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Comments RE Caribou Industries Mixed -Use Project November 17, 2020 Page 5 of 9 The mistake is plain to see. Both parcels are counted for in the lot density (90 units per acre), but then the 75 hotel units are omitted from the ultimate unit density calculation.z As a result, the Project is getting way over the allowable density (even with bonuses), while providing too little affordable housing (the density bonus calculations at 11% affordable for total units are too little - if the 75 hotel units were counted, the Project needs to provide at least 8+ more affordable units). Staff Report 10/20/20 page 75A-9 makes this clear: DensitV Bonus Under the State's Density Bonus Law, developers providing 11 percent very -low income units may request a numerical density bonus of 35 percent from the base density (California Government Code Section 65915 (f)(2)). The General Plan land use designation for the site is District Center, which allows 90 dwelling units per acre and a maximum floor area ratio of 3.0. Based on the site area of 1.41 acres at 90 dwelling units per acre, 127 units are allowed. In exchange for providing 11 percent very -low income units on site, an additional 45 units are permitted through a density bonus. Therefore, the project proposes a total of 171 units with a total floor area ratio (FAR) of 4.2 for the development site. Application of the floor area ratio maximum would physically preclude development of on -site affordable housing units. Table 6: Density Bonus Calculation Ditinol or Bonus . owed for: Project _ P Base Density 127 units (1.41 acres x 90 127 Units units/acre 35-Percent State Density 45 units (127 x 0.35) +44 Units Bonus Total Units 172 units maximum 171 units pr000sed The bottom line is that the 75 hotel units are omitted from the density bonus calculation, even as the hotel acreage is counted for density purposes. This is a shell game. Either the hotel units must be accounted for in the density unit calculation, or the hotel acreage not counted. An example may be helpful, e.g., if a 0.1-acre residential project were proposed along with a next door 5-acre office project subject to the 90 dwelling units per acre and 3:1 floor -area -ratio ("FAR') density. In such a situation, could this residential/office development be built as a mixed -use project allowing 459 dwelling units3 built on the 0.1-acre residential site perhaps 30+ stories tall, in addition to the 666,468 square feet^ of office use built on the 5.0-acre office site? That would make no sense - the density of the residential building must be tethered to the actual size of the residential lot, the 5 acres available for residential density on the adjacent lot cannot be entirely ignored, and the City may not pretend that the office density does not cut into the available density of the residential density.5 The same reasoning applies here. Otherwise, the density concessions (meant for housing, not hotels) are ripe for abuse. As a result, instead of the 90 dwellina units per acre allowed under the Santa Ana General Plan Land Use Element (page A-11), which would be 127 units for a 1.41-acre site, the Project is getting 171 residential units plus 75'free' hotel room units - a total of246 units or almost 100% more than allowed: 2 Other hotel projects approvals in the City show that hotels are subject to the 90-dwelling unit per acre density rules. See Hampton Inn Mitigated Negative Declaration p. 2 httus://www.santa-ana.org/sites/ default/files /Documents/HamptonlnnlSMND. dfdf. 3 (5.1 acres) x (90 dwelling units per acre). 4 (5.1 acres or 222,156 SF) x (3:1 FAR). 5 The Santa Ana General Plan Land Use Element (p. A-15) suggests that FAR can be averaged along two contiguous parcels that are part of a mixed -use project - but the buildings on both lots need to be counted. (See httos: //www.santa-ana.org/sites/default/files/Documents/Lan dUseElement1dE) 5_