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June 20, 2023 <br />Mayor Valerie Amezcua <br />City of Santa Ana <br />22 Civic Center Plaza <br />Santa Ana, CA 92701 <br />RE: File Item 432 — Exempting Parcels from AB 2011 and SB 6 <br />Dear Mayor Amezcua and City Council Members, <br />On behalf of the Building Industry Association of Southern California — Orange County Chapter <br />(BIA/OC) and the Building Industry Legal Defense Foundation (BILD), I write to request <br />clarification on the renewed consideration of File Item 32. <br />As noted in the Staff Report, consideration of this matter was continued from the meeting on May <br />16, 2023 as a result of a comment letter received from the State Attorney General's Office. As <br />further noted, based on "input from the discussions with State staff, City staff has refined the <br />recommended scope of the proposed resolutions." <br />BIA/OC and BIL,D are interested in clarification of what was discussed and what refinements were <br />made in relation to those conversations. AB 2011 and SB 6 are powerful tools that are still not <br />available for use. Understanding the position of the city, the state, and how those two intend to <br />interpret this proposal is of paramount interest. <br />Upon reading the plain language of AB 2011 and SB 6, it would appear there is disagreement <br />between the city and statute as to what is meant by "no net loss." It seems this term would freeze <br />the total unit count of Santa Ana's residential opportunity areas and then add additional housing <br />on top of that to accommodate any AB 2011/SB 6 parcel exemption. Understanding the position <br />of Santa Ana, the State and the implications of both approaches would be well served by a council <br />study session or special hearing. <br />Clarifying the changes made since the last hearing and how all interested parties define "no net <br />loss" would be greatly appreciated prior to further action. Housing policy remains a crisis -level <br />problem for California and ensuring opportunity in Santa Ana, and across the region, is a <br />fundamental goal of BIA/OC and BIL,D. <br />Sincerely, <br />_x4vx- <br />Adam Wood <br />BIA/OC & BIL,D <br />