Resolution - 2022-110RESOLUTION NO. 2022-110
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
WEST COVINA, CALIFORNIA, ADOPTING GENERAL
PLAN AMENDMENT (GPA) NO. 22-02 BY ADOPTING THE
2021-2029 HOUSING ELEMENT
WHEREAS, Government Code section 65300 requires every city to adopt a
general plan, including a housing element that complies with the provisions of
Government Code section 65580 et seq.; and
WHEREAS, cities must comply with the requirements of Government Code section
65350 et seq. in preparing, adopting and amending general plans; and
WHEREAS, the City of West Covina ("City") has initiated and prepared an update
to the Housing Element of the West Covina General Plan for the 2021-2029 planning
period; and
WHEREAS, the City held meetings on the draft Housing Element, including a joint
City Council and Planning Commission meeting on May 20, 2021 and a Town Hall
meeting on October 27, 2021; and
WHEREAS, the draft Housing Element has been posted on the City's website for
review and comment; and
WHEREAS, in November 2021, the City submitted the draft 2021-2029 Housing
Element to the California Department of Housing and Community Development ("HCD")
for comment; and
WHEREAS, on January 14, 2022, HCD issued a letter finding that the draft 2021-
2029 Housing Element addressed many statutory requirements; however, revisions
would be necessary to comply with State Housing Element Law; and
WHEREAS, the City held meetings on the draft Housing Element and the review
letter received from HCD, including a Planning Commission meeting on February 8, 2022
and a City Council meeting on March 1, 2022; and
WHEREAS, revisions to the draft 2021-2029 Housing Element were made to
address the issues raised in HCD's January 14, 2022 review letter and incorporated into
the final draft; and
WHEREAS, the revisions are summarized in the City Council staff report
accompanying this Resolution; and
WHEREAS, the staff report and supporting materials accompanying this
Resolution are found to be true, are adopted as facts and findings, and are incorporated
by reference in this Resolution; and
WHEREAS, based on the factors and substantial evidence described in Appendix
B of the Housing Element, incorporated herein by reference, the existing uses on sites
identified to accommodate the lower -income Regional Housing Needs Assessment
(RHNA) allocation 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, on October 11, 2022, the Planning Commission of the City of West
Covina held a duly noticed public hearing in accordance with State law requirements, at
which time it considered all evidence presented, both written and oral;
WHEREAS, at the close of the public hearing, the Planning Commission adopted
Resolution No. 22-6115, recommending that the City Council approve the 2021-2029
Housing Element Update; and
WHEREAS, on November 15, 2022, the City Council held a duly noticed public
hearing on the Housing Element in accordance with State law requirements, at which time
it considered all evidence presented, both written and oral; and
WHEREAS, the City Council finds that the 2021-2029 Housing Element, as revised
as shown in Exhibit "A" to this Resolution, incorporates changes that fully address the
January 14, 2022 comments from HCD in compliance with State law; and
WHEREAS, the City Council further finds that the 2021-2029 Housing Element will
promote the public health, safety and welfare, and will leave the General Plan an
integrated and internally consistent statement of policies; and
WHEREAS, the 2021-2029 Housing Element Update was reviewed and found to
be exempt from further review under the California Environmental Quality Act ("CEQA")
pursuant to CEQA Guidelines Section 15061(b)(3) (Common Sense Exception), as more
fully described below; and
WHEREAS, all legal prerequisites prior to adoption of this Resolution have
occurred.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF WEST COVINA,
CALIFORNIA DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. Findings. The City Council of the City of West Covina does hereby
find as follows:
(a) The foregoing recitals are true and correct.
(b) The Housing Element was prepared in accordance with State law and in
substantial compliance with the Housing Element Law.
(c) It is necessary to update the City's Housing Element to comply with State
law.
SECTION 2. CEQA. The City Council finds that the proposed General Plan
Amendment, as set forth in Exhibit "A" to this Resolution, is exempt from the requirements
of CEQA pursuant to CEQA Guidelines (14 Cal. Code Regs. § 15000 et seq.) Section
15061(b)(3) (Common Sense Exception) because no development project or other
physical change to the environment would be approved by the adoption of the Housing
Element. The City Council has reviewed the City staff determination of exemption, and
based on its own independent judgment, concurs in staffs determination that the
proposed General Plan Amendment is exempt from CEQA.
SECTION 3. Adoption. After giving full consideration to all evidence presented at
the public hearing, and in consideration of the findings stated above, the City Council of
the City of West Covina hereby adopts the 2021-2029 Housing Element as set forth in
Exhibit "A" attached hereto, and directs the Planning Manager to submit the document to
HCD for certification. The City Manager is authorized to make any technical or clerical
revisions to the adopted Housing Element that may be necessary to obtain a finding of
substantial compliance by the California Department of Housing and Community
Development.
SECTION 4. Certification. The City Clerk shall certify to the adoption of this
Resolution and shall enter it into the book of original resolutions.
APPROVED AND ADOPTED on this 15th day of November, 2022.
APPROVERAS TO FORM
Thomas P. Made
City Attorney
K L Zdg.."
Dario Castellanos
Mayor
ATTEST
FOY'' Lisa Sh4rrick
Assistant City Clerk
I, LISA SHERRICK, ASSISTANT CITY CLERK of the City of West Covina,
California, do hereby certify that the foregoing Resolution No. 2022-110 was duly adopted
by the City Council of the City of West Covina, California, at a regular meeting thereof
held on the 15th day of November, 2022, by the following vote of the City Council:
AYES:
Castellanos, Diaz, Lopez-Viado, Tabatabai, Wu
NOES:
None
ABSENT:
None
ABSTAIN:
None
�Lisa Sherri k
o
Assistant City Clerk
EXHIBIT A
WEST COVINA 2021-2029 HOUSING ELEMENT
City of West Covina
Y _I _ t J
2021-2029 Housing Element
Revised Draft I October 2022
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List of Tables
........................................................................................................................
Table 2-1
Table 3-1
Table 3-2
Table 3-3
Table 3-4
Table 3-5
Table 3-6
Table 3-7
Table 3-8
Table 4-1
Table 4-2
Table 4-3
Table 4-4
Table 4-5
Table 4-6
Table 4-7
Table 4-8
Table 4-9
Table 4-10
2021-2029 Quantified Objectives........................................................................................22
Overpayment by Income Category- West Covina........................................................34
Elderly Households by Income and Tenure........................................................................35
Disability by Employment Status - West Covina................................................................ 37
Developmental Disabilities - West Covina.........................................................................38
Extremely -Low -Income Households by Tenure- West Covina ...................
Agricultural Employment- West Covina .......................................................
Affordable Housing Projects -West Covina .................................................
Regional Housing Needs Assessment (RHNA) 2021-2029 ............................
General Plan Designations and Corresponding Transect Zones ................
Development Standards for Single -Family Residential by Area District.....
Development Standards for Multiple Family Residential Zones ..................
Minimum Floor Area for Multi -family Units by Area District ..........................
Downtown Plan Development Standards ....................................................
Special Incentives: Modified Unit Size............................................................
City of West Covina Fee Schedule................................................................
Development Impact Fee Summary .............................................................
Development Fee Summary ...........................................................................
Local Development Processing Time Limits ..................................................
.................... 39
.................... 42
.................... 42
.................... 43
.................... 45
.................... 48
.................... 49
.................... 50
.................... 51
.................... 53
.................... 56
.................... 57
.................... 58
.................... 59
List of Figures
........................................................................................................................
Figure 3-1 Population Trends 2000-2020- West Covina vs. SCAG Region ................................
Figure 3-2 Population by Age and Gender - West Covina .......................................................
Figure 3-3 Employment by Industry - West Covina.....................................................................
Figure 3-4 Employment by Occupation - West Covina..............................................................
Figure 3-5 Household Size by Tenure - West Covina...................................................................
Figure 3-6 Housing Units by Type - West Covina.........................................................................
Figure 3-7 Housing by Tenure - West Covina vs. SCAG Region .................................................
Figure 3-8 Housing Tenure by Age - West Covina......................................................................
Figure 3-9 Vacant Units by Type - West Covina vs. SCAG Region ............................................
Figure 3-10 Year Structure Built- West Covina vs. SCAG Region ................................................
Figure 3-1 1 Median Home Sales Prices for Existing Homes 2000-2018- West Covina vs. SCAG
Region.............................................................................................................................
Figure 3-12 Monthly Owner Costs for Mortgage Holders - West Covina vs. SCAG Region .....
Figure 3-13 Percentage of Income Spent on Rent - West Covina ..............................................
Figure 3-14 Rental Cost by Income Category- West Covina ......................................................
Figure 3-15 Overcrowding by Tenure - West Covina vs. SCAG Region .....................................
Figure 3-16 Female -Headed Households- West Covina.............................................................
Figure 3-17 Female -Headed Households by Poverty Status - West Covina ..............................
Figure 3-18 Disability by Type - West Covina.................................................................................
Figure 3-19 Disability by Type for Seniors - West Covina vs. SCAG Region ................................
City of West Covina v
City of West Covina
/-021-2U/-y dousing clerrlem
Adopted
Resolution
Acknowledgements
City Council
Dario Castellanos, Mayor
Rosario Diaz, Mayor Pro Tern
Letty Lopez Viado, Councilmember
Brian Tabatabai, Councilmember
Tony Wu, Councilmember
Planning Commission
Nickolas Lewis, Chair
Brian Gutierrez, Vice Chair
Livier Becerra, Commissioner
Sheena Heng, Commissioner
Shelby Williams, Commissioner
Table of Contents
Section1
Introduction.......................................................................................................1
1.1
Housing Element Purpose..........................................................................................
1
1.2
General Plan Consistency.........................................................................................
1
1.3
Citizen Participation...................................................................................................2
1.4
Housing Element Organization.................................................................................2
Section2
Housing Plan......................................................................................................3
2.1
Goals, Policies, Programs and Objectives...............................................................3
2.2
Quantified Objectives..............................................................................................21
Section 3
Housing Needs Assessment...........................................................................23
3.1
Introduction...............................................................................................................23
3.2
Data Sources.............................................................................................................24
3.3
Population Trends and Characteristics..................................................................24
3.4
Household Characteristics.......................................................................................26
3.5
Housing Inventory and Market Conditions............................................................27
3.6
Housing Costs............................................................................................................30
3.7
Special Needs Groups.............................................................................................34
3.8
Housing At -Risk of Conversion to Market Rate......................................................42
3.9
Future Housing Needs 2021-2029............................................................................43
Section 4
Housing Constraints........................................................................................44
4.1
Governmental Constraints......................................................................................44
4.2
Non -Governmental Constraints..............................................................................67
4.3
Environmental Constraints.......................................................................................69
Section 5
Housing Resources.........................................................................................71
5.1
Availability of Sites for Housing................................................................................71
5.2
Financial and Administrative Resources................................................................71
5.3
Energy Conservation Opportunities.......................................................................72
Appendix A — Review of the Prior Housing Element............................................................74
AppendixB — Sites Inventory .................................................................................................80
Appendix C — Public Participation.......................................................................................116
Appendix D — Fair Housing Assessment.............................................................................131
City of West Covina iv
Section 1
.........................................................................................................................
Introduction
1.1 Housing Element Purpose
State law requires every jurisdiction in California to adopt a General Plan, including a
Housing Element. The Housing Element establishes policies, procedures and incentives to
adequately accommodate the housing needs of households currently living or expected
to live in West Covina over the 2021-2029 period.
The Housing Element identifies strategies and programs that focus on the preservation and
improvement of housing and neighborhoods, providing adequate housing sites, assisting in
the provision of affordable housing, removing governmental and other constraints to
housing investment, and promoting fair and equal housing opportunities. These City
commitments address the statewide housing goal of "early attainment of decent housing
and a suitable living environment for every Californian."
Specific requirements for data collection and analysis necessary to prepare the Housing
Element are set forth in Government Code Section 65583 and are discussed later in this
document. The Government Code also requires that draft Housing Elements be reviewed
by the California Department of Housing and Community Development (HCD) and that the
Department's findings be considered by the City prior to Housing Element adoption.
1.2 General Plan Consistency
The Housing Element is one of the required seven elements of the West Covina General Plan.
The goals, policies, standards and proposals within this element relate directly to, and are
consistent with, all other elements. The City's Housing Element identifies programs and
resources required for the preservation, improvement and development of housing to meet
the existing and projected needs of its population. Through the regulation of the amount
and variety of open space and recreation areas, acceptable noise levels in residential
areas, and programs to provide for the safety of the residents, policies contained in General
Plan elements directly affect the quality of life for all West Covina citizens.
The Housing Element is correlated with development policies contained in the Land Use
Element, which establishes the location, type, intensity and distribution of land uses
throughout the City, and defines the land use build -out potential. In designating land for
residential development, the Land Use Element describes the types and location of housing
City of West Covina 1
units that may be constructed in the City. The acreage designated for a range of
commercial and office uses creates employment opportunities for various income groups.
The presence and potential for jobs affects the current and future demand for housing at
the various income levels in the City.
The Circulation Element of the General Plan also affects the implementation of the Housing
Element. The Circulation Element establishes policies for a balanced circulation system in
the City. The element also provides policies for essential infrastructure to support housing
development along with mitigating the effects of growth.
The Housing Element utilizes the recent data published by the U.S. Census Bureau,
particularly American Community Survey estimates.
The Housing Element has been reviewed for consistency with the City's other General Plan
elements, and the policies and programs in this Element are consistent with the policy
direction contained in other parts of the General Plan. As portions of the General Plan are
amended from time to time, the Housing Element will be reviewed to ensure that internal
consistency is maintained.
1.3 Citizen Participation
California law requires that local governments make a diligent effort to achieve public
participation from all economic segments of the community in the preparation of the
Housing Element. The public involvement process during the 2021 Housing Element Update
is described in Appendix C.
1.4 Housing Element Organization
This Housing Element is an update to the City's 2013-2021 Housing Element and has been
revised to address current housing needs, conditions, and changes in State law. To address
the State requirements, the Housing Element has been divided into the following sections:
Housing Plan to address West Covina's identified housing needs, including
housing goals, policies, programs and objectives.
2. Housing Needs Assessment including an analysis of the City's population,
household and employment base, characteristics of the housing stock, special
housing needs, and an assessment of fair housing issues;
3. Housing Constraints examining governmental and non -governmental
constraints on the production, maintenance, and affordability of housing;
4. Housing Resources presenting an inventory of potential housing sites, financial
resources and administrative capabilities.
Appendix A - Evaluation of the Prior Housing Element
Appendix B-Sites Inventory
Appendix C - Public Participation
City of West Covina 2
Section 2
.........................................................................................................................
Housing Plan
This Housing Plan includes goals, policies, programs and objectives to guide the
development and preservation of a balanced inventory of housing to meet the needs of
present and future residents of the City. The Plan is organized into the following major
themes:
Preservation of the City's existing housing stock;
2. Increased affordable housing opportunities;
3. Removal of constraints to the construction of housing opportunities;
4. Affirmatively furthering fair housing;
5. Identification of adequate sites to achieve a variety and diversity of housing.
For each of the goals identified, specific policies, programs and objectives are described.
It should be noted that the successful implementation of many of these programs will be
dependent on the availability of sufficient financial resources provided by other
governmental agencies or actions of other entities that are not under the City's control.
2.1 Goals, Policies, Programs and Objectives
Continued maintenance and preservation of the existing housing stock in West Covina is
crucial to ensure quality neighborhoods. Housing programs focused on the achievement of
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. Through code enforcement, neighborhood, and home improvement
programs, the City is able to maintain the condition of existing housing units.
Policy 1.1: When available, provide financial assistance to rehabilitate dwelling units
owned or occupied by seniors and low-income individuals.
Policy 1.2: Encourage citizen involvement in property maintenance and efforts to improve
the housing stock and overall neighborhood quality.
City of West Covina 3
Policy 1.3: 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 1.4: Continue to monitor affordable housing developments, second units, and
vacant units within the City.
Policy 1.5: Preserve the existing affordable housing stock, including mobile homes, through
the implementation of City regulations, on -going monitoring and the provision
of financial assistance.
Policy 1.8: Continue to support the provision of rental assistance to lower -income
households and encourage property owners to list units with the Housing
Authority.
Policy 1.9: Promote housing that is developed exceeding Title 24 Standards of the
California Building Code.
Programs
Program 1.1 — Housing Preservation
West Covina places a high priority on maintaining the quality of its housing stock. The
Housing Preservation Loan Program (HPP) for moderate -income households provides
residents with small loans of up to $10,000 to complete a variety of home improvements
including, but not limited to: room additions, handicap modifications, structural repairs,
exterior enhancements, interior improvements, electrical and/or plumbing work.
Homeowners can apply for loans of up to $10,000; however approved loans are typically
for smaller amounts allowing for more residents to take advantage of the program. An
interest rate of 5% is applied by the City on loans made to residents. Historically, the HPP was
funded using Redevelopment Set -Aside funds; however, the elimination of the
Redevelopment Agency has resulted in the loss of a permanent funding source for this
program. For the 2021-2029 planning period the City will annually evaluate new funding
opportunities and administer funds as they become available. If and when a permanent
funding source is identified, the City will provide information about the program at City Hall,
on the City's website and in other public places to increase awareness and solicit
applications.
Responsible Agency: West Covina Community Development Department,
Community and Economic Development Division
Time Frame: Ongoing, 2021-2029
Potential Funding Sources: CDBG funds, Additional funding sources needed.
Objectives:
• Investigate new funding sources, annually evaluate opportunities, and administer
funds as they become available.
City of West Covina 4
• Promote energy efficiency improvements to households participating in the Housing
Preservation Program.
• Continue to provide informational materials about the HPP at City Hall, on the City's
website and in other public places to increase awareness.
• When funding is available, advertise the HPP and other programs in the City's
newsletter (Discover West Covina).
Program 1.2 — Monitor and Preserve Affordable Housing
West Covina currently has one deed -restricted affordable multi -family housing complexwith
84 units with affordability covenants that could expire during the next 10 years. The City will
work cooperatively with the property owner and other entities to facilitate the preservation
of these affordable units to the extent feasible. Specific actions the City will take to facilitate
the preservation of these at -risk units include:
• Monitor the Risk Assessment report published by the California Housing Partnership
Corporation annually.
• Maintain regular contact at least once each yearwith the local HUD office regarding
early warnings of possible opt -outs.
• Maintain contact with the owners and managers of existing affordable housing at
least once each year to determine if there are plans to opt out in the future, and
offer assistance in locating eligible buyers.
• Develop and maintain a list of potential purchasers of at -risk units and act as a liaison
between owners and eligible purchasers.
• Ensure that all owners and managers of affordable housing are provided with
applicable state and federal laws regarding notice to tenants of the owner's desire
to opt out or prepay.
Responsible Agency: West Covina Community Development Department,
Community and Economic Development Division
Time Frame: Annual outreach; Ongoing, 2021-2029
Potential Funding Sources: General Fund
Objectives:
• Preserve all existing affordable units.
Program 1.3 — Energy -Efficient Design
The City will review ordinances and recommend changes where necessary to encourage
energy efficient housing design and practices that are consistent with state regulations. The
City will periodically distribute literature or post information on the website regarding energy
conservation, including solar power, energy efficient insulation, and subsidies available from
utility companies, and encourage homeowners and landlords to incorporate these features
into construction and remodeling projects. When possible the City will encourage energy
conservation devices including, but not limited to lighting, water heater treatments, and
solar energy systems for all new and existing residential projects. The City will encourage
maximum utilization of Federal, State, and local government programs, including the
City of West Covina 5
County of Los Angeles Home Weatherization Program, that are intended to help
homeowners implement energy conservation measures. Additionally, as part of the Housing
Preservation Loan Program, outlined above, residents can apply for loans to increase the
energy efficiency of their home.
Responsible Agency: West Covina Community Development Department, Planning
Division
Time Frame: Ongoing, 2021-2029. The City will continue to monitor
technology advances and new materials and equipment and
review new ordinances when appropriate.
Potential Funding Sources: General Fund
Objectives:
Maintain and distribute literature on energy conservation, including solar power,
additional insulation, and subsidies available from utility companies, and encourage
homeowners and landlords to incorporate these features into construction and
remodeling projects.
• Encourage energy conservation devices, including but not limited to lighting, water
heater treatments, and solar energy systems for all residential projects.
• Encourage maximum utilization of Federal, State, and local government programs,
such as the County of Los Angeles Home Weatherization Program, that assist
homeowners in providing energy conservation measures.
• Continue to provide information on home loan programs available through the City
and encourage residents to use the programs to implement energy efficient design.
• Continue to partner with Southern California Edison to offer homeowners
opportunities to reduce energy usage and in turn the City's carbon footprint.
Program 1.4 — Code Enforcement
Code enforcement is essential to ensuring housing preservation and rehabilitation. The City
will undertake the enforcement of the Property Maintenance Ordinance, which is intended
to preserve existing residential and nonresidential structures in attractive, safe, and sanitary
conditions. The City will enforce, on a complaint or request basis, local zoning; housing, fire,
and building codes; and standards for landscaping under its Community Enhancement
Program to maintain safe and decent housing. Property owners with code violations who
meet eligibility requirements for participation in the City's Home Improvement Program will
be offered an opportunity to correct code violations through financial assistance from the
Program, when funds are available. The primary goal of the regulation is to provide
reasonable controls for the maintenance, rehabilitation, preservation, and conservation of
existing commercial and residential properties. The City anticipates that approximately
$100,000 of CDBG funding will be available annually to provide code enforcement
assistance.
City of West Covina 6
Responsible Agency: West Covina Community Development Department, Code
Enforcement Division
Time Frame: Ongoing, 2021-2029
Potential Funding Source: Departmental Budget, CDBG funds
Objectives:
Continue to implement the Community Enhancement program to bring substandard
housing units into compliance with City building and property maintenance codes.
• Enforce and expand where necessary, the property maintenance provisions
embodied in the California Green Building Code and the Zoning Ordinance to
conserve and improve the quality of the housing units in the City.
West Covina strives to provide a variety of housing types, with housing units available for all
income segments of the population. The existing housing stock offers many affordable
options throughout the City. The intent of this goal is to assist in the provision of adequate
housing to meet the needs of the community, including the needs of both renter and owner
households.
Policy 2.1: Continue to participate in State and federally sponsored programs designed to
maintain housing affordability, including the Section 8 Housing Choice Voucher
program.
Policy 2.2: Continue to support non-profit and for -profit organizations in their efforts to
construct, acquire, and improve housing to accommodate households with
lower and moderate incomes.
Policy 2.3: Facilitate development of affordable housing through use of financial and/or
regulatory incentives.
Policy 2A: Provide high -quality housing for current and future residents at all income levels
to achieve a balanced community.
Policy 2.5: Encourage the provision of housing to address the City of West Covina's
growing senior population, including design that supports aging in place, senior
housing with supportive services, assisted living facilities and accessory units.
Policy 2.6: Facilitate the provision of accessory dwelling units as a means of providing
affordable rental housing in existing neighborhoods. Ensure compatibility with
the primary unit and surrounding neighborhood.
City of West Covina 7
Programs
Program 2.1 — Acquisition and Rehabilitation
One of the most significant barriers to affordable housing is the acquisition of the property
on which to construct affordable housing. The City can assist in the provision of affordable
housing by utilizing available funds to write down the cost of land for development of
affordable housing. The City will encourage the acquisition and rehabilitation of existing,
underutilized and substandard residential units and motels. As part of the land write -down
program, the City may also assist in the acquiring and assembling property and in subsidizing
on- and off -site improvements. The City will establish and maintain contacts with non -profits
in the area to solicit interest in participating in programs and projects in West Covina. This
program will contribute to the improvement of the City by providing affordable units,
eliminating blighted properties, and encouraging private investment. During the previous
planning period, the City partnered with the Regional Occupation Program to construct a
single-family low-income unit. The City plans to continue its efforts to identify additional
partnerships in the future.
The State's elimination of the City's Redevelopment Agency has resulted in a loss of a
permanent funding source for this program. For the 2021-2029 planning period the City will
annually evaluate and investigate potential new funding opportunities and administer
funds as they become available. If and when a permanent funding source is identified, the
City will provide information about the program at City Hall, on the City's website and in
other public places to increase awareness.
Responsible Agency: West Covina Community Development Department,
Community and Economic Development Division
Time Frame: Ongoing; 2021-2029
Funding Sources: New funding sources needed
Objectives:
Investigate new funding sources, annually evaluate opportunities, and administer
funds as they become available. If, and when, a permanent funding source is
identified, the City will provide information at City Hall, on the City's website and in
other public places to increase awareness.
• Continue to provide financial and regulatory incentives to increase the supply of
affordable housing.
• Assist developers in the assemblage of property and, as appropriate and necessary;
provide land write -downs for affordable housing developments.
Program 2.2 — Affordable Housing Financing
The California Housing Finance Agency (CaIHFA) provides financing programs that create
safe, decent and affordable housing opportunities for low- and moderate -income
Californians. Established in 1975, CaIHFA was chartered as the State's affordable housing
bank to make low -interest loans through the sale of tax-exempt bonds. CaIHFA offers a
variety of programs for multi -family developers to first time home buyers. As the City of West
Covina has little control over how CaIFHA's programs are administered, the City will be
City of West Covina 8
responsible for providing program information on the City's website, in the City's newsletter
(Discover West Covina) and at City Hall. The City will proactively explore and pursue funding
opportunities from all sources annually in partnership with nonprofit developers and service
providers.
Responsible Agency: West Covina Community Development Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund
Objectives:
Provide informational materials about the program at City Hall, on the City's website,
in the City's newsletter (Discover West Covina) and in other public place to increase
awareness.
On an annual basis proactively explore and pursue funding opportunities from all
sources in partnership with nonprofit developers and service providers.
Program 2.3 — Alternative Housing Models
The City recognizes that seniors and persons with disabilities may require alternative forms
of housing. To meet the needs of these groups, the City will encourage the provision of
innovative housing types, including community care facilities, supportive housing, and
assisted living. Assisted living facilities are designed for individuals needing assistance with
activities of daily living but desiring to live independently for as long as possible. Such
facilities bridge the gap between independent living and nursing homes, and offer residents
help with daily activities such as eating bathing, dressing, laundry, housekeeping, and
assistance with medications. Assisted living can help to meet the housing and supportive
services needs of West Covina's seniors and those with disabilities.
Responsible Agency: West Covina Community Development Department, Planning
Division and Community and Economic Development Division
Time Frame: Ongoing, 2021-2029
Potential Funding Sources: Departmental Budgets
Objectives:
Facilitate the development of alternative housing models suited to the housing needs
of seniors and persons with disabilities through 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.
Program 2.4 — Los Angeles County Partnerships
As a means of further leveraging housing assistance, the City will proactively cooperate with
the Los Angeles County Development Authority (LACDA) each year to promote resident
awareness and application for County -run housing assistance programs. These programs
include:
City of West Covina 9
• Mortgage Credit Certificate Program (MCC),
• Home Ownership Program (HOP),
• First Home Mortgage Program,
• Section 8 Housing Choice Vouchers,
• Multi -Family Bond Program,
• Multi -Family Rental Program,
• Single -Family Grant Program (SFGP), and
• Single -Family Rehabilitation Loan Program.
LACDA offers a variety of housing assistance programs that can supplement the City's
current housing programs. As the City has little control over how the County's programs are
administered the City will be responsible for providing program information on the City's
website, in the City's new letter (Discover West Covina) and at City Hall.
Responsible Agency: Community Development Department and Public Services
Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund
Objectives:
Increase resident awareness about housing programs offered by LACDA by
advertising them on the City's website, periodically in the City's newsletter (Discover
West Covina) and by offering Staff assistance at City Hall.
Market factors and governmental regulations may at times constrain the development of
adequate and affordable housing. These factors tend to disproportionately impact lower -
and moderate -income households due to their limited resources. The City is committed to
removing governmental constraints that hinder the production of housing and offers a "one -
stop" streamlined permitting process to facilitate efficient entitlement and building permit
processing.
Policy 3.1: Support innovative public, private and non-profit efforts toward the
development of affordable housing.
Policy 3.2: Periodically review and revise the City's development standards, if necessary,
to facilitate quality housing that is affordable to all income levels.
Policy 3.3: When feasible, consider reducing, subsidizing, or deferring development fees to
facilitate the provision of affordable housing.
Policy 3.4: Continue the provision of incentives, including the density bonus incentive
program, which encourages developers to include affordable units in their
projects.
City of West Covina 10
Policy 3.5: Encourage production of accessory dwelling units as an additional source of
infill housing opportunities.
Policy 3.6: Identify funding to subsidize land costs of for housing developments that include
affordable units.
Policy 3.7: Provide flexibility in development standards to accommodate alternative
approaches to provide affordable housing such as mixed -use projects.
Programs
Program 3.1 - Reduce Development Constraints
As part of the comprehensive Development Code update the City will review residential
and mixed -use regulations to identify development standards or procedures that may
constrain the development of affordable housing and housing for persons with special
needs. Specific Code amendments will include:
• Emergency shelters - AB 139 (2019) limited the allowable parking standards for
emergency shelters to the number of spaces required for staff.
• Supportive housing - AB 2162 (2018) amended State law to require that supportive
housing be a use by -right in zones where multi -family and mixed uses are permitted,
including non-residential zones permitting multi -family uses, if the proposed housing
development meets specified criteria.
• Low barrier navigation centers - AB 101 (2019) added the requirement that low barrier
navigation centers meeting specified standards be allowed by -right in areas zoned
for mixed use and in non-residential zones permitting multi -family uses pursuant to
Government Code §65660 et seq.
• Residential care facilities - As part of the Development Code update a definition and
regulations will be established for residential care facilities for seven or more people
consistent with State law and fair housing requirements, including replacing or
modifying the CUP requirement to provide greater objectivity and certainty to
expand housing opportunities for persons with disabilities.
• Agricultural employee housing -The Employee Housing Act (Health and Safety Code,
§ 17021.5 and § 17021.6) requires agricultural employee housing for six or fewer
employees to be treated as a single-family structure and permitted in the some
manner as other dwellings of the some type in the same zone, and requires
employee housing consisting of no more than 12 units or 36 beds to be permitted in
the some manner as other agricultural uses in the same zone.
City of West Covina 11
Responsible Agency: West Covina Community Development Department, Planning
Division
Time Frame: Development Code amendment by December 2022
Potential Funding Source: Grant funds
Objectives:
Process amendments to the Development Code to update City regulations for
emergency shelters, supportive housing, low barrier navigation centers, residential
care facilities for seven or more persons, and agricultural employee housing
consistent with current law.
Program 3.2 - Density Bonus
State law requires cities to allow an increase in residential density and other incentives when
developments provide affordable or senior housing. Recent State legislation has amended
density bonus requirements. West Covina Municipal Code Section 26-676 et seq. (Low and
Moderate Income and Senior Citizen Housing) establishes City standards and procedures
to implement State density bonus law. As part of the comprehensive Development Code
update, the City will amend density bonus regulations in conformance with current State
law. In addition, the City will promote the use of density bonuses to facilitate production of
affordable and senior housing.
Responsible Agency: West Covina Community Development Department, Planning
Division
Time Frame: Development Code amendment in 2022/23
Potential Funding Source: General Fund
Objectives:
• Amend City density bonus regulations consistent with State law (Government Code
§65915 et sec.).
• Continue to promote the City's density bonus ordinance by providing informational
materials at City Hall, on the City's website and in other public places to increase
awareness.
Program 3.3 - Priority Processing for Affordable and Special Needs Housing
Affordable housing developers often face constraints in developing affordable housing
projects. One way the City can assist such developers is by providing fast-track/priority
processing for low-income and special needs housing projects. This service can encourage
affordable housing development by allowing developers to go through the approval and
permitting process quicker keeping costs down and units affordable. It is important that
following the construction of the project that units are monitored to ensure that subsequent
tenants are households with special needs and/or lower income.
The City will proactively reach out to affordable and special needs housing developers
annually to encourage and facilitate housing development in West Covina.
City of West Covina 12
Under some circumstances development applications may be eligible for "streamlined
ministerial review" such as pursuant to SB 35 (Government Code §65913.4). Qualifying
projects are subject to specified procedures and development standards intended to
simplify and expedite the development process. As part of the comprehensive
Development Code update the City will establish written guidelines to assist applicants and
City staff in complying with these requirements.
In compliance with transparency requirements, all zoning, development standards and fees
will be posted on the City website and other public places.
Responsible Agency: Community Development Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund
Objectives:
• The City will assign senior staff to handle the projects, and staff assistance may be
provided to prepare the necessary documents.
• Reach out to affordable and special needs housing developers annually
• Provide informational materials about development regulations, fees and fast -track
processing, including SB 35 streamlined review, at City Hall, on the City's website and
in other public places to increase awareness.
Program 3.4 — Accessory Dwelling Units
Allowing for the development of accessory dwelling units (ADUs) offers an important
affordable housing option for lower -income households and others such as seniors,
caregivers, or young adults. ADUs can also provide property owners with an additional
source of income. Recent changes to State law encourage ADU production. The City
amended local ADU regulations in October 2020 and July 2022 in conformance with State
law. The City has addressed the Department of Housing and Community Development's
February 2022 ADU Ordinance comment letter and has made applicable revisions to the
ADU regulations. The City will continue to monitor legislation and update City ADU
regulations as necessary to ensure consistency with State law.
In addition, the City will incentivize and promote ADU development in the following ways:
• Assist property owners with ADU applications
• Post informational ADU flyers in City Hall, on the Planning Department website and
other public places
• Explore and pursue ADU funding assistance annually
• Modify development standards
• Reduce fees beyond what is required by State law
• Provide pre -approved ADU plans
City of West Covina 13
Responsible Agency: West Covina Community Development Department, Planning
Division
Time Frame: Review and update ADU regulations annually as necessary to
incorporate changes to State law; Encourage ADU production
throughout the planning period.
Potential Funding Sources: Departmental Budget
Objectives:
Monitor legislation and amend City regulations as necessary to ensure consistency
with State ADU law.
• Promote additional ADU development.
Program 3.5 — Manufactured Housing and Mobile Home Rent Control
Manufactured housing and mobile home parks represent affordable housing resources for
the City's low-income and elderly households. Manufactured housing units in West Covina
are found in two mobile home parks. The City has adopted the Mobile Home Rent Control
Ordinance and restricts conversion of mobile home parks to other uses. State law requires
local jurisdictions to permit manufactured housing and mobile homes in all residential zones.
The City will continue to permit new mobile home parks in multi -family zones and
manufactured homes on permanent foundations on individual lots or in new manufactured
home subdivisions. Manufactured homes on single-family lots must comply with
development standards applicable to the zones in which they are located.
Responsible Agency: West Covina Community Development Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund
Objectives:
Encourage the provision of manufactured housing (including mobile homes) in
single-family residential zones, subject to the conditions consistent with State law.
Maintain the Mobile Home Rent Control Ordinance of 1984 to limit rent increases for
mobile home spaces to retain mobile home parks as a continued source of
affordable housing in the City.
Program 3.6 — Priority Water and Sewer Service for Affordable Housing
In accordance with Government Code §65589.7, immediately following City Council
adoption, the City will deliver a copy of the Housing Element to all public agencies or private
entities that provide water or sewer services to properties within West Covina, including
reference to the State requirement that water and sewer service providers must establish
specific procedures to grant priority water and sewer service to developments with units
affordable to lower -income households.
City of West Covina 14
Responsible Agency: West Covina Community Development Department, Planning
Division
Time Frame: Immediately following Housing Element adoption
Potential Funding Source: General Fund
Objectives:
Immediately following the adoption of the Housing Element, Staff will deliver copies
to all providers of sewer and water service within the City of West Covina.
To fully meet the community's housing needs, the City must promote housing accessibility
for all residents, regardless of age, race, religion, family status, or physical disability. The City
attempts to achieve this through reasonable accommodation and through a partnership
with the Housing Rights Center.
Policy 4.1: Continue to enforce fair housing laws prohibiting discrimination in the building,
financing, selling, or renting of housing on the basis of race, ethnicity, ancestry,
national origin, religion, sex, disability, age, marital status, familial status, source
of income, sexual orientation, or any other arbitrary factor.
Policy 4.2: Promote greater awareness of tenant and landlord rights and obligations.
Policy 4.3: Provide that displacement of low-income households is avoided and, where
necessary, is carried out in an equitable manner.
Policy 4.4: Encourage housing construction or alteration to meet the needs of residents
with special needs such as large families, the elderly and persons with
disabilities.
Programs
Program 4.1 — Fair Housing
The City will continue to affirmatively further fair housing through the following meaningful
actions: contract with the Housing Rights Center to provide residents with fair housing
services using Community Development Block Grant (CDBG) funds. Fair housing services
provided by the Housing Rights Center include counseling and mediation between tenants
and landlords. The Housing Rights Center also conducts seminars and information activities
throughout the region. The Citywill refer fair housing complaints to the Housing Rights Center
SGVFHC as appropriate. The City will assist in program outreach through placement of fair
housing program brochures in both English and Spanish at the public counter, City library,
post office, and other community locations such as the City's senior center.
City of West Covina 15
• Continue directing fair housing inquiries to the Housing Rights Center.
• Continue to support the provision of housing for persons with disabilities through
reasonable accommodation and zoning regulations that encourage and facilitate
housing for persons with special needs.
• Post information at the Senior Center regarding fair housing and conduct a
presentation every two years at the Center about services available through the
County CDC, Housing Rights Center and the City.
• In cooperation with the Housing Rights Center, contact low-income apartment
complexes to provide education and materials about the Section 8 program
including multi-lingual materials.
• Publish links to fair housing information via social media.
• Conduct ongoing, proactive outreach to engage members of all socio-economic
groups and recruit members of underrepresented groups to participate in City
meetings.
Responsible Agency: West Covina Public Services Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: Departmental Budget; Community Development Block Grants
Objectives:
• Continue to assist households, and refer fair housing complaints to the Housing Rights
Center.
• Continue to comply with all State and federal fair housing requirements when
implementing housing programs or delivering housing -related services.
• Continue to promote fair housing practices, including advertisement on the City's
website, and provide educational information on fair housing to the public.
• Increase education to residents and landlords regarding fair housing laws.
Program 4.2 — Reasonable Accommodation for Persons with Disabilities
The Fair Housing Act requires that cities and counties provide reasonable accommodation
to rules, policies, practices, and procedures where such accommodation may be
necessary to afford individuals with disabilities equal housing opportunities. Reasonable
accommodation provides a basis for residents with disabilities to request flexibility in the
application of land use and zoning regulations or, in some instances, even a waiver of
certain restrictions or requirements from the local government to ensure equal access to
housing opportunities. 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
case law interpreting the statutes. The City of West Covina encourages and promotes
accessible housing for persons with disabilities and through Municipal Code §26-298.02,
which establishes procedures to consider requests for reasonable accommodation. This
includes the retrofitting of existing dwelling units and enforcement of the State accessibility
standards for new residential construction. Removal of architectural barriers is also an
eligible improvement under the City's Home Improvement Loan Program. As part of the
comprehensive Development Code update, the City's reasonable accommodation
procedures will be revised as necessary to ensure compliance with fair housing law.
City of West Covina 16
Responsible Agency: West Covina Community Development Department, Planning
Division
Time Frame: Code amendment by December 2022; Ongoing 2021-2029
Potential Funding Source: Departmental Budget
Objectives:
• Continue to provide information to residents on reasonable accommodation
procedures at public counters and on the City website.
• Promote the Home Improvement Loan Program as a potential funding source for
persons with disabilities or the elderly to make accessibility improvements to their
homes.
Program 4.3 — Senior Center Shared Housing
The Senior Citizens' Center at Cortez Avenue offers a variety of services aimed at senior
residents, including: help in finding home care/home chore workers; transportation; services
to help those who would like help in maintaining independence in their homes, including
case management; assistance with Social Security and Medicare forms/questions;
volunteer opportunities; and support groups. These services are intended to allow senior
residents to be independent in their own homes as an alternative to group care facilities.
The City currently advertises the program on its website and will continue to administer funds
as they become available.
Responsible Agency: West Covina Public Services Department
Time Frame: Ongoing, 2021-2029, subject to the availability of funds
Potential Funding Source: General Fund and Community Development Block Grants
Objectives:
• Continue to operate the housing match program through the Senior Citizens' Center
at Cortez Avenue with the goal of making 10 matches a year.
Program 4.4 — Homeless Assistance
The City will continue to use CDBG funds to support agencies providing services to the
homeless, persons at risk of becoming homeless and non -homeless persons with special
needs. The City will continue to support efforts by local non -profits to expand the services
provided to at -risk population groups. On an annual basis, the City provides CDBG funds for
supportive services and transitional and temporary housing providers serving West Covina
residents. The City has provided CDBG funds to assist non -profits such as East San Gabriel
Valley Coalition for the Homeless, YWCA (Meals on Wheels) and food pantries. In addition,
the City also issues vouchers for shelters to homeless persons at nearby motels to
complement the Salvation Army.
City of West Covina 17
Responsible Agency: West Covina Public Services Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund and Community Development Block Grants
Objectives:
• Provide in CDBG funding to care providers and associated facilities.
• Provide referrals to the local organizations that serve the homeless. Also provide
informational materials about tenant and landlord housing rights at City Hall, in the
City's newsletter (Discover West Covina), on the City's website and in other public
places to increase awareness.
Program 4.5 — Housing for Persons with Disabilities
The housing needs of persons with disabilities, including persons with developmental
disabilities are typically not addressed by Title 24 Regulations. The housing needs of persons
with disabilities, in addition to basic affordability, range from slightly modifying existing units
to requiring a varying range of supportive housing facilities. To accommodate residents with
developmental disabilities the City will seek State and Federal monies, as funding becomes
available, in support of housing construction and rehabilitation targeted for persons with
disabilities, including developmental disabilities. West Covina will also provide regulatory
incentives, such as expedited permit processing and fee waivers and deferrals, to projects
targeted for persons with disabilities, including persons with developmental disabilities. To
further facilitate the development of units to accommodate persons with developmental
disabilities, the City shall reach out annually to developers of supportive housing to
encourage development of projects targeted for special needs groups. Finally, as housing
is developed or identified, West Covina will work with the San Gabriel/Pomona Regional
Center to implement an outreach program informing families within the City of housing and
services available for persons with developmental disabilities. Information will be made
available on the City's website.
Responsible Agency: West Covina Community Development Department and Public
Services Department
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund
Objectives:
Offer specific regulatory incentives throughout the planning period, when funding is
available, apply for funding at least twice during the planning period to encourage
development of unit specifically for persons with disabilities, will reach out annually
to special needs housing developers.
• Work cooperatively with the San Gabriel/Pomona Regional Center to publicize
available services.
City of West Covina 18
Meeting the housing needs of all residents of the community requires the identification of
adequate sites for all types of housing. By capitalizing on the allowances in the
Development Code and continuing to maintain an inventory of potential sites, the City will
assure that adequate residentially zoned and mixed use sites are available.
Policy 5.1: Provide for a range of residential development types in West Covina, 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 5.2: Create mixed -use opportunities along key commercial corridors as a means of
enhancing pedestrian activity and community interaction.
Policy 5.3: Maintain zoning regulations that permit by -right, in designated zones, housing
that meets temporary and short-term housing needs for individuals and families.
Policy 5.4: Provide incentives to facilitate the development of senior housing options.
Policy 5.5: Require that housing constructed expressly for low- and moderate -income
households not be concentrated in any single portion of the City.
Policy 5.6: Explore opportunities for new residential development within those areas of the
City occupied by vacant or underutilized, obsolete commercial and industrial
uses.
Programs
Program 5.1 — Ensure Adequate Sites to Accommodate the RHNA
The City's analysis of sites with potential for additional residential development is presented
in Appendix B. That analysis demonstrates that there are adequate sites with sufficient
capacity to accommodate additional housing at all income levels commensurate with the
City's RHNA allocation for the 2021-2029 planning period.
Potential sites for lower -income housing are located in the Downtown area, which permits
high -density infill development. Development in the Downtown is guided by the Downtown
Plan and Code, which requires and encourages the development of high -density
residential uses and allows for a mixture of residential and non-residential development on
approximately 70 acres of the total 250-acre Downtown area. The Downtown Plan and
Code identifies sites that require residential development at a minimum density of 21
dwelling units per acre up to a maximum of 54 dwelling units per acre.
The sites inventory also includes parcels outside the Downtown that are suitable for
moderate- or above -moderate -income housing. The City is currently preparing a new
Development Code that will update regulations for sites outside the Downtown.
City of West Covina 19
To encourage the development of residential projects with affordable units, the City will
continue to meet with land owners to facilitate redevelopment on sites within the
Downtown and other areas. To further encourage development, the City may offer a menu
of incentives including: development fee modifications, fast track processing, density bonus
incentives, flexible development standards, and funding for off -site improvements, as
indicated in the Housing Plan. Due to the State dissolution of redevelopment agencies,
funding for these regulatory and financial incentives will be provided through CDBG and
other grant funds. The City will also prioritize funding for projects that incorporate units for
extremely -low-income households and persons with special needs.
In conformance with Government Code §65583.2(c), for any underutilized site identified in
the prior Housing Element, residential development shall be allowed on the site by -right if at
least 20% of units are affordable to lower -income households.
Pursuant to Government Code §65583.2(g)(3), for any development project on a
nonvacant site identified in the sites inventory that currently has residential uses, or within
the last five years have had residential uses that have been vacated or demolished, and
were either rent or price restricted, or were occupied by low- or very -low-income
households, replacement of those units affordable to the some or lower income level shall
be required as a condition of development approval consistent with State Density Bonus
Law.
Responsible Agency: West Covina Planning Division
Time Frame: 2021-2029; completion of the Development Code update by
2024
Potential Funding Source: General Fund
Objectives:
• Facilitate housing development commensurate with the RHNA allocation
• Make the vacant and underutilized residential sites inventory available to housing
developers on the City's website.
• Monitor development to ensure that adequate sites are available throughout the
planning period.
• Require replacement of lower -income units displaced due to redevelopment
Program 5.2 — Encourage Lot Consolidation
Parcels identified as housing opportunity sites within the Downtown range in size from
approximately 0.5 acres to 7 acres and in some cases are narrow or shallow in size, which
could be seen as an additional constraint to the development of housing. To encourage
the development of residential and mixed -use projects, the City encourages lot
consolidation through incentives such as a reduction in development standards (i.e., lot size,
parking, and open space requirements) to merge adjacent lots. When funds are available,
the City may also offer to subsidize a portion of development fees to encourage lot
consolidation and to promote more intense residential and mixed -use development on
City of West Covina 20
vacant and underutilized sites within the Downtown. The City will promote the program at
City Hall, on its website and will evaluate requests for funding on a case -by -case basis.
Responsible Agency: West Covina Planning Division
Time Frame: Ongoing, 2021-2029
Potential Funding Source: General Fund
Objectives:
Encourage lot consolidation of smaller parcels to accommodate projects including
a minimum of 16 units at a density of at least 30 dwelling units per acre or higher.
Program 5.3 — Local Agency Surplus Land for Affordable Housing
During the disposal of surplus land, the City or the Successor Agency shall negotiate in good
faith with entities that respond to the local agency's offer to sell or rent surplus property,
pursuant to Government Code §54222. Land sold for affordable housing shall be required
to provide 25% of the units at affordable housing cost to lower -income households and to
maintain the affordable housing units within the development at a cost to lower -income
households for a period of at least 55 years.
Responsible Agency: Successor Agency of the West Covina Redevelopment Agency
Timeframe: Ongoing, 2021-2029
Potential Funding Source: Sale or rent of City or Successor Agency surplus properties
Objectives:
• Prioritize use of surplus property sites to increase the supply of housing affordable to
lower -income households.
2.2 Quantified Objectives
State housing law requires that to the extent feasible, each jurisdiction establish the number
of housing units that can be constructed, rehabilitated, and preserved over the planning
period. The Quantified Objectives for this Housing Element reflect the planning period from
October 5, 2021 to October 15, 2029.
It is important to note that while the City must identify quantified objectives, the City of West
Covina cannot guarantee that these objectives will be met given the limitations on financial
and other resources, both at the City level and for other governmental resources.
Achievement of the City's assigned regional housing needs will heavily depend on a variety
of factors beyond the City's control, including private decisions of property owners and
developers and resources provided by State, Federal and County programs to support the
needs of the extremely low-, very -low-, low-, and moderate -income households.
Additionally, broad economic forces heavily influence the housing market. Accordingly,
State law recognizes that cities may not achieve their assigned shares of regional housing
need.
City of West Covina 21
Table 2-1 2021-2029 Quantified Objectives
(a) Construction objectives represent the City's 2021-2029 RHNA allocation
(b) Any CDBG funding received during the planning period will be used to fund projects that improve and
maintain the quality of the City's housing stock and residential infrastructure.
(c) At -risk units.
City of West Covina 22
Section 3
.........................................................................................................................
Housing Needs Assessment
3.1 Introduction
Incorporated in 1923 the development of West Covina began in earnest with the post -World
War II housing boom. The growth of the City continued through the 1950s and 1960s
paralleling the suburbanization of the eastern half of San Gabriel Valley. Suburbanization
played a large role in shaping the development of the City, shifting the City away from a
more traditional development consisting of a densely concentrated commercial center
downtown surrounded by housing whose age increases the further the unit is from the
downtown. The City is instead, characterized as a series of residential neighborhoods, with
commercial districts along arterial streets and large, regional commercial (primarily retail)
centers along either side of the San Bernardino Freeway (Interstate 10).
Although the City of West Covina was incorporated in the 1920s, there are few remaining
structures in the City that pre -date the 1940s. The western and northern portions of the City
bordering Baldwin Park and Covina more predominately contain the neighborhoods with
older homes. These sections of the city include residences on smaller lots, many of which
have lower property values. Some of the residences in these older neighborhoods are in
need of improvements and rehabilitation due to their age. In contrast, the eastern portion
of the City is characterized by newer more expensive housing typically on larger lots. These
wealthier neighborhoods are most commonly located the hillside areas bordering the City
of Walnut where many of the neighborhoods were developed from the subdivision of old
estates and ranches.
Historically, the City of West Covina has provided affordable housing alternatives to the
"closer in" Los Angeles communities of Pasadena, San Marino, Monterey Park, and Arcadia.
For much of the 20th century it was relatively easy for the average household to find a
reasonably priced home in the City. This changed, however, by the 1980s as the disparity
between income and housing cost had increased rapidly largely due to the increased
demand for housing throughout the Southern California region. The gap between housing
and income increased further in the latter part of the 1990s when Southern California
experienced a significant economic boom. The beginning of the 21 It century brought with
it a significant economic upturn and consequently housing prices in West Covina more than
doubled between 2000 and 2007. Following several years of economic decline during the
"Great Recession" the local economy stabilized and the housing market has strengthened
considerable in the past few years.
City of West Covina 23
The economic base of West Covina is dominated by regional and local retail, service -
oriented businesses, and health care establishments. While other types of commercial and
industrial land uses exist in the City, roughly two-thirds of the jobs in West Covina are retail
and service -related.
3.2 Data Sources
The primary data sources used for the Needs Assessment include the U.S. Census and
American Community Survey (ACS), the federal Department of Housing and Urban
Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), California
Department of Finance, and the Southern California Association of Governments (SCAG).
3.3 Population Trends and Characteristics
3.3.1 Population Growth Trends
According to recent California Department of Finance estimates, West Covina had a 2020
population of 105,999 including 674 living in group quarters. Over the period 2000-2020 West
Covina's population increased only slightly (Figure 3-1).
Figure 3-1
a
c
Population Trends 2000-2020 - West Covina vs
108.5
108.0
107.5
107.0
106.5
106.0
105.5
105.0
104.5
104.0
103.5 2000 2005 2010 2015 20M
West Oovim 105.080 107,955 106,098 107,720 105,999
—SCAG 16,516,703 17,541,873 18,051,534 18,731,901 19,021,787
CA DOF E-5 Population and Housing Unit Estimates
SCAG Region
19.5
19.0
18.5
18.0
17.5 c
17.0 9
16.5
16.0
15.5
15.0
3.3.2 Age Composition
The age composition of a population is an important factor in evaluating housing needs.
The traditional assumption in many communities is that young adults tend to prefer
apartments, low- to moderate -cost condominiums, and smaller or more affordable single-
family units. In comparison, it is assumed that mature adults provide the market for
moderate- to high -end condominiums and single-family homes. Finally, the senior
population tend to generate demand for low- to moderate -cost apartments and
condominiums, community residential settings, and mobile homes.
According to recent Census estimates the population of West Covina is about 48.5% male
and 51.5% female. The share of the population of West Covina under 18 years of age is
21.8%, which is lower than the regional share of 23.4%. West Covina's seniors (65 and above)
City of West Covina 24
make up about 15% of the population, which is higher than the regional share of 13% (Figure
3-2).
Figure 3-2 Population by Age and Gender— West Covina
5,000
4,000
3,000
2,000
1,000
0
1,000
2,000
3,000
4,000
5,000
•Male —Female
American Community Survey 2014-2018 5-year estimates
3.3.3 Employment Characteristics
Employment is an important factor that affects a household's income and ability to secure
housing. West Covina residents are employed in a variety of industries, with the largest
percentage of the population employed in the education and social services sector (Figure
3-3).
Figure 3-3 Employment by Industry —West Covina
Agrlwlture
, 330
Gor15bYC
2,789
Manufacuring
5.332
Wholesale Wade
Z240
Retail Trade
6?48
Trartrsportatm
3,068
Information
1,115
Fhente
3,370
Profrsfonal Services
5,048
Educauon 6 Social Services
Am, Entertainment, Recreation
4,90E
Olher
2,302
Public Admminsuution
2.479
12,472
0 2000 4,000 6,000 8,000 10,000 12,000 14,000
American Community Survey 2014-2018 5-year estimates using groupings of 2-digit NAICS codes.
Employment by occupation for West Covina residents compared to the SCAG region as a
whole is shown in Figure 3-4. The most common occupational category in both the city and
the region is management.
City of West Covina 25
Figure 3-4 Employment by Occupation -West Covina
40.0%
35.0%
30.0% van,
25.0%
200% •air'. ooss_
urs sa. m
1o.o%
s.ax.
001% Mw gernent Services Stiles Nati•al Resource: Production
- West Cou,na 35.2'% 17.4'% 27.7X. 6.6, 13.1%
• SCAG 34.2'% 19.6% 2289. 8.8% 14.6%
- West ONIM • SCAG
American Community Survey 2014-2018 5-year estimates using groupings of SOC codes.
3.4 Household Characteristics
Before current housing problems can be understood and future needs anticipated, housing
occupancy characteristics need to be identified in the City. The following is an analysis of
household types and sizes, and other household characteristics that may affect housing
needs.
3.4.1 Household Size
Household composition and size are often two interrelated factors as communities with a
large proportion of families with children tend to have a large average household size. Such
communities have a greater need for larger units with adequate open space and
recreational opportunities for children.
Figure 3-5 illustrates the range of household sizes in West Covina for owners, renters, and
overall. The most commonly occurring household size is two people (25.2%) and the second -
most commonly occurring household size is three people (21.2%). West Covina has a lower
share of single -person households than the SCAG region overall (15.6% vs. 23.4%) and a
higher share of 7+ person households than the SCAG region overall (3.6% vs. 3.1 %).
Figure 3-5 Household Size by Tenure —West Covina
30.0%
� o g B
d 250%
U N
m 20.0% $
N <
15.0%
10.0% Om
L 0 N
N O
0 5.0%
0.0%
1 2 3 4 5 6
Number of People per Household
■Renter ■Owner •Total
American Community Survey 2014-2018 5-year estimates.
7+
City of West Covina 26
3.5 Housing Inventory and Market Conditions
This section summarizes the existing housing stock in West Covina and prevailing market
conditions.
3.5.1 Housing Type
Diversity in the types of housing available within a community promotes equal housing
opportunity for persons of all income levels. A balanced housing stock allows households of
all income levels, age, and size the opportunity to find housing suited to their needs.
According to recent Census estimates (Figure 3-6), the most prevalent housing type in West
Covina is single-family detached. The share of all single-family units in West Covina is 74.1 %,
which is higher than the 61.7% share in the SCAG region as a whole. The overall vacancy
rate is about 4.5% and the average household size (as expressed by the population to
housing unit ratio) is approximately 3.35.
Figure 3-6 Housing Units by Type —West Covina
1D0%
90%
n 6o%
70%
21.=
0 6D%
50%
6 40%
30%
6.960
20%
10%
3,117
1,235
345
on
W M
� M
(%
Sine-Famiy
Single -Family
MJlifamily,2-4
Multlfamily, 5+ Mobile Hanes
Detached
Attached
Units
Units
■West Covina, l%)
64.6%
9-5%
38%
2L1% L0%
. SCAC (%)
54.4%
72%
7.5%
27.3% 3.5%
CA DOF E-5 Population and Housing Unit
Estimates
3.5.2 Tenure
Housing tenure refers to whether a given unit is owned or rented. According to recent
Census estimates, nearly two-thirds of housing units in West Covina were owner -occupied
compared to only about 53% for the region as a whole (Figure 3-7). Figure 3-8 shows the
relationship between tenure and the age of West Covina residents. The majority of residents
under age 35 are renters while most older residents are homeowners.
City of West Covina 27
Figure 3-7 Housing by Tenure —West Covina vs. SCAG Region
70.OX. 64.1%
6ODY. --
z
0 40.OX.
E
L 30.0%
� 20.0%
10.0%
o.ox
West CMM
■ Owner ('z) - Renter i
American Community Survey 2014-2018 5-year estimates.
Figure 3-8 Housing Tenure by Age —West Covina
5,000
4,500
4,000
3,500
a 3,000
2,500
o' 2,000
i
1,500
1,000
500LLLL
J
0 0-24 25,34 35-44 45-54 55-59 6064 65-74 7584 85•
■Owner 50 L255 3,069 4,439 2,658 2,324 3,479 1,534 782
■Renner 481 2,392 2,559 2217 964 775 784 619 1W
American Community Survey 2014-2018 5-year estimates.
3.5.3 Vacancy Rates
Vacancy rates indicate how well the types of housing units that exist in the City meet the
current market demand for housing. A low vacancy rate suggests that households may
have difficulty finding a unit within their price range due to a limited supply of available
housing. Low vacancy rates may also be related to overcrowding, as discussed in later
sections. In contrast, a high vacancy rate may indicate either the existence of a high
number of units undesirable for occupancy, or an oversupply of housing units. Figure 3-9
shows recent data regarding vacant housing units in West Covina as compared to the
SCAG region as a whole.
City of West Covina 28
Figure 3-9
45%
n 90%
9 35%
E 30%
a
25%
20%
6 15%
110%
5%
0%
Vacant Units by Type — West Covina vs. SCAG Region
38.6%
20.7%
6.1% 5.4%
6.6% 7-9%
■ ■
am
For RM Rented
For Sale
40.1%
33.5%
27.7%
33%45% 5-3X,
- ■ . OOP. 0.3'X, It
Sdtl Seasonal Migrant Other
• West Covina ■SCAG
American Community Survey 2014-2018 5-year estimates.
3.5.4 Age of Housing Stock
The age and condition of the City's housing stock provides an additional measure of
housing adequacy and availability in many communities. Although age does not always
correlate with substandard housing conditions, neighborhoods with a large proportion of
the housing stock over 40 years old are more likely than newer neighborhoods to have a
concentration of housing problems related to deferred maintenance, inadequate
landscaping care, outdated utilities or interior amenities, and a need for housing
rehabilitation.
The age of housing can be an indicator of the current condition of the housing unit. Well -
constructed homes typically show signs of deterioration and require repair after 30 years if
not adequately maintained. This timeframe can be shortened depending on the
construction techniques and other factors such as weather conditions. Figure 3-10 indicates
that more than two-thirds of the City's housing stock was built before 1980.
Figure 3-10 Year Structure Built — West Covina vs. SCAG Region
40%
35%
n 30%
z 25%
S
20%
15%
8 10%
5% j r � J
2014 6 2010 2000- 1990- 1980- 1970 1960- 1950- 1940- 1939 &
Leter 2013 2009 1999 1989 1979 1969 1959 1949 Enrber
West ODwint('%) L1%. 0.5% 2.7% 6.6'% 12.39. 21.3'% 12.2'% 37.6% 3.4% 2.3%
SCAG (%) 10% L5% 10.1% 9.5% 15.0% 16.3% 14.5% 15.9% 6.9% 9.3%
■ West Covina (%) •SCAG (%)
American Community Survey 2014-2018 5-year estimates.
3.5.5 Housing Conditions
Housing is considered to be substandard when physical conditions are below the minimum
standards of living defined by Section 1001 of the Uniform Housing Code. Residents living in
City of West Covina 29
substandard conditions are considered to be in need of housing assistance even if they are
not actively seeking alternative housing arrangements.
In general housing units range in the types of features they offer and depending on the year
they were built and the quality of construction they can lack basic amenities such as a
complete kitchen, and/or plumbing facilities.
Because roughly 80% of the City's housing stock is more than 40 years old, it is likely that a
large number of homes are in need of rehabilitation. A general reconnaissance of older
neighborhoods in the City suggests that between 2% and 3% of the City's housing stock is in
need of repair, while fewer than a dozen homes may be in need of replacement.
3.6 Housing Costs
The following section discusses recent data regarding owner and rental housing cost in West
Covina.
3.6.1 Owner -occupied Housing
Housing costs in West Covina can vary substantially by neighborhood. In general, western
and northern portions of the City that border Baldwin Park and Covina contain
neighborhoods with housing that is older and substantially lower in cost than neighborhoods
in eastern and southern portions of the community bordering the City of Walnut. The latter
parts of West Covina include hillside areas that have developed from former ranches and
large estates. Consequently larger, more expensive homes on larger lots are common. In
general, housing in eastern and southern West Covina is newer than in the western and
northern parts of the City although there are exceptions where redevelopment of residential
areas has occurred.
Figure 3-11 shows housing sale price trends in West Covina compared to the SCAG region
as a whole during 2000 to 2018. During this period, median home sales prices in West Covina
increased 192% while prices in the SCAG region as a whole increased 151 %. 2018 median
home sales prices in West Covina were $545,000 and the highest experienced since 2000
was $545,000 in 2018. Prices in West Covina have ranged from a low of 83.6% of the SCAG
region median in 2000 and a high of 112.9% in 2009.
City of West Covina 30
Figure 3-11 Median Home Sales Prices for Existing Homes 2000-2018 —West
Covina vs. SCAG Region
S-
00o Doti Doti oo� ooa �h oo� � o00 otio otiti o,>ti Nti otia 11, op oy otie
M1 1 M1 M1 ry M1 ti ti ti ti M1 M1 'ti ti ti ry M1 M1 ry
120.0%
100.0%
ea.0%
60.0%
40.0%
20.0%
0.0%
Wes[ Cana � SCAG — — — West Canna PercefflW of SCAG Price
SCAB Local Profiles, Core Logic/Data Quick. SCAG median home sales price calculated as household -weighted average of county
medians.
As shown in Figure 3-12, the most common monthly cost for homeowners with a mortgage
in both West Covina and the region as a whole is $2,000-3,000.
Figure 3-12 Monthly Owner Costs for Mortgage Holders — West Covina vs.
SCAG Region
5% 13 g%5.1%
5% OA%0.5% - ■
<$500 $50031000
41.4%
h
z,
24,5:.
i
a I
$100051500 $00042000 $2000-f3000
Mortgage - Monthly Pnyr m
■ West Covina ■SCAG
American Community Survey 2014-2018 5-year estimates.
14.2J5.4%
''
12.34
a.s% '
$3000-$4000
>$4000
As housing demand continues to surpass supply, the cost of housing in Southern California
is expected to remain high in comparison to the nation as a whole. This is of great concern
not only for lower -income families who often cannot afford a large down payment but is
increasingly impacting middle class and workforce families (e.g., teachers, firefighters) who
have difficulty affording a decent home.
3.6.2 Rental Rates
Figure 3-13 shows recent Census estimates of rental costs as a percentage of income in
West Covina. The most common monthly rental expense is more than 50% of income, which
is considered by State and federal standards to be overpayment. As seen in Figure 3-14,
the percentage of household income spent on rent is typically higher for households at the
City of West Covina 31
lower end of the income spectrum. According to recent Census estimates, the median rent
in West Covina is approximately $1,674 per month.
Figure 3-13 Percentage of Income Spent on Rent - West Covina
3,500
3_ms
0 3,000
a
� 2,500
i° 2,000
1,632
g
1,500
],307
8
E
1,008
e 73
1000
z
500
_
1
e
1
'
453
164
,
1 ,
.0
�
<10% 1015% 15-20%
20-25% 25-30% 30-35% 3540%
4049%
>50% Not
Comprmed
Percent of Income Spent on Rent
Figure 3-14 Rental Cost by Income Category - West Covina
100>..
$ 90a`
8 80%
70%
60%
50%
o: 40%
20%
= 10%
0%
Less than
$20.000 to
$35,000 to
$5aoo0 to
$20,000
$34,999
$49,999
$74.999
■>5D%
1,336
1,346
503
81
■3049%
154
503
756
738
■20.29%
89
59
207
654
■<20%
23
16
11
191
Income Category
American Community Survey 2014-2018 5-year estimates.
3.6.3 Overcrowding
5,000 to $100.000 or
99.999
more
0
0
187
71
1,351
579
121
1,514
■>50%
■30d9%
■20-29%
■<20%
In response to higher home prices, lower -income households must often accept smaller
housing units. This can result in overcrowding, which places a strain on physical facilities,
does not provide a satisfying living environment, and can have an effect on local
neighborhoods. The US Census defines overcrowding as 1.01 or more persons per room, and
extreme overcrowding as more than 1.5 persons per room. Overcrowding typically results
when:
• A family or household is living in too small a dwelling;
• Familial household includes extended family members; and/or
• A family is renting living space to non -family members.
Overcrowding is often symptomatic of greater affordability issues. Some scenarios of how a
lack of affordability promotes overcrowded conditions include:
City of West Covina 32
• Large households unable to afford larger dwellings that must then move into smaller
than acceptable units;
• Older children wishing to leave home who are prohibited from doing so because
they cannot qualify for a home loan and/or are unable to make rental payments; or
• Grandparents or elders on fixed incomes who are unable to afford housing suitable
for their physical handicaps, and must often move in with their grown children or
other family members.
Figure 3-15 Overcrowding by Tenure — West Covina vs. SCAG Region
18.0%
• 16.0% 152% 15.6%
s
0 14.096
3 ]2.0%
m
10.0%
8.0% 6.4%
6.4.1% 0% 4.9% 4.9%
4.0%
2.0% . 3.0x 13%
0.0% Illllllllllllli•
1D•/roan L5+/romi 10•/room 15i/roan
0n Dnner Reimer Renter
■ West Covina ■ SCAG
American Community Survey 2014-2018 5-year estimates.
Figure 3-15 summarizes the status of overcrowding in West Covina compared to the SCAG
region as a whole. In West Covina, 4.1 % of owner -occupied households and 15.1 % of renter -
occupied households had more than 1.0 occupants per room, while an additional 1.0% of
owner -occupied households and 4.9% of renter -occupied households had more than 1.5
occupants per room. The rate of overcrowding in West Covina was slightly lower than the
regional average.
3.6.4 Overpayment
State and Federal standards specify that households spending more than 30% of gross
annual income on housing are experiencing overpayment. Overpayment may cause a
series of related financial problems, and can result in a deterioration of housing stock. Funds
that would be allocated for maintenance are instead sacrificed for more immediate
expenses (e.g., food, clothing, medical care, and utilities). Overpayment also leads to
overcrowding, which contributes to a variety of problems, from accelerating the rate of
deterioration, to children's decreased performance in school, to code enforcement issues.
Higher -income households are generally more able to secure housing within their budgets,
and are more capable of paying a larger proportion of their income for housing. Therefore,
housing overpayment estimates usually focus on lower income groups.
City of West Covina 33
Table 3-1 summarizes recent estimates of overpayment in West Covina by income category.
As may be expected, households in the lowest income categories had the highest rates of
overpayment.
Table 3-1 Overpayment by Income Category — West Covina
< 307. HAMFI
485
504
2,960
30-50% HAMFI
1,020
1,449
1,705
50-80% HAMFI
2,595
2,320
867
80-100% HAMA
2,505
1,095
149
> 100% HAMFI
11.240
1.320
153
HUD CHAS, 2012-2016. HAMFI refers to Housing Urban Development Area Median Family Income.
3.7 Special Needs Groups
State law identifies several categories of persons as having special needs that must be
addressed in the Housing Element. These include the elderly, persons with disabilities,
including developmental disabilities, large families with 5 or more persons, female heads of
household, the homeless, and farmworkers.
3.7.1 Elderly
Federal housing data define a household type as 'elderly family' if it consists of two persons
with either or both age 62 or over. The special housing needs of the elderly are an important
concern in West Covina, particularly as the number of elderly persons in the City increases.
The elderly population is a crucial group as retired persons are more likely to be on fixed low
incomes, have disabilities, and/or experience housing overpayment. The special housing
needs of the elderly also extend to the construction and location of units. The elderly often
require housing features such as ramps, handrails, lower cupboards and counters to allow
access and function. Similarly, the elderly often find it more difficult to access public facilities
(i.e., medical and shopping) due to limited mobility. Finding reliable means of transportation
to medical appointments, senior centers, meal sites and shopping also remains a serious
problem for many seniors. This can be alleviated by locating units close to the amenities
commonly used by the elderly.
Table 3-2 shows that about 23.8% of elderly households in West Covina earn less than 30%
of the surrounding area income, (compared to 24.2% in the SCAG region), 44.5% earn less
than 50% of the surrounding area income (compared to 30.9% in the SCAG region).
City of West Covina 34
Table 3-2 Elderly Households by Income and Tenure
<307.HAMFI
800
795
1,595
23.87.
30-50%HAMFI
990
395
1,385
20.7%
50-80%HAMFI
935
260
1,195
17.8%
80-100%HAMFI
595
120
715
10.7%
> 10007 HAMFI
1.575
230
1.805
27.007.
HUD CHAS, 2012-2016. HAMFI refers to Housing Urban Development Area Median Family Income.
3.7.2 Large Families
Large families are defined as those with five or more persons. Large families require special
consideration, because they generally require larger dwellings with sufficient bedrooms to
meet their housing needs without overcrowding.
According to recent Census estimates, large families represented about 3,856 (20%) owner -
occupied households and about 2,270 (21%) renter -occupied households in West Covina.
Difficulties in securing housing large enough to accommodate all members of a household
is more challenging for renters, because multi -family rental units are typically smaller than
single-family ownership units. While apartment complexes in the City offering three
bedrooms are common, apartments with four or more bedroom units are rare. It is more
likely that a large family will experience overcrowding in comparison to smaller families.
3.7.3 Female -Headed Households
Female -headed households are considered a special needs group because women
leading families have proportionally lower rates of homeownership, lower incomes and
higher poverty rates than other family compositions. Figure 3-16 indicates characteristics of
the female -headed households in the City of West Covina. According to recent Census
estimates, about 16.3%of West Covina households are female -headed (compared to 14.3%
in the SCAG region), 6% are female -headed and with children (compared to 6.6% in the
SCAG region), and 0.9% are female -headed and with children under 6 (compared to 1.0%
in the SCAG region).
About 5.2% of West Covina's households are experiencing poverty, compared to 7.9% of
households in the SCAG region. Figure 3-17 shows estimated poverty rates for female -
headed households in West Covina.
City of West Covina 35
Figure 3-16 Female -Headed Households — West Covina
FHH w/children under 6 ' 0.9%; 281
FHH w/children - 6.0%; 1822
Total FHH 16.3%; 4980
Total Households
O 5000 10000 15000 20000 25000
Percent of total househrds; Nunber of households
American Community Survey 2014-2018 5-year estimates.
30513
Figure 3-17 Female -Headed Households by Poverty Status — West Covina
Female4ieaded with 3 or more children _ O4, 126
Female -headed with children 1.3t.; 387
Femnle-headed
Total Io ehods in poverty
20%; 607
5.2%; 1,597
O 200 400 600 800 L OOO 1.200 1,400 1,600 1,800
Percent of total Ihouselholds; Number of households
American Community Survey 2014-2018 5-year estimates.
3.7.4 Persons with Disabilities
Access and affordability are the two major housing needs of persons with disabilities.
Disabilities often require special features in dwelling units to allow mobility. California
Administrative Code Title 24 sets forth some access and adaptability requirements to
address mobility issues.
Figure 3-18 shows recent Census estimates of the types of disabilities affecting West Covina
residents while Figure 3-19 shows disabilities among senior citizens. Approximately 39% of
West Covina residents with a disability are in the labor force.
Figure 3-18 Disability by Type — West Covina
Independent Living 4,672
Selfc re 2,798
Ambulatory 1 6,108
copmve 4,156
Vision 1,727
Henning 2,783
0 1,000 2,000 3,000 4,000 5,000 6,000 7,000
American Community Survey 2014-2018 5-year estimates.
City of West Covina 36
Figure 3-19 Disability by Type for Seniors - West Covina vs. SCAG Region
30.0%
25.0% 24.07f_.
a
9
20.0% 18.47117.5%
£ 15.01A
y 10.19It0.1% 10.0g40.5%
102%
8 5.4% fi.6X
5.0% 1
0.0%
Hearing VWM Oaomve Ambulatory Selfr m Indepmdent Lim%
■ West Covina Per ■SLAG Region Pem:
American Community Survey 2014-2018 5-year estimates.
Table 3-3 Disability by Employment Status -West Covina
With a Disability �
Percent of Total
No Disability Percent of Total
Employed
1,695
35%
47,582 76%
Unemployed
205
4%
3,375 5%
Not in Labor Force
2,894
60%
11,948 19%
Total
4,794
-
62,905 -
American Community Survey 2014-2018 5-year estimates
According to the Department of Social Services there are approximately 22 residential care
facilities in West Covina to serve the needs to those with disabilities.
Both the federal Fair Housing Act and the California Fair Employment and the Housing Act
impose an affirmative duty on local governments to make reasonable accommodations
(i.e., modifications or exceptions) in their zoning and other land use regulations when such
accommodations may be necessary to afford disabled persons an equal opportunity to
use and enjoy a dwelling. The City Zoning Code establishes a formal procedure to consider
applications for reasonable accommodation.
3.7.5 Developmental Disabilities
According to Section 4512 of the Welfare and Institutions Code, a "Developmental
disability" means a disability that originates before an individual attains age 18 years,
continues, or can be expected to continue, indefinitely, and constitutes a substantial
disability for that individual which includes mental retardation, cerebral palsy, epilepsy, and
autism. This term shall also include disabling conditions found to be closely related to mental
retardation or to require treatment similar to that required for individuals with mental
retardation, but shall not include other handicapping conditions that are solely physical in
nature.
Many persons with developmental disabilities can live and work independently within a
conventional housing environment. More severely affected individuals may require a group
living environment where supervision is provided. The most severely affected individuals may
City of West Covina 37
require an institutional environment where medical attention and physical therapy are
provided. Because developmental disabilities exist before adulthood, a major issue in
supportive housing for persons with a developmental disability is the transition from the
person's childhood living situation to an appropriate level of independence as an adult.
The State Department of Developmental Services (DDS) provides community -based
services to persons with developmental disabilities and their families through a statewide
system of 21 regional centers, four developmental centers, and two community -based
facilities. The San Gabriel/Pomona Regional Center is one of 21 regional centers in the State
of California that provides point of entry to services for people with developmental
disabilities. The center is a private, non-profit community agency that contracts with local
businesses to offer a wide range of services to individuals with developmental disabilities
and their families.
Table 3-4 shows recent data regarding persons with a developmental disability in the City
of West Covina.
Table 3-4 Developmental Disabilities - West Covina
By Residence
Home of Parent/Family/Guardian
981
Independent/Supported Living
79
Community Care Facility
182
Intermediate Care Facility
49
Foster/Family Home
26
Other
5
By Age
0-17 years
1,322
18+ veors
558
CA Dos consumer count by CA ZIP as reported by SCAG, June 2019.
To address the housing needs for persons with developmental disabilities, the Housing Plan
includes Program 2.3 - Alternative Housing Models and Program 3.1 - Reduce
Governmental Constraints. The City will continue to coordinate with the San
Gabriel/Pomona Regional Center and encourage housing providers to designate a portion
of new affordable housing developments for persons with disabilities, especially persons with
developmental disabilities, and pursue funding sources designated for persons with special
needs and disabilities.
3.7.6 Extremely -Low -Income Households
Housing the extremely -low-income population (below 30% of area median income) can be
especially challenging. HUD's CHAS dataset provides information on such households in
West Covina. Table 3-5 provides a breakdown of households by income category, tenure
and degree of overpayment. This table shows that households in the lowest income
categories, especially renters, experience a very high level of cost burden. According to
SCAG tabulations, the race/ethnicity with the highest share of extremely -low-income
households in West Covina is Black, non -Hispanic (16.9% compared to 13.7% of total
City of West Covina 38
population). In the SCAG region, the highest share of extremely -low-income households is
Black, non -Hispanic (27.1 % compared to 17.7% of total households).
Table 3-5 Extremely -Low -Income Households by Tenure —West Covina
burden
Cost burden >)
Income by Cost Burden (Renters only)
Total
> 30%
50%
Household Income less -than or- 30% HAMFI
1,970
1,760
2,300
Household Income >30% to less -than or- 50%
1,810
1,175
2,045
HAMFI
Household Income >50% to less -than or- 80°k
1,355
255
2,150
HAMFI
Household Income >80% to less -than or-100%
255
15
1,275
HAMFI
Household Income >100% HAMFI
115
3,175
Total
5,505
3,205
10,945
Cost burden
Cost burden >Total>
Income by Cost Burden (Owners only)
30%
50%
Household Income less -than or- 30% HAMFI
965
805
1,305
Household Income >30% to less -than or- 50%
1,100
760
1,690
HAMFI
Household Income >50% to less -than or- 80%
1,850
755
3,180
HAMFI
Household Income >80% to less -than or- 100%
955
140
2,145
HAMFI
Household Income >100% HAMFI
1,345
175
11,245
Total
6,215
2,635
19,570
There are limited opportunities to address the housing needs of extremely -low-income
households in West Covina. However, the needs of this special needs group are taken into
consideration and are generally addressed through the City's overall programs for housing
affordability. The City also provides a number of deed -restricted units that offer housing
opportunities for ELI households.
3.7.7 Homelessness
Homelessness continues to be a regional as well as a national issue. Enumerating the total
number of homeless is difficult due to the transient nature of the population, as well as the
existence of the hidden homeless. The term hidden homeless refers to individuals that are
not necessarily on the street and are often not counted in homeless surveys. These
individuals typically reside in temporary housing situations (e.g., doubling up with another
household or in motels).
To better address and serve the homeless population, the Los Angeles Homeless Services
Authority (LAHSA) was established in 1993 as an independent agency by the County and
the City of Los Angeles. LAHSA periodically conducts a point -in -time survey to count the
City of West Covina 39
number of homeless individuals, sheltered or unsheltered, living throughout Los Angeles
County. West Covina is within LAHSA's Service Planning Area (SPA) 3.
The most recent data available for the City of West Covina (January 2020) estimated that
there were approximately 124 homeless persons individuals in the city and 5,082 homeless
persons in SPA 3.
There are numerous factors that contribute to homelessness in West Covina and Los Angeles
County. Difficulties in obtaining employment, insufficient education, mental illness, and
substance abuse are a few of the more traditional factors. The rapid increase in housing
costs during the last few years has also contributed to homelessness.
Emergency shelters, low barrier navigation centers and transitional or supportive housing
help to address the needs of the homeless. Services and facilities available for the homeless
in West Covina are coordinated primarily through the Los Angeles County continuum of
care, which 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 following agencies offer homeless assistance in and around West Covina:
• Citrus Valley Health Foundation provides a drop -in center where homeless persons
can access a wide variety of services. The Foundation also serves the terminally ill
and those in need of short-term acute care.
• The Institute for Urban Research and Development provides emergency shelter,
breakfast and dinner, access to showers and toilets, limited case management
services, and referrals to more comprehensive services to homeless families. IURD is
housing participants at the Valley Inn in La Puente and the American Inn & Suites in
Pomona.
• Catholic Charities Brother Miguel Center in Pomona provides vouchers/assistance
referrals for those seeking shelter. They also provide utility disconnection and eviction
prevention services, along with other counseling, training, and emergency/food
assistance.
• YMCA -Wings Shelter for Battered Women located in West Covina provides shelter,
counseling, and other needs of battered women and their children.
• The House of Ruth in Claremont provides services to women and their dependent
children.
• Community Food Bank of West Covina provides assistance and emergency help for
West Covina residents in need of food.
• The Salvation Army offers temporary shelter and food vouchers and referrals for West
Covina and San Gabriel residents. Adult rehabilitation centers are among the most
widely known of all Salvation Army services and comprise the largest resident
City of West Covina 40
rehabilitation program in the United States. Individuals with identifiable and treatable
needs are able to check -in to facilities that assist them in becoming healthy. At the
center they receive adequate housing, nourishing meals and necessary medical
care, and they engage in work therapy. They also benefit from group therapy,
spiritual guidance and skilled addictions counseling in clean and wholesome
surroundings.
• Inland Valley Council of Churches serves homeless families through their emergency
shelter and transitional housing programs. Those in need of shelter are able to stay a
maximum of 30 days while those using the transitional housing are able to stay
between 12 and 24 months.
• The Santa Anita Family Services Senior Center serves low-income elderly with
temporary personal care, in -home care during illness, respite for family caregivers,
employment assistance, housekeeping, and assistance in filling out forms or with
other legal matters. They also offer minor home renovation for low-income seniors
with physical limitations.
• The East San Gabriel Valley Coalition for the Homeless is a nonprofit organization,
helping the homeless find shelter. They offer referral services for medical
appointment, hotel and motel and taxi vouchers, emergency food, sack lunches,
showers and hygiene kits. They also offer referral assistance for paying rent and
utilities. The Coalition also offers a Cold Weather Shelter that runs from mid -November
until the end of March.
The City's zoning regulations related to facilities serving the homeless, including emergency
shelters, low barrier navigation centers, transitional housing and supportive housing, are
discussed in Section 4.1.6 Other Housing -Related Regulations.
3.7.8 Farmworkers
Like many other cities in Southern California, West Covina's economy was at one time linked
to agriculture. Changes in the local economy to production and service -oriented sectors
have virtually eliminated significant agricultural production within City limits. The Census of
Agriculture from the US Department of Agriculture (USDA) documented that out of
California's approximate 377,500 agricultural workers, less than 1% (3,266) were located
within Los Angeles County as of 2017. While Los Angeles County still has areas with
agricultural activity, farmland in West Covina has been almost entirely converted as the City
reaches buildout. Consequently, many of the remaining agricultural uses are specialty
nurseries or stables, which do not employ migrant farmworkers. Recent Census estimates
reported 224 total jobs in the farming, fishing and forestry occupations held by West Covina
residents, of which 164 were full-time year-round jobs (Table 3-6). City regulations regarding
farmworker housing are discussed in Chapter 4.
City of West Covina 41
Table 3-6 Agricultural Employment —West Covina
Farmworkers by Occupation:
d
totalWest
We"
Covina
Covku.
workers:
8CA3Total
224
0.43%
57,741
Total jobs: Farming, fishing, and forestry occupations
164
0.45%
31,521
Full-time, year-round jobs: Farming, fishing, and forestry occupations
Employment in the Agricultural Industry:
Percent of
total West
West
Covina
Covina
workers:
SCAO Total
293
0.57%
73,778
Total in agriculture, forestry, fishing, and hunting
267
0.74%
44,979
Full-time, year-round In agriculture, forestry, fishing and hunting
American Community Survey 2014-2018 5-year estimates using groupings of NAICS and SOC codes.
3.8 Housing At -Risk of Conversion to Market Rate
Under State housing law government -assisted low-income rental units that are eligible for
conversion to market rate housing during the 2021 to 2031 period are considered to be "at -
risk." Reasons for this conversion may include expiration of subsidies, mortgage pre-
payments or pay-offs, and concurrent expiration of affordability restrictions. Table 3-7 shows
assisted low-income rental units in West Covina. Of the 834 affordable units, 349 are
targeted for seniors. None of these projects is at -risk of conversion to market rate during
2021-2031.
Table 3-7 Affordable Housing Projects —West Covina
Project
Project Type
�•
Brookhollow Apartments
Non -targeted
85
LIHTC
2053
No
2600 S. Azusa Ave.
Lark Ellen Village
Large family
121
LIHTC; HUD;
2037
No
1350 E San Bernardino Rd.
CalHFA
The Promenade
Non -targeted
123
LIHTC
2070
No
1333 W GarveyAve N.
Vintage Gardens
Senior
186
LIHTC
2054
No
1950 Badillo St.
West Covina Senior Villas I
Senior
17
CalHFA
2035
No
1842 E. Workman Ave.
West Covina Senior Villas II
Senior
64
CalHFA
2102
No
1838 E. Workman Ave.
Cameron Park
Non -targeted
156
LIHTC; HUD
2073
No
929 W. Cameron Ave.
Olive Tree Terrace
Senior
82
HUD
2040
No
721 N. Azusa Ave.
Source: Calitomia Housing Partnership Corporation; City of West Covina, 2022.
City of West Covina 42
3.9 Future Housing Needs 2021-2029
The Regional Housing Needs Assessment (RHNA) is a key tool for local governments to plan
for anticipated growth. The RHNA quantifies the anticipated need for housing within each
jurisdiction for the 2021 to 2029 period, also referred to as the "6'h cycle" in reference to the
six RHNA cycles that have occurred since the comprehensive revision of State Housing
Element law in 1980. Communities then determine how they will address this need through
the process of updating the Housing Elements of their General Plans.
The 2021-2029 RHNA Plan was adopted by the Southern California Association of
Governments (SCAG) in March 2021. The need for housing is determined by the forecasted
growth in households in a community as well as existing needs such as overpayment and
overcrowding. The housing need for new households is adjusted to maintain a desirable
level of vacancy to promote housing choice and mobility. An adjustment is also made to
account for units expected to be lost due to demolition, natural disaster, or conversion to
non -housing uses. Total housing need is then distributed among four income categories on
the basis of the county's income distribution, with adjustments to avoid an over -
concentration of lower -income households in any community. Additional detail regarding
SCAG's methodology used to prepare the RHNA can be reviewed on SCAG's website at
https://scaa.ca.aov/rhna.
The City of West Covina's RHNA allocation is 5,346 additional housing units during the 2021-
2029 planning period, with those units distributed among the four income categories as
shown in Table 3-8. The City must demonstrate that its land inventory is sufficient to
accommodate the amount of additional housing assigned in the RHNA for each income
group (see Chapter 5 and Appendix B).
Table 3-8 Regional Housing Needs Assessment (RHNA) 2021-2029
Group
Number
PercentageIncome
Very Low*
1,653
25%
Low
850
16%
Moderate
865
17%
Above Moderate
1,978
42%
Total
5,346
100%
Source: Southern California Association of Governments, 2021.
*It is assumed that 50% (827 units) of the City's very -low-income RHNA will address the needs of extremely -low-
income households, earning less than 30%of the AMI.
City of West Covina 43
Section 4
Housing Constraints
Pursuant to State law, a Housing Element shall provide an analysis of existing and potential
governmental and non -governmental constraints on the improvement, maintenance, and
development of the housing stock. This analysis must include housing for all segments of the
population including all income levels and persons with special needs (such as the
homeless, disabled, and elderly). This analysis of potential housing constraints considers the
following:
• Governmental Constraints refers to those regulations, ordinances, and/or controls
that may impede the development of new housing or otherwise increase the cost of
residential development;
• Market Constraints refers to those economic and market factors that may affect the
cost of new housing development; and
• Environmental Constraints refers to those aspects of the environment (e.g., vacant
land, utilities, natural hazards) that may affect the cost and/or feasibility of
development.
4.1 Governmental Constraints
Local policies and regulations can affect the availability of housing and in particular, the
provision of affordable housing. Land use controls, site improvement requirements, fees and
exactions, permit processing procedures, and other factors can affect the maintenance,
development, and improvement of housing. State, federal and regional regulations, which
the City has no control over, also affect the availability of land for housing and the cost of
producing housing. Regulations related to environmental protection, building codes, and
other topics have significant, often adverse impacts on housing cost and availability. While
constraints exist at other levels of government, this section focuses on policies and
regulations that are under the control of the City.
It is important to note that the City of West Covina's intent is to find a balance between
implementing community standards and quality for new residential development, and
maintaining a development review process and appropriate regulations that do not
unreasonably constrain new residential construction. The City has been successful in
achieving that balance as evidenced by the construction of approximately 860 new
City of West Covina 44
residential units during the 2000-2020 period despite being "built -out" and experiencing the
negative economic effects on the housing market during the Great Recession.
4.1.1 Land Use Controls
Land use controls are policies, regulations, plans, and other methods of regulating the
possible uses and development of property, including such things as zoning, subdivision
regulations, and floodplain regulation. The two primary regulatory documents in West
Covina are the General Plan and Zoning Code (Title 26 of the Municipal Code).
General Plan
The General Plan, required by Government Code §65000 et seq., is a comprehensive, long-
range policy document that guides physical development in West Covina. State law
requires seven elements or chapters in the General Plan, including the Housing Element.
Each of the elements provides policy guidance for the built environment; however, the Land
Use Element has a direct relationship with allowable uses of property and development
standards. The Land Use Element provides the long-term vision and direction for land uses
and development through a series of goals, policies, and implementation measures. The
Land Use Element also includes a map with land use designations that describe the
distribution, density, and location of land uses in the City. Consequently, there is a significant
relationship between the Land Use Element and housing development in a City.
In 2016, the City adopted a comprehensive update to the General Plan (also known as Plan
WC). Plan WC implements the Transect system, which is system of natural -to -urban transect
zones or "human habitats." For each transect zone there is an equivalent land use
designation.
Through implementation of the General Plan, the City utilizes a number of planning tools
including specific plans, zoning regulations, and a subdivision ordinance. With these
documents, the City establishes more specific development standards, allowable uses, and
limitations. The West Covina General Plan provides for seven planning designations with
corresponding transect zones. General Plan residential land use designations express
densities as dwelling units per acre (du/ac). Table 4-1 describes the General Plan land use
designations that permit residential uses.
Table 4-1 General Plan Designations and Corresponding Transect Zones
Neighborhood Low
T3 Sub -Urban and T4
Emphasizes detached houses with some attached units in a
General Urban
small mix of building types from 0 up to 8 dwelling units per acre.
Predominantly residential, with opportunity for limited home
occupation and neighborhood services sensitively located
along corridors and at intersections.
Neighborhood
T3 Sub -Urban, T4
Anticipates a mixture of detached and attached dwellings and
Medium
General Urban, and
higher building types at approximately 9 to 20 dwelling units per
T5 Urban Center
acre. Predominantly residential with small scale commercial at
key locations, primarily at intersections and adjacent to corridors.
City of West Covina 45
Transect
Description
High
T3 Sub -Urban
Accommodates a broader mix of building types, primarily
through T6 Urban
attached, from 21 to 54 dwelling units per acre; A mix of
Core
residential, commercial, office, and entertainment that includes
mixed -use buildings.
Commerce
T4 General Urban
Encourages a wide range of building types of anywhere from
through T6 regional
two to six stories (depending on neighborhood characteristics)
center, urban core,
that house a mix of functions, including commercial,
neighborhood
entertainment, office and housing. Intended housing densities
center
are 21 to 54 units per acre in the Downtown Plan area and 9 to
20 units per acre outside the Downtown.
Industry
T4 to T6 Urban Core
Encourages intensive manufacturing, processing, warehousing
and similar uses, as well as light, clean industries and support
offices; also encourages workplace -serving retail functions and
work -live residences where such secondary functions would
complement and be compatible with industrial uses. Primarily
large-scale buildings.
Civic
Tl Preserve through
Accommodates civic functions such as government offices,
T6 Urban Core
libraries, schools, community center, and places of religious
worship.
Parks and Open
Tl Preserve through
Designate lands to public recreation and leisure and visual
Space
T6 Urban Core
resources, and can range from neighborhood tot lots and
pocket parks to urban squares and plazas and playgrounds to
large regional parks and natural preserves.
• Source: General Plan, Land Use Element, 2016.
Development Code
State law (Government Code §65454) requires that a City's General Plan and zoning
regulations be consistent. This is critical as zoning regulations serve as a key General Plan
implementation tool. The West Covina Zoning Ordinance accommodates a diversity of
residential housing types. The Code allows for innovation in design, provided that the
development does not exceed the overall density and dwelling unit capacity shown in
Table 4-2. The West Covina Zoning Code presently provides for the following seven
residential land use categories:
• Agricultural Residential (R-A)
• Single Family Residential (R-1)
• Low Density Multi -Family, Condominium Zone (MF-8)
• Low -Medium Density Residential (MF-15)
• Medium Density Residential (MF-20)
• High Density Residential (MF-45)
• Planned Community Development (PCD)
The allowable densities of the zones range from one unit per acre to 54 units per acre. Zoning
regulations establish standards for density, lot area, floor area ratio, lot coverage, yard
setbacks, structure height, minimum open space and minimum parking spaces.
Development and design standards may increase the costs of housing and hinder the
creation of affordable housing for low-income and senior residents. To minimize constraints
and maintain incentives for affordable housing developers, the City encourages the use of
density bonuses consistent with State law.
City of West Covina 46
Table 4-2, Table 4-3 and Table 4-4 display the City's zoning requirements for single-family
and multi -family residential zones, while also presenting any standards specific to the City's
area districts. The City is currently updating the Zoning Ordinance to revise allowable uses
and development standards consistent with the General Plan update adopted in 2016.
City of West Covina 47
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A
Table 4-4 Minimum Floor Area for Multi -family Units by Area District
Area District 1
Number of Bedrooms
800 1,000 1,2000 1,350 +150
Area District 11
950
1,150
1,350
1,500
+150
Area District IIA
1,050
1,250
1,450
1,600
+150
Area District 111
1,350
1,550
1,750
1,900
+200
Area District IV&V
1,450
1,650
1,850
2,000
+200
MF-15
600
600
800
1,000
1,200
1,350
+150
MF-20
600
600
725
900
1,100
1,250
+150
MF-45
500
500
600
800
990
1,125
+125
Source: City of West Covina, 2013
The minimum multi -family floor area standards shown in Table 4-4 may be modified through
the City's density bonus regulations (Municipal Code §26-676, et seq.) discussed later in this
chapter.
Downtown Plan and Code
A primary focus of the General Plan is
encouraging the redevelopment and
improvement of the City's Downtown,
which includes the Plaza West Covina
shopping mall, located south of
Interstate 10. In 2016 the City adopted the
Downtown Plan & Code, which presents a
community -led vision and development
standards for revitalization of the Downtown
area. The development standards in the Weal Covina
Downtown Plan encourage and facilitate Downtown Plan & Code
the development of higher -density
residential infill and mixed -use projects by
allowing reduced parking requirements and
deviations from the standards typically _
required in multi -family residential zones. .r
Table 4-5 presents the development
standards in the Downtown Plan & Code.
Because the Downtown Plan utilizes form -
based standards, no maximum densities or
floor area ratios are established although
the General Plan identifies residential densities up to 54 units/acre for the Downtown.
City of West Covina 50
Table 4-5 Downtown Plan Development Standards
Transect Zone
Allowed Building Types
Urban Center
Flex building
Hybrid court
Liner
Live -work
General Urban
Flex building
Hybrid court
Liner
Live -work
Urban Neighborhood
Court
Live -work
Row -house
Rosewalk court
Bungalow court
Duplex/Multiplex
Setbacks from Property Line
Primary Street
0'-10'
0'-10'
15'-35'
Side street
0'-10'
0'-10'
10'-15'
Side Yard
0'
0'
5'
Rear Yard no alle -with alley)
5'-15'
5'-15'
20'
Building Height
Minimum
1 sto /24'
1 sto /24'
1 sto /18'
Maximum
5 stories/70'
3 stories/40'
3 stories/40'
Site Width/Depth
Minimum
25'/100'
25'/75'
50795'
Maximum
200'/200'
150'/150'
200'/150'
Parkin
Residential Uses: 0-1 bedroom
1.5 space/unit
1.5 space/unit
1.5 space/unit
Residential Uses: 2+ bedrooms
2 spaces/unit
2 spaces/unit
2 spaces/unit
Non-residential uses
65%of Municipal Code parking requirements
Mixed Use Overlay Zone
The General Plan encourages a wide range of building types within the Commerce land -
use designation, including a mix of functions such as commercial, entertainment, office and
housing at densities up to 54 units per acre in the Downtown Plan area and up to 20 units
per acre outside the Downtown Plan area. The Mixed Use Overlay (MUO) Zone establishes
development standards for housing in non-residential zones consistent with the intent of the
General Plan.
Allowable residential uses in the MUO area include single-family detached or attached
units, home occupations and low barrier navigation centers. SB 35 projects and
developments providing at least 25% low-income units are eligible for ministerial review and
approval by the Community Development Director subject to the Multifamily Objective
Design Standards. A minimum leasable commercial gross FAR of 0.15 is required for mixed -
use projects to serve residential uses with a 45-foot height limit.
Parking Requirements
City parking standards for residential developments are tailored to the vehicle ownership
patterns associated with different residential uses. Parking is very expensive and can
consume valuable space that could be used for additional housing or amenities such as
common or private open space.
City of West Covina 51
The Zoning Code requires parking based on the number of dwellings on the property. As
shown in Table 4-2 and Table 4-3 above, the City of West Covina has established the
following minimum parking requirements:
l . Single-family residences: 2 covered spaces and 2 non -enclosed spaces. Single-
family homes that are greater than 4,500 square feet or with 5 or more
bedrooms, 3 covered parking spaces and 2 non -enclosed spaces.
2. Multi -family condominiums: two enclosed spaces plus 1 guest space per 4 every
four units
The City's parking requirements are typical of suburban communities; however, the required
number of resident parking is higher than what is typically seen in similar size cities. The City
requires a greater amount of guest and off-street parking in new developments to ensure
that public streets remain open and free of an overabundance of parked vehicles. The City
also calls for two enclosed resident spaces per dwelling unit regardless of the number of
bedrooms.
While the City of West Covina's multi -family parking requirements may appear to make it
more difficult to accommodate affordable housing, the standards have not prevented the
development of high -density multi -family projects in recent years. Generally, the precise
impact on the number of units and affordability will depend on project location, whether
the project is for seniors only, and the unit mix (studios, one -bedrooms, two -bedrooms, etc.).
To better facilitate the development of affordable housing the City has established reduced
parking standards for senior projects and projects with affordability components when
located in close proximity to transportation routes and public services. In recent years the
City has approved two multi -family housing projects at 65 and 75 units per acre that were
granted modified parking standards as well as a number of other modified development
standards. The City has also established flexible parking standards for the Downtown, to
encourage and facilitate higher -density residential projects within a walkable environment.
The City is committed to working with developers to modify parking requirements as
necessary to encourage and facilitate the development of affordable housing. The City's
parking requirements are not considered to be a constraint to the development of housing.
Open Space Requirements
To improve the character of the City and overall quality of residential neighborhoods,
localities typically require dwelling units to maintain a certain percentage of open space
that may include yard area, common space and landscaping. In West Covina open space
for single-family homes is regulated through lot coverage, yard coverage and setbacks.
Regulations that apply to open space in single-family zones are identified in Table 4-2,
Development Standards for Single Family Residential and Agricultural Residential by Area
District. In multi -family zones, open space is regulated by setbacks and the provision of
leisure space. For each dwelling unit, 200 square feet of leisure space must be provided. The
recreational/leisure space must have a minimum dimension of 50 feet if the project is one -
or two-story and a minimum dimension of 75 feet if the project is three-story. Required side
City of West Covina 52
and rear yards may be included in the recreational/leisure calculation. Communal facilities
such as swimming pools or community rooms may also be included in the area. The specific
regulations are provided in Table 4-3, Development Standards for Multiple Family Residential
Zones.
Open space requirements could constrain the development of housing as land is already
at a premium in West Covina, and the city is largely built out. However, the City's open
space requirements are considered standard for most cities in southern California and do
not act as a considerable constraint to housing development. The City is committed to
working with developers to modify this requirement as necessary to encourage and
facilitate the development of affordable housing. In recent years, several affordable
housing projects, including a senior residential facility of 65 units on a 1.05-acre parcel, have
been developed and these requirements were not considered to be a constraint to
development. The City's open space requirements are not considered to be a constraint to
the development of housing.
Minimum Floor Area Requirements
In addition to regulating open space, the City of West Covina also requires a minimum
square footage for multi -family units. The specific regulations are shown in Table 4-4.
The minimum floor areas required depend on the unit location and zoning. For some units
the minimum floor areas may be greater than the area that is typically required by private
development standards for affordable and senior housing. Regulating square footage
ensures that minimum health and safety requirements are met and that units are able to
adequately accommodate families. The ranges allowed are also broad enough to allow
for significant variation of unit size and have not constrained the development of affordable
housing in the City. The City is committed to working with developers to ensure that this
standard does not constrain the development of housing and allows modifications to
minimum unit sizes as shown in Table 4-6 as part of the density bonus regulations for
qualifying developments.
Table 4-6 Special Incentives: Modified Unit Size
Unit Type
Studio
Minimum Square Footage
500 square feet
One Bedroom
575 square feet
Two Bedroom
650 square feet
Source: West Covina Municipal Code §26-678.5(c(.
Building Codes and Enforcement
The City adopted the 2019 California Building Code (CBC) with Los Angeles County
Amendments and further amended Chapter 9, Fire Sprinkler Requirements to be in
coordination with Fire Code Amendments. Like many other jurisdictions, property and
building maintenance standards are included in the Municipal Code to protect the
appearance and character of residential neighborhoods. The established standards require
property owners to maintain landscaped areas for aesthetic, health, and fire safety reasons.
Building maintenance regulations address abandoned buildings, deteriorating paint,
City of West Covina 53
deteriorating roofs, or broken windows. Analysis of the City's landscape maintenance
standards for buildings and residential properties reveals that the standards imposed are
minimal routine maintenance requirements and do not pose a significant impediment or
act as a constraint to existing residential housing units or to the development and
maintenance of affordable housing. These codes are typical of other cities and do not act
as a constraint on the cost and supply of housing.
Cumulative Effect of Land Use Controls
The City is currently in the process of comprehensively updating the Development Code to
ensure consistency with the General Plan and streamline the development review process.
Specific objectives for the Development Code update are listed below and are also
included in several of the programs contained in the Housing Plan (Section 2).
• Adopt mixed -use development standards to allow residential development in
commercial zones
• Adopt objective design standards for multifamily residential development
• Combine zoning and subdivision regulations into a Development Code
• Consolidate commercial and residential zoning categories
• Reduce parking standards in all categories
• Create performance standards for certain uses
• Revise land -use matrix to allow more uses by -right and through staff level approval
• Create performance standards for certain commercial uses
4.1.2 On -Site and Off -Site Improvements
Site improvements and property dedications are important components of new
development and contribute to the creation of decent and affordable housing. For
residential development the required site improvements will typically vary by size and
location of the proposed development. Required improvements may include, but are not
limited to:
• Street improvements (minor neighborhood streets in the City are a minimum 32 feet
between exterior curbs)
• Adequate distribution lines for domestic water supply
• Sewage collecting system where main lines of an adequate disposal system are
available
• Roadway paving to the street center line
• Street lighting
• Concrete curbs and gutters
• Full width concrete sidewalks (4-5 feet width)
City of West Covina 54
• Street trees and appropriate irrigation systems
• Adequate grading and surfacing of streets, highways, and alleys
• Fire hydrants at locations recommended by the City Engineer and Fire Department
• Traffic control devices
• Necessary barricades and safety devices
• Fees for, or dedication of, parks and recreation facilities
The City of West Covina maintains a high engineering standard for curbs, gutters, sidewalks,
and streets, and these standards regulate construction and such items as width and grade.
In the past, the City has approved residential subdivisions with private streets where the
standards have been modified to reduce housing costs. The City will continue to review the
general development standards such as street width, parking lanes, and sidewalks, not only
to result in lower costs, but also in a more pleasing appearance for the subdivision.
Site improvements, particularly infrastructure, such as upgrades to major and local streets;
curbs, gutters, and sidewalks; water and sewer lines; storm drains; and street lighting can be
viewed as a constraint to the development of affordable housing. In most cases, these
improvements are dedicated to the City, which is then responsible for their maintenance.
The cost of these facilities is borne by developers, is added to the cost of new housing units,
and eventually is passed on to the homebuyer or property owner. West Covina, like many
jurisdictions in Los Angeles County is almost entirely built out and already has existing
infrastructure and roadways throughout the City. To reduce the impact of infrastructure
requirements on the development of affordable units, sites identified in the Sites Inventory
to accommodate very low- and low-income housing are located along major roadways
that will not require further upgrades if a project is proposed. If improvements are necessary,
the City may use CDBG or other available funding sources, when available, to offset the
cost of on- and off -site improvements and enhance the feasibility of affordable housing
development. Additionally, through the density bonus ordinance the City will continue to
provide incentives, such as assistance with on- and off -site improvements whenever
feasible.
4.1.3 Fees and Exactions
Planning and permitting fees are charged on an at -cost basis to cover staff services and
administrative expenses for processing development applications. Development impact
fees are required to provide essential public services and infrastructure to serve new
residents. In addition, developer fees and exactions imposed on new development can
help to minimize impacts on existing infrastructure and enable required upgrades of
infrastructure consistent with demands of the new development. State law requires that
these fees be reasonably related to the mitigation of the identified impact, and that they
be proportionate to the extent of impact associated with any given development project.
These development fees are typically passed on to renters and homeowners in the
price/rent of housing, and thus affect housing affordability.
City of West Covina 55
The City's Planning and Development Fee Schedules are outlined in Table 4-7. In 2019 the
City performed an analysis and updated the fee schedule. The development fees for the
City of West Covina are comparable to other local jurisdictions and are not considered to
be a major constraint to the development of affordable or market rate housing.
Table 4-7 City of West Covina Fee Schedule
Fee Type
Plannin Commission - Publlc Hearin Items
Fee Amount
Conditional Use Permit (CUP)
$90 per hour of staff time
Development Plan (DP)
Actual cost of City Attorney
General Plan Amendment (GPA)
$3,000 deposit required for CUP and
Precise Plan (PP)
Variance, $2500 deposit for DP and Adult
Tentative Parcel or Tract Map (TPM-TTM)
Oriented Business; $8000 deposit for GPA,
Variance (VAR)
ZC, TfM; $4000 deposit for PP and TPM,
Zone Change (ZC)
$7000 deposit for PP at Downtown
Adult Oriented Businesses
Miscellaneous Permits/Requests
Administrative Use Permit Includes:
Large Family Daycares
Outdoor Dining/Uses in O-U Zone
$90 per hour staff time
Single Family Dwelling Large Expansion
$770 deposit t required
Maximum Unit Size Exception
Sign Exception Review
Retaining Walls/Elevated Structures
Mounted Wireless Telecommunication Facility
Administrative Review
$90 per hour of staff time
440 deposit required
AIPP Review
$90 per hour of staff time
$1,000 deposit required
Appeal to Planning Commission
$750 non-refundable filing fee
$90 per hour of staff time
Appeal to Planning Commission (Non -Hearing Items)
$348 non-refundable filing fee
$90 per hour of staff time
Code, Covenants & Restrictions Review
$1,094 Flat Fee
Actual cost of City Attorney
Conceptual Plan Review
$90 per hour of staff time
$4,000 deposit required for all cases
Covenant Preparation Fee
559 Flat Fee
Extension Time for TTM, TPM, PP, VAR, ZC
$948 Flat Fee
Extension of Time for AUP
$175 Flat Fee
Historic Property Certificate of Appropriateness
$3,040 Flat Fee
Landscaping Plan Review & Inspection
Actual cost of Consultant Review
$2,500 deposit required
Minor Modification Review/Minor Site Plan Review (includes
$90 per hour of staff time
Massage Technician Review and Model Home Marketing
$1,300 deposit required
Complex)
Preliminary Review Meeting
$3,000 Flat Fee
Prospective Homeowners Awareness Package Review
$1,094 Flat Fee
Actual cost of City Attorney
Slight Modification
$90 per hour of staff time
1,300 deposit required
Source: West Covina Fee Schedule, 2021.
The City also charges a limited number of impact fees to ensure that services and
infrastructure are in place to serve the planned developments (see Table 4-8). West
Covina's impact fees include a dwelling unit fee, park fees, and school fees. Los Angeles
City of West Covina 56
County provides sewer service to the City, and charges a related sewer connection fee.
The dwelling unit fees are applied to pay a portion of the costs identified for public facilities
used for transportation services, storm drain facilities, and police and fire services. Although
impact fees and requirements for offsite improvements add to the cost of housing, these
fees and requirements are necessary to maintain public health and safety within a
community.
In an effort to promote accessory dwelling units, affordable housing, and senior housing, the
City provides parkland fee exemptions or reductions for these uses. New ADUs on a property
with one existing single-family house pay only half of the required in -lieu parkland fees.
Residential development restricted to low- and moderate -income households and/or senior
citizens are exempt from parkland fees.
Although development fees act as a constraint to housing development by increasing
development cost, local governments have little control over this issue due to the statewide
property tax limitations imposed by the voters in 1978 through Proposition 13. As a result, new
development typically bears a larger share of the cost of public services and facilities than
existing property owners. Based on the voters' rejection of Proposition 15 in 2020 it appears
that property tax limitations will continue to act as constraint to the financing of public
facilities in the foreseeable future.
Table 4-8 Development Impact Fee Summary
Impact Fee Category
Traffic Congestion Relief Fees
Fee Amount
A mitigation fee might be charged if project is creating traffic impacts.
Park & Recreation Land
Dedication
The Park/Recreation Impact Fee or In -Lieu fee is based on the amount of
land to be dedicated that provides three (3) acres of park area for 1,000
residents. Park area is based on the number of dwelling units to be
constructed and the density factor of 3.35 persons per dwelling unit and
2.35 for senior or affordable housing complexes.
Sewer Connection Fee
$400 per connection
Plumbing Fee
$8.80 per fixture + $22.10 for permit issuance
Electrical Fee
1.5x County fee
Construction Tax
$505 per 1,000 square feet
Art in Public Places Program*
One -Half Percent (0.5%) of the Total Building Valuation
School Fees
Covina -Valley Unified
$2.24 per square foot
Baldwin Park Unified
$1.93 per square foot
Rowland Unified
$2.05 per square foot
Walnut Valley Unified
$1.84 per square foot
West Covina Unified
$2.05 per square foot
Building Department Fees
1.5x County fee
$1-10,000value
$57.00-$216.00
$10,001-40,000value
$233.00-$420.00
$40,001-70,000value
$423.00-$550.00
$70,001 -100,000 value
$555.00-$682.00
$100,001-500,000 value
$682 for the first $100,000.00 valuation,
plus $4.50 for each additional $1,000.00 or fraction thereof, to $500,000
Source: City of West Covina, 2021
*Art in Public Places Fee only applies to residential development projects with more than 10 dwelling units and is
based on 0.57. of the total building valuation excluding land.
City of West Covina 57
While fees charged on residential developments in West Covina vary depending on many
factors unique to each project, total fees are estimated to be approximately $24,441 for a
typical single-family unit and $15,011 for a typical multi -family unit, which represents
approximately 7% of total development cost for a typical single-family unit and 6% for a
typical multi -family unit. These fees were established based upon applicable State law, are
comparable to those of surrounding communities in Los Angeles County and are not
considered to be an unreasonable constraint to the development of housing within the
context of the statewide property tax limitations.
Table 4-9 Development Fee Summary
Source: City of West Covina, 2022
Based upon typical developments
4.1.4 Processing and Permit Procedures
Builders and developers frequently cite the cost of holding land during the evaluation and
review process as a significant factor to the cost of housing. Processing times vary with the
complexity of the project. Approval for single-family homes, multi -family development
projects with less than five units, and other minor tenant improvements can usually be
processed within 30 days of submission to the City. Multi -family development projects with
five or more dwelling units are subject to review and approval by the Planning Commission,
which can add another four to six weeks for review. Projects requiring a Conditional Use
Permit, Zoning Amendment, or other discretionary action require more extensive review,
resulting in a longer processing timeline; usually 60 to 90 days unless an EIR is required by
CEQA.
The City of West Covina's development approval process is designed to facilitate
appropriate development. Table 4-10 provides a summary of typical processing times for
various procedures from application to final approval. The Planning Division is the lead
agency responsible for processing residential development applications and coordinating
submittals with other City departments and agencies. The time required to process a
development entitlement application can have cost implications for affordable housing.
Changes in zoning designations or standards may be typical of entitlement requests
accompanying proposals for affordable housing.
City of West Covina 58
Table 4-10 Local Development Processing Time Limits
Item
Conditional Use Permit
Approximate Length
.Hearing
2 -3 months
Site Plan Review
30 days
Tentative Tract Map/Parcel Map/Subdivision
3-4 months
Variance
2 -3 months
Zoning Amendments or Zone Change
3-5 months
General Plan Amendment
3-5 months
Environmental Impact Report
90+ days
Initial Study
60-90 days
Miti aced Negative Declaration
60-90 days
Source: City of West Covina Planning Division
Permit Processing for Single -Story Single -Family Construction
The permitting approval process for a residential project depends on the intensity and
number of units requested by the applicant. Permits to construct a single -story single-family
home are submitted to the Planning Division for initial review to ensure the application is
complete. The more information an applicant provides, and the quicker they correct any
revisions on their plans, the shorter the permit processing time. Upon completion of the initial
review the Planning Division schedules the application for review by the Planning
Commission Subcommittee for Design Review (Subcommittee). The Subcommittee typically
reviews the plans for architectural and design compatibility with the surrounding
neighborhood and the character of the City. The Subcommittee has the authority to
approve or deny the plans or to suggest modifications. Once the plans have been
approved by the Subcommittee the City notifies the applicant and permits can be issued.
This review process typically takes between 2 to 4 weeks; however, the processing time is
often dependent on how quickly the applicant revises and resubmits plans if corrections are
required.
Permit Processing for Multi -Story Single -Family Construction
Permits applications for multi -story single-family homes are reviewed and approved through
the Administrative Use Permit process. Once the applicant submits their application and
plans, an appointment is scheduled with the Planning Commission Subcommittee for Design
Review (Subcommittee), which is composed of City Staff and two appointed Planning
Commissioners. The Subcommittee evaluates the plans for completeness, as well as
assessing comments made by the various other City departments including, fire, public
works and building. The Subcommittee also typically reviews the plans for architectural and
design compatibility with the surrounding neighborhood and consistency with the
character of the City.
In addition to review by the Subcommittee, an Administrative Use Permit also requires that
notices be sent to property owners living within 300 feet of the proposed project. The notice
is intended to inform residents of the applicant's plans and to allow them to request a public
hearing before the Planning Commission to discuss the application and any express
concerns. Notices are sent out prior to Subcommittee review. If no public hearing is
City of West Covina 59
requested the Subcommittee is responsible for project approval and the review process can
take as little as 2-4 weeks. If a public hearing by the Planning Commission is requested, the
process can extend up to 8 weeks and the Planning Commission becomes the decision -
making entity.
Permit Processing for Multi -Family Construction
For a multi -family residential project the permitting procedure can be more complex and
consequently can result in longer and more variable processing times. The City currently has
different submittal requirements for multi -family developments; one for projects with rental
units and another for projects with ownership units. For multi -family rental units a Precise Plan
is required while for ownership units a Precise Plan as well as a Tentative Tract Map is
required. Generally, the application process is similar for both types of units.
Once the applicant submits the application and plans, an initial meeting is schedule with
the developer to discuss design and phasing of the project. Following this meeting, an
appointment with the Development Review Committee is scheduled and the plans are
routed to the various City departments including Fire, Public Works and Building for review.
The Development Review Committee evaluates the plans for completeness as well as
assessing comments made by the various City departments. The Committee also typically
reviews the plans for architectural and design compatibility with the surrounding
neighborhood and consistency with the character of the City. The Committee may also
determine if any conditions of approval, such as capital improvements, are necessary to
complete the project. Conditions of approval typically protect the health, safety and
welfare of the public and ensure a project's consistency with established architectural
design guidelines.
Upon completing its review the Committee's conditions of approval are sent to the
applicant. At the applicant's request a meeting can be scheduled to discuss the conditions
of approval. If the applicant accepts the findings and conditions the project is scheduled
for public hearing before the Planning Commission. Findings and conditions do not exceed
the limits and requirements of State law. Any finding or conditions are provided primarily to
ensure that the project is consistent with the City's General Plan, the Zoning Code and
Health and Safety codes, Typical findings for a multi -family housing project include
compliance with required street improvements, fire suppression, and water quality
standards. In most cases a project would then be approved by the Planning Commission
and permits would be issued soon after. The processing time for a multi -family development
typically takes between 10 and 12 weeks. Similar to the process for single-family projects,
the processing time is often dependent on how quickly the applicant revises and resubmits
plans if corrections are required.
Requests to develop housing at densities below those identified in the
inventory and the length of time between receiving approval for a housing
development and submittal of an application for building permits
City of West Covina 60
State law requires the Housing Element to describe whether housing developers request
densities less than what is allowed under zoning regulations, and also the typical length of
time between project approval and submittal of a building permit application. Based on
recent project examples, proposed densities vary from the lower end of the allowable
density range to near the maximum. Desired densities are based on the developer's analysis
of market conditions to maximize profit margins.
The time from project approval to submittal of building permit applications varies
depending on the complexity of the project. Recent project examples have ranged from
approximately 4 months to 9 months depending on project size and complexity.
4.1.5 Housing for Persons with Disabilities
State law requires jurisdictions to analyze potential constraints on housing for persons with
disabilities, demonstrate efforts to remove governmental constraints, and include programs
to accommodate housing designed for people with disabilities. The City has no special
zoning or land use restrictions that regulate the development of housing for persons with
disabilities. However, one of the purposes of the City's Senior Housing Overlay Zone (SHO) is
to ensure that federally regulated requirements related to the Americans Disabilities Act
(ADA) and Universal Design principles are incorporated within senior housing developments.
Reasonable Accommodation for Persons with Disabilities
Both the federal Fair Housing Act and the California Fair Employment and Housing Act
impose an affirmative duty on local governments to allow reasonable accommodation
(i.e., modifications or exceptions) in their zoning laws and other land use regulations when
necessary to afford disabled persons an equal opportunity to use and enjoy a dwelling. The
building codes adopted by the City incorporate accessibility standards contained in Title
24 of the California Administrative Code.
City procedures for ensuring that reasonable accommodation is available for persons with
disabilities are established in Municipal Code §26-298.02. Applications for reasonable
accommodation are reviewed administratively by the Community Development Director
unless the application is part of a larger project subject to a higher level of review, in which
case the decision on the reasonable accommodation is made as part of the larger
package of applications.
The following factors are considered in making a determination regarding the
reasonableness of any request for reasonable accommodation:
(1) The need for the requested modification, including alternatives that may
provide an equivalent level of benefit;
(2) The physical attributes of and any proposed changes to the subject property
and structures;
(3) Whether the requested modification would impose an undue financial or
administrative burden on the city;
City of West Covina 61
(4) Whether the requested modification would constitute a fundamental alteration
of the city's general plan, applicable specific plan, zoning or subdivision
program;
(5) Whether the requested modification would result in a concentration of uses
otherwise not allowed in a residential neighborhood to the substantial detriment
of the residential character of that neighborhood;
(6) Whether the requested modification is being provided primarily to benefit one
(1) or more persons with a disability;
(7) Whether the requested modification is necessary for therapeutic benefit to the
person(s) with a disability;
(8) Whether the requested modification would result in a substantial increase in
traffic or insufficient parking;
(9) Whether the requested modification would significantly deprive any
neighboring property owners of the use and enjoyment of their own properties;
(10) Whether there are preferable and/or feasible alternatives to the requested
accommodation that may provide an equivalent level of benefit;
(11) Whether proposed changes to property or structures are compatible with
surrounding development or create potential impact(s) on surrounding uses;
(12) Whether the findings of section 26-298.12(b) exist;
(13) Any other factor that may have a bearing on the request.
Based upon these factors, the reasonable accommodation request may be approved
based upon the following findings:
(1) That the dwelling, which is the subject of the request for reasonable
accommodation, will be used by an individual with a disability protected under
the Acts;
(2) That the requested modification is necessary to make the dwelling available to
an individual with a disability protected under the Acts;
(3) That the requested modification would not impose an undue financial burden
on the city;
(4) That the requested accommodation would not require a fundamental
alteration in the nature of the city's overall land use and zoning;
(5) That the accommodation will not result in a direct threat to the health and
safety of other persons or physical damage to the property of others.
No reasonable accommodation requests have been submitted in recent years. However,
to ensure that City procedures do not act as an unreasonable constraint on housing for
persons with disabilities, these procedures will be reviewed and updated as necessary to
ensure compliance with fair housing law as part of the comprehensive Development Code
update (Program 4.2).
Residential Care Facilities
In accordance with State law residential care facilities for six or fewer residents are allowed
as a permitted use in all single-family residential zones. West Covina does not impose
additional zoning, building code, or permitting procedures on small care facilities other than
those that apply to single-family uses as allowed by State law.
City of West Covina 62
Larger residential care facilities for seven or more persons are not currently defined in the
Zoning Ordinance; however, skilled nursing and assisted living facilities are explicitly allowed
by the Code subject to approval of a conditional use permit in the R-1, R-A, MF-8, MF-15,
MF-20, MF-45, N-C, S-C, R-C, O-P, C-2, C-3 zones (Municipal Code §26-597).
In recent years the City has approved two large assisted living projects - 1400 W. Covina
Parkway, a 5-story facility with 131 beds and 111 units and memory care (2017) and 1415 W.
Garvey Avenue North, a 5-story facility with 107 beds and 92 units and memory care (2019).
To ensure clarity in City regulations and minimize potential constraints to persons with
disabilities, the Development Code update will include a definition and regulations for large
residential care facilities consistent with fair housing law (see Program 3.1 in Section 2).
Definition of "Family"
The Municipal Code defines Family as "an individual or group of individuals, related or
unrelated, living together as a single housekeeping unit, including necessary servants. A
family does not include institutional group living situations such as a residential facility, rest
home, dormitory, or similar use, nor does it include such commercial group living
arrangements such as a roominghouse, motel, hotel, or similar uses." This definition is
consistent with fair housing law and does not act as a constraint on housing for persons with
disabilities.
Additionally, the Land Use Element in the City's General Plan does not require, nor regulate
the siting of special needs housing in relationship to one another. Based on its zoning, land
use policies, and building code practices, as described above, there is no evidence that
West Covina has created significant constraints to the location, construction, or cost of
special needs housing for persons with disabilities.
4.1.6 Other Housing -Related Regulations
In an effort to provide flexibility within the development standards in the West Covina
Municipal Code there are a number of ordinances aimed at providing additional
affordable housing in the City. These ordinances allow for density bonuses, accessory
dwelling unit (ADU) development, homeless and transitional shelters, supportive housing,
and two overlay districts. West Covina has implemented these ordinances to assist
developers in providing quality and affordable housing throughout the City.
Density Bonus
In response to State -mandated requirements and local needs, the City has adopted
regulations to permit higher densities than generally permitted. The West Covina Zoning
Code provides housing incentives to assist in the provision of sound affordable housing for
low- and moderate -income households and senior citizen households. In accordance with
§§65915 et seq. of the California Government Code, the density bonus ordinance assists in
achieving the goals and implementing the policies of the Housing Element and
Comprehensive Housing Assistance Strategy.
City of West Covina 63
Known as a "density bonus," State law allows a developer to increase the density of a
residential development above the maximum allowable residential density if the project
provides deed -restricted affordable or senior housing.
The West Covina Municipal Code also includes a section titled "Low and Moderate Income
and Senior Citizen Housing." This section specifically allows for density bonuses between 25%
and 160% to offset land and construction costs. In addition, this section of the Code allows
the modification of development standards to render the development economically
feasible. This section of the Code is intended to facilitate the development of housing for
low and very -low-income households that is restricted for a period of no less than 45 years
for owners and 55 years for renters. The City promotes the use of the density bonus ordinance
for senior housing, and in conjunction with mixed use projects and within Specific Plans.
Development projects that qualify for a mandatory density bonus will in addition to the
density increase be granted incentives or concessions based on the affordability level and
number of units. State density bonus law has been recently amended; therefore, Program
3.2 is included in the Housing Plan to monitor legislation and update the City's density bonus
regulations consistent with State law.
Manufactured Housing
Government Code §65852.3 requires that manufactured housing on a permanent
foundation be permitted in the same manner as single-family housing in the same zone. City
regulations are consistent with this requirement.
Accessory Dwelling Unit Requirements
In response to State requirements and local needs, the City of West Covina allows the
development of both attached and detached accessory dwelling units (ADUs) and junior
accessory dwelling units (JADUs). Traditionally intended for elderly or other members of
owner -occupant families, ADUs and JADUs can provide an important part of the City's
overall strategy for meeting affordable housing needs. In recent years the State Legislature
has amended ADU law numerous times to encourage production. The City's current ADU
regulations were adopted in July 2022 and are incorporated as §26-685.30 of the Municipal
Code. These regulations incorporate comments provided by the Department of Housing
and Community Development in February 2022 and are consistent with current State law.
Program 3.4 in the Housing Plan describes actions the City will take to encourage and
facilitate production of ADUs.
Emergency Shelters and Low Barrier Navigation Centers
Emergency shelters provide temporary housing for homeless persons for a limited period of
time. Section 50801 of the Health and Safety Code defines emergency shelters as "housing
with minimal supportive services for homeless persons that is limited to occupancy of six
months or less by a homeless person. No individual or household may be denied emergency
due to an inability to pay."
City of West Covina 64
The Zoning Code allows emergency shelters by -right (i.e., without a conditional use permit
or other discretionary action) in the Light Manufacturing (M-1) zone. The M-1 zone is
appropriate to accommodate emergency shelters as these areas are typically located
along major roadways with access to employment centers and near stores and other
services. The M-1 zone includes approximately 45 parcels totaling 60 acres. Of these sites
approximately 11 parcels are between 0.5 and 5 acres in size, are underutilized and can
accommodate a shelter of approximately 20 beds. Standards for emergency shelters are
established in Municipal Code §26-685.7500 and include the following:
• Maximum capacity of 30 occupants. An emergency shelter with a capacity greater
than 30 occupants may be permitted subject to the approval of a conditional use
permit
• The facility shall operate on a first -come, first serve basis with clients only permitted
on -site and admitted to the facility between 6:00 p.m. and 7:00 a.m. during Pacific
Daylight Time, and 5:00 p.m. and 7:00 a.m. during Pacific Standard Time. Clients must
vacate the facility by 8:00 a.m. and have no guaranteed bed for the next night. A
curfew of 10:00 p.m. (or earlier) shall be established and strictly enforced and clients
shall not be admitted after the curfew.
• Maximum stay of 120 days in a 365-day period
• Minimum distance of 300 feet shall be maintained from any other emergency shelter
• Minimum of 1 staff member per 15 beds shall be awake and on duty when the facility
is open. Facility staff shall be trained in operating procedures, safety plans, and
assisting clients. The facility shall not employ staff who have been convicted of a
felony or who are required to register as a sex registrant under Penal Code 290.
• Bike rack parking
• Exterior lighting
• A waiting area with a minimum of 10 square feet per bed in a location not adjacent
to the public right-of-way, and visually separated from public view by a minimum 6-
foot tall visually screening decorative wall or fence
• Outdoor storage shall be screened from public view by a minimum 6-foot decorative
wall or fence
• A minimum of 1 toilet and 1 shower per 8 beds per gender, and a private shower and
toilet facility for each area designated for use by families
• An operational plan shall be provided for the review and approval of the community
development director and police chief
• Off-street parking at the ratio of 1 space per 4 beds, and/or 0.5 per bedroom
designated as a family unit with children, plus 1 space per staff member.
Low barrier navigation centers. AB 101 (2019) established requirements related to local
regulation of low barrier navigation centers, which are defined as "Housing First, low -barrier,
service -enriched shelters focused on moving people into permanent housing that provides
City of West Covina 65
temporary living facilities while case managers connect individuals experiencing
homelessness to income, public benefits, health services, shelter, and housing." Low Barrier
means best practices to reduce barriers to entry, and may include, but is not limited to:
(1) The presence of partners if it is not a population -specific site, such as for survivors
of domestic violence or sexual assault, women, or youth
(2) Accommodation of residents' pets
(3) The storage of possessions
(4) Privacy, such as partitions around beds in a dormitory setting or in larger rooms
containing more than two beds, or private rooms
Low barrier navigation centers meeting specified standards must be allowed by -right in
areas zoned for mixed use and in nonresidential zones permitting multi -family uses. Program
3.1 is included in the Housing Plan to update City regulations consistent with AB 101.
Transitional and Supportive Housing
Transitional housing provides longer -term shelter, typically up to two years, while supportive
housing may have no occupancy time limit. Entities that operate transitional and supportive
housing generally require that residents participate in a structured program to work toward
established goals so that they can move on to permanent housing and may include
supportive services such as counseling.
State law also requires that transitional and supportive housing be regulated as a residential
use that is subject only to the same requirements and procedures as other residential uses
of the some type in the same zone. AB 2162 of 2018 (Government Code § 65583(c) (3)) further
requires that supportive housing development projects meeting specific criteria must be
allowed by -right in all zones allowing multi -family development, including mixed -use and
nonresidential zones. Program 3.1 is included in the Housing Plan to review and update City
regulations regarding transitional and supportive housing as necessary to ensure consistent
with current State law.
Agricultural Employee Housing
The Employee Housing Act (Health and Safety Code § 17021.5 and § 17021.6) requires
agricultural employee housing for six or fewer employees to be treated as a single-family
structure and permitted in the same manner as other dwellings of the same type in the some
zone, and requires employee housing consisting of no more than 12 units or 36 beds to be
permitted in the same manner as other agricultural uses in the same zone. The current
Zoning Code does not include a definition of agricultural employee housing or regulations
for agricultural employee housing. Program 3.1 is included in the Housing Plan to update
City regulations for agricultural employee housing consistent with current law.
Other Local Ordinances
Inclusionary housing. The City has not adopted inclusionary housing requirements.
Short-term rentals. Short-term vacation rentals are not allowed in residential zones.
City of West Covina 66
SB 9 Urban Lot Splits. The City has adopted regulations for urban lot splits consistent with SB 9.
4.2 Non -Governmental Constraints
In addition to the governmental constraints addressed above, non -governmental issues
such as real estate market conditions, environmental issues and infrastructure constraints
can also affect housing cost and supply.
4.2.1 Market Constraints
Market constraints can play a large role in driving up the cost of housing production leading
to an overall lower number of affordable units. Potential constraints include land prices,
construction costs, and the cost and availability of financing.
Land Prices
The cost of land directly influences the cost of housing. Land prices are determined by a
number of factors, most important of which are land availability and permitted
development density. As land becomes scarcer, the price for land increases. Land prices
are also positively correlated with the number of units permitted on each lot. Thus, a higher
density lot may command a higher price than one designated for lower densities, but upon
completion the developer may realize a higher profit margin based on a greater number
of units sold.
West Covina is typical of the suburban communities surrounding the City of Los Angeles in
that it is largely built out. The cost of land varies depending on many factors but can exceed
$2 million per acre.
Construction Costs
The cost of construction depends primarily on the cost of materials and labor, but it is also
influenced by market demand and market -based changes in the cost of materials. The cost
of construction also depends on the type of unit being built and on the quality of the
product being produced. Typically as the number of units constructed increases, overall
costs generally decrease as builders can benefit from economies of scale. For both single-
family and multi -family construction there is wide variation in price, depending on the size
of the unit, the number and quality of amenities provided, quality of construction, and the
types and quality of materials used.
In recent years total construction costs per square foot, excluding land costs, can range
from $150 to $200 per square foot or more depending on the quality and amenities of the
home.
A reduction in construction costs can be brought about in several ways. One such method
involves a reduction in amenities and quality of building materials in new homes (still above
the minimum acceptability for health, safety and adequate performance), which may
result in lower costs. State Housing Law provides that local building departments can
City of West Covina 67
authorize the use of materials and construction methods if the proposed design is found to
be satisfactory and the materials or methods are at least equivalent to that prescribed by
the applicable State building codes.
In addition, pre -fabricated factory built housing may provide cost savings by reducing labor
and materials costs. As the number of units built in scale increases, savings in construction
costs over the entire development can be realized, particularly when combined with
density bonus provisions. The City may implement a variety of programs to write down land
costs or provide other developer incentives such as modifications in development standards
or processing fees in order to increase affordability, subject to the developer providing a
percentage of units with affordability restrictions.
Availability of Financing
Mortgage interest rates have a large influence over the affordability of housing. Increases
in interest rates also increase the monthly mortgage payment and decrease the number of
persons able to afford a home purchase. Decreases in interest rates result in more potential
homebuyers introduced into the market.
National policies and economic conditions determine interest rates, and there is little that
local governments can do to affect these rates. Government - typically at the state and
federal level - can, however, "leverage" funds by offering interest rate write -downs to
extend home purchase opportunities to lower -income households. In addition, government
insured loan programs may be available to reduce mortgage down payment requirements.
The ability to secure financing can be influenced by several factors, including
creditworthiness, debt -to -income ratio, and the restrictiveness of mortgage lending
standards. Data compiled under the Home Mortgage Disclosure Act (HMDA) provides an
indication how lending practices affect a community's home sales. While the availability of
mortgage financing in West Covina is similar to other areas of the Los Angeles metropolitan
area, the most recent Los Angeles County Analysis of Impediments' reported that fair
housing public input and HMDA data indicate that racial and ethnic minorities, as well as
other protected classes, face discrimination in private rental and homeowner markets.
HMDA data shows that some racial and ethnic minorities are more likely to be denied a
mortgage. In addition, HUD Fair Housing Complaint Data for the Los Angeles Urban County
area, which includes West Covina, showed over 2,600 complaints between 2008 and 2016.
The basis of these complaints was most likely to be disability, race, or familial status. In
addition, the Fair Housing survey found that 9.3% of respondents indicated that their home
loan application was denied in the past 5 years. According to HMDA data, between 2008
and 2015, black mortgage applicants are denied at a rate more than 7 percentage points
higher than white applicants, and Hispanic applicants are denied at a rate more than 5
percentage points higher than non -Hispanic applicants.
2018 Analysis of Impediments of Fair Housing Choice for the Community Development Commission and
Housing Authority of Los Angeles County
City of West Covina 68
While the primary responsibility for addressing such discrimination lies with federal and state
regulatory agencies, cities can assist local residents who feel they have been affected by
discrimination by publicizing fair housing referral information (see Program 4.1).
4.3 Environmental Constraints
Seismic Ground Shaking
The potential for seismic activity and ground shaking in West Covina is determined by the
City's proximity to the affected fault and the intensity of the seismic event along the fault.
Damage associated with earthquakes is dependent on a number of variable factors
including: the strength or magnitude of the earthquake, the length (time) of the shaking,
the distance from the earthquake, the substrate that is being affected by the quake, and
the construction of the structure.
There are traces of two known faults within the borders of West Covina, these are the Walnut
Creek fault and the San Jose Hills fault. These two faults are not well defined or studied. The
Walnut Creek tracing is located under basin sediment that has for years been deposited
from the San Gabriel and surrounding mountains. The City has implemented the Uniform
Building Code seismic safety standards for structural construction. The City will continue to
enact these and other seismic safety programs to minimize hazards from earthquakes and
other seismic hazards.
Liquefaction
A secondary effect from earthquakes includes liquefaction. Liquefaction occurs when
ground shaking causes wet granular soils to change from a solid state to a liquid state. This
results in the loss of soil strength and the soil's ability to support weight. Buildings and their
occupants are at risk when the ground can no longer support these buildings and structures.
Many communities in Southern California are built on ancient river bottoms and have sandy
soil. In some cases this ground may be subject to liquefaction, depending on the depth of
the water table. Data provided by water service providers around West Covina indicate
that a depth to groundwater is more than 50 feet, and therefore liquefaction hazards are
generally low. Liquefaction hazards, where present, can generally be remedied by
standard engineering practices. Liquefaction is not seen as a constraint to the development
of affordable or market rate housing.
4.3.1 Infrastructure Constraints
In planning for future residential development, it is important to evaluate current service
levels provided to existing residents, deficiencies in the levels of services provided, and the
need for additional public services and facilities to support new development. This section
addresses the ability of water and wastewater utilities to serve an increase in population.
Generally, infrastructure development is not seen as a constraint to the development of
affordable or market rate housing.
City of West Covina 69
Water
Potable water in West Covina is provided by eight water companies depending on the
location of the residence in the City. Suburban Water Systems (SWS) provides water to the
majority of the City serving a population of approximately 300,000 persons. SWS receives
wholesale water supplies from the Upper San Gabriel Valley Municipal Water District
(USGVMWD). The USGVMWD is in turn a member of the Metropolitan Water District of
Southern California, which provides the USGVMWD with approximately 20% of its water
supply. The remaining water supply is supplied locally through groundwater supplies. Based
on verbal communication with SWS it is anticipated that there is adequate water supply to
accommodate the City's RHNA allocation. Project -specific analysis may be required when
a project is proposed to determine if the existing infrastructure and proposed demand need
to be addressed. Generally, water supply is not seen as a constraint to the development of
housing .in West Covina.
Wastewater
West Covina is located within the service area of Los Angeles County Sanitation District No.
15. Wastewater generated within the city is discharged to local sewer lines, maintained by
the City, for conveyance to the County Sanitation District of Los Angeles County truck sewer
network. Wastewater is treated at the San Jose Creek Water Reclamation Plant (SJCWRP)
near the City of Whittier, where it is cleaned and reused as groundwater recharge and for
the irrigation of parks, schools, and greenbelts. Some of the wastewater not used, or flows
which exceed capacity of the SJCWRP, is diverted to the Joint Water Pollution Control Plan
in Carson. The sewer line system is considered adequate to handle foreseeable future
development accommodating the City's RHNA allocation.
Dry Utilities
Residential utilities such as electricity, telephone, cable, and internet service are provided
by private entities as development occurs and are available in all residential areas of the
city.
City of West Covina 70
Section 5
.........................................................................................................................
Housing Resources
This section summarizes the land, financial, and administrative resources available for the
development and preservation of housing in West Covina. The analysis includes an
evaluation of the availability of land resources for future housing development; the City's
ability to satisfy its share of the region's future housing needs, the financial resources
available to support housing activities, and the administrative resources available to assist
in implementing the City's housing programs and policies.
5.1 Availability of Sites for Housing
State law requires that a community identify sufficient sites to accommodate the amount
of new housing assigned through the Regional Housing Needs Assessment (RHNA) process.
Adequate sites are those with appropriate zoning and development standards with
services, and facilities needed to facilitate and encourage the development of a variety of
housing for all income levels.
An analysis and inventory of potential sites for housing development is presented in
Appendix B.
5.2 Financial and Administrative Resources
5.2.1 Financial Resources
A variety of Federal, State, and local programs are available to create and/or maintain
rental units and purchase affordability for lower -income households and for persons with
special needs. These programs are also available to other jurisdictions for potential
acquisition, subsidy, or replacement of units at -risk. After the State's elimination of
redevelopment agencies, the primary sources of funding for local housing programs are
from Federal and State grants
5.2.2 Administrative Resources
The primary responsibility of the Planning Division is managing the physical development of
the City to promote health, safety, and sustainability. The department ensures the City's
viability through enforcement of land use, construction, health, safety, and environmental
regulations. This involves land use and development standards, building codes, economic
City of West Covina 71
vitality, and adherence to the General Plan. It is also responsible for the administration of
the General Plan and implementation of the Zoning Ordinance and Specific Plans.
5.3 Energy Conservation Opportunities
As residential energy costs rise, the subsequent increasing utility costs reduce the
affordability of housing. State of California Energy Efficiency Standards for Residential and
Nonresidential Buildings were established in 1978 in response to a legislative mandate to
reduce California's energy consumption. The standards are codified in Title 24 of the
California Code of Regulations and are updated periodically to allow consideration and
possible incorporation of new energy efficiency technologies and methods. California's
building efficiency standards (along with those for energy efficient appliances) have saved
billions of dollars in electricity and natural gas costs?
Title 24 sets forth mandatory energy standards and requires the adoption of an "energy
budget" for all new residential buildings and additions to residential buildings. The standards
specify energy saving design for lighting, walls, ceilings and floor installations, as well as
heating and cooling equipment and systems, gas cooling devices, conservation standards
and the use of non -depleting energy sources, such as solar energy. Residential builders must
comply with these standards while localities are responsible for enforcing the energy
conservation regulations through the plan check and building inspection processes.
Local energy conservation programs include:
• Free Energy Assessment Screening for Your Home (EASY) - EASY provides a whole
house energy assessment to help homeowners identify opportunities that reduce
energy usage and energy costs. Participating homes will receive a customized home
report with project recommendations, information about incentive and rebate
programs through local utility companies like So Cal Edison and So Cal Gas, and
suggestions for immediate home improvement projects. EASY is a program of the San
Gabriel Valley Council of Governments, and home assessments are conducted by
members trained in building science.
• HERO Financing Program for Home Retrofits - The Home Energy Retrofit Opportunity
(HERO) Financing Program will assist in funding energy efficiency projects for Covina
homeowners. Through the HERO program, homeowners will work alongside
contractors to identify home energy projects and products that are eligible for low -
interest financing. The low interest loans are paid back as an additional line item on
the home's property tax. There are no up -front costs.
• Savings by Design - This program is designed for non-residential new construction,
renovation, and remodel projects. Savings by Design provides energy -efficient
design ideas to primary decision -makers such as building owners, developers,
architects, engineers, designers, contractors, and builders. A Savings by Design
analysis provides detailed technical and financial assistance data that allows owners
2 California Energy Commission (http://w .energy.co.gov/title24)
City of West Covina 72
and design teams to make informed decisions regarding energy efficiency features.
This approach offers the non-residential building industry a multi -faceted program
designed to consistently serve the needs of the building community throughout
California. Savings by Design encourages energy -efficient building design and
construction practices, promoting the efficient use of energy by offering up -front
design assistance supported by financial incentives based on project performance.
• PACE Financing Program for Commercial Properties - Upgrading or retrofitting
buildings to use less energy and water or produce clean energy can lower operating
costs while increasing property value. In an effort to make these energy
improvements more attainable for property owners, Renovate America offers the
Property Assessed Clean Energy (PACE) financing program. Unlike a traditional loan,
PACE financing is paid back via an assessment on the property tax bill. PACE
financing allows owners of commercial properties to finance up to 100% of the cost
of installing energy -efficient, renewable energy and water -saving improvements and
immediately enjoy the benefits of lower utility bills. PACE offers low fixed rates and
extended terms of 5 to 20 years to help keep payments affordable.
• Electric Lawn Mower Rebate Program - A rebate is available to residents that
purchase a qualifying electric lawn mower. Residents that purchase a new, cordless
electric lawn mower and scrap their old gas mower are eligible for a rebate based
on the purchase price of the new mower. The on-line application is available at
www.aamd.aov/lawnmower. Rebates range from $150 to $250, depending on the
purchase price of the new electric lawn mower. Over 20 electric lawn mower models
qualify.
City of West Covina 73
Appendix A-
.........................................................................................................................
Review of the Prior
Housing Element
The Progress Report reviews the previous Housing Element's programs, objectives, and
actions that were to be implemented during the previous planning period. The City of West
Covina's Housing Element identified five goals that the City anticipated to implement during
the previous planning period. Each goal has specific policies that were to be achieved in
order to facilitate the construction of affordable housing and to maintain the existing
affordable housing stock. The City also established a set of objectives with corresponding
goals to further improve housing opportunities throughout the City. Each of the actions and
objectives had a timeframe for completion along with a responsible agency to monitor the
program.
For each program, the City's accomplishments and status of implementation is described,
with quantitative results whenever possible, along with how the program should continue to
be implemented, modified, or removed. Section 65588 of the State Housing law requires
that all local governments initiate a timely review of the housing element to evaluate all of
the following:
• The appropriateness of the housing goals, objectives, and policies in contributing to
the attainment of the State's housing goal;
The effectiveness of the Housing Element in attainment of the community's housing
goals and objectives; and
• The progress of the City in the implementation of the Housing Element.
Cumulative Effectiveness in Meeting the Housing Needs of Persons with Special
Needs
According to the Department of Social Services there are approximately 22 residential care
facilities in West Covina to serve the needs to those with disabilities. In recent years the City
has approved two large assisted living projects - 1400 W. Covina Parkway, a 5-story facility
with 131 beds and 111 units and memory care (2017) and 1415 W. Garvey Avenue North, a
5-story facility with 107 beds and 92 units and memory care (2019).
City of West Covina 74
Appendix A - Review of the Prior Housing Element
The City of West Covina currently has six affordable multifamily housing complexes and five
additional deed -restricted complexes. Six of these housing communities have housing
specifically reserved for seniors. In total the city has 687 deed -restricted affordable units.
To determine how effective the City's housing programs have been in the development
and maintenance of affordable housing, the city will monitor these affordable units to
ensure that the rent payments charged are consistent with levels appropriate for the
identified income category. The city has posted the AB 987 Affordable Housing database
on its website and will continue to track affordable housing units citywide through the
annual certification process. In addition, as the city develops additional affordable units
these properties will be added to the table and will be monitored annually to ensure they
meet affordability requirements.
City of West Covina 75
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A
Appendix B -
........................................
Sites Inventory
This appendix describes the methodology and analysis for determining the City's residential
land inventory for the 2021-2029 planning period.
Regional Housing Needs Assessment (RHNA)
The City's RHNA allocation for the 2021-2029 period is as follows:
Very -low-income 1,653 units
Low-income
850 units
Moderate -income
865 units
Above -moderate
1,978 units
Total
5,346 units
Potential Sites to Accommodate the (RHNA)
The inventory of sites for potential housing development is comprised of approved projects,
vacant and underutilized properties with potential for additional residential development or
redevelopment, and potential accessory dwelling units (ADUs), as summarized in Table B-1.
As seen in this table, the sites inventory is sufficient to accommodate the RHNA in all income
categories.
Table B-1
Sites Inventory Summary
Approved Projects (Table B-2)
Very Low
Income
Low
Category
Mod
Above
..
379
Total
379
Vacant or Underutilized Sites (Table B-3)
2,000
1,090
5,427
8,864
Potential ADUs
34
64
3
42
143
Total Sites Inventory
2,034
1,154
5,430
421
9,386
R H NA 2021 - 2029
1,653
850
865
1,978
5,346
Adequate Sites?
Yes
Yes
Yes
Yes
Yes
Source: City of West Covina, 2022
Approved Projects
Housing developments that have received approval and are expected to be completed
during the 61h cycle RHNA period are listed in Table B-2. These projects are conservatively
assigned to the above -moderate affordability categories.
City of West Covina 80
Appendix B - Sites Inventory
Sites Inventory Overview and Analytical Approach
As with many mature communities in the highly urbanized areas of Los Angeles County,
West Covina has almost no vacant land suitable for residential development. Pursuant to
Government Code §65583.2(g) (2) when a city is relying on underutilized non -vacant sites to
accommodate 50% or more of its lower -income housing need, the methodology used to
determine additional development potential shall demonstrate that the existing use does
not constitute an impediment to additional residential development during the period
covered by the housing element. An existing use shall be presumed to impede additional
residential development, absent findings based on substantial evidence that the use is likely
to be discontinued during the planning period. The following analysis has been prepared in
conformance with these provisions of State law.
Most new residential development in West Covina is expected to occur in two general
areas: the Downtown Plan Area and the Mixed Use Overlay Zone.
Downtown Plan Area
As discussed previously in the Constraints section, a primary focus of the General Plan is
encouraging the redevelopment and improvement of the City's Downtown, which includes
the Plaza West Covina shopping mall, located south of Interstate 10. In 2016 the City
adopted the Downtown Plan & Code, which include development standards to encourage
and facilitate the development of higher -density residential infill and mixed -use projects by
allowing reduced parking requirements and deviations from the standards typically
required in multi -family residential zones. Residential densities up to 54 units/acre are
allowed in the Downtown. The Downtown Plan area is shown in Figure B-1.
Legend
mn. agN.ye
I 1 Ammel KeepingO day Zane
L l A.I. Ru.O H., Zo
n DawmmnPlan Ovedey Zo
I y HIIIeIdeO deybne
Downtown Mn 2onllp 2W2
General W WnZene
U,Mn Nelghb.,ha dZone
U,Mn Gnu. Zone
Tde end Open Spn
Ovlc Zone
OrM1er
Figure B-1
Downtown Plan Overlay Zone Map
C
o®DD
AW nYimn n n .WI
City of West Covina 81
Appendix B - Sites Inventory
Mixed Use Overlay Zone
The General Plan encourages a wide range of building types within the Commerce land -
use designation, including a mix of functions such as commercial, entertainment, office and
housing at densities up to 54 units per acre in the Downtown Plan area and up to 20 units
per acre outside the Downtown Plan area. The Mixed Use Overlay (MUO) Zone establishes
development standards for housing and mixed -use at densities up to 20 units/acre in non-
residential zones outside the Downtown Plan area consistent with the intent of the General
Plan.
Allowable residential uses in the MUO area include single-family detached or attached
units, home occupations and low barrier navigation centers. SB 35 projects and
developments providing at least 25% low-income units are eligible for ministerial review and
approval by the Community Development Director subject to the Multifamily Objective
Design Standards. A minimum leasable commercial gross FAR of 0.15 is required for mixed -
use projects to serve residential uses with a 45-foot height limit.
City of West Covina 82
Appendix B - Sites Inventory
Figure B-2
Mixed Use Overlay Zone Map
City of west Covina
Mixed -Use Overlay Zane
: mow .4.:"-7
Wesi Covina Baundpry
E) mixed -use Ovedw lent
City of West Covina 83
Appendix B - Sites Inventory
Affordability Assumptions
Based on the "default density" provisions of State law,3 sites of at least one-half acre zoned
to allow multi -family or mixed -use development at 30+ units/acre are deemed suitable for
very -low- and low-income housing, while sites allowing multi -family development at a
density of 12 to 29 units per acre are considered suitable for moderate -income housing. Sites
allowing residential development at less than 12 units per acre are assigned to the above -
moderate income category. Small sites less than one-half acre in size are assigned to either
the moderate or the above -moderate category pursuant to Government Code
§ 65583.2(c) (2) (A).
Development Trends and Assumptions for Underutilized Sites
Recent real estate development trends in the San Gabriel Valley have been highly
favorable for multi -family development and the City has seen significant interest in housing
redevelopment on non -vacant properties. Table B-3 illustrates the strong interest in multi-
family and mixed -use redevelopment in West Covina. These examples demonstrate that
existing uses on nonvacant commercial properties do not constitute an impediment to
redevelopment. While the assessed improvements -to -land (I/L) ratio is often used as an
indicator of economic underutilization, it should be noted that 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.
A recent example of new mixed -use develop-
ment on a non -vacant site in the Downtown is
The Colony, a 5-story 450-unit project at a
density of 68 units/acre. This project includes
ground floor commercial with 4 residential
levels above and is built at 127% of the
maximum density for the Downtown zone. The
site was previously occupied by a furniture
store.
Table B-3 summarizes recent housing development projects in West Covina on non -vacant
sites. This summary shows that the average density of these projects was over 100% of the
maximum allowable density under zoning regulations, and all but one of the projects had a
density of at least 89% of the allowable maximum. In recent years, there have been no
applications in West Covina for 100% non-residential development in zones that allow both
residential or non-residential uses.
Based on this analysis the realistic capacity of parcels in the sites inventory (Table B-4) has
been conservatively estimated as 75% of the maximum allowable.
3 California Government Code§65583.2(c)(3)(B)(iv)
City of West Covina 84
Appendix B - Sites Inventory
Underutilized Sites Inventory
Underutilized sites suitable for housing
development are listed in Table B-4. This table
demonstrates that there is potential capacity
for approximately 8,864 new housing units on
these sites. All of the sites assigned to the lower -
income categories are located within the
Downtown Plan area (Figure B-1). The General
Plan establishes allowable densities of up to 54
units/acre in the Downtown Plan area.
Each of the sites identified as suitable for lower -
income housing has one or more of the
following factors that enhance its potential for
additional housing development during the
planning period:
• Location near high -quality transit
• Vacant buildings or lower -value uses
such as storage
• Low value of site improvements
compared to land value (I/L ratio)
• Structures more than 40 years old
w0Sc uwwa
Downtown Plan & Code
aewh4ww.bswrx,
1 µ
• Low development intensity/density compared to the allowable intensity under
current zoning
• Existing nonconforming buildings
• Other nearby sites within the Downtown Plan area have recently been approved
for housing development (see Table B-2 and photo above)
For all of these reasons, the sites listed in Table B-3 are considered suitable for development
during the planning period. Potential capacity is conservatively estimated as 75% of the
allowable density.
Availability of Infrastructure
Adequate water, wastewater and dry utilities are available to serve the sites identified for
potential development during the planning period.
Environmental Constraints
Although there are a variety of environmental issues (e.g., geological conditions, flood
hazards) that affect development, these issues are not expected to preclude development
of identified sites during the planning period.
Accessory Dwelling Units
Under State law, two accessory dwelling units (ADUs) - one ADU and one junior ADU (JADU)
- may be permitted on most single-family residential lots. Therefore, ADUs represent a
City of West Covina 85
Appendix B — Sites Inventory
significant source of new affordable housing that can be created within the fabric of
existing residential neighborhoods. To encourage property owners to build ADUs or JADUs,
the City has created a webpage4 with application instructions, development standards and
sample plans.
As residents have become more aware of opportunities for ADUs, building permits during
the past 3 years in West Covina have shown a steadily increasing trend in ADU development
as follows:
2019: 15 ADU permits
2020: 17 ADU permits
2021. 20 ADU permits
Total: 52 ADU permits (average 17.3 per year)
A comprehensive study of ADU affordability in Southern California5 recently conducted by
the Southern California Association of Governments (SCAG) concluded that a significant
portion of ADUs are affordable to low- and moderate -income households. Based on recent
ADU permit trends and SCAG's analysis, it is assumed that an average of 17.3 ADUs per year
(143 total ADUs) will be produced in the following income categories during the 2021-2029
projection period.
Source: City of West Covina, 2022; SCAG 2020
Program 3.4 in the Housing Plan describes actions the City will take to encourage the
continued production of ADUs. In addition to monitoring legislation and updating City ADU
regulations as necessary to ensure ongoing consistency with State law, the City will
incentivize and promote ADU development in the following ways:
• Assist property owners with ADU applications
• Post informational ADU flyers in City Hall, on the Planning Department website and
other public places
• Explore and pursue ADU funding assistance annually
• Modify development standards
• Reduce fees beyond what is required by State law
• Provide pre -approved ADU plans
4 https://www.westcovina.orci/departments/community-development/planning-division/adu-accessory-
dwelling-units
5 https://scaci.ca.ciov/sites/main/files/file-attachments/adu affordability analysis 12012Ov2.pdf?1606868527
City of West Covina 86
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Appendix C -
.........................................................................................................................
Public Participation
Public participation is an important component of the Housing Element update.
Government Code §65583(c) (8) states that "The local government shall make diligent effort
to achieve public participation of all the economic segments of the community in the
development of the housing element, and the program shall describe this effort." Public
participation played an important role in the formulation and refinement of the City's
housing goals and policies and in the development of a Land Use Plan that determines the
extent and density of future residential development in the community.
To ensure that the interests of lower -income households and persons with special needs
were represented, upon initiation of the Housing Element update process the City prepared
an updated list of stakeholders that included affordable housing developers, housing
advocates, organizations serving the needs of low-income households and persons with
special needs (see Table C-1). In addition, to ensure access for non-English speakers, the
City has bilingual staff (Spanish and English) and can provide translation services upon
request. The City website also includes a feature that enables viewers to translate the
content into many different languages.
City residents and other interested parties were given many opportunities to identify housing
issues of concern, recommend strategies, review the draft Housing Element, and provide
recommendations to decision -makers. A Housing Element web page was established to
provide interested persons with information including meeting notices, agendas, staff
reports, Frequently Asked Questions (provided below) and other reference materials. An
online housing survey was also conducted (see results below).
The following public meetings were conducted regarding the Housing Element update:
May 20, 2021
Public Workshop #1
October 27, 2021
Town Hall meeting
February 8, 2022
Planning Commission meeting
March 1, 2022
City Council meeting
May 24, 2022
Town Hall meeting
October 11, 2022
Planning Commission public hearing
TBD
City Council public hearing
Prior to each public meeting, notices were posted on the City's website and also sent
directly to each organization and person on the stakeholder list either by email or U.S. mail,
or both. Notification was also published in the local newspaper in advance of the public
City of West Covina 116
Appendix C - Public Participation
hearings. Copies of the draft Housing Element were made available for review at City Hall
and were posted on the City website, and notices were sent directly to housing interest
groups and organizations that serve the City's special needs populations (see Table C-1).
City of West Covina 117
Table C-1
Housing Element Stakeholder Groups
Organization
Housing Authority of Los Angeles County
700 West Main Street
Alhambra
Baldwin Park Housing Authority
14403 Pacific Avenue
Baldwin Park
San Gabriel/Pomona Regional Center
761 Corporate Center Or
Pomona
Southern California Housing Rights Center
520 S. Virgil Avenue, Suite 400
Los Angeles
Human Services Association
6800 Florence Ave.
Bell Gardens
L.A. County Public Social Services
12860 Crossroads Parkway South
Industry
Lamp Community Homeless Drop In Ctr
627 San Julian Street
Los Angeles
Los Angeles Mission
303 East 5'th Street
Los Angeles
TELACU Development Corporation
5400 E Olympic Blvd,
Commerce
Habitat for Humanity
2111 Bonita Avenue
La Verne
Mercy Housing California
1500 S. Grand Avenue, Suite 100
Los Angeles
BRIDGE Housing Corporation
19200 Von Karmen Avenue
Irvine
LINC Housing
110 Pine Avenue, Suite 500
Long Beach
So. Calif. Association of Nonprofit Housing
501 Shatto Place, Suite 403
Los Angeles
Abode Communities
701 East 3ro Street, Suite 400
Los Angeles
California Housing Partnership Corporation
800 S. Figueroa Street, Suite 760
Los Angeles
Shelter Partnership
523 W. 6th Street #616
Los Angeles
San Gabriel Valley YMCA— WINGS Shelter
943 N. Grand Avenue
Covina
American Red Cross/San Gabriel Valley
1838 E. Workman Avenue
West Covina
Salvation Army
180 East Ocean Blvd., Suite 500
Long Beach
Assistance League/Pomona Valley
655 N. Palomares Street
Pomona
Catholic Charities/Brother Miguel Center
315 N. Park Avenue
Pomona
Catholic Charities/West Covina
415 Glendora Avenue, Suite F
West Covina
Chinatown Service Center
767 N. Hill Street, Suite 400
Los Angeles
Cold Weather Shelter
P.O. Box 76
San Gabriel
Covina Area Emergency Aid
534 N. Barranca Avenue
Covina
Dellhaven Community Center
15135 Fair rove Avenue
La Puente
East San Gabriel Valley Coalition for the Homeless
1345 Turnbull Canyon Road
Hacienda Heights
Elizabeth House
P.O. Box 94077
Pasadena
Filipino American Service Group
135 N. Park View Street
Los Angeles
Food Finders
3434 Atlantic Avenue
Long Beach
Information Line/Los Angeles
P.O. Box 726
San Gabriel
WIC Program
12781 Schabarum Avenue
Irwindale
Love, IncfWorld Vision
P.O. Box 3505
Covina
Volunteers of America
1760 W Cameron Ave
West Covina
Assistance League of Covina Valley
636 E San Bernardino Road
Covina
Action Food Pantry
2110 W Francis uito Avenue
West Covina
She herd's Pantry
1418 Arrow Hwy
Irwindale
Inland Valley Hoe Partners
1553 N. Park Avenue
Pomona
Citrus Valley Health Foundation
1115 S. Sunset Avenue
West Covina
Low Income Investment Fund
800 S. Figueroa Street, Suite 1800
Los Angeles
Santa Anita Family Services
206 E. Las Tunas, Suite 12
San Gabriel
A Community of Friends
3701 Wilshire Blvd, Suite 700
Los Angeles
Beyond Shelter
340 North Madison Avenue
Los Angeles
House of Ruth
P.O. Box 459
Claremont
Brookhollow Apartments
2600 S. Azusa Avenue
West Covina
The Promenade
1333 W. Garvey Avenue
West Covina
Lark Ellen Village Apartments
1350 E. San Bernardino Road
West Covina
Mauna Loa Apartments
2000 W. Pacific Avenue
West Covina
Heritage Park Senior Apartments
1800 W. Badillo Street
West Covina
Vintage Gardens
1950 Badillo Street
West Covina
West Covina Senior Villas
1842 E. Workman Avenue
West Covina
West Covina Senior Villas II
1838 E. Workman Avenue
West Covina
City of West Covina 118
Appendix C — Public Participation
The public comments resulting from this broad effort to involve all segments of the
community were considered by City decision -makers in preparing this Housing Element
update. Common themes raised during the update and how those comments are
addressed in the Housing Element are summarized in Table C-2 below.
Table C-2
Summary of Public Comments
Comment
How this Comment was Addressed
There is not sufficient housing in West Covina to
This is unfortunately the case in nearly all areas, and while cities have an
meet the need.
important role in facilitating additional housing development, there are many
other factors that restrict development or contribute to high housing cost. The
Housing Element identifies many strategies the City of West Covina is
implementing to encourage housing production and affordability.
Environmental issues such as water supply limit
The Housing Element includes analysis of environmental and infrastructure
the amount of new housing
constraints on potential housing development.
Housing assistance for seniors is needed
The Housing Element identifies programs to address the housing needs of
seniors and other groups with special housing needs.
The City should publicize housing programs and
In addition to the City website, information on housing programs and
public meetings on its website
meetings is made available in City Hall, in other public offices, and in social
media.
The Housing Element seems to equate areas
This is certainly true, and the City's efforts focus on maintaining and
with older housing as being lower income, but
improving older neighborhoods.
that's not always the case.
The shortage of affordable housing is in part due
The State's dissolution of redevelopment agencies resulted in a loss of about
to the abolishment of Redevelopment Agencies.
$1 billion per year in funds for affordable housing statewide.
Cities should encourage homes that are
The City encourages housing accessibility through building codes and also
compatible with seniors.
through reasonable accommodation for persons with disabilities.
Requirements for more housing need to consider
State housing mandates through the Regional Housing Needs Assessment
the impact of additional vehicles and traffic on
do not consider impacts such as increased traffic.
existing neighborhoods.
Cities should require affordable housing in some
Mandatory requirements for affordable housing (referred to as "inclusionary
of the more expensive developments.
housing") have been adopted in some cities; however, other strategies such
as density bonus incentives can also facilitate production of affordable
housing.
If a site is listed in the inventory, is it required to
No, the sites inventory only describes where additional housing could be built
be developed for affordable housing?
based on zoning regulations. Property owners will decide if and when
development occurs. The City or the State cannot force property owners to
develop their property for housing.
The sites inventory should Include the HCD-
As noted in Appendix B, the sites inventory includes conservative
recommended buffer of at least 15-30% extra
assumptions regarding the number of potential housing units to ensure a
capacity in order to avoid violating the No Net
buffer above the RHNA.
Loss requirement
Lower -income sites should be located in high
As noted in the sites inventory and the AFFH analysis, all of the sites are
opportunity areas to affirmatively further fair
located in areas identified by TCAC as high or moderate resource.
housing.
Housing element updates should use an HCD-
The ADU estimate in the sites inventory is based on HCD methodology.
recommended "safe harbor' methodology for
forecasting future ADU production.
The Southwest Regional Council of Carpenters
The City understands SRCC's desire to maximize the use of union labor in
recommends that the City require housing
housing developments and the potential air quality benefits of local hire
projects to require local hire and use of a skilled
policies. While such requirements would benefit SRCC's members, such
and trained workforce to build such projects.
requirements would also increase the cost of housing.
City of West Covina 119
Appendix C — Public Participation
Comment
How this Comment was Addressed
Development should not permanently displace
As noted in Appendix B (Sites Inventory) very few of the sites identified for
current residents. Housing replacement
future housing development are occupied by residential uses; therefore,
programs, temporary housing vouchers, right of
minimal displacement of existing residents will occur. In rare instances where
return, and demolition controls will create
existing housing units could be displaced, appropriate provisions will be
stability for renters while allowing new homes to
required consistent with State law..
be built for new households and to
accommodate the growth associated with RHNA.
In your sites inventory and rezoning programs,
you should prioritize development on sites with
owner -occupied housing & commercial uses
over those with existing rent -controlled
apartments or other rental housing with lower
income residents.
The housing element should identify
The Housing Element supports home ownership through first-time homebuyer
opportunities to create a variety of for -sale
programs as well as through the expansion of housing and mixed -use
housing types and create programs to facilitate
development opportunities.
property ownership among excluded groups.
Ensure that a site's density will accommodate
As described in the Constraints analysis and Appendix B (Sites Inventory),
the number of homes that are projected to be
development standards such as height and FAR are appropriate to facilitate
built. In addition, make sure height limits,
development at the densities assumed in the sites inventory.
setback requirements, FAR, and other controls
allow for adequate density and the ability to
achieve a site's realistic capacity. This density
should be emphasized around jobs and transit
and should go beyond the Mullin density in those
areas.
Allow residential to be built in areas that are
As described in Appendix B (Sites Inventory) the Mixed Use Overlay zone
zoned for commercial use.
allows higher -density residential development in areas currently zoned only
for non-residential use.
City of West Covina 120
Appendix C - Public Participation
Frequently Asked Questions
2021 Housing Element Update
What is a Housing Element?
State law' requires each city to adopt a comprehensive, long-term General Plan for its
physical development. General Plans include several "elements" that address various
topics. The West Covina General Plan' - referred to as Plan WC - is organized under the
following themes:
• Our Natural Community (Conservation, Open Space)
• Our Prosperous Community (Economic Development)
• Our Well -Planned Community (Land Use/Design, Housing, Parks/Recreation)
• Our Accessible Community (Circulation)
• Our Resilient Community (Land Use)
• Our Healthy & Safe Community (Public Health, Safety, Noise, and Land Use)
• Our Active Community (Land Use, Open Space, Parks/Recreation)
• Our Creative Community (Culture)
Plan WC was adopted in 2016 and has a time horizon of about 20 years. However, State
law requires that the Housing Element be updated every 8 years. Housing Element
planning periods are sometimes referred to as "cycles". The City's current Housing
Element covers the planning period extending from 2013 to 2021, which is referred to
as the "5'" Housing Element cycle" in reference to the five required updates that have
occurred since the comprehensive revision to State Housing Element law in 1980. Every
city in the Southern California Association of Governments ("SCAG") region' is required
to prepare a Housing Element update for the 6" planning cycle, which spans the 2021-
2029 period, regardless of when the other elements of the General Plan were adopted.
State law° establishes detailed requirements for Housing Elements, which are
summarized in California Government Code Section 65583:
The housing element shall consist of an identification and analysis of existing and
projected housing needs and a statement of goals, policies, quantified objectives,
financial resources, and scheduled programs for the preservation, improvement,
and development of housing. The housing element shall identify adequate sites for
housing, including rental housing, factory -built housing, mobile homes, and
emergency shelters, and shall make adequate provision for the existing and
projected needs of all economic segments of the community.
'California Government Code Sec. 65300 et seq.
' https://ww. mAcminaom/departments/community-develoomea/planning-division/general-plan
3 The SCAG region includes Los Angeles, Orange, Riverside, San Bernardino, Vemura and Imperial counties.
' California Government Code Sec. 65580 et seq.
May 2021
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City of West Covina 121
Appendix C — Public Participation
City of West Covina 2021 Housing Element FAQ
2. What are the most important issues that must be
addressed in the Housing Element?
The major issues that must be addressed in the Housing Element are: 1) how City
policies, plans and regulations help to meet the region's housing needs for households
of all income levels; and 2) how City land use regulations accommodate the special
housing needs of persons with disabilities or other difficulties.
• Accommodating Regional Housing Needs. Every community is dependent on a
variety of low- and moderate -income workers in jobs such as child and elder
care, medical support, business and personal services, retail trade, construction
and maintenance. Governmental programs provide funding assistance for
affordable housing, but city plans and regulations determine the type and
location of new housing. Therefore, a sufficient supply of affordable housing is
dependent on both city regulations and housing subsidies. Under State law' all
cities are required to plan for additional housing to accommodate population
growth and existing housing problems such as overcrowding and high housing
cost. State law recognizes that most housing is built by private developers and
builders, not cities. However, cities are required to adopt policies, plans,
development regulations and standards to encourage a variety of housing types
that are affordable for persons of all income levels, including multi -family rental
housing and accessory dwelling units ("ADUs"). The Regional Housing Needs
Assessment ("RHNA") is the method by which each jurisdiction's share of new
housing needs is determined (see #4 below).
• Housing for Persons with Special Needs. Under State laws cities must also
ensure that their plans and regulations encourage the provision of housing for
persons with special needs including:
✓ Reasonable accommodation for persons with disabilities
✓ Transitional housing
✓ Supportive housing
✓ Residential care facilities
✓ Emergency shelters and "navigation centers"
✓ Large (5+) families
3. What is "affordable" housing?
By definition, housing is usually considered "affordable" when total housing cost,
including utilities, is no more than 30% of a family's gross income. State law describes
five income categories, which are based on county median income as shown in Table 1.
Table 1. Household Income Categories
% of county
Income Category median income
Extremely low Up to 30%
Very low 31-50%
Low 51-80%
Moderate 81-120%
Above moderate Over 120%
Source: California Government Code Sec. 65584(f)
' California Government Code Sec. 65583
° California Government Code Sec. 65583(a)(5)
May 2021 Page 2
City of West Covina 122
Appendix C - Public Participation
City of West Covina 2021 Housing Element FAQ
Affordable housing costs for all jurisdictions in Los Angeles County that correspond to
these income categories are shown in the following table. Affordability figures are
adjusted each year and are based on family size. Table 2 provides figures for a 4-person
family in Los Angeles County in 2020/21.
Table 2. Income Categories and Affordable Housing Costs - Los Angeles County
%
Extremely lowr
S33,800
$845
'
Very low
$56,300
$1,407
'
Low
$90,100
$2,252
"
Moderate
$92,750
$2,319
$375,000
Above moderate
Over $92 750
Over $2 319
Over $375 000
Assumptions:
-Based on a family of 4 and 2020 State income limits
-30%of gross income for rent or principal, interest, taxes & insurance plus utility allowance
-10%down payment, 3,75%interest, 1.25%taxes &insurance, $300 HOA dues
" For -sale affordable housing is typically at the moderate -income level
Source: Cal. HCD; JHD Planning LLC
4. What is the RHNA why is it important?
Each California city is required to plan for new housing to accommodate a share of
regional needs. The Regional Housing Needs Assessment ("RHNA") is the process
established in State law' by which each city's housing needs are assigned.
Prior to each Housing Element planning cycle the region's total housing need is
determined by HCD based upon economic and demographic trends, existing housing
problems such as overcrowding and overpayment, and additional housing needed to
ensure reasonable vacancy rates and replace units lost due to demolition or natural
disasters. The total housing need for the region is then distributed to cities and counties
by SCAG based upon criteria established in State law.'
In 2019 HCD determined that the total new housing need for the entire SCAG region in
the 611 Housing Element cycle is 1,341,827 units. SCAG then prepared a RHNA plan that
fully allocates the total RHNA to jurisdictions in the SCAG region.' SCAG adopted the
final RHNA plan in March 2021.
Table 3 shows the RHNA allocations for West Covina, Los Angeles County, and the entire
SCAG region.
Table 3. 6" Cycle RHNA - West Covina, Los Angeles County and SCAG Region
The RHNA distributes each jurisdiction's total housing need by the income categories
shown in Tables 1 and 2 above (the extremely -low and very -low categories are combined
California Government Code Sec. 65584 et seq.
California Government Code Sec. 65584(d)
http://w ..scan.ca.gov/programs/pages/housing.wpx
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City of West Covina 123
Appendix C - Public Participation
City of West Covina 2021 Housing Element FAQ
for RHNA purposes). For West Covina the 611 cycle RHNA allocation by income category is
shown in Table 4.
Table 4. 6'" RHNA by Income Category - West Covina
Very Above
Low Low Moderate Moderate Total
1,653 850 865 1,978 5,346
Source: SCAG, 3/4/2021
Is the RHNA a construction quota or mandate?
The RHNA allocation identifies the amount of additional housing a jurisdiction would
require in order to have enough housing at all price levels to fully meet the needs of its
existing population plus its assigned share projected growth over the next 8 years while
avoiding problems like overcrowding and overpayment. The RHNA is a planning
requirement that determines housing need, not a construction quota or mandate.
jurisdictions are not required to build housing or issue permits to achieve their RHNA
allocations, but some provisions of State law establish specific requirements when
housing production falls short of RHNA allocations. One such requirement is
streamlined review and approval of housing development applications that meet specific
standards.10 Other than requirements for streamlined permit processing, there are
currently no legal or financial penalties imposed on cities that do not achieve their RHNA
allocations.
6. What must cities do to comply with the RHNA?
Each Housing Element update must analyze the city's capacity for additional housing
based on an evaluation of land use patterns, development regulations, development
constraints (such as infrastructure availability and environmental conditions) and real
estate market trends. The analysis must be prepared at a parcel -specific level of detail
and identify properties (or "sites') where additional housing could be built consistent
with current regulations. This evaluation is referred to as the "sites analysis" and State
law requires the analysis to demonstrate that the city has adequate capacity to fully
accommodate its RHNA allocation in each income category. If the sites analysis does not
demonstrate that adequate capacity exists to fully accommodate the RHNA, the Housing
Element must describe what steps will be taken to increase capacity commensurate with
the RHNA- typically through amendments to land use and zoning regulations that could
facilitate additional housing development. Such amendments typically include increasing
the allowable residential density or allowing housing to be built in areas that are
currently restricted to only non-residential land uses.
West Covina is fully developed. Why is the RHNA
allocation so high?
SCAG's total RHNA allocation for the 611 cycle is 1,341,827 units compared to 412,137
units in the 51h cycle. There are two main reasons why the region -wide 6'" RHNA
allocation is so much higher than the 511 cycle.
1O California Government Code Sec. 65913.4 (56 35 of 2017)
May 2021 Page 4
City of West Covina 124
Appendix C - Public Participation
City of West Covina 2021 Housing Element FAQ
First, the 5" RHNA allocation was established in 2012 while the severe economic effects
of the "Great Recession" were still adversely affecting growth and the foreclosure crisis
led to high vacancy rates. As a result, the 5`" RHNA was uncharacteristically low. For
comparison, SCAG's 4" cycle (2006-2013) RHNA allocation was approximately 700,000
units.
Second, for the 6`" cycle the State made a major modification to the process for
determining RHNA allocations due to the "housing crisis." In prior RHNA cycles, total
housing need was based only on projected population growth. However, for the 61"
RHNA cycle the State added existing need to the total RHNA calculation. Existing need
includes households that are currently overcrowded (defined as more than one person
per room) or are overpaying for housing (defined as more than 30% of gross income).
The total 6'" cycle RHNA allocation for the SCAG region is comprised of the sum of
existing need and projected need, as follows:
Existing need: 836,857 units
Projected need: 504,970 units
Total need: 1,341,827 units
Source: SCAG, 5/3/2021 letter to the State Legislature
As seen from this breakdown, if existing need were not included (as in prior RHNA
cycles) the total need for the SCAG region would be similar to prior RHNA allocations.
With regard to jurisdictional RHNA allocations, the methodology adopted by SCAG for
the 61" cycle places greater emphasis on the proximity of jobs and transportation rather
than vacant developable land. As a result, the urbanized areas of Los Angeles and
Orange counties are assigned a higher proportion of the region's housing need as
compared to prior cycles even though they generally have much less vacant land than
inland areas.
8. How can West Covina accommodate its RHNA allocation
and remain in compliance with State housing law?
The RHNA is a planning target and cities are not required to achieve their RHNA
allocations but must demonstrate that their land use plans and regulations allow
housing development commensurate with the RHNA. Because there is very little vacant
land in West Covina that is suitable for housing development, the most significant
opportunities for new housing are in areas zoned for non-residential or mixed use.
Under State law, areas that are zoned to allow residential development at a density of 30
units/acre are considered appropriate to facilitate production of affordable housing. As
part of the Housing Element update, the City will evaluate the potential for new housing
development and determine whether any changes to land use plans and zoning are
necessary in order to accommodate the amount of new housing assigned to the City in
the RHNA.
9. Housing development is very expensive in the urban
areas of Southern California. How can cities achieve their
assigned affordable housing needs?
Housing development is very expensive in Southern California, and housing that is
affordable to low- and moderate -income families typically requires large subsidies. While
State housing law is based on the premise that every city has an obligation to use its
governmental powers to encourage housing development at all income levels, it is
May 2021 Page 5
City of West Covina 125
Appendix C - Public Participation
City of West Covina 2021 Housing Element FAQ
recognized that available financial resources are not sufficient to produce all of the
affordable housing needed. Therefore, if a city has adopted appropriate plans and
regulations to encourage housing development commensurate with its RHNA allocation,
it will not be penalized if actual production does not achieve assigned needs.
10. What is "certification" of the Housing Element and why is
it important?
The State Legislature has delegated to the California Department of Housing and
Community Development C'HCD") the authority to review Housing Elements and issue
findings regarding the elements' compliance with the law." When HCD issues a letter
finding that the Housing Element is in substantial compliance with State law it is referred
to as "certification" of the Housing Element. In 2014 HCD determined that West Covina's
current Housing Element was in full compliance with State law. The City is now
preparing a Housing Element update for the 2021-2029 period.
Housing Element certification is important for several reasons:
• Local control. The General Plan and its various elements provide the foundation
for the City's land use plans and zoning regulations, and the Housing Element is
part of the General Plan. If the City were challenged in court on a planning or
zoning matter and the Housing Element were found by the court to be invalid,
the court could order changes to City land use plans or regulations and assume
control over City land use decisions. HCD certification establishes a `rebuttable
presumption of validity"' that the Housing Element is adequate under State law,
which would support the City's legal defense. Recent laws also allow for courts to
impose fines if ajurisdiction fails to adopt a compliant Housing Element."
• Eligibility for grant funds. Some State grant funds are contingent upon
Housing Element certification.
" California Government Code Sec. 65585
"California Government Code Sec. 65589.3.
"AS 101 of 2019
May 2021 Page 6
City of West Covina 126
Appendix C - Public Participation
Online Housing Survey Results
Do you currently live and/or work in West Covina?
77 responses
1 live in West Covina but work
somewhere else
1 work in West Covina but live
somewhere else
1 live and work in West Covina
1 live in West Covina and do not
currently work or I'm retired
What do you consider to be the most pressing housing problems in West Covina?
77 responses
I'm not aware of any significant housin...
Too many people can't find suitable ho...
More housing options are needed for...
More houses and apartments with 4+...
More housing options with supportive...
Fair housing
Risk of foreclosure for homeowners
Risk of eviction for renters
1/4
What do you consider to be the most pressing housing problems in West Covina?
77 responses
Financial assistance with home repair...
More small apartments or condos are...
More temporary housing is needed for...
More housing is needed close to scho...
We don't need more housing. Financi...
Lack of leadership
Homeless
vocational, substance dependence, m...
A2/4V
City of West Covina 127
Appendix C - Public Participation
What do you consider to be the most pressing housing problems in West Covina?
77 responses
Too many homeless people on streets
Homeless people at parks and public...
State legislation not allowing the City t...
High Density Housing is destroying th...
Stop all these illegal garage conversio...
Safety/ homelessness issues need to...
vocational , health and resource for di...
Less new projects of high density / am...
3/4
What do you consider to be the most pressing housing problems in West Covina?
77 responses
Two: low & middle income housing is
unavailable/unattainable; homeless
need homes -public health concern
4/4
If you live in West Covina, what were the main reasons you chose to live here?
75 responses
Close to my workplace
Housing quality
Attractive neighborhoods
Local recreational amenities
Close to family and/or friends
Good housing value
Quality of local schools
Neighborhood safety
1/3
City of West Covina 128
Appendix C - Public Participation
If you live in West Covina, what were the main reasons you chose to live here?
75 responses
City services, facilities and programs
Proximity to shopping and services
1 came here to claim my piece of subu...
Grew up here
Long time resident when a great corn...
no choice
1 was raised in West Covina and later...
I've lived here my entire life (45yrs)
2/3
If you live in West Covina, what were the main reasons you chose to live here?
75 responses
Because I bought my house 20 years
ago. It's gone to hell since then and I
can't wait to leave.
been here all my life
In 2007, was better than where we were
at the time. Seemed nice.
1 grew up here
3/3 -'
City of West Covina 129
Appendix D -
.........................................................................................................................
Fair Housing Assessment
Assembly Bill 686, signed in 2018, establishes a statewide framework to affirmatively further
fair housing (AFFH) with the goal of achieving better economic and health outcomes for all
Californians through equitable housing policies. AB 686 requires cities and counties to take
deliberate actions to foster inclusive communities, advance fair and equal housing choice,
and address racial and economic disparities through local policies and programs. Housing
elements are now required to address the following five components:
• Inclusive and Equitable Outreach: A summary of fair housing outreach and capacity
that includes all economic segments of the community.
• Assessment of Fair Housing: An assessment of fair housing issues, including integration
and segregation patterns, racially or ethnically concentrated areas of poverty,
disparities in access to opportunity, and disproportionate housing needs.
• Analysis of Sites Inventory: An evaluation of whether the sites inventory improve or
exacerbate conditions for fair housing.
• Identification of Contributing Factors: The identification and prioritization of
contributing factors related to fair housing issue.
• Priorities, Goals, and Actions to AFFH: The identification of fair housing goals and
actions that directly address the contributing factors outlined above. The housing
element should include metrics and milestones for evaluating progress and fair
housing results.
1. Outreach
As discussed in Appendix C: Public Participation, early in the Housing Element update
process the City developed a list of stakeholders with local expertise in housing issues,
including fair housing. The stakeholder list included local service providers, affordable
housing developers, and fair housing organizations in an effort to include the interests of
lower -income residents and persons with special needs in the community.
Over the course of the Housing Element update process the City conducted a series of
public meetings. Public notice of each meeting was posted on the City's dedicated
Housing Element website and was also sent directly to persons and organizations on the
stakeholder list. Public meetings were held both online and in person to encourage those
with mobility difficulties to participate. Agendas and other information for each meeting
was posted on the City website to allow interested stakeholders to access to this information
throughout the process. Interested persons were also encouraged to provide input or ask
questions via telephone or email. Please refer to Appendix C for additional information
regarding the outreach efforts and how public input was incorporated into the Housing
City of West Covina 131
Appendix D — Fair Housing Assessment
Element. All notices and other information posted on the website was available in multiple
languages.
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In addition to public workshops and hearings, the City also directly contacted housing
advocates, housing service providers, and community organizations who serve the interests
of lower -income households and special needs groups to solicit comments on housing
needs, barriers to fair and affordable housing, and opportunities for development.
To encourage continuing stakeholder involvement in local housing issues throughout the
planning period, Program 4.1 includes a commitment to conduct ongoing, proactive
outreach to engage members of all socio-economic groups and recruit members of
underrepresented groups to participate in City meetings.
2. Fair Housing Assessment
This section provides an assessment of fair housing issues in West Covina including fair
housing enforcement and outreach capacity, patterns of integration and segregation,
racial or ethnic patterns of concentration, disparities in access to opportunities, and
disproportionate housing needs, including displacement risk.
City of West Covina 132
Appendix D - Fair Housing Assessment
A. Fair Housing Enforcement and Outreach Capacity
Fair housing complaints can be an indicator of housing discrimination. Fair housing issues
can arise through discrimination against an individual based on disability, race, national
origin, familial status, disability, religion, or sex when renting or selling a dwelling unit.
The U.S. Department of Housing and Urban Development's (HUD) Office of Fair Housing and
Equal Opportunity (FHEO) is the federal agency responsible for eliminating housing
discrimination, promote economic opportunity, and achieve diverse, inclusive
communities. FHEO services and activities include investigating fair housing complaints,
conducting compliance reviews, ensuring civil rights in HUD programs, and managing fair
housing grants.
Locally, the City of West Covina partners with the Housing Rights Center (HRC) to investigate
and address fair housing complaints. HRC is a non-profit organization approved by HUD that
works with local government offices to ensure fair housing laws are upheld. HRC provides
various services to Los Angeles County stakeholders, including tenant/landlord mediation,
credit counseling, and fair housing training and workshops.
During the most recent reporting period for the 2020-2021 fiscal year, the HRC provided
assistance to 66 West Covina residents, 11 of which were related to housing discrimination
and 55 were for other housing issues. HRC noted that of the 11 discrimination inquiries, 9
were related to physical disability and 2 were related to national origin. HRC opened
investigations for 3 of these matters, one of which was successfully conciliated, with the
other 2 closed when the clients withdrew their complaints. Of the 55 residents with general
housing questions, the greatest number addressed notices/evictions (25.5%), seeking
housing (21.8%), and rent increases (12.7%). Most of those residents served (97%) were of low
to extremely -low income and 51.5% reported their ethnicity as Hispanic/Latino.
The City does not have any pending lawsuits, enforcement actions, judgements,
settlements, or findings related to fair housing and civil rights.
The City provides residents with fair housing information by posting links to fair housing
organizations on the City's website.
Program 4.1 is included in the Housing Plan (Chapter 2) to continue to ensure that fair
housing information and links to service providers are available through the City's website,
as well as the City's promotion and distribution of fair housing and anti -displacement
resources to residents, especially those at -risk of displacement.
As seen in Figure D-1, the HCD AFFH Data Viewer reported a Fair Housing Enforcement and
Outreach (FHEO) inquiry rate of less than 0.25 per 1,000 persons for the 2013-2021 period in
West Covina.
City of West Covina 133
Appendix D — Fair Housing Assessment
Figure D-1
FHEO Inquiries - West Covina
West Covina, CA, USA X I Q
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EI M Weat wln
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117.81234.059 Dgree
M
(R) FHEO Inquiries by City (HUD, 2013-2021)
Tote l Inquires per Ona-Thousand People
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lT`iiit]
O a 1 Inquiry
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1.5ingoides
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The Constraints section (Chapter 4) of this Housing Element describes ways that the City
works to address potential impediments to fair housing choice. The City continues to work
cooperatively with the HRC to implement the regional Fair Housing Plan (Al) and to offer fair
housing services and tenant/landlord counseling to residents.
B. Patterns of Integration and Segregation
1) Race and Ethnicity
As seen in Figure D-2, the percentage of non-White population is more than 60% in most
areas of West Covina and is similar to the adjacent cities. The non-White percentage is
slightly lower (41%-60%) in the eastern portion of the city, which is similar to the adjacent
unincorporated County area. Racial characteristics for the larger San Gabriel Valley area
are illustrated in Figure D-3. These maps indicate that there are no significant non-White
population concentrations in West Covina.
City of West Covina 134
Appendix D - Fair Housing Assessment
Figure D-2
Racial Demographics - West Covina
Figure D-3
Racial Demographics - San Gabriel Valley Area
City of West Covina 135
Appendix D - Fair Housing Assessment
2) Persons with Disabilities
As shown on Figure D-4, estimated disability rates in all areas of West Covina are less than
20%, although some census tracts show disability rates less than 10%.
Additional information regarding persons with disabilities by disability type in West Covina is
provided in Figure 3-18 and Figure 3-19 of the Housing Needs Assessment. Some individuals
may experience more than one disability, and some disability types are not recorded for
children below a certain age. Based upon California Department of Developmental
Services (DDS) data, SCAG reported that there are approximately 3,202 persons with
developmental disabilities within the ZIP code areas that encompass the City of West
Covina.
Figure D-4
Population with a Disability - West Covina
West Covina, CA, USA X
".� —h rem ks br Wart Co...
(R) Population with a Disability (ACS, 2015 - 2019) - Traa
Pemaneaf Populab—wrth a Disability
>40%
30%-40%
20%-30%
10%-20%
<10%
IN Li
boa
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City of West Covina 136
Appendix D - Fair Housing Assessment
Disability data for the larger San Gabriel Valley area are shown in Figure D-5. This map shows
that disability rates in West Covina are generally similar to the region as a whole.
Figure D-5
Population with a Disability - San Gabriel Valley Area
(R) Population with a Disability (ACS, 2015 - 2019)-Tract
ercent of Population with a Diubiliry
>a0%
30%- 40%
20%-30%
10%-20%
® <10%
The housing needs of persons with disabilities vary, but generally include accessible and
affordable housing, and access to supportive services. More severely disabled individuals
may require a group living environment where supervision is provided, and the most severely
affected individuals may require an institutional environment where medical attention and
physical therapy are provided. As discussed in detail in Section 4 - Housing Constraints, the
City of West Covina facilitates housing for persons with disabilities through its Reasonable
Accommodation procedures and regulations to encourage production of supportive
housing and residential care facilities.
3) Familial Status
Familial status refers to the presence of children under the age of 18, whether the child is
biologically related to the head of household, and the martial status of the head of
households. Families with children may face housing discrimination by landlords who fear
that children will cause property damage. Some landlords may have cultural biases against
children of the opposite sex sharing a bedroom. Differential treatments such as limiting the
number of children in a complex or confining children to a specific location are also fair
housing concerns.
Single -parent households are also protected by fair housing law. Female -headed
households with children require special consideration and assistance because of their
greater need for affordable housing and accessible day care, health care, and other
City of West Covina 137
Appendix D - Fair Housing Assessment
supportive services. As discussed in Section 3.7.3 of the Housing Needs Assessment, about
16.3% of West Covina households are female -headed (compared to 14.3% in the SCAG
region), 6% are female -headed and with children (compared to 6.6% in the SCAG region),
and 0.9% are female -headed and with children under 6 (compared to 1.0% in the SCAG
region). Figure D-6 shows the percentage of children living in married couple households in
West Covina while Figure D-7 shows similar data for the San Gabriel Valley region as a whole.
Figure D-6
Percentage of Children in Married Couple Households - West Covina
(R) Felon of Children in Marred- Couple Households(A , 2015-2019) - Tract
Pe, ,tol Ch,ld,e,,,Ma./M-Couple Households
hil , 80%
hk 60% 80%
40%. M%
20% a0%
e20%
Figure D-7
Percentage of Children in Married Couple Households - San Gabriel Valley Area
(R) Percent of Children in Married -Couple Households
P-1 of Ch ld,en in Married -Couple Households
hill> 80%
' 60%-80%
40%-60%
City of West Covina 138
Appendix D - Fair Housing Assessment
4) Income
Identifying low/moderate-income (LMI) areas is an important aspect in understanding
patterns of segregation. HUD defines a LMI area as a Census tract or block group where
over 51 % of the population is LMI (based on HUD income definition of up to 80% of the AMI).
Figure D-8 shows that the percentage of LMI households in most areas West Covina range
from 25 to 75%, although a few tracts in the east -central portion of the city show LMI
percentages less than 25%. There are no tracts in West Covina with an LMI percentage
higher than 75%.
For the larger San Gabriel Valley area, higher LMI concentrations are generally located in
the western part of the valley (Figure D-9).
Figure D-8
Low/Moderate Income Population - West Covina
(A) Low to Moderate Income Population (HUD) -Tract
Percent LowModerateIncome Population
J5%-100%
50%-]5%
25%-50%
<25%
City of West Covina 139
Appendix D - Fair Housing Assessment
Figure D-9
Low/Moderate Income Population - San Gabriel Valley Area
C. Racially/Ethnically Concentrated Areas
1) Racially/Concentrated Areas of Poverty
According to HUD, a racially or ethnically concentrated area of poverty (R/ECAP) is an area
in which 50% or more of the population identifies as non-White and 40% or more of residents
are living in poverty. As shown in Figure D-10, there are no designated R/ECAP areas in West
Covina. The nearest R/ECAP areas to West Covina are located in El Monte to the west and
Pomona to the east (Figure D-1 1).
City of West Covina 140
Appendix D - Fair Housing Assessment
Figure D-10
Racially/Ethnically Concentrated Areas of Poverty - West Covina
West Covina, CA, USA x C,
W,,,Ca
ki V Y la (R)Racially or riatly Concentrated Areas of Povedy'MCAP'S'(HUD, 21M9.2013)
Toad
C�e��WECAP Sco,e
I, A. usok, ®t.RrECnP
0-N—Ii
I ¢O a• -err i iubw wP. _
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Figure D-11
Racially/Ethnically Concentrated Areas of Poverty - San Gabriel Valley Area
City of West Covina 141
Appendix D — Fair Housing Assessment
Recent Census estimates regarding poverty status of households in West Covina are shown
in Figure D-12. As seen in this map, poverty rates are below 10% in most census tracts,
although some areas have poverty rates between 10 and 20%. Figure D-13 shows that
poverty rates in West Covina are similar to other areas of the San Gabriel Valley.
Figure D-12
Poverty Status - West Covina
West Covina, CA, USA X "
Show search reso Its for Wert Co.. � - _-
e (R)Poverty Sl s(AC5, 2015-2019)-Taa
Percent of Population whose income in the pan 12 momhs Is Ixlow poverty level
hk >4M
kh 30% M%
hk 20%-30%
bk 10%-20%
IJ <10%
U
Figure D-13
Poverty Status - San Gabriel Valley Area
City of West Covina 142
Appendix D — Fair Housing Assessment
Programs in the Housing Plan that specifically target assistance for households with incomes
below the poverty line include 1.2 - Monitor and Preserve Affordable Housing, 2.1 -
Acquisition and Rehabilitation, 2.2-Affordable Housing Financing, 2.4-Los Angeles County
Partnerships, 3.1 - Reduce Development Constraints, 3.2 - Density Bonus, 3.3 - Priority
Processing for Affordable and Special Needs Housing, 3.4 - Accessory Dwelling Units, 3.5 -
Manufactured Housing and Mobile Home Rent Control, 4.1 - Fair Housing, 4.2 - Reasonable
Accommodation for Persons with Disabilities, 4.3 - Senior Center Shared Housing, 4.4 -
Homeless Assistance, 4.5 - Housing for Persons with Disabilities, 5.1 - Ensure Adequate Sites
to Accommodate the RHNA, and 5.3 - Local Agency Surplus Land for Affordable Housing.
2) Racially/Concentrated Areas of Affluence
According to the Housing and Community Development AFFH Guidance Memo,
"segregation is a continuum, with polarity between race, poverty, and affluence, which
can be a direct product of the same policies and practices." Therefore, both sides of the
continuum must be examined. While HCD does not provide a standard definition for RCAAs
and the HCD Data Viewer does not currently provide RCAA maps, available data regarding
the percentage White population and median household income can provide insight into
racially concentrated areas of affluence.
Table D-1 compares the median household incomes of White/non-Hispanic residents in West
Covina and Los Angeles County as a whole to the median incomes for the total population
of the city and county. This table shows that in West Covina, the median income for non -
Hispanic White households is about 7% lower than for the city's population as a whole.
Countywide, the median income for non -Hispanic White households is about 28% higher
than for the population as a whole. These data suggest that there is much less racial
concentration of affluence in West Covina that in Los Angeles County as a whole.
Table D-1
Median Household Income by Race - West Covina and Los Angeles County
White Alone (not Hispanic)
All Households
$79,909
$85,626
$91,323
$71,358
Source: U.S. Census ACS 2016-2020
B19013 (all)
B19013H (white alone, not Hispanic)
D. Disparities in Access to Opportunity
1) Overview
California housing law requires cities to analyze disparities in access to opportunity as part
of the fair housing assessment. The California Tax Allocation Committee (TCAC) and the
California Department of Housing and Community Development (HCD) have developed
maps showing access to various types of opportunities such as education, economic,
transportation, and environmental indicators.
City of West Covina 143
Appendix D — Fair Housing Assessment
2) Educational Opportunity
The West Covina Unified School District (WCUSD) serves the majority of West Covina, while
Covina -Valley Unified School District also serves portions of the city. As shown in Figure D-14,
TCAC educational opportunity scores are highest (>0.75) in the eastern and western
portions of the city, while the majority of the city received a score of 0.5 - 0.75). The lowest
scores (0.25 - 0.50) were reported in a small area in the for southern portion of the city
adjacent to the City of Industry and unincorporated county territory.
The County Al describes overall school proficiency in the Urban County Area in relation to
race and ethnicity. White and Asian residents generally have greater access to proficient
schools, particularly in Santa Monica and Glendora, while Black and Hispanic residents living
in Palmdale, Inglewood, and Montebello lived among schools with the lowest levels of
proficiency within the Urban County area. The largest concentrations of low scores are
found near Downtown Los Angeles. Figure D-15 shows educational opportunity scores in
West Covina in the context of the larger San Gabriel Valley area.
Figure D-14
TCAC Educational Opportunity Areas - West Covina
West Covina, CA USA x Q. ( ®�
56ow zearcb r—ln for Wert Co_. 4
in (R) TCAC Opportunity Areas (2021) -Education Scare Trec[
Education Domain Scare (by region)
No Dam
> 0.75 (More Positive Education Outcomes)
050-OJ5
025-0.50
10.25 (Less Positive Education Outcomes)
fl*M111
City of West Covina 144
Appendix D - Fair Housing Assessment
Figure D-15
TCAC Educational Opportunity Areas - San Gabriel Valley Area
Covina, CA, USA X I UL L
Show search results for Covina,...
=iuAwl
3) Economic Opportunity
":biLu b
ism (R)TGAC Opportunity Areas(2021)-Education Score
Education Domain score (by region)
No Dace
> 0.75 (Mom Positive Education Outcomes)
® 0.50-0.75
l — 0.25-0.50
"p r1`Ll]JO ® <0.25(L ss Positive Eduction Oucomes)
Two factors in measuring the Economic Opportunity Score are job proximity and labor
market engagement. In West Covina, the highest economic opportunity scores (0.5 - 0.75)
are found in the eastern portions of the city (Figure D-16).
The County Al reported that economic opportunity scores for the Urban County area were
similar for Whites, Black, and Asian/Pacific Islander while the score for Hispanics was slightly
lower. However, labor market engagement index values were significantly higher for Whites
and Asian/Pacific Islanders compared to African Americans and Hispanics. Figure D-17
shows economic opportunity scores in West Covina in the context of the larger San Gabriel
Valley area.
City of West Covina 145
Appendix D - Fair Housing Assessment
Figure D-16
TCAC Economic Opportunity - West Covina
ury,
West Covina, CA, USA X Q -
Show search resulaiorWest Co... I -
(R)TCAC OpportunityAreas (2021) - Economic Score -Tract
Economic Domain Scare (by region)
No Data
> 0J5 (More Positive Economic Outcome)
0,50-0.75
0.25-0.50
<0.25 (Leas Positive Economic Outcome)
Figure D-17
TCAC Economic Opportunity - San Gabriel Valley Area
Covina, CA, USA X Q [.
Show search results for Covina....
kk`X s b
q�0
PaG9 (R)TCAC Opportunity Areas (2021)-Economic Score
_ Economic Domain Score (by region)
No Data
> 0.75 (More Poskly, Economic Outcome)
050-OJ5
1
- � 0.25-0.50
<0.25 (Lose Positive Economic Outcome)
City of West Covina 146
Appendix D — Fair Housing Assessment
4) Transportation Opportunity
West Covina enjoys excellent public transportation, as shown in Figure D-18. Metrolink rail
service is accessible at the Covina Transit Center immediately to the north of West Covina,
and several bus routes also serve the city.
Figure D-18
San Gabriel Valley Transit Service Map
N,°, ` San Gabriel Valley
Bus Rail Seroa
Sii RRAMADRz
[11Ao11a1
-
., = .......aR�w.
.N
[E
t aa re. 6 X
eN _
N AN
uX.
NAN
N FAN cIOILE Xa
uere.
d` i
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o
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RIVERSIDE
COUNTY
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According to the County Al, the transit trip index for the Urban County area shows little
disparity among the racial or ethnic classes.
5) Environmental Opportunities
Environmental opportunity scores are related to potential exposure to harmful toxins and
are based on EPA estimates of air quality carcinogenic, respiratory and neurological toxins.
A higher index value means less exposure to toxins.
In West Covina, the highest environmental opportunity scores (0.5 — 0.75) are found in the
northern portion of the city (Figure D-19) while most areas show lower scores (less than 0.5).
City of West Covina 147
Appendix D - Fair Housing Assessment
Figure D-19
TCAC Environmental Opportunity - West Covina
West Covina, CA, USA x
Snow search results for West Co...
a"
(R) TCAC Opportunity Areas (2021)- Environmental Score T.a
Environmental Domain Smre
LNo Data
75 -1 (Mom Positive En—rmmial Outcomes)
.50 .J5
.25 .50
a.25 (Less Positive Environmental Outcomes)
In the context of the larger San Gabriel Valley, environmental opportunity scores in West
Covina are similar to adjacent areas to the east, west and south but lower than areas to the
north (Figure D-20).
I
Figure D-20
TCAC Environmental Opportunity - San Gabriel Valley Area
Covina, CA, USA x
Show search results for Covina,._
LJYLa
(R) TCAC Opportunity Areas (2021) -Environmental Score
Environmental Domain Score
LNo Data
.75 -1 (More Positive Environmental Outcomes(
El - 1 .50-.75
.25-.50
hk<.25(tass Positive Environmental Outcomes)
City of West Covina 148
Appendix D - Fair Housing Assessment
6) Disadvantaged Communities
Senate Bill 1000 (SB 1000) requires cities with identified disadvantaged communities (DACs)
to include environmental justice goals and policies in the General Plan. Per SB 1000, the
California EPA uses CalEnviroScreen, a mapping tool to identify disadvantaged
communities. CalEnviroScreen examines various indicators to characterize pollution and
socioeconomic factors. As seen in Figure D-21 below, portions of West Covina along the 1-10
freeway are classified as disadvantaged communities.
Figure D-21
Disadvantaged Communities - West Covina
City of West Covina 149
Appendix D — Fair Housing Assessment
As seen in Figure D-22, disadvantaged communities in the San Gabriel Valley area are
primarily found to the west and south of West Covina and also in the Pomona area to the
east.
Figure D-22
Disadvantaged Communities - San Gabriel Valley Area
eCovina, CA, USA X Q
Show:e h—.11. for Covina,... 111
1111111.�.M M - M ail
(A) SB 535 Disadvantaged Communities
111111111
E. Disproportionate Housing Needs and Displacement Risk
The AFFH Rule Guidebook (24 C.F.R. §5.152) defines "disproportionate housing needs" as "a
condition in which there are significant disparities in the proportion of members of a
protected class experiencing a category of housing needs when compared to the
proportion of a member of any other relevant groups or the total population experiencing
the category of housing need in the applicable geographic area." The analysis is
completed by assessing cost burden, overcrowding, and substandard housing. In addition,
this analysis examines homelessness and displacement risk.
1) Cost Burden (Overpayment)
A household is considered cost -burdened if it spends more than 30% of its income in housing
costs, including utilities. Reducing housing cost burden can also help foster more inclusive
communities and increase access to opportunities for persons of color, persons with
disabilities, and other protected classes.
Overpayment is a problem for many West Covina residents, particularly lower -income
households. According to recent HUD CHAS estimates (Figure D-23) approximately 5,505
City of West Covina 150
Appendix D - Fair Housing Assessment
renter households (50% of all renters) and 6,215 owner households (32% of all owners) were
paying more than 307o of income for housing. The highest rates of overpayment occur
among very -low-income and extremely -low-income households. The impact of housing
overpayment on lower income households is particularly significant for special needs
populations- seniors, persons with disabilities, and female -headed households with
children.
Figure D-23
Cost Burden by Tenure and Income Category - West Covina
Income by Cost Burden (Renters only)
Cost burden
Cost burden >Total
> 30%
50%
Household Income less -than or- 30% HAMFI
1,970
1,760
2,300
Household Income >30% to less -than or- 50%
1,810
1,175
2,045
HAMFI
Household Income >50%to less -than or- 80%
1,355
255
2,150
HAMFI
Household Income >80%to less -than or-- 100%
255
15
1,275
HAMFI
Household Income >100% HAMFI
115
3,175
Total
5,505
3.205
10,945
Intone by Cost Burden (Owners only)
burden
Cost burden >
Total)
> 30%
50%
Household Income less -than or- 30% HAMFI
965
805
1,305
Household Income >30% to less -than or= 50%
1,100
760
1,690
HAMFI
Household Income >50%to less -than or= 80%
1,850
755
3,180
HAMFI
Household Income >80%to less -than or-- 100%
HAMFI
955
140
2,145
Household Income >100% HAMFI
1,345
175
11,245
Total
6,215
2,635
19,570
As shown in Figure D-24, overpayment among renters is most prevalent in the northern,
portion of the city where more than 60% of renters are overpaying for housing in some
census tracts. When compared to conditions in other areas of the San Gabriel Valley (Figure
D-25) overpayment among West Covina renters appears be similar to adjacent
communities.
City of West Covina 151
Appendix D — Fair Housing Assessment
Figure D-24
Renters Overpaying for Housing - West Covina
W.M CONn., CA, USA X Q
sM1o......,.n,Fs,dv. ��Wea Co
( rll
(R)Cv T mem by Kamm(ACS, 2015.2019)-T.d
P.m` dR.n...... Wd,f—h—C—RmRm, N, T.mm.P.Id Utileim)i. 390
Pem -M.-of X.—Wdlnc
EO% BO%
30% <0%
z 39%
Figure D-25
Renters Overpaying for Housing - San Gabriel Valley Area
X 4 emaiaau
0
(R) Ormpeymem by Remen (ACS. 2015 - 2019)-Tnm
mW Wmv RauwFeld,b. wFom G.a., WmlCam..a Rm,Plm T.mnuP.Id UfIIdw11, 300
bk
- o. Mon d NeuwFdd Inmme
30% Q%
30%
Overpayment among West Covina homeowners ranges from 20% to 60% in most portions
of the city, although higher overpayment rates of 60% to 80% are seen in the eastern
neighborhoods (Figure D-26). Rates of overpayment among homeowners in West Covina
appear to be similar to the adjacent communities of the San Gabriel Valley.
The problems of overpayment are addressed through programs in the Housing Plan
(Chapter 2) including 1.2 - Monitor and Preserve Affordable Housing, 2.1 - Acquisition and
Rehabilitation, 2.2 - Affordable Housing Financing, 2.4 - Los Angeles County Partnerships,
City of West Covina 152
Appendix D - Fair Housing Assessment
3.1 - Reduce Development Constraints, 3.2 - Density Bonus, 3.3 - Priority Processing for
Affordable and Special Needs Housing, 3.4 - Accessory Dwelling Units, 3.5 - Manufactured
Housing and Mobile Home Rent Control, 4.1 - Fair Housing, 4.2 - Reasonable
Accommodation for Persons with Disabilities, 4.3 - Senior Center Shared Housing, 4.4 -
Homeless Assistance, 4.5 - Housing for Persons with Disabilities, 5.1 - Ensure Adequate Sites
to Accommodate the RHNA, and 5.3 - Local Agency Surplus Land for Affordable Housing.
Figure D-26
Homeowners Overpaying for Housing - West Covina
(R)O. q.yment by Home O..(ACS, 2015.2019)-Tnct
Wrcms of Cm—H...Wds wilh Mongego whoa M—N, Own., Cone en 30.0 NI —I or
Mom of Hom.hold Income
Ill >am
hk 60% 90%
aM 60%
20% 0%
<20%
Figure D-27
Homeowners Overpaying for Housing - San Gabriel Valley Area
CoAno, CA U$ x
Shoo s...d—.lss fo, C ,w,...
NEr�!'. 1'
L
F.�3tti (R)Weryaymemby Home Ow m(AC5,2015-2019)-Trot
]0,21 Momo ooumhod com ldswffi Mortgages wM1ou Mond�ly Owner Cosu ere 30.0 Por<mtar
Marc of NouseAald Income
hk -80%
60% BO%
of-w%
City of West Covina 153
Appendix D - Fair Housing Assessment
2) Overcrowding
"Overcrowding" is defined as a housing unit occupied by more than 1.01 persons per room
(excluding kitchens, porches, and hallways). A unit with more than 1.51 occupants per room
is considered "severely overcrowded." The incidence of overcrowded housing is a general
measure of whether there is an available supply of adequately sized housing units.
Overcrowding is also related to overpayment, because households may not be able to
afford a large enough home to accommodate their needs. Overcrowding can lead to a
variety of other problems such as lower educational performance among children,
psychological stress and adverse health impacts.
In West Covina, some neighborhoods in the southern and western portions of the city have
overcrowding rates of 12%-20% while the central and eastern portions of the city have
overcrowding rates less than 12% (Figure D-28). When viewed in the context of the larger
San Gabriel Valley area, overcrowding in West Covina is generally similar to adjacent cities
to the north and east but lower than many areas to the south and west.
The problems of overcrowding are addressed in the Housing Plan through efforts to facilitate
production and preservation of affordable housing (see Programs 1.2 - Monitor and
Preserve Affordable Housing, 2.1 - Acquisition and Rehabilitation, 2.2 - Affordable Housing
Financing, 2.4 - Los Angeles County Partnerships, 3.1 - Reduce Development Constraints,
3.2 - Density Bonus, 3.3 - Priority Processing for Affordable and Special Needs Housing, 3.4 -
Accessory Dwelling Units, 3.5 - Manufactured Housing and Mobile Home Rent Control, 4.1 -
Fair Housing, 4.2 - Reasonable Accommodation for Persons with Disabilities, 4.3 - Senior
Center Shared Housing, 4.4 - Homeless Assistance, 4.5 - Housing for Persons with Disabilities,
5.1 - Ensure Adequate Sites to Accommodate the RHNA, and 5.3 - Local Agency Surplus
Land for Affordable Housing).
City of West Covina 154
Appendix D — Fair Housing Assessment
Figure D-28
Overcrowded Households - West Covina
West Covina, CA, USA X
Show search results for Wes[Co...
0 iel Ga l
u
(R) Overcrowded Households (CHHS) -Trl
Percent of Overcrowded Households
>20%
hk 15.01%-20%
12.01%-15%
8.3%-12%
18.2%(Stscewide Aveage)
Figure D-29
Overcrowded Households - San Gabriel Valley Area
e
AFFH Data Viewer Call Depararrunt of Hl and Cortununity, Development AFFH DATAAND MAPPPING RESOURCI
Covina, CA, USA X r City/Town Boundaries
Q
Show search results for Covina, III
Px�i)
n M ha La (R)Overcrowded Households(CHHS) -Tract
Percent of Overcrowded Households
> 20%
15.01%-20%
r—
� n t , 1201%-15%
8.3%-12%
- s 8.2%(Stawwide Average)
Y+w
City of West Covina 155
Appendix D - Fair Housing Assessment
3) Substandard Housing
The age of a housing unit is often an indicator of housing conditions. Housing units without
proper maintenance can deteriorate overtime. Housing units built before 1980 are the most
likely to need rehabilitation and to have lead -based paint in deteriorated condition. Lead -
based paint becomes hazardous to children and pregnant women when it peels off walls
or is pulverized by windows and doors opening and closing. Also, older units may not be
built to current building standards for fire and earthquake safety.
The age of housing units in West Covina compared to the SCAG region as a whole is shown
in Figure D-30. This chart indicates that about 80% of housing units in West Covina were
constructed before 1980. This suggests that there is likely to be a need for maintenance and
rehabilitation, including remediation of lead -based paint, for a substantial number of
housing units in the city. A general reconnaissance of older neighborhoods in the City
suggests that between 2% and 3% of the City's housing stock is in need of repair, while fewer
than a dozen homes may be in need of replacement. The Housing Plan includes Program
1.1 - Housing Preservation to provide funding assistance to low- and moderate -income
homeowners for home repairs.
Figure D-30
Age of Housing Units - West Covina vs. SCAG Region
40%
3596
.E 30%
m 25%
G
`o
20%
15%
5%
J
20148 201P 2000- 1990- 198D- 1970- 1960- 1950- 1940- 19398
Later 2013 2009 1999 1989 1979 1969 1959 1949 Earlier
West Covina (%) 11% 0.5% 2.7% 6.6% 12.3% 21.3% 122% 37.6% 3.4% 2.3%
SLAG rx.) 10% 1-5% 10.1% 9.5% 15.0% 16.3% 14.5% 15.9% 6.9% 9.3%
■west Ovine(%) ■SM (%)
4) Homelessness
Homelessness is a continuing problem throughout California and urban areas nationwide.
During the past two decades, an increasing number of single persons have remained
homeless year after year and have become the most visible of all homeless persons. Other
persons (particularly families) have experienced shorter periods of homelessness. However,
they are often replaced by other families and individuals in a seemingly endless cycle of
homelessness.
The homeless count conducted by the Los Angeles Homeless Services Authority (LAHSA) in
2020 estimated that there were approximately 58,936 homeless persons Los Angeles County.
City of West Covina 156
Appendix D - Fair Housing Assessment
These include families that might be displaced through evictions, women and children
displaced through abusive family life, persons with substance abuse problems, veterans, or
persons with serious mental illness. West Covina is located within the San Gabriel Valley
Service Planning Area (SPA 3), which had a 2020 homeless estimate of 5,082 people. LAHSA
estimated that there were 124 homeless persons in West Covina in 2020.6
In 1995 the San Gabriel Valley Consortium on Homelessness was created to help the region
develop a strong regional response to the needs of the growing homeless population. The
Consortium has a focus on facilitating partnerships, educating the community and member
agencies, and advocating for appropriate services. In 2019, the Consortium reset its
direction to a more concentrated effort to support and build capacity for local service
providers. The San Gabriel Valley Council of Governments (COG) is another regional
agency that also addresses regional homelessness issues. As a member agency in the San
Gabriel Valley COG, West Covina cooperates with its sister cities to address the issue of
homelessness.
Emergency shelters, low barrier navigation centers and transitional or supportive housing
help to address the needs of the homeless. Services and facilities available for the homeless
in West Covina are coordinated primarily through the Los Angeles County continuum of
care, which 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 following agencies offer homeless assistance in and around West Covina:
• Citrus Valley Health Foundation provides a drop -in center where homeless
persons can access a wide variety of services. The Foundation also serves the
terminally ill and those in need of short-term acute care.
• The Institute for Urban Research and Development provides emergency shelter,
breakfast and dinner, access to showers and toilets, limited case management
services, and referrals to more comprehensive services to homeless families. IURD
is housing participants at the Valley Inn in La Puente and the American Inn & Suites
in Pomona.
• Catholic Charities Brother Miguel Center in Pomona provides vouchers/assistance
referrals for those seeking shelter. They also provide utility disconnection and
eviction prevention services, along with other counseling, training, and
emergency/food assistance.
• YMCA -Wings Shelter for Battered Women located in West Covina provides shelter,
counseling, and other needs of battered women and their children.
• The House of Ruth in Claremont provides services to women and their dependent
children.
6 https://www.lahso.org/documents?id=5201-homelessness-statistics-by-city.pdf
City of West Covina 157
Appendix D — Fair Housing Assessment
• Community Food Bank of West Covina provides assistance and emergency help
for West Covina residents in need of food.
• The Salvation Army offers temporary shelter and food vouchers and referrals for
West Covina and San Gabriel residents. Adult rehabilitation centers are among
the most widely known of all Salvation Army services and comprise the largest
resident rehabilitation program in the United States. Individuals with identifiable
and treatable needs are able to check -in to facilities that assist them in becoming
healthy. At the center they receive adequate housing, nourishing meals and
necessary medical care, and they engage in work therapy. They also benefit from
group therapy, spiritual guidance and skilled addictions counseling in clean and
wholesome surroundings.
• Inland Valley Council of Churches serves homeless families through their
emergency shelter and transitional housing programs. Those in need of shelter are
able to stay a maximum of 30 days while those using the transitional housing are
able to stay between 12 and 24 months.
• The Santa Anita Family Services Senior Center serves low-income elderly with
temporary personal care, in -home care during illness, respite for family caregivers,
employment assistance, housekeeping, and assistance in filling out forms or with
other legal matters. They also offer minor home renovation for low-income seniors
with physical limitations.
• The East San Gabriel Valley Coalition for the Homeless is a nonprofit organization,
helping the homeless find shelter. They offer referral services for medical
appointment, hotel and motel and taxi vouchers, emergency food, sack lunches,
showers and hygiene kits. They also offer referral assistance for paying rent and
utilities. The Coalition also offers a Cold Weather Shelter that runs from mid -
November until the end of March.
The City's zoning regulations related to facilities serving the homeless, including emergency
shelters, low barrier navigation centers, transitional housing and supportive housing, are
discussed in Section 4.1.6 Other Housing -Related Regulations.
5) Displacement Risk
In 2016, the Urban Displacement Project7 team developed a neighborhood change
database to help stakeholders better understand where neighborhood transformations are
occurring and to identify areas that are vulnerable to gentrification and displacement in
Southern California. The database includes Los Angeles, Orange, and San Diego counties,
with gentrification and sociodemographic indicators based on data from the Census
Bureau American Community Survey and shows whether each Census tract gentrified
between 1990 and 2000; gentrified between 2000 and 2015; gentrified during both of these
periods; or exhibited characteristics of a "disadvantaged" tract that did not gentrify
between 1990 and 2015.
7 https://www.urbandisplacement.orci/maps/los-angeles-gentrification-and-displacement/
City of West Covina 158
Appendix D — Fair Housing Assessment
Based on this neighborhood change database, the team found that the areas most
susceptible to displacement in the San Gabriel Valley are portions of Pasadena, Altadena,
Monrovia and Duarte, as well as the cities in the southern portion of the Valley. Figure D-31
shows areas considered vulnerable to displacement in West Covina and surrounding areas.
As noted in the Housing Plan, Program 5.1 includes a commitment to ensure compliance
with legal protections and replacement housing requirements for existing tenants who may
be displaced by new developments.
Figure D-31
Displacement Vulnerability - West Covina
West Covina, CA, USA x D,
-.-cn results fo, West Co._
(A) Sensitive Communities (UCe, Urban Displacement Project)
vulnerable
- - Other
41
tit �iE
As discussed in Section 3.8 of the Housing Needs Assessment, there is one development -
Mountain Shadows - with 84 lower -income units at risk of converting to market rate during
the 2021 to 2031 period. Program 1.2 - Monitor and Preserve Affordable Housing is included
in the Housing Plan to facilitate the preservation of these affordable units.
3. Sites Inventory Analysis
The City's inventory of sites for potential housing is presented in Appendix B. As summarized
in Table B-1, the inventory is comprised of approved or pending projects, non -vacant
underutilized sites and future ADUs. As with most cities in the metro areas of Southern
California, vacant developable land is very rare, and underutilized sites - particularly
commercially -zoned land - provide the majority of future housing development capacity.
Access to opportunity is analyzed in Section D, above. As shown in Appendix B - Sites
Inventory, a significant component to underutilized sites are located in the Downtown Plan
Overlay Zone area. This area is designated by the TCAC/HCD opportunity composite score
map as High Resource and Moderate Resource (Figure D-32).
City of West Covina 159
Appendix D - Fair Housing Assessment
The following findings summarize how the sites inventory furthers fair housing in West Covina.
&au'L
• Sites zoned for high density mixed -use development in the Downtown will include
housing for a variety of income levels, fostering mobility of households in the city.
• Sites in the Downtown are located in the TCAC High Resource and Moderate
Resource areas, which provide access to opportunity.
• A significant portion of the sites identified in the Downtown area do not currently
contain housing units, which minimizes the potential for displacement. In the
event that any future development would displace existing residential units,
Program 5.1 in the Housing Plan will ensure compliance with State protections for
existing tenants and replacement housing requirements.
• New mixed -use development in the Downtown will create additional economic
opportunities for local residents.
• While the Downtown area provides the largest component of the potential
residential inventory, it is important to recognize that existing single-family
residential neighborhoods also provide substantial potential for new housing in
areas of high opportunity through ADUs and SB 9 urban lot splits.
Figure D-32
TCAC Opportunity Areas Composite Score - West Covina
(R) TCAC Opportunity Areas (2021)- Composke Scare -Tract
Highest Resource
High Resource
Moderate Resource (Rapidly Changing)
Model Resource
Low Resource
High Segregation & Poverty
® Missing/Insu(Rcient Data
City of West Covina 160
Appendix D - Fair Housing Assessment
4. Contributing Factors, Goals, Policies and Actions
The Housing Element AFFH analysis must include an identification and prioritization of
significant contributing factors to segregation, racially or ethnically concentrated areas of
poverty, disparities in access to opportunity, and disproportionate housing needs. "Fair
housing contributing factor" means a factor that creates, contributes to, perpetuates, or
increases the severity of one or more fair housing issues. Contributing factors should be
based on all the prior efforts and analyses: outreach, assessment of fair housing, and site
inventory. Contributing factors must also be prioritized in terms of needed impact on fair
housing choice and strongly connect to goals and actions.
Through the participation of stakeholders, fair housing advocates, and the assessment of
fair housing issues described in this appendix, the City has identified fair housing issues and
contributing factors as well as meaningful actions to address those issues as described in
Table D-2 below. Program 4.1 in the Housing Plan incorporates specific measures to
implement these actions.
City of West Covina 161
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