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City of Santa Ana– First American Mixed-Use Project [114 and 117 East Fifth Street] – Comments to City Council November 18, 2019 Page 12 of 13 Many of the above-listed Policies were added or updated to reflect input the City received from its residents and businesses, expanding on the City’s commitment to affordable housing and workforce housing via policy HE-2.6, HE-3.7 and HE-3.8 and program 29. Housing Element, p. E-10. The Project is not consistent with the Goals and Policies of the Housing Element related to affordable housing. The Project merely provides 11 units or 5% to affordable housing. Specifically, Policy HE-2.6, consistently with the Housing Opportunity Ordinance (“HOO”), requires rental housing projects to include at least 15% of the units as affordable to lower income households for rentals. The Addendum fails to analyze whether the Project complies with the HOO, in addition to any of the other goals and policies of the Housing Element. B. The Project’s Proposed Amendment to Allow Seven Stories Eviscerates the Application of the 2010 EIR The proposed project has a General Plan designation of District Center-Downtown District, and both parcels are zoned Specific Development No. 84 (SD-84) in TZC – Downtown (DT) Zone. Addendum, p. 2-16. The TZC provides that the maximum building height for Lined Block buildings is five stories. However, one of the Project’s buildings will be seven stories in height, which requires an amendment to the current zoning. Id. However, the allowance of amendment of the current TPZ zoning limits to building height eliminates even the little value the 2010 EIR has in relation to this specific Project. In addition, if additional amendments to other developments within the TPZ are allowed in the present and the future, what was the whole point of setting up the TPZ in the first place? As a result of the proposed amendment of the TPZ to allow the Project’s excessive building height, whatever value the TPZ and its 2010 EIR might have had to the Project are completely gone. C. The Project’s Inconsistency with the General Plan Also Violates CEQA Under the CEQA Guidelines, an environmental impact report (EIR) must discuss "any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans." 14 Cal Code Regs §15125(d).