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Response AB 2011 includes CECtA exemptions for projects developed through AB 2011 streamlining, which will result in a direct change to the environment. The recommended actions only include administrative changes to the application processing as there is no land use change being proposed. All alternative parcels not subjectto AB 2011 identified already permit residential development atthe densities included in the resolutions by right. The only matter being considered by these resolutions is administrative procedures in response to and in the application of state law. As is outlined in the staff reportand resolutions, these actions are notsubjectto CEQA because it is an organizational or administrative activity that will not result in director indirect physical changes in the environment and is therefore nota "project," pursuantto Section 15378(b)(5) of the CEQA Guidelines. 01. Response to People for Housing, dated June 14, 2023. 01-1 This comment states that the housing shortage is dire, and the intention of AB 2011 and SB 6 is to facilitate development of housing on sites currently zoned for commercial with expedited review. Delays in housing production i m pact everyone, but especially the 75 percent of low-income residents who qualify to live in affordable housing orfor housing choice vouchers. The Cityis illegally attemptingto exempt itself entirely from these laws. Response Both laws include provisions that allow local jurisdictions to exempt parcels of land from streaming provided certain findings can be made. The actions that are being proposed are not illegal, rather, are expressly permitted by both of the laws. Moreover, the City is not attempting to exempt itself entirely from the laws. As detailed in the staff report, only certain parcels that are at odds with the approved land use plan are proposed to be exempted. There are hundredsof parcelsthatare AB 2011 eligible that are not being exempted and are listed in the Attachments to the Resolutions as being AB 2011 eligible. Santa Ana has proven to be a leader in the production of housing, especially housing affordable to lower income households, as proven by exceeding its5l' cycle Regional Housing Needs Allocation (RHNA) by 2,400 percent and already having met 52 percent of its RHNA for the 61^ cycle, a mere 18 months into an eight year planning period. While there is a housing crisis in the state, Santa Ana has and will continue to meet its share of the overall housing production goals. 01-2 This comment states that the May 16, 2023, City Council meeting staff report misunderstands what no net loss in relation to AB 2011 means. Comment states that the City would need to meet no net loss through upzoning alternative lots and/or makingthem newlyeligible. Response See response to Al-3. 01-3 This comment states that the May 16, 2023, City Council meeting staff report misunderstands what no net loss in relation to SB 6 means. Comment states that the City would need to meet no net lossthrough upzoning alternative lots and/or making them newlyeligible. Response The findings forSB 6differthan thoseforAB2011. The City demonstrated that the lost residential densityfrom each exempted parcel can be accommodated on a site orsites allowing residential densities at or above those required bySB 6. Moreover, thosesites