

Transportation. The City of Avenal is served by the Kings Area Regional Transit (KART) system, which provides limited public transportation options within the county. A single fixed-route line operates in Avenal, with connections to Hanford and Lemoore—two larger cities that offer greater access to jobs, healthcare, and services. Locally, this transit line follows a loop path along Highway 269 and San Joaquin Street, with all designated stops located north of Highway 269.

While the KART system offers essential connectivity, transit service coverage and frequency are limited, and access is less convenient for residents living south of Highway 269. Additionally, the city lacks dedicated infrastructure for alternative transportation modes, such as protected bicycle lanes or fully connected pedestrian pathways. Although some roads feature “share the road” signage, there is no formal bike network, and walking paths are incomplete in certain areas.

Residents without access to a private vehicle face significant transportation challenges. Many rely on informal ride-sharing arrangements, often paying neighbors or acquaintances for transportation to work or appointments. The Avenal State Prison provides van services for employees, which helps offset the transportation burden for some. However, these solutions are inconsistent and not accessible to all residents, particularly those who need reliable access to medical care, educational institutions, or regional employment centers.

The physical condition of local roads varies. While most neighborhoods have streetlights, they are inconsistent at intersections, and overall road conditions are fair to poor, though the city has initiated a routine maintenance program. The only identified high-collision corridor is Skyline Boulevard, which also carries the most traffic volume.

To improve safety and mobility, the city has adopted a Safe Routes to School Plan and is actively seeking Active Transportation Program (ATP) funding for its implementation. This plan is designed to enhance pedestrian and bicycle infrastructure, especially for students. Most neighborhoods have sidewalks, and there are no major differences in pedestrian infrastructure access between neighborhoods.

Recent and ongoing infrastructure improvements include:
• Reconstruction of 7th Avenue
• Development of a new pocket park with fitness equipment • Construction of a community building/sports facility on Hydril • Planned 7th Avenue Trail from Skyline to Mariposa, for recreational and active transportation use While Avenal’s transportation infrastructure does not exhibit stark neighborhood disparities, the city as a whole faces significant transportation limitation that constrain residents' access to opportunity. These include limited public transit, poor internet connectivity for telecommuting, minimal bike infrastructure, and an overreliance on informal transportation networks. Continued investment in multimodal

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 75 infrastructure and transportation equity will be essential to meet the needs of low-income, transit-dependent, and non-driving residents.

Environment. Environmental conditions in the City of Avenal do not currently show significant neighborhood-level disparities, based on available local knowledge. There are no known public safety reports identifying differences in environmental quality—such as water quality, sewer infrastructure, or stormwater circulation—between neighborhoods. However, the absence of formal data may limit the city’s ability to proactively address potential environmental justice concerns.

Some potential sources of pollution have been identified:
• The local landfill, which may pose air or groundwater contamination risks, although no environmental testing data is currently available to confirm the extent of its impact. • Lead-based paint exposure in older housing stock may be another concern, particularly given the citywide aging condition of housing. Again, the city does not maintain data on the prevalence of this hazard.

There is no known environmental condition or site formally identified as unsuitable for residential development, nor has the city identified any existing developments significantly affected by environmental hazards. However, without detailed environmental assessments, these risks remain undocumented but possible.

In terms of access to outdoor amenities, the city has made strides in providing park space and recreational facilities. However, park distribution is uneven, with most facilities concentrated in the northeastern and southwestern areas of Avenal. The eastern and northern portions of the city are noted to lack convenient access to parks and open spaces, which may limit opportunities for physical activity, especially for lowincome families and youth in those areas.

Other key amenities—such as grocery stores and retail centers—are limited across the city. There are no reported disparities between neighborhoods in terms of access to healthy foods or shopping, but rather a citywide lack of commercial retail options, which contributes to Avenal being considered a “food desert” community under some definitions.

The city has not developed any new subdivisions or master-planned areas in recent years, and therefore no significant differences in environmental infrastructure, park availability, or public space access have emerged through new development patterns.

In conclusion, while Avenal does not show evidence of environmental disparities between neighborhoods, the city faces broad environmental challenges related to aging infrastructure, possible pollution sources, and limited park and food access in certain areas. These issues underscore the importance of environmental monitoring and equitable distribution of green space and resources in future planning and capital improvement strategies.

