HomeMy WebLinkAboutD-1 Staff Report - Amended Housing ElementPUBLIC HEARING/SCHEDULED ITEM
D-1
TO: HONORABLE MAYOR AND MEMBERS OF THE CITY COUNCIL
VIA: SERGIO GONZALEZ, CITY MANAGER
FROM: JOSE D. JIMENEZ, DIRECTOR OF ECONOMIC AND COMMUNITY
DEVELOPMENT
DATE: JUNE 19, 2023
SUBJECT: PUBLIC HEARING - CONSIDERATION OF A GENERAL PLAN
AMENDMENT (GPA-2022-01A) TO ADOPT MODIFICATIONS TO THE CITY
OF AZUSA HOUSING ELEMENT
BACKGROUND:
California Government Code Section 65583 et seq. requires every jurisdiction in California to
adopt a Housing Element as part of its General Plan and update it every eight years. For all cities
and counties within the Southern California Association of Governments (SCAG) region, that
eight-year period extends from 2021 to 2029. The Housing Element must also be reviewed for
compliance with State Housing Element law by the California Department of Housing and
Community Development (HCD).
The Housing Element update process included a robust community outreach program, work with
the Housing Element Advisory Committee, drafting the Housing Element update, preparing the
environmental analysis as required by the California Environmental Quality Act (CEQA), and
coordinating with the State of California Department of Housing and Community Development.
The project timeline for Housing Element adoption included the following major milestones:
•March 9, 2021 - Community Workshop #1
•March 10, 2021 - Advisory Committee Meeting #1
•March 30, 2021- Community Workshop #2
•March 1 – 31, 2021 - Online Housing Survey
•April 19, 2021 - City Council and Planning Commission Joint Study Session
•June 15, 2021 - Advisory Committee Meeting #2
•June 21, 2021 - City Council and Planning Commission Joint Study Session
Approved
City Council
June 19, 2023
Housing Element Amendment
June 19, 2023
Page 2
• July 6, 2021 - Draft Housing Element submitted to HCD (60-day review)
• September 3, 2021 - City receives letter from HCD requesting changes
• September 29, 2021 - Revised Draft Housing Element submitted to HCD (60-day review)
• November 23, 2021 - Letter from HCD received requesting changes
• December 2021 – February 2022 - Housing Element revised and prepared for hearings
• February 23, 2022 - Planning Commission Hearing
• March 7, 2022 - City Council Adoption Hearing
Following adoption of the Housing Element in March 2022, the Housing Element was again
submitted to HCD for their review. Milestones subsequent to Housing Element adoption included:
• March 21, 2022 - Adopted Housing Element submitted to HCD
• May 20, 2022 - City received letter from HCD requesting changes
• November 17, 2022 - Revised Adopted Housing Element submitted to HCD (60-day
review)
• January 4, 2023 - City rescinded submission to HCD in order to make revisions after verbal
comments from HCD
• March 28, 2023 - Revised Adopted Housing Element re-submitted to HCD
• May 11, 2023 - Received verbal confirmation from HCD that the Housing Element as
revised is compliant with State Housing Element law
• May 24, 2023 - Letter from HCD confirming verbal comments received
On May 31, 2023, the Planning Commission adopted PC Resolution 2023-PC07, recommending
that the City Council adopt the amended City of Azusa 2021-2029 Housing Element to include the
non-substantive changes made to the adopted Housing Element in response to comments received
from the HCD.
RECOMMENDATIONS:
Staff recommends that the City Council take the following actions:
1) Open the Public Hearing, receive public testimony, and close the Public Hearing;
2) Adopt Resolution No. 2023-C28, adopting General Plan Amendment No. GPA-2022-01A
to the 2021-2029 Housing Element of the City of Azusa General Plan to include additional
non-substantive changes made to the previously adopted Housing Element in response to
comments received from the Department of Housing and Community Development; and
3) Find that the revisions to the Housing Element are minor in nature and no significant
change to the originally analyzed Project occurred. As such, impacts associated with the
amended Housing Element are the same as those analyzed in the Negative Declaration and
the original CEQA conclusions stand; no further supplemental environmental review is
required.
Housing Element Amendment
June 19, 2023
Page 3
ANALYSIS:
In the previous (5th cycle) Housing Element update cycle (2013-2021), the California Department
of Housing and Community Development (HCD) would conduct a 60-day review of a draft
Housing Element, which included reviewing and providing comments on a jurisdiction’s draft
Element as submitted. In the same 60-day period, HCD would provide verbal comments and the
jurisdiction would propose suggested revisions in response. HCD would review and provide
additional comments, if necessary. At the end of the 60-day review, HCD and the jurisdiction in
general had an agreed-upon edited Draft Housing Element for the jurisdiction’s adoption process.
The jurisdiction would then adopt the Draft Housing Element.
The housing crisis in California has since led the legislature to adopt a myriad of housing laws that
place mandates on cities to approve housing at a faster rate. Since 2017, the Governor has signed
dozens of housing bills aimed at reducing barriers to housing production, which apply to this 6th
cycle (2021-2029). In this Housing Element cycle, in general, HCD staff has not been able to work
with cities to discuss revisions within the 60-day review period. Instead, at the end of the review
period, HCD has provided letters (often multiple times) outlining revisions and clarifications
needed to comply with evolving State law. Typically, HCD has required two, three, or even four
rounds of 60-day review for every draft Element.
Following a year of significant public engagement and drafting of the Housing Element, Azusa
submitted the draft Housing Element to HCD for review in July 2021. HCD reviewer Colin Cross
met with City staff and consultant (MIG, Inc.) on August 28, 2021 to provide verbal comments
and issued a comment letter on September 2, 2021. Staff and MIG revised the Housing Element
to respond to HCD’s comments and resubmitted the draft to HCD on September 29, 2021 for a
second 60-day review. HCD reviewer Colin Cross met with City staff and MIG on November 18,
2023, indicating that there were additional comments/revisions required. On November 23, 2021,
HCD’s formal comment letter was received. City staff and MIG revised the Housing Element
accordingly and brought the document forward to the Azusa Planning Commission and City
Council for adoption hearings.
Following adoption, the Housing Element was again submitted to HCD for review. The previous
reviewer, Colin Cross left HCD and a new HCD reviewer Molivann Phlong was assigned. HCD
staff Molivann Phlong met with City staff and MIG on May 10, 2022 to provide additional
comments, followed by a letter received May 20, 2022 indicating that further analysis and
discussion were required regarding affirmatively furthering fair housing and justifying
assumptions about reuse of nonvacant commercial sites, building on religious institution sites, and
trends for accessory dwelling unit (ADU) production.
The City and MIG revised the Housing Element to add additional analysis, information, and
modified program actions to address comments and made the revisions available for public review
on the Housing for All website and via emails to the stakeholder list. On November 17, 2022, the
revised adopted Housing Element was again submitted to HCD. HCD reviewer Molivann Phlong
and HCD supervisor Melinda Coy met with City staff and MIG to discuss the final remaining
comments and needed information. Because the remaining revisions were minimal, the City
rescinded the original submittal for HCD’s review, made the required revisions, and resubmitted
the document to HCD on March 28, 2023. On May 11, 2023, City staff and MIG received verbal
Housing Element Amendment
June 19, 2023
Page 4
confirmation from HCD that, with these final revisions, HCD would find the Housing Element in
full compliance.
The revised Adopted Housing Element reflects all of the comments and directed revisions by HCD.
City staff is required to submit the Housing Element, post City Council adoption, to HCD for final
certification to ensure that the document remains the same as the previously reviewed versions.
Staff does not anticipate any additional revisions will be required. Should any further edits be
required by HCD during the final certification process, Planning Commission Resolution 2023-
PC07 contains a provision that the City Council’s adoption of the Housing Element would allow
the Community Development Director to make additional non-substantive changes to the approved
Housing Element in response to additional comments received from HCD on the adopted Housing
Element.
Content of Revisions Post Adoption
After the March 7, 2022 adoption of the Housing Element, HCD provided comments stating that
additional information, specific metrics, and analysis were required. City staff and MIG responded
by incorporating additional clarifications, explanations, and analysis.
Affirmatively Furthering Fair Housing (AFFH)
In response to specific comments from HCD, the Housing Element analysis was augmented to
address patterns at the local and regional levels and trends in patterns over time, further analyzing
various socio-economic characteristics, including the patterns and trends of race and ethnicity in
comparison to the region and neighboring cities and for the City as a whole. HCD also requested
additional information related to poverty levels over time and more specifics on median household
income and trends for Black and Asian residents in the City, as well as analyzing demographics
related to disability status to identify patterns and trends over time; this information was provided
in the revised document.
Revisions to respond to HCD comments include the addition of specific milestones and measurable
actions (i.e., more detail) to the Housing Element implementation programs in an effort to
overcome contributing factors to fair housing issues and target meaningful fair housing outcomes.
Inventory of Land Suitable and Available for Residential Development
HCD also requested additional information on the suitability of nonvacant sites. In response,
additional information was provided to demonstrate how factors and trends used to identify sites
relate to the sites selected in the inventory and how those factors support the potential for
redevelopment within the planning period. In addition, additional outreach was conducted to sites
with an existing church on site to assess interest in redevelopment with housing within the planning
period; sites were removed if no interest was indicated.
Revisions also remove program language that indicated the City would “explore” certain options,
and instead commit to conducting studies and moving forward with procedures for decision maker
consideration. Additional clarifications regarding efforts to encourage development of accessory
dwelling units and mixed-use development were also provided.
The Draft recommended by the Planning Commission for adoption by the City Council reflects all
Housing Element Amendment
June 19, 2023
Page 5
of the revisions directed by HCD. City staff is also required to submit the Housing Element, post
adoption, to HCD for final certification to ensure that the document remains the same as the
previously reviewed drafts.
ENVIRONMENTAL DOCUMENTATION
The adopted 2021-2029 Housing Element implements existing land use policy set forth in the
Azusa General Plan Land Use Element. To assess potential environmental impacts associated with
Element adoption, the City prepared an Initial Study pursuant to the California Environmental
Quality Act (CEQA). The Initial Study concluded that potential environmental impacts resulting
from adoption of the Housing Element would not result in impacts which would require the
incorporation of mitigation measures to reduce the impact to a less than significant effect on the
environment. Therefore, a Negative Declaration was prepared, circulated, and adopted by the City
Council in March 2022.
The proposed amendment to the adopted 2021-2029 Housing Element does not result in any
substantial changes to the project scope or circumstances in the Initial Study and Negative
Declaration. Revisions to the adopted 2021-2029 Housing Element reflect minor edits to a
programmatic document and any potential significant impacts have been considered in the adopted
Initial Study and Negative Declaration. Revisions to the adopted 2021-2029 Housing Element do
not involve an environmentally sensitive area, nor do revisions change or expand the proposed
uses, increase intensity, or result in a change from the original CEQA conclusions. As such, no
further supplemental environmental review is required.
PUBLIC NOTICING
Notice of Hearing was published in the San Gabriel Valley Tribune on June 8, 2023. As of the
date of this report, the City has not received any written or oral public comments received in favor
or opposition.
FISCAL IMPACT:
There is no fiscal impact associated with the recommended action.
Prepared by: Reviewed by:
Genevieve Sharrow, MIG Project Planner Jose D. Jimenez
Knarik Vizcarra, Planning Manager Economic and Community
Development Director
Fiscal Review by: Reviewed and Approved by:
Talika M. Johnson Sergio Gonzalez
Director of Administrative Services City Manager
Attachments:
1) City Council Resolution No. 2023-C28
Exhibit A - City of Azusa 6 th Cycle 2021-2029 Draft Amended Housing Element
2) HCD Comment Letters and Matrices of Revisions to Respond to HCD Comments
3) CEQA Consistency Finding
RESOLUTION NO. 2023-C28
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF AZUSA
ADOPTING GENERAL PLAN AMENDMENT NO. GPA-2022-01A
AMENDMENT TO THE 2021-2029 HOUSING ELEMENT OF THE
CITY OF AZUSA GENERAL PLAN
WHEREAS, California Government Code Sections 65580-65589.9 require cities to
prepare a Housing Element as a component of each city's General Plan and to revise the Housing
Element regularly on a schedule set forth in the law to be in compliance with changes in housing
laws, to reflect population trends, and to demonstrate that the Regional Housing Needs Assessment
(RHNA) can be satisfied; and
WHEREAS, the City Council of the City of Azusa adopted the 2021-2029 Housing
Element update on March 7, 2022; and
WHEREAS, the California Department of Housing and Community Development (HCD)
reviewed the adopted 2021-2029 Housing Element and directed the City to make additional
revisions; and
WHEREAS, City staff revised the adopted 2021-2029 Housing Element as directed by
HCD; and
WHEREAS, on May 26, 2023 HCD submitted a letter to the City of Azusa affirming that
the Housing Element, including those revisions, would comply with State Housing Element law;
and
WHEREAS, the 2021-2029 Housing Element fully complies with the requirements of
State law by identifying adequate sites for a variety of housing types and makes adequate provision
for the existing and projected needs of all economic segments of the Azusa community; and
WHEREAS, in accordance with Government Code Section 65583.2, the City finds,
based on the facts described in the Findings section below that the existing uses on the sites
identified in the sites inventory to accommodate the lower income RHNA are likely to be
discontinued during the planning period, and therefore do not constitute an impediment to
additional residential development during the period covered by the housing element; and
WHEREAS, in accordance with Government Code Section 65583, the City finds that the
2021-2029 Housing Element (2021-2029) complies with the duty to Affirmatively Further Fair
Housing; and
WHEREAS, the Planning Commission of the City of Azusa, held a public hearing on
May 31, 2023, for a City-initiated amendment to the General Plan, General Plan Amendment
No. GPA-2022-01A to adopt an amendment to the 2021-2029 Housing Element Update, and
adopted PC Resolution 2023 -07 recommending that the City Council Adopt the Housing Element
Amendment as presented; and
WHEREAS, the City Council of the City of Azusa, has given notice thereof as required
by law, held a public hearing on June 19, 2023, for a City-initiated amendment to the General
Plan, General Plan Amendment No. GPA-2022-01A to adopt an amendment to the 2021-2029
Housing Element Update; and
Attachment 1
RESOLUTION NO.
GENERAL PLAN AMENDMENT NO. GPA-2022-01A
WHEREAS, the City Council has carefully considered all pertinent testimony and the staff
report offered in the case as presented at the public hearing; and
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF AZUSA DOES
HEREBY RESOLVE AS FOLLOWS:
SECTION 1: Consistency with the California Environmental Quality Act – Pursuant to
California Environmental Quality Act, an Initial Study and Negative Declaration was prepared
for the adopted 2021-2029 Housing Element, finding that the proposed project could not have a
significant effect on the environment and certified by the City Council. The Planning
Commission recommends that the City Council of the City of Azusa finds that no further
environmental documentation is required because all potentially significant effects (a) have been
analyzed adequately in the previously-certified Negative Declaration pursuant to applicable
standards, and (b) have been avoided pursuant to the previously-certified Negative Declaration.
Therefore, in accordance with CEQA and the CEQA Guidelines (Section 15168(c)), the project
elements are within the scope of the previously-certified Negative Declaration; that Negative
Declaration continues to be pertinent with considerable information value; and project elements
do not give rise to any new or substantially more severe significant effects, nor do they require
any new mitigation measures or alternatives. Accordingly, no new environmental document is
required.
SECTION 2: Consistency with State Housing Element Law – Statutory requirements for the
Housing Element are delineated in California State Government Code Section 65580 – 65589.11.
The Housing Element is required to be updated every eight years in accordance with a specific
schedule of dates established by the California Department of Housing and Community
Development (HCD). This Housing Element Update is part of the sixth cycle, which covers the
period of October 15, 2021 through October 15, 2029 for the Southern California Association of
Governments (SCAG) region. Because housing needs are recognized as a matter of statewide
concern, the State, through HCD, must certify the compliance of every jurisdiction’s Housing
Element upon adoption. The adopted Azusa 2021-2029 Housing Element was submitted for
HCD review on March 21, 2022 for a 60-day review period. HCD issued a letter of findings and
requested revisions on May 20, 2022. City staff revised the Housing Element based on HCD’s
comments and on November 17, 2022, City staff transmitted the Draft Housing Element to HCD
for another 60-day review period. On January 4, 2023, HCD staff verbally indicated that the draft
Housing Element addressed many statutory requirements, but that some minor additional
revisions would be necessary to comply with State Housing Element Law, and set forth
recommended revisions to the Draft Housing Element. Revisions to respond to these comments
were subsequently incorporated and resolved in the revised draft, sent to HCD on March 28,
2023. On May 11, 2023, HCD verbally indicated that, including the revisions submitted, the
revised Housing Element is consistent with state Housing Element law (California State
Government Code Section 65580 – 65589.11). On May 26, 2023, HCD issued a letter concurring
the verbal indication from May 11, 2023; and no further findings are required.
SECTION 3: General Plan Amendment Findings – In accordance with Section 88.51.080.F of
RESOLUTION NO.
GENERAL PLAN AMENDMENT NO. GPA-2022-01A
the Azusa Development Code, it is found that the project would not unreasonably interfere with
the use or enjoyment of property in the vicinity, and would not adversely affect the public peace,
health, safety or general welfare. The Planning Commission hereby recommends approval and
adoption of said General Plan Amendment based on the following findings:
1. The proposed amendment is in the public interest, and there will be a community benefit
resulting from the amendment:
The adopted 2021-2029 Housing Element is in the public interest and will benefit the
community by encouraging the City’s participation in programs that provide housing
opportunities for diverse households, facilitating the development of housing for all income
levels, including very low-, low-, moderate-, and above moderate-income levels for the 2021-
2029 planning period, and affirmatively furthering fair housing. The adopted 2021-2029
Housing Element identifies housing goals and policies to address the City’s fair share of the
regional housing needs, while encouraging improvement and enhancement of existing
residential neighborhoods throughout the city. The Housing Element Amendment does not
modify any of these conclusions, as revisions to respond to HCD are aligned with the adopted
2021-2029 Housing Element and provide further specificity on the City’s housing policies and
implementation programs.
2. The proposed amendment is consistent with the other goals, policies, and objectives of the
General Plan.
State law requires that the General Plan have internal consistency among its elements
(Government Code Section 65300.5). The proposed 2021-2029 Housing Element Amendment
is consistent with the goals, policies, and objectives of the current General Plan in that it
encourages a balanced approach to meeting housing needs in various parts of the City, in
alignment with the Built Environment Element allowing for mixed-use development along
corridors, in neighborhoods, and in the TOD Specific Plan areas, and is consistent with the
allowed densities indicated in the General Plan.
3. The proposed amendment will not conflict with provisions of the Development Code,
subdivision regulations, or any applicable specific plan; and.
The proposed 2021-2029 Housing Element Amendment contains goals, policies, and
implementation programs related to the development and rehabilitation of housing throughout
the City that are consistent with the current Development Code, subdivision regulations, and
existing specific plans. The Housing Element includes program actions to review, and modify
as needed, the Development Code to be compliant with State law and further encourage diverse
housing options, consistent with HCD requirements.
4. In the event that the proposed amendment is a change to the land use policy map, that the
amendment will not adversely affect surrounding properties.
The proposed General Plan Amendment does not include a change to the Land Use policy map.
RESOLUTION NO.
GENERAL PLAN AMENDMENT NO. GPA-2022-01A
SECTION 4: Non-vacant Sites Findings – If a Housing Element relies on non-vacant sites to
accommodate 50 percent or more of its RHNA for lower income households, the non-vacant
site’s existing use is presumed to impede additional residential development, unless the Housing
Element describes findings based on substantial evidence that the use will likely be during the
planning period. Based on substantial evidence set forth in Chapter 5, Housing Resources of the
6th Cycle Housing Element, the existing uses on nonvacant sites identified in the sites inventory
to accommodate lower income housing are likely to be discontinued during the planning period,
and therefore do not constitute an impediment to additional residential development during the
period covered by the Housing Element.
A. Parcels with existing uses that were not likely to be discontinued during the planning
period were not examined for suitability, as follows:
• Parcels in the Rec (Recreation) and OS (Open Space) Districts;
• Parcels with existing designated historic resources;
• Parcels that are under construction, or have recently completed projects, approved
entitlements, or pending entitlements for commercial uses only;
• Parcels that have unique land uses, such as Azusa City Hall, schools, parks, and
libraries;
• Parcels developed with affordable housing;
• Parcels developed with condominium units; and
• Parcels with newer buildings developed post 1980.
B. All remaining parcels with existing uses that would allow residential redevelopment
were examined for suitability. Parcels with existing uses were selected for the
inventory based on the following factors and evidence:
(1) Approved/Pending Project Sites: Sites for which entitlements have been issued for
housing development projects or applications have been received for housing
development projects; evidence that in the previous planning period, only less
than five percent of approved or pending residential projects are withdrawn and/or
have had permits expire.
(2) Underutilized Religious Institution Sites: Evidence that all sites are in residential
zones, allowing residential uses. Evidence that existing structures do not need to
be removed to accommodate additional development capacity to support
affordable housing, which can be developed in landscaped areas or within half of
underutilized parking areas. Program H3-9 will further support redevelopment
with a new zoning process to encourage housing on religious institution sites with
development incentives.
(3) Underutilized Residentially Zoned Sites: Evidence that existing uses are either
nonconforming or significantly underutilized based on building age (at least 40
years of age) or surface parking lots and are able to at least double the number of
housing units on site.
RESOLUTION NO.
GENERAL PLAN AMENDMENT NO. GPA-2022-01A
(4) Underutilized Mixed-Use and TOD Specific Plan Zoned Sites: Evidence that
property owners have expressed past or current development interest; the
properties are underdeveloped below current maximum floor area ratio allowed or
have single tenants. Evidence that past and current proposed housing projects all
occurred on similar nonvacant sites with existing uses consisting of older
buildings (at least 40 years of age) or surface parking lots. Evidence that
improvement value is less than half of the land value. Evidence that in the past
decade development in Azusa has trended towards new residential development
rather than new commercial development, especially in the TOD Specific Plan
area.
C. The City of Azusa surveyed property owners for sites that are included in the sites
inventory to gauge redevelopment interest. While not all property owners responded,
those that did had existing uses on their sites and all indicated they were “very
interested” in redeveloping their property with residential uses.
SECTION 5: Based on the aforementioned findings, the City Council does hereby approve and
adopt General Plan Amendment GPA-2022-01A for the adoption of the Azusa General Plan 2021-
2029 Housing Element Amendment (replacing the Azusa General Plan 2021-2029 Housing
Element in its entirety, as provided in Exhibit “A” attached hereto and made part hereof, plus any
additional non-substantive edits made as directed by HCD after the Department’s review of the
Adopted 2021-2029 Housing Element Amendment or to correct typographical errors).
SECTION 6: The City Clerk shall certify to the adoption of this resolution.
PASSED, APPROVED, AND ADOPTED the 19th day of June, 2023.
____________________________________________
Robert Gonzales
Mayor
ATTEST:
____________________________________________
Jeffrey Lawrence Cornejo, Jr.
City Clerk
STATE OF CALIFORNIA )
COUNTY OF LOS ANGELES )ss.
CITY OF AZUSA )
RESOLUTION NO.
GENERAL PLAN AMENDMENT NO. GPA-2022-01A
I HEREBY CERTIFY that the foregoing Resolution No. 2023–C28 was duly adopted by the City
Council of the City of Azusa, at a meeting thereof held on the 19th day of June 2023, by the
following vote of the Council:
AYES:
NOES:
ABSENT:
____________________________________________
Jeffrey Lawrence Cornejo, Jr.
City Clerk
APPROVED AS TO FORM
__________________________________
Marco Martinez
City Attorney
Best Best & Krieger LLP
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT
DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
May 24, 2023
Knarik Vizcarra, Planning Manager
City of Azusa
213 E. Foothill Blvd.
Azusa, CA, 91702
Dear Knarik Vizcarra:
RE: City of Azusa’s 6th Cycle (2021-2029) Revised Draft Housing Element
Thank you for submitting the City of Azusa’s revised draft housing element update
received for review on March 28, 2023. Pursuant to Government Code section 65585,
subdivision (b), the California Department of Housing and Community Development
(HCD) is reporting the results of its review. Our review was facilitated by a telephone
conversation on May 11, 2023 with you and Genevieve Sharrow, the City’s consultant.
The revised draft element meets the statutory requirements described in HCD’s
May 20, 2022 review. The housing element will substantially comply with State
Housing Element Law (Gov. Code, § 65580 et seq) when it is adopted, submitted
to and approved by HCD, in accordance with Government Code section 65585,
subdivision (g).
Public participation in the development, adoption and implementation of the housing
element is essential to effective housing planning. Throughout the housing element
process, the City must continue to engage the community, including organizations that
represent lower-income and special needs households, by making information
regularly available while considering and incorporating comments where appropriate.
Please be aware, any revisions to the element must be posted on the local
government’s website and to email a link to all individuals and organizations that have
previously requested notices relating to the local government’s housing element at
least seven days before submitting to HCD.
Several federal, state, and regional funding programs consider housing element
compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill
(SB) 1 Sustainable Communities grant, the Housing and Sustainable Communities
programs, and HCD’s Permanent Local Housing Allocation consider housing element
compliance and/or annual reporting requirements pursuant to Government Code section
Attachment 2
Knarik Vizcarra, Planning Manager
Page 2
65400. With a compliant housing element, the City meets housing element
requirements for these and other funding sources.
For your information, some general plan element updates are triggered by housing
element adoption. HCD reminds the City to consider timing provisions and welcomes
the opportunity to provide assistance. For information, please see the Technical
Advisories issued by the Governor’s Office of Planning and Research at:
https://www.opr.ca.gov/planning/general-plan/guidelines.html.
HCD appreciates the hard work and dedication you and your consultants provided in
preparation of the City’s housing element and looks forward to receiving the City’s
adopted housing element. If you have any questions or need additional technical
assistance, please contact me at Melinda.Coy@hcd.ca.gov.
Sincerely,
Melinda Coy
Proactive Housing Accountability Chief
City of Azusa
General Plan
Azusa Housing for All
Housing Element 2021-2029
Approved March 7, 2022 per Resolution No. 2022-C17
Revised October 2022, March 2023, and May 2023 per
HCD Comments
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AZUSA HOUSING FOR ALL | AZUSA HOUSING ELEMENT 2021-2029
City of Azusa City Council
Robert Gonzales, Mayor
Jesse Avila, Mayor Pro-tem
Edward J. Alvarez, Council Member
Andrew N. Mendez, Council Member
Dennis Beckwith, Council Member
City of Azusa Planning Commission
Robert Donnelson, Chair
Elizabeth Ramirez, Vice Chair
Mercedes Castro, Commissioner
Charles Frank Allen, Commissioner
Brittany Martinez, Commissioner
Asuza Housing for All Advisory Committee Members
Mercedes Castro, Chair — City of Azusa Planning Commission
Andrew N. Mendez, Vice-Chair — City of Azusa City of Azusa City Council
Christell Hutchinson, Azusa Senior Advisory Committee
Steve Castro, Azusa Chamber of Commerce
Latasha Jamal, Azusa Unified School District
Maureen Taylor, Azusa Pacific University
City of Azusa Department of Economic & Community Development
Matt Marquez, Director
Manuel Muñoz, Planning Manager/Azusa Housing for All Project Manager
Carina Campos, Economic Development Specialist
Consultant Team
MIG, Inc.
City of Azusa
Department of Economic & Community Development
Planning Division
213 E. Foothill Blvd.
Azusa, CA 91702
626-812-5262
www.azusaca.gov
Acknowledgements
Approved March 7, 2022 per Resolution No. 2022-C17 | City of Azusa General Plan
This document was funded by the California Department of Housing and Community Development’s Local Early Action
Planning (LEAP) Grant.
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AZUSA HOUSING FOR ALL | HOUSING ELEMENT 2021-2029
Contents
Chapter 1: Introduction.........................................................2
Regulatory Framework ��������������������������������������������������������������������������5
Scope and Content of the Housing Element �������������������������������������������� 5
Acronyms ����������������������������������������������������������������������������������������������6
Relationship to Other General Plan Elements������������������������������������������ 7
Public Participation �������������������������������������������������������������������������������8
Public Review Draft Housing Element ������������������������������������������������������12
Chapter 2: Housing Plan ...................................................14
Goals and Policies ��������������������������������������������������������������������������������15
Summary of Quantified Objectives ����������������������������������������������������������40
Chapter 3: Needs Assessment............................................42
Population and Employment Trends ���������������������������������������������������������42
Household Characteristics �������������������������������������������������������������������47
Housing Stock Characteristics �������������������������������������������������������������49
Special Housing Needs ������������������������������������������������������������������������51
Energy Conservation Opportunities���������������������������������������������������������57
At-Risk Housing Analysis ���������������������������������������������������������������������58
Projected Housing Need (RHNA) ����������������������������������������������������������61
Chapter 4: Constraints Analysis..........................................64
Non-Governmental Constraints: Market Constraints ������������������������������64
Government Code 65583(a)(6) Development Analysis ����������������������������67
Governmental Constraints �������������������������������������������������������������������69
Affirmatively Furthering Fair Housing����������������������������������������������������105
Environmental and Infrastructure Constraints���������������������������������������148
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Chapter 5: Housing Resources..........................................152
Availability of Sites for Housing ���������������������������������������������������������152
Administrative Resources �������������������������������������������������������������������190
Financial Resources ����������������������������������������������������������������������������192
Chapter 6: Housing Element Program Accomplishments.196
Quantified Objectives ������������������������������������������������������������������������210
Appendix A.......................................................................212
Appendix B.......................................................................246
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Introduction
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AZUSA HOUSING ELEMENT 2021-2029 | INTRODUCTION
Introduction
1 California Department of Finance, Report E-1: Population Estimates for Cities, Counties and the State, 2021.
Background & Purpose
The City of Azusa, known as the “Canyon City,” lies at the foot of the San Gabriel Mountains
in Los Angeles County. Founded in 1887, Azusa was incorporated as a general law city on
December 29, 1898. Beginning with a population of 865 in 1899, Azusa grew from 29,380
residents in 1980 to 41,330 residents in 1990, an increase of 41 percent. Since 1990, population
growth has been relatively moderate, reflecting the economic recession of the early to mid-
1990s. Even so, in 2019, Azusa was recognized as the fastest growing city in the San Gabriel
Valley. As of 2020, Azusa had an estimated population of 49,6581 , representing an increase of 11
percent since 2000.
Among the eight San Gabriel Valley foothill communities, Azusa has long supplied a
disproportionate amount of affordable housing. Most neighboring jurisdictions have a history
of actively discouraging the provision of multi-family or entry-level housing. As a result, among
foothill cities, Azusa has had the lowest rate of home ownership, lowest median housing sales
price, and the highest rates of overcrowding and substandard housing. In the past, these factors
also contributed to a decline in retail economic activity, as surrounding cities aggressively
pursued sales tax revenue drawn by their stronger buying power. As a result, many older
neighborhoods in Azusa went into decline, with property values and reinvestment falling and
crime and rental turn-over increasing.
During recent decades, Azusa’s demographics have changed. The Hispanic population
continues to grow in the city, from 53 percent in 1990 to over two thirds (68 percent) in 2018.
In recent years, the Asian/Pacific Islander population has also been increasing in Azusa, from
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INTRODUCTION | AZUSA HOUSING ELEMENT 2021-2029
six percent in 2000 to 14 percent in 2018.
The population also grew older, as the
percentage of middle-aged adults (45 to
64 years) enumerated in the 2010 Census
increased by 39 percent from the population
counts in 2000. As of 2018, 31 percent
of the population is over 45 years old.
As population shifts occur, the pressure
increases on older housing, neighborhoods,
and services and programs to provide a safe
and healthy environment for residents.
The lack of affordable housing in
surrounding cities has also exacerbated
the squeeze on Azusa’s housing, as rents have risen without substantial reinvestment due to
a regional housing shortage. Because substantial residential growth occurred in the 1950s
and 1960s, over 70 percent of the housing stock in the City is 30 years or older, the age
when most homes begin to require major repairs. Recognizing this as an important housing
concern, the City has become a leader in promoting neighborhood improvements through
a pioneering rental inspection program, neighborhood code enforcement and provision of
home improvement/rehabilitation assistance. Continuation of these programs is necessary, as a
growing share of the housing stock requires improvement or rehabilitation.
Of the 14,651 housing units in Azusa, 46 percent are single-family detached homes, 14 percent
are single family attached homes, 36 percent are multifamily units, and four percent are mobile
homes. While housing prices have been steadily increasing throughout the region, housing costs
in Azusa are lower than neighboring cities. In 2000, the median price of a single-family home was
about $150,000. Housing prices peaked in 2006 in Azusa, with a median sale price of $429,500.
In November 2012, the City’s median home price had declined to $306,000, reflecting national
trends associated with the mortgage meltdown that began in 2007. As of 2020, home prices had
recovered to their previous highs, with homes selling in September 2020 at an average $495,500.
Home sales prices of existing homes in Azusa are generally in the moderate-income range,
while recently developed and planned new single-family developments will provide a greater
stock available to upper-income households.
Despite comparatively lower housing prices and rents, because of the generally lower incomes
of existing residents, many households still face a housing cost burden. In particular, almost half
(44 percent) of renter households in Azusa are experiencing a housing cost burden and may
have to double up with other families to afford rents, which in turn contributes to overcrowding
(13 percent of units in Azusa are overcrowded).
4
This Housing Element places housing within the larger context of economic prosperity,
environmental sustainability and neighborhood quality of life. This Housing Element
looks beyond the singular goal of meeting Azusa’s legal obligations for planning for new
housing. It looks to meeting the community’s goals of providing safe and healthy homes and
neighborhoods for all of Azusa’s diverse families.
Through the 2004 comprehensive General Plan update, areas to accommodate future residential
growth while respecting the existing character of the community were defined. Citizens
embraced the vision of integrating housing as part of the revitalization of the community’s
underutilized commercial corridors as both a tool for economic revitalization and to create
needed new housing opportunities. In 2015, the City adopted a TOD Specific Plan with a vision
to revitalize and renew the areas around the light rail stations, Azusa’s Downtown and adjacent
residential neighborhoods. This Specific Plan provides flexibility with no site-specific density
limits and has resulted in a renewed interest in residential development at the city’s core. In
addition to opportunities for mixed use, residential infill in existing neighborhoods and adaptive
reuse will combine to provide needed sites to address the City’s share of regional housing
needs.
As articulated in the community engagement efforts for the 2004 General Plan, the community
strongly believes that it is not enough to provide housing, especially for low- income families. All
families deserve access to quality education and community services, including parks, libraries,
law enforcement, transportation, and recreation. Too often in the past, “affordable housing”
has inferred substandard or crime-ridden housing. The City of Azusa is proud to welcome
families of all incomes with a well-planned strategy for improving the neighborhoods and entire
community to allow all to work to improve their economic status and provide opportunities for
their children. By improving the community “one neighborhood at a time,” affordable housing
can become a positive reality.
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INTRODUCTION | AZUSA HOUSING ELEMENT 2021-2029
Regulatory Framework
The Housing Element is a mandatory General Plan element. It identifies ways in which the
housing needs of existing and future residents can be met. State law requires that all cities
adopt a Housing Element and describes in detail the necessary contents of the Housing
Element. California planning law provides more detailed requirements for the Housing Element
than for any other General Plan element. This Housing Element responds to those requirements
and responds specifically to conditions and policy directives unique to Azusa.
The California Legislature has identified the attainment of a decent home and suitable living
environment for every Californian as the state’s main housing goal. Recognizing the important
part that local planning programs play in pursuit of this goal, the Legislature has mandated that
all cities and counties prepare a Housing Element as part of their comprehensive General Plans.
Section 65581 of the California Government Code reflects the legislative intent for mandating
that each city and county prepare a Housing Element:
1. To ensure that counties and cities recognize their responsibilities in contributing to the
attainment of the State housing goal
2. To ensure that counties and cities will prepare and implement housing elements which,
along with federal and state programs, will move toward attainment of the state housing
goals
3. To recognize that each locality is best capable of determining what efforts are required
by it to contribute to the attainment of the state housing goal, provided such a
determination is compatible with the state housing goal and regional housing needs
4. To ensure that each local government cooperates with other local governments to
address regional housing needs
Scope and Content of the Housing Element
The Housing Element covers the planning period of October 15, 2021 through October 15, 2029
and identifies strategies and programs to: 1) encourage the development of a variety of housing
opportunities; 2) provide housing opportunities for persons of lower and moderate incomes;
3) preserve the quality of the existing housing stock in Azusa; 4) minimize governmental
constraints; and 5) promote equal housing opportunities for all residents.
Toward these ends, the Housing Element consists of:
• An introduction of the scope and purpose of the Housing Element
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AZUSA HOUSING ELEMENT 2021-2029 | INTRODUCTION
• A Housing Plan to address the identified housing needs, including housing goals,
policies, and programs
• An analysis of the City’s demographic and housing characteristics and trends
• A review of potential market, governmental, and environmental constraints to meeting
the City’s identified housing needs
• An evaluation of land, administrative, and financial resources available to address the
housing goals
• A review of past accomplishments under the previous Housing Element
Acronyms
This element includes use of many acronyms to identify agencies, housing programs, funding
sources, and planning terms. Commonly used acronyms are:
AFFH Affirmatively Furthering Fair Housing
AI Analysis of Impediments to Fair Housing
ACS American Community Survey
AMI Area Median Income
CDBG Community Development Block Grant
CEQA California Environmental Quality Act
CHAS Comprehensive Housing Affordability Strategy
CHDO Community Housing Development Organization
DOF State of California Department of Finance
HCD State of California Department of Housing and Community Development
HUD Federal Department of Housing and Urban Development
LIHTC Low-Income Housing Tax Credit
MFI Median Family Income
MRB Mortgage Revenue Bonds
RHNA Regional Housing Needs Assessment
SCAG Southern California Association of Governments
SRO Single Room Occupancy
TOD Transit-Oriented Development
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INTRODUCTION | AZUSA HOUSING ELEMENT 2021-2029
Relationship to Other General Plan Elements
The Housing Element builds upon the other elements within the Azusa General Plan and is
consistent with the General Plan’s policies and proposals. Housing policy draws upon the
development capacity levels established in the Land Use Element to determine the appropriate
location for housing development. One of the General Plan’s primary themes is to facilitate
mixed-use development along key commercial corridors in the city. Whenever any element of
the General Plan is amended, the Housing Element will be reviewed and modified, if necessary,
to ensure continued consistency between elements.
Several new laws trigger additional General Plan update requirements upon revision of the
Housing Element.
• Government Code Section 65302.10 requires that before the due date for adoption of
the next Housing Element after January 1, 2012, the General Plan Land Use Element
must be updated to identify and describe disadvantaged unincorporated communities
(DUC) that exists within the city’s sphere of influence (SOI). Concurrent with the 2014-
2021 Housing Element adoption, the City updated the Built Environment Chapter
(Infrastructure Element) to identify the three DUCs that exist within Azusa’s SOI and
existing infrastructure considerations.
• Government Code Section 65302(g) and Section 65302.5 requires that, upon the next
revision of housing elements after 2014, the Safety Element must be reviewed and
updated as necessary to address wildfire risks. The City will review the Safety Element
for compliance with State law. Program 30 is included in the Housing Plan (see Chapter
2) to indicate that the City will update the Safety Element as part of an upcoming
comprehensive update to the General Plan.
• Government Code Section 65302(d)(3) and Government Cde Section (g)(2)(B) require
that, upon the next revision to housing elements after 2009, the Conservation and Safety
Elements be reviewed and updated to identify land that can accommodate floodwater
and address flooding risks. Concurrent with the 2014-2021 Housing Element adoption,
the City updated the Built Environment Chapter, the City updated the City Design
Element, the Geological Hazards Element, and the Open Space and Biological Resources
Element to address this State law.
• Government Code Section 65302(h) requires local jurisdictions to add an Environmental
Justice element to their General Plans if any disadvantaged communities are present.
This new Element (which may also be integrated into an existing element) is required
when two or more elements are updated concurrently, beginning January 1, 2018. The
City does not have an Environmental Justice Element but will comply with State law
upon the next revision to two or more concurrent General Plan elements, as indicated in
Program 30 in the Housing Plan.
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AZUSA HOUSING ELEMENT 2021-2029 | INTRODUCTION
The Housing Element is also closely related to the Development Code and assesses multiple
ordinances and Development Code sections that pertain to housing for compliance with State
law. As new ordinances are considered, the City will review the Housing Element to ensure
compliance with housing policies.
Public Participation
The Housing Element must reflect the values and preferences of the community; therefore,
public participation plays an important role in the development of this Element. Section 65583(c)
(7) of the Government Code states: “The local government shall make diligent effort to achieve
public participation of all economic segments of the community in the development of the
housing element, and the program shall describe this effort.” This process not only includes
residents of the community, but also coordinates participation among local agencies and
housing groups, community organizations, and housing sponsors.
Community participation formed the foundation for the 2004 comprehensive update to the
Azusa General Plan. Over 20 public meetings were conducted during development of the
General Plan, drawing active participation from hundreds of residents, business people and
other stakeholders from the community. Special efforts were successfully pursued to increase
the participation of Spanish speakers, young people and other traditionally under-represented
community stakeholders. Advertisement of meetings was conducted through direct mail
notification of residents and community-based groups. Service organizations were directly
contacted to solicit participation in the program, and included organizations representing lower-
income Latinos, single-parent households, seniors and youth, among others. Shuttle service was
provided to increase participation among the transit dependent population, and included stops
at the City’s senior housing facilities and other locations. Spanish translators were present at all
public meetings carried out for the General Plan, including several Citywide Citizen Congress
meetings. One Citizen Congress meeting specifically focused on outreach to the Spanish-
speaking residents of the City and was conducted entirely in Spanish. Through this outreach
process, the strategies in the Housing Element were defined. This 2021 Housing Element
Update builds upon these strategies, maintaining direction defined in the extensive General
Plan outreach process.
Community outreach for the 2021 Housing Element update included two workshops, a
community survey, the convening of a subcommittee, study sessions with the joint Planning
Commission and City Council, and a digital education campaign, including a website, video,
social media posts, and youth activities. Outreach for the sixth cycle Housing Element was
challenging because much of the update process occurred during the COVID-19 pandemic.
Restrictions on public gatherings prevented the City from holding traditional public workshops.
Instead, the city utilized online engagement tools, including an online survey, social media
posts, an educational video, collaboration with the library for youth activities, and online
documents to provide opportunities for the community to share their feedback. Following
guidance from public health agencies regarding public gatherings and COVID-19, all workshops
and meetings were held virtually using online video conferencing (Zoom). The workshops,
survey, and outreach material was accessible to English, Spanish, and Mandarin speakers.
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INTRODUCTION | AZUSA HOUSING ELEMENT 2021-2029
COMMUNITY WORKSHOP
On March 9 and March 30, 2021, the City conducted community workshops to gather input from
key local stakeholders, housing advocates, and residents. The meeting included a PowerPoint
presentation about the intent of the Housing Element update and Regional Housing Needs
Assessment (RHNA), opportunities to meet local housing needs, and creative approaches
to address the City’s constraints to housing production, which was followed by a facilitated
discussion regarding housing issues. The first
workshop had 19 attendees and the second
workshop had 22 attendees. To ensure that
the housing concerns of low- and moderate-
income and special needs residents were
addressed, the City notified agencies and
organizations that serve these communities
in Azusa and surrounding areas.
The list of agencies and organizations
invited to the workshop are listed in
Appendix A and included nearly 100 groups
and agencies working with special needs
groups, civic and religious groups, and
housing developers and local businesses.
Outreach for the workshops was conducted
in English, Spanish, and Chinese using
flyers, social media posts, and emails to the
stakeholder list. Information was posted on
the General Plan/Housing Element website.
The community workshops had dedicated
Spanish and Mandarin breakout rooms
where the presentation and discussion were
available in both languages. A summary of
the workshops is provided in Appendix A.
Community input included the need for:
• More affordable, multi-family housing
• Education on housing policies,
opportunities, and new housing types
for tenants and landlords
• New housing by transit and
commercial corridors
• Long term maintenance plan for
larger apartment buildings
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AZUSA HOUSING ELEMENT 2021-2029 | INTRODUCTION
• Addressing development constraints, especially those related to parking issues
• Creative housing solutions such as housing on churches, tiny homes,
repurposed malls, etc.
• Homeless and supportive housing and services
• More affordable housing and more homeownership opportunities
• Respecting the current community members
• A full array of new housing types
• Addressing overcrowding
• Ensuring housing is safe and contemporary
• Supporting housing on vacant school sites
HOUSING ELEMENT SURVEY
The City of Azusa developed a community survey to gather feedback for the 2021-2029 Housing
Element Update from Azusa residents, workers, property owners and others interested in
housing issues in and around the city. The survey was
posted on the City of Azusa’s website from February 26,
2021 to March 31, 2021 and available in English, Spanish,
and Chinese. Weekly social media posts and giveaways
encouraged the Azusa community to participate. The
survey received a total of 260 responses. A total of 59
percent were homeowners and over one-quarter (27
percent) were renters. Nearly twelve percent lived with
friends and family and/or did not have a permanent
home.
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INTRODUCTION | AZUSA HOUSING ELEMENT 2021-2029
Survey findings included:
• More than sixty percent of respondents live in a single-family home (64 percent).
• Around one fifth of Azusa residents said they chose to live in Azusa due to close distance
to family and friends (20 percent) and the cost of housing (17.5 percent).
• Some of the most important housing challenges to respondents included ensuring that
children who grow up in Azusa can afford to live in the city on their own; encouraging
rehabilitation of existing housing in older neighborhoods; supporting programs to help
homeowners at risk of mortgage default to keep their homes; and establishing housing
for households with special needs such as seniors, large families, veterans, and/or
persons with disabilities.
• Respondents ranked the best general locations for new housing in Azusa, identifying
areas along Foothill Boulevard, along Arrow Highway, and along Azusa Avenue and San
Gabriel Avenue as the top three options.
• Respondents considered the tradeoffs associated with new housing development and
said new housing should be concentrated near existing and planned public transit, new
housing should blend in with the character of surrounding neighborhoods, and new
housing should be spread evenly across all parts of the city.
• Over one in three respondents said they have lived in Azusa for 20 or more years (37
percent).
See Appendix A for a complete survey summary.
ADVISORY COMMITTEE MEETINGS
The City Council appointed a Housing Element Advisory Committee as an engagement group
for the Housing Element update and invited representatives from the senior advisory group,
school district, Azusa Pacific University, Planning Commission, City Council, residents at-large,
and the business community. The first Advisory Committee meeting was held on March 10, 2021,
where a chair was nominated, and an overview of the Housing Element was provided. Advisory
Committee members were asked to share their thoughts on the key housing issues in Azusa and
how the City can best address local housing needs. The meeting was attended by a total of 17
participants.
Advisory Committee input included the need to:
• Consider infrastructure impacts with an increase in housing
• Prioritize redevelopment of underutilized properties
• The need for senior housing and multi-generational housing
• Balance the types of new housing (i.e., small and large apartment complexes, single-
family homes, ADUs, etc.)
• Identify the prime areas for redevelopment
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AZUSA HOUSING ELEMENT 2021-2029 | INTRODUCTION
The Advisory Committee also held a public meeting in June to review a preliminary draft of
the Housing Element and provide an opportunity for additional public input. Subcommittee
members and one member of the public attended the meeting and discussed the need to
be forward-thinking and have a balanced approach to land-use planning. The committee
discussed adding two additional programs to the Housing Element: one to study options for
an inclusionary housing ordinance, and the other to conduct long-term master planning studies
for infrastructure. These programs were added to the Draft Housing Element. A summary of the
meetings is provided in Appendix A.
PLANNING COMMISSION AND CITY COUNCIL STUDY SESSIONS
On April 19, 2021, the City conducted the first Planning Commission and City Council Study
Session to present proposed key policy directives for the Housing Element based on information
gathered during the community workshops, survey, and first subcommittee meeting. The
session also covered additional opportunities for engagement before providing an overview
of the Housing Element. Upon the conclusion of the first study session presentation, the City
provided a timeline of next steps and then opened the meeting for any final questions or
comments. There were no further comments recorded during the first study session.
Public Review Draft Housing Element
The Draft Housing Element was posted on the City’s website and distributed to stakeholders on
June 16, 2021. During the public review period, a study session with the Planning Commission
and City Council was held to provide an additional opportunity for public input (June 21,
2021) prior to submitting the draft to HCD for review and comment on July 6, 2021. During the
meeting, the City’s consultant presented a summary of Housing Element requirements, public
input, and the content of the Housing Element. There were no public comments received during
the study session. Between June 16, 2021 and July 5, 2021, the draft Housing Element was
advertised for public review and an online comment form was available for the public to provide
feedback on the Draft Element. During this time, three public comments were received. The
public comments are included in Appendix A (Outreach). In response to these comments, the
Housing Plan was reviewed, and the following changes were made:
• Program H3-4 (ADUs) was revised to ensure consistency with State law for ADU
regulations
• Program H3-6 (Homelessness) was revised to support ongoing efforts to address
homelessness through the provision of emergency shelter, transitional housing, and
supportive housing
The Draft Element remained available on the City’s website for additional public review and
comment during the HCD review period. As revisions were made to respond to HCD comments,
this information was also posted on the City’s website. HCD reviewed the draft Element and
provided comment letters with requests for revisions. The Housing Element was revised in
response to these comments and the public was invited to attend and comment on the Housing
Element at hearings held before the Planning Commission and the City Council. The revised
Draft Housing Element was available on the website and at City Hall no less than 10 days prior to
each hearing.
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
Housing Plan
This Housing Plan’s goals, policies, and programs have been established to address housing
issues in Azusa and to meet State law housing requirements. The City’s enduring objective is
to facilitate and encourage safe, decent housing that fulfills the diverse needs of current and
future residents. To achieve this vision, the Housing Plan identifies long-term housing goals
and shorter-term policies and programs to address identified housing needs, constraints to
development confronting the City, and resources available to address the housing needs. These
are informed by recent community input, the housing needs assessment (Chapter 3), housing
constraints analysis (Chapter 4), housing resources analysis (Chapter 5), and the review of
program accomplishments for the previous (2014-2021) Housing Element (Chapter 6).
To make adequate provision for the housing needs for people of all income levels, State law
(Government Code 65583[c]) requires that the City, at a minimum, identify programs that do all
of the following:
• Identify adequate sites, with appropriate zoning and development standards and
services to accommodate the locality’s share of the regional housing needs for each
income level.
• Assist in the development of adequate housing to meet the needs of extremely low-,
very low-, low-, and moderate-income households.
• Address and, where possible, remove governmental constraints to the maintenance,
improvement, and development of housing, including housing for people at all income
levels, as well as housing for people with disabilities.
• Conserve and improve the condition of the existing affordable housing stock and
preserve assisted housing developments at risk of conversion to market-rate housing.
• Promote equal housing opportunities for all people, regardless of race, religion, sex,
marital status, ancestry, national origin, color, familial status, or disability.
The programs below identify the actions that will be taken to make sites available during the
planning period with appropriate land use and development standards, and with services and
facilities to accommodate the City’s share of regional housing need for each income level. The
programs also address identified housing issues in Azusa and approaches to meet State law
housing requirements.
Programs generally include a statement of specific City action(s) necessary to implement a
policy or goal and identify the City department or other agency responsible for implementation,
the quantified objectives (where applicable), and a timeframe for completion. A summary of
quantified objectives is included following the program descriptions.
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
Goals and Policies
A� MAINTAIN AND PRESERVE EXISTING AFFORDABLE HOUSING
STOCKS
Continued maintenance and preservation of the existing housing stock in Azusa is a high
priority to ensure high-quality neighborhoods. Housing activities that help achieve this goal
include rehabilitation of single- and multi-family housing units, code enforcement, and efforts to
preserve assisted housing units that may be at risk of converting to market-rate housing.
Goal H1: Maintain and enhance the quality of existing housing and residential
neighborhoods in Azusa.
Policy H1.1 Encourage neighborhood involvement and pursue comprehensive
neighborhood preservation and reinvestment strategies and for portions of the
community with aging and deteriorating housing and infrastructure.
Policy H1.2 Leverage State and federal loans and grants to assist in preserving
existing housing through rehabilitation and home improvement assistance to lower- and
moderate-income households, seniors, and the disabled.
Policy H1.3 Encourage the rehabilitation of substandard residential properties by
homeowners and landlords.
Policy H1.4 Promote increased awareness among property owners and residents of
the importance of property maintenance to long-term affordable housing.
Policy H1.5 Cooperate with non-profit housing providers in the acquisition,
rehabilitation, and maintenance of older apartment complexes and single-family houses
to be preserved as long-term affordable housing.
Policy H1.6 Assist in the conservation and preservation of all affordable housing
units, and work to preserve existing affordable housing that is considered at risk of
converting to market-level rents.
Program H1-1: Residential Rehabilitation Program
• Using CDBG funds, provide grants to extremely low-, very low-, low-, and moderate-
income households for the rehabilitation of residences. Examples of eligible repairs and
improvements include but are not limited to energy efficiency improvements, removal
of impediments and material barriers that obstruct accessibility, roofing, plumbing
repairs, electrical repairs, exterior painting, and window replacement. Prioritize grants for
extremely low-income households.
• Promote energy efficiency improvements to households participating in rehabilitation
programs.
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
• Continue to promote funding opportunities on the City’s website and through placement
of brochures in public locations and at community events.
Timeframe/Objective: Annually identify and implement projects to receive CDBG funding
through the Annual Action Plan process
Responsible Agency: Economic and Community Development Department
Funding Sources: CDBG
Quantified Objective: Provide 10 grants annually up to a maximum amount of $12,000 per
household, to assist a total of 80 households during the 2021-2029 planning cycle.
Program H1-2: Rental Housing Inspection Program
• Continue to administer the rental inspection program to ensure properties remain safe
and well maintained, preserving existing rental housing in the city.
• Coordinate with Los Angeles County Development Authority (LACDA) and other multi-
family property owners or non-profit organizations that own and manage affordable
housing in the city to advise on any necessary improvements to multi-family housing that
needs rehabilitation. Support funding opportunities initiated by these entities to improve
neighborhood quality.
Timeframe/Objective: Ongoing; annually monitor the 743 rental units that require regular
oversight; coordinate with property owners as rehabilitation needs are identified.
Responsible Agency: Economic and Community Development Department - Community
Improvement Division
Funding Sources: Departmental Budget, Outside Funding Sources
Quantified Objective: Annually inspect 1,000 rental units
Program H1-3: Neighborhood Improvement Zone Program
• Using CDBG funding, support neighborhood improvements, including sidewalks and
housing rehabilitation and house painting.
• Pursue additional funding sources to identify target neighborhoods and involve residents
to identify and implement needed improvements.
• Using CDBG funds, construct Americans-with-Disabilities Act Compliant (ADA)
improvements that improve accessibility and mobility for all persons, especially providing
elderly and severely disabled persons safe and clear paths of travel.
Timeframe/Objective: Annually, install approximately 15-20 Americans with Disabilities
Act-compliant curb ramps with truncated domes and replace damaged sidewalks to provide
accessible, unobstructed path of travel for severely disabled adults and elderly persons; identify
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and apply for additional funding for target neighborhoods in 2025.
Responsible Agency: Economic and Community Development Department
Funding Sources: CDBG, Outside Funding Sources
Program H1-4: Monitor and Preserve Affordable Housing and At-Risk
Rental Housing
• Maintain an inventory of affordable housing units in the city, with unit affordability
information to ensure landlords are compliant with deed restrictions. Three
developments have expiring affordability covenants (or recently expired) in Azusa: Alosta
Gardens, Villa Azusa Senior Apartments, and Azusa Park Apartments (whose affordability
covenants expired in 2020).
• Continue to monitor the status of subsidized affordable projects, rental projects, and
mobile homes and provide technical and financial assistance, when possible, to ensure
long-term affordability.
• Continue to work with non-profit organizations to preserve existing affordable housing in
the City.
• Support funding applications to preserve at-risk units.
• For developments considering converting to market rate, work with the owners and
property managers to discuss preservation options and present options to owners
for rehabilitation assistance and/or mortgage refinancing in exchange for long-term
affordability restrictions.
• Hold public hearings upon receipt of any Notice of Intent to Sell or Notice of Intent to
Convert to Market Rate Housing, pursuant to Section 65863.10 of the Government Code
and provide tenant education on housing rights.
Timeframe/Objective: Contact owners with expiring covenants two years in advance of the
expiring covenant; annually report as part of the Annual Progress Report process; implement
preservation measures to preserve 178 units of affordable housing units through the planning
period.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H1-5: Code Enforcement
In conjunction with the Residential Rehabilitation Program (Program H1-1), the Code
Enforcement Program aids in arresting the decline of residential low- and moderate-income
areas that have been deemed deteriorating or deteriorated. Code violations addressed through
this CDBG-funded activity include graffiti abatement, unpermitted/illegal construction, vehicles
parked on lawns, illegal garage conversions, roofs in disrepair, broken windows, and over
accumulation of trash and/or debris.
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Timeframe/Objective: Ongoing; inspect 200-300 reports of code enforcement violations
annually; refer eligible cases to the Housing Rehabilitation Program; annually report progress
through the Comprehensive Annual Performance Evaluation Report (CAPER) process.
Responsible Agency: Economic and Community Development Department
Funding Source: CDBG
B� ASSIST IN THE DEVELOPMENT OF AFFORDABLE HOUSING
Azusa strives to have a balanced community, with housing units available for all income
segments of the population. Prior to its dissolution, the Redevelopment Agency facilitated the
production of affordable for-sale and rental housing through the provision of both financial and
regulatory incentives. With the dissolution of Redevelopment, the City supports affordable
housing through participation in the CDBG and HOME programs, through technical assistance
and regulatory incentives, and through regional programs.
Goal H2: Assist in the provision of adequate housing to meet the needs of the
community. Establish a balanced approach to meeting housing needs that includes the
needs of both renter and owner households.
Policy H2.1 Facilitate housing development of affordable to lower-income
households by providing technical assistance, regulatory incentives and concessions,
and financial resources as funding permits.
Policy H2.2 Encourage and provide incentives for both the private and public
sectors to produce or assist in the production of affordable housing, with emphasis
on housing affordable to persons with disabilities, seniors, large families, female-headed
households with children, and people experiencing homelessness.
Policy H2.3 Establish partnerships with private developers and non-profit housing
corporations to assist Azusa in meeting its housing goals.
Policy H2.4 As funding allows, provide rental assistance to address existing housing
problems and support regional programs to assist prospective homebuyers.
Program H2-1: First-Time Homebuyer Assistance Programs
• Continue to support first-time, low-and moderate-income home buyers in Azusa by
connecting interested residents and members of the public to the Mortgage Credit
Certificate (MCC) and First Home Mortgage programs, run locally by Los Angeles County
Development Authority (LACDA).
• Direct residents to the LACDA offices and website and review key eligibility
requirements. Advertise and encourage interested first-time, low-income homebuyers
in Azusa to apply for the federal Home Ownership Program (HOP), financed with HOME
funds provided by the U.S. Department of Housing and Urban Development (HUD).
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• Coordinate with Azusa service providers and other community-based organizations to
publicize these housing assistance programs. Provide information on these programs on
the City’s website and via social media, through flyers posted at City facilities, and via
staff assistance at City Hall.
Timeframe/Objective: Ongoing to increase access to information about available resources
for all community members; update the City’s website and begin advertising homeownership
housing assistance programs within one year of Housing Element adoption.
Responsible Agency: Economic and Community Development Department, Community
Development Commission of the County of Los Angeles
Funding Sources: Departmental Budget; HOME; Federal Income Tax Credit
Program H2-2: Affordable Housing Funding Sources
• As federal funding permits, continue to provide loans and grants as part of the
Residential Rehabilitation Program (see Program H1-1) as a means to maintaining a high-
quality housing stock, and assisting lower-income households and property owners in
maintaining affordable housing units.
• Actively support efforts to secure State, federal, and private funding sources as a means
of leveraging local funds and maximizing assistance.
Timeframe/Objective: Annually plan and report on CDBG and HOME funding through the
Annual Action Plan and Consolidated Annual Performance Evaluation Report (CAPER) process;
pursue additional grants for housing support within three years of Housing Element adoption to
secure at least one additional grant during the planning period.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget; CDBG; HOME
Program H2-3: Section 8 Housing Choice Voucher Program
• Continue partnership with the Los Angeles County Development Authority (LACDA),
which administers the Housing Choice Voucher (Section 8) rental assistance program
in Azusa to foster housing opportunities for extremely low-, very low-, and low-income
residents. Support additional Housing Choice Vouchers in the community and encourage
rental property owners to rent to Housing Choice Voucher holders and register their units
with the LACDA.
• Promote housing mobility by affirmatively marketing and promoting the use of Housing
Choice Vouchers in high opportunity areas.
• Advertise and encourage landlords in Azusa to participate in the Homeless Incentive
Program run by LACDA, which provides financial support for property owners who rent
to homeless Section 8 voucher holders. Send an annual notice to all multifamily property
owners in Azusa about participation in the HCV program including available incentives
from the LACDC.
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• Direct interested residents to the LACDA website and continue to provide information on
the Housing Choice Voucher program, including new legal requirements pursuant to SB
329, which prohibits housing discrimination on the basis of source of income (including
Housing Choice Vouchers).
Timeframe/Objective: Ongoing; annually review Housing Choice Voucher participation
and adjust information dissemination efforts as appropriate to preserve 242 Housing Choice
Vouchers currently in use in Azusa; increase the number of units available to HCV holders by at
least 5.
Responsible Agency: Housing Authority of the County of Los Angeles; Economic and
Community Development Department
Funding Sources: HUD
Program H2-4: Inclusionary Housing Ordinance
Inclusionary housing policies require developers to reserve a certain percentage of housing
units for extremely low/very low, low, and moderate-income households in new residential
developments or to pay an in-lieu fee for affordable housing. Over 20 percent of jurisdictions in
California have adopted inclusionary housing ordinances or General Plan policies.
• Study and, if shown to be appropriate for Azusa, adopt an inclusionary housing ordinance
and program. Assess any constraints such an ordinance might have on residential
development in the city and modify accordingly.
• Ensure consistency between a new Inclusionary Housing Ordinance and State density
bonus regulations.
• Monitor the impact of an adopted inclusionary housing policy/ordinance on production
of market rate housing in response to market conditions.
Timeframe/Objective: Evaluate feasibility of an inclusionary ordinance within one year of
Housing Element adoption; if appropriate, develop for possible adoption within two years of
Element adoption, including a plan for ongoing monitoring and updates.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget; General Fund; State grants
C� ENCOURAGE HOUSING VARIETY
Meeting the housing needs of all residents in the community requires the identification of
adequate sites for all types of housing. By capitalizing on the allowances in the Development
Code and TOD Specific Plan and continuing to maintain an inventory of potential sites, the City
will ensure that adequate residentially zoned and mixed-use sites are available.
Goal H3: Encourage a variety of housing types to meet the existing and future needs of
Azusa residents.
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Policy H3.1 Accommodate a range of residential development types in Azusa,
including low-density single-family homes, moderate-density townhomes, higher-
density multi-family units, and residential/commercial mixed use in order to address the
City’s share of regional housing needs.
Policy H3.2 Continue to maintain an up-to-date residential sites inventory, and
provide information to interested developers in conjunction with information on
available development incentives.
Policy H3.3 Create mixed-use opportunities along key commercial corridors as a
means of enhancing pedestrian activity and community interaction.
Policy H3.4 Encourage development and long-range planning that uses compact
urban forms that foster connectivity, walkability, and use of alternative transportation
modes, in particular within the Azusa TOD planning area.
Policy H3.4 Continue to allow accessory dwelling units as a means of providing
additional infill housing opportunities.
Policy H3.5 Support the provision of high-quality rental housing for large families,
students, and senior households.
Policy H3.6 Encourage housing for low- and moderate-income households to be
located in many different locations and not concentrated in any single portion of
the city.
Policy H3.7 Encourage infill development and recycling of land to provide adequate
residential sites and support the assembly of small vacant or underutilized parcels to
enhance the feasibility of infill development.
Program H3-1: Ensure Adequate Sites to Accommodate Regional Fair
Share of Housing Growth
The City has a Regional Housing Needs Assessment (RHNA) of 760 extremely low/very low-
income, 368 low-income, 382 moderate-income, and 1,141 above moderate-income units for
the 2021-2029 RHNA planning period (2,651 units total). A portion of this target will be achieved
with credits for approved and proposed projects. The sites inventory identifies vacant and
underutilized land in residential and mixed-use zones, as well as projections about accessory
dwelling units (ADUs), and shows that the City can adequately accommodate the City’s
remaining RHNA under existing General Plan and Development Code standards.
• Maintain an inventory of available sites for residential development and provide it to
prospective residential developers upon request.
• Continue to track new housing projects and progress toward meeting the City’s RHNA
and will post the sites inventory on the City’s webpage.
• Create a regulatory environment that enables the private market to build a variety of
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housing types and income levels.
Timeframe/Objective: Ongoing; annually review progress as part of the Annual Progress
Report process (see also Program H5-7).
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H3-2: Mixed-Use and TOD Sites Lot Consolidation
• Continue to facilitate the construction of residences in mixed-use zones and within the
TOD Specific Plan area. Continue to provide zoning and development standards to
facilitate residential and mixed-use development within the TOD Specific Plan Area,
including incentives for the inclusion of units affordable to extremely low-, very low-,
low-, and moderate-income households, such as the State density bonus. The City is
also considering a new inclusionary Housing Ordinance (Program H2-4: Inclusionary
Housing Ordinance) and allows SROs (Program H4-2: Housing for Extremely Low-Income
Households) to facilitate construction of housing affordable to extremely low-income
households.
• Continue to streamline the process for development in the TOD Specific Plan area.
Move affordable housing projects to the front of the line during processing, and give
affordable housing projects priority for meeting agendizing and staff resources.
• Provide impact and processing fee deferrals to projects with affordable housing.
• Continue to monitor development interest, inquiries and, progress towards mixed-use
development. Periodically re-evaluate approach and progress.
• Continue to provide incentives for consolidation of parcels in mixed-use areas, including
rounding up when calculating allowable units. Provide impact and processing fee
deferrals to projects that consolidate multiple lots. Provide technical assistance with
consolidation of parcels. Technical assistance includes land development counseling by
Economic and Community Development staff.
• Advertise lot consolidation incentives and potential site opportunities to existing
property owners and prospective mixed-use and affordable housing developers.
Advertisement actions may include preparation and distribution of a brochure with
information about program incentives and an invitation to attend a working session
to discuss opportunities for lot consolidation and mixed-use residential development,
including affordable housing development.
• Monitor and review development trends every two years. If more nonresidential
development is being proposed or built on mixed-use sites than residential development
(over 50 percent), then within six months the City will adopt additional performance
standards to ensure residential construction.
