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Memorandum - #32
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Memorandum - #32
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6/21/2023 3:22:44 PM
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6/20/2023
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choice voucher assistance, but receive neither. These residents are forced to <br />compete with higher income residents in the unsubsidized market. <br />Santa Ana has done admirable work in improving its ability to help meet the <br />region's and state's housing needs. We were therefore surprised to see that it <br />is illegally attempting to exempt itself entirely from these important laws. <br />The Staff Report prepared for the May 16th, 2023 city council meeting for the <br />proposed exemptions misunderstands what "no net loss" means. It states that <br />the AB2011 exemption would remove the potential for 18,454 units, while <br />alternate sites, which are already eligible for AS2011, provide for 89,802 <br />potential units. This means that absent the proposed exemption, there would <br />be a total of 108,256 potential units on this collection of lots. Going from <br />108,256 to 89,802 is clearly a net loss. To avoid a net loss, the City would need <br />to take action to keep the development potential at 108,256 units, either by <br />upzoning alternative lots and/or making them newly eligible for AB2011. By <br />simply removing parcels from AB2011 coverage with no compensating <br />increase in development elsewhere, the City is violating both the letter and <br />spirit of an important statute intended to increase housing supply. <br />Similarly, in discussing the SB6 exemption, the Staff Report claims that there <br />will be no "no loss of residential density by exempting these parcels." The <br />arithmetic is the same. If those parcels were subject to SB6 they could provide <br />18,582 units. The "alternate" parcels can yield 89,802. Without the exemption, <br />these parcels in total could provide 108,384. The 89,802 units that would <br />remain after exemption would be a net loss. The Staff Report is misleading. <br />t0 R yoG <br />4 sc Fighting for a future of abundant housing in Orange County. <br />peopleforhousing.org <br />Orenp Cony <br />01-1 <br />cont. <br />0 1 - 2 <br />01-3 <br />
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