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While the City has seen increased production of affordable housing there has been a disproportionate <br />production of above moderate housing with a total of 3,274 above moderate units produced between 2013- <br />2021, the City exceeded its RHNA allocation by 3,638% per the City's RHNA progress reports submitted <br />to the state. With average rents of$2000 - $4000, none of these above market rental units are affordable to <br />most of Santa Ana's working families. Housing costs in Santa Ana have been out of reach and will continue <br />to be out of reach in this current economic climate. Households in Santa Ana must earn $44.83 an hour to <br />afford two-bedroom housing.'The proposed amendments further incentivize housing units with market rate <br />rents and are not affordable to the majority of the City's residents. <br />The Commission supports the amendments to update the in-lieu fee to $15 per sq ft to be in line with a fee <br />that is fair and allows the City to fund much needed affordable housing for Santa Ana residents. We also <br />support the wider application of the Housing Opportunities Ordinance in the City of Santa Ana. This will <br />continue to facilitate the development of affordable housing in various areas of the city. The Commission <br />also recommends that the HOO apply to all residential developments in the City. At a minimum the HOO <br />affordable housing requirements should apply to all residential and mixed use developments that are asking <br />for zone changes,upzonings, following city initiated specific plans, general plan updates or those asking for <br />other development incentives. <br />In addition, the HOO should apply to all developments taking advantage of City initiated land use and <br />zoning changes, specific plans and general plan updates and amendments. Land use changes may create <br />higher land values,profit, and incentives for market rate developers. At the same time many of these market <br />developments are not affordable to the majority of Santa Ana's residents. In exchange for these development <br />incentives, new affordable housing for Santa Ana residents must be created. <br />The City must also ensure that the Inclusionary Housing Fund monies prioritize the construction of <br />affordable housing for extremely low- and very low-income families. These are the families that have the <br />most pressing needs in the City of Santa Ana. In addition,the fund should also prioritize addressing housing <br />insecurity, eviction prevention, and housing legal assistance for residents that would directly help current <br />Santa Ana residents with the exception of code enforcement. Diversion of these funds to other programs <br />unrelated to housing and direct help for families would not increase or improve the supply of affordable <br />housing. <br />We urge you to take into consideration the amendments and proposed recommendations to the Housing <br />Opportunity Ordinance. These recommendations will help the city increase affordable housing options for <br />residents and help the city meet equitable housing production goals. <br />Sincerely, <br />Cesar Covarrubias <br />Executive Director <br />4 <br />National Low Income Housing Coalition.Out of Reach The High Cost of Housing 2021,pg.18.Out of Reach 2021(nlihc.org)