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Timeframe/Objective: Ongoing; engage in advertisement efforts at least once per year;
re-evaluate approach and progress towards mixed-use development in 2025 and biennially
thereafter and update if development trends do not support predominantly residential
development in a timely manner (i.e., within approximately six months)
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H3-3: Senior Housing
• Continue to provide appropriate standards to encourage development of senior housing
to meet the needs of the City’s growing senior population, including include densities up
to 40 units per acre and reduced parking and dwelling unit size requirements.
• Amend the Development Code to remove the Minor Use Permit requirement for senior
citizen apartments in all zones where it is currently permitted with a Minor Use Permit,
and instead allow senior citizen apartments as a permitted use.
Timeframe/Objective: Ongoing; amend the Development Code within two years of Element
adoption
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H3-4: Accessory Dwelling Units (ADUs)
• Review the Development Code to ensure consistency with State law and revise to comply
with State law, including flexible zoning requirements and development standards. In
addition, remove regulations pertaining to second units that may conflict with State
law, to provide consistency and clarity in the implementation of accessory dwelling unit
standards.
• As revisions to State law occur, update the City’s ADU Ordinance to comply.
• Create a public outreach program to encourage ADU development, including
development of an information packet to market ADU construction and brochures to
clearly outline the process. Inform ADU applicants of the California Housing Finance
Agency’s (Cal HFA) ADU Grant Program. Cal HFA’s ADU Grant Program provides up to
$40,000 to reimburse pre-development and non-reoccurring closing costs associated
with the construction of the ADU. Opportunities could include advertising ADU
development opportunities on the City’s website, through social media, at City Hall, and
at City events.
• Continue to coordinate with Code Enforcement on cases of unpermitted ADUs and
provide information to the applicant/homeowner to encourage conversion of existing
unpermitted ADUs into permitted ADUs without fines/penalties.
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
• Identify and retain an ADU specialist within the Planning Department to respond to
inquiries and support outreach efforts.
• Prioritize and streamline ADU review processes for approval. Prepare and provide
updated ADU application materials and update the building permit application to
request rent information to track affordability.
• Coordinate with neighboring jurisdictions and the local council of governments to
participate in educational opportunities and ADU incentives for the Azusa community,
such as workshops on ADUs, pre-approved ADU construction stock plans that are
customizable at a minimal cost to the applicant, etc.
• Annually monitor ADU permit applications and approvals (including the affordability of
constructed ADUs) through the Housing Element Annual Progress Report process.
Timeframe/Objective: Support the development of 242 accessory dwelling units during the
planning period through the following efforts: Review/revise Development Code within one
year of Element adoption and submit revised ADU Ordinance to HCD for review; ongoing
ADU development support with outreach materials provided in 2024; identify and retain ADU
specialist in 2023; prepare updated application materials in 2023; participate in the SGVCOG
pre-approved ADU plan work effort in 2022/2023 and publish ADU stock plans on the City’s
website in 2023; annually monitor ADU construction and affordability; in 2025, evaluate progress
compared to projections—If targets are not being achieved, implement new strategies in
a timely manner (i.e., within approximately six months) to encourage ADU development to
ensure adequate sites are available to address the lower income RHNA or commit to rezoning
additional sites within one year (as necessary) to offset any shortfall. Take additional actions, if
necessary, in a timely manner (i.e., within 6 months).
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget, State grants
Program H3-5: Alternative Housing Models
• Encourage the provision of innovative housing types that may be suitable for the
community, including modular homes, middle housing types, community care facilities,
supportive housing, and assisted living for seniors.
• Promote alternative housing models during discussions with developers.
• Review the Building Code (Municipal Code Chapter 14) and Development Code (Section
88.42.128) and modify as necessary to ensure that manufactured housing is subject to the
same standards applicable to conventional single-family dwellings.
Timeframe/Objective: Review and modify Building Code within two years of Housing Element
adoption; on an ongoing basis discuss alternative options for housing with developers and
project applicants.
Responsible Agency: Economic and Community Development Department
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
Funding Sources: Departmental Budget
Program H3-6: Address Homelessness
• Continue to support local organizations that provide emergency resources and provide
opportunities for service expansion, such as co-location at public facilities such as the
Azusa Library.
• Continue to participate in regional efforts to address homelessness, and support
additional bridge housing, access centers, and other homeless services offered in the
region.
• Continue to allow emergency shelters as a permitted use (by right) in the West End
Industrial District, subject to those conditions and standards consistent with State law.
Subject emergency shelters to the same development standards as other similar uses
within the West End Industrial District, except for those provisions permitted by State
Law and included in the Development Code for emergency shelters.
• Support ongoing efforts to address homelessness through the provision of emergency
shelter, transitional housing, and supportive housing and seek innovative solutions to
address homelessness.
• Implement the Goals and Supporting Actions identified in the Azusa Plan to Combat
Homelessness.
Timeframe/Objective: Ongoing; assess success of efforts to address homelessness in 2025 and
update strategies by January 2026; see also Program H4-2.
Responsible Agency: Administration and Economic and Community Development
Department
Funding Sources: Departmental Budgets
Program H3-7: No Net Loss
Government Code §65863 states that no jurisdiction shall “reduce, or require, or permit the
reduction of, the residential density for any parcel to, or allow development of any parcel at, a
lower residential density, or allow development at a lower residential density than projected”
for sites identified in the Housing Element sites inventory unless the jurisdiction makes written
findings that the reduction is consistent with the General Plan, and that the remaining sites
identified in the Housing Element are adequate to accommodate the jurisdiction’s need.
• Evaluate residential development proposals for consistency with goals and policies of
the General Plan and the 2021-2029 Housing Element sites inventory and make written
findings that any density reduction is consistent with the General Plan and that the
remaining sites identified in the Housing Element are adequate to accommodate the
RHNA by income level.
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
• If a proposed reduction of residential density will result in the residential sites inventory
failing to accommodate the RHNA by income level, identify and make available additional
adequate sites to accommodate its share of housing need by income level within 180
days of approving the reduced density project.
Timeframe/Objective: Ongoing; when necessary, identify and make available additional
adequate sites to accommodate the RHNA by income level within 180 days of approving a
reduced density project.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H3-8: Replacement of Units on Sites
Pursuant to Government Code Section 65583.2(g)(3), require the replacement of units affordable
to the same or lower income level as a condition of any development on a nonvacant site
identified in the Housing Element consistent with those requirements set forth in Government
Code section 65915(c)(3). Replacement requirements shall be required for sites identified in the
inventory that currently have residential uses, or within the past five years have had residential
uses that have been vacated or demolished, and:
• Were subject to a recorded covenant, ordinance, or law that restricts rents to levels
affordable to persons and families of low or very low-income; or
• Subject to any other form of rent or price control through a public entity’s valid exercise
of its police power; or
• Occupied by low or very low-income households
For the purpose of this program “previous five years” is based on the date the application for
development was submitted.
Pursuant to Government Code section 66300(d) (Chapter 654, Statutes of 2019 (SB 330)), the City
shall not approve a housing development project that will require the demolition of residential
dwelling units regardless of whether the parcel was listed in the inventory unless a) the project
will create at least as many residential dwelling units as will be demolished, and b) certain
affordability criteria are met.
Timeframe/Objective: Routinely as part of the housing development approval process, require
replacement of any of units if (a) they are planned to be demolished for purposes of building
new housing, and (b) they are determined to be occupied by low-income households, require
the provision of assistance to prevent displacement of lower-income households due to loss of
affordable units.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
Program H3-9: Development on Religious Institution Sites
SB 899 and AB 1851 (2020 legislative session) allows religious institutions to build 100 percent
affordable housing projects on their properties through a ministerial process and allows for
removal of existing parking areas. AB 2244 (2022 legislative session) expands the law to allow
development of housing on both existing and new places of worship. Azusa is home to a
multitude of properties owned by churches, temples, and other religious institutions, with
capacity for additional development.
• The City will create standards and a review process for the establishment of affordable
housing via a Religious Institution Housing Ordinance or other zoning approach,
including a streamlining of the approval process (allowing housing with at least 20% of
units affordable ministerially).
• The City will proactively reach out to property owners to gauge development interest,
provide educational materials regarding SB 899, AB 1851, and AB 2244.
• The City will proactively reach out to affordable housing developers with experience
developing housing on religious institution sites, including Habitat for Humanity and
National Core, to discuss options for development in Azusa, and connect religious
institution leadership with developers.
Timeframe/Objective: Create new standards and a review process within 3 years of the
Housing Element planning period; conduct proactive outreach to property owners and
affordable housing developers in 2025.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H3-10: Development on Nonvacant Sites
Promote residential development on nonvacant sites by:
• Targeting nonvacant sites identified in the Housing Element as priorities for fund
allocation as funds are available.
• Expanding the opportunities for adaptive reuse of nonresidential existing buildings for
housing through the expansion of by-right processes, reduced parking standards, flexible
building standards, and increased flexibility on the types of uses (e.g. live/work) and
locations that can be converted to support proposed developments.
• Proactively outreaching to property owners with a survey on how the city can support
redevelopment efforts.
• As part of the City’s comprehensive General Plan update, the City will pursue
implementation of a variety of tools to encourage housing development on nonvacant
sites, including marketing housing as an economic development tool and the potential
of implementing Enhanced Infrastructure Financing Districts as a method for funding
affordable housing. Newer state legislative mechanisms (AB 733 and SB 1145) that have
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materialized in the wake of redevelopment agency dissolution allow agencies to utilize
growth in tax revenue, or tax increment, to finance certain projects, including at least
20% for affordable housing, within a limited geographic area.
Timeframe/Objective: Ongoing; conduct a study on potential adaptive reuse incentives in 2024
and hold hearings with Planning Commission/City Council regarding adaptive reuse standards
in 2025; initiate General Plan update in 2023 and conduct a study on EIFDs and other housing
related economic development tools in 2024; implement recommendations from study in 2025.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
D� REMOVE CONSTRAINTS TO HOUSING DEVELOPMENT
Market and governmental factors pose constraints to the provision of adequate and affordable
housing. These factors tend to disproportionately impact low- and moderate-income
households due to their limited resources for absorbing the costs. Azusa is committed to
removing governmental constraints that might hinder the production of housing.
Goal H4: Minimize the impact of governmental constraints on housing production and
affordability.
Policy H4.1 Review and adjust residential development standards, regulations,
ordinances, departmental processing procedures, and residential fees related to
rehabilitation and construction that are determined to constrain housing development.
Policy H4.2 Provide regulatory incentives, such as density bonuses and reduced
parking, to offset the costs of developing affordable housing.
Policy H4.4 Maintain the City’s coordinated, interdepartmental Development
Review process for larger-scale projects in the City.
Policy H4.5 Monitor State and federal housing-related legislation, and update City
plans, ordinances, and processes as appropriate to remove or reduce governmental
constraints.
Policy H4.6 Facilitate coordination between lending institutions, the real estate and
development community, and the City to better understand and address non-
governmental constraints and facilitate production of affordable housing.
Program H4-1: Density Bonuses
• Update the City’s density bonus ordinance to comply with Government Code §65915.
• Monitor State legislation and as changes are made to Government Code §65915, update
the City’s density bonus accordingly to be consistent.
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• Continue to promote the use of density bonuses to provide affordable housing and
discuss with developers their interests in and constraints to using a density bonus.
Timeframe/Objective: Adopt a density bonus ordinance within one year of Housing Element
adoption; monitor State legislation on an ongoing basis and update within one year of
applicable revisions to state law; develop an informational brochure in 2024 and on an ongoing
basis advise developers of density bonus provisions.
Responsible Agency: Economic and Community Development Department – Planning
Division
Funding Sources: Departmental Budget
Program H4-2: Housing for Extremely Low-Income Households
• Continue to allow the establishment of transitional and supportive housing development
and single-room occupancy developments (SROs), where allowed and consistent with
Development Code provisions, to support housing opportunities for extremely low-
income households.
• Consistent with State law, transitional housing shall be considered a residential use of
property, and shall be subject only to those restrictions that apply to other residential
dwellings of the same type in the same zone. Identify and draft any necessary revisions to
the Development Code to make this intent clear, including new definitions and additions
to allowed uses tables.
• Update the Development Code to comply with AB 2162 (Supportive Housing
Streamlining Act), effective January 1, 2019, which requires supportive housing to be
considered a use by right (ministerially permitted) in zones where multi-family and mixed
use are permitted, including nonresidential zones permitting multi-family uses, if the
proposed housing development meets specified criteria. Add a definition of supportive
housing in the Development Code. Comply with AB 2162 requirements to allow for
modifications for required parking for units occupied supportive housing residents that
are located within one-half mile of a public transit stop.
• Review the Development Code and make any necessary changes to ensure compliance
with AB 101 (Low-Barrier Navigation Centers). Law AB 101 requires that Low-Barrier
Navigation Centers be allowed by right in areas zoned for mixed-use and nonresidential
zones permitting (by right or conditionally) multi-family uses.
• Prioritize funding toward extremely low-income housing projects, as available. Prioritize
project streamlining for housing that serves extremely low-income households.
• Continue to pursue and identify new funding sources to support rental assistance
programs for extremely low-income households, including emergency rental assistance,
to the extent feasible.
• Contact affordable housing developers to discuss options and potential sites in Azusa for
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
development of housing affordable to extremely low-income households or conversion
of existing spaces, such as hotels, into housing options for extremely low-income
households.
Timeframe/Objective: Adopt Development Code amendments within one year of Housing
Element adoption; implement the Development Code on an ongoing basis; Contact/discuss
development options with affordable housing developers within two years of Housing Element
adoption; develop a priority staff-level planning entitlement process to streamline and expedite
housing for extremely low-income households within two years of Housing Element adoption (in
conjunction with Program H4-8).
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H4-3: Development Process Streamlining
• Provide timely review of discretionary and non-discretionary residential development
requests, with fees sufficiently only to cover the actual costs (direct and overhead)
incurred by the City. Periodically evaluate land development processing procedures to
ensure that project review is accomplished in the minimum time necessary to implement
the General Plan and ensure protection of public health, safety, and welfare.
• Update the Development Code (Affordable Housing Incentives Section) to refer to
streamlining options available through the California Government Code.
• To accommodate future SB 35 applications and inquiries, the City will create and make
available an informational packet that explains SB 35 streamlining provisions in Azusa and
provides SB 35 eligibility information.
• Streamline the development review process for affordable housing. Allow projects that
include at least 20% affordable housing that complies with objective standards to be
reviewed ministerially.
Timeframe/Objective: Ongoing; create SB 35 informational packet within one year of Housing
Element adoption; revise process to streamline affordable housing development in conjunction
with Program H4-8 (Objective Design Standards) within two years of Housing Element adoption.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H4-4: Stacked Flats and Other Multi-Family Housing
• Review and update the Development Code to allow stacked flats as a permitted use in all
neighborhoods, corridors, and districts where currently townhomes are currently allowed,
within both mixed-use arrangements and as stand-alone residential housing. Remove the
requirement for a Minor Use Permit. Assess new multi-family developments through the
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
Design Review process.
• Continue to promote and provide incentives for the development of stacked flats in the
Azusa TOD Specific Planning Area.
• Promote and provide incentives, as appropriate, for the development of stacked flats in
the Moderate Density Neighborhoods, Neighborhood Centers, and Mixed-Use Districts.
• Review and update the Development Code to remove the MUP requirement for triplexes
and fourplexes, townhouses and rowhouses in the higher density Neighborhood
Districts. Assess new multi-family developments through the Design Review process.
Timeframe/Objective: Adopt Development Code amendments within three years of Housing
Element adoption; promote development types and incentives such as density bonuses on an
ongoing basis with information at public counters and on the City’s website -- create materials
within one year of Development Code amendments.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H4-5: Minimum Unit Sizes
Amend the Development Code to reduce the minimum unit sizes in Neighborhoods, Centers,
and Districts to match the minimum unit sizes allowed in the TOD Specific Plan.
Timeframe/Objective: Adopt Development Code amendments within three years of Housing
Element adoption
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H4-6: Parking for Multi-family Uses
• Amend the Development Code to remove the requirement for garages for multi-family
dwellings. Instead, allow parking in the form of parking structures, subterranean, and
carports. Include in the Development Code standards for parking design.
• Continue to allow waivers of covered parking requirements for affordable housing units,
consistent with existing Development Code Section 88.36.080.
Timeframe/Objective: Adopt Development Code amendments within three years of Housing
Element adoption
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H4-7: Objective Design Standards
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
• Amend the Development Code to add reference to the Housing Accountability Act
Requirements, indicating that multi-family housing (and mixed-use buildings containing
at least two-thirds residential) cannot be denied or density reduced.
• Review the existing Form-Based Code and draft revisions to support objective design
standards. Adopt objective design standards to ensure that the City can provide local
guidance on design and standards for by-right projects as allowed by State law. Adoption
of objective design standards will facilitate high-quality residential development and
compliance with State objectives. The objective design standards will ensure provision
of adequate private open space, parking, and related features, as well as architectural
design.
• Allow multi-family residential development that conforms with objective design and
development standards as an allowed use without a public hearing.
Timeframe/Objective: Adopt Objective Design Standards and Housing Accountability Act
language within two years of Housing Element adoption
Responsible Agency: Economic and Community Development Department
Funding Sources: State LEAP Grant
Program H4-8: Nongovernmental Constraints
Although the City has limited influence over non-governmental constraints, if non-governmental
constraints are identified, the City will review, and if necessary, revise, any development
regulations or processes that can potentially lessen those constraints.
Timeframe/Objective: As needed as constraints are identified. See also Program H5-7.
Responsible Party: Economic and Community Development Department
Funding Source: Departmental Budget
Program H4-9: Water and Sewer Service Providers
Immediately following adoption, deliver the 2021-2029 Azusa Housing Element to all providers
of sewer and water service within the City of Azusa—including internal City departments—in
accordance with Government Code §65589.7.
Timeframe/Objective: Deliver the Housing Element to all sewer and water providers within one
month of adoption of the Housing Element.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H4-10: Infrastructure Master Planning
Azusa is a forward-thinking community that values inclusive planning that takes into account
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
all factors. To that end, the City will undertake comprehensive Master Planning efforts for
infrastructure systems, including sewer, stormwater, and other utilities and systems that support
development of local land use policy to ensure systems are adequate and up-to-date to support
planned development.
Timeframe/Objective: Undertake comprehensive Master Planning efforts within three years of
adoption of the Housing Element in conjunction with Program H5-5.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget; General Fund
E� PROMOTE EQUAL HOUSING OPPORTUNITY
To fully meet the community’s housing needs, housing must be accessible to all residents,
regardless of race, religion, family status, age, or physical disability.
Goal H5: Promote and affirmatively further fair housing opportunities and promote
housing throughout the community for all.
Policy H5.1 Affirmatively further fair housing related to the sale, rental, and financing
of housing to avoid discrimination based on race, religion, age, sex, marital status,
ancestry, national origin, color, familial status, or disability, or any other arbitrary factor.
Policy H5.2 Assist in the enforcement of fair housing laws by providing support to
organizations that can receive and investigate fair housing allegations, monitor
compliance with fair housing laws, and refer possible violations to enforcing agencies.
Policy H5.3 Facilitate increased participation among traditionally underrepresented
groups in the public decision-making process.
Policy H5.4 Promote greater awareness of fair housing practices and requirements,
tenant and landlord rights and obligations through outreach and education for
the broader community of residents, residential property owners and operators.
Policy H5.5 Encourage housing construction or alteration to meet the needs of
residents with special needs, such as the elderly and disabled.
Program H5-1: Special Needs Housing
• Provide opportunities to meet the housing needs of special needs residents—including
seniors, residents with disabilities and developmental disabilities, large families,
extremely low-income households, and those experiencing homelessness—by giving
priority to development projects that include a component for special needs groups in
addition to other lower-income households.
• Review Development Code standards and procedures associated with the approval
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
of residential care facilities; revise as appropriate to streamline and provide consistent
application of standards and ensure that these uses are treated objectively and do not
discriminate against persons with disabilities.
• Encourage developers of single-family dwellings to incorporate universal design and/or
”visitability” improvements.
Timeframe/Objective: Develop priority streamlining process in 2024; update Development
Code within one year of Housing Element adoption; develop materials to encourage universal
design and visitability and provide at public counters; pursue pre-approved stock plans for
ADUs that include an ADA-accessible option.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H5-2: Fair Housing Services
• Continue to assist households through the Housing Rights Center, providing fair housing
services and educational programs concerning fair housing issues. Refer fair housing
complaints to the Housing Rights Center.
• Continue to promote fair housing practices, including advertisement on the City’s
website, and provide educational information on fair housing to the public.
• Continue to comply with all State and federal fair housing requirements when
implementing housing programs or delivering housing-related services.
• Promote public awareness of federal, State, and local regulations regarding equal access
to housing. Provide information to the public on various state and federal housing
programs and fair housing law. Maintain referral information on the City’s website and
at a variety of other locations such as community and senior centers, local social service
offices, in City utility bills, and at other public locations including City Hall and the library.
Add resources and information in Spanish and make available to the public.
• Include a fair housing presentation in City Council meetings.
• Ensure that all development applications are considered, reviewed, and approved
without prejudice to the proposed residents, contingent on the development
application’s compliance with all entitlement requirements.
Timeframe/Objective: Ongoing; promotion efforts conducted four times per year as part
of fair housing workshops by the Housing Rights Center and other housing related events;
fair housing presentation made to the City Council at least once per year; evaluate approval
procedures with a fair housing lens every other year.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
Program H5-3: Affirmatively Furthering Fair Housing
Identified Fair
Housing Issue and
Priority
(High, Medium, Low)
Contributing Factors Meaningful Actions
1. Displacement
risk due to regional
economic pressure
(Priority: Medium)
2. Disproportionate
housing needs in
areas with lower
incomes, higher
proportions of
renters, and disabled
residents (Priority:
High)
• Inadequate supply/
production of
affordable/special
needs housing
• Displacement of
residents due to
regional economic
pressures
• High land and
development costs
in the region
• Land use and zoning
laws
• Public opposition to
new development
and land use and
zoning laws
• Potentially large
population of
students
• Limited access
to opportunity
(education,
transportation,
economic)
Two identified fair housing issues are closely related, as such, the meaningful
action items address both issues.
Housing Choice and Affordability:
• Study and, if shown to be appropriate for Azusa, adopt an
inclusionary housing ordinance and program to increase the
City’s stock of affordable housing (see Program H2-4: Inclusionary
Housing).
• Provide opportunities for a variety of housing types in various
locations throughout Azusa, including High Opportunity Areas (see
Program H3-4: Accessory Dwelling Units; Program H3-9: Housing
on Religious Institution Sites; Program H4-2: Housing for Extremely
Low-Income Households; Program H5-1: Special Needs Housing).
• Allow projects that include at least 20% affordable housing that
complies with objective standards to be reviewed ministerially (see
Program H4-3: Development Process Streamlining).
• Remove constraints to development to increase housing production
(see Programs H4-4: Stacked Flats, H4-5:Minimum Unit Sizes, and
H4-6: Parking for Multi-Family Uses).
• Allow multi-family residential development that conforms with
objective design and development standards as an allowed use
without a public hearing (see Program H4-7: Objective Design
Standards).
• Monitor and adapt policy throughout the planning period to
achieve goals (see Program H5-7: Annual Review, Monitoring, and
Mid-Cycle Report).
Address Displacement Risk:
• Address potential displacement by requiring the replacement of
units affordable to the same or lower income level as a condition of
any housing development on a nonvacant site (see Program H3-8:
Replacement of Units On Sites).
• Research and implement anti-displacement tools that could
include: draft and adopt a just cause eviction ordinance; identify
resources for emergency rent assistance for residents who are
behind on their rent or utility payments; support local efforts for
community land trust development. Timeframe: 2024.
• Preserve 178 units of affordable housing through the planning
period (see Program H1-4: Monitor And Preserve Affordable
Housing And At-Risk Housing).
• Monitor and inspect rental units to ensure adequate housing
conditions (see Program H1-2).
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
Program H5-3: Affirmatively Furthering Fair Housing
Identified Fair
Housing Issue and
Priority
(High, Medium, Low)
Contributing Factors Meaningful Actions
Housing Mobility Enhancement:
• Support additional Housing Choice Vouchers in the community
and encourage rental property owners to rent to Housing
Choice Voucher holders (see Program H2-3: Section 8 Housing
Choice Voucher Program).
• Continue to inform rental property owners of reasonable
accommodation procedures and disability access laws by
providing /mailing property owners with informational materials.
Timeframe: In 2024, add information on fair housing with a utility
bill mailing to all customers.
Address Disproportionate Needs:
• Conduct public meetings at suitable times, accessible to
persons with disabilities, and near public transit. Resources
will be invested to provide interpretation. Timeframe: In
2023, adjust meeting times and translation services based on
attendance and public feedback, and review annually to adjust
times and need for translation services.
• Coordinate with local universities and community colleges to
assess student housing needs and participate in any campus
planning efforts. Timeframe: Perform proactive outreach to
local universities and community colleges every two years.
• Continue to use the Rental Inspection Program as a tool to
monitor and address fair housing issues. Timeframe: Evaluate
trends in fair housing issues identified through the Rental
Inspection Program’s annual inspections of 1,000 rental units
as part of the Annual Progress Report process and develop
strategies to address issues in a timely manner (i.e., within the
following year of the APR).
• Implement an accessibility policy that establishes standards
and procedures for providing equal access to City services
and programs to all residents, including persons with limited
proficiency in English, and persons with disabilities. Timeframe:
By 2023.
• Continue to implement the Analysis of Impediments to Fair
Housing Choice (AI) and HUD Consolidated Plan. Timeframe:
Prepare Consolidated Annual Performance Evaluation Reports
and Annual Plans each year and update the AI in 2025.
• Actively recruit residents from the lowest opportunity areas
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
Program H5-3: Affirmatively Furthering Fair Housing
Identified Fair
Housing Issue and
Priority
(High, Medium, Low)
Contributing Factors Meaningful Actions
to serve or participate on boards, committees, and
other local government bodies as positions are made
available due to the regular appointment process
or vacancies. Timeframe: Advertise positions as
soon as they become available through all of the
City’s communication channels and with community
organization partners.
Place-Based Strategies for Community Preservation and
Revitalization:
• Support neighborhood improvements in low-income
neighborhoods (see Program H1-3: Neighborhood
Improvement Zone Program).
• Initiate a General Plan update and engage the
community around achieving better economic
outcomes for residents, including supporting school
advancement and high-paying jobs in the community.
Timeframe: Initiate General Plan update in 2023.
• Establish a priority list of investment projects in high
need areas (based on factors such as environmental
justice communities designation, proportion of low/
moderate income households, and opportunity index
scores) as part of the General Plan update process.
Use an equity lens to develop and carry out an
implementation program for the General Plan, linked
to the Capital Improvement Plan, to prioritize funding
these projects during the planning period and for the
long term. Timeframe: To be developed as part of the
General Plan update, anticipated to complete in 2025.
• Prioritize place-based revitalization of neighborhoods
identified as environmental justice/disadvantaged
communities as part of the General Plan update
anticipated to start in 2023. Ensure economic
development plans reflect the needs of lower-
opportunity neighborhoods. Place-based strategies
may include, for example, plans to construct parks,
open space, and tree plantings in these areas to
improve environmental health and ensure access to
parks or open space within one half mile of all housing;
development of active transportation facilities and
focus on pedestrian safety measures including high
visibility crosswalks and accessibility improvements
to sidewalks and curbs; and evaluatation/
implementation of transitional buffers or screening
between residential and heavy industrial uses in new
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
Program H5-3: Affirmatively Furthering Fair Housing
Identified Fair Housing
Issue and Priority
(High, Medium, Low)
Contributing Factors Meaningful Actions
* State law requires that prioritization of contributing factors giving highest priority to those factors that
most affect fair housing choice or access to opportunity in Azusa.
Timeframe/Objective: Varies by action item, see action items above.
Responsible Party: Economic and Community Development Department
Funding Source: Departmental Budget
3. Disparities
in educational
achievement
throughout the City.
(Low)
• Potential lack of
culturally relevant
educational
opportunities
outside of
the school
environment
• Potential lack of
culturally relevant
parent/student
support
• Partner with Azusa Pacific University and local community
colleges to advertise pathways to higher education for
Azusa youth. Timeframe: By 2025
• Through the Azusa Recreation and Family Services
Department, offer culturally sensitive educational
programming at local libraries and community and
recreation centers. Programs could include classes in
critical reading, computer science, math, robotics, etc.
Timeframe: As part of the Department’s regular process
for developing recreational programming.
• Conduct targeted and culturally sensitive outreach
promoting program offerings. Timeframe: Seasonally
Program H5-4: Outreach Plan
Achieving consensus on housing policy and proposed housing developments can be a difficult
process. Through active and continued dialogue with neighborhood groups, the likelihood
of achieving neighborhood consensus for new developments is increased significantly. Azusa
supports efforts to help residents be informed about housing facts, which helps provide
sound direction on housing solutions. Efforts will include exploring avenues to help residents
understand development tradeoffs, the benefits of affordable housing, and measures necessary
to implement Azusa’s vision for a thriving Downtown and safe and stable neighborhoods.
Objective:
• Implement an outreach plan to establish outreach protocol for housing-related issues,
such as Housing Element updates. Reach out to the community regarding housing topics
development. Timeframe: Construct parks/open space,
active transportation facilities, and buffers for industrial
uses during the planning period starting in 2024, with at
least one funding application annually and one priority
project such as park improvements, bike lane expansions,
sidewalk, and/or crosswalk improvements to occur each
year.
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HOUSING PLAN | AZUSA HOUSING ELEMENT 2021-2029
in general, as well as with regard to specific new developments.
• Expand outreach to non-profit developers, area service providers, and community-
based organizations. As part of the upcoming comprehensive General Plan update,
partner with local community-based organizations to hold community meetings to
gain input from Azusa residents about housing needs, issues, and ideas to support the
development of more affordable housing in the city. Invest resources to provide food,
childcare, interpretation, and translation services at these events.
• Actively recruit residents from underserved neighborhoods to participate on
committees to address homelessness and affordable housing needs.
• Develop presentations and/or materials that address the local need for affordable
housing and more resilient neighborhoods.
Timeframe/Objective: Implement outreach plan within one year of Housing Element
adoption; implement on an ongoing basis and in conjunction with Program H5-5.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H5-5: General Plan Update
As part of a comprehensive update to the General Plan, update the Safety Element and adopt
a new Environmental Justice Element to comply with State law. Pursue implementation of
anti-displacement strategies and community benefit zoning and/or other land value recapture
strategies as part of the General Plan update.
Timeframe/Objective: Adopt a comprehensive General Plan update within three years of
Housing Element adoption
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Program H5-6: Reasonable Accommodation
The City has established reasonable accommodation procedures in place. In order to ensure
consistent application and clarity, the City will re-evaluate these procedures and modify to
enhance equal housing opportunity.
Timeframe/Objective: Identify and adopt revisions to reasonable accommodation procedures
to ensure consistent application and clarity within one year of Housing Element adoption.
Responsible Agency: Economic and Community Development Department
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING PLAN
Funding Sources: Departmental Budget
Program H5-7: Annual Review, Monitoring, and Mid-Cycle Report
The Planning Commission will hold an annual public hearing each spring to evaluate progress
toward meeting housing goals and regional housing needs obligations. The review will
examine annual quantitative housing production goals and monitor vacant and non-vacant
sites in the sites inventory, and if the City is not meeting those quantitative goals, City staff
will make recommendations to the Planning Commission on adjustments to processes or
requirements to improve performance. At the public hearing, the Planning Commission will
make recommendations for City Council consideration and action.
The annual review will include a review of the Annual Progress Report on Housing Element
implementation in the format required by HCD as defined by Government Code Section
65400(a)(2)(B). In addition, the City will conduct a mid-term evaluation at year 4 of the 8-year
cycle. The mid-term evaluation shall document progress made towards affirmatively furthering
fair housing and progress made on non-vacant sites to achieve the regional housing need. If
the evaluation finds that existing Housing Element programs are not achieving the objectives
and targets, the Planning Commission and City Council will hold public hearings to consider
and take action on any additional programs or zoning amendments necessary to acheive the
Housing Element objectives within one year.
Timeframe/Objective: Provide annual reviews and a mid-term evaluation at year 4 of the 8-year
cycle
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
SUMMARY OF QUANTIFIED OBJECTIVES
Table H-2.1 summarizes Azusa’s quantified objectives for the 2021-2029 Housing Element planning period
Table H-2.1 Summary of 2021-2029 Housing Element Quantified ObjectivesIncome Level
Extremely
Low Very Low Low Moderate Above
Moderate Total
Construction
Objective
(RHNA)
760 368 382 1,141 2,651
Rehabilitation
Objective 80 --80
At-Risk
Housing Units
to Preserve
178 ----178
Azusa
Pedestrian
Plan
Needs
Assessment
3
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Population and
Employment Trends
To best understand the types of housing
that are needed to meet existing and future
demand, Housing Element law requires
that the Housing Element assess local
population demographics and housing
stock characteristics. Characteristics such
as age, ethnicity, and employment influence
the type and cost of housing needed or
in high demand. Tracking changes in the
demographics can also help City leaders
better respond to or anticipate changing
housing demand. This section evaluates the
various population characteristics that affect
Azusa’s housing needs.
CURRENT POPULATION AND
POPULATION GROWTH
Since incorporation in 1898, Azusa has
had steady population growth. The City
experienced its most substantial increase in
population, 41 percent, between 1980 and
1990. During this time, the population jumped
from 29,380 to 41,333. In 2000, the Census
Bureau indicated that the City had reached a
population of 44,371. Between 2010 and 2020,
as reported by the Census, the population
of Azusa grew approximately six percent,
from 46,631 to 49,658 residents. This growth
rate was slightly greater in Azusa than in Los
Angeles County as a whole (four percent).
The Southern California Association of
Governments (SCAG) growth forecasts predict
a steady increase in population through 2045.
From 2020 to 2045, SCAG estimates that the
Azusa population will grow by 11.6 percent,
while countywide population is expected to
increase by 14.8 percent.
In addition to population projections, several
other demographic characteristics and
trends define housing needs. Among these
characteristics are age composition, racial and
ethnic composition, and employment.
AGE
Population age distribution serves as an
important indicator of housing needs, because
housing needs and preferences change as
individuals or households grow older. Young
families tend to focus more on cost and the
Needs Assessment
Table H-3.1: Population Growth and Projected Growth
% Change$% Change
2010 2020 2045 2010-2020 2020-2045
Azusa 46,361 49,658 56,200 6.6%11.6%
Los Angeles
County 9,758,256 10,172,951 11,677,000 4.1%14.8%
Source: CA DOF E-5 Population and Housing Estimates, SCAG Growth Forecasts
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
ability to become first-time homebuyers.
Table H-3.2 shows the age distribution of
Azusa residents. In 2018, the 25-44 year old
age group constituted the largest age group
at approximately 27 percent, followed by
the 15-24 years old age group at nearly a
quarter of the population. Of note, certain
segments of the population are increasing
while others decrease. For example, the city’s
share of seniors (65 years old and above) and
15-24 year olds increased by two and seven
percentage points, respectively, while the
0-14 age group decreased by six percentage
points.
When compared with the Southern California
region at large, Azusa generally parallels the
region, with a similar share of its population
that is younger than 18 (22 percent compared
to 23.4 percent in the region). Azusa’s seniors
make up nearly 10 percent of the population,
which is lower than the regional share of 13
percent. This younger demographic is also
reflected in the median age; Azusa’s median
age is 29.3 years, compared with the County
(36.2 years) and the state (36.3 years). The
large population of children and young adults
means that demand will likely continue to
grow for larger family-sized units.
RACE AND ETHNICITY
Table H-3.3 shows the racial/ethnic
distribution of population in the City of Azusa.
Hispanic (64 percent) and White (19 percent)
residents make up the majority of the Azusa
population, followed by Asian (14 percent),
and Black (3 percent). When compared with
Los Angeles County at large, Azusa has
fewer Black residents (3 percent compared
to 8 percent) and White residents (19
percent compared to 26 percent), and more
Hispanic residents (68 percent compared
to 48 percent). Since 2010, the portion of
the population that is Asian in Azusa has
increased by five percentage points, while
the Hispanic population has decreased by
four percentage points. The Black and White
proportions of the population in Azusa have
remained the same since 2010.
Table H-3.2: Age
Demographic Profile 2010 Percentage 2018 Percentage
Age
0-14 12,407 27%9,267 19%
15-24 7,724 17%11,691 24%
25-44 13,185 28%13,280 27%
45-64 9,469 20%10,503 21%
65+3,576 8%4,803 10%
Median Age 28.1 --29.3 --
Sources: US Census Bureau 2010 Census, American Community Survey 2014-2018 5-year estimates
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Table H-3.3: Race and Ethnicity
Demographic Profile 2010 Percentage 2018 Percentage
Race and Ethnicity
White (non-Hispanic)8,808 19%9,488 19%
Hispanic 31,328 68%31,379 64%
Black 1,499 3%1,601 3%
Asian/Pacific Islander 4,141 9%6,223 14%
Other 562 2%141 0%
Sources: US Census Bureau 2010 Census, American Community Survey 2014-2018 5-year estimates
EMPLOYMENT
Azusa has 23,899 workers living within its borders who work across 13 major industrial sectors.
Table H-3.4 provides detailed employment information. Many Azusa residents work in
educational services (27 percent); retail trade; manufacturing; professional and administrative
services; and arts, entertainment, and recreation industries (11 percent each). Between 2010
and 2018, there was an increase in educational services; at the same time, construction and
manufacturing employment decreased.
Table H-3.4: Employment by Industry
Demographic Profile 2010 Percentage 2018 Percentage
Employment by Industry
Educational services, and
health care and social
assistance
5,185 23%6,105 26%
Retail trade 2,064 9%2,522 11%
Manufacturing 3,122 14%2,622 11%
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
Table H-3.4: Employment by Industry
Demographic Profile 2010 Percentage 2018 Percentage
Professional, scientific,
and management, and
administrative and waste
management services
2,359 11%2,558 11%
Construction 1,599 7%1,131 5%
Arts, entertainment,
and recreation, and
accommodation and food
services
2,206 10%2,704 11%
Finance and insurance, and
real estate and rental and
leasing
1,271 6%1,066 4%
Other services, except public
administration 1,242 6%1,245 5%
Transportation and
warehousing, and utilities 908 4%1,369 6%
Public Administration 686 3%762 3%
Wholesale Trade 951 4%1,023 4%
Information 396 2%594 2%
Agriculture, forestry, fishing
and hunting, and mining 333 1%198 1%
Sources: US Census Bureau 2010 Census, American Community Survey 2014-2018 5-year estimates
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Table H-3.5 indicates the 10 largest employers in Azusa, with significant representation from the
educational sector, including Azusa Pacific University and Azusa Unified School District.
Table H-3.5: 10 Principal Employers, 2019
Employer Number of Employees Percentage
Azusa Pacific University 2,297 9.19%
Azusa Unified School District 1,586 6.34%
Northrop Grumman 921 3.68%
City of Azusa 370 1.48%
Costco Wholesale Corporation 319 1.28%
Hanson Distribution Company 292 1.17%
S&S Foods LLC 275 1.10%
Buena Vista Food Products 206 0.82%
OJ Insulation 176 0.70%
Alliance Environmental Group 164 0.66%
Source: City of Azusa Comprehensive Annual Financial Report, June 30, 2019
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
Household
Characteristics
The characteristics of a community’s
households impact the type of housing
needed in that community. Household type,
income levels, the presence of special needs
populations, and other household traits are
all factors that affect the housing needs of
a community. This section discusses the
household characteristics affecting the
housing needs of Azusa residents.
Characteristics for Azusa households are
summarized in Table H-3.6. The number of
households in Azusa has remained relatively
stable (12,641 total households) since 2010.
The percentage of owners in Azusa has also
remained relatively the same since 2010
(52.7 percent) to 2018 (52.1 percent). The
City has increased single-family and multi-
family units between 2010 and 2020 (see
Table H-3.7). However, vacancy rates are still
low for both owner and renter households
and the overcrowding rate (13 percent)
is slightly higher than the County rate (11
percent), which suggests that the City should
continue to increase housing construction to
accommodate residents.
Table H-3.6: Household Characteristics by Tenure
Household Characteristic Owner Households Renter Households All Households
Number of Households* 6,619 (52.1%)6,078 (47.9%)12,697
Median Household Income*$82,312 $43,821 $60,227
Household Income
Categories**
Extremely Low Income (0-30%
AMI)485 (7.3%)1,540 (26.2%)2,025 (16.2%)
Very Low Income (30-50%
AMI)895 (13.5%)1,410 (24.0%)2,305 (18.4%)
Low Income (50-80% AMI)1,250 (18.9%)1,325 (22.5%)2,575 (20.6%)
Moderate Income (80-100%
AMI)885 (13.4%)475 (8.1%)1,360 (10.9%)
Above Moderate Income
(100% + AMI)3,100 (46.9%)1,130 (19.2%)4,230 (33.9%)
Total 6,615 5,880 12,495
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Table H-3.6: Household Characteristics by Tenure
Household Characteristic Owner Households Renter Households All Households
Overpayment
All Households Overpaying
for Housing 2,195 (33%)3,358 (57%)5,553 (44%)
Lower Income Households
Overpaying for Housing (0-
80% AMI)**
1,480 (56%)3,240 (76%)4,720 (68%)
Source(*): US Census Bureau, American Community Survey 2014-2018 5-year estimates
Source(**): U.S. Department of Housing and Urban Development Comprehensive Housing Affordability Strategy (CHAS)
Tables 2013-2017
INCOME
According to the 2018 American Community
Survey, the median household income for
Azusa was $60,227, which is somewhat lower
to that of the County of Los Angeles median
household income of $64,251. Median
household income differs significantly by
tenure; owner households in Azusa earn
double what renter households make.
Census data estimates that 15 percent of
residents live in poverty, as defined by federal
guidelines. This proportion is similar to that of
the County of Los Angeles where 16 percent
of residents live in poverty. Generally, various
populations living in poverty, such as different
race/ethnic, age, etc. groups, are similar to
that of the County. However, the proportion
of persons or households living in poverty is
much higher for unemployed residents (26.7
percent), and specifically unemployed women
(31.9 percent).
For housing planning and funding purposes,
the State Department of Housing and
Community Development (HCD) uses five
income categories to evaluate housing need
based on the Area Median Income (AMI) for
the County:
• Extremely Low-Income Households
earn 0-30 percent of AMI
• Very Low-Income Households earn 30-
50 percent of AMI
• Low-Income Households earn 50-80
percent of AMI
• Moderate-Income Households earn
80- 120 percent of AMI (federal data
uses 100%)
• Above Moderate-Income Households
earn over 120 percent of AMI (federal
data uses 100%+)
Comprehensive Housing Affordability
Strategy (CHAS) data provides special
Census tabulations (developed for HUD)
and calculates household income adjusted
for family size and tenure. As shown in Table
H-3.6, in Azusa, above moderate-income
households represent the largest share of
all households (34 percent), and low-income
households comprise the second largest
category (21 percent). Income also differs
by tenure; as indicated in Table H-3.6, more
renter households are in the lower income
categories (0-80 percent AMI) than owner
households.
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
HOUSING OVERPAYMENT
State and federal standards specify that
households spending more than 30 percent of
gross annual income on housing experience
a housing cost burden. Housing cost burdens
occur when housing costs increase faster
than household income. When a household
spends more than 30 percent of its income on
housing costs, it has less disposable income
for other necessities such as health care, day
care, and food. In the event of unexpected
circumstances such as loss of employment or
health problems, lower-income households
with a housing cost burden are more likely
to become homeless or double up with
other households. In Azusa, 44 percent of
households are overpaying for housing.
Lower income households have a higher rate
of overpayment (68 percent of lower income
households are overpaying), especially
lower income renter households, of which
76 percent are experiencing a housing cost
burden.
Housing Stock
Characteristics
HOUSING STOCK
In 2020, the Department of Finance estimates
there are 14,651 housing units in the city.
Compared to 2010, the city’s housing stock
has increased by 1,265 units. Azusa was
developed as a community of single-family
dwelling units and has primarily remained as
such. Most of the City’s housing stock is made
up of single-family homes (60 percent), with
36 percent multi-family, and mobile homes
and other housing filling out the remaining
4 percent. Census data indicates that 2.6
percent of owner units and 2.5 percent of
rental units are vacant.
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Table H-3.7: Housing Stock Characteristics by Tenure
Housing Characteristic Renter
Households All Households Percentage
Single Family Detached
N/A N/A
6,763
(46%)
Single Family Attached 1,985
(14%)
Multi-Family Units 5,349
(36%)
Mobile home, other units 554 (4%)
Total units 14,651
Average or median Household Size 3.45
Vacancy Rate 2.6%2.5%7.4%
Overcrowded Units 502 1,179 1,681
Units Needing Replacement/Rehabilitation N/A N/A 37 - 743
Housing Cost $495,500 $1,389 N/A
Sources: US Census Bureau, American Community Survey 2014-2018 5-year estimates, CoreLogic September 2020, and
California Department of Finance E-5 Population and Housing Estimates
OVERCROWDING
Overcrowding occurs when the relatively high
cost of housing either forces a household to
double-up with another household or live
in a smaller housing unit in order to afford
food and other basic needs. According to
both California and federal standards, a
housing unit is considered overcrowded if
it is occupied by more than one person per
room (excluding kitchens, bathrooms, and
halls). In Azusa, 13 percent of housing units
are overcrowded. Overcrowding is more
prevalent in rental households than owner
households. Azusa experiences slightly more
overcrowding than Los Angeles County at
large, where 11 percent of households are
overcrowded.
HOUSING CONDITION
The age and condition of Azusa’s housing
stock is an indicator of potential rehabilitation
needs. Commonly, housing over 30 years of
age needs some form of major rehabilitation,
such as a new roof, foundation work,
plumbing, etc. The housing stock in the city is
aging, as a majority of the housing stock was
built between the 1950s and 1980s. According
to the American Community Survey, 68
percent of Azusa’s housing stock was built
during this time period. Only 19 percent of
the city’s housing stock has been built since
the 1990s.
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
The Census includes surveys about
three factors of what may be considered
substandard housing. In Azusa, 157 units lack
telephone service, 37 units lack plumbing
facilities, and 92 units lack complete kitchen
facilities, as of 2018. The City performs
annual inspections of rental properties to
ensure proper maintenance and upkeep,
as well as presale inspections of all homes
that are sold. These efforts have allowed
Code Enforcement staff to have a deep
understanding of existing needs in the
community, and to continue to work with
property owners of apartment buildings
that are in particular need of rehabilitation,
maintenance, and repair. The City maintains
a list of 743 rental units (in 66 buildings)
that require additional oversight to ensure
buildings and properties are maintained and
comply with codes.
HOUSING COST
The cost of housing in a community can
be directly correlated to the number of
housing problems and affordability issues.
High housing costs can price low-income
families out of the market, cause extreme
cost burdens, or force households into
overcrowded or substandard conditions. The
Azusa median home price in September 2020,
based information provided by CoreLogic,
was $495,500. This was three percent higher
than the median price in 2019. The median
home price in Los Angeles County in
September 2020 was $710,000, significantly
higher than the median price in Azusa.
Nearly half (48 percent) of Azusa households
live in rental housing. Census data shows that
the average rent in Azusa is $1,468 per month,
ranging from $1,102 for a studio/efficiency up
to $2,377 for a four-bedroom unit. Table H-3.8
shows that the HUD-determined fair market
rents for Los Angeles County generally
exceed the range of the rents within Azusa.
Therefore, the rental rates in Azusa are lower
than some other areas of the county.
Special Housing Needs
Housing-element law requires local
governments to include an analysis of housing
needs for residents in specific special needs
groups and to address resources available to
address these needs. These special needs
groups often spend a disproportionate
amount of their income to secure safe and
decent housing and are sometimes subject to
discrimination based on their specific needs
or circumstances.
Table H-3.8: Fair Market Rents in Los Angeles County
Year Efficiency One-
Bedroom
Two-
Bedroom
Three-
Bedroom
Four-
Bedroom
Fair Market Rents (HUD)$1,279 $1,517 $1,956 $2,614 $2,857
Median Rents (Census)$1,102 $1,216 $1,535 $1,839 $2,377
Sources: US Census Bureau 2010 Census, American Community Survey 2014-2018 5-year estimates
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
PERSONS WITH DISABILITIES
INCLUDING PERSONS WITH
DEVELOPMENTAL DISABILITIES
Disabled residents face housing access and
safety challenges. Disabled people, in many
cases, are of limited incomes and may receive
Social Security income only. As such, most
of their monthly income is often devoted to
housing costs. In addition, disabled persons
may face difficulty finding accessible housing
(housing that is made accessible to people
with disabilities through the positioning
of appliances and fixtures, the heights of
installations and cabinets, layout of unit to
facilitate wheelchair movement, etc.) because
of the limited number of such units.
Many Azusa residents have disabilities that
prevent them from working, restrict their
mobility, or make it difficult to care for
themselves. There are 4,126 residents with a
disability in Azusa, representing 8.4 percent
of residents. The majority of residents
with a disability are 75 years or older (58
percent), followed by those 65 to 74 years
(20 percent). The most commonly occurring
disability amongst seniors 65 and older is
an ambulatory disability, experienced by
21 percent of Azusa’s seniors. In Azusa, the
proportion of the population with a disability
living in poverty (17.7 percent) is higher than
those without a disability (14.8 percent).
Many factors limit the supply of housing
available to households of persons with
disabilities. In addition to the need for
housing that is accessible or ADA-compliant,
housing affordability is a key limitation
as many persons with disabilities live on
disability incomes or fixed income. Location
of housing is also an important factor for
many persons with disabilities, as they often
rely upon public transportation to travel
to necessary services and shops. Many
developmentally disabled persons can live
and work independently within a conventional
housing environment but may require a group
living environment. Because developmental
disabilities exist before adulthood, the
first issue in supportive housing for the
Table H-3.9: Special Needs Groups
Special Needs Category Count Percent
Persons with Disabilities*4,126 persons 8.4% of residents
Persons with Developmental
Disabilities*1,757 persons 3.8% of residents
Elderly (65+ years)*
4,803 persons
941 householdss
10% of residents
7.4% of households
Large Households (5+
members)*2,572 households 20.3% of households
Farmworkers**136 persons 0.6 of labor force
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
Table H-3.9: Special Needs Groups
Special Needs Category Count Percent
Female Headed Households*2,390 households 18.8% of households
People Experiencing
Homelessness***329 persons N/A
Source(*): US Census Bureau, American Community Survey 2014-2018 5-year estimates
Source(**): California Department of Developmental Services, 2020; DDS consumer count by CA ZIP Codes 91702
Source (***): 2019 Greater Los Angeles Homeless Count Report
developmentally disabled is the transition
from the person’s living situation as a child to
an adult.
The State 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. The San Gabriel/Pomona Regional
Center serves residents in Azusa. The center
is a private, non-profit community agency
that contracts with local service providers to
offer a wide range of services to individuals
with developmental disabilities and their
families. In Azusa, 754 persons are reported
as consumers of the services provided at
the local Regional Center. This includes 333
residents that are 18 years and younger and
421 residents over 18 years old receiving
services from DDS. The majority of individuals
live in home settings, often with a parent or
family guardian.
For those living in single-family homes,
residents can benefit from accessibility
improvements such as wider doorways
and hallways, access ramps and railings,
larger bathrooms with grab bars, lowered
countertops, and other features common
to “barrier free” housing. According to the
State Department of Social Services, seven
small residential care facilities with capacity to
support 33 residents are located in Azusa. In
addition, four large residential care facilities
for the elderly accommodate 114 Azusa
disabled seniors.
Accommodating a sufficient quantity and
quality of housing for people with disabilities
of any kind is a significant challenge in
these times due to the lack of funding and
complexity of housing and service needs
involved. Azusa supports the provision of
housing for persons with disabilities and
has provisions in the Development Code to
enable group housing through the residential
care facility process. The City has in place a
reasonable accommodation procedure and,
as of 2021, was revisiting the procedure to
ensure clarity and a streamlined application,
review, and approval process for housing for
persons with disabilities.
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
ELDERLY (65+ YEARS)
Many senior-headed households have special
needs due to their relatively low incomes,
disabilities or limitations, and dependency
needs. Specifically, many people aged 65
years and older live alone and may have
difficulty maintaining their homes, are usually
retired and living on a limited income, and
are more likely to have high health care costs
and rely on public transportation, especially
those with disabilities. The limited income of
many elderly persons often makes it difficult
for them to find affordable housing. There are
941 households headed by elderly residents,
representing 7.4 percent of total households
in Azusa. A total of 12.3 percent of elderly
residents are living in poverty in Azusa.
Seniors with limited incomes may have
difficulty finding affordable housing. The Los
Angeles Housing Authority is responsible
for the Housing Choice Voucher (Section 8)
program in the City of Azusa. Priority is given
to senior (62 years old or older), disabled
or handicapped residents that meet the
income guideline limits established by the
Federal Government. Many Azusa seniors
reside in conventional single-family homes.
Senior homeowners who need maintenance
assistance can apply to the City’s Residential
Rehabilitation Program, which provides grants
to eligible homeowners/occupants of single-
family detached homes to create a safe living
environment.
Azusa also has been active in providing for
a variety of housing options that are age-
restricted for seniors. The City has reduced
development standards for senior housing;
this has fostered new development including
the Gladstone Senior Villas, constructed in
2020 (60 units). Azusa is also home to four
assisted living facilities. The Azusa Senior
Center serves as a resource for seniors in the
community, providing meals and information
to support the population.
LARGE HOUSEHOLDS (5+
MEMBERS)
Large households, defined by HCD as
households containing five or more persons,
have special housing needs due to the
limited availability of adequately sized,
affordable housing units. Larger units can be
very expensive; as such, large households
are often forced to reside in smaller, less
expensive units or double-up with other
families or extended family to save on
housing costs, both of which may result in
unit overcrowding. There are 2,572 large
households in Azusa, representing 20 percent
of all households. A larger percentage of
renter households (11 percent) are large (5+
members) as compared to owner households
(9 percent).
The majority of housing in Azusa has two
or fewer bedrooms (51 percent). One third
of housing has three bedrooms, 13 percent
has four bedrooms, and two percent have
five or more bedrooms. Significantly more
owner-occupied housing has three or more
bedrooms, as indicated in Figure H3-1.
However, 26 percent of rental housing has
three or more bedrooms. Given that the
population of large households within Azusa
is less than the existing housing stock for
large units, existing supply may be adequate
to support this group. However, support
services may be necessary to address existing
overcrowding due to an inability to afford
larger unit sizes.
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
The Los Angeles Community Development Authority (LACDA) implements the Housing Choice
Voucher/Section 8 rental assistance on behalf of Azusa. Housing choice vouchers are provided
to approximately 242 households in Azusa earning low or very low incomes. These vouchers are
portable and not tied to a specific apartment project.
Figure H-3.1: Tenure by Bedrooms
Source: US Census Bureau, American Community Survey 2014-2018 5-year estimates
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
FARMWORKERS
Due to the high cost of housing and low
wages, a significant number of migrant
farmworkers have difficulty finding affordable,
safe, and sanitary housing. There are 136
residents who are employed in agriculture,
forestry, fishing, and hunting industries in
Azusa, representing only 0.6 percent of
the city’s labor force. Maps from the State
of California Department of Conservation
Farmland Mapping and Monitoring Program
show no farmland in Azusa. Due to the low
number of agricultural workers in the City, the
housing needs of migrant and/or farmworker
housing need can be met through general
affordable housing programs.
FEMALE HEADED
HOUSEHOLDS
Single-parent households require special
consideration and assistance because of
the greater need for childcare, health care,
and other services. In particular, female-
headed households with children tend to
have lower incomes and a greater need for
affordable housing and accessible childcare
and other supportive services. The relatively
low incomes earned by female-headed
households, combined with the increased
need for supportive services, severely limit
the housing options available to them. There
are 2,390 female-headed family households in
Azusa, representing 19 percent of households.
A total of 18 percent of female-headed family
households live in poverty.
Providing housing opportunities for families
in Azusa is a challenging task. The primary
need for female-headed households is for
more affordable housing and supportive
services, including childcare. The Los Angeles
Community Development Authority (LACDA)
implements the Housing Choice Voucher/
Section 8 rental assistance on behalf of
Azusa. Housing choice vouchers are provided
to approximately 242 households in Azusa
earning low or very low incomes. These
vouchers are portable and not tied to a
specific apartment project. Program H2-3 is
included in the Housing Plan to continue to
partner with LACDA and promote the use and
availability of Housing Choice Vouchers in the
community.
PEOPLE EXPERIENCING
HOMELESSNESS
Homelessness continues to be a regional
and national issue. The City of Azusa is part
of the county-wide Los Angeles Continuum
of Care (LACoC) to provide assistance to
homeless persons at every level of need and
assist in the move from homelessness to
permanent housing. The continuum of care
begins with assessment of the needs of the
homeless individual or family. The person/
family may then be referred to permanent
housing or to transitional housing where
supportive services are provided to prepare
them for independent living. The goal of a
comprehensive homeless service system is to
ensure that homeless individuals and families
move from homelessness to self-sufficiency,
permanent housing, and independent living.
The LACoC services and facilities available
for the homeless in Azusa are coordinated by
the Los Angeles Homeless Services Authority
(LAHSA).
Because of the transient nature of
homelessness, gauging an estimate of
homeless persons is difficult. One source
of information on homelessness is the 2019
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
Greater Los Angeles Homeless Count Report.
In 2019, there was a total of 329 homeless
individuals in Azusa, 94 percent of which were
unsheltered. The City allows shelters by right
in the West End Industrial District, and with
a Use Permit in the West End Light Industrial
District and the University District-Mixed Use.
In addition, through Program H4-2, Azusa
will allow Low-Barrier Navigation Centers (a
housing first, low barrier, service-enriched
shelter focused on moving people into
permanent housing) by right in all areas zoned
for mixed-use and nonresidential zones that
allow multi-family uses.
The City of Azusa continues to work
with regional partners, including local
nonprofits and surrounding jurisdictions,
to address homelessness. In 2018, the City
adopted a Plan to Prevent and Combat
Homelessness, which outline the City’s
priorities as it continues to address issues
related to homelessness. In 2019, the City
received additional funds to build capacity
by expanding on the existing work of
Neighborhood Connections, a library-based
program, to establish a community-wide
approach to homeless solutions and better
route for community members experiencing
homelessness into and through the initial
Centralized Entry System.
Energy Conservation
Opportunities
Energy-related housing costs can directly
impact the affordability of housing. While
state building code standards contain
mandatory energy efficiency requirements
for new development, the City and utility
providers are also important resources to
encourage and facilitate energy conservation
and to help residents minimize energy-related
expenses. Policies addressing climate change
and energy conservation are integrated into
the Azusa General Plan. The primary avenues
to address climate change in Azusa are
through incorporating energy conservation
efforts into the design of all new construction
and site development, encouraging the
retrofit of energy efficient features to existing
buildings, and requiring new development
and significant renovation projects to
include more bicycle, pedestrian, and transit
amenities.
Azusa is serviced by the Azusa Light & Water
Department, which offers various energy
conservation programs to residents and
businesses in the city. There are a variety of
retrofit and energy usage audit programs
to encourage owners to provide buildings
and appliances that are as energy efficient
as possible. Residential customers can take
advantage of several rebate and energy
programs, such as the Home Weatherization
and Residential EnergyStar Appliance Rebate.
Low-income households have the option to
apply to the Azusa Light & Water Low-income
Assistance program for financial support on
their energy bills.
Additionally, the Southern California Gas
Company offers various rebate programs
for energy-efficient appliances and makes
available to residents energy efficient kits
at no cost. The Gas Company also offers
no-cost weatherization and furnace repair
or replacement services for qualified limited-
income customers.
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
At-Risk Housing Analysis
State housing element law requires an
inventory and analysis of government-
assisted dwelling units eligible for conversion
from lower income housing to market rate
housing during the next ten years. Reasons
for this conversion may include expiration
of subsidies, mortgage pre-payments or
pay-offs, and concurrent expiration of
affordability restrictions. Three developments
have expiring affordability covenants (or
recently expired) in Azusa. Azusa Park
Apartments affordability covenants expired
in 2020; however, the City has not received
any notifications from the property owner
regarding conversion to market rate housing.
Table H-3.10: Assisted Rental Housing in Azusa
Assisted
Developments
Tenant
Type
Affordable
Units
Total
Units Funding Programs
Earliest
Conversion
Date
Azusa
Apartments
805 S. Cerritos
Ave.
Family 81 88
LIHTC, Section
8Sec.241(f)/
Sec.236(i)(1)
2068
Alosta Gardens
745 E. 5th Street
Family 60 60 Section 8 and
Sec. 221(d)(4)2024
Azusa Park
Apartments
363 N. Calera
Ave.
Family 88 90 Section 8 and
Sec.221(d)(4)2020
Villa Azusa
Senior
Apartments
200 E. Gladstone
Elderly 30 147 Redevelopment
Agency 2023
Azusa Gardens
601 E. Alosta
Ave.
Family 23 112
Redevelopment
Agency, HUD,
Mortgage
Revenue Bonds,
CDBG
2035
Iris Gardens
385 N. Rockvale
Ave.
Family 118 120 LIHTC 2054
Sources: California Housing Partnership Corporation, City of Azusa, 2021.
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
PRESERVATION AND
REPLACEMENT OPTIONS
Based on City records and information
from the California Housing Partnership
Corporation, in the next 10 years (2021-2031),
affordability covenants at Villa Azusa Senior
Apartments and Alosta Gardens are set to
expire. In addition, affordability covenants at
Azusa Park Apartments have since expired.
These three projects, with a total of 178
affordable units, are identified as high risk of
conversion to market rate and are analyzed
below.
Preservation of at-risk projects can be
achieved in a variety of ways, with adequate
funding availability. Alternatively, units that
are converted to market rate may be replaced
with new assisted multi-family units with
specified affordability timeframes.
Rental Assistance
State, local, or other funding sources can
be used to provide rental subsidies to
maintain the affordability of at-risk projects.
These subsidies can be structured to mirror
the Housing Choice Voucher/Section 8
program, whereby the subsidy covers the
cost of the unit above what is determined
to be affordable for the tenant’s household
income (including a utility allowance) up to
the fair market value of the apartment. Unit
sizes for the at-risk properties range from
one-bedroom to three-bedroom units and
are distributed among low- and moderate-
income categories. The total annual subsidy
to maintain the 178 at-risk units is estimated
at about $1.1 million.1
Transfer of Ownership
If the current organizations managing the
units at risk are no longer able to maintain
the project, transferring ownership of the
affordable units to a nonprofit housing
organization is a viable way to preserve
affordable housing for the long term. The
estimated market value for the 178 affordable
units that are potentially at risk of converting
to market rate is nearly $36 million.
1 Rental subsidies are calculated using the difference
in affordability (by income level and unit size) and the
fair market rent for the metro area
Table H-3.11: Assisted Housing Acquisition Cost
Project Size Developments at Risk (Units)
0-bdrm 0
1-bdrm 30
2-bdrm 111
3-bdrm 37
4-bdrm 0
Total 178
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Table H-3.11: Assisted Housing Acquisition Cost
Project Size Developments at Risk (Units)
Annual Operating Costs ($826,500)
Gross Annual Income $4,096,522
Net Annual Income $3,270,022
Market Value $35,970,238
Notes:
Fair Market Rents (2020) for Los Angeles-Long Beach-Glendale HUD Metro Area
Average Size: Studio = 500 sqft, 1-bed = 700 sqft, 2-bed = 900 sqft, 3-bed = 1200 sqft, 4-bed = 1500 sqft
5% vacancy rate and annual operating expenses per square foot = $5.00
Construction of Replacement Units
The construction of new low-income housing
can be a means to replace at-risk units. The
cost of developing new housing depends on
a variety of factors including density, size of
units, construction quality and type, location,
and land cost. Assuming a development
cost of $167.27 per square feet (ICC Building
Valuation Data 2020) and the average size
of units, the construction cost of replacing
all 178 affordable at-risk units would be
approximately $27.65 million.
Entities Interested in Participating
in California’s First Right of Refusal
Program
An owner of a multi-family rental housing
development with rental restrictions (i.e., is
under agreement with federal, State, and
local entities to receive subsidies for low-
income tenants), may plan to sell their “at
risk” property. The California Department of
Housing and Community Development (HCD)
have listed qualified entities that may be
interested in participating in California’s First
Right of Refusal Program. If an owner decides
to terminate a subsidy contract, or prepay
the mortgage or sell or otherwise dispose of
the assisted housing development, or if the
owner has an assisted housing development
in which there will be the expiration of rental
restrictions, the owner must first give notice
of the opportunity to offer to purchase to a
list of qualified entities provided to the owner.
HCD has listed 42 entities that may be
interested in participating in California’s First
Right of Refusal Program in Los Angeles
County.2 If a development becomes at risk of
conversion to market-rate housing, the City
will maintain contact with local organizations
and housing providers who may have an
interest in acquiring at-risk units and will assist
other organizations in applying for funding to
acquire at-risk units.
2 California Department of Housing and Community
Development website accessed April 27, 2021.
https://www.hcd.ca.gov/policy-research/docs/HPD-
00-01.xlsx
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NEEDS ASSESSMENT | AZUSA HOUSING ELEMENT 2021-2029
Funding Sources
A critical component to implement any of
these preservation options is the availability
of adequate funding, which can be difficult
to secure. In general, Low-Income Housing
Tax Credit funding is not readily available
for rehabilitation and preservation, as
the grant application process is highly
competitive and prioritizes new construction.
The City’s previous funding source, Low/
Mod Housing Funds available through the
Redevelopment Agency, no longer exist due
to the dissolution of Redevelopment nearly a
decade ago. Available funding sources that
can support affordable housing preservation
include sources from the federal and state
governments, as well as local and regional
funding.
Federal Funding
• HOME Investment Partnerships
(HOME) Program
• Project-Based Vouchers (Section 8)
• Section 811 Project Rental Assistance
State Funding
• Affordable Housing and Sustainable
Communities Program
• Golden State Acquisition Fund (GSAF)
• Project Homekey
• Housing for a Healthy California
• Multifamily Housing Program (MHP)
• National Housing Trust Fund
• Predevelopment Loan Program (PDLP)
Regional, Local, and Nonprofit Funding
• San Gabriel Valley Regional Housing
Trust
• Foundations and Nonprofits
Another option to preserve the affordability
of at-risk projects is to restructure the
financing of the projects by paying off the
remaining balance or writing down the
interest rate on the remaining loan balance.
The feasibility of this option depends on
whether the complexes are too highly
leveraged.
Projected Housing Need
(RHNA)
Housing-element law requires a quantification
of each jurisdiction’s share of the regional
housing need as established in the RHNA-
Plan prepared by the jurisdiction’s council
of governments. The California Department
of Housing and Community Development
(HCD), in conjunction with the SCAG,
determine a projected housing need for
the region covered by SCAG, including the
counties of Riverside, San Bernardino, Los
Angeles, Orange, Ventura and Imperial.
This share, known as the Regional Housing
Needs Allocation (RHNA), is 1,341,834 new
housing units for the 2021-2029 planning
period throughout the SCAG region. SCAG
has, in turn, allocated this share among its
constituent jurisdictions, distributing to
each its own RHNA divided along income
levels. The City of Azusa has a RHNA of 2,651
housing units to accommodate in the housing
element period. The income distribution is as
shown in Table H-3.12.
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AZUSA HOUSING ELEMENT 2021-2029 | NEEDS ASSESSMENT
Table H-3.12: Regional Housing Needs Allocation 2021-2029
Income Group % of County AMI Number of Units
Allocated
Percent of Total
Allocation
Very Low 0-50%760 28.7%
Low >50-80%368 13.9%
Moderate >80-120%382 14.4%
Above Moderate 120%+1,141 43.0%
Total --2,651 --
Note: Pursuant to AB 2634, local jurisdictions are also required to project the housing needs of extremely low-income households (0-
30% AMI). In estimating the number of extremely low-income households, a jurisdiction can use 50% of the very low-income allocation
or apportion the very low-income figure based on Census data. There are 2,025 extremely low- and 2,305 very low-income households,
with extremely low-income households comprising 46.7% of the total of both these categories. Therefore, the City’s very low-income
RHNA of 760 units can be split into 355 extremely low-income and 405 very low-income units.
Azusa
Pedestrian
Plan
CONSTRAINTS
ANALYSIS
4
64
AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Many factors can encourage or constrain the
development, maintenance, and improvement
of the housing stock. These factors are
categorized into two umbrellas: Governmental
and non-governmental constraints and
include physical constraints, land availability,
the economics of development, and
governmental regulations, all of which may
impact the cost and amount of housing
produced. These constraints may result in
housing that is not affordable to low- and
moderate-income households or may render
residential construction economically difficult
for developers. Constraints to housing
production significantly impact households
with lower incomes and special needs. This
chapter addresses both the governmental
and non-governmental constraints that
impact the City of Azusa’s housing market
and production.
State law requires that Housing Elements
analyze potential and actual governmental
and non-governmental constraints to the
production, maintenance, and improvement
of housing for persons of all income levels
and disabilities. The constraints analysis must
also demonstrate local efforts to remove or
mitigate barriers to housing production and
housing for persons with disabilities. Where
constraints to housing production related to
the City’s regulations or land use controls are
identified, appropriate programs to remove or
mitigate these constraints are included in the
Housing Plan.
Non-Governmental
Constraints: Market
Constraints
Construction costs, land costs, and the
availability of financing all contribute to the
cost of housing production. To a large degree,
the City has virtually no control over these
constraints, as the market dictates the costs.
The primary non-governmental constraints
to the development of new housing are land
costs, construction costs, and environmental
constraints. Through programs such as home
ownership assistance and the use of flexible
design standards, the City can take steps
offset their effects.
DEVELOPMENT COSTS
Price of Land
Land costs include acquisition and the cost
of holding land throughout the development
process. These costs can account for as much
as half of the final sales prices of new homes in
small developments or in areas where land is
scarce. The variables affecting the cost of land
are the size of lots, location and amenities, the
availability and proximity of public services,
and the financing arrangement between the
buyer and seller. The price of land has been
one of the largest components of housing
development costs in Southern California.
Land costs may vary depending on whether
the site is vacant or has an existing use that
must be removed. Similarly, site constraints
such as environmental issues (steep slopes,
soil stability, seismic hazards, or flooding)
can also be factored into the cost of land.
Constraints Analysis
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Generally, the costs of land increase as
densities increase. However, the cost per unit
will typically decline. The cost of vacant land
in Azusa has historically been less than that of
other Southern California cities, a factor that
has contributed to Azusa’s significant supply
of affordable housing in the City. In April 2021,
three lots were listed available for sale that
allow residential development in Azusa.
Cost of Construction
Construction costs, which can comprise a
significant portion of the sales price of a
home, are one of the major cost factors with
residential development. Construction cost is
determined primarily by the cost of labor and
materials. The relative importance of each is a
function of the complexity of the construction
job and the desired quality of the finished
product. The price paid for material and
labor at any one time will reflect short-term
considerations of supply and demand. Future
costs are difficult to predict given the cyclical
fluctuations in demand and supply that in
large part are created by fluctuations in the
Table H-4.1: Vacant Land Costs
Address/Zone Cost Acres Estimated Units Cost per Unit
Gladstone
St/NG3 - NC $1,280,000 0.479 9 $142,222
Pasadena
Ave/
Residential
Medium
$559,000 0.170 2 $279,500
N Azusa Ave/
TOD SP $765,000 0.162 5 $153,000
Source: Zillow.com, April 2021.
state and national economies. Such policies
unilaterally impact construction in a region and
therefore do not deter housing construction in
any specific community.
According to data from the California
Construction Cost Index, hard construction
costs in California grew by 44 percent between
2014 and 2018, or an additional $80 per square
foot.1 Construction costs are estimated to
account for upwards of 60 percent of the
production cost of a new home, especially for
multi-unit residential buildings which often
require the use of more expensive materials,
like steel, and need additional amenities
such as parking structures.2 Variations in the
quality of materials, type of amenities, labor
1 Hayley Raetz, Teddy Forscher, Elizabeth Kneebone
and Carolina Reid, The Hard Costs of Construction:
Recent Trends in Labor and Materials Costs for
Apartment Buildings in California, The Terner Center
for Housing Innovation, University of California
Berkeley, March 2020, p.8, http://ternercenter.
berkeley.edu/uploads/Hard_Construction_Costs_
March_2020.pdf
2 Ibid., Raetz et al, p.4.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
costs and the quality of building materials
could result in higher or lower construction
costs for a new home. Pre-fabricated factory
built housing, with variation on the quality of
materials and amenities may also affect the
final construction cost per square foot of a
housing project.
An indicator of construction costs is
Building Valuation Data compiled by the
International Code Council (ICC). The unit
costs compiled by the ICC include structural,
electrical, plumbing, and mechanical work,
in addition to interior finish and normal site
preparation. The data is national and does
not consider regional differences, nor does
the data include the price of the land upon
which the buildings are built. The 2020
national averages for costs per square foot of
apartment units and single-family homes are
as follows:
• Type I or II, Multi-Family: $129.23 to
$167.27 per square foot
• Type V Wood Frame, Multi-Family:
$112.76 to $147.50 per square foot
• Type V Wood Frame, One and Two
Family Dwelling: $122.46 to $141.72 per
square foot
The City’s ability to mitigate high construction
costs is limited without direct subsidies.
Another factor related to construction cost is
development density. With an increase in the
number of units built in a project, overall costs
generally decrease as builders can benefit
from the economies of scale. Throughout
Southern California, builders have remarked
on high construction costs in 2021, which are
driven both by labor and materials costs.
Labor Cost
The California Labor Code applies prevailing
wage rates to public works projects exceeding
$1,000 in value. Public works projects
include construction, alteration, installation,
demolition, or repair work performed under
contract and paid for in whole or in part out
of public funds. Furthermore, if federal funds
are involved, Davis-Bacon wages often apply.
While the cost differential in prevailing and
standard wages varies based on the skill level
of the occupation, prevailing wages tend to
add to the overall cost of development. In the
case of affordable housing projects, prevailing
wage requirements could effectively reduce
the number of affordable units that can be
achieved with public subsidies.
Availability of Financing
The availability of capital to finance new
residential development is a significant factor
that can impact both the cost and supply of
housing. Two types of capital are involved
in the housing market: 1) capital used by
developers for initial site preparation and
construction and 2) capital for financing
the purchase of units by homeowners
and investors. Interest rates substantially
impact home construction, purchase, and
improvement costs. A fluctuation in rates
of just a few percentage points can make
a dramatic difference in the annual income
needed to qualify for a loan. In general,
financing for new residential development
is available at reasonable rates. However,
economic fluctuations due to COVID-19 have
caused caution among lenders and may have
lasting effects through this Housing Element
planning period. And while interest rates are
low, lenders are considering applicants much
more closely than in the past, leading to credit
tightening despite affordable interest rates.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Government
Code 65583(a)(6)
Development Analysis
Government Code section 65583(a)
(6) requires an analysis of requests to
develop housing at densities below those
anticipated in site inventory and the length
of time between receiving approval for
housing development and submittal of an
application for building permit. The analysis
must also look at local efforts to remove
nongovernmental constraints that create a
gap in the jurisdiction’s ability to meet RHNA
by income category.
REQUESTS FOR LOWER
DEVELOPMENT DENSITIES
The City of Azusa adopted one of the first
hybrid form-based codes in the state. Due
to the form-based structure of the code,
applicants are not required to stay within a
maximum density; instead, the project must
simply show how development standards
can be met. The constraining factors for
development density are (1) parking, (2) open
space, (3) stacked flats, and (4) minimum unit
size.
• Parking: The City requires new
development to provide adequate
onsite parking to avoid impacts to
the surrounding neighborhoods. On
smaller sites, this requirement may
result in site design that requires
subterranean construction for parking.
Generally, due to the market rents
and sale prices, subterranean parking
increases project costs to the point
that the project no longer pencils
and revised site designs may result,
which lowers the project density. As
market rents rise, this impediment may
be lessened. Despite this potential
constraint, providing adequate
parking is a crucial component of
project design and neighborhood
compatibility.
• Open Space: The provision of open
space is related to quality of life and
enhances our neighborhoods and
multi-family developments. The City’s
open space standards are in line with
similar surrounding jurisdictions and are
a necessary component of quality site
plan design.
• Stacked Flats: The City’s existing code
requires multi-family to be in the form
of townhomes/attached housing in
most zones. Stacked flats, or a standard
multi-family unit, are only allowed in the
TOD Specific Plan area or if a project is
reserved as senior housing. This design
requirement limits the ability for a
variety of housing types. Program H4-4
is included in the Housing Element to
remove this limitation.
• Minimum Unit Size: The existing
code was developed with a minimum
unit size to support the form-based
function. However, this may become an
impediment to housing development
and limits creative and emerging
housing types. As such, Program H4-5
is included in the Housing Element to
modify this requirement to correlate
with reduced minimum unit sizes
included in the TOD Specific Plan.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
The City adopted a TOD Specific Plan
in 2015; the TOD Specific Plan does not
include any parcel-specific density limits.
This Specific Plan has been highly successful
in encouraging high-density projects, on
both small and large sites. For example,
The Orchard (under construction in 2021)
is located on 2.24 acres at a density of over
72 units per acre; The Avenue (entitled as of
2021) is located on 1.2 acres at a density of
105 units to the acre. Smaller sites are also
able to achieve densities above those Azusa
has seen in the recent past, though are more
modest due to site constraints. For example,
the six-unit project at 619 N. San Gabriel will
achieve a density of 37 units per acre (under
construction in 2021). In the sites inventory,
these trends are taken into consideration.
Development densities for smaller sites in
the TOD Specific Plan area are assumed to
be lower than large sites, which can achieve
higher densities due to site design economies
of scale. Development approval of projects
with densities lower than what is anticipated
in the Housing Element is not expected.
BUILDING PERMIT TIMEFRAME
In Azusa, the length of time between
receiving approval for housing development
and submittal of an application for building
permit is typically 20 to 60 days, depending
on project complexity. For example, a multi-
family residential project with complex
grading and drainage plans may take
longer than usual to submit permits. Also,
developers may struggle with feasibility
analyses, financing, or negotiations with
design professionals which are outside the
control of the City. Most small projects submit
within one month of entitlement approval.
The City also offers concurrent review with
a “hold harmless” process, where applicants
may submit for planning and building permits
concurrently, which provides flexibility for
applicants and can speed up the overall
development timeline.
LOCAL EFFORTS TO REMOVE
NONGOVERNMENTAL
CONSTRAINTS
Government Code 65583(a)(6) also
requires a review of local efforts to remove
nongovernmental constraints that create a
gap in the jurisdiction’s ability to meet the
RHNA by income category. The primary non-
governmental constraint is the overall cost of
affordable housing development (high land
and development costs) in most parts of the
State. In general, constructing affordable
housing, especially for low- and very low-
income households is not profitable to housing
developers. Therefore, deed-restricted
affordable units require subsidy beyond
available density or financial incentives. This
places the construction burden on non-
profits and similar grant-funded housing
developments and may result in affordable
housing projects that are not always dispersed
throughout the region but are concentrated
in limited areas with lower development costs.
While the City can offer developer incentives
such as expedited permit processing or fee
deferrals, it cannot afford to fully mitigate
the high cost of development for affordable
housing developments. The City has limited
ability to provide direct financial assistance.
However, the City does have programs
that can assist in alleviating some impacts
of non-governmental constraints, such as
facilitating the acquisition and rehabilitation/
redevelopment of substandard multi-family
rental properties by qualified developers. In
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
the past, the City provided development
assistance through Redevelopment Set-
Aside Funds as a means to reduce overall
development costs. However, with the
dissolution of Redevelopment Agencies
in 2014, the City’s ability to provide direct
financial support has been extremely
curtailed. The City can also support by
providing advantageous development
standards. The City has included programs in
the Housing Plan to amend various sections
of the Development Code to comply with new
state laws and better facilitate housing and
affordable housing in Azusa.
Governmental
Constraints
Although local governments have little
influence on such market factors as
interest rates and availability of funding for
development, their policies and regulations
can affect both the amount of residential
development that occurs and the affordability
of housing. Since governmental actions can
constrain development and affordability
of housing, State law requires the Housing
Element to “address and, where appropriate
and legally possible, remove governmental
constraints to the maintenance, improvement,
and development of housing.” Land use
controls, building codes, fees, and other
local programs intended to improve the
overall quality of housing may also serve as a
constraint to housing development.
Consistent with State law (Section 65583), this
section addresses six potential governmental
constraints to housing development:
• Land use controls
• Building codes and their enforcement
• Site improvements (on and off-site)
• Fees and exactions
• Processing and permit procedures
• Housing for people with disabilities
LAND USE CONTROLS
Land use controls set forth by the General Plan
and Chapter 88, the Development Code, and
the adopted Specific Plans could have direct
effects on the availability and affordability of
housing in the City. Azusa has adopted a form-
based code, which primarily controls physical
form, with a lesser focus on land use. The
code designates the desired form and scale
of development rather than clear standards
of land use, as is the case with conventional
zoning ordinances. Land use provisions
currently in place in Azusa are described
below and presented in Tables H-4.2 to H-4.12.
The City adopted a density bonus ordinance
in 2011. While consistent with Government
Code 65915 at the time of adoption, the State
Legislature has passed numerous changes
to the density bonus requirements. Program
H4-1 is included in the Housing Element to
ensure the City’s density bonus ordinance is
consistent with the most current state laws.
General Plan Land Use Element
The City of Azusa General Plan Built
Environment Chapter sets forth the City’s
policies for guiding local development and
growth (Chapter 3). These policies, together
with the development code, establish the
amount and distribution of land uses and
design standards within the City. The Built
Environment Element provides a range of
residential development opportunities that are
implemented through the City’s Regulating
Plan for Azusa’s Planning Areas, which includes
the designation of neighborhoods, districts,
and corridors.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Housing supply and costs are affected by
the amount of land designated for residential
use and the density at which development
is permitted. According to the General Plan,
approximately 1,255 acres in Azusa (22.6
percent) are designated for residential use.
The designated areas allow for the
traditional low-, medium-, and moderate-
density residential areas. Additionally, the
City establishes residential components
in Neighborhood Center, Mixed Use,
and Transit Station areas. These areas are
allowed a maximum density limit of 27 units
per acre, which is the same density limit as
the Moderate Density Residential category.
The table below summarizes the maximum
densities and Floor Area Ratio (FAR) for the
different land use categories in the General
Plan.
Table H-4.2: Azusa General Plan Residential Land Use Designations
Category Typical Principal Use
Maximum Density/
Intensity and Heights
Low Density Residential Single Family Residential 0-8 units per net acre
Medium Density Residential Single Family Residential 8.1-15 units per net acre
Moderate Density Residential Multi-Family Residential 15.1-27 units per acre
Neighborhood Center
Neighborhood serving retail
(restaurants, household
goods, personal services,
etc.)
Mixed Use
Single Use Residential: 14-27
units per net acre
Single Use Commercial: 0.35-
1.8 FAR
Commercial/Residential
Mixed Use
Residential/Commercial
Mixed Use
Commercial (office and retail)
/Residential
Residential/Commercial
(office and retail)
Mixed Use: 1.5 FAR
Single Use Commercial: 0.35-
1.8 FAR
Single Use Residential: 14-27
units per net acre
TOD Specific Plan District
Transit depot
Commercial (retail and office)
/Residential Mixed Use
N/A
Source: City of Azusa General Plan Built Environment Element, Amended 2017
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Development Code
The City of Azusa’s Development Codes
uses the designation of neighborhoods,
districts, and corridors to regulate building
form as it relates to other nearby structures,
streetscapes and adjacent uses instead of the
traditional land use zones or districts, which
regulates the types of uses allowed on land.
By using form-based standards to regulate
the scale, bulk and density, of allowed land
uses, the City can more effectively meet
urban design objectives for distinct areas
while ensuring that development is consistent
with the City’s character and identity. The
specific regulations of the Development Code
for each neighborhood, district, and corridor
are intended to provide for an appropriate
mixture of land uses that function compatibly
with one another, and development that is
oriented to the both the needs of pedestrians
and automobile.
Table H-4.3: Residential Development Standards for Neighborhoods
Neighborhood
Centers
Traditional
Neighborhoods
Transitional
Neighborhoods
Tract
Neighborhoods
Maximum
Density
(units/acre)
27
Low: 8
Med: 15
Mod: 27
Low: 8
Med: 15
Mod: 27
Low: 8
Med: 15
Mod: 27
Minimum Lot
Area 10,000 sf
Low: 7,500 sf
Med: 4,000 sf
Mod: 6,000 sf
Low: 6,000 sf
Med: 4,000 sf
Mod: 6,000 sf
Low: 7,500 sf
Med: 4,000 sf
Mod: 6,000 sf
Minimum
floor area per
dwelling unit
1,200 sf
(single family
dwelling)
850 sf
(duplex)
500 sf (studio)
675 sf (1-bed)
800 sf (2-bed)
975 sf (3-bed)
Low: 1,200 sf
Med: 1,200 sf
Mod: 850 sf
(duplex)
500 sf (studio)
675 sf (1-bed)
800 sf (2-bed)
975 sf (3-bed)
Low: 1,200 sf
Med: 1,200 sf
Mod: 850 sf
(duplex)
500 sf (studio)
675 sf (1-bed)
800 sf (2-bed)
975 sf (3-bed)
Low: 1,200 sf
Med: 1,200 sf
Mod: 850 sf
(duplex)
500 sf
(studio)
675 sf (1-bed)
800 sf (2-bed)
975 sf (3-bed)
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Table H-4.3: Residential Development Standards for Neighborhoods
Neighborhood
Centers
Traditional
Neighborhoods
Transitional
Neighborhoods
Tract
Neighborhoods
Minimum Set
Backs
Front: 0 ft;
5 ft max for
80% min of
lot frontage
Side Street:
0 ft; 5 ft
max for 80%
min of lot
frontage
Sideyard: 0 ft;
10 ft next to
residential
Rear: 20 ft
min
Front: 20 ft
min
Side Street:
10 ft min
Sideyard: 5 ft
min
Rear: 20 ft
min
Front: 25 ft
min
Side Street:
10 ft min
Sideyard: 5 ft
min
Rear: 25 ft
min
Front: 25 ft
min
Side Street:
10 ft min
Sideyard: 5 ft
min
Rear: 25 ft
min
Maximum
Building Height
3 stories or 35 ft
for single use; 3
stories or 40 ft
for mixed use
2 ½ stories or
35 ft
2 ½ stories or
35 ft
2 ½ stories or
35 ft
Source: City of Azusa Development Code, 2021.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Table H-4.4: Residential Development Standards for Districts
University District Edgewood District
Maximum Density (units/acre)
Mixed Use: 27
Res Med: 15
Res Med: 27
Res Med: 15
Res Mod: 27
Minimum Lot Area
Mixed Use: 10,000sf
Med: 4,000 sf
Mod: 6,000 sf
6,000 sf
Minimum floor area per
dwelling unit
Low: 1,200 sf
Med: 1,200 sf
Mod: 850 sf (duplex)
500 sf (studio)
675 sf (1-bed)
800 sf (2-bed)
975 sf (3-bed)
Med: 1,200 sf
Mod: 850 sf (duplex)
500 sf (studio)
675 sf (1-bed)
800 sf (2-bed)
975 sf (3-bed)
Minimum Set Backs
Front: 10 ft min; 20 ft max for
75% min of lot frontage
Side Street: 10 ft min; 20
ft max for 75% min of lot
frontage
Sideyard: 15 ft
Rear: 15 ft
Front: Within 150 ft of Azusa/
Gladstone intersection: 10 ft
min; 20 ft max for 75% min of
lot frontage
Side Street: Within 150
ft of Azusa/ Gladstone
intersection: 10 ft min; 20
ft max for 75% min of lot
frontage
Sideyard: 15 ft
Rear: 15 ft
Maximum Building Height
3 stories or 35 ft for single
use; 3 stories or 40 ft for
mixed use
3 stories or 35 ft for single
use; 3 stories or 40 ft for
mixed use
Source: City of Azusa Development Code, 2021.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Table H-4.5: Residential Development Standards for Corridors
Foothill
Boulevard
Corridor
Azusa Avenue
Corridor
San Gabriel
Avenue Corridor
South Azusa
Avenue Corridor
Arrow Highway
Corridor
Maximum
Density
(units/acre)
27 27 27 27 27
Minimum
Lot Area 10,000 sf 10,000 sf 10,000 sf 10,000 sf 10,000 sf
Minimum
floor
area per
dwelling
unit
1,200 sf
(single
family
dwelling)
850 sf
(duplex)
500 sf
(studio)
675 sf (1-
bed)
800 sf (2-
bed)
975 sf (3-
bed)
Low: 1,200
sf
Med: 1,200
sf
Mod: 850 sf
(duplex)
500 sf
(studio)
675 sf (1-
bed)
800 sf (2-
bed)
975 sf (3-
bed)
Low: 1,200
sf
Med: 1,200
sf
Mod: 850 sf
(duplex)
500 sf
(studio)
675 sf (1-
bed)
800 sf (2-
bed)
975 sf (3-
bed)
Low: 1,200
sf
Med: 1,200
sf
Mod: 850 sf
(duplex)
500 sf
(studio)
675 sf (1-
bed)
800 sf (2-
bed)
975 sf (3-
bed)
Low: 1,200
sf
Med: 1,200
sf
Mod: 850 sf
(duplex)
500 sf
(studio)
675 sf (1-
bed)
800 sf (2-
bed)
975 sf (3-
bed
Minimum
Set Backs
Front: 10 ft;
20 ft max for
60% min of
lot width
Side Street:
10 ft min
Sideyard: 0
ft or 10 ft for
residential
Rear: 0 ft
or 10 ft for
residential
Front: 10 ft;
20 ft max
for 60% min
of lot width
Side Street:
10 ft min
Sideyard:
0 ft; 5 ft
min for
residential,
or when
adjacent to
residential
Rear: 0 ft;
5 ft min for
residential,
or when
adjacent to
residential
Front: 10 ft;
20 ft max for
60% min of
lot width
Side Street:
10 ft min
Sideyard:
0 ft; 5 ft
min for
residential,
or when
adjacent to
residential
Rear: 0 ft;
5 ft min for
residential,
or when
adjacent to
residential
Front: 15 ft;
20 ft max for
60% min of
lot width
Side Street:
10 ft min, 20
ft max for
60% min of
lot width
Sideyard:
10 ft min for
residential,
or when
adjacent to
residential
Rear: 10
ft min for
residential,
or when
adjacent to
residential
Front: 15 ft;
25 ft max for
60% min of
lot width
Side Street:
15 ft min, 25
ft max for
60% min of
lot width
Sideyard:
10 ft min for
residential,
or when
adjacent to
residential
Rear: 50
ft min for
residential,
or when
adjacent to
residential
Maximum
Building
Height
3 stories
or 35 ft for
single use; 3
stories or 40
ft for mixed
use
3 stories
or 35 ft for
single use;
3 stories
or 40 ft for
mixed use
3 stories
or 35 ft for
single use; 3
stories or 40
ft for mixed
use
3 stories
or 35 ft for
single use; 3
stories or 40
ft for mixed
use
3 stories
or 35 ft for
single use; 3
stories or 40
ft for mixed
use
Source: City of Azusa Development Code, 2021.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Open Space
To improve the living environment of
residential neighborhoods, communities
typically require housing to have a certain
amount of open space, such as yards,
common space, and landscaping. In
Azusa, open space is reflected in setbacks
requirements for single-family developments
and minimum required private and
common open space areas for multi-family
developments.
For single-family homes in any neighborhood,
buildings must be set back between 20
to 25 feet in the front and back of the lot.
Additionally, paved improvements cannot
exceed 40 percent in the front setback area.
Multi-family unit developments must provide
the following amount of open space for
residents:
• Developments with two to four units are
required to provide 200 square feet of
common space;
• Developments with five to 10 units are
required to provide 500 square feet of
common space;
• Developments with 11 to 30 units are
required to provide 1,000 square feet of
common space; and
• Developments with 31 or more units are
required to provide 2,000 square feet of
common space.
Each common open space area shall have a
minimum dimension of 20 feet. In addition
to this, all units must also have access to 150
square feet of private open space that is
accessible from each unit. The review authority
may make exceptions where it determines
that existing public park space or other usable
public open space is within convenient walking
distance of a development.
In the TOD Specific Plan, required open
space areas are significantly reduced to
accommodate a more urban form, while still
providing adequate open spaces for each
project.
Table H-4.6: TOD Specific Plan Open Space Standards
Gold Line District and Foothill Boulevard
Corridor
Azusa Avenue
Corridor
San Gabriel Avenue
Corridor
Residential Only Residential Only Residential and
Mixed Use
Residential and
Mixed Use
• Private: 100 SF
• Common: 25 SF
• Private: 125 SF
• Common: 25 SF
• Private: 150 SF
• Common: 30 SF
• Private: 200 SF
• Common: 40 SF
Mixed Use Mixed Use
• Private: 60 SF
• Common: 65 SF
• Private: 60 SF
• Common: 90 F
Source: City of Azusa TOD Specific Plan, 2018.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Parking
The City of Azusa Development Code carries
out the policies of the Azusa General Plan by
regulating development and land uses within
the City, consistent with the General Plan.
One of the purposes of the Development
Code is to minimize automobile congestion
through pedestrian-oriented development,
compact community form, safe and effective
traffic circulation, and adequate parking
facilities. As such, City parking standards for
residential developments are tailored to the
vehicle ownership patterns associated with
different residential uses. The Development
Code (Section 88.36.050) requires parking
based on the number of units on the
property. Parking requirements for residential
uses are listed in Table H-4.7.
For single-family developments, the
Development Code requires two spaces
within a garage for a dwelling with four or
fewer bedrooms and three spaces within
a garage for a dwelling with five or more
bedrooms. Multi-family residential parking
requirements are based on the number of
units, number of bedrooms per unit, and
also require guest parking. Senior housing
developments are required to have only one
space per unit, as well as some guest parking.
The parking and development standards in
Azusa are similar to those established for
surrounding communities in the San Gabriel
Valley, and do not pose a constraint to
residential development. The City has tailored
the standards to allow properties to achieve
maximum permitted densities while retaining
neighborhood character and amenities.
Parking standards are also a reflection of
the demand for parking spaces by Azusa
households. Given the City’s demographic
characteristics, average household size in
Azusa is larger than many other communities
in Southern California. Azusa’s 2019 average
household size is estimated to be 3.24 for
owner-occupied units and 3.70 for renter-
occupied units by the 2019 American Census
Survey, while the average household size for
all incorporated areas in Los Angeles County
is only 3.17 for owner-occupied units and
2.83 for renter-occupied units. In addition,
between 2015-2019, 39 percent of occupied
housing units had two vehicles available
and 30 percent have three or more vehicles
available. This is compared to the 35 percent
and 22 percent in Los Angeles county at
large, respectively. The City’s support for
transit and pedestrian-oriented development,
and provisions intended to discourage
“excessive” parking, provide for reduced
parking standards within the Downtown TOD
Specific Plan. As part of the Downtown TOD
Specific Plan, a Parking Management Plan
was prepared, accompanied by an analysis of
parking utilization and parking management
measures that allow the City to right-size
parking requirements within the Specific Plan
area. As such, parking requirements are not
prohibitive to housing development.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Existing parking standards in Azusa, including
garage requirements, do not impede a
developer’s ability to achieve maximum
densities. Many developers have indicated
that owners and tenants of townhomes and
rowhouses prefer enclosed parking due to
the added safety for both the vehicles parked
and the people getting in and out of their
cars. In addition, uncovered parking in surface
lots creates a less efficient use of land and
could potentially reduce overall residential
unit yield. For larger-scale residential and
mixed-use developments, common parking
areas in subterranean or structured parking
formats can be utilized to meet the garage
requirement. If an applicant chooses to
include more than the required number of
parking spaces, a use permit can be applied
for. Conversely, if a developer believes
that the residential parking requirements
constrain or places a burden on the proposed
development project, the developer has
the option to seek a Minor Use Permit to
modify parking requirements. For example,
through the Minor Use Permit, parking may
be allowed in tandem formation, or payment
of a parking in lieu fee could be possible. A
Minor Use permit would not add a significant
amount of time to the review period for a new
multi-family housing project, as the Review
Authority3 would review the application
for the Design Review concurrently. The
City’s parking standards are therefore not
considered a constraint to development. Even
so, to further encourage flexibility of parking
3 Review Authority is the individual or official city
body (the community development director,
planning commission, or city council) identified by
the Development Code as having the responsibility
and authority to review, and approve or disapprove
the permit applications described in Article 5
(Development Code Administration and Procedures).
arrangements for multi-family housing/stacked
flats, Program 4-6 is included in the Housing
Plan to study the City’s parking standards
for this type of development and consider
allowing surface format parking to meet
the requirement through carport structures
rather than garages. Any changes to parking
standards in the Zoning Code should also
include standards in to support parking
design.
Additionally, the City provides flexibility in
parking standards by having a clear process
for senior housing projects and mixed-
use projects to apply for a reduction of
requirements. The City understands that the
increase in cost potentially associated with
covered parking may constrain development
of affordable housing. As such, the City clearly
states in the Development Code that the
review authority may waive the requirement
that parking be covered for affordable
housing units. This process is completed as
part of a density bonus request, and does not
substantially add to the review or processing
times. The City has included Program H4-6 in
this Housing Element to ensure that this waiver
process is continued.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Table H-4.7: Parking Requirements
Dwelling Type Vehicle Spaces Required
Caretaker/manger unit 2 spaces for each unit
Rowhouse, townhome, and courtyard units:
• Studio and/or one bedroom unit
• Two to four bedroom units
• Five or more bedroom units
• Guest parking
• 1 space within a garage for each unit
• 2 spaces within a garage for each unit
• 3 spaces within a garage for each unit
• 1 space for each 3 units in a project with 5 or
more units
Duplex 2 spaces within a garage for each unit
Accessory dwelling unit (ADU)1 off-street parking space per unit or per
bedroom, whichever is less.
Live/work unit 2 spaces for each unit
Mobile home:
• Individual mobile home
• Mobile home within a mobile home park
• 2 spaces within a garage
• 2 spaces for each mobile home, plus 1
additional space for each four mobile
homes shall be provided for guest parking,
which shall be dispersed throughout the
park
Multi-family dwelling/stacked flats:
• Studio and/or one bedroom unit
• Two or more bedroom unit
• Guest parking for all of the above
• 1 covered space within a garage for each
unit
• 2 covered spaces within a garage for the
first two bedrooms, plus one additional
space, covered or uncovered, for each
additional bedroom
• 1 space for each 3 units in a project of 5 or
more units
Organizational house 1 space for each bedroom
Residential care home:
• Six or fewer clients
• Seven or more clients
• 2 covered spaces within a garage
• 1 space for each three beds, plus space for
on-site employee housing
Rooming or boarding house • 1 space for each bedroom
Senior housing project • 1 space for each unit in a garage, plus 1
guest parking space for each four units
Single-family dwelling, detached
2 spaces within a garage for a dwelling with 4 or
fewer bedrooms; 3 spaces within a garage for a
dwelling with 5 or more bedrooms
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Table H-4.7: Parking Requirements
Dwelling Type Vehicle Spaces Required
Residential uses in the TOD Specific Plan area:
• Studio and/or one bedroom unit
• Two or more bedroom units
• Guest parking
• 1 space/unit
• 1.5 spaces/unit
• Projects with only residential uses are
required to provide 1 guest parking space
for every 6 residential units. Mixed-use
projects containing residential uses are not
required to provide guest parking spaces.
Source: City of Azusa TOD Specific Plan, 2018.
Mixed-Use Development Standards
Nearly all of Azusa is developed; there is
an extremely limited amount of vacant land
within City limits. It is expected that the
City will need to rely on infill and mixed-use
development to provide increased residential
capacity within the City. Mixed-use projects
combine residential and nonresidential uses
on the same site, or within the same structure.
Residential units are typically located above
the nonresidential uses for what is defined as
a vertical mixed-use project. Residential units
may also be allowed at ground level behind
street-fronting nonresidential uses (horizontal
mixed use) under limited circumstances
with corresponding development and siting
standards. The General Plan recognizes the
importance and increased vitality provided
by mixed-use areas and permits mixed-
use within the following planning areas:
Neighborhood Center, Edgewood District,
Azusa Avenue Corridor, San Gabriel Avenue
Corridor, South Azusa Avenue Corridor, Arrow
Highway Corridor, and Foothill Boulevard
Corridor, as well as the TOD Specific Plan
area. Section 88.36.080 (Reduction of Parking
Requirements) allow for shared on-site
parking, reduction of the number of parking
spaces required through a variance process,
reduced parking for restricted senior housing
projects, and waivers for covered parking
requirements for affordable housing units.
Specific Plans
The City of Azusa has adopted several
specific plans that provide for further variety
in residential types and locations. There
are three large-scale plans with substantial
residential components:
• Azusa Pacific University Specific Plan
• Monrovia Nursery Specific Plan
• Azusa TOD Specific Plan
Azusa Pacific University Specific Plan
The City adopted the Azusa Pacific
University Specific Plan in 2006 to provide
a comprehensive development plan and
standards for the east and west campuses
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
of Azusa Pacific University. The Specific Plan
is divided into three phases, with student
housing included in each phase. Housing and
other master plan buildings will be pursued
as funding becomes available and as student
enrollment increases.
Monrovia Nursery Specific Plan (aka
Rosedale)
The Monrovia Nursery Specific Plan, now
developed as the Rosedale neighborhood,
lays out the vision for a master-planned
community of approximately 1,250 new
dwelling units where the former Monrovia
Nursery was in the northeastern portion of
Azusa (411 acres were annexed from Los
Angeles County in 2004 as part of the Specific
Plan process). The 517-acre project features
detached homes on minimum lot sizes of
4,000, 5,000, and 7,200 square feet, as well as
a transit-oriented development with attached
dwelling units adjacent to a future Gold Line
Station. The Specific Plan for this project
was adopted in 2004, but the economic
crisis of 2007/2008 caused the developers
to delay construction. Since 2012, however,
development within the Specific Plan area
resumed. As of 2021, most of the Specific Plan
area has been built out with limited capacity
to provide additional sites or units. The
developer is pursuing a minor modification
to the Specific Plan to allow for residential
development in an area previously planned
for institutional uses with the remaining
undeveloped portion.
Azusa Transit-Oriented Development
Specific Plan
Adopted in 2015 with amendments in 2017 and
2018, the overall vision of the Azusa Transit-
Oriented Development (TOD) Specific Plan
is to revitalize and renew the areas around
the light rail stations, Azusa’s Downtown and
adjacent residential neighborhoods. As shown
in Table H-4.8, the development standards
defined in the Specific Plan do not define
minimum or maximum densities but rather rely
on lot coverage and specific design standards
to guide the aesthetics of the area.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Table H-4.8: Residential Standards for Districts within the TOD Specific Plan
Development
Standard
Gold Line
District
Downtown
District
Downtown
Expansion
District
Route 66
District
Transition
District Civic District
Maximum
Density (units/
acre)
Determined through lot size, coverage and entitlements
Maximum Lot
Coverage 100%100%100%80%80%100%
Minimum
floor area per
dwelling unit
500 sf (studio)
600 sf (1-bed)
725 sf (2-bed)
875 sf (>3-bed)
500 sf (studio)
600 sf (1-bed)
725 sf (2-bed)
875 sf (>3-bed)
500 sf (studio)
600 sf (1-bed)
725 sf (2-bed)
875 sf (>3-bed)
500 sf (studio)
600 sf (1-bed)
725 sf (2-bed)
875 sf (>3-bed)
500 sf (studio)
600 sf (1-bed)
725 sf (2-bed)
875 sf (>3-bed)
500 sf (studio)
600 sf (1-bed)
725 sf (2-bed)
875 sf (>3-bed)
Minimum Set
Backs
Street: 0 ft
Side: 0 ft
Rear: 0 ft
Street: 0 ft
Side: 0 ft
Rear: 0 ft
Street: 0 ft
Side: 0 ft
Rear: 0 ft
Street: 5 ft
Side: 0 ft
Rear: 0 ft
Street: 10 ft
Side: 5 ft
Rear: 10 ft
None Defined
Min/Maximum
Building Height
Min: 25 ft
Max: 60 ft
Min: 25 ft
Max: 50 ft
Min: 25 ft
Max: 45 ft
Min: 20 ft
Max: 40 ft
Max: 35 ft
Source: City of Azusa TOD Specific Plan, 2018.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Density Bonus
Azusa encourages the development of
affordable housing through Chapter
88.32 (Affordable Housing Incentives of
the Development Code). This section of
the Development Code is intended to
implement the requirements of Government
Code §65915, which allow incentives for
the development of affordable housing for
low-income, moderate-income, and senior
households. The density bonus regulations
also allow for exceptions to applicable zoning
and other development standards to further
encourage development of affordable
housing. The City has not yet updated their
density bonus ordinance to be consistent
with the recent State legislative actions
passed that resulted in numerous changes
to the density bonus requirements under
Government Code §65915; Program H4-1 is
included in the Housing Element to revise the
Development Code to comply with State law.
Locally Adopted Ordinances
State law requires that cities include an
analysis of any locally adopted ordinance
that directly impacts the cost and supply of
residential development. The City of Azusa
does not have any requirements specific to
inclusionary housing and does not regulate
short-term rentals. The TOD Specific Plan,
a form-based code without site-specific
density limitations, does include an overall
development limit of 840 new units. The
development limit was established as part
of the CEQA Environmental Impact Report.
While the Specific Plan does have an overall
development limitation, it at the same
time allows for higher density residential
development and includes provisions for
flexibility and relief from development
standards that help reduce costs and increase
supply of residential development.
Building Codes and Enforcement
The City of Azusa has adopted and
implements the following California Building
Standards Codes (California Code of
Regulations, Title 24) and uniform codes
through Chapter 14 of the Municipal Code:
• The California Building Code, 2019
Edition, Volumes 1 and 2 (California
Code of Regulations, Title 24, Part 2)
• The California Residential Code, 2019
Edition (California Code of Regulations,
Title 24, Part 2.5)
• The California Electrical Code, 2019
Edition (California Code of Regulations,
Title 24, Part 3)
• The California Mechanical Code, 2019
Edition (California Code of Regulations,
Title 24, Part 4)
• The California Plumbing Code, 2019
Edition (California Code of Regulations,
Title 24, Part 5)
• The California Existing Building Code,
2019 Edition (California Code of
Regulations, Title 24, Part 10)
• The California Green Building
Standards Code, 2019 Edition
(California Code of Regulations, Title
24, Part 11)
• The International Swimming Pool, Spa
and Hot Tube Code, 2018 Edition;
published by the International Code
Council (ICC).
The City enforces code compliance to
promote property maintenance in accordance
with the City Development and Building
ordinances and State and County Health
Codes. The City of Azusa has not adopted any
local amendments to the model codes that
would substantially increase housing costs.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Enforcement of building code standards
does not constrain the production or
improvement of housing in Azusa, but
instead serves to maintain the condition
of the City’s neighborhoods. Further, the
California Building Code is adopted by many
cities throughout Southern California and
does not, in general, pose a constraint to
residential development. The mission of the
Code Enforcement Division and Development
Services Department is to promote
community awareness of, and encourage
voluntary compliance with, Azusa’s Municipal
Code. This enforcement enhances Azusa’s
neighborhoods and economic conditions
so that Azusa is a good place to live, raise a
family, work, and retire. Code Enforcement
staff investigate and enforce City codes and
State statutes when applicable. Violation
of a code regulation can result in a warning,
citation, fine, or legal action. If a code
violation involves a potential emergency,
officers will respond immediately; otherwise,
complaints are generally followed up within
one working day by visiting the site of the
alleged violation, and if necessary beginning
the process of correcting the situation either
through the permitting process or through
maintenance and rehabilitation actions that
are the responsibility of the owner.
Opportunities for Energy
Conservation
Planning to maximize energy efficiency and
the incorporation of energy conservation and
green building features can contribute to
reduced housing costs for homeowners and
renters, in addition to promoting sustainable
community design, reduced dependence
on vehicles, and reduced greenhouse gas
emissions. The City continues to achieve
incremental improvements in energy
conservation through implementation of
California’s Green Building Standards Code,
Title 24 of the California Code of Regulations,
known as CALGreen. CALGreen applies to the
planning, design, operation, construction, use,
and occupancy of every newly constructed
building or structures and also applies to
most additions and alterations to existing
buildings, including residential structures.
Efforts to educate the community about
energy conservation include the provision
of information regarding energy efficient
rehabilitation techniques and referrals to
energy conservation programs, including
handouts at the Building Counter and on
the City’s website. Also, all new homes and
apartment buildings up to three stories
in height are required to install a solar
photovoltaic (PV) system as an electricity
source, consistent with State law.
ON- AND OFF-SITE
IMPROVEMENTS
Site improvements are a necessary component
of the development process. Improvements
can include the planning and construction
of sewer, water, and streets for use by a
community when that infrastructure is
lacking, and these improvements make the
development feasible. Due to the built-out
nature of Azusa, residential areas are already
served with infrastructure. Site improvement
requirements vary depending on the
existing condition of each project. Typically,
requirements include the undergrounding of
utilities, provision of a fire sprinkler system,
ensuring the existence of one fire hydrant
within 250 feet from the property line, and
smoke detectors. Developers are required
to purchase and have the City install water
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
service pipes and meters, and may be
responsible for upgrading sewer laterals
or installing backflow prevention devices.
Portions of curbs, gutters, sidewalks and
driveways may be required to be replaced,
depending on their condition. Fees collected
for this work are commonly referred to as
System Development Charges.
PROVIDING FOR A VARIETY OF
HOUSING TYPES
The General Plan Built Environment Chapter
and the Development Code contain the basic
standards that allow for the development of
a variety of housing types in Azusa. Housing
Element law specifies that jurisdictions must
identify facilitate and encourage a range of
housing types for all economic segments of
the community. This includes single-family
housing, multi-family housing, mobile and
manufactured homes, emergency shelters,
and transitional housing, among others.
Various housing types are permitted within
residential areas of the neighborhood,
district, and corridor zones in the City; all are
summarized in Tables H-4.9, H-4.10, H-4.11,
and Table H-4.12 for the TOD Specific Plan.
Multi-Family Housing
A multi-family housing unit is defined in
Chapter 88.70 of the Development Code
as a dwelling unit that is part of a structure
containing one or more other dwelling units,
or a non-residential use in a mixed-use
project. Multi-family housing types include
courtyard, duplex, triplex, fourplex, flat,
townhouse, rowhouse, and stacked flats.
One or more of these types of multi-family
developments are permitted in the following
planning areas: medium- and moderate-
density Traditional, Transitional, and Tract
Neighborhoods, the Neighborhood Centers,
all University Districts, the Edgewood District,
and all Corridors. The maximum densities
are generally 15 dwelling units per acre in
medium-density neighborhoods and 27
dwelling units per acre in the other planning
areas. Multi-family housing is also permitted in
the TOD Specific Plan area as shown in Table
H-4.12.
Many of the zones in the City do not currently
permit stacked flats. Historically Azusa has
provided a disproportionately large share of
affordable housing for the San Gabriel Valley
region. In response to this, as part of the
General Plan update in 2001, new housing
in the form of townhomes was prioritized in
most existing neighborhoods. However, this
limitation can reduce the allowable density
based on this housing type and may be
inconsistent with the Housing Accountability
Act. As such, the City has included Program
H4-4 in the Housing Element to revise the
Development Code to allow stacked flats in
all neighborhoods, corridors, and districts
where currently townhomes are allowed, within
mixed-use arrangements and as stand-alone
residential.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Table H-4.9: Permitted Uses in Neighborhood Zones
Land Use Type
Permit Required by Zone
Specific Use
RegulationsNCNG1NG2NG3
L MED MOD L MED MOD L MED MOD
Residential Uses
Courtyard housing ----MUP MUP --MUP MUP --MUP MUP 88.42.140
Duplex ----P P --P P --P P 88.42.140
Live/work unit MUP ------------------88.42.110
Mixed use project
residential
component
P ------------------88.42.120
Mobile home park --UP UP UP UP UP UP UP UP UP 88.42.130
Mobile/
manufactured home --P P P P P P P P P 88.42.128
Residential
accessory use or
structure
--P P P P P P P P P 88.42.020
Second unit or
carriage house --P P P P P P P P P 88.42.190
Senior citizen
apartment ----MUP MUP --MUP MUP ----MUP 88.42.200
Single-family
dwelling --P P P P P P P P P
Stacked flats --------------------
Townhouses or
rowhouses ----MUP MUP --MUP MUP --MUP MUP 88.42.140
Triplex or fourplex ----MUP MUP --MUP MUP --MUP MUP 88.42.140
Day Care Facilities
Adult day care P MUP MUP MUP MUP MUP MUP MUP MUP MUP
Child day care-Small
family day care home --P P P P P P P P P
Child day care-Large
family day care home --MUP MUP MUP MUP MUP MUP MUP MUP MUP 88.42.060
Child day care center MUP MUP MUP MUP MUP MUP MUP MUP MUP MUP 88.42.060
Residential Care Facilities
Residential care, 6 or
fewer clients --P P P P P P P P P
Residential care, 7 or
more clients --MUP MUP MUP MUP MUP MUP MUP MUP MUP
Other Residential Use
Organizational
house (sorority,
monastery, etc.)
----MUP MUP --MUP MUP ------
Rooming or
boarding house --MUP MUP MUP MUP MUP MUP ------
Lodging-Bed and
breakfast inn --MUP MUP MUP P P P P P P
P = Permitted Use, Zoning Clearance
MUP = Minor Use Permit
UP = Use Permit
-- = Use not allowed
NC = Neighborhood Center L = Low Density
NG1 = Traditional Neighborhood MED = Medium Density
NG2 = Transitional Neighborhood MOD = Moderate Density
NG3 = Tract Neighborhood
Source: City of Azusa Development Code, 2021.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Table H-4.10: Permitted Uses in District Zones
Land Use Type
Permit Required by Zone Specific Use
Regulations
DE DW DWL DU-
MU
DU-
RM
DU-
RMO
Residential Uses
Caretaker/manager unit P P P P ----
Courtyard housing ------P MUP MUP 88.42.142
Duplex, triplex, fourplex --------P P 88.42.140
Emergency/Transitional shelter --P UP UP ----88.42.082
Live/work unit --MUP MUP P ----88.42.110
Mixed use project residential component
(not stacked flats)
P ----P ----88.42.120
Mixed use project residential component
(not stacked flats)-Phased
S ----S ----88.42.120
Residential accessory use or structure ------P P P 88.42.020
Senior citizen apartment MUP ----MUP MUP MUP 88.42.200
Single- Family dwelling N/A N/A N/A MUP MUP MUP
Single room occupancy facility ------MUP MUP MUP
Stacked flats as part of a vertical mixed
use project
------MUP ----88.42.120
Townhouses or rowhouses ------P --MUP 88.42.140
Triplex or Fourplex --P P
Day Care Facilities
Child day care-Large family day care
home
------P MUP MUP 88.42.060
Child day care-Small family day care home ------P P P 88.42.060
Day care center-Child or Adult MUP --MUP P MUP MUP 88.42.060
Residential Care Facilities
Residential care, 6 or fewer clients ------P P P
Residential care, 7 or more clients ------MUP MUP MUP
Other Residential Use
Organizational house (sorority, monastery,
etc.)
------MUP MUP MUP
Rooming or boarding house ------P P P
Lodging - Bed and breakfast inn ------P ----
Lodging - Hotel or motel ------P ----
P = Permitted Use, Zoning Clearance
MUP = Minor Use Permit
UP = Use Permit
S = Permit requirement by Specific Use
Regulations
-- = Use not allowed
DE = Edgewood District
DU-MU = University District-Mixed Use
DU-RM = University District-Residential Medium
DU-RMO = University District-Residential Moderate
DW = West End Industrial District
DWL= West End Light Industrial
Source: City of Azusa Development Code, 2021
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Table H-4.11: Permitted Uses in Corridor Zones
Land Use Type Permit Required by Zone Specific Use
Regulations
CAZ CSG CSA CAH CFB
Residential Uses
Courtyard housing MUP MUP MUP MUP MUP 88.42.100
Duplex, triplex, fourplex P P ----P 88.42.110
Live/work unit P P P P P
Mixed use project residential component (not
stacked flats)
P P P P P 88.42.120
Residential accessory use or structure P P P P P
Second unit or carriage house P P ----P
Senior citizen apartment MUP MUP MUP MUP MUP
Single-family dwelling --P ------88.42.120
Stacked flats ----------
Townhouse or rowhouse P P P P P 88.42.190
Day Care Facilities
Day care center-Child or Adult MUP MUP MUP MUP MUP 88.42.060
Residential Care Facilities
Residential care, 6 or fewer clients P P P P P 88.42.140
Residential care, 7 or more clients P P P P P
Other Residential Use
Organizational house (sorority, monastery, etc.)MUP MUP MUP MUP MUP
Rooming or boarding house P P ----P
Lodging-Bed and breakfast inn P P P P P
Lodging-Hotel or motel P --P P P
P = Permitted Use, Zoning Clearance
MUP = Minor Use Permit
UP = Use Permit
-- = Use not allowed
CAZ = Azusa Avenue Corridor
CSG = San Gabriel Avenue Corridor
CSA = South Azusa Avenue Corridor
CAH = Arrow Highway Corridor
CFB = Foothill Boulevard Corridor
Source: City of Azusa Development Code, 2021
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Du-/Tri-/Fourplex --P P P P --
Multi-family P P P P P --
Live-work MUP MUP MUP P MUP --
Townhouse, Rowhouse ----P P ----
Senior housing P P P P P MUP
Home Occupations P P P P P --
Courtyard Housing --P P P P --
Single Family --------P --
Residential Accessory
Structure
P ----P P --
Residential Care (6 or fewer
clients)
------P P --
Residential Care (Seven or
More clients)
MUP P P P ----
Source: City of Azusa TOD Specific Plan, 2018
Accessory Dwelling Units
Formerly known as a Second Unit or Carriage
House, an Accessory Dwelling Unit (ADU) is
a residential dwelling unit that is detached
from, attached to, or located within the living
area of an existing primary dwelling unit on
the same site. The Accessory Dwelling Unit
provides independent living facilities for one
or more persons with a kitchen and bathroom
facility.
An ADU can be an important source of
affordable housing since they are smaller than
primary units and do not have direct land
acquisition costs. ADU development expands
housing opportunities for very low-, low-, and
moderate-income households by increasing
the number of rental units available within
existing neighborhoods.
In recent years, the State Legislature
has passed numerous changes to ADU
requirements to promote the development
of ADUs. These include allowing ADUs to
be built concurrently with a single-family
home, opening areas where ADUs can
be built to include all zoning districts that
allow single-family uses, allowing ADUs in
multi-family developments, modifying fees
from utilities such as special districts and
water corporations, and reducing parking
requirements. The City last updated its ADU
ordinance in 2020. In Azusa, consistent with
the Government Code Section 65852.2,
ADUs are permitted by right in residential
zones and are subject to development
standards permitted by State law. The City
also adopted a clear process for the City to
review and approve ADUs that do not qualify
for ministerial review (e.g., second-story ADUs),
including noticing procedures, development
Table H-4.12: Permitted Uses in Districts within the TOD Specific Plan
Permit Required by Zone
Gold Line
District
Downtown
District
Downtown
Expansion
District
Route 66
District
Transition
District
Civic
District
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
standards, and appropriate findings. Certain
development standards are not consistent
with State law, as identified by HCD. The City
will work with HCD to address areas of the
ordinance that are out of compliance, and
adjust accordingly.
In addition, to provide additional clarity, the
City will also modify the allowable use tables
to remove “second units/carriage house”
and replace this terminology with “accessory
dwelling uses”, clearly allowing these uses in
all zones that allow residential uses. Program
H3-4 in the Housing Plan commits the City to
updating the ADU ordinance to comply with
Government Code Section 65852.2, continue
to update the ordinance as State law evolves,
and to conduct community outreach to inform
residents of ADU development opportunities.
Senior Housing
The City recognizes that the housing needs
of older residents may differ from those of
the general population in terms of dwelling
size, unit accessibility, parking requirements,
and housing affordability, among other
considerations. To facilitate these reductions,
senior housing is permitted at a density of
up to 40 units per acre in all residential base
zones.
In determining whether to grant a use permit
for senior apartments, or, if granted, the
nature and extent of conditions to impose
of the permit, the Planning Commission
considers the following:
• The nature and use of real property
within 500 feet of the proposed site.
• Adequate buffering from incompatible
land uses through the use of increased
setbacks, landscaping, screening walls,
the location of windows, and building
design and orientation.
• Access and proximity to shopping
areas, medical services, public transit
stops, and other providers of needs
particular to senior citizens.
• Appropriate common open space and
recreational facilities.
Additionally, the City encourages the
development of senior projects by providing
concessions on property development.
Minimum parking requirements for senior
housing are lower than other types of multi-
family housing. Further, the City may reduce
the number of parking spaces required for
senior housing projects based on quantitative
information provided by the applicant that
documents the need for fewer spaces for
these types of residential development
projects. To further facilitate senior housing
in Azusa, Program H3-3 is included in the
Housing Element to remove the requirement
for a use permit for senior housing.
Emergency Shelters
Emergency shelters are facilities for the
temporary shelter and feeding of homeless,
disaster victims, or persons facing other
difficulties, such as domestic violence.
Currently, these facilities are permitted by
right in the West End Industrial District, and
with a Use Permit in the West End Light
Industrial District and the University District-
Mixed Use.
The West End Industrial District
accommodates a wide range of
manufacturing, industrial, and commercial
uses. The West End Industrial District is
located in the southwestern area of the City,
south of the 210 Freeway and north of Arrow
Highway, and is bounded by Vernon Avenue
on the east and the City of Irwindale on
the west. The standards for this district are
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
intended to accommodate a full range of light
and medium-intensity manufacturing and
industrial activities, and automotive services.
Caretaker’s quarters and live-work units are
also allowed in this District.
The West End Industrial District area
encompasses over 215 acres and has sufficient
capacity for at least one year-round shelter.
Realizing the expense associated with new
construction, Azusa identified this zone
to have a mix of medium- to large-sized
buildings that could transition to reuse as
homeless shelters. There are multiple lots
that are underutilized. Properties in the West
End Industrial District are served by regional
transportation options, with ready access
to the 210 Freeway and major roads such as
Irwindale Avenue, Foothill Boulevard, Arrow
Highway. In addition, Foothill Transit operates
at least three different bus routes that service
this area, with bus stops located at Irwindale
Avenue and Gladstone Street and Irwindale
Avenue and Foothill Boulevard.
Based on the size of the zone identified,
opportunities for adaptive reuse of existing
buildings, and ready access to services
and transportation, the zone has sufficient
capacity to accommodate the City’s homeless
need in at least one year-round shelter.
(In 2019, there was a total of 329 homeless
individuals in Azusa, 94 percent of which were
unsheltered.)
The development and management
standards for emergency shelters in the
Azusa Development Code (Section 88.42.082)
were drafted to be consistent with State law.
Specific provisions for emergency shelters in
Azusa specify:
• The emergency shelter shall contain a
maximum of 30 beds and shall serve no
more than 30 homeless persons at any
one time.
• Onsite management of the facility shall
be required during all open hours of
operation.
• Occupancy by an individual or family
may not exceed 180 consecutive days
unless the management plan provides
for longer residency by those enrolled
and regularly participating in a training
or rehabilitation program. Services
shall be provided to assist residents to
obtain permanent shelter, income, and
services. No individual or household
may be denied emergency shelter
because of an inability to pay.
• Adequate external lighting shall be
provided for security purposes. The
lighting shall be stationary, directed
away from adjacent properties and
public rights-of-way. The intensity shall
comply with standard city performance
standards for outdoor lighting.
• The emergency shelter provider/
operator shall have a written
management plan including, as
applicable, provisions for staff training,
neighborhood outreach, transportation
issues, security, screening to ensure
compatibility with services provided at
the facility, and for training, counseling,
and treatment programs for residents.
• The emergency shelter facility shall
demonstrate that it is in and maintains
in good standing with County and/
or State licenses, if required by these
agencies for the owner(s), operator(s),
and/or staff on the proposed facility.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
• One parking space for each five
beds and two additional spaces are
required. Given that most shelter
residents do not require parking and
two additional spaces are required
(anticipated to allow for employee
parking), the minimum standards are
adequate. Shelters are also able to
provide additional parking beyond
the minimums required by the
Development Code, if more parking is
needed for employees.
• Interior onsite waiting and client intake
areas must be at least 200 square feet.
Outdoor onsite waiting areas may be a
maximum of 100 square feet, and must
be located within 50 feet of the public
right-of-way.
• No more than one emergency shelter
shall be permitted within a radius of
300 feet of another such facility.
• The development may provide one
or more common facility areas for the
exclusive use of residents, including
central cooking and dining rooms,
recreation room, counseling center,
child care facility and other support
services.
As part of a countywide initiative, Azusa along
with Covina, Duarte, Glendora and West
Covina received funds through LA County’s
Measure H Initiative to support the County’s
Homeless Initiative. The five cities received a
total of $343,250 in January 2019 to provide
Centralized Entry System (CES) assessment
and intake, housing navigation/intensive
case management services for homeless
persons in the East San Gabriel Valley, with
one housing navigator located in each of the
participating cities. At the end of May 2019,
the City of Azusa was selected for additional
funds under the 2018 Cities’ Homelessness
Plan Implementation Request for Proposal
to build capacity to reduce the impact of
homelessness by expanding on the existing
work of Neighborhood Connections, a library-
based program, to establish a community-
wide approach to homeless solutions and
better route for community members
experiencing homelessness into and through
the initial Centralized Entry System.
Recent State Law AB 101 requires that Low-
Barrier Navigation Centers be allowed by
right in areas zoned for mixed-use and
nonresidential zones permitting (by right or
conditionally) multi-family uses. Program H4-2
is included in the Housing Element indicating
that the City will revise the Development
Code to ensure that the regulations satisfy the
requirements of AB 101.
Transitional and Supportive Housing
State law requires cities to allow transitional
and supportive housing as a residential use
and allowed by right in all zones that allow
similar residential uses, consistent with SB2.
Supportive Housing is a model that is targeted
to support those who have experienced
long-term or chronic homelessness because
of drug abuse, disabilities or a persons who
have a long history of homelessness. Using
a combination of affordable housing with
social services for individuals and families,
supportive housing programs are centered
around efforts to permanently keep those in
the program from becoming homeless again.
Transitional housing is a type of supportive
housing, which provides longer-term housing
(up to two years), coupled with supportive
services such as job training and counseling, to
individuals and families who are transitioning
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
to permanent housing. In Azusa, transitional
and supportive housing are considered
single-family or multi-family uses and are thus
held to the same development standards as
other residential uses of the same type in the
same zone. However, the Development Code
does not currently define transitional housing.
Program H4-2 is included in the Housing
Element to provide a definition of transitional
housing and indicate that it is allowed in the
same manner as other residential uses in each
applicable zone
Effective January 1, 2019, AB 2162 (Supportive
Housing Streamlining Act) requires supportive
housing to be considered a use by right in
zones where multi-family and mixed-uses are
permitted, including nonresidential zones
permitting multi-family uses, if the proposed
housing development meets specified criteria.
The Development Code does not currently
define supportive housing. Program H4-2 is
included in the Housing Element to provide
a definition of supportive housing and clearly
indicate that it is a use allowed by right. The
law prohibits the local government from
imposing any minimum parking requirement
for units occupied by supportive housing
residents if the development is located within
one-half mile of a public transit stop. AB
2162 also require local entities to streamline
the approval of housing projects containing
a minimum amount of supportive housing
by providing a ministerial approval process,
removing the requirement for CEQA analysis,
and removing the requirement for a CUP
or other similar discretionary entitlements.
Program H4-2 is included in the Housing
Element to ensure compliance with this new
law.
Mobile Homes
According to the California Department of
Finance, 554 mobile home units existed in
the City as of January 2019. Individual mobile
homes installed on a foundation system are
treated as single-family dwellings in Azusa,
and they are permitted in all neighborhoods
(except Neighborhood Centers). As such, they
must comply with all zoning, subdivision, and
development standards applicable to any
conventional single-family dwelling unit that
could be built on the parcel.
Chapter 14 (Buildings and Building
Regulations) of the Municipal Code states
that “the use of manufactured housing for
residential purposes is permitted, but only
in those zones where such a structure is
specifically indicated to be a permitted use.”
However, because manufactured housing is
treated as a single-family dwelling, the zones
do not specifically indicate manufactured
housing as a permitted use. Furthermore,
Section 88.42.128 includes a requirement
that manufactured homes shall have an
eave and gable overhangs of not less than
12 inches and the roof pitch shall be no less
than 5:12. Program H3-5 is included in the
Housing Element to modify this section of
the Building Code to comply with State law,
and to remove the design requirements in the
Development Code to allow for flexibility as
the manufactured housing market evolves.
Farmworker / Agricultural Employees
Housing
The Employee Housing Act (Government
Code Section 17021.5 and 17021.6) requires
that any employee housing occupied by six
or fewer employees shall be considered a
single-family structure within a residential
land use and must be treated the same as
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
a single-family dwelling of the same type
in the same zone. In addition, employee
housing consisting of no more than 36
beds in a group quarters, or 12 units or
separate rooms or spaces designed for use
by a single-family or household, must be
considered an agricultural land use and be
treated the same as any other agricultural
activity in the same zone. The City of Azusa
does not have land zoned for or remaining
in agricultural use and does not have any
inventory of farm housing. Therefore, none
of the zoning districts specifically distinguish
housing for Agricultural Employees from any
other programmatic housing dedicated or
developed to be affordable.
Single-Room Occupancy Housing
Single-room occupancy hotels and/or
boarding homes are collectively referred to as
SROs. SRO units are one-room units intended
for occupancy by a single individual. It is
distinct from a studio or efficiency unit, in that
a studio is a one-room unit that must contain
a kitchen and bathroom. Although SRO
units are not required to have a kitchen or
bathroom, many SROs have one or the other.
SROs are allowed with a Minor Use Permit in
the DU-MU, DU-RM, and DU-RMO Districts.
The Development Code allows for rooming/
boarding houses in a variety of corridors
and districts, including as a permitted use
in the Azusa Avenue, San Gabriel Avenue,
and Foothill Boulevard Corridors and in the
University Districts.
HOUSING FOR PERSONS WITH
DISABILITIES
Housing element law requires that, in
addition to the needs analysis for people with
disabilities, the Housing Element must analyze
potential governmental constraints to the
development, improvement, and maintenance
of housing for people with disabilities;
demonstrate local efforts to remove any
such constraints; and provide for reasonable
accommodations for persons with disabilities
through programs that remove constraints.
Zoning and Land Use
A residential care facility is a single-family
dwelling unit or multi-unit facility licensed
or supervised by a Federal, State, or local
health/welfare agency that provides 24-hour
nonmedical care of unrelated persons who
are handicapped and in need of personal
services, supervision, or assistance essential
for sustaining the activities of daily living or
for the protection of the individual in a family-
like environment. Under State Lanterman
Developmental Disabilities Services Act
(“Lanterman Act”), small State-licensed
residential care facilities for six or fewer
persons must be permitted in all zones that
allow single- or multi-family uses, subject to
the same permit processing requirements and
development standards; Azusa is compliant
with the Lanterman Act. In addition, to provide
additional opportunities for residential care
facilities, large residential care facilities with
more than six persons are permitted by right
in all Corridors and with a Minor Use Permit
(MUP) in the University District and in all
neighborhood zones except Neighborhood
Center.
The MUP process applicable in the University
District and Neighborhood Zines is not a
constraint to development of large residential
care facilities. The MUP process is conducted
at the staff level with review and approval
by the Zoning Administrator; no public
hearing is required. The MUP process is
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
intended to serve the important functions
of providing a project with conditions of
approval and allowing assessment of each
individual site. When MUPs are approved,
standard conditions are attached. The City
is currently (in 2021) reviewing standards
and procedures for group homes, large
residential care facilities, and reasonable
accommodation procedures to allow for
consistent implementation of regulations and
streamlining. Program H-5.1 in the Housing
Plan includes an action item to review the
standards and processing procedure for
residential care facilities to ensure that these
uses are treated objectively and do not
discriminate against persons with disabilities.
As stated above, the City has adopted the
California Building Code. Standards within
the Code include provisions to ensure
accessibility for persons with disabilities.
These standards are consistent with
the Americans with Disabilities Act. No
local amendments that would constrain
accessibility or increase the cost of housing
for persons with disabilities have been
adopted. To accommodate disabled persons
in public facilities, the City defers to Title 24 of
the California Handicap Accessibility Code.
Definition of Family
The definition of “family” may limit access
to housing for persons with disabilities when
municipalities narrowly define the word,
illegally limiting the development of group
homes for persons with disabilities, but not
for housing similar sized and situated families.
The Azusa Development Code does not
discriminate nor limit access to housing for
persons with disabilities because it does not
define “family”.
Reasonable Accommodation
Both the Federal Fair Housing Act and the
California Fair Employment and Housing
Act direct local governments to provide
reasonable accommodation to rules,
policies, practices, and procedures where
such accommodation may be necessary
to afford individuals with disabilities equal
housing opportunities. While fair housing
laws intend that all people have equal access
to housing, the law also recognizes that
people with disabilities may need extra tools
for equity. Reasonable accommodation is
one of the tools intended to further housing
opportunities for people with disabilities.
For developers and providers of housing
for people with disabilities who are often
confronted with siting or use restrictions,
reasonable accommodation provides a means
of requesting from the local government
flexibility in the application of land use and
zoning regulations or, in some instances, even
a waiver of certain restrictions or requirements
because it is necessary to achieve equal access
to housing. Cities and counties are required
to consider requests for accommodations
related to housing for people with disabilities
and provide the accommodation when it is
determined to be “reasonable” based on fair
housing laws and the case law interpreting the
statutes.
State law allows for a statutorily based four-
part analysis to be used in evaluating requests
for reasonable accommodation related to
land use and zoning matters and can be
incorporated into reasonable accommodation
procedures. This analysis gives great weight
to furthering the housing needs of people
with disabilities and also considers the
impact or effect of providing the requested
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
accommodation on the City and its overall
zoning scheme. Developers and providers
of housing for people with disabilities must
be ready to address each element of the
following four-part analysis:
• The housing that is the subject
of the request for reasonable
accommodation is for people with
disabilities as defined in federal or
state fair housing laws;
• The reasonable accommodation
requested is necessary to make
specific housing available to people
with disabilities who are protected
under fair housing laws;
• The requested accommodation will
not impose an undue financial or
administrative burden on the local
government; and
• The requested accommodation will not
result in a fundamental alteration in the
local zoning code.
To create a process for making requests for
reasonable accommodation to land use and
zoning decisions and procedures regulating
the siting, funding, development, and use of
housing for people with disabilities, the City
established a reasonable accommodation
process in 2012. The City provides notice
to the public of the availability of an
accommodation process at all counters
where applications are made for permits and
licenses, and on the City’s website.
Reasonable accommodation requests are
reviewed by the Azusa Community and
Economic Development Director. Decisions
are appealable to the Planning Commission.
As noted in the application, flexibility and/
or waivers of certain restrictions shall be
provided if the following four elements are
determined to be true based on substantial
evidence provided by the applicant:
• The housing that is the subject of the
request for reasonable accommodation
is for people with disabilities as defined
in federal or state fair housing laws;
• The reasonable accommodation
requested is necessary to make specific
housing available to people with
disabilities who are protected under fair
housing laws;
• The requested accommodation will
not impose an undue financial or
administrative burden on the local
government; and
• The requested accommodation will not
result in a fundamental alteration in the
local zoning code.
As of 2021, the City is currently reviewing
standards and procedures for group homes,
large residential care facilities, and reasonable
accommodation procedures to allow for
consistent implementation of regulations and
streamlining. Program H-5.7 is included in the
Housing Plan to re-evaluate the procedures
in place to ensure consistent application and
clarity.
FEES AND EXACTIONS
Housing construction imposes certain short-
and long-term costs upon local government,
such as the cost of providing planning services
and inspections. As a result, the City relies
upon various planning and development fees
to recoup costs and ensure that essential
services and infrastructure are available when
needed. Impacts fees are also charged to
cover the cost of providing municipal services
or mitigating project impacts. These fees are
summarized in Table H-4.13. The total amount
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
of fees varies from project to project based
on type, existing infrastructure, and the cost
of mitigating environmental impacts. School
fees are managed by separate districts.
The City assesses various fees to cover the
costs of permit processing (Table H-4.13).
Most of the fees charged are flat fees based
on the cost of services, with a few fees
dependent on the size of the project. State
law requires that locally imposed fees must
not exceed the estimated reasonable costs of
providing the service. Azusa abides by State
law with respect to fees and exactions.
The City also charges impact fees to ensure
that services and infrastructure are in place to
serve planned developments (Table H-4.13).
State law requires that impact fees have a
substantial nexus to the development and that
the dedication of land or fees be proportional
to its impact. Although impact fees and
requirements for offsite improvements
add to the cost of housing, these fees and
requirements are necessary to maintain the
quality of life within a community. Azusa’s
impact fees include a Quimby park fee and a
water development fee. The fees are intended
to provide funds to recoup the cost of
providing infrastructure to the developments,
while not unduly constraining the feasibility of
both market-rate and affordable housing.
Table H-4.13: Planning, Building, and Impact Fees
Permit Type Azusa
General Plan Amendment (deposit)$17,250.00
Zone Change (deposit)$5,750.00
Specific Plan (deposit)$11,500.00
Specific Plan Amendment (deposit)$5,750.00
Use Permit $7,147.25
Modification to Use Permit $3,590.00
Minor Use Permit (MUP)$1,361.60
Modification to MUP $752.10
Variance for single family residential
Property
$1,150.00
Variance for all others $6,097.30
Minor Variance $1,841.15
Zoning Clearance (over the counter)$132.35
Preliminary Plan Review $2,211.45
Design Review:
Minor $2,441.45
Director’s review $5,476.30
Major Project review (deposit)$11,500.00
Tentative Parcel Maps $10,042.95
Tentative Tract Maps:
5-20 lots $10,476.50
20-50 lots $12,210.70
50-100 lots $16,450.75
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
100+ lots $18,378.15
Lot Line Adjustment $2,212.60
Lot Merger $2,122.90
Reversion to Acreage $3,401.70
Certificate of Compliance $1,805.50
Condominium Conversion $7,990.20
Accessory Dwelling Unit Permit:
Plan Check Only (Conversions of existing
structures)
$132.35
Over the Counter Permit (New construction)$302.52
Discretionary Permit (Does not comply with
regulations)
$2,441.45
Environmental Review:
Categorical Exemption Review $409.40
Initial Study $6,075.45
EIR Preparation $11,500.00
EIR Review $11,500.00
Mitigated Negative Declaration $11,500.00
Building Permit Fees Varies depending on the type and complexity of
project
Technology Enhancement Fee 5% of building permit fees
General Plan Fee 10% of building permit fees
Table H-4.13: Planning, Building, and Impact Fees
Permit Type Azusa
Capital Facilities/Impact Fees SFR MFR (Per Unit)
Parks (Quimby Fee): 1 bedroom
2 bedroom
3 bedroom
4 bedroom
Mobile home unit
$150.00
$300.00
$450.00
$600.00
$150.00
$150.00
$300.00
$450.00
$600.00
$150.00
Water and Sewer Water System Development Fee: $2,091
Water Service Installation Fee: Time & Material + 7% overhead, ($4,000
deposit)
Sewer Hook-Up: $3.00/linear foot of frontage to roadway
School $3.36/square foot $2.95/square foot
Source: City of Azusa, 2021 Adopted Fee Schedule.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Most, if not all, developers consider any fee a
significant constraint to the development of
affordable housing. For affordable housing
projects, financing generally includes some
form of state or federal assistance, with
rents set through the funding program. As
such, fees cannot and do not increase the
rents. Although the various fees account
for a significant portion of the development
cost, the fees collected are necessary to pay
for much needed infrastructure and to help
mitigate new growth throughout the city.
Table H-4.14 identifies the average fees that
are collected for a new single-family house, a
small multifamily project, and a large multi-
family project. Development fees make
up approximately seven to 11 percent of
a home purchase price. The City of Azusa
fees are typical for most communities and
are comparable to those of surrounding
communities. The Azusa median home
price in September 2020, based information
provided by CoreLogic, was $495,500. This
was three percent higher than the median
price in 2019. The median home price in
Los Angeles County in September 2020 was
$710,000, nearly double the median price
Azusa. As such, fees may represent a larger
portion of development cost in Azusa than
other areas of the County not because fees are
higher, but because housing sale prices and
rents are lower.
DEVELOPMENT REVIEW AND
PERMIT PROCESSING
Processing and permit procedures may pose a
considerable constraint to the production and
improvement of housing. Common constraints
include lengthy processing time, unclear
permitting procedures, layered reviews,
multiple discretionary review requirements,
and costly conditions of approval. These
constraints increase the final cost of housing,
uncertainty in the development of the project,
and overall financial risk assumed by the
developer.
Table H-4.14: Proportion of Fee In Overall Development Cost
Development Cost for
a Typical Unit Single-Family Small Multi-Family
Project
Large Multi-Family
Project
Total estimated fees per
unit $36,382 $40,355.36 $46,248.90
Typical estimated cost
of development per
unit
$253,153.00 $293,528.83 $254,430.26
Estimated proportion
of fee cost to overall
development cost per
unit
14%14%18%
Estimated sales price
per unit $495,500 $435,000 $435,000
Estimated proportion
of fee cost to sales price
per unit
7%9%11%
Source: City of Azusa, 2021; Corelogic, 2020.
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Table H-4.15: Timelines for Permit Procedures
Type of Approval, Permit, or Review Typical Processing Time
These time periods begin when a complete application is submitted and are extended when additional
information is requested by the City. The timeframes below are target issuance date—when the applicant can
expect a decision on their application.
Use Permit/Minor Use Permit
Use Permit – 2-6 months
Minor Use Permit – 2-4 months
Zoning Amendment (Zone Change)6-12 months
General Plan Amendment 6-12 months
Design Review 2-4 months (usually depending on how many
rounds of corrections with applicant)
Tract Maps 3-6 months
Parcel Map 3-6 months
Initial Environmental Study 3-6 months
Environmental Impact Report 6-12 months
Source: City of Azusa, 2021.
Table H-4.16: Typical Processing Procedures by Project Type
Single Family
Unit Subdivision
Multi-family
< 20 units
Multi-family
> 20 units
Typical
Approval
Requirements
Design Review Tentative Map (in conjunction
with Design Review)
Design Review;
MUP only for
exceptions (such as
tandem parking)
Design Review;
MUP only for
exceptions (such as
tandem parking)
Building Permit
plan check
Planning Commission TTM
Approval
City Council Final Map
Approval
Building Permit Plan Check
Building Permit
plan check
Building Permit
plan check
Permitting: May obtain permits once all clearances are obtained from all departments (fees paid,
plan check complete, etc.).
Inspection: Inspection conducted by all appropriate depts once construction is complete. Once all
depts. sign off, C of O is obtained by applicant.
Est. Total
Processing
Time
Planning = 30 calendar day review period (per Permit streamlining act) for every submittal/
correction. Typical approval time is anywhere from 2-4 months.
Plan Check = 10 business day plan check periods. Typical approval depends on how many rounds
of corrections (anywhere from 1-6 months).
Note: Processing times may vary by sq. ft., building type, design, complexity and volume of workload; inspection times not included
Source: City of Azusa, 2021
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Processing Timelines
The City of Azusa’s development review
process is designed to accommodate
housing development applications of various
levels of complexity and requiring different
entitlements. Processing times vary with
the complexity of the project. The tables
below outline the typical timelines for various
residential projects in Azusa. Table H-4.15
focuses more specifically on the individual
entitlement approvals that may be required,
providing estimated processing timelines
for each as well as identifying the approving
body. Table H-4.16 generally identifies the
typical approvals required for single-family
and multi-family projects along with the
estimated processing times of the planning
and building departments.
Streamlining
In response to State law, California cities are
required to improve the efficiency of permit
and review processes by providing “one-stop
processing.” The City of Azusa received an
SB 2 grant to fund a City Hall-West Wing
remodel, transforming the Economic &
Community Development Department into
one-stop “Permit Center” to allow for a
more streamlined submittal and application
review process. Additionally, the SB 2 grant
has funded a new Land Management System
software to allow for permit tracking and
streamlining, including coordination with
agencies such as Azusa Water and Light.
The City offers applicants preliminary site
plan/cursory review as a free service via
e-mail, to provide preliminary feedback
on project compliance with regulations
and support the development application
process. The City also provides a Preliminary
Plan Review (architectural plan set) for a small
fee prior to formal submittal of entitlement
application, to provide feedback to applicants
throughout their plan development process.
To encourage and facilitate the development
of a variety of housing types, City staff
continues to monitor permit processing times
to ensure the fastest possible turnaround
for applications. The City fully implements
the provisions of the Permit Streamlining
Act, which limits processing times for
entitlements to a 30-day review period and
60 days for a hearing. Local processing times
are comparable to those experienced in
neighboring communities. Plans are accepted
electronically, and with Land Management
System software, it is anticipated that further
streamlining will be achieved.
In 2021, the City is pursuing a comprehensive
nexus study for development fees to right-
size fees and streamline the process of fee
estimation (saving time in the application
process). The City plans to complete the
comprehensive nexus study in 2022. Also,
the City is committed to updating standards
and permit streamlining to comply with
recent State legislation. The City has initiated
an update to all application handouts and
is creating “how-to” videos and an online
resource page that describes development
policies and process.
Development Review Requirements
Table H-4.17 summarizes the Development
Review requirements in Azusa, indicating
the review authority for a variety of planning
decisions.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Table H-4.17: Development Review Requirements
Type of Decision
Role of Review Authority*
Director Zoning
Administrator
Planning
Commission City Council
Administrative and Legislative Decisions
Development Code
Interpretations D --A A
General Plan or Zoning
Amendments, Specific Plan,
or Development Agreement
R --R D
Planning Permit Decisions
Zoning Clearance D ------
Design Review**D D D/A A
Minor Use Permit R D A A
Use Permit R --D A
Minor Variance R D A A
Variance R --D A
(*) “Recommend” (R) means that the Review Authority makes a recommendation to a higher decision-making body; “Decision”
(D) means that the Review Authority makes the final decision on the matter. The Review Authority may consider and decide upon
appeals (A) to the decision of an earlier decision-making body, in compliance with Division 88.56 (Appeals).
(**) Decisions on Design Review are by the Director, except that where the project also requires discretionary planning permit
approval (i.e., Minor Use Permit, Use Permit, Minor Variance, or Variance), Design Review shall instead be by the review authority for
the other discretionary planning permit.
Source: City of Azusa Development Code Administration and Procedures, Ch. 88.50-Planning Permit Filing and Processing
Ministerial Review
Many minor permits are issued requiring
only “over-the-counter” approval, such as for
residential room additions and residential
rehabilitation permits (plumbing, electrical,
roofing). For accessory dwelling units
(ADUs), no discretionary review process is
required (assuming the proposed residence
meets of all the zoning requirements). For
ADUs located within an existing structure
(conversion of existing space) the application
can proceed directly to plan check. For new
structures, ADUs are issued an “Over the
Counter Permit,” with Planning Department
staff reviewing the application for compliance
with zoning standards. To ensure high-
quality design and compliance with all zoning
regulations, all other residential applications
for new construction are subject to the Design
Review process, described below.
Design Review
The Design Review process ensures that
the design of proposed development and
new land uses are maintained and enhance
the aesthetics of a community. The process
provides for the review of the design for new
single-family dwellings, multi-family projects,
second floor additions to existing dwellings,
alterations to façade visible from a street,
ground floor additions that increase existing
floor area by more than 29 percent of 499
square feet, and non-residential projects,
including permanent outdoor sales and
displays, news and flower stands, and outdoor
dining.
As part of the Design Review process, each
application is reviewed by the Community
Development Director to ensure that the
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
proposal complies with all applicable
requirements in Chapter 88.22 and 88.51.032
of the Development Code, which include:
appropriate and compatible design,
massing, and scale of buildings with the site
surroundings and the community; attractive
and desirable site layout and design;
efficient and safe public access, circulation,
and parking; and appropriate open space
and landscaping. Similar to the Use Permit
process, there are 6 findings that must be
found to approve a Design Review project:
1. Provides architectural design, building
massing and scale appropriate to and
compatible with the site surroundings
and the community;
2. Provides attractive and desirable site
layout and design, including, but not
limited to, building arrangement,
exterior appearance and setbacks,
drainage, fences and walls, grading,
landscaping, lighting, signs, etc.;
3. Provides efficient and safe public
access, circulation and parking;
4. Provides appropriate open space and
landscaping, including the use of water
efficient landscaping;
5. Is consistent with the general plan any
applicable specific plan, development
agreement, and/or any previously
approved planning permit; and
6. Complies with all applicable
requirements of this Development
Code, and any other adopted city
design standards, guidelines, and
policies.
Design Review is completed at the Director
level, unless the proposed project also
requires the approval of a discretionary
planning permit (i.e., use permit, variance), in
which case the Planning Commission becomes
the review authority. For multi-family projects,
applications are subject to Design Review
process, typically an eight-week process from
the time an application is filed and the project
is approved.
Azusa’s form-based Development Code
provides context, form, and design guidelines
in Article 2 – Urban Standards for all
neighborhoods, districts, and corridors in
Azusa. Urban Standards are related to building
placement on the lot, garages and parking
location, and allowable frontage types (i.e.
stoop, porch, common yard), among other
things. These guidelines are depicted clearly
and graphically for all residential areas in the
City. As part of the design review process,
City staff reviews proposed projects against
these design guidelines that are in place
in the Development Code, in addition to
policies outlined in the General Plan. As such,
the process is intended to be transparent
and easy for developers to understand. The
Design Review process helps to support
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
neighborhood stability and identity with the
introduction of quality housing in existing and
new neighborhoods, and is not considered a
constraint to development.
The Design Review findings are intended
to be straightforward, clear, and objective.
However, there remains some subjectivity with
regard to compatibility. To provide a clear and
objective process, Program H4-7 is included
to adopt Objective Design Standards for all
multi-family residential projects and mixed-
use that is at least two-thirds residential.
Use Permit and Minor Use Permit
As part of the Development Code, the City
has defined land uses that are allowed by
right. Generally, these are accompanied with
standards that the development must be
consistent with. The City has also identified
uses and activities that may be appropriate
for the zoning district. These proposals are
submitted to the City for review through the
User Permit and Minor Use Permit process
in order for the impacts on the site and the
surrounding areas to be reviewed and their
impacts assessed against the current adopted
development code, general plan, and any
applicable specific plans to determine if the
allowance of the proposed use will adversely
impact the immediate and surrounding
environment.
A Use Permit application is subject to a public
hearing before the Planning Commission prior
to a formal decision on the application. A
Minor Use Permit process requires a decision
by Zoning Administrator. These discretionary
approvals are carefully considered by decision
makers. Consistent with State law, land use
decisions must be made based on substantial
evidence. The General Plan policies,
Development Code, and any related Specific
Plans provide decision makers with guidance
on discretionary planning actions. The review
authority may approve a Use Permit or Minor
Use Permit only after first finding all the
following, as defined in Section 88.51.040.F:
• The proposed use is allowed within the
applicable zoning district and complies
with all other applicable provisions of
the Development Code and Municipal
Code;
• The proposed use is consistent with
the General Plan and any applicable
specific plan;
• The design, location, size, and
operating characteristics of the
proposed activity are compatible with
the existing and future land uses in the
vicinity;
• The site is physically suitable for the
type, density, and intensity of use being
proposed, including access, utilities,
and the absence of physical constraints;
and
• Granting the permit would not be
detrimental to the public interest,
health, safety, convenience, or welfare,
or materially injurious to persons,
property, or improvements in the
vicinity and zoning district in which the
property is located.
In an effort to streamline and prioritize housing
development, Program H4-4 is included in
the Housing Plan to remove existing MUP
requirements for multi-family residential
uses, including senior housing, townhouses,
triplexes and fourplexes and stacked flats.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Discretionary Review
Discretionary permits (such as variances,
CUPs, and tentative maps) typically require
three to four months to review and process
for a public hearing, and processing time
varies with the type of environmental review
required. Plans can be submitted to plan
check prior to the Planning Commission and
City Council final approval of the project with
the submittal of a hold harmless agreement.
The City has established a tiered system
for discretionary review, with a Zoning
Administrator who acts as a review authority
for minor items, including Minor Use Permits,
and Minor Variances. Planning Commission is
involved in the discretionary review process
for larger scale projects, such as a Use Permit
or a Variance. When the processing involves a
legislative action, or if a Planning Commission
decision is appealed, approval by the City
Council is required.
ENVIRONMENTAL REVIEW
State regulations require environmental
review of discretionary project proposals
(e.g., subdivision maps, precise plans, use
permits, etc.). The timeframes associated
with environmental review are regulated
by the California Environmental Quality
Act (CEQA). In compliance with the Permit
Streamlining Act, City staff ensures that non-
legislative proposals are heard at the Planning
Commission within 60 days of receipt of an
application being deemed complete.
Senate Bill 35 (SB 35) Approval
Process
SB 35 requires cities and counties to
streamline review and approval of eligible
affordable housing projects by providing
a ministerial approval process, exempting
such projects from environmental review
under the California Environmental Quality
Act (CEQA). When the state determines that
jurisdictions have insufficient progress toward
their lower-income RHNA (very low and low
income), these jurisdictions are subject to the
streamlined ministerial approval process (SB
35 [Chapter 366, Statutes of 2017] streamlining)
for proposed developments with at least
50 percent affordability. If the jurisdiction
also has insufficient progress toward their
above-moderate-income RHNA, then they
are subject to the more inclusive streamlining
for developments with at least 10 percent
affordability. SB 35 will automatically sunset on
January 1, 2026.
As of June 2019, the City of Azusa was
determined to be subject to SB 35
streamlining for proposed developments with
10 percent or greater affordability. The City
has not received any applications or inquires
for SB 35 streamlining. To accommodate any
future SB 35 applications or inquiries, Program
H4-3 is included in the Housing Plan, to
provide an informational packet to interested
parties that explains the SB 35 streamlining
provisions and provides SB 35 eligibility
information. In addition, Program H4-7
specifies that City will adopt objective design
standards to provide local guidance on design
and standards for by-right projects as allowed
by state law. The purpose of adopting such
objective standards is to give certainty to both
the City and the development community that
the architectural and general appearance of
buildings and grounds are in keeping with the
character of the various neighborhoods of the
City, while providing clear objective standards
upon which review decisions are based.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Affirmatively Furthering
Fair Housing
In January 2017, Assembly Bill 686 (AB 686)
introduced an obligation to affirmatively
further fair housing (AFFH) into California
state law. AB 686 defined “affirmatively
further fair housing” to mean “taking
meaningful actions, in addition to combat
discrimination, that overcome patterns of
segregation and foster inclusive communities
free from barriers that restrict access to
opportunity” for persons of color, persons
with disabilities, and other protected
classes. The bill requires that the Housing
Element assess fair housing through the
following components: a summary of fair
housing issues and assessment of the City’s
fair housing enforcement and outreach
capacity; an analysis of segregation patterns
and disparities in access to opportunities,
an assessment of contributing factors,
and an identification of fair housing goals
and actions. The primary data sources for
the AFFH analysis are the 2018 Analysis of
Impediments (AI) to Fair Housing Choice
for the Los Angeles County Development
Authority (LACDA) and Housing Authority
of the County of Los Angeles and the State
of California Department of Housing and
Community Development (HCD) AFFH Data
Viewer.
FAIR HOUSING ASSESSMENT
Fair housing is a condition in which individuals
of similar income levels in the same housing
market have like ranges of choice available
to them regardless of race, color, national
origin, religion, sex, disability, familial
status, ancestry, age, marital status, gender,
gender identity, gender expression, genetic
information, sexual orientation, source of
income, or any other arbitrary factor.
Fair Housing Enforcement and
Capacity
The 2018 Analysis of Impediments (AI) to
Fair Housing Choice for the Los Angeles
County Development Authority (LACDA)
and Housing Authority of the County of Los
Angeles serves as the fair housing planning
document for portions of County of Los
Angeles, including unincorporated areas
and the Urban County which represents 47
smaller cities in the county, including the
City of Azusa. As a part of the consolidated
planning process, entitlement communities
that receive Community Development Block
Grant (CDBG), HOME Investment Partnerships
(HOME), Emergency Shelter Grants (ESG),
and Housing Opportunities for Persons with
AIDS (HOPWA) funds as a formula allocation
directly from HUD are required to submit to
HUD certification that they are affirmatively
furthering fair housing (AFFH).
The AI examines local housing conditions,
economics, policies, and practices in order to
ensure that housing choices and opportunities
for all residents are available in an environment
free from discrimination. The AI assembles
fair housing information, identifies existing
impediments that limit housing choice,
and proposes actions to mitigate those
impediments.
There are a number of organizations that
provide fair housing services, including
outreach and education, complaint intake,
and testing and enforcement activities, for
both providers and consumers of housing
in Los Angeles County. These organizations
include the U.S. Department of Housing and
Urban Development (HUD), the California
Department of Fair Employment and Housing
(DFEH), which exists as substantially equivalent
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
agency to HUD in the state, and the Housing
Rights Center (HRC), which serves all of
the cities and communities in Los Angeles
County. The HRC receives a multi-year grant
from HUD to conduct systemic testing in
areas within Los Angeles County where
statistics point to any form of discrimination
covered by applicable fair housing laws and,
in particular, persistent housing discrimination
based on race, national origin, familial status,
and disability. HRC also provides intake of
allegations of housing discrimination and
provides resolution for housing discrimination,
including mediation and litigation. The
Housing Authority of the County of Los
Angeles (HACoLA) provides fair housing
resources for residents via its website, such
as links to file complaints of a violation of fair
housing, a link to the Housing Rights Center,
a link to HUD’s webpage on Fair Housing and
Equal Opportunity, a link to the National Fair
Housing Advocate Online blog, a copy of
HACoLA’s non-discrimination policy, and a
link to information on the Assessment of Fair
Housing. The City of Azusa directs residents
with fair housing complaints to the HRC and
includes HRC contact information on the
City’s website. The City’s Rental Housing
Inspection Program (Program H1-2) also
supports fair housing efforts by ensuring
properties remain safe and well maintained
in order to preserve existing rental housing
in the city. The program directs the City to
coordinate with the Los County Development
Authority and other multi-family property
owners or non-profit organizations that own
and manage affordable housing in the city
to advise on any necessary improvements of
multi-family housing that needs rehabilitation.
Complaints filed with HUD
HUD’s fair housing complaint data from 2008
through 2016 was calculated for the Los
Angeles County Service Area. During that
time, the most common basis for a complaint
was for some form of a disability, that being
the basis for nearly twice as many complaints
as the next most common basis – race. Of all
complaints found with cause, disability was
also the most common basis for the complaint,
although not by such a runaway margin. In
complaints found with cause, disability was
the most common basis, cited 370 times in
complaints, followed by familial status and
race as the basis for 238 and 145 complaints,
respectively. Fair housing complaints were
most common in 2008, when 456 were logged,
and reduced steadily in number to only 186
in 2012. After 2012, complaints began to rise
again (to 303 in 2016). Other complaints
during that time, besides those already
listed, were largely based on familial status,
retaliation, national origin, and sex. Complaints
found with cause logged mostly in 2008 and
2009, when nearly a third of all complaints with
cause were logged during the time period
2008 through 2016. Of the 2,610 complaints
logged from 2008 through 2016, all of them
were closed, dismissed, or settled in a variety
of ways. Nearly 57 percent of these complaints
were determined to have no cause, while 564
(21.6 percent) of the complaints were deemed
successfully settled. Of all complaints found
with cause, the most common issue was failure
to make reasonable accommodation, cited
290 times. The second most commonly cited
issue was discriminatory terms, conditions,
privileges, or services and facilities.
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Local Fair Housing Enforcement and
Outreach
The HCD AFFH Data viewer provides
additional information on local fair housing
enforcement and outreach. Fair housing
inquiries data from the U.S. Department of
Housing and Urban Development (HUD)
indicates that from 2013 to 2021, there were
21 inquiries originating from residents in
Azusa, which is equivalent to 0.42 inquiries
per 1,000 residents (see Figure H-4.1). The
basis for complaints is only available for three
of the inquiries; in these three cases the basis
for the complaint was based on race or sex.
Compared with surrounding jurisdictions, the
number of inquiries per thousand residents
is generally higher in Azusa. Bradbury (0.00),
Monrovia (0.10), Duarte (0.14), and Glendora
(0.09) have two to three times lower the level
of inquiries to that of Azusa; however, Azusa’s
proportion of renters is significantly higher
than in these jurisdictions.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Segregation and Opportunity
Patterns and Trends
The AFFH analysis must address areas of
ongoing and concentrated segregation and
integration and compare concentrations of
protected characteristics and incomes. The
following information discusses the levels
of segregation and integration for race and
ethnicity, income, familial status, persons with
disabilities.
Race/Ethnicity
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. Azusa
is racially and ethnically diverse. Hispanic (64
percent) and White (19 percent) residents
make up the majority of the City’s population,
followed by Asian/Pacific Islander (14 percent)
and Black (3 percent). Since 2010, the portion
of the population that is Asian in Azusa has
increased by five percentage points, while
the Hispanic population has decreased by
four percentage points. The Black and White
proportions of the population in Azusa have
remained the same since 2010. Between 1990
and 2000, following a trend seen throughout
Los Angeles County in the last decade,
Azusa’s White population experienced
a decline (going from 36 percent of the
population to 24 percent of the population,
a decline of 28 percent), while the Hispanic
population increased by almost the same
amount (29 percent, going from 53 percent
to 64 percent). By and large, the changes in
Azusa’s racial and ethnic composition have
paralleled trends in Los Angeles County.
The AFFH Data Viewer provides a
measurement of the predominant racial/ethnic
group for each census tract and the extent of
the group’s prominence. This is measured as
predominant (> 50 percent), sizeable (10-50
percent), and slim (< 10 percent). The entire
city of Azusa shows a Hispanic majority with
much of the city showing a prominence value
of 50 percent or greater. There is one census
tract that has a White majority prominence
value of 47 percent in the eastern area of
the city. This census tract encompasses
a portion of Glendora, which has a larger
White population and more census tracts
with a White majority. In Azusa, there are
no other racial groups with prominence
values. Additionally, Figure H-4.2 shows the
distribution of non-white residents in Azusa
based on 2018 block group data from HUD’s
AFFH Data Viewer. The majority of the city is
comprised of block groups where 91 percent
or more of the population is non-white. Areas
in northern Azusa have 61 to 80 percent non-
white residents. There is one block group in
the far northeast area of the city with a lower
proportion (38 percent) of non-white residents.
This block group contains the Azusa Pacific
University and the Citrus Community College
and is likely reflecting the demographics of the
student population enrolled in these schools.
Azusa differs slightly when compared to other
foothill communities, such as Sierra Madre,
Pasadena, and Glendora where the foothill
areas have proportions of non-white residents
at 40 percent or less. In terms of the broader
Los Angeles County region, areas with a
large proportion of tracts with a predominant
Hispanic majority include central, east, and
southeast Los Angeles County, the east San
Fernando Valley, and the east San Gabriel
Valley. These areas have historically been
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
home to a large Hispanic population.
To measure segregation in a given
jurisdiction receiving direct federal funding,
the US Department of Housing and Urban
Development (HUD) provides racial or
ethnic dissimilarity trends. Dissimilarity
indices are used to measure the evenness
with which two groups (frequently defined
on racial or ethnic characteristics) are
distributed across the geographic units, such
as block groups within a community. The
“dissimilarity index” provides a quantitative
measure of segregation in an area, based
on the demographic composition of smaller
geographic units within that area. The
dissimilarity index represents the percentage
of one group that would have to move into
a new neighborhood to achieve perfect
integration with another group. An index
score can range in value from 0, indicating
complete integration, to 100, indicating
complete segregation. A value of 60 (or
above) is considered high, values of 40 or
50 are usually considered a moderate level
of segregation, and values of 30 or below
are considered to be fairly low. The higher
the dissimilarity index value, the higher
the level of segregation in an area. One
way of understanding the index is that it
indicates how evenly two demographic
groups are distributed throughout an area:
if the composition of both groups in each
geographic unit (e.g., Census tract) is the
same as the composition of both groups in
the area as a whole (e.g., county), then the
dissimilarity index score for that entire area
will be 0.
Dissimilarity index data are only available for
the Los Angeles Urban County (as provided
by the AI) and not for the City of Azusa.
For the Los Angeles Urban County, the
Dissimilarity Index shows a mix of moderate
and high levels of segregation between racial
and ethnic groups. Asian (non-Hispanic)
populations show the lowest race-specific
levels of segregation with Whites (non-
Hispanic) with an index of 53.0. Hispanics
have the highest levels of segregation (index
of 64.9), followed by Blacks (non-Hispanic),
with an index of 64.2. The Non-White and
White populations show a segregation index
of 55.7, indicating a high level of segregation
within the Urban County. Long Beach and
Los Angeles have the highest Dissimilarity
Index values, with consistently moderate to-
high levels of segregation among the ethnic/
racial groups. For the Urban County at large,
the Non-White/White Dissimilarity Index has
remained fairly consistent since 1990, dropping
a single point value since then. These numbers
indicate that the Non-White/White index
values have been hovering just inside the
“high segregation” thresholds since 1990. The
Black/White index value peaked in 1990 with a
value of nearly 73, but has fallen and remained
steady near a value of 67 since that time. The
Hispanic/White index value has fallen nearly
a full point since 2010, but is nearly two full
points higher than it was in 1990. Finally, the
Asian/White index value has risen steadily
since its 1990 value of just over 46 to a peak
of 50.21 in 2010; 2015 is the first year the
Asian/White index has fallen in value (down
about one-quarter of a value point). While
there is no dissimilarity index data for Azusa,
the discussion above on the distribution
of non-white residents and the location of
predominant racial population groups in the
City suggest that Azusa as a whole is not as
segregated as the County. Regionally, there
are cities with fewer proportions of non-white
residents, which are mostly located in western
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Los Angeles County (Santa Monica, Malibu,
and Beverly Hills). Azusa’s demographic
profile is similar to that of El Monte, Baldwin
Park, East Los Angeles, and several other
cities in central and Southeast Los Angeles
County (Table H-4.18). Following a trend
seen throughout Los Angeles County in
the last 20 years, Azusa’s White population
experienced a decline (going from 24 percent
in 2000 to 19 percent in 2018), while other
races/ethnicities generally increased (the
Hispanic population stayed the same at 64
percent, Asian increased from 6 percent to 14
percent, and the Black population decreased
proportionally from 4 to 3 percent).
To assist in the local analysis of integration
and segregation, the Department of Housing
and Community Development (HCD)
and the California Tax Credit Allocation
Committee (CTCAC) created Opportunity
Maps to identify resources levels across the
state. These opportunity maps are made
from composite scores of three different
domains (economic, environmental, and
education) made up of a set of indicators.
The opportunity maps include a measure or
“filter” to identify areas with poverty and racial
segregation (Census tracts with at least 30
percent of the population under the federal
poverty line and a location quotient higher
than 1.25 for Blacks, Hispanics, Asians, or all
people of color in comparison to the County).
According to the California Fair Housing
Task Force’s 2021 opportunity maps, there
are no census tracts or areas of high racial
segregation and poverty in Azusa. Regionally,
areas with high segregation and poverty in the
San Gabriel Valley include portions of cities of
Pomona, Rosemead, El Monte, and Pasadena
(HCD AFFH Data Viewer).
Generally, these areas also correspond
to historic patterns of segregation and
redlining (AFFH-Data Viewer). The Home
Owners’ Loan Corporation (HOLC), a defunct
financial services corporation from the
1930s, developed a neighborhood ranking
system (known today as redlining) to assess
credit-worthiness by mortgage security. The
grades ranged from A to D, where A included
predominantly white or upper-middle-class
neighborhoods that the HOLC defined as
posing minimal risk, and D included areas that
Table H-4.18: Racial Composition in Neighboring Cities, West Los Angeles, and
County
Azusa Baldwin
Park
El
Monte Whittier Santa
Monica Malibu Beverly
Hills
Los
Angeles
County
White (non-
Hispanic)19%4%4%25%64%85%78%26%
Hispanic 64%74%66%67%16%9%6%48%
Black 3%4%0.5%1%4%1%2%8%
Asian/Pacific
Islander 14%20%29%4%10%2%10%15%
Native American 0.2%0.2%0.1%0.3%0.1%0%0.1%0.2%
Other 0.1%0.2%0.1%1%0.4%0%0.4%0.3%
Source: American Community Survey 2014-2018 5-year estimates
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
predominantly contained marginalized low-
income populations, such as Jewish, Asian,
Mexican, and Black residents. These areas
were also more likely to be near industrial
areas, freeways, and have an older housing
stock. The effects of disinvestments caused
by redlining can still be observable today,
where formerly redlined neighborhoods
have fewer resources such as quality schools,
access to fresh food and health care. Many of
the neighborhoods in the cities mentioned
above were graded C (Declining) or D
(Hazardous) and are still challenged by high
rates of segregation and poverty in the 21st
century. Historically, Azusa’s downtown
area was classified as either Declining or
Hazardous. The City has actively pursued
opportunities for the downtown that will
provide new services, housing, and address
disinvestment. To ensure such positive
change does not displace existing residents,
Government Code Section 65583.2(g)(3) and
Government Code section 66300(d) require
housing is not demolished without being
replaced and certain affordability criteria
are met. Program H3-8 ensures projects
proposed in Azusa comply with this law.
Persons with Disabilities
With regards to fair housing, persons with
disabilities have special housing needs
because of the lack of ADA-accessible and
affordable housing, the potential for higher
health costs associated with their disability,
and the potential need for access to transit. In
addition, many may be on fixed incomes which
further limits their housing options.
According to the 2014-2018 American
Community Survey, 8.4 percent of the
population in Azusa had a disability and this
rate has decreased significantly over the past
two decades (Table H-4.19). The majority
of residents with a disability are 75 years or
older (58 percent), followed by those 65 to
74 years (20 percent). The most commonly
occurring disability amongst seniors 65 and
older is an ambulatory disability, experienced
by 21 percent of Azusa’s seniors. In Azusa, the
proportion of the population with a disability
living in poverty (17.7 percent) is higher than
those without a disability (14.8 percent).
Figure H-4.3 shows the population of persons
with a disability by Census tract in the city
using American Community Survey data from
Table H-4.19: Disability by Age (2000 - 2018) - Azusa
Age Group
2000 2010 2018
Persons
w/ a
Disability
% of
Total Age
Group
Persons
w/ a
Disability
% of
Total Age
Group
Persons
w/ a
Disability
% of
Total Age
Group
Under 5 0 0%0 0%16 0.5%
5-17 Years 343 4%120 1%199 2.6%
18-64 Years 7,203 25%2,045 7%2,242 13.5%
Over 65 Years 1,498 49.1%1,335%38%1,669 78.6%
Total 9,044 22%3,500 0.3%4,126 8.4%
Source: U.S Decennial Census, American Community Survey 2008-2010 5-year estimates and 2014-2018 5-year estimates
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
2015-2019. There is one Census tract with a
slightly higher concentration (13.3 percent)
of people with a disability, which is located
directly south of Foothill Boulevard between
Irwindale Avenue and San Gabriel Avenue.
This tract overlaps with high proportions
of residents living in poverty, renter-
occupied housing units, and overcrowded
households. These patterns are reflective
of socioeconomic characteristics typically
experienced by people with disabilities. This
tract is located near Downtown and as such
has good access to transit and services. At
a regional level, Azusa is similar to the rest
of the county in that almost all of the census
tracts have less than 10 percent of their
population living with a disability.
Familial Status
Single-parent households require special
consideration and assistance because of
the greater need for day care, health care,
and other services. In particular, female-
headed households with children tend to
have lower incomes and a greater need for
affordable housing and accessible daycare
and other supportive services. There are 2,390
female-headed family households in Azusa,
representing 19 percent of households. A
total of 18 percent of female-headed family
households live in poverty. Figures H-4.4
and H-4.5 show the percent of children in
married-couple households in the region and
the percent of children in female-headed
households (no spouse/partner) using ACS
data from 2015-2019. The majority of census
tracts have 60-80 percent of children living
in married couple households and with one
census tract having 80 percent or greater
of married-couple households. Most of the
census tracts in Azusa have proportions of 40
percent or less of children living in female-
headed households. Azusa’s familial status
demographics are similar to those of Arcadia,
Glendora, and Sierra Madre, but with slightly
higher rates of female-headed households.
Income Level
According to the 2019 American Community
Survey, the median household income for
Azusa was $68,216, which is somewhat lower
than that of the County of Los Angeles
median household income of $72,797. This
trend has existed over the past decades;
in 2000, the median income in Azusa was
$39,191, lower than the County’s median
income of $42,189. Median household
income differs significantly by tenure; owner
households in Azusa earn double what renter
households make. Income also varies by
race; Census data shows that the median
income for households that identify as
White (Non-Hispanic) is $76,613, exceeding
both the City and County median; while
Hispanic households have a median income
of $62,977. Black and Asian households
both have median incomes that exceed the
City median income at $86,369 and $82,946
respectively. This is also higher than the
median income for Black ($45,886) and Asian
($75,326) households in the County. These
trends have also stayed constant over the past
two decades; in 2000, non-Hispanic Whites
in Azusa had a median income of $42,444,
Hispanic households had a median income
of $33,820, Black households had a median
income of $38,587, and Asian households
had a median income of $50,368. Black and
Asian households have experienced the most
growth in median income over the past two
decades.
Census data estimates that 15 percent of
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Azusa residents live in poverty, as defined by
federal guidelines. Poverty has decreased
since 2000, when it was estimated that 18.8
percent of the population lived in poverty. In
Los Angeles County, 16 percent of residents
live in poverty and this has reamained
relatively constant since 2000 when 17.9
percent of residents lived in poverty.
Figure H-4.6 shows that most of the city
has a median income between $55,000 and
$87,000. There are a three Census block
groups that have a median income of between
$30,000 and $55,000. Some of these areas are
located in close proximity to the Azusa Pacific
University and could reflect the local student
population. Two additional block groups,
near Downtown and near Base Line Road
on the eastern end of the city, have median
household incomes of less than $30,000.
Figure H-4.7 shows that the majority of the
city has 10 percent or less of residents living
below the poverty level, with portions of the
city having up to 20 percent of residents in
poverty. One area shows 20 to 30 percent
poverty; however, this is likely reflective of the
local student population.
Identifying low or moderate-income (LMI)
geographic areas and individuals is important
to overcome patterns of segregation. HUD
defines an LMI area as a Census tract or block
group where over 51 percent of the population
is LMI (based on HUD income definition of up
to 80 percent of the AMI). Figure H-4.6 shows
the Lower and Moderate Income (LMI) areas in
Azusa by Census block group. At the County
level, the latest iteration of this data from the
2011-2015 American Community Survey (ACS)
shows 5,526,154 residents in Los Angeles
County are low- and moderate-income,
compared to the total population of 9,863,025.
More than half (56 percent) of the countywide
population is considered low- or moderate-
income and are members of households
earning less than 80 percent of Area Median
Income. Though significant, this percentage
is similar to the broader geographical region.
Neighboring Orange County’s is 49 percent
low- and moderate-income; San Bernardino is
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
44 percent; and San Diego, 48 percent. Much
of Los Angeles County has high proportions
of LMI areas particularly in Southeast and
Central Los Angeles and the San Gabriel
Valley (cities of El Monte, Rosemead,
Alhambra, Pomona, and Baldwin Park). Azusa
has a higher low- and moderate-income
percentage of 62.09 percent. Within the City,
LMI areas are mostly in the eastern portions of
Downtown and near Azusa Pacific University.
Racially/Ethnically Concentrated
Areas of Poverty (R/ECAP)
Racially or ethnically concentrated areas of
poverty (R/ECAPs) are Census tracts with
relatively high concentrations of non-white
residents with these residents living in
poverty. Formally, an area is designated an
R/ECAP if two conditions exist: (1) the non-
white population, whether Hispanic or non-
Hispanic, must account for at least 50 percent
of the Census tract population; and (2) the
poverty rate in that Census tract must exceed
a certain threshold. That threshold is set at
either 40 percent or three times the overall
poverty rate, whichever is lower. No R/ECAPs
are identified in the City of Azusa.
In Los Angeles County, there are R/ECAPs
concentrated around the central parts of the
City of Los Angeles, with a few scattered in
San Fernando, San Gabriel, and Antelope
Valleys. The closest R/ECAPs to the City
of Azusa are located 11 miles southwest in
the cities of El Monte and South El Monte.
This finding is supported by the HCD AFFH
data viewer. While there are no R/ECAPs
in the City, Figure 3.1 shows that most of
the City’s block groups show a non-white
population that is 60 percent or greater and
is predominantly composed of a Hispanic
population.
Racially Concentrated Areas of Affluence
Racially or Ethnically Concentrated Areas of
Affluence (RCAAs) are generally understood
to be neighborhoods in which there are both
high concentrations of non-Hispanic White
households and high household income
rates. In Azusa, there are no significant
concentrations of White households and high
household incomes. There is one Census tract
that has a 38 percent non-white population,
which is the lowest proportion of non-white
residents in the City. This tract borders and
includes an area within the City of Glendora.
However, this tract shows a median income
that is less than the median income for the
State ($87,100) indicating that no Census tracts
in the City qualify as RCAAs.
Compared with Los Angeles County, the City
has a higher percentage of Hispanic residents
and a lower percentage of white, non-Hispanic
residents. As a result, Azusa has fewer
concentrations of White residents. A regional
comparison shows that Azusa has fewer areas
with predominantly White residents compared
with other foothill cities and the County. There
is no Census tract in Azusa with predominance
values for the White population.
Opportunity Access/Disparities
As a guide to aiding resource investments in
the County, the AI includes a single composite
index representing a rating of Census tracts,
based on a variety of factors, including
education, job and labor markets, housing,
transportation, and environmental health.
Those areas scoring a high value on the
index represent the areas with the greatest
opportunity. These areas have desirable
attributes, such as high-performing schools,
availability of well-paying jobs, and clean air
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
quality, among others. Areas with a low index
value represent areas with low opportunity
and are generally heavily populated with R/
ECAP areas. The index is designed to better
understand what an “area of opportunity”
represents and what disparities in opportunity
mean. Investments can be either place-
based or to enhance mobility, but the
opportunity index score aids in helping us to
better evaluate equity and the distribution
and access to opportunity within the larger
community. In developing this index, HUD-
provided data as well as local data were
incorporated as part of the methodology.
Variables in each of the five categories
(Education, Economic, Housing,
Transportation, and Health) were given equal
weighting. The five categories were then
compiled into one “master” opportunity
index value, with 35 percent weight each
to Education and Housing, 15 percent
weight to Economic, 10 percent weight to
Transportation, and five percent weight
to Health. The factors listed below were
incorporated in the development of this
index:
• Education: School Proficiency Index,
Percent of Persons Enrolled in School,
High School Graduation Rate
• Economic: Job Proximity Index,
Labor Market Engagement Index,
Employment Rate
• Housing: Percent Occupied Housing
Units, Percent No Cost Burden, Percent
No Overcrowding, Percent Non-HAL
(high-annual percentage rate) Loans
• Transportation: Transit Trips Index,
Low Transportation Cost Index,
Percent Walking to Work
• Health: Environmental Health Index
Within the Urban County, the lowest
opportunity area index values (scoring 44
to 5) are in Central Los Angeles and to the
southeast, near Westmont and Lynwood.
Census tracts in the highest category of
opportunity (those with values from 70.1
to 80), can be found scattered throughout
the peripheries of the county including
east of the county near Glendora and San
Dimas. The City of Azusa was identified to
be in a moderate opportunity area (scoring
50 to 70). Neighboring Glendora provides
significantly higher levels of opportunity than
Azusa, indicating a disparity between these
neighboring jurisdictions. While not within the
lowest opportunity scores, Azusa represents
an underserved area in the region where
additional funding and efforts to improve
education, economic, housing, transportation,
and health opportunities could help support
improvements in quality of life for residents.
Additional analysis is presented below to
describe each of these factors in more detail,
through an updated index prepared by the
Department of Housing and Community
Development (HCD) and the California Tax
Credit Allocation Committee (TCAC) and
relevant efforts.
TCAC Opportunity Maps (2021)
The Department of Housing and Community
Development (HCD) and the California
Tax Credit Allocation Committee (TCAC)
undertook an effort to evaluate access to
opportunity by producing annual opportunity
maps using a similar methodology and data
found in the AI. The maps illustrate an overall
composite score derived from characteristics
grouped into three main categories:
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
economic, environmental, and educational.
The composite score ranges from low
to highest resources, with low resources
indicating less access to opportunity and
high resources indicating greater access to
opportunity. The TCAC/HCD Opportunity
Maps are intended to display the areas that
offer low-income children and adults the
best chance at economic advancement, high
educational attainment, and good physical
and mental health. The primary function of
TCAC is to oversee the Low-Income Housing
Tax Credit (LIHTC) Program, which provides
funding to developers of affordable rental
housing. The opportunity maps play a
critical role in shaping the future distribution
of affordable housing in areas with the
highest opportunity. The 2021 TCAC maps
show that a majority of Azusa is identified
as “moderate” resource (see Figure H-4.8).
Moderate resources areas are located in the
northwestern part of the city and in a few
central areas. The city also has areas of low
and high resources. Low resource areas are
located in the southwestern parts of the city
where there are large areas of industrial uses.
The high resource areas are situated in the
northeastern parts of the city and include the
Azusa Pacific University (APU) and APU/Citrus
College transit station are located.
The discussion below addresses opportunity
access in Azusa in more depth regarding
education, environmental, transportation, and
economic scores.
Education
The TCAC Opportunity maps address
education, economic, and environmental
opportunity. TCAC’s education score is based
on math proficiency, reading proficiency, high
school graduation rates, and the student
poverty rate. According to TCAC’s educational
opportunity map (Figure H-4.14), no Census
Tracts in Azusa score below 0.25—opportunity
scores are presented on a scale from zero
to one and the higher the number, the more
positive the outcomes. Most Census Tracts
score between 0.25 and 0.5, with a few Census
Tracts (Downtown, Rosedale, and near APU)
scoring 0.5 to 0.75. No Census Tracts in Azusa
score in the top tier, 0.75 and above; however,
neighboring jurisdiction Glendora and nearby
Arcadia score predominately 0.75 and above.
Information on schools in the Azusa Unified
School District (from publicschoolreview.com)
show that the district’s average testing ranking
is 4/10, which is in the bottom 50 percent
of public schools in California and is ranked
within the bottom 50 percent of all 989 school
districts in California (based on combined
math and reading proficiency testing data)
for the 2018-2019 school year. School ranking
had no significant variation by location. A
comparison of schools in the Azusa Unified
School District on publicschoolreview.com
shows that most K-12 schools have a score
of six or less. Only one high-ranking school
is available in the city (8/10). This school is
Paramount Elementary and is located in a
low resource area. Despite low-performance
scores, Azusa Unified has a high school
graduation rate at 91 percent, which is higher
than the California average rate of 84 percent.
School performance is impacted by a myriad
of factors, but one often cited reason is lack
of sufficient funding. California went from
having some of the highest per-student
funding of schools to one of the lowest, due
to the decline in tax revenue caused by the
passage of Proposition 13 in 1978. Inadequate
school funding has also created inequalities
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
amongst school districts, where wealthier
neighborhoods have better access to
educational resources and higher-performing
schools, than poorer neighborhoods.
More affluent school districts tend to have
attributes that support better student
performance, such as smaller classroom
sizes, a more experienced and credentialed
teacher force, and more advanced placement
courses. Many education reforms have been
adopted by the State in recent years to
increase school investment, particularly in
disadvantaged neighborhoods. However,
even with more investment pouring into
education, performance still lags across many
schools pointing to a much more complex
set of factors. This conundrum is reflected
in the Azusa Unified School District, where
the District has higher revenue per student
and spending per student than the State
median. The District also fairs better than the
State on several metrics relating to school
environment, such as small class sizes and a
large proportion of certified and experienced
teachers (Table H-4.20).
Based on these metrics, Azusa Unified’s
low performance could be related to factors
external to the education system. Research has
shown that parents with higher educational
attainment correlates with their children
having better educational outcomes. Parents
with higher education are likely to expose
and have access to educational opportunities
outside of school, such as science camps,
music school, etc. They are also likely to have
higher incomes, which allows them to provide
for extracurricular activities and to have more
time and stability to assist their children in
their schoolwork. Low-income parents with
lower educational attainment may have more
stressful jobs that can undermine their health
and ability to access cognitively stimulating
opportunities for their children.4 In Azusa,
71.9 percent of Hispanic residents have a high
school degree and only 11.3 percent have a
bachelor’s degree. This is in comparison to
36.3 percent of White residents, 42 percent
of Black residents, and 55 percent of Asian
residents with a bachelor’s degree. These
4 Eccles, J.S. (November, 2005). Influence of parents’
education on their children’s educational attainments:
the role of parent and child perceptions. London
Review of Education.
Table H-4.20: School Performance Metrics - State and Azusa
Revenue per
student
Spending
per student
Students
per teacher
% of
teachers
with 3
or more
years of
experience
% of
full time
teachers
who are
certified
Azusa Unified School
District $18,212 $18,869 20:1 94%98%
State $15,969
(median)
$16,042
(median)
22:1
(average)
88%
(average)
98%
(average)
Source: publicschoolreview.com; greatschools.org
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
percentages also correlate with median
income, where Hispanic residents have the
lowest household income amongst all racial/
ethnic groups in the City. Overall, it appears
that the District’s low-performance is possibly
correlated with the educational attainment of
parents and there are significant disparities
amongst Hispanic residents. These disparities
could be attributed to language barriers,
immigrant status, and other factors unique to
Hispanic households.
Additionally, the demographics of the District
show a large population of Hispanic students,
many of which are English learners. In the
2020/21 school year, 75 percent of students
qualified for free/reduced-price meals due
to household income, were English learners,
or were foster youth within the Azusa
Unified School District. English learners
are predominately Spanish speaking. The
Education Data Partnership reports an ethnic
diversity score of 8. The Ethnic Diversity Index
reflects how evenly distributed these students
are among the race/ethnicity categories. The
more evenly distributed the student body, the
higher the number. A school where all of the
students are the same ethnicity would have an
index of 0. The index is out of 100; the highest
score any school currently receives in the
country is 76. Azusa Unified School District’s
score reflects a largely homogenous student
body, with approximately 92 percent Hispanic
or Latino students; this score has remained
relatively steady in recent years, dropping
from nine in 2016/17. Between 2016/17 and
2020/21, enrollment has dropped in Azusa
Unified by 16.5 percent. This trend is reflected
nationally, reflecting reduced birth rates.
In sum, improving school performance
requires a multi-pronged approach
that continues to advocate more school
funding, pathways to higher education for
students, and support for students’ access
to educational experiences and well-being
outside of the classroom.
Environmental Justice
The California Office of Environmental
Health Hazard Assessment (OEHHA)
developed a screening methodology
to help identify California communities
disproportionately burdened by multiple
sources of pollution called the California
Communities Environmental Health
Screening Tool (CalEnviro Screen). In
addition to environmental factors (pollutant
exposure, groundwater threats, toxic sites,
and hazardous materials exposure) and
sensitive receptors (seniors, children, persons
with asthma, and low birth weight infants),
CalEnviro Screen also takes into consideration
socioeconomic factors. These factors include
educational attainment, linguistic isolation,
poverty, and unemployment. Research has
shown a heightened vulnerability of people of
certain ethnicities and lower socioeconomic
status to environmental pollutants. Figure
H-4.12 shows CalEnviroScreen results for
Azusa. Areas in Central Azusa score in the top
25 percent for pollution and health burdens
and also have concentrations of lower income
households. Major industrial uses such as the
Azusa Quarry as well as the location of the
I-210 freeway through this area are some of the
contributing pollution factors. Compared to
the County, Azusa had similar scores to areas
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
located in the central and eastern parts of
the County. The lowest scoring areas (i.e. less
pollution burdened) are concentrated along
the coast, the Santa Monica and San Gabriel
Mountains, parts of the Antelope Valley, and
certain other foothill cities like Glendora,
Pasadena, Arcadia, and La Verne.
Transportation
Los Angeles County residents in urban and
suburban areas generally enjoy superior
access to transportation infrastructure. The
County is also traversed by numerous major
freeways within its boundaries (including
Interstates 5, 10, 210, 605; all of which are
either in close proximity or intersect with
Azusa). Proximity to these highways allows
access to employment and other activity
centers in Downtown Los Angeles, San
Gabriel Valley, West Los Angeles, and
Orange County. Azusa has access to five
major bus routes provided by Foothill Transit
and one light rail line provided by LA Metro.
Two light rail stations are located in the city,
one in Downtown and the other at Azusa
Pacific University/Citrus College.
The Santa Fe railroad corridor played a key
historic role in the development of Azusa’s
downtown and industry, and served Azusa
at the Downtown Train Station until 1994,
when the Northridge Earthquake damaged
the rail line and caused its closure. In 2016,
the station reopened as an extension of the
Metro Gold Line (now renamed the L Line), a
31-mile light rail line running from Azusa to
East Los Angeles via Downtown Los Angeles.
Azusa is home to two L Line Stations, the one
in Downtown, and one near Azusa Pacific
University (APU). The next phase of the Gold
Line Foothill Extension will connect the APU/
Citrus College station in Azusa (currently the
terminus of the line) and the Pomona–North
Metrolink station in Pomona. This phase is
under construction as of 2022, with a current
estimated completion date of 2026.
Azusa provides Dial-A-Ride services to
residents aged 55 or older. Any person with
a permanent disability under the age of 55
can also use the service. Service is available
between 5:00AM – 6:00PM Monday through
Friday. Prospective riders can register for the
service by mailing or emailing an eligibility
application to Azusa’s Transportation Division.
Access Services also offers paratransit service,
which provides curb-to-curb shared-ride
service within ¾ mile of fixed-route bus and
rail lines throughout Los Angeles County.
Regular service is offered from 4:00AM to
12:00AM, 7 days a week. Access supplements
any gaps in service not provided by Dial-A-
Ride. Low-income transit riders can participate
in the Low-Income Fare is Easy (LIFE) Program,
which provides transportation assistance to
low-income individuals in Los Angeles County.
LIFE offers fare subsidies that may be applied
toward to the fare purchase of Metro, Foothill
Transit, or any LIFE-participating transit
agencies.
According to AllTransit, an online source of
transit connectivity, access, and frequency
data, the City scored 7.3 for its overall transit
performance, indicating that the City has a
very good combination of trips per week and
number of jobs accessible enabling many
people to take transit to work.5 The City’s
score was higher than the County score of 6.8.
AllTransit data also shows that in Azusa, 87.4
percent of workers live within ½ mile of transit
5 Center for Neighborhood Technology 2019,
AllTransit, alltransit.cnt.org
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
compared with 90.1 percent for the County.
In terms of transit access by race/ethnicity,
Hispanic residents have the greatest access
to transit in Azusa, where almost 70 percent
of all Hispanic residents live within ½ mile
of transit. This is followed by 16.7 percent of
White residents, 9.5 percent Asian residents,
2.1 percent Black residents, and less than one
percent for Native Americans.
The HCD AFFH Data viewer provides
information on job proximity, creating an
index by Census Block Group indicting
areas that are most proximate to jobs. The
higher the index value, the better the access
to employment opportunities for residents
in a neighborhood (out of 100). Despite
existing transit (bus and rail) available in the
area, the southeastern portions of Azusa
rank in the lowest category (20 and below),
with Downtown and areas near APU ranked
20-40 (see Figure H-4.15). The City’s focus
on creating new opportunities for jobs and
housing near transit within the Downtown and
along major corridors is continuing to support
a high-quality living and working environment
for Azusa residents.
Employment/Economic
Local economic characteristics impact
local housing needs, even though these
characteristics may not be directly related to
fair housing. These economic characteristics
include the types of jobs available within
the municipality, the way residents access
jobs (e.g., auto, transit, etc.), the types
of occupations held by residents, and
their household income. Azusa’s top ten
employers are primarily in the education
and manufacturing sector. Residents who
work within Azusa are primarily employed
in educational services, retail trade, and
manufacturing. This is consistent with the
major employers in the City of Azusa. Major
employers in the City include Azusa Pacific
University with 2,297 employees, Azusa
Unified School District with 1,586 employees,
Northrop Grumman with 921 employees, and
City of Azusa with 370 employees.
In terms of unemployment, October
2021 unemployment data from the State
Employment Development Department
reported that Los Angeles County had an
unemployment rate of 9.4 percent while the
State of California had an unemployment
rate of 6.4 percent. Azusa had similar level of
unemployment (6.9 percent) as most foothill
cities in Los Angeles County; Glendora (6.2
percent), Pasadena (6.5 percent), La Verne
(6.7 percent), and Monrovia (6.3 percent).
Unemployment in Azusa was lower than
foothill cities such as Altadena (7.2 percent)
and Duarte (8.9 percent). According to
the American Community Survey, in 2019
Hispanic and White residents had the highest
unemployment rate at 6.1 percent, followed
by Asian (5.6 percent), Black (5.5 percent), and
Native American (4.5 percent). Additionally,
those with a disability had an unemployment
rate of 14.9 percent.
The HCD AFFH Data viewer provides
additional information on economic
opportunities. The Economic Opportunity
Index is a composite of four indicators
depicting elements of neighborhood socio-
economic character. The southern half of the
City (below Foothill Boulevard) ranks below
0.25 in the lowest category; areas north of
Foothill rank between 0.25 and 0.5 and the
northernmost areas of the city rank 0.5 to 0.75
(no areas in the community rank in the highest
quartile). See Figure H-4.16.
There are two primary ways that economic
indicators can improve in any location. The
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
first is through educational attainment: better
educated and skilled residents earn higher
wages. The primary way in which a city can
attract higher skilled workers is through
improving local amenities and services,
such as improving schools. The second is by
nurturing the city’s better-paying industries
and attracting more of such industries,
consistent with the city’s job base. Better-
paying industries can provide employment
opportunities for local workers and enhance
their ability to earn higher incomes. As Azusa
pursues the General Plan update, it will
seek to improve economic indicators in the
community and focus attention in these areas.
Disproportionate Need
A disproportionate housing need exists
when the members of a racial/ethnic group
at a given income level experience housing
problems at a greater rate (10 percentage
points or more) than the jurisdiction as a
whole. In the Urban County, the percentage
of Asian and Native American households
experiencing housing problems is far less than
the Hispanic percentage, at around 50 percent
for each group. White households fare even
better, with only 43 percent of households
experiencing any of the four housing
problems. A disproportionate need exists for
Hispanic and Black households, with Hispanic
and Black households experiencing severe
housing problems at a percentage higher than
that of the service area.
Table H-4.21: Azusa Households with Disproportionate Housing Needs
Owner
Households
Renter
Households All Households
Households experiencing housing
problems 39%64%51%
Households experiencing severe housing
problems 21%44%32%
Households experiencing housing problems by income
Household Income <= 30% HAMFI 67%86%82%
Household Income >30% to <=50%
HAMFI 63%87%77%
Household Income >50% to <=80%
HAMFI 60%71%66%
Household Income >80% to <=100%
HAMFI 41%45%43%
Household Income >100% HAMFI 19%7%16%
Households experiencing housing problems by race
White 30%62%42%
Black 41%61%54%
Asian & Pacific Islander 41%50%44%
Native American 27%50%40%
Hispanic 42%69%57%
Note: HUD Area Median Family Income
Source: U.S. Department of Housing and Urban Development. Comprehensive Housing Affordability Strategy (CHAS) data. https://
www.huduser.gov/portal/datasets/cp.html. Accessed March 2021
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Cost Burden
State and federal standards specify that
households spending more than 30 percent of
gross annual income on housing experience
a housing cost burden. When a household
spends more than 30 percent of its income
on housing costs, it has less disposable
income for other necessities such as health
care In Azusa, 44 percent of households
are overpaying for housing. Thirty-two
percent of owner-occupied households
are cost burdened, versus 55 percent of
renter-occupied households. Lower income
households have a higher rate of overpayment
(68 percent of lower income households
are overpaying), especially lower income
renter households, of which 76 percent are
experiencing a housing cost burden. Table
H-4.22 provides a further breakdown of cost-
burdened households by race. The greatest
proportion of households spending more
While the AI does not provide an analysis at
smaller geographies, HUD data, known as
the Comprehensive Housing Affordability
Strategy, or CHAS, for 2013-2017 shows
that renter households experience housing
problems at a greater proportion than
owner households (Table H-4.21). Lower-
income households also experience
significantly higher proportion of housing
problems compared with their high-income
counterparts. Disparities exist amongst
different racial and ethnic groups, where Black
and Hispanic households have the highest
levels of disproportionate housing needs.
In addition to the analysis presented in the AI,
the disproportionate housing need analysis
prepared for this housing element uses the
AFFH Data Viewer to visualize areas in Azusa
experiencing cost burden, overcrowding, and
environmental justice.
Table H-4.22: Cost Burden by Race/Ethnicity
Cost Burden
(>30%)
Severe Cost
Burden (>50%)Total Households
Owner-Occupied
White, non-Hispanic 325 (18%)195 (11%)1,815
Black, non-Hispanic 50 (34%)10 (7%)145
Asian and Pacific Islander, non-Hispanic 240 (20%)230 (19%)1,224
Native American, non-Hispanic 0 (0%)4 (27%)15
Hispanic 685 (21%)385 (12%)3,335
Other 20 (25%)0 (0%)80
Renter-Occupied
White, non-Hispanic 275 (26%)360 (34%)1,065
Black, non-Hispanic 100 (35%)70 (25%)285
Asian and Pacific Islander, non-Hispanic 100 (22%)85 (19%)450
Native American, non-Hispanic 0 (0%)10 (50%)20
Hispanic 1,085 (26%)1,275 (31%)4,150
Other 15 (14%)30 (28%)105
Source: U.S. Department of Housing and Urban Development. Comprehensive Housing Affordability Strategy (CHAS) data. https://
www.huduser.gov/portal/datasets/cp.html. Accessed March 2021
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
than 30 percent of their income on housing
are Black homeowners and renters. However,
Black homeowners experience the least
severe cost burden. Generally, all racial/ethnic
experience around the same level of cost
burden.
Figures H-4.9 and H-4.10 show cost burden
(overpayment) for homeowners and for
renters. Compared with the surrounding
areas, Azusa has similar levels of cost burden
for homeowners with all parts of the city
experiencing cost burden for 20 to 60 percent
of homeowners. For renters, all areas of the
city show cost burden for 40 to 60 percent of
renter households except for a few areas. The
Census tracts south of Gladstone Street and
one Census tract near Downtown Azusa show
60 percent or greater of renter households
overpaying for housing.
Overcrowding and Substandard Housing
In response to a mismatch between household
income and housing costs in a community,
some households may not be able to buy
or rent housing that provides a reasonable
level of privacy and space. According to
both California and federal standards, a
housing unit is considered overcrowded if
it is occupied by more than one person per
room (excluding kitchens, bathrooms, and
halls). In Azusa, 13 percent of housing units are
overcrowded. Overcrowding is more prevalent
in rental households than owner households.
Figure H-4.11 shows that overcrowding is the
most severe in the central areas of Azusa
between Foothill Boulevard and I-210 and
the area just south of Gladstone Street. In
these areas, 20 to 30 percent of households
are overcrowded. The areas with the least
overcrowding are in the foothills and are also
areas where there are slightly lower renter
households as shown by Figure H-4.13.
In the San Gabriel Valley, the cities of Baldwin
Park, El Monte, San Gabriel, Rosemead, and
Pomona show that there are significantly more
tracts with overcrowding levels higher than
the State average. Cities such as Pasadena,
Arcadia, Sierra Madre, South Pasadena, and
Glendora show few tracts with overcrowding
levels higher than the State average.
Substandard housing is housing that poses a
risk to the health, safety, and/or physical well-
being of residents. These issues can increase
the risk of disease, crime, poor mental health,
and other social impacts. HUD CHAS data
(2014-2018) provide an estimate of households
with at least one of four housing problems
that contribute to substandard housing
(incomplete kitchen facilities, incomplete
plumbing facilities, more than one person per
room, or cost burden greater than 30 percent).
