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STATE OF CALIFORNIA- BUSINESS, CONSUMER SERVICES AND] HOUSING AGENCY GAVIN NEWSO _Qoyemor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT 2020 W. El Camino Avenue, Suite 500 Sacramento, CA 95833 , (916) 263-2911 1 FAX (916) 263-7453 www. hcd. ca.gov Al June 19, 2023 City of Santa Ana Mayor Valerie Amezcua, Mayor Pro Tern Jessie Lopez, and Councilmembers 20 Civic Center Plaza P.O. Box 1988 Santa Ana, CA 92702 Dear Mayor Valerie Amezcua, Mayor Pro Tem Jessie Lopez, and Councilmembers Thai Viet Phan, Benjamin Vazquez, Phill Bacerra, Johnathan Ryan Hernandez, and David Penaloza: RE: City of Santa Ana's Proposed Resolution to Exempt 806 Parcels from Assembly Bill 2011 — Letter of Technical Assistance The California Department of Housing and Community Development (HCD) understands that the City Council will hold a public hearing on June 20, 2023, to consider proposed resolutions exempting certain parcels from Assembly Bill (AB) 2011 and Senate Bill (SB) 6 pursuant to Government Code sections 65912.114, 65912.124, and 65852.24, agendized as item number 32 in its consent calendar. At the urging of the Attorney General, the City Council declined to consider an earlier version of the proposed resolution so as to provide more time and opportunity for interested parties and stakeholders to review the proposal. Since then, HCD has reviewed the resolutions and met with City of Santa Ana (City) staff to discuss the City's proposed parcel exemptions and provide technical assistance regarding implementation of the exemption provisions in AB 2011 and SB 6. The purpose of this letter is to provide further technical assistance regarding the City's actions related to AB 2011 and to advise the City that adoption of the resolutions may be inconsistent with AB 2011. Though the focus of this letter is on AB 2011, HCD may provide additional technical assistance on the proposed companion resolution exempting SB 6 parcels at a later date. HCD recognizes the City's efforts and meaningful progress promoting housing production. The City has met its 6M cycle regional housing needs allocation (RHNA) for the lower - income category with its pipeline and accessory dwelling unit (ADU) projects.' Table C-6 of the 6th Cycle Housing Element demonstrates that the City was able to meet its RHNA without the need for rezoning. HCD understands that the City completed the General Plan update in April of 2022. The updated General Plan identified Five Focus Areas2 with land 1 The City of Santa Ana, 611 cycle housing element, page C-26, Table C-6 Summary of RHNA and Housing Sites Table. 2 Ibid. at page LU-27, Figure LU-5.