Disproportionate Housing Needs, Including Displacement
Overpayment. The City of Avenal is experiencing a citywide increase in housing costs, largely driven by a chronic shortage of available housing units. Both rental and for-sale prices have risen, although no neighborhood-specific differences in pricing have been identified. Given the city’s uniformly low-income population, these rising costs are likely to result in a high incidence of housing cost burden (overpayment), particularly among renter households. However, no data is available to document eviction or foreclosure

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KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 76 patterns by neighborhood, and no formal records suggest localized displacement pressures.

Overcrowding. While no specific areas have been identified as having high rates of overcrowding, local knowledge suggests that overcrowding and multi-generational living are common citywide, particularly in response to housing shortages and affordability constraints. The lack of formal code enforcement data on this issue may mask the true extent of the problem.

Housing Conditions. Avenal’s housing stock is predominantly older and in need of maintenance or rehabilitation, and this trend is consistent across all housing types and areas of the city. No neighborhoods have been singled out as having especially poor housing conditions, and there are no known differences in housing quality between single-family, multi-family, or mobile home units. However, because of the age of the housing stock, many homes may require safety, accessibility, or energy-efficiency upgrades.

The city has not seen any new subdivisions or master-planned developments in the past decade. As a result, there are no newer areas with upgraded infrastructure or better housing quality. Likewise, differences in rents or home prices based on housing location or age are not evident, due to the city’s broadly uniform housing supply conditions.

There is very limited housing availability citywide, regardless of housing type or price point. This lack of supply exacerbates both overcrowding and cost burden, while reducing mobility and housing choice for residents.

No areas have been identified as experiencing a disproportionate number of code enforcement complaints, and there is no data to suggest variation in housing-related violations or complaints across neighborhoods.

Disproportionate housing needs in Avenal are not concentrated in specific neighborhoods, but are broadly experienced across the city. The lack of new development, aging housing stock, and low supply contribute to widespread issues of overpayment, overcrowding, and substandard housing conditions. Addressing these challenges will require significant public investment in housing rehabilitation, expansion of affordable housing supply, and continued monitoring to ensure housing conditions remain safe and habitable for all residents.

Persons Experiencing Homelessness. At this time, the City of Avenal reports no known locations where individuals experiencing homelessness congregate, such as informal encampments, vehicle-dwelling sites, or daytime gathering spots near public amenities like parks or libraries. This may reflect the small size and rural character of the city, the absence of local homelessness services, or underreporting or limited visibility of the unhoused population.

There are no dedicated emergency shelter programs or housing navigation services provided directly by the City. Instead, Avenal relies on Kings County and statewide programs to support individuals facing housing insecurity. These services may include emergency rental assistance, rapid rehousing, or homelessness prevention programs, though access is centralized at the county level and may not be easily navigable for all Avenal residents, particularly those without reliable transportation or internet access.

There are no neighborhood-level differences in access to these resources because such programs are not administered locally. This citywide absence of service delivery infrastructure underscores the importance of regional collaboration, as well as the need to enhance local outreach and referral networks to ensure vulnerable residents are connected with available resources.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 77 In conclusion, while there is no visible concentration of homelessness within Avenal, the lack of local shelters, support services, and direct data collection may mask the extent of housing insecurity in the community. Strengthening coordination with Kings County’s Continuum of Care and improving service accessibility within Avenal will be key to addressing the needs of persons at risk of or currently experiencing homelessness.

Displacement. Figure 19 shows that Census Tract 17.02 is fully at risk of displacement while Census Tract

16.01 has only low displacement risk. The City of Avenal has not identified any specific neighborhoods that have experienced significant displacement due to rising rents or home prices. However, local knowledge indicates that a lack of overall housing availability has led to increased housing costs and overcrowding across the city, which may exert indirect displacement pressure, particularly on low-income renters. Despite this trend, there is no formal documentation of widespread evictions or resident displacement attributed to redevelopment, gentrification, or infrastructure projects.

There have been no major local events—such as rezoning, demolitions, or natural disasters—that directly caused displacement. Instead, displacement risks in Avenal are largely driven by longstanding underinvestment in new housing and infrastructure, which constrains housing supply and limits residential mobility.

