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the most significant increase of housing has been in the above moderate housing category. The City's above moderate allocation is 90 units for the current RHNA planning period. To date, the City has approved 2,409 above moderate income units. This means that the City has exceeded its's above moderate income RHNA allocation by 2,677 percent, per the City's RHNA Annual Progress Report submitted to the CA Department of Housing and Community Development 2 With above moderate average rents of $2000 - $4000 in these developments, none of these above market rent units are affordable to most of Santa Ana's working families3. Since 80% of renters in Santa Ana fall into the moderate, low and very low income category and 84 percent of residents hold low-income occupations that pay less than $53,500 per year, the majority of these new rental housing units are not available to address the housing needs of most working families in Santa Ana. 4 The need for affordable housing is now greater than ever, as the COVID-19 pandemic has exacerbated housing and economic needs that were already impacting low income working families in Santa Ana. Housing costs in Santa Ana have been out of reach and will continue to be out of reach in this current economic climate. Households that live in the 92701 zip code, the city's most affordable zip code, must earn $35.68 an hour to afford two -bedroom housings This housing cost and wage is clearly out of reach for the majority of working families in Santa Ana. New Construction of affordable housing needs to continue to be a priority to address the housing needs of Santa Ana residents. Opposition to Proposed Amendments We have provided public comment and submitted letters to the City Council and informed the Councilmembers of our opposition to efforts to weaken the HOO. The proposed amendments are troubling as there has been no public participation or input on the proposed changes. These proposed changes are advanced by a Council Committee that has created these objectives in nonpublic meetings and has not shared data or allowed public input. The proposal seems to advance a market rate housing agenda without considerations on the impacts of the proposed change on much needed affordable housing for Santa Ana residents. These proposals only incentivize additional new housing units with market rate rents and will not be affordable to the majority of the City's residents. The proposed amendments do not address the city's needs and create further inequity for the city's residents with the greatest housing need. Furthermore, these amendments will compromise the City's ability to reach its Housing Element goals and requirements in the upcoming 6a' Cycle Housing Element. In addition, we believe that the City Council cannot make finding of consistency with its current Housing Element and General Plan policies and objectives. We urge the City Council to vote against these proposed amendments. The proposed changes to the HOO violate the Housing Element for the City of Santa Ana because it directly contravenes the Housing Opportunity Ordinance Program (Program 29) identified in Santa Ana's 2014-2021 Housing Element and it results in the constructive 'City of Santa Ana Housing Element Progress Report 2019, April 2020 ' Rent survey of recent market rate developments - The Marke, Essex Skyline and Broadstone Arden ° City of Santa Ana General Plan Housing Element 2014-2021, p. 12 and 14, January 2014. ' National Low Income Housing Coalition's "Out of Reach: The High Cost of Housing in 2020" Report.