In Azusa, 51.7 percent of households reported
one of these housing problems, a level similar
to Los Angeles County (51.0 percent) and
higher than the State (44.3 percent).
The City performs annual inspections of rental
properties to ensure proper maintenance
and upkeep, as well as presale inspections
of all homes that are sold. These efforts have
allowed Code Enforcement staff to have a
deep understanding of existing needs in the
community, and to continue to work with
property owners of apartment buildings
that are in particular need of rehabilitation,
maintenance, and repair. The City maintains
a list of 743 rental units (in 66 buildings)
that require additional oversight to ensure
buildings and properties are maintained
and comply with codes. The City’s Code
Enforcement staff has confirmed that these
buildings are not concentrated in one area of
the city. These units are scattered throughout
the city, including the southern portion of
the city, in lower density neighborhoods, and
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
along major corridors. Properties range from
small-scale make-shift structures, to small
apartments, to large apartment complexes.
Homelessness
The 2019 Greater Los Angeles Homeless
Count Report estimated a total of 329
homeless individuals in Azusa, 94 percent of
which were unsheltered. Throughout the San
Gabriel Valley, roughly 3,880 residents are at
any given time experiencing homelessness.
Of the 3,880 residents experiencing
homelessness, 71 percent are concentrated
in five cities: Azusa, Baldwin Park, El Monte,
Pasadena, and Pomona. The 2019 Greater Los
Angeles Homeless Count Report does not
have demographic data at the city level, but it
does provide this for the County Continuum
of Care which is an intregrated system of care
that guides and tracks homeless individuals.
In the County, 36.5 percent of homeless
individuals were Hispanic, followed by 33.3
percent Black, 24.7 percent White, 1.7 percent
Native American, and 1.4 percent Asian or
Pacific Islander. Despite making up only 8.3
percent of the total County population, Black
people are 4 times more likely to experience
homelessness. In terms of disability, 29
percent of people experiencing homelessness
report a serious mental illness and/or
substance disorder.
In Azusa, homeless persons are often
located in Downtown near transit or in the
riverbed and canyons. The City of Azusa
continues to work with regional partners,
including local nonprofits and surrounding
jurisdictions, to address homelessness. The
City also works with Los Angeles County
Sheriff’s Homeless Outreach Services Team
to provide information on services and
housing to homeless residents. In 2018, the
City adopted a Plan to Prevent and Combat
Homelessness, which outline the City’s
priorities as it continues to address issues
related to homelessness. In 2019, the City
received additional funds to build capacity
by expanding on the existing work of
Neighborhood Connections, a library-based
program, to establish a community-wide
approach to homeless solutions and better
route for community members experiencing
homelessness into and through the initial
Centralized Entry System.
Environmental Justice
The California Office of Environmental Health
Hazard Assessment (OEHHA) developed
a screening methodology to help identify
California communities disproportionately
burdened by multiple sources of pollution
called the California Communities
Environmental Health Screening Tool
(CalEnviroScreen). In addition to environmental
factors (pollutant exposure, groundwater
threats, toxic sites, and hazardous materials
exposure) and sensitive receptors (seniors,
children, persons with asthma, and low
birth weight infants), CalEnviroScreen also
takes into consideration socioeconomic
factors. These factors include educational
attainment, linguistic isolation, poverty,
and unemployment. Research has shown a
heightened vulnerability of people of certain
ethnicities and lower socioeconomic status to
environmental pollutants. Figure H-4.12 shows
CalEnviroScreen results for Azusa. Areas in
Central Azusa score in the top 25 percent for
pollution and health burdens and also have
concentrations of lower income households.
Major industrial uses such as the Azusa Quarry
as well as the location of the I-210 freeway
through this area are some of the contributing
pollution factors. Consistent with SB 1000
requirements to add a new Environmental
Justice Element to General Plans, this
topic will be further explored, along with
implementation actions to address findings,
through the comprehensive General Plan
update process that will begin in 2022.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
Displacement Risk
HCD defines sensitive communities
as “communities [that] currently have
populations vulnerable to displacement
in the event of increased development
or drastic shifts in housing cost.” The
following characteristics define a vulnerable
community:
• The share of very low-income residents
is above 20%; and
• The tract meets two of the following
criteria:
• Share of renters is above 40%;
• Share of people of color is above 50%;
• Share of very low-income households
(50% AMI or below) that are severely
rent burdened households is above
the county median;
• The community or areas in close
proximity have been experiencing
displacement pressures (percent
change in rent above County median
for rent increases); or
• Difference between Census tract
median rent and median rent for sur-
rounding Census tracts above median
for all tracts in the County (rent gap)
In Azusa, there are a number of census
tracts identified as vulnerable communities
by the Urban Displacement Project (Figure
H-4.17). These communities are generally
located south of the I-210 Freeway and near
Downtown and are the areas that meet
some or most of the criteria above. Areas in
southern Azusa are considered susceptible
to displacement, and areas in central
Azusa and near Downtown are described
as experiencing advanced gentrification.
Other parts of Azusa are identified as stable
moderate/mixed-income. Many of the
immediately surrounding communities have
already experienced increases in housing costs
and are either at risk of becoming exclusive or
already are exclusive. Azusa retains affordable
housing options and prioritizes the goal
of providing diverse housing choices for
residents.
In April 2017, the California Housing
Partnership and the Corporation for
Supportive Housing completed a report on
affordable housing in Los Angeles County
and found that more than 550,000 affordable
homes are needed to meet current demand
among low-income renter households. The
report mapped countywide patterns of
transit access, displacement risk, and the
ratio of low-wage jobs to affordable homes
(a metric referred to as having a good “fit”)
and found that gentrification occurred
almost entirely in urban areas well-served by
transit. Gentrification will place an inordinate
displacement pressure on low-income
households, especially for those living in the
areas well served by transit. Figure H-4.13
shows high renter concentrations in central
Azusa, where 40-80 percent of households are
renter occupied.
These areas also correspond with slightly
lower median incomes of around $55,000
making these areas somewhat susceptible to
displacement due to the combination of lower
median income and high proportion of renters.
State housing law requires an inventory and
analysis of government-assisted dwelling units
eligible for conversion from lower income
housing to market rate housing during the
next ten years. Reasons for this conversion
may include expiration of subsidies, mortgage
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
pre-payments or pay-offs, and concurrent
expiration of affordability restrictions. The
California Housing Partnership (CHP) provides
data on assisted housing units and assesses
the level of risk to converting to market rate.
These data identify homes without a known
overlapping subsidy that would extend
affordability beyond the indicated timeframe
and unless otherwise noted are not owned
by a large/stable non-profit, mission-driven
developer.
In the next 10 years, 178 units of affordable
housing are at-risk of converting to market
rate housing. Projects at risk include Villa
Azusa Senior Apartments (30 units) and Alosta
Gardens (23 units). In addition, Azusa Park
Apartments (88 units) affordability covenants
expired in 2020; however, the City has not
received any notifications from the property
owner regarding conversion to market rate
housing. Many of these units are located
in the Downtown area and include Azusa
Gardens, Alosta Gardens, Iris Gardens, and
Azusa Park Apartments.
State housing law requires an inventory and
analysis of government-assisted dwelling units
eligible for conversion from lower income
housing to market rate housing during the
next ten years. Reasons for this conversion
may include expiration of subsidies, mortgage
pre-payments or pay-offs, and concurrent
expiration of affordability restrictions. The
California Housing Partnership (CHP) provides
data on assisted housing units and assesses
the level of risk to converting to market rate.
These data identify homes without a known
overlapping subsidy that would extend
affordability beyond the indicated timeframe
and unless otherwise noted are not owned
by a large/stable non-profit, mission-driven
developer. In the next 10 years, 178 units of
affordable housing are at-risk of converting to
market rate housing. Projects at risk include
Villa Azusa Senior Apartments (30 units) and
Alosta Gardens (23 units). In addition, Azusa
Park Apartments (88 units) affordability
covenants expired in 2020; however, the
City has not received any notifications from
the property owner regarding conversion to
market rate housing. Many of these units are
located in the Downtown area and include
Azusa Gardens, Alosta Gardens, Iris Gardens,
and Azusa Park Apartments. Program H1-4 is
included in the Housing Plan to monitor and
support the preservation of these units.
Sites Inventory
State law requires that for housing elements
due on or after January 1, 2021, sites must
be identified throughout the community in a
manner that affirmatively furthers fair housing
opportunities (Government Code Section
65583[c][10]). “Affirmatively furthering fair
housing” means taking meaningful actions
that, taken together, address significant
disparities in housing needs and in access
to opportunity. Figure H-5.2 (in the Housing
Resources Chapter) shows the sites inventory
to address the City’s RHNA for 2021-2029,
overlaid with TCAC areas of opportunity. State
law correlates higher density sites with the
ability to provide lower-income housing. As
such, the majority of the lower income RHNA
sites are located in the Azusa TOD Specific
Plan area (which has no density limit) and on
religious institution land, where churches are
allowed to add housing. These sites combined
have a capacity for 1,542 housing units.
The following describes the distribution of
the sites with respect to areas of analysis
discussed above.
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Segregation and Integration
Most of the Census tracts in Azusa contain
a Hispanic majority and no other racial or
ethnic group has significant prominence
values within the city, indicating that the city
does not have areas where lower-income
households overlap with concentrations of
non-white residents. The areas with the lowest
median income are in close proximity to the
Azusa Pacific University, suggesting that there
is likely a large local student population living
near the university. Additionally, almost all of
Azusa has low rates of people with disabilities
and children living in female-headed
households. Overall, the sites identified in the
inventory improve integration by connecting
housing to critical jobs and services in
Downtown and in key transportation corridors
which help increase regional access to
opportunity for all residents, particularly
those with lower-incomes or special needs. In
addition to sites identified in Figure H-5.2 (in
the Housing Resources Chapter), accessory
dwelling units (ADUs) are projected to
contribute to additional affordable housing
opportunities throughout the community,
often in lower-density neighborhoods.
Integration of additional opportunities for
smaller, more affordable units through ADUs
and new lot splits and duplexes allowed by
SB 9 also support integration and increase
options for housing in higher opportunity
areas.
R/ECAPs
According to the TCAC Opportunity maps,
there are no areas with a high concentration
of segregation and poverty within the city.
There are also no racially concentrated
areas of affluence due to the city’s majority
non-white population. Therefore, the sites
inventory has no effect on R/ECAPs or racially
concentrated areas of affluence.
Access to Opportunity
The distribution of lower income RHNA sites
improves fair housing and equal opportunity
conditions in Azusa because sites are mostly
distributed in moderate resources areas and
not lower resource areas. The sites represent
locations where new higher-density housing
can be provided and residents will have access
to good schools, diverse jobs, transportation,
and distant from industrial use.
Disproportionate Housing Needs
Azusa has significant overcrowding issues,
and the site inventory alleviates this burden
by providing more affordable and accessible
housing, particularly in the central areas
of the City. As the TOD Specific Plan
encourages additional development within
the Downtown, residents will have even more
access to services and retail, as well as existing
resources including the local library, City Hall,
and high-quality transit.
Local Knowledge – Public Outreach
As part of the outreach efforts for the Azusa
Housing Element, a housing survey was widely
distributed (see Appendix A). As part of the
survey, participants were asked to rank the
importance of current housing challenges in
Azusa. Participants responded that targeted
efforts to address long-term inequities in the
housing market, including discrimination, was
important; though it ranked fifth among eight
priorities.
• Ranked 1: Ensure that children who
grow up in Azusa can afford to live in
Azusa on their own
• Ranked 2: Encourage the rehabilitation
of existing housing in older
neighborhoods
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
• Ranked 3: Support programs to help
homeowners at risk of mortgage
default to keep their homes, including
mortgage loan programs
• Ranked 4: Establish housing for
households with special needs such as
seniors, large families, veterans, and/or
persons with disabilities
• Ranked 5: Targeted efforts to address
long-term inequities in the housing
market, including discrimination in
renting
• Ranked 6: Streamline the process for
new housing construction
• Ranked 7: Focus new housing near
commercial areas, creating “live/work”
neighborhoods
• Ranked 8: Provide shelters and
transitional housing for homeless
families and individuals, together
along with services that help move
people into permanent housing
Fair Housing Issues and
Contributing Factors
AI Recommendations to Improve Fair
Housing
The 2018 AI provides a list of impediments
that have been identified as contributing to
fair housing issues pertaining specifically
to the Urban County and HACoLA’s service
areas. The impediments and contributing
factors identified in the AI are in relation to
the fair housing issues listed below:
• Segregation
• Racially or ethnically concentrated
areas of poverty (R/ECAPs)
• Disparities in access to opportunity
• Disproportionate housing needs
• Discrimination or violations of civil
rights laws or regulations related to
housing
The 2018 AI provides a prioritization of these
contributing factors based on the ability
of the LACDA and HACoLA to address the
fair housing issues. A low priority does not
diminish the importance of the factor in the
Urban County or HACoLA service areas but
reflects the priority in addressing issues of fair
housing.
However, not all of these contributing factors
are likely present in Azusa. Based on the
analysis prepared using the AFFH Data Viewer
Tool, the contributing factors most applicable
to the city of Azusa are those related to
disproportionate housing needs. The following
specific impediments/contributing factors are
included in the 2018 AI and only those most
applicable to Azusa are listed below.6
High Priority Contributing Factors:
• Lack of affordable housing in a range
of sizes
• Lack of sufficient accessible housing in
a range of unit sizes
• Lack of information on affordable
housing
• Discrimination in the private accessible
rental markets
• Lack of resources and services for
working families (e.g., helping find
housing for minorities)
The 2018 Analysis of Impediments included
eight goals for the Urban County. Table
H-4.23 only lists goals that are most relevant
for Azusa, along with the corresponding
impediment and fair housing issue.
6 For more detail, please visit: https://wwwa.lacda.
org/programs/community-development-block-grant/
plans-and-reports/assessment-of-fair-housing
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
Identification and Prioritization of Local
Fair Housing Issues and Contributing
Factors
Housing Element law requires that the City
list and prioritize contributing factors to
fair housing issues. Contributing factors
create, contribute to, perpetuate, or increase
the severity of fair housing issues, are
fundamental to adequate goals and actions,
and must be related to the overall analysis.
This identification and prioritization must give
highest priority to factors that limit or deny fair
housing choice or access to opportunity or
negatively impact fair housing.
Azusa has long provided a disproportionate
share of affordable housing, compared to the
region at large. The City seeks to continue to
provide for a variety of housing types as well
as other economic opportunities to create a
high-quality of life and access to opportunities
for all residents. The following are contributing
factors that affect fair housing choice in Azusa:
Table H-4.23: County of Los Angeles: Analysis of Impediments to Fair Housing
Choice/Assessment of Fair Housing Fair Housing Goals, Issues, and Proposed
Achievements: Urban County (select)
Fair Housing Goal Impediments/ Contributing
Factors Fair Housing Issue
Promote more affordable housing
for special needs populations
Lack of affordable housing in a
range of sizes
Segregation
Disparities in Access to
Opportunity
Disproportionate Housing Needs
Promote understanding and
knowledge of fair housing and
ADA laws
Discrimination in private rental and
homes sales markets
Disparities in Access to
Opportunity
Discrimination
Segregation
Lack of on-line fair housing
material to distribute information
Disparities in Access to
Opportunity
Access to financial services
Segregation
R/ECAPs
Disparities in Access to
Opportunity
Disproportionate Housing Needs
Coordinate the AI with other
agencies’ plans and programs to
address contributing factors
Lack of coordination with other
Planning Processes and Programs
to address contributing factors
Segregation
R/ECAPs
Disparities in Access to
Opportunity
Disproportionate Housing Needs
Source: County of Los Angeles: Analysis of Impediments to Fair Housing Choice, 2018.
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
1. Displacement risk due to regional
economic pressure
Areas with high demand for homes drive
up housing costs and increase pressure for
redevelopment, resulting in the potential
for displacement. Inadequate supply and
production of affordable homes available
to low-income households and persons in
protected classes as well as public opposition
to new development are contributing factors
to this fair housing issue. Azusa residents also
indicated ensuring that children who grow up
in Azusa can afford to live in Azusa on their
own is a top priority. While displacement risk
is not very high now, it is likely to continue as
regional housing prices continue to climb and
put pressure on the more affordable housing
markets, such as Azusa.
Contributing factors:
• Inadequate supply/production of
affordable/special needs housing
• Displacement of residents due to
regional economic pressures
• High land and development costs in
the region
• Land use and zoning laws
• Public opposition to new development
and land use and zoning laws
2. Disproportionate housing needs in areas
with lower incomes, higher proportions of
renters, and disabled residents.
The analysis found that Downtown and
areas near Azusa Pacific University/Citrus
College had higher levels of overcrowding
that overlapped with lower median incomes,
higher proportions of renters, and disabled
residents. The disproportionate housing
needs of residents in Azusa should be
supported with new housing opportunities, as
well as increased economic opportunities to
create a balanced and high-quality of life.
Contributing factors:
• Inadequate supply/production of
affordable/special needs housing
• Potentially large population of students
• Limited access to opportunity
(education, transportation, economic)
3. Disparities in educational achievement
throughout the City.
Low performing schools are located
throughout the city, despite the Azusa Unified
School District exhibiting school environment
metrics that support academic achievement
such as high student spending and small class
sizes. One potential reason for this, is that a
majority of the adult population do not have a
bachelor’s degree or high and is significantly
low amongst the Hispanic population, which
research has shown parent’s educational
attainment affects children educational
outcomes. Additionally, over 75 percent of
low-income students in District were English
learners pointing to possible language and
cultural barriers.
Contributing factors:
• Potential lack of culturally relevant
educational opportunities outside of
the school environment
• Potential lack of culturally relevant
parent/student support
Actions to Address Contributing Factors to
Fair Housing Issues
The City is taking several actions (reflected
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
in the Housing Plan) to address these
contributing factors to fair housing issues
and affirmatively further fair housing
throughout the city. The main strategy to
address displacements risk is to expand the
opportunity for the development of housing
for a variety of income levels as well as provide
better access to economic opportunity for
local residents. These factors will be key points
to focus on during the upcoming General Plan
update, scheduled to begin in 2022.
7 City of Azusa General Plan EIR, 2003.
Environmental
and Infrastructure
Constraints
Environmental and infrastructure constraints
can hamper development of sufficient housing
for all economic segments. The following
section discusses potential environmental
and infrastructure constraints to residential
development in Azusa.
Environmental Constraints
Azusa is largely urbanized. Relatively natural
vegetation communities and habitats
for wildlife are limited to the remaining
undeveloped floodplain of the San Gabriel
River and its tributaries. Six plant and animal
species in Azusa have been identified as
federally endangered: the Quino checkerspot
butterfly, the southern steelhead trout, the
unarmored threespine stickleback (fish),
the Least Bell’s vireo (bird), the Braunton’s
milkvech (plant), and the slender-horned
spineflower.7 The City’s topography is variable.
The elevation of land in Azusa ranges from
about 2,080 feet at the north edge along the
National Forest boundary to about 475 feet
at Arrow Highway and Vincent Avenue. The
Vulcan gravel pit has elevations below 350
feet but occupies only a very small area of the
City near its southwestern edge. Although
no State-designated special studies zones
for fault rupture hazard (so-called Earthquake
Hazard Fault Zones) exist within the City,
previous geological studies have identified
seven faults that may traverse the City: the
Sierra Madre Fault, Faults “C” and “D” within
the Rosedale area, Upper Duarte Fault,
Raymond Fault, Whittier Fault, and Duarte
Fault. In the event of significant seismic activity
in Southern California, ground shaking as the
potential for substantial damage. The General
Plan provides policies that protect people
and structures from earthquake faults, strong
seismic ground shaking, and seismic-related
ground failure, including liquefaction and
landslides.
Infrastructure Constraints
Infrastructure is considered critical to the
maintenance and development of new
housing. The ability of a site and development
to provide water facilities, sewerage facilities,
streets, and sidewalks. The main source of
water is provided by ground water in the
San Gabriel Groundwater Basin, a portion of
which lies directly underneath the City and
distribution and maintenance is provided by
the City. When ground water is not sufficient
to meet water demand, the City will then
obtain water from the San Gabriel River. In
extreme conditions, water is purchased from
the Metropolitan Water District of the San
Gabriel Valley Municipal Water District to
meet demand when water from wells and
the river cannot. The General Plan contains
policies and programs to minimize water
consumption through site design, use of
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CONSTRAINTS ANALYSIS | AZUSA HOUSING ELEMENT 2021-2029
efficient systems, and other techniques. Plan
policies aim to reduce reliance on imported
water and wastewater discharges. The General
Plan Environmental Impact report notes that
existing water facilities are adequate to serve
the City of Azusa given anticipated growth.
The City of Azusa owns, operates, and
maintains the local sewer lines that collect
wastewater generated in the City. The City
prepared a Sewer Master Plan (2001) to
analyze the existing and projected demand
and capacity of the City’s wastewater system
to accommodate the anticipated growth in
sewage and wastewater per day, consistent
with General Plan land use policy. The City
does not treat the sewer flows generated
within its service area. According to the
City’s Sewer System Master Plan (2010), the
wastewater collected in the local sewer lines
are connected to the Los Angeles County
Sanitation District (LACSD) trunk lines. The
trunk sewer lines connect to the San Jose
Creek Water Reclamation Plant and the Joint
Water Pollution Control Plant, which are
overseen by the LACSD.
The provision and maintenance of
infrastructure in a community enhances not
only the character of the neighborhoods, but
also serves as an incentive to homeowners
to routinely maintain the condition of their
homes. In the alternative, when public
improvements are left to deteriorate or are
overextended in use, the neighborhoods in
which they are located become neglected
and show signs of deterioration. A number
of new streets were planned in the General
Plan to complete missing links in the City’s
street system and to fully develop the street
system to allow access to all areas of the
City. These have largely been completed.
Through creation of multi-use, density-rich
developments, Azusa shows its desire to
minimize cost of infrastructure. Additionally,
the General Plan contains policies to maintain
and improve existing public facilities, such as
libraries, police stations, and fire stations to
provide needed amenities for residents.
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AZUSA HOUSING ELEMENT 2021-2029 | CONSTRAINTS ANALYSIS
151
Azusa
Pedestrian
PlanHousing
Resources
5
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
This section analyzes the resources available
for the development, rehabilitation, and
preservation of housing in Azusa. This
includes an evaluation of the availability of
land resources, the City’s ability to satisfy its
share of the region’s future housing needs,
the financial resources available to support
the provision of affordable housing, as well as
the administrative resources available to assist
in implementing the City’s housing programs.
Availability of Sites for
Housing
A critical component of the Housing Element
is the identification of sites for future
housing development, and evaluation of
the ability of these sites to accommodate
the City’s share of regional housing needs
as determined by the Southern California
Association of Governments (SCAG). Azusa
is a highly urbanized community that has
very little vacant, uncommitted land for new
development. In Azusa, additional residential
growth will occur on properties with
development capacity in the low, medium,
and moderate density residential zones, along
the major corridors, and in areas close to
the Metro Gold Line stations. The following
discussion summarizes the residential growth
potential in each of these areas and concludes
with an assessment of how these sites can
address the City’s share of regional housing
needs.
REGIONAL HOUSING NEEDS
ALLOCATION
California State law requires that each city and
county has land zoned to accommodate its fair
share of regional housing need. To determine
whether a jurisdiction has sufficient land to
accommodate its share of regional housing
needs for all income groups, that jurisdiction
must identify “adequate sites.” Under State
law (California Government Code §65583[c]
[1]), adequate sites are those with appropriate
zoning and development standards to
facilitate and encourage the development of a
variety of housing types suitable for all income
levels.
The share for the Southern California
Association of Governments (SCAG) region
is known as the Regional Housing Needs
Allocation, or RHNA. The sixth cycle RHNA for
the SCAG region covers an 8.3-year planning
period (June 30, 2021 – October 15, 2029) and
is divided into four income categories: very
low, low, moderate, and above moderate.
The California Department of Housing and
Community Development (HCD) determined
that the projected housing need for the
Southern California region (including the
counties of Los Angeles, Orange, Riverside,
San Bernardino, Ventura, and Imperial) is 1.34
million new housing units for this Housing
Element planning period. SCAG allocated
this projected growth to the various cities
and unincorporated county areas within the
SCAG region, creating the RHNA. Azusa’s
RHNA for the 2021-2029 planning period is
2,651 housing units, with the units distributed
among the four income categories as shown
in Table H-5.1. As illustrated in this chapter,
Azusa has sufficient capacity under existing
land use policy to meet its 2021-2029 RHNA
obligations.
Housing Resources
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
PROGRESS TOWARDS RHNA
Since the RHNA uses June 30, 2021 as the
baseline for growth projections for the
Housing Element planning period of 2021 to
2029, jurisdictions may count units approved,
proposed, or under construction that are
anticipated to be complete after June 30,
2021.
Proposed and approved residential
development projects credited toward the
2021-2029 include a variety of affordable and
market rate projects. Many of these projects
are concentrated within and around the City’s
transit-oriented districts and mixed-use areas,
which provides a high level of opportunity
for access to services and transit. Combined,
these approved and proposed projects can
accommodate 510 units (Table H-5.2). The
City has a remaining RHNA of 2,141 units to be
addressed through ADU projections and site
identification.
Approved and Under Construction
Projects
619 N. San Gabriel Avenue
This infill project (0.16 acres), under
construction in spring 2021 in the TOD
Specific Plan Downtown Expansion Zone,
will provide retail (888 square feet) and six
residential units. The project will feature
a roof garden for residents and Craftsman
style. Situated along San Gabriel Avenue, the
project will enhance the pedestrian-oriented
public realm and contribute to revitalization of
the Downtown.
The Orchard (626 N. Azusa Avenue)
The Orchard, a four-story mixed-use project
located at the southeast corner of Azusa
Avenue and Foothill Boulevard, will complete
construction in 2022. The property is zoned
Downtown District within the Azusa TOD
Specific Plan and includes approximately
31,500 square feet of commercial space
for theater, retail, and restaurant uses and
approximately and 163 apartment units,
of which 3 units will be live/work units. The
project is designed with upper floor setbacks
and frontages and framing to emphasize the
public realm.
Table H-5.1 Azusa RHNA
Income Group % of County MFI
RHNA
(Housing Units)
Percentage of Units
Very Low 0-50%760 28.7%
Low 51-80%368 13.9%
Moderate 81-120%382 14.4%
Above Moderate 120% +1,141 43.0%
Total 2,651 100%
Source: SCAG, 6th Cycle RHNA Allocation 2021
619 N. San Gabriel Avenue
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
Table H-5.2 Approved and Proposed Projects
Project Project Status
Extremely/
Very Low-
Income (0-
50% AMI)
Low-
Income
(50-80%
AMI)
Moderate-
Income (80-
120% AMI)
Above
Moderate-
Income
(+120%)
Total
619 N. San Gabriel
Avenue
Under
Construction ------6 6
The Orchard
Under
Construction ------163 163
511 N. Azusa Avenue
Under
Construction ------4 4
820 N. Soldano Plan Check ------6 6
300 W. Foothill Plan Check ------7 7
The Citrus View
Prelim Plan
Review ------102 102
573-577 E. Arrow
Highway Plan Check ------10 10
The Avenue (800 N.
Azusa)Entitled ------127 127
807 The Promenade
Entitlement
Phase ------23 23
333 N. Azusa Avenue
Entitlement
Phase ------4 4
175 N. Azusa Avenue
Entitlement
Phase ------4 4
243 N. Azusa Avenue
Entitlement
Phase ------4 4
120 N. Aspan
Entitlement
Phase --2 --20 22
326 N. Azusa Avenue
Entitlement
Phase ------8 8
736-740 N. Angeleno
Avenue
Entitlement
Phase --4 ----4
631-635 N. San Gabriel
Avenue
Entitlement
Phase ------16 16
Total --6 --504 510
511 N. Azusa Avenue
This project was originally approved in 2014
but was postponed by the developer. It
will include four two- and three-bedroom
condominiums and 845 square feet of
commercial. It is under construction in 2022 in
the TOD Specific Plan area.
Proposed Projects
As of 2022, the City is in the process of
reviewing applications and preliminary plans
for over 300 new units in Azusa (Table H-5.2).
820 N. Soldano
The 820 N. Soldano proposed project
of six townhomes will be developed on
The Orchard
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
approximately 0.26 acres (combining two lots)
within the Transition District of the Azusa TOD
Specific Plan. The residential units range from
two to four bedrooms with between 1,555
square feet and 1,854 square feet. The project
is undergoing plan check as of May 2021.
300 W. Foothill
The proposed mixed-use project is located
within the Route 66 District of the Azusa TOD
Specific Plan. Mixed-use developments are
permitted by right in the Route 66 District
with Design Review approval. Tentative
Tract Maps are subject to Subdivision Map
Act requirements and require Planning
Commission approval. In addition to the
subdivision of the individual residential
and commercial units, two parcels will be
combined to result in a project with a 633
square-foot commercial building, 447 square-
foot community gym, and seven residential
townhome units with three to four bedrooms
each (four buildings total).
The Citrus View (525 N. Azusa Avenue)
The Citrus View is a four-story project with 102
residential units, 4,600 square feet of retail
and one level of subterranean parking. The
design of the project will include a mixture
of materials to be consistent with the mix of
materials on Azusa Avenue. All retail frontage
will be oriented toward Azusa Avenue to
encourage the connectivity of Downtown
Azusa. This project will replace the existing
Post Office located on the site.
573-577 E. Arrow Highway
This project, in plan check as of May 2021, is
a 10-unit attached townhome development
consisting of four buildings with two-car
garages for each unit. The proposed project
will merge the two existing parcels into one.
Construction of townhomes are permitted
by right in the CAH (Arrow Highway Corridor)
zone with Design Review approval. Tentative
Tract Map applications, which are subject to
Subdivision Map Act requirements, require
Planning Commission approval.
The Avenue (800 N. Azusa Avenue)
The proposed project, comprised of four
parcels totaling 1.20 acres, is located
within the Gold Line District of the Azusa
TOD Specific Plan. The project will include
approximately 12,000 square feet of retail and
restaurant uses and 127 apartment units. As
part of the project, the following entitlements
were approved: a Use Permit for alcohol sales,
Minor Use Permits for extended hours and
outdoor dining, and a Tentative Tract Map for
the subdivision of commercial/residential area
along with a lot line adjustment and parcel
consolidation.
807 The Promenade
Located within the Monrovia Nursery Specific
Plan, commonly known as Rosedale, this
project is currently in the entitlement phase
and proposes to revise existing land planning
that would have included institutional space
and replace with 23 dwellings. This project
also includes the development of a new public
park.
The Citrus View
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
333 N. Azusa Avenue
This project is located within the Azusa
Corridor zone and is in the entitlement phase
(application under review) as of May 2021.
The project involves four residential units and
1,000 square feet of commercial on a 0.16 acre
lot.
175 N. Azusa Avenue
This project is located within the Azusa
Corridor zone and is in the entitlement phase
(pre-application under review) as of 2022. The
project involves four residential units on a 0.17
acre lot.
243 N. Azusa Avenue
This project is located within the Azusa
Corridor zone and is in the entitlement phase
(pre-application under review) as of 2022. The
project involves four residential units on a 0.16
acre lot.
120 N. Aspan
This project is located in southern Azusa
on an underutilized residential lot, currently
occupied by nonconforming commercial use
(largely parking). The project is requesting a
density bonus and in exchange will provide
two low-income units and 20 market-rate units,
for a total of 22 single-family units.
326 N. Azusa Avenue
This project is located within the Azusa
Corridor zone and is in the entitlement phase
(pre-application under review) as of 2022. The
project involves eight residential units on two
adjacent lots (and a lot merger) for a total 0.32
acre site.
736-740 N. Angeleno Avenue
City staff have been in negotiations with San
Gabriel Valley Habitat for Humanity regarding
the disposition of a City owned property
located at 736 and 740 N. Angeleno Avenue.
The property would be used to develop four
affordable for-sale housing units.
631-635 N. San Gabriel Avenue
The project is located in the San Gabriel
Corridor zone and is in the entitlement phase
(pre-application under review). This 16-unit
Table H-5.3: Sites to Meet the RHNA
Project
Extremely/
Very Low-
Income (0-
50% AMI)
Low-
Income
(50-80%
AMI)
Moderate-
Income
(80-120%
AMI)
Above
Moderate-
Income
(+120%)
Total
Projected ADU construction 57 108 5 72 242
Vacant Residential Sites ----2 32 34
Underutilized Residential Sites ----87 16 103
Vacant Mixed-Use Sites ------162 162
Underutilized Mixed-Use Sites ----259 177 436
Azusa TOD Specific Plan Sites 741 276 48 216 1,281
Religious Institution Sites 47 ----18 65
Total 845 384 401 693 2,323
Notes: Estimated ADU production is credited toward the RHNA consistent with HCD guidelines and SCAG affordability distribution
assumptions (SCAG Regional Accessory Dwelling Unit Affordability Analysis, 2020)
Sites allowing the State-designated default density standard (at least 30 du/ac) are credited toward the lower income RHNA. Small sites meeting
the default density standard are credited toward the moderate- and above moderate-income category, as are sites with lower densities.
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
project will include three live/work units on
two parcels totaling 0.24 acres in size.
SITES INVENTORY
The Housing Element Sites Inventory consists
of accessory dwelling unit (ADU) projections
and vacant and underutilized sites in
residential, mixed-use, and transit-oriented
development district areas. Together, these
2019, 12 ADU building permits were issued;
in 2020, 17 building permits were issued;
and in 2021, 32 ADU building permits were
issued between January and September 8,
2021. Applying a projection of existing 2021
performance to the remainder of the year, an
additional 13+ ADU permits are anticipated
to be issued in 2021 for a total of at least 40
ADUs. The City estimates that interest will
continue to increase over the next few years
before leveling off. The City is predominately
made up of single-family neighborhoods; as
such there is ample capacity for additional
ADUs. As of 2021, there were 5,583 parcels
zoned for single-family housing, totaling
1,024 acres. In addition, ADUs are permitted
in multi-family developments and mixed-use
developments, which represent a significant
share of the City’s land and include the
Downtown area, corridors, and transit-adjacent
areas. In addition, the recent ADU activity may
be somewhat depressed by the COVID-19
pandemic and other events of 2020. The
significant increase in 2021 is likely to be more
representative of ADU production moving
forward, based on ADU trends in Azusa,
new and pending favorable ADU legislation
that created new incentives and streamlined
processes to build ADUs, and the pent-up
demand for additional housing in Azusa and
the Southern California region at large. While
it is impossible to predict with certainty the
exact number of ADUs that will be developed
in the planning period (2021-2029), the City has
estimated a level of ADU development that
accounts for pent-up demand at the start of
the planning period and the potential leveling
off of ADU development in the latter part of
the planning period. This is a conservative
approach, especially given legislation that will
go into effect on January 1, 2022 to expand
sites ensure that the remaining RHNA can
adequately be accommodated during
the planning period. The sites have no
identified constraints that would prevent
development or reuse during the Housing
Element period. Table H-5.3 summarizes
the sites inventory, which is graphically
represented in Figure H-5.1.
ADU Projections
Since 2017, the Legislature has passed a
series of new laws that significantly increase
the potential for development of new ADUs
and Junior ADUs (JADUs) by removing
development barriers, allowing ADUs
through ministerial permits, and requiring
jurisdictions to include programs in their
housing element that incentivize their
development. Interest in constructing ADUs
is high in Azusa and continues to grow.
In 2018, 15 applications were received; in
2019, 22 were received; and in 2020, 35 ADU
applications were received. This represents
a 47 percent increase between 2018 and
2019, and a 59 percent increase between
2019 and 2020. The issuance of building
permits follows application submittals;
as such, lower numbers occurred in 2018
when new laws became effective to allow
for the time in designing projects and
submitting for applications. In 2018, two
ADU building permits were issued; in
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
ADU opportunities even further (SB 9) and a
continuing push in the legislature for more
such legislation in coming years. To account
for near-term pent-up demand, but also to
provide a conservative approach, the City
assumes the following ADU construction
during the planning period:
• June 30, 2021 to December 31, 2021:
20 units – This represents half of
the projected annual construction,
based on trend information available
(building permits issued) between
January 1, 2021 and September 8,
2021.
• 2024 to October 15, 2029: 29 units
annually – Conservatively, the City
estimates that ADU permits may
decrease to 29 units annually (the
average of 2020 and 2021 building
permits issued) and remain constant
at that level through the rest of the
planning period (due to the planning
period end date in October, only 19
ADUs are assumed in 2029).
The affordability assumptions for the ADUs
are based on the Southern California
Association of Governments (SCAG) ADU
affordability analysis for Los Angeles County
II, which has been pre-certified by HCD1.
The City will encourage ADUs and other
innovative building types by keeping its
ADU ordinance current with new State laws,
developing and disseminating educational
information on ADUs, and identifying an ADU
1 SCAG estimates an affordability breakdown of ADUs
in the Los Angeles County II subregion as follows:
15% extremely low-income, 9% very low-income,
45% low-income, 2% moderate-income, and 30%
above moderate-income. 6th Cycle Housing Element
Update Technical Assistance – ADU Affordability
Analysis, August 27, 2020.
specialist within the Planning Department.
The City will evaluate ADU production by
affordability level throughout the planning
period and will identify and implement
additional incentives and strategies midway
through the planning period (2024) if needed
(Program H3-4).
Density Assumptions and Cost of
Housing in Azusa
State law has established “default densities”
that are considered sufficient to provide
market-based incentives for the development
of housing for lower-income households.
For jurisdictions such as Azusa that have
a population greater than 25,000 and are
located within a Metropolitan Statistical Area
(MSA) with a population of more than two
million, the default density is 30 dwelling units
per acre (or higher). This default standard
applies equally to communities with higher
residential property values (such as Los
Angeles or Pasadena), and to communities
where home prices, rents, and the cost of
vacant land are significantly below the regional
average (such as Azusa).
The Azusa General Plan (adopted in 2004)
identifies many areas in the city as appropriate
for higher density residential development
and mixed-use development at a maximum
density of 27 units per acre, and the TOD
Specific Plan does not restrict densities for
individual properties. A discussion of density
assumptions and the affordability level of
particular sites is included in the discussion
below.
Vacant and Underutilized Residential
Land
State law requires that jurisdictions
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demonstrate in the Housing Element that the
land inventory is adequate to accommodate
that jurisdiction’s share of the region’s
projected growth. Vacant, uncommitted land
in residential zones throughout the city was
identified, totaling 4.03 acres. Generally, most
development in residential zones occurs at
or near maximum densities. As a fully built-
out community, there is very little remaining
vacant land in the city. A review of recent
housing development on vacant land in Azusa
shows only one residential project in recent
years (2018-2021) was proposed on vacant
land outside of the Downtown TOD Specific
Plan area. The project (573-577 E. Arrow
Highway in the Arrow Highway Corridor zone)
had a maximum allowable density of 27 du/
ac. The project was approved at 22.72 du/ac,
equivalent to 84 percent of maximum density.
Table H-5.5: Underutilized Residential Land Inventory
General Plan
Designation Zoning Maximum
Density
Assumed
Density
Vacant
Acres
Potential
Dwelling
Units
Affordability Level
Moderate Density
Residential MODR 27 du/
acre
22 du/
acre 3.7 87 Moderate
Medium Density
Residential MDR 15 du/
acre
12 du/
acre 0.44 6 Above Moderate
Low Density
Residential LDR 8 du/
acre
6 du/
acre 1.56 10 Above Moderate
Total ------5.7 103 --
Note: Potential dwelling units do not reflect straight application of maximum density to vacant land. The number of potential dwelling units
in residential areas has been reduced by 16 percent based on local development trends.
Two other projects outside of the TOD Specific
Plan area were constructed on nonvacant lots
during this time; both of these achieved higher
densities (24 and 25 du/ac, respectively). Using
the lowest density example as a conservative
approach, 84 percent of the maximum density
was utilized to calculate realistic capacity
for vacant residential sites, resulting in an
estimated capacity of 34 new dwelling units on
vacant residential lots (Table H-5.4).
In addition to vacant sites, up to 103 future
housing units can be accommodated on
underutilized residential lots developed at less
than the maximum permitted density (Table
H-5.5). Based on recent development trends,
84 percent of maximum density was utilized
to calculate realistic capacity for nonvacant
residential sites.
Table H-5.4: Vacant Residential Land Inventory
General Plan
Designation Zoning Maximum
Density
Assumed
Density
Vacant
Acres
Potential
Dwelling Units
Affordability
Level
Mod Density Residential MODR 27 du/acre 22 du/acre 0.08 2 Moderate
Med Density Residential MDR 15 du/acre 12 du/acre 0.94 12 Above Moderate
Low Density Residential LDR 8 du/acre 6 du/acre 3.01 20 Above Moderate
Total -- ----4.03 34 --
Note: Potential dwelling units do not reflect straight application of maximum density to vacant land. The number of potential dwelling units in
residential areas has been reduced by 16 percent based on local development trends.
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Given the scarcity of developable land in
Azusa and the continuing demand for housing
in Los Angeles County, nearly all of the
recent residential construction in the city has
involved infill development on underutilized
properties. The analysis of residential
capacity on recyclable land included in this
section includes underutilized parcels in
the low, medium, and moderate density
residential zones. The parcels identified in
the LDR (Low Density Residential Zone) have
nonconforming commercial or industrial uses
and are large sites. Parcels identified in the
MDR (Medium Density Residential Zone) and
MODR (Moderate Density Residential Zone)
are underutilized based on building age and
are able to at least double the number of
units on the site.
Residential Zones - Density and
Affordability Assumptions
The analysis of vacant land for residential
sites utilized City Geographic Information
System (GIS) data to identify vacant parcels
designated as one of the three General
Plan residential land use designations/
Zoning subzones: Low Density Residential
(LDR), Medium Density Residential (MDR),
and Moderate Density Residential (MODR).
Underutilized sites were identified with
the help of the City’s GIS data. In order
to calculate realistic potential units in
residential areas, potential site constraints
and applicable development standards were
considered.
Due to the predominantly built-out nature of
Azusa, most development will occur as infill
on underutilized sites. In residential areas,
these underutilized parcels generally are
occupied by only one or two single-family
homes, parking lots, and nonconforming
uses. Program H3-8 is included in the
Housing Plan requiring the replacement of
units affordable to the same or lower income
level as a condition of any development
on a nonvacant site consistent with those
requirements set forth in Government Code
section 65915(c)(3). The identified sites in the
LDR, MDR, and MODR zones are appropriate
for accommodating moderate and above-
moderate income households and may also
support lower income housing. Sites in the
LDR (maximum density of eight units per
acre) and MDR (maximum density of 15 units
per acre) zones are identified to meet the
above moderate-income RHNA. Sites in the
MODR (maximum density of 27 units per
acre) are identified to meet the moderate-
income RHNA. Senior housing is permitted
with an MUP in MDR and MODR up to 40
units per acre. Program H3-3 is included in the
Housing Plan (Chapter 2) to remove the MUP
requirement from senior housing in all zones.
The rental and ownership housing stock in
Azusa is significantly more affordable (on
average) than surrounding Los Angeles County
cities. Many cities in the region have a history
of actively discouraging the provision of multi-
family or entry-level housing. As a result, Azusa
has long been and remains one of the most
affordable cities in Los Angeles County for
both renters and owners (48 percent of Azusa
households are renters). As noted in Chapter
3 (Needs Assessment), average rents are
well below the fair market rent for the region,
and median home sale prices in Azusa are
over $200,000 lower than the median for Los
Angeles County. Due to the significantly lower
housing costs in Azusa relative to other Los
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Angeles County communities, the City has
determined that 27 units per acre is adequate
to facilitate the development of affordable
housing for moderate-income households,
and may likely also be appropriate to facilitate
the development of affordable housing for
very low- or low-income households as well.
Recycling to higher-intensity uses is likely
to occur in Azusa. Most development in
Azusa occurs as infill development and
replaces less intense uses. The scarcity of
land makes higher-density development
most cost effective in the Moderate Density
Residential (MODR) areas. Even so, the City
acknowledges that small lot development in
residential areas may be more difficult and
thus has only identified properties that have
the potential for sufficient added capacity
to make recycling of land economically
feasible. For all underutilized residential
properties included in this sites inventory
(with the exception of residential projects
that are currently proposed), realistic
capacity was calculated to be at least twice
the number of existing housing units. The
calculations presented in Tables H-5.4 and
H-5.5 do not include potential density bonus
units. In addition, nearly all sites identified in
the MODR zone offer opportunities for lot
consolidation, with multiple adjacent sites
identified.
Vacant and Underutilized Mixed-Use
Land
Nearly all of Azusa is developed; there
is an extremely limited amount of vacant
land within City limits. However, the mixed-
used zones, developed as part of the 2004
General Plan, have capacity to accommodate
additional residential growth. The General
Plan recognizes the importance of and
increased vitality provided by mixed-use areas
and permits mixed-use within the following
planning areas: Neighborhood Center,
Edgewood District, Azusa Avenue Corridor,
San Gabriel Avenue Corridor, South Azusa
Avenue Corridor, Arrow Highway Corridor,
Table H-5.6: Vacant Mixed-Use Sites
General Plan
Designation Zoning Maximum
Density
Assumed
Density
Vacant
Acres
Potential
Dwelling
Units
Affordability
Level
Commercial Mixed-Use Arrow Highway
Corridor 27 du/acre 18 du/acre 0.18 3 Above
Moderate
Commercial Mixed-Use Azusa Avenue
Corridor 27 du/acre 18 du/acre 1.17 21 Above
Moderate
Residential Mixed Use South Azusa
Avenue Corridor 27 du/acre 18 du/acre 4.0 73 Above
Moderate
Commercial/Residential
Mixed Use District Edgewood District 27 du/acre 18 du/acre 0.33 6 Above
Moderate
Commercial/Residential
Mixed Use District University District 27 du/acre 18 du/acre 1.4 28 Above
Moderate
Neighborhood Center Neighborhood
Center 27 du/acre 18 du/acre 1.55 25 Above
Moderate
Residential Mixed Use San Gabriel Avenue
Corridor 27 du/acre 18 du/acre 0.32 6 Above
Moderate
Total 8.95 162
Note: Potential dwelling units do not reflect straight application of maximum density to vacant land. The number of potential
dwelling units has been reduced to 67 percent of the maximum density in previous mixed-use projects to reflect the possibility of
commercial development or individual site constraints on unique parcels.
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and Foothill Boulevard Corridor. These areas
allow residential development at up to 27
units per acre and are generally concentrated
along major corridors. These designations
are intended to provide enhanced pedestrian
activity and facilitate connections between
neighborhoods and districts. Neighborhood
Centers are intended to provide a place for
neighbors to gather and combine a mix of
uses.
The potential for development of residential
units in mixed-use areas is predicated on the
interest from developers and on the limited
opportunities for higher-density development
elsewhere in the immediate surrounding
areas. The Housing Element assumes
development would realistically occur at
18 units per acre for housing in mixed-use
zones, which is less than the average density
Table H-5.7: Underutilized Mixed-Use Sites
General Plan
Designation Zoning Maximum
Density
Assumed
Density
Vacant
Acres
Potential
Dwelling
Units
Affordability
Level
Commercial Mixed-Use Arrow Highway
Corridor 27 du/acre 18 du/acre 8.79 159
Above
Moderate/
Moderate
Commercial Mixed-Use Azusa Avenue
Corridor 27 du/acre 18 du/acre 2.09 39
Above
Moderate/
Moderate
Residential Mixed Use
South Azusa
Avenue
Corridor
27 du/acre 18 du/acre 1.25 23
Above
Moderate/
Moderate
Commercial/Residential
Mixed Use District
University
District 27 du/acre 18 du/acre 11.22 203
Above
Moderate/
Moderate
Neighborhood Center Neighborhood
Center 27 du/acre 18 du/acre 0.16 3
Above
Moderate/
Moderate
Residential Mixed Use
San Gabriel
Avenue
Corridor
27 du/acre 18 du/acre 0.48 9
Above
Moderate/
Moderate
Total 23.99 436
Note: Potential dwelling units do not reflect straight application of maximum density to underutilized land. The number of
potential dwelling units has been reduced to 67 percent of the maximum density in previous mixed-use projects to reflect the
possibility of commercial development or individual site constraints on unique parcels.
for mixed-use projects currently in the
pipeline. This is equivalent to 67 percent of the
maximum capacity for mixed-use sites and will
also account for the possibility of commercial
development or individual site constraints on
unique parcels.
A survey of vacant land was conducted in
areas that permit mixed-use development.
Vacant land allowing mixed-use development
totals 8.95 acres, with a potential for 162 new
dwelling units (Table H-5.6).
In addition to these vacant sites, there are also
a number of underutilized properties along
the major corridors that allow mixed use. A
total of 23.99 acres of underutilized parcels
in mixed-use zones were identified, with a
potential to yield 436 new dwelling units (Table
H-5.7).
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The sites chosen are significantly
underutilized given their size, age of structure,
and given the development potential under
the mixed use development standards. All of
the sites with existing residential uses provide
the opportunity to more than double the unit
capacity. Other criteria that were applied
to further identify underutilized sites within
mixed use areas parallel recent development
trends and include:
• Existing uses are not higher-density
residential (condominiums or
apartments).
• Property contains structures/site
improvements that are 30 years or
older.
• Potential for lot consolidation exists.
These sites are included because the
multiple parcels function as one site,
such as a structure and its attached
parking lot or a single structure located
on multiple parcels, or have significant
potential for lot consolidation due
to substantially underutilized uses
on adjacent parcels. Many also have
common or government ownership.
• Uses are characterized by small-scale,
declining, or legal nonconforming
uses, such as auto repair and sales,
retail stores, or offices, often with
vacancies, or one residential unit,
consistent with recent local and
regional development trends.
• Property contains structures/site that
is considered underutilized with an
existing FAR less than one, smaller
buildings, and large parking lot areas.
• Sites located near recent mixed-use or
residential development on properties
exhibiting similar characteristics.
• In general, land values are higher than
improvement values.
• No recent, significant enhancements
have been made (exempt
enhancements include site cleanup or
paint).
• Property owners or developers have
expressed interest in redeveloping the
site.
Sites that meet a combination of at least
four of the criteria listed above have been
included in the sites inventory (Appendix
B) due to redevelopment/recycling trends
exhibited in the City as shown in Tables H-5.12
and H-5.13.
Typical characteristics of underutilized
mixed use sites include low-intensity uses
(all sites have an FAR of less than one), low
improvement to land value ratio (75% of
sites have an ILR of less than one), existing
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structures over 30 years (all sites have
structures older than 30 years), and potential
for lot consolidation (two-thirds have the
potential for lot consolidation).
In a few cases, a parcel is included with a
slightly higher improvement value if the
structure is older or shows obvious signs
of deferred maintenance or if the site is
underutilized (characterized by large surface
parking or unused surface area on the site). It
is important to note that while the assessed
improvement-to-land (I/L) ratio is often used
as an indicator of economic underutilization,
limitations on assessments under Proposition
13 can distort I/L ratios when a property has
not sold and been reassessed at market value
in many years, resulting in a higher ratio than
would actually be calculated if the property
were reassessed with today’s land values.
Additional information on the redevelopment
potential of underutilized sites with residential
and nonresidential uses in both Mixed
Use Zones and TOD Specific Plan areas is
discussed in more detail following Table
H-5.12.
Mixed-Use Zones - Density and
Affordability Assumptions
Many areas within the city are identified
for mixed-use development, including
Districts (University and Edgewood) and
Corridors (Foothill Boulevard, Azusa Avenue,
San Gabriel Avenue, South Azusa Avenue,
and Arrow Highway). Since the maximum
allowable density is 27 du/acre for all of these
zones, the sites identified in the mixed-use
areas are appropriate for accommodating
moderate-income housing. Senior housing is
permitted at 40 units per acre in all Corridor
zones. Several recent proposed projects
are located in mixed use zones, as shown in
Table H-5.8, and have achieved density near
the maximum density (or exceeding it). The
Gladstone Senior Village received a density
bonus for provision of six low-income units,
thus reaching 49 units per acre (senior housing
is permitted at 40 units per acre). The other
two projects consist largely of townhomes,
which generally lend themselves to a lower
density by design. Program H4-4 is included in
the Housing Element to allow stacked flats in
all of these zones, allowing for an increase in
density through site design.
Many of the mixed-use designations in
Azusa require a portion of the project to
be a commercial use to facilitate an active
pedestrian environment at the ground floor of
projects. Azusa’s mixed-use standards include
limited setback requirements and incentives
for mixed-use that have resulted in approved
housing projects nearing maximum densities.
Projects can also comply with the requirement
for commercial ground floor uses by including
live/work units on the ground floor. For
example, the proposed project at 333 N.
Azusa will adapt an existing small commercial
space into a live/work unit and add three
townhomes behind the former commercial
space.
Even so, to be conservative, the Housing
Element assumes development would
realistically occur at 18 units per acre for
housing in mixed-use zones, which is
equivalent to 67 percent of the maximum
density of projects currently in the pipeline.
This also accounts for the possibility of
commercial development or individual site
constraints on unique parcels.
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Table H-5.8: Density of Proposed Projects in Mixed-Use Zones
Project Name Zoning Actual
Density Housing Type # of
units Status Affordability
Level
Gladstone Senior
Village
Edgewood
District 49 du/acre Apartments 60 Constructed Above Moderate
and 6 Low
573-577 E. Arrow
Highway CAH 23 du/acre Townhomes 10 Plan check Above Moderate
333 N Azusa Ave CAZ 25 du/acre Townhomes
and Live/Work 4 Entitlement
Phase Above Moderate
Source: City of Azusa, 2021
Table 5.9: Azusa TOD Specific Plan Sites
TOD Specific Plan Zone
Small Sites
Realistic
Capacity
Affordability
Level
Large Sites
Realistic
Capacity
Affordability Level
Total Sites
Realistic
Capacity
Downtown District 34 Above
Moderate 66 Very Low/Low 100
Gold Line District 15 Above
Moderate 77 Very Low/Low 92
Route 66 District 181 Above
Moderate 481 Very Low/Low 662
Downtown Expansion District 4 Above
Moderate 127 Very Low/Low 131
Transition District 21 Above
Moderate 266 Very Low/Low 287
Civic 9 Above
Moderate --Very Low/Low 9
Total 264 Above
Moderate 1,017 Very Low/Low 1,281
Note: Potential dwelling units reflect average densities of recent development trends in the Specific Plan area; smaller sites at 28 du/ac and larger
sites at 102 du/ac. The number of potential dwelling units has been reduced to 85 percent of maximum allowable units to reflect the probability of
commercial development.
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Vacant and Underutilized Transit-
Oriented Development (TOD)
District Land
The Azusa TOD Specific Plan, adopted in
2015 and amended in 2018, was initiated by
the City to guide growth and development
in Downtown and near Metro L (Gold) Line
Stations, encourage economic revitalization,
and create a lively center of activity. The
Specific Plan encompasses the area generally
within 0.25 mile radius of the two transit
stations (APU/Citrus and Azusa Downtown)
for a total of 350 acres of land. The plan
provides a framework to establish a mix
of uses in six unique districts, each with
specific development standards and design
guidelines. Azusa’s Downtown is envisioned
as a vibrant urban center providing a wide
array of dining, working, living, shopping,
entertainment, and cultural opportunities all
within a short walking distance. The Specific
Plan emphasizes the importance of mixed-
use and pedestrian-oriented development
within the L (Gold) Line station areas, to
support both the character of the city and
transit ridership. The Specific Plan allows a
wide range of housing types to encourage
ridership and economic growth.
As discussed in the Constraints Chapter,
the development standards defined in the
TOD Specific Plan do not define minimum
or maximum densities but rather rely on lot
coverage and specific design standards to
guide the aesthetics of the area. Current
development trends in the Specific Plan
area show that a range of medium to high
residential density is feasible and realistic,
appropriate to accommodate housing for all
income levels.
The realistic capacity calculated for sites in
the TOD Specific Plan is based on the average
density and acreage of projects approved in
the past few years. A conservative estimate
of 85 percent of the average density has
been applied to account for the possibility of
commercial development or any individual site
constraints on unique parcels.
A survey of vacant and underutilized land
reveals that the Specific Plan area has 18.47
acres of vacant and underutilized land that
could realistically yield 1,281 units. Table
H-5.9 summarizes the capacity calculated and
affordability assumptions. See Appendix B for
more details and the affordability assumption
for each site identified. Site selection in the
TOD Specific Plan area is based on both
vacant and the underutilized nature of the
sites. This area, as the center of Azusa provides
a high profile and the City is seeing increasing
demand for residential development,
encouraged by the flexibility provided by the
TOD Specific Plan. Key sites with existing uses
that are ripe for redevelopment were chosen
because they contained older structures
(over 30 years of age) and are underutilized
given the development potential afforded
by the Specific Plan development standards.
Examples of existing uses include small-scale
commercial uses, car washes, and structures
with large surface parking lots. All of the sites
with existing residential uses provide the
opportunity for significant capacity increases
(more than double). Other criteria that were
applied to further identify underutilized sites
within the TOD Specific Plan area include:
• Existing uses are not higher-density
residential (condominiums or
apartments).
• Property contains structures/site
improvements 30 years old or more.
• Potential for lot consolidation exists.
These sites are included because the
multiple parcels function as one site,
such as a structure and its attached
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Table H-5.10: Projects in Azusa TOD Specific Plan Area
Project Name Zoning Acres # of
units
Actual
Density
Housing
Type Status Affordability
Level
820 N. Soldano Transition 0.25 6 24 du/
acre Townhome Plan Check Above
Moderate
The Orchard (626 N.
Azusa)Downtown 2.24 163 73 du/
acre Apartment Under
Construction
Above
Moderate
619 N. San Gabriel
Ave
Downtown
Expansion 0.16 6 38 du/
acre Apartment Under
Construction
Above
Moderate
300 W. Foothill Blvd Route 66 0.34 7 21 du/
acre Townhome Plan Check Above
Moderate
The Avenue (800 N.
Azusa)Gold Line 1.20 127 106 du/
acre Apartment Entitled Above
Moderate
The Citrus View (525
N. Azusa)Downtown 0.80 102
128 du/
acre Apartment Prelim Plan
Review
Above
Moderate
Source: City of Azusa, 2021
parking lot or a single structure located
on multiple parcels, or have significant
potential for lot consolidation due
to substantially underutilized uses
on adjacent parcels. Many also have
common or government ownership.
• Uses are characterized by small-scale,
declining, or legal nonconforming
uses, such as auto repair and sales,
retail stores, or offices, often with
vacancies, or older single-family
structures.
• Property contains structures/site that
is considered underutilized, with an
existing FAR less than one, smaller
buildings, and large parking lot areas.
• Sites are located near recent mixed-
use or residential development
on properties exhibiting similar
characteristics, which may act as a
catalyst to redevelopment.
• Sites are located near high quality
transit (within a 10-minute walk). TOD
Specific Plan area sites are located
near two Metro L (Gold) Line stations
(Azusa Downtown and APU/Citrus
Station). In addition to increasing
development potential, these parcels
are also subject to AB 2097 and
no minimum parking requirements
may be required by the City, further
encouraging redevelopment.
• In general, land values are higher than
improvement values. In a few cases, a
parcel is included with a slightly higher
improvement value if the structure
is older or shows obvious signs of
deferred maintenance or if the site is
underutilized (characterized by large
surface parking or unused surface
area on the site). For sites comprised
of several parcels, the improvement
to land value was calculated for
the whole site, since these types of
sites function as one. In some cases,
this criterion is not met. While the
assessed improvements-to-land (I/L)
ratio is often used as an indicator of
economic underutilization, limitations
on assessments under Proposition 13
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can distort I/L ratios when a property
has not sold and been reassessed at
market value in many years, resulting
in a higher ratio than would actually
be calculated if the property were
reassessed with today’s land values.
• No recent, significant enhancements
have been made (exempt
enhancements include site cleanup or
paint).
• Expressed interests from property
owners or developers
Not all non-vacant sites in the TOD Specific
Plan area contain each of these criteria;
however, all TOD sites contain a combination
of at least four of the characteristics listed
above. Typical characteristics of sites in the
TOD Specific Plan area include low-intensity
uses (all sites have an FAR of one or less),
low improvement to land value ratio (83
percent of sites have an ILR of less than one),
existing structures over 30 years (all sites
have structures over 30 years old), location
near recent catalytic housing developments,
location very near transit in a zone that
allows unlimited density, and potential for lot
consolidation (79 percent have the potential
for lot consolidation, many with common
ownership). Sites that meet a combination
of at least four of the criteria listed above
have been included in the sites inventory
(Appendix B) due to correlation with the
redevelopment/recycling trends exhibited in
the City as shown in Table H-5.12 and H-5.13.
Appendix B also provides more detail on the
sites included in the inventory including the
criteria used in identifying underutilized sites.
Azusa TOD Specific Plan - Density and
Affordability Assumptions
Since the City adopted the Azusa TOD
Specific Plan in 2015, the City has seen an
incredible increase in development interest in
the Downtown and near the transit stations,
including six of the 10 pending and approved
projects as of spring 2021. The estimated
realistic capacity for sites in the Azusa TOD
Specific Plan area is based on allowed uses
and recent development trends. Since the
Specific Plan does not define minimum or
maximum densities, the site inventory analysis
calculated the realistic capacity based on
the average density and acreage of the
approved projects listed in Table H-5.10.
There is variation in the densities achieved for
smaller projects (less than 0.5 acres) and larger
projects (greater than 0.5 acres); the average
densities for smaller sites are generally lower
than densities achieved on larger sites. Recent
projects on large sites (greater than 0.5
acres) have an average density of 102 du/acre
and current proposed projects are seeking
densities as high as 128 du/acre. Small projects
have an average density of 28 du/acre. Due to
the range in potential densities, the Specific
Plan has the capacity to accommodate a range
of housing types for all income levels. Large
sites that are more than 0.5 acres are identified
as most appropriate to accommodate lower-
income housing. Sites smaller than 0.5 acres
are identified as suitable to accommodate
above moderate-income households. A
conservative estimate of 85 percent of the
average density for large and small sites has
been applied to account for the possibility of
commercial development or any individual site
constraints on unique parcels.
Mixed Use Assumptions for Realistic
Capacity (Mixed-Use Zones and TOD
Specific Plan)
Many of the mixed-use designations in
Azusa require a portion of the project to
be a commercial use to facilitate an active
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
pedestrian environment at the ground floor of
projects. Azusa’s mixed-use standards include
limited setback requirements and incentives
for mixed-use that have resulted in approved
housing projects nearing maximum densities.
Projects can also comply with the requirement
for commercial ground floor uses by including
live/work units on the ground floor. For
example, the proposed project at 333 N.
Azusa will adapt an existing small commercial
space into a live/work unit and add three
townhomes behind the former commercial
space.
A survey of recent local development trends
was performed to estimate the possibility of
commercial development vs. mixed-use or
residential development throughout Azusa
(Table H-5.11).
Between 2018 and 2020, nine developments
were approved in the mixed-use zones and the
TOD Specific Plan areas. Of these, three were
entirely commercial and the rest were housing
or mixed-use projects (Table H-5.11). Mixed-
use projects were predominately residential
with a small portion of commercial and did
not diminish the ability of projects to achieve
maximum densities (commercial allowances
and residential allowances are calculated
separately.) While it is possible for projects to
be 100 percent commercial in the mixed-use
districts, only 33 percent of the projects over
the past few years have been 100 percent
commercial, and none of these have occurred
in the City’s TOD Specific Plan. The remaining
66 percent have included housing of a variety
of different types and sizes, adding 317
new units to the City’s housing stock. These
Table H-5.11: Mixed-Use Development Trends
Project Name Zoning Actual
Density
Commercial
Space
# of
units
Year
Approved Status
Raising Cane’s (855 E.
Alosta Ave.)
University
District --3,051 s.f. --2018 Constructed
In-N-Out (998 E. Alosta
Ave.)
University
District --3,800 s.f.--2018 Constructed
573-577 E. Arrow
Highway
Arrow
Highway
Corridor
23 du/acre --10 2018 Plan Check
333 N Azusa Ave
Azusa
Avenue
Corridor
25 du/acre 5,500 s.f.4 2020 Entitled
1041 W. Arrow Hwy
(Express Car Wash)
Arrow
Highway
Corridor
--3,006 s.f.--2020 Plan Check
The Orchard (626 N.
Azusa Ave.)
TOD SP:
Downtown 73 du/acre 23,366 s.f.163 2018 Under
Construction
The Avenue (800 N.
Azusa Ave.)
TOD SP:
Gold Line
106 du/
acre 12,000 s.f.127 2018 Entitled
300 W. Foothill Blvd TOD SP:
Route 66 21 du/acre 633 s.f.7 2019 Plan Check
820 N. Soldano Ave.TOD SP:
Transition 24 du/acre --6 2019 Plan Check
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projects have achieved densities nearing
maximum allowed density, and Program
H4-4 is anticipated to open up additional
opportunities along major corridors with
a new building type, allowing for stacked
flats rather than limiting building types to
townhomes. This program is anticipated
to facilitate densities well beyond those
assumed for the realistic capacity analysis in
the Housing Element (67 percent of maximum
capacity in Mixed Use zones).
Furthermore, with the declining trend of retail
and potential impacts of COVID-19 on office
use, as well as the continued upward trend in
housing prices, the prospect of 100 percent
commercial projects is not likely to increase
in the near future. The estimate of potential
residential capacity is based on densities that
are below the demonstrated trends. Through
the City’s upcoming General Plan update, the
corridors will be re-evaluated and incentives
for additional housing opportunities are also
anticipated. Therefore, this sites inventory
includes a healthy buffer to accommodate the
potential loss of residential capacity due to
commercial development.
Redevelopment of Existing Residential
Uses (Mixed-Use Zones and TOD
Specific Plan)
The City’s 2002 General Plan update sought
to reverse previous standards and policies
that segregate complimentary land uses
and contribute to “dreary sprawl.” The
General Plan aims to “repair the City’s
damaged urban form and reverse the
decline of neighborhoods and districts by
applying the principles of New Urbanism
(i.e., walkability, connectivity, mixed-use,
traditional neighborhood structure, timeless
architecture and human-scale urban design).”
The City’s districts and corridors were
updated to allow for flexibility and a mix of
uses. In some of these locations, existing
residential uses are common. The General
Plan allows for additional capacity within
these neighborhoods, corridors, and districts
that are prime for additional density. Some of
these are included in the sites inventory, some
are proposed, and some have already been
redeveloped.
Table H-5.12 summarizes recent (since
2017 ) redevelopment of sites with existing
residential uses to include additional housing
units. Since 2017, 13 sites each containing
one residential unit have redeveloped or are
under preliminary review for higher intensity
housing. Sites smaller than a half-acre have
all added an additional unit, doubling the
existing capacity, while larger sites have
increased capacity by 6 to 21 times. This
summary does not include ADU development
and indicates that development trends in
Azusa are favorable to convert lower-density
residential uses into higher density residential
uses.
The extremely limited supply of vacant land
in Azusa and across the Los Angeles County
region indicate market conditions for more
intensive, compact, and infill development
or redevelopment. Many cities across the
County have recent redevelopment occurring
on sites that held a previous residential or
nonresidential use.