In terms of environmental risk, no areas within Avenal have been identified as more susceptible to damage due to building age, structural design, or environmental exposure. The city's housing stock is uniformly older, but there is no current data indicating elevated environmental vulnerability or differential risk between neighborhoods.

Additionally, the city does not conduct defensible space inspections or other proactive environmental hazard mitigation programs. There are no known areas prone to flash flooding or related environmental conditions outside of FEMA-designated zones that would impact residential stability.

In summary, while Avenal is not currently experiencing acute or localized displacement, the citywide housing shortage and increasing cost burden pose a chronic displacement risk, particularly for low-income and overcrowded households. Addressing these risks will require new affordable housing development, rehabilitation of existing units, and targeted investment to stabilize vulnerable residents before displacement becomes more pronounced.

Other Relevant Factors Influencing Fair Housing Conditions Avenal’s socio-economic development has been shaped by a distinct historical and economic trajectory.

Originally established as a booming oil town, the city once attracted a more affluent population. However, following the collapse of the local oil industry, Avenal experienced significant population decline and economic disinvestment. In the 1960s and thereafter, the city was repopulated largely by migrant agricultural workers, contributing to a lasting shift in both the city’s demographic composition and income distribution.

There is no documented history of redlining, restrictive covenants, or racially exclusionary zoning practices, though formal records are limited. Likewise, there are no known past zoning or land use decisions that directly influenced present-day socio-economic disparities. That said, the lack of housing and economic reinvestment since the oil industry's decline has likely contributed to persistent poverty and limited housing choice.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 78 Settlement patterns in Avenal have remained relatively stable over the past several decades, with little to no new major housing or commercial developments. The absence of recent subdivisions or master-planned communities reflects the city’s limited growth and constrained investment climate.

Avenal’s land use pattern is significantly shaped by transportation corridors and major facilities. The city is bordered by Highway 33 to the west and bisected by Highway 269, which connects to Interstate 5 approximately five miles to the north. These roadways influence the city’s connectivity and may create subtle barriers in land use or access to services. Additionally, two major land uses—the Avenal State Prison and the city landfill—play outsized roles in the city’s economy and spatial development. While these facilities provide jobs and revenue, they may also deter private sector investment in surrounding areas, contributing to a lack of diverse economic activity and housing development.

There are no recent engineering assessments or capital improvement reports available that identify differences in infrastructure quality or public safety between neighborhoods. As such, current understanding of disparities in infrastructure access or service delivery is based primarily on qualitative observation and local knowledge rather than empirical evaluation.

Avenal’s economic legacy, migration patterns, infrastructure placement, and limited development activity all contribute to current housing and opportunity patterns. While the city does not have a documented history of exclusionary policies, it faces structural challenges stemming from historical economic shifts, limited reinvestment, and geographic isolation that warrant targeted attention in future housing and community development planning.

E. Sites Analysis
This section provides a review of available vacant sites in the City of Avenal that would allow for and facilitate production of the city’s regional share of housing as required by State Law. This data is supplemented with local knowledge of existing conditions in the community to present a more accurate depiction of fair housing issues in the City. Figures 22 and 23 present the vacant sites inventory of the City of Avenal.

To ensure adequate capacity for meeting the City of Avenal’s 2024–2032 Regional Housing Needs Allocation (RHNA), the Housing Element includes a detailed inventory of land suitable for residential development. This includes both vacant parcels and non-vacant sites with realistic redevelopment potential, categorized and analyzed by zoning designation, existing use, and income level potential. Housing Element Appendix B: Land Use Inventory present parcel-level data for each site identified, including:
• Parcel size and Assessor’s Parcel Number (APN)
• General Plan designation and zoning classification
• Current use and existing structures (if any)
• Realistic unit capacity based on allowed densities
• Status (vacant or underutilized)
• Income category assignment
• Availability of infrastructure

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 79 Figure 22: City of Avenal Vacant Sites 6,000 Square Feet or Greater

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 80 Figure 23: City of Avenal Vacant Sites by Income Level

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 81 Figure 24: City of Avenal by Block Groups

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 82 Figure 25: Low to Moderate Income Population by Block Group Sources: California Department of Housing and Community Development (HUD), 2011-2015. Updated: March, 2023.

Redevelopment Potential of Non-vacant Sites
The City of Avenal is able to fulfill its lower-income RHNA obligations through utilizing vacant sites. The City has a RHNA allocation of 85 Extremely Low/Very Low/Low income units and 55 Moderate units.

