80A - SUPPLEMENTAL - SANTA ANA TRANSITZONINGCODE POST- RESPONSE TO COMMENTS - FEIR

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Chapter 13 TEXT CHANGES same number of units that would be rented to low, very -low and extremely -low income households in the proposed Developer Project. (Id.) Alternative 5 would also offer for sale 16 low income units, one moderate income unit and four market rate units. Findings The Agency hereby finds that specific economic, legal, social, technological, or other considerations make the adoption of this alternative infeasible. Specifically, Alternative 5 would reduce the number of residential units by 11 and would increase costs to the Agency by approximately $6.62 million, according to the financial analysis prepared by Keyser Marston Associates (KMA) for the City of Santa Ana (as updated on May 22, 2010) and included in Appendix J of the EIR. Additionally, this alternative would cost the Agency approximately $56,800 more per unit than the proposed Developer Project, due primarily to the substantial rehabilitation and relocation costs that would be involved in this alternative. (Refer to Appendix J (updated).) This represents a 39% increase in per unit costs. This is a significantly less efficient and effective way to spend the funds available for redevelopment of the Agency -owned parcels than the proposed Developer Project. The significant additional cost to the Agency of this Alternative renders it economically infeasible. Additionally_ Alternative 5 does not to meet the City's policy of "maximiz[ind affordable housing on Agency -owned properties that is of high duality_ sustainable_ and available to various income levels." (Refer to Santa Ana Housing Element [2006- 20141_ Policy HE -2.8.1 Nor does it �4o far enou6h to meet the City's policy to "encourage the construction of rental housing for Santa Ana's residents and workforce_ including a commitment to very low_ low and moderate income residents and moderate income Santa Ana workers" (Policy HE -23) or its policy to "facilitate and encourage a diversity and range in types_ prices_ and sizes of housing including single - family homes_ apartments_ town homes mixed /multiuse housing_ transit - oriented developments_ and live /work housing" (Policy HE- 2.4;_(Refer to Santa Ana Housing Element [2006- 20141.) Moreover_ the California Legislature has enacted Government Code Section 65589.5. the "Housin Accountability Act" which restricts the City's ability to disapprove_ or require density reductions_ in certain types of residential projects. Specifically, the City may not disapprove a housing development project for very low_ low -_ or moderate - income households unless it makes certain findings set forth in Government Code section 65589.5; subsection (l. The City is unable to make any of these findings at this time. Therefore_ disapproval of the proposed Developer Project is legall y infeasible. Further, under Alternative 5, the proposed park identified in the Developer Project would no longer be included as a project component. The park was one element of several in the overall vision for development of the Agency -owned properties. The selection of Alternative 5 effectively eliminates the ability to construct a park on the block on which it is currently envisioned given that the three structures currently located on the Agency -owned properties within that block would remain under Alternative 5. Finally, Alternative 5 would not meet the objective of the Developer Proposal to redevelop all of the Agency -owned properties. