Huntington Park City Council
October 17, 2023

Environmental Impact Analysis
Land Use and Planning
Draft Environmental Assessment 4.10-3
 Professional Commercial: The Professional Commercial land use designation permits business and professional offices and services, legal services, and related uses in or near the Central Business District and served by public transportation, where their locations are conveniently accessible. Typical uses include attorney’s offices, banks, beauty shops, medical offices, and travel agencies, among others. Institutional uses are also conditionally permitted in areas designated for Professional Commercial. The maximum permitted FAR is 1:1.  Mixed Use Overlay: The Mixed-Use land use designation allows residential development to occur in an area designated for another land use. The area along Sante Fe Avenue between Randolph Street and Florence Avenue will allow Medium Density Residential Development in additional to the land uses provided for under the current General Commercial Land Use designation, and property to the south of Clarendon Avenue will be limited to either commercial uses or vertically oriented mixed-use development (i.e. commercial/residential with only nonresidential uses on the ground level). Property located north of Clarendon Avenue will allow commercial uses, mixed uses, or solely residential use. Residential densities will be allowed to a maximum of 17.4 dwelling units per acre. The maximum permitted FAR is 1:1.  Single Room Occupancy (“SRO”) Overlay: The SRO Overlay designation allows mixed use development of commercial uses together with single room occupancy hotels. The overlay area is located on the east side of Santa Fe Avenue north of Randolph Street. The density is permitted up to 400 units per acre in addition to the uses provided for under the current General Commercial Land Use designation at a maximum FAR of 1:1.

OTHER
 Light Industry: The Light Industry land use designation permitted uses include light manufacturing, processing, warehousing, distribution, wholesaling, and related developments.

Some of the allowable uses in this designation are cloth manufacturing, electric appliance assembly, and trade schools. The maximum permitted FAR is 1:1.  Industrial Manufacturing: The Industrial Manufacturing land use designation permitted uses include manufacturing, processing, warehousing, distribution, wholesaling, and related developments of a more intense nature than those uses permitted in the Light Industry category. For example, brick manufacturing, lumber yards, and tool and die shops are permitted in this designation. The maximum permitted FAR is 0.5:1.  Parks and Recreation: The Parks and Recreation land use designation includes all the public parks in Huntington Park, including their structures and facilities.  Schools: The School land use designation includes all the public schools in Huntington Park, including their playground area.
 Public Facilities: The Public Facilities land use designation includes all federal, state, and local government properties– such as post offices, the Civic Center, and fire stations. Public Facilities also include hospitals and the Los Angeles Department of Water and Power utility easement that traverses the City near California Avenue and Muni Park. This category permits other land uses (such as nurseries) which are compatible with adjacent uses, and which provide an economic return on the land.
 Rail Transportation Corridor: The Rail Transportation Corridor land use designation includes three rail corridors that traverse Huntington Park:

Southern Pacific Railroad on Alameda Street
Southern Pacific Railroad on Randolph Street
City of Huntington Park
Housing Element and General Plan Update

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Union Pacific Railroad on Salt Lake Avenue
 Parking Overlay: A Parking Overlay designation can exist in addition to the underlying land use designation. This overlay identifies areas where private owners or the City are encouraged to acquire property for parking facilities in order to alleviate parking shortages, for example, on portions of Gage and Florence avenues.

4.10.2 Regulatory Setting
a. State Regulations
California Housing Element Law
California Housing Element law (Government Code Sections 65580 to 65589.8) includes provisions related to the requirements for housing elements of local government General Plans. Among these requirements are an assessment of housing needs and an inventory of resources and constraints relevant to meeting these needs. Additionally, to assure that counties and cities recognize their responsibilities in contributing to the attainment of the State housing goals, this section of the Government Code calls for local jurisdictions to plan for, and facilitate the construction of, their fair share of the region’s projected housing needs, known as the Regional Housing Needs Allocation (RHNA). The City of Huntington Park’s most recent 2008-2014 Housing Element was adopted in February 2009.

Local Agency Formation Commissions
The Cortese-Knox-Hertzberg Local Government Reorganization Act (Cortese-Knox-Hertzberg Act) of 2000 (Government Code Section 56000 et seq.) establishes the process through which local agency boundaries are established and revised. Each county must have a Local Agency Formation Commission (LAFCO), which is the agency that has the responsibility to create orderly local government boundaries, with the goal of encouraging "planned, well-ordered, efficient urban development patterns," the preservation of open-space lands, and the discouragement of urban sprawl. While LAFCOs have no land use power, their actions determine which local government will be responsible for planning new areas. LAFCOs address a wide range of boundary actions, including the creation and modifications of spheres of influence for cities and special districts, annexations, reorganizations, incorporations, and the detachment of areas from special districts. A city’s or special district’s sphere of influence is an indication of an agency’s future growth boundaries.

Planning and Zoning Law
State law requires each city and county in California to adopt a general plan for the physical development of the land within its planning area (Government Code Sections 65300-65404). The general plan must contain land use, housing, circulation, open space, conservation, noise, and safety elements, as well as any other elements that the city or county may wish to adopt. The circulation element of a local general plan must be correlated with the land use element.

Zoning authority originates from city and county police power and from the State’s Planning and Zoning Law, which sets minimum requirements for local zoning ordinances. The city or county zoning code is the set of detailed requirements that implement the general plan policies at the level of the individual parcel. The zoning code presents standards for different uses and identifies which uses are allowed in the various zoning districts of the jurisdiction. Since 1971, State law has required the city or county zoning code to be consistent with the jurisdiction’s general plan.

Environmental Impact Analysis
Land Use and Planning
Draft Environmental Assessment 4.10-5
Sustainable Communities and Climate Protection Act (SB 375) The Sustainable Communities and Climate Protection Act (SB 375) supports the State's climate goals by helping reduce greenhouse gas emissions through coordinated transportation, housing, and land use planning. Under the Act, the California Air Resources Board (CARB) set targets for 2020 and 2035 for each of the 18 metropolitan planning organization regions in 2010 and updated them in 2018. Each of the regions must prepare a SCS, as an integral part of its regional transportation plan, which contains land use, housing, and transportation strategies that, if implemented, would allow the region to meet CARB’s targets. The Act establishes some incentives to encourage implementation of the development patterns and strategies included in an SCS. Developers can get relief from certain environmental review requirements under the CEQA if their new residential and mixed-use projects are consistent with a region’s SCS that meets the targets (see Public Resources Code Sections 21155, 21155.1, 21155.2, 21159.28).
b. Regional Regulations
Southern California Association of Governments (SCAG)
SCAG is responsible for regional planning in the southern California area. SCAG provides a framework to coordinate local and regional decisions regarding future growth and development and prepares future growth forecasts for the region. As the designated MPO for the area, SCAG is mandated by the Federal government to research and develop plans for transportation, growth management, hazardous waste management, and air quality based on the regional growth projections. As SCAG is the largest MPO in the United States, it has subregional councils of government to provide for the subregions’ land use and transportation planning at a more local level. The sub-regional council for Huntington Park is the Gateway Cities Council of Governments (GCCOG).

South Coast Air Quality Management Plan
SCAQMD is responsible for the production of a regional AQMP and has prepared multiple AQMPs to accomplish the goal of an annual five-percent reduction in air pollutant emissions. The most recent AQMP was published and adopted in 2017 (AQMD 2016). The AQMD is currently in the process of developing the next AQMP.
c. Local Regulations
City of Huntington Park General Plan
Huntington Park’s General Plan was adopted in February 1991 and consists of the Land Use, Housing, Circulation, Open Space and Conservation, Safety, Noise, Public Facilities, and Urban Design Elements. All elements bear equal weight, and no element has legal precedence over another. California Government Code Section 65583(c) requires the Housing Element to maintain internal consistency with other General Plan Elements. The following land use and planning goals, policies, and actions are applicable to the proposed project as part of the Land Use, Open Space and Conservation, Noise, and Urban Design Elements (Huntington Park 1991):

LAND USE ELEMENT
The Land Use Element describes existing land use patterns and provides the physical framework for land use and development in the City. The Land Use Element also contains policies to improve the City of Huntington Park
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City’s visual quality and livability, including its compatibility between neighborhoods, mixed-use areas, commercial areas, and industrial areas. It describes the economic context and sets out goals and policies to stimulate development, maintain fiscal health, and support other efforts to enhance the City’s economy (Huntington Park 1991).

OPEN SPACE AND CONSERVATION ELEMENT
The Open Space and Conservation Element describes existing air quality, groundwater, energy conservation, open space, parks, and recreation patterns in the City. The Open Space and Conservation Element also contains policies to reduce air pollution through land use, transportation, and energy use planning. It identifies the goals, policies, and specific measures for managing the community’s natural resources, open space, and recreational areas (Huntington Park 1991).

URBAN DESIGN ELEMENT
The Urban Design Element further builds on the Land Use Element, focusing on the on the quality and character of public areas and private development in the city. The Urban Design Element describes the goals, policies, and design concepts regarding the preservation and improvement of the quality and character of the City (Huntington Park 1991).

City of Huntington Park Municipal Code (HPMC)
The HPMC establishes regulations that implement the City’s General Plan. Title 8, Building Regulations, of the HPMC describes the City’s building codes and other related regulations. Title 9, Zoning, describes the City’s zoning regulations and districts including special purpose zones, overlay zones, and the DTSP. Title 10, Subdivisions, focuses on planning and building codes for subdivisions.

Downtown Huntington Park Specific Plan
DTSP was adopted in August 2008 by the City of Huntington Park. The DTSP is intended to create a unique and identifiable downtown area for the City that is economically vibrant and pedestrian oriented. The Specific Plan extends from Randolph Street to the north, Seville Avenue and Zoe Avenue to the east, Florence Avenue to the south, and Rugby Avenue to the west. The DTSP is divided into four districts: District A– Gateway, District B– Festival, District C– Neighborhood, and District D– Zoe. The Specific Plan sets a vision for the 85-acre area to become a cleaner, more beautiful, mixed-use, pedestrian oriented neighborhood.

4.10.3 Impact Analysis
a. Methodology and Significance Thresholds
The analysis in this section focuses on environmental impacts from the project’s zoning ordinance amendments on the Draft Housing Opportunity Sites, as well as consistency with any applicable land use plans, policies, or regulations. The following thresholds of significance are based on Appendix G of the CEQA Guidelines. For purposes of this EA, implementation of the proposed project may have a significant adverse impact if it would do any of the following:

Physically divide an established community
Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect Environmental Impact Analysis
Land Use and Planning
Draft Environmental Assessment 4.10-7
The consistency analysis describes existing regional and local plans and policies and is intended to fulfill the requirements of CEQA Guidelines Section 15125(d). The emphasis of the analysis is on the project’s inconsistency and potential conflicts between the proposed project and existing applicable land use plans adopted for the purpose of avoiding or mitigating an environmental effect, and whether any inconsistencies are significant environmental effects. The proposed project is considered consistent with the provisions of the identified regional and local plans if it meets the general intent of the applicable plans and does not conflict with directly applicable policies. A given project need not be in perfect conformity with each and every policy nor does state law require precise conformity of a proposed project with every policy or land use designation. Courts have also acknowledged that general and specific plans attempt to balance a range of competing interests, and that it is nearly, if not absolutely, impossible for a project to be in perfect conformity with each and every policy set forth in the applicable plan. Additionally, in reaching such consistency conclusions, the City may also consider the consequences of denial of a project, which can also result in other policy inconsistencies. For example, Government Code Section 65589.5 explains that the potential consequences of limiting the approval of housing are reduced mobility, urban sprawl, excessive commuting, and air quality deterioration.

For an impact to be considered significant, an inconsistency would also have to result in a significant adverse change in the environment not already addressed in the other resource chapters of this EA.

The analysis below provides a discussion of the most relevant policies from the various planning documents. However, the City’s consistency conclusions are based upon the planning documents as a whole.

Threshold 1: Would the project physically divide an established community? Impact LU-1 IMPLEMENTATION OF THE PROPOSED PROJECT WOULD NOT PHYSICALLY DIVIDE AN ESTABLISHED COMMUNITY. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Development facilitated by the proposed project would not result in the construction of barriers, such as new roads or other linear development or infrastructure, that would divide the existing communities surrounding the sites. Short-term construction impacts would be mostly contained within the housing inventory sites themselves; however, off-site improvements for utilities may be required for some of the sites for water and wastewater (refer to Section 4.15, Utilities and Service Systems).

No new transportation infrastructure would be required (refer to Section 4.14, Transportation, and Section 4.15, Utilities and Service Systems). Therefore, existing roadways would not be blocked, and construction would not limit access to a community or restrict movement within a community.

Development facilitated by the proposed project would not divide a community; rather it would promote the development of existing vacant, underdeveloped or underutilized properties, thereby locating people closer to existing employment, goods and services within an established community.

Therefore, impacts related to dividing an established community would be less than significant.

Mitigation Measure
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

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Housing Element and General Plan Update

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Threshold 2: Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Impact LU-2 THE PROPOSED PROJECT WOULD UPDATE THE LAND USE ELEMENT, HOUSING ELEMENT, AND SAFETY ELEMENT TO BRING THE CITY’S GENERAL PLAN INTO CONFORMANCE WITH STATE REQUIREMENTS AND FACILITATE DEVELOPMENT ALIGNED WITH THE VISION OF THE GENERAL PLAN. THESE UPDATES WOULD NOT

CONFLICT WITH ANY LAND USE PLAN, POLICY, OR REGULATION ADOPTED FOR THE PURPOSE OF AVOIDING OR MITIGATING AN ENVIRONMENTAL EFFECT. THERE WOULD BE NO IMPACT.

As set forth by State law, the General Plan serves as the primary planning document for the City and all subordinate documents and plans are required to be consistent with the General Plan. The proposed project would amend the Huntington Park General Plan and associated changes with the Housing Element, Land Use Element, and Safety Element as described in Section 2, Project Description, to remove constraints to housing development and facilitate the sufficient development of housing at densities appropriate for respective income levels consistent with the RHNA. The building types supported by the amendments to the allowable densities, FAR, and building heights would support the type of residential and mixed-use infill development envisioned in the General Plan.

The proposed project would facilitate development that would exceed the buildout projections described in the General Plan, as discussed in Section 4.12, Population and Housing. However, the proposed project would comply with pertinent State housing law and the City’s 6th cycle RHNA allocation and has been prepared specifically to be consistent with applicable requirements of housing law. Thus, despite accommodating growth beyond that anticipated in the General Plan, housing growth under the proposed project would not be substantial or unplanned. The proposed project would update the General Plan to reflect new housing requirements; therefore, the planned growth under the proposed project would not conflict with the adopted General Plan.

Development standards associated with the proposed project would be required to be consistent with the other portions of the General Plan, including policies and programs adopted to address environmental impacts. All development in the City would be reviewed for consistency with the City’s development standards set forth in HPMC as part of the design review process. The proposed project would not remove or modify any policies or measures from the General Plan that are intended for environmental protection and would not conflict with any General Plan policies or measures that are intended for environmental protection.

Therefore, the proposed project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, and potential impacts would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Environmental Impact Analysis
Land Use and Planning
Draft Environmental Assessment 4.10-9

4.10.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). The geographic scope for cumulative land use and planning impacts includes the geographic area of the City of Huntington Park. Development that is considered part of the cumulative analysis includes buildout of the City’s General Plan.

Cumulative development in accordance with the City’s General Plan would incrementally modify land use patterns and the general setting of the City. Planned cumulative development would incrementally increase overall development intensity throughout the City. However, land use and policy consistency impacts associated with buildout of the City’s General Plan would be addressed on a case-by-case basis to determine consistency with applicable plans and policies. Since the planned projects would be required to be consistent with the General Plan, they would implement the City’s vision for Huntington Park. In addition, these projects would generally reduce motor vehicle trips, trip lengths, and associated environmental impacts by being constructed near transit, jobs, services, and open spaces. Because the project’s impacts related to land use compatibility and consistency with local plans and goals would be less than significant, the project’s contribution to cumulative land use impacts would be less than significant.

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Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-1

4.11 Noise
This section evaluates noise and groundborne vibration impacts resulting from the construction and operation of new housing development accommodated by the proposed project. Topics addressed consist of short-term construction and long-term operational noise and vibration, including the exposure of noise-sensitive receivers to substantial or incompatible noise levels. Noise modeling results and the vibration calculations associated with the analysis herein are included in Appendix G to this EA.

4.11.1 Environmental Setting
a. Fundamentals of Noise
Sound is a vibratory disturbance created by a moving or vibrating source, which is capable of being detected by the hearing organs (e.g., the human ear). Noise is defined as sound that is loud, unpleasant, unexpected, or undesired and may therefore be classified as a more specific group of sounds. The effects of noise on people can include general annoyance, interference with speech communication, sleep disturbance, and, in the extreme, hearing impairment (California Department of Transportation [Caltrans] 2013).

Noise levels are commonly measured in decibels (dB) using the A-weighted sound pressure level (dBA). The A-weighting scale is an adjustment to the actual sound pressure levels so that they are consistent with the human hearing response, which is most sensitive to frequencies around 4,000 Hertz (Hz) and less sensitive to frequencies around and below 100 Hz (Kinsler, et. al. 1999).

Decibels are measured on a logarithmic scale that quantifies sound intensity in a manner similar to the Richter scale used to measure earthquake magnitudes. A doubling of the energy of a noise source, such as a doubling of traffic volume, would increase the noise level by 3 dB; similarly, dividing the energy in half would result in a decrease of 3 dB (Crocker 2007). Common outdoor and indoor noise sources and their typical corresponding A-weighted noise levels are shown in Figure 4.11-1.

Human perception of noise has no simple correlation with sound energy. The perception of sound is not linear in terms of dBA or in terms of sound energy. Two sources do not “sound twice as loud” as one source. It is widely accepted that the average healthy ear can barely perceive an increase (or decrease) of up to 3 dBA in noise levels (i.e., twice [or half] the sound energy); that a change of 5 dBA is readily perceptible; and that an increase (or decrease) of 10 dBA sounds twice (or half) as loud (Crocker 2007).

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Figure 4.11-1 Examples of Typical Noise Levels
Source: Caltrans 2013
Noise Level
(dBA)
Common Indoor
Noise Levels
Common Outdoor
Noise Levels
Rock band
Inside subway train
Food blender at 3 ft.

Garbage disposal at 3 ft.

Shouting at 3 ft.

Vacuum cleaner at 10 ft.

Normal speech at 3 ft.

Large business office
Dishwasher next room
Small theater, conference
room (background)
Library
Bedroom at night
Concert hall (background)
Broadcast and
recording studio
Threshold of hearing
Jet flyover at 1,000 ft.

Gas lawnmower at 3 ft.

Diesel truck at 50 ft.

Noisy urban daytime
Gas lawnmower at 100 ft.

Commercial area
Heavy traffic 300 ft.

Quiet urban daytime
Quiet urban nighttime
Quiet suburban nighttime
Quiet rural nighttime
110
100
90 80
70 60
50 40
30 20
10 0
Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-3
Sound changes in both level and frequency spectrum as it travels from the source to the receiver.

The most obvious change is the decrease in sound level as the distance from the source increases.

The manner by which noise declines with distance depends on factors such as the type of sources (e.g., point or line), the path the sound will travel, site conditions, and obstructions. Noise levels from a point source (e.g., construction, industrial machinery, ventilation units) typically attenuate, or drop off, at a rate of 6 dBA per doubling of distance. Noise from a line source (e.g., roadway, pipeline, railroad) typically attenuates at about 3 dBA per doubling of distance (Caltrans 2013). The propagation of noise is also affected by the intervening ground, known as ground absorption. A hard site, such as a parking lot or smooth body of water, receives no additional ground attenuation and the changes in noise levels with distance (drop-off rate) result simply from the geometric spreading of the source. An additional ground attenuation value of 1.5 dBA per doubling of distance applies to a soft site (e.g., soft dirt, grass, or scattered bushes and trees) (Caltrans 2013).

Noise levels may also be reduced by intervening structures. The amount of attenuation provided by this “shielding” depends on the size of the object and the frequencies of the noise levels. Natural terrain features, such as hills and dense woods, and man-made features, such as buildings and walls, can alter noise levels. Generally, any large structure blocking the line of sight will provide at least a 5 dBA reduction in source noise levels at the receiver (Federal Highway Administration [FHWA] 2011).

Structures can substantially reduce occupants’ exposure to noise as well. The FHWA’s guidelines indicate that modern building construction generally provides an exterior-to-interior noise level reduction of 20 to 35 dBA with closed windows.

Descriptors
The impact of noise is not a function of loudness alone. The time of day when noise occurs, its frequency, and the duration of the noise are also important. In addition, most noise that lasts for more than a few seconds is variable in its intensity. Consequently, a variety of noise descriptors have been developed.

One of the most frequently used noise metrics that considers both duration and intensity is the equivalent noise level (Leq). The Leq is defined as the single steady A-weighted level that is equivalent to the same amount of energy as that contained in the actual fluctuating levels over a period of time. Typically, Leq is equivalent to a one-hour period, even when measured for shorter durations as the noise level of a 10- to 30-minute period would be the same as the hour if the noise source is relatively steady. Lmax is the highest Root Mean Squared (RMS) sound pressure level within the sampling period, and Lmin is the lowest RMS sound pressure level within the measuring period (Crocker 2007). Normal conversational levels at three feet are in the 60- to 65-dBA Leq range and ambient noise levels greater than 65 dBA Leq can interrupt conversations (Federal Transit Administration [FTA] 2018).

Noise that occurs at night tends to be more disturbing than that which occurs during the day.

Community noise is usually measured using Day-Night Average Level (Ldn or DNL), which is a 24-hour average noise level with a +10 dBA penalty for noise occurring during nighttime (10:00 p.m. to 7:00 a.m.) hours, or Community Noise Equivalent Level (CNEL), which is the 24-hour average noise level with a +5 dBA penalty for noise occurring from 7:00 p.m. to 10:00 p.m. and a +10 dBA penalty for noise occurring from 10:00 p.m. to 7:00 a.m. (Caltrans 2013). Noise levels described by DNL and CNEL usually differ by about 0.5 dBA. Quiet suburban areas typically have a CNEL in the range of 40 to 50 dBA, while areas near arterial streets are typically in the 50 to 70+ CNEL range.

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Propagation
Sound from a small, localized source (approximating a “point” source) radiates uniformly outward as it travels away from the source in a spherical pattern, known as geometric spreading. The sound level decreases or drops off at a rate of approximately 6 dBA for each doubling of distance.

Traffic noise is not a single, stationary point source of sound. Rather, the movement of vehicles makes the source of the sound appear to emanate from a line (line source) rather than a point. The drop-off rate for a line source is approximately 3 dBA for each doubling of distance. b. Overview of Groundborne Vibration
Groundborne vibration of concern in environmental analysis consists of the oscillatory waves that move from a source through the ground to adjacent structures. The number of cycles per second of oscillation makes up the vibration frequency, described in terms of Hertz. The frequency of a vibrating object describes how rapidly it oscillates. The normal frequency range of most groundborne vibration that can be felt by the human body is from a low of less than 1 Hertz up to a high of about 200 Hertz (Crocker 2007). Typically, groundborne vibration generated by human activities attenuates rapidly with distance from the source of the vibration.

While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration in buildings, such as from nearby construction activities, may cause windows, items on shelves, and pictures on walls to rattle. Vibration of building components can also take the form of an audible low-frequency rumbling noise, referred to as groundborne noise. Groundborne noise is usually only a problem when the originating vibration spectrum is dominated by frequencies in the upper end of the range (60 to 200 Hertz), or when foundations or utilities, such as sewer and water pipes, physically connect the structure and the vibration source (FTA 2018).

Vibration energy spreads out as it travels through the ground, causing the vibration level to diminish with distance away from the source. High-frequency vibrations diminish much more rapidly than low frequencies, so low frequencies tend to dominate the spectrum at large distances from the source. Discontinuities in the soil strata can also cause diffractions or channeling effects that affect the propagation of vibration over long distances (Caltrans 2020). When a building is impacted by vibration, a ground-to-foundation coupling loss will usually reduce the overall vibration level.

However, under rare circumstances, the ground-to-foundation coupling may amplify the vibration level due to structural resonances of the floors and walls.

Vibration amplitudes are usually expressed in peak particle velocity (PPV). The PPV is normally described in inches per second (in/sec). PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in monitoring of blasting vibration and other construction activity because it is related to the stresses that are experienced by buildings (Caltrans 2020). Table 4.11-1 summarizes the vibration damage criteria recommended by the FTA for evaluating the potential for architectural damage to buildings.

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Noise
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Table 4.11-1 Criteria for Vibration Damage Potential
Building Category PPV (in/sec)
I. Reinforced concrete, steel, or timber (no plaster) 0.5 II. Engineered concrete and masonry (no plaster) 0.3
III. Nonengineered timber and masonry buildings 0.2
IV. Buildings extremely susceptible to vibration damage 0.12 in/sec = inches per second; PPV = peak particle velocity Source: FTA 2018
c. Sensitive Receivers
Noise exposure goals for various types of land uses reflect the varying noise sensitivities associated with those uses. According to the Huntington Park 1991 General Plan Noise Element, residential areas, hospitals, convalescent homes, churches, libraries, schools, and childcare facilities are considered noise-sensitive uses (City of Huntington Park 1991).

Vibration-sensitive receivers, which are similar to noise-sensitive receivers, include residences and institutional uses, such as hospitals, schools, and churches. However, vibration-sensitive receivers also include buildings where vibrations may interfere with vibration-sensitive equipment (e.g., recording studies or medical facilities with sensitive equipment). Other uses that may have particular sensitivity to groundborne vibration include historic sites and structures.

Residential uses comprise most of the sensitive receivers in the City. Other sensitive receivers consist of recreational uses (e.g., parks) and institutional (e.g., schools, hospitals) uses. Also, refer to Chapter 4.4, Cultural and Tribal Cultural Resources, for a discussion of historic properties in the City, which may be particularly sensitive to increases in groundborne vibration levels. d. Existing Conditions
Noise Sources
Huntington Park is affected by a variety of noise sources, including mobile and stationary sources.

The most prevalent noise source in the City is traffic on the major arterial routes and trains utilizing Alameda Corridor. Roadways with the highest traffic volumes and speeds produce the highest noise levels. The roadways in Huntington Park with the highest traffic volumes and, thus, the highest noise levels are East Florence Avenue, Walnut Street, East Slauson Avenue, and South Alameda Street.

Table 4.11-2 provides existing roadway vehicle noise levels along roadways in the plan area. Noise from trains using the Atchison, Topeka and Santa Fe (AT&SF), Union Pacific (UPRR) and Southern Pacific (SPRR) rail lines are a secondary source of mobile noise. The UPRR line along the western section of the City affects residential uses at the western end of the City. Residential areas generate noise from resident gatherings and activities, vehicles, and operating household equipment. Schools in the City also create noise from buses, students, school activities, maintenance, and outdoor games.

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Table 4.11-2 Existing Roadway Vehicle Noise Along Roadway Segments Roadway Segment Existing ADT
Existing Traffic Noise
Level at 50 feet
(dBA CNEL)
S. Alameda Street - E. Slauson Avenue to E. Gage Avenue 49,336 75.1 S. Alameda Street - E. Gage Avenue to E. Florence Avenue 43,381 74.8 S. Santa Fe Avenue - Fruitland Avenue to E. Slauson Avenue 28,998 73.8 Santa Fe Avenue - E. Slauson Avenue to Randolph Street 36,425 74.0 Santa Fe Avenue - Randolph Street to E. Gage Avenue 25,723 73.0 Santa Fe Avenue - E. Gage Avenue to Walnut Street 34,656 73.7 Pacific Boulevard - Fruitland Avenue to E. Slauson Avenue 28,173 70.4 Pacific Boulevard - E. Slauson Avenue to Randolph Street 22,262 68.4 Pacific Boulevard - Randolph Street to E. Gage Avenue 15,130 66.0 Pacific Boulevard - E. Gage Avenue to E. Florence Avenue 18,163 66.7 S. Soto Street - Fruitland Avenue to E. Slauson Avenue 28,937 70.9 Stafford Avenue - E. Slauson Avenue to Randolph Street 8,268 61.5 Stafford Avenue - E. Gage Avenue to E. Florence Avenue 3,671 58.8 Miles Avenue - E. Slauson Avenue to Randolph Street 22,463 67.5 Miles Avenue - Randolph Street to E. Gage Avenue 23,306 67.4 Miles Avenue - E. Gage Avenue to East Florence Avenue 16,221 66.2 Mountainview Avenue - Walnut Street to Santa Ana Street 18,685 66.9 S. Boyle Avenue - Fruitland Avenue to E. Slauson Avenue 20,113 72.6 S. Boyle Avenue - E. Slauson Avenue to Randolph Street 26,718 73.2 State Street - Randolph Street to E. Gage Avenue 16,566 71.0 State Street - E. Gage Avenue to Walnut Street 17,901 70.7 State Street - Walnut Street to Santa Ana Street 13,996 70.0 Salt Lake Avenue - E. Gage Avenue to E. Florence Avenue 11,050 65.2 California Avenue - E. Florence Avenue to Santa Ana Street 18,623 69.7 S. Maywood Avenue - E. Slauson Avenue to Randolph Street 18,157 68.7 S. Maywood Avenue - Randolph Street to E. Gage Avenue 17,690 67.9 Salt Lake Avenue - E. Florence Avenue to Live Oak Street 19,953 67.4 Gifford Avenue - E. Slauson Avenue to Randolph Street 12,605 67.5 Otis Avenue - Salt Lake Avenue to Santa Ana Street 16,740 65.7 E. Slauson Avenue - Wilmington Avenue to Alameda Street 50,986 76.4 E. Slauson Avenue - Alameda Street to S. Santa Fe Avenue 41,757 75.0 E. Slauson Avenue - S. Santa Fe Avenue to Pacific Boulevard 39,195 74.6 E. Slauson Avenue - Pacific Boulevard to Stafford Avenue 41,800 74.2 E. Slauson Avenue - Stafford Avenue to S. Soto Street 33,985 73.6 E. Slauson Avenue - S. Soto Street to S. Boyle Avenue 39,333 73.9 E. Gage Avenue - Wilmington Avenue to S. Alameda Street 30,134 70.6 E. Gage Avenue - S. Alameda Street to Santa Fe Avenue 20,338 68.6 E. Gage Avenue - Santa Fe Avenue to Pacific Boulevard 23,086 68.6 Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-7
Roadway Segment Existing ADT
Existing Traffic Noise
Level at 50 feet
(dBA CNEL)
E. Gage Avenue - Pacific Boulevard to Stafford Avenue 23,697 68.8 E. Gage Avenue - Stafford Avenue to Miles Avenue 23,727 68.9 E. Gage Avenue - Miles Avenue to State Street 28,371 69.2 E. Gage Avenue - State Street to Salt Lake Avenue 20,030 68.7 E. Gage Avenue - Salt Lake Avenue to California Avenue 16,044 67.3 Randolph Street - Santa Fe Avenue to Pacific Boulevard 6,441 65.9 Randolph Street - Stafford Avenue to Miles Avenue 6,062 63.6 Randolph Street - S. Maywood Avenue to Gifford Avenue 3,175 63.0 Randolph Street - Gifford Avenue to Atlantic Boulevard 6,419 65.9 E. Florence Avenue - Wilmington Avenue to S. Alameda Street 33,621 71.7 E. Florence Avenue - S. Alameda Street to Santa Fe Avenue 46,406 73.0 Walnut Street - Santa Fe Avenue to Pacific Boulevard 44,269 69.5 E. Florence Avenue - Pacific Boulevard to Seville Avenue 37,682 71.9 E. Florence Avenue - Seville Avenue to Stafford Avenue 37,075 72.0 E. Florence Avenue - Stafford Avenue to Miles Avenue 39,708 72.1 Walnut Street - Miles Avenue to Mountain View Avenue 54,240 71.0 Walnut Street - Mountain View Avenue to State Street 41,707 69.6 E. Florence Avenue - State Street to Salt Lake Avenue 49,530 73.3 E. Florence Avenue - Salt Lake Avenue to California Avenue 73,887 75.4 Walnut Street - California Avenue to Bear Avenue 48,107 70.6 Santa Ana Street - Mountain View Avenue to State Street 6,925 62.9 Santa Ana Street - State Street to California Avenue 13,196 65.9 Santa Ana Street - California Avenue to Otis Avenue 7,989 63.8 Santa Ana Street - Otis Avenue to Salt Lake Avenue 14,449 66.6 ADT = average daily traffic.

Source: Data provided by Translutions 2023.

Vibration Sources
Existing sources of operational vibration in the EA Study Area include vehicle traffic on roadways and trains on the rail lines. Caltrans has studied the effects of propagation of vehicle vibration on sensitive land uses and notes that “heavy trucks, and quite frequently buses, generate the highest earthborn vibrations of normal traffic.” Caltrans further notes that the highest traffic-generated vibrations are along freeways and state routes. Their study finds that “vibrations measured on freeway shoulders (five meters from the centerline of the nearest lane) have never exceeded 0.08 in/sec, with the worst combinations of heavy trucks and poor roadway conditions (while such trucks were moving at freeway speeds). This level coincides with the maximum recommended safe level for ruins and ancient monuments (and historic buildings)” (Caltrans 2020). Construction vibration levels have the potential to be significant when equipment such as impact and vibratory pile drivers, rock blasting, and vibratory rollers is used during project construction.

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4.11.2 Regulatory Setting
a. Federal
Department of Housing and Urban Development
The federal Department of Housing and Urban Development (HUD) sets environmental criteria and standards in Title 24 of the Code of Federal Regulations (CFR), Part 51. New construction proposed in areas that exceed 65 dBA Ldn must incorporate noise attenuation features to maintain interior noise levels at 45 dBA Ldn. Development in areas exceeding 65 dBA Ldn requires further attenuation features. In general, the HUD regulations match the California state regulations discussed below.

Federal Transit Administration
The FTA provides reasonable criteria for assessing construction noise impacts based on the potential for adverse community reaction in their Transit and Noise Vibration Impact Assessment Manual (FTA 2018). For residential uses, the daytime noise threshold is 80 dBA Leq for an 8-hour period.

Occupational Health and Safety Administration
The federal government regulates occupational noise exposure common in the workplace through the Occupational Health and Safety Administration (OSHA) under the EPA. Noise limitations would apply to the operation of construction equipment and could also apply to any proposed industrial land uses. Noise exposure of this type is dependent on work conditions and is addressed through a facility’s Health and Safety Plan, as required under OSHA, and is not addressed further in this analysis.
b. State
California General Plan Guidelines
State law requires general plans to include a Noise Element under Government Code Section 65302(f). The California General Plan Guidelines, published by the Governor’s Office of Planning and Research, indicate acceptable, specific land use types in areas with specific noise exposure. The guidelines also offer adjustment factors that may be used to arrive at noise acceptability standards that reflect the noise control goals of the community, the community’s sensitivity to noise, and the community’s assessment of the relative importance of noise pollution. These guidelines are advisory, and local jurisdictions have the authority to set specific noise standards based on local conditions.

California Building Code
California Code of Regulations Title 24, Building Standards Administrative Code, Part 2, Chapter 12, and the California Building Code codify the State noise insulation standards. These noise standards apply to new construction in California to control interior noise levels as they are affected by exterior noise sources and interior noise sources from separate areas. The regulations specify that interior noise levels shall not exceed 45 dB CNEL/Ldn in any habitable room, as well as specifying sound transmission class requirements for walls, floors, and ceilings around sleeping units.

Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-9
California Green Building Code
California Green Building Standards Code 2022 (CALGreen) Section 5.507.4, Acoustical Control, regulates construction of non-residential uses within the 65 dBA CNEL/Ldn contour of an airport, freeway, expressway, railroad, industrial noise source, or other fixed source. According to Section

5.507.4.1.1 “buildings exposed to a noise level of 65 dB Leq(1-hr) during any hour of operation shall employ sound-resistant assemblies as determined by a prescriptive method (CALGreen Section

5.507.4.1) or performance method (CALGreen Section 5.507.4.2).

Projects may demonstrate compliance through the prescriptive method if wall and roof-ceiling assemblies exposed to the noise source meet a composite sound transmission class (STC) rating of at least 50 or a composite outdoor/indoor transmission class (OITC) rating of no less than 40, with exterior windows of a minimum STC of 40 or OITC of 30. Projects may demonstrate compliance through the performance method if wall and roof-ceiling assemblies exposed to the noise source are constructed to provide an interior noise environment that does not exceed 50 dB Leq-1Hr in occupied areas during hours of operations.
c. Regional
Airport Land Use Commission
In Los Angeles County, the Regional Planning Commission has the responsibility for acting as the Airport Land Use Commission (ALUC) and for coordinating the airport planning of public agencies within the county. The ALUC coordinates planning for the areas surrounding public use airports, and the Airport Land Use Plan (ALUP) provides for the orderly expansion of the County's public use airports and the area surrounding them. It is intended to provide for the adoption of land use measures that will minimize the public’s exposure to excessive noise and safety hazards. The City of Huntington Park is not located within the noise impact areas of nearby airports, however, there are several airports in the City’s vicinity, including the Long Beach Airport, the Compton Airport, and the Los Angeles International Airport. The Los Angeles County ALUC is responsible for implementing airport land use plans for these airports that promote compatibility between each airport in the county and the surrounding land uses to ensure that hazardous conditions, including incompatible noise levels, are not created (Los Angeles County 2004). d. Local
City of Huntington Park General Plan Noise Element
The Noise Element describes the existing and future noise conditions and issues in the City. The Noise Element establishes goals, policies, and standards which regulate the noise within Huntington Park (Huntington Park 1991).

The following goals and policies from the 1991 General Plan Noise Element are relevant to the proposed project:

Goal 1.0: Reduce noise impacts from transportation noise sources.

Policy 1.1: Require construction of barriers to shield noise-sensitive uses from excessive noise.

Policy 1.5: Monitor noise from buses and other heavy vehicles in residential areas. If necessary, consider alternate circulation routes for those types of vehicles.

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Policy 1.6: Discourage through-traffic in residential neighborhoods by use of speed bumps and/or one-way streets.

Goal 2.0: Incorporate noise considerations into land use planning decisions.

Policy 2.1: Establish targeted limits of noise for various land uses throughout the community, in accordance with Table 4.11-3.

Policy 2.2: Ensure acceptable noise levels near schools hospitals, convalescent homes, and other noise-sensitive areas, in accordance with Table 4.11-3.

Policy 2.4: Require noise-reduction techniques in site planning, architectural design, and construction where noise reduction is necessary.

Policy 2.5: Discourage and, if necessary, prohibit the location of noise-sensitive land uses in noisy environments.

Goal 3.0: Minimize noise spillover from commercial and industrial uses into nearby residential neighborhood.

Policy 3.1: Enforce the 65 dBA State standard for exterior noise levels for all commercial uses.

Policy 3.2: Require that a minimum of fifteen (15) feet be landscaped as a buffer between a commercial or mixed use structure and an adjoining residential parcel.

Policy 3.3: Require that automobile and truck access to commercial properties located adjacent to residential parcels be located at the maximum practical distance from the residential parcel.

Policy 3.4: Prohibit truck deliveries to commercial and industrial properties abutting residential uses before 7 a.m. and after 9 p.m. unless there is no feasible alternative.

Goal 4.0: Minimize the noise impacts associated with the development of residential units above ground floor commercial uses in mixed use developments.

Policy 4.1: Require that commercial uses developed as part of a mixed us project (with residential uses) not be noise-intensive.

Policy 4.2: Require that mixed us structures be designed to prevent transfer of noise and vibration from the commercial to the residential use.

Policy 4.3: Orient mixed use residential units away from major noise sources.

Policy 4.4: Locate balconies and openable windows of residential units in mixed use projects away from the primary street and other major noise sources.

Table 4.11-3 show standards and criteria that specify acceptable limits of noise for various land uses throughout Huntington Park. These standards and criteria will be incorporated into the land use planning process to reduce future noise and land use incompatibilities.

Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-11
Table 4.11-3 Interior and Exterior Noise Standards
Land Use Category Uses Interior (CNEL) Exterior (CNEL)
Residential Single Family Duplex,
Multi-Family
45 65
Mobile Homes - 65
Commercial
Industrial
Institutional
Hotel, Motel, Transient
Lodging
Commercial Retail, Bank,
Restaurant
Office Building, Research
and Development,
Professional Offices, City
Office Building
Amphitheater, Concert
Hall, Auditorium, Meeting
Hall
Gymnasium
Sports Club
Manufacturing,
Warehousing, Wholesale,
Utilities
Movie Theatres
45 55
50 45
50 55
65 45
-
-
-
-
-
-
-
-
Institutional Hospital; Schools classroom
Church, Library
45 45
65 -
Open Space Parks - 65
Source: City of Huntington Park 1991 General Plan
Goal 5.0: Develop measures to control non-transportation noise impacts.

Policy 5.3: Reduce noise generated by building activities by requiring sound attenuation devices on construction equipment.

Policy 5.4:Establish and maintain coordination among the agencies involved in noise abatement.

City of Huntington Park Municipal Code
The City’s noise standards, found in Title 5, Chapter 11, Article 1 (Noise) and Title 9, Chapter 3, Article 5 (Noise Standards) of the HPMC, sets forth hours of operation for certain activities and standards for determining when noise is deemed to be a disturbance.

According to Section 5-11.01 of the HPMC, any noise created, made, maintained, or produced by, through, or on account of the operation, starting, manipulation, use, movement, working, handling, or maneuvering of any device, appliance, apparatus, equipment, object, or thing, mechanical or otherwise, within the City by any person, and which noise is of sufficient loudness, intensity, or character and/or of such continuance or recurrence as to disturb the peace or quiet of any neighborhood within the City, is hereby declared to be a nuisance affecting the public peace, health, and safety of the City.

Furthermore, according to Section 5-11.03.1 of the HPMC, no person shall use or operate a radio, tape player, tape recorder, record player, television or similar sound device in a vehicle on any City of Huntington Park
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property within the City, such that it annoys, disturbs, injures or endangers the comfort, repose, health, peace or safety of others. In addition, the operation of any radio or similar sound device in such a manner as to be plainly audible at a distance of 25 feet from the vehicle in which the device is located shall be accepted as evidence of a violation of this section. This section does not prohibit or inhibit the operation of emergency vehicles, law enforcement functions or other functions specifically authorized by the City.

Similarly, according to Section 5-11.04 of the HPMC prohibits any person to keep, maintain, allow, or permit to be kept or maintained at or upon any premises in Zone R¬1 or R¬3 of the City, which premises are owned, occupied, and controlled by such person, any workshop or work or repairing or industry which is unsightly or the noise or noxious odors from which disturb the peace and quiet of the owners of adjoining property or which depreciates the value of adjoining and surrounding property.

Finally, Section 9-3.506 of the HPMC states that noise sources associated with construction, repair, remodeling or grading of any real property, provided the activities do not take place between the hours of 7:00 p.m. and 7:00 a.m. on weekdays, including Saturdays, or at any time on Sundays or Federal holidays

4.11.3 Impact Analysis
a. Methodology and Thresholds of Significance
Thresholds
In accordance with Appendix G of the CEQA Guidelines, the Housing Element Update’s noise and vibration impacts would be significant if it would:

Generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies
Generate excessive groundborne vibration or groundborne noise levels For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the project area to excessive noise levels

CONSTRUCTION NOISE THRESHOLDS
Development facilitated by the project could have a significant impact if temporary construction noise during permitted daytime hours exposed noise-sensitive receivers to significantly adverse noise levels, or if construction noise occurred outside the hours detailed in Municipal Code Section 9-1-1-105.10. As the City does not define a quantitative construction noise threshold, for purposes of analyzing impacts from the project, the City has determined that the FTA construction criteria are applicable to the project. The FTA provides reasonable criteria for assessing construction noise impacts based on the potential for adverse community reaction in their Transit and Noise Vibration Impact Assessment Manual (FTA 2018). For residential uses, the daytime noise threshold is 80 dBA Leq(8hr) for an 8-hour period. Construction noise would be significant if it exceeds this threshold.

Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-13

OPERATIONAL NOISE THRESHOLDS
The City does not have quantified limits in the Municipal Code for stationary noise sources such as HVAC and other mechanical equipment. Therefore, operational noise standards based upon U.S.

EPA are provided for this analysis. At residential and other noise-sensitive land uses, a daytime limit of 60 dBA Leq to prevent potential speech interference is used. For nighttime noise at residential properties, an exterior limit of 50 dBA Leq is used. Based upon available sleep criteria data, an interior nighttime level of 35 dBA is considered acceptable (U.S. EPA 1974). Assuming a 15 dBA reduction with windows open, an exterior noise level of 50 dBA Leq would be required to maintain an acceptable interior noise environment of 35 dBA.

For traffic noise increases, the following thresholds of significance are used to assess traffic noise impacts at sensitive receptor locations, which are generally based on those recommended by the Federal Aviation Administration (FAA):
 Greater than 1.5 dBA increase for ambient noise environments of 65 dBA CNEL and higher;  Greater than 3 dBA increase for ambient noise environments of 60 -64 CNEL; and  Greater than 5 dBA increase for ambient noise environments of less than 60 dBA CNEL.

LAND USE COMPATIBILITY THRESHOLDS
Agencies subject to CEQA generally are not required to analyze the impact of existing environmental conditions on a project‘s future users or residents. In California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal. 4th 369, the California Supreme Court explained that an agency is only required to analyze the potential impacts to future residents if the project would exacerbate those existing environmental hazards or conditions, new school projects, and projects affected by airport noise. CEQA analysis is, therefore, generally concerned with a project’s impact on the environment, rather than with the environment’s impact on a project and its users or residents. Implementation of the proposed project could expose future residents to ambient noise levels that exceed the City’s noise and land use compatibility standards for acceptable noise exposure. General Plan Noise Element Policy 2.2 ensures acceptable noise exposure at schools, hospitals, convalescent homes, and other noise-sensitive areas based on the City’s noise and land use compatibility standards.

GROUNDBORNE VIBRATION THRESHOLDS
The City has not adopted quantified limits to assess vibration impacts during construction and operation. Therefore, the Transit Noise and Vibration Impact Assessment Manual (FTA 2018) is used to evaluate potential construction vibration impacts. Construction vibration impacts would be significant if vibration levels exceed the FTA criteria shown in Table 4.11-1. For example, impacts would be significant if vibration levels exceed 0.2 in/sec PPV for residential structures and 0.3 in/sec PPV for commercial structures, which is the limit where minor cosmetic (i.e., non-structural) damage may occur to these buildings. Construction vibration impacts would also be significant if vibration levels exceed 0.12 in/sec PPV for extremely fragile historic buildings, as shown in Table 4.11-1.

AIRPORT NOISE THRESHOLDS
Exposure to airport noise would be significant if new housing development is located within the noise contours of the Long Beach, Compton, or Los Angeles International Airports that exceed the City’s land use compatibility standards shown in Table 4.11-3.

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Methodology
The following describes the methodology, including models, used to evaluate the significance of potential noise and vibration impacts related to the proposed project.

CONSTRUCTION NOISE
Construction equipment can be considered to operate in two modes: stationery and mobile.

Stationary equipment operates in a single location for one or more days at a time, with either fixedpower operation (e.g., pumps, generators, and compressors) or variable-power operation (e.g., pile drivers, rock drills, and pavement breakers). Mobile equipment moves around a construction site with power applied in cyclic fashion, such as bulldozers, graders, and loaders. Each phase of construction has its own noise characteristics due to specific equipment mixes; some will have higher continuous noise levels than others and some may have high-impact intermittent noise levels. Therefore, construction noise levels may fluctuate depending on the type of equipment being used, construction phase, or equipment location. Typically, grading activities generate the highest noise levels because grading involves the largest equipment and covers the greatest area.

Variation in power imposes difficulty in characterizing the noise source level from construction equipment. Power variation is accounted for by describing the noise at a reference distance from the equipment operating at full power and adjusting it based on the duty cycle of the activity to determine the Leq of the operation (FHWA 2006). It is very common for programmatic analysis such as this to utilize a conservative standard reference distance of 50 feet; project-specific noise analysis might use more specific values and it would be uncommon for there to be multiple pieces of heavy equipment operating together so close to a nearby property line for very long.

Heavy construction equipment during grading and site preparation for development facilitated by the project would typically include bulldozers, excavators, front-end loaders, dump trucks, and graders. It is assumed that diesel engines would power all construction equipment. Construction equipment would not all operate at the same time or location due to the different tasks performed by each piece of equipment. In addition, construction equipment would not be in constant use during the 8-hour operating day.

Impact devices such as pile drivers may be used for construction of development facilitated by the project. Although use of pile drivers is uncommon during construction for the type of development facilitated by the project, this analysis considers the potential for use of this equipment as a conservative analysis as some ground types or subterranean parking facilities may require their use.

A pile driver is sometimes used to drive foundation piles into the ground. These devices would typically operate separately from other equipment. Typical noise levels associated with the types of heavy equipment most likely to be utilized during development associated with the project are given in Table 4.11-4 below.

Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-15
Table 4.11-4 Typical Construction Equipment Noise Levels Equipment
Estimated Noise Levels at Nearest Sensitive Receptors (dBA Leq) 50 feet 100 feet
Air Compressor 80 74
Backhoe 80 74
Concrete Mixer 85 79
Dozer 85 79
Grader 85 79
Jack Hammer 88 82
Loader 80 74
Paver 85 79
Pile-drive (Impact) 101 95
Pile-driver (Sonic) 95 89
Roller 85 79
Saw 76 70
Scarified 83 77
Scraper 85 79
Truck 84 78
Source: FTA 2018

OPERATIONAL STATIONARY NOISE
The primary on-site noise sources associated with operation of residential units, and those discussed in this analysis, would include noise from stationary heating, ventilation, and air conditioning (HVAC) equipment and outdoor activities from residential uses, and HVAC and other mechanical equipment and truck loading/unloading at light industrial uses.

OPERATIONAL TRAFFIC NOISE
Development accommodated under the Housing Element Update would generate motor vehicle trips, thereby increasing off-site traffic on area roadways. The Project’s traffic noise impacts are analyzed based on data provided by Translutions. The overall increase in traffic noise was estimated using the FHWA roadway vehicle noise prediction model methodology. Roadway vehicle noise impacts are analyzed based on average daily traffic (ADT) volumes for Existing (SCAG 2020) and 2040 Buildout (2040 SCAG Huntington HE) traffic conditions, as well as speeds, vehicle mix, and number of lanes data. The FHWA model predicts noise levels through a series of adjustments to a reference sound level. These adjustments account for distances from the roadway, roadway vehicle volumes, vehicle speeds, car/truck mix, and number of lanes. Traffic noise modeling inputs and outputs are included in Appendix G.

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GROUNDBORNE VIBRATION
Operation of the proposed project would not include any substantial vibration sources (e.g., use of heavy equipment). Rather, construction activities would have the greatest potential to generate groundborne vibration affecting sensitive receivers and/or structures adjacent to a construction site, especially during grading and when a site is located near a historic site or structure.

Table 4.11-5 shows typical vibration levels for various pieces of construction equipment.

Table 4.11-5 Typical Vibration Levels for Construction Equipment Equipment PPV (in/sec) at 25 Feet
Pile Driver (Impact) 1.518
Pile Driver (Sonic) 0.734
Vibratory Roller 0.210
Hoe Ram 0.089
Large Bulldozer 0.089
Caisson Drilling 0.089
Loaded Truck 0.076
Jackhammer 0.035
Small Bulldozer 0.003
Sources: FTA 2018
Because groundborne vibration could cause physical damage to structures and is measured in an instantaneous period, vibration impacts are typically modeled based on the distance from the location of vibration-intensive construction activities, which is conservatively assumed to be edge of a project site, to the edge of the nearest off-site structures. Construction vibration levels that could occur due to buildout of the proposed project are based on reference vibration levels published by the FTA.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the proposed plan generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
Impact NOI-1 CONSTRUCTION OF INDIVIDUAL PROJECTS FACILITATED BY THE PROPOSED PROJECT WOULD TEMPORARILY INCREASE NOISE LEVELS, POTENTIALLY AFFECTING NEARBY NOISE-SENSITIVE LAND USES.

DEVELOPMENT FACILITATED BY THE PROPOSED PROJECT WOULD ALSO INTRODUCE NEW NOISE SOURCES AND CONTRIBUTE TO INCREASES IN OPERATIONAL NOISE. THE CONTINUED REGULATION OF NOISE, CONSISTENT WITH

THE CITY CODE AND GENERAL PLAN NOISE ELEMENT POLICIES WOULD MINIMIZE DISTURBANCE TO ADJACENT LAND USES. HOWEVER, CONSTRUCTION AND OPERATIONAL STATIONARY NOISE COULD EXCEED STANDARDS.

CONSTRUCTION NOISE WOULD BE SIGNIFICANT AND UNAVOIDABLE EVEN WITH MITIGATION.

Construction
Noise from individual construction projects facilitated by the project would temporarily increase ambient noise levels at adjacent property lines. Since there are no specific plans or time scales for Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-17
individual development projects that would be facilitated by the project, it is not possible to determine exact noise levels or time periods for construction of such projects, or construction noise at adjacent properties.

Construction activities would generate noise around the City. Table 4.11-4 illustrates typical noise levels associated with construction equipment at a distance of 50 feet. Noise would typically drop off at a rate of about 6 dBA per doubling of distance. Therefore, noise levels would be about 6 dBA lower than shown in Table 4.11-4 at 100 feet from the noise source and 12 dBA lower at a distance of 200 feet from the noise source. Construction may involve the operation of pile drivers. Pile foundations are generally used under two situations: 1) when there is a layer of weak soil at the ground surface that cannot support the weight of a building; or 2) when a building or structure has very heavy, concentrated loads, such as in a high-rise structure, bridge, or water tank.