The City’s land inventory is capable of accommodating 375 Extremely Low/Very Low and Low income units with vacant land designated for High Density Residential (R3) development. Two additional underutilized sites (APNs 038-432-012 and 038-432-010) zoned R3 are included in the Sites Inventory with a capacity of accommodating an additional 24 lower income units. However, these sites are not being depended upon to demonstrate the City’s ability to meet the RHNA lower income RHNA requirements.

Similarly, the City’s land inventory is capable of accommodating 196 Moderate units with vacant land designated for Medium Density Residential (R2) development. One additional underutilized site (APN 038-280-043) zoned R2 is included in the Sites Inventory with a capacity of accommodating an additional 48 moderate income units. Therefore, the City concludes that it has identify more than triple the amount of vacant land at appropriate densities to accommodate its lower and moderate income RHNA allocations.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 83 Infrastructure and Public Services Availability
All identified sites are located within areas served by existing municipal infrastructure, including water, sewer, storm drainage, and roadway access, as verified through coordination with the City’s Public Works and Utilities Departments. The FHA confirms that no major infrastructure extensions are needed to support development on these parcels during the 2024–2032 planning period. These sites also benefit from access to public transit routes, proximity to schools and parks, and proximity to commercial services, meeting state guidance for access to opportunity and promoting infill development consistent with environmental sustainability goals.

Small Sites Analysis
The City of Avenal acknowledges the importance of demonstrating the realistic potential for lower-income housing development on small sites, particularly those less than 0.5 acres in size. Data from the recent Census for Avenal on the suitability of small sites indicate that smaller, infill multifamily projects represent a growing share of new residential development, particularly in other cities in the county such as Hanford, Lemoore, and Corcoran, where land costs are comparatively moderate. Between 2017 and 2022, approximately 28% of new multifamily units were constructed on parcels smaller than 0.5 acres, achieving densities between 20 to 28 units per acre4
. Specific examples of small sites include:
• Hanford – Elm Street Apartments (2021): Developed on a 0.45-acre site, achieved a density of 24 units per acre, and provided 6 units affordable to lower-income households through project-based voucher support.
• Lemoore – East D Street Flats (2020): Constructed on a 0.38-acre site, achieving a density of 26 units per acre, with 5 units reserved for very low-income households.

Sites Inventory Findings
Table 28 provides a summary of the RHNA allocation by income category and compares it with the total unit capacity identified across the site inventory. This ensures that the City has designated adequate capacity, including an identified buffer, to meet its assigned housing needs. The RHNA includes allocations for extremely low-, very low-, low-, moderate-, and above moderate-income units, all of which are addressed through the collective development potential of listed sites. Based on the site inventory presented in Appendix B, there are adequate sites to accommodate the RHNA housing units figures for Avenal.

Table 28: Land Inventory and RHNA Targets
City of Avenal
Income Category
EL/VL Low Mod Total
Above
Mod
RHNA (Table 2-32) 48 37 55 137 277
Housing sites 399 244 1,822 1,966
Adequate Capacity Yes Yes Yes Yes
4 US Census / ACS Building Permits Survey 2022

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 84 The land use inventory tables in Appendix B clearly distinguish between vacant sites zoned for residential use and underutilized infill parcels within areas supported by existing infrastructure, allowable densities of the General Plan and Zoning Ordinance, size of the parcel, and public/private ownership.

The identified sites are located in zoning districts that allow residential development by right or with minimal entitlement requirements. High- and medium-density zones such as R-2, R-3, and Mixed-Use Residential (MUR) provide opportunities for multi-family housing at densities consistent with accommodating lower-income units. The default density threshold established under Government Code § 65583.2(c)(3)(B) for small jurisdictions in Kings County is met or exceeded on applicable sites.

The Element also describes development standards that ensure feasibility, such as minimum lot sizes, parking requirements, height allowances, and open space ratios, with reference to the Avenal Zoning Code.

These standards have been reviewed to confirm that they do not unreasonably constrain development potential on sites listed for lower-income housing.

Census Tract 16.01. The only area identified as a Moderate Resource in the City of Avenal. It is also an area identified as High POC Segregation. All the census tracts in the City of Avenal are in the highest percentile bracket of the CalEnviroScreen 4.0 score that measures environmental hazard risk. One of the disadvantages of this area is that it does not provide access to employment opportunities within a 45 minute commute. There are no vacant sites identified in census tract 16.01.

