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CHRISTIAN GARCIA <br />CHRISTIAN@CAFORHOMES.ORG <br />TEL: (213) 739-8206 <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> <br /> June 27, 2022 <br /> <br />VIA EMAIL <br />Planning Commission <br />Santa Ana <br />20 Civic Center Plaza, Conf. Room 1600 <br />Santa Ana, CA <br />Email: PBAecomments@santa-ana.org <br /> <br />RE: 1814 and 1818 East First Street <br />Site Plan Review No. 2022-03 <br /> <br />To the Planning Commission: <br />Californians for Homeownership is a 501(c)(3) organization devoted to using legal tools <br />to address California’s housing crisis. We are writing regarding the 1814 and 1818 East First <br />Street project. The City’s approval of this project is governed by the Housing Accountability Act, <br />Government Code Section 65589.5. For the purposes of Government Code Section 65589.5(k)(2), <br />this letter constitutes our written comments submitted in connection with the project. <br />The Housing Accountability Act generally requires the City to approve a housing <br />development project unless the project fails to comply with “applicable, objective general plan, <br />zoning, and subdivision standards and criteria, including design review standards, in effect at the <br />time that the application was deemed complete.” Gov. Code § 65589.5(j)(1). To count as <br />“objective,” a standard must “involve[e] no personal or subjective judgment by a public official <br />and be[] uniformly verifiable by reference to an external and uniform benchmark or criterion <br />available and knowable by both the development applicant or proponent and the public official.” <br />Gov. Code § 65589.5(h)(8). In making this determination, the City must approve the project if the <br />evidence “would allow a reasonable person to conclude” that the project met the relevant standard. <br />Gov. Code § 65589.5(f)(4). Projects subject to modified standards pursuant to a density bonus are <br />judged against the City’s standards as modified. Gov. Code § 65589.5(j)(3). <br />The City is subject to strict timing requirements under the Act. If the City desires to find <br />that a project is inconsistent with any of its land use standards, it must issue written findings to <br />that effect within 30 to 60 days after the application to develop the project is determined to be <br />complete. Gov. Code § 65589.5(j)(2)(A). If the City fails to do so, the project is deemed consistent <br />with those standards. Gov. Code § 65589.5(j)(2)(B).