As shown in Table 4.11-4 noise levels at 50 feet from construction activity associated with development facilitated by the project could approach 88 dBA Lmax with typical heavy-duty construction equipment such as a jackhammer, and up to 101 dBA Lmax with more intensive equipment such as an impact pile driver. Depending on the type of equipment, the duration of use, the distance to receivers, and the potential for pile driving, construction noise could exceed the daytime FTA construction noise thresholds of 80 dBA Leq, for an 8-hour period for residential uses.

Construction noise could increase ambient noise levels and may temporarily disturb people at neighboring properties.

The temporary nature of construction noise and compliance with HPMC Section 9-3.506, which limits construction activity to the hours of 7:00 a.m. to 7:00 p.m. on weekdays and Saturdays, would minimize construction noise impacts. General Plan Noise Element Policy 5.3 requires sound attenuation devices on construction equipment. However, it is still possible that construction noise would not result in a substantial increase over ambient noise levels or that nighttime construction noise may sometimes be necessary if pumps need to run continuously or for concrete pours. The construction noise threshold of 80 dBA Leq daytime at residential uses could be exceeded during future development under the project and, therefore, construction noise is considered potentially significant. Mitigation Measure NOI-1 is required to reduce construction noise impacts.

Operation

OPERATIONAL STATIONARY NOISE
Stationary sources of noise may occur on all types of land uses. Residential uses would generate noise from landscaping, maintenance activities, and mechanical equipment such as ground-level and rooftop ventilation and heating (HVAC) systems. Commercial uses would generate noise from HVAC systems, loading docks, and other sources. Other noise generated by residential or commercial uses such as conversations and parking lot activity is generally short and intermittent. A common HVAC unit is expected to generate up to approximately 72 dBA at three feet. For large buildings, such units are typically located on the roof, where operational noise is greatly reduced by distance and the intervening building or parapet wall itself. However, for smaller buildings including smaller multi-family residential units, large HVAC units are often placed at ground level on a concrete pad adjacent to the building. Existing noise sensitive receivers could be affected by operational noise from properties developed under the project.

The HPMC does not establish quantitative operational noise thresholds, but HPMC Section 5-11.01 prohibits any noise created, made, maintained, or produced by, through, or on account of the operation, starting, manipulation, use, movement, working, handling, or maneuvering of any device, City of Huntington Park
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appliance, apparatus, equipment, object, or thing, mechanical or otherwise, within the City by any person, and which noise is of sufficient loudness, intensity, or character and/or of such continuance or recurrence as to disturb the peace or quiet of any neighborhood within the City.

Development under the proposed project would adhere to General Plan Policy 3.2, which requires that a minimum of 15 feet be landscaped as a buffer between a commercial or mixed-use structure and the adjoining residential parcel. At a distance of 15 feet, it is estimated that HVAC noise could be up to 58 dBA, which is below the daytime significance threshold of 60 dBA Leq but above the nighttime significance threshold of 50 dBA Leq for residential and other noise-sensitive receptors.

General Plan Noise Element Policies 3.3, 3.4, 4.1, 4.2, and 4.3 would reduce stationary source noise impacts. However, the increase in ambient noise levels from operational use of residential-scale HVAC units or mechanical equipment and other stationary sources from mixed-use residential projects would be potentially significant. Mitigation Measure NOI-2 would be required.

OPERATIONAL TRAFFIC NOISE
Cumulative development would result in increased vehicle trips on various roadway segments, as shown in Table 4.11-6. All roadway segments would have a less than 1.5 dBA CNEL increase in traffic noise, which is the most stringent threshold for traffic noise increases for all existing ambient noise environments. Therefore, traffic noise increases from the proposed project would be less than significant.

Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-19
Table 4.11-6 Traffic Noise Increases Along Roadway Segments Roadway Segment
Existing
ADT
2040
Buildout
ADT
Existing Roadway
Vehicle Noise Level
at 50 feet
(dBA CNEL)
2040 Roadway
Vehicle Noise Level
at 50 feet
(dBA CNEL)
Roadway
Vehicle Noise
Increase
(dBA CNEL)
Significant?
Y/N
S. Alameda Street - E. Slauson Avenue to E. Gage Avenue 49,336 49,597 75.1 75.1 0.0 N S. Alameda Street - E. Gage Avenue to E. Florence Avenue 43,381 43,652 74.8 74.8 0.0 N S. Santa Fe Avenue - Fruitland Avenue to E. Slauson Avenue 28,998 28,451 73.8 73.7 -0.1 N Santa Fe Avenue - E. Slauson Avenue to Randolph Street 36,425 36,094 74.0 74.1 0.1 N Santa Fe Avenue - Randolph Street to E. Gage Avenue 25,723 24,717 73.0 73.1 0.1 N Santa Fe Avenue - E. Gage Avenue to Walnut Street 34,656 34,788 73.7 73.6 -0.1 N Pacific Boulevard - Fruitland Avenue to E. Slauson Avenue 28,173 27,431 70.4 70.9 0.5 N Pacific Boulevard - E. Slauson Avenue to Randolph Street 22,262 20,817 68.4 68.6 0.2 N Pacific Boulevard - Randolph Street to E. Gage Avenue 15,130 14,982 66.0 65.6 -0.4 N Pacific Boulevard - E. Gage Avenue to E. Florence Avenue 18,163 18,799 66.7 66.9 0.2 N S. Soto Street - Fruitland Avenue to E. Slauson Avenue 28,937 28,012 70.9 71.3 0.5 N Stafford Avenue - E. Slauson Avenue to Randolph Street 8,268 8,124 61.5 61.5 0.0 N Stafford Avenue - E. Gage Avenue to E. Florence Avenue 3,671 3,355 58.8 58.2 -0.5 N Miles Avenue - E. Slauson Avenue to Randolph Street 22,463 22,174 67.5 67.8 0.3 N Miles Avenue - Randolph Street to E. Gage Avenue 23,306 22,530 67.4 67.4 0.0 N Miles Avenue - E. Gage Avenue to East Florence Avenue 16,221 15,685 66.2 66.5 0.3 N Mountainview Avenue - Walnut Street to Santa Ana Street 18,685 17,619 66.9 67.1 0.2 N S. Boyle Avenue - Fruitland Avenue to E. Slauson Avenue 20,113 19,453 72.6 73.0 0.4 N S. Boyle Avenue - E. Slauson Avenue to Randolph Street 26,718 25,512 73.2 73.3 0.2 N State Street - Randolph Street to E. Gage Avenue 16,566 16,256 71.0 71.2 0.3 N State Street - E. Gage Avenue to Walnut Street 17,901 18,017 70.7 70.7 0.0 N State Street - Walnut Street to Santa Ana Street 13,996 13,547 70.0 70.1 0.1 N Salt Lake Avenue - E. Gage Avenue to E. Florence Avenue 11,050 11,191 65.2 64.7 -0.5 N California Avenue - E. Florence Avenue to Santa Ana Street 18,623 18,247 69.7 69.9 0.2 N City of Huntington Park
Housing Element and General Plan Update

4.11-20
Roadway Segment
Existing
ADT
2040
Buildout
ADT
Existing Roadway
Vehicle Noise Level
at 50 feet
(dBA CNEL)
2040 Roadway
Vehicle Noise Level
at 50 feet
(dBA CNEL)
Roadway
Vehicle Noise
Increase
(dBA CNEL)
Significant?
Y/N
S. Maywood Avenue - E. Slauson Avenue to Randolph Street 18,157 17,553 68.7 68.5 -0.2 N S. Maywood Avenue - Randolph Street to E. Gage Avenue 17,690 17,886 67.9 67.7 -0.2 N Salt Lake Avenue - E. Florence Avenue to Live Oak Street 19,953 19,983 67.4 67.4 0.0 N Gifford Avenue - E. Slauson Avenue to Randolph Street 12,605 11,868 67.5 68.7 1.1 N Otis Avenue - Salt Lake Avenue to Santa Ana Street 16,740 15,724 65.7 65.7 0.0 N E. Slauson Avenue - Wilmington Avenue to Alameda Street 50,986 50,739 76.4 75.9 -0.5 N E. Slauson Avenue - Alameda Street to S. Santa Fe Avenue 41,757 41,558 75.0 75.6 0.6 N E. Slauson Avenue - S. Santa Fe Avenue to Pacific Boulevard 39,195 39,384 74.6 75.4 0.8 N E. Slauson Avenue - Pacific Boulevard to Stafford Avenue 41,800 41,572 74.2 75.0 0.8 N E. Slauson Avenue - Stafford Avenue to S. Soto Street 33,985 33,684 73.6 74.5 0.9 N E. Slauson Avenue - S. Soto Street to S. Boyle Avenue 39,333 40,056 73.9 74.9 1.0 N E. Gage Avenue - Wilmington Avenue to S. Alameda Street 30,134 30,390 70.6 71.0 0.4 N E. Gage Avenue - S. Alameda Street to Santa Fe Avenue 20,338 19,452 68.6 68.9 0.2 N E. Gage Avenue - Santa Fe Avenue to Pacific Boulevard 23,086 23,006 68.6 68.9 0.3 N E. Gage Avenue - Pacific Boulevard to Stafford Avenue 23,697 23,524 68.8 68.5 -0.3 N E. Gage Avenue - Stafford Avenue to Miles Avenue 23,727 23,712 68.9 68.6 -0.2 N E. Gage Avenue - Miles Avenue to State Street 28,371 28,666 69.2 69.5 0.3 N E. Gage Avenue - State Street to Salt Lake Avenue 20,030 20,461 68.7 68.5 -0.3 N E. Gage Avenue - Salt Lake Avenue to California Avenue 16,044 15,755 67.3 67.4 0.1 N Randolph Street - Santa Fe Avenue to Pacific Boulevard 6,441 5,693 65.9 66.4 0.5 N Randolph Street - Stafford Avenue to Miles Avenue 6,062 5,767 63.6 63.4 -0.2 N Randolph Street - S. Maywood Avenue to Gifford Avenue 3,175 2,855 63.0 63.0 0.0 N Randolph Street - Gifford Avenue to Atlantic Boulevard 6,419 5,735 65.9 65.8 0.0 N E. Florence Avenue - Wilmington Avenue to S. Alameda Street 33,621 32,828 71.7 71.9 0.1 N E. Florence Avenue - S. Alameda Street to Santa Fe Avenue 46,406 46,198 73.0 73.1 0.1 N Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-21
Roadway Segment
Existing
ADT
2040
Buildout
ADT
Existing Roadway
Vehicle Noise Level
at 50 feet
(dBA CNEL)
2040 Roadway
Vehicle Noise Level
at 50 feet
(dBA CNEL)
Roadway
Vehicle Noise
Increase
(dBA CNEL)
Significant?
Y/N
Walnut Street - Santa Fe Avenue to Pacific Boulevard 44,269 44,736 69.5 69.7 0.2 N E. Florence Avenue - Pacific Boulevard to Seville Avenue 37,682 37,982 71.9 71.8 -0.1 N E. Florence Avenue - Seville Avenue to Stafford Avenue 37075 38,376 72.0 71.9 0.0 N E. Florence Avenue - Stafford Avenue to Miles Avenue 39,708 39,817 72.1 72.4 0.2 N Walnut Street - Miles Avenue to Mountain View Avenue 54,240 54,579 71.0 70.7 -0.3 N Walnut Street - Mountain View Avenue to State Street 41,707 41,811 69.6 69.3 -0.4 N E. Florence Avenue - State Street to Salt Lake Avenue 49,530 49,147 73.3 73.6 0.3 N E. Florence Avenue - Salt Lake Avenue to California Avenue 73,887 73,176 75.4 75.6 0.3 N Walnut Street - California Avenue to Bear Avenue 48,107 47,432 70.6 71.0 0.5 N Santa Ana Street - Mountain View Avenue to State Street 6,925 6,728 62.9 62.8 -0.1 N Santa Ana Street - State Street to California Avenue 13,196 12,784 65.9 65.8 -0.1 N Santa Ana Street - California Avenue to Otis Avenue 7,989 7,530 63.8 63.4 -0.4 N Santa Ana Street - Otis Avenue to Salt Lake Avenue 14,449 13,775 66.6 66.9 0.2 N ADT = average daily trips
Source: Traffic data provided by Translutions 2023
City of Huntington Park
Housing Element and General Plan Update

4.11-22
Mitigation Measures
NOI-1 Construction Noise Reduction Measures
Construction contractors of projects implemented under the proposed project shall implement the following measures for construction activities conducted within the City. Construction plans submitted to the City shall include construction noise analysis and identify these measures on demolition, grading, and construction plans submitted to the City. The City shall verify that grading, demolition, and/or construction plans submitted to the City include these notations prior to issuance of demolition, grading and/or building permits.

Mufflers. During all construction phases, all construction equipment, fixed or mobile, shall be operated with closed engine doors and shall be equipped with properly operating and maintained mufflers consistent with manufacturers’ standards.

Shielding and Silencing. Power construction equipment (including combustion engines), fixed or mobile, shall be equipped with noise shielding and silencing devices consistent with manufacturer’s standards or the Best Available Control Technology. Equipment shall be properly maintained, and the project applicant or owner shall require any construction contractor to keep documentation on-site during any earthwork or construction activities demonstrating that the equipment has been maintained in accordance with manufacturer’s specifications.

Stationary Equipment. All stationary construction equipment shall be placed so that emitted noise is directed away from the nearest sensitive receivers.

Signage. For the duration of construction, the applicant or contractor shall post a sign in a construction zone that includes contact information for any individual who desires to file a noise complaint.

Construction Staging Areas. Construction staging areas shall be located as far from noisesensitive uses as reasonably possible and feasible in consideration of site boundaries, topography, intervening roads and uses, and operational constraints.

Smart Back-Up Alarms. Mobile construction equipment shall have smart back-up alarms that automatically adjust the sound level of the alarm in response to ambient noise levels.

Alternatively, back-up alarms shall be disabled and replaced with human spotters to ensure safety when mobile construction equipment is moving in the reverse direction.

Equipment Idling. Construction vehicles and equipment shall not be left idling for longer than five minutes when not in use.

Use of Driven Pile Systems. Driven (impact), sonic, or vibratory pile drivers shall not be used, except in locations where the underlying geology renders alternative methods infeasible, as determined by a soils or geotechnical engineer and documented in a soils report.

Temporary Noise Barriers. Erect temporary noise barriers, where feasible, when construction noise is predicted to exceed the acceptable standards (e.g., 80 dBA Leq at residential receptors during the daytime) and when the anticipated construction duration is greater than is typical (e.g., two years or greater). Temporary noise barriers shall be constructed with solid materials (e.g., wood) with a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier. If a sound blanket is used, barriers shall be constructed with solid material with a density of at least 1 pound per square foot with no gaps from the ground to the top of the barrier and be lined on the construction side with acoustical blanket, curtain or equivalent absorptive material rated sound transmission class (STC) 32 or higher.

Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-23
Noise Complaint Response. Project applicants shall designate an on-site construction project manager who shall be responsible for responding to any complaints about construction noise.

This person shall be responsible for responding to concerns of neighboring properties about construction noise disturbance and shall be available for responding to any construction noise complaints during the hours that construction is to take place. They shall also be responsible for determining the cause of the noise complaint (e.g., bad silencer) and shall require that reasonable measures be implemented to correct the problem. A toll-free telephone number shall be posted in a highly visible manner on the construction site at all times and provided in all notices (mailed, online website, and construction site postings) for receiving questions or complaints during construction and shall also include procedures requiring that the on-site construction manager to respond to callers. The on-site construction project manager shall be required to track complaints pertaining to construction noise, ongoing throughout demolition, grading, and/or construction and shall notify the City’s Community Development Director of each complaint occurrence.

NOI-2 Operational Stationary Source Noise Reduction Measures The City shall update the HPMC to include exterior noise limits for non-transportation, stationary sources of 60 dBA Leq during the daytime (7:00 a.m. and 10:00 p.m.) and 50 dBA Leq during the nighttime (10:00 p.m. and 7:00 a.m.) at residential uses and other sensitive receptor property lines.

The nighttime limit shall only apply to sensitive receptors which are in use at night. Development projects shall conduct site-specific noise analysis, including any necessary noise reduction measures, to ensure that stationary source (e.g., mechanical equipment and truck loading docks) noise levels remain below these exterior noise standards.

Significance After Mitigation
It is anticipated that, with implementation of Mitigation Measure NOI-1, construction noise levels associated with smaller housing development could be reduced below the eight-hour 80 dBA Leq daytime residential noise thresholds. However, noise generated by larger housing development may still exceed the threshold. This would most commonly occur when a development project requiring larger equipment generates high noise levels (e.g., pile driving) on a property abutting a sensitive receiver, where there are multi-story receptors where temporary noise barriers would not be as effective, or when nighttime construction work is required. Therefore, noise impacts from construction activities related to the proposed project would be significant and unavoidable. It should be noted that the identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects analyzed at the project level.

Implementation of Mitigation Measure NOI-2 would reduce noise levels from operational stationary source noise levels to less than significant through the establishment of quantified exterior noise standards and the requirement that individual projects under buildout of the project include noise reduction measures, as necessary, to reduce noise levels to less than significant.

City of Huntington Park
Housing Element and General Plan Update

4.11-24
Threshold 2: Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
Impact NOI-2 CONSTRUCTION OF INDIVIDUAL PROJECTS FACILITATED BY THE PROJECT WOULD TEMPORARILY GENERATE GROUNDBORNE VIBRATION, POTENTIALLY AFFECTING NEARBY LAND USES.

OPERATION OF DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT RESULT IN SUBSTANTIAL GROUNDBORNE VIBRATION AND NOISE. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Construction activities associated with development facilitated by the project would result in varying degrees of groundborne vibration depending on the equipment and methods employed. As depicted in Table 4.11-5 above, the greatest typical source of vibration during general construction activities at development facilitated by the project would be caused by use of vibratory rollers, which would create approximately 0.21 in/sec PPV at a distance of 25 feet (FTA 2018). Additionally, as discussed under Impact NOI-1, it is possible that pile drivers would be used for construction of certain projects, which would generate approximately 1.518 in/sec PPV at a distance of 25 feet (FTA 2018). As discussed under Thresholds of Significance above, the most conservative level for structures is 0.12 in/sec for historic structures; the level is higher for residential buildings at 0.2 in/sec.

Pile driving may be necessary to facilitate development resulting from the project. The use of pile driving equipment is dictated by site soils and the need for secure or deep foundational pilings based on building height or design, and thus cannot be predicted with reasonable certainty at a program-level analysis. At close distance, impacts from vibration from pile driver or other highintensity construction activity would be significant and Mitigation Measure NOI-3 would be required.

Residential and mixed-use land uses facilitated by the 2040 General Plan would not involve substantial vibration sources associated with operation such as railroad and subway. Therefore, proposed project operational groundborne vibration and noise impacts would be less than significant.

Mitigation Measures
NOI-3 Construction Vibration Control Plan
Prior to issuance of a building permit for a project requiring pile driving during construction within 135 feet of fragile structures such as historical resources, 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no plaster); a vibratory roller within 40 feet of fragile historical resources or 25 feet of any other structure; or a dozer or other large earthmoving equipment within 20 feet for a fragile historical structure or 15 feet of any other structure, the project applicant shall prepare a groundborne vibration analysis to assess and mitigate potential noise and vibration impacts related to these construction activities. This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed FTA architectural damage thresholds (e.g., 0.12 in/sec PPV for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower horsepower earthmoving equipment shall be used. If necessary, construction vibration monitoring shall be Environmental Impact Analysis
Noise
Draft Environmental Assessment 4.11-25
conducted by a qualified acoustical consultant or structural engineer to ensure FTA vibration thresholds are not exceeded.

Significance After Mitigation
Although most construction activities located in the City are not anticipated to have significant vibration impacts, it is possible that some development projects under the proposed project could have significant vibration impacts during construction. This would most commonly occur when a development project using equipment that generates high vibration levels (e.g., pile driving or vibratory roller) would be located next to a historical resource constructed of fragile building materials, which is more sensitive to vibration damage, than structures that were built based on more recent building codes. However, Mitigation Measure NOI-3 would reduce vibration impacts associated with construction activities. If a site-specific construction analysis shows that construction vibration could still exceed established limits, vibration monitoring would be required to ensure that established limits are not exceeded. Therefore, construction vibration impacts related to buildout of the proposed project would be less than significant with mitigation.

Threshold 3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Impact NOI-3 THE PROPOSED PROJECT WOULD NOT FACILITATE DEVELOPMENT WITHIN THE VICINITY OF AN AIRPORT LAND USE PLAN OR AIRPORT. THE IMPACT OF AIRPORT OR AIRSTRIP OPERATIONS ON NEW DEVELOPMENT WOULD BE LESS THAN SIGNIFICANT.

As discussed in Section 4.8, Hazards and Hazardous Materials, there are no airports in the City. The nearest airport to the City of Huntington Park is the Compton/Woodley Airport, which is located approximately 6 miles south. The City of Huntington Park is located outside of the airport’s noise contours and the airport influence area (Los Angeles County 2009). Therefore, the proposed project would not expose people residing or working in the plan area to excessive noise levels. This impact would be less than significant.

Mitigation Measures
No mitigation measures are required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

City of Huntington Park
Housing Element and General Plan Update

4.11-26

4.11.4 Cumulative Impacts
The geographic area to analyze cumulatively considerable noise impacts includes the City and immediately adjacent areas that could be indirectly affected by noise generated in the City.

Construction Noise
Construction noise generated by the project, in combination with construction activities for other cumulative projects that may be constructed simultaneously could, without mitigation, substantially increase noise levels in the vicinity of future projects. Mitigation measures have been identified to help reduce noise from construction equipment from the proposed project. Therefore, unless construction of cumulative projects, including those proposed under development facilitated by the proposed project, occur in close proximity to each other and simultaneously, noise from individual construction projects have a small chance of combining to create significant cumulative impacts.

Although this scenario is unlikely, and mitigation measures would be implemented to the extent feasible, the potential remains for a cumulatively considerable increase in construction noise from individual projects. Therefore, Mitigation Measure NOI-1 would be required and the cumulative impact related to construction noise would be significant and unavoidable.

Operational Stationary Noise
Development facilitated by the proposed project would introduce new stationary noise sources to the ambient noise environment in the vicinity of the plan area, including new mechanical ventilation equipment. These sources may combine with other nearby cumulative projects to result in higher noise levels. However, operational noise from these sources is localized and rapidly attenuates within an urbanized setting due to the effects of intervening structures and topography that block the line of sight and due to other noise sources closer to receptors that obscure project-related noise. Implementation of Mitigation Measure NOI-2 would ensure that noise from new stationary sources as part of the cumulative projects would be within acceptable levels. Therefore, the cumulative impact related to operational stationary noise would be less than significant.

Operational Mobile Noise
As discussed in Impact NOI-1, traffic noise increases from development facilitated by the proposed project including cumulative conditions would be less than significant. Therefore, in combination with traffic noise for other cumulative projects, the cumulative impact related to traffic noise would be less than significant.

Groundborne Vibration
Although there could be other cumulative projects simultaneously under construction near a development project facilitated by the proposed project, the potential for construction groundborne vibration impacts is within relatively close distances (e.g., within approximately 25 feet for a vibratory roller). Implementation of Mitigation Measure NOI-3 would ensure that a groundborne vibration analysis is prepared when necessary to assess and mitigate potential groundborne vibration impacts related to construction activities. With implementation of Mitigation Measure NOI-3, cumulative groundborne vibration impacts would be less than significant.

Overall Level of Cumulative Significance
Significant and unavoidable.

Environmental Impact Analysis
Population and Housing
Draft Environmental Assessment 4.12-1

4.12 Population and Housing
This section evaluates potential impacts to population and housing that could arise from implementation of the proposed project.

4.12.1 Setting
a. City of Huntington Park
Table 4.12-1 provides the 2020 estimates of population and housing for the City of Huntington Park and Los Angeles County. The City of Huntington Park had a population of 59,337 residents in 2020, representing approximately 0.59 percent of the Los Angeles County population of 10,135,614 (California Department of Finance [DOF] 2021). The City’s population increased by 1,223 persons, or approximately 2.1 percent, from the 2010 population of 58,114 (DOF 2021). In comparison, the County of Los Angeles population grew by approximately 3.2 percent over the same period (DOF 2021).

Table 4.12-1 2020 Population, Households, and Housing Unit Estimates City of Huntington Park Los Angeles County
Population 59,337 10,135,614
Housing Units (Total) 15,228 3,590,574
Housing Units (Occupied) 1 14,827 3,360,402
Persons/Household Ratio2 3.99 2.96
1 Estimated by applying a derived civilian vacancy rate to the estimated civilian housing units. Vacancy rates are based on 2010 Census benchmark data, adjusted to incorporate the directional changes described by the latest available American Community Survey (ACS) data.
2 This is a ratio of persons (household) to an occupied housing unit.

Source: DOF 2021
In 2020, the City of Huntington Park had 15,228 housing units with an average persons per household of 3.99 (DOF 2021). The City’s housing inventory grew by 110 units, or approximately .73 percent, from the 2010 housing inventory of 15,151 units and average household size of 3.96 persons (DOF 2021).

Table 4.12-2 SCAG Population, Housing, and Employment Forecasts City of Huntington Park 2016 2045
Population 59,400 64,000
Housing Units 14,700 16,500
Employment 15,900 17,800
Employment/Housing Ratio 1.1 1.1
Source: SCAG 2020
Table 4.12-2 shows the City and County employment, housing, and population estimates and forecasts from the SCAG 2020-2045 RTP/SCS Demographics & Growth Forecast. The proposed project assumes a potential increase of 2,668 housing units.

City of Huntington Park
Housing Element and General Plan Update

4.12-2

4.12.2 Regulatory Setting
The following section summarizes regulations that pertain to population and housing. a. State Regulations
Housing Element Law: California Government Code Section 65584(a)(1) Pursuant to California Government Code Section 65584(a)(1), HCD is responsible for determining the regional housing needs assessment (segmented by income levels) for each region’s planning body known as a “council of governments” (COG), SCAG being the COG serving the Southern California area. HCD prepares an initial housing needs assessment and then coordinates with each COG to arrive at the final regional housing needs assessment. To date, there have been five previous housing element update “cycles.” California is now in its sixth “housing-element update cycle.” The SCAG RHNA and the City’s General Plan Housing Element are discussed further below.

The Sustainable Communities and Climate Protection Act of 2008 (SB 375, Steinberg)
SB 375 focuses on aligning transportation, housing, and other land uses to achieve regional GHG emission reduction targets established under the California Global Warming Solutions Act, also known as AB 32. SB 375 requires MPO to develop an SCS as part of the RTP, with the purpose of identifying policies and strategies to reduce per capita passenger vehicle generated GHG emissions.

As set forth in SB 375, the SCS must: (1) identify the general location of land uses, residential densities, and building intensities within the region; (2) identify areas within the region sufficient to house all the population of the region, including all economic segments of the population, over the course of the planning period; (3) identify areas within the region sufficient to house an eight-year projection of the regional housing need; (4) identify a transportation network to service the regional transportation needs; (5) gather and consider the best practically available scientific information regarding resource areas and farmland in the region; (6) consider the state housing goals; (7) establish the land use development pattern for the region that, when integrated with the transportation network and other transportation measures and policies, will reduce GHG emissions from automobiles and light-duty trucks to achieve GHG emission reduction targets set by CARB, if there is a feasible way to do so; and (8) comply with air quality requirements established under the Clean Air Act.

The City of Huntington Park is located in the jurisdiction of SCAG, a Joint Powers Agency established under California Government Code Section 6502 et seq. Pursuant to federal and State law, SCAG serves as a Council of Governments, a Regional Transportation Planning Agency, and the MPO for Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial Counties. SCAG is responsible for preparing the RTP/SCS and RHNA in coordination with other State and local agencies. These documents include population, employment, and housing projections for the region and its 15 subregions.

Existing law requires local governments to adopt a housing element as part of their general plan and update the housing element every four to eight years. SB 375 requires the RHNA to allocate housing units within the region in a manner consistent with the development pattern adopted by the SCS.

On September 3, 2020, SCAG adopted its Connect SoCal: The 2020-2045 RTP/SCS, which is an update to the previous 2016 RTP/SCS. Using growth forecasts and economic trends, the RTP/SCS provides a vision for transportation throughout the region for the next 25 years that achieves the Environmental Impact Analysis
Population and Housing
Draft Environmental Assessment 4.12-3
statewide reduction targets and in so doing identifies the amount and location of growth expected to occur within the region.

Housing Crisis Act of 2019 – (SB 330, Skinner)
The Housing Crisis Act of 2019 (SB 330) seeks to speed up housing production in the next half decade by eliminating some of the most common entitlement impediments to the creation of new housing, including delays in the local permitting process and cities enacting new requirements after an application is complete and undergoing local review—both of which can exacerbate the cost and uncertainty that sponsors of housing projects face. In addition to speeding up the timeline to obtain building permits, the bill prohibits local governments from reducing the number of homes that can be built through down-planning or down-zoning or the introduction of new discretionary design guidelines. The bill is in effect as of January 1, 2020 and expires on January 1, 2025.

Fair Employment and Housing Act (FEHA)
The FEHA of 1959 (Government Code Section 12900 et seq.) prohibits housing discrimination on the basis of race, color, religion, sexual orientation, marital status, national origin, ancestry, familial status, disability, or source of income.

The Unruh Civil Rights Act
The Unruh Civil Rights Act of 1959 (Civ. Code Section 51) prohibits discrimination in “all business establishments of every kind whatsoever.” The provision has been interpreted to include businesses and persons engaged in the sale or rental of housing accommodations.

AB 1763
AB 1763, effective January 1, 2020, amends the State Density Bonus Law (Section 65915) to allow for taller and denser 100 percent affordable housing developments, especially those near transit, through the creation of an enhanced affordable housing density bonus.

Housing Element Law: California Government Code Section 65583(c)(7) Section 65583 of the California Government Code requires cities and counties to prepare a housing element, as one of the state-mandated elements of the General Plan, with specific direction on its content. Pursuant to Section 65583(c)(7), the Housing Element must develop a plan that incentivizes and promotes the creation of accessory dwelling units that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households.

Housing Element Law: California Government Code Section 65583.2(g)(3) Pursuant to California Government Code Section 65583.2(g)(3), the Housing Element is required to include a program to impose housing replacement requirements on certain sites identified in the inventory of sites. Under these requirements, the replacement of units affordable to the same or lower income level, consistent with those requirements set forth in State Density Bonus Law (Government Code Section 65915(c)(3)), would be required.

City of Huntington Park
Housing Element and General Plan Update

4.12-4
Relocation Assistance: California Government Code Section 7261(a) Section 7261(a) of the California Government Code requires that programs or projects undertaken by a public entity must be planned in a manner that (1) recognizes, at an early stage in the planning of the programs or projects and before the commencement of any actions which will cause displacements, the problems associated with the displacement of individuals, families, businesses, and farm operations, and (2) provides for the resolution of these problems in order to minimize adverse impacts on displaced persons and to expedite program or project advancement and completion. The displacing agency must ensure the relocation assistance advisory services are made available to all persons displaced by the public entity. If the agency determines that any person occupying property immediately adjacent to the property where the displacing activity occurs is caused substantial economic injury as a result of the displacement, the agency may also make the advisory services available to that person.
b. Regional Regulations
Regional Housing Needs Assessment
SCAG prepares the RHNA mandated by State law so that local jurisdictions can use this information during their periodic updates of the General Plan Housing Element. The RHNA identifies the housing needs for very low income, low income, moderate income, and above moderate-income groups, and allocates these targets among the local jurisdictions that comprise SCAG. The RHNA addresses existing and future housing needs based on the most recent U.S. Census, data on forecasted household growth, historical growth patterns, job creation, household formation rates, and other factors. The need for new housing is distributed among income groups so that each community moves closer to the regional average income distribution. The project accounts for the 5th and 6th cycles of RHNA allocation, the two most recent allocations, summarized in Table 4.12-3. The City of Huntington Park was assigned a RHNA of 865 units for the 5th cycle and 1,605 units for the 6th cycle, totaling 2,500 units accounted for in this project (SCAG 2020). This allocation identifies housing needs for the planning period between October 2021 and October 2029. Local jurisdictions are required by State law to update their General Plan Housing Elements based on the most recently adopted RHNA allocation.

Table 4.12-3 RHNA Percentage of Income Distribution
Income Level
Percent of Area
Median Income (AMI) 5th Cycle 6th Cycle
Total RHNA
Allocation
Very Low 0-50% 216 264 480
Low 51-80% 128 196 324
Moderate 81-120% 149 243 392
Above Moderate >120% 402 902 1304
Total -- 865 1,605 2,500
Source: SCAG 2020
Environmental Impact Analysis
Population and Housing
Draft Environmental Assessment 4.12-5
c. Local Regulations
City of Huntington Park General Plan
Huntington Park’s General Plan was adopted in February 1991 and consists of the Land Use, Housing, Circulation, Open Space and Conservation, Safety, Noise, Public Facilities, and Urban Design Elements. All elements bear equal weight, and no element has legal precedence over another. California Government Code Section 65583(c) requires the Housing Element to maintain internal consistency with other General Plan Elements. The following goals, policies, and actions are applicable to the proposed project as part of Land Use and Community Development Element (Huntington Park 1991):

Land Use and Community Development Element
The Land Use and Community Development Element describes existing land use patterns and provides the physical framework for land use and development in the City. The Land Use and Community Development Element also contains policies to improve the City’s visual quality and livability, including its compatibility between neighborhoods, mixed-use areas, commercial areas, and industrial areas. It describes the economic context and sets out goals and policies to ensure new development is planned in coordination with infrastructure, public services, and recreational facilities (Huntington Park 1991).

City of Huntington Park Municipal Code
The HPMC establishes regulations that implement the City’s General Plan. Title 8, Building Regulations, of the HPMC describes the City’s building codes and other related regulations. Title 9, Zoning, describes the City’s zoning regulations and districts including special purpose zones, overlay zones, and the Downtown Huntington Park Specific Plan (DTSP). Title 10, Subdivisions, focuses on planning and building codes for subdivisions.

Downtown Huntington Park Specific Plan
The DTSP was adopted in August 2008 by the City of Huntington Park. The DTSP is intended to create a unique and identifiable downtown area for the City that is economically vibrant and pedestrian oriented. The Specific Plan extends from Randolph Street to the north, Seville Avenue and Zoe Avenue to the east, Florence Avenue to the south, and Rugby Avenue to the west. The DTSP is divided into four districts: District A– Gateway, District B– Festival, District C– Neighborhood, and District D– Zoe. The Specific Plan sets a vision for the 85-acre area to become a cleaner, more beautiful, mixed-use, pedestrian oriented neighborhood.

4.12.3 Impact Analysis
a. Significance Thresholds
The following thresholds of significance were developed based on the CEQA Guidelines, specifically from Appendix G. Accordingly, the project would have a significant impact with respect to population and housing if it would:

Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).

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Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.
b. Methodology
Although CEQA requires an EIR to consider its growth-inducing impacts, CEQA provides that the EIR “should not assume that growth is necessarily beneficial, detrimental, or of little significance.” The underlying purpose of the Housing Element Update is to accommodate housing needs, which includes needs as a result of population growth and existing growth in the City. Even substantial growth is not a significant impact if it accommodates growth projections for the City that can be accommodated by existing or planned facilities and services, and is consistent with the City’s General Plan, as well as State and regional policies and regulations. As such, a significant impact for purposes of this threshold is whether the updates to the Housing Element will induce unplanned growth.
c. Project Impacts and Mitigation Measures
Threshold 1: Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Impact POP-1 IMPLEMENTATION OF THE PROPOSED PROJECT WOULD ALLOW UP TO 2,668 ADDITIONAL HOUSING UNITS AND AN ESTIMATED 10,646 RESIDENTS. THIS WOULD EXCEED CONNECT SOCAL 2020 POPULATION AND HOUSING FORECASTS BUT WOULD BE CONSISTENT WITH THE CITY’S RHNA ALLOCATION.

SCAG’S NEXT RTP/SCS WOULD INCORPORATE THE HOUSING ELEMENT AND GENERAL PLAN UPDATE.

GROWTH RESULTING FROM THE PROJECT WOULD THEREFORE BE ANTICIPATED AND WOULD NOT RESULT IN UNPLANNED POPULATION GROWTH. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Huntington Park is a largely built-out community with few remaining vacant parcels open for future development. As such, the proposed project would primarily accommodate new housing units on infill sites, which would increase development density in portions of the City. The RHNA allocation is intended to accommodate forecasted population growth.

Development under the proposed project could add up to 2,668 additional residential units in the city by the year 2029 (see Section 2, Project Description). Considering the City’s persons per household ratio and the potential housing unit increase facilitated by the proposed project, it could create a population increase of 10,646 persons (2,668 units x 3.99 persons/household ratio). In the unlikely event that all potential buildout of inventory sites occurs, and assuming the growth is all new and not already accounted for under existing projections, the total population of the city in 2029 would be 69,983, which is 9.3 percent above SCAG’s 2045 population forecast of 64,000 (SCAG 2020).

Although development under the proposed project could exceed the SCAG regional population projection, the 2021-2029 Housing Element Growth anticipated under the proposed project is intended in part to meet regional housing needs over the long term, as it includes state mandated housing goals. The proposed project would be consistent with State requirements for the RHNA.

Although the proposed project would facilitate development beyond what is forecast in SCAG’s Connect SoCal 2020 Plan, it would bring the forecasts for the City’s General Plan and the RTP/SCS into consistency since the RTP/SCS will be updated in the next cycle to reflect new forecasts for each city in the region.

Environmental Impact Analysis
Population and Housing
Draft Environmental Assessment 4.12-7
In addition, the State requires that all local governments adequately plan to meet the housing needs of their communities. Given that the State is currently in an ongoing housing crisis due to an insufficient housing supply, the additional units under the proposed project would further assist in addressing the existing crisis and meeting the housing needs of the City’s communities.

Furthermore, the proposed project would first be submitted to the HCD for review and approval to ensure that it would adequately address the housing needs and demands of the City. Approval by the HCD would ensure that population and housing growth under the 2021-2029 Housing Element would not be substantial or unplanned.

Lastly, this analysis is conservative because it assumes a maximum buildout scenario and includes sites already planned for development and maximum buildout under the proposed zoning changes.

The project’s actual contribution to population growth may be less than estimated. In addition, the project would not involve the extension of roads or other infrastructure that could indirectly lead to population growth. As discussed in Section 4.13, Public Services and Recreation, and Section 4.16, Utilities and Service Systems, the City is mostly developed and is supported by existing public services and infrastructure which are sufficient to serve the additional housing units. Therefore, the project would not result in substantial unplanned population growth, either directly or indirectly.

This impact would be less than significant.

Mitigation Measures
No mitigation is required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 2: Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? Impact POP-2 DEVELOPMENT FACILITATED BY THE PROJECT WOULD OCCUR ON VACANT,

UNDERUTILIZED OR UNDERDEVELOPED LOTS, AND WOULD NOT DISPLACE SUBSTANTIAL NUMBERS OF EXISTING PEOPLE OR HOUSING. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

For the purpose of this analysis, “substantial” displacement would occur if allowed land uses would displace more residences than would be accommodated through growth facilitated by the project.

The goal of the proposed project is to accommodate and encourage new residential development in Huntington Park at the inventory sites. The proposed project addresses the need for future housing development beyond that required by the RHNA to account for a reasonable sites buffer. This buffer of additional units, which is considered in the inventory of candidate housing sites analyzed in this EA, is intended to help the City address future “no net loss,” if it becomes necessary to identify a replacement site for the project if a site is developed with fewer units or at a higher income category than assumed in the sites inventory. A portion of the housing units would be developed at a density range that could accommodate low and very-income housing as required to meet the RHNA 6th Cycle allocation. Development under the proposed project could result in up to 2,668 new housing units developed by 2029. The types of housing units anticipated under the proposed project would generally fall into the following categories of development projects: single-family, multifamily residential, and/or mixed-use development on vacant sites, redevelopment of existing nonresidential and residential sites that would allow residential use or higher density residential use. Therefore, overall, the proposed project would add to the City’s housing stock to meet housing City of Huntington Park
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goals. Development facilitated by the project would not result in the displacement of a substantial number of existing residences in order to accommodate for the planned increase in development intensity since most Draft Housing Opportunity Sites would be located on underdeveloped, underutilized, or vacant lots. In addition, although no projects have been identified that would displace existing units, if displacement did occur, new residential units would be constructed to more than replace existing displaced residences. Therefore, impacts related to displacement of existing residences would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.12.4 Cumulative Impact Analysis
Inducement of Substantial Population Growth
The cumulative projects in the city would have the potential to result in a significant cumulative impact if they would, in combination, directly or indirectly induce substantial unplanned population growth. The project would accommodate all projected citywide population and housing growth through 2029. Employment growth would be mostly filled by the existing workforce and would not induce substantial population growth. Therefore, cumulative impacts relating to population and housing would be the same as project impacts under Impact POP-1 and would be less than significant. The project incorporates regional growth anticipated by SCAG’s RHNA projections and thus considers cumulative growth.

Displacement of People and Housing
Implementation of the project would accommodate the City’s forecasted population and housing demand through 2029. The project would result in an overall net increase of housing units in the City, including affordable housing, and would not result in the displacement of people or housing.

Other jurisdictions in the region are updating their respective Housing Elements and have similar impacts related to displacement, but they would contain programs and policies to provide housing for low-income and special needs populations. Therefore, the proposed project would not contribute to cumulative impacts.

Environmental Impact Analysis
Public Services and Recreation
Draft Environmental Assessment 4.13-1

4.13 Public Services and Recreation
This section evaluates potential environmental impacts from implementation of the proposed project with respect to the following public services: fire protection services, police protection services, public schools, and parks and recreation facilities. Other public facilities and services such as water, wastewater, and solid waste are addressed in Section 4.16, Utilities and Service Systems.

4.13.1 Setting
a. Fire Protection
The City of Huntington Park contracts with the Los Angeles County Fire Department (LACoFD) for fire protection and emergency services. The LACoFD has a service area covering over 22,000 square miles and 4.1 million residents (LACoFD 2021). There are 177 fire stations throughout the County that responded to 378,517 calls in 2020 (LACoFD 2021). The City of Huntington Park has access to all the resources and facilities of the County Fire Department. Huntington Park is serviced by the Los Angeles County Fire Department Battalion 13, which is responsible for securing Huntington Park's safety with two fire stations. Fire station 164 houses the Battalion’s Headquarters. Still, other fire stations may respond to a fire in the City of Huntington Park if the need arises. The Los Angeles County Fire Department operates two fire stations in the City: Fire Station 164, located at 6301 South Santa Fe Avenue, serves as the area’s battalion headquarters (Huntington Park is serviced by Los Angeles County Fire Department-Battalion 13); and Fire Station 165, located at 3255 Saturn Avenue. Response time county-wide is under five minutes. b. Police Services
The Huntington Park Police Department (HPPD) is a full-service law enforcement agency composed of 108 full-time employees which includes approximately 60 sworn personnel and 50 civilian employees. The Department also has 25 part-time employees. The Huntington Park Police Department is made up of various divisions and works with the community in addressing crime and quality of life issues.
c. Schools
The City of Huntington Park is served by the Los Angeles Unified School District (LAUSD), which operates a total of 21 schools in the City. This includes five public schools in the City that are charter schools, nine elementary schools, one K-8 preparatory school, three middle schools, one 6-12 preparatory school, and seven high schools. Huntington Park is also within the service boundaries of East Los Angeles Community College. Table 4.13-1 lists the schools, location, and 2021-2022 enrollment for all schools in Huntington Park.

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Table 4.13-1 Schools and Enrollment for Huntington Park in 2021-2022 School Name Address 2021-2022 Enrollment
Alliance Collins Family College-Ready High 2071 Saturn Avenue 624 Alliance Margaret M. Bloomfield Technology Academy High 7907 Santa Fe Avenue 574 Aspire Ollin University Preparatory Academy 2540 East 58th Street 559 Chester W. Nimitz Middle 6021 Carmelita Avenue 1,233
Henry T. Gage Middle 2880 East Gage Avenue 1,197
Hope Street Elementary 7560 State Street 403
Huntington Park Elementary 6055 Corona Avenue 331
Huntington Park Senior High 6020 Miles Avenue 1,455
KIPP Comienza Community Prep 7300 Roseberry Avenue 1,048 Linda Esperanza Marquez High: Huntington Park Institute of Applied Medicine
6361 Cottage Street 763
Linda Esperanza Marquez High: Libra Academy 6361 Cottage Street 643 Linda Esperanza Marquez High: School of Social Justice 6361 Cottage Street 663 Lucille Roybal-Allard Elementary 3232 Saturn Avenue 467 Middleton Primary Center 2410 Zoe Avenue 223
Middleton Street Elementary 6537 Malabar Street 659
Miles Avenue Elementary 6720 Miles Avenue 815
Pacific Boulevard 2660 East 57th Street 334
PREPA TEC – Los Angeles 8001 Sante Fe Avenue 273
San Antonio Continuation High 2911 Belgrave Avenue 95
San Antonio Elementary 6222 State Street 487
Walnut Park Elementary 2642 Olive Street 549
Total Enrollment 13,395
Source: National Center for Education Statistics (NCES) 2022 As of the 2021-2022 school year, LAUSD is below capacity for each school level throughout the district, as summarized in Table 4.13-2.

Table 4.13-2 Summary of Available 2020-2021 LAUSD Capacity Grade Level State Capacity Space Needed Available Capacity TK through 6 371,125 332,699 38,426
7 through 8 90,963 87,335 3,628
9 through 12 204,876 176,646 28,230
SDC- Non-Severe 26,104 18,601 7,503
SDC- Severe 9,045 6,255 2,790
Totals 702,113 621,536 80,577
Source: LAUSD 2022
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Public Services and Recreation
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d. Parks
The City provides residents with more than 45.02 acres of total space, which includes playgrounds, picnic areas, athletic facilities, and meeting rooms, among other amenities. Table 4.13-3 lists parks within the City and their size in acres while Figure 4.13.1, illustrates its location.

Table 4.13-3 City Parks
Park Park Area (Acres)
Chelsey Park 0.2
Freedom Park 1.6
Raul R Perez Memorial Park 4.5
Robert Keller Park 2.6
Salt Lake Park 30.12
Veteran’s Park/Linear Park 6
Total 45.02
Source: Quintero 2022
The State has an established parkland-to-population recommendation of 5.0 acres of parkland per 1,000 persons. The City’s 2020 population was estimated to be 59,337 and maintains approximately

0.76 acres of parkland per 1,000.

4.13.2 Regulatory Setting
a. Federal Regulations
Occupational Safety and Health Administration
The Federal Occupational Safety and Health Administrations (OSHA) as well as California OSHA (CalOSHA) enforce the provisions of the federal and state Occupational Safety and Health Acts, respectively, which collectively require safety and health regulations for construction under Part 1926 of Title 29 Code of Federal Regulations (CFR). The fire-related requirements of the Federal Occupational Safety and Health Act are specifically contained in Subpart F, Fire Protection and Prevention, of Part 1926. Examples of general requirements related to fire protection and prevention include maintaining fire suppression equipment specific to construction on-site; providing a temporary or permanent water supply of sufficient volume, duration, and pressure; properly operating the on-site fire-fighting equipment; and keeping storage sites free from accumulation of unnecessary combustible materials.

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Figure 4.13-1 Parks in Huntingon Park
Environmental Impact Analysis
Public Services and Recreation
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Federal Emergency Management Act (FEMA)
FEMA was established in 1979 via executive order and is an independent agency of the federal government. In March 2003, FEMA became part of the U.S. Department of Homeland Security with the mission to lead the effort in preparing the nation for all hazards and effectively manage federal response and recovery efforts following any national incident. FEMA also initiates proactive mitigation activities, trains first responders, and manages the National Flood Insurance Program and the U.S. Fire Administration.

Disaster Mitigation Act of 2000
Disaster Mitigation Act (42 United States Code [U.S.C.] Section 5121) provides the legal basis for FEMA mitigation planning requirements for state, local, and Indian Tribal governments as a condition of mitigation grant assistance. It amends the Robert T. Stafford Disaster Relief Act of 1988 (42 U.S.C. Section 5121-5207) by repealing the previous mitigation planning provisions and replacing them with a new set of requirements that emphasize the need and creates incentives for state, tribal, and local agencies to closely coordinate mitigation planning and implementation efforts. This Act reinforces the importance of pre-disaster infrastructure mitigation planning to reduce disaster losses nationwide and the streamlining of the administration of federal disaster relief and programs to promote mitigation activities. Some of the major provisions of this Act include:
 Funding pre-disaster mitigation activities
 Developing experimental multi-hazard maps to better understand risk  Establishing state and local government infrastructure mitigation planning requirements  Defining how states can assume more responsibility in managing the Hazard Mitigation Grant Program (HMGP)
 Adjusting ways in which management costs for projects are funded The mitigation planning provisions outlined in Section 322 of this Act establish performance-based standards for mitigation plans and require states to have a public assistance program (Advance Infrastructure Mitigation [AIM]) to develop county government plans. The consequence for counties that fail to develop an infrastructure mitigation plan is the chance of a reduced federal share of damage assistance from 75 percent to 25 percent if the damaged facility has been damaged on more than one occasion in the preceding 10-year period by the same type of event. b. State Regulations
Fire Protection

CALIFORNIA FIRE AND BUILDING CODE
The State of California provides minimum standards for building design through the CBC, which is located in Part 2 of Title 24, California Building Standards Code, of the CCR. The CBC is based on the International Building Code but has been amended for California conditions. It is generally adopted on a jurisdiction-by-jurisdiction basis, subject to further modification based on local conditions.

Commercial and residential buildings are plan-checked by local building officials for compliance with the CBC. Typical fire safety requirements of the CBC include: the installation of sprinklers in all highrise buildings; the establishment of fire resistance standards for fire doors, building materials, and City of Huntington Park
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particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas.

CALIFORNIA CODE OF REGULATIONS
The California Code of Regulations, Title 5 Education Code, governs all aspects of education within the State. California State Assembly Bill 2926 (AB 2926) – School Facilities Act of 1986 – was enacted by the State of California in 1986 and added to the California Government Code (Section 65995). It authorizes school districts to collect development fees, based on demonstrated need, and generate revenue for school districts for capital acquisitions and improvements. It also established that the maximum fees which may be collected under this and any other school fee authorization are $1.50 per square foot ($1.50/ft2
) for residential development and $0.25/ft2 for commercial and industrial development. AB 2926 was expanded and revised in 1987 through the passage of AB 1600, which added Section 66000 et seq. of the Government code. Under this statute, payment of statutory fees by developers serves as total mitigation under CEQA to satisfy the impact of development on school facilities. However, subsequent legislative actions have alternatively expanded and contracted the limits placed on school fees by AB 2926.

CALIFORNIA FIRE SERVICE AND RESCUE EMERGENCY AID SYSTEM LACoFD participates in the California Fire Service and Rescue Emergency Mutual Aid System through which the California Governor’s Office of Emergency Service (OES), Fire and Rescue Division is responsible for the development, implementation and coordination of the California Fire Service and Rescue Emergency Mutual Aid Plan (Mutual Aid Plan) (Governor’s Office of Emergency Services, Fire and Rescue Division 2023). The Mutual Aid Plan outlines procedures for establishing mutual aid agreements at the local, operational, regional, and State levels, and divides the State into six mutual aid regions to facilitate the coordination of mutual aid. LACoFD is located in Region I. Through the Mutual Aid Plan, the OES is informed of conditions in each geographic and organizational area of the state, and the occurrence or imminent threat of disaster.

CALIFORNIA GOVERNOR’S OFFICE OF EMERGENCY SERVICES (CAL OES) In 2009, the State of California passed legislation creating the Cal OES and authorized it to prepare a Standard Emergency Management System (SEMS) program (Gov. Code Section 8607; Title 19 CCR Section 2401 et seq.), which sets forth measures by which a jurisdiction should handle emergency disasters. In California, SEMS provides the mechanism by which local government requests assistance. Non-compliance with SEMS could result in the state withholding disaster relief from the non-complying jurisdiction in the event of an emergency disaster. Cal OES coordinates the state’s preparation for, prevention of, and response to major disasters, such as fires, floods, earthquakes and terrorist attacks. During an emergency, Cal OES serves as the lead state agency for emergency management in the state. It also serves as the lead agency for mobilizing the state’s resources and obtaining federal resources. Cal OES coordinates the state response to major emergencies in support of local government. The primary responsibility for emergency management resides with local government. Local jurisdictions first use their own resources and, as they are exhausted, obtain more from neighboring cities and special districts, the county in which they are located, and other counties throughout the state through the statewide mutual aid system. California Emergency Management Agency (Cal-EMA) maintains oversight of the state’s mutual aid system.

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Public Services and Recreation
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Public Schools
SENATE BILL 50
The Leroy F. Greene School Facilities Act of 1998 (known as the Greene Act), enacted in 1998, is a program for funding school facilities largely based on matching funds. For new school construction, grants provide funding on a 50/50 State and local match basis. For school modernization, grants provide funding on a 60/40 State and local match basis. Districts that are unable to provide some, or all, of the local match requirement and are able to meet the financial hardship provisions may be eligible for additional State funding (State of California, Office of Public School Construction 2019).

The Greene Act permits the local district to levy a fee, charge, dedication, or other requirement against any development project within its boundaries, for the purpose of funding the construction or reconstruction of school facilities. The Act also sets a maximum level of fees a developer may be required to pay. Pursuant to Government Code Section 65996, the payment of these fees by a developer serves to mitigate all potential impacts on school facilities that may result from implementation of a project to a less-than-significant level.

Parks and Recreation

QUIMBY ACT
California Government Code Section 66477, also known as the Quimby Act, was enacted by the California legislature in 1965. The Quimby Act authorizes cities and counties to enact ordinances requiring the dedication of land, or the payment of fees for park and/or recreational facilities in lieu thereof, or both, by developers of residential subdivisions as a condition to the approval of a tentative tract map or parcel map.

State Public Park Preservation Act (California Public Resource Code Selection 5400 – 5409)
The State Public Park Preservation Act is the primary instrument for protecting and preserving parkland in California. Under the Act, cities and counties may not acquire any real property that is in use as a public park for any non-park use unless compensation or land, or both, are provided to replace the parkland acquired. This ensures a no net loss of parkland and facilities.

Quimby Act (California Government Code Section 66477)
The Quimby Act allows cities and counties to adopt park dedication standards/ordinances requiring developers to set aside land, donate conservation easements, or pay fees towards parkland when property is subdivided.
c. Local Regulations
City of Huntington Park General Plan
Huntington Park’s General Plan was adopted in February 1991 and consists of the Land Use, Housing, Circulation, Open Space and Conservation, Safety, Noise, Public Facilities, and Urban Design Elements. All elements bear equal weight, and no element has legal precedence over another. California Government Code Section 65583(c) requires the Housing Element to maintain internal consistency with other General Plan Elements. The following public services and recreation City of Huntington Park
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goals, policies, and actions are applicable to the proposed project as part of the Land Use, Circulation, Open Space and Conservation, Safety, and Public Facilities Element (Huntington Park 1991):

Land Use Element
The Land Use Element describes existing land use patterns and provides the physical framework for land use and development in the City. The Land Use Element also contains policies to improve the City’s visual quality and livability, including its compatibility between neighborhoods, mixed-use areas, commercial areas, and industrial areas. It describes the economic context and sets out goals and policies to ensure new development is planned in coordination with infrastructure, public services, and recreational facilities (Huntington Park 1991).

Circulation Element
The Circulation Element describes the existing transportation patterns and setting and provides the framework for transportation development in the City. The Circulation Element also contains goals, policies, and specific measures to improve the City’s efficiency and safety of the City’s transportation system (Huntington Park 1991).

Open Space and Conservation Element
The Open Space and Conservation Element describes existing air quality, groundwater, energy conservation, open space, parks, and recreation patterns in the City. The Open Space and Conservation Element also contains goals, policies, and specific measures to preserve and enhance the City’s open space, parks, and recreation (Huntington Park 1991).

Safety Element
The Safety Element describes the natural and man-made hazards that require special consideration in the land use planning and development process. The Safety Element establishes goals, policies, and specific measures to support public services, such as law enforcement, fire protection, and emergency medical services, to minimize danger to residents, workers, and visitors (Huntington Park 1991).

Public Facilities Element
The Public Facilities Element describes the existing setting for the City’s public facilities including law enforcement, fire protection, emergency medical services, education, libraries, water and sewer service, storm drainage, and solid waste and recycling. The Public Facilities Element also contains goals, policies, and specific measures to maintain and enhance the City’s public facilities and services (Huntington Park 1991).

City of Huntington Park Municipal Code
Title 4 Public Safety Chapter 5, Huntington Park Fire Code, of the Huntington Park Municipal Code adopts the 2010 California Fire Code as the City’s fire code and provides City-specific amendments, as necessary.

Environmental Impact Analysis
Public Services and Recreation
Draft Environmental Assessment 4.13-9

4.13.3 Impact Analysis
a. Significance Thresholds and Methodology
According to Appendix G of the CEQA Guidelines, impacts related to public services and recreation from implementation of the proposed project would be significant if it would:

1. Result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts in order to maintain acceptable service ratios, response times, or other objectives for any of the following public services:
a. Fire protection;
b. Police protection;
c. Schools;
d. Parks; or
e. Other public facilities;

2. Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated; or

3. Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. b. Project Impacts
Threshold 1a: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives?
Impact PS-1 DEVELOPMENT FACILITATED BY THE PROPOSED PROJECT WOULD INCREASE THE POPULATION IN THE CITY, WHICH WOULD INCREASE DEMAND FOR FIRE PROTECTION SERVICES. HOWEVER, THIS INCREASE WOULD NOT REQUIRE ADDITIONAL AND/OR EXPANDED FIRE PROTECTION FACILITIES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

As discussed in Section 4.12, Population and Housing, development facilitated by the project would add an estimated 10,646 residents to the City, increasing Huntington Park’s population from 59,337 to 69,983 persons. The population growth accommodated under the project would account for approximately 0.26 percent of LACoFD’s service population of over 4.1 million persons. The fire stations that would be most impacted by the project would be LACoFD Stations 164 and 165, which are both within City limits.

Planning for new or physically altered LACoFD stations is based on an assessment of the cumulative need for new facilities. The project’s incremental contribution to demand for new fire protection services would be offset by payment of proportionate property taxes, sales taxes, and/or development fees that would result from increased development and population growth. New or expanded fire protection facilities needed to accommodate future growth in LACoFD’s service area City of Huntington Park
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would be speculative at this time. Future proposals, if warranted, would undergo an independent environmental review under CEQA.

Local policies, including those in the proposed Land Use and proposed Safety Elements would continue and improve disaster preparedness efforts, community safety, and coordination between fire protection agencies. Specifically, Health and Safety Element Policies 9 through 12 and Public Facilities Policies 1.1 through 1.8 would ensure the provision of adequate fire services in the City.

Additionally, new development would be required to comply with all applicable federal, State, and local regulations governing the provision of fire protection services, including adequate fire access, fire flows, and number of hydrants, such as the 2022 California Fire Code and 2022 California Building Code. Potential future development under the proposed project would be subject to LACoFD review to ensure that sufficient provisions for emergency access and response are made, fire code requirements are satisfied, and adequate levels of service can be provided.

It is anticipated that a potential future fire station or an expansion to an existing station will be subject to CEQA review at the time a site is identified and a specific design proposed. Additionally, implementation of the Safety Element Update will provide additional improvements regarding emergency access and evacuation beyond the current Safety Element. In particular, Health and Safety Element Policies 17 through 23 would ensure that property evacuation, as needed, is performed. Therefore, the project would not result in significant environmental impacts associated with the need for the provision of new or physically altered fire protection facilities, and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 1b: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities, or the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives? Impact PS-2 DEVELOPMENT FACILITATED BY THE PROPOSED PROJECT WOULD INCREASE THE POPULATION IN THE CITY, WHICH WOULD INCREASE DEMAND FOR POLICE PROTECTION SERVICES. HOWEVER, THIS INCREASE WOULD NOT REQUIRE ADDITIONAL AND/OR EXPANDED POLICE PROTECTION FACILITIES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

As discussed in Section 4.12, Population and Housing, development facilitated by the project would add an estimated 10,646 residents to the City, increasing Huntington Park’s population from 59,337 to 69,983 persons. Based on HPPD’s current staffing level of approximately 60 sworn officers, the HPPD’s officer/resident ratio would drop from 1.01 to approximately 0.86 sworn officers per 1,000 residents. The City currently does not have standards set for its response time or service ratio.

Policy 4.3 in Huntington Park’s Land Use Element and policies 1.1, 1.2, and 1.5 in Huntington Park’s Safety Element require the HPPD to ensure that there is adequate staffing, facilities, equipment, technology, and funding to meet existing services demands. Additional demand for police service Environmental Impact Analysis
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would be accommodated through the expansion of policy personnel and facilities to continue to maintain adequate police protection services. Police protection service levels would continue to be evaluated and maintained by HPPD in accordance with existing policies, procedures and practices as development occurs over the lifetime of the proposed project.

What’s more, local policies, including those in the update to the Safety Element would continue and improve disaster preparedness efforts, community safety, and coordination between law enforcement agencies. Specifically, Health and Safety Element Policy 17 through 23 of the 2030 General Plan aims to provide and maintain high-quality emergency, evacuation, and preparedness police services.

Planning for new or physically altered HPPD stations is based on an assessment of the cumulative need for new facilities. The proposed project itself would not result in the need for new or expanded facilities. The incremental contribution to demand for increased HPPD protection services would be offset by payment of proportionate property taxes and sales taxes and development impact fees to the City of Huntington Park by developers and the addition of new residents.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 1c: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered schools, or the need for new or physically altered schools, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives?
Impact PS-3 DEVELOPMENT ACCOMMODATED BY THE PROPOSED PROJECT WOULD RESULT IN AN

INCREASE IN POPULATION IN THE PLANNING AREA, POTENTIALLY RESULTING IN THE NEED FOR ADDITIONAL AND/OR EXPANDED SCHOOL FACILITIES. HOWEVER, GOVERNMENT CODE 65995 (B) WOULD REQUIRE

FUNDING FOR THE PROVISION OR EXPANSION OF NEW SCHOOL FACILITIES TO OFFSET IMPACTS FROM NEW RESIDENTIAL. ADDITIONALLY, ACCOMMODATING GROWTH PURSUANT TO THE RHNA MAY REQUIRE ADJUSTMENTS TO THE RATE OF INTER-DISTRICT PERMITS. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

The proposed project would not directly affect local schools but would generate new students entering the LAUSD. Implementation of the proposed project would add an estimated 2,668 dwelling units and 10,646 residents, in which some of those residents would be school-aged children. Based on student generation rates for the LAUSD, the proposed project could generate an estimated 987 students, including 517 elementary school students (grades TK-6), 144 middle school students (grade 7-8), 286 high school students (grades 9-12), and 40 special day class (SDC) students, as shown in Table 4.13-4.

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Table 4.13-4 Estimated Student Generation from Project
Grade Level
Students per
Household
Dwelling
Units
Total Students
Generated*
District
Available
Capacity
District
Available
Capacity
With Project
Exceeds
Capacity?
TK through 6 0.1935 2,668 517 38,426 37,909 No
7 through 8 0.0538 2,668 144 3,628 3,484 No
9 through 12 0.1071 2,668 286 28,230 27,944 No
SDC 0.0148 2,668 40 10,293 10,253 No
Total 987 80,577 79,590 No
Source: LAUSD 2022
*Results rounded up to the nearest whole number
As shown in Table 4.13-2, enrollment capacity in the LAUSD as of school years 2020 and 2021 would adequately accommodate the estimated 987 students assumed as part of the proposed project, as this estimated increase would account for 1.2% of the total available capacity of 80,577 students. In addition, to offset a project’s potential impact to schools, the LAUSD implements developer fees which reduce potential student impacts from development activity, these fees for 2022 are summarized below, in Table 4.13-5. Any development facilitated by the proposed Housing Element and General Plan Update would be subject to these State-mandated school impact fees and collected at the time of building permit issuance. Pursuant to Section 65995.5 of the California Government Code (Senate Bill 50, chaptered August 27, 1998), the payment of statutory fees “is deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization.” LAUSD will continue to evaluate demand, capacity, and plans for facility needs as future projects under the Housing Element are built out, including any required adjustments to the number of inter-districts permits relative to new student population generated from additional housing development in the City.

Table 4.13-5 2022 LAUSD Developer Fee Collection Rates
Development Type Fee Rate per Square Foot
Residential $4.79
Commercial/Industrial $0.78
Rental Self Storage Facilities $0.24
Parking Structures $0.34
Source: LAUSD 2022
There are no planned improvements to add capacity through expansion. In the event that LAUSD constructs a new school or physically alter an existing facility, a project-specific environmental analysis would be required under CEQA to address site-specific environmental concerns. As described above, existing laws and regulations would require funding for the provision or expansion of new school facilities to offset impacts from new residential development and impacts would be less than significant.

Environmental Impact Analysis
Public Services and Recreation
Draft Environmental Assessment 4.13-13
Mitigation Measures
No mitigation measures are required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 1e: Would the Project result in substantial adverse physical impacts associated with the provision of other public facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives?
Impact PS-4 DEVELOPMENT UNDER THE PROJECT WOULD INCREMENTALLY INCREASE THE CITY POPULATION AND INCREASE THE USE OF EXISTING LIBRARY FACILITIES. HOWEVER, PROPERTY TAXES RELATED TO NEW DEVELOPMENT WOULD CONTRIBUTE TO ANY NECESSARY NEW OR EXPANDED LIBRARY FACILITIES. IMPACTS

RELATED TO THE PROVISION OF NEW OR PHYSICALLY ALTERED PUBLIC FACILITIES WOULD BE LESS THAN SIGNIFICANT.

The Huntington Park Public Library is one of 85 Los Angeles County libraries, there are three other nearby libraries in Florence-Graham, Bell, and Maywood. The Huntington Park Library is open Tuesday through Saturday for 40 hours per week. The library building is 33,482 square feet and includes one meeting room which has a capacity of 41 people. As discussed in Section 4.12, Population and Housing, development facilitated by the project would increase Huntington Park’s population from 59,337 to 69,983 persons, an 18 percent increase of the City’s estimated 2020 population. Given that not all new residents would visit the library frequently, the increase in monthly visitation would be lower than 18 percent.

While a less than 18 percent increase would be a large increase to the usage of the library, this is in line with RHNA’s housing unit allocation for the area and the growth is also anticipated to occur over the next eight years and would not occur all at once. Moreover, the library maintenance and potential new or expanded facilities are funded from local property taxes, which would continue to be paid by property owners. Therefore, project impacts to public library facilities would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

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Threshold 1d: Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered parks, or the need for new or physically altered parks, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives? Threshold 2: Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Threshold 3: Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment?
Impact PS-5 DEVELOPMENT UNDER THE PROJECT WOULD INCREMENTALLY INCREASE THE CITY’S

POPULATION AND INCREASE THE USE OF EXISTING PARKS AND RECREATIONAL FACILITIES AND REDUCE THE CITY’S PARKLAND TO POPULATION RATIO. HOWEVER, DEVELOPMENT FEES IN-LIEU OF PARKS PURSUANT TO THE QUIMBY ACT WOULD BE REQUIRED AS PART OF THE INDIVIDUAL PROJECTS. IMPACTS RELATED TO THE PHYSICAL

DETERIORATION OF PARKLAND OR RECREATIONAL FACILITIES, AND THE NEED TO CONSTRUCT NEW FACILITIES, WOULD BE LESS THAN SIGNIFICANT.

The project would facilitate an increase of up to 10,646 residents resulting in a potential increase in the use of the parks and recreational facilities throughout Huntington Park. The city currently has

45.02 acres of parkland, with a parkland to population ratio of 0.76 acres per 1,000 residents.

Development under the project would increase the population of the City by an estimated 10,646 residents, resulting in a total City population of approximately 69,983 residents and a parkland ratio of 0.64 acres per 1,000 residents. The current and projected population to parkland ratio are far below the State recommendation of 5.0 acres of parkland per 1,000. The City of Huntington Park would not be able to achieve this goal as the City is highly urbanized and lacks the amount of undeveloped land the City would need to be developed into parkland to meet the goal.

As future residential development projects are approved, parkland in-lieu fees (pursuant to the Quimby Act) would be required by HPMC Article 9-3.1602 as part of the individual projects. Funding for maintenance of new and existing facilities is provided through property assessments and taxes.

Park and recreational facility maintenance and acquisition needs in the city are evaluated with respect to population growth, locational needs, and budget. The project would not preclude implementation or expansion of any parkland, trails, or recreation facility.

Any project associated with new or expanding parkland or recreation facilities would be subject to project-specific environmental review and mitigation pursuant to CEQA. It is anticipated that the City’s review processes would adequately mitigate potential environmental impacts relating to the development of new or redeveloped parkland, open space, or other recreational facilities as new residential development would be required to pay an impact fee and/or to dedicate parkland to offset the increase in park needs resulting from new residents. Therefore, the project would result in less than significant substantial physical deterioration of existing parkland or substantial adverse physical impacts associated with the provision of new or physically altered parkland.

Mitigation Measures
No mitigation measures would be required.

Environmental Impact Analysis
Public Services and Recreation
Draft Environmental Assessment 4.13-15
Significance After Mitigation
Impacts would be less than significant without mitigation.

4.13.4 Cumulative Impacts
Fire Protection
Cumulative development would increase the population such that there is an increase in reported incidents, leading to longer response times unless the Fire Department increases staffing. As described above under Impact PS-1, with continued implementation of General Plan policies and Fire Code requirements, it is not anticipated that a new fire station is needed to serve cumulative development in Huntington Park. Therefore, the cumulative impacts related to fire protection facilities would be less than significant, and the proposed project’s contribution to these impacts would not be cumulatively considerable.

Police Protection
Cumulative development would increase population such that there is an increase in reported incidents, leading to longer response times unless the police department increases staffing. Should additional staffing be needed to serve the areas around the project sites accounting for future cumulative development, staffing is reviewed each budget cycle and considers historical and current year information related to police services. Overall, although additional staffing may be needed, it is not anticipated that additional police department facilities would be needed to serve cumulative growth in the project areas. Therefore, the cumulative impacts related to police facilities would be less than significant, and the proposed project’s contribution to these impacts would not be cumulatively considerable.

Schools
Cumulative development would increase the number of children attending LAUSD schools.

However, as stated in Impact PS-3, the district is below capacity and the potential increase in students would not exceed that capacity. Furthermore, compliance with SB 50 would require future development in Huntington Park to pay school impact fees established to offset potential impacts from new development. Therefore, pursuant to California Government Code Section 65995.5, the cumulative impact relating to school capacity would be less than significant, and the project’s contribution to this impact would not be cumulatively considerable.

Parks and Recreation Facilities
Cumulative development would increase demand for park and recreational facilities. As described in the PS-6 above, the project would increase the population of Huntington Park thereby reducing the ratio of parkland within the city limits to parkland ratio to approximately 0.47 acres per 1,000 residents, which is below the State recommendation of five acres of parkland per 1,000 people.

However, new development projects would have to adhere to HPMC Article 9-3.1602 which requires development to provide Quimby parkland in-lieu fees and park improvement impact fees, which would ensure any cumulative significant impacts to park and recreational facilities would be reduced to less than significant. Therefore, cumulative impacts related to new or expanded park and recreation facilities, or the physical deterioration of existing park and recreation facilities, would be City of Huntington Park
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less than significant, and the proposed project would not have a cumulatively considerable contribution to a significant cumulative impact regarding park and recreation facilities.

Environmental Impact Analysis
Transportation
Draft Environmental Assessment 4.14-1

4.14 Transportation
This section analyzes the potential impacts of the project on transportation, including conflicts with transportation plans, vehicle miles traveled (VMT), project-related transportation hazards, and emergency access, associated with the implementation of the proposed project. The information provided in this section was based primarily on a VMT Impact Analysis authored by Translutions, Inc. (Translutions) in March 2023, included as Appendix H to this report.

4.14.1 Setting
The existing vehicular circulation, bicycle and pedestrian facilities, and transit services in the project vicinity are described below.

Major Highways
There are no highways within the city limits of Huntington Park. Regional access is provided to Huntington Park through Interstate 5 and 10 to the north, Interstate 110 to the west, Interstate 105 to the south, and Interstate 710 to the east.

Public Transit
Los Angeles County Metropolitan Transportation Authority (MTA) The Los Angeles County Metropolitan Transportation Authority (MTA) buses run along major streets in the City including Pacific Boulevard, Florence Avenue, Gage Avenue, and Santa Fe Avenue. MTA buses passing through Huntington Park include Routes 60, 102, 108-358, 110, 111-311, 251, 254, 611, 612, 751, and 760. These routes pass through all major arterial roadways in the City and provide connections to most communities and major activity centers throughout the region. The MTA Metro Blue Line is a commuter rail service serving downtown Los Angeles and areas to the south down to Long Beach. The Blue Line is operated through Prop A funds with a fixed fare for any length of the trip. Bus routes complement the Blue Line, and several park-and-ride and kiss-and-ride lots have been developed along the route to encourage use of the Blue Line.

HP Express: Huntington Park Local Transit Shuttle
The HP Express is a project of the City of Huntington Park and is a component of Metro, the region’s integrated transportation system. HP Express operates from 6:30 AM to 6:30 PM on weekdays and from 8:00 AM to 5:00 PM on Saturdays. HP Express does not operate on Sundays.

Dial-A-Ride Service
The City of Huntington Park contracts with Metro Transit to offer economical taxicab services that provide curb-to-curb transportation to the residents of Huntington Park who are at least 65 years old, or disabled, or already enrolled in the program as of June 2016.

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4.14.2 Regulatory Setting
a. Federal Regulations
The US Department of Transportation (USDOT) provides a number of grant programs, primarily for the construction and upgrading of major highways and transit facilities. Many of these grants are administered by the state and regional governments. Use of federal grant funding also invokes the National Environmental Protection Act in some cases. The Federal Highway Administration (FHWA) sets design standards (such as interchange spacing) for interstate highways, such as the Long Beach (I-710) Freeway. The Federal Railroad Administration within the USDOT establishes safety rules regarding the operation of railroads (e.g., maximum train speeds, maximum allowed highway crossing blockage time).

Americans with Disabilities Act
The Americans with Disabilities Act (ADA) provides comprehensive rights and protections to individuals with disabilities. The goal of the ADA is to assure equality of opportunity, full participation, independent living, and economic self-sufficiency. To implement this goal, the United States Access Board has created accessibility guidelines for public rights-of-way. The guidelines address various issues, including roadway design practices, slope and terrain issues, pedestrian access to streets, sidewalks, curb ramps, street furnishings, pedestrian signals, parking, and other components of public rights-of-way. The City of Huntington Park works to ensure that people with disabilities have access to City programs, services, activities, and facilities. The City of Huntington Park in coordination with Owen group, was undertaking a survey on accessibility needs that will shape the City’s roadmap for accessibility in 2018, which has not been completed yet. b. State Regulations
California Senate Bill 743
Senate Bill 743 (SB 743) was signed into law on September 27, 2013 and directed OPR to develop revisions to the CEQA Guidelines to establish new criteria for determining the significance of transportation impacts. SB 743 was enacted, in part, as further implementation of California’s Climate Action Plan to meet California Global Warming Solutions Act (Assembly Bill [AB] 32) GHG emission reduction targets. SB 743 seeks to reduce criteria air pollutants and GHG emissions in the transportation sector by reducing VMT. SB 743 changed the approach to transportation impact analysis by establishing measures such as VMT, VMT per capita, or automobile trip generation rates as the primary measures of transportation impacts and eliminates the traditionally used measures of auto delay and congestion, such as Level of Service (LOS), and other measures of traffic congestion as a basis for determining significant impacts.

In December 2018, OPR adopted and promulgated its changes to the CEQA Guidelines (14 California Code of Regulations [CCR] Section 15000 et seq.) in response to SB 743. Section 15064.3 of the CEQA Guidelines contains the operative language for implementing the goals of SB 743 when determining the significance of a project’s transportation impacts. There are four key aspects of CEQA Guidelines Section 15064.3 that apply in the case of the project:
“[A] project’s effect on automobile delay shall not constitute a significant environmental impact” (Section 15064.3[a]).

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Transportation
Draft Environmental Assessment 4.14-3
For a land use project like the proposed project, “Vehicle miles traveled exceeding an applicable threshold of significance may indicate a significant impact… Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact” (Section 15064.3[b][1]). “A lead agency has discretion to choose the most appropriate methodology to evaluate a project’s vehicle miles traveled, including whether to express the change in absolute terms, per capita, per household or in any other measure” (Section 15064.3[b][(4]).

The terms and conditions of Section 15064.3 apply prospectively and a lead agency “may elect to be governed by the provisions of [15064.3] immediately. Beginning on July 1, 2020, the provisions of [15064.3] shall apply statewide” (Section 15064.3[c]). c. Regional and Local Regulations
Southern California Association of Governments
SCAG is the metropolitan planning organization for the southern California region, which includes Ventura, Los Angeles, San Bernardino, Orange, Riverside, and Imperial Counties. In 2020, SCAG’s Regional Council approved and adopted Connect SoCal, the agency’s 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal is a long-range visioning plan that builds upon and expands land use and transportation strategies established over several planning cycles to increase mobility options and achieve a more sustainable growth pattern (SCAG 2020). It charts a path toward a more mobile, sustainable, and prosperous region by making connections between transportation networks, between planning strategies, and between the people whose collaboration can improve the quality of life for those who live in southern California.

Connect SoCal provides maps of priority growth/neighborhood mobility areas, high-quality transit areas, and transit priority areas, some of which occur in Huntington Park, that provide the potential to streamline development along the transportation corridors within cities.

City of Huntington Park General Plan
Huntington Park’s General Plan was adopted in February 1991 and consists of the Land Use, Housing, Circulation, Open Space and Conservation, Safety, Noise, Public Facilities, and Urban Design Elements. All elements bear equal weight, and no element has legal precedence over another. The General Plan lists several traffic and transportation goals, policies, and actions as part of the Circulation Element. The following goals, policies, and actions are applicable to the proposed Project (Huntington Park 1991):

Circulation Element
The Circulation Element establishes goals, policies, and specific measures to provide safe and efficient mobility within the City of Huntington Park and to surrounding communities (Huntington Park 1991).

City of Huntington Park Municipal Code
The City of Huntington Park lists several policies within its Municipal Code to mitigate potential traffic hazards. Title 4 Public Safety Chapter 7, Traffic, of the Huntington Park Municipal Code details traffic guidelines and regulations.

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City of Huntington Park Bicycle Transportation Master Plan The City of Huntington Park Bicycle Transportation Master Plan, adopted in February 2014, includes policies and strategies designed to increase bicycle ridership within the city and improve local and regional connectivity.

4.14.3 Impact Analysis
a. Traffic Impact Assessment under CEQA
State law has changed with respect to how transportation-related impacts may be addressed under CEQA. Traditionally, lead agencies used LOS to assess the significance of such impacts, with greater levels of congestion considered to be more significant than lesser levels. Mitigation measures typically took the form of capacity-increasing improvements, which often had their own secondary environmental impacts (e.g., to biological and cultural resources). Depending on circumstances, and an agency’s tolerance for congestion (e.g., as reflected in its general plan), LOS D, E, or F often represented significant environmental effects. As described above, in 2013, however, the Legislature passed legislation to ultimately do away with LOS in most instances as a basis for environmental analysis under CEQA. Enacted as part of SB 743, PRC section 21099(b)(1), directed OPR to prepare, develop, and transmit to the Secretary of the Natural Resources Agency for certification and adoption proposed CEQA Guidelines addressing “criteria for determining the significance of transportation impacts of projects within transit priority areas. Those criteria shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses. In developing the criteria, [OPR] shall recommend potential metrics to measure transportation impacts that may include, but are not limited to, vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated. The office may also establish criteria for models used to analyze transportation impacts to ensure the models are accurate, reliable, and consistent with the intent of this section.” PRC section 21099(b)(2) further provides that “[u]pon certification of the guidelines by the Secretary of the Natural Resources Agency pursuant to this section, automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment pursuant to [CEQA], except in locations specifically identified in the guidelines, if any.”
Pursuant to SB 743, the Natural Resources Agency promulgated CEQA Guidelines section 15064.3 in late 2018. It became effective in early 2019. Subdivision (a) of that section provides that “[g]enerally, vehicle miles traveled is the most appropriate measure of transportation impacts. For the purposes of this section, ‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project. Other relevant considerations may include the effects of the project on transit and non-motorized travel. Except as provided in subdivision (b)(2) [regarding roadway capacity], a project’s effect on automobile delay shall not constitute a significant environmental impact.”
b. Methodology and Significance Thresholds
Consistent with the State CEQA Guidelines, impacts related to transportation and circulation would be considered potentially significant if implementation of the project would result in any of the following:

Environmental Impact Analysis
Transportation
Draft Environmental Assessment 4.14-5
Conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, and bicycle and pedestrian facilities Conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b)1 Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

Result in inadequate emergency access.

Methodology
The SCAG RTP model uses a two-tier traffic analysis zone (TAZ) system – Tier 1 zones and Tier 2 zones, as referenced Appendix H. To note, two or more Tier 2 zones make up a Tier 1 zone. The model utilizes Tier 2 zone system for modeling steps such as trip generation, trip distribution, and mode choice while it uses Tier 1 zone system for assignment purposes. Given the inability to perform zone splits in the SCAG RTP model and based on how the guidelines require evaluation of plans and programs, the additive method was used for the analysis. Under this method, project related Socioeconomic Data (SED) was added to the existing (or future) SED of the TAZs to evaluate with proposed project VMT.

MODEL SOCIOECONOMIC DATA
The model consists of both residential (households and population) and non-residential land uses (employment by type/category) as inputs. For households, the travel model uses household characteristics such as household income, household size, and household workers etc., to determine the household travel patterns. The number of households by dwelling unit type were based on the proposed project information provided by the City. This evaluation is based on 2,668 units.

The average household size from 2016 SCAG RTP/SCS model for each TAZ was maintained and carried over to the number of new dwelling units proposed as part of the proposed project.

Table 4.14-1 shows the change in households and population that is forecast to occur at each TAZ because of the proposed project. As shown on Table 4.14-1, the project will result in an increase of 2,668 households which would translate into a population increase of 10,346.

Table 4.14-1 Project Related Increase in Households and Population by TAZ Tier 2 TAZ Proposed HH Population
21561100 812 3,897
21575300 421 1,264
21578100 129 525
21592100 235 902
21592200 328 982
21594100 354 1,383
21594200 116 359
21601200 53 196
21601300 183 690
21633100 37 148
Total 2,668 10,646
1 CEQA Guidelines Section 15064.3, subdivision (b) refers to the discontinuation of vehicle LOS as an impact metric for transportation analysis and instead recommends the use of VMT; this section gives lead agencies discretion to choose the most appropriate methodology to evaluate a project’s VMT.

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MODEL RUNS AND OUTPUTS
Model Runs were conducted for the 2020 and 2040 conditions for both without project and with project conditions with the above discussed SED and networks. Consistent to standard modeling practice, each model was run with conditions that at least 5-loops2 be run or until a convergence of

0.01 (i.e., 1.0%) is achieved.

Significance Criteria
For General Plans and Specific Plans, the following would result in a significant project generated VMT:

The baseline project generated VMT per service population exceeds the baseline VMT per service population (VMT/SP) for the City, or
The cumulative project generated VMT per service population exceeds the future year VMT per service population (VMT/SP) for the City.

The VMT analysis methodology utilizes the procedures described in Appendix H. c. Project Impacts and Mitigation Measures
Threshold: Would the project conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities? Impact TRA-1 THE PROPOSED PROJECT WOULD NOT CONFLICT WITH A PROGRAM, PLAN, ORDINANCE,

OR POLICY ADDRESSING THE CIRCULATION SYSTEM, INCLUDING TRANSIT, ROADWAY, AND BICYCLE AND PEDESTRIAN FACILITIES. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Implementation of the proposed project would be subject to and required to implement the General Plan policies applicable to the circulation system including transit, roadway, bicycle, and pedestrian facilities. Additionally, development projects facilitated by the proposed project would be subject to all applicable City guidelines, standards, and specifications related to transit, roadway, bicycle, or pedestrian facilities.

Currently, there are no specific development projects or roadway modification projects associated with the proposed project; thus, specific projects cannot be evaluated for potential impacts to transit, roadway, bicycle, and/or pedestrian facilities at this time. Any modifications or new transit, roadway, bicycle, and pedestrian facilities would be subject to and designed in accordance with all applicable General Plan policies.

The proposed Housing Element Update is consistent with these General Plan policies by facilitating the development of new housing with relatively higher densities mostly along the City’s arterials and collectors, which provide better access to existing and proposed transit service as well pedestrian and bicycle facilities than the rest of the City.

The proposed project is also consistent with Housing Element Policy 3.3 (Reducing Vehicle Miles Traveled), which supports changes that reduce VMT, by reducing the average household VMT per 2 Models are run with feedback loops wherein the output of one run is becomes the basis of the next run. In this process, the predicted speeds are used to re-compute highway and transit travel times, and the entire model sequence is repeated until input and output speeds are generally consistent with each other. Each iteration is referred to as a loop. The percentage change in total travel cost between one iteration and the next is referred to as “convergence”. A convergence of 0.01 means that the change in travel cost between one run and the next is 1%. Models in the SCAG region are generally run for 5 loops or a convergence of 0.01.

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Draft Environmental Assessment 4.14-7
capita in the City of Huntington Park as described in Impact T-2 discussion below. This policy encourages the use of alternatives to current parking standards that lower the cost of housing and reduces VMT.

To note, the proposed project does not include any modifications to the public right-of-way, and therefore, would not preclude the installation of the planned or proposed pedestrian, bicycle, and safety improvements on the streets within the City of Huntington Park. Therefore, the proposed project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, and bicycle and pedestrian facilities.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
Impact TRA-2 THE PROPOSED PROJECT WOULD NOT CONFLICT WITH OR BE INCONSISTENT WITH CEQA GUIDELINES SECTION 15064.3. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

Baseline (2020) plus Project Conditions
Table 4.14-2 shows the model outputs for the baseline (2020) conditions as well as the plus project conditions.

Table 4.14-2 Proposed VMT in the Short Term
2020 No Project 2020 With Project Net New Project
Population 27,672 38,018 10,346
Employment 12,343 12,343 –
Service Population 40,015 50,361 10,346
Vehicle No Trucks
Total vehicle VMT (no trucks) 1,004,762 1,091,681 86,919 Average vehicle trip distance (no trucks) 8.62 8.52 7.53 Total vehicle trips (no trucks) 116,616 128,154 11,538
Trucks Only
Total truck VMT 95,042 97,285 2,243
Average truck trip distance 25.70 25.22 14.08
Total vehicle trips (include trucks) 120,315 132,012 11,697 Total truck trips 3,699 3,858 159
All Vehicles
Total VMT (include trucks) 1,099,804 1,188,965 89,161
Total VMT per service population (include trucks) 9.14 9.01 7.62 City of Huntington Park
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The 7.53 mile of average vehicle trip distance (no construction trucks) and 14.08 mile of average truck trip distance are not the trip lengths generated by the net new development directly, but the effect on vehicle trip and VMT for the whole project area. In particular, the effect of adding more housing to the study area will reduce trip length on average when compared to adding housing to areas outside of the study area. In order to compute the average vehicle distance, the net new VMT is divided by the net new vehicle trips, but this should not be interpreted to mean that the new development will have markedly different patterns than existing conditions; rather the effects on travel of adding housing will be to bring everyone’s average down (including existing uses) since the average vehicle trip distance will be shortened with development in the Study Area.

As shown in Table 4.14-2, the baseline (2020) plus project VMT/SP is 9.14 miles while the without project VMT/SP is 9.01 miles. The project related VMT/SP is 7.62, which is significantly less than the baseline VMT/SP for the City. Therefore, the project has a less than significant VMT impact under baseline conditions.

Year 2040 plus Project Conditions
Table 4.14-3 shows the model outputs for the year 2040 conditions as well as the plus project conditions.

Table 4.14-3 Proposed VMT in the Long Term
2040 No Project 2040 With Project Net New Project
Population 30,423 40,769 10,346
Socio-Economic Data
Employment 13,470 13,470 –
Service Population 43,893 54,239 10,346
Automobiles Only
Total Vehicle VMT (No Trucks) 945,871 1,036,465 90,594
Average Vehicle Trip Distance (No Trucks) 8.36 8.23 7.04 Total Vehicle Trips (No Trucks) 113,135 126,005 12,870
Trucks Only
Total Truck VMT 135,311 138,191 2,880
Average Truck Trip Distance 31.96 31.42 17.44
Total Truck Trips 4,234 4,399 165
Total Vehicle Trips (Include Trucks) 117,369 130,404 13,035 All Vehicles
Total VMT (Include Trucks) 1,081,182 1,174,656 93,474
Total VMT Per Service Population (Include Trucks) 9.21 9.01 7.17 Similar to the Proposed VMT in the Short Term discussion above, the 7.53 mile of average vehicle trip distance (no construction trucks) and 14.08 mile of average truck trip distance are not the trip lengths generated by the net new development directly, but the effect on vehicle trip and VMT for the whole project area. In particular, the effect of adding more housing to the study area will reduce trip length on average when compared to adding housing to areas outside of the study area. In order to compute the average vehicle distance, the net new VMT is divided by the net new vehicle trips, but this should not be interpreted to mean that the new development will have markedly Environmental Impact Analysis
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different patterns than existing conditions; rather the effects on travel of adding housing will be to bring everyone’s average down (including existing uses) since the average vehicle trip distance will be shortened with development in the Study Area.

As shown in Table 4.14-3, the year 2040 plus project VMT/SP is 9.21 miles while the without project VMT/SP is 9.01 miles. The project related VMT/SP is forecast to be 7.17, which is significantly less than the baseline VMT/SP for the City. Therefore, the project VMT per service population is less than the VMT/SP under without project conditions and therefore, the project has a less than significant VMT impact under future 2040 conditions.

The results of the VMT analysis shows that the project related VMT/SP is lower than the VMT/SP for the City. In fact, the proposed project reduces the Citywide VMT/SP under both analysis conditions.

Therefore, the proposed project has a less than significant impact under both the baseline and future year conditions.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible use (e.g., farm equipment)? Impact TRA-3 THE HOUSING ELEMENT UPDATE WOULD NOT INTRODUCE HAZARDOUS ROAD DESIGN FEATURES OR INCOMPATIBLE USES. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Development under the Housing Element Update would largely be infill development on parcels with existing uses (e.g., parking lots, underutilized uses) and would not involve the development of any roadways that would introduce hazardous features. Vacant housing opportunity sites are located in urbanized areas with access to existing roadways. While the specific designs of projects that could be developed is not known at this time, each project would be reviewed by the City and required to be consistent with appropriate regulations and design standards set forth by applicable plans, programs, and policies. Goals and policies in the General Plan encourage safe and convenient modes of transportation including walking and biking to increase connectivity among neighborhoods and adjacent cities. Finally, the Housing Element Update would promote development of residential and mixed-use projects that would be compatible with surrounding uses, including other residential and mixed-use developments. Projects developed under the Housing Element Update would not introduce incompatible agricultural, industrial, or other uses within the city.

During development, projects could include interim modifications to public rights-of-way, such as lane closures during construction or the addition of new driveways or pedestrian facilities. These features could affect transportation safety. With adherence to the City’s existing goals, policies, and ordinances, projects implemented under the Housing Element Update would be less than significant.

Mitigation Measures
No mitigation measures would be required.

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Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold: Would the project result in inadequate emergency access? Impact TRA-4 IMPLEMENTATION OF THE HOUSING ELEMENT UPDATE INVOLVES INFILL DEVELOPMENT IN AREAS CURRENTLY SERVED BY EMERGENCY ACCESS. ALTHOUGH DEVELOPMENT DENSITY WOULD INCREASE, ACCESS TO SITES WOULD NOT CHANGE. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The housing opportunity sites proposed in the Housing Element Update are all situated in areas currently served by adequate emergency access, including roadways with multiple ingress and egress. The Safety Element Update included an assessment of access to existing neighborhoods and developed goals and policies to ensure adequate emergency access for existing and future development. These include goals and policies that instruct the City to identify areas with inadequate access/evacuation routes and to consider mitigation to address emergency access.

Furthermore, additional goals and policies from the Safety Element Update are designed to ensure the City and the residents of Huntington Park are prepared for evacuation during natural and human-caused disasters. Specifically, policies in the Safety Element Update include designating and publicizing evacuation routes; regularly evaluating availability and demand of community evacuation centers; developing and employing alternative emergency access routes in neighborhoods with a single ingress/egress and developing evaluation alternatives for residents with mobility challenges.

Development facilitated by the Housing Element Update would be required to provide adequate accommodation of fire access to structure frontages and, depending on the size of the development, multiple access points to development on the housing opportunity sites, pursuant to 2022 California Building Code Requirements. Development that would not meet required standards and codes would not be permitted. Therefore, there would be adequate emergency service and access and the Housing Element Update would have a less than significant impact on emergency access.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.14.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). The geographic scope for cumulative transportation impacts is the City of Huntington Park.

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OPR provides the following guidance regarding cumulative impacts analysis and VMT:

When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in terms of efficiency (as recommended below for use on residential and office projects), cannot be summed because they employ a denominator. A project that falls below an efficiency-based threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would imply a less than significant cumulative impact, and vice versa (OPR 2018).

As described above in Section 4.6.3, Impact Analysis, the Housing Element and General Plan Update would not result in significant impact related to VMT (Impact TRA-2). The Housing Element Update’s incremental contribution to cumulative impacts would be less than significant.

Impact TRA-1 analyzes the project’s compatibility with programs, plans, ordinances, and policies related to the circulation system. Cumulative development projects, like the Housing Element Update, would be required to comply with local regulations and policies. The Housing Element Update’s incremental contribution to cumulative impacts would be less than significant.

As described in Impact TRA-3, any modifications to public rights-of-way would be consistent with appropriate regulations and design standards set forth by the City’s applicable plans, programs, and policies. Similarly, cumulative development projects would also be required to comply with the City’s regulations and policies, and the Housing Element Update’s incremental contribution to cumulative impacts would be less than significant.

Impact TRA-4 discusses potential impacts from inadequate emergency access. As stated therein, the project would be required to meet all applicable state and local codes and ordinances related to fire protection, including Safety Element Update policies that address emergency access. Similarly, cumulative development projects would also be required to comply with local and statewide regulations. Thus, impacts would be less than significant.

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4.15 Utilities and Service Systems
This section analyzes the effects of the proposed project on utilities and service systems. It considers potential impacts with respect to water supply and infrastructure, wastewater conveyance and treatment facilities, stormwater and drainage facilities, solid waste disposal, and electricity, natural gas, and telecommunications facilities.

4.15.1 Setting
a. Water Supply
Water service to the majority of Huntington Park is provided by the City of Huntington Park Water Department, a publicly owned utility under the Huntington Park Water and Sewer Division of the Public Works Department. Two small portions of the residential population are not served by the City of Huntington Park Water Department. Approximately 4 percent of the City’s population in the northeastern corner of the City is served by Maywood Mutual Water Company and approximately 1 percent of the City’s population in the southern area of the City is served by the Walnut Park Mutual Water Company (Huntington Park 2021). A small portion of industrial and commercial use along the western boundary of the City is served by Golden State Water Company. In 2020, the City’s Water Department provided water for 95% of the City’s population, therefore the analysis for this document will be focused on the Huntington Park Water Department (Huntington Park 2021).

The City of Huntington Park Water Department is supplied by approximately 5,100-acre-feet (AF) available each year. Approximately 75 percent of the supply comes from groundwater and the remaining 25 percent comes from imported water (Huntington Park 2021). The City obtains its groundwater supply from the Central Groundwater Subbasin (“Central Basin”), in which the City has annual extraction rights of 3,853 AF and extracted 3,360 AF on average annually between the years of 2011-2015 (Huntington Park 2021). The City extracts groundwater through four active wells and two inactive wells, one of which is temporarily inactive during improvements due to be completed in 2023. The City’s imported water supply is received from the Metropolitan Water District (MWD) and originates from the Colorado River and the Sacramento-San Joaquin River Delta in Northern California. The City’s import connection capacity is 7,200 AFY while the average purchase between 2016 and 2020 was 892 AF (Huntington Park 2021). The City has a goal of reducing its dependence on imported water, in which more groundwater use would be necessary.

The City Water Department is responsible for implementing an Urban Water Management Plan (UWMP). The current 2020 UWMP includes an assessment of past and future water supplies and demands, evaluation of the future reliability of the region’s water supplies over a 20-year planning horizon, and discussion of demand management measures (Huntington Park 2021). The UWMP determined that the City has supply capabilities sufficient to meet expected demands through 2045 under a single dry-year condition and a period of drought lasting five consecutive years. Water supply and quality are also addressed in Section 4.9, Hydrology and Water Quality. b. Wastewater
Wastewater treatment for development facilitated by the project would be provided by existing infrastructure in Huntington Park. The City’s sewage is transported through approximately 60 miles of sewer mains throughout the City (Huntington Park 2020). Wastewater generated within the City of Huntington Park
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Huntington Park city limits is collected and transmitted through the City sewer system to the Los Angeles County Sanitation Districts (LACSD).

Wastewater generated in Huntington Park is ultimately treated at the Joint Water Pollution Control Plant (JWPCP) in Carson, California. The JWPCP provides water treatment for approximately 280 million gallons per day (mgd) and has a permitted capacity of 400 mgd, providing a remaining capacity of 120 mgd for future development in the region (LACSD 2022). Treated wastewater is discharged to the Pacific Ocean through two outfalls and no treated wastewater is used as recycled water.
c. Stormwater
The main form of stormwater management in the City and surrounding area is through the Los Angeles River Channel. The Los Angeles River is a 500 feet wide concrete lined channel located north and east of the City, approximately two miles east of City borders at its closest point. The river is maintained by the Los Angeles County Department of Public Works, Flood Control District. The storm drains throughout the City which extend along major roadways and flow directly into the Los Angeles River are also owned and maintained by the Los Angeles County Flood Control District.

In 2021, the LARWQCB adopted the Final Waste Discharge Requirements for MS4 Discharges within the Coastal Watersheds of Los Angeles County, which regulates discharges of stormwater and urban runoff from storm drain systems. Furthermore, the County Flood Control District has an established Storm Water Quality Management Program that educates existing and future efforts relating to stormwater management across the City.
d. Solid Waste
Solid waste generated in Huntington Park is sent to waste disposal sites (i.e., landfills) operated by the County of Los Angeles as well as by private companies. In addition, transfer stations temporarily store debris until larger haul trucks are available to transport the materials directly to the landfills.

Table 4.15-1 lists the city in which each landfill is located, remaining capacity, daily intake, and Annual Tonnage (County of Los Angeles 2020). The Commerce Refuse to Energy Facility and the Southeast Resource Recovery Facility extend the landfill capacity by combusting solid waste and selling energy generated by combustion to local utility companies. While neither facility currently encounters maximum capacity issues, both are restricted in regard to the daily amount and type of solid waste that they can accept and process. Another alternate solid waste disposal method includes recycling businesses, with the most notable location being the Azusa Reclamation facility.

The City is primarily served by the Sunshine Canyon Landfill, which accepts residential, commercial, and construction waste. As shown in Table 4.15-1, the combined daily intake average is 18,620 tons per day.

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Table 4.15-1 Solid Waste Facilities Serving the City of Huntington Park Facility Name
Landfill Site
Location
Remaining Capacity
(Mil. tons)[1]
2019 Average
Disposal (tons/day)
Annual
Tonnage
Antelope Valley Palmdale 11.0 2,046 638,400
Calabasas Agoura 4.3 842 262,800
Chiquita Canyon Castaic 57.0 5,115 1,596,000
Lancaster Lancaster 9.9 350 109,100
Sunshine Canyon Los Angeles 55.2 6,919 2,158,700
Scholl Canyon Glendale 3.8 1,075 335,500
Commerce Refuse to Energy
Facility/b/
Commerce - - -
Southeast Resource Recovery
Facility/b/
Long Beach - 1,235 444,600
Azusa Land Reclamation Azusa 59 1,038 373,680
Totals 200.2 18,620 5,918,780
*Source: County of Los Angeles 2020.
e. Telecommunications, Electricity and Natural Gas
Telecommunications services in Huntington Park are provided by private companies, including AT&T, Spectrum, Viasat, and other providers which provide internet, phone, and television.

Electricity is provided to the City by the Southern California Edison Company (SCE) through overhead and underground powerlines. Huntington Park’s natural gas service is provided by the Southern California Gas Company (SoCalGas) which services more than 21 million residents throughout Central and Southern California. Natural gas and electricity are also addressed in Section

4.5, Energy.

4.15.2 Regulatory Setting
a. Water Supply
Federal Regulations
Clean Water Act
The federal Clean Water Act, enacted by Congress in 1972 and amended several times since, is the primary federal law that regulates water quality in the United States. It forms the basis for several State and local laws throughout the country. The Clean Water Act established the basic structure for regulating discharges of pollutants into the waters of the United States. The Clean Water Act gave the U.S. Environmental Protection Agency the authority to implement federal pollution control programs, such as setting water quality standards for contaminants in surface water, establishing wastewater and effluent discharge limits for various industry contaminants in surface water, establishing wastewater and effluent discharge limits for various industry categories, and imposing requirements for controlling nonpoint-source pollution. At the federal level, the Clean Water Act is administered by the U.S. Environmental Protection Agency and USACE. At the state and regional levels in California, the act is administered and enforced by SWRCB and the nine RWQCBs.

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State Regulations
Senate Bill 610
In 2001, California adopted SB 610, thereby amending California Water Code. Under this law, certain types of development projects are now required to provide detailed water supply assessments to planning agencies. Any project that is subject to CEQA and would demand more than 75 AFY of water, or an amount of water equivalent to, or greater than, the amount of water required by a 500-dwelling-unit project, is subject to SB 610 and is required to prepare a Water Supply Assessment (WSA). The primary purpose of a WSA is to determine whether the identified water supply or water supplier will be able to meet projected demands for the project, in addition to existing and planned future uses, over a 20-year projection and with consideration to normal, dry, and multi-dry water years.

A General Plan Update (including Housing and Element Updates) is not subject to preparation of a Water Supply Assessment because (1) it is not expressly listed as a project which is subject to a Water Supply Assessment under Water Code Section 10912; (2) General Plan law sets forth an alternative process for local governments to consult with water supply agencies during General Plan preparation (see Government Code Section 65352.5); and (3) the California Legislature envisioned the General Plan being considered during preparation of long-term Urban Water Management Plan preparation, to serve as the first tier of land use and water supply planning coordination, prior to consideration of individual development projects. Furthermore, the County of San Bernardino Superior Court rules in Citizens for Responsible Equitable Environmental Development v. City of Chino (2011) that a “General Plan is not the type of actual development project identified in Water Code 10912 triggering the WSA requirement.” Therefore, the proposed project does not require preparation of a WSA pursuant to SB 610. Nevertheless, water supply availability is assessed under Impact UTIL-2.

Senate Bill 221
Whereas SB 610 requires a written assessment of water supply availability, SB 221 requires lead agencies to obtain an affirmative written verification of sufficient water supply prior to approval of certain specified subdivision projects. For this purpose, water suppliers may rely on an UWMP if the updates to the General Plan (including a Housing and Safety Element Update) is accounted for within the UWMP, a WSA or other acceptable information that constitutes “substantial evidence.” “Sufficient water supply” is defined in SB 221 as the total water supplies available during normal, single-dry and multiple-dry water years within the 20-year (or greater) projection period that are available to meet the projected demand associated with the General Plan Update, in addition to existing and planned future uses. WSAs are required for residential projects of more than 500 units or a proposed shopping center or business establishment employing more than 1,000 persons or having more than 500,000 square feet of floor space. Because the proposed project is a plan and not a subdivision project, it does not require affirmative written verification of sufficient water supply. Nevertheless, water supply availability is assessed under Impact UTIL-2.

California Safe Drinking Water Act
The California Safe Drinking Water Act (SDWA) (Health & Safety Code Section 116270 et seq.; 22 Cal.

Code Regs. Section 64400 et seq.) regulates drinking water more rigorously than the federal law.

Like the Federal SDWA, California requires that primary and secondary maximum contaminant levels be established for pollutants in drinking water; however, some California maximum Environmental Impact Analysis
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contaminant levels are more protective of health. The Act also requires the SWRCB to issue domestic water supply permits to public water systems.

Implementation of the federal SDWA is delegated to the State of California. The SWRCB enforces the federal and state SDWAs and regulates more than 7,500 public water systems across the state.

The SWRCB’s Division of Drinking Water oversees the State’s comprehensive Drinking Water Program. The Drinking Water Program is the agency authorized to issue public water systems permits.

Sustainable Groundwater Management Act
In September 2014, the governor signed legislation requiring that California’s critical groundwater resources be sustainably managed by local agencies. The Sustainable Groundwater Management Act gives local agencies the power to sustainably manage groundwater and requires groundwater sustainability plans to be developed for medium- and high-priority groundwater basins, as defined by the DWR. The Central Groundwater Basin in which Huntington Park lies upon and uses for groundwater supply is a low priority basin and not subject to a groundwater sustainability plan.

Urban Water Management Planning Act
In 1983, the California Legislature enacted the Urban Water Management Planning Act (Water Code, Section 10610 et seq.), which requires urban water suppliers to develop water management plans to actively pursue the efficient use of available supplies. Every five years, water suppliers are required to develop UWMPs to identify short-term and long-term water demand management measures to meet growing water demands. The City’s most recent UWMP was adopted in 2020 and used to inform this analysis.

Senate Bill 7x7 Statewide Water Conservation
In November 2009 the California State Legislature passed and the Governor approved a comprehensive package of water legislation, including SB 7x7 addressing water conservation. In general SB 7x7 requires a 20 percent reduction in per capita urban water use by 2020, with an interim 10 percent target in 2015. The legislation requires urban water users to develop consistent water use targets and to use those targets in their UWMPs.

Porter-Cologne Water Quality Control Act (California Water Code) The State of California is authorized to administer Federal or State laws regulating water pollution within the State. The Porter-Cologne Water Quality Control Act (Water Code Section 13000, et seq.) includes provisions to address requirements of the Clean Water Act. These provisions include National Pollutant Discharge Elimination System (NPDES) permitting, dredge and fill programs, and civil and administrative penalties. The Porter-Cologne Act is broad in scope and addresses issues relating to the conservation, control, and utilization of the water resources of the State.

Additionally, the Porter-Cologne Act states that the quality of all the waters of the State, including groundwater and surface water, must be protected for the use and enjoyment by the people of the State.

In California, the NPDES program is administered by the SWRCB through the Regional Water Quality Control Boards (RWQCB) and requires municipalities to obtain permits that outline programs and activities to control wastewater and stormwater pollution. The federal Clean Water Act prohibits discharges of stormwater from construction projects unless the discharge follows an NPDES permit.

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The SWRCB is the permitting authority in California and adopted an NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, otherwise known as the Construction General Permit (Order 2009-0009, as amended by Orders 2010-0014- DWQ and 2012-006-DWQ). The Order applies to construction sites that include one or more acre of soil disturbance. Construction activities include clearing, grading, grubbing, excavation, stockpiling, and reconstruction of existing facilities involving removal or replacement. The Construction General Permit requires that the landowner and/or contractor file permit registration documents prior to commencing construction and then pay a fee annually through the duration of construction. These documents include a notice of intent, risk assessment, site map, stormwater pollution prevention plan (SWPPP), and signed certification statement. The SWPPP must include measures to ensure that: all pollutants and their sources are controlled; non-stormwater discharges are identified and eliminated, controlled, or treated; site Best Management Practices (BMPs) are effective and result in the reduction or elimination of pollutants in stormwater discharges and authorized non-stormwater discharges; and BMPs installed to reduce or eliminate pollutants after construction are completed and maintained. The Construction General Permit specifies minimum BMP requirements for stormwater control based on the risk level of the site. The Permit also specifies minimum qualifications for a qualified SWPPP developer and qualified SWPPP practitioner.

Local Regulations
Greater Los Angeles County Region IRWMP
The Greater Los Angeles County (GLAC) Integrated Regional Water Management Plan (IRWMP) is a regional plan designed to improve collaboration in water resources management. To make governance and stakeholder involvement manageable, the GLAC Region was organized into five Subregions which consider both geographic and demographic variations over the 2,058 square mile area. These Subregions include Lower San Gabriel and Los Angeles Rivers; North Santa Monica Bay; South Bay; Upper Los Angeles River Area (ULARA); Upper San Gabriel and Rio Hondo Rivers. Of these regions, BWP is a member of the ULARA. The first IRWMP for the GLAC Region was published in 2006, following a multi-year collaborative effort between water retailers, wastewater agencies, stormwater and flood managers, watershed groups, businesses, tribes, the agriculture community, and non-profits. The IRWMP provides a mechanism for: 1) coordinating, refining, and integrating existing planning efforts within a comprehensive, regional context; 2) identifying specific regional and watershed-based priorities for implementation projects; and 3) providing funding support for the plans, programs, projects, and priorities of existing agencies and stakeholders.

City of Huntington Park UWMP
The City Water Department is responsible for implementing an UWMP. The current 2020 UWMP includes an assessment of past and future water supplies and demands, evaluation of the future reliability of the region’s water supplies over a 20-year planning horizon, and discussion of demand management measures (Huntington Park 2021).

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b. Stormwater
Federal Regulations
Clean Water Act Section 402
Section 402 of the Clean Water Act requires that all construction sites on an acre or greater of land, as well as municipal, industrial and commercial facilities discharging wastewater or stormwater directly from a point source (e.g., pipe, ditch, or channel) into a surface water of the United States must obtain permission under the National Pollutant Discharge Elimination System (NPDES) permit.

All NPDES permits are written to ensure that the surface water receiving discharges will achieve specified water quality standards.

According to federal regulations, NPDES permit coverage for stormwater discharges associated with construction activity can be obtained through individual State permits or general permits. Individual permitting involves the submittal of specific data on a single construction project to the appropriate permitting agency that will issue a site-specific NPDES permit to a project. NPDES coverage under a general permit involves the submittal of a Notice of Intent by the regulated construction project that they intend to comply with a general permit to be developed by USEPA or a state with delegated permitting authority.

Cobey-Alquist Floodplain Management Act
The Cobey-Alquist Floodplain Management Act (Water Code Section 8400-8435) gives support to the National Flood Insurance Program by encouraging local governments to plan, adopt, and enforce land use regulations for floodplain management, to protect people and property from flooding hazards. The Act also identifies requirements that jurisdictions must meet to receive State financial assistance for flood control.

State Regulations
California Construction Stormwater Permit
The California Construction Stormwater Permit (Construction General Permit), adopted by the SWRCB, regulates construction activities that include soil disturbance of at least one acre of total land area. The Construction General Permit authorizes the discharge of stormwater to surface waters from construction activities. It prohibits the discharge of materials other than stormwater, authorized non-stormwater discharges, and all discharges that contain a hazardous substance in excess of reportable quantities established at 40 CFR 117.3 or 40 CFR 302.4, unless a separate NPDES Permit has been issued to regulate those discharges.

The Construction General Permit requires that all developers of land where construction activities will occur over more than one acre do the following:
 Complete a Risk Assessment to determine pollution prevention requirements pursuant to the three Risk Levels established in the General Permit
 Eliminate or reduce non-stormwater discharges to storm sewer systems and other waters  Develop and implement a Stormwater Pollution Protection Plan which specifies BMPs that will reduce pollution in stormwater discharges to the Best Available Technology Economically Achievable/Best Conventional Pollutant Control Technology standards  Perform inspections and maintenance of all BMPs
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Typical BMPs contained in Stormwater Pollution Protection Plans are designed to minimize erosion during construction, stabilize construction areas, control sediment and pollutants from construction materials, and address post construction runoff. The Stormwater Pollution Protection Plan also includes a plan for inspection and maintenance of all BMPs, as well as procedures for altering or increasing BMPs based on changing project conditions.

California Green Building Standards Code
The California Green Building Standards Code (24 CCR, Part 11) includes mandatory measures for residential and nonresidential development. For example, Section 4.106.2 requires residential projects that disturb less than one acre and are not part of a larger common plan of development to manage stormwater drainage during construction through on-site retention basins, filtration systems, and/or compliance with a stormwater management ordinance. Section 5.106.1 requires newly constructed nonresidential projects and additions of less than one acre to prevent the pollution of stormwater runoff from construction through compliance with a local ordinance or implementing BMPs that address soil loss and good housekeeping to manage equipment, materials, and wastes. Section 5.303 sets measures for indoor water use for non-residential development requiring metering devices to conserve water.

Local Regulations
County of Los Angeles MS4 Permit
Los Angeles County MS4 Permit is the vehicle through which the Los Angeles RWQCB regulates discharges from medium and large MS4s. The permits are issued under the NPDES program. NPDES permitting is a national program overseen by the USEPA to address water pollution by regulating point sources that discharge pollutants to waters of the United States. It is part of the 1972 Clean Water Act and authorizes state governments to perform the permitting, administrative, and enforcement of the program through the RWQCBs. The permits require that new development and redevelopment projects to incorporate low-impact development (LID) techniques that include permeable surfaces, bioswales, and other design components that help water to percolate into the ground rather than run off into the stormwater system (gutters). c. Wastewater
Federal Regulations
Clean Water Act Section 401
Under Section 401 of the Clean Water Act, the Regional Water Quality Control Boards (RWQCBs) have regulatory authority over actions in waters of the United States and/or the State of California through the issuance of water quality certifications, which are issued in conjunction with any federal permit (e.g., permits issued by the USACE under Section 404 of the Clean Water Act, described above). Section 401 of the Clean Water Act provides the SWRCB and the RWQCBs with the regulatory authority to waive, certify, or deny any proposed activity that could result in a discharge to surface waters of the State. To waive or certify an activity, these agencies must find that the proposed discharge would comply with State water quality standards, including those protecting beneficial uses and water quality. If these agencies deny the proposed activity, the federal permit cannot be issued. This water quality certification is generally required for projects requiring Environmental Impact Analysis
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Section 404 authorization involving the discharge of dredged or fill material to wetlands or other waters of the United States.

Clean Water Act Section 402
Section 402 of the Clean Water Act requires that all construction sites on an acre or greater of land, as well as municipal, industrial and commercial facilities discharging wastewater or stormwater (as noted above in the stormwater section) directly from a point source, such as a pipe, ditch, or channel, into a surface water of the United States must obtain permission under the NPDES permit.

All NPDES permits are written to ensure that the surface water receiving discharges will achieve specified water quality standards.

State and Regional Regulations
Title 22 of California Code of Regulations
Title 22 regulates the use of reclaimed wastewater. In most cases only disinfected tertiary water may be used on food crops where the recycled water comes into contact with the edible portion of the crop. Disinfected secondary treatment may be used for food crops where the edible portion is produced below ground and will not come into contact with the secondary effluent. Lesser levels of treatment are required for other types of crops, such as orchards, vineyards, and fiber crops.

The California Department of Public Health sets specific requirements for treated effluent reuse, or recycled water, through Title 22 of the California Code of Regulations. These requirements are primarily set to protect public health. The California Code of Regulations Title 22, Division 4, Chapter 3, Sections 60301 through 60355 are used to regulate recycled wastewater and are administered jointly by the California Department of Public Health and the RWQCBs. Title 22 contains effluent requirements for four levels of wastewater treatment, from un-disinfected secondary recycled water to disinfected tertiary recycled water. Higher levels of treatment have higher effluent standards, allowing for a greater number of uses under Title 22, including irrigation of freeway landscaping, pasture for milk animals, parks and playgrounds, and vineyards and orchards for disinfected tertiary recycled water.

California Plumbing Code
The California Plumbing Code is codified in Title 24, California Code of Regulations, Part 5. The Plumbing Code contains regulations including, but not limited to, plumbing materials, fixtures, water heaters, water supply and distribution, ventilation, and drainage. More specifically, Part 5, Chapter 4, contains provisions requiring the installation of low flow fixtures and toilets. Existing development will also be required to reduce its wastewater generation by retrofitting existing structures with water efficient fixtures (SB 407 [2009] Civil Code Sections 1101.1 et seq.). d. Solid Waste
Federal Regulations
Title 40 of the Code of Federal Regulations
Title 40 of the Code of Federal Regulations (CFR), Part 258 (Resource Conservation and Recovery Act RCRA, Subtitle D) contains regulations for municipal solid waste landfills and requires states to implement their own permitting programs incorporating the federal landfill criteria. The federal City of Huntington Park
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regulations address the location, operation, design, groundwater monitoring, and closure of landfills.

State Regulations
California Department of Resources Recycling and Recovery California Department of Resources Recycling and Recovery (CalRecycle) oversees, manages, and monitors waste generated in California. CalRecycle provides limited grants and loans to help California cities, counties, businesses, and organizations meet the State waste reduction, reuse, and recycling goals. It also provides funds to clean up solid waste disposal sites and co-disposal sites, including facilities that accept hazardous waste substances and non-hazardous waste. CalRecycle develops, manages, and enforces waste disposal and recycling regulations, including AB 939 and SB 1016, both of which are described below.

Assembly Bill 939
AB 939 (Public Resources Code 41780) requires cities and counties to prepare integrated waste management plans and to divert 50 percent of solid waste from landfills beginning in calendar year 2000 and each year thereafter. AB 939 also requires cities and counties to prepare Source Reduction and Recycling Elements as part of the integrated waste management plans. These elements are designed to develop recycling services to achieve diversion goals, stimulate local recycling in manufacturing and stimulate the purchase of recycled products.

Assembly Bill 341 – Mandatory Commercial Recycling
The purpose of AB 341 is to reduce GHG emissions by diverting commercial solid waste to recycling efforts and to expand the opportunity for additional recycling services and recycling manufacturing facilities in California. AB 341 required all businesses that generate four or more cubic yards of garbage per week and multi-family dwellings with five or more units to recycle by July 1, 2012.

AB341 also sets a statewide goal of 75 percent waste diversion.

Senate Bill 1016
SB 1016 requires that the 50 percent solid waste diversion requirement established by AB 939 be expressed in pounds per person per day. SB 1016 changed the CalRecycle review process for each municipality’s integrated waste management plan. CalRecycle reviews a jurisdiction’s source reduction and recycling element and hazardous waste element once every two years.

Assembly Bill 1826
In October 2014 Governor Brown signed AB 1826, requiring businesses to recycle their organic waste on and after April 1, 2016, depending on the amount of waste they generate per week. This law also requires that on and after January 1, 2016, local jurisdictions across the state implement an organic waste recycling program to divert organic waste generated by businesses, including multifamily residential dwellings that consist of five or more units (although multifamily dwellings are not required to have a food waste diversion program). Organic waste means food waste, green waste, landscape and pruning waste, nonhazardous wood waste, and food-soiled paper waste that is mixed in with food waste. This law phases in the mandatory recycling of commercial organics over time, while also offering an exemption process for rural counties. In particular, the minimum Environmental Impact Analysis
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threshold of organic waste generation by businesses decreases over time, which means an increasingly greater proportion of the commercial sector will be required to comply.

California’s Short-Lived Climate Pollutant Reduction Strategy (SB 1383) Signed into law in September 2016, SB 1383 establishes methane emissions reduction targets for California in a statewide effort to reduce emissions of short-lived climate pollutants. The targets are to reduce organic waste disposal 50 percent by 2020 and 75 percent by 2025. The law also grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than 20 percent of currently disposed edible food is recovered for human consumption by 2025. Enforcement of these targets starts January 1, 2022. e. Telecommunications
The California Public Utilities Commission (CPUC) develops and implements policies for the telecommunication industry. The Communications Division is responsible for licensing, registration and the processing tariffs of local exchange carriers, competitive local carriers, and non-dominant interexchange carriers. It is also responsible for registration of wireless service providers and franchising of video service providers. The Division tracks compliance with commission decisions and monitors consumer protection and service issues and Commission reliability standards for safe and adequate service. The Communications Division is responsible for oversight and implementation of the six public purpose Universal Service Programs (CPUC 2021b).

4.15.3 Impact Analysis
a. Methodology and Significance Thresholds
The following thresholds are based on CEQA Guidelines Appendix G. For purposes of this EA, impacts related to water supplies, wastewater, solid waste, storm water conveyance, electric power, natural gas or telecommunications facilities are considered significant if implementation of the proposed project would:

Require or result in the relocation or construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects; Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry, and multiple dry years; Result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the projects’ projected demand in addition to the provider’s existing commitments;
Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals; or Comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

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b. Project Impacts and Mitigation Measures
Threshold 1: Would the project require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water drainage, electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects?
Impact UTIL-1 DEVELOPMENT FACILITATED THE PROPOSED PROJECT MAY REQUIRE THE RELOCATION OR

CONSTRUCTION OF NEW OR EXPANDED WATER, WASTEWATER TREATMENT, STORMWATER DRAINAGE, ELECTRIC POWER, NATURAL GAS, AND TELECOMMUNICATIONS FACILITIES IN HUNTINGTON PARK. WHILE NEW

CONNECTIONS TO EXISTING UTILITY SERVICE SYSTEMS WOULD BE REQUIRED, SUCH CONNECTIONS WOULD NOT

RESULT IN DISTURBANCE BEYOND INDIVIDUAL DEVELOPMENT SITES AND ADJACENT INFRASTRUCTURE CORRIDORS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Water
Construction activities associated with reasonably foreseeable development under the proposed project would require recycled water for dust suppression, concrete manufacturing, and such activities as washing wheels and equipment. Temporary construction recycled water would be trucked to active construction sites or produced from existing fire hydrants near the applicable site(s), with City approval. Temporary construction water demands would not require new connections or conveyance facilities, as existing or mobile facilities would be used.

Reasonably foreseeable development facilitated by the proposed project may require installation of additional water main lines, lateral connections, and hydrants within the City. Such upgrades would occur within existing utility easements and would be located underground, primarily within existing roadways. Housing development under the proposed project would be located in previously developed areas that are either currently zoned for residential development or would be rezoned for residential development under the proposed project. Furthermore, reasonably foreseeable development would be subject to the City’s 1991 General Plan policies related to the provision of adequate water services and facilities, such as Open Space and Conservation Element Policies 2.1 and 2.2 and Public Facilities Element Policies 6.1 through 6.3, described above under local regulatory setting.

Developers are responsible for funding any infrastructure improvements that are required to mitigate project impacts and have not been previously identified as part of a capital improvement program covered by development impact fees. Consistent with applicable State law, the City’s development fees will ensure that the developers pay the cost attributable to the increased demand for the affected public facilities reasonably related to the development project in order to refurbish the existing facilities to maintain the existing level of service and achieve an adopted level of service that is consistent with the City’s General Plan (California Government Code Section 66001(g)).

As individual housing projects are proposed and considered for approval by the City, project proponents would be required to demonstrate that any identified system deficiencies reasonably related to the development project are adequately addressed by the responsible project proponent and future upgrades are designed in accordance with the HPMC and to the satisfaction of the City Engineer. In addition, the City requires applicants to coordinate with the Los Angeles County Fire Department and City of Huntington Park Building and Safety Division to ensure that existing and planned fire hydrants provide sufficient fire flow pressure requirements. The City’s issuance of building permits is contingent upon review, testing, and approval that sufficient fire flow pressure is Environmental Impact Analysis
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provided for the applicable site. Due to the existing built-up nature of the City, it is reasonably anticipated that future improvements for water supply and fire flow requirements would not disturb previously undisturbed areas and would be situated within existing utility rights-of-way, such as but not limited to within public roadways.

Water service to the majority of Huntington Park is provided by the City of Huntington Park Water Department, the remaining small portions of the City are served by Maywood Mutual Water Company, Walnut Park Mutual Water Company, and Golden State Water Company. The City of Huntington Park Water Department receives imported water from the State Water Project and groundwater from the Central Groundwater Basin. The availability and reliability of water supply for the proposed project is addressed below, under Impact UTIL-2. Potential impacts related to relocation or construction of water supply facilities would be less than significant.

Wastewater
Wastewater treatment for development facilitated by the proposed project would be provided by existing infrastructure in Huntington Park. The City’s sewage is transported through approximately 60 miles of sewer mains throughout the City (Huntington Park 2020). Wastewater generated within the Huntington Park city limits is collected and transmitted through the City sewer system to the LACSD.

Wastewater generated in Huntington Park is ultimately treated at the Joint Water Pollution Control Plant (JWPCP) in Carson, California. The JWPCP provides water treatment for approximately 280 million gallons per day (mgd) and has a permitted capacity of 400 mgd, providing a remaining capacity of 120 mgd for future development in the region (LACSD 2022). Treated wastewater is discharged to the Pacific Ocean through two outfalls and no treated wastewater is used as recycled water. As detailed below in Impacts UTIL-2 and UTIL-3, the City’s projected wastewater flow in 2045 is only slightly higher than 2020 estimated flows because as the City’s population grows, the water use efficiency is projected to increase as well.

Development facilitated by the proposed project may require the installation of upsized sewer lines and additional lateral connections within Huntington Park. As with water facilities, sewer laterals and main extensions necessary to serve the future development would generally be installed within the already disturbed rights-of-way of existing roads or within the disturbance footprints of such projects. As such, the construction of these infrastructure improvements would not substantially increase a project’s disturbance area or otherwise cause significant environmental effects beyond those identified throughout this EA.

Furthermore, applicants for projects facilitated by the proposed project would be responsible for constructing on-site wastewater treatment conveyance systems and paying standard sewer connection fees, as necessary. The City’s Community Development Department screens project proposals for the potential to create wastewater in excess of capacity of the sanitary sewer system and enforces building and construction standards. Therefore, the proposed project would not require or result in the relocation or construction of new or expanded wastewater treatment facilities and impacts would be less than significant.

Stormwater
Reasonably foreseeable residential development under the proposed project would not result in a substantial increase in impervious surfaces since it would be focused in urban infill areas already largely covered with impervious surfaces. Compliance with Health and Safety Element Policies 2.1 City of Huntington Park
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through 2.4 and Public Facilities Policies 6.1 through 6.3 of the Huntington Park 1991 General Plan would ensure that future development projects resulting from the proposed project would be implemented with appropriately sized and sited stormwater conveyance facilities. In the long-term, redevelopment of properties in the City is anticipated to improve the quality of stormwater runoff by replacing older development with new development that incorporates Low Impact Development (LID) methods, as required in Chapter 7-9 of the HPMC. LID methods include features such as stormwater detention basins and vegetation requirements that slow the velocity of surface runoff and filter some water quality constituents before the runoff percolates to the underlying groundwater system or is conveyed through the City’s, or Los Angeles County Flood Control District’s, stormwater infrastructure. Therefore, while individual housing developments would include site-specific stormwater drainage and conveyance facilities, such facilities would be designed and built-in accordance with the HPMC and BMPs for stormwater management. Potential impacts related to relocation or construction of new wastewater conveyance facilities would be less than significant.

Electricity and Natural Gas
Electricity is provided to the City by the Southern California Edison Company through overhead and underground powerlines. Huntington Park’s natural gas service is provided by the Southern California Gas Company which services more than 21 million residents throughout Central and Southern California. Natural gas and electricity are also addressed in Section 4.5, Energy.

The project would require connections to existing electrical transmission and distribution systems on site to serve development facilitated by the project. This service would be provided in accordance with the rules and regulations of SCE on file with and approved by CPUC. Based on the availability of existing electrical infrastructure, it is not anticipated that the construction of new electrical transmission and distribution lines or other facilities would be required, and all sites would be able to connect to existing infrastructure. Therefore, there would be adequate electrical facilities to serve development as a result of the project and impacts related to electricity would be less than significant.

Development facilitated by the project would connect to existing natural gas infrastructure to meet the needs of housing units. Therefore, no new natural gas lines are anticipated for most future construction. Based on the availability of existing natural gas infrastructure, construction of new natural gas pipelines would not be required, and all sites would be able to connect to existing infrastructure. Therefore, there would be adequate natural gas facilities to serve the development as a result of the project and impacts related to natural gas would be less than significant.

Telecommunications
The City is highly urbanized with existing above- and below-ground telecommunications infrastructure. Telecommunications services are provided by AT&T, Spectrum, Viasat, or other providers, at the discretion of current and future residents. Reasonably foreseeable development under the proposed Project would increase demand for existing telecommunications in the City.

Individual telecommunication providers implement planned improvements throughout their service areas on an as-needed basis, which are typically limited to small-scale upgrades and new facilities in existing developed areas. Construction of additional telecommunications facilities or upgrades to existing facilities to meet demands from the proposed Project would be undertaken by private telecommunication service providers in accordance with applicable federal, state, and local regulations. Telecommunications are generally available in the City and substantial upgrades to Environmental Impact Analysis
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existing telecommunications facilities would not likely be necessary. Necessary facility upgrades to accommodate new service connections would be undertaken by individual telecommunication providers. No restrictions on the ability to provide adequate telecommunication service are present or anticipated to occur as a result of the proposed Project. In addition, due to the built-up nature of the City and the nature of telecommunication upgrades being small-scale and sited within the development footprint of new projects, potential impacts associated with new or expanded facilities would be less than significant.

Mitigation Measures
Impacts would be less than significant without mitigation.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 2: Would the project have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years?
Impact UTIL-2 POPULATION INCREASE ANTICIPATED BY IMPLEMENTATION OF THE PROPOSED PROJECT COULD PLACE INCREASED DEMAND ON WATER SUPPLY IN NORMAL AND DROUGHT YEARS. WHILE

PROJECTIONS CONSIDERED IN THE UWMP ARE LESS THAN THOSE AFFORDED BY IMPLEMENTATION OF THE

PROPOSED PROJECT, SUFFICIENT WATER SUPPLY EXISTS TO SERVE THE POPULATION DUE TO CONSERVATION EFFORTS AND DURING MULTIPLE DRY YEARS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

As discussed in 4.15.1, Setting, the majority of water supply in Huntington Park is provided by the City of Huntington Park Water Department, which consists of imported water from MWD and groundwater pumped from the Central Basin.

Table 4.15-2 Normal Year Supply and Demand Projections
2025 2030 2035 2040 2045
Demand Totals 4,390 4,344 4,296 4,245 4,193
Supply Totals 5,100 5,100 5,100 5,100 5,100
Surplus 710 756 804 855 907
*Units are presented in acre feet (af) per calendar year.

Source: Huntington Park 2021
Reasonably foreseeable development facilitated under the proposed project would involve up to 2,668 new residential units, increasing the City population by 10,646 persons. While The City’s 2020 UWMP reports that 2020 water demand was 69 gallons per capita per day (gpcd), the demand is projected to decrease to 68.5 gpcd in 2025, then decrease by 2045 to 62.5 gpcd. Assuming a per capita water demand of 62.5 gpcd in 2045, as discussed above, the additional population of 10,646 persons would increase water demand by 665,375 gallons per day, which equates to approximately 745 AFY. This represents approximately 14.6 percent of the City’s projected available water supply in 2045 under normal water year (non-drought) conditions, as shown in Table 4.15-2. The increased citywide water demand of up to 745 AFY can be accommodated for in the surplus of 907 AFY under a normal (non-drought year). Therefore, the proposed project would have a less than significant impact on water supply during a normal (non-drought) year.

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Table 4.15-3 Single Dry Year Supply and Demand
2025 2030 2035 2040 2045
Demand Totals 4,609 4,561 4,510 4,458 4,402
Supply Totals 5,100 5,100 5,100 5,100 5,100
Surplus 491 539 590 642 698
*Units are presented in acre feet (af) per calendar year.

Source: Huntington Park 2021
As discussed above, the proposed project would facilitate an increased citywide water demand of up to 745 AFY. The increased demand would not be accommodated for in the surplus of 698 AFY under a single dry year, as shown in Table 4.15-3. It should be noted that not all projects would be developed in one year, but rather over time with a yearly assessment performed. The above calculations do not include residents moving out of the City, due to unforeseen circumstances.

Nonetheless, MWD would ensure that available water would be available to the residents of Huntington Park during a non-drought year.

Table 4.15-4 Multiple Dry Years Supply and Demand
2025 2030 2035 2040 2045
Demand Totals 4,477 4,431 4,382 4,330 4,277
Supply Totals 5,100 5,100 5,100 5,100 5,100
Surplus 623 669 719 769 823
*Units are presented in acre feet (af) per calendar year.

Source: Huntington Park 2021
As discussed above, the proposed project would facilitate an increased citywide water demand of up to 745 AFY. The increased demand would be accommodated for in the surplus of 823 AFY under multiple dry years, as shown in Table 4.15-4. Therefore, the proposed project would have a less than significant impact on water supply during multiple dry years.

Mitigation Measures
No mitigation measures are proposed.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 3: Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments? Impact UTIL-3 DEVELOPMENT FACILITATED THE PROPOSED PROJECT WOULD NOT REQUIRE THE RELOCATION OR CONSTRUCTION OF NEW OR EXPANDED WASTEWATER TREATMENT FACILITIES IN HUNTINGTON PARK.

IMPACTS WOULD BE LESS THAN SIGNIFICANT.

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and main extensions necessary to serve the future development would generally be installed within the already disturbed rights-of-way of existing roads or within the disturbance footprints of such projects.

As discussed in Section 4.15.1(b), all wastewater generated in the City of Huntington Park is conveyed via existing sewer laterals to the sewer mainline, which conveys wastewater through the LACSD ultimately to the JWPCP for treatment and reuse as applicable. The JWPCP has a design capacity of 400 mgd and currently treats approximately 280 mgd, providing a remaining capacity of 120 mgd for future regional development (LACSD 2022). According to the 2020 UWMP, Huntington Park’s 2020 sewage generation was 1,016 MG/year (2.78 mgd) and is expected to slightly increase to 1,025 MG/year (2.81 mgd) in 2045. Based on the difference in 2045 population projections between the 2020 UWMP and development facilitated by the proposed project, sewage generation would be expected to increase to approximately 1,138 MG/year (3.12 mgd) which would be accounted for in the 120 mgd remaining capacity at the JWPCP. Therefore, the JWPCP would have sufficient capacity to accommodate wastewater generated by the proposed project.

Furthermore, applicants for projects facilitated by the proposed project would be responsible for constructing on-site wastewater treatment conveyance systems and paying standard sewer connection fees, as necessary. The City’s Community Development Department screens project proposals for the potential to create wastewater in excess of capacity of the sanitary sewer system and enforces building and construction standards. Therefore, the proposed project would not require or result in the relocation or construction of new or expanded wastewater treatment facilities and impacts would be less than significant.

Mitigation Measures
No mitigation measures are proposed.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 4: Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Threshold 5: Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Impact UTIL-4 DEVELOPMENT FACILITATED BY THE PROJECT WOULD NOT GENERATE SOLID WASTE IN EXCESS OF STATE OR LOCAL STANDARDS, OR IN EXCESS OF THE CAPACITY OF LOCAL INFRASTRUCTURE. THE PROJECT

WOULD NOT IMPAIR THE ATTAINMENT OF SOLID WASTE REDUCTION GOALS AND WOULD COMPLY WITH FEDERAL, STATE, AND LOCAL STATUTES AND REGULATIONS RELATED TO SOLID WASTE. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Development facilitated by the project could result in the addition of up to 10,646 residents and 2,668 residential units throughout the City. Based on the 2020 solid waste generation rate of 4.30 pounds per person per day, the proposed project would generate an additional estimated 44,995 pounds per day (approximately 23 tons or 27 cubic yards) or about 16.4 million pounds per year (8,212 tons or 9,744 cubic yards) (CalRecycle 2020). The calculation for the project does not take into consideration current and planned City programs to divert solid waste from landfills. As shown City of Huntington Park
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above, the combined daily intake capacity of landfills serving the proposed project is 18,620 tons per day. Therefore, available capacity (200.2 million tons per day) can accommodate the estimated daily solid waste that would be generated by the proposed project. Assuming no diversion, the increase in project related generated solid waste would represent less than 1 percent of the total available daily capacity.

Based on the County of Los Angeles Countywide Integrated Waste Management Plan (CIWMP) 2019 Annual Report (County of Los Angeles 2020), Los Angeles County would be able to meet the disposal needs of all County jurisdictions through the 15-year planning period for six of seven scenarios considered. Although daily capacity at area landfills is currently available (as noted above), the CIWMP Annual Report concludes that reliance on existing permitted County landfill capacity alone is insufficient to meet the County’s long-term disposal needs; however, under the “status quo” scenario (i.e., solid waste disposed will continue to be managed by existing permitted in-County disposal infrastructure and available out-of-County landfill capacity and diversion efforts by individual jurisdictions continue, resulting in a countywide diversion rate of 65 percent) and each of the other scenarios contemplated in the CIWMP Annual Report, no shortfall in capacity is expected.

The “status quo” scenario is conservative insofar as it assumes no new waste reduction programs or disposal facilities and no increase in waste diversion. Based on these facts, sufficient permitted capacity is anticipated to be available to accommodate the proposed project’s solid waste disposal needs and impacts related to solid waste would be less than significant.

Finally, development facilitated by the project would also be required to demonstrate compliance with all applicable regulations. The project’s solid waste disposal would have a less than significant impact for local solid waste infrastructure.

Mitigation Measures
No mitigation measures are proposed.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.15.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3].).

Water
The analysis provided under Impact UTL-2 and UTIL-3 is cumulative in nature and considers water demand associated with development within the City’s Water Department service area. Cumulative development within Huntington Park will continue to increase demands on water supplies. There would be sufficient existing water supplies to accommodate anticipated cumulative development and achieve full buildout of the housing opportunity sites for other nearby cities under normal and dry year conditions by relying on the estimated surplus and implementation of ongoing conservation measures. Therefore, the proposed project would not have a cumulatively considerable contribution to a significant cumulative impact regarding water supply services.

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Wastewater
As discussed above under Impact UTIL-1, new wastewater service connections would be installed as needed, on a project-specific basis; this would occur for non-residential developments within the cumulative scenario as it would for residential developments under the proposed project. LACSD and the City of Huntington Park conduct repairs and upgrades to the existing wastewater conveyance system throughout the City on an as-needed basis and would continue to do so for both residential developments under the proposed project as well as non-residential projects in the cumulative scenario.

Electricity and Natural Gas
The geographic scope for cumulative electricity and natural gas impacts is the Southern California Edison and Southern California Gas service area. This geographic scope is appropriate because the local providers are responsible for transmitting electricity and natural gas to all land uses within their service areas, including those that would occur on the housing opportunity sites. Development considered part of the cumulative analysis includes buildout of local General Plans.

Southern California Edison and Southern California Gas are subject to the requirements set forth and/or enforced by the CPUC. The need for electric and natural gas infrastructure would be addressed on a case-by-case basis for each cumulative project, and would be subject to CPUC requirements, similar to those applicable to the proposed project. Therefore, cumulative impacts related to electric power and natural gas transmission facilities would be less than significant.

Therefore, the proposed project would not have a cumulatively considerable contribution to a cumulative impact regarding electricity and natural gas.

Telecommunication
The geographic scope for cumulative telecommunications impacts is the telecommunication provider service area. This geographic scope is appropriate because local providers are responsible to provide adequate telecommunication infrastructure to all land uses within its service area, including the housing opportunity sites.

As discussed above under Impact UTIL-1, project implementation requires connections to existing utility infrastructure to meet the needs of site residents and tenants. Cumulative development would increase demand for telecommunications infrastructure in the City. However, cumulative projects would each be required to provide adequate telecommunications infrastructure on a project-by-project basis and would be subject to the same requirements as the proposed project.

Therefore, cumulative impacts related to telecommunications infrastructure would be less than significant. The proposed project would not have a cumulatively considerable contribution to a cumulative impact regarding telecommunication services.

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Environmental Impact Analysis
Effects Found Not to be Significant
Draft Environmental Assessment 4.16-1

4.16 Effects Found Not to be Significant
CEQA Guidelines Section 15128 requires an EIR to briefly describe any possible effects that were determined not to be significant and were therefore not discussed in detail in the EIR. The sections below include the checklist questions listed in Appendix G of the CEQA Guidelines and a brief discussion of environmental impacts that were determined to be less than significant.

4.16.1 Agricultural and Forestry Resources
Would the project:
 Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use?  Conflict with existing zoning for agricultural use, or a Williamson Act contract?  Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?  Result in the loss of forest land or conversion of forest land to non-forest use?  Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland, to non-agricultural use or conversion of forest land to nonforest use? The City of Huntington Park is a highly urbanized city, and farmland maps prepared by the California Department of Conservation (CDOC) show that Huntington Park does not contain any Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (CDOC 2016).

Because the project would intensify development within Huntington Park on parcels already zoned for residential or mixed-use development or rezoning manufacturing or commercial development sites to residential or mixed use development, the project would not impact agricultural or forestry resources. Proposed policies included in the updates to the Housing Element and Safety Element, would not impact agricultural or forestry resources. The project would not result in the conversion of farmland to non-agricultural use and would not conflict with agricultural zoning or Williamson Act contracts. Further, the project would not conflict with zoning or result in the conversion of forestland, timberland, or timberland production areas. There would be no impact.

4.16.2 Mineral Resources
Would the project:
 Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
 Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan? There are no actively used mineral resources or mining operations within the City of Huntington Park. The project would not interfere with mining operations or the loss of availability of known mineral resources, there would be no impact to mineral resources.

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4.16.3 Wildfire
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
 Substantially impair an adopted emergency response plan or emergency evacuation plan?  Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
 Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?  Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes? Wildfire as an impact area was not analyzed in the 1988 General Plan or related EIR. To note, there are no Very High Fire Hazard Severity Zones (VHFHZS) within or near the city limits of Huntington Park (CALFIRE 2023). The nearest VHFHSZ is located approximately five miles north of Huntington Park. County emergency response plans are updated regularly and would reflect the most recent population estimates and growth projections. Implementation of the proposed project would not substantially impair adopted emergency response or emergency evacuation plans as the Draft Housing Opportunity Sites would be accessed by existing roadways and would not impair the use of emergency evacuation routes through the modification of roadways. Additionally, as described in Section 4.13, Public Services and Recreation, the project would not itself result in the need for new or expanded emergency services, including police and fire protection. Development facilitated by the project would be constructed in accordance with federal, state, regional, and local requirements, which are intended to ensure the safety of residents and structures to the extent feasible. Compliance with these standard regulations would be consistent with Los Angeles County’s adopted emergency response plan.

The project would accommodate increased density, FAR, and building heights in existing developed areas of the city, on sites already zoned for residential or mixed use development that are not located in a VHFHZS. Development in the City would be required to conform with the latest fire code, including provisions for emergency access. The increase in population associated with the project would not result in significant impacts to evacuation routes or plans in the event of a wildfire, and proposed policies in the Safety Element Update would increase coordination between safety and law enforcement agencies in the event of an emergency. Policies associated with the Housing Element and General Plan Update would not expose people or structures to significant risks associated with wildfire.

Additionally, the proposed project would not impair emergency response or evacuation plans and would not involve the installation of infrastructure that may exacerbate fire risk or expose people or structures to significant risks associated with wildfire hazards. Accordingly, potential impacts would be less than significant.

Other CEQA Required Discussions
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5 Other CEQA Required Discussions
This section discusses the potential growth-inducing impacts and irreversible environmental impacts associated with the implementation of the proposed project.

5.1 Growth Inducement
Section 15126(d) of the CEQA Guidelines requires a discussion of a proposed project’s potential to foster economic or population growth, including ways in which a project could remove an obstacle to growth. Growth does not necessarily create significant physical changes to the environment.

However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. The proposed project’s growth inducing potential is therefore considered significant if project-induced growth could result in significant physical effects in one or more environmental issue areas.

5.1.1 Population Growth
As discussed in Section 4.12, Population and Housing, while development facilitated by the proposed project would directly generate population growth, the City has established the need for additional housing. The project would facilitate an estimated population growth of approximately 10,646 new residents by 2045 based on the maximum project-facilitated buildout of 2,668 housing units. While the proposed project would increase the buildout potential beyond that anticipated in the current General Plan, the project would be consistent with City-identified housing need and the draft RHNA, as it would allow the future development of new housing on the Draft Housing Opportunity Sites. Additionally, the increase in housing and population from the provision of this new housing would be within the SCAG estimates for the region’s housing needs.

Moreover, as discussed in Section 4.2, Air Quality, and Section 4.7, Greenhouse Gas Emissions, development facilitated by the proposed project would not generate air quality or greenhouse gas emissions that would result in a significant impact. Additionally, the project would not involve the expansion of the existing City limits or the City’s sphere of influence or substantial extension of infrastructure outside of City limits; rather, it involves increased density within the Draft Housing Opportunity Sites, which has been analyzed in detail throughout this EA.

Therefore, population growth associated with the project would not result in significant long-term physical environmental effects, as described in Section 4.

5.1.2 Economic Growth
Development facilitated by the project would generate temporary employment opportunities during construction. Because construction workers would be expected to be drawn from the existing regional work force, project construction would not be growth-inducing from an employment standpoint. The proposed project would not induce substantial economic expansion to the extent that direct physical environmental effects would result.

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5.1.3 Removal of Obstacles to Growth
As discussed in Section 2, Project Description, the Draft Housing Opportunity Sites are zoned for development. The Draft Housing Opportunity Sites are mostly located within City limits and are served by existing infrastructure. As discussed in Section 4.14, Transportation and Section 4.15, Utilities and Service Systems of this EA, existing infrastructure would be adequate to serve development facilitated by the project. No new water, sewer, or other utility infrastructure would be required, and no new roads would be required. Because the project would facilitate development on underdeveloped and underutilized lots within urbanized areas and would not require the extension of infrastructure through undeveloped areas, project implementation would not remove an obstacle to growth.

5.2 Irreversible Environmental Effects
CEQA Guidelines Section 15126.2(c) requires EIRs contain a discussion of significant irreversible environmental changes. This section addresses non-renewable resources, the commitment of future generations to the proposed uses, and irreversible impacts associated with the proposed project.

The project would facilitate infill residential development on undeveloped and underdeveloped sites in the City of Huntington Park. Construction and operation of development facilitated by the project would involve an irreversible commitment of construction materials and non-renewable energy resources. Development would involve the use of building materials and energy, some of which are non-renewable resources, to construct new residential buildings and associated infrastructure and landscaping. Consumption of these resources would occur with any development in the region and are not unique to the proposed project.

Operation of development facilitated by the project would also irreversibly increase local demand for non-renewable energy resources such as petroleum products and natural gas. However, increasingly efficient building design would offset this demand to some degree by reducing energy demands of the project. As described in Section 4.5, Energy, development facilitated by the project would be subject to the energy conservation requirements of the California Energy Code (Title 24, Part 6, of the California Code of Regulations, California’s Energy Efficiency Standards for Residential and Nonresidential Buildings) and the California Green Building Standards Code (Title 24, Part 11 of the California Code of Regulations). The California Energy Code provides energy conservation standards for all new and renovated residential buildings, and the Green Building Standards Code requires solar access, natural ventilation, and stormwater capture. Consequently, development facilitated by the project would not use unusual amounts of energy or construction materials and impacts related to consumption of non-renewable and renewable resources would be less than significant. Consumption of these resources would occur with any development in the region and is not unique to the proposed project.

5.3 Mandatory Findings of Significance
Following each environmental impact discussion in Section 4, Environmental Impact Analysis, is a list of mitigation measures (if required) and the residual effects or level of significance remaining after implementation of the measure(s). In cases where the mitigation measure could cause a significant environmental impact in another issue area, this impact is discussed and evaluated as a secondary impact. The impact analysis concludes with a discussion of cumulative effects, which evaluates the impacts associated with the project in conjunction with the build-out of the City General Plan.

Other CEQA Required Discussions
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CEQA Guidelines Section 15065 also requires the following specific Mandatory Findings of Significance be addressed as part of the environmental review for the project:
 The potential for the project to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory;  Project impacts are individually limited, but cumulatively considerable. (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects); and
 Environmental effects of the project which will cause substantial adverse effects on human beings, either directly or indirectly.

Besides air quality and noise, the impact areas addressed by this Mandatory Findings of Significance section would be less than significant. Potential adverse environmental effects to human beings are discussed in Section 4.2, Air Quality and Section 4.11, Noise. Furthermore, as discussed above, each environmental analysis section of the EA concludes with a discussion of the project’s contribution to cumulative effects.

The Executive Summary of this EA summarizes all impacts and mitigation measures that apply to the project.

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Alternatives
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6 Alternatives
As required by CEQA Guidelines Section 15126.6, this chapter examines a range of reasonable alternatives to the proposed project that would attain most of the basic project objectives but would avoid or substantially lessen the significant adverse impacts.

As discussed in Section 2, Project Description, the project objectives are as follows:
 Provide a framework for accommodating approximately 2,500 new housing units, with a reasonable buffer of at least 14 percent above RHNA for lower- and moderate-income units for a total of 2,668 new units, at all levels of affordability within access to transit, job centers, schools, services, and open spaces.
 Plan for a buffer range of approximately 338 units to ensure ongoing compliance with the No Net Loss provisions of State housing law.
 Accommodate the City’s share of the State-required RHNA for 5th and 6th Cycle Housing Element planning periods.
 Bring the Housing, Safety, and Land Use Elements into conformance with recently enacted State laws.
 Identify future housing sites with a collective capacity to meet the City’s RHNA, including the requisite buffer capacity; and
 Continue to provide excellent services, parks, schools, and environmental setting, and offer new programs that support the City’s increasing diversity and improved housing affordability. New Housing Element programs support this growth and self-mitigate potential negative impacts of growth on the physical environment in Huntington Park and the surrounding region.

This analysis presents two alternatives including the CEQA-required “no project” alternative that involve changes to the project that may reduce the project-related environmental impacts identified in this EA. These Alternatives have been developed to provide a reasonable range of options to consider that would help decision makers and the public understand the general implications of revising or eliminating certain components of the proposed project.

The following alternatives are evaluated in this EA:

Alternative 1: No Project
Alternative 2: Alternative Candidate Sites
Table 6-1, below, provides a summary comparison of the proposed project and each of the alternatives considered. Detailed descriptions of the alternatives are included in the impact analysis for each alternative. The potential environmental impacts of each alternative are analyzed in Sections 6.1 and 6.2, below.

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Table 6-1 Comparison of Project Alternatives’ Buildout Characteristics Proposed
Project
Alternative 1:

No Project
Alternative 2:

Alternative
Candidate Sites
Total Allowable Dwelling Units Under Alternative 2,668 1,800 1,958 Change in Total Maximum Dwelling Units Compared to
proposed project
n/a -1,084 -710
Total Additional Residents Under Alternative 8,250 5,400 6,070 Change in Population Potential Compared to proposed project (Number of Residents)
n/a -2,710 -2,180

6.1 Alternative 1: No Project Alternative
The CEQA Guidelines (Section 15126.6[e][2]) require that the alternatives discussion include an analysis of a No Project Alternative. Pursuant to CEQA, the No Project Alternative refers to the analysis of existing conditions and what would reasonably be expected to occur in the foreseeable future if the project were not approved, based on current plans and consistent with available infrastructure and community services. The No Project Alternative typically will proceed along one of two lines: (1) when a project is a revision of an existing regulatory plan or policy, the No Project Alternative will be continuation of the existing plan or policy; or (2) if a project is a development project on identifiable property, the No Project Alternative is the circumstance under which the project does not proceed. In this case, the No Project Alternative represents the continuation of existing zoning and General Plan designations on the Draft Housing Opportunity Sites, and full buildout under those existing designations is assumed to occur under this alternative. Typical development assumptions are included in the below analysis of this alternative, including compliance with applicable regulations or typical City-required measures.

6.1.1 Description
The No Project Alternative assumes there is no change in zoning or General Plan land use designations for the parcels identified by the project. Current uses on the sites would continue under this alternative, with future full buildout of the Draft Housing Opportunity Sites limited by the existing zoning and General Plan designations. Buildout of the Draft Housing Opportunity Sites under existing zoning would allow for up to roughly 1,800 total housing units, housing a population of 5,400 residents (refer to Table 6-1). This alternative would only accomplish two of the six objectives identified for the project. Among others, it would not accomplish the project objectives of planning a buffer of up to 2,668 (14%) new housing units to ensure ongoing compliance with the No Net Loss provisions of State housing law.

6.1.2 Impact Analysis
Aesthetics
Under the No Project Alternative, buildout consistent with the existing zoning and land use of the Draft Housing Opportunity Sites would occur. The Draft Housing Opportunity Sites do not offer notable scenic vistas and are not within the view of a State scenic highway, as described under Impact AES-1. Similar to the proposed project, mitigation may be applied to individual projects to reduce visual impact during the project design review process. Development allowed under existing Alternatives
Draft Environmental Assessment 6-3
zoning would also increase lighting and glare on some of the Draft Housing Opportunity Sites, but fewer Draft Housing Opportunity Sites than under the proposed project. Similarly, compliance with City General Plan goals and policies and the design development standards required through the design review process and building permit applications would still be required. Overall, impacts would be reduced when compared to the proposed project.

Air Quality
Under the No Project Alternative, fewer residential units would be constructed than the project, consistent with allowed existing zoning. Temporary construction-related air quality impacts from grading and construction and long-term air quality impacts from building operation (energy usage, maintenance), would be lower than under the proposed project, which included both a construction and operational emissions significant and unavoidable impact. Also, individual project mitigation may be required to ensure compliance with BAAQMD’s current recommended basic control measures to comply with standard permit conditions. Nonetheless, potential Impacts under Alternative 1 would be reduced when compared to the proposed project.

Biological Resources
The No Project Alternative would allow development under existing zoning. Because of the potential for sensitive species and habitats to exist on the Draft Housing Opportunity Sites, direct impacts to biological resources would be similar to those that would occur with the proposed project, but only 1,800 dwelling units would be developed. Thus, development allowed under the No Project Alternative would be smaller in terms of number of sites developed; however, ground disturbance and vegetation removal, especially of Draft Housing Opportunity Sites would result in similar impacts to biological resources. Under the No Project Alternative, development of the Draft Housing Opportunity Sites would not increase the likelihood of special-status species being affected and there would be no impact on special-status species. Therefore, impacts under the No Project Alternative would be similar to the impacts under the proposed project with implementation of relevant General Plan Policies mentioned in Section 4.3, Biological Resources.

Cultural and Tribal Cultural Resources
The No Project Alternative would allow development under existing zoning at a smaller scale than under the proposed project but could still entail ground disturbance or excavation activities. There are no known historical resources located within the Draft Housing Opportunity Sites. Ground disturbance from development allowed under existing zoning would still have potential impacts to archaeological resources and human remains, although likely to a lesser extent than under the proposed project due to fewer residential units. As all of the Draft Housing Opportunity Sites are currently zoned for development, development under the No Project Alternative would not create any new and significant impacts to cultural resources. Potential impacts would be addressed by regulations established in the City’s General Plan and Municipal Code. As the No Project Alternative would result in the same number of Draft Housing Opportunity Sites being affected as under the proposed project, impacts would be similar to the proposed project.

Energy
Under the No Project Alternative, construction- and operation-related energy use from development allowed under the existing zoning of the Draft Housing Opportunity Sites would occur, but the decreased scale and intensity of the allowed development would be less than under the City of Huntington Park
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proposed project. Similar to the proposed project, development under the No Project Alternative would comply with the 2022 California Building Energy Efficiency Standards for Residential Buildings and CALGreen (California Code of Regulations Title 24, Parts 6 and 11) or later versions, which require certain energy efficient development features. Impacts would be reduced when compared to the proposed project.

Geology and Soils
The No Project Alternative would allow for development under existing zoning, which would involve construction or ground disturbance that could expose and loosen soils and increase the potential for erosion. The Draft Housing Opportunity Sites remain outside Alquist-Priolo fault zones, and future construction on any of the sites would be required to comply with California Building Code requirements and implement General Plan goals and policies, ensuring the stability of new structures during seismic events or due to unstable or expansive soils. Development allowed under existing zoning, similar to development facilitated by the proposed project, would occur within areas of high paleontological sensitivity; however, the No Project Alternative would allow fewer residential units to be developed than under the proposed project. Impacts would be similar when compared to the proposed project.

Greenhouse Gas Emissions
Under the No Project Alternative, less development would occur, consistent with allowed existing zoning. Temporary construction-related GHG emissions that result from grading and construction of new development and long-term impacts resulting from building operation (energy use, maintenance, and traffic) would be lower than under the proposed project. Impacts would be reduced when compared to the proposed project.

Hazards and Hazardous Materials
Under the No Project Alternative, the transport, storage, and use of hazardous materials associated with construction of development allowed under existing zoning, and operation of housing, commercial and industrial uses, such as paints and solvents, would be required to comply with existing regulations, similar to the proposed project. Sites containing existing or potential contamination would continue to require remediation and compliance with State and local regulations to allow for development under existing zoning. Impacts related to airport safety hazards and noise would be less than significant with compliance with General Plan goals and policies. As stated in Section 2, Project Description, all of the Draft Housing Opportunity Sites are currently zoned for development. As such, implementation of the No Project Alternative which would involve development of sites already zoned for development would not increase the likelihood of wildland fires and impacts would be less than significant. Impacts would be similar to those under the proposed project.

Hydrology and Water Quality
The No Project Alternative would allow development under existing zoning, which could include construction activities that would loosen and expose soils, otherwise increase the potential for soil erosion and sedimentation, and create new or additional impervious surfaces. Due to the fewer development sites allowed under existing zoning, these impacts would be less than those under the proposed project. Similar to the proposed project, development allowed under the No Project Alternative would not substantially decrease groundwater supplies or violate water quality Alternatives
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standards, following compliance with applicable laws and regulations. The smaller total buildout allowed under existing zoning would have fewer impacts on hydrology and water quality than the proposed project. Impacts would be reduced when compared to the proposed project.

Land Use and Planning
Under the No Project Alternative, the Draft Housing Opportunity Sites would retain their existing zoning, allowing future buildout in accordance with that zoning. The No Project Alternative would not alter connectivity with adjacent areas or divide established communities. Future development under existing zoning would be required to comply with regulatory goals and policies, similar to the proposed project, as discussed in Impact LU-2. The No Project Alternative would result in less intensive future development, which would not promote high-density housing opportunities to the extent that the proposed project would in terms of consistency with General Plan goals and policies around encouraging the development of accessible housing. Impacts would be similar to the proposed project.

Noise
Under the No Project Alternative, less intensive impacts associated with temporary constructionrelated noise would result from grading and construction of development allowed under existing zoning, as less intensive development of the Draft Housing Opportunity Sites would be allowed. Less intensive long-term noise impacts resulting from building operation and fewer vehicle trips would also occur. Individual project mitigation may be required to reduce project-specific noise and vibration impacts in compliance with standard permit conditions. Impacts would be reduced when compared to the proposed project.

Population and Housing
Since development would follow existing zoning, the No Project Alternative would not induce substantial population growth, as the development allowed under existing zoning is already accounted for in regional population and housing projections. As a result, the No Project Alternative would not contribute to unplanned growth and would also not displace people or housing. The No Project Alternative would have no impacts to population and housing, while the proposed project would have less than significant impacts. Impacts under the No Project Alternative would be less than those for the proposed project. However, the No Project Alternative would not provide the benefits associated with the provision of housing that would occur under the proposed project.

Public Services and Recreation
Development allowed by existing zoning would occur under the No Project Alternative, and this alternative would result in a smaller increase to emergency calls to the area, as well as a smaller increase in additional demand for schools, parks, libraries, recreational facilities, or other public services compared to the proposed project as the project would result in a population growth of 5,400 people, 2,850 people less than the proposed project. Impacts under the No Project Alternative would be less than that under the proposed project.

Transportation
Under the No Project Alternative, less intensive temporary construction-related traffic impacts from grading and construction of development allowed under existing zoning would occur. The No Project Alternative would have a smaller increase in transit demand or interference with existing or City of Huntington Park
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planned transit facilities than the proposed project due to the smaller population growth compared to the proposed project. The No Project Alternative would result in a smaller increase in overall VMT due to the reduced number of units which would be built though VMT per capita would increase due to the reduced population growth that would take place. Similar to the proposed project, the No Project Alternative would meet the City’s VMT screening criteria and would therefore not result in a substantial increase in VMT. Impacts would be reduced when compared to the proposed project.

Utilities and Service Systems
Development allowed under existing zoning would occur under the No Project Alternative. This would result in an increase in demand for water, wastewater, electricity, natural gas, telecommunications, and solid waste service. This increase in demand would be less than the proposed project due to the reduced development potential allowed under existing zoning; however, the expansion of water, wastewater, electricity, natural gas, and telecommunication infrastructure would still be required for sites where existing utility lines and connections do not already exist or are not large enough to service the Draft Housing Opportunity Sites. Impacts would be reduced when compared to the proposed project.

Cumulative Impacts
Based on the analysis herein, the No Project Alternative would have lesser impacts to aesthetics, air quality, cultural resources, energy, GHG emissions, hydrology and water quality, noise, population and housing, public services and recreation, transportation, tribal cultural resources, and utilities and service systems than the proposed project. Impacts to biological resources, cultural resources, geology and soils, hazards and hazardous materials, land use and planning, and tribal cultural resources would be similar to the proposed project. Because impacts under the No Project Alternative would be less than or similar to the proposed project, and the proposed project’s contribution to cumulative impacts analyzed in the General Plan and Specific Plan EIRs for most of these resource areas was determined not to be cumulatively considerable, the No Project Alternative would also not be cumulatively considerable.

6.2 Alternative 2: Alternative Candidate Sites

6.2.1 Description
The “Alternative Candidate Sites” Alternative’s characteristics are generally as described for the proposed project in Section 2, Project Description. This alternative involves General Plan, Zoning Code, and Specific Plan Amendments to as many as 89 low-and very-low income candidate sites.

Similar to the proposed project, the residential sites inventory identified vacant and under-utilized sites in Huntington Park for Alternative 2. As noted in the Draft Housing Element, the DTSP area is ideal to accommodate high density residential uses. Current development standards make higher density (up to 70 dwelling units per acre) residential infill development feasible and desirable.

Further, the concentration of vacant, for lease or sale, unoccupied, and underutilized commercial buildings in this area indicate a high potential for redevelopment. The planned West Santa Ana Branch Light Rail project and the associated Pacific/Randolph station at the north end of the DTSP has the potential to bring economic revitalization and increase residential demand in the area. For Alternatives
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this reason, all sites identified within the DTSP are located within one mile of the planned Pacific/Randolph station.

Similar to the proposed project, Policy 4.6 will require that rezoned Alternative 2 sites will permit multifamily uses by right pursuant to Government Code section 65583.2(i) for developments in which 20 percent or more of the units are affordable to lower-income households.

Table 6-2 Alternative Candidate Sites
Address APN Existing Use
2660 Randolph St. 6320-022-007 Five or more apartments
2668 Randolph St. 6320-022-009 Three Units (Any Combination) 2664 Randolph St. 6320-022-008 Five or more apartments
6213 Seville Ave. 6320-022-016 Single
6503 Rita Ave. 6322-004-021 Five or more apartments
6433 Rita Ave. 6322-004-019 Five or more apartments
2663 Zoe Ave. 6322-005-017 Five or more apartments
6518 Rita Ave. 6322-005-010 Five or more apartments
6423 Seville Ave. 6322-005-007 Five or more apartments
6603 Stafford Ave. 6322-014-014 Two Units
6606 Templeton St. 6322-012-003 Single
6618 Templeton St. 6322-012-005 Five or more apartments 6528 Templeton St. 6322-008-014 Five or more apartments 6523 Miles Ave. 6322-008-030 Three Units (Any Combination) 6529 Miles Ave. 6322-008-031 Two Units
6532 Stafford Ave. 6322-007-015 Single
6541 Templeton St. 6322-007-033 Two Units
6523 Templeton St. 6322-007-030 Five or more apartments 6533 Templeton St. 6322-007-032 Five or more apartments 6528 Stafford Ave. 6322-007-014 Two Units
6538 Stafford Ave. 6322-007-016 Two Units
6522 Templeton St. 6322-008-013 Single
2811 Zoe Ave. 6322-008-017 Single
6532 Templeton St. 6322-008-015 Five or more apartments 2817 Zoe Ave. 6322-008-033 Three Units (Any Combination) 6602 Templeton St. 6322-012-001 Three Units (Any Combination) 2680 Zoe Ave. 6322-015-008 Five or more apartments
6612 Templeton St. 6322-012-004 Two Units
2810 Zoe Ave. 6322-012-002 Single
6529 Templeton St. 6322-007-031 Four Units (Any Combination) 6538 Templeton St. 6322-008-016 Two Units
6535 Miles Ave. 6322-008-032 Three Units (Any Combination) 6537 Stafford Ave. 6322-006-034 Three Units (Any Combination) 6533 Stafford Ave. 6322-006-033 Three Units (Any Combination) City of Huntington Park
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Address APN Existing Use
6528 Seville Ave. 6322-006-015 Five or more apartments
6522 Seville Ave. 6322-006-014 Single
6615 Templeton St. 6322-013-021 Five or more apartments 6603 Miles Ave. 6322-012-018 Two Units
6613 Miles Ave. 6322-012-020 Single
6607 Templeton St. 6322-013-020 Five or more apartments 6618 Seville Ave. 6322-014-001 Five or more apartments
2713 Zoe Ave. 6322-006-018 Single
6603 Templeton St. 6322-013-019 Single
6619 Templeton St. 6322-013-022 Four Units (Any Combination) 6608 Stafford Ave. 6322-013-002 Four Units (Any Combination) 6613 Stafford Ave. 6322-014-016 Two Units
6609 Miles Ave. 6322-012-019 Single
6602 Stafford Ave. 6322-013-001 Two Units
6619 Miles Ave. 6322-012-021 Five or more apartments
6612 Stafford Ave. 6322-013-003 Five or more apartments 6618 Stafford Ave. 6322-013-004 Three Units (Any Combination) 2776 Zoe Ave. 6322-013-018 Single
6529 Stafford Ave. 6322-006-032 Five or more apartments 6810 Rita Ave. 6322-016-008 Four Units (Any Combination) 6707 Seville Ave. 6322-015-017 Five or more apartments
6800 Rita Ave. 6322-016-007 Five or more apartments
6728 Rita Ave. 6322-016-004 Three Units (Any Combination) 6812 Rita Ave. 6322-016-020 Four Units (Any Combination) 6718 Rita Ave. 6322-015-014 Three Units (Any Combination) 6724 Rita Ave. 6322-016-003 Five or more apartments
6703 Seville Ave. 6322-015-016 Five or more apartments
6729 Seville Ave. 6322-016-002 Three Units (Any Combination) 6815 Seville Ave. 6322-016-009 Five or more apartments
6809 Seville Ave. 6322-016-006 Five or more apartments
6819 Seville Ave. 6322-016-010 Three Units (Any Combination) 7001 Seville Ave. 6322-025-036 Five or more apartments
6919 Seville Ave. 6322-025-037 Four Units (Any Combination) 7013 Seville Ave. 6322-025-042 Four Units (Any Combination) 7102 Rita Ave. 6322-025-011 Five or more apartments
7101 Seville Ave. 6322-025-029 Five or more apartments
7029 Seville Ave. 6322-025-030 Five or more apartments
7126 Rugby Ave. 6322-023-013 Five or more apartments
7139 Seville Ave. 6322-025-022 Five or more apartments
7135 Seville Ave. 6322-025-023 Five or more apartments
Alternatives
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Address APN Existing Use
7113 Seville Ave. 6322-025-027 Five or more apartments
7109 Seville Ave. 6322-025-028 Five or more apartments
7003 Rita Ave. 6322-024-023 Five or more apartments
6918 Rugby Ave. 6322-023-004 Three Units (Any Combination) 6804 Rugby Ave. 6322-018-008 Four Units (Any Combination) 6816 Rugby Ave. 6322-018-010 Five or more apartments
6814 Rugby Ave. 6322-018-009 Five or more apartments
6420 Rugby Ave. 6322-003-004 Four Units (Any Combination) 6123 Seville Ave. 6320-022-012 Three Units (Any Combination) 6433 Seville Ave. 6322-005-020 Two Units
6400 Pacific Blvd. 6322-004-001 Commercial Retail
2675 Saturn Ave. 6322-016-013 Office Building
6717 Pacific Blvd. 6322-018-029 Commercial Retail
6415 Pacific Blvd. 6322-003-009 Commercial Retail
6325 Pacific Blvd. 6320-031-022 Commercial Retail
For purposes of the environmental analysis, it was assumed that all 89 Draft Housing Opportunity Sites would be developed with strictly residential uses, similar to the proposed project. This assumption was used to develop an alternative that would reduce or avoid environmental impacts, particularly those related to VMT, to the extent feasible.

Alternative 2 would result in approximately 1,958 new dwelling units and approximately 6,070 new residents. This would equate to approximately 710 less units and approximately 2,180 less new residents than the proposed project. Like the proposed project, this Alternative also proposes various confirming amendments to the Zoning Code, General Plan, and related Specific Plans, and ancillary amendments to other planning documents, as necessary for clarification. This alternative would meet or exceed four of the six project objectives. In particular, this alternative does not create a framework for accommodating approximately 2,500 new housing units, with a reasonable buffer of at least 14 percent above RHNA for lower- and moderate-income units.

6.2.2 Impact Analysis
Aesthetics
For purposes of the analysis, it was assumed that the development facilitated by Alternative 2 would involve 710 fewer dwelling units and fewer gross acres due to a limited number of sites, as compared to the proposed project. Thus, potential aesthetic impacts concerning plan consistency, public views, visual character, and scenic resources would generally be similar to the proposed project and less in some instances.

The Alternative Candidate Sites do not offer notable scenic vistas and are not within the view of a State scenic highway, as described under Impact AES-1. Similar to the proposed project, mitigation may be applied to individual projects to reduce visual impact during the project design review process. Development allowed under Alternative 2 would also increase lighting and glare on some of the Alternative Candidate Sites, but fewer than under the proposed project. Similarly, compliance with City General Plan goals and policies and the design development standards required through City of Huntington Park
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the design review process and building permit applications would still be required. Thus, impacts would be reduced when compared to the proposed project.

Air Quality
Alternative 2 would generate less pollutant emissions than the proposed project, given this Alternative would involve approximately fewer residential development. However, the Alternative Candidate Sites Alternative would not avoid the project’s significant and unavoidable short-term, long-term, localized pollutant concentrations, and cumulative impacts to air quality, since it would involve only slightly less development that would generate pollutant emissions that would still exceed impact thresholds. Thus, the Alternative Candidate Sites Alternative would be considered environmentally superior to the proposed project concerning air quality.

Biological Resources
Although Alternative 2 would involve less development area than the proposed project, it would result in comparable impacts to biological resources, including special status plant and wildlife species and riparian habitat and other sensitive natural communities. Like the proposed project, this Alternative’s potential impacts to biological resources would be reduced to less than significant following compliance with the existing regulatory framework and recommended mitigation measures. Given some impacts would be avoided while others would be introduced, this Alternative would result in similar impacts as the proposed project concerning biological resources. Thus, Alternative 2 would be considered neither environmentally superior nor inferior to the proposed project concerning biological resources. Impacts would be similar to the proposed project.

Cultural and Tribal Cultural Resources
The development facilitated by Alternative 2 would residential in nature, but the required area of ground disturbance would be similar in nature as under the proposed project. However, as excavation and ground disturbance would already be needed under the proposed project, impacts would be similar to those under the proposed project. Specifically, this Alternative would involve comparable impacts to cultural and tribal cultural resources following compliance with the established regulatory framework, recommended mitigation measures, and site-specific mitigation measures. In particular, If historical resources are identified within the area of a proposed development, efforts shall be made to the extent feasible to ensure that impacts are mitigated in a manner consistent with Secretary of the Interior’s Standards for the Treatments of Historic Properties (Standards). If significant historical resources are identified on a development site and compliance with the Standards and or avoidance is not possible, appropriate site-specific mitigation measures shall be established and undertaken. Therefore, impacts to historic resources, archaeological resources, tribal cultural resources, and human remains would be less than significant. Overall, impacts would be similar to the proposed project.

Energy
The development facilitated by Alternative 2 would be less than the proposed project, given the sole number of dwelling units proposed, which would lower per-capita VMT compared to the proposed project. Similar to the proposed project, development facilitated by Alternative 2 would be required to comply with the 2022 California Building Energy Efficiency Standards for Residential Buildings and CALGreen (California Code of Regulations Title 24, Parts 6 and 11) or later versions, which require certain energy-efficient development features. In addition, Alternative 2 would have a lower overall Alternatives
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amount of VMT than the proposed project due to the decreased number of people who would reside in development built under Alternative 2. The operational energy use associated with the electricity consumption would also be decreased when compared to that under the proposed project. Therefore, the project under Alternative 2 would result in a more efficient use of energy than under the proposed project and would have a less than significant impact.

Geology and Soils
Following compliance with the established regulatory framework and recommended mitigation measures, the proposed project would result in less than significant impacts concerning the exposure of people or structures to potential substantial adverse effects involving strong seismic ground shaking, seismic-related ground failure, and landslides, soil erosion, unstable geologic units, and expansive soils.

This Alternative would decrease the number of people and structures potentially exposed to seismic and geological hazards, given that slightly less residential development would occur. However, because this Alternative would involve only a slightly smaller development footprint, like the Project, this Alternative would result in less than significant impacts concerning geology and soils, following compliance with the established regulatory framework and recommended mitigation measures. As with the proposed project, impacts involving geology and soils under this Alternative would be less than significant following compliance with the established regulatory framework and recommended mitigation. Therefore, this Alternative would be considered neither environmentally superior nor inferior to the proposed project concerning geology and soils.

Greenhouse Gas Emissions
Under Alternative 2, a decreased amount of development would occur when compared to the proposed project. Alternative 2 would have a lower operational VMT per capita compared to the proposed project, due to the overall reduction in Alternative 2 traffic. Therefore, Alternative 2 would result in decreased overall operational GHG emissions compared to the proposed project and would have less overall GHG impacts as a result. In addition, GHG emissions per capita would also decrease as residents would be in proximity to commercial uses and transit which would reduce VMT per capita. Finally, development under Alternative 2 would have the same or increased compatibility with the Scoping Plan and City General Plan detailed in Section 4.7, Greenhouse Gas Emissions, as development under Alternative 2 would reduce VMT per capita; facilitate economic expansion; and encourage higher density, transit-oriented development. Impacts would be reduced when compared to the proposed project and would remain less than significant.

Hazards and Hazardous Materials
Alternative 2 would result in less development than the Project, which would decrease the likelihood that this development would occur within 0.25 mile of a school that could result in the release of hazardous materials. Nonetheless, just as with the Project, compliance with regional and federal regulations and compliance with the Safety Element policies would minimize the risk of releases and exposure to these materials. Impacts would remain less than significant.

As discussed in Section 4.8, Hazards and Hazardous Materials, there are multiple locations within the City that are designated as hazardous materials sites. It is likely that development would occur on one of these sites due to the amount of development that would occur under this alternative.

Sites containing existing or potential contamination would continue to require remediation and compliance with State and local regulations to allow for development under existing zoning. Impacts City of Huntington Park
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related to airport safety hazards and noise would be less than significant with compliance with General Plan goals and policies. Additionally, the impacts would be more severe due to the increased likelihood of development although the impact would remain less than significant.

Hydrology and Water Quality
As concluded, the proposed project would result in less than significant impacts concerning water quality, groundwater supplies, alterations to drainage patterns, contributions to runoff water, and dam inundation, following compliance with the established regulatory framework. Impacts related to hydrology and water quality under this Alternative would be comparable to the proposed project.

Future development under both the proposed project and the Alternative Candidate Sites Alternative would be subject to Federal, State, and local regulations aimed at controlling hydrology and water quality related impacts. Therefore, this Alternative would be considered neither environmentally superior nor inferior to the proposed project concerning hydrology and water quality.

Land Use and Planning
Similar to the project, Alternative 2 would not alter connectivity with adjacent areas or divide established communities, as it would encourage infill development within designated urban service areas. Under Alternative 2, development would be consistent with the General Plan goals and policies identified in Section 4.10, Land Use and Planning, as development under Alternative 2 would encourage housing development, development of infill sites, and mixed-use development.

Alternative 2 would not introduce new land uses and would be consistent with local and regional plans to intensify residential development near transit. As such, Alternative 2 would have a less than significant impact, similar to the project.

Noise
As concluded in Section 4.11, Noise, following compliance with the established regulatory framework, the proposed project would result in less than significant impacts concerning permanent increases in ambient traffic noise levels and exposure of persons noise levels exceeding City standards. However, significant and unavoidable impacts are expected to occur with regard to construction noise, even with mitigation. Nonetheless, Alternative 2 would generate slightly less operational noise than the proposed project, given this Alternative would involve less residential development.

Overall, the noise-related impacts associated with this Alternative would be less than the proposed Project’s, given less residential development is expected to occur. Long-term operational impacts from roadway vehicle noise would be less than the project due to the increase in mode split and decrease in VMT per capita. With that said, it is also expected that short term significant construction impacts would occur under Alternative 2, similar to the impacts identified for the proposed project.
impacts related noise would be similar to the project and would remain less than significant related to operations and significant and unavoidable with regard to construction. Thus, the Alternative Candidate Sites Alternative would be considered environmentally superior to the proposed project concerning noise, since the overall amount of noise produced has the potential to be lower than the proposed project.

Alternatives
Draft Environmental Assessment 6-13
Population and Housing
As concluded in Section 4.12, Population and Housing, the project’s impacts concerning it’s potential to concentrate population growth and displace housing/people would be less than significant.

Under this Alternative, existing housing/people would be similarly displaced, as with the proposed Project, although to a slightly lesser degree than the project. However, as with the Project, impacts under this Alternative would be a less than significant impact.

Although population growth would occur under this Alternative as with the proposed project, the degree of growth would be less. With this Alternative, the forecast population growth would be approximately 6,070 persons, or approximately 2,180 persons less population growth than the proposed project. Both the proposed project and this Alternative would be required to adhere to City policies and standards, and provide required development impact fees, to assure that the City can support the population growth.

Although, impacts concerning displacement of people/housing from Alternative 2 would be slightly fewer than the proposed project, this Alternative’s forecast population growth would be less than with the proposed Project. Thus, Alternative 2 would be considered environmentally superior to the proposed project concerning population and housing.

Public Services and Recreation
Buildout under Alternative 2 would be similar to the project and would result in an increase of service ratios for police or fire stations in that area and increased use of school, library, and park and recreation facilities. However, similar to the project, these impacts would be mitigated by 2045 General Plan policies and payment of required development impact fees at the time of development of individual projects. Therefore, Alternative 2 would result in a less than significant impact, similar to the project.

Transportation
Alternative 2 would generate less traffic than the proposed project, given less development would occur. It is anticipated this Alternative would result in similar impacts to roadway segments, freeway segments, intersections, ramp intersections, and ramp metering, as the proposed project.

Thus, Alternative 2 would be considered environmentally superior to the proposed Project concerning transportation and traffic, since less population and dwelling units would be added to the area.

Utilities and Service Systems
The residential development and forecast population growth under the “Alternative Candidate Sites” Alternative would be slightly less than the proposed Project. Thus, this Alternative would generate less demand for utilities and service systems than the proposed Project. Site-specific development accommodated under the “Alternative Candidate Sites” Alternative would involve comparable, however less, impacts to utilities and service systems as the proposed project, following compliance with the established regulatory framework. Thus, the “Alternative Candidate Sites” Alternative would be considered environmentally superior to the proposed Project concerning utilities and service systems.

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Cumulative Impacts
Based on the analysis herein, Alternative 2 would have much fewer impacts to aesthetics, air quality, energy, GHG emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, population and housing, public services and recreation, and utilities and service systems than the proposed project. Impacts to biological resources, cultural resources, geology and soils, land use and planning, transportation, and tribal cultural resources would be similar to or less than the proposed project. The proposed project was determined to have a cumulatively considerable contribution to cumulative impacts as discussed in Section 4, Environmental Impact Analysis. Because noise impacts under Alternative 2 would be similar to the proposed project or incrementally greater and significant and unavoidable in terms of construction noise impacts, the impact under Alternative 2 was determined to not be cumulatively considerable.

6.3 Alternatives Considered but Rejected
The following summarizes those alternatives considered, but ultimately rejected for inclusion in the analysis as they would not meet most of the project objectives, would not substantially reduce impacts compared to the proposed project, or were determined to be infeasible.

The City considered a mixed-use alternative that would allow for retail to be included as allowable uses of the ground floor of the Draft Housing Opportunity Sites. This alternative would involve amending the zoning code to allow for mixed-use development to occur in the Downtown Specific Plan Area. This alternative assumes that approximately one quarter of the development proposed under the project would be mixed-use. This pattern of development would encourage locally serving retail uses along with residences at the Draft Housing Opportunity Sites, which would reduce the VMT for residents of those sites and surrounding areas because they would live close to some commercial uses. The commercial component of this alternative would allow for commercial uses on the ground floor with up to five stories of residential uses above. The building envelopes under this alternative would be identical to those under the proposed project, as the reduction in residential square footage would be offset by the increase in commercial square footage. This alternative would provide housing development opportunities, and encourage the development of additional high-density housing, although to a lesser extent than the proposed project. However, this alternative would not meet all of the project objectives because it would not include enough units to ensure ongoing compliance with the No Net Loss provisions of State housing law.

The City considered an alternative that would require an updating to the zoning code to include requiring noise barriers to reduce construction noise for development on any Draft Housing Opportunity Site. Noise barriers would reduce on-site noise by about 10 to 20 dBA depending on construction materials and barrier height, since noise barriers are traditionally constructed of material with a minimum weight of 2 pounds per square foot with no gaps or perforations.

Noise barriers may be constructed of, but are not limited to, 5/8‑inch plywood, 5/8‑inchoriented strand board, or hay bales. This alternative, which would require noise barriers that would reduce construction noise, could reduce the significant construction noise impact, but would not reduce the significant and unavoidable operational noise impact. This alternative would meet project objectives to provide housing, but fewer housing units would likely be built, because development on certain sites would be infeasible due to construction cost constraints.

Alternatives
Draft Environmental Assessment 6-15

6.4 Environmentally Superior Alternative
CEQA requires identification of the environmentally superior alternative among the alternatives to the proposed project. The environmentally superior alternative must be an alternative that reduces some of the project’s environmental impacts, regardless of the financial costs associated.

Identification of the environmentally superior alternative is an informational procedure and the alternative identified as the environmentally superior alternative may not be that which best meets the goals or needs of the proposed project. Table 6-3 indicates whether each alternative’s environmental impact is greater than, less than, or similar to that of the proposed project for each of the issue areas studied.

Based on the analysis of alternatives in this section, the No Project Alternative is the environmentally superior alternative as it would either avoid or lessen the severity of most impacts of the proposed project. Because the No Project Alternative would not generate new population within the City above existing buildout projections, impacts to population and housing, public services and recreation, and utilities and service systems would be eliminated. In addition, significant but mitigable impacts related to aesthetics, air quality, and noise would be reduced compared to the proposed project. However, this alternative would not meet the project objectives, as it would not increase the opportunities or encourage the development of housing in the City.

If the No Project Alternative is determined to avoid or reduce more impacts than any other alternative, CEQA requires that the EIR identify an environmentally superior alternative among the other alternatives (CEQA Guidelines Section 15126.6[e]). Of the other alternatives evaluated in this EIR, the proposed project would be the environmentally superior alternative.

The proposed project is the environmentally superior alternative as it would either avoid or lessen the severity of most impacts of the proposed project. The proposed project would meet all four of the project objectives identified in Section 2, Project Description, as it would provide a framework for accommodating a total of 2,668 units at all levels of affordability within access to transit, Downtown jobs, services, and open spaces; plan for a buffer of units to ensure ongoing compliance with the No Net Loss provision of State housing law.

Table 6-3 Impact Comparison of Alternatives
Issue
Proposed Project
Impact
Classification
Alternative 1:

No Project
Alternative 2:

Alternative Candidate
Sites
Aesthetics LTS + =
Air Quality LTSM + +
Biological Resources LTS = =
Cultural and Tribal Cultural Resources LTS = =
Energy LTS + +
Geology and Soils LTS = =
Greenhouse Gas Emissions LTSM + +
Hazards and Hazardous Materials LTS = =
Hydrology and Water Quality LTS + =
Land Use and Planning LTS = -
Noise SU + +
City of Huntington Park
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Issue
Proposed Project
Impact
Classification
Alternative 1:

No Project
Alternative 2:

Alternative Candidate
Sites
Population and Housing LTS + =
Public Services and Recreation LTS + -
Transportation LTSM + +
Utilities and Service Systems LTS + =
NI = No Impact; LTS = Less than Significant; LTSM = Less than Significant with Mitigation; SU = Significant and Unavoidable + Superior to the proposed project (reduced level of impact) - Inferior to the proposed project (increased level of impact) = Similar level of impact to the proposed project
The No Project Alternative would generally result in similar or decreased environmental impacts compared to the proposed project. By reducing the number of Draft Housing Opportunity Sites, this alternative would reduce impacts related to aesthetics, air quality, biological resources, energy, GHG emissions, hydrology and water quality, noise, population and housing, public services and recreation, transportation, and utilities and service systems. The No Project Alternative would have similar impact levels to the proposed project related to cultural resources, geology and soils, hazards and hazardous materials, land use and planning, tribal cultural resources, and wildfire impacts. However, this alternative would not meet the project objectives, as it would not increase the opportunities or encourage the development of housing in the City of Huntington Park.

Alternative 2 would generally result in similar or incrementally decreased environmental impacts compared to the proposed project. By allowing for less residential uses, this alternative would reduce VMT per capita.

References
Draft Environmental Assessment 7-1
7 References

7.1 Bibliography
Project Description
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Environmental Setting
California Department of Finance (DOF). 2022. E-5 Population and Housing Estimates for Cities, Counties, and the State, January 2021-2022, with 2020 Census Benchmark. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housingestimates-for-cities-counties-and-the-state-2020-2022/ Accessed April 2023.

Southern California Association of Governments (SCAG). 2020. Current Context Demographics and Growth Forecast. https://scag.ca.gov/sites/main/files/fileattachments/0903fconnectsocal_demographics-and-growth-forecast.pdf Accessed August 2022.

Aesthetics
California Department of Transportation (Caltrans). 2019. List of eligible and officially designated State Scenic Highways. https://dot.ca.gov/-/media/dotmedia/programs/design/documents/desig-and-eligible-aug2019_a11y.xlsx Accessed November 2022.

Huntington Park, City of. 1991. City of Huntington Park General Plan. https://www.hpca.gov/DocumentCenter/View/407/HP-General-Plan?bidId= (accessed April 2023).
2008. Downtown Huntington Park Specific Plan.
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. 2010. Historic Preservation Design Review Guidelines. https://www.laconservancy.org/sites/default/files/community_documents/Huntington%20 Park%20Design%20Guidelines%2C%202010.pdf Accessed November 2022.

Cultural and Tribal Cultural Resources
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Baker, Bob. 1991. “Los Angeles’s Booming Auto Industry Now a Memory,” Los Angeles Times, 20 July 1991. Accessed online at http://articles.latimes.com/1991-07-20/news/mn-2136_1_autoplant, August 2, 2018.

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Bancroft, Hubert How. 1885. History of California, Volume III: 1825-1840. San Francisco, California:

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Bean, Walton. 1968. California: An Interpretive History. New York: McGraw Hill.

Bean, Lowell John and Charles R. Smith. 1978. “Gabrielino.” in California, edited by Robert F. Heizer, pp. 538–549. Handbook of North American Indians, Vol. 8, W.C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C.

Dumke, Glenn S. 1994. “The Boom of the 1880s in Southern California.” Southern California Quarterly 76(1):99-114.

Erlandson, Jon M. 1991. Early Maritime Adaptations on the Northern Channel Islands in HunterGatherers of Early Holocene Coastal California. Volume 1: Perspectives in California Archaeology. J. M. Erlandson and R. Colten, eds. Pp. 101-111. Los Angeles, California: Costen Institute of Archaeology Press.
1994. Early Hunter-Gatherers of the California Coast. New York, New York: Plenum Press.

Erlandson, Jon M., Theodore Cooley, and Richard Carrico. 1987. A Fluted Projectile Point Fragment from the Southern California Coast: Chronology and Context at CA-SBA-1951. Journal of California and Great Basin Anthropology 9:120–128.

Erlandson, Jon M., Torben C. Rick, Terry L. Jones, and Judith F. Porcasi. 2007. One If by Land, Two If by Sea: Who Were the First Californians? in California Prehistory: Colonization, Culture, and Complexity. Terry L. Jones and Kathryn A. Klar, eds. Pp. 53-62. Lanham, Maryland: AltaMira Press.

Fogelson, Robert M. [1967] 1993. The Fragmented Metropolis: Los Angeles, 1850–1930. Cambridge, MA: Harvard University Press.

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Colonization, Culture, and Complexity. Terry L. Jones and Kathryn A. Klar, eds. Pp. 191-213.

Lanham, Maryland: AltaMira Press.

Gumprecht, Blake. 1999. The Los Angeles River: Its Life, Death, and Possible Rebirth. Baltimore, Maryland: Johns Hopkins University Press.

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Jones, Terry L. and Georgie Waugh. 1997. Climatic Consequences or Population Pragmatism?: A Middle Holocene Prehistory of the Central California Coast. In Archaeology of the California Coast during the Middle Holocene. Perspectives in California Archaeology, Vol. 4, edited by J.M. Erlandson and M.A. Glassow, pp. 111-128. Costen Institute of Archaeology, University of California, Los Angeles.

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Perspectives in California Archaeology. Jon M. Erlandson and Terry L. Jones, eds. Pp. 205- 232. Los Angeles, California: Costen Institute of Archaeology, University of California, Los Angeles.

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AltaMira Press.

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McIntosh, Katie. 2020. “The Untold Story of California Missions,” Confluence [web site]. November 6, 2020. https://confluence.gallatin.nyu.edu/sections/research/the-untold-story-ofcalifornia-missions (accessed October 2022).

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Treganza, Adan E. and Agnes Bierman. 1958. The Topanga Culture: Final Report on Excavations, 1948. University of California Anthropological Records 20(2):45–86.

United States Census Bureau. 2022. “QuickFacts: Huntington Park city, California.” United States Census bureau web site.
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Viehe, Frank W. 1991. “The Social-Spatial Distribution in the Black Gold Suburbs of Los Angeles, 1900-1930,” Southern California Quarterly 73, no. 1 (Spring), 33-54.

Villa, Sam. 2017. “Tongva People: Introduction.” Tongvapeople.org. Electronic document. Accessed October 22, 2021.

Wallace, William J. 1955. A Suggested Chronology for Southern California Coastal Archaeology.

Southwestern Journal of Anthropology 11(3):214-230.
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36. Washington, D.C.: Smithsonian Institution Scholarly Press.

Warren, Claude N. 1968. Cultural Tradition and Ecological Adaptation on the Southern California Coast in Archaic Prehistory in the Western United States. C. Irwin-Williams, ed. Eastern New Mexico University Contributions in Anthropology 1(3):1–14.

Waugh, John C. 2003. On the Brink of Civil War: The Compromise of 1850 and How it Changed the Course of American History. Wilmington, Delaware: Scholarly Resources Inc.

References
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Welch, Rosanne. 2006. “A Brief History of the Tongva Tribe: The Native Inhabitants of the Lands of Puente Hills Preserve.” Department of History, Claremont Graduate University, Claremont, California.

Geology and Soils
California Department of Conservation (DOC). 1998. Seismic Hazard Zone Report for the South Gate

7.5-Minute Quadrangle, Los Angeles County, California.
. 2022a. Compilation of Quaternary Surficial Deposits.
https://maps.conservation.ca.gov/cgs/qsd/ Accessed December 2022. . 2022b. Earthquake Zone App.
https://maps.conservation.ca.gov/geologichazards/DataViewer/index.html Accessed December 2022.
. 2022c. Earthquake Zones of Required Investigation.
https://maps.conservation.ca.gov/cgs/EQZApp/App/ Accessed December 2022. . 2022d. Landslide Inventory. https://maps.conservation.ca.gov/cgs/lsi/ Accessed December 2022.

California Geological Survey (CGS). 2002. California Geomorphic Provinces, Note 36.

Huntington Park, City of. 1991. City of Huntington Park General Plan. https://www.hpca.gov/DocumentCenter/View/407/HP-General-Plan?bidId= (accessed April 2023).

Jefferson, G.T. 2010. A catalogue of late Quaternary vertebrates from California. Natural History Museum of Los Angeles County Technical Report 7, p. 5-172.

Paleobiology Database. 2023. Online fossil locality database. Available online:
https://www.paleobiodb.org/#/. Accessed April 2023.

Society of Vertebrate Paleontology (SVP). 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wpcontent/uploads/2021/01/SVP_Impact_Mitigation_Guidelines.pdf Accessed September 2022.

University of California Museum of Paleontology (UCMP). 2023. UCMP online database specimen search portal. https://ucmpdb.berkeley.edu/ Accessed April 2023.

Yerkes, R. F., T. H. McCulloh, J. E. Schoellhamer, and J. G. Vedder. 1965. Geology of the Los Angeles Basin California- an Introduction.

Hazards and Hazardous Materials
California Department of Toxic Substances Control (DTSC). 2022. EnviroStor Database. https://www.envirostor.dtsc.ca.gov/public/ (accessed September 2022).

Huntington Park, City of. 1991. City of Huntington Park General Plan. https://www.hpca.gov/DocumentCenter/View/407/HP-General-Plan?bidId= (accessed April 2023).

State Water Resources Control Board (SWRCB). 2022. GeoTracker Database. https://geotracker.waterboards.ca.gov/ (accessed September 2022).

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Los Angeles County. 2009. Airport Land Use Commission (ALUC). https://planning.lacounty.gov/aluc/airports. Accessed September 2022.

United States Environmental Protection Agency (U.S. EPA). 2023a. Learn About Asbsestos. https://www.epa.gov/asbestos/learn-about-asbestos#:~:text=into%20the%20air.- ,Health%20Effects%20From%20Exposure%20to%20Asbestos,of%20developing%20harmful %20health%20effects. (accessed April 2023).
2023b. Learn About Lead. https://www.epa.gov/lead/learn-aboutlead#:~:text=Adults%20exposed%20to%20lead%20can,in%20both%20men%20and%20wom en). (accessed April 2023).
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Hydrology and Water Quality
California Department of Water Resources (CDWR). 2015. California’s Groundwater Update 2013, South Coast Hydrologic Region. https://water.ca.gov/-/media/DWR-Website/WebPages/Programs/Groundwater-Management/Bulletin-118/Files/StatewideReports/GWU2013_Ch6_SouthCoast_Final.pdf Accessed October 2022.

California Water Board. 2014. Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties.
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CWE. 2015. Los Angeles River Upper Reach 2 Watershed Management Area (LAR UR2 WMA), Watershed Management Program (WMP) Plan.
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Population and Housing
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Draft Environmental Assessment 7-7
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Huntington Park, City of. 1991. City of Huntington Park General Plan. https://www.hpca.gov/DocumentCenter/View/407/HP-General-Plan?bidId= (accessed April 2023).

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Public Services and Recreation
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Quintero, Lemessis. 2022. Associate Planner. Personal communication via email regarding park acreage in Huntington Park with Nina Belluci, Senior Planner, Rincon Consultants, Inc.

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Transportation
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Utilities and Service Systems
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7-8
2021. 2020 Urban Water Management Plan.
https://www.hpca.gov/DocumentCenter/View/9067/Final-Draft-2020-Urban-WatershedManagement-Plan Accessed October 2022.

Los Angeles County Sanitation Districts (LACSD). 2022. Joint Water Pollution Control Plant, Plant Performance. https://www.lacsd.org/services/wastewater-sewage/facilities/joint-waterpollution-control-plant/plant-performance Accessed November 2022.

Effects Found Not to be Significant
California Department of Conservation (CDOC). 2016. California Important Farmland Finder. https://maps.conservation.ca.gov/DLRP/CIFF/ Accessed November 2022.

7.2 List of Preparers
This EA was prepared by the City of Huntington Park, with the assistance of Rincon Consultants, Inc.

Consultant staff involved in the preparation of the EA are listed below.

RINCON CONSULTANTS, INC.

Kimiko Lizardi, Principal
Ryan Luckert, Supervising Planner
Bill Vosti, Senior Planner
Lillie Colville, Environmental Planner
Mabel Chan, Environmental Planner
Appendix A
Draft 2021-2029 Housing Element Update
HCD
City of
Huntington Park
Housing Element
2021-2029
FOR ADOPTION, SEPTEMBER 18, 2023
Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 i

TABLE OF CONTENTS
I. Introduction........................................................................................................................I-1 Background.................................................................................................................. I-1 Housing Element Purpose and Content...................................................................... I-1 Relationship to Other General Plan Elements ............................................................ I-2 Summary of Public Participation................................................................................. I-2 Public Noticing.......................................................................................................................... I-3 Advisory Committee ................................................................................................................ I-3 Stakeholder Interviews and Focus Group Meetings ........................................................... I-4 Community Pop-Up Events..................................................................................................... I-6 Project Website ........................................................................................................................ I-8 Community Workshops ........................................................................................................... I-8 Survey........................................................................................................................................ I-9 City Council and Planning Commission Study Sessions.................................................... I-9 Draft Housing Element Available for Public Input................................................................ I-9 II. Housing Needs Assessment............................................................................................ II-1 Population Characteristics ......................................................................................... II-1 Population Growth Trends ..................................................................................................... II-1 Age............................................................................................................................................ II-1 Household Characteristics ......................................................................................... II-2 Overcrowding .......................................................................................................................... II-2 Housing Affordability and Overpayment.............................................................................. II-3 Employment ................................................................................................................ II-8 Housing Stock Characteristics................................................................................... II-9 Housing Type and Tenure ..................................................................................................... II-9 Housing Age and Conditions...............................................................................................II-11 Special Housing Needs............................................................................................. II-13 Persons with Disabilities.......................................................................................................II-13 Elderly .....................................................................................................................................II-16 Large Households .................................................................................................................II-18 Female-Headed Households ...............................................................................................II-18 Farm Workers ........................................................................................................................II-19 People Experiencing Homelessness ..................................................................................II-20 Extremely Low-Income Households...................................................................................II-24 Assisted Housing at Risk of Conversion .................................................................. II-26 Resources Available .............................................................................................................II-28 Cost Comparison...................................................................................................................II-31 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 ii
Future Growth Needs................................................................................................ II-33 Overview of the Regional Housing Needs Allocation ...................................................... II-33 2021-2029 Huntington Park Growth Needs...................................................................... II-33 Assessment of Fair Housing (AFH)........................................................................... II-34 Introduction............................................................................................................................ II-34 Fair Housing Enforcement and Outreach Capacity ......................................................... II-35 Integration and Segregation................................................................................................ II-36 Access to Opportunity ......................................................................................................... II-68 Disproportionate Housing Needs ....................................................................................... II-82 Analysis of Sites Inventory.................................................................................................II-104 Local Data and Knowledge................................................................................................II-111 Identification of Contributing Factors...............................................................................II-112 III. Resources and Opportunities......................................................................................... III-1 Land Resources.......................................................................................................... III-1 Financial and Administrative Resources................................................................... III-1 State and Federal Resources............................................................................................... III-1 Local Resources .................................................................................................................... III-2 Energy Conservation Opportunities.......................................................................... III-3 Availability of Infrastructure and Services................................................................ III-4 Wastewater System............................................................................................................... III-4 Potable Water System........................................................................................................... III-4 Storm Water and Drainage................................................................................................... III-5 Circulation System................................................................................................................. III-5 V. Sites Inventory ................................................................................................................V-1 Regional Housing Needs Allocation ..........................................................................V-1 RHNA Credits ..............................................................................................................V-2 Accessory Dwelling Units .....................................................................................................V-2 Pending or Approved Projects .............................................................................................V-4 Summary of RHNA Credits ...................................................................................................V-4 Inventory of Opportunity Sites ..................................................................................V-4 Suitable Sites for Affordable Housing .................................................................................V-5 Determining Realistic Capacity ............................................................................................V-5 Methodology for Site Selection ...........................................................................................V-7 Existing Opportunity Sites ....................................................................................................V-8 Rezoning to Accommodate a Shortfall of Capacity ........................................................V-11 Suitability of Nonvacant Sites ..................................................................................V-19 Environmental Constraints .......................................................................................V-23 Types of Uses, Mitigation, and Remediation ....................................................................V-23 Resources for Cleanup .......................................................................................................V-32 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 iii
Cleanup Regulations ........................................................................................................... V-33 Residential Development in Zones that Allow Nonresidential Uses ...................... V-33 Adequacy of Residential Sites Inventory in Meeting RHNA ................................... V-34 IV. Constraints...................................................................................................................... IV-1 Governmental Constraints ........................................................................................ IV-1 Land Use Controls .................................................................................................................IV-1 Off-Street Parking Requirements.........................................................................................IV-9 Requests to Develop Housing at Densities Lower Than Anticipated in the Sites Inventory............................................................................................................................... IV-11 Design Guidelines ............................................................................................................... IV-11 Local Ordinances ................................................................................................................ IV-12 Special Needs Housing...................................................................................................... IV-13 Permits and Procedures..................................................................................................... IV-22 Processing Timeframes...................................................................................................... IV-26 Fees....................................................................................................................................... IV-27 Building Codes .................................................................................................................... IV-30 Non-Governmental Constraints .............................................................................. IV-30 Environmental Constraints................................................................................................. IV-30 Hazardous Materials ........................................................................................................... IV-35 Federal and State Environmental Regulations................................................................ IV-36 Infrastructure Constraints .................................................................................................. IV-37 Market Constraints.............................................................................................................. IV-38 VI. Housing Action Plan........................................................................................................ VI-1 Goals and Policies...................................................................................................... VI-1 Provision of New Housing.....................................................................................................VI-1 Housing Conservation and Maintenance............................................................................VI-2 Removal of Governmental Constraints ...............................................................................VI-3 Provision of Adequate Housing Sites..................................................................................VI-3 Equal Housing Opportunity...................................................................................................VI-4 Housing Programs ..................................................................................................... VI-4 Provision of New Housing.....................................................................................................VI-5 Housing Conservation and Maintenance............................................................................VI-7 Removal of Constraints ...................................................................................................... VI-12 Provision of Adequate Housing Sites............................................................................... VI-16 Equal Housing Opportunities............................................................................................. VI-20 Quantified Objectives for 6th Cycle........................................................................ VI-25 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 iv

LIST OF TABLES
Table II-1 Population Trends 2000-2020 Huntington Park vs. SCAG Region............................. II-1 Table II-2 Population by Age and Sex Huntington Park ................................................................ II-2 Table II-3 Overcrowding by Tenure Huntington Park and SCAG Region .................................. II-3 Table II-4 Income Categories and Affordable Housing Costs Los Angeles County................... II-4 Table II-5 Percentage of Income Spent on Rent Huntington Park .............................................. II-4 Table II-6 Percentage of Income Spent on Rent by Income Category Huntington Park ...................................................................................................................................... II-5 Table II-7 Median Home Sales Price for Existing Homes Huntington Park and SCAG Region ................................................................................................................................. II-6 Table II-8 Monthly Mortgage Cost Huntington Park and SCAG Region ..................................... II-6 Table II-9 Monthly Mortgage Cost by Income Category Huntington Park................................... II-7 Table II-10 Overpayment by Income Category Huntington Park.................................................... II-7 Table II-11 Employment by Industry Huntington Park ..................................................................... II-8 Table II-12 Employment by Occupation Huntington Park vs. SCAG Region ............................... II-9 Table II-13 Housing by Type Huntington Park and SCAG Region ............................................... II-10 Table II-14 Housing by Tenure Huntington Park and SCAG Region ........................................... II-10 Table II-15 Housing Tenure by Age of Householder Huntington Park......................................... II-11 Table II-16 Vacant Units by Type Huntington Park and SCAG Region ....................................... II-11 Table II-17 Age of Housing Stock Huntington Park and SCAG Region ...................................... II-12 Table II-18 Disabilities by Type Huntington Park............................................................................. II-13 Table II-19 Disabilities by Type for Seniors 65+ Huntington Park and SCAG Region .............. II-14 Table II-20 Developmental Disabilities by Residence and Age Huntington Park........................ II-15 Table II-21 Elderly Households by Income and Tenure Huntington Park ................................... II-17 Table II-22 Household Size by Tenure Huntington Park ............................................................... II-18 Table II-23 Household Type by Tenure Huntington Park .............................................................. II-19 Table II-24 Employment in the Agricultural Industry Huntington Park ........................................ II-20 Table II-25 Extremely Low-Income Households Huntington Park ............................................... II-25 Table II-26 Summary of At-Risk Units .............................................................................................. II-27 Table II-27 Qualified Entities .............................................................................................................. II-29 Table II-28 Estimated New Construction Costs (Huntington Park) .............................................. II-32 Table II-29 Rent Subsidies Required to Preserve At-Risk Rental Units........................................ II-33 Table II-30 2021-2029 Regional Housing Growth Needs Huntington Park ................................. II-34 Table II-31 Fair Housing Foundation Complaints ............................................................................ II-36 Table II-32 Cost-Burdened Households by Tenure, Huntington Park, 2015 and 2018 ............ II-82 Table II-33 Substandard Units ........................................................................................................... II-88 Table II-34 Housing Problems by Tenure ........................................................................................ II-88 Table II-35 TCAC Scores by Census Tract ...................................................................................II-106 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 v
Table II-36 Number of Units by TCAC Opportunity Category ....................................................II-106 Table II-37 Number of Units by Percentage of Lower and Moderate Income Households in Census Tract...............................................................................................................II-107 Table II-38 Number of Units by Median Household Income of Census Tract ...........................II-107 Table II-39 Number of Units by Median Household Income of Census Tract ...........................II-108 Table II-40 Number of Units by Housing Need Factors of Census Tract ...................................II-109 Table II-41 Sites Inventory by Census Tract Characteristics.......................................................II-110 Table IV-1 Residential Land Use Designations Huntington Park General Plan ..........................IV-2 Table IV-2 Permitted Residential Development by Zoning District ...............................................IV-4 Table IV-3 Residential Development Standards (Commercial and Residential Zoning Districts) .............................................................................................................................IV-6 Table IV-4 Residential Development Standards (Downtown Specific Plan) ...............................IV-7 Table IV-5 Residential Parking Requirements .............................................................................. IV-10 Table IV-6 Planning Fees ................................................................................................................. IV-28 Table V-1 Huntington Park Housing Needs for 2021 – 2029 .........................................................V-1 Table V-2 Los Angeles County Maximum Rent by RHNA Income Category...............................V-2 Table V-3 Accessory Dwelling Unit Production City of Huntington Park......................................V-2 Table V-4 Affordability Breakdown of Rented ADUs .......................................................................V-3 Table V-5 Projected ADU Production Between 2021-2029 Affordability Assignment................V-3 Table V-6 Pending or Approved Projects..........................................................................................V-4 Table V-7 Credits Towards RHNA......................................................................................................V-4 Table V-8 Typical Densities of Multifamily Residential Projects in the Gateway Cities ..............V-6 Table V-9 Residential Capacity of Opportunity Sites and RHNA Shortfall ...................................V-9 Table V-10 Total Residential Capacity of Rezoned Parcels in Future Station Areas ................. V-17 Table V-11 Development Standards in the Willowbrook Specific Plan........................................ V-18 Table V-12 Development Standards in the North Paramount Gateway Specific Plan............... V-18 Table V-13 Existing Uses of Nonvacant Sites.................................................................................. V-20 Table V-14 Comparison of Development Standards ...................................................................... V-21 Table V-15 Housing Opportunity Sites, Existing Conditions.......................................................... V-25 Table V-16 Summary of Adequate Opportunity Sites .................................................................... V-34 Table V-17 Housing Opportunity Sites in the Downtown Specific Plan....................................... V-36 Table V-18 Housing Opportunity Sites Within ½ Mile of Planned Light Rail Station.................. V-42 Table VI-1 Quantified Housing Objectives ..................................................................................... VI-25 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 vi

LIST OF FIGURES
Figure II-1 Homeless County by Subpopulation, Service Planning Area 7, 2022...................... II-22 Figure II-2 Characteristics of Homelessness, Los Angeles County, 2022 .................................. II-22 Figure II-3 Characteristics of Homelessness, Los Angeles County, 2022 .................................. II-23 Figure II-4 Racial Demographics (2018), Huntington Park............................................................ II-38 Figure II-5 Racial Demographics (2018), Los Angeles Region..................................................... II-39 Figure II-6 Predominant Population – Hispanic Majority, Huntington Park................................. II-40 Figure II-7 Predominant Population – Hispanic Majority, Los Angeles Region .......................... II-41 Figure II-8 Diversity Index (2018), Huntington Park ....................................................................... II-42 Figure II-9 Diversity Index (2018) Los Angeles Region ................................................................. II-43 Figure II-10 Population with a Disability By Census Tract (2014), Huntington Park.................... II-46 Figure II-11 Population with a Disability by Census Tract (2019), Los Angeles Region ............. II-47 Figure II-12 FHEO Cases – Disability Bias (2020), Huntington Park .............................................. II-48 Figure II-13 FHEO Cases – Disability Bias (2020), Los Angeles Region ....................................... II-49 Figure II-14 Percent of Children in Married-Couple Households (2019), Huntington Park ........ II-52 Figure II-15 Percent of Children in Married-Couple Households (2019), Los Angeles Region................................................................................................................................ II-53 Figure II-16 Percent of Children in Female Householder, No Spouse/Partner Present Households (2019), Los Angeles Region...................................................................... II-54 Figure II-17 Percent of Adults Living with Spouse/Partner (2019), Huntington Park .................. II-55 Figure II-18 Percent of Adult Population Living Alone (2019), Los Angeles Region ................... II-56 Figure II-19 Percent of Population 18 Years and Older in Households Living Alone (2019), Los Angeles Region......................................................................................................... II-57 Figure II-20 Poverty Status By Census Tract (2019), Huntington Park ......................................... II-59 Figure II-21 Low to Moderate Income Population, Los Angeles County....................................... II-60 Figure II-22 Median Income (2019), Huntington Park...................................................................... II-61 Figure II-23 Median Income (2019), Los Angeles Region ............................................................... II-62 Figure II-24 Racially or Ethnically Concentrated Areas of Poverty (2009-2013), Huntington Park .................................................................................................................................... II-64 Figure II-25 Racially or Ethnically Concentrated Areas of Poverty (2009-2013), Los Angeles Region ................................................................................................................ II-65 Figure II-26 TCAC Area of High Segregation and Poverty (2021), Huntington Park .................. II-66 Figure II-27 TCAC Areas of High Segregation and Poverty (2021), Los Angeles Region.......... II-67 Figure II-28 TCAC Opportunity Areas – Composite (2021) Huntington Park............................... II-72 Figure II-29 TCAC Opportunity Areas – Composite (2021), Los Angeles Region....................... II-73 Figure II-30 TCAC Opportunity Areas – Educational Opportunity (2021), Huntington Park ...... II-74 Figure II-31 TCAC Opportunity Areas – Educational Opportunity (2021), Los Angeles Region................................................................................................................................ II-75 Figure II-32 TCAC Opportunity Areas – Economic Score (2021), Huntington Park.................... II-76 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 vii
Figure II-33 TCAC Opportunity Areas – Economic Score (2021), Los Angeles Region .............II-77 Figure II-34 TCAC Opportunity Areas – Environmental Score (2021), Huntington Park ............II-78 Figure II-35 TCAC Opportunity Areas – Environmental Score (2021), Los Angeles Region......II-79 Figure II-36 CalEnviroScreen 4.0 (2021), Huntington Park .............................................................II-80 Figure II-37 CalEnviroScreen 4.0 (2021), Los Angeles Region.......................................................II-81 Figure II-38 Overpayment by Renters (2019), Huntington Park .....................................................II-84 Figure II-39 Overpayment by Renters (2014), Los Angeles Region...............................................II-85 Figure II-40 Overpayment by Homeowners (2019), Huntington Park............................................II-86 Figure II-41 Overpayment by Homeowners (2014), Los Angeles Region.....................................II-87 Figure II-42 Percent of All Households with Any of the 4 Severe Housing Problems, Huntington Park ................................................................................................................II-90 Figure II-43 Percent of All Households with Any of the 4 Severe Housing Problems, Los Angeles Region.................................................................................................................II-91 Figure II-44 Overcrowded Households, Huntington Park ................................................................II-94 Figure II-45 Overcrowded Households, Los Angeles Region .........................................................II-95 Figure II-46 Severely Overcrowded Households Huntington Park.................................................II-96 Figure II-47 Severely Overcrowded Households Los Angeles Region..........................................II-97 Figure II-48 Social Vulnerability Index (2018), Huntington Park ...................................................II-100 Figure II-49 Social Vulnerability Index (CDC, 2018), Los Angeles Region..................................II-101 Figure II-50 Sensitive Communities, Huntington Park....................................................................II-102 Figure II-51 Sensitive Communities, Los Angeles Region.............................................................II-103 Figure IV-1 Areas In The City of Huntington Park Subject to Potential Liquefaction ................ IV-33 Figure V-1 Opportunity Sites in the Downtown Specific Plan Area............................................. V-10 Figure V-2 Opportunity Sites Within One-Half Mile of the Slauson/Long Beach Transit Station ............................................................................................................................... V-14 Figure V-3 Opportunity Sites Within One-Half Mile of the Pacific/Randolph Transit Station ............................................................................................................................... V-15 Figure V-4 Opportunity Sites Within One-Half Mile of the Florence/Salt Lake Transit Station ............................................................................................................................... V-16 Huntington Park 2021-2029 Housing Element Table of Contents For Adoption September 18, 2023 viii
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Huntington Park 2021-2029 Housing Element Introduction
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I. INTRODUCTION
Background
The City of Huntington Park is one of the cities that makes up the Gateway Cities district of southeastern Los Angeles County. The City is three square miles, bounded by the unincorporated community of Florence-Graham to the west, the City of Vernon to the north, three Gateway Cities to the east, and the City of South Gate to the south. Huntington Park is surrounded by major highway connections with Interstate 5 and 10 to the North, I-710 to the east, I-105 to the south, and I-110 to the west.

Since its incorporation in 1906, Huntington Park has been known for its central location and easy access to nearby cities. Located approximately six miles south of Downtown Los Angeles, 15 miles northeast of Los Angeles International Airport Huntington Park, and with proximity to major highways, Huntington Park is well-situated for regional connectivity. Huntington Park originally developed as a streetcar suburb for industrial workers in the early 1900s. The Gateway Cities region was largely developed amid a boom in manufacturing that focused Los Angeles County’s industrial production in areas southeast of Downtown Los Angeles. The city of Huntington Park and surrounding cities became home to much of the County’s industry sector, as well as a home to those working-class industry workers that serviced this economy. Like many Gateway Cities, Huntington Park’s proximity to historical and current industrial activities has left a legacy of pollution, and the city experiences a higher pollution burden than the rest of the region and the state.

Huntington Park is a majority Hispanic/Latino community. U.S. Census data shows that over 90 percent of the city’s population speaks a language other than English at home. Furthermore, some data sources show that up to 25 percent of the City’s population is undocumented, which could mean that the City’s population data may not fully count all residents of the city. Undocumented status can contribute to housing instability and a household’s ability to access services. The city’s population is disproportionately cost-burdened, meaning that households spend more than 30 percent of their income on rent. Huntington Park is one of the densest cities in the country, and high housing costs and low inventory have contributed to overcrowded housing conditions disproportionate to the region.

The city is nearly entirely built out, with very little vacant or underutilized land available for development. This Housing Element’s Site Inventory consists of sites in several opportunity areas— the Downtown Specific Plan area along Pacific Boulevard, and the areas around three planned LA Metro stations at Slauson Avenue and Long Beach Avenue, Pacific Boulevard and Randolph Street, and Florence Avenue and Salt Lake Avenue.

Housing Element Purpose and Content
Pursuant to Government Code Section 65302, the General Plan must include the following elements: land use, housing, circulation, noise, safety, conservation, open space, and environmental justice. As mandated by California Government Code Section 65581, the Housing Element is the only element required to be updated on a routine basis, every eight years. The Housing Element is a comprehensive strategy for providing safe, decent, and affordable housing for all residents. The Housing Element must include:

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-2
• Identification and analysis of existing and projected housing needs, resources, and constraints;
• Identification of adequate sites for housing to meet the existing and projected needs of all economic segments of the community; and
• Goals, policies, quantified objectives, and scheduled programs for preservation, improvement, and development of housing.

The Housing Element helps the City determine how to address existing and future housing needs and plan for future growth by establishing actions and priorities for housing programs. This Housing Element was prepared for the planning period of October 2021 to October 2029, and represents the 6th Housing Element cycle.

Relationship to Other General Plan Elements
Huntington Park’s General Plan was adopted in 1991 and consists of the Land Use, Housing, Circulation, Open Space and Conservation, Safety, Noise, Public Facilities, and Urban Design elements. All elements bear equal weight, and no element has legal precedence over another.

California Government Code Section 65583(c) requires the Housing Element to maintain internal consistency with other General Plan Elements.

Two other elements have recently been updated or are being updated at the time of publishing this Housing Element, as required by state law.
• Senate Bill (SB) 1000 (2016) amended Government Code Section 65302 to require that cities and counties that have disadvantaged communities to incorporate environmental justice policies into their general plans, either in a separate environmental justice element or by integrating related goals, policies, and objectives throughout the other elements upon the adoption or next revision of two or more elements concurrently. The City prepared a stand-alone Environmental Justice Element, which was adopted November 15, 2022. • Safety elements must be updated during each update of the Housing Element if additional information relating to climate adaptation or resilience becomes available. The City’s Safety Element update is in progress at the time of publishing this Housing Element update.

Summary of Public Participation
The Housing Element update process began in early 2021, with a draft first released for public review July 9 to August 6, 2021. The California Department of Housing and Community Development reviewed that draft and a subsequent draft, and provided comments necessitating additional data collection, public input, and analysis. This draft addresses the comments from HCD and reflects the additional analysis, and a summary of the additional community outreach follows.

The Housing Element must reflect the values and preferences of the community. Accordingly, community participation is an important component of the development of this Element.

Government Code Section 65583(c)(8) states that the local government must make “a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element.” This process not only includes community members, but also participation from local agencies and housing groups, community organizations, and housing developers.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-3
In 2021, the City released a housing survey, held two community workshops, and a study session with the City Council and Planning Commission. In 2022, as part of revisions to the City’s Housing Element draft originally released in 2021, the City re-engaged the community to solicit more input from stakeholders and community members. Community engagement events in 2022 included meetings with the City’s Environmental Justice Advisory Committee, stakeholder interviews with service providers and housing developers, community pop-up events, a project-specific website, in-person and virtual community workshops, and study sessions with decision makers. A complete record of the public engagement program is available in Appendix A.

Public Noticing
To reach the largest and broadest spectrum of community members and stakeholders, Huntington Park utilized the following notification methods throughout the Housing Element update process:
• Regular posts to the City’s social media accounts, including Facebook, Twitter, and Instagram, announcing community workshops, study sessions, and public comment periods.
• City staff developed email and mailing lists of community and advocacy groups, non-profits, faith-based organizations, and school-based organizations to provide outreach and regular updates about the Housing Element, Environmental Justice Element, and Safety Element Updates.
• The interested parties email list was regularly maintained and included community members who had signed up on the project website, at community pop-up events, and at community workshops.
• The City developed flyers in English and Spanish advertising the project. City staff handed out flyers at community pop-up events. See Appendix A for example flyers.

Advisory Committee
An advisory committee was established to discuss and obtain input primarily on environmental justice issues. The advisory committee consists of the following 12 community members:
• Laura Cortez, East Yard Communities for Environmental Justice • Eileen Garcia, Tree People
• Dr. Wilma Franco, Southeast Los Angeles Collaborative • Carol Xochimitl, HUB Cities
• Laura Avila, Human Services Association
• Areli Caballero, College Student (Environmental Science Major) • Mia Calderon, Youth Resident
• Miguel Vargas, Community Resident
• Chris Aguilar, Community Resident
• Ana Michel, Small Business Owner/Resident
• Ricardo Barbosa, Planning Commissioner
• Alicia Rodarte, AltaMed
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For Adoption September 18, 2023 I-4
While the committee was formed to support development of the City’s Environmental Justice Element (adopted November 15, 2022), the members also provided valuable insight on affirmatively furthering fair housing issues and policy development at its July 12, 2022, August 13, 2022, and September 13, 2022, meetings. Members also received a presentation on the ongoing Safety Element Update and provided input on climate vulnerability issues to inform the development of the Safety Element.

The advisory committee reviewed the proposed sites inventory, initial AFFH findings, and proposed policies addressing AFFH issues and provided the following comments related to housing:
• Concerns about concentrating lower-income housing in any one area of Huntington Park, i.e., a preference to distribute lower-income housing throughout the city. • Concerns with constructing housing near areas with high pollution and contamination, specifically sites around the planned Slauson/Long Beach and Pacific/Randolph transit stations due to contamination and pollution from industrial uses in the area. • Identified six sites in the downtown specific plan (DTSP) for development to provide lowerincome housing. • Support of programs related to inclusionary housing and rent control. • Identified higher concentration of people with disabilities in downtown area because of public transportation that runs through that area creating more opportunities for access for people who cannot drive.
• Identified higher educational outcomes in certain areas because of concentration of charter schools, which put a lot more emphasis on STEM education. Also, identified high education attainment located on the westside because two high schools are located there, so educational attainment scores could be related to school access. • Concerns about the affordability of living in Huntington Park and how it leads to overcrowding. There should be programs to help address the cost and subsidize it. • Support for a rent escrow program to help keep landlords and property managers accountable.

Stakeholder Interviews and Focus Group Meetings
As part of the outreach process, the City reached out to various stakeholder representatives, service providers, and housing developers to inform the organizations about the Housing Element Update. Staff asked that the organizations participate in a stakeholder interview to share their organization’s experience with affordable and attainable housing in Huntington Park and other Los Angeles gateway communities.

In August 2022, the City met with representatives from the following community-based organizations and/or service providers:
• Advocates for Human Potential, an organization that advises local governments on accessing funding and developing strategies around housing and homelessness. • Hub Cities Consortium, which provides job training and placement to residents of the Gateway Cities, with some specialized programs for people transitioning out of homelessness.

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• Southeast Community Development Corporation, which has community and technology centers in nearby Bell and Cudahy, and provides education for children and adults on technology, and new programs to educate first-time homebuyers on the homebuying process.
• Gateway Cities Council of Governments, the subregional government for the Gateway Cities, with a number of housing-related Regional Early Action Planning Grant-funded programs to help Gateway Cities meet their housing needs.

These interviews covered the following topic areas:
• The housing issues faced by the organization’s clientele • What the City of Huntington Park is doing well to address housing issues • What solutions other similar or nearby cities have developed that have been effective at addressing housing issues in the region
The City met with affordable and market-rate housing developers including BRIDGE Housing, National CORE, NewStart Housing, and Warmington Residential. Not all developers had worked in Huntington Park, so the questions focused on development processes and regulations generally.

Discussion topics included:
• Potential for building in Huntington Park
• Parking standards, open space requirements, density, and other development standards • The value of a by-right development process vs. a discretionary process • Developers’ experience using new state streamlining laws to help speed up the process of development
• Examples of processes or new regulations implemented by similar or nearby cities that have been effective at increasing housing production
• Challenges in redeveloping formerly industrial and/or contaminated land • Challenges in developing smaller, nonvacant, and/or infill sites common in Huntington Park Focus Group Meeting with Communities for a Better Environment On Monday, August 29, 2022, the City met with Communities for a Better Environment (CBE) to present and discuss key components of the Housing Element Update, including housing constraints, affirmatively furthering fair housing, and developing the housing sites inventory. The presentation was translated in Spanish verbally and written form. At the end of the presentation, attendees were able to provide the following comments and questions:
• What will be the City’s process for environmental cleanup before development? We want to encourage environmental cleanup before development.
• What other efforts besides the Downtown Specific Plan are there to develop housing? How much affordable housing will the City require for each of these projects? • Because there are three transit sites, does that mean the City will create a transit-oriented development? For the amount of housing that is required, we are concerned about prioritizing the very low income and low income when there are four income levels, when the City does not have a TOD policy.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-6
• How does the City meets its regional housing needs assessment for moderate income and above? Why is the City prioritizing these income levels when the community needs more affordable housing for low income and very low income?
• What is the City doing to ensure housing is available for other vulnerable populations, such as seniors and those with disabilities? What about transitional housing and senior supportive housing?
• We know that residents lack access to parks and green spaces. What is the City’s plan to ensure that residents will have access to parks and green spaces when building new housing?
• What has the City done to address lead and asbestos contamination in housing? What other programs are the City trying to address these issues and maintain poor quality housing? We need it.
• A comment on what we have seen other cities doing. Bell Gardens passed rent control up to four percent cap. We would like to see a similar policy in Huntington Park.

Community Pop-Up Events
The City hosted an informational booth at the City’s farmers market to distribute flyers, advertise upcoming community workshops, and gather input from the community on housing needs, fair housing issues and climate vulnerabilities. The City’s farmers market is a well-attended and reliable community event held every Wednesday. The pop-up events were held from 8:30 am – 1:30 pm on August 17, August 31, and September 7, 2022. Two of the community pop-up events included interactive posters and a raffle giveaway to incentivize participation and to collect community input for updates to the Housing Element and Safety Element. All materials at the pop-up events were provided in both English and Spanish. Also Spanish facilitation was utilized to prevent language barriers in participation. Informational flyers about the housing element, focused general plan updates and upcoming events were distributed and included a QR code so participants could conveniently access the project website from their cell phones for additional information. The following summarizes the input received from the three interactive pop-up events. See Appendix A for the interactive posters, pictures, and public comments collected.

August 17, 2022 Farmers Market
The City set up a booth at the farmers market on August 17, 2022. The objective of this pop-up event was to distribute flyers advertising upcoming workshops and collect public comments related to housing, safety, and environmental justice. An email sign-up sheet was available to expand the interested parties’ email list. Open-ended comment cards were available, and the following comments were collected:
• School traffic is causing public safety issues for residents. • I would like them to take action on Randolph and Milles Street, especially that [drivers] do not double park, respect driveways and do not block pedestrian pathways. • Illegal body shop on Newell and Gage Street; paint cars and they do not have adequate security. In front there are a lot of cars that they don’t serve, and this is unsafe for our kids that walk through there from school.

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August 31, 2022 Farmers Market
The City set up a booth at the farmers market on August 31, 2022 with two interactive posters available to spark conversation about and gain input for the Housing and Safety element updates.

Once participants gave feedback, their name was entered into a raffle, a total of four names were drawn and each person received a $50 gift card. The team also distributed flyers advertising the two study sessions as well as an educational flyer on the overall General Plan update. Based on the input from the interactive posters and conversations with participants, the main themes for each element were:

Housing
• Rent is too high, and housing is unaffordable.
• Rent control is needed.
• Residents have experienced poor housing conditions, paying too much, and overcrowding. • More programs are needed to support homeownership, housing repairs, and renters rights/rent control/rent assistance.

Safety
• Worsened air quality is the biggest climate concern.
• Power often goes out and many people experience fatigue during heat waves. • Want education on how to protect yourself from heat and climate change. • More education opportunities on placing solar panels in homes. • Better and safer public transit.

September 7, 2022 Farmers Market
The September 7th farmers market pop-up event included the same interactive posters and a raffle activity as the August 31st event. The intent was to continue to collect community input regarding housing needs, fair housing, and climate vulnerabilities. Based on the input from the interactive posters and conversations with participants, the main themes for each element were similar to the August 31st event. For housing these included the high cost of rent and housing affordability, poor housing conditions including overcrowding; and suggestions to support more programs for homeownership, repairs, and renter’s rights. For safety these included worsening air quality and increased heat waves. The following summarizes some of the additional input provided by the community:

Housing
• Poor housing quality and limited code enforcement.
• Concerns about homelessness and public safety in neighborhoods. • Suggested housing programs included first-time homebuyer programs, lowering rents, landlord-renter mediation services, and education regarding affordable housing and home ownership as well as educational programs for youth.

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Safety
• Health risks associated with heat waves for children and adults, including heat sickness, nausea, dizziness, blood pressure issues.
• Suggested programs included cooling areas, tree planting and shade programs, energy/electricity programs, community outreach, programs and activities for seniors (e.g., swimming programs for seniors).

Project Website
The City’s website hosted and created a separate dedicated project website. The project website served as a key information hub where residents could see all events listed, find links to join meetings, and various other ways to get involved. The project website provided detailed background information on the Housing Element, Environmental Justice Element, and Safety Element updates including the purpose of each element, informational videos, and links to the City’s previous educational websites.
• The City’s housing element website is available at www.hpca.gov/787/Housing-Element. • The City’s new housing element website (described below) is available at www.huntingtonparkgpupdates.com.

Project materials associated with each element were updated regularly on the websites, including information for upcoming events, and virtual workshop PowerPoint presentations and video recordings. A form on the website enabled people to sign up for project email updates and provide comment at any time throughout the project process. The City’s housing element web page and the dedicated project website were available in English and Spanish.

Community Workshops
Workshops Hosted in 2021
In 2021, the City hosted two educational community workshops. On July 1, 2021, the City explained its past non-compliance with Housing Element requirements, new requirements and the 6th Cycle Housing Element update, and the Regional Housing Needs Allocation (RHNA) requirements. On August 2, 2021, the City hosted a second workshop to provide information about resources and opportunities in Huntington Park, constraints to development, and the housing action plan. Both workshops provided the opportunity for community members to ask questions.

Workshops Hosted in 2022
In 2022, workshops for the Housing Element were held both virtually and in person during the month of August. These workshops were hosted on two formats to encourage broader community engagement of community members and prioritize safety of those who are not able to attend inperson events due to the COVID-19 pandemic. The workshops held on August 23 and 24, 2022, focused on the Housing Element update process, key concepts related to fair housing, the Safety Element update, and opportunities for community members to stay involved in the process.

Attendees had the opportunity to answer pre-written polling questions and questionnaires on housing needs and conditions. Due to low attendance at the workshops, the virtual workshop presentations were also posted to the project website, described above. There were forms on the project website also by which community members could submit comments and provide feedback.

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Survey
In June 2021, the City circulated a survey to ask stakeholders and community members questions regarding housing needs and current conditions. Survey questions focused on satisfaction with their current housing, physical conditions of their housing, satisfaction with housing options in Huntington Park, housing types, community amenities, home ownership barriers, rezoning, housing concerns, and demographic questions. There were 130 responses to the survey.

City Council and Planning Commission Study Sessions
The City held study sessions with the City Council as well as public hearings with the Planning Commission and City Council following release of the Draft Housing Element.

May 13, 2021 – City Council and Planning Commission Study Session The City hosted a joint study session with the City Council and Planning Commission that was open to the public on May 13, 2021. The presentation described existing challenges and Housing Element requirements, including special needs housing and the RHNA. All material was translated into Spanish. The presentation concluded with the opportunity for decision makers and community members to ask questions and provide comments.

August 31, 2022 – Planning Commission Study Session
The City hosted a study session with the Planning Commission that was open to the public on August 31, 2022. At this study session, the City explained the objectives and requirements for the Environmental Justice Element, including current conditions in Huntington Park; the Housing Element, including fair housing practices and sites inventory; and the Safety Element, including current hazard conditions and potential climate change impacts. The presentation was given in person and via Zoom and Spanish translation services were provided.

September 6, 2022 – City Council Study Session
The City hosted a study session with the City Council that was open to the public on September 6, 2022. At this study session, the City explained the objectives and requirements for the Environmental Justice Element, including current conditions in Huntington Park; the Housing Element, including fair housing practices and sites inventory; and the Safety Element, including current hazard conditions and potential climate change impacts. The presentation was given in person and via Zoom and Spanish translation services were provided.

Draft Housing Element Available for Public Input
The draft Housing Element was first released for public review from July 9, 2021, to August 6, 2021.

The draft Housing Element was posted to the City’s website and a notice was emailed to interested parties.

September 15, 2023 Draft
After revisions that were required to address comments from HCD, the draft Housing Element was released for public review September 15, 2023, for the minimum statutorily required seven days.

The Housing Element was posted on the project website, and a notice was emailed to all interested parties.

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Two comments were received. Both comments expressed support for housing strategies, policies, and programs that provide opportunities for home ownership. Section V, Housing Action Plan, provides policies and programs to balance the need for rental housing with the need for for-sale housing (both of which were substantiated by a review of demographic data and community input).

Policy 1.1 supports existing and potential new programs that support home ownership (financial assistance and policies to increase the supply of affordable for-sale housing). Program 1 contains a number of actions to promote, augment, and continue existing financial assistance programs for first-time homebuyers. Program 5, Preservation of At-Risk Units, contains actions through which the City will explore the feasibility of tenant opportunity to purchase programs, which could expand opportunities for lower-income households to purchase existing rental units. Inclusionary requirements for for-sale projects referenced in Policy 1.1 may be adopted under Action 11-3, which would build on subregional inclusionary studies and strategies done by the Gateway Cities Council of Governments.

One comment letter from Communities for a Better Environment (CBE), the Public Interest Law Project, and Disability Rights California was received after the public comment period had closed, on October 17, 2022. This comment letter was considered in the preparation of the subsequent draft and by HCD as a third-party comment.

The draft was submitted to HCD for review on September 27, 2023, and a letter of findings from HCD was received November 10, 2022.

January 10, 2023 Draft
A draft addressing public comments and findings from HCD’s review was published for the statutorily required seven days on January 10, 2023. The Housing Element was posted on the project website, and a notice was emailed to all interested parties.

One comment letter from CBE et al was received on January 17, 2023. The following changes were made to address comments in the January 17 CBE et al letter:

Comment Response
The advisory group committee mentioned on page I-3 was not an advisory committee formed for the explicit purposes of commenting on the Housing Element, but rather for commenting on the creation of the Environmental Justice Element, that the City was required to complete. Only one meeting was set aside to discuss the Housing Element explicitly and that meeting was not attended by the majority of the Environmental Justice Advisory Committee.

Clarified the purpose of the Advisory Committee and the specific meetings at which the Housing Element was
discussed. (Page I-3)
On page I-9, the last public review of the Housing Element draft dated, September 15, 2023, refers to the 7 days that was set aside for public comment as required. A 7 day comment letter period is not the requirement but rather the minimum amount,“[f]or any subsequent draft revision, the local government shall post the draft revision on its internet website and shall email a link to the draft revision to all individuals and organizations that have previously requested notices relating to the local government’s housing element at least seven days before submitting the draft revision to the department.”
Clarified that the seven-day public review period is the minimum statutorily required review period. (Page I-9)
There is no mention on pages I-9 and I-10 of our letter dated October 17, 2022 and sent to Mr. Steve Forster, Director, Department of Community Development. Please see Attachment 1 for further reference.

Added reference to comment letter from CBE et al on
September 15, 2023, draft. (Page I-10)
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Comment Response
Concern that there is no homeless shelter in the City of Huntington Park and the City does not administer a homeless prevention program. Under SB 2 (effective January 2008) amended the California’s Housing Accountability Act (HAA) to require local governments to take specific zoning actions to encourage the development of emergency shelters and transitional and supportive housing. Suitability of a zone for emergency shelter uses is determined by examining what other uses are permitted in that zone, and whether those uses are generally compatible with residential and shelter use. On pg. IV-14 “[e]mergency shelters with up to 30 beds are permitted by right in the Industrial/Manufacturing Planned Development (MPD) zone and emergency shelters with more than 30 beds are conditionally permitted in the C-G (General Commercial) zone,” this proposed zoning raises concerns as it is noted that there are many industrial uses in the City that are sources of pollution that may impact public health. It would be inappropriate to site emergency shelters in these zones by right as it is likely to pose health risks.

The City provides funding to nonprofits to support
homelessness programs, described in detail in Chapter 2, Housing Needs Assessment. Chapter 2 and Chapter 3,
Constraints, describe in detail the need for emergency
shelters, and transitional and supportive housing to serve the City’s homeless population and the barriers to developing those facilities. Program Housing Element Program 7 contains provisions to modify the zoning code to facilitate emergency shelters and seek funding for the development and operation of emergency shelters. Emergency shelters will also be
allowed in the new Transit-Oriented Development Overlay District, and a clarifying statement has been added to Action 10-5. Programs 7 and 13 contain provisions to modify the zoning code to facilitate transitional and supportive housing and seek funding for the development and operation of such facilities.

Concerns over developers’ statement that “required open space often goes unused,and can constrain their ability to achieve the maximum density allowed.” While the City’s RHNA will likely amount to more density, we do not feel that development of units should sacrifice open space. The City is park poor and admittedly very dense and in order to provide residents some open space developers should be asked to incorporate open space design elements in their projects.

Open space and green space have shown to provide positive health impacts to communities.

The Housing Element acknowledges (consistent with the
Environmental Justice Element adopted November 15, 2022) that the increased provision of open space is crucial to creating more equitable access to resources throughout the city. The Housing Element does not commit to reducing open space
requirements, only that those requirements will be the subject of ongoing outreach to determine the most effective way to provide open space in new development while ensuring
projects develop at densities that will meet the City’s obligations under the Housing Element. The provision of open space throughout the City will be addressed comprehensively through Program 14.

We appreciate the acknowledgment that Slauson/Long Beach and Pacific/Randolph “have high pollution exposure” and that soil remediation may be required. However, given that a proposed TOD ordinance might create streamlined, administrative approval for qualifying projects how exactly will the City ensure safeguards from vapor intrusion, soil contamination, air emissions, etc. for projects sited in these areas.

Policy 4.7 in the January 9, 2023, HCD Review Draft of the Housing Element requires environmental remediation for
development of all properties near or with on-site
contamination.

Creating Green City Ordinance is a positive step, but we would like to see the City adopt a “Building Decarbonization” ordinance. The City has the opportunity to encourage all new buildings that come online to be completely electrified. As a City that has been negatively impacted by a multiple sources of pollutions for decades ensuring that new buildings are built with electrification in mind can help reduce indoor pollution that comes from burning gas stoves and gas heaters. Furthermore, encouraging electrification in new building can help reduce Green House Gas emissions originating from buildings.

The City may consider a building electrification ordinance in the future. However, it is recommended that this be done more holistically and in concert with a more comprehensive carbon reduction strategy. The preparation of a future ordinance should consider additional cost burden or displacement risk to vulnerable communities, the phasing of implementation,
funding strategies, regulatory barriers, and coordination with utility providers and other agencies.

Concerns over the proposed Action 13-1, Protecting Existing Residents from Displacement. This draft Housing Element covers how many residents are in fact rent burdened and many families would qualify for being considered Very Low Income and Extremely Low Income, however there is no discussion anywhere in this Housing Element on Rent Control or Just Cause Evictions. The City is aware that many of its proposed sites for development would create projects in the Downtown area but it does not acknowledge how such development can cause gentrification and in turn cause The language in Action 13-1 has been modified to clarify that the City will adopt local regulations aimed at protecting existing residents from displacement, examples of which are listed in Action 13-1. Based in this comment, a rent control or just cause eviction ordinance has been added to the list of local regulations that will be considered. Action 13-5 has been added as an interim measure to provide residents with
information about statewide regulations and Action 13-6 has Huntington Park 2021-2029 Housing Element Introduction
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Comment Response
displacement. Having programs such as rent control and just cause eviction protections can help with community stability. It is not enough to do tenants workshop, right of return requirements if tenants are unable to pay the current rent. A rent control ordinance can help protect tenants from land speculators and unjust rent increases.

Furthermore, just cause eviction protections will dissuade unsubstantiated unlawful detainer filings.
been added to commit the City to adopt a local relocation plan that complies with and implements state law.

Action 13-2. Homeless Services and Housing. Rather than invest in the City of Huntington Park Police Department participating in SERMET, it may be better to create an actual team of specialists that can help with mental health crises. Historically, police departments are not the best equipped in mental health and homeless outreach.

Working with different County services maybe be a better partnership than allowing for the police to manage these sensitive cases.

SERMET is a successful regional program that the Huntington Park Police Department participates in along with police departments from other southeast Los Angeles cities, together with the Los Angeles County Department of Mental Health.

Action 13-2 contains other provisions to support homelessness programs, emergency housing assistance, and the
development and operation of housing for people experiencing homelessness.

The draft was submitted to HCD for review on February 7, 2023. An additional comment letter from CBE et al was received by the City and HCD on March 3, 2023. This letter was considered by the City in the preparation of the subsequent draft, and by HCD as a third-party comment. A letter of findings from HCD was received March 24, 2023.

The following changes were made to address comments in the March 3 CBE et al letter:

Comment Response
…Given the increase in homelessness within the City, the element should include a complete analysis of characteristics of persons experiencing homelessness including by protected characteristics such as race and ethnicity, familial status, and persons with disabilities. [page 1]
Using all available data including qualitative data from City staff and service providers, the homelessness analysis has been updated.

The element still lacks analysis and evaluation on the displacement pressures on existing residents for specific areas such as the Downtown Specific Plan area and TOD overlay and programs with specific actions, metrics, and milestones to address both displacement risk and environmental risk. [page 2]
… while the City commits to evaluating antidisplacement policies, it must commit to programs as well, with concrete methods and timelines. Additionally, rent control requires a just cause eviction ordinance to be effective, so the City should have a program regarding both types of ordinances, rather than one “or” the other. [page 2]
The draft Action 13-1 was modified to commit to adopting one of the listed strategies and added milestones (page VI-21). …despite the revisions since the last draft Housing Element, it is still unclear that the City has considered how to ensure that additional housing capacity is created in moderate-resourced tracts. [page 3] The Sites Inventory identifies 635 total units in moderateresource census tracts, or about 25 percent of the total units.

The Housing Action Plan contains a number of programs to increase investment in lower-resource areas (including but not limited to Action 10-3, Action 10-5, Action 13-4, Action 14-3, Action 14-4).

Because more than 50 percent of the City’s identified sites are nonvacant it is presumed that existing uses will impede residential development of the non-vacant sites until finds based “on substantial evidence that the use is likely to be discontinued during the planning period.” Government Code section 65583.2(g)(2) these non-vacant site. The analysis contained in the February Draft (p. V-26). does not Additional analysis was added to “Suitability of Nonvacant Sites” in Section V.

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Comment Response
satisfy the requirements of Government Code section 65583.2(g)(2). [page 4]
While we agree that requiring a Phase I Environmental Site Assessment for all residential projects within 500 feet of sites that are active or have historical pollution (Policy 4.7) would address environmental constraints on sites, the City should require this analysis for all vacant and nonvacant sites in the City which could be developed for residential use during the planning period. [page 4] …Policy 4.7 should extend to all sites in the City to ensure a proper evaluation for lead and other contaminants that may be on the site. [page 5]
Policy 4.7 was modified to apply to all residential projects in the city.

The ability to have assistance in retrofitting homes with air filtration is well received, however, more specific programs to decrease in-home pollution must be added.

References to Environmental Justice policies to address pollution were added to the Assessment of Fair Housing (page II-106).

Given the likelihood of contamination in the community there must be some safeguard for streamlined projects in the City. [page 4] Policy 4.7 addresses contamination issues outside of the CEQA process to ensure contamination is addressed for
projects allowed by-right, other processing or CEQA
streamlining provisions.

Lastly, it is still unclear whether the sufficient existing or planned water, sewer, and other dry utilities to accommodate the City’s regional housing needs for the planning period. [page 5] The availability of infrastructure is discussed in Section III, and Program 14 addresses deficiencies in the current systems.

In analyzing the threat of displacement in the sites inventory analysis it would be helpful to concretely name those preventative actions. [page 5]
Program 13 has been revised to specify the measures the City commits to analyzing and adopting.

City residents ask for a commitment to developing homes that would include family-size units and providing goals for developments of such units in the site inventory analysis would guide development in the City. [page 5]
Action 7-4 states that the City will modify local density bonus regulations to allow bonuses for “family housing.” Added “family-sized housing” for clarification.

City-owned sites must go through a Surplus Lands Act (SLA) notification process prior to being disposed by the City. The sites inventory assumes that some of the properties will not be sold under the SLA and they would be used for above moderate-income housing. Even if that is the case, the Surplus Land Act requires that sites that can accommodate 10 or more residential units in the property must have no less than 15 percent of the total number of residential units developed sold or rented as affordable housing as defined Section 202(c)(1).…These sites should properly account for the affordable housing required under the SLA. [page 5-6] The City formulated assumptions about affordability based on HCD guidelines and Housing Element Law. City-owned sites did not meet the criteria to count toward the City’s share of the lower-income RHNA. Action 10-4 has been edited to clarify that the City will follow the Surplus Land Act in the development and disposition of those sites, including any affordability requirements.
…The TOD overlay would serve better use if more than 30 percent, preferably 50 percent, of the available units are allocated for very low- and low-income RHNA categories. [page 6]
The City applied assumptions for affordability as outlined in the Sites Inventory.

However, the City should be able to estimate total fees for multifamily developments of different sizes and compare those fees to what neighboring cities charge. [page 6]
The fees analysis was updated to include fees charged for actual projects.

Action 7-2 commits to “[m]odify the required findings for Development Permits (Section 9-2.1007) to remove subjective language.” Draft, VI-13. However, the Draft does not acknowledge that finding 2 (“harmonious and compatible”) is also subjective, and Action 7-2 does not identify the subjective language to be removed or amended. Draft, IV-23, VI-13. Further, the Draft does not analyze the possibility of allowing some or all multifamily housing by-right in The program commits to Finding 3, 5, and 7. Finding 2 is not subjective (“the proposed development is consistent with the General Plan”).

The TOD Overlay Zone will allow multifamily housing by-right.

Modifications to the Development Permit process would
remove subjectivity for all multifamily housing.

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Comment Response
some or all residential zones, despite acknowledging that singlefamily homes are allowed by-right in multiple zones. [page7] Similarly, the Draft acknowledges that the City’s subjective design review process constrains housing development. Draft, IV-27.

However, the only program that addresses this requirement, Action 7-2, is vague, committing only to “[c]reate processes that allow projects with an affordable component to proceed along a faster entitlement path, that would avoid discretionary review” sometime in 2023. That Housing Element should commit to specific amendments to the design review and development permit processes that will, by a specific date, eliminate discretionary permit requirements for affordable housing developments. [page 7]
Action 7-2 was edited to specify actions the City will take to reduce subjectivity in housing development review.

Further, while HCD’s group home guidance indicates that cities may require conditional use permits for licensed residential care facilities serving more than six residents, it goes on to explain: “Local governments must still provide flexible and efficient reasonable accommodations in these permitting processes. This means that some requests for exceptions to permitting processes should be resolved through reasonable accommodation procedures instead of conditional use procedures.” HCD, Group Home Technical Advisory (Dec. 2022), 26 (emphasis added). In contrast, the Draft, in describing the City’s reasonable accommodation ordinance, states:
“A reasonable accommodation cannot waive a requirement for an entitlement (e.g., Conditional Use Permit, Development Permit, General Plan Amendment, Zoning Amendment, Subdivision Map) when otherwise required or result in approval of uses otherwise prohibited by the City’s land use and zoning regulations.” Draft, IV19. The Draft does not commit to amending this aspect of the reasonable accommodation ordinance. [page 8]
Action 7-2 commits to allowing the Reasonable
Accommodation process to allow an exception to the
requirement for a CUP for large group homes.

The February Draft fails to describe or analyze requests to develop housing at densities lower than those projected in the site inventory as it did in previous versions as well. [page 9]
This analysis is included and is located on page IV-11.

While the February Draft now commits to removing the CUP requirement for SROs, as well as the prohibition against conversion of hotels and motels into SROs, it does not analyze the City’s other restrictions on SROs as constraints. [page 9]
Analysis of the City’s SRO standards has been expanded in Section IV, and additional actions to address constraints added to Action 13-3.

Action 2-3. Affordable Accessory Dwelling Units: Revise this program to detail what grants and financial incentives will be available and how the City will promote homeowner participation in the HCV program. Please clarify whether the grants and incentives will be available to low income households attempting to rent an ADU or to homeowners who rent their ADU to a lower income family or individual. Also, clarification is needed about when will the City begin to monitor the affordability levels of permitted ADU’s and what point in the planning period will the City determine if the projections are incorrect and whether additional incentives or rezoning are necessary Revisions should commit to making this determination by 2025 [page 9-10]
Action 2-3 was modified to include additional specific actions and timeframe for actions. Clarified that incentives would be offered to lower-income households for building new ADUs or legalizing existing ADUs.

Action 3-2. Rental Inspections: The rental inspection ordinance should prohibit rent increases within a year of requested repairs to ensure that cost of repairs is not passed on to tenants in addition to making owners aware of resources to make repairs. [page 10] Action 3-2 includes referrals to the Fair Housing Foundation to ensure tenants are not adversely affected by the inspection process and any required repairs.

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Comment Response
Action 7-1. Zoning Changes to Achieve Consistency with State Law:

In addition to the changes listed in this program, the zoning code must be amended to allow by-right development if more than 20% of the units are affordable to lower income households on sites rezoned to accommodate the RHNA from the 5th cycle (Government Code section 65583.2(h)). [page 10]
Policy 4.4 and state law establish this requirement.

Action 10-1. Lot Consolidation: Revise the program to identify whether fee waivers or deferrals will be available, and if both are possible clarify who will decide which is available for a particular project and what criteria will be used to decide between the two incentives. [page 10]
Action 10-1 modified to specify that the City will offer fee deferrals in all cases.

Action 10-5. Transit-Oriented Development Overlay District To partially address displacement due to increased development pressures on properties included in the TOD Overlay, the zoning code should allow by-right development when more than 20 percent of the units are affordable. Also, review the zoning code and commit to any needed changes to the code in order to comply with Government Code section 65583.2(h)(allowing 100% residential use in the mixed-use zone and permitting residential development byright in the mixed-use zone if the proposed development requires at least 20% of the units to be affordable to lower income households).

This program should also include efforts to support locally owned business remain in the neighborhoods where they are located. [page 11]
Existing programs to support local businesses described in Section II. (page II-101) Action 13-7 was added to address displacement of local businesses.

Action 12-2. Housing Choice Voucher Program Promotion
This program is focused on making tenants aware of the Housing Choice Voucher (HCV) Program. Los Angeles County already has a years’ long waiting list of families and individuals who desperately need a housing subsidy. In order for the program to be effective more landlords are needed to participate and accept vouchers. To increase mobility and to address families overpaying rent, the City should revise this program to do outreach to landlords to: 1) encourage their participation in the HCV, and 2) educate landlords about the state law prohibiting discrimination against voucher holders. [page 11]
Action 12-2 was modified to include these recommended
actions.

Action 13-1. Protecting Existing Residents from Displacement While it is commendable that this program now commits to adopting an antidisplacement measure, it is unclear if one of example measures listed in the program will be adopted, or if the “example” language would allow the City choose a strategy not listed in the program. Please revise the program to state that “One of the following strategies will be evaluated.” Also, the timeline for adoption should be moved back to 2025 so that the strategy is in place before the displacement pressures are insurmountable. [page 11] The draft Action 13-1 was modified to commit to adopting one of the listed strategies and added milestones (page VI-21). The City met with CBE during the development of the subsequent draft, and CBE submitted additional written comments on this program. The City considered these comments and
incorporated some of CBE’s recommendations into the draft, including consideration of additional tenant protections.

Action 13-2. Special Needs Housing
Include outreach to landlords to participate in the HCV program and educate landlords about the state prohibition against refusing to rent to voucher holders. Also, this program should commit the City to remove any limitation on unlicensed group homes of more than 6 people. [page 11]
See edits to Action 12-2.

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Comment Response
Action 13-6. Relocation Requirements
Revise the program to indicate that replacements units are required if rent controlled units, units with deed restricted rents, or units that are or were occupied by lower or very low-income households must be replaced. [page 11]
Added clarifying language from the statute to Action 13-6.

May 2023 Draft
A draft addressing public comments and findings from HCD’s review was published for the statutorily required seven days on May 8, 2023. The Housing Element was posted on the project website, and a notice was emailed to all interested parties.

One comment letter from CBE et al was received on May 16, 2023. Comments and the City’s responses incorporated into this draft are summarized as follows:

Comment Response
Commenters noted that programs (Actions 13-4, 14-3 and 14-4) to address investment in lower-resources areas of the city are not in the Housing Element.

Action 13-4 (Placemaking), Action 14-3 (Open Space Planning), and Action 14-4 (Active Transportation Planning) are in the Housing Element Housing Plan. Program actions to address investment in lower-resources areas include, but are not limited to, Action 13-4, Action 14-1 (General Plan Update), Action 14-3, and Action 14-4.

Commenters asked that analysis of feasibility of non-vacant sites “indicate why similar projects would be feasible in Huntington Park if Huntington Park does not have its own track record of converting non-vacant sites to residential
development.”
Section V, Sites Inventory, contains a detailed analysis of example projects in the Gateway Cities area and their relevance to inventory sites in Huntington Park. The Housing Element analyzes transit areas similar to the future transit areas in Huntington Park, brownfield redevelopment sites similar to those in Huntington Park, and declining commercial or industrial areas similar to those in Huntington Park.

Commenters asked that the City include a program to establish “just cause tenant protections and a vacant property tax, and create a separate program to address the after effects of displacement.” Commenters also requested additional
displacement analysis. Commenters also request that the City commit to adopting all four strategies outlined in Program 13-1, adopting rent control, and adding clarification to strategies in Program 13-1.

The City met with CBE et al to discuss previously expressed concerns regarding the Draft Housing Element’s displacement analysis and the City’s proposed anti-displacement strategies. The City made numerous changes to the draft Housing Element to address commenters’ concerns regarding displacement of local businesses, programs addressing replacement housing, strategies such as rent control and just cause evictions. Commenters previously asked for clarification regarding the strategies proposed in Program 13-1 and that has been added to the program language.

Commenters clarified prior remarks regarding affordability of future Transit-Oriented Overlay District projects and asked that affordability requirements be included in the TOD regulations.

Commenters also asked that multi-family development be
allowed by right in more zoning districts than the TOD overlay district.

The Draft Housing Element includes numerous programs to encourage and prioritize affordable housing through permit streamlining, density bonus programs, and ministerial, objective review processes. Adding affordability requirements to a new zoning district may act as a constraint to development in a city which has not experienced much multifamily development in recent years, and which has an obligation to provide housing at all income levels. Under Action 7-5, the City will monitor its progress toward meeting its share of the RHNA for every income level and make zoning changes as appropriate to keep pace and encourage affordable housing development.

With changes to existing regulations in programs 7 and 10, multifamily development in the R-M, R-H, C-P, C-G, and all DTSP zones would be allowed by right, with a Development Permit approved administratively. The approval process would not include discretionary review.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-17
Comment Response
While noting that the City has addressed prior concerns with group home regulations, commenters asked that Housing
Element analyze the City’s definition of “family” as a constraint to group homes.

Commenters state “zoning ordinances sometimes restrict or limit group homes in single-family residential zones through definitions of single housekeeping units or single-family homes.” The City’s zoning ordinance contains provisions for group homes noted by commenters to be modified through Program 7. The City’s definition of family is analyzed as a constraint on page VI-18. The definition does not exclude group homes. The development of group homes is not constrained by this definition. Local group home regulations do not rely on the definition of “family” to regulate group homes.

Commenters asked that the analysis provide “information as to why developers are requesting lower densities than those projected in the site inventory.”
As noted elsewhere in the Housing Element and by commenters, there have been few multi-family projects approved in the City.

There have been no requests to develop housing at lower densities than those anticipated in the sites inventory. Clarification has been added to this analysis (page IV-11). Nonetheless, Housing Element programs 10 and 11 would address future requests by establishing minimum densities in the Downtown Specific Plan area and the new TOD Overlay District.

Commenters asked that specific ADU-related grants and
incentives be identified in Action 2-3.

Potential sources of funding were added to Action 2-3.

Commenters request an anti-harrassment ordinance, no fault eviction protection, temporary relocation assistance, or mandatory relocation assistance be incorporated into Action 3-2, Rental Inspection.

Under Action 3-2, Code Enforcement staff will connect property owners with rehabilitation assistance to maintain the affordability of a unit requiring repairs, and connect tenants with fair housing resources to ensure tenants are not displaced or priced out of the housing units once repaired. Other anti-displacement strategies are discussed and addressed in Action 13-1.

Commenters noted that a timeframe and objectives were
missing from Action 13-2, and asked for additional analysis regarding displacement of small businesses.

A timeframe and objective has been added to the action related to small businesses, Action 13-7. Additional details regarding small business outreach and potential sources of funding were added to Action 13-7.

Commenters noted that Action 12-2 does not include objectives related to landlord outreach and participation or enforcement of source of income protections.

Objectives regarding landlord participation and the Fair Employment and Housing Act were added to Action 12-2.

Commenters requested Action 13-6 include references to other relocation requirements (Density Bonus Law and sites inventory requirements).

References to and details about replacement requirements in Density Bonus law and Housing Element Law (sites inventory) have been added to Action 13-6.

The draft was submitted to HCD for review on June 7, 2023. An additional comment letter from CBE et al was received by the City and HCD on July 12, 2023. Comments and the City’s responses incorporated into this draft are summarized as follows:

This letter was considered by the City in the preparation of the subsequent draft, and by HCD as a third-party comment. A letter of findings from HCD was received July 21, 2023.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-18
Comment Response
Displacement. The May 2023 Draft continues to lack the analysis of displacement pressures as indicated in our prior comments. We do note the changes to Program 13-1 do include a commitment to enact a specific action after the stakeholder process completes.

Comment noted and previously responded to.

Housing capacity in moderate resource areas. We appreciate the clarification about Actions 13-4, 14-3 and 14-4 in the June 2023 Draft. Looking back at the May 2023 Draft it appears that Action 13-1 was titled Placemaking but in the June 2023 Draft it is Action 13-4.

Our mistakes about the numbering, lack of numbering, or incorrect numbering aside, the focus of our comments was to inquire whether there are programs intended to increase housing capacity in moderate resource areas as well as in lower resource areas, which is the focus of Actions 13-4, 14-3, and 14-4.

The City should add programs to increase housing capacity in all areas of the City including areas identified as having moderate resources.

Comment noted and previously responded to.

Additional evidence of the feasibility of non-vacant sites. The City provides information about the conversion of non-vacant sites into residential development in this planning period by pointing to examples in other communities. This analysis should indicate why similar non-vacant sites would be feasible in Huntington Park. Government Code section 65583.2(g)(1) requires the City to explain its methodology to support the feasibility of nonvacant sites development potential. The statute requires particular factors to be part of the methodology, including the City’s past experience “converting existing uses to high density residential development.“ The City relies on the redevelopment activity of neighboring communities to demonstrate how the non-vacant sites in Huntington Park will also have redevelopment potential. If the City is allowed to rely on the development patterns in other cities to demonstrate the redevelopment potential in its own city, the analysis must include additional information comparing Huntington Park’s development standards, available incentives and funding to these neighboring cities in order to demonstrate that the sites in Huntington Park have the same redevelopment potential as the sites in these neighboring communities.

A new section (“Development Standards,” page V-20)
was added comparing the development standards of
Huntington Park’s Downtown Specific Area Plan and
the new TOD Overlay District with the example
projects and comparable station area plans that
informed the sites inventory analysis.

Displacement Prevention. We appreciate that the City met with us and amended Program 13-1 to include greater certainty in what actions it will take to address displacement once it has already occurred. The City should create a Program focused on displacement prevention actions, such as just cause tenant protections and a vacant property tax, and create a separate program to address the after effects of displacement.

Comment noted and previously responded to.

TOD Affordability. We renew our request for affordability requirements in the TOD overlay as it would help to ensure that residents subject to displacement pressure around transit centers can find affordable housing in their community.

Our comments were not intended to suggest that all developments in the TOD be 100 percent affordable but that requiring some affordability in the TOD would guarantee a variety of housing types for a variety of income levels.

Based on the development pressure near affordable transportation options it would not act as a constraint on development.

The rezone program (Action 10-5) complies with
Government Code Section 65583.2(h) and (i), which
requires that projects on rezone sites that allow byright development include a minimum of 20 percent affordable units.

Reasonable Accommodation for Group Homes. We note the City’s commitment through Program 7 to amend the Zoning Code to remove constraints for group homes. The June 2023 Draft finds that City’s definition of “family,” does not pose a constraint on the development of group homes.

Because the City currently requires a CUP for large group homes when the City’s removes this requirement as outlined in Program 7, we want to ensure that group homes do not face greater scrutiny or opposition based on whether they fit within the confines of the City’s definition of a family. The City’s definition of family, specifically the requirement that “family” be a “single nonAction 7-2 now commits the City to clarifying the meaning of “housekeeping” and removing the
reference to “nonprofit” in the definition of “family.” Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-19
Comment Response
profit housekeeping unit,” is overly restrictive and risks violating not only state housing laws, but the California Constitution’s protections of the rights of unrelated persons to live together in communal housing.

The City defines “family” as living as a single housekeeping unit, but does not define single housing keeping unit. It also specifies that a family is a single non-profit housekeeping unit, which excludes for profit businesses. In general, localities should avoid including provisions in definitions of shared housekeeping units, single-family homes, or other single residential dwellings that automatically exclude group homes that are owned by for-profit businesses or that pay a house manager or resident to help manage a home’s operations. These are well-established models for group homes. See HCD’s Group Home Technical Advisory 2022 at 23-24. The City should develop an inclusive definition of “housekeeping unit”, or explicitly state in its zoning code that group homes meet the definition of “family.”
Rental Inspections. To ensure that the costs of repairs are not passed on to tenants through this program, the program should also include temporary relocation assistance to tenants who are temporarily displaced due to code violations and mandatory owner paid relocation assistance if tenants are permanently displaced due to code violations. Referrals to Fair Housing organizations are not meaningful for code violations because the failure to make repairs is not necessarily related to discriminatory practices.

Comment noted and previously responded to.

Air Pollution Mitigation and Green Space Design. There are no programs to address high levels of air pollution or increase air filtration use and availability for residents, although previous drafts did include discussion of air pollution conditions. In addition, there is no mention of integrating green space in design features for housing in the City which would address both housing and environmental justice element goals.

Comment noted and previously responded to.

Policy 4.7. Require Phase I Environmental Site Assessments and, if required, subsequent remediation, to be completed for all residential projects.

Under CA Health and Safety Code §78090: “Phase I environmental assessment” means a preliminary assessment of a property to determine whether there has been, or have been, a release of a hazardous substance based on reasonably available information about the property and general vicinity. A phase I environmental assessment may include, but is not limited to, a review of public and private records, current and historical land uses, prior releases of a hazardous material, database searches, reviews of relevant files of federal, state and local agencies, visual and other surveys of the property and general vicinity, interview with current and previous owners and operators, and review of regulatory correspondence and environmental reports. Sampling or testing is not required as part of a phase I environmental assessment.

Instead, the City should adopt a policy to require a Phase II Environmental Assessment as well as a Preliminary Endangerment Assessment. These additional tests and requirements should take place in known environmental justice communities, such as Huntington Park.

Action 10-3. Brownfields Program. The City needs to maintain a balance between the City’s need for housing and also its need for open space. Action 10-3 should be modified to prioritize open space as well as residential purposes when seeking funding and assistance to remediate brownfields. New residential sites should be developed at least 1,600 feet from industrial sites and at least 3,200 feet from oil and gas producing sites. Due to the level of contamination that has been found throughout the City we ask that the highest amount of environmental assessment is undertaken. For example, all remediation to previously contaminated land should include a Phase I and If the results of a Phase I site assessment resulted in findings that would warrant a Phase II assessment, a
Phase II assessment would be required.

Reducing and mitigating the negative impacts of
exposure of residents to hazardous materials and
environmental pollution existing industrial land uses is a primary focus area of and addressed by the
Environmental Justice Element.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-20
Comment Response
Phase II environmental assessment as well as a preliminary endangerment assessment.

Program 6. Energy Conservation Program. In addition to the actions included in Program 6, the City should include additional action items such as ensuring new developments are built without extending gas lines. The City would also benefit from a building decarbonization ordinance. And last, we recommend that all new buildings that come online should be electric only.

Comment noted and previously responded to.

Action 10-7. Reuse of Site with Existing Uses. This Action item should be modified to ensure that it is aligned with the standards forth in AB 2011 (Wicks). AB 2011, the Affordable Housing and High Road Jobs Act of 2022, authorizes a development proponent to submit an application for a housing development that meets specified objective standards and affordability and site criteria, including being located within a zone where office, retail, or parking are principally uses, and would make the development a use by right.

The City will comply with state law in review of all
projects.

Action 10-5. Transit-Oriented Development Overlay District. The City will accommodate its inventory shortfall through the TOD overlay that will allow greater densities than the underlying zoning permits. It is unclear from the program’s description if the underlying density still permitted on these sites is less than 20 units/acre. It is clear that the Overlay would have a minimum density of 20 units/acre but the clarification would be to describe what density the underlying zoning permits. The program also anticipates completion by June 2023 and this deadline should be amended if the deadline has already passed.

Comment addressed on page V-11, and the
timeframe for program completion has been updated.

Action 13-1 Protecting Existing Residents from Displacement. We appreciate that the City has incorporated some of our prior comments into the first action under Program 13, including the addition of references to a tenant protection ordinance and just cause eviction protections. However, we encourage the City to commit to adopting all four of the identified strategies rather than limiting itself to one of the identified strategies. We also urge the City to include rent control in this Action, to clarify the subparts under “Community benefit zoning” and to clarify when and where replacement requirements will apply. Given the severe risk of displacement, the City should clarify this program to ensure, not only that the City will comply relocation and replacement requirements of applicable state laws but also that it will adopt its own relocation, replacement, and tenant protection policies that maximize protections for lower-income tenants at risk of displacement.

Comment noted and previously responded to.

An additional comment letter from CBE et al was received by the City on August 8, 2023. Comments and the City’s responses incorporated into this draft are summarized as follows:

This letter was considered by the City in the preparation of the subsequent adoption draft.

Comment Response
Inadequate Environmental Justice Programs. One example of how the City’s Environmental Justice Element falls short of meeting its obligations is that it lacks a comprehensive approach to reducing air pollution. The Element does have an air filtration program for specific residents - low income and senior residents – but that only addresses air quality indoors when the windows are closed and does not address the outside air quality. Another example of an inadequate Environmental Justice Element program under Government Code §65302(h) is the soil remediation program that relies on developers to identify soil contamination and does not have standards that will increase the likelihood that remediation is successfully completed.