Census Tract 17.02. This census tract is identified as an area with High Segregation and Poverty. This census tract has the highest rates of poverty and overpayment by renters in the City of Avenal. All the census tracts in the City of Avenal are in the highest percentile bracket of the CalEnviroScreen 4.0 score that measures environmental hazard risk. A portion of the census tract is in the 1% Annual Chance Flood Hazard. The majority of the vacant land in census tract 17.02 is outside of the 1% Annual Chance Flood Hazard. The sites accommodate lower density housing production.

Census Tract 17.03. This census tract is identified as an area with High Segregation and Poverty. This census tract has a higher percentage of overpayment by owners compared to renters. It also has the highest rates of overcrowded and severely overcrowded units. All the census tracts in the City of Avenal are in the highest percentile bracket of the CalEnviroScreen 4.0 score that measures environmental hazard risk.

Census Tract 9818. This census tract consists of the Avenal State Prison. There are no vacant sites identified in this census tract.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 85 Table 29: Characteristics by City of Avenal Census Tracts Characteristics Census Tract

16.01 Census Tract

17.02 Census Tract

17.03 Census Tract
9818
TCAC/HCD Opportunity
Areas
Moderate
Resource
High Segregation &
Poverty
High Segregation &
Poverty
N/A
Local Median Income $35,000 - $60,000 $35,000 - $60,000 $35,000 - $60,000 N/A Poverty Status 20% - 30% 30% -40% 10% - 20% < 10%
Local Racial
Demographics
High POC
Segregation N/A N/A Racially Integrated
Local RCAAs Not a RCAA Not a RCAA Not a RCAA Not a RCAA Single Parent Female
Headed Households with
Children
20% - 40% 20% - 40% 20% - 40% N/A
Population with a
Disability
< 10% 10% - 20% < 10% < 10%
Jobs Within 45-Minute
Transit Commute
0 1 – 2,500
1-2,500
A small portion to
the south has
1 – 2,500
0 CalEnviroScreen 4.0 75% - 100% 75% - 100% 75% - 100% N/A Flood Hazard Zones and
Fire Hazard Severity
Zones
Small north portion
contain 1% Annual
Chance Flood
Hazard
Southern portions
contain 1% Annual
Chance Flood
Hazard
Southern portions
contain 1% Annual
Chance Flood
Hazard
No identified flood
hazard
No Identified Risk No Identified Risk No Identified Risk No Identified Risk Overcrowded Units 10%-15% 5.19% - 10% 10%-15% N/A
Severely Overcrowded
Units < 2.5% < 2.5% 2.5%-6.5% N/A
Overpayment by Renters < 20% 40% - 60% 20%-40% N/A
Overpayment by
Homeowners 20%-40% < 20% 20%-40% N/A
Estimated Displacement
Risk
At Risk
Displacement
At Risk
Displacement
At Risk
Displacement N/A
Table 30 below provides additional details regarding the distribution of housing sites throughout the City.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 86 Table 30: Identified Sites and Affirmatively Furthering Fair Housing (AFFH) Characteristic Census Tract

16.01 Census Tract

17.02 Census Tract

17.03 Census Tract
9818
Socio-economic Characteristics
TCAC Resource Category Moderate Resource High Segregation & Poverty
High Segregation &
Poverty
N/A
Median Income $35,000 - $60,000 $35,000 - $60,000 $35,000 - $60,000 N/A Poverty Level 20% - 30% 30% -40% 10% - 20% < 10%
Persons with Disabilities < 10% 10% - 20% < 10% < 10%
Overpayment < 20% 40% - 60% 20%-40% N/A
Overcrowding 10%-15% 5.19% - 10% 10%-15% N/A
Displacement Risk At Risk
Displacement
At Risk
Displacement
At Risk
Displacement N/A
Regional Housing Need Allocation
Lower Income 0 92 307 0
Moderate Income 0 2 242 0
Above Moderate Income 0 524 655 0
TOTAL 0 618 1,204 0
Discussion
• Distribution of the total RHNA
The City’s housing capacity to accommodate its RHNA is highly concentrated within Census Tracts 17.02 and 17.03, which together account for 100 percent of the total identified residential capacity. Specifically, Census Tract 17.02 contains 976 units of capacity and Census Tract 17.03 contains 362 units, while no capacity is located in Census Tract 16.01 or Census Tract 9818. This concentration reflects the City’s geographic extent, as the majority of the City lies within these two census tracts. • Magnitude of the Distribution on Socio-Economic Characteristics The magnitude of the impact on socio-economic characteristics is minimal, as all housing capacity is located within Census Tracts 17.02 and 17.03, both of which are designated as High Segregation & Poverty areas.

