01-14-19_AGENDA PACKET - Laserfiche WebLink

Home Browse Search

Response to Comment City of Santa Ana 6 Magnolia at the Park Multi-Family Residential Project December 2018 within the City of Orange was similar at 3.0 percent. As described in the Draft EIR, an adequate supply of housing is essential to maintaining adequate choices for residents, moderating housing prices, and encouraging the normal maintenance of properties. Low vacancy rates result in price and rent escalation, while excess vacancy rates result in price depreciation, rent declines, and deferred maintenance. The City’s Housing Element identifies that a housing vacancy rate of 5–6 percent for rental units is optimal. Thus, the new rental units provided by the project would provide additional housing options and could assist in increasing the vacancy rate and lowering rent costs, as more supply would be available to meet the rental housing demand. As a result, the project would not generate any impacts related to the feasibility of developing income-restricted housing, and analysis related to this issue is not required. Comment 14: This comment asserts that the Final EIR rejects comments made concerning affordable housing because the issue is socio-economic and not environmental, and therefore not within the scope of CEQA. The comment asserts that urban decay is a CEQA issue and that the lack of affordable housing has led to an increase in homelessness, which is a prime contributor to urban decay. The comment refers to CEQA and states that an EIR may trace a chain of cause and effect from a proposed decision through anticipated economic or social changes resulting from the project to physical changes caused in turn by the economic and social changes. Response 14: Refer to Responses 12 and 13. The proposed project would develop rental units that are affordable to moderate income households and provide for low and/or very low-income housing through the options included in the City’s Municipal Code. The project would assist in providing an adequate supply of housing that would help to improve the vacancy rate and result in lowering rent costs, as more supply would be available to meet the rental housing demand. Thus, the project would provide residential units; not result in homelessness. Furthermore, the project site is currently vacant, and the existing building is unused. Typical urban decay as described in Bakersfield Citizens for Local Control v. City of Bakersfield (2004) (124 Cal.App.4th 1184) (Bakersfield Citizens) occurs from vacant buildings and unused properties that are unmaintained. The project would implement new development and landscaping on the project site that would be maintained during operation of the project, as required by the proposed SD zone. Overall, the project would not result in physical changes to the environment related to urban decay or blight. Comment 15: This comment provides a summary of CEQA requirements through references of court decisions and statutes related to policies such as ordinances that are adopted to avoid or mitigate environmental effects. Response 15: This comment is general in nature and does not provide any examples or citations of where the project would conflict with a policy or ordnance that was adopted to avoid or mitigate an environmental effect or where analysis within the EIR is flawed. To the extent such argument is asserted, Section 4.7, Land Use and Planning, of the Draft EIR, thoroughly evaluated the relevant policies and the project’s compliance with these policies. Additionally, each environmental analysis section of the EIR lists the existing regulations that would assist in the reduction or avoidance of potential impacts. As detailed within the Draft and Final EIRs the project would result in less than significant impacts related to potential conflict with a regulation or policy that was adopted to avoid or mitigate environmental effects. Comment 16: This comment asserts that a recirculated Draft EIR should be prepared to analyze the impacts of the project’s lack of affordable housing and the impact on urban decay. The comment also states that feasible mitigation measures should be proposed, such as requiring more affordable housing in the project and contributions to low- income housing funding. 2-302