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density. As used in this paragraph, a "specific, adverse impact" means a significant, quantifiable, direct, and unavoidable impact, based on objective, identified written public health or safety standards, policies, or conditions as they existed on the date the application was deemed complete. (2) There is no feasible method to satisfactorily mitigate or avoid the adverse impact identified pursuant to paragraph (1), other than the disapproval of the housing development project or the approval of the project upon the condition that it be developed at a lower density. (4) For purposes of this section, a proposed housing development project is not inconsistent with the applicable zoning standards and criteria, and shall not require a rezoning, if the housing development project is consistent with the objective general plan standards and criteria but the zoning for the project site is inconsistent with the general plan. If the local agency has complied with paragraph (2), the local agency may require the proposed housing development project to comply with the objective standards and criteria of the zoning which is consistent with the general plan, however, the standards and criteria shall be applied to facilitate and accommodate development at the density allowed on the site by the general plan and proposed by the proposed housing development project. The applicant proposes to construct a 552-unit affordable housing project at 2110, 2114, and 202o East First Street. The Santa Ana General Plan allows for 90 units per acre, which, at 6.89 acres, allows for a base unit count of 620 units. With the State and Local density bonuses the maximum number of units allowed on the site is 1,054. The proposed development also complies with all applicable zoning and development standards in the city. This project would bring much -needed affordable housing to Santa Ana. It is a type of project that the city has planned for and enacted regulations to allow for in this very location. The concerns about the project scale, density, or parking provided are not valid reasons to deny or fail to act on a project, when the project clearly complies with the city's own regulations governing these issues. We are therefore writing to remind the Santa Ana City Council that they are required by the HAA to either approve the application, or else make findings to the effect that the proposed project would have an adverse impact on public health and safety, as described above. We ask that the city council bring the project back for consideration at the next meeting, and approve it as proposed. We will seek to hold Santa Ana accountable for the requirements of the HAA in the event the city council disapproves of the proposed development without making the findings outlined above supported by a preponderance of evidence on the record, as required by the HAA. If the city fails to act on the application, such inaction would be considered the equivalent of a disapproval of the project under the HAA, and we will seek to hold the city accountable (Gov. Code § 65589.5(h)(5).) California Renters Legal Advocacy and Education Fund - hi@carlaef.org 1260 Mission St, San Francisco, CA 94103