These conditions indicate that socio-economic characteristics such as lower median incomes and higher poverty rates are present throughout the City. As a result, future housing development is likely to occur within areas that already experience these conditions.
• Lower-income RHNA Concentrations and the Magnitude of the Impact

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 87 Lower-income housing capacity is concentrated entirely within Census Tracts 17.02 and 17.03, with 92 units located in Tract 17.02 and 307 units located in Tract 17.03. No lower-income capacity is identified in Census Tract 16.01 or Census Tract 9818. As a result, 100 percent of the City’s lower-income housing capacity is located within areas designated as High Segregation & Poverty. The magnitude of this concentration is significant, as it reflects existing citywide socio-economic conditions and limits opportunities to distribute lower-income housing in areas of varying resource levels. • Moderate and Above Moderate-income RHNA and the Magnitude of the Impact Moderate and above moderate-income housing capacity is also concentrated within Census Tracts 17.02 and

17.03. Moderate-income capacity is located almost entirely within Census Tract 17.03, while above moderateincome capacity is distributed between both tracts, with 524 units in Tract 17.02 and 655 units in Tract 17.03.

No moderate- or above moderate-income capacity is located in Census Tract 16.01 or Census Tract 9818.

The magnitude of this concentration is significant, as all housing capacity across income levels is located within areas designated as High Segregation & Poverty.

Conclusion:

Overall, the identified sites are likely to maintain existing socio-economic patterns, as housing capacity across all income levels is concentrated within areas designated as High Segregation & Poverty.

Identification of Contributing Factors and Fair Housing The City of Avenal supports the recommendations of the 2014 San Joaquin Valley Fair Housing and Equity Assessment (FHEA) that was prepared by the California Coalition for Rural Housing. The FHEA analyzes patterns in racial and economic segregation, discusses how segregation impacts individuals’ and families’ ability to access housing opportunity, and proposes strategies and recommendations to create more equitable and integrated communities.

Based on the issues identified in this Fair Housing Analysis, the following are the top 5 issues to be addressed through the programs in the Housing Plan:

1. Maintaining and preserving the existing affordable housing stock;

2. Assisting in the provision of housing;

3. Removing governmental constraints, as necessary;

4. Providing adequate sites to achieve a variety and diversity of housing; and

5. Promoting equal housing opportunity.

After considering these issues and FHEA recommendations, the City has identified in Table 30 - potential contributing factors to fair housing issues in Avenal and outlines the meaningful actions to be taken. The meaningful actions listed in the Table relate to the actions identified in the Housing Element.

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 88 Table 31: Factors Contributing to Fair Housing Issues
Fair Housing Issue Contributing Factors Priority Meaningful Actions Limitations in local
Consolidated Planning
Processes, ongoing CDBG and
HOME funding allocations,
Housing Elements Processes,
and other city planning
documents.

Existing low-density
residential
development under
general plan and
zoning code
Gap between low
density and medium
density and highdensity classification
High Program 1.10 Assist
Affordable Housing:

Through direct financial
assistance such as CDBG
and HOME, priority
entitlement processing,
regulatory incentives such as
density bonus and modified
development standards
Assist in the provision of
housing by removing
government constraints and
promoting equal housing
opportunity
Limitations in zoning
code and density
classifications
Permission of preapproved design, and
development standards
High Programs 1.9 Section 8
Rental Assistance
Program 1.13 Emergency
Shelters and
Transitional/Supportive
Housing
Program 1.14 Farmworker
and Employee Housing
Program 1.11 Special Needs
Housing for Seniors and
Persons with Disabilities
Funding for marginalized or
distressed communities, such as
Transit Oriented Development
Funds, Strategic Growth
Council grants, HCD's
Housing-Related Parks
Program, Safe Routes to
School, and Brownfield
funding.

