Item No. 1_Public Comment_Willowick

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Verny Carvajal October 6, 2020 Page 5 Willowick site to be developed into approximately 270 affordable housing units. See Willowick Community Park Proposal at 30. The Willowick development by itself would not be sufficient to meet the City’s affordable housing needs—the Update must provide for increased affordable housing development citywide. However, the Update fails to provide for sufficient housing at the affordability levels the City needs, and its upzonings would instead undermine the effectiveness of the city’s Housing Opportunity Ordinance. The Update would increase residential density limits in many areas of Santa Ana. It would modify land use designations in five Focus Areas (South Main Street Focus Area, Grand Avenue & 17th Street, West Santa Ana Boulevard, 55 Freeway & Dyer Road, and South Bristol Street), re-designating portions of those areas for more intensive development and increasing the allowable dwellings per acre and floor-area ratio for residential construction in those areas. DPEIR at 1-6, 1-7, H-a-7. The Update would also add a “Corridor Residential” land use designation, which would allow higher density residential development in additional areas. DPEIR at 3-52. These upzonings will facilitate increased housing construction, but would also undermine the HOO’s inclusionary housing requirements. The HOO requires developers to construct affordable units or pay a fee when the number of residential units in a new development exceeds the density permitted by applicable zoning. Santa Ana Muni. Code § 41-1902. Development projects are not subject to the HOO’s inclusionary requirements if they do not exceed established density limits under the zoning for the site. Id. Because the Update would increase density limits in many areas of the City and allow more by-right development, fewer developments will need to seek City approval for additional density. In many, if not most, cases the HOO’s inclusionary requirements will be triggered less often. As a result, the HOO will apply to fewer projects. Developers will build fewer affordable units and pay less into the City’s inclusionary housing fund. By reducing the effectiveness of the HOO, the Update would also undermine General Plan Housing Element Policy 2.6, which provides that “pursuant to the Housing Opportunity Ordinance,” the City must “require eligible rental and ownership housing projects to include at least 15 percent of the housing units as affordable for lower and moderate-income households.” DPEIR at 5.10-17. The Update will thus create an internal inconsistency within the General Plan, as the increased by-right densities will impede achievement of the Housing Element’s goal. To avoid this illegal inconsistency, the City must, within or simultaneous with the Update, revise the HOO to ensure sufficient affordable housing production. Gov. Code §