Comments are directed at the City’s Environmental
Justice Element which was adopted on November 15,
2022.

It should be noted that previous comments pertaining
to the Housing Element regarding indoor air pollution
and soil remediation programs were responded to in
responses to the January 17, March 3, and July 12
letters.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-21
Comment Response
Action 13-2 Anti-Displacement Programs. The latest version of the City’s Draft Housing Element incorporated some of our proposed changes into Action 13-1,the first term of a potential settlement would be for the City to incorporate the remaining changes Petitioners proposed into Action 13-, (e.g. imposing a tax for vacant properties rather than imposing a monitoring fee on landlords who maintain vacant properties). The purpose of these action items should be to prevent displacement of existing residents as development activity increases in Huntington Park.

Comment noted and previously responded to in
responses to the January 17, March 3, May 16 and
July 12 letters.

As stated in response to the May 16 letter. The City
met with CBE et al to discuss previously expressed
concerns regarding the Draft Housing Element’s
displacement analysis and the City’s proposed antidisplacement strategies. The City made numerous changes to the draft Housing Element to address
commenters’ concerns regarding displacement of local
businesses, programs addressing replacement
housing, strategies such as rent control and just cause evictions. Commenters previously asked for
clarification regarding the strategies proposed in
Program 13-1 and that was also added to the program
language.

Increased Affordability in the TOD Overlay. Similar to the affordability requirements established in the Surplus Land Act, the TOD Overlay should require a minimum 15 percent of the residential units built employing the Overlay to be affordable to low and very low-income households, with incentives and concessions granted for higher percentages of affordable units.

Comment noted and previously responded to in
responses to the July 12 letter as follows:

The rezone program (Action 10-5) complies with
Government Code Section 65583.2(h) and (i), which
requires that projects on rezone sites that allow byright development include a minimum of 20 percent affordable units.

Addressing Air Pollution Issues. In order to create a comprehensive approach to address and reduce air pollution the General Plan must include the following policies and programs aimed to improve air quality: 1) create appropriate setbacks from polluting industries in the community; 2) ensure new residential sites cannot be developed at least 1,600 feet from parcels zoned as industrial; 3) prohibit freight truck traffic from main thoroughfares; 4) create a building decarbonization ordinance to reduce indoor air pollution; and, 5) require adequate green space throughout the City along with appropriate tree planting and urban greening measures.

Comments are directed at the General Plan and
comprehensive air pollution policies and programs.

It should be noted that the City’s adopted
Environmental Justice Element includes a policy to
increase urban greening across the City and a
program that commits the City to develop an Urban
Greening Plan for Huntington Park, a comprehensive
approach to address this citywide need, including
identification of funding strategies. The Environmental Justice Element also includes a policy and programs to
reduce air pollution through designation of truck routes and enforcement of truck idling requirements.

As previously stated in response to the January 17
comment letter, the City may consider a building
electrification ordinance in the future. However, it is recommended that this be done more holistically and
in concert with a more comprehensive carbon
reduction strategy. The preparation of a future
ordinance should consider additional cost burden or
displacement risk to vulnerable communities, the
phasing of implementation, funding strategies,
regulatory barriers, and coordination with utility
providers and other agencies.

Huntington Park 2021-2029 Housing Element Introduction
For Adoption September 18, 2023 I-22
Comment Response
Commenters recommend a 1,600 foot buffer or
setback for new residential sites from industrial zoned parcels without consideration of the broad impacts for
a City as compact and constrained as Huntington Park.

A 1,600 setback or buffer from industrial zoned parcels would render nearly 46% of the city as unavailable for
future residential development, including areas of the
city that are currently zoned and developed with
existing housing, schools and other amenities. Rather
than impose a buffer or setback that would further
impede the City’s ability to identify opportunities for future housing development and associated amenities,
the City’s adopted Environmental Justice Element
includes policies and programs that support a more
holistic and targeted approach to protect Huntington
Park from pollution exposure. These adopted policies
include implementing the Southeast Los Angeles
Community Emissions Reduction Plan, locating
sensitive uses away from significant pollution sources
to the maximum extent possible, and facilitating
remediation of all Brownfield sites within Huntington
Park and their subsequent redevelopment to nonindustrial and non-polluting uses.

Appropriate Soil Remediation Measures and Oversight. There is an immediate need to deal with the many brownfields located in the City and because some sites in the Housing Element site inventory target areas that are particularly close to industrial lands the General Plan must include specific standards that will ensure the health and safety of the existing and future community. The City must require developers to do a Phase I and Phase environmental site assessment as well as enroll in the Department of Toxic Substance Control’s voluntary programs for consultation with remediation actions.

See response to above comment regarding policies
targeting remediation of brownfield sites.

Comment regarding Phase I and Phase II
environmental site assessments was previously
responded to in response to the July 12 comment
letter.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-1
II. HOUSING NEEDS ASSESSMENT
This section examines Huntington Park’s general population and household characteristics and trends, such as age, employment, household composition and size, household income, and special needs. Characteristics of the existing housing stock (e.g., number of units and type, tenure, age and condition, costs) are also addressed. Finally, the City’s projected housing needs based on the 2021-2029 Regional Housing Needs Assessment (RHNA) are examined.

The data presented in this section has been compiled by the Southern California Association of Governments (SCAG) based upon recent data from the U.S. Census, California Department of Finance (DOF), California Employment Development Department (EDD), and other relevant sources and has been pre-approved by the California Department of Housing and Community Development (HCD).

Population Characteristics
Population Growth Trends
Huntington Park was incorporated in 1906 as a streetcar suburb on the Los Angeles Railway for workers in the rapidly expanding industries to the southeast of downtown Los Angeles. From 2000 to 2020, the City’s population decreased from 61,348 to an estimated population of 59,515 (see Table II-1), an annual growth rate of -0.2% compared to 0.7% for the SCAG region as a whole.

Table II-1
Population Trends 2000-2020
Huntington Park vs. SCAG Region
Age
Housing needs are influenced by the age characteristics of the population. Different age groups require different accommodations based on lifestyle, family type, income level, and housing preference. Table II-2 provides a comparison of the City’s population by age group. According to the table, the population of Huntington Park is 50% male and 50% female. The share of the Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-2
population of Huntington Park below 18 years of age is 28.3%, which is higher than the regional share of 23.4%. Huntington Park’s seniors (65 and above) make up 8.3% of the population, which is lower than the regional share of 13%.

Table II-2
Population by Age and Sex
Huntington Park
Household Characteristics
Overcrowding
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 severely overcrowded when there are more than 1.5 persons per room. Overcrowding can be caused by high housing costs. Some households may not be able to afford high-cost housing and instead accept smaller, lower-cost housing that is comfortable for the family size. Households may also house extended family members to share the cost among more people or reside with other unrelated individuals or families in the same home. Cultural differences also contribute to overcrowded conditions. Some cultures tend to have a larger household size than others due to the preference of living with extended family members and may not have sufficient income or housing choices to reside in a home that has adequate accommodation for a larger number of people.

Huntington Park is one of the densest cities in the United States according to Census data.

Overcrowding is prevalent throughout Huntington Park, more so among renters than homeowners (Table II-3). About sixty percent of the city’s renter-occupied households are overcrowded (of those, about 20 percent are severely overcrowded). About 21 percent of owner-occupied households are overcrowded (of those, about four percent are severely overcrowded).

Overcrowding is more common in Huntington Park than in the SCAG region (Table II-3). Regionally, 22 percent of renter households are overcrowded, compared to about six percent of homeowner households. Overcrowding by neighborhood and demographic characteristics is analyzed further in the Assessment of Fair Housing.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-3
Huntington Park’s higher rate of overcrowding indicates a lack of family-sized housing sufficient to meet demand. Program 7, Zoning Code Updates, contains provisions for a number of changes to Huntington Park’s zoning ordinance to allow incentives for larger unit sizes.

Table II-3
Overcrowding by Tenure
Huntington Park and SCAG Region
Housing Affordability and Overpayment
Housing Affordability Criteria
State law establishes five income categories for purposes of housing programs based on the area (i.e., county) median income (“AMI”): extremely low (30% or less of AMI), very low (31-50% of AMI), low (51-80% of AMI), moderate (81-120% of AMI) and above moderate (over 120% of AMI). Housing affordability is based on the relationship between household income and housing expenses.

According to the U.S. Department of Housing and Urban Development (“HUD”) and the California Department of Housing and Community Development (“HCD”), housing is considered “affordable” if monthly housing costs are no more than 30% of a household’s gross income.

Table II-4 shows affordable rent levels and estimated affordable purchase prices for housing in Los Angeles County by income category. Based on State-adopted standards for a 4-person family, the maximum affordable monthly rent for extremely low-income households is $845, while the maximum affordable rent for very low-income households is $1,407. The maximum affordable rent for low-income households is $2,252, while the maximum for moderate-income households is $2,319. Maximum purchase prices are more difficult to determine due to variations in mortgage interest rates and qualifying procedures, down payments, special tax assessments, homeowner association fees, property insurance rates, etc. With this caveat, the maximum affordable home purchase price for moderate-income households has been estimated based on typical conditions.

Affordable prices have not been estimated for the lower-income categories because most for-sale affordable housing is provided at the moderate-income level.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-4
Table II-4
Income Categories and Affordable Housing Costs
Los Angeles County
2020 COUNTY MEDIAN INCOME = $77,300 INCOME LIMITS* AFFORDABLE RENT

AFFORDABLE PRICE
(EST.)
Extremely Low (<30%) $33,800 $845 *
Very Low (31-50%) $56,300 $1,407 *
Low (51-80%) $90,100 $2,252 *
Moderate (81-120%) $92,750 $2,319 $375,000
Above moderate (120%+) Over $92,750 Over $2,319 Over $375,000 Assumptions:
-Based on a family of 4 and 2020 State income limits
-30% of gross income for rent or principal, interest, taxes & insurance plus utility allowance -10% down payment, 3.75% interest, 1.25% taxes & insurance, $300 HOA dues * Because of State adjustments in high housing cost areas, some of these income limits are higher than the percentages of median income Source: Cal. HCD; JHD Planning LLC
Rental Housing
Across Huntington Park’s 10,617 renter households, 6,679 (62.9%) spend 30% or more of gross income on housing cost, compared to 55.3% in the SCAG region.1 Additionally, 3,357 renter households in Huntington Park (31.6%) spend 50% or more of gross income on housing cost, compared to 28.9% in the SCAG region (Table II-5).

Table II-5
Percentage of Income Spent on Rent
Huntington Park
Recent Census data also allows for the analysis of Huntington Park's 10,415 renter households (for which income data are available) by spending on rent by income bracket. As one might expect, the general trend is that low-income households spend a higher share of income on housing (often 1 The SCAG region includes Los Angeles, Orange, Riverside, San Bernardino, Imperial, and Ventura counties.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-5
more than 50%) while high-income households are more likely to spend under 20% of their income on housing (Table II-6).

Table II-6
Percentage of Income Spent on Rent by Income Category
Huntington Park
The annual median household income in Huntington Park in 2019 was $42,447. 2 Income varies by
location in the city, with the lowest median income in central Huntington Park, and higher median incomes in north and east Huntington Park.

The 2019 median monthly household income was $3,537. Meanwhile, the census 2015-2019 data indicated the median rent in the city is an estimated $1,081/month, indicating that the average household is paying approximately 30 percent of their income towards rent. 3 For-Sale Housing
Median sales price trends for existing homes during 2000-2018 are shown in Table II-7. According to the table, median home sale prices in Huntington Park have ranged from a low of 61.5% of the SCAG region median in 2002 and a high of 79.8% in 2006. By 2018, median home sales prices in Huntington Park were $400,000. The median home sales prices in Huntington Park increased 167% while prices in the SCAG region increased 151%.
2 U.S. Census, ACS 5-Year Estimates, 2019. 3 Census.gov: https://www.census.gov/quickfacts/fact/table/huntingtonparkcitycalifornia/HSG860219 Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-6
Table II-7
Median Home Sales Price for Existing Homes
Huntington Park and SCAG Region
Table II-8 compares typical monthly mortgage costs in Huntington Park to the SCAG region as a whole, while Table II-9 confirms that the percentage of income spent on mortgage payments is higher for households at the lower income levels.

Table II-8
Monthly Mortgage Cost
Huntington Park and SCAG Region
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-7
Table II-9
Monthly Mortgage Cost by Income Category
Huntington Park
According to State housing policy, overpaying occurs when housing costs exceed 30% of gross household income. Table II-10 displays recent estimates for overpayment by income category for Huntington Park residents and shows that overpayment is much more frequent for households at the extremely low- and very low- income levels than those households in higher income categories.

Table II-10
Overpayment by Income Category
Huntington Park
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-8
Employment
Employment is an important factor affecting housing needs within a community. The jobs available in each employment sector and the wages for these jobs affect the type and size of housing residents can afford.

According to recent Census data, Huntington Park had 25,913 workers living within its borders who work across 13 major industrial sectors (Table II-11). Manufacturing is the most prevalent industry in the city with 5,163 employees (19.9% of total) followed by Education and Social Services with 3,702 employees (14.3% of total).

Table II-11
Employment by Industry
Huntington Park
In addition to collecting data on the industries in which the residents of Huntington Park work, the Census also tracks the types of jobs residents hold. The most prevalent occupational category in Huntington Park is Production, in which 9,008 (34.8% of total) employees work. The second-most prevalent type of work is in Sales, which employ 6,250 (24.1% of total) in Huntington Park (Table II-12).

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-9
Table II-12
Employment by Occupation
Huntington Park vs. SCAG Region
Housing Stock Characteristics
This section presents an evaluation of the characteristics of the community’s housing stock which can help identify and prioritize the community’s needs. The factors evaluated include the number and type of housing units, tenure, vacancy, housing age, and housing condition. A housing unit is defined as a house, apartment, mobile home, or group of rooms, occupied as separate living quarters, or if vacant, intended for occupancy as separate living quarters.

Housing Type and Tenure
Huntington Park’s housing stock contained a total of approximately 15,228 units in 2020, of which about 41.2% were single-family detached homes (Table II-13). As seen in Table II-14, 27.2% of homes in Huntington Park were owner-occupied as compared to about 52% in the SCAG region.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-10
Table II-13
Housing by Type
Huntington Park and SCAG Region
Table II-14
Housing by Tenure
Huntington Park and SCAG Region
Housing tenure varies substantially based on the age of the householder. In Huntington Park, the age group where renters represent the largest proportion of householders is 15-24. The age group where owners represent the largest proportion of householders is 60-64 (Table II-15).

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-11
Table II-15
Housing Tenure by Age of Householder
Huntington Park
Table II-16 shows recent data for vacant units in Huntington Park and the SCAG region. The largest categories of vacant units in Huntington Park were units for rent and units designated as other.

Table II-16
Vacant Units by Type
Huntington Park and SCAG Region
Housing Age and Conditions
The age of housing stock is often an important indicator of housing conditions. Housing units built prior to 1978, before stringent limits on the amount of lead in paint were imposed, may have interior Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-12
or exterior building components coated with lead-based paint. Lead-based paint becomes hazardous to children under age six and pregnant women when it peels off walls or is pulverized by years of opening and closing windows and doors. Housing units built before 1970 are the most likely to have lead-based paint in a deteriorated condition and need rehabilitation.

Table II-17 shows the age distribution of the housing stock in Huntington Park compared to the SCAG region as a whole. This table shows that 78% of the housing stock in Huntington Park was built prior to 1980, and 26.2% of those homes, the largest proportion, was constructed prior to 1939. These findings suggest that there may be a need for maintenance and rehabilitation, including the remediation of lead-based paint, for a substantial number of housing units. Typically housing over 30 years of age is likely to need rehabilitation work to major elements of the structure, such as roofing, siding, plumbing, and electrical. As a result, a large majority of Huntington Park’s housing stock is in substandard condition.

Table II-17
Age of Housing Stock
Huntington Park and SCAG Region
According to the 2020-2025 5-Year Consolidated Plan, approximately 12,395 units citywide are estimated to need some level of rehabilitation and/or may require replacement. This represents about 80 percent of the City’s total housing stock. City staff report that code enforcement issues are widespread, but concentrated in the lower-income parts of the city, including the central neighborhoods. Program 3, Safe and Sanitary Homes, contains a number of actions to fund rehabilitation programs and connect households in need with resources. The City will make that connection through code enforcement efforts, effectively targeting areas of the city with the most need.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-13
Special Housing Needs
Certain groups have greater difficulty finding decent, affordable housing due to special circumstances. Such circumstances may be related to one’s employment and income, family characteristics, disability, or other conditions. As a result, some Huntington Park residents may experience a higher prevalence of overpayment, overcrowding, or other housing problems.

State Housing Element law defines “special needs” groups to include persons with disabilities, the elderly, large households, female-headed households with children, homeless people, and farm workers. This section contains a discussion of the housing needs facing each of these groups.

Persons with Disabilities
Physical, mental, and/or developmental disabilities may prevent a person from working, restrict one’s mobility, or make it difficult to care for oneself. Persons with disabilities often have special housing needs related to limited earning capacity, higher health costs associated with a disability, and a housing stock that is accessible and affordable. Housing opportunities for those with disabilities can be maximized through housing assistance programs and providing universal design features such as widened doorways, accessibility ramps, lowered countertops, single-level units, and ground-floor units. Still, some disabilities require living in an institutional setting. Because of these conditions, persons with disabilities have special housing needs.

According to recent Census estimates, the most prevalent types of disabilities for Huntington Park residents were ambulatory, independent living, and cognitive disabilities (see Table II-18).

Table II-18
Disabilities by Type
Huntington Park
In Huntington Park, the most commonly occurring disability among seniors 65 and older was an ambulatory disability, experienced by 25.8% of Huntington Park’s seniors and 22.9% of seniors in the SCAG region (Table II-19).

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-14
Table II-19
Disabilities by Type for Seniors 65+
Huntington Park and SCAG Region
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 22;
• 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) self-direction; f) capacity for independent living; or g) economic self-sufficiency; and • 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 as a separate category of disability.

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%. 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.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-15
Table II-20
Developmental Disabilities by Residence and Age
Huntington Park
Resources Available
Many disabled persons receive Social Security Income (SSI) assistance, but benefit payments are well below the level necessary to afford market-rate apartments in Huntington Park. The city has a number of residential care facilities that provide supportive housing and services to persons with disabilities. According to the California Department of Social Services, Community Care Licensing Division, there are two 24-hour residential care facilities for children, four adult residential facilities, and one Home Care facility in Huntington Park. There are no residential elderly care facilities in Huntington Park, which is a gap in local resources.

There are a number of housing types appropriate for people living with a development disability, including rent-subsidized homes, licensed and unlicensed single-family homes, Section 8 vouchers, special programs for home purchase, HUD housing, and residential care facilities. The design of housing-accessibility modifications, the proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving this need group.

Incorporating barrier-free design in all new multifamily housing (as required by California and Federal Fair Housing laws) is especially important to provide the widest range of choices for disabled residents. Special consideration should also be given to the affordability of housing, as people with disabilities may be living on a fixed income.

Throughout the region served by the Los Angeles Homeless Services Authority (LAHSA)’s Continuum of Care (CoC), certain transitional housing programs are specifically designed for persons with mental health disorders and provide mental health counseling and treatment as well as focused case management support. For example, Wesley Health Centers’ Recuperative Care Transitional Housing is specifically designed to support homeless persons being discharged from the hospital with physical health issues from which they need to recover. The majority of the CoC- Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-16
funded Permanent Supportive Housing (PSH) programs are targeted to persons with mental health and/or physical health disabilities and provide services focused on supporting persons and families with these types of disabilities.

The California Department of Developmental Services (DDS) currently provides community-based services to persons with developmental disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community-based facilities. The South Central Los Angeles Regional Center (SCLARC), with locations in the cities of Los Angeles and South Gate (https://sclarc.org/), provides services to individuals with developmental disabilities and their families.

Regional centers are required by law to provide services in the most cost-effective way possible.

They must use all other resources, including generic resources, before using any regional center funds. A generic resource is a service provided by an agency that has a legal responsibility to provide services to the general public and receives public funds for providing those services. Some generic agencies may include the local school district, county social services department, MediCal, Social Security Administration, Department of Rehabilitation, and others. Other resources may include natural supports. This is help that disabled persons may get from family, friends or others at little or no cost.

Elderly
The elderly have a number of special needs including housing, transportation, health care, and other services. Housing is a particular challenge because many elderly households are on fixed incomes. As housing expenses rise, they may have less money available for medical costs and other vital services. Elderly homeowners may also be physically unable to maintain their homes or cope with living alone. The housing needs of this group can be addressed through smaller units, accessory dwelling units on lots with existing homes, shared living arrangements, congregate housing, and housing assistance programs.

Federal housing data define a household type as an “elderly family” if it consists of two persons either, or both, age 62 or over. Of Huntington Park’s 2,149 such households, 49.6% earn less than 30% of the surrounding area income (compared to 24.2% in the SCAG region), and 70.3% earn less than 50% of the surrounding area income (compared to 30.9% in the SCAG region). (Table II-21)
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-17
Table II-21
Elderly Households by Income and Tenure
Huntington Park
The elderly tend to have higher rates of disabilities than younger persons; therefore, many of the programs noted in the previous section (Person with Disabilities) also apply to seniors since their housing needs include both affordability and accessibility.

Resources Available
Huntington Park has four senior housing projects providing 650 units, with approximately 360 of these units restricted to occupancy by lower-income households at affordable rents. According to the California Department of Social Services, Community Care Licensing Division, there are no residential elderly care facilities in Huntington Park, which is a gap in local resources. The City will modify its development standards for residential care facilities through completion of Program 7, Zoning Code Updates. Additional information on development standards for residential care facilities are found in Constraints. There is one convalescent home in the city, Huntington Park Nursing Center, with 99 beds.

In the past, the City has administered a HOME-funded Residential Rehabilitation Loan program which offers financial assistance to single-family homeowners (1 to 4 units) for rehabilitation and repairs. Because of funding limitations, the program has only able to assist approximately three lowand moderate-income households annually. The City also administered a CDBG-funded Minor Home Repair program which provided exterior repair services to lower-income elderly and disabled households. The City will re-initiate these programs during the Consolidated Plan period of 2020 to 2024 (Program 4, Home Rehabilitation). In 2022, the City was awarded a California Department of Housing & Community Development CalHome grant for $1,800,000 for an Owner-Occupied Rehabilitation program for households with incomes under eighty percent of AMI. It is estimated that 15 units will be assisted through this program.

The City Park and Recreation Department offers a Senior Program at the Huntington Park Community Center three days per week. A variety of free recreational and educational activities are offered, in addition to periodic fieldtrips and dances. The Huntington Park Family Center provides a no- to low-cost senior lunch program at their facility, in addition to delivering to home-bound Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-18
seniors. A senior and handicapped dial-a-ride and taxi voucher program are also provided through the Family Center, as well as "COMBI", the City's fixed-route bus system.

Large Households
Household size is an indicator of need for large housing units. Large households are defined as those with five or more members. Table II-22 illustrates the range of household sizes in Huntington Park for owners, renters, and overall. The most commonly occurring household size is four people (20.7%) and the second-most commonly occurring household is two people (20%). Huntington Park has a lower share of single-person households than the SCAG region overall (11.3% vs. 23.4%) and a higher share of 7+ person households than the SCAG region overall (7.9% vs. 3.1%). This distribution indicates that the need for large units with four or more bedrooms is expected to be significantly greater than for smaller units. In addition, large families needing units with more bedrooms generally face higher housing costs and, as a result, may benefit from several types of assistance.

As discussed in Overcrowding, above, there is a lack of available, affordable housing units that can accommodate large households. Through changes to the City’s zoning ordinance, Program 7, Zoning Code Updates, will increase the supply of larger units appropriate for larger households.

Program 2, Accessory Dwelling Units and Missing Middle Housing, will also increase opportunities for homeowners to build ADUs, providing additional living space for large households in singlefamily homes.

Table II-22
Household Size by Tenure
Huntington Park
Female-Headed Households
Female-headed households are likely to live on lower incomes, and on one income only, and can have limited options for affordable, decent, and safe housing. As a result, single parents are among the groups most at risk of experiencing poverty.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-19
Of Huntington Park’s 14,577 total households, 24.4 percent are female headed (compared to 14.3 percent in the SCAG region), 12.5 percent are female-headed and with children (compared to 6.6 percent in the SCAG region), and 1.8 percent are female headed with children under 6 (compared to one percent in the SCAG region) (Table II-23). Female-headed households in Huntington Park experience greater rate of poverty proportional to their share of the total population. About 20 percent of all households experience poverty; female-headed households are about 45 percent of the total households experiencing poverty (about 40 percent all households experiencing poverty are female-headed households with children).4
Table II-23
Household Type by Tenure
Huntington Park
Resources Available
Single-parent and female-headed households can benefit from a variety of programs and services provided by the city of Huntington Park. The Huntington Park Library provides educational services to children. No-cost youth services for lower-income families and female-headed households are provided by Huntington Park through CDBG funding.5
A Community Needs Survey conducted in preparation of the 2015-2020 Consolidated Plan described youth centers as one of the top priority needs in the community. This is a gap in resources to female-headed households. Under Program 13, Affirmatively Furthering Fair Housing and Increasing Access to Opportunity, the City will seek and prioritize funding for resources to assist female-headed households.

Farm Workers
Farmworkers are traditionally defined as people whose primary incomes are earned through permanent or seasonal agricultural labor. Farmworkers are generally considered to have special housing needs due to their limited income and the often unstable nature of their employment. In addition, farmworker households tend to have high rates of poverty, live disproportionately in 4 U.S. Census Bureau, 2020 ACS 5-Year Estimates, Table B17012, Poverty Status In The Past 12 Months Of Families By Household Type By Number Of Related Children Under 18 Years. 5 City of Huntington Park, 2020-2024 Draft Consolidated Plan Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-20
housing that is in the poorest condition, have extremely high rates of overcrowding, and have low homeownership rates.

According to recent Census estimates, about 182 Huntington Park residents were employed in the agricultural industry, and 132 of those were employed full-time (Table II-24). The city is fully urbanized and no commercial agricultural operations exist within the jurisdictional boundaries.

Residents employed in agricultural industry commute to work outside of the city. The nearest agricultural area to Huntington Park is in San Bernardino County to the east. Since there are no major agricultural operations within Huntington Park and housing costs are significantly lower in the Inland Empire, there is little need for farm worker housing in the City.

Table II-24
Employment in the Agricultural Industry
Huntington Park
Resources Available
Because farmworkers make up a small percentage of the City’s population, no specific housing programs are necessary. The housing needs of farmworkers in Huntington Park can be addressed through the City’s general affordable housing programs for lower-income households. Certain programs and services offered by agencies detailed in Chapter 6 can also be of assistance to Huntington Park’s farmworkers.

People Experiencing Homelessness
Homelessness is a continuing and growing crisis throughout California and urban areas nationwide.

Government Code Section 65583(a)(7) mandates that municipalities address the special needs of homeless persons within their jurisdictional boundaries. “Homelessness” as defined by the U.S.

Department of Housing and Urban Development (HUD), describes:
• Individuals/families who lack a fixed, regular, and adequate nighttime residence, including:
o Place not meant for human habitation;
o Living in a shelter; or
o Exiting an institution.
• Individuals/families who will imminently (within 14 days) lose their primary nighttime residence.
• Unaccompanied youth (under 25 years of age) or families with children/youth. • Individuals/families fleeing or attempting to flee domestic violence.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-21
Individuals and families experiencing homelessness are without permanent housing largely due to a lack of affordable housing. Homelessness is often compounded by a lack of job training and supportive services to handle cases of domestic violence or treat mental illness or substance abuse.

The most recent homeless point-in-time count was conducted in January of 2022 by the Los Angeles Homeless Services Authority (LAHSA). There are an estimated 56,078 homeless persons in Los Angeles County (up from 54,291in 2020), and 86 unsheltered persons in Huntington Park (down from 282 in 2020).
6 Causes of homelessness in Los Angeles County are more varied than in Huntington Park, given the broader population surveyed. The majority of people are living on the street (27 percent), living in RVs/Campers (26 percent), in makeshift shelters (16 percent), or in tents (13 percent). In Huntington Park, the majority of people are living on the street (59 percent), followed by living in makeshift shelters (22 percent) (Figure II-1 and Figure II-2). The characteristics of Huntington Park’s homeless population indicate a greater need for emergency shelters.

Certain characteristics are available by Service Planning Area, which is a geographic region used by LAHSA and other Los Angeles County agencies. Service Planning Area (SPA) 7 includes the communities of Artesia, Bell, Bellflower, Bell Gardens, Cerritos, City of Commerce, City Terrace, Cudahy, Downey, East Los Angeles, Hawaiian Gardens, Huntington Park, La Habra Heights, Lakewood, La Mirada, Los Nietos, Maywood, Montebello, Norwalk, Pico Rivera, Santa Fe Springs, Signal Hill, South Gate, Vernon, Walnut Park, Whittier, and others. Demographic data by SPA is discussed in the Assessment of Fair Housing (AFH) (Homelessness), below. In SPA7, the largest subpopulations of persons experiencing homelessness are veterans, people experiencing domestic violence, and chronically homeless individuals (Figure II-3). Substance use, mental illness, and physical disabilities are also common characteristics. In addition to emergency housing, housing needs include transitional or supportive housing for these specific subpopulations to help them avoid returning to homelessness.

Geographic data collected as part of the point-in-time count is limited to the scale of the SPA.

Locally, City staff report that people experiencing homelessness congregate in the Downtown Specific Plan area (around Pacific Boulevard, Rita Avenue, and Rugby Avenue), along railroad rights of ways, parks, and the neighborhood defined by Slauson Avenue, Randolph Street, Santa Fe Avenue, and Alameda Street.

Program 13 (Homeless Services and Housing) contains provisions to reduce barriers to developing housing for people experiencing homelessness, including emergency shelters and transitional and supportive housing. Program 13 would concentrate outreach efforts in areas identified above. 6 Los Angeles Homeless Services Authority, 2020 and 2022 Homeless Count by Community/City. https://www.lahsa.org/data?id=45-2020-homeless-count-by-community-city Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-22
Figure II-1
Homeless County by Subpopulation, Service Planning Area 7, 2022 Source: Los Angeles Homeless Services Authority, 2022 Point-In-Time Count, 2022. https://www.lahsa.org/data?id=54-homelesscount-by-city-community and https://www.lahsa.org/data?id=51-homeless-count-by-service-planning-area-2015-2022 Figure II-2
Characteristics of Homelessness, Los Angeles County, 2022 Source: Los Angeles Homeless Services Authority, 2022 Point-In-Time Count, 2022. https://www.lahsa.org/data?id=54-homelesscount-by-city-community and https://www.lahsa.org/data?id=51-homeless-count-by-service-planning-area-2015-2022 Chronically
Homeless
Individuals
16% Chronically
Homeless Family
Members
1%
Serious Mental
Illness
6%
Substance Use
Issues
12%

HIV/AIDS
0%
Chronic Illness
7%
Physical Disability
6%
Brain Injury
3%
Veterans
34%
Domestic Violence
15%
Persons in Cars
10%
Persons in Vans
7%
Persons in
RVs/Campers
26%
Persons in Makeshift
Shelters
16%
Persons in Tents
13%
Persons on the
Street
27%
Persons in Safe
Parking
1%
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-23
Figure II-3
Characteristics of Homelessness, Los Angeles County, 2022 Source: Los Angeles Homeless Services Authority, 2022 Point-In-Time Count, 2022. https://www.lahsa.org/data?id=54-homelesscount-by-city-community and https://www.lahsa.org/data?id=51-homeless-count-by-service-planning-area-2015-2022 Resources Available
Homelessness has generally increased over time throughout California, but crisis housing resources established or improved during the COVID-19 pandemic were successful at temporarily housing many people formerly experiencing homelessness. However, many of those programs were temporary in nature, and increased local and regional resources are still needed.

There are currently no homeless shelters in the City of Huntington Park, but there is one permanent housing facility serving the City’s homeless population. Mosaic Gardens at Huntington Park has a total of 24 beds. Tiki Gardens is a transitional housing project with 35 units for homeless persons.

The City of Huntington Park does not administer a homeless prevention program; however, two local homeless providers, the Southeast Churches Service Center (partially funded with CDBG funds) and the Salvation Army Southeast Communities, both provide a referral service and transportation to the nearby Salvation Army Bell Shelter in the City of Bell. The Bell Shelter assesses the individual needs of homeless persons including case management, supportive and transitional housing, individual or group counseling, a drug and alcohol program, job search assistance, homeless veteran’s reintegration, adult education, and a mobile medical clinic.

The Los Angeles County Development Authority (LACDA) offers several programs and is involved in County initiatives designed to assist homeless individuals, families, and veterans in securing stable housing.

The City of Huntington Park Police Department (HPPD) is a member of the Southeast Regional Mental Evaluation Team (SERMET), a successful mental health and homeless outreach partnership with the Los Angeles County Department of Mental Health. SERMET facilitates police officers and mental health clinicians to work together to provide support and resources to the mentally ill and homeless population in the community. Resources include outreach, referral services to other Persons in Cars
3% Persons in Vans
10%
Persons in
RVs/Campers
4%
Persons in
Makeshift Shelters
22%
Persons in Tents
2%
Persons on the
Street
59%
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-24
institutions, and assistance with housing. Homeless individuals or families and those at risk of homelessness had the opportunity to get connected to supportive services, treatments, public resources, and support groups through the Salvation Army.

The City participates in SPA 7 of the Continuum of Care for Los Angeles City and County, and coordinates with the LAHSA, local communities, and various service agencies to provide a continuum of services and facilities for the homeless and persons at risk of becoming homeless.

The City’s 2022-2023 Annual Action Plan for the use of CDBG and HOME funds designates the following funds to homeless services:

1. $83,418 in CDGB funds to the Inner City Vision Program, which provides case management, referral, and/or supportive services to the City’s homeless residents

2. In 2021-2022, the City provided emergency food $83,418 to the Salvation Army Service Program, which provides laundry services and hygiene kits to Huntington Park’s homeless residents, those at risk of becoming homeless, and lower-income households The Los Angeles County Development Authority (LACDA) is the local public agency providing Housing Choice Vouchers in Huntington Park.

Homelessness has increased over time in Huntington Park and Los Angeles County, indicating the resources available are not meeting the demand for those resources. The City will evaluate its emergency shelter and transitional housing standards and revise them to be compliant with state law (Program 7, Zoning Code Updates) and seek and prioritize funding for homeless services (Program 13, Affirmatively Furthering Fair Housing and Increasing Access to Opportunity). For further discussion on emergency shelters and transitional housing, refer to Section IV, Housing Constraints.

Extremely Low-Income Households
Household income is a primary challenge affecting housing needs in a community, particularly for extremely low-income households, defined as earning 30 percent of the area median income or less. Approximately 35 percent of total households in Huntington Park were within the extremely low-income (ELI) category, and 42 percent of renter households are extremely low-income, compared to 14 percent of owner-occupied households (Table II-25).

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-25
Table II-25
Extremely Low-Income Households
Huntington Park
Extremely low-income households are more likely to experience housing problems. As described in more detail in Disproportionate Housing Needs in Assessment of Fair Housing, “housing problems” means cost burden and severe cost burden, overcrowding, and substandard housing conditions. 7 In Huntington Park, 91 percent of extremely low-income households have at least one housing problem, compared to under 30 percent of households earning more than the median income, and 70 percent of total households. Cost burden describes the extent to which a household pays more than 30 percent of its income on rent. Ninety percent of extremely low-income households are cost burdened, compared to two percent of households earning above the median income and 55 percent of all households.8

As discussed further in Displacement in Assessment of Fair Housing, extremely low-income households may be at particular risk of displacement. These households may also need assistance with housing subsidies, utility allowances, and other living expense subsidies, as well as supportive services.

Over time, there has not been significant changes in the correlation between a household’s status as extremely low-income and their likelihood of experiencing disproportionate housing needs. ACS 5-Year Estimates for 2010-2014 showed similar rates of extremely low-income households as a share of the total city population, and similar rates of experiencing housing problems.

The city will promote financial assistance for extremely low-income housing by supporting the Housing Choice Voucher program and encouraging ADU owners to participate in the program as landlords (Program 2, Accessory Dwelling Units and Missing Middle Housing) and publicize the program to city residents (Program 12, Fair Housing).
7 See 80 FR 42271, p. 42354 (2015). 8 HUD CHAS Data, 2014-2018 ACS. https://www.huduser.gov/portal/datasets/cp.html Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-26
The share of the City’s RHNA that must meet the needs of extremely low-income households is estimated to be 132 (Extremely Low-Income Housing Need), well below the estimated more than 14,000 extremely low-income households already living in the city.

Given the ratio of extremely low-income renter households to owner households, there is a significant need for additional rental housing affordable to extremely low-income households. The City’s homeless population is also likely to be extremely low income. Transitional and supportive housing and alternative housing such as single-room occupancy developments are all housing that can help meet the needs of extremely low-income households in Huntington Park. Through Program 13, Affirmatively Furthering Fair Housing, the City will facilitate the development of alternative housing types mentioned above, and update the City’s density bonus ordinance to provide greater incentives for projects that provide units for extremely low-income households.

Resources Available
The City has facilitated the development of eight residential developments, and the acquisition/rehabilitation of six projects with long-term affordability covenants on all or some of the units. There are 67 units in the Huntington Plaza Apartments project restricted for extremely lowincome households, well below the number of extremely low-income households in the city.

The Los Angeles County Development Authority (LACDA) serves as the public housing authority for the City of Huntington Park. LACDA operates the Housing Choice Voucher (HCV, formerly Section 8) Program in Huntington Park and manages some public housing projects in Huntington Park. The HCV program offers tenant-based assistance funded by the U.S. Department of Housing and Urban Development (HUD). Participants find their own rental housing in the open market and pay a portion of their income towards rent. The Housing Choice Voucher subsidizes the balance of the monthly rent through direct payments to the property owner.

LACDA also maintains and manages public and affordable housing located throughout Los Angeles County, although there are no LACDA properties in Huntington Park. 9 Assisted Housing at Risk of Conversion
California housing element law requires all jurisdictions to study all low-income housing units which may at some future time be lost to the affordable inventory by the expiration of some type of affordability restrictions. Assisted housing at risk of conversion are those housing projects with affordability restrictions that are scheduled to expire within ten years of October 2021 (the beginning of the Housing Element planning period).

Affordable projects in Huntington Park are financed through a variety of funding sources, including Low-Income Housing Tax Credits and HOME funds, which require long-term affordability controls.

There is one project, Concord Huntington Park, with a total of 162 assisted housing units at risk of conversion before October 2031, as shown in Table II-26 below. The city will monitor and coordinate with owners of at-risk projects to identify resources and ensure property noticing under Program 5, Monitoring and Preserving Affordable Housing. Program 5 contains a number of measures to direct City resources to preservation of at-risk units, including rental assistance, partnering with non-profit 9 Los Angeles County Development Authority, Locate Housing. https://www.lacda.org/public-housing/shared-info/locatehousing Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-27
organizations to acquire at-risk properties, providing rehabilitation assistance, providing lump-sum payments to purchase and extend affordability contracts.

Table II-26
Summary of At-Risk Units

PROJECT

NAME ADDRESS
NUMBER
AND

TYPE OF
UNITS

TYPE OF

SUBSIDY

ELDERLY
UNITS

CURRENT
OWNER

EARLIEST

DATE OF

EXPIRATION

OPTIONS FOR

RENEWAL
ATRISK
Middleton
Place
6614
Middleton
St
20 LIHTC
(19);
HOME
(11)
20 OldTimers
Housing
Development
Corp
1/1/2073
6822
Malabar St
6822
Malabar St
10 HOME 10 OldTimers
Housing
Development
Corp
7/1/2063
Casa Rita 6508 Rita
Ave
103 LIHTC
(102)
0 John
Stewart Co.
1/1/2035
Casa
Bonita
Senior
Apartments
6512
Rugby Ave
80 HOME
(79)
80 Western
Community
Housing, Inc
1/1/2033
Huntington
Plaza
Apartments
6330
Rugby Ave
182 LIHTC
(182),
HOME
(91)
0 USA
Properties
Fund, Inc
4/1/2068
6308
Bissell St
6308
Bissell St
7 HOME (6) 0 OldTimers
Housing
Development
Corp
4/1/2062
6340
Bissell
Street
Apartments
Project
6340
Bissell St
4 HOME 0 OldTimers
Housing
Development
Corp
4/1/2061
Acquisition/
Rehab
6342-6344
Bissell St
6342
Bissell St
4 HOME 0 OldTimers
Housing
Development
Corp
4/1/2062
Concord
Huntington
Park
6900
Seville Ave
162 LIHTC
(160),
HUD
insured
(162),
ProjectBased
Vouchers
(155)
0 Huntington
Concord
Partners LP
2029 Acquisition/Rehabilitation,
Rental Subsidies
162
Tiki
Apartments
7306 Santa
Fe Ave
36 LIHTC
(35)
0 7301 Santa
Fe Avenue
LP aka John
Stewart Co.
1/1/2071
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-28

PROJECT

NAME ADDRESS
NUMBER
AND

TYPE OF
UNITS

TYPE OF

SUBSIDY

ELDERLY
UNITS

CURRENT
OWNER

EARLIEST

DATE OF

EXPIRATION

OPTIONS FOR

RENEWAL
ATRISK
Mosaic
Gardens at
Huntington
Park
6337
Middleton
St
24 LIHTC
(23),
HOME
(11),
ProjectBased
Vouchers
(15)
0 Linc Housing
Corp
1/1/2068
TOTAL 632 0 162
Source: City of Huntington Park, 2022
Resources Available
Funding Sources to Preserve At-Risk Units
The following state and federal programs provide financing for assisted housing units. The City currently has no source of local or redevelopment funds.

Community Development Block Grant Program
The Community Development Block Grant (CDBG) Program provides annual grants on a formula basis to states, cities, and counties to develop viable urban communities by providing decent housing and a suitable living environment, and by expanding economic opportunities, principally for low- and moderate-income persons. The City’s Economic Development Department administers the City’s annual CDBG entitlement grant, which totaled $1,112,249 in 2022. According to the City’s 2022 Draft Annual Action Plan, $2,224,498 is expected to be available for the remainder of the Consolidated Plan period (2020 through 2024), based on the same funding level for future years.

No CDBG funding is currently allocated for preservation, and through Program 5, Monitoring and Preserving Affordable Housing, the City will pursue additional funding and in its next Action Plan, allocate CDBG funds for preservation prior to 2029 when the affordability agreement for Concord Huntington Park is anticipated to expire.

HOME Investment Partnerships Program
The HOME Investment Partnerships Program (HOME) is a HUD program that assists cities, counties, and non-profit community housing development organizations (CHDOs) to create and retain affordable housing for lower-income renters or owners. HOME funds are available as loans for housing rehabilitation, new construction, and acquisition and rehabilitation of single- and multifamily projects and as grants for tenant-based rental assistance. The City Economic Development Department administers the City’s annual HOME entitlement grant, which totaled $640,934 in 2021.

The 2022 Annual Action Plan estimates $1,281,868 for the remainder of the Consolidated Plan period (2020 through 2024), based on the same funding level for future years. The City also received an additional $2.2 million in HOME funds authorized by the American Rescue Plan. No HOME funds are currently allocated for preservation, and through Program 5, the City will pursue additional funding and, in its next Action Plan, allocate HOME funds for preservation prior to 2029.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-29
Housing Choice Voucher Program
The HUD-funded Housing Choice Voucher (formerly Section 8) program provides tenant-based rental assistance, Under HUD regulations, housing authorities may use up to 20 percent of its vouchers to units in an existing project if the owner agrees to rehabilitate the units or set aside a portion of the units. The Los Angeles County Development Authority (LACDA) administers the project-based voucher program for Huntington Park. Through Program 5, the City will advocate for projects in Huntington Park with at-risk units to be awarded project-based vouchers.

Low-Income Housing Tax Credit (LIHTC)
The Low-Income Housing Tax Credit (LIHTC) program awards tax credits to developers of affordable housing projects, which can then be sold to investors to fund the project development.

The California Tax Credit Allocation Committee (TCAC) develops scoring methodology and makes awards. LIHTC-funded projects in Huntington Park are listed in Table II-26, above.

California Housing Finance Agency (CalHFA)
CalHFA uses approved private lenders and purchases loans that meet CalHFA standards to support very low, low, and moderate income assisted units. CalHFA partners with jurisdictions, developers, and other organizations to provide a variety of resources including loan assistance programs for homebuyers and renters aimed at increasing housing opportunities for low- and moderate-income residents.

Qualified Entities
Public agencies, nonprofit and for-profit organizations are integral to preservation efforts.

Table II-27 is a list of organizations operating in Los Angeles County which have requested inclusion in HCD’s Qualified Entities list, and which have demonstrated the capacity to manage affordable housing properties.

Table II-27
Qualified Entities

ORGANIZATION ADDRESS CITY STATE

TYPE OF

ORGANIZATION
West Hollywood
Community Housing Corp.
7530 Santa Monica Blvd,
Suite 1
West Hollywood CA Local, regional, public
agency
City of Pomona Housing
Authority
505 South Garey Ave Pomona CA Local, regional, national nonprofit org.

Hollywood Community
Housing Corp.
1726 N. Whitley Ave Hollywood CA Local, regional, national nonprofit org.

Hope - Net 760 S. Westmoreland Ave Los Angeles CA Local, regional, national nonprofit org.

Skid Row Housing Trust 1317 E. 7th St Los Angeles CA Local, regional, national nonprofit org.

The Long Beach Housing
Development Co.
333 W. Ocean Blvd., 2nd Flr Long Beach CA Local, regional, national nonprofit org.

Housing Authority of the
City of Los Angeles
2500 Wilshire Blvd, PHA Los Angeles CA Local, regional, national public agency
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-30

ORGANIZATION ADDRESS CITY STATE

TYPE OF

ORGANIZATION
Century Housing
Corporation
1000 Corporate Pointe Culver City CA Local, regional, national public agency
FAME Corporation 1968 W. Adams Blvd. Los Angeles CA Local, regional, national nonprofit org.

American Family Housing 15161 Jackson St. Midway City CA Local, regional, national nonprofit org.

The Long Beach Housing
Development Co.
836 Avalon Ave Lafayette CA Local, regional, national
public agency
PICO Union Housing
Corporation
1038 Venice Blvd. Los Angeles CA Local, regional, national nonprofit org.

Korean Youth &
Community Center, Inc.
(KYCC)
680 S. Wilton Place Los Angeles CA Local, regional, national nonprofit org.

Long Beach Affordable
Housing Coalition, Inc
5855 Naples Plaza, Suite 209 Long Beach CA Local, regional, national public agency
Housing Corporation of
America
31423 Coast Highway, Ste.
7100
Laguna Beach CA Local, regional, national
public agency
Abode Communities 701 E. Third St., Ste. 400 Los Angeles CA Local, regional, national public agency
Southern California
Presbyterian Homes
516 Burchett St Glendale CA Local, regional, national
public agency
The East Los Angeles
Community Union
(TELACU)
1248 Goodrich Blvd. Los Angeles CA Local, regional, national public agency
LTSC Community
Development Corporation
231 East Third Street, Ste. G
106
Los Angeles CA Local, regional, national
nonprofit org.

Nexus for Affordable
Housing
1572 N. Main Street Orange CA Local, regional, national nonprofit org.

Francis R. Hardy, Jr. 2735 W. 94th Street Inglewood CA
A Community of Friends 9 Cushing, Ste. 200 Irvine CA
Many Mansions, Inc. 1459 E. Thousand Oaks
Blvd.,Ste.C
Thousand Oaks CA Local, regional, national
nonprofit org.

Winnetka King, LLC 23586 Calabasas Road, Ste.
100
Los Angeles CA
Los Angeles Housing &
Community Invest Dept
1200 W.7th Street, 9th Floor Los Angeles CA
Orange Housing
Development Corporation
414 E. Chapman Avenue Orange CA
Home and Community 2425 Riverside Place Los Angeles CA
Hart Community Homes 2807 E. Lincoln Ave Anaheim CA
Keller & Company 4309 Argos Drive San Diego CA
Poker Flats LLC 1726 Webster Los Angeles CA
Coalition for Economic
Survival
514 Shatto Place, Suite 270 Los Angeles CA
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-31

ORGANIZATION ADDRESS CITY STATE

TYPE OF

ORGANIZATION
Clifford Beers Housing,
Inc.
1200 Wilshire Blvd. Ste. 205 Los Angeles CA
CSI Support &
Development Services
201 E. Huntington Drive Monrovia CA
ROEM Development
Corporation
1650 Lafayette Circle Santa Clara CA
Abbey Road Inc. 15305 Rayen Street North Hills CA
Innovative Housing
Opportunities, Inc.
19772 Macarthur Bv., Ste.
110
Irvine CA Local, regional, national
nonprofit org.

Community Development
Commission
700 W. Main Street Los Angeles CA Local, regional, national public agency
Los Angeles County
Development Authority
700 W. Main Street Alhambra CA Local, regional, national public agency
Santa Fe Art Colony
Tenants Association
2415 S. Sante Fe Avenue,
Unit 2
Los Angeles CA Tenants' Association
San Gabriel Valley Habitat
for Humanity, Inc.
400 S Irwindale Ave Azusa CA Local, regional, national
nonprofit org.

New Economics for
Women
303 South Loma Drive Los Angeles CA Local, regional, national nonprofit org.

L + M Fund Management
LLC
1865 Palmer Ave Westchester NY Profit-motivated individual or organization
Alliance Property Group
Inc
1730 E Holly Ave #327 El Segundo CA Profit-motivated individual or organization
NewStart Housing
Corporation
3355 E. Gage Ave. Huntington Park CA
Source: City of Huntington Park, 2022 and California Department of Housing and Community Development, Preserving Existing Affordable Housing, list of qualified entities, 2022. https://www.hcd.ca.gov/policy-research/preserving-existing-affordable-housing.shtml Cost Comparison
The estimated cost to preserve at-risk units is difficult to fully calculate due to the various options, affordability, potential density bonus entitlement costs, and developer and land profits costs. In general, providing additional incentives/subsidies to extend the affordability covenant would require the least funding over the long run, whereas the construction of new units would be the costliest option.

The following analysis demonstrates the cost to the City to preserve these at-risk units. Acquisition and/or rehabilitation is the most cost-effective, feasible method of preservation for most at-risk units.

New Construction
Preserving existing affordable units is the surest way to ensure existing affordable homes remain affordable—building new affordable housing is a slow and expensive process. According to the Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-32
University of Riverside School of Business,10 the estimated cost to build new housing in Huntington Park is $712,156 per unit, which includes the estimated construction costs, development impact fees, and land and building costs (Table II-28). Therefore, the estimated total cost to replace all 162 at-risk units would be over $115 million.

Table II-28
Estimated New Construction Costs (Huntington Park)

ESTIMATE

CONSTRUCTION COST
PER UNIT*

ESTIMATED IMPACT

FEE PER UNIT

ESTIMATED LAND AND

BUILDING COSTS PER
UNIT

ESTIMATED GROSS

BUILDING COSTS PER
UNIT
$579,133 $30,000 $103,023 $712,156
*Construction per unit estimate based on UCR, School of Business, Economy White Paper Series, February 2020 Acquisition/Rehabilitation
The majority of the assisted housing units at risk of conversion in Huntington Park are nonprofit owned, which makes preservation more likely given sufficient appropriate resources.

If an at-risk property consists of 100 percent deed-restricted affordable units, transferring ownership of an at-risk project to a non-profit housing provider is one of the least costly ways to ensure that the at-risk units remain affordable for the long term. By transferring property ownership to a non-profit organization, low-income restrictions can be secured, and the project would become potentially eligible for a greater range of governmental subsidies.

California law (Affordable Housing Preservation Law, Government Code Sections 65863.10-13) requires owners of certain deed-restricted properties to follow a specified procedure prior to the expiration of those affordability requirements. The law requires that rental housing with expiring federal and/or state subsidies and/or affordability protections be offered for sale first to qualified preservation purchasers at market-rate value.

If only a portion of a property has deed-restricted units, it is more difficult to preserve the affordable units by acquisition. In those cases, rehabilitation funds (CDBG, HOME, PBVs, or LIHTC) may be used to rehabilitate and preserve affordability for a portion of the project’s units.

Rental Subsidies
Similar to Housing Choice Vouchers, the City could provide rent subsidies to tenants of at-risk units through a variety of potential funding sources. The level of the subsidy required to preserve the atrisk units is estimated to equal the Fair Market Rent (FMR) for a unit minus the housing cost affordable to a lower income household. According to HUD, FMR for a 1-bedroom unit is $1,517.

State, local, or other funding sources can also be used to provide rental subsidies to maintain the affordability of at-risk projects. These subsidies can be structured to mirror the voucher program, whereby the subsidy covers the cost of the unit above what is determined to be affordable for the tenants’ household income (including a utility allowance) up to the fair market value of the apartment. The per-unit subsidy is based on the difference between fair market rents and the annual 10 UCR, School of Business, Economy White Paper Series: https://ucreconomicforecast.org/wpcontent/uploads/2020/03/UCR_CEFD_Multifamily_Housing_White-Paper_3_2020.pdf Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-33
amount affordable to a low-income household. Given the unit sizes and affordability of the at-risk developments, the total annual subsidy to maintain the 391 at-risk units is estimated at over $1.8 million, as shown in Table II-29 below.

