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EXHIBIT 2 <br />SPR No. 2017-09/DBA No. 2017-02 <br />May 21, 2018 <br />Page 6 <br />Nearly half (48 percent) of the project's units will contain one or two bedrooms. The original project <br />proposed at the site contained both senior and family -oriented housing in nearly 700 residential <br />units. Following feedback from elected officials and City staff on housing needs identified in the <br />2014 Housing Element, the applicant revised the project to completely eliminate the senior <br />component; the unit count was reduced to the present 552. In doing so, the applicant increased the <br />number of multi -bedroom units. <br />In 2010, the US Census reported that the average household size in Santa Ana was 4.37 and that <br />the average family size was 4.54. Santa Ana's average household and family sizes are above <br />Orange County's, which has an average household size of 3.99. As a result, the lower bedroom <br />count of the project may serve a different segment of the population not identified in any local <br />demographic (household or family size) figures or in the 2014 Housing Element. This issue may be <br />exacerbated by the community's overall lower -than -average unit square footage of 1,061 square <br />feet, which is below the 1,200-square foot unit average stated as a guideline in the MEMU <br />regulating plan. <br />2. Housing Opportunity Ordinance (HOO) and the State's Density Bonus Law <br />Under the State's Density Bonus Law, developers of affordable family -oriented housing projects <br />may request a numerical density bonus up to 35 percent from base density. The City's Housing <br />Opportunity Ordinance (HOO), last updated in 2015, augments the density bonus concept by <br />allowing a developer to seek an additional 35 percent density bonus calculated from base density <br />(SAMC Sec. 41-1904.1). Despite this opportunity for a "double density bonus," staffs interpretation <br />of the intent of both the State law and local ordinance support the concept of mixed -income housing <br />development, with affordable housing units forming a component of such developments. Pursuant <br />to SAMC Sec. 41-1600, the purpose of the City's ordinance is "to provide increased residential <br />densities to developers who guarantee that a portion of their residential development will be <br />available to low income, very low-income, or senior (also known as "qualified") households." <br />Moreover, 'The regulations are intended to ... provide a balance of housing opportunities for low <br />income, very low-income, and senior households throughout the city." <br />Mixed -income housing developments provide a "portion" of affordable units in an integrated, mixed - <br />income development unless it is financially or physically infeasible to do so, in which case a <br />developer may pay an in -lieu fee to facilitate construction of affordable housing developments <br />offsite. The City's Housing Opportunity Ordinance's furthers this goal, stating that is purpose is to <br />"encourage the development of housing that is affordable to a range of households with varying <br />income levels" (SAMC Sec. 41-1900). <br />It is also important to note the language in SAMC Sec. 41-1600 that encourages development of <br />affordable housing for "households throughout the City" (geographically dispersed). The developer <br />has recently entitled an all -affordable senior project ("Villa Court") on a project site approximately <br />320 feet to the east at 2222 East First Street that will contain 418 units. If approved, the proposed <br />project would add another 552 all -affordable housing units in nearby, for a combined 970 affordable <br />housing units in close proximity to one another. <br />60A-52 <br />