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built.These cities are also paying the price as both the courts and the Attorney General work toward ensuring compliance with state laws aimed at increasing housing production. This proposal to effectively exempt the city of Santa Ana from AB 2011 and SB 6 opens the city to similar scrutiny and legal action from the state. Additionally, the methodology used to identify alternative sites for housing development is flawed, as it identifies sites that are already zoned for residential development or that have recently completed construction or adopted specific development plans, which goes against the clear reading of AB 2011. Replacement properties require ALL the same requirements under AB 2011: • Sites must be currently zoned for a use other than residential / housing, or if zoned residential, they need to significantly increase the density. • Replacement properties need to benefit from all the policies enabled under AB 2011, such as CEQA exemption, fair wage policies and a streamlined and ministerial approval process. The city has ignored these requirements and instead focused on RHNA numbers, which are not pertinent to either SB 6 or AB 2011. In addition, it is highly likely these replacement sites have been calculated with a theoretical zoned capacity that is not feasible to build. Assessing the "realistic capacity" of a site is possible on a small scale, but remains purely theoretical when applied to all the parcels across the entire city. We urge you to change course. Your selection of sites is contrary to a plain reading of both SB 6 and AB 2011 and opens the city to litigation from the AG and property owners, whose rights to streamlined development process will be undermined by this resolution. el.�Fy.o I `Py Fighting for a future of abundant housing in Orange County. a �+ peopleforhousi ng.org 2 Orange County