Memorandum - #32 - Laserfiche WebLink

Home Browse Search

automatically provide fora density bonus underthe State Density Bonus Law, which is specifically authorized under AB 2011. It is possible, if not likely, that the net new numberof housing units allowed under AB2011 would exceed the net new number of units that could bed eve I oped on the alternative parcels. Response The figures cited in the letter are from the previous version of the staff report and analysis, before meeting with HCD and refining the methodology and exempt properties list. See response to A1-3 for methodology. Santa Ana is a built -out community. All parcels eligibleforAB2011 are alreadydevelopedorinthe processof being redeveloped. The law does not include provisionsto only applyto parcels likely to develop based on a list of criteria. Rather, the law and exemption processis framed around theoretical densities and does not account for other factors that make properties prime for redevelopment. AB 2011 does not expressly require that no net lass and baseline density calculation include potential units gained through Density Bonus Law. Moreover, this issue was not raised by HCD duringthe five interactions staff held with them between May 16 and June 20, 2023. 02-4 This comment states that exempting the parcels will result in a net loss of potential affordable housing in the City because the potential additional units gained through Density Bonus Law are not accounted for. Additionally, the City's local inclusionary housing ordinance allows project sponsors to pay an in -lieu fee. This option could result in zero affordable units being constructed unless and until the in -lieu feesare used bythe Cityto separately develop affordable units. Response See response to 02-3. 02-5 The commentcitesthe May 16h staff report and resolutions andthe CEQAexemption it referenced. The comment states that the actions could result in a foreseeable indirect physical change in the environment, which qualifies as a project subject to CEQA. Response SeeresponsetoAl-4. 02-6 This comment states that based on the information provided, the City Council cannot make required findings under AB 2011 to exempt the properties from AB 2011 streaming. Response The staff report, finclingsof fact, and resolutions have all been updated fromthe May 16,2023, version to address comments received by HCD. Resolutions and attachments along with the staff report demonstrate that all required findings by AB 2011 have been made.