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While the City has seen increased production of affordable housing there has been a disproportionate production of above moderate housing with a total of 3,274 above moderate units produced between 2013- 2021, the City exceeded its RHNA allocation by 3,638% per the City's RHNA progress reports submitted to the state. With average rents of$2000 - $4000, none of these above market rental units are affordable to most of Santa Ana's working families. Housing costs in Santa Ana have been out of reach and will continue to be out of reach in this current economic climate. Households in Santa Ana must earn $44.83 an hour to afford two-bedroom housing.'The proposed amendments further incentivize housing units with market rate rents and are not affordable to the majority of the City's residents. The Commission supports the amendments to update the in-lieu fee to $15 per sq ft to be in line with a fee that is fair and allows the City to fund much needed affordable housing for Santa Ana residents. We also support the wider application of the Housing Opportunities Ordinance in the City of Santa Ana. This will continue to facilitate the development of affordable housing in various areas of the city. The Commission also recommends that the HOO apply to all residential developments in the City. At a minimum the HOO affordable housing requirements should apply to all residential and mixed use developments that are asking for zone changes,upzonings, following city initiated specific plans, general plan updates or those asking for other development incentives. In addition, the HOO should apply to all developments taking advantage of City initiated land use and zoning changes, specific plans and general plan updates and amendments. Land use changes may create higher land values,profit, and incentives for market rate developers. At the same time many of these market developments are not affordable to the majority of Santa Ana's residents. In exchange for these development incentives, new affordable housing for Santa Ana residents must be created. The City must also ensure that the Inclusionary Housing Fund monies prioritize the construction of affordable housing for extremely low- and very low-income families. These are the families that have the most pressing needs in the City of Santa Ana. In addition,the fund should also prioritize addressing housing insecurity, eviction prevention, and housing legal assistance for residents that would directly help current Santa Ana residents with the exception of code enforcement. Diversion of these funds to other programs unrelated to housing and direct help for families would not increase or improve the supply of affordable housing. We urge you to take into consideration the amendments and proposed recommendations to the Housing Opportunity Ordinance. These recommendations will help the city increase affordable housing options for residents and help the city meet equitable housing production goals. Sincerely, Cesar Covarrubias Executive Director 4 National Low Income Housing Coalition.Out of Reach The High Cost of Housing 2021,pg.18.Out of Reach 2021(nlihc.org)