Table II-29
Rent Subsidies Required to Preserve At-Risk Rental Units UNIT

SIZE/HOUSEHOLD
SIZE
NUMBER

OF UNITS
FAIR
MARKET
RENT1

HOUSEHOLD
ANNUAL
INCOME2

AFFORDABL

E HOUSING
COST3

MONTHLY

PER UNIT
SUBSIDY4
TOTAL

MONTHLY

SUBSIDY
TOTAL
ANNUAL

SUBSIDY
1-bedroom/2-person
household
391 $1,517 $45,050 $1,113 $404 $157,964 $1,895,568

1. Fair Market Rent (FMR) is determined by HUD. These calculations use the 2020 HUD FMR for the Los Angeles-Long Beach-Glendale, CA HUD Metro FMR Area.

2. FY 2021 Income Limits Summary for the Los Angeles-Long Beach-Glendale, CA HUD Metro FMR Area.

3. The affordable housing cost is calculated based on 30% of the AMI, minus utilities for rentals.

4. The monthly subsidy covers the gap between the FMR and the affordable housing cost.

5. Rents are restricted to 50% AMI in these buildings, which puts residents in the Very Low Income Category, set by the California Department of Housing and Community Development (HCD).

Future Growth Needs
Overview of the Regional Housing Needs Allocation
The Regional Housing Needs Allocation (RHNA) is a key requirement for local governments to plan for anticipated growth. The RHNA quantifies the anticipated need for housing within each jurisdiction for the 6th Housing Element cycle extending from July 2021 to October 2029.

Communities then determine how they will address this need through the process of updating the Housing Elements of their General Plans.

The RHNA for the 6th cycle was adopted by the Southern California Association of Governments (SCAG) in March 2021. The need for housing is determined by the forecasted growth in households as well as existing need due to overcrowding and overpayment. Each new household created by a child moving out of a parent’s home or by a family moving to a community creates the need for a housing unit. The housing need for new households is then adjusted to maintain a desirable level of vacancy to promote housing choice and mobility. An adjustment is also made to account for units lost due to demolition, natural disaster, or conversion to non-housing uses. Total housing need is then distributed among four income categories on the basis of the county’s income distribution, with adjustments to avoid an over-concentration of lower-income households in any community.

More information about the RHNA process may be found on SCAG’s website at https://scag.ca.gov/rhna.
2021-2029 Huntington Park Growth Needs
The total housing growth need for the City of Huntington Park during the 2021-2029 planning period is 1,605 units. This total is distributed by income category as shown in Table II-30.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-34
Table II-30
2021-2029 Regional Housing Growth Needs
Huntington Park

VERY LOW LOW MODERATE ABOVE MODERATE TOTAL
264* 196 243 902 1,605
*Per state law, half of the very low units are assumed to be in the extremely low category Source: SCAG 3/4/2021
The City’s inventory of land to accommodate its share of the RHNA is discussed in Section III, Resources and Opportunities.

Extremely Low-Income Housing Need
The RHNA does not project the need for extremely low-income units, but pursuant to Housing Element law (Government Code Section 65583(a)), the City must project its extremely low-income housing needs using one of two methodologies census data to determine the number of extremely low-income households in the city, or assume 50 percent of the very low-income households qualify as extremely low income, and therefore assume 50 percent of the City’s very low-income RHNA to be extremely low income.

In this analysis, the projected housing needs for extremely low-income households are estimated at 50 percent of the very low-income RHNA. The City’s very low-income allocation is 264 units.

Therefore, the City’s extremely low-income housing need is 132 units.

Assessment of Fair Housing (AFH)
Introduction
To adequately meet the housing needs of all segments of the community, the Housing Plan must promote housing opportunities for all people.

Pursuant to Government Code Section 65583, cities and counties are required to take deliberate action to relieve patterns of segregation and foster inclusive communities. Housing Elements are now required to include the following:
• Fair Housing Enforcement and Outreach: The Housing Element must describe the City’s fair housing enforcement and outreach capacity, which must include meaningful, frequent, and ongoing public participation with stakeholders.
• Integration and Segregation: The Housing Element must describe patterns of integration and segregation across multiple demographic characteristics, both locally in the city and regionally.
• Disparities in Access to Opportunity: Using state opportunity mapping tools, the Housing Element must analyze the areas of the city with the disparities in access to opportunity, including education, economic, and environmental outcomes. The Housing Element must compare access to opportunity within the city and compared to the region. • Disproportionate Housing Needs: The Housing Element must analyze the extent to which different population groups experience disproportionate housing needs.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-35
• Analysis of Sites Inventory: Local jurisdictions must evaluate and address how particular sites available for housing development will meet the needs of households at all income levels. The Housing Element must analyze and conclude whether the identified sites improve or exacerbate conditions for fair housing.
• Identification of Contributing Factors: Based on findings from the previous steps, Housing Elements must identify, evaluate, and prioritize the contributing factors related to fair housing issues.
• Priorities, Goals, and Actions: Local jurisdictions must adopt fair housing goals and actions that are significant, meaningful, and sufficient to overcome identified patterns of segregation and affirmatively further fair housing. The Housing Element should include metrics and milestones for evaluating progress and fair housing results.

The assessment of fair housing practices examines existing conditions and demographic patterns, concentrated areas of poverty within the city, concentrated areas of low- and median-income housing, and areas of low and high opportunity to identify segregated living patterns and replace them with integrated and balanced living patterns.

The purpose of this analysis is to provide a basis for policies and programs that will replace segregated living patterns with truly integrated and balanced living patterns to transform racially and ethnically concentrated areas of poverty into areas of opportunity. Community amenities and access to opportunities are inherently spatial in nature and are not always readily accessible or attainable due to the different types of social, cultural, and economic barriers in our society.

Ensuring that sites for housing, particularly lower-income units, are in high resource areas rather than concentrated in areas of high segregation and poverty requires jurisdictions to plan for housing with regards to the accessibility of various opportunities including jobs, transportation, good education, and health services.

Fair Housing Enforcement and Outreach Capacity
Enforcement
Fair housing complaints can be used as an indicator to identify characteristics of households experiencing discrimination in housing. Pursuant to the California Fair Employment and Housing Act Government Code Section 12921 (a), the opportunity to seek, obtain, and hold housing cannot be determined by an individual’s “race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, marital status, national origin, ancestry, familial status, source of income, disability, veteran or military status, genetic information, or any other basis prohibited by Section 51 of the Civil Code.”
Fair housing issues include, but are not limited to:
• Housing design that makes a dwelling unit inaccessible to an individual with a disability; • Discrimination against an individual based on race, national origin, familial status, disability, religion, sex, or other characteristics when renting or selling a housing unit; and • Disproportionate housing needs, including cost burden, overcrowding, substandard housing, and risk of displacement.

The City refers discrimination complaints to the Fair Housing Foundation (FHF) to conduct outreach related to fair housing.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-36
Table II-31
Fair Housing Foundation Complaints
TYPE OF COMPLAINT 2014-15 2015-16 2016-17 2017-18 2018-19 2019-20 Mental/Physical Disability 3 3 1 - 1 2
Race/Ethnicity - - - - - -
Familial/Marital Status - - - 2 1 -
Female-Headed Households 16 15 7 15 8 24
Gender/Sexual Orientation - - - - - 1
FHF Resolved 55 46 62 61 31 33
Total Unduplicated 320 312 248 240 194 189
Source: Fair Housing Subrecipient Quarterly Performance Reports (SQPR) According to the data, around 20 percent of complaints received are resolved by FHF by the time the report is sent out. Generally, most complaints received were in regard to rent increases, habitability, and notices. Most of the fair housing-related complaints were of mental/physical disabilities at an average of two or three complaints per year and an average of 14 of the complaints are from female-headed households.

Outreach
FHF reaches the Huntington Park community in a variety of ways to provide services regardless of language or mobility. FHF hosts fair housing workshops in person and virtually, in English, Spanish, and Vietnamese. Workshops are targeted to tenants, landlords, property managers, property owners, attorneys, and realtors. In-person events are held in different cities on a weekly basis.

Every year, the FHF provides updated literature to the city and participates in presentations on an as-needed basis. On request, FHF staff will give presentations to community groups about their services and conduct staff trainings.

FHF holds “walk-in” clinics (in-person and virtually) that allow tenants and landlords to meet with a Housing Counselor one-on-one to discuss fair housing issue and ask questions. Services are provided in all languages.11
Integration and Segregation
Race, Ethnicity, and Poverty
The ethnic and racial composition of a region is useful in analyzing housing demand and any related fair housing concerns as it tends to demonstrate a relationship with other characteristics such as household size, locational preferences, and mobility. Low-income and communities of color disproportionately experience issues related to overcrowding, housing problems, and access to economic opportunity due to exclusionary governmental policies, biased mortgage lending practices and other tactics that promote segregation and spatial inequities. 11 Fair Housing Foundation. https://fhfca.org/
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-37
According to HCD, race is a known contributor to unfair housing practices.12 The existence of concentrations of minorities living in one location may be an indicator that some minority groups in Huntington Park do not have as many housing choices as nonminority residents. Huntington Park is predominantly Hispanic/Latino (97 percent and unchanged since 2010).

The city has become more concentrated since 2010; in 2018, the population of all census tracts in the city was over 80 percent non-white (Figure II-4). In 2010, that level of concentration was limited to two tracts in the northwestern part of the city, with the majority of the city in the range of 41 to 60 percent non-white, and one census tract near Salt Lake Park in the 21 to 41 percent range.

Census tracts in Vernon, to the north, are in the less than 41 to 60 percent non-white category, while all other surrounding communities are similarly concentrated.

The city’s diversity index has not changed from 2010 to 2018. There are high-diversity Census block groups in the western part of the city, and lower-diversity block groups scattered throughout the central and southern portion of the city.

Residents who are linguistically isolated may face additional challenges with becoming integrated.

They may face potential barriers to employment and adequate housing, which may dictate where they may choose or be able to settle and locate. More than 40 percent of the population in California speak a language other than English at home.13 The CalEnviroScreen linguistic isolation indicator measures the percentage of households in each census tract in which no one over 14 speaks English well. The Huntington Park Environmental Justice Technical Report (2022) analyzed the rate of linguistic isolation by census tract, finding that all census tracts in the city have a high rate of linguistic isolation, above the 75th percentile. Many tracts scored above the 90th percentile. There is no notable geographic trend in linguistic isolation. The primary language spoken besides English throughout the City is Spanish, but there are areas where a significant portion of the population speaks Chinese and Tagalog. The city’s population is about 46 percent foreign-born, compared to about 26 percent statewide.14
Regional Context
According to the California Fair Housing Task Force’s 2021 opportunity maps, areas in the Los Angeles region with high segregation and poverty are most prominent in the neighborhoods surrounding Downtown Los Angeles, South Central Los Angeles, and East Los Angeles. Areas of high segregation and poverty are also present within the San Fernando Valley region near the neighborhoods of Panorama City, Arleta, and North Hills. In North Los Angeles County, high segregation and poverty areas are present within the cities of Palmdale and Lancaster (Figure II-5).

Race and ethnicity characteristics mirror segregation and poverty trends. Hispanic populations are most concentrated in and around South Los Angeles, to the north of Los Angeles near San Fernando, and in central Orange County near the City of Santa Ana. Asian populations are most concentrated just east of Downtown Los Angeles and in East Los Angeles, near Alhambra and Monterey Park. The largest concentration of black populations can be found in South Los Angeles and unincorporated areas nearby, such as Athens-Westmont and View Park/Windsor Hills. White populations tend to have highest concentrations near the coast and along the Interstate 210 Corridor south of the San Gabriel Mountains. (See Figure II-5, Figure II-7, and Figure II-9.) 12 HCD, AFFH Guidance, p 5. 2021. https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4- 27-2021.pdf#page=23 13 ACS 2020 ACS 5-Year Estimates, Table S1601 Language Spoken At Home 14 2020 ACS 5-Year Estimates, Table DP02 Selected Social Characteristics Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-38
Figure II-4
Racial Demographics (2018), Huntington Park
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-39
Figure II-5
Racial Demographics (2018), Los Angeles Region
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-40
Figure II-6
Predominant Population – Hispanic Majority, Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-41
Figure II-7
Predominant Population – Hispanic Majority, Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-42
Figure II-8
Diversity Index (2018), Huntington Park
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-43
Figure II-9
Diversity Index (2018) Los Angeles Region
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-44
Disability
The US Census Bureau defines disability as one of the following: hearing difficulty, vision difficulty, cognitive difficulty, ambulatory difficulty, self-care difficulty, and independent living difficulty.

Physical, mental, and/or developmental disabilities may prevent a person from working, restrict one’s mobility, or make it difficult to care of oneself. Disabled persons often have special housing needs related to limited earning capacity, a lack of accessible and affordable housing, and higher health costs associated with a disability. The living arrangement of persons with disabilities depends on the severity of the disabilities and the available resources. Many persons live at home in an independent arrangement or with other family members. To maintain independent living, persons living with disabilities may need assistance.

Affordability, design, location, and discrimination significantly limit the supply of housing available to households of persons with disabilities. Housing opportunities for disabled persons are impeded by practices in both the private and public sectors. For instance, “denied reasonable modification/accommodation” is often cited as an alleged act in housing discrimination complaints.

Additionally, apartment rental ads often state “no pets allowed,” although disabled persons may have service or companion animals. In the public sector, housing opportunities can be impeded because a community has not adopted a reasonable accommodation procedure, or if adopted, has not made the procedure widely known in the community.

As discussed in Housing for Special Needs Populations, in Huntington Park, the most prevalent types of disabilities are ambulatory difficulty, independent living difficulty, and cognitive difficulty.

The most prevalent type of disability for residents age 65 and older is an ambulatory disability. The percentage of Huntington Park’s residents living with a disability (about 19 percent) has remained stable from 2015 to 2020.15
There is a concentration of residents with disabilities located in the northwestern portion of the city, in and around the Downtown Specific Plan area. (Figure II-10). HUD Fair Housing Enforcement Office (FHEO) data shows that the majority (65 to 85 percent) of fair housing cases in Huntington Park involve a disability bias (Figure II-12). Huntington Park’s Fair Housing Foundation quarterly reports from 2014-2021 indicate that the city averages approximately one to three disability complaints per year.

Due to the concentration of persons with a disability in the DTSP area, and the large number of housing inventory sites in that area, Program 11 (Density Bonus and Other Affordable Housing Incentives) will amend the City’s density bonus program to provide incentives for including universal design elements into new housing projects.

Regional Context
Approximately 10 percent of the Los Angeles County population lives with one or more disabilities (2015-2019 ACS estimates). Of this total population living with one or more disabilities, 6.6 percent is age 18 or younger, 44.9 percent are between the ages of 18 and 64, and 46.4 percent are 65 and older, showing that adults and senior citizens are more likely than younger residents to live with disabilities. Figure II-11 shows the percent of population living with disabilities for each census tract in the Los Angeles County region. Census tracts south of Los Angeles around Huntington Park are a mixture of 10 to 20 percent of the population living with a disability. 15 ACS 2015 & 2020 ACS 5-Year Estimates, Table S1810 Disability Characteristics.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-45
Similar to Huntington Park, FHEO data shows that the majority (65 to 85 percent) of fair housing cases in Los Angeles County involve a disability bias (Figure II-12).

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-46
Figure II-10
Population with a Disability By Census Tract (2014), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-47
Figure II-11
Population with a Disability by Census Tract (2019), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-48
Figure II-12
FHEO Cases – Disability Bias (2020), Huntington Park
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-49
Figure II-13
FHEO Cases – Disability Bias (2020), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-50
Familial Status
The Fair Housing Act (FHA)16 bans discrimination based on certain protected classes, including “familial status.” Familial status refers to the presence of children under the age of 18, regardless of whether the child is biologically related to the head of household, and the marital status of the head of households. All families with children are protected by the FHA against familial status discrimination, including same-sex couples with children and single-parent households. HUD provides examples of familial discrimination as (a) refusing to rent to families with children; (b) evicting families once a child joins the family through, e.g., birth, adoption, custody; (c) requiring families with children to live on specific floors or in specific buildings or areas; (d) imposing overly restrictive rules about children’s use of the common areas (e.g., pools, hallways, open spaces); and I advertising that prohibits children.17 Families with children may face housing discrimination by landlords who fear that children will cause property damage. Some landlords may have cultural biases against children of the opposite sex sharing a bedroom. Differential treatments such as limiting the number of children in a complex or confining children to a specific location are also fair housing concerns. HUD data shows that familial status discrimination ranks third in discrimination of protected classes, behind discrimination due to disability and race.18 Single-parent households are protected by Government Code Section 65583(a)(7). Because they are likely to live on one income only, single-parent households can have limited options for affordable, decent, and safe housing. As a result, single parents are among the groups most at-risk of experiencing poverty.

Large families can also experience housing discrimination as property owners impose occupancy limitations that can preclude large families with children.

As discussed in more detail in Housing for Special Needs Populations, in Huntington Park, about 24 percent of all households are female headed. Of those, about 13 percent are female-headed and with children, and two percent are female-headed and with children under six. The percentage of total households that are female headed has not changed significantly since 2015 (increase of four percent).19
Populations in the northeastern portion of the city adjacent to Vernon and Bell are 60 to 80 percent married couples with children (Figure II-14). The remainder of the city is 40 to 60 percent married couples with children.

In Huntington Park, female-headed households are concentrated in the central part of the city, the downtown area (Figure II-16). These areas have between 40 to 60 percent of children living in female-headed households. The remainder of the city has between 20 to 40 percent of children living in female-headed households.
16 42 U.S. Code sections 3601, et seq., the Fair Housing Act. 17Department of Housing and Urban Development, Fair Housing Enforcement Office, “Discrimination Against Families with Children.”
https://www.hud.gov/program_offices/fair_housing_equal_opp/discrimination_against_families_children#_Who_Is_Pr otected? 18 U.S. Department of Housing and Urban Development. “Annual Report on Fair Housing FY 2017.” 19 U.S. Census Bureau, 19 2020 & 2015 ACS 5-Year Estimates, Table B11001, Household Type (Including Living Alone).

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-51
Throughout the city, 20 to 40 percent of adults are living with a spouse, and less than 20 percent of the population over 18 is living alone.20
The city’s demographics show that there is a need for family housing more than housing ideal for single-person households. Through Program 7 (Zoning Code Updates), the City will update its zoning code to provide incentives for new housing projects to include family housing and services.

Regional Context
The SCAG region has a lower share of households that are female headed than Huntington Park.

About 14 percent of households in the SCAG region are female headed, and about seven percent are female headed and with children, also lower than Huntington Park. (Special Housing Needs) The percentage of total households that are female headed in Los Angeles County has not changed significantly since 2015, though in contrast to Huntington Park’s four percent increase, it has decreased by four percent.21
In Los Angeles County, about 60 percent of owner-occupied households are married couple families while 23 percent are categorized as non-family households. Additionally, 12 percent owneroccupied households are headed by a female householder while six percent are headed by a male householder.

In contrast, non-family households constitute 42 percent of renter-occupied households and 33 percent are categorized as married-couple families. More single-parent renter households are female headed (17 percent) than male headed (eight percent).

There are greater percentages of children in married-couple households in relatively less urbanized communities of the county. For example, highly urbanized neighborhoods within and surrounding the City of Los Angeles have lower percentages of children in married-couple households as compared to cities located near the coastal region and the county periphery. Furthermore, areas with higher percentages of children in married-couple households are generally located in areas with relatively higher TCAC opportunity scores. (See Figure II-15 and Figure II-16.) While less than 20 percent of adults live alone in most of the county, areas surrounding the cities of Los Angeles, West Hollywood, Santa Monica, and Pasadena are estimated to have higher percentages of adults living alone. (See Figure II-18, and Figure II-19.) 20 Add reference—AFFH viewer
21 U.S. Census Bureau, 21 2020 & 2015 ACS 5-Year Estimates, Table B11001, Household Type (Including Living Alone).

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Figure II-14
Percent of Children in Married-Couple Households (2019), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-53
Figure II-15
Percent of Children in Married-Couple Households (2019), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-54
Figure II-16
Percent of Children in Female Householder, No Spouse/Partner Present Households (2019), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-55
Figure II-17
Percent of Adults Living with Spouse/Partner (2019), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-56
Figure II-18
Percent of Adult Population Living Alone (2019), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-57
Figure II-19
Percent of Population 18 Years and Older in Households Living Alone (2019), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-58
Income
Identifying lower-income geographies and individuals is essential to overcoming patterns of segregation. Household income is directly connected to the ability to afford housing. Higher incomes households are more likely to own rather than rent housing. As household income decreases, households tend to pay a disproportionate amount of their income for housing and the number of persons occupying unsound and overcrowded housing increases.

There are several metrics used to identify concentrated areas of lower-income households. HUD defines a low- or moderate-income (LMI) area as a census tract or block group where over 51 percent of the population is LMI (which HUD defines as earning up to 80 percent of the area median income).

The percentage of households in a given area living below poverty thresholds can also indicate a concentration of lower-income households. In Huntington Park (Figure II-20), the majority of the census tracts are in the range of 10 to 30 percent, with census tracts where 30 to 40 percent of the population live in poverty located in the northeasterly area of the city adjacent to the downtown area and the southern portion of the city bordered by portions of unincorporated areas of Los Angeles County. The percentage of households living below the poverty level has decreased slightly from 2015 (29.6 percent) to 2020 (21.6 percent).22 Figure II-22 shows the median income in Huntington Park. Areas with median income of $30,000 or less are located in central portions of the Downtown Specific Plan. The lower median income in that area could be due to the amount of senior and affordable housing.

Regional Context
The median income in Los Angeles County varies widely across jurisdictions (Figure II-23).

Figure II-21 displays large concentrations of low- and moderate-income populations in and around the City of Los Angeles and scattered throughout cities in the San Fernando and San Gabriel Valley regions. The largest concentration of low- to moderate-income groups is in the downtown and south-central neighborhoods of Los Angeles. It is estimated that between 75 and 100 percent of residents in these areas are low to moderate income. Regionally, coastal cities such as Rancho Palos Verdes and Malibu have far fewer lower-income residents (less than 25 percent), except for the cities of Long Beach, Malibu, and Santa Monica, where a greater percentage of lower-income populations are present.

In those areas where the low- and moderate-income population is a small percentage of the overall population, median annual household income also tends to be greater than $100,000. In areas with higher lower-income populations, median income is less than $40,000.

The percentage of the population living below the poverty level in Los Angeles County is 14.2 percent in 2020, lower than in Huntington Park. Similar to Huntington Park, that figure has decreased slightly since 2015, when 18.2 percent of the population was below the poverty level.23 22 U.S. Census Bureau, 2015 and 2020 ACS 5-Year Estimates, Table S1701, Poverty Status in the Past 12 Months. 23 23 U.S. Census Bureau, 2015 and 2020 ACS 5-Year Estimates, Table S1701, Poverty Status in the Past 12 Months.

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Figure II-20
Poverty Status By Census Tract (2019), Huntington Park
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Figure II-21
Low to Moderate Income Population, Los Angeles County
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Figure II-22
Median Income (2019), Huntington Park
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Figure II-23
Median Income (2019), Los Angeles Region
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Racially and Ethnically Concentrated Areas of Poverty
Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) are neighborhoods in which there are both racial concentrations and high poverty rates. HUD’s definition of R/ECAP is:
• A census tract that has a non-white population of 50 percent or more (majority-minority) or, for non-urban areas, 20 percent, as well as a poverty rate of 40 percent or more; OR • A census tract that has a non-white population of 50 percent or more (majority-minority) and the poverty rate is three times the average tract poverty rate for the county, whichever is lower.

A southwestern portion of the city meets HUD’s definition of a R/ECAP (Figure II-24). This portion of the city is on the border of unincorporated Los Angeles County and borders E. Florence Avenue to the south, S. Alameda Street to the east, Zoe Avenue to the north, and Stafford Avenue to the east. Like the rest of the city, this area is predominantly Hispanic/Latino.

Regional Context
Countywide, poverty and segregation may work to exasperate existing impediments such as concentrations of lower- and moderate-income populations, lending discrimination, and overcrowded conditions. Figure II-25 shows areas of high segregation and concentrated poverty throughout Los Angeles County. The most prominent RECAP areas are in the south-central region of the City of Los Angeles. According to the Urban Displacement Project, these RECAP areas contain Neighborhood Segregation tracts that are predominantly Black-Latinx, Mostly Latinx, and 3 Group Mix (Black-Latinx-White). RECAP areas are also present in the cities of Long Beach, Huntington Park, Bell, Bell Gardens, Compton, Palmdale, Lancaster, and Pomona. A large portion of these RECAP areas predominantly Hispanic/Latino. A smaller portion of these areas have a sizeable gap for predominant Hispanic/Latino Majority. Only a few isolated tracts of African American Majority and Asian Majority occur in Long Beach, Compton, and the south-central region of the City of Los Angeles. In addition, most of these tracts also contain LMI concentrations, specifically in the Los Angeles, Compton, and Long Beach (Figure II-25).

Most neighboring communities also contain R/ECAPs, including Bell, the City of Los Angeles, South Gate, Lynwood, Westmont, and Willowbrook.

Racially/Ethnically Concentrated Areas of High Segregation and Poverty Some neighborhoods may not meet the definition of a R/ECAP, but nevertheless are areas of high segregation and poverty. In Huntington Park, these are the central areas in the downtown area and the southern portion of the city along E. Florence Avenue, which borders portions of unincorporated areas of Los Angeles County (Figure II-26).

Regional Context
Regionally, much of Los Angeles to the west of Huntington Park is an area of high segregation and poverty, as well as portions of Bell, Bell Gardens, and Cudahy (Figure II-26 and Figure II-27).

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Figure II-24
Racially or Ethnically Concentrated Areas of Poverty (2009-2013), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-65
Figure II-25
Racially or Ethnically Concentrated Areas of Poverty (2009-2013), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-66
Figure II-26
TCAC Area of High Segregation and Poverty (2021), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-67
Figure II-27
TCAC Areas of High Segregation and Poverty (2021), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-68
Concentrated Areas of Affluence
While RECAPs have long been the focus of fair housing policies, racially concentrated areas of affluence (RCAAs) must also be analyzed to ensure housing is integrated, a key to fair housing choice. HCD defines an RCAA as a census tract in which 80 percent or more of the population is white and has a median income of at least $125,000.
24 There are no RCAAs in Huntington Park.

Regional Context
Many coastal cities, including Malibu, Santa Monica, Redondo Beach, and Rancho Palos Verdes, reflect a white majority (Figure II-23). Areas of white majority that correspond to areas that have low concentration of low- and moderate-income populations include the Palos Verdes Peninsula, Hollywood Hills, Santa Monica Mountains, and La Cañada/Flintridge (Figure II-23). Pasadena ($83,068), South Pasadena ($104,308), and San Marino ($166,607) have higher median household incomes than Huntington Park ($46,738) and Los Angeles County ($71,358). Census data reflect white majorities within these census tracts.

Access to Opportunity
An area’s access to opportunity is defined by HUD as its potential to support positive economic, educational, and health outcomes for low-income families, particularly in terms of long-term outcomes for children. The Department of Housing and Community Development (HCD) and the California Tax Credit Allocation Committee (TCAC) analyzed poverty rates, school proficiency, unemployment rates, jobs proximity, transit metrics, and CalEnviroScreen 4.0 scores to assess access to opportunity throughout the City of Huntington Park. The 2021 TCAC/HCD Opportunity Maps are comprised of composite index scores, including education, economic, and environmental.

The higher composite scores mean more access to resources that offer residents a better chance at economic advancement, positive educational outcomes, and better physical and mental health.

The majority of the city is categorized as low resource (Figure II-28); these areas are concentrated around the borders of the city, which neighbor the City of Vernon and the City of Bell. There are also areas of high segregation and poverty in the central regions of the city (discussed further in Racially and Ethnically Concentrated Areas of Poverty, above).

Educational Score
Educational outcome scores are based on the following indicators:
• Math proficiency (the percentage of 4th graders who meet or exceed math proficiency standards)
• Reading proficiency (the percentage of 4th graders who meet or exceed literacy standards) • High school graduation rates (the percentage of high school cohort that graduated on time) • Student poverty rate (the percent of students not receiving free or reduced-price lunch) Most of the city has low educational outcome scores (less than 0.5 on a scale of 1). Areas with a higher outcome score are south of the downtown area (Figure II-30). 24 https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf.

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Regional Context
Surrounding communities have similar educational outcome scores. Much of Walnut Park, in unincorporated Los Angeles County, adjacent to the area of higher educational outcome score in Huntington Park, has a similarly high score. Vernon and the City of Los Angeles to the north and west, Bell to the east, and South Gate and Cudahy to the south have low scores (lower than 0.5 with many areas lower than 0.25). See Figure II-29 for regional scores.

Economic Score
The educational outcome scoring methodology is based on the following indicators:
• Poverty (the percent of the population with income above 200 percent of the federal poverty line)
• Adult education (the percent of adults with a bachelor’s degree or above) • Employment (the percent of adults aged 20-64 who are employed in the civilian labor force or in the armed forces)
• Job proximity (the number of jobs filled by workers with less than a bachelor’s degree that fall within a given radius (determined by the typical commute distance of low-wage workers in each region)
• Median home value (value of owner-occupied units)
The majority of Huntington Park has low economic scores. A small concentration of Census tracts located in the northern portion of the city received a high Economic Opportunity Score (0.5 to 0.75).

These Census tracts contain portions of downtown and Huntington Park High School and are adjacent to Vernon and that city’s manufacturing and warehousing job opportunities (Figure II-32).

Neighboring communities have similarly low economic scores, with isolated census tracts in Cudahy, Southgate, Vernon, and Los Angeles scoring higher (Figure II-33).

Environmental Score
The environmental outcome score is based on the CalEnviroScreen Environmental Effect Indicator Tool, which measures the extent to which toxic compounds and hazardous sites are present in a community. The northern part of the city, adjacent to Vernon and the city of Los Angeles, has the lowest scores (less than 0.25). The central parts of the city, south and east of downtown, have the highest scores (0.75 to 1). The remainder of the city has scores in the range of 0.25 to 0.75 (Figure II-34). CalEnviroScreen exposure indicators for Huntington Park are discussed in more detail in the Environmental Justice Technical Report.

Regional Context
Surrounding communities have a mix of scores. The majority of Walnut Park, adjacent to the high scoring areas of Huntington Park, has similarly high scores, as does the central part of South Gate.

In all communities, areas near freeways, rail lines, and heavy industry all score less than 0.25 (Figure II-37).

Local Context
The CalEnviroScreen data identified the highest scores north of the city, which borders the City of Vernon. The City of Vernon is exclusively industrial with a population estimate of 110 residents Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-70
according to the 2019 United States Census. The air pollution disperses to surrounding areas, causing an impact on air quality in Huntington Park. However, according to the Environmental Score, the DTSP is .50 – 1, which concludes a more positive environmental outcome within the DTSP. The skewed data may be due to the residential nature of Walnut Park to the south of Huntington Park and the available resources surrounding the area.

Due to the nature of the surrounding cities, the development sites may pose environmental issues which should be captured within the CEQA analyses for any “project.” Mitigation measures to provide more trees to encapsulate particulate matter from industrial properties and other solutions would have to be included on a project-to-project basis. In addition, any identification of contaminated sites, groundwater contamination, and hazardous waste would have to be reviewed and potentially mitigated through a thorough CEQA analysis of each site. Unless the project is administered through a Minor Development Permit (i.e., single-family, ADU, subject to SB 9), all projects will be subject to CEQA or require an Initial Study to review any potential contaminants.

Transportation
Huntington Park is served by two different transit providers: the city of Huntington Park and the Los Angeles County Metropolitan Transportation Authority (LA Metro). The city operates two local bus lines and a dial-a-ride service for Huntington Park residents through the HP Express local transit bus. These services provide cost efficient transportation needs for members of the community including those in protected classes.

LA Metro operates the regional bus lines that pass through the city across 11 bus lines and an extensive network of bus stops.

LA Metro operates the following bus lines in the city of Huntington Park:
• 60. Pacific Street
• 102. Florence Avenue
• 108/358. Slauson Avenue
• 110. Gage
• 111/311. Florence
• 251. Slauson, Pacific, Florence
• 254. Gage, Santa Fe
• 611. Florence
• 612. Florence
• 751. Slauson, Pacific
• 760. Pacific
The City of Huntington Park transit service details are described below based on transit type:
• Dial-A-Ride. The city operates a budget-friendly taxicab service that offers door-to-door transportation for eligible Huntington Park residents.
• HP Express. HP Express operates Monday through Friday between 6:00 a.m. and 6:30 p.m. and Saturdays between 8:00 a.m. and 5:30 p.m.

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The existing public transportation system in Huntington Park is intended to provide local and regional accessibility for those residents that cannot rely on automobile transportation. There are 43 existing HP Express bus stops across the city, with bus stop locations in a majority of city census tracts. The access to affordable mass transit systems is especially critical given the needs of the members of the protected classes and the low-income populace of the city. Furthermore, free ridership on the HP Express is offered to seniors (62+), persons with disabilities, Medicare cardholders, and children four years old and younger. Major transit stops are available along Pacific Avenue, going north and south. Slauson Avenue runs east and west, Gage Avenue runs east and west, and Holmes Avenue runs east and west. Huntington Park will also have the new West Santa Ana Branch Transit Corridor running north of Huntington Park with transit stops at Pacific/Randolph and Slauson/A Line (Blue).

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Figure II-28
TCAC Opportunity Areas – Composite (2021)
Huntington Park
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Figure II-29
TCAC Opportunity Areas – Composite (2021), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-74
Figure II-30
TCAC Opportunity Areas – Educational Opportunity (2021), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-75
Figure II-31
TCAC Opportunity Areas – Educational Opportunity (2021), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-76
Figure II-32
TCAC Opportunity Areas – Economic Score (2021), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-77
Figure II-33
TCAC Opportunity Areas – Economic Score (2021), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-78
Figure II-34
TCAC Opportunity Areas – Environmental Score (2021), Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-79
Figure II-35
TCAC Opportunity Areas – Environmental Score (2021), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-80
Figure II-36
CalEnviroScreen 4.0 (2021), Huntington Park
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Figure II-37
CalEnviroScreen 4.0 (2021), Los Angeles Region
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Disproportionate Housing Needs
According to HUD’s 2015 Final Rule, “disproportionate housing needs” generally refers to a condition in which there are significant disparities in the proportion of members of a protected class experiencing a category of housing need when compared to the proportion of members of any other relevant groups, or the total population experiencing that category of housing need in the applicable geographic area. For purposes of this definition, categories of housing need are based on such factors as cost burden and severe cost burden, overcrowding, and substandard housing conditions.
25 Collectively, these are referred to as “housing problems.” Other disproportionate needs discussed in this analysis include homelessness and displacement.

Cost Burden
Low-income households and persons in protected classes disproportionately experience housing cost burden. Cost burden is defined by the Code of Federal Regulations as “[t]he extent to which gross housing costs, including utility costs, exceed 30 percent of gross income, based on data available from the U.S. Census Bureau.”26 Households spending a minimum of 30 percent of their total gross income on housing costs are considered cost burdened, whereas households spending over 50 percent on housing costs are considered severely cost burdened.27 • A greater share of renters than owners in Huntington Park spend more than 50 percent of their income on housing costs. Thirty percent of renters are cost burdened, and 31 percent are severely cost burdened. The share of owners who are cost burdened is less than renters at 24 percent, and 17 percent are severely cost burdened. 28 • Cost burden has stayed relatively stable since 2017. (Table II-32) • Cost-burdened renter households are dispersed throughout the City (Figure II-38), but costburdened owner-occupied households are more heavily concentrated in the downtown area (Figure II-40).
• The highest levels of cost burden are in the downtown area and southern part of the city, where at least 60 percent of renters are cost burdened (Figure II-38).

Table II-32
Cost-Burdened Households by Tenure, Huntington Park, 2015 and 2018 OWNER
(% OF TOTAL

HOUSEHOLDS,
2015)
RENTER

HOUSEHOLDS
(% OF TOTAL

HOUSEHOLDS,
2015)
OWNER

HOUSEHOLDS
(% OF TOTAL

HOUSEHOLDS,
2018)
RENTER

HOUSEHOLDS
(% OF TOTAL

HOUSEHOLDS,
2018)
Cost Burdened 24% 31% 24% 30%
Severely Cost Burdened 25% 34% 17% 31%
Source: HUD CHAS Data, Huntington Park city, 2014-2018 ACS and 2011-2015 ACS 25 See 80 FR 42271, p. 42354 (2015). 26 24 C.F.R. § 91.5. 27 HUD USER, Rental Burdens: Rethinking Affordability Measures. https://www.huduser.gov/portal/pdredge/pdr_edge_featd_article_092214.html 28 HUD CHAS Data, Huntington Park city, California, 2014-2018 ACS Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-83
Regional Context
A smaller share of households in Los Angeles County are cost burdened, and the data follows a similar pattern between renters and owners. Among renters, 25 percent are cost burdened, and 29 percent are severely cost burdened. Among homeowners, 18 percent are cost burdened, and 16 percent are severely cost burdened. Cost burden among owner and renter households has also not changed significantly since 2015. About 25 percent of renters and 20 percent of owners were cost burdened in 2015.29
Neighborhoods in the south-central region of the City of Los Angeles contain concentrations of census tracts where at least 60 percent of renter households are cost burdened. In contrast, renter households located in coastal areas, where median incomes tend to be higher, generally experience less housing cost burden. (See Figure II-39 and Figure II-41.) 29 HUD CHAS Data, Los Angeles County, California, 2014-2018 ACS and 2011-2015 ACS Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-84
Figure II-38
Overpayment by Renters (2019), Huntington Park
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Figure II-39
Overpayment by Renters (2014), Los Angeles Region
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Figure II-40
Overpayment by Homeowners (2019), Huntington Park
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Figure II-41
Overpayment by Homeowners (2014), Los Angeles Region
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Substandard Housing
Substandard housing is defined as a housing unit lacking complete plumbing or kitchen facilities.

As discussed in Housing Stock Characteristics, above, most of the housing stock in Huntington Park was built before 1980. According to 2015-2019 ACS estimates, about 78.5 percent of the housing units were built over 40 years ago. Approximately 81 percent of the owner-occupied housing stock in the County was constructed over 40 years ago, compared to 78 percent of renteroccupied units. A slightly higher proportion of renters occupy new housing than owners. For housing units constructed since 2010, 0.2 percent are owner-occupied while 0.7 percent are renteroccupied housing units. A small percentage of Huntington Park’s occupied housing units lack complete kitchen (1.9 percent) or plumbing (0.8 percent) facilities, but those percentages have increased since 2015, and are slightly higher than Los Angeles County (Table II-33).

Table II-33
Substandard Units

CONDITION
NUMBER
(HUNTINGTON
PARK, 2020)

PERCENTAGE
(HUNTINGTON
PARK, 2020)

PERCENTAGE
(HUNTINGTON
PARK, 2015)

PERCENTAGE
(LOS ANGELES
COUNTY, 2015)

PERCENTAGE
(LOS ANGELES
COUNTY, 2020)
Lacking complete
plumbing facilities
115 0.8% 0.7% 0.5% 0.5%
Lacking complete kitchen
facilities
278 1.9% 1.1% 1.6% 1.6%
Source: Census Bureau, ACS 5-Year Estimates 2015 and 2020, Table S2504, Physical Housing Characteristics for Occupied Housing Units All of the city’s census tracts contain more than 50 percent of households experiencing any of the four severe housing problems, as shown in Figure II-42. Almost 70 percent (10,045 households) of all households in the city experience at least one of four housing problems (Table II 34).

Table II 34
Housing Problems by Tenure

OWNER RENTER TOTAL
Household has at least 1 of 4 Housing Problems 2,105 7,940 10,045 Household has none of 4 Housing Problems OR cost burden not available, no other problems
1,875 2,695 4,570
Total 3,980 10,635 14,620
Source: HUD CHAS Data, Huntington Park city, 2015-2019 ACS Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-89
Regional Context
Regionally, there are a total of 3,559,790 housing units in Los Angeles County.30 Approximately 74 percent of the housing units were built over 40 years ago. Approximately 76 percent of the owneroccupied housing stock in the County was constructed over 40 years ago, compared to 73 percent of renter-occupied units. These older units potentially require repairs and modernization improvements, and the need for rehabilitation is slightly higher among homeowners than renters.

A slightly higher proportion of renters occupy new housing than owners. For housing units constructed since 2010, 1.6 percent are owner-occupied while 2.7 percent are renter-occupied housing units.

There has been no significant change in the percentage of substandard units in Los Angeles County since 2015 (Table II-33).
30 ACS 5-year Estimates (2020), Los Angeles County. Table DP04, Selected Housing Characteristics. https://data.census.gov/cedsci/table?g=0400000US06_0500000US06037&tid=ACSDP5Y2019.DP04&hidePreview=t rue
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Figure II-42
Percent of All Households with Any of the 4 Severe Housing Problems, Huntington Park Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-91
Figure II-43
Percent of All Households with Any of the 4 Severe Housing Problems, Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-92
Homelessness
Homelessness is a continuing and growing crisis throughout California and urban areas nationwide.

Individuals and families experiencing homelessness are without permanent housing largely due to a lack of affordable housing. Homelessness is often compounded by a lack of job training and supportive services to treat mental illness, substance abuse, or domestic violence.

For homeless individuals or those at risk of becoming homeless, the most significant problem is the lack of affordable rental housing. For chronically homeless persons and transitional-age youth, who often struggle with physical and mental health problems and substance abuse issues, there is an insufficient inventory of transitional housing and permanent housing with supportive services designed to meet the specific needs of these populations.

Homelessness and resources available to people experiencing homelessness are discussed further in People Experiencing Homelessness, in Housing Needs Assessment.

Regional Context
There are an estimated 56,078 homeless persons in Los Angeles County, according to the 2022 Homeless Count conducted by the Los Angeles Homeless Services Authority (LAHSA). This represents an increase of three percent countywide.

Homelessness is more common among black residents countywide. Black residents are nearly nine percent of the County’s population but make up 34 percent of the homeless population. Asian and Hispanic/Latino residents are underrepresented in the homeless population. Asian residents make up about 14 percent of the County’s population and are less than two percent of the homeless population, and Hispanic residents are nearly 50 percent of the population and make up about 36 percent of the homeless population. Other racial/ethnic groups are similarly represented in the population broadly and the homeless population.31
Local Context
The 2022 Homeless Count estimated the homeless population of the City of Huntington Park to be

86. LAHSA staff cautions that more specific demographic data is not available on a citywide basis due to limitations in the methodology. Demographic information is surveyed and sampled and applied only to the aggregate Point-In-Time population.32 Certain characteristics are available by Service Planning Area (SPA), which is a geographic area within Los Angeles County used by LAHSA and other Los Angeles County agencies. Huntington Park is in SPA 7.
33 In SPA 7, the vast majority of persons experiencing homelessness are individuals (defined as adults in households with no children under 18).34 Very few unaccompanied minors are in SPA7 and 16 31 Los Angeles Homeless Services Authority, Homeless Count by Race & Ethnicity. https://www.lahsa.org/data-refresh 32 Correspondence with Los Angeles Homeless Services Authority staff, December 12, 2022. 33 County of Los Angeles Public Health, Service Planning Area 7. http://publichealth.lacounty.gov/chs/SPA7/ 34 Los Angeles Homeless Services Authority, 2022 Point-In-Time Count, 2022. https://www.lahsa.org/data?id=54- homeless-count-by-city-community and https://www.lahsa.org/data?id=51-homeless-count-by-service-planningarea-2015-2022 Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-93
percent of the area’s homeless population are family members (households with at least one child under 18 and one adult over a18).35
Overcrowding
The U.S. Census Bureau considers a household to be overcrowded when there is more than one person per room, excluding bathrooms and kitchens. A household is severely overcrowded when there are more than 1.5 persons per room. Overcrowding is also discussed in Household Characteristics.

High housing costs may cause families to accept housing that is too small for the family size, or to house extended family members or unrelated people to share the cost among more people.

Potential fair housing issues emerge if non-traditional households are discouraged or denied housing due to a perception of overcrowding. Overcrowding can also strain physical facilities and the delivery of public services, reduce the quality of the physical environment, contribute to a shortage of parking, and accelerate the deterioration of homes. As a result, some property owners may be more hesitant to rent to larger families, thus making access to adequate housing even more difficult. Addressing the issue of large households is complex as there is no set guidance for determining the maximum capacity for a unit, and policies aimed to limit overcrowding often have a disparate impact on lower-income households and racial or ethnic groups experiencing higher rates of overcrowding.

In Huntington Park, overcrowding is more common among renters than homeowners. (Household Characteristics) Overcrowding is present throughout the city (Figure II-44), with slightly less overcrowding present in the southeast corner of the city. Severely overcrowded households are more common in the central parts of the city, including the Downtown Specific Plan Area.

Regional Context
Los Angeles County households experience overcrowding at significantly lower levels than Huntington Park. Renters are still more likely to live in overcrowded conditions, at 16 percent (seven percent severely overcrowded). Six percent of owner-occupant households are overcrowded (two percent severely overcrowded).36 The percentage of overcrowding has not changed since 2015, with six percent of owner-occupied households considered overcrowded, and 17 percent of renter occupied households overcrowded.37
Overcrowded households are concentrated in central Los Angeles and cities to the southeast, as well as portions of the San Fernando Valley to the northwest of Los Angeles. There is considerable correlation between areas of high poverty (Figure II-20) and areas with concentrations of overcrowded households (Figure II-44).
35 Los Angeles Homeless Services Authority, 2022 Point-In-Time Count, 2022. https://www.lahsa.org/data?id=54- homeless-count-by-city-community and https://www.lahsa.org/data?id=51-homeless-count-by-service-planningarea-2015-2022 36 ACS 5-year Estimates (2020), Los Angeles County, Table B25014, Tenure by Occupants per Room. https://data.census.gov/cedsci/table?q=Occupants%20Per%20Room&g=0500000US06037 37 ACS 5-year Estimates (2015), Los Angeles County, Table B25014, Tenure by Occupants per Room. https://data.census.gov/cedsci/table?q=Occupants%20Per%20Room&g=0500000US06037_1600000US0636056&ti d=ACSDT5Y2015.B25014
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-94
Figure II-44
Overcrowded Households, Huntington Park
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-95
Figure II-45
Overcrowded Households, Los Angeles Region
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Figure II-46
Severely Overcrowded Households
Huntington Park
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-97
Figure II-47
Severely Overcrowded Households
Los Angeles Region
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-98
Displacement
For the purpose of AFFH analysis, “displacement is used to describe any involuntary household move caused by landlord action or market changes.”38 Contributing factors to displacement include rising housing costs, rising income inequality and stagnant wages, and insufficient market-rate housing production.39 Neighborhoods can experience displacement for a variety of reasons:
• Disinvestment-driven displacement occurs when lower-income communities which receive less public sector investment deteriorate. Evaluating access to opportunity, including access to transit, high performing schools, parks, and other services/amenities can identify areas that lack investment in infrastructure improvements and are considered low resource.

According to the TCAC Opportunity Maps, most of the city is considered low resource, with low resource areas concentrated around the borders of the city, neighboring the Cities of Vernon and Bell.
• Investment-driven displacement generally occurs after a period of disinvestment, when the market encourages a flood of public and private investment lead to real estate speculation and infrastructure improvements. There are two major infrastructure improvements scheduled to be completed in 2014, after the Housing Element planning period. The Los Angeles Metro West Santa Ana Branch Transit Corridor project will locate three new stations in and near Huntington Park: one at Florence Avenue and Salt Lake Avenue, and one at Pacific Avenue and Randolph Street.40
• Disaster-driven displacement occurs when housing is destroyed or compromised by disasters and the result is that the housing is not rebuilt. Lower-income households who tend to rent (and therefore lack control over whether their homes are rebuilt) or lowerincome homeowners have fewer financial resources to rebuild their homes are most at risk of this type of displacement. Huntington Park has some risk due to seismic activity, which could cause substantial or disproportionate displacement risk.41 However, all census tracts achieve high Social Vulnerability Index (SVI) scores in both 2018 (Figure II-48) and 2014.

The SVI was developed by the CDC and uses multiple Census data points (e.g., poverty and employment status, income, education, age, disability status, language isolation, housing type, and access to transportation) to determine communities that are likely to need additional support as a result of natural disasters.42
There are a number of indicators that can be associated with displacement risk.43 Those that correlate with Huntington Park’s demographic and housing characteristics include:
• High share of renter-occupied housing
• High rates of overcrowding
38 California Department of Housing & Community Development, Affirmatively Furthering Fair Housing for All Public Entities and for Housing Elements, 2021, 40. 39 Been, V., Ingrid, E., & O’Regan, K. 2019. Supply Skepticism: Housing Supply and Affordability. Housing Policy Debate, 29(1), 25-40 40 Los Angeles Metro, West Santa Ana Branch Transit Corridor. https://www.metro.net/projects/west-santa-ana/ 41 Huntington Park General Plan, Safety Element, 1991. 42 U.S. Department of Health & Human Services, At A Glance: CDC/ATSDR Social Vulnerability Index, 2021. https://www.atsdr.cdc.gov/placeandhealth/svi/at-a-glance_svi.html 43 California Department of Housing & Community Development, Affirmatively Furthering Fair Housing for All Public Entities and for Housing Elements, 2021, 44.

Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-99
• High rates of cost-burdened renter households
The Urban Displacement Project has identified communities at greatest risk of displacement, based on characteristics like share of renters, share of very low-income rent-burdened residents, and other demographic and housing market characteristics.44 All of Huntington Park is a sensitive community (Figure II-50).

The City encourages and supports efforts to assist small businesses and prevent displacement of those businesses due to conversion of land uses from commercial to mixed-use or residential. The City coordinates with the Chamber of Commerce to conduct outreach to local businesses and provide small business loans. The City also contracts with the Hub Cities Career Center to operate the Huntington Park Business Assistance program. The program provides businesses with technical assistance for obtaining access to capital, using new technologies, developing marketing plans, and hiring and training workers.

Program 13 (Affirmatively Furthering Fair Housing and Increasing Access to Opportunity) contains actions to protect small business owners, renters, and lower-income homeowners from the types of displacement described above.

Regional Context
Regionally, much of the greater Los Angeles region is considered vulnerable to displacement due to increases in housing costs combined with disparities in income and access to opportunity. West of Huntington Park, throughout the City of Los Angeles, most neighborhoods within the areas of South-Central and East Los Angeles exhibit concentrations of sensitive communities (Figure II-51).

East of Huntington Park, in the San Gabriel Valley, nearby cities such as Alhambra, San Gabriel, El Monte, and Montebello have large segments of vulnerable communities. In contrast, regional cities such as Arcadia, South Pasadena, Pasadena, Monrovia and coastal cities contain relatively fewer vulnerable communities. Sensitive communities tend to correspond to areas of high poverty. In 2018, Los Angeles County had an overall SVI score of 0.7862,45 decreased slightly from a score of

0.7997 in 2014.46
44 Urban Displacement Project, Sensitive Communities In California: Mapping Vulnerability And Displacement Pressure, 2020. https://www.urbandisplacement.org/blog/sensitive-communities-in-california-mapping-vulnerability-anddisplacement-pressure/ 45 Possible scores range from 0 (lowest vulnerability) to 1 (highest vulnerability). 46 U.S. Department of Health & Human Services, Center for Disease Control, Agency for Toxic Substances and Disease Registry, 2022. https://svi.cdc.gov/map.html
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Figure II-48
Social Vulnerability Index (2018), Huntington Park
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Figure II-49
Social Vulnerability Index (CDC, 2018), Los Angeles Region Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-102
Figure II-50
Sensitive Communities, Huntington Park
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Figure II-51
Sensitive Communities, Los Angeles Region
Huntington Park 2021-2029 Housing Element Housing Needs Assessment For Adoption September 18, 2023 II-104
Analysis of Sites Inventory
The housing element must demonstrate that there are adequate sites zoned to accommodate the number of new housing units needed at each income level as identified in the Regional Housing Needs Allocation (RHNA). In the context of AFFH, the process of sites identification involves an analysis of site capacity to accommodate the RHNA, and 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.

The Sites Inventory includes parcels within seven discrete census tracts which vary with regards to the fair housing factors considered. Two of the census tracts (532605 and 533104) encompass the DTSP area with sites with capacity to accommodate 1,033 new units including 144 very lowincome, 139 low-income, 135 moderate-income, and 615 above moderate-income units. The remaining sites identified in the inventory are in five census tracts and within one-half mile of planned transit stations. These sites have capacity for 1,635 units including 261 very low-income, 229 low-income, 327 moderate-income, and 818 above moderate-income units.

Access to Opportunity
HCD/TCAC opportunity maps identify areas throughout the state that support positive economic (low poverty, high employment, high median household income), educational (reading and math proficiency, high school graduation rates, low student poverty rates), and environmental outcomes (low exposure to pollution) for residents. The HCD/TCAC opportunity areas maps rank census tracts from Highest Resource to Low Resource based on these characteristics. A census tract with a designation of High Resource indicates that the census tract has strong educational and economic opportunities for current and future residents.

Pollution exposure is highest in the northwest and southeast part of the city, 47 likely due to the
presence of industrial uses. As many opportunity sites are along the West Santa Ana Branch Transit Corridor in the northern part of the city, the new residences in those areas may experience higher pollution exposure. Pollution exposure for existing and new residents will be mitigated through policies and programs in the City’s General Plan Environmental Justice Element, including:

Policy 1.1: Reduce Particulate Matter (Diesel PM and PM 2.5) pollution for sensitive land uses by establishing roadway-adjacent pollution mitigation strategies (green walls, vegetative barriers, etc.) in locations where a major local roadway interfaces with a sensitive land use by the year 2024.