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elimination of the program. The HOO program specifically states that "[t]he inclusionary requirement is triggered by: a request to increase the permitted density above that permitted in the zone, conversion of commercial or industrial land to residential uses, conversion of rental units to condominiums, and various other conditions." The proposed amendment would only require the inclusion of affordable units where a General Plan amendment is required. This requirement is far more onerous and much less likely to occur than the circumstances triggering the HOO that are identified in the Housing Element, especially in light of the City's proposed General Plan and Land Use Element updates that aim to streamline development and increase densities by rights without an expectation of a community benefit or affordable housing. In addition, the HOO and its funding are a vital tool to the City's future efforts to Affirmatively Further Fair Housing by creating housing opportunities for all income levels throughout the City, especially for lower income families who's housing needs are not being address by the market rate housing that is being incentivized by the proposed changes. New construction of affordable housing is vital to providing affordable housing options and not segregating residents to poverty in lower income neighborhoods that are already impacted and disadvantaged. The City of Santa Ana can only accomplish a diverse housing stock and meet its residents housing needs by preserving the HOO and its affordable housing funding. For these reasons, we urge the City Council to vote against approving Zoning Ordinance Amendment No. 2020-03. Should the Council move to consider the proposed amendments, we would request consideration to the following comments: 1. The City Council should delay any action on the HOO to January 2021, given the devastating impacts of the Coronavirus on everyone, and in particular, those who are in lower -income households of the City of Santa Ana. hi addition, there needs to be greater analysis and consideration on the impacts of the proposed amendments. 2. The proposed amendment would reduce the in -lieu fee from $15 to $5. The city must retain a $15 in -lieu fee and secure this funding source for much needed affordable housing. The city risks losing state and federal housing matching funds by lowering the in -lieu fee, at a time we face economic uncertainty as a result of the pandemic. Should the Council consider an in lieu fee change, it should be supported by financial analysis and data. 3. The City should remove the priority on acquisition and rehabilitation and prioritize construction of new affordable housing units. If the City wants to jointly prioritize acquisition/rehabilitation and construction of new units to address the City's housing crisis, it should set goals and percentages in each program to identity how it will help them meet its housing goals and Housing Element requirements. 4. Clarify that where a rehabilitation project results in displacement of tenants, the City will pay relocation costs in line with the requirements of the California Relocation Assistance Act.