Ensuring funding is
available for
marginalized and
distressed community
High Research, identify, and
apply for funds available
through the CDBG and
HOME Programs, Mobile
home Park Rehabilitation
and Resident Ownership
Program (MPRROP),
United States Department of
Agriculture (USDA), Capand-Trade Program, and
other funding sources that
support affordable housing
development and

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 89 preservation, infrastructure
investment, energy
efficiency, homeownership,
code enforcement,
farmworker housing, etc.

Program 1.8 First-Time
Homebuyer Program
Program 1.9 Section 8
Rental Assistance
Program 1.17 Energy
Conservation
Provide guidance for site
selection of affordable housing
developments.

Housing Element
identifies adequate sites
to accommodate the
City’s share of the
Regional Housing Needs
Allocation of 277 units
High Program 1.4 Adequate Sites:

Adequate sites are those with
sufficient development and
density standards, water and
sewer services, and adequate
infrastructure.

Develop a program to educate
and encourage landlords to
accept Housing Choice
Vouchers.

Lack of readily available
information regarding fair
housing resources and
assistance to persons in
filing a complaint
Lack of education of
public and housing
providers regarding rights
and responsibilities under
the AFH and FEHA
High Program 1.16 Promote Equal
Housing Opportunities
Develop and implement a
proactive code enforcement
program that holds property
owners accountable and
proactively plans for resident
relocation when necessary.

Code enforcement High Program 1.1 Code
Enforcement
Program 1.2 Housing
Rehabilitation Program,
Prioritize basic infrastructure
improvements like water,
sewer, and streetlights.

Ensuring availability of
basic infrastructure to
proposed development of
lower-income households
High Program 1.4 Adequate Sites

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 90 Disproportionate Housing
Needs, including Overpayment
and Substandard Housing
Ongoing need for
affordable housing
Need for assistance with
monthly housing costs
Lack of local information
regarding available
housing rehabilitation,
emergency repair, and
weatherization programs
Need for targeted
housing revitalization
strategies
Medium Program 1.9 Section 8 Rental
Assistance
Program 1.13 Emergency
Shelters and
Transitional/Supportive
Housing
Program 1.14 Farmworker
and Employee Housing

1.11 Special Needs Housing
for Seniors and Persons with
Disabilities
Use design tools to seamlessly
integrate affordable housing
development into larger mixedincome developments.

Limitations in zoning
code and density
classifications ·
Approval process
Medium Program 1.10 Affordable
Housing Assistance
Displacement Risk Land use and zoning laws
Displacement of residents
due to economic
pressures
Medium Program 1.3 Preservation of
At-Risk Affordable Housing
and Mobile Home Parks

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 91 .

ATTACHMENT: City of Avenal Questionnaire to City Staff.

Responses from staff provided local insight into existing conditions, trends, and potential development in the City.

Segregation and Integration
Race
• Any areas or neighborhoods considered to be concentrated minority communities?? o None. All areas of the city are considered concentrated minority communities. • Are any areas known to have particularly low concentrations of minority residents? o No, the city’s demographic is made up primarily of minority residents with no low concentrations in any specific areas.
• Are there any known historic factors that have led to these p atterns? Are there current factors that reinforce these patterns? Are there any factors that are changing these patterns over time? o Potentially the history of oil discovery and its subsequent collapse that led to a steady decline of bot the economy and population until an influx of agricultural workers repopulated the city and surrounding area in the 1960s.

Disability
• Any areas or neighborhoods with concentrations of persons with disabilities? o No known concentrations of persons with disabilities. • Any concentrations of group homes or residential care facilities? o No know RCF or Group Homes in the City
• Have there been any permits issued for construction of ramp or other accessibility modifications to homes in the area?
o None known
• Have any requests for reasonable accommodation been made during the last planning period? o No
• Any locational differences in terms of disabilities? Recent accessibility improvements? Areas in need of improvements?
o No.

Familial Status
• Any areas or neighborhoods with concentrations of families? Non-families or smaller homes? o No, families are throughout the city
• Any child care facilities? Any locational differences? o There are two child care facilities on the eastern and southern boundary of the city: Maria Resendez Family Child Care and KCAO Oasis Opportunity
Income
• Any areas of the community that are considered to be lower-income, high-poverty areas? o The entire city is considered lower-income.
• Any areas of the community that are considered to be higher-income areas? o No.
• Are there any known areas where a lot of HCV/Section 8 renters live?

