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3.2 Submittal to HCD and Response to Comments <br />Following the study sessions, we will revise the draft Housing Element <br />for distribution to and review by the California HCD. The HCD has 60 <br />days to complete the review and reply with written comments and their <br />determination of its adequacy. They will direct the majority of its focus <br />on housing sites, zoning, development standards, and programs to <br />determine whether they are sufficient to encourage and facilitate housing <br />production commensurate with the Ciyy's RHNA. <br />As is the case with large and complex communities, we anticipate the <br />HCD review process will be detailed. Rather than offer strategies and <br />wait for HCD's response, we recommend working with them up front <br />to determine the feasibility of various strategies. This would avoid the <br />situation where the City Council accepts a concept only to have it <br />rejected by the HCD. We will work with HCD through informal <br />consultations to flesh out any potential areas of concern upfront, <br />so these issues can be addressed before submitting the draft. <br />Once we have received written comments from the HCD, we will work <br />closely with City staff and HCD reviewers to address any outstanding <br />concerns on the draft. This is typically an iterative process, requiring a <br />series of formal and informal communications. If significant program <br />commitments are required to achieve substantial compliance, we <br />recommend holding a City Council study session prior to resubmitting <br />the draft to the HCD. However, based on the Ciy's RHNA, we do not <br />anticipate the need for an additional study session. <br />For budget purposes, we anticipate two rounds of formal review. <br />Typically, the need for a third round of HCD review depends on the <br />nature of the challenges faced in the Housing Element and how <br />aggressive the programs are in the first draft. To ensure a speedy and <br />predictable review process, we will work with the HCD throughout the <br />development of the Housing Element to identify any areas of potential <br />concern upfront so that the draft Housing Element submitted to the <br />HCD has the best chances of securing a speedy review and approval. <br />Deliverables <br />HCD Review Draft Housing Element (2 copies) <br />Third Preliminary HCD Housing Element <br />Summary of changes made to the Housing Element <br />Page 2-20 Proposal to City of Santa Ana <br />