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average h.ousing unit subsidies that a public agency in Orange County nught use. The conclusions of this analysis supports the District estimate of a $25,000 subsidy, assuming a land cost per acre of $1.090,000 and various mix and assumptions of affordable housing tyPes and financial parameters" (page Financial Burden or Detriment-15). The Agency disagrees with. the analysis and conclusions drawn regarding the level of subsid, y requ. ired to assist low and moderate income new housmgumts..A numb. er of the assUmptions used to support the District's esttmate of $25,000 per unit average subsidy are not ap. propr.iate to use in. regards to Santa Ana projects. The following pmnts substantiate this conclusion: 1) Unit Mix - Given the housing market in the City, there is no subsidy required to assist moderate income units. The rental rates of moderate income units are the same as market rate units; therefore, it is inappropriate to assume a subsidy would be provided, 2) Units Per Acre - The General Plan for the City of Santa A:n.a provides for a maximum density of 15 un[ts per acre wnhin those areas designated medium density residential. There is no portion of the City currently designat.ed in the General Plan for high density residential, except m the context of a m. aster planned mixed use development. It is assumed that if low income units were constructed, a density bonus would be granted and, therefore, 20 housing units per acre density is more appropriate. 3) Unit Size and Cost - The CSA report utilizes different unit sizes and per square foot construction cost depending on ,ncome level. Unit size and construction cost standards within the City do not change based strictly on income levels. A 3 to 4 person unit would be the same size whether for a very low or low income tenant. The table below presents a revis!on of the analysis provided by the District based upon the revisions noted above. This revised calculation presents an average subsidy of $50,985. 29 I