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 92 o The eastern and southern boundary of town: El Palmar, Heartstone Village • Any housing assisted by public financing in the city? If so, any areas of the city with a concentration of housing assisted by public financing?
o None known
Disparities in Access to Opportunity Education
• Discuss local schools and geographic availability
o Reef-Sunset School District:
 Reef-sunset Middle School
 Sunrise High School
 Avenal High School
 Tamarack Elementary School
 Avenal Elementary School
o Other:
 Reef-Sunset Secondary School
 Avenal Adult School
o Schools are located generally on the north side of HWY 269 with the exception of Tamarack Elementary
• Discuss local school performance compared to the region o Per US NEWS: In Reef-Sunset Unified School District, 19% of elementary students tested at or above the proficient level for reading, and 11% tested at or above that level for math.

Also, 24% of middle school students tested at or above the proficient level for reading, and 15% tested at or above that level for math. And 44% of high school students tested at or above the proficient level for reading, and 8% tested at or above that level for math. o Per CAASPP: 18.7% met or exceeded standard for ELA; 9.07% met or exceeded standard for math
• Discuss local performance and any differences in access to education opportunities from neighborhood to neighborhood
o None; there are no differences to access to education opportunities; small city and small school district. School performance likely due to other factors other than access to school • Discuss any upper education opportunities, including vocational opportunities o West hills college – Avenal Campus (Community College) o Avenal Adult School
o Avenal High School Career Center
• Discuss any trends and past and current local efforts to improve access to education opportunities o Adult School has classes & Wonderful prepares high School student for college. • Do community members have the opportunity to select the schools that their students attend, or are schools assigned by geography? Are there private or charter options in the community? If families have the ability to select schools, are there higher-demand schools in the community? o Limited options for schools; there is one middle school and two each of elementary and high schools – these are geographically based. No known charters or private schools in city limits.
• Are there any known factors that influence the current rates of high school graduation or college attendance?

APPENDIX D2: CITY OF AVENAL FAIR HOUSING ANALYSIS
KINGS COUNTY MULTI-JURISDICTION HOUSING ELEMENT | April 2026 | 93 o No known; potentially the performance metrics for absenteeism, suspension, English learner progress, math, and language arts. Despite this, Sunset-Reef has a high graduation rate.
• Are there any organizations that provide services like tutoring that could help to improve educational outcomes? Any differences between neighborhoods in terms of access? o None known
• Any new subdivisions? New master planned areas? Differences in schools? o No
Economic
• What are the major employers in the area, or major industries? Where are they located? o Are there major industries that are not nearby that many residents work in?  Avenal State Prison (within city limits)
 Wonderful Pistachio (30+ mins away in Lost Hills, CA)  Sunset-Reef School District (within city limits)
o How has this changed recently? Are there new areas of the county that have developed commercial or industrial uses? Or are there areas that were previously job centers that are no longer in as high of use?
 The City’s rich oil history and subsequent collapse of the oil industry led to a mass exodus.
• Is high-speed internet readily available in the area? Do any areas have known challenges with cell signal access?
o The signal is really bad and all the town has issues with internet access and it slow. • Are there any known economic development programs or initiatives planned or in place that might influence the jobs landscape in the next ten years?
o No.

Transportation
• Discuss countywide transportation system, including different modes o KART – Kings Area Regional Transit runs one line on a fixed route with stops ultimately in Hanford and Lemoore.
• Discuss local access to the countywide transportation system, such as routes and locations o All fixed route stops are north of hwy 269; but operates in a ‘loop path along hwy 269 and San Joaquin Street
• Discuss any local efforts to assist access to different transportation modes, including public transit, walking and biking.
o Limited dedicated walking and bike paths
• How do residents without access to a car travel to work or to access resources like medical care? Is this different depending on the industry that residents work in? o They ask one another for rides to get to work for a fee. The Avenal State Prison uses vans to come to work and make it more feasible.
• Any engineering reports or assessments of capital improvements? Any differences between neighborhoods?
o no assessments, no maintenance districts
• What are the physical conditions of local roads like? Are there street lights, traffic lights, or bike infrastructure in any parts of the community?