As indicated in Table H-5.12, significant
redevelopment of single-family residential
uses has been underway in Azusa in recent
years. Characteristics of sites identified to
meet the RHNA in the Mixed-Use Zones and
TOD Specific Plan area are similar to the sites
that have redeveloped into housing in the
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Table H-5.12: Redevelopment with Existing Residential Uses
Project Zone
Lot Size
(Acres)
Building
Size
(Sq� Ft �)
Year
Built
Existing
Units
Proposed
Units
New
Total
Units
Year
Approved Criteria
626 N. Dalton
Ave.
NG2 0.173 1,938 1926 1 1 2 2017 • Structure over 30
years old
• Doubled capacity
• Low intensity use
1103 N.
Azusa Ave.NG1 0.339 1,762 1897 1 1 2 2017
• Structure over 30
years old
• Doubled capacity
• Low intensity use
306 N.
Soldano Ave.NG2 0.173 1,054 1928 1 1 2 2017
• Structure over 30
years old
• Doubled capacity
• Low intensity use
418 N. Dalton
Ave.NG2 0.17 ----1 1 2 2018
• Structure over 30
years old
• Doubled capacity
• Low intensity use
315 N. Dalton
Ave.NG2 0.162 1,088 1930 1 1 2 2018
• Structure over 30
years old
• Doubled capacity
• Low intensity use
513 N. Dalton
Ave.NG2 0.162 1,052 1949 1 1 2 2018
• Structure over 30
years old
• Doubled capacity
• Low intensity use
342 N. Dalton
Ave.NG2 0.17 1,038 1927 1 1 2 2019
• Structure over 30
years old
• Doubled capacity
• Low intensity use
1014 N.
Vernon Ave.NG1 0.159 1,631 1957 1 1 2 2019
• Structure over 30
years old
• Doubled capacity
• Low intensity use
820 N.
Soldano Ave.
TOD SP -
Transition 0.259 2,000 1927 2 4 6 2019
• Structure over 30
years old
• Property located
in mixed use
zones or specific
plan areas
• Doubled capacity
• Low intensity use
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Table H-5.12: Redevelopment with Existing Residential Uses
Project Zone
Lot Size
(Acres)
Building
Size
(Sq� Ft�)
Year
Built
Existing
Units
Proposed
Units
New
Total
Units
Year
Approved Criteria
171 N. Dalton
Ave.NG2 0.17 1,024 1927 1 3 4 2021
440 E. 1st St.CSA 0.43 948 1953 1 21 22
Prelim
Review
• Structure over 30
years old
• Property located
in mixed use
zones or specific
plan areas
• Doubled capacity
• Low intensity use
627 Old
Sierra Madre
Rd.NG3 2.025 1,203 1930 1 6 7
Prelim
Review
• Structure over 30
years old
• Doubled capacity
• Low intensity use
504 E. 6th St.NG2 0.256 1,808 1950 1 3 4
Prelim
Review
• Structure over 30
years old
• Doubled capacity
• Low intensity use
area recently, as summarized in Table H-5.12.
The identified sites in the inventory with
existing residential uses have a similar existing
building and lot size pattern; past trends show
a median building size of 1,146 square feet
and a median lot size of 0.17 acres. Sites with
existing residential uses in the inventory have
a median building size of 1,332 square feet
and a median lot size of 0.16 acres. Past trends
show that buildings were generally older than
30 years. The identified sites do not include
any buildings that were constructed in the last
30 years. Past trends show redevelopment at
least doubles existing capacity; all sites with
existing residential uses included in the sites
inventory have the ability to at least double
the existing capacity, with many having
significant capacity potential.
As such, the same factors that exist for the
recent developments outlined in Table H-5.12
are shown for each site in the sites inventory
(see Appendix B) to justify inclusion based on
similarities to approved/built projects.
For the sites located in the TOD Specific
Plan, the most compatible use that enables
higher transit ridership is multi-family housing,
making high intensity housing the highest and
best use in these areas. The redevelopment
of residential uses near new transit lines has
also been occurring in many cities across Los
Angeles County, including redeveloping a
full block or row of single-family homes. In
Monrovia, the Arroyo at Monrovia Station,
which was approved by the City Council
in 2020, plans to replace nine single-family
homes and two commercial buildings with 324
new residential units. This project is adjacent
to Metro’s L Line’s Monrovia Station. In
Pasadena, Union Village, constructed in 2016,
replaced 3 single-family homes, a two-story
apartment building, and parking lots with 118
two-story townhomes. Another project at 130-
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
140 N. Mar Vista Avenue in Pasadena, which
is slated for construction, will replace two
single-family homes. Both of these Pasadena
developments are within a mile of L Line
stations. In the City of Los Angeles, Carmel
Partners is planning to replace 16 single-
family homes with 455 new residential units,
about a block away from the Metro E Line’s
Expo/Bundy Station. The project is currently
going through the entitlement process and
has also been included in the City of Los
Angeles’s recently certified Housing Element
as a pipeline project. The developer of the
project hopes to break ground in 2023. These
regional trends show similarities to several of
the sites included in the inventory, where a
consolidated group of four to six single-family
homes were chosen based on their potential
to increase capacity by 6 to 21 times. Regional
trends have shown that anywhere from a
group of three to more than a dozen single-
family homes have been or are slated to be
demolished to make way for high-density
multi-family residential uses near Metro
light rail stations. Given the close proximity
of these sties to Azusa’s light rail stations,
the single-family sites in the inventory were
chosen based on characteristics showing
declining value and the potential for greater
compatibility between higher-density
residential uses and transit, reflective of these
regional trends.
Property owners of sites identified to
meet the RHNA were contacted as part
of the Housing Element update. While
responses were limited, all who responded
indicated that they were “very interested” in
redevelopment with higher density residential
uses, including property owners with a single
residential unit as the existing use.
Based on the above and development history
presented in Table H-5.12, there is a clear
demonstration that:
• The City has experienced the
conversion of a single residential
unit to higher density residential
development
• Existing uses do not pose an
impediment to additional residential
development and have similar
characteristics to local and regional
redevelopment trends
• Market demand exists for higher
density residential development on
underutilized sites
Redevelopment of Existing
Nonresidential Uses (Mixed-Use Zones
and TOD Specific Plan)
Where existing uses are nonresidential, the
City has also seen significant redevelopment
interest in recent years, which is anticipated
to continue to grow as market trends support
additional housing development. Nearly all
redevelopment occurs on sites that at some
point held a previous use, either recently or
a more distant past with a building that had
been demolished after it fell into disrepair.
Details about the types of uses that typically
redevelop in Azusa are useful to understand
redevelopment trends specific to Azusa and
support the likelihood of redevelopment of
sites identified in the inventory. Table H-5.13
summarizes recent housing projects in Azusa
and the surrounding region, portraying typical
development patterns and trends.
While certain sites included in the inventory
are located on Historic US Route 66, this
designation does not institute any additional
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
constraints to development along the Route.
No sites include buildings that are listed on
any local, state, or federal historic registers.
As indicated in Table H-5.13, there is a
large variety of existing uses that are being
recycled and replaced with housing, ranging
from small-scale commercial, offices, auto-
repair, and single- and two-unit housing.
Many of these sites also had large parking
lots, low land to value ratios, and aging
buildings. These trends were used to identify
the sites in the sites inventory to meet the
RHNA . Sites were chosen for inclusion in the
sites inventory based on similar characteristics
to recent or active projects (Table H-5.12 and
Table H-5.13) such as: similar existing uses,
structures 30 years or older, improvement
values less than 1.0, and FAR less than
1.0. The following describes how these
characteristics relate to the sites identified
and their similarity to past or recent projects.
Improvement to land value ratio of less than
one. Improvement-to-land (I/L) value ratio
provide insight to the declining condition
of the structure on site. Generally, a ratio
of less than one indicates that the existing
use is of marginal or low-value. Typically,
parking lots are a low-intensity and low-value
use that require minimal investment cost in
comparison to the cost of land. While the
assessed I/L ratio is often used as an indicator
of economic underutilization, limitations on
assessments under Proposition 13 can distort
I/L ratios when a property has not sold and
been reassessed at market value in many
years, resulting in a higher ratio than would
actually be calculated if the property were
reassessed with today’s land values. About
80 percent of identified nonvacant sites in
Mixed Use Zones and TOD (small and large
sites) areas have I/L ratios below one, with
the median ratio being 0.29. Several parcels
included in the inventory are improved only
with a surface parking lot.
Property contains structures/site
improvements 30 years old or more. The
age of a structure is a key indicator in
assessing the existing condition of a site.
Older structures are often characterized by
deterioration, lack of adequate property
maintenance, or outdated interior/exterior
building components. These characteristics
often point to a need for remodeling or
upgrades to the structures making them ripe
for redevelopment. All nonvacant parcels in
Mixed-Use Zones and the TOD Specific Plan
(small and large sites) area that are included
in the inventory are over 30 year old or more,
with median age of 68 years. Some of these
structures also exhibit signs of declining
conditions, such as worn out exteriors or
signage. The age of the structures in the
inventory is similar to that of the previous
uses in recent/active projects in the City and
region (Table H-5.13), where most projects are
over 30 years old, with one housing project
in Azusa having redeveloped a structure that
was built in 2003, replacing the previous use
with housing.
Small-scale, declining, or legal
nonconforming uses, such as auto repair
and sales uses, retail stores, or offices.
Small-scale, declining, and marginal uses
have a history of being discontinued and
redeveloped into residential and mixed-use
developments. The demand for office and
retail space in many Southern California
communities, including Azusa, has been
declining due to a historic over-retailing
of corridors and the more recent boom of
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
e-commerce and COVID-19’s influence.
More than two-thirds of the sites identified
contain uses such as single-family homes,
hair salons, small restaurants, psychics, small
clothing stores, etc. Where there are existing
residential uses, sites were only chosen if
redevelopment could increase capacity by
more than double. Existing uses on the sites
are older or show signs of disinvestment
or deferred maintenance, indicating a
“ripeness” for redevelopment. To ensure
that appropriate sites have been chosen,
properties that show recent investments
or updates or that contain uses of local
importance are not included.
Uses that are nonconforming are also
considered marginal, given limitations in the
ability for property owners to expand that
use and clear policy direction for alternative
uses. Several zoning districts in the TOD
Specific Plan area do not all auto repair
services, rental of vehicles, towing services,
or single-family homes, among other uses. All
zoning districts in the TOD Specific Plan area,
except for the Transition District, do not allow
single-family residences. About 10 percent of
existing one- and two-unit dwellings are legal
nonconforming uses located in the Downtown
Expansion and Route 66 District. All of the
single-family residences in the sites inventory
are within a 1/2 mile of the Azusa Downtown
Station. This area of the community is the
most likely to redevelop, as the TOD Specific
Plan encourages higher-intensity residential
development to facilitate transit ridership with
no limitation on density. Regional trends have
shown the conversion of a cluster or block of
single-family homes to high-density multi-
family developments near transit, such as
Metro’s E and L light rail lines (see p.171).
Property contains structures/site that is
considered underutilized (i.e., buildings
that have existing FAR lower than one). For
nonresidential uses, FAR can be used to
measure building intensity; defined as the
ratio of building floor area to overall site
area. A low FAR, typically less than one,
means the building is smaller in floor area in
comparison to the overall site and therefore
has potential for intensification. All sites in the
Mixed-Use zones and TOD Specific Plan area
have an existing FAR of one or less, with the
median value of 0.12. Several of these sites
contain surface parking lots. This indicates
a significant degree of underutilization of
nonvacant uses in the mixed use and TOD
areas. Regional and local trends show that
previous uses had a median FAR of 0.18.
Location near recent mixed-use or residential
development activities on properties
exhibiting similar characteristics. Recent or
active residential development activities
tend to stimulate redevelopment of
surrounding properties, particularly those
that are underdeveloped or in need of major
rehabilitation. As shown in Table H-5.2, 11 of
the recently approved or proposed projects
are occurring in either the TOD Specific Plan
Area or mixed-use districts, resulting in the
addition of 510 new units in these areas. Many
of these projects are redeveloping existing
commercial or industrial uses. These trends
indicate the continued decline of marginal
nonresidential uses and the simultaneous
increase of high-density residential (either
as stand-alone or mixed use) development.
Furthermore, several sites in the TOD Specific
Plan and Mixed Use Zones area are within a
10-minute walk of one of two Metro L (Gold)
Line stations (Azusa Downtown and APU/
Citrus Station), which are both high-quality
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
transit stops. Redevelopment is anticipated
to be further encouraged in these areas by
AB 2097, which requires no additional parking
for residential uses near high-quality transit.
Approximately 53 percent of sites in Mixed
Use zones and TOD Specific Plan areas (small
and large sites) are within a 1/2 mile of a light
rail station.
Potential for lot consolidation. Parcels
that could be consolidated with adjacent
properties to form larger, higher-density
residential developments were included in the
inventory. Azusa has a record of approving
projects that utilize lot consolidations for
comprehensive, high-quality projects. The
City’s history of approvals of projects over
the years that consolidated lots (Table
H-5.15) demonstrates that there is developer
interest in consolidating parcels in the city,
and that Azusa has few constraints to lot
consolidation associated with new projects.
The City, through the former Redevelopment
Agency, supported the consolidation of
parcels and coordination of redevelopment
of the area formerly known as Block 36, now
under construction as the Orchard. About 75
percent of sites in the inventory have potential
for lot consolidation, some of which are also
under common or government ownership.
Expressed interests from property owners
or developers. The City surveyed property
owners in the sites inventory inquiring about
their interest in redeveloping their properties
for residential uses. All property owners who
responded to the survey indicated that they
were “very interested” in redevelopment.
No responses were received indicating no
interest in redevelopment. The respondents
were all located within the TOD Specific Plan
boundary. Properties included a variety of
current uses and lease lengths, including
commercial buildings with leases expiring in
the next 10 years, industrial buildings with
leases expiring within the next year, and
single-family houses with no current leases.
An additional factor related to trends is
the potential capacity increase available to
property owners. On the sites chosen for the
inventory, the residential capacity is two to 14
times the existing development. A majority of
sites are larger sites (i.e., one acre or larger),
which have more potential to significantly
increase residential capacity. Sites to meet
the RHNA are located in the City’s zones that
are designed to encourage higher density
residential development along corridors and
near the Metro L (Gold) Line stations.
In general, the market in Azusa and the
San Gabriel Valley supports housing as the
highest and best use of property, yielding
highest returns for property owners,
especially in existing neighborhoods, along
corridors, and in Downtowns such as Azusa’s,
with access to goods, services, and high-
quality transit. This new development is
most often occurring on properties without
recent investments, with aging structures, and
large parking lots due to the lack of available
vacant land throughout the region. A key
incentive to support this redevelopment
is increased density, such as the flexible
density allowances in the TOD Specific Plan,
which does not cap density on an individual
parcel basis. Many cities and neighborhoods
across Los Angeles County, such as in
Chinatown, Duarte, and Monrovia, have seen
the development of high intensity housing
near transit stations. Furthermore, changes
in consumer preferences and a shift from
traditional brick-and-mortar to e-commerce
present opportunities to repurpose existing
retail uses for new mixed-use residential
developments. This trend has occurred locally
and regionally as evidenced by Azusa’s Citrus
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
Junction, Alhambra’s Alhambra Place, and
Baldwin Park’s ROEM that serve as successful
examples of retail to residential mixed-use
conversions. The availability of aging retail
centers create multiple opportunities for
redevelopment of existing retail for residential
uses in the City. For example, several parcels
located near Citrus Junction contain shopping
centers and fast-food restaurants that were
originally developed in the late 1980s, are
surrounded by large parking fields, and lack
the walkable, place-making attributes of
today’s successful retail centers. The existing
layout of these retail uses, which are also
close to key activity centers like the Azusa
Pacific University and the L (Gold) Line’s APU/
Citrus College Station, mark these properties
underdeveloped and match regional trends
for redevelopment.
In June 2021, Azusa surveyed property
owners included in the sites inventory; three
property owners responded. All respondents
had existing uses on their sites and were
“very interested” in redevelopment with
higher density residential uses. Uses on their
properties included single-family residential,
commercial retail/services, and industrial uses.
All respondents were currently leasing to one
or two tenants or did not have a current lease
with tenants. Lease terms ranged from one
year remaining to 5-10 years remaining on the
lease. All respondents had a current lease
with tenants, and all respondents expressed
they were “very interested” in redeveloping
their property with housing uses.
Lease terms ranged from one year to 15 years,
indicating that leases have the potential to
be re-negotiated. Existing uses on properties
included industrial, commercial, and single-
family housing. No responses were received
indicating no interest in redevelopment.
This sites inventory presents the City’s good
faith effort to only identify sites that show
the most potential or where there is clear
interest for redevelopment. The City will
continue to engage local property owners to
discuss redevelopment opportunities on their
properties. Program H3-10 is included in the
Housing Plan to establish tools and actions to
support the redevelopment of existing non-
residential uses. Based on this analysis and
future efforts undertaken through Program
H3-10, the City concludes that existing
uses will not impede additional residential
development and all sites identified in
this Housing Element are intended to
demonstrate adequate sites to accommodate
the RHNA.
Based on the above, there is a clear
demonstration of:
• Local trends of converting existing
uses to higher density residential
development
• Existing uses do not pose an
impediment to additional residential
development and have similar
characteristics to local and regional
redevelopment trends
• Existing uses that do not pose an
impediment to additional residential
development
• A declining demand for sprawled-
out shopping centers in favor of
e-commerce or compact mixed-use
development
• Property owner interest in
redevelopment and potential for lease
renegotiation
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Table H-5.13: Redevelopment Trends of Nonvacant, Nonresidential Sites - City of Azusa and Los Angeles County Region
City of Azusa - Redevelopment Trends (Existing Uses on Approved and Proposed Projects)
Project Name/Location
New Units Previous Use FAR Previous
Structure Year
Built
Building
SF
Zoning Criteria
619 N. San Gabriel Avenue 6 Auto repair shop N/A 1970s N/A Downtown
Expansion
District
• Structure over 30 years old
• Use is discontinued or nonconforming to
the zoning district
• Occupied by small-scale, marginal uses
• Low-intensity structures/low FAR
• Property located in mixed use zones or
specific plan areas
The Orchard 163 Parking lot owned by
the City
------Downtown
District
• Common or government ownership of
parcels
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Property owner or developer interest to
redevelop
• Property located in mixed use zones or
specific plan areas
820 N. Soldano 6 Two dwelling units 0.17 1927 2,000 Transition
District
• Structures over 30 years old
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Property located in mixed use zones or
specific plan areas
• Doubled capacity
• Property located within 1/2 mile of light rail
station
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Table H-5.13: Redevelopment Trends of Nonvacant, Nonresidential Sites - City of Azusa and Los Angeles County Region
City of Azusa - Redevelopment Trends (Existing Uses on Approved and Proposed Projects)
Project Name/Location
New Units Previous Use FAR Previous
Structure Year
Built
Building
SF
Zoning Criteria
300 W. Foothill 7 Baseball Batting Cages
business; not in use
since 2014
0.4 --946 Route 66
District
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Property located in mixed use zones or
specific plan areas
• Property located within 1/2 mile of light rail
station
• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
The Citrus View 102 Currently has a Post
Office on site
0.3 1965 11,690 Downtown
District
• Structure over 30 years old
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Property located in mixed use zones or
specific plan areas
• Common or government ownership of
parcels
573-577 E. Arrow Highway 10 1960s commercial
building; the former
site of a sports bar that
ceased operation in
2013 and the building
was demolished in
2018
0.14 1960s 2,700 Arrow
Highway
Corridor
• Structure over 30 years old
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Property located in mixed use zones or
specific plan areas
• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING ELEMENT APPENDICES
Table H-5.13: Redevelopment Trends of Nonvacant, Nonresidential Sites - City of Azusa and Los Angeles County Region
City of Azusa - Redevelopment Trends (Existing Uses on Approved and Proposed Projects)
Project Name/Location
New Units Previous Use FAR Previous
Structure Year
Built
Building
SF
Zoning Criteria
The Avenue (800 N. Azusa)127 Vacant; previously
contained small-scale
commercial businesses
that were demolished
in 2009
------Gold Line
District
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Property located in mixed use zones or
specific plan areas
• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
• Property located within 1/2 mile of light rail
station
• Common or government ownership of
parcels
333 N. Azusa Avenue 4 Existing commercial
building that is the
current site of an
insurance company.
0.25 2003 1,800 Azusa
Avenue
Corridor
• Occupied by small-scale, marginal uses
• Low-intensity uses/low FAR
• Considered underdeveloped/underutilized
based on allowed intensity
• Property located in mixed use zones or
specific plan areas
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Table H-5.13: Redevelopment Trends of Nonvacant, Nonresidential Sites - City of Azusa and Los Angeles County Region
Los Angeles County Region - Redevelopment Trends
Project Name/Location
New Units Previous Use FAR Year
Built
Building
SF
Zoning Criteria
8408-8416 Garvey Avenue &
2736-2746 Delta Avenue
(City of Rosemead)
46 Restaurant, office, and
residential
0.08 1976 3,907 --• Structure over 30 years old
• Property located in mixed use zones or
specific plan areas
• Low-intensity uses/low FAR
11105 Ramona Blvd.
(City of El Monte)
62 Auto repair and storage 0.09 1960 12,901 --• Structures/site improvements over 30
years old
• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
• Low-intensity uses/low FAR/large surface
parking lot
• Parcel adjacency and/or presence of
common ownership
11336-11436 Valley Blvd., 11229
Oak St.
(City of El Monte)
51 Financial institution 0.082 1964 1,628 --• Structures/site improvements over 30
years old
• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
• Low-intensity uses/low FAR/large surface
parking lot
• Common or government ownership
9829 La Serna Drive
(City of Whittier)
42 Restaurant and associated
parking lot
--------• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
• Low-intensity uses/low FAR
• Common or government ownership
11757 Hadley Street
(City of Whittier)
32 Gas and service station --------• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
• Low-intensity uses/low FAR
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Table H-5.13: Redevelopment Trends of Nonvacant, Nonresidential Sites - City of Azusa and Los Angeles County Region
Los Angeles County Region - Redevelopment Trends
Project Name/Location
New Units Previous Use FAR Year
Built
Building
SF
Zoning Criteria
15000 Badillo
(City of Baldwin Park)
16 Banquet hall and wedding
chapel
0.25 1964 10,404 --• Structure over 30 years old
• Property located in mixed use zones or
specific plan areas
• Occupied by small scale marginal uses
• Low-intensity uses/low FAR
14617 Ramona (Cesar Chavez)
(City of Baldwin Park)
51 Air conditioning heating
supplies and services
0.19 1940s 6,970 --• Structure over 30 years old
• Occupied by small-scale, marginal uses
• Property located in mixed use zones or
specific plan areas
• Existing use showed signed of deferred
maintenance, neglect; and obsolete
design or construction
• Low-intensity uses/low FAR
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In addition, as indicated in Program H4-7, the
City will streamline housing approvals and
allow multi-family residential development
that conforms with objective design and
development standards by-right, without a
public hearing, further reducing barriers and
supporting the potential for redevelopment
within the planning period.
Land Owned by Religious
Institutions
Properties owned by faith-based organizations
often have large, underutilized parking
facilities. Recent State legislation has made
it easier for religious institutions to build
housing on these sites. AB 1851, approved in
September 2020, eases parking requirements
for a religious institution (or through
partnership with a nonprofit developer) that
seeks to build affordable housing on land
they own or lease. The law allows religious
institutions to build housing on underutilized
parking lot areas and prohibits cities from
requiring replacement of those parking
spaces. However, no more than half of the
available on-site parking spaces can be
requested to be eliminated. In Azusa, the City
has been approached by local developers
regarding development of housing at one
local church site. This site, located on Azusa
Avenue south of West Paramount Street, has
been identified by local developers for its
potential redevelopment with housing uses
and is included in this sites inventory as an
opportunity site to meet the RHNA (APN
8614-015-028). Other cities in the San Gabriel
Valley have also seen increasing interest
from developers for redeveloping housing
on religious institution sites. West Covina
approved a 19-unit gated housing project on
a church site in 2013 in residentially zoned
land. The church sold off a portion of its 5.1-
acre land that included a vacant elementary
school to the developer Brandywine Homes.
Baldwin Park has seen significant interest from
developers seeking to redevelop housing on
religious sites. Baldwin Park currently has three
religious sites, where developers have either
purchased the religious property or have been
coordinating with the property owners to
assess the feasibility of redeveloping the site
to residential uses. Baldwin Park also recently
completed a 10-unit residential project on a
church site that had ceased operations. This
project began construction in 2021. In South
LA, developer RMG Housing has several
affordable housing projects planned or have
broken ground in the past year on church land,
such as the Heavenly Vision Church, Southside
Bethel Baptist Church, and Pueblo del Rio.
In Orange County, developer National Core
has created partnerships with five churches in
cities across Southern California to building
affordable housing on underutilized church
land, which include Placentia, Santa Ana, and
Buena Park. Based on these trends and local
interest, the City is confident that interest in
redeveloping religious institutions for housing
is likely to continue and even increase during
the planning period. As AB 1851 incentives
become more broadly known, it is anticipated
that interest will continue to rise. In addition,
in 2022, AB 2255 was passed (effective
January 1, 2023) to further encourage housing
development associated with religious uses--
AB 2244 expands the definition of “religious-
use parking spaces” to include both existing
and new places of worship.
The site inventory identifies several sites
owned and operated by religious institutions
located in residential and mixed-use zones.
The sites identified as suitable for infill housing
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accounts for a total of 8.28 acres with a
realistic capacity of 65 units (Table H-5.14).
The City of Azusa has many local religious
institutions located on large lots. A total of
11 church sites were identified in Azusa that
presented potential for housing capacity.
These were selected because they are located
in zones that already allow residential uses
and have large underutilized parking lots or
other excess area. Seven of these are located
in lower density residential areas; as such they
are included in the above moderate-income
category, even though affordable housing is
likely to occur in conjunction with the religious
institutions’ missions. The remaining four sites
are anticipated to accommodate very low-
income housing, given their zoning that allows
high densities and the mission driven nature
of religious institutions. Currently, housing
would be allowed on all church sites identified
in the sites inventory based on the density
allowed in that particular zone.
The City has reached out to all religious
institution sites included in the inventory,
including direct contact with phone calls and
multiple follow ups. All property owners that
responded and are included in the inventory
indicated potential interest in housing
development on their site. As an example, the
City spoke with the pastor at Azusa Hispanic
Foursquare Church (325 S. Azusa Avenue), who
indicated the church owns the property and is
interested in potential housing opportunities.
The property owner of the church located at
777 E. Alosta Avenue also indicated interest in
residential development at their site. One site
that indicated a lack of interest was removed
from the inventory. The City will continue
to facilitate development on such sites via
Housing Program H3-9, which will create
standards and a review process for housing on
religious institution sites and support ongoing
coordination between the City, religious
institution property owners, and developers.
Land Owned by Places of Worship -
Density and Affordability Assumptions
To calculate the realistic capacity of sites
owned and operated by religious institutions,
which might support infill development on
underutilized portions and parking lots, this
Table H-5.14: Religious Institution Sites
General Plan
Designation Zoning Maximum
Density
Assumed
Density
Vacant
Acres
Potential
Dwelling
Units
Affordability
Level
Low Density Residential LDR 8 du/acre 6 du/acre 2.91 10 Above
Moderate
Medium Density
Residential MDR 15 du/acre 12 du/acre 1.28 8 Above
Moderate
Moderate Density
Residential MODR 27 du/acre 22 du/acre 1.86 21 Very Low
Commercial Mixed Use CSA 27 du/acre 22 du/acre 2.09 24 Very Low
Residential Mixed Use CSG 27 du/acre 22 du/acre 0.14 2 Very Low
Total 8.28 65
Note: Potential dwelling units do not reflect straight application of maximum density to religious institutional land. The number of potential
dwelling units has been reduced to 84 percent of maximum allowable units to reflect a conservative estimate and accounts for only 50% of a
site’s parking area consistent with State law.
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
Housing Element assumes that housing could
occur on half of existing parking lot areas
and does not assume the acreage of the
entire site. As such, these estimates do not
represent redevelopment of the sites; rather,
the capacity estimates parallel the allowed
housing on half of the parking area allowed by
AB1851. Additional capacity, beyond what is
identified in each individual realistic capacity
calculation, is available on many sites in open
space/lawn areas; these were not included
in calculations of realistic capacity. Realistic
capacity assumptions were limited to 50
percent of parking lot area. Since most of the
religious sites are located in residential zones
the same assumption of 84 percent of the
maximum allowable density has been applied
to calculate the realistic capacity. Appendix
B shows aerial views of each religious
institution site, highlighting in yellow the
entire parking lot area. Calculations are based
on one-half of this highlighted area, using
the underlying zoning’s maximum allowable
density, with a reduction to 84 percent of the
maximum allowable density. This estimate
is conservative, especially on sites where
additional capacity is available in open space
areas that is not included in the development
calculations. While two sites conservatively
estimate one housing unit could be built, there
are examples of development on church sites
supporting this possibility. In nearby Pasadena,
Knox Presbyterian has one housing unit on
their property. These units support caretaking
of church property and the congregation’s
mission to provide affordable housing to those
in need. In addition, given recent trends in
accessory dwelling unit construction in Azusa,
Table H-5.15: Azusa Lot Consolidations
Project Name/
Address Zone Project Type Total
Lots
Total Acreage
of Combined
Lots
Approval
Date
Block 36/
The Orchard
Downtown Town
Center (TOD SP)
163 units
31,500 sq. ft. commercial 17 2.24 acres 2008
900 N. Alameda
Ave.
NG1-Moderate
Density 14 units 4 0.64 2012
336-338 N.
Azusa Ave.
CAZ (Azusa Avenue
Corridor) 6 units 2 0.32 2013
201 N. Azusa
Ave.CAZ 6 units 2 0.25 2014
475 E. Arrow
Hwy
CAH (Arrow Highway
Corridor)70 units 3 2.91 2015
803 N. Dalton
Ave.Gold Line District 30 units 4 1.72 2016
820 N. Soldano Transition District
(TOD SP)7 units 2 0.26 2019
300 W. Foothill Route 66 District
(TOD SP)
8 units
733 sq. ft. commercial 2 0.34 2019
573-577 E. Arrow
Highway
Arrow Highway
Corridor 10 units 2 0.44 2018
The Avenue 800
N. Azusa
Gold Line District
(TOD SP)
127 units
12,000 sq. ft. commercial 4 1.2 acres 2018
Source: City of Azusa, 2021
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small single unit development is common and
can be supported by a variety of construction
models, including manufactured housing.
SMALL SITES AND LOT
CONSOLIDATION
The City acknowledges that small lot
development may be more difficult and thus
has only identified properties to meet the
lower income RHNA that have the potential
for sufficient added capacity to make
recycling of land economically feasible. Due
to the City’s historical subdivision patterns,
the vast majority of properties are less than
half an acre in size, and many are much
smaller. The properties less than half an acre
in size that are included in this inventory to
meet the lower income RHNA have a realistic
capacity (80 percent of maximum density)
yielding more than twice the number of
existing housing units and have realistic
potential to consolidate with adjacent lots.
Many of the residential and mixed-use sites in
the sites inventory are contiguous parcels and
provide opportunities for lot consolidation.
Azusa has a record of approving projects that
utilize lot consolidations for comprehensive,
high-quality projects. The City’s history
of approvals over the years (Table H-5.15)
demonstrates that there is developer
interest in consolidating parcels in the city,
and that Azusa has few constraints to lot
consolidation associated with new projects.
The City, through the former Redevelopment
Agency, supported the consolidation of
parcels and coordination of redevelopment
of the area formerly known as Block 36,
now under construction as the Orchard.
These catalytic improvements are paving
the way for additional lot consolidations and
development in the TOD Specific Plan area.
AB 1397
Consistent with updated Housing Element law
(Assembly Bill 1397) related to the suitability
of small and large sites, the lower-income sites
inventory presented in this section is limited
to sites of between 0.5 and 10 acres in size, as
HCD has indicated these size parameters best
accommodate lower-income housing. In this
inventory, several sites include multiple parcels
that are less than one-half acre in size, however
when consolidated with adjacent parcels
are more than 0.5 acres. Lot consolidation
is common in Azusa, and Program H3-9
is included to advertise lot consolidation
incentives. Small sites (less than one-half acre)
are credited toward the moderate- and above-
moderate income categories to account for a
potential variety of types, sizes, and amenity
levels in future higher-density development
projects.
AB 1397 also adds specific criteria for
assessment of the realistic availability of
non-vacant sites during the planning period.
If non-vacant sites accommodate half or
more of the lower-income need, the Housing
Element must present “substantial evidence”
that the existing use does not constitute an
impediment for additional residential use on
the site. Due to the built-out nature of Azusa,
most sites have existing uses. Non-vacant
sites included in the inventory have been
chosen due to their location, existing uses,
and potential for intensification. To ensure
that appropriate sites have been chosen,
properties that show recent investments
or updates or that contain uses of local
importance are not included, and clear criteria
were used to evaluate all sites within Azusa, as
described above.
AB 1397 also requires that specific parameters
be placed on sites that were used in previous
planning cycles but did not develop and are
now used in the current Housing Element to
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
meet the lower income RHNA. However, as
noted in HCD guidance documents, due to
updates in the prior planning period to the
general plan or other planning activities,
such as the creation of a specific plan, some
sites previously identified in the housing
element may have been rezoned allowing
a higher density, and therefore increasing
the potential housing capacity of the site.
Because the zoning characteristics of this site
have changed, it can be considered a new
site for the purposes of the housing element
inventory.
Due to the adoption of the TOD Specific Plan,
which significantly increased development
capacity by removing maximum densities,
no vacant or non-vacant sites included in
the sites inventory to meet the lower-income
RHNA must comply with this provision of
AB 1397. Non-vacant sites identified in the
previous Housing Element and vacant sites
identified in the previous two Housing
Elements but credited toward the moderate-
or above moderate-income RHNA in the
previous and current Housing Element are not
subject to the provisions of AB 1397 since they
are not intended to meet the lower-income
RHNA.
NO NET LOSS PROVISION
Government Code Section 65863 stipulates
that a jurisdiction must ensure that its Housing
Element inventory can accommodate its share
of the RHNA by income level throughout the
planning period. If a jurisdiction approves
a housing project at a lower density or with
fewer units by income category than identified
in the Housing Element, it must quantify at the
time of approval the remaining unmet housing
need at each income level and determine
whether there is sufficient capacity to meet
that need. If not, the city must “identify and
make available” additional adequate sites
to accommodate the jurisdiction’s share of
housing need by income level within 180 days
of approving the reduced-density project.
Program H3-7 is included in the Housing
Table H-5.16: Comparison of Sites, Pipeline Projects, and RNHA
Project
Extremely/
Very Low-
Income (0-
50% AMI)
Low-Income
(50-80%
AMI)
Moderate-
Income
(80-120%
AMI)
Above Moderate-
Income (+120%)Total
2021-2029 RHNA 760 368 382 1,141 2,651
Approved and Proposed Projects --6 --504 510
Projected ADU construction 57 108 5 72 242
Vacant Residential Sites ----2 34 36
Underutilized Residential Sites ----87 16 103
Vacant Mixed-Use Sites ------162 162
Underutilized Mixed-Use Sites ----259 177 436
Azusa TOD Specific Plan Sites 741 276 48 216 1,281
Religious Institution Sites 47 ----18 65
Total 845 390 401 1,197 2,833
Surplus RHNA Sites 85 22 19 56 182
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
Element to set up a process for compliance.
COMPARISON OF SITES
INVENTORY AND RHNA
Combined, the opportunity sites identified
have the potential to accommodate 2,323
residential units. As Table H-5.16 indicates,
these sites and the densities allowed will
provide opportunities to achieve remaining
RHNA goals for all income categories as well
as provide surplus of 182 units, which help
support no net loss provisions consistent with
State law.
The opportunity areas identified involve sites
that can realistically be redeveloped with
residential units during the planning period.
These areas are considered highly likely to
experience recycling for two key reasons:
1) the high demand for more affordable
housing throughout Los Angeles County,
and 2) the availability of underutilized land
in areas recently designated for mixed-
use, with the potential for high-density
residential development. The sites chosen
are significantly underutilized given their size
and location. As market forces continue to
push toward higher densities, recycling of
underutilized land is expected to occur at an
increasing rate. If the trend continues, the City
can anticipate increased recycling of land,
particularly in higher-density areas where
economies of scale can be realized.
Additional opportunities beyond the sites
inventory exist, including surplus properties
owned by the Azusa Unified School District
(AUSD is accepting applications to serve on
the Surplus Property Committee). In addition,
the City is undertaking a comprehensive
General Plan update (anticipated to begin
in 2023), which will reevaluate additional
opportunities to meet housing needs for the
next 20 years.
Consistency with Affirmatively
Furthering Fair Housing (AFFH)
State law requires that for housing elements
due on or after January 1, 2021, sites must
be identified throughout the community
in a manner that affirmatively furthers fair
housing opportunities (Government Code
Section 65583(c)(10)). Affirmatively furthering
fair housing means taking meaningful
actions that address significant disparities in
housing needs and in access to opportunity.
For purposes of the Housing Element sites
inventory, this means that sites identified to
accommodate the lower-income need are
not concentrated in low-resourced areas
(for example, with a lack of access to high
performing schools, proximity to jobs, location
disproportionately exposed to pollution or
other health impacts) or areas of segregation
and concentrations of poverty.
HCD and the California Tax Credit Allocation
Committee (TCAC) coordinated efforts to
produce opportunity maps that evaluate
specific economic, environmental, and
educational characteristics that have been
shown by research to support positive
economic, educational, and health outcomes
for low-income families. Figure H-5.2 shows
the TCAC opportunity areas in Azusa, ranging
from low to high resources, with a majority of
the city categorized as moderate resource.
Racially or ethnically concentrated areas
of poverty (R/ECAPs) are HUD-designated
Census tracts with relatively high
concentrations of non-white residents living in
poverty. There are no R/ECAPs within Azusa.
The distribution of identified sites improves
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
fair housing and equal opportunity conditions
in Azusa because sites are mostly distributed
in moderate resources areas. This is positive,
considering that these represent locations
where new higher-density housing can be
provided and residents will have access to
good schools, diverse jobs, and distant from
industrial uses—and not concentrated in
existing low poverty areas.
A thorough AFFH analysis based on the City’s
most current Analysis of Impediments to Fair
Housing Choice is included in the Housing
Constraints section of this Housing Element.
Infrastructure Capacity
The sites inventoried in this Housing Element
all lie within urban areas well served by street
and utility infrastructure. The City operates its
own street, water, wastewater, and storm drain
systems, prepares master plans to ensure
infrastructure improvements are planned and
funded to meet growth needs, and works
with Los Angeles County Sanitation Districts,
independent water agencies that serve small
portions of the City, and Los Angeles County
Flood Control to ensure cooperative use
of the shared systems. Aside from the non-
governmental and governmental constraints
discussed in Chapter 4 (Constraints), no
additional constraints would impede the
development of new housing units in the
future on the identified sites.
Azusa is fully developed, and full urban-
level services are available to each site in
the inventory. Specifically, water, sewer,
and dry utility services are available for
all the sites included in the inventory. To
ensure that infrastructure needs of specific
projects are addressed, the City requires that
project applications for new development
be reviewed for adequate infrastructure.
Applications are evaluated on a case-by-case
basis to ensure the capacity exists to service
new developments.
Administrative
Resources
THE CITY OF AZUSA
ECONOMIC AND COMMUNITY
DEVELOPMENT DEPARTMENT
The Economic and Community Development
Department promotes and maintains
livable communities. This involves, planning
for the future, building and maintaining
strong neighborhoods, ensuring high
quality development, encouraging business
redevelopment, preserving our past and
environment, and ensuring a high quality of
life. To achieve these objectives, the Economic
and Community Development Department
offers a wide range of services in the Building,
Business Licensing, Community Improvement,
and Planning divisions.
Agencies with administrative capacity to
implement programs contained in the Housing
Element include the City of Azusa and local
and regional non-profit private developers.
The Planning Division within the Economic
and Community Development Department
takes the lead to implement Housing Element
programs and policies. The Division is
responsible for implementing the General
Plan by ensuring that development projects
are consistent with the General Plan, the
Development Code, and State codes. The City
also invites non-profit developers to expand
affordable housing options in the City.
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING RESOURCES
Financial Resources
The City has access to a variety of funding
sources for affordable housing development
and preservation of affordable units at risk of
converting to market rate housing. Funding
is obtained from federal, state, and local
sources. The key housing financial resources
currently utilized are summarized below.
Due to both the high cost of developing
and preserving housing, and limitations on
both the amount and uses of funds, layering
of funding sources may be required for
affordable housing programs and projects.
COMMUNITY DEVELOPMENT
BLOCK GRANT (CDBG)
The City participates under the Los Angeles
Urban County Community Development
Block Grant (CDBG) program. The CDBG
program is flexible in that funds can be used
for a range of community development
activities primarily benefiting lower-income
households. The eligible activities include,
but are not limited to: acquisition and/or
disposition of real estate or property, public
facilities and improvements, relocation,
rehabilitation and construction (under certain
limitations) of housing, homeownership
assistance, and clearance activities. For the
2020-2021 Program Year, the City will receive
nearly $417,819 in CDBG funds.
OTHER RESOURCES
A variety of funding resources including but
not limited to those listed below are resources
available to help Azusa to maximize the
effectiveness of available funds.
State Resources
• State Low-Income Housing Tax Credit
Program
• Building Equity and Growth in
Neighborhoods Program (BEGIN)
• CalHome Program
• Multifamily Housing Program (MHP)
• Housing Related Parks Grant
• CalHFA Single and Multi-Family
Program
• Mental Health Service Act (MHSA)
Funding
Local Resources
• Los Angeles County Continuum of Care
(CoC)
• Housing Authority of County of Los
Angeles County (HACoLA)
• Southern California Home Financing
Authority (SCHFA)
Private Resources
• Federal Home Loan Bank Affordable
Housing Program (AHP)
• Community Reinvestment Act
Programs
• United Way Funding
• Private Contributions
The City has also received funding from the
State of California Local Early Action Planning
Grant Program (LEAP) for planning activities
that accelerate housing production. LEAP
provides one-time grant funding to cities and
counties to update their planning documents
and implement process improvements that
will facilitate the acceleration of housing
production and help local governments
prepare for their sixth cycle housing elements.
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HOUSING RESOURCES | AZUSA HOUSING ELEMENT 2021-2029
The City of Azusa also received an SB 2
grant from the State of California to fund a
City Hall-West Wing remodel, transforming
the Economic & Community Development
Department into one-stop “Permit Center”
to allow for a more streamlined submittal
and application review process. Additionally,
the SB 2 grant has funded a new Land
Management System software to allow for
permit tracking and streamlining, including
coordination with agencies such as Azusa
Water and Light.
Several resources from the County of Los
Angeles are available to the Azusa community.
The federally funded Housing Choice Voucher
program (formerly Section 8) is overseen
by the Los Angeles County Development
Authority (LACDA) and provides rental
assistance payments to owners of private
market rate units on behalf of low-income
tenants. LACDA also oversees the First Home
Mortgage Program, which is open to all Los
Angeles County residents (outside of the
City of Los Angeles). The Mortgage Credit
Certificate (MCC) program provides federal
tax credit for low- and moderate- income
homebuyers who have not owned a home in
the past three years. Allocation for MCC is
provided by the State and administered by the
County of Los Angeles.
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195
Azusa
Pedestrian
Plan
Housing Element
Program
Accomplishments
6
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AZUSA HOUSING ELEMENT 2021-2029 | HOUSING ELEMENT PROGRAM ACCOMPLISHMENTS
Housing Element
Program
Accomplishments
This chapter analyzes program performance
for the City of Azusa’s 2014-2021 Housing
Element programs. State law (California
Government Code Section 65588[a]) requires
each jurisdiction to review its Housing
Element as frequently as appropriate and
evaluate:
• The appropriateness of the housing
goals, objectives, and policies in
contributing to the attainment of the
state housing goals
• The effectiveness of the Housing
Element in attainment of the
community’s housing goals and
objectives
• Progress in implementation of the
Housing Element
This evaluation provides critical information
on the extent to which programs have
achieved stated objectives and whether
these programs continue to be relevant to
addressing current and future housing needs
in Azusa. The evaluation provides the basis
for recommended modifications to policies
and programs and the establishment of new
housing objectives.
The Department of Housing and Community
Development determined that the Azusa
2014-2021 Housing Element was in full
compliance with State law. Following
adoption in 2014, the City was tasked with
following through on the commitments made
in the 19 housing programs.
Through program implementation during
the 2014-2021 planning period, the City of
Azusa has made considerable progress in
addressing the housing needs of special
needs populations (e.g., elderly, persons
with disabilities, large households, female
headed households, farmworkers and persons
experiencing homelessness).
The City allocated HOME and CDBG funds to
support single family rehabilitation projects
throughout the planning period, significantly
exceeding objectives (Program 1). Of the 91
projects completed, 40 supported female-
headed households and 56 households
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HOUSING ELEMENT PROGRAM ACCOMPLISHMENTS | AZUSA HOUSING ELEMENT 2021-2029
included elderly or disabled residents.1
Projects included exterior and interior
paint, electrical upgrades, new plumbing,
installation of new windows, doors, and
roofing, and ADA-compliant handrails to
support physically disabled households.
Program 4 allocated funds toward street and
sidewalk improvements in low- and moderate-
income neighborhoods, including Act
(ADA)-compliant installation of curb ramps
that improve mobility and enhance paths of
travel for disabled and senior adults. CDBG
funds also supported ADA-accessibility
improvements at the Azusa Main Library;
converting the existing restroom facilities to
multi-use ADA accessible Men’s and Women’s
restrooms. Through implementation of
Program 19, the City developed provisions for
reasonable accommodation procedures to
provide fair access to housing for persons with
disabilities. The City continues to refine this
policy to ensure it is clear and implemented
consistently. As such, as of 2021, the City is
reviewing and reassessing these procedures
and will revise accordingly to promote equal
housing opportunity.
To address the needs of seniors, the City
has reduced standards for senior housing
developments. In response, the Gladstone
Senior Villas was constructed in 2020, with 60
units (six of which are reserved for low-income
seniors).
To support the needs of persons experiencing
homelessness, the City adopted a policy
to decriminalize homelessness, respect the
rights of homeless individuals, and direct
individuals to services. The Azusa Library
1 The numbers sum to more than 100% because some
households were both female-headed or elderly/
disabled.
established the Neighborhood Connections
program, which provides residents with
information about employment, housing,
health care, education, citizenship, family and
senior services, and access to food. Based
in the library, the program is supported by
a community resource specialist, part-time
social workers, and master’s level social work
interns who maintain a community resource
guide and make referrals and provide follow
up with clients, to local resources, including
to the homeless Coordinated Entry System.
In 2018, the City adopted a Plan to Prevent
and Combat Homelessness, which identifies
specific actions to implement the plan’s
goals, including ongoing coordination,
increased outreach workers from Union
Station Homeless Services, and an expanded
Neighborhood Connections program.
Table H-6.1 outlines the City’s progress toward
meeting objectives identified in the 2014-
2021 Housing Element. Following Table H-6.1,
Table H-6.2 summarizes quantified objective
performance.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 1. SINGLE-FAMILY
REHABILITATION PROGRAMS
• Provide one grant or loan annually,
to assist a total of eight households
during the 2014-2021 planning cycle.
Continue to allocate CDBG and HOME
funds for this program.
• Continue to permit funding from the
single-family rehabilitation programs
to be used towards room additions to
alleviate overcrowded conditions.
• Promote energy efficiency
improvements to households
participating in rehabilitation
programs.
• Continue to promote the program
on the City’s website and through
placement of brochures in public
locations and at community events.
The City provided 91 grants since 2014.
Grants of a maximum amount of $12,000 are
used to rehabilitate the existing living space
to make the house habitable. Currently, the
maximum amount does not support room
additions. The City also incorporates energy
efficient items into the scope of work when
possible. The program is advertised through
1) word of mouth, 2) the Azusa website and
social media, and 3) advertised in the water
bill annually.
Continued Appropriateness:
Grants to maintain existing housing and the
promotion of energy efficiency improvements
are important goals for the City. This program
is continued in the Housing Element.
PROGRAM 2. MULTI-FAMILY HOUSING
ACQUISITION AND REHABILITATION
PROGRAM
• Facilitate the acquisition and
rehabilitation/ redevelopment of
substandard rental properties by
qualified developers through the
coordination of funding sources and
interested parties.
With the end of Redevelopment in California,
Low and Moderate Income Housing Funds
are no longer being collected and the City’s
ability to support multi-family acquisition and
rehabilitation has been significantly curtailed.
Continued Appropriateness:
Preservation of multi-family dwelling units
is an important goal for the City; however,
a funding source does not currently exist.
This program is consolidated with the Rental
Housing Inspection Program in the 2021
Housing Element. The program includes
strategies to coordinate with LACDA and
other multi-family property owners to advise
on any necessary improvements and to
support funding opportunities initiated by
these entities.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 3. RENTAL HOUSING
INSPECTION PROGRAM
• Continue to administer the rental
inspection program to ensure
properties remain safe and well
maintained, preserving existing
affordable housing in the City.
Since 1989, Azusa has required annual
inspections of all rental housing in the City.
This program ensures compliance with
state and local laws involving property
maintenance and prevents units from falling
into substandard conditions. The program is
continued in the 2021 Housing Element.
PROGRAM 4. NEIGHBORHOOD
IMPROVEMENT ZONE PROGRAM
• Pursue additional funding sources
to fund neighborhood-specific
improvement projects, identify target
neighborhoods, and involve residents
to identify and implement needed
improvements.
Using Community Development Block
Grant funds, the City annually performs
infrastructure improvements within eligible
low and moderate income census tracts
including Americans’ with Disability Act
(ADA)-compliant installation of curb ramps
that improve mobility and enhance paths of
travel for disabled and senior adults. In 2019,
CDBG funds supported ADA-accessibility
improvements at the Azusa Main Library;
converting the existing restroom facilities to
multi-use ADA accessible Men’s and Women’s
restrooms.
Continued Appropriateness:
Upholding and improving the quality of life
within the community is critical to the livability
of residents. This program will remain in the
2021 Housing Element.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 5. PRESERVATION OF AT-
RISK RENTAL HOUSING
• Monitor the status of the 323
affordable housing units that are at risk
of converting to market rate.
• Work with owners and property
managers to discuss preservation
options of affordable housing units at
risk of converting to market rate.
• Monitor Section 8 legislation and
provide technical assistance to
property owners as necessary.
• Inform non-profit housing
organizations of opportunities to
acquire and continue affordability of
at-risk units.
• Hold public hearings upon receipt of
any Notice of Intent to Sell or Notice
of Intent to Convert to Market Rate
Housing, pursuant to Section 65836,10
of the Government Code and provide
tenant education on housing rights.
• Inform residents in units that
are converting to market rents
of affordable housing programs
available in the City, including Section
8 and other affordable housing
developments.
Azusa Apartments, Alosta Gardens, Azusa
Park Apartments, Pacific Glen/Crestview
Apartments, and Villas Azusa Senior
Apartments were at risk of converting to
market rate. Deed restrictions expired for
Azusa Park Apartments in 2020. Alosta
Gardens deed restrictions expire in 2024. Both
of these developments have reestablished
affordability covenants over the years. Azusa
Apartments received LIHTC funding and is
preserved as affordable to 2068.
Continued Appropriateness:
An updated version of this program is
included in the updated Housing Element, as
preservation of affordable housing remains an
important goal for the City.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 6. FIRST-TIME HOMEBUYER
PROGRAM
• As funding becomes available, provide
homeownership opportunities to
residents through down payment
assistance loans.
• As funding becomes available,
advertise homebuyer assistance
opportunities through brochures
available at City Hall and/or
information on the City’s website.
• Continue to participate in the
regional MCC program, and provide
information to interested residents at
City Hall and on the City’s website.
• Continue to provide information
on the Los Angeles County HOP
program, ICLFA Access, and NHF Gold
programs to interested residents.
After the dissolution of the City’s
Redevelopment Agency, the City did not offer
any funds for first-time homebuyer loans.
Inquiries are now referred to LA County or
State and Federal programs.
Continued Appropriateness:
Due to the limited resources available, this
program has been adjusted for the 2021-
2029 Housing Element to refer to available
resources countywide.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 7. AFFORDABLE HOUSING
FUNDING SOURCES
• Provide, on a case-by-case basis,
development assistance through
regulatory incentives and technical
assistance as a means to reduce overall
development cost, thereby facilitating
construction of lower-income housing.
• As federal funding permits, continue
issuing loans and grants as part
of the Residential Rehabilitation
Program (see Program 1) as a means
to reducing overcrowding, maintaining
a high-quality housing stock, and
assisting lower-income households
and property owners in maintaining
affordable housing units.
• Actively pursue State, federal, and
private funding sources as a means of
leveraging local funds and maximizing
assistance.
The City provides a Preliminary Plan Review
(PPR) process as a form of technical assistance
for applicants. Density bonus options and the
TOD Specific Plan allow for more density and
less parking requirements in certain areas,
providing viable regulatory incentives.
The City received a LEAP grant to support
the 2021 Housing Element effort, which
will address existing constraints to housing
development and identify strategies to
support housing development.
Additionally, the City has made efforts to
streamline the submittal and application
review process and implemented a new Land
Management System software to allow for
permit tracking and streamlining (funded with
an SB 2 grant).
Continued Appropriateness:
Funding and technical assistance are
important tools for facilitating development of
affordable housing. This program is continued
in the updated Housing Element.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 8. SECTION 8 HOUSING
CHOICE VOUCHER PROGRAM
• Support the County’s efforts to
maintain, and possibly to increase,
the current number of Housing
Choice Vouchers, and direct eligible
households to the program.
• Provide information on the Housing
Choice Voucher Program to interested
multi-family property owners and
managers.
As of 2019, there were a total of 242 residents
in Azusa that received a Housing Choice
Voucher. Another 20 residents received
housing assistance through a non-Housing
Choice Voucher program.
Continued Appropriateness:
Rental assistance remains a critical form
of housing assistance for lower-income
households, as well as seniors. This program is
continued in the updated Housing Element.
PROGRAM 9. ENSURE ADEQUATE
SITES TO ACCOMMODATE REGIONAL
FAIR SHARE OF HOUSING GROWTH
• Continue to provide appropriate
land use designations and maintain
an inventory of suitable sites for
residential development.
• Make the vacant and underutilized
residential sites inventory available
to non-profit and for-profit housing
developers on the City’s website.
The City continued to provide adequate sites
to accommodate the RHNA throughout the
planning period. In addition, in 2015, the
City adopted the Azusa TOD Specific Plan,
a form-based specific plan with no limit on
site-specific densities within the TOD areas.
The 2014-2021 Housing Element, including
the sites inventory, is available on the City’s
website.
Continued Appropriateness:
The maintenance of adequate sites is an
important goal for the City. This program
will be continued and modified to include
objectives pertaining to tracking to ensure no
net loss of sites during the planning period.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 10. MIXED-USE SITES
• Continue to facilitate the construction
of residences in mixed-use
developments.
• Continue to monitor development
interest, inquiries and, progress
towards mixed-use development.
Periodically re-evaluate approach and
progress.
• Continue to provide incentives for
consolidation of parcels in mixed-use
areas, including rounding up when
calculating allowable units. Provide
technical assistance with consolidation
of parcels. Technical assistance
includes land development counseling
by Economic and Community
Development staff.
During the planning period, the City
continued to facilitate the construction of
residences in mixed-use developments,
which was bolstered by the adoption of the
Azusa TOD Specific Plan (which provides
additional incentives, including no limitations
to onsite density). Two mixed use projects
(The Orchard, with 163 units and over 30,000
square feet of retail, and 619 N. San Gabriel,
with six units and 888 square feet of retail)
are under construction. Four other mixed-
use projects are entitled, in plan check, or in
preliminary plan review in 2021.
Continued Appropriateness:
Mixed-use sites remain a key approach
to meeting the City’s housing needs. This
program will be modified to reflect incentives,
the Azusa TOD Specific Plan, updated
procedures, and continued in the updated
Housing Element.
PROGRAM 11. SENIOR HOUSING
• Continue to provide appropriate
standards to encourage development
of senior housing to meet the needs of
the City’s growing senior population.
The City continues to encourage new housing
and senior housing in the community. In 2020,
Gladstone Senior Villas was constructed,
offering 60 senior housing apartments on 1.23
acres. Six units are reserved for low-income
seniors.
Continued Appropriateness:
Ensuring that the senior population have safe,
high-quality, and affordable housing options
is a central goal to the Housing Element.
This program will remain in the 2021 Housing
Element, and updated to reference the
removal of an MUP requirement, to further
encourage this type of housing in Azusa.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 12. ALTERNATIVE HOUSING
MODELS
• Facilitate the development of
alternative housing models suited
to the community housing needs
through the provision of flexible zoning
regulations.
• Promote alternative housing models
during discussions with developers.
• Actively promote outside funding
opportunities and regulatory
incentives such as density bonuses to
offset the costs of providing affordable
units.
The City continues to support alternative
housing models and has received multiple
inquires around the construction of tiny
homes and modular models. However, none
of these projects has yet come to fruition. In
2016, an assisted living facility for a residential
elderly care facility was developed.
Continued Appropriateness:
Ensuring high quality housing stock to
meet varying ranges of affordability is a key
approach to implementing the Housing
Element programs. This program will remain
in the 2021 Housing Element.
PROGRAM 13. DENSITY BONUS/
DEVELOPMENT INCENTIVES
• Continue to comply with State law
for density bonuses as a means
to facilitate affordable housing
development.
• Continue to allow waivers of covered
parking requirements for affordable
housing units, consistent with existing
Development Code Section 88.36.080.
The City continues to provide Density
Bonuses per State law. The most recent
Density Bonus Ordinance was updated in
2011. Gladstone Senior Villas is the most
recent development that has sought a density
bonus through the provision.
Continued Appropriateness:
To ensure compliance with State law and
provide flexibility for developers, this program
will remain, and be updated to include an
action item to update the City’s density bonus
ordinance to be consistent with State law.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 14. EXTREMELY LOW-
INCOME AND SPECIAL NEEDS
HOUSING
• Continue to facilitate housing
opportunities for extremely low-
income persons by allowing
emergency shelters as a permitted
use (without a permit) in the West End
Industrial District, subject to those
conditions and standards consistent
with State law. Subject emergency
shelters to the same development
standards as other similar uses within
the West End Industrial District, except
for those provisions permitted by State
Law and included in the Development
Code for emergency shelters.
• Continue to allow the establishment
of transitional and supportive housing
development and single-room
occupancy developments (SRO).
Consistent with State law, transitional
housing and supportive housing shall
be considered a residential use of
property, and shall be subject only to
those restrictions that apply to other
residential dwellings of the same type
in the same zone.
• Prioritize projects that include housing
for extremely low-income households
in the development application review
process.
• Seek State and federal funding for
low-income housing construction
and rehabilitation, especially for the
development of housing affordable to
extremely low-income households.
The City continues to allow emergency
shelters in the West End Industrial District by
right, and allows SROs in certain zones. No
applications for these types of housing have
been received during the planning period.
Continued Appropriateness:
Ensuring adequate housing availability for
extremely low-income and special needs
demographic is a goal for the City. This
program will be continued in the updated
Housing Element and updated to include new
State law requirements to allow Low Barrier
Navigation Centers by right in certain zones.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 15. WATER AND SEWER
SERVICE PROVIDERS
• Immediately following adoption,
deliver the 2014-2021 Azusa Housing
Element to all providers of sewer and
water service within the City of Azusa.
The City provided the Housing Element to
water and sewer service providers upon
adoption.
Continued Appropriateness:
This remains a requirement of Housing
Element law and will remain in the updated
Housing Element.
PROGRAM 16. OUTREACH PLAN
• Implement an outreach plan to
establish outreach protocol for
housing-related issues, such as
Housing Element updates. Reach out
to the community regarding housing
topics in general, as well as with regard
to specific new developments.
The City developed a comprehensive
outreach plan to engage the community in the
2021 Housing Element update, centered on
three tenants: Engage, Educate, and Inform.
Outreach included a widely distributed survey,
virtual community meetings held in English,
Spanish, and Mandarin, advisory community
meetings, and working sessions with the
Planning Commission and City Council. In
addition, the City developed an informational
video to educate about housing needs and
the update process. These outreach avenues
are intended to develop the foundation for
additional engagement and ongoing planning
discussions in the community. Meetings,
surveys, and flyers were provided in English,
Spanish, and Mandarin.
Continued Appropriateness:
Outreach with the community remains a
key goal for the City. This program will be
modified to address ongoing and upcoming
long-range planning discussions and
continued in the updated Housing Element.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 17. RESIDENTIAL
DENSITIES ON IDENTIFIED SITES
• As part of the Preliminary Plan and
Design Review processes, continue to
evaluate new projects for consistency
with General Plan objectives as they
relate to housing and the RHNA
obligations.
As part of Preliminary Plan and Design Review,
staff evaluates projects against zoning and
General Plan requirements.
Continued Appropriateness:
State law requires that Housing Element sites
remain available throughout the planning
period. The City will continue to track
development progress, housing element
sites, and ensure no net loss in the availability
of units to meet the RHNA. This program is
continued and will be modified to include
a tracking mechanism for the City in the
updated Housing Element.
PROGRAM 18. FAIR HOUSING
PROGRAM
• Continue to assist households through
the Housing Rights Center, providing
fair housing services and educational
programs concerning fair housing
issues. Refer fair housing complaints
to the Housing Rights Center and
continue to provide funding support.
• Continue to promote fair housing
practices, including advertisement
on the City’s website, and provide
educational information on fair housing
to the public.
• Continue to comply with all State and
federal fair housing requirements when
implementing housing programs or
delivering housing-related services.
The Housing Rights Center (HRC) provides
free fair housing services to Azusa residents
and community members. Information to
contact HRC is included on the City’s website.
The City complies with all State and federal
fair housing requirements.
Continued Appropriateness:
Fair housing remains an important goal for the
City; this program is continued in the updated
Housing Element.
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Table H-6.1: 2014-2021 Program Accomplishments
2014-2021 Housing Element Program Progress and Continued Appropriateness
PROGRAM 19. REASONABLE
ACCOMMODATION
• Provide information to residents
on reasonable accommodation
procedures via public counters and the
City website.
The City of Azusa has established a
Reasonable Accommodation procedure
regulating the siting, funding, development,
and use of housing for people with
disabilities.
Continued Appropriateness:
This program has been completed. However,
the City is re-evaluating the procedures for
consistency in application and clarity. The
program will be modified and continued in
the Housing Element.
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Quantified Objectives
Table H-6.2 summarizes Azusa’s quantified
objectives for the 2014-2021 Housing Element
planning period and the progress the City has
made, including progress meeting the City’s
fifth cycle RHNA. Through 2020, construction
exceeded the total RHNA allocation (1,079
units were constructed with a target of
779 units). However, this is mostly due to
development of moderate- and above-
moderate units. Only six low-income units
were built so far during this period. Between
2014-2018, all new multi-family housing units
were allocated to the moderate-income
category, based on assumed market rents.
The City exceeded the 2014 rehabilitation
target through the single-family rehabilitation
programs funded with CDBG. Through this
funding source, a total of 91 grants of up to
$12,000 were provided toward improvements
to residential properties occupied by low- to
moderate-income households.
The conservation goal was to preserve five
affordable housing projects that were at risk of
converting to market rate. None the affordable
multi-family housing converted to market rate
housing during the planning period.
Table H-6.2: Summary of 2008-2014 Housing Element Quantified Objectives
Objectives
Income Level
TotalExtremely
Low Very Low Low Moderate Above
Moderate
Construction Objectives (RHNA)
Goal 198 118 127 336 779
Progress 0 6 861 200 1,067
Single-Family Rehabilitation Objective
Goal 8 --8
Progress 91 --91
At-Risk Housing Units to Preserve
Goal 323 ----323
Progress 323 ----323
211
Azusa
Pedestrian
PlanAppendix A:
Community
Engagement
A
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Appendix A-1: Stakeholder List
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East Valley Community Health Center x
Abundant Housing LA x
Foothill Unity Center x x
City Ventures x
Elizabeth House x x x x
Parent’s Place FRC x x x
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Immigration Resource Center of SGV x x x
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Union Station Homeless Services x x x
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Appendix A-1: Stakeholder List
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Appendix A-1: Stakeholder List
Company/Organization
Group Served/ Sector
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Project Sister x
ABILITY FIRST/Lawrence L. Frank Center x x
Esperanza Charities, Inc. x x x
Asian Youth Center x x
SPIRITT Family Services x x x x
Serenity Infant Care Homes Inc. x
East San Gabriel Valley Coalition For The
Homeless x
SGV Consortium on Homelessness x
San Gabriel/Pomona Regional Center x x x
YWCA San Gabriel Valley x x x x x x
Active SGV x
Housing Rights Center x x x
Cesar Chavez Foundation x x x x
Beyond Shelter x x x x x
Union Station Homeless Services x x x
Services Center for Independent Living x x x x
Empowering Families Educational Services x x x x
Santa Anita Family Services and Senior Services x x x
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Appendix A-1: Stakeholder List
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Fiesta Educativa, Inc. x x x
Lions Gate Home x x
AIDS SERVICE CENTER x x
Los Angeles Homeless Services Authority x x x x x x
California Mental Health Connection Teri G.
Muse Family Service Center x x x x
Emotional Anonymous Teri G. Muse Family
Service Center x x x x
Los Angeles County Office of Education x x x x x x x
California Family Counseling Network x x x x x
Housing Rights Center x x x x x x
Enki – La Puente Valley Mental Health Center x x x x x
Los Angeles County Public Social Services x x x x x x x x
New Hope Christian Counseling Centers x x
Project Sister x x
Richard D. Davis Foundation, Developmentally
Disabled, Inc.x x x x
Center for Aging Resources Heritage Clinic -
Pasadena x x x x
Catholic Charities – San Gabriel Valley Region x x x x x x
Services Center for Independent Living x x x x x
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Appendix A-1: Stakeholder List
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Foothill Association of Realtors x x x
Azusa Unified School District x x x x x x x
Azusa City Library x x x x x x
Boys & Girls Club of West SGV x x x x x
ACTION Food Pantry x x x x x
Azusa Pacific Community Counceling Center x x x
PHFE WIC x x
Covina Woman’s Club x
East SGV Japanese Community Center x
Azusa Chamber of Commerce x
Neighborhood Homework House x x x
Azusa Adult Education Center x x x x x x
Shepherd’s Pantry x x x x x x
YMCA of West SGV x x x
Volunteers of America- West Covina x x x x x x
East San Gabriel Valley Coalition for the
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Door of Hope x x x x
Elizabeth House x x x x
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Appendix A-2: Workshop Summaries
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City of Azusa Housing Element Update Community
Survey: Meeting Our Housing Needs
The City of Azusa developed a community survey to gather feedback for the 2021 Housing
Element Update from Azusa residents, workers, property owners and others interested in
housing issues in the city. The survey was posted on the City of Azusa’s website, distributed to
service providers, and publicized on social media. It was available from February 26 - March 31,
2021 in English, Spanish and Mandarin.
