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are in excess of the acreage required to accommodate the City's share of housing for lower income households, as detailed in the staff report and resolutions. 01-4 The com me nt states that the resolutions are subject to CEQA and reducing the allowed development in Santa Ana pushes that growth into otherjurisdictions, where housing is IikeIyto further from jobs and schools, and closer to sensitive habitats and fire zones. Response See response toA1-4. 01-5 The com me nt states that exempting parce Is from these two state I awswill incite not- ! n-my-backyard IN IMBY) cities to attempt similar illegal actions to avoid developing denser more affordable housing. Response Both I awsinclude exemption provisions. See response to 01-1. 02. Response to Allen Matkins, dated June 20, 2023. 02-1 This com me nt states that AB 2011 is not yet operative, therefore, any attempt by the City Co u nci Ito exempt pa rce Is to the cited n on -operative Gove rn me nt Code provisions will be legally ineffective. Response UnderAB2011(Gov. Code sections 65912.114(i) and 65912.124(i)),alocalagencymay exempt parcels from AB 2011 before a development proponent submits a development application on a parcel pursuanttoAB 2011. In orderto exempta parcel from AB 2011 before July 1, when the law takes effect and a proponent is legally permitted to submit an application, the local agency is effectively charged with having to take action before. 02-2 This comment states that the City did not confirm that the replacement parcels meet the criteria described in subdivision (b) and (e) to (h), inclusive, of Section 65912.121 as required. These include specific siting requirementsthatthe alternativesites cannot be located on habitat for protected species, including candidate species, prime farmland wetlands, withina high orvery high fire hazard zones, hazardous waste sites, a delineated earthquake fault zone, special flood hazard areas, within a regulatory floodway, or lands identified forconservation. Response The alternative parcels identified by the City area[ lwithin existing specific plan areas, form based code areas, or within the five Focus Areas in the General Plan. Theas areas all permit residential development by right. The extensive environmental reviews conducted by the development of those plans demonstrate that the alternative sites identified by the City are not located on sites identified as habitat for protected species, prime farmland, wetlands, within a high orvery high fire hazard severity zone, a hazardous waste site, within a delineated earthquake fault zone, a special flood hazard area, within a regulatoryfloodwayorland identified forconservation. 02-3 This comment states that the capacity in the alternative parcels of 89,802 units is more than the 45,502 units that would otherwise be permissible on the parcels being exempted pursuant AB 2011. Additionally, the comment states that some to the alternative parcels are entitled or under construction. The staff report states that the typical base density is 30dwelling units peracre forSB 6 and AB 2011. AB 2011 permits densities up to 80 dwelling units per acre for some properties. Lastly, the calculation ignoresthe on -site affordable housing requirement underAB2011 that would intum El