The survey received a total of 260 responses; 6 surveys (2.3%) were completed using the Spanish
language version of the survey.
The figures below display respondents’ answers on how the City of Azusa might meet its
housing needs in the coming years. The “n =” which follows at the end of each figure heading
refers to the total number of responses for that question. Where multiple responses were
allowed, the “n” may exceed the total number of respondents.
affordable housing projects that were at risk of converting to market rate. None the affordable
multi-family housing converted to market rate housing during the planning period.
Appendix A-3: Survey Summary
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Figure 1: Currently, do you: (Question 1; n=260)
Figure 2: Which best describes your current living situation? (Question 2; n=250)
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Figure 3: Which best describes your current housing situation? (Question 3; n=245)
Figure 4: What are your reasons for living in Azusa? Choose all that apply (Question
4; n=555)
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Other responses:
• I do not live in Azusa
• My hometown. I have lived here my whole life
• I do not live in Azusa. I work in Azusa.
• Was my mom’s house
• N/A
• I do not live in Azusa.
• I work in Azusa but do not live in Azusa
• I do not live in Azusa. I work in the city.
• I don’t live in Azusa, I work here.
• None
• Raised in Azusa
• at the time, special financing about 15+ yrs ago.
• I don’t live here I work here
• I do not live in Azusa, but do the housing rehabilitation program
Figure 5: Prior to the coronavirus outbreak, had you experienced any of the
following housing issues within the last 5 years? (Question 5; n=363)
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Figure 6: Have you experienced any of the following housing issues this year since
the coronavirus outbreak? (Question 6; n=343)
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Figure 7: What types of housing does Azusa need most? (Question 7; n=240)
Other responses:
• quality of housing decrease for not being able to use amenities
• Not able to find an affordable home to buy
• Apt needs repairs, but manager/owner doesn’t wear mask or social distance from others,
so we don’t want them in our apt. -_-
• I have many applicants that are behind on their mortgage and or taxes
Objectives
Housing Needs in Azusa
1 2 3 4 5 6 7 8 9 10 Rank (Total
Ranking Points)
Duplexes or Triplexes (2 or 3 unit
buildings)32 54 53 22 29 24 6 9 6 5
1st
(1,746)
Smaller scale apartments (4 units or fewer)13 33 48 37 39 27 25 7 6 4
2nd
(1,576)
Senior housing 32 24 25 37 36 31 29 14 4 6
3rd
(1,538)
Detached single-family homes 75 22 19 15 8 9 8 10 43 19
4th
(1,465)
Condominiums/townhomes 12 28 24 29 27 38 28 28 16 8
5th
(1,355)
Larger scale apartment buildings (5 units
or more)10 10 21 32 23 39 28 17 26 20
6th
(1,150)
Housing for families and individuals who
need supportive services like jobs training
and social services
21 21 9 19 17 16 37 35 37 21
7th
(1,146)
Interim/transitional housing for people
looking to transition from homelessness 15 16 13 5 13 10 21 48 38 27
8th
(1,134)
Accessory dwelling units (granny flats or
guest houses)15 11 15 15 15 13 20 21 29 70
9th
(900)
Mobile home parks 2 2 5 12 21 25 31 40 24 27
10th
(732)
Mixed-use (commercial and residential)
properties 13 19 8 17 12 8 7 11 16 34
11th
(723)
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Figure 8: Rank the importance of current housing challenges in Azusa.
(Question 8; n=246)
Housing Challenges in Azusa
Important Somewhat
Important
Not
Important
Ranking
(Points)
Ensure that children who grow up in
Azusa can afford to live in Azusa on their
own
139 75 26
1st
(593)
Encourage the rehabilitation of existing
housing in older neighborhoods 131 92 11
2nd
(588)
Support programs to help homeowners
at risk of mortgage default to keep
their homes, including mortgage loan
programs
119 102 16
3rd
(577)
Establish housing for households with
special needs such as seniors, large
families, veterans, and/or persons with
disabilities
105 107 23
4th
(552)
Targeted efforts to address long-
term inequities in the housing market,
including discrimination in renting
109 82 41
5th
(532)
Streamline the process for new housing
construction 96 95 37
6th
(515)
Focus new housing near commercial
areas, creating “live/work”
neighborhoods
80 107 44
7th
(498)
Provide shelters and transitional housing
for homeless families and individuals,
together along with services that help
move people into permanent housing
83 99 50
8th
(497)
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Figure 9: To meet the City’s long-term housing needs, the City will need to plan for
more homes. This includes single-family homes as well as apartments, townhomes,
and condominiums. Please rank the ideas below based on what you think are the
best general locations in Azusa for new housing. (Question 9; n=243)
Housing Needs in Azusa
1 2 3 4 5 6 7 8 9 Rank (Average)
Along Foothill Boulevard 50 50 38 32 22 0 0 1 0
1st
(1,420)
Along Arrow Highway 37 41 44 24 23 0 0 0 1
2nd
(1,229)
Along Azusa Avenue and San Gabriel
Avenue 22 37 46 35 27 0 0 0 0
3rd
(1,161)
In the Downtown area 23 21 28 55 46 2 0 0 0
4th
(1,139)
Near Azusa Pacific University 14 17 23 28 29 54 41 24 13
5th
(1,136)
In the area immediately surrounding
Downtown 29 26 23 33 52 1 1 0 0
6th
(1,095)
In existing multi-family neighborhoods 29 13 16 17 18 20 68 32 30
7th
(1,047)
In hotels or motels that can be converted
to housing 36 16 16 11 17 9 20 26 92
8th
(955)
On parking lots of churches if those
institutions wish to develop housing 3 22 9 8 9 10 20 96 66
9th
(717)
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Figure 10: Are there other places in Azusa, not mentioned in the previous question,
where you would want to prioritize new housing? (Question 10; n=243)
Figure 11: Where would you want to prioritize new housing? (Question 11; n=45)
• Abandoned industrial lots
• Along gladstone
• Along Gladstone near Neighborhood Center zones and Edgewood District Zone.
• Angeleno Ave
• At empty school lots
• Azusa Canyon area
• Azusa does not need any more housing. Azusa has a reputation of being similar to
Baldwin Park, La Puente, Pomona...etc. Azusa should not be creating a “housing for all”
idea. They should be creating a safer community for all idea.
• Badillo
• By the Santa fee dam trail
• Closer to the freeway
• Create a new Rosedale where the Edgewood Shopping Center is and create single family
homes - clean up that area and clean up where the old Arby’s used to be and add single
family housing there, stop making duplex everywhere!
• create single family homes on the golf course, create single family homes near Vernon,
near Mountain View School, convert vacant commercial lots to create more residential
single family housing
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• Down Where there are empty buildings and parking lots not being used. Tear down the
old buildings that are sitting empty
• Edgewood Shopping Center
• Empty lots
• Gladstone
• Glendora
• Golf course property
• If any schools are closed, that land could be used for housing.
• In hotel areas,
• In the north side of town above Foothill Blvd from Citrus to Todd Ave
• In vacant lots not being used
• Na
• Near Mountain Cove
• Near transportation hubs. Peioritized my choices according to this, and to address
neighborhoods that lack attention/upkeep
• North Azusa along San Gabriel & Sierra Madre and
• north azusa by the golf course
• Off Irwindale Ave, closer to freeway entrance or further up Irwindale
• On Gladstone, Edgewood shopping area
• On my lot located at 677 E Camellia Way in Azusa, CA. I have a huge lot of 30Ksf. But the
HOA stipulation will NOT allow a lot split.
• On Sierra Madre. Put new homes on the higher mountains area were there are not too
many homes. South Azusa is already over populated
• On Vernon Ave north of First St. Along First St. And Azusa Ave between 3rd and First
• Over by Zacatecas park
• Rosedale
• Rosedale
• Rosedale and surrounding areas of riverbed
• Rosedale area
• Route 66 aka)alosta
• Shopping centers like Gladstone and Azusa where the sketcher stores need to go and
place housing there instead.
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• Single homes could be converted into duplexes.
• Some industrial areas are rundown and could be converted to trendy partners/ housing
• Stop building huge apartments on main roadways. We need more single family homes
which offer middle class living.
• Up by Mountain Cove
• Vacant lots or not utilized lots from foothilll to baseline, citrus to azusa ave
• We need a shelter on Irwindale Avenue
Figure 12: There are a number of tradeoffs associated with different approaches to
providing more housing in Azusa. Please rank the following in order of importance.
(Question 12; n=244)
Housing Tradeoffs
1 2 3 4 5 6 7 Rank (Average)
New housing should be concentrated near
existing and planned public transit.80 46 46 30 0 0 0
1st
(1,186)
New housing should blend in with the
character of surrounding neighborhoods.58 73 44 22 1 0 0
2nd
(1,155)
New housing should be spread evenly
across all parts of the city.41 39 56 43 20 2 0
3rd
(1,037)
New housing should be located where
it will have the least impact on traffic in
Azusa.
30 31 38 56 2 0 0 4th
(816)
New housing should be located within
easy access to open space/parks 15 18 27 22 34 25 98
5th
(686)
New housing should be located within
easy access to health resources, such as
clinics and wellness centers
3 16 15 31 38 92 44
6th
(658)
New housing should be located within
easy access to shops.12 16 13 35 1 1 3
7th
(393)
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Figure 13: Do you have anything else that you would like the City to consider when
updating Azusa’s Housing Element? (Question 13; n=249)
Figure 14: What else that you would like the City to consider when updating Azusa’s
Housing Element? (Question 14; n=68)
• Access to community centers: people need to connect with neighbors in positive ways
- ability to have family and neighborhood activities which foster strong, healthy and
diverse interaction in concentric circles. Families, churches, neighborhoods, communities,
city... I feel Azusa has been trying to meet these needs, please don’t give up!
• Apartments with small playground are Duplexes/townhouses for veterans w/
handicapped parking, ramps & exercise machines like at the park. Most cant afford
apartments with elevators, a pool/jacuzzi.
• As an Azusan and a single mother. I would love to see low income housing not
apartments. I would love to be able to rent a home instead an apartment.
• Azusa is lack of decent grocery/shopping center (i.e. Trader’s Joe) except Costco. This
city does not have Kaiser, Trader’s joe, variety of restaurants which made people moved
out or not visiting Azusa.
• Azusa needs to think about its current residents and their safety. Catering to the
unknown is a recipe for disaster. If you want to make Azusa more enticing and repair is
poor reputation, take a look at Glendora, upland, Rancho Cucamonga or other similar
cities.
• Blighted areas or older areas that need improvement should be targeted with investment
for new or improved housing. Many of these areas are smaller, however citizens would
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appreciate money invested to improve the appearance thus making the area safer and
more attractive to new residents. Also, until Azusa realises our schools are sub par and
need stricter standards our city and housing will not improve overall. People don’t move
here for the schools but would love to!
• Build new housing that is free from HOA
• Concentrate on single family homes to preserve and welcome new families in the city
for longevity and increase support and participation in public schools. No to low income
housing, apartments, condos, motels, hotels, homeless shelters. Increase families in
neighborhoods to own to have a sense of ownership pride and in turn beautify the city as
they keep their property well kept.
• Converted garages mother in law suits
• Create more single family homes similar to Rosedale, and how Glendora did on Grand
near Sierra Madre; Stop creating ADUs and Duplexs
• Create programs to help middle class afford homes, cost of living & home prices are too
high! Low income families already get help or adjust the income levels to real cost of
living to be able afford a home in Azusa
• Don’t focus on apartments. I understand you want people paying an endless amount for
a living situation they will never own, but Azusa has had to many apartments built that it
is congestive to the city. I am looking for property to own, and Azusa has demonstrated
they don’t want to invest in single family home.
• Either to partner with Habitat for Humanity or to model home building and loan
programs on theirs. Have people help build their homes, give 0% interest loans, must be
a primary residence and not rented out, city has first option to buy back if resident wishes
to move. Must consider how to create affordable housing and avoid house flipping or
buying with no intent to live in themselves. We need a stable population invested in their
community.
• Find incentives and ways to support 2nd generation azusans/locals to afford staying in
the area
• Gentrification. This will help bring in more tax revenue and eventually drive out much of
the gang issues. I suggest starting with the downtown area and expanding to areas north
of the freeway moving south.
• Greater support to small business and incentives for new “small” businesses and current
businesses to come or stay in Azusa*****
• Housing should not be blocking view of the mountains, etc. Each new home should
require an older home to be rehabilitated or torn down/rebuilt first before adding
another home. Incentives could be given for older homes of homeowners to update their
home, thereby making it more palatable to allow more homes to be added (more people)
to our community. This will preserve Azusa’s integrity and not as likely to make a mess of
the city. Pride of ownership is key.
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• How can we prevent the gentrification of Azusa given the development of the downtown
area?
• I no there are other areas for new places
• I oppose this idea. In a perfect world providing housing would solve all the cities
homeless problems. However, history has shown housing projects bring in crime and
lower home values. The city is already plagued with crime. I suggest the housing be
placed in the neighborhoods of all city council members who believe this is a good
idea. In the alternative build housing away from existing dwellings so established
neighborhoods are not impacted.
• I think Azusa should focus on a clean and safe city and worry about bringing in
businesses to help the economy. There are housing options here. The city is unsafe
with many bad drivers a transients walking the streets along with feces and so much
trash on the ground. Especially downtown area. It’s so bad we travel to Glendora to not
experience problems. Until the city is clean and safe, it won’t matter if you build 1000000
homes the value of living here is still low. It’s been a disappointment
• I think that the golf course should be turned into a large park with a bmx course. And a
dedicated soccer field and a dog park surrounded by walking paths
• I worry for the character of Azusa. The city I grew up in is quickly becoming out of price
for a working professional like me. Lifelong locals are getting priced out. South Azusa
where I live is a food desert, we are routinely ignored when it comes to housing and
community projects. The city hasn’t invested enough in the citizens of south Azusa.
• I would like the City Of Azusa to get rid of homeless people in our parks that should be
for our children to play in safe environment and also to clean our infested drug addict
homeless from our Azusa Canyons that have been ruined with trash, glass and homeless
publically doing drugs. We the people, tax paying citizen have rights to live in a safe
environment.
• If housing is built close to areas of public transport, such as the Metro line, it will greatly
incentivize people to take public transportation.
• It should be easier for people living in azusa to obtain permits for home additions and
renovations
• Lack of public parking in Azusa
• Less apartments and motels as there seems to be an association with crime in these
areas
• Less permits and red tape!!!
• Limit 1 car per house hold for overnight parking
• Lots of people come here for higher education (citrus and azusa pacific), having low
income housing can help these and other people afford to live and spend money here
helping everyone
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• Low income high density houseing is what we need. We are losing to many family’s
becuse no one can afford rent/morage. I would love to buy a home here but can not
afford it
• Low income housing
• Make adding ADU units easier. The staff in the planning dept. has been horrible. They
tell us one thing and then when we speak to someone else in the dept. they give us a
completely different answer. One person even told my husband and myself that a door
should be in a 3 foot wide space on the side of the house because fire dept. will know to
look there for an entrance. I work in emergency services that was utter baloney. Simplify
you rules and make sure you hire ppl who are knowledgeable.
• Make Downtown Azusa more Family Oriented. Include more restaurants, bars, and more
shops. Make parks more exercise friendly, specifically more walking trails that include lots
of trees.
• Make requirements for granny flats as lenient as possible. Drop the requirement for
garage conversions needing individual utility service lines. Allow the use of existing utility
services for the main house.
• New housing should be affordable for the average citizen in Azusa. Not just the rich.
Rosedale was out of reach for most people in Azusa and wasn’t affordable to move up
into a larger residential home.
• No more mass apartments... there are too many eye sore Apts and motels in this city it
feels unsafe to walk with so many people coming and going, gang activity, graffiti and
homeless wandering. The city exhibits a poor community feel with too many apartments
housing big families or attracting people who are only renting temporarily. People come
and go lets get more PERMANENT housing and build a permanent community.
• Other neiborghs and I believe that the city inspectors and the building department
needs to do a better job. By supporting and making the process to build ADU’s smoother
instead of making the process very discouraging and extremely painful.
• Owners who are trying to repair or update homes should be able too without so many
barriers from the city. Help owners improve homes so we can stay! Need more support
to streamline process.
• Parking space for the new homes. I live on Dalton and my home is surrounded by duplex
and apartments and it’s hard to park in-front of my house . So if you make more houses,
please make space for the car or cars. Parking permits help some what but you still have
the congestion of parking sometimes there’s no parking
• Please continue to check up on slumlords, especially when they are the hoarder kind.
Abandoned vehicles, trash everywhere, tools and equipment left laying around in
walkways, trash left out and filled with standing water. It feels very unsafe at times, but
the rent is cheap, so we’re stuck.
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• Please do not change zoning to accommodate large senior apartments companies
• Please take into consideration who will live there. We have so many bad apples in
our neighborhoods. There’s always something going on with graffiti, littering on the
sidewalks, some people just really don’t care about this city and not mention all the gang
members, guns, standoffs, it’s getting out of control. You’ll need to do some serious
background checks before renting or selling.
• Prioritizing homeless community and making prices equitable for not just those that can
afford to move to the city.
• Que las viviendas para personas mayores esten ubicadas cerca de centros de salud.
• Restoring and preserving historic dwellings
• rezone commercial vacant lots to single family housing lots
• Senior programming, gang intervention programs, grants for small businesses
• Several years ago it seemed that apartment complex is worth being built all over the city.
Today most of those buildings are poorly kept and are eyesores. Apartment complexes
should be kept away from neighborhoods with single family homes. I also strongly
opposed mobile home parks because they tend to attract crime and blight.
• State funding for property owners who want to build Accessory Dwelling Units (ADU) for
the purpose of providing housing to senior citizens and veterans.
• Sufficient parking especially for apartments condos and senior properties it should be at
definitely one if not two parking spots per address or home number
• Sustainable and earth friendly. Solar panels if possible like some apartments from
Glendora
• The idea of making Azusa a commuter city will only work when public transit is more
available, cleaned up, reliable, and safe. Most of these elements are not in our control. It
is a better investment for the city to focus on single-family homes rather than overpriced
condos
• There is a lot of single mothers that would like to raise their children here in the city we
need low-income housing
• There is still vacant land in Rosedale. It was designated for a public school and park, but
should be considered for more housing, if needed. However, Azusa shouldn’t have to
participate in this State charade since Rosedale put hundreds of new housing units into
the city within the last few years. Unless the State implements some type of substantial
punitive action against Azusa, we should develop any new housing based on the city’s
needs NOT the State.
• There should be the option of going solar with no problem along with the incentives
Such as roof replacements and alike.
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• Tiny Houses for the unhoused who wish to use them.
• To me, the biggest concern with new housing is making sure it is affordable. A lot of new
housing does not include any backyard or it is only a small patio area and yet they want to
charge $500k+. It is impossible for those born and raised in Azusa to continue their lives
here. I am in my 30s and am still living with parents hoping one day I can afford to move
out. It is sad because I have a good job, but the housing market is ridiculous in this area.
• Traffic patterns/control. New stop signs & stoplights in more heavily traveled residential
areas, & areas where street parking obstructs line of sight.
• Transitional Housing for unhoused and day care facilities in SFR and MFR Zones
• Try to build homes up North of Azusa, Don’t decrease more the value of homes in South
Azusa
• We NEED affordable housing for growing Azusa families. Rosedale is NOT affordable
housing. Think about the students that go to school IN Azusa, that is who you need to
focus on ensuring that they have adquate, accessible and affordable housing. Build with
the community you have. We do not want to leave, we are being pushed out.
• We need housing for one person senior housing that goes by how much you income you
make. But spacious dwellings. With elevators is a must.
• We need more affordable housing. We should consider adding community oriented
micro-housing in the downtown w/ gold line/buses/uber/lyft/self-driving/bikes
transportation in mind
• We should have as little new housing as possible because it’s too crowded already.
• When creating low income housing the units should not be concentrated in one singular
area but rather integrated into higher income neighborhoods.
• Why does the city of Azusa need to make housing for transient folks? Glendora and other
surrounding cities would never allow that. Housing transients are going to make Azusans
want to leave their city. We should prioritize small business retail stores and restaurants
in downtown along with new apartments to build Azusa up and actually make it a place
where people want to “live and play”.
• Work more closely with Azusa School District to help improve our schools which will also
increase our property values.
• Yes, I would like to address the high value of owning property in Azusa. We need to have
programs like in irwindale who provide owning a home for long time residents at minimal
expense.
•
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Figure 15: How long have you lived in Azusa? (Question 15; n=249)
Figure 16: Please indicate your gender (Question 16; n=250)
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Figure 17: How do you identify yourself? (Question 17; n=250)
Other responses
• Chicano
• Black irish
• Multi racial
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Figure 18: What language is primarily spoken in your household? (Question 18;
n=248)
Other responses
• Gujarati,English
• Tagalog
• Tagalog
• Tagalog
• all three
• Both Spanish and English
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Figure 19: How old are you? (Question 19; n=249)
Figure 20: Which ZIP code do you reside in? (Question 20; n=234)
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Figure 21: Which best describes your annual household income? (Question 21;
n=240)
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HOUSING ELEMENT APPENDICES | AZUSA HOUSING ELEMENT 2021-2029
Figure 22: Check all that apply to you (Question 21; n=238)
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Appendix A-4: Public Comments on Draft Housing Element
Comment Page Number/Location
I represent (thought I don’t speak for all)
over 3,000 stakeholders in the SGV that are
supportive of increased housing and services
for those experiencing homelessness. I
support your Housing element, especially:
H2-4-Inclusionary Zoning: Needed since
affordable housing does not occur naturally, as
you stated that only 6 units were developed in
your last cycle H3-6-Address Homelessness:
I would only urge you to change “to allow”
to make the commitment of supportive and
transitional housing more in line with SB5
and your plan to develop shelter/short term
housing H4-2-Supportive and Transitional:
Completely support ALL housing, including
special NEEDs (H5-1) that is for ALL of Azusa.
2/3 of suburban homelessness have 2 or 3 ties
to that community of origin. So 67% of those
Azusa homeless have grown up, work, or have
family in Azusa, so they are Azusa’s neighbors
Table H.2.1: I support the active building of 759
low and very low units as part of the Housing
Element. With 99% of housing build during the
last cycle in the SGV, for only market rate, I urge
Azusa to not only plan, but implement these
units, as part of a comprehensive economic
development program that keeps families
and seniors housed, and staying in their city!
I am willing to meet with city staff to find ways
to develop community support for those
programs listed above. Thank you
H2-4, H3-6, H4,2, H5-1, H.2.1
Make adding ADUs easier in the City of Azusa.
Building and planning department needs
to train staff to encourage homeowners to
maximize ADU size to accommodate more
habitable units for people to live in. The current
ADU ordinance the City adopted restricts
bedroom counts within ADUs. This illegal
according to HCD and is grounds for review by
the attorney general.
Page 22, Program H3-4
While very comprehensive, the policy info fails
to address specific situations.The entire policy program.
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Azusa
Pedestrian
PlanAppendix B:
Detailed Sites
Inventory
B
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226
APPENDIX B: SITES INVENTORY
Table H‐B.1: Residential Vacant Sites
Parcel Number
(APN) General Plan Designation Zoning
Allowable
Density
(du/ac) Acres
Potential Lot
Consolidation
Current
Use
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints
4th
Cycle
Site
5th Cycle
Site
Subject
to AB
1397 Affordability Level
8608‐021‐902 Medium Density Residential Med 15 0.15 ‐‐ Vacant ‐‐ 2 Yes No No No No Above Moderate
8617‐015‐044 Low Density Residential Low 8 0.35 ‐‐ Vacant ‐‐ 2 Yes No No Yes No Above Moderate
8611‐030‐036 Low Density Residential Low 8 0.13
Yes
Vacant Owner A
2
Yes No No Yes No Above Moderate
8611‐030‐044 Low Density Residential Low 8 0.16 Vacant Owner A Yes No Yes Yes No Above Moderate
8611‐034‐003 Medium Density Residential Med 15 0.17 ‐‐ Vacant ‐‐ 2 Yes No No Yes No Above Moderate
8611‐025‐020 Medium Density Residential Med 15 0.08 ‐‐ Vacant ‐‐ 1 Yes No No Yes No Above Moderate
8611‐020‐011 Medium Density Residential Med 15 0.16
Yes
Vacant Owner A
4
Yes No Yes No Above Moderate
8611‐020‐012 Medium Density Residential Med 15 0.16 Vacant Owner B Yes No No No No Above Moderate
8611‐009‐024 Moderate Density Residential Mod 27 0.08 ‐‐ Vacant ‐‐ 2 Yes No Yes Yes No Moderate
8614‐017‐012 Low Density Residential Low 8 0.14 ‐‐ Vacant ‐‐ 1 Yes No No Yes No Above Moderate
8608‐001‐001 Low Density Residential Low 8 0.52 ‐‐ Vacant ‐‐ 3 Yes No Yes Yes No Above Moderate
8684‐019‐002 Low Density Residential Low 8 0.7
Yes
Vacant Owner A
11
Yes No No Yes No Above Moderate
8684‐019‐003 Low Density Residential Low 8 1.01 Vacant Owner A Yes No Yes Yes No Above Moderate
8612‐010‐039 Medium Density Residential Med 15 0.07
Yes
Vacant Owner A
2
Yes No No No No Above Moderate
8612‐010‐040 Medium Density Residential Med 15 0.07 Vacant Owner A Yes No No No No Above Moderate
8611‐013‐013 Medium Density Residential Med 15 0.23 ‐‐ Vacant ‐‐ 3 Yes No No Yes No Above Moderate
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227
Table H‐B.2: Residential Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built
Underutilized
Criteria
4th Cycle
Site
5th Cycle
Site
Subject
to AB
1397
Affordability
Level
8608‐019‐005
Moderate Density
Residential Mod 27 0.16 1 Unit ‐‐ ‐‐ 4 Yes No 1.5 1955
Double
capacity
Structure
over 30
years old
Near MFRs
Property
located
within ½
mile of
light rail
station No Yes No
Moderate
8608‐020‐009
Moderate Density
Residential Mod 27 0.12 1 Unit ‐‐ ‐‐ 3 Yes No 0.5 1923
Double
capacity
Structure
over 30
years old
Near MFRs
Low ILR
Property
located
within ½
mile of
light rail
station No Yes No
Moderate
8611‐008‐036
Moderate Density
Residential Mod 27 0.16 1 Unit ‐‐ ‐‐ 4 Yes No 0.3 1897
Double
capacity
Structure
over 30
years old
Near MFRs
Low ILR
Property
located
within ½
mile of
light rail
station No Yes No
Moderate
8616‐005‐900
Moderate Density
Residential Mod 27 0.87
Fire Station + Parking
Lot ‐‐ ‐‐ 20 Yes No 0.0 ‐‐ Near MFRs Yes Yes No
Moderate
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Table H‐B.2: Residential Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built
Underutilized
Criteria
4th Cycle
Site
5th Cycle
Site
Subject
to AB
1397
Affordability
Level
Low
FAR/Large
Parking lot
Low ILR
Property
located
within ½
mile of
light rail
station
8605‐010‐001
Moderate Density
Residential Mod 27 0.16 1 Unit
Yes
Owner A
15
Yes No 2.3 1924
Double
capacity
Structure
over 30
years old
Near MFRs
Low ILR
Yes Yes No
Moderate
8605‐010‐002
Moderate Density
Residential Mod 27 0.16 1 Unit Owner B Yes No 0.3 1948 Yes Yes No
Moderate
8605‐010‐003
Moderate Density
Residential Mod 27 0.17 1 Unit Owner C Yes No 0.5 1949 Yes Yes No
Moderate
8611‐009‐025
Moderate Density
Residential Mod 27 0.16 1 Unit ‐‐ 4 Yes
Potential
historical
resource 0.0 1901
Double
capacity
Structure
over 30
years old
Near MFRs
Property
located
within ½
mile of
transit Yes Yes No
Moderate
8619‐013‐066
Medium Density
Residential Med 15 0.44
Convenience Store/Gas
Station ‐‐ 6 Yes No ‐‐ 1964
Structures
over 30
years old
Small
scale,
marginal
uses
Low
FAR/Large
surface
parking lot Yes Yes No
Above
Moderate
8615‐019‐028
Low Density
Residential Low 8 1.56 Machine Shop Yes Owner A 10 Yes No 0.0 ‐‐
Structure
over 30
years old No Yes No
Above
Moderate
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229
Table H‐B.2: Residential Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built
Underutilized
Criteria
4th Cycle
Site
5th Cycle
Site
Subject
to AB
1397
Affordability
Level
Low ILR
Low FAR
Small
scale,
marginal
use
8611‐022‐001
Moderate Density
Residential Mod 27 0.17 1 Unit
Yes
Owner A
21
Yes No 0.8 1958
Double
capacity
Structure
over 30
years old
Near MFRs
Low ILR
No Yes No
Moderate
8611‐022‐002
Moderate Density
Residential Mod 27 0.18 1 Unit Owner B Yes No 0.2 1953 Yes Yes No
Moderate
8611‐022‐003
Moderate Density
Residential Mod 27 0.17 1 Unit Owner C Yes No 0.6 1910 Yes Yes No
Moderate
8611‐022‐004
Moderate Density
Residential Mod 27 0.18 1 Unit Owner D Yes No 0.5 1925 Yes Yes No
Moderate
8611‐022‐007
Moderate Density
Residential Mod 27 0.12 1 Unit Owner E Yes No 1.1 1928 Yes Yes No
Moderate
8611‐022‐006
Moderate Density
Residential Mod 27 0.11 1 Unit Owner F Yes No 2.6 1929 Yes Yes No
Moderate
8616‐005‐019
Moderate Density
Residential Mod 27 0.18 1 Unit Yes Owner A 8 Yes No 0.6 2003
Double
capacity
Near MFRs
Low ILR
Lot Cons. Yes Yes No
Moderate
8616‐005‐018
Moderate Density
Residential Mod 27 0.17 1 Unit
Owner B
4
Yes No 0.1 1917
Double
capacity
Near MFRs
Low ILR
Structure
over 30
years old
Property
located
within ½
mile of
transit
No Yes No
Moderate
8608‐019‐001
Moderate Density
Residential Mod 27 0.16 1 Unit
Yes
Owner A
11
Yes No 1.0 1922
Double
capacity
Structure
over 30
years old
Yes Yes No
Moderate
8608‐019‐002
Moderate Density
Residential Mod 27 0.32 2 Units Owner B Yes No 0.4 1935 Yes Yes No
Moderate
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Table H‐B.2: Residential Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built
Underutilized
Criteria
4th Cycle
Site
5th Cycle
Site
Subject
to AB
1397
Affordability
Level
Near MFRs
Property
located
within ½
mile of
transit
8608‐021‐901
Medium Density
Residential Med 15 0.13 1 Unit ‐‐ ‐‐ 2 Yes No 0.0 1901
Double
capacity
Near MFRs
Low ILR Yes No No
Above
Moderate
8608‐020‐027
Moderate Density
Residential Mod 27 0.16 1 Unit ‐‐ ‐‐ 4 Yes No 0.2 1923
Double
capacity
Near MFRs
Low ILR
Structure
over 30
years old
Property
located
within ½
mile of
transit No No No
Moderate
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231
Table H‐B.3: Vacant Mixed‐Use Sites
Parcel
Number
(APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres
Potential Lot
Consolidation
Common
Ownership Current Use Realistic Capacity
Infrastructure
Capacity
On‐Site
Constraints
4th
Cycle
Site
5th
Cycle
Site
Subject
to
1397 Affordability Level
8619‐016‐048
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.18 ‐‐ ‐‐ Vacant 3 Yes No No No No Above Moderate
8611‐030‐007
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.13 ‐‐ ‐‐ Vacant 3 Yes No No No No Above Moderate
8613‐026‐018
Residential
Mixed Use
South Azusa
Avenue
Corridor 27 1.05 ‐‐ ‐‐ Vacant 20 Yes No No No No Above Moderate
8613‐026‐016
Residential
Mixed Use
South Azusa
Avenue
Corridor 27 0.22 ‐‐ ‐‐‐ Vacant 4 Yes No No No No Above Moderate
8621‐024‐012
Residential
Mixed Use
South Azusa
Avenue
Corridor 27 0.35 ‐‐ ‐‐ Vacant 7 Yes
Triangular
parcel
presents
design
constraints No Yes No Above Moderate
8611‐031‐026
Commercial
Mixed Use
South Azusa
Avenue
Corridor 27 0.3 ‐‐ ‐‐ Vacant 5 Yes No Yes No No Above Moderate
8614‐016‐030
Commercial
Mixed Use
Edgewood
District 27 0.33 ‐‐ ‐‐ Vacant 6 Yes No No No No Above Moderate
8630‐008‐903
Neighborhood
Center
Neighborhood
Center 27 0.75 ‐‐ ‐‐ Vacant 14 Yes No No No No Above Moderate
8614‐026‐034
Neighborhood
Center
Neighborhood
Center 27 0.32 ‐‐ ‐‐ Vacant 6 Yes No Yes Yes No Above Moderate
8622‐002‐030
Neighborhood
Center
Neighborhood
Center 27 0.48 ‐‐ ‐‐ Vacant 9 Yes No No No No Above Moderate
8620‐004‐015
Commercial
Mixed Use
South Azusa
Avenue
Corridor 27 1.61 ‐‐ ‐‐ Vacant 29 Yes No No No No Above Moderate
8624‐021‐037
Commercial
Mixed Use
University
District ‐ Mixed
Use 27 1.4 ‐‐ ‐‐ Vacant 25 Yes No No No No Above Moderate
8611‐014‐900
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.32
Yes
Azusa City Vacant
10
Yes No Yes Yes No Above Moderate
8611‐014‐021
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.08 Owner B Vacant Yes No Yes Yes No Above Moderate
8611‐014‐020
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.16 Owner B Vacant Yes No Yes Yes No Above Moderate
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Table H‐B.3: Vacant Mixed‐Use Sites
Parcel
Number
(APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres
Potential Lot
Consolidation
Common
Ownership Current Use Realistic Capacity
Infrastructure
Capacity
On‐Site
Constraints
4th
Cycle
Site
5th
Cycle
Site
Subject
to
1397 Affordability Level
8611‐027‐004
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.08
Yes
Owner A Vacant
9
Yes No No Yes No Above Moderate
8611‐027‐006
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.32 Owner B Vacant Yes No Yes Yes No Above Moderate
8611‐027‐005
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.08 Owner C Vacant Yes No Yes Yes No Above Moderate
8611‐015‐030
Residential
Mixed Use
San Gabriel
Avenue
Corridor 27 0.08
Yes
Owner A Vacant
6
Yes No No No No Above Moderate
8611‐015‐031
Residential
Mixed Use
San Gabriel
Avenue
Corridor 27 0.24 Owner A Vacant Yes No No No No Above Moderate
8613‐026‐017
Residential
Mixed Use
South Azusa
Avenue
Corridor 27 0.12
Yes
Owner A Vacant
9
Yes No No No No Above Moderate
8613‐024‐024
Residential
Mixed Use
South Azusa
Avenue
Corridor 27 0.35 Owner B Vacant Yes No No No No Above Moderate
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Table H‐B.4: Mixed Use Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8628‐004‐166 Commercial
University District
‐ Mixed Use 27 5.6
Shopping center
(tire sales, fitness,
medical) ‐‐ ‐‐ 101 Yes No ‐‐ 1989 0.20
Structures over
30 years old
Low FAR/Large
parking lot
Near new MFRs
Small‐scale,
marginal uses
Property located
in mixed use
zone No No No Moderate
8611‐015‐023
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.97 Restaurant
Yes
Owner A 18 Yes No 1.5 1950 0.29
Structures over
30 years old
Low FAR/Large
parking lot
Near new MFRs
Small‐scale,
marginal uses
Property located
in mixed use
zone
Property located
within ½ mile of
transit
Yes Yes No Moderate
8611‐015‐026
Residential
Mixed Use
San Gabriel
Avenue Corridor 27 0.48
Parking Lot of
Restaurant Owner A 9 Yes No 0.1 1951 0.00 Yes Yes No Moderate
8624‐021‐035
Commercial
Mixed Use
University District
‐ Mixed Use 27 5.62
Parking Lot of
Shopping Center ‐‐ ‐‐ 102 Yes No 0.0 1956‐1985 0.00
Structures of
shopping center
over 30 years old
Low FAR/Large
parking lot
Near new MFRs
Low ILR
Property located
in mixed use
zone No No No Moderate
8611‐036‐011
Commercial
Mixed Use
South Azusa
Avenue Corridor 27 0.43 1 Unit
‐‐
‐‐ 3 Yes No 0.7 1953 0.05
Double capacity
Structure over
30 years old
Near MFRs
Small‐scale,
marginal uses
No No
Moderate
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Table H‐B.4: Mixed Use Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8611‐018‐012
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.16 1 Unit ‐‐ ‐‐ 8 Yes No 0.2 1923 0.08
Double capacity
Structure over
30 years old
Near MFRs
Low ILR
Small‐scale,
marginal uses
Property located
in mixed use
zone No No No Moderate
8611‐027‐001
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.16 1 Unit ‐‐ ‐‐ 3 Yes No 0.4 1915 0.12
Double capacity
Structure over
30 years old
Near MFRs
Small‐scale,
marginal uses
Low ILR
Property located
in mixed use
zone No No No Moderate
8619‐013‐063
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.39 Cell phone store
Yes
Owner A
40
Yes No 4.9 1988 0.97
Structures over
30 years old
Low FAR/Large
parking lot
Near MFRs
Lot consolidation
potential with
common
ownership
Small‐scale,
marginal uses
Property located
in mixed use
zone
Yes Yes No
Above
Moderate
8619‐013‐061
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.25 Liquor store Owner A Yes No 1.1 1965 0.21 Yes Yes No
Above
Moderate
8619‐013‐047
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.75 Restaurant Owner B Yes No 0.6 1970 0.11 Yes Yes No
Above
Moderate
8619‐013‐064
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.44 Driving School Owner A Yes No 0.0 ‐‐ 0.00 Yes Yes No
Above
Moderate
8619‐013‐062
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.35 Hair Salon Owner A Yes No 0.0 ‐‐ 0.00 Yes Yes No
Above
Moderate
8619‐013‐065
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.04 Clothing store Owner B Yes No 0.0 ‐‐ 0.00 Yes Yes No
Above
Moderate
8622‐024‐008
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.83 Auto Body Shop
Yes
Owner A
30
Yes No 1.1 1978 0.14
Structures over
30 years old
Small‐scale,
marginal uses
Near MFRs
Yes Yes No
Above
Moderate
8622‐024‐003
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.83 Auto Body Shop Owner B Yes No 1.7 1976 0.55 Yes Yes No
Above
Moderate
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Table H‐B.4: Mixed Use Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Low FAR/Large
parking lot
Property located
in mixed use
zone
8622‐023‐002
Commercial
Mixed Use
Arrow Highway
Corridor 27 1.66 Auto Body Shop
Yes
Owner A
89
Yes No ‐‐ 1980 0.11
Structures over
30 years old
Small‐scale,
marginal uses
Low FAR/Large
surface parking
lot
Near MFRs
Low ILR
Property located
in mixed use
zone
No Yes No
Above
Moderate
8622‐024‐020
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.45
Psychic, nutrition
shop Owner B Yes No ‐‐ 1982 0.17 Yes Yes No
Above
Moderate
8622‐023‐001
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.82 Auto Body Shop Owner C Yes No 1.4 1968 0.09 Yes Yes No
Above
Moderate
8622‐024‐022
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.68 Auto Body Shop Owner D Yes No 0.7 1965 0.05 No Yes No
Above
Moderate
8622‐024‐024
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.5 Used car sales Owner E Yes No 0.3 1969 0.18 No Yes No
Above
Moderate
8622‐024‐006
Commercial
Mixed Use
Arrow Highway
Corridor 27 0.8 Used car sales Owner F Yes No 0.3 1953 0.04 Yes Yes No
Above
Moderate
8611‐026‐014
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.32 Restaurant
Yes
Owner A
9
Yes No 0.5 1956 0.19
Structures over
30 years old
Low FAR/Large
parking lot
Near MFRs
Lot consolidation
potential with
common
ownership
Low ILR
Small‐scale,
marginal uses
Property located
in mixed use
zone
Yes Yes No
Above
Moderate
8611‐026‐015
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.16
Restaurant parking
lot Owner A Yes No 0.0 ‐‐ 0.00 Yes Yes No
Above
Moderate
8611‐026‐024
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.16 Strip Mall
Yes
Owner A
6
Yes No 0.0 1965 1.00
Structures over
30 years old
Low FAR/Large
parking lot
Near MFRs
Common
ownership
No No No
Above
Moderate
8611‐026‐025
Commercial
Mixed Use
Azusa Avenue
Corridor 27 0.16 Parking Lot Owner A Yes No 0.0 ‐‐ 0.00 No Yes No
Above
Moderate
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Table H‐B.4: Mixed Use Underutilized Sites
Parcel
Number (APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Small‐scale,
marginal uses
Property located
in mixed use
zone
8620‐004‐016
Commercial
Mixed Use
South Azusa
Avenue Corridor 27 0.82 Car Wash ‐‐ ‐‐ 15 Yes No 0.8 1965 0.16
Structures over
30 years old
Small‐scale,
marginal uses
Near MFRs
Low ILR
Low FAR
Property located
in mixed use
zone Yes Yes No Moderate
8608‐020‐026
Moderate
Density
Residential
Neighborhood
Center 27 0.16 1 Unit ‐‐ ‐‐ 3 Yes No 0.2 1901 0.10
Double capacity
Structures over
30 years old
Near MFRs
Low ILR
Property located
in mixed use
zone
Property located
within ½ mile of
light rail station No No No
Above
Moderate
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Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8611‐008‐019
Downtown
District Downtown 28 0.24 Clothing Store ‐‐ ‐‐ 6 Yes No 0.4 1952 0.58
Structures over
30 years old
Near MFRs
Low ILR
Low FAR
Scall‐scale,
marginal uses
Property
located in
specific plan
area
Property
located within ½
mile of a light
rail station No No No
Above
Moderate
8611‐008‐035
Downtown
District Downtown 28 0.24 Car Wash ‐‐ ‐‐ 6 Yes No 0.1 1965 0.15
Structure over
30 years old
Small‐scale,
marginal uses
Near MFRs
Low ILR
Low FAR
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station No No No
Above
Moderate
8611‐008‐800
Downtown
District Downtown 28 0.32 Parking Lot ‐‐ ‐‐ 8 Yes No ‐‐ ‐‐ 0.00
Large surface
parking lot
Near MFRs
Low ILR
Low intensity
use
Property
located in No No No
Above
Moderate
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Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
specific plan
area
Property
located within ½
mile of transit
8611‐004‐023
Downtown
District Downtown 28 0.16 Vacant ‐‐ ‐‐ 4 Yes No 0.0 ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8608‐026‐901
Gold Line
District Gold Line 28 0.16 Parking Lot ‐‐ City of Azusa 4 Yes No 0.0 0.00
Large surface
parking lot
Low intensity
use
Near MFRs
Low ILR
Government
ownership
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station No No No
Above
Moderate
8608‐029‐041
Route 66
District Route 66 28 0.23 Restaurant ‐‐ ‐‐ 5 Yes No 0.7 1989 0.29
Structure over
30 years old
Low FAR/Large
surface parking
lot
Near MFRs
Low ILR
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station No No No
Above
Moderate
8608‐029‐040
Route 66
District Route 66 28 0.24
Convenience
Store ‐‐ ‐‐ 6 Yes No 0.4 1974 0.13
Structure over
30 years old No No No
Above
Moderate
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Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Low FAR/Large
surface parking
lot
Near MFRs
Low ILR
Small‐scale,
marginal uses
Property
located in
specific plan
area
Property
located within ½
of light rail
station
8608‐029‐039
Route 66
District Route 66 28 0.22 Laundromat ‐‐ F‐‐ 5 Yes No 1.0 1974 0.25
Structure over
30 years old
Low FAR/Large
surface parking
lot
Near MFRs
Small‐scale,
marginal uses
Property
located in
specific plan
area
Property
located within ½
mile of transit No No No
Above
Moderate
8611‐005‐005
Route 66
District Route 66 28 0.2
Chamber of
Commerce
building ‐‐ ‐‐ 5 Yes No 0.4 1927 0.15
Structure over
30 years old
Low FAR/Large
surface parking
lot
Near MFRs
Low ILR
Small‐scale,
marginal uses
Property
located in No No No
Above
Moderate
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Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
specific plan
area
Property
located within ½
mile of light rail
station
8611‐001‐006
Route 66
District Route 66 28 0.17 Parking Lot ‐‐ ‐‐ 4 Yes No 0.0 ‐‐ 0.00
Large surface
parking lot
Low intensity
use
Near MFRs
Low ILR
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station No Yes No
Above
Moderate
8616‐005‐002
Route 66
District Route 66 28 0.17 Parking Lot ‐‐ ‐‐ 4 Yes No 0.0 ‐‐ 0.00
Large surface
parking lot
Low intensity
use
Near MFRs
Low ILR
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station No Yes No
Above
Moderate
8612‐003‐014
Route 66
District Route 66 28 0.18 Parking Lot ‐‐ ‐‐ 4 Yes No 0.0 ‐‐ 0.00
Large surface
parking lot
Low intensity
use
Near MFRs
Low ILR No No No
Above
Moderate
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Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Property
located in
specific plan
area
8612‐001‐919
Route 66
District Route 66 28 0.13 Vacant ‐‐
LA County
Housing
Authority 3 Yes No 0.0 ‐‐ 0.00
Vacant lot
No Yes No
Above
Moderate
8608‐019‐050
Transit
District Transition 28 0.13 2 Units ‐‐ ‐‐ 3 Yes No 0.5 1994
No No No
Above
Moderate
8611‐005‐009
Transit
District Transition 28 0.16 1 Unit ‐‐ ‐‐ 4 Yes No 0.7 1936 0.11
Double capacity
Structure over
30 years old
Property
located within ½
mile of light rail
station
Low ILR No Yes No
Above
Moderate
8608‐019‐051
Transit
District Transition 28 0.32 3 Units ‐‐ ‐‐ 8 Yes No 1.1 1988 0.07
Double capacity
Structure over
30 years old
Property
located within ½
mile of light rail
station
Property
located in
specific plan
area Yes Yes No
Above
Moderate
8612‐001‐907
Route 66
District Route 66 28 0.14 Vacant
Yes
Data Not
Available 3 Yes No ‐‐ ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8612‐001‐908
Route 66
District Route 66 28 0.13 Vacant
LA County
Housing
Authority 3 Yes No 0.0 ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8612‐001‐905
Route 66
District Route 66 28 0.14 Vacant
Yes
Data Not
Available 3 Yes No ‐‐ ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8612‐001‐915
Route 66
District Route 66 28 0.14 Vacant
LA County
Housing
Authority 3 Yes No 0.0 ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8612‐001‐920
Route 66
District Route 66 28 0.14 Vacant
LA County
Housing
Authority 3 Yes No 0.0 ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
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242
Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8612‐001‐906
Route 66
District Route 66 28 0.25 Vacant
Yes
Data Not
Available 6 Yes No ‐‐ ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8612‐001‐912
Route 66
District Route 66 28 0.18 Vacant
LA County
Housing
Authority 4 Yes No 0.0 ‐‐ 0.00
Vacant
No Yes No
Above
Moderate
8611‐005‐027
Downtown
Expansion
District
Downtown
Expansion 28 0.08 Parking Lot Yes Owner A 2 Yes No 0.1 1973
Large surface
parking lot
Near MFRs
Low ILR No No No
Above
Moderate
8611‐005‐026
Downtown
Expansion
District
Downtown
Expansion 28 0.16
Chiropractor
Office
Owner B 4 Yes No 0.2 1938 0.24
Low FAR/Large
surface parking
lot
Near MFRs
Small‐scale,
marginal uses
Low ILR
Structure over
30 years old
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station Yes No No
Above
Moderate
8611‐005‐028
Downtown
Expansion
District
Downtown
Expansion 28 0.16 Auto Body Shop
Owner A 4 Yes No 0.3 1952
Large surface
parking lot
Near new MFRs
Low ILR No No No
Above
Moderate
8611‐002‐041
Downtown
District Downtown 28 0.26 Hair Salon
Yes
Owner A 6 Yes No 0.4 1953 0.20
Low FAR/Large
surface parking
lot
Near MFRs
Small‐scale,
marginal uses
Low ILR
Property
located in
Yes No No
Above
Moderate
8611‐002‐001
Downtown
District Downtown 28 0.2 Parking Lot Owner A 5 Yes No 0.1 1911 0.85 Yes No No
Above
Moderate
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Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
specific plan
area
Common
ownership
Property
located within ½
mile of light rail
station
8608‐026‐004
Gold Line
District Gold Line 28 0.06 Parking Lot
Yes
Owner A 1 Yes No 0.0 1950
0.00 Low FAR/Large
surface parking
lot
Near MFRs
Small‐scale,
marginal use
Low ILR
Structure over
30 years old
Empty store
suggests high
tenant turnover
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station
No No No
Above
Moderate
8608‐026‐007
Gold Line
District Gold Line 28 0.12
Empty Store
Front Owner A 3 Yes No 0.2 1925 0.96 No No No
Above
Moderate
8611‐001‐003
Route 66
District Route 66 28 0.18
Computer
Services Office
Yes
Owner A 4 Yes No 0.3 1916 0.21
Low FAR/Large
surface parking
lot
Near new MFRs
Small‐scale,
marginal use
Low ILR
Structure over
30 years old
Property
located in
No No No
Above
Moderate
8611‐001‐005
Route 66
District Route 66 28 0.17 Parking Lot Owner B 4 Yes No 0.2 1944 0.21 No No No
Above
Moderate
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244
Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
specific plan
area
Property
located within ½
mile of light rail
station
8608‐026‐903
Gold Line
District Gold Line 28 0.28 Parking Lot
‐‐
Redevelopment
Agency of
Azusa 7 Yes No ‐‐ -- 0.00
Large surface
parking lot
Low intensity
use
Near MFRs
Government
ownership
Low ILR
Property
located within ½
mile of light rail
station
Property
located in
specific plan
area No No No
Above
Moderate
8612‐003‐032
Route 66
District Route 66 28 0.07 Vacant
Yes
Owner A 2 Yes No 0.0 ‐‐ 0.00
Low FAR/Large
surface parking
lot
Near MFRs
Low ILR
Adjacent to
vacant sites
Property
located in
specific plan
area
No No
No Above
Moderate
8612‐003‐033
Route 66
District Route 66 28 0.03 Vacant Owner A 1 Yes No 0.0 ‐‐ 0.00 No No
No Above
Moderate
8612‐003‐031
Route 66
District Route 66 28 0.1 Vacant Owner B 2 Yes No 0.0 ‐‐ 0.00 No No
No Above
Moderate
8612‐003‐025
Route 66
District Route 66 28 0.17 Commercial Owner A 4 Yes No 2.0 ‐‐ 0.00 No No No
Above
Moderate
8612‐003‐026
Route 66
District Route 66 28 0.32 Commercial Owner A 8 Yes No 0.6 ‐‐ 0.15 No No No
Above
Moderate
8608‐028‐903
Civic
District Civic 28 0.19 Parking Lot
Yes
City of Azusa 5 Yes No 0.0 ‐‐ 0.00
Large surface
parking lot
Low intensity
use
Government
ownership
Low ILR
No No No
Above
Moderate
8608‐028‐901
Civic
District Civic 28 0.18 Parking Lot City of Azusa 4 Yes No 0.0 ‐‐ 0.00 No No No
Above
Moderate
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245
Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station
8608‐021‐001
Transit
District Transition 28 0.24 1 Unit
Yes
Owner A 6 Yes No 0.5 1953 0.14
Double capacity
Structure over
30 years old
Near MFRs
Low ILR
Property
located in
specific plan
area
Property
located within ½
mile of light rail
station
Yes Yes No
Above
Moderate
8608‐021‐002
Transit
District Transition 28 0.16 1 Unit Owner B 4 Yes No 1.6 1910 0.27 Yes Yes No
Above
Moderate
8612‐001‐067
Route 66
District Route 66 102 0.52 Restaurant ‐‐ ‐‐ 45 Yes No 0.3 1984 0.10
Low FAR/Large
surface parking
lot
Near new MFRs
Structure over
30 years old
Low ILR
Small‐scale,
marginal uses
Property
located in
specific plan
area Yes No
No
Above
Moderate
8612‐003‐046
Route 66
District Route 66 102 0.55 1 Unit ‐‐ ‐‐ 48 Yes No 0.1 1914 0.06
Double capacity
Structure over
30 years old
Near MFRs
Low ILR No No
No
Moderate
AZUSA HOUSING ELEM ENT 2021-2029 | HOUSING ELEM ENT APPENDICES
246
Table H‐B.5: Azusa TOD Specific Plan Small Parcel Sites (Less than 0.5 acres)
Parcel
Number (APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR
Year
Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Property
located in
specific plan
area
Legal non‐
conforming use
AZUSA HOUSING ELEM ENT 2021-2029 | HOUSING ELEM ENT APPENDICES
247
Table H‐B.6: Large Parcels Azusa TOD Specific Plan
Parcel Number
(APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8608‐023‐027
Gold Line
District Gold Line 102 0.89 Parking Lot ‐‐ ‐‐ 77 Yes No 0.0 ‐‐ 1.00
Large surface
parking lot
Low intensity use
Low ILR
Near MFRs
Property located
in specific plan
area
Property located
within ½ mile of
light rail transit
station No No
No
Very Low
8624‐002‐025
Route 66
District Route 66 102 1.11 Autobody Shop ‐‐ ‐‐ 96 Yes No 3.1 2016
Large surface
parking lot
Declining use
Near MFRs Yes Yes
No
Very Low
8612‐001‐001
Route 66
District Route 66 102 0.71 Parking Lot ‐‐ ‐‐ 62 Yes No 0.0 ‐‐ 0.00
Large surface
parking lot
Low intensity use
Low ILR
Property located
in specific plan
area
Property located
within ½ mile of
light rail station No No
No
Very Low
8608‐021‐001
Transit
District Transition 102 0.24 1 Unit Site 11 Owner A 21 Yes No 0.5 1953
Double capacity
Older Structure
Near MFRs
Low ILR Yes Yes
No
Very Low
8608‐021‐002
Transit
District Transition 102 0.16 1 Unit
Owner B 14 Yes No 1.6 1910
Double capacity
Older Structure
Near MFRs Yes Yes
No
Very Low
8608‐021‐004
Transit
District Transition 102 0.16 1 Unit
Yes
Owner D 14 Yes No 1.6 1961 0.19
Double capacity
Structure over 30
years old
Near MFRs
Yes Yes
No
Very Low
8608‐021‐005
Transit
District Transition 102 0.16 1 Unit Owner E 14 Yes No 0.4 1896 0.18 Yes Yes
No
Very Low
8608‐021‐006
Transit
District Transition 102 0.24 1 Unit Owner F 21 Yes No 0.4 1912 0.12 Yes Yes
No
Very Low
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Table H‐B.6: Large Parcels Azusa TOD Specific Plan
Parcel Number
(APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Property located
within specific
plan area
Property located
within ½ mile of
light rail station
8616‐005‐035
Route 66
District Route 66 102 0.92 Liquor store
Site 12
Owner A 80 Yes No 0.7 1948 0.15
Low FAR/Large
surface parking
lot
Near MFRs
Structure over 30
years old
Small scale,
marginal uses
Double capacity
Common and
government
ownership
Low ILR
Vacant sites
Property located
in specific plan
area
Property located
within ½ mile of
light rail station
No Yes
No
Very Low
8616‐005‐034
Route 66
District Route 66 102 0.45
Landscaping
Office Building Owner B 39 Yes No 0.3 1946 0.30 Yes Yes
No
Very Low
8612‐001‐053
Route 66
District Route 66 102 0.14 4 Units Owner C 12 Yes No 5.2 1963 0.61 Yes Yes
No
Very Low
8612‐001‐910
Route 66
District Route 66 102 0.14 4 Units
LA County
Housing
Authority 12 Yes No 0.0 1963 0.61 No Yes
No
Very Low
8612‐001‐100
Route 66
District Route 66 102 0.13 4 Units Owner D 11 Yes No 1.5 1963 0.66 No Yes
No
Very Low
8612‐001‐059
Route 66
District Route 66 102 0.01 Vacant Owner C 1 Yes No 0.0 ‐‐ 0.00 Yes Yes
No
Very Low
8612‐001‐911
Route 66
District Route 66 102 0.14 Vacant
LA County
Housing
Authority 12 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8612‐001‐918
Route 66
District Route 66 102 0.14 Vacant
LA County
Housing
Authority 12 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8612‐001‐921
Route 66
District Route 66 102 0.14 Vacant
LA County
Housing
Authority 12 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8612‐001‐917
Route 66
District Route 66 102 0.13 Vacant
LA County
Housing
Authority 11 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8612‐001‐916
Route 66
District Route 66 102 0.15 Vacant
LA County
Housing
Authority 13 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8612‐001‐038
Route 66
District Route 66 102 0.14 4 Units
Site 14
Owner A 12 Yes No 1.5 1963 0.58
Double capacity
Vacant sites No Yes
No
Very Low
8612‐001‐914
Route 66
District Route 66 102 0.14 Vacant
LA County
Housing
Authority 12 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
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Table H‐B.6: Large Parcels Azusa TOD Specific Plan
Parcel Number
(APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8612‐001‐909
Route 66
District Route 66 102 0.14 Vacant
LA County
Housing
Authority 12 Yes No 0.0 ‐‐ 0.00
Common and
government
ownership
Structure over 30
years old
Property located
in specific plan
area
No Yes
No
Very Low
8612‐001‐913
Route 66
District Route 66 102 0.15 Vacant
LA County
Housing
Authority 13 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8611‐002‐032
Downtown
Expansion
District
Downtown
Expansion 102 0.16 1 Unit
Site 3
Owner B 14 Yes No 1.5 1956 0.22
Structure over 30
years old
Double capacity
Near MFRs
Low ILR
Legal
nonconforming
use
Property located
in specific plan
area
Property located
within ½ mile of
light rail station
Property owner
development
interest
Yes Yes
No
Very Low
8611‐002‐018
Downtown
Expansion
District
Downtown
Expansion 102 0.08 1 Unit Owner C 7 Yes No 0.6 1950 0.20 Yes Yes
No
Very Low
8611‐002‐013
Downtown
Expansion
District
Downtown
Expansion 102 0.16 1 Unit Owner D 14 Yes No 0.5 1914 0.23 Yes Yes
No
Very Low
8611‐002‐019
Downtown
Expansion
District
Downtown
Expansion 102 0.19 1 Unit Owner E 16 Yes No 0.2 1913 0.13 Yes Yes
No
Very Low
8611‐002‐020
Downtown
Expansion
District
Downtown
Expansion 102 0.21 1 Unit Owner F 18 Yes No 0.5 1905 0.14 Yes Yes
No
Very Low
8611‐002‐040
Downtown
Expansion
District
Downtown
Expansion 102 0.16 4 Units, Owner G 14 Yes No 1.5 1988 0.56 Yes Yes
No
Very Low
8611‐007‐007
Downtown
District Downtown 102 0.28 Medical Office
Site 35
Owner A 24 Yes No 0.6 1954 0.05
Structures over
30 years old
Small scale,
marginal uses
Near MFRs
Low FAR/Large
parking lot
Property located
in specific plan
area
Property located
within ½ mile of
light rail station
No No
No
Very Low
8611‐007‐008
Downtown
District Downtown 102 0.16
Salon and Bridal
Shop Owner B 14 Yes No 1.2 1964 0.57 No No
No
Very Low
8611‐007‐036
Downtown
District Downtown 102 0.32
Strip Mall (liquor
store, fitness
studio,
water/discount
store) Owner C 28 Yes No 1.2 1964 0.00 Yes No
No
Very Low
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Table H‐B.6: Large Parcels Azusa TOD Specific Plan
Parcel Number
(APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
8608‐029‐001
Downtown
Expansion
District
Downtown
Expansion 102 0.34 Restaurant
Site 4
Owner A 29 Yes No 0.7 1957 0.16
Structure over 30
years old
Small scale,
marginal uses
Near MFRs
Low FAR/Large
parking lot
Low ILR
Property owner
development
interest
Property located
in specific plan
area
Property located
within ½ mile of
light rail station
No Yes
No
Very Low
8608‐029‐043
Downtown
Expansion
District
Downtown
Expansion 102 0.17
Restaurant
Parking Lot Owner A 15 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8608‐028‐010
Transit
District Transition 102 1.02
Plumbing Supply
Store
Site 5
Owner A 88 Yes No 3.4 1901 0.64
Structure over 30
years old
Near MFRs
Property located
within ½ mile of
light rail station
Low FAR/Large
surface parking
lot
Property owner
development
interest
Property located
in specific plan
area
No Yes
No
Very Low
8608‐028‐001
Transit
District Transition 102 0.10
Plumbing Supply
Store Parking Lot Owner B 8 Yes No 0.0 ‐‐ 0.00 No Yes
No
Very Low
8611‐005‐013
Transit
District Transition 102 0.16 1 Unit
Site 7
Owner A 14 Yes No 0.3 1929 0.14
Structures over
30 years old
Double capacity
Near new MFRs
Property located
within ½ mile of
light rail station
Low ILR
No Yes
No
Low
8611‐005‐014
Transit
District Transition 102 0.15 1 Unit Owner B 13 Yes No 0.5 1929 0.15 Yes Yes
No
Low
8611‐005‐015
Transit
District Transition 102 0.18 1 Unit Owner C 16 Yes No 0.4 1921 0.18 Yes Yes
No
Low
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Table H‐B.6: Large Parcels Azusa TOD Specific Plan
Parcel Number
(APN)
General
Plan
Designation Zoning
Assumed
Average
Density
(du/ac) Acres Current Use
Potential
Consolidation
Common
Ownership
Realistic
Capacity
Infrastructure
Capacity
On‐Site
Constraints ILR Year Built FAR
Underutilized
Criteria
4th
Cycle
Site
5th
Cycle
Site
Subject
to AB
1397
Affordability
Level
Property located
within specific
plan area
8608‐028‐002
Transit
District Transition 102 0.17
2 Units, 1‐4
Stories
Site 70
Owner A 15 Yes No 0.3 1961 0.13
Structures over
30 years old
Double capacity
Near MFRs
Property located
within ½ mile of
transit
Low ILR
Property located
in specific plan
area
Yes No
No
Low
8608‐028‐003
Transit
District Transition 102 0.18
3 Units, 1‐4
Stories Owner B 16 Yes No 0.1 1921 0.08 No No
No
Low
8608‐028‐004
Transit
District Transition 102 0.09 1 Unit Owner C 8 Yes No 0.2 1958 0.22 No No
No
Low
8608‐028‐013
Transit
District Transition 102 0.17 1 Unit Owner D 15 Yes No 0.3 1925 0.12 Yes No
No
Low
8608‐028‐005
Transit
District Transition 102 0.09 1 Unit Owner E 8 Yes No 0.3 1923 0.11 No No
No
Low
8608‐028‐006
Transit
District Transition 102 0.18 1 Unit Owner E 16 Yes No 0.4 1960 0.17 No No
No
Low
8612‐003‐036
Route 66
District Route 66 102 0.33 Strip Mall
Site 72
Owner A 29 Yes No 1.8 1987 0.58
Structure over 30
years old
Low FAR/Large
surface parking
Lots
Small‐scale,
marginal uses
Low ILR
Property located
in specific plan
area
No No
No
Low
8612‐003‐034
Route 66
District Route 66 102 0.19
Strip Mall
(bakery, book
store, liquor
store) Owner B 16 Yes No 0.7 1979 0.40 No No
No
Low
8612‐003‐035
Route 66
District Route 66 102 0.27 Parking Lot Owner A 23 Yes No 0.0 ‐‐ 0.00 No No
No
Low
8624‐002‐049
Route 66
District Route 66 102 0.52 Motel
Site 77
Owner A 45 Yes No 2.7 1987 0.39
Structures over
30 years old
Low FAR/Large
surface parking
Lots
Double Capacity
Property located
in specific plan
area
No No
No
Low
8624‐002‐045
Route 66
District Route 66 102 0.48 Assisted living Owner B 42 Yes No 0.6 1948 0.25 No No
No
Low
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Table H‐B.7: Religious Institution Sites
Parcel Number
(APN)
General Plan
Designation Zoning
Allowable
Density
(du/ac)
Total
Parking
Lot
Acres
Half
Parking
Lot
Acres Current Use
Potential Lot
Consolidation
Common
Ownership
Realistic
Capacity*
Infrastructure
Capacity
On‐Site
Constraints ILR FAR Criteria
4th Cycle
Sites
5th Cycle
Sites
Subject
to AB
1397
Affordability
Levels
8616‐007‐046
Low Density
Residential Low 8 0.38 0.19 Church, 1 Story ‐‐ ‐‐ 1 Yes No 2.1 0.26
Large
underutilized
parking lot
Structure
over 30
years old
Property
;ocated in
residential
zone Yes No No
Above
Moderate
8611‐035‐023
Low Density
Residential Low 8 0.78 0.39 Church, 1 Story ‐‐ ‐‐ 3 Yes No 0.9 0.16
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone
Low ILR Yes No No
Above
Moderate
8615‐019‐027
Low Density
Residential Low 8 0.81 0.405 Church, 1 Story ‐‐ ‐‐ 3 Yes No 1.9 0.24
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone Yes No No
Above
Moderate
8611‐016‐026
Low Density
Residential Low 8 0.65 0.325 Church, 1 Story ‐‐ ‐‐ 2 Yes No 1.3 0.09
Large
underutilized
parking lot
Structure
over 30
years old No No No
Above
Moderate
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Located in
residential
zone
8611‐011‐029
Medium Density
Residential Med 15 0.95 0.475 Church, 1 Story ‐‐ ‐‐ 6 Yes No 2.9 0.10
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone Yes No No
Above
Moderate
8611‐023‐034
Medium Density
Residential Med 15 0.33 0.165 Church, 1 Story ‐‐ ‐‐ 2 Yes No 1.0 0.05
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone Yes No No
Above
Moderate
8612‐020‐192
Low Density
Residential Low 8 0.29 0.145 Church, 1 Story ‐‐ ‐‐ 1 Yes No 4.0 0.40
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone No No No
Above
Moderate
8614‐016‐049
Commercial Mixed
Use CSA 27 2.3 1.15 Church, 1 Story ‐‐ ‐‐ 26 Yes No 0.6 0.03
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone
Low ILR No No No Very Low
8614‐015‐028
Commercial Mixed
Use CSA 27 2.09 1.045 Church, 1 Story ‐‐ ‐‐ 24 Yes No 4.8 0.06
Large
underutilized
parking lot
Structure
over 30
years old No No No Very Low
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Located in
residential
zone
Developer
interest
8611‐028‐025
Residential Mixed
Use CSG 27 0.14 0.07 Church, 1 Story ‐‐ ‐‐ 2 Yes No 0.4 0.35
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone
Low ILR Yes No No Very Low
8624‐002‐042
Moderate Density
Residential RMO 27 1.77 0.885 Church, 1 Story
Yes
Owner A
21
Yes No 10.4 0.14
Large
underutilized
parking lot
Structure
over 30
years old
Located in
residential
zone
Developer
interest
Yes No No Very Low
8624‐002‐043
Moderate Density
Residential RMO 27 0.09 0.045 Church, 1 Story Owner A Yes No 0.2 0.90 No No No Very Low
*Note: The number of potential dwelling units has been reduced to 84 percent of maximum allowable units to reflect a conservative estimate and accounts for only 50% of a site’s parking area consistent with State law.
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Table H‐B.8: Underutilized Sites to Accommodate Lower Income Housing
APN: 8612‐001‐067
Notes: Low FAR/Large surface parking lot, Near new MFRs, Structure over 30 years old, Low
ILR, Small‐scale, marginal uses, Property located in specific plan area
APN: 8612‐003‐046
Notes: Double capacity, Structure over 30 years old, Near MFRs, Low ILR, Property
located in specific plan area
APN: 8608‐021‐004 to 006
Notes: Double capacity, Structure over 30 years old, Near MFRs, Property
located within specific plan area, Property located within ½ mile of light rail
station
APN:
8616‐005‐035; 8616‐005‐034; 8612‐001‐053; 8612‐001‐910; 8612‐001‐100; 8612‐001‐059;
8612‐001‐911; 8612‐001‐918; 8612‐001‐921; 8612‐001‐917; 8612‐001‐916
APN:
8611‐002‐018; 8611‐002‐013; 8611‐002‐019; 8611‐002‐020; 8611‐002‐040
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Notes: Low FAR/Large surface parking lot, Near MFRs, Structure over 30 years old, Small
scale, marginal uses, Double capacity, Common and government ownership, Low ILR, Vacant
sites, Property located in specific plan area
Notes: Structures over 30 years old, Double capacity, Near MFRs, Low ILR
APN:
8611‐007‐007; 8611‐007‐008; 8611‐007‐036; 8611‐007‐038; 8611‐007‐009; 8611‐007‐010
Notes: Structures over 30 years old, Small scale, marginal uses, Near MFRs, Low FAR/Large
parking lot, Property located in specific plan area
APN:
8611‐005‐013; 8611‐005‐014; 8611‐005‐015
Notes: Structures over 30 years old, Double capacity, Near new MFRs, Property
located within ½ mile of light rail station, Low ILR, Property located within specific
plan area
APN: 8608‐028‐002; 8608‐028‐003; 8608‐028‐004; 8608‐028‐013; 8608‐028‐005;
8608‐028‐006
Notes: Structures over 30 years old, Double capacity, Near MFRs, Property
located within ½ mile of transit, Low ILR, Property located in specific plan area
APN: 8612‐003‐036; 8612‐003‐034; 8612‐003‐035 APN: 8624‐002‐049; 8624‐002‐045
APN: 8608‐029‐001; 8608‐029‐043
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257
Notes: Structure over 30 years old, Low FAR/Large surface parking Lots, Small‐scale,
marginal uses, Low ILR, Property located in specific plan area
Notes: Structures over 30 years old, Low FAR/Large surface parking Lots, Double
Capacity, Property located in specific plan area
Notes: Structures over 30 years old, Low FAR/Large surface parking Lots, Double
Capacity, Property located in specific plan area
Table H‐B.9: Religious Institution Sites
APN: 8616‐007‐046
APN: 8611‐035‐023
APN: 8615‐019‐027
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APN: 8611‐016‐026
APN: 8611‐011‐029
APN: 8611‐023‐034
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APN: 8612‐020‐192
APN: 8614‐016‐049
APN: 8614‐015‐028
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APN: 8624‐002‐042 ; 8624‐002‐043
Note: The areas highlighted in yellow represent 100% of the available parking lot, but our realistic capacity calculations only utilized 50% of the parking lot area.
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City of Azusa HCD Findings/Edits Summary – October 2022
1
HCD Questions/Comments from
May 20, 2022 Letter
Response
A. Housing Needs, Resources, and Constraints
1. Affirmatively further[ing] fair housing (AFFH)
Patterns and Trends: The revised element includes
information on racial composition and trends over
time, a discussion of redlining, racial or ethnically
concentrated areas of poverty (R/ECAPs) or racially
concentrated areas of affluence (RCAAs),
substandard housing, and location of persons at
risk of displacement throughout the City. However,
the analysis should address patterns at the local
and regional levels and trends in patterns over
time. The element must further analyze the various
socio-economic characteristics, such as analyzing
the patterns and trends of race and ethnicity in
comparison to the region or neighboring cities. The
element provided a discussion on dissimilarity
indices between ethnic groups; however, it must
also provide this discussion for the City. For
Income, the element also identifies that 15 percent
of residents live in poverty (p. 112); however, the
element should analyze this pattern over time and
describe the specific median household income
and trends for Black and Asian residents in the City.
For disabilities, the element states that 8.4 percent
of residents live with disabilities (p. 111); however,
the element must analyze this and identify
patterns and trends over time.
Significant additional information is added to the Housing Element Constraints Chapter to describe patterns and trends over
time and at the local/regional levels, as described for each topic below (race, income, and disabilities).
The following analysis has been added regarding race (p. 109-111), with new revisions underlined in green:
Figure H-4.2 shows the distribution of non-white residents in Azusa based on 2018 block group data from HUD’s AFFH Data Viewer. The
majority of the city is comprised of block groups where 91 percent or more of the population is non-white. Areas in northern Azusa have
61 to 80 percent non-white residents. There is one block group in the far northeast area of the city with a lower proportion (38 percent) of
non-white residents. This block group contains the Azusa Pacific University and the Citrus Community College and is likely reflecting the
demographics of the student population enrolled in these schools. Azusa differs slightly when compared to other foothill communities,
such as Sierra Madre, Pasadena, and Glendora where the foothill areas have proportions of non-white residents at 40 percent or less. In
terms of the broader Los Angeles County region, areas with a large proportion of tracts with a predominant Hispanic majority include
central, east, and southeast Los Angeles County, the east San Fernando Valley, and the east San Gabriel Valley. These areas have
historically been home to a large Hispanic population.
To measure segregation in a given jurisdiction receiving direct federal funding, the US Department of Housing and Urban Development
(HUD) provides racial or ethnic dissimilarity trends. … Dissimilarity index data are only available for the Los Angeles Urban County (as
provided by the AI) and not for the City of Azusa.
…
While there is no dissimilarity index data for Azusa, the discussion above on the distribution of non-white residents and the location of
predominant racial population groups in the City suggest that Azusa as a whole is not as segregated as the County. Regionally, there are
cities with fewer proportions of non-white residents, which are mostly located in western Los Angeles County (Santa Monica, Malibu, and
Beverly Hills). Azusa’s demographic profile is similar to that of El Monte, Baldwin Park, East Los Angeles, and several other cities in
central and Southeast Los Angeles County (Table H-4.18). Following a trend seen throughout Los Angeles County in the last 20 years,
Azusa’s White population experienced a decline (going from 24 percent in 2000 to 19 percent in 2018), while other races/ethnicities
generally increased (the Hispanic population stayed the same at 64 percent, Asian increased from 6 percent to 14 percent, and the Black
population decreased proportionally from 4 to 3 percent).
City of Azusa HCD Findings/Edits Summary – October 2022
2
HCD Questions/Comments from
May 20, 2022 Letter
Response
The following analysis has been added regarding race/income (p. 121), with new revisions underlined in green:
Racially Concentrated Areas of Affluence
Racially or Ethnically Concentrated Areas of Affluence (RCAAs) are generally understood to be neighborhoods in which there are both
high concentrations of non-Hispanic White households and high household income rates. In Azusa, there are no significant
concentrations of White households and high household incomes. There is one Census tract that has a 38 percent non-white population,
which is the lowest proportion of non-white residents in the City. This tract borders and includes an area within the City of Glendora.
However, this tract shows a median income that is less than the median income for the State ($87,100) indicating that no Census tracts in
the City qualify as RCAAs.
The following analysis has been added regarding income (p. 113-114), with new revisions underlined in green:
Black and Asian households both have median incomes that exceed the City median income at $86,369 and $82,946 respectively. This is
City of Azusa HCD Findings/Edits Summary – October 2022
3
HCD Questions/Comments from
May 20, 2022 Letter
Response
also higher than the median income for Black ($45,886) and Asian ($75,326) households in the County. These trends have also stayed
constant over the past two decades; in 2000, non-Hispanic Whites in Azusa had a median income of $42,444, Hispanic households had a
median income of $33,820, Black households had a median income of $38,587, and Asian households had a median income of $50,368.
Black and Asian households have experienced the most growth in median income over the past two decades.
Census data estimates that 15 percent of Azusa residents live in poverty, as defined by federal guidelines. Poverty has decreased since
2000, when it was estimated that 18.8 percent of the population lived in poverty. In Los Angeles County, 16 percent of residents live in
poverty and this has remained relatively constant since 2000 when 17.9 percent of residents lived in poverty.
The following analysis has been added regarding disability (p. 112-113), with new revisions highlighted in green:
Persons with Disabilities
With regards to fair housing, persons with disabilities have special housing needs because of the lack of ADA-accessible and affordable
housing, and the potential for higher health costs associated with their disability. In addition, many may be on fixed incomes which
further limits their housing options.
According to the 2014-2018 American Community Survey, 8.4 percent of the population in Azusa had a disability and this rate has
decreased significantly over the past two decades (Table H-4.19). The majority of residents with a disability are 75 years or older (58
percent), followed by those 65 to 74 years (20 percent). The most commonly occurring disability amongst seniors 65 and older is an
ambulatory disability, experienced by 21 percent of Azusa’s seniors. In Azusa, the proportion of the population with a disability living in
poverty (17.7 percent) is higher than those without a disability (14.8 percent).
Figure H-4.3 shows the population of persons with a disability by Census tract in the city using American Community Survey data from
2015-2019. There is one Census tract with a slightly higher concentration (13.3 percent) of people with a disability, which is located
directly south of Foothill Boulevard between Irwindale Avenue and San Gabriel Avenue. This tract overlaps with high proportions of
residents living in poverty, renter-occupied housing units, and overcrowded households. These patterns are reflective of socioeconomic
characteristics typically experienced by people with disabilities. This tract is located near Downtown and as such has good access to
transit and services. At a regional level, Azusa is similar to the rest of the county in that almost all of the census tracts have less than 10
percent of their population living with a disability.
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Additional information is also added on unemployment by race/ethnicity (p.128):
According to the American Community Survey, in 2019 Hispanic and White residents had the highest unemployment rate at 6.1 percent,
followed by Asian (5.6 percent), Black (5.5 percent), and Native American (4.5 percent). Additionally, those with a disability had an
unemployment rate of 14.9 percent.
Additional information is also added on housing problems by race/ethnicity; see green highlighted sections on p. 129 through
p. 131
While the AI does not provide an analysis at smaller geographies, HUD data, known as the Comprehensive Housing Affordability
Strategy, or CHAS, for 2013-2017 shows that renter households experience housing problems at a greater proportion than owner
households (Table H-4.21). Lower-income households also experience significantly higher proportion of housing problems compared
with their high-income counterparts. Disparities exist amongst different racial and ethnic groups, where Black and Hispanic households
have the highest levels of disproportionate housing needs.
In addition to the analysis presented in the AI, the disproportionate housing need analysis prepared for this housing element uses the
AFFH Data Viewer to visualize areas in Azusa experiencing cost burden, overcrowding, and environmental justice.
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Cost Burden
State and federal standards specify that households spending more than 30 percent of gross annual income on housing experience a
housing cost burden. When a household spends more than 30 percent of its income on housing costs, it has less disposable income for
other necessities such as health care In Azusa, 44 percent of households are overpaying for housing. Thirty-two percent of owner-
occupied households are cost burdened, versus 55 percent of renter-occupied households. Lower income households have a higher rate
of overpayment (68 percent of lower income households are overpaying), especially lower income renter households, of which 76
percent are experiencing a housing cost burden. Table H-4.22 provides a further breakdown of cost-burdened households by race. The
greatest proportion of households spending more than 30 percent of their income on housing are Black homeowners and renters.
However, Black homeowners experience the least severe cost burden. Generally, all racial/ethnic experience around the same level of
cost burden.
In addition, more information on race/ethnicity of homeless persons was added on p. 132 (see green highlights).
The 2019 Greater Los Angeles Homeless Count Report does not have demographic data at the city level, but it does provide this for the
County Continuum of Care which is an intregrated system of care that guides and tracks homeless individuals. In the County, 36.5
percent of homeless individuals were Hispanic, followed by 33.3 percent Black, 24.7 percent White, 1.7 percent Native American, and 1.4
percent Asian or Pacific Islander. Despite making up only 8.3 percent of the total County population, Black people are 4 times more
likely to experience homelessness. In terms of disability, 29 percent of people experiencing homelessness report a serious mental illness
and/or substance disorder.
In Azusa, homeless persons are often located in Downtown near transit or in the riverbed and canyons. The City of Azusa continues to
work with regional partners, including local nonprofits and surrounding jurisdictions, to address homelessness. The City also works with
Los Angeles County Sheriff’s Homeless Outreach Services Team to provide information on services and housing to homeless residents.
Disparities in Access to Opportunity: The revised
element includes information on neighborhood
access to resources, disparities in access to
education, disparities in access to the environment,
and employment. However, the element must
The following analysis is added to the Housing Element to identify transportation options available to seniors, persons with
disabilities, and low-income residents, as well as to analyze disparities in access to opportunity for transportation and job
proximity (p.127-128):
Transportation
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identify transportation options available to seniors,
persons with disabilities, and low-income residents
in the City and analyze the disparities in access to
opportunity for transportation. The element should
also address the housing and community needs of
persons with disabilities. The element could also
include any local knowledge and background
information on school rankings by evaluating the
presence or lack of policies, practices, and
investment that contribute to low-ranking schools.
Los Angeles County residents in urban and suburban areas generally enjoy superior access to transportation infrastructure. The County is
also traversed by numerous major freeways within its boundaries (including Interstates 5, 10, 210, 605; all of which are either in close
proximity or intersect with Azusa). Proximity to these highways allows access to employment and other activity centers in Downtown Los
Angeles, San Gabriel Valley, West Los Angeles, and Orange County. Azusa has access to five major bus routes provided by Foothill
Transit and one light rail line provided by LA Metro. Two light rail stations are located in the city, one in Downtown and the other at
Azusa Pacific University/Citrus College.
The Santa Fe railroad corridor played a key historic role in the development of Azusa’s downtown and industry, and served Azusa at the
Downtown Train Station until 1994, when the Northridge Earthquake damaged the rail line and caused its closure. In 2016, the station
reopened as an extension of the Metro Gold Line (now renamed the L Line), a 31-mile light rail line running from Azusa to East Los
Angeles via Downtown Los Angeles. Azusa is home to two L Line Stations, the one in Downtown, and one near Azusa Pacific University
(APU). The next phase of the Gold Line Foothill Extension will connect the APU/Citrus College station in Azusa (currently the terminus of
the line) and the Pomona–North Metrolink station in Pomona. This phase is under construction as of 2022, with a current estimated
completion date of 2026.
Azusa provides Dial-A-Ride services to residents aged 55 or older. Any person with a permanent disability under the age of 55 can also
use the service. Service is available between 5:00AM – 6:00PM Monday through Friday. Prospective riders can register for the service by
mailing or emailing an eligibility application to Azusa’s Transportation Division. Access Services also offers paratransit service, which
provides curb-to-curb shared-ride service within ¾ mile of fixed-route bus and rail lines throughout Los Angeles County. Regular service
is offered from 4:00AM to 12:00AM, 7 days a week. Access supplements any gaps in service not provided by Dial-A-Ride. Low-income
transit riders can participate in the Low-Income Fare is Easy (LIFE) Program, which provides transportation assistance to low-income
individuals in Los Angeles County. LIFE offers fare subsidies that may be applied toward to the fare purchase of Metro, Foothill Transit,
or any LIFE-participating transit agencies.
According to AllTransit, an online source of transit connectivity, access, and frequency data, the City scored 7.3 for its overall transit
performance, indicating that the City has a very good combination of trips per week and number of jobs accessible enabling many
people to take transit to work.1 The City’s score was higher than the County score of 6.8. AllTransit data also shows that in Azusa, 87.4
percent of workers live within ½ mile of transit compared with 90.1 percent for the County. In terms of transit access by race/ethnicity,
Hispanic residents have the greatest access to transit in Azusa, where almost 70 percent of all Hispanic residents live within ½ mile of
transit. This is followed by 16.7 percent of White residents, 9.5 percent Asian residents, 2.1 percent Black residents, and less than one
1 Center for Neighborhood Technology 2019, AllTransit, alltransit.cnt.org
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percent for Native Americans.
The HCD AFFH Data viewer provides information on job proximity, creating an index by Census Block Group indicting areas that are
most proximate to jobs. The higher the index value, the better the access to employment opportunities for residents in a neighborhood
(out of 100). Despite existing transit (bus and rail) available in the area, the southeastern portions of Azusa rank in the lowest category (20
and below), with Downtown and areas near APU ranked 20-40 (see Figure H-4.15). The City’s focus on creating new opportunities for
jobs and housing near transit within the Downtown and along major corridors is continuing to support a high-quality living and working
environment for Azusa residents.
The following analysis is currently in the Needs Assessment regarding the housing and community needs of persons with
disabilities (p. 52-53):
Many factors limit the supply of housing available to households of persons with disabilities. In addition to the need for housing that is
accessible or ADA-compliant, housing affordability is a key limitation as many persons with disabilities live on disability incomes or fixed
income. Location of housing is also an important factor for many persons with disabilities, as they often rely upon public transportation
to travel to necessary services and shops. Many developmentally disabled persons can live and work independently within a
conventional housing environment but may require a group living environment. 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 adult.
The State 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. The San Gabriel/Pomona Regional Center serves
residents in Azusa. The center is a private, non-profit community agency that contracts with local service providers to offer a wide range
of services to individuals with developmental disabilities and their families. In Azusa, 754 persons are reported as consumers of the
services provided at the local Regional Center. This includes 333 residents that are 18 years and younger and 421 residents over 18 years
old receiving services from DDS. The majority of individuals live in home settings, often with a parent or family guardian.
For those living in single-family homes, residents can benefit from accessibility improvements such as wider doorways and hallways,
access ramps and railings, larger bathrooms with grab bars, lowered countertops, and other features common to “barrier free” housing.
According to the State Department of Social Services, seven small residential care facilities with capacity to support 33 residents are
located in Azusa. In addition, four large residential care facilities for the elderly accommodate 114 Azusa disabled seniors.
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Accommodating a sufficient quantity and quality of housing for people with disabilities of any kind is a significant challenge in these
times due to the lack of funding and complexity of housing and service needs involved. Azusa supports the provision of housing for
persons with disabilities and has provisions in the Development Code to enable group housing through the residential care facility
process. The City has in place a reasonable accommodation procedure and, as of 2021, was revisiting the procedure to ensure clarity
and a streamlined application, review, and approval process for housing for persons with disabilities.
In addition, the following information is added regarding the housing and community needs of persons with disabilities (p.
112), with new revisions underlined in green:
With regards to fair housing, persons with disabilities have special housing needs because of the lack of ADA-accessible and affordable
housing, the potential for higher health costs associated with their disability, and the potential need for access to transit. In addition,
many may be on fixed incomes which further limits their housing options.
The following analysis has been added regarding school performance and education (p. 123-125), with new revisions
underlined in green:
Despite low-performance scores, Azusa Unified has a high school graduation rate at 91 percent, which is higher than the California
average rate of 84 percent.
School performance is impacted by a myriad of factors, but one often cited reason is lack of sufficient funding. California went from
having some of the highest per-student funding of schools to one of the lowest, due to the decline in tax revenue caused by the passage
of Proposition 13 in 1978. Inadequate school funding has also created inequalities amongst school districts, where wealthier
neighborhoods have better access to educational resources and higher-performing schools, than poorer neighborhoods. More affluent
school districts tend to have attributes that support better student performance, such as smaller classroom sizes, a more experienced
and credentialed teacher force, and more advanced placement courses. Many education reforms have been adopted by the State in
recent years to increase school investment, particularly in disadvantaged neighborhoods. However, even with more investment pouring
into education, performance still lags across many schools pointing to a much more complex set of factors. This conundrum is reflected
in the Azusa Unified School District, where the District has higher revenue per student and spending per student than the State median.
The District also fairs better than the State on several metrics relating to school environment, such as small class sizes and a large
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proportion of certified and experienced teachers (Table H-4.20).
Based on these metrics, Azusa Unified’s low performance could be related to factors external to the education system. Research has
shown that parents with higher educational attainment correlates with their children having better educational outcomes. Parents with
higher education are likely to expose and have access to educational opportunities outside of school, such as science camps, music
school, etc. They are also likely to have higher incomes, which allows them to provide for extracurricular activities and to have more time
and stability to assist their children in their schoolwork. Low-income parents with lower educational attainment may have more stressful
jobs that can undermine their health and ability to access cognitively stimulating opportunities for their children.2 In Azusa, 71.9 percent
of Hispanic residents have a high school degree and only 11.3 percent have a bachelor’s degree. This is in comparison to 36.3 percent of
White residents, 42 percent of Black residents, and 55 percent of Asian residents with a bachelor’s degree. These percentages also
correlate with median income, where Hispanic residents have the lowest household income amongst all racial/ethnic groups in the City.
Overall, it appears that the District’s low-performance is possibly correlated with the educational attainment of parents and there are
significant disparities amongst Hispanic residents. These disparities could be attributed to language barriers, immigrant status, and
other factors unique to Hispanic households.
Additionally, the demographics of the District show a large population of Hispanic students, many of which are English learners. In the
2020/21 school year, 75 percent of students qualified for free/reduced-price meals due to household income, were English learners, or
were foster youth within the Azusa Unified School District. English learners are predominately Spanish speaking. The Education Data
Partnership reports an ethnic diversity score of 8. The Ethnic Diversity Index reflects how evenly distributed these students are among
the race/ethnicity categories. The more evenly distributed the student body, the higher the number. A school where all of the students
are the same ethnicity would have an index of 0. The index is out of 100; the highest score any school currently receives in the country is
76. Azusa Unified School District’s score reflects a largely homogenous student body, with approximately 92 percent Hispanic or Latino
students; this score has remained relatively steady in recent years, dropping from nine in 2016/17. Between 2016/17 and 2020/21,
enrollment has dropped in Azusa Unified by 16.5 percent. This trend is reflected nationally, reflecting reduced birth rates.
In sum, improving school performance requires a multi-pronged approach that continues to advocate more school funding, pathways to
higher education for students, and support for students’ access to educational experiences and well-being outside of the classroom.
2 Eccles, J.S. (November, 2005). Influence of parents’ education on their children’s educational attainments: the role of parent and child perceptions. London Review of Education.
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The following analysis has been added regarding disparities in educational achievement (p. 147), with new revisions
underlined in green:
3. Disparities in educational achievement throughout the City.
Low performing schools are located throughout the city, despite the Azusa Unified School District exhibiting school environment metrics
that support academic achievement such as high student spending and small class sizes. One potential reason for this, is that a majority
of the adult population do not have a bachelor’s degree or high and is significantly low amongst the Hispanic population, which research
has shown parent’s educational attainment affects children educational outcomes. Additionally, over 75 percent of low-income students
in District were English learners pointing to possible language and cultural barriers.
Contributing factors:
• Potential lack of culturally relevant educational opportunities outside of the school environment
• Potential lack of culturally relevant parent/student support
Disproportionate Housing Needs, Including The following analysis has been added regarding substandard housing locations (p. 131-132), with new revisions underlined
in green:
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Displacement Risk: The element should evaluate
the location of substandard housing throughout
the City.
The City performs annual inspections of rental properties to ensure proper maintenance and upkeep, as well as presale inspections of all
homes that are sold. These efforts have allowed Code Enforcement staff to have a deep understanding of existing needs in the
community, and to continue to work with property owners of apartment buildings that are in particular need of rehabilitation,
maintenance, and repair. The City maintains a list of 743 rental units (in 66 buildings) that require additional oversight to ensure buildings
and properties are maintained and comply with codes. The City’s Code Enforcement staff has confirmed that these buildings are not
concentrated in one area of the city. These units are scattered throughout the city, including the southern portion of the city, in lower
density neighborhoods, and along major corridors. Properties range from small-scale make-shift structures, to small apartments, to large
apartment complexes.
Goals and Actions: The revised element includes
discrete timelines for some programs. However,
programs containing language such as “Continue”
or “Ongoing” should be amended to include
specific milestones and measurable actions, even if
the action is considered “Ongoing”. Goals and
actions must significantly seek to overcome
contributing factors to fair housing issues and must
include metrics and milestones to target
meaningful fair housing outcomes. The element
must revise programs based on a complete analysis
and connect to prioritized contributing factors to
fair housing issues.
The following programs are modified with additional specificity to target meaningful outcomes, with new revisions underlined
in green:
Program H1-1: Timeframe/Objective: Annually identify and implement projects to receive CDBG funding through the Annual Action
Plan process
Program H1-2: Timeframe/Objective: Ongoing; annually monitor the 743 rental units that require regular oversight; coordinate with
property owners as rehabilitation needs are identified.
Program H1-3: Timeframe/Objective: Annually, install approximately 15-20 Americans with Disabilities Act-compliant curb ramps with
truncated domes and replace damaged sidewalks to provide accessible, unobstructed path of travel for severely disabled adults and
elderly persons; identify and apply for additional funding for target neighborhoods in 2025.
Program H1-4: Timeframe/Objective: Contact owners with expiring covenants two years in advance of the expiring covenant; annually
report as part of the Annual Progress Report process; implement preservation measures as needed to preserve 178 units of affordable
housing units through the planning period.
Program H1-5: Timeframe/Objective: Ongoing; inspect 200-300 reports of code enforcement violations annually; refer eligible cases
to the Housing Rehabilitation Program; annually report progress through the Comprehensive Annual Performance Evaluation Report
(CAPER) process.
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Program H2-1: Timeframe/Objective: Ongoing to increase access to information about available resources for all community
members; update the City’s website and begin advertising homeownership housing assistance programs within one year of Housing
Element adoption
Program H2-3:
• Promote housing mobility by affirmatively marketing and promoting the use of Housing Choice Vouchers in high opportunity
areas.
• Advertise and encourage landlords in Azusa to participate in the Homeless Incentive Program run by LACDA, which provides
financial support for property owners who rent to homeless Section 8 voucher holders. Send an annual notice to all multifamily
property owners in Azusa about participation in the HCV program including available incentives from the LACDC.
• Direct interested residents to the LACDA website and continue to provide information on the Housing Choice Voucher
program, including new legal requirements pursuant to SB 329, which prohibits housing discrimination on the basis of source of
income (including Housing Choice Vouchers).
Timeframe/Objective: Ongoing; annually review Housing Choice Voucher participation and adjust information dissemination efforts as
appropriate to preserve 242 Housing Choice Vouchers currently in use in Azusa; increase the number of units available to HCV holders
by at least 5.
Program H3-1: Timeframe/Objective: Ongoing; annually review progress as part of the Annual Progress Report process (see
also Program H5-7).
Program H3-5: Timeframe/Objective: Review and modify Building Code within two years of Housing Element adoption; on an
ongoing basis discuss alternative options for housing with developers and project applicants
Program H3-6: Timeframe/Objective: Ongoing; assess success of efforts to address homelessness in 2025 and revise strategies as
needed; see also Program H4-2.
Program H3-7: Timeframe/Objective: Ongoing; when necessary, identify and make available additional adequate sites to
accommodate the RHNA by income level within 180 days of approving a reduced density project
Program H3-8: Timeframe/Objective: Routinely as part of the housing development approval process, require replacement of any of
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units if (a) they are planned to be demolished for purposes of building new housing, and (b) they are determined to be occupied by low-
income households, require the provision of assistance to prevent displacement of lower-income households due to loss of affordable
units.
Program H4-1: Timeframe/Objective: Adopt a density bonus ordinance within one year of Housing Element adoption; monitor State
legislation on an ongoing basis and update within one year of applicable revisions to state law; develop an informational brochure in
2024 and on an ongoing basis advise developers of density bonus provisions
Program H4-2: Timeframe/Objective: Adopt Development Code amendments within one year of Housing Element adoption;
implement the Development Code on an ongoing basis; Contact/discuss development options with affordable housing developers
within two years of Housing Element adoption; develop a priority staff-level planning entitlement process to streamline and expedite
housing for extremely low-income households within two years of Housing Element adoption (in conjunction with Program H4-8).
Program H4-3:
• Streamline the development review process for affordable housing. Allow projects that include at least 20% affordable
housing that complies with objective standards to be reviewed ministerially.
Timeframe/Objective: Ongoing; create SB 35 informational packet within one year of Housing Element adoption; revise process to
streamline affordable housing development in conjunction with Program H4-8 (Objective Design Standards) within two years of Housing
Element adoption
Program H4-4: Timeframe/Objective: Adopt Development Code amendments within three years of Housing Element adoption;
promote development types and incentives such as density bonuses on an ongoing basis with information at public counters and on the
City’s website -- create materials within one year of Development Code amendments
Program H4-7:
• Review the existing Form-Based Code and draft revisions to support objective design standards. Adopt objective design
standards to ensure that the City can provide local guidance on design and standards for by-right projects as allowed by
State law. Adoption of objective design standards will facilitate high-quality residential development and compliance with
State objectives. The objective design standards will ensure provision of adequate private open space, parking, and related
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features, as well as architectural design.
• Allow multi-family residential development that conforms with objective design and development standards as an allowed
use without a public hearing.
Timeframe/Objective: Adopt Objective Design Standards and Housing Accountability Act language within two years of Housing
Element adoption
Program H4-8: Timeframe/Objective: As needed as constraints are identified. See also Program H5-7.
Program H4-9: Timeframe/Objective: Deliver the Housing Element to all sewer and water providers within one month of adoption of
the Housing Element
Program H4-10: Timeframe/Objective: Undertake comprehensive Master Planning efforts within three years of adoption of the Housing
Element in conjunction with Program H5-5.
Program H5-2: Timeframe/Objective: Develop priority streamlining process in 2024; update Development Code within one year of
Housing Element adoption; develop materials to encourage universal design and visitability and provide at public counters; pursue pre-
approved stock plans for ADUs that include an ADA-accessible option.
Program H5-4: Timeframe/Objective: Implement outreach plan within one year of Housing Element adoption; implement on an
ongoing basis and in conjunction with Program H5-5.
Program H5-6: Timeframe/Objective: Identify and, as needed, adopt revisions to reasonable accommodation procedures within one
year of Housing Element adoption
Program H5-7: Annual Review, Monitoring, and Mid-Cycle Report
The Planning Commission will hold an annual public hearing each spring to evaluate progress toward meeting housing goals and
regional housing needs obligations. The review will examine annual quantitative housing production goals and monitor vacant and non-
vacant sites in the sites inventory, and if the City is not meeting those quantitative goals, City staff will make recommendations to the
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Planning Commission on adjustments to processes or requirements to improve performance. At the public hearing, the Planning
Commission will make recommendations for City Council consideration and action.
The annual review will include a review of the Annual Progress Report on Housing Element implementation in the format required by
HCD as defined by Government Code Section 65400(a)(2)(B). In addition, the City will conduct a mid-term evaluation at year 4 of the 8-
year cycle. The mid-term evaluation shall document progress made towards affirmatively furthering fair housing and progress made on
non-vacant sites to achieve the regional housing need. If the evaluation finds that existing Housing Element programs are not achieving
the objectives and targets, the Planning Commission and City Council will hold public hearings to consider and take action on any
additional programs or zoning amendments necessary to acheive the Housing Element objectives within one year.
Timeframe/Objective: Provide annual reviews and a mid-term evaluation at year 4 of the 8-year cycle
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
See also Program H5-3 revisions pertaining to affirmative fair housing, discussed later in this matrix.
2. An inventory of land suitable and available for residential development
Suitability of Nonvacant Sites: The revised element
includes additional information on the suitability of
nonvacant sites and Program H3-10 (p. 27) to
support redevelopment of existing nonresidential
uses. However, the element must demonstrate
how factors and trends used to identify sites relate
to the sites selected in the inventory and how
those factors support the potential for
redevelopment within the planning period. The
analysis should also describe any existing leases or
other contracts that would perpetuate the existing
use or prevent redevelopment of the site for
additional residential development, development
The following analysis has been added regarding suitability of nonvacant sites (p. 168-173), with new revisions underlined in
green:
Table H-5.12 summarizes recent (since 2017) redevelopment of sites with existing residential uses to include additional housing units.
Since 2017, 13 sites each containing one residential unit have redeveloped or are under preliminary review for higher intensity housing.
Sites smaller than a a half-acre have all added an additional unit, doubling the existing capacity, while larger sites have increased
capacity by 6 to 21 times. This summary does not include ADU development and indicates that development trends in Azusa are
favorable to convert lower-density residential uses into higher density residential uses.
The extremely limited supply of vacant land in Azusa and across the Los Angeles County region indicate market conditions for more
intensive, compact, and infill development or redevelopment. Many cities across the County have recent redevelopment occurring on
sites that held a previous residential or nonresidential use. Sites with existing residential uses that were chosen to be included in this
inventory all have the ability to at least double the existing capacity, contain older structures, and have low improvement to land ratios.
For the sites located in the TOD Specific Plan, the most compatible use that enables higher transit ridership is multi-family housing,
making high intensity housing the highest and best use in these areas. The redevelopment of residential uses near new transit lines has
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trends, market conditions, and regulatory or other
incentives or standards to encourage additional
residential development on these sites. In addition,
Table H-B.5: Azusa TOD Specific Plan Small Parcel
Sites (Less than 0.5 acres) (p. 247), identifies sites
that are on Historic US Route 66. The analysis must
further analyze the suitability of nonvacant sites in
historically designated areas and should consider
factors including if any of the existing uses on sites
identified are on local, state, or federal historic
registers and the extent to which existing uses may
constitute an impediment to additional residential
development. Depending on the results of this
analysis, program actions may need to be added or
modified as appropriate.
also been occurring in many cities across Los Angeles County.
Property owners of sites identified to meet the RHNA were contacted as part of the Housing Element update. While responses were
limited, all who responded indicated that they were “very interested” in redevelopment with higher density residential uses, including
property owners with a single residential unit as the existing use.
Based on the above and development history presented in Table H-5.12, there is a clear demonstration that:
• The City has experienced the conversion of a single residential unit to higher density residential development
• Existing uses do not pose an impediment to additional residential development
• Market demand exists for higher density residential development on underutilized sites
Redevelopment of Existing Nonresidential Uses (Mixed-Use Zones and TOD Specific Plan)
Where existing uses are nonresidential, the City has also seen significant redevelopment interest in recent years, which is anticipated to
continue to grow as market trends support additional housing development. Nearly all redevelopment occurs on sites that at some point
held a previous use, either recently or a more distant past with a building that had been demolished after it fell into disrepair. Details
about the types of uses that typically redevelop in Azusa are useful to understand redevelopment trends specific to Azusa and support
the likelihood of redevelopment of sites identified in the inventory. Table H-5.13 summarizes the previous use located on parcels where
approved and proposed projects are currently located as summarized in Table H-5.2.
While certain sites included in the inventory are located on Historic US Route 66, this designation does not institute any additional
constraints to development along the Route. No sites include buildings that are listed on any local, state, or federal historic registers.
The summary of previous uses on parcels where residential development is currently occurring shows that there are a large variety of
existing uses that are being recycled and replaced with housing, ranging from small-scale commercial, offices, auto-repair, and housing.
Many of these sites also had large parking lots, low land to value ratios, and aging buildings. These trends were used to identify the sites
in the sites inventory. Sites were chosen based on similar characteristics such as: similar existing uses, structures 30 years or older, and
improvement values less than 1.0. Most identified nonvacant sites have improvement to land value ratios below 0.75, with those above
having generally older buildings and underutilized land, specifically surface parking, which is a common trend identified in
redevelopment of nonvacant sites throughout the region. An additional factor related to trends is the potential capacity increase
available to property owners. On the sites chosen for the inventory, the residential capacity is two to 14 times the existing development.
A majority of sites are larger sites (i.e., one acre or larger), which have more potential to significantly increase residential capacity.
Existing uses on the sites are older or show signs of disinvestment or deferred maintenance, indicating a “ripeness” for redevelopment.
To ensure that appropriate sites have been chosen, properties that show recent investments or updates or that contain uses of local
importance are not included.
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
In general, the market in Azusa and the San Gabriel Valley supports housing as the highest and best use of property, yielding highest
returns for property owners, especially in existing neighborhoods, along corridors, and in Downtowns such as Azusa’s, with access to
goods, services, and high-quality transit. This new development is most often occurring on properties without recent investments, with
aging structures, and large parking lots due to the lack of available vacant land throughout the region. A key incentive to support this
redevelopment is increased density, such as the flexible density allowances in the TOD Specific Plan, which does not cap density on an
individual parcel basis. Again, many cities and neighborhoods across Los Angeles County, such as in Chinatown, Duarte, and Monrovia,
have seen the development of high intensity housing near transit stations. Furthermore, changes in consumer preferences and a shift
from traditional brick-and-mortar to e-commerce present opportunities to repurpose existing retail uses for new mixed-use residential
developments. This trend has occurred locally and regionally as evidenced by Azusa’s Citrus Junction, Alhambra’s Alhambra Place, and
Baldwin Park’s ROEM that serve as successful examples of retail to residential mixed-use conversions. The availability of aging retail
centers create multiple opportunities for redevelopment of existing retail for residential uses in the City. For example, several parcels
located near Citrus Junction contain shopping centers and fast-food restaurants that were originally developed in the late 1980s, are
surrounded by large parking fields, and lack the walkable, place-making attributes of today’s successful retail centers. The existing layout
of these retail uses, which are also close to key activity centers like the Azusa Pacific University and the L (Gold) Line’s APU/Citrus College
Station, mark these properties underdeveloped and match regional trends for redevelopment.
In June 2021, Azusa surveyed property owners included in the sites inventory; three property owners responded. All respondents had
existing uses on their sites and were “very interested” in redevelopment with higher density residential uses. Uses on their properties
included single-family residential, commercial retail/services, and industrial uses. All respondents were currently leasing to one or two
tenants or did not have a current lease with tenants. Lease terms ranged from one year remaining to 5-10 years remaining on the lease.
All respondents had a current lease with tenants, and all respondents expressed they were “very interested” in redeveloping their
property with housing uses. Lease terms ranged from one year to 15 years, indicating that leases have the potential to be re-negotiated.
Existing uses on properties included industrial, commercial, and single-family housing. The City will continue to engage local property
owners to discuss redevelopment opportunities on their properties. Program H3-10 is included in the Housing Plan to establish tools and
actions to support the redevelopment of existing non-residential uses. Based on this analysis and future efforts undertaken through
Program H3-10, the City concludes that existing uses will not impede additional residential development and all sites identified in this
Housing Element are intended to demonstrate adequate sites to accommodate the RHNA.
Based on the above, there is a clear demonstration of:
• Local trends of converting existing uses to higher density residential development
• Existing uses that do not pose an impediment to additional residential development
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
• A declining demand for sprawled-out shopping centers in favor of e-commerce or compact mixed-use development
• Property owner interest in redevelopment and potential for lease renegotiation
In addition, as indicated in Program H4-7, the City will streamline housing approvals and allow multi-family residential development that
conforms with objective design and development standards by-right, without a public hearing, further reducing barriers and supporting
the potential for redevelopment within the planning period.
Additionally, the element states (p. 163) a local
church site was identified by local developers for
potential redevelopment; however, no further
description was provided. The element states that
housing is allowed on all church sites as these sites
are in residential zoned areas and the underlying
zoning is compatible with residential use. Further
support and analysis are needed to demonstrate
the feasibility of these sites. For example, the
element could also analyze how church sites were
selected, outreach conducted, further describe
expressed interests of landowners of religious
institutions, and further analyze the compatibility
of these sites with residential use or the underlying
zoning. In addition, the element should also
analyze the feasibility of developing one unit on
religious institutional sites. The analysis should
further examine the sites in question for their
development capacity, and profile actions the City
is taking to make such development feasible.
The following analysis has been added regarding religious institution sites (p. 173-176), with new revisions underlined in
green:
Land Owned by Religious Institutions
Properties owned by faith-based organizations often have large, underutilized parking facilities. Recent State legislation has made it
easier for religious institutions to build housing on these sites. AB 1851, approved in September 2020, eases parking requirements for a
religious institution (or through partnership with a nonprofit developer) that seeks to build affordable housing on land they own or lease.
The law allows religious institutions to build housing on underutilized parking lot areas and prohibits cities from requiring replacement of
those parking spaces. However, no more than half of the available on-site parking spaces can be requested to be eliminated. In Azusa,
the City has been approached by local developers regarding development of housing at one local church site. This site, located on
Azusa Avenue south of West Paramount Street, has been identified by local developers for its potential redevelopment with housing
uses and is included in the sites inventory as an opportunity site to meet the RHNA (APN 8614-015-028). Other cities in the San Gabriel
Valley have also seen increasing interest from developers for redeveloping housing on religious institution sites. West Covina approved a
19-unit gated housing project on a church site in 2013 in residentially zoned land. The church sold off a portion of its 5.1-acre land that
included a vacant elementary school to the developer Brandywine Homes. Baldwin Park has a preliminary application to construct
townhomes on the site of a former church, which is also located in a residential zone. In South LA, developer RMG Housing has several
affordable housing projects planned or have broken ground in the past year on church land, such as the Heavenly Vision Church,
Southside Bethel Baptist Church, and Pueblo del Rio. In Orange County, developer National Core has created partnerships with five
churches in cities across Southern California to building affordable housing on underutilized church land, which include Placentia, Santa
Ana, and Buena Park. As AB 1851 incentives become more broadly known, it is anticipated that interest will continue to rise. In addition,
in 2022, AB 2255 was passed (effective January 1, 2023) to further encourage housing development associated with religious uses--AB
2244 expands the definition of “religious-use parking spaces” to include both existing and new places of worship.
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
The site inventory identifies several sites owned and operated by religious institutions located in residential and mixed-use zones. The
sites identified as suitable for infill housing accounts for a total of 10.58 acres with a realistic capacity of 90 units (Table H-5.14). The City
of Azusa has many local religious institutions located on large lots. A total of 11 church sites were identified in Azusa that presented
potential for housing capacity. These were selected because they are located in zones that already allow residential uses and have large
underutilized parking lots or other excess area. Seven of these are located in lower density residential areas; as such they are included in
the above moderate-income category, even though affordable housing is likely to occur in conjunction with the religious institutions’
missions. The remaining four sites are anticipated to accommodate very low-income housing, given their zoning that allows high
densities and the mission driven nature of religious institutions. Currently, housing would be allowed on all church sites identified in the
sites inventory based on the density allowed in that particular zone. Program H3-9 is included in the Housing Plan to articulate a zoning
process to encourage housing on religious institution sites, develop an ordinance to offer more development incentives, and proactively
outreach to property owners to support development efforts.
Land Owned by Places of Worship - Density and Affordability Assumptions
To calculate the realistic capacity of sites owned and operated by religious institutions, which might support infill development on
underutilized portions and parking lots, this Housing Element assumes that housing could occur on half of existing parking lot areas and
does not assume the acreage of the entire site. As such, these estimates do not represent redevelopment of the sites; rather, the
capacity estimates parallel the allowed housing on half of the parking area allowed by AB1851. Additional capacity, beyond what is
identified in each individual realistic capacity calculation, is available on many sites in open space/lawn areas; these were not included in
calculations of realistic capacity. Realistic capacity assumptions were limited to 50 percent of parking lot area. Since most of the religious
sites are located in residential zones the same assumption of 84 percent of the maximum allowable density has been applied to calculate
the realistic capacity. Appendix B shows aerial views of each religious institution site, highlighting in yellow the entire parking lot area.
Calculations are based on one-half of this highlighted area, using the underlying zoning’s maximum allowable density, with a reduction
to 84 percent of the maximum allowable density. This estimate is conservative, especially on sites where additional capacity is available
in open space areas that is not included in the development calculations. While two sites conservatively estimate one housing unit could
be built, there are examples of development on church sites supporting this possibility. In nearby Pasadena, Knox Presbyterian has one
housing unit on their property. These units support caretaking of church property and the congregation’s mission to provide affordable
housing to those in need. In addition, given recent trends in accessory dwelling unit construction in Azusa, small single unit development
is common and can be supported by a variety of construction models, including manufactured housing.
Program H3-9 is modified (p. 26-27), with new revisions underlined in green:
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
Program H3-9: Development on Religious Institution Sites
SB 899 and AB 1851 (2020 legislative session) allows religious institutions to build 100 percent affordable housing projects on their
properties through a ministerial process and allows for removal of existing parking areas. AB 2244 (2022 legislative session) expands the
law to allow development of housing on both existing and new places of worship. Azusa is home to a multitude of properties owned by
churches, temples, and other religious institutions, with capacity for additional development.
• The City will create standards and a review process for the establishment of affordable housing via a Religious
Institution Housing Ordinance or other zoning approach, including a streamlining of the approval process (allowing
housing with at least 20% of units affordable ministerially).
• The City will proactively reach out to property owners to gauge development interest, provide educational materials
regarding SB 899, AB 1851, and AB 2244.
• The City will proactively reach out to affordable housing developers with experience developing housing on religious
institution sites, including Habitat for Humanity and National Core, to discuss options for development in Azusa, and
connect religious institution leadership with developers.
Timeframe/Objective: Create new standards and a review process within 3 years of the Housing Element planning period; conduct
proactive outreach to property owners and affordable housing developers in 2025.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Absent findings (e.g., adoption resolution) based
on substantial evidence, the existing uses will be
presumed to impede additional residential
development and will not be utilized toward
demonstrating adequate sites to accommodate the
regional housing need allocation (RHNA). Any
future re-adoption of the housing element must
include the appropriate finding as part of the
As indicated above, the existing uses are not presumed to impede additional residential development. The adoption
resolution included findings based on substantial evidence.
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HCD Questions/Comments from
May 20, 2022 Letter
Response
adoption resolution.
B. Housing Programs
1. Identify actions that will be taken to make sites available during the planning period
As noted in Finding A2, the element does not
include a complete site analysis, therefore, the
adequacy of sites and zoning were not established.
Based on the results of a complete sites inventory
and analysis, the City may need to add or revise
programs to address a shortfall of sites or zoning
available to encourage a variety of housing types.
As indicated above, there are adequate sites to meet the RHNA in Azusa.
The revised element includes Program H3-10 (p.
27) to establish tools and actions to support the
redevelopment of existing nonresidential uses.
However, this program should go beyond “Explore”
with specific commitment to milestones and
measurable actions to facilitate significant and
meaningful change (e.g., amend, complete,
establish).
Program H3-10 has been modified as follows (p. 25); see green underlines:
Program H3-10: Development on Nonvacant Sites
Promote residential development on nonvacant sites by:
Targeting nonvacant sites identified in the Housing Element as priorities for fund allocation as funds are available.
Expanding the opportunities for adaptive reuse of nonresidential existing buildings for housing through the expansion of by-
right processes, reduced parking standards, flexible building standards, and increased flexibility on the types of uses (e.g.
live/work) and locations that can be converted to support proposed developments.
Proactively outreaching to property owners with a survey on how the city can support redevelopment efforts.
As part of the City’s comprehensive General Plan update, the City will pursue implementation of a variety of tools to encourage
housing development on nonvacant sites, including marketing housing as an economic development tool and the potential of
implementing Enhanced Infrastructure Financing Districts as a method for funding affordable housing. Newer state legislative
mechanisms (AB 733 and SB 1145) that have materialized in the wake of redevelopment agency dissolution allow agencies to
utilize growth in tax revenue, or tax increment, to finance certain projects, including at least 20% for affordable housing, within
a limited geographic area.
Timeframe/Objective: Ongoing; conduct a study on potential adaptive reuse incentives in 2024 and hold hearings with Planning
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
Commission/City Council regarding adaptive reuse standards in 2025; initiate General Plan update in 2023 and conduct a study on EIFDs
and other housing related economic development tools in 2024; implement recommendations from study in 2025.
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
Accessory Dwelling Units (ADUs): The revised
element (p. 23) included a reduction in
assumptions for ADUs to 29 per year for an
estimated total of 242 units during the planning
period. However, Program H3-4 (Accessory
Dwelling Units (ADUs)) should be revised with
specific commitments to adequately support ADU
assumptions. For example, the program could
identify and retain an ADU specialist to respond to
inquiries and support outreach efforts (within a
year of housing element adoption); provide specific
additional resources, incentives, and strategies,
such as flexible zoning requirements, development
standards, waiving plan check and permit fees for
ADUs, preparing and providing updated ADU
forms, brochures, and pre-approved ADU
construction plans that are customizable at a
minimal cost to the applicant; and prioritize and
streamline ADU review processes for approval. The
Program should also be revised to provide specific
timeframes for implementation of each identified
action early enough in the planning period to
ensure a beneficial impact on housing production.
Program H3-4 has been modified as follows (p. 23-24); see green underlines:
Program H3-4: Accessory Dwelling Units (ADUs)
Review the Development Code to ensure consistency with State law and revise to comply with State law, including flexible
zoning requirements and development standards. In addition, remove regulations pertaining to second units that may conflict
with State law, to provide consistency and clarity in the implementation of accessory dwelling unit standards.
As revisions to State law occur, update the City’s ADU Ordinance to comply.
Create a public outreach program to encourage ADU development, including development of an information packet to market
ADU construction and brouchures to clearly outline the process. Inform ADU applicants of the California Housing Finance
Agency’s (Cal HFA) ADU Grant Program. Cal HFA’s ADU Grant Program provides up to $40,000 to reimburse pre-development
and non-reoccurring closing costs associated with the construction of the ADU. Opportunities could include advertising ADU
development opportunities on the City’s website, through social media, at City Hall, and at City events.
Continue to coordinate with Code Enforcement on cases of unpermitted ADUs and provide information to the
applicant/homeowner to encourage conversion of existing unpermitted ADUs into permitted ADUs without fines/penalties.
Identify and retain an ADU specialist within the Planning Department to respond to inquiries and support outreach efforts.
Prioritize and streamline ADU review processes for approval. Prepare and provide updated ADU application materials and
update the building permit application to request rent information to track affordability.
Coordinate with neighboring jurisdictions and the local council of governments to participate in educational opportunities and
ADU incentives for the Azusa community, such as workshops on ADUs, pre-approved ADU construction stock plans that are
customizable at a minimal cost to the applicant, etc.
Annually monitor ADU permit applications and approvals (including the affordability of constructed ADUs) through the Housing
Element Annual Progress Report process.
Timeframe/Objective: Support the development of 242 accessory dwelling units during the planning period through the following
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
efforts: Review/revise Development Code within one year of Element adoption and submit revised ADU Ordinance to HCD for review;
ongoing ADU development support with outreach materials provided in 2024; identify and retain ADU specialist in 2023; prepare
updated application materials in 2023; participate in the SGVCOG pre-approved ADU plan work effort in 2022/2023 and publish ADU
stock plans on the City’s website in 2023; annually monitor ADU construction and affordability; in 2025, evaluate progress compared to
projections—If targets are not being achieved, implement new strategies in a timely manner (i.e., within approximately six months) to
encourage ADU development to ensure adequate sites are available to address the lower income RHNA or commit to rezoning
additional sites within one year (as necessary) to offset any shortfall. Take additional actions, if necessary, in a timely manner (e.g., within
6 months).
Although Program H3-4 proposes to monitor ADU
permit and approvals, and to implement additional
incentives or other strategies to ensure adequate
sites if ADU production targets are not met at the
midpoint of the planning period, the Program
should commit to annually or bi-annually
monitoring ADU production and affordability. If
ADU production levels fall short, Program H3-4
should commit to ensuring adequate sites are
available to address the lower income RHNA or
commit to rezoning additional sites within one year
(as necessary) to offset any shortfall. Additional
actions, if necessary, should be taken in a timely
manner (e.g., within 6 months).
See revision to Program H3-4 above, which includes the following additional information on timing:
Annually monitor ADU construction and affordability; in 2025, evaluate progress compared to projections—If targets are not being
achieved, implement new strategies in a timely manner (i.e., within approximately six months) to encourage ADU development to ensure
adequate sites are available to address the lower income RHNA or commit to rezoning additional sites within one year (as necessary) to
offset any shortfall. Take additional actions, if necessary, in a timely manner (e.g., within 6 months).
2. Extremely low-, very low-, low-, and moderate-income households programs
Program H3-2 commits to facilitating the
construction of residential units in mixed-use zones
and within the TOD Specific Plan Area, along with
zoning and development standards and incentives
See revision to Program H3-2 (p. 22), which includes the following additional information in green underline:
Program H3-2: Mixed-Use and TOD Sites Lot Consolidation
Continue to facilitate the construction of residences in mixed-use zones and within the TOD Specific Plan area. Continue to provide
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
for the inclusion of units affordable to extremely
low-, very low-, low-, and moderate-income
households. However, the element should identify
the particular incentives that are included in these
areas for the provisions of these units. In
particular, the element should identify if there are
any specific provisions that further facilitate the
construction of housing affordable to extremely
low-income households.
zoning and development standards to facilitate residential and mixed-use development within the TOD Specific Plan Area,
including incentives for the inclusion of units affordable to extremely low-, very low-, low-, and moderate-income households,
such as the State density bonus. The City is also considering a new inclusionary Housing Ordinance (Program H2-4: Inclusionary
Housing Ordinance) and allows SROs (Program H4-2: Housing for Extremely Low-Income Households) to facilitate construction of
housing affordable to extremely low-income households.
Continue to monitor development interest, inquiries and, progress towards mixed-use development. Periodically re-evaluate
approach and progress.
Continue to provide incentives for consolidation of parcels in mixed-use areas, including rounding up when calculating allowable
units. Provide technical assistance with consolidation of parcels. Technical assistance includes land development counseling by
Economic and Community Development staff.
Advertise lot consolidation incentives and potential site opportunities to existing property owners and prospective mixed-use and
affordable housing developers. Advertisement actions may include preparation and distribution of a brochure with information
about program incentives and an invitation to attend a working session to discuss opportunities for lot consolidation and mixed-
use residential development, including affordable housing development.
Timeframe/Objective: Ongoing; engage in advertisement efforts at least once per year; re-evaluate approach and progress towards
mixed-use development in 2025 and update as needed in a timely manner (i.e., within approximately six months)
Responsible Agency: Economic and Community Development Department
Funding Sources: Departmental Budget
3. Promote and affirmatively further fair housing opportunities
As noted in Finding A1, the element does not
contain programs which satisfy the AFFH
requirements for specific and meaningful actions
to overcome fair housing issues. Based on a
complete analysis, the element must add or revise
programs.
See revision to Program H5-3 (p. 35-38), which includes the following additional information in green underline:
Two identified fair housing issues are closely related, as such, the meaningful action items address both issues.
Housing Choice and Affordability:
• Study and, if shown to be appropriate for Azusa, adopt an inclusionary housing ordinance and program to increase the City’s stock of affordable housing
(see Program H2-4: Inclusionary Housing).
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
• Provide opportunities for a variety of housing types in various locations throughout Azusa, including High Opportunity Areas (see Program H3-4: Accessory
Dwelling Units; Program H3-9: Housing on Religious Institution Sites; Program H4-2: Housing for Extremely Low-Income Households; Program H5-1: Special
Needs Housing).
• Allow projects that include at least 20% affordable housing that complies with objective standards to be reviewed ministerially (see Program H4-3:
Development Process Streamlining).
• Remove constraints to development to increase housing production (see Programs H4-4: Stacked Flats, H4-5:Minimum Unit Sizes, and H4-6: Parking for
Multi-Family Uses).
• Allow multi-family residential development that conforms with objective design and development standards as an allowed use without a public hearing (see
Program H4-7: Objective Design Standards).
• Monitor and adapt policy throughout the planning period to achieve goals (see Program H5-7: Annual Review, Monitoring, and Mid-Cycle Report).
Address Displacement Risk:
• Address potential displacement by requiring the replacement of units affordable to the same or lower income level as a condition of any housing development
on a nonvacant site (see Program H3-8: Replacement of Units On Sites).
• Research and implement anti-displacement tools that could include: draft and adopt a just cause eviction ordinance; identify resources for emergency rent
assistance for residents who are behind on their rent or utility payments; support local efforts for community land trust development. Timeframe: 2024.
Preserve 178 units of affordable housing through the planning period (see Program H1-4: Monitor And Preserve Affordable Housing And At-Risk Housing).
• Monitor and inspect rental units to ensure adequate housing conditions (see Program H1-2).
Housing Mobility Enhancement:
• Support additional Housing Choice Vouchers in the community and encourage rental property owners to rent to Housing Choice Voucher holders (see Program
H2-3: Section 8 Housing Choice Voucher Program).
• Continue to inform rental property owners of reasonable accommodation procedures and disability access laws by providing /mailing property owners with
informational materials. Timeframe: In 2024, add information on fair housing with a utility bill mailing to all customers.
Address Disproportionate Needs:
• Conduct public meetings at suitable times, accessible to persons with disabilities, and near public transit. Resources will be invested to provide interpretation.
Timeframe: Adjust meeting times and translation services based on attendance and public feedback.
• Coordinate with local universities and community colleges to assess student housing needs and participate in any campus planning efforts. Timeframe: Peform
proactive outreach to local universities and community colleges every two years.
• Continue to use the Rental Inspection Program as a tool to monitor and address fair housing issues. Timeframe: Evaluate trends in fair housing issues identified
through the Rental Inspection Program as part of the Annual Progress Report process and develop strategies to address issues in a timely manner (i.e., within
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
the following year of the APR).
• Implement an accessibility policy that establishes standards and procedures for providing equal access to City services and programs to all residents, including
persons with limited proficiency in English, and persons with disabilities. Timeframe: By 2023
Continue to implement the Analysis of Impediments to Fair Housing Choice (AI) and HUD Consolidated Plan. Timeframe: Prepare Consolidated Annual
Performance Evaluation Reports and Annual Plans each year and update the AI in 2025.
Place-Based Strategies for Community Preservation and Revitalization:
• Support neighborhood improvements in low-income neighborhoods (see Program H1-3: Neighborhood Improvement Zone Program)
• Pursue place-based strategies for funding and target neighborhoods of concentrated poverty and in lowest opportunity areas for investment in
rehabilitation, parks, transit, and active transportation. Ensure economic development plans reflect the needs of lower-opportunity neighborhoods.
Timeframe: one funding application annually. Initiate a General Plan update and engage the community around achieving better economic outcomes for
residents, including supporting school advancement and high-paying jobs in the community in 2023.
• Facilitate place-based revitalization of neighborhoods identified as environmental justice/disadvantaged communities, including a plan to construct parks,
open space and tree plantings in these areas to improve environmental health, develop active transportation facilities and focus on pedestrian safety
measures; and evaluate transitional buffers or screening between residential and heavy industrial uses in new development Timeframe: Initiate General Plan
update in 2023.
Disparities in educational achievement throughout the City. (Low)
Contributing Factors:
• Potential lack of culturally relevant educational opportunities outside of the school environment
• Potential lack of culturally relevant parent/student support
Meaningful Actions:
• Partner with Azusa Pacific University and local community colleges to advertise pathways to higher education for Azusa youth. Timeframe: By 2025
• Through the Azusa Recreation and Family Services Department, offer culturally sensitive educational programming at local libraries and community and
recreation centers. Programs could include classes in critical reading, computer science, math, robotics, etc. Timeframe: As part of the Department’s regular
process for developing recreational programming.
• Conduct targeted and culturally sensitive outreach promoting program offerings. Timeframe: Seasonally
Goals and actions must significantly seek to
overcome contributing factors to fair housing
issues. Currently, the element identifies program(s)
See response above, which includes metrics/milestones and meaningful actions.
City of Azusa HCD Findings/Edits Summary – October 2022
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HCD Questions/Comments from
May 20, 2022 Letter
Response
to encourage and promote affordable housing;
however, most of these programs do not appear to
facilitate any meaningful change nor address
affirmatively furthering fair housing requirements.
Furthermore, the element must include metrics
and milestones for evaluating progress on
programs, actions, and fair housing results. HCD
will send samples under separate cover.
The City also added additional updated information that became available pertaining to projects in the pipeline, and modified the Resources chapter accordingly. Those changes are highlighted
in the revised Housing Element in yellow (see page 153-173). In addition, the City made certain changes to respond to verbal comments from HCD; these too are highlighted in yellow in the
revised Housing Element (see Needs Assessment).
HCD Comment Revision Loca�on
Programs
Remove “as needed” from Programs, with the
excep�on of H4-8 where “as needed” can remain
Removed “as needed” from Program H1-4, H2-4,
H3-2, H3-6, H5-6.
AFFH Program (Place Based Strategies): Provide
more informa�on on ac�ons and implementa�on
Addi�onal ac�ons added; see purple highlighted
text on page 37-38.
AFFH Program (Address dispropor�onate needs):
Clarify quan�fiable metrics (i.e., number of units
inspected in rental inspec�on program) and
addi�onal ac�on/implementa�on measures
Addi�onal ac�ons added; see purple highlighted
text on page 36-37.
Program H3-2 (Mixed Use TOD): Provide
addi�onal ac�ons to support nonvacant mixed
use sites
See revisions to Program H3-2 (purple highlights)
on pages 22-23.
Sites
Nonvacant: Provide addi�onal informa�on on
exis�ng uses and show how those are related to
uses in Table 5.13, including single-family exis�ng
uses.
The sites inventory was modified to:
• Update the Approved/Proposed projects
in Tab le H-5.2, and accordingly remove
those parcels from the Sites Inventory
(see page 154 and 156)
• Five addi�onal sites were removed from
the inventory, as they did not meet the
criteria iden�fied for site selec�on.
Significant addi�onal informa�on was added to
reflect exis�ng uses on sites and similar
redevelopment that has occurred in Azusa and
the surrounding region, and paralleling the
factors related to development trends (previous
housing redevelopment sites) with the sites
iden�fied to meet the RHNA. See purple
highlighted text throughout the Resources
Chapter, especially pages 163 through 182.
Nonvacant (Religious Ins�tu�on Exis�ng Use):
Provide more informa�on on why these sites
were chosen and outreach to property owners.
The City has proac�vely reached out to all
religious ins�tu�ons included in the sites
inventory. Addi�onal informa�on is included
indica�ng support of property owners for housing
development on religious ins�tu�on sites. One
site was removed from the inventory, as the
property representa�ves indicated that they were
not interested in developing housing on their site.
See purple highlighted text on page 183 through
184.
California Environmental Quality Act (CEQA)
Finding of Consistency
Project Title:
City of Azusa 2021-2029 Housing Element Amendment
Project Location – Specific:
City of Azusa (citywide)
Project Location – City and County:
City of Azusa, County of Los Angeles
Description of Nature, Purpose and Beneficiaries of the Project:
The Azusa 2021-2029 Housing Element is a required component of the General Plan and was adopted by
the Azusa City Council on March 7, 2022. The adopted 2021-2029 Housing Element includes policies and
programs to meet the City’s housing needs, remove constraints to housing development, affirmatively
further fair housing, and show adequate sites with zoning in place to meet the city’s portion of regional
housing needs (also known as the regional housing needs assessment, or RHNA). The Azusa 2021-2029
Housing Element Update Initial Study and Negative Declaration assessed the impacts of this programmatic
project, including 2,865 potential units that could be developed on sites with existing zoning in place, plus
448 projects in the pipeline for a total of 3,313 units by 2029, which is within the buildout capacity
assumed by the General Plan Environmental Impact Report (EIR).
The Azusa 2021-2029 Housing Element Update amendment includes revisions to the document to comply
with State Housing Element law, as required by the California Department of Housing and Community
Development (HCD). In response to comments received by HCD during that agency’s required review of
the adopted document, additional analysis and clarification were provided including specific metrics and
objectives to accomplish housing policy set forth in the adopted 2021-2029 Housing Element. Additional
analysis regarding 1) housing needs of specials needs groups, 2) factors contributing to fair housing, and
3)analysis of non-vacant sites to meet city’s RHNA numbers were also provided.
There have been no substantial changes to the project scope or circumstances in the Initial Study and
Negative Declaration. Revisions to the adopted 2021-2029 Housing Element reflect minor edits to a
programmatic document and any potential significant impacts have been considered in the Initial Study
and Negative Declaration. Revisions to the adopted 2021-2029 Housing Element do not involve an
environmentally sensitive area, nor do revisions change or expand the proposed uses, increase intensity,
or result in a change from the original CEQA conclusions.
Name of Public Agency Approving the Project:
The Azusa City Council
Name of Persons or Agency Carrying Out the Project:
City of Azusa
Attachment 3
The project is within scope of the adopted 2021-2029 Housing Element, which was the subject of an
environmental evaluation in the adopted Initial Study and Negative Declaration. The Initial Study and
Negative Declaration was completed in accordance with the California Environmental Quality Act (CEQA)
and the State CEQA Guidelines. Further, the adopted Initial Study and Negative Declaration remains
pertinent and continues to have strong informational value. The above-described project has been
evaluated under CEQA to determine whether the project scope, circumstances, or information would
trigger the need for any supplemental environmental documentation based on new or substantially more
severe significant environmental impacts. After a thorough factual evaluation, the City of Azusa has
determined that no further supplemental environmental review is required because:
(1)The project does not propose substantial changes to the original project as described in the 2019-
2029 Housing Element Initial Study and Negative Declaration, which would require major revisions
to the previously-adopted Negative Declaration due to the involvement of new or substantially
more severe significant impacts;
(2)The project will not involve substantial changes with respect to the circumstances under which
the original project was undertaken, which would require major revisions to the previously-
adopted Negative Declaration due to the involvement of new or substantially more severe
significant impacts; and
(3)No substantially important new information requiring new analysis of significant effects,
mitigation, or alternatives is known that would require major revisions to the previously-adopted
Negative Declaration due to the project scope.
The City Council of the City of Azusa finds that no further environmental documentation is required
because all potentially significant effects (a) have been analyzed adequately in the previously-adopted
Negative Declaration pursuant to applicable standards, and (b) have been avoided pursuant to the
previously-adopted Negative Declaration. Therefore, in accordance with CEQA and the CEQA Guidelines
(Section 15168(c)), the project elements are within the scope of the previously-adopted Negative
Declaration; that Negative Declaration continues to be pertinent with considerable information value; and
project elements do not give rise to any new or substantially more severe significant effects, nor do they
require any new mitigation measures or alternatives. Accordingly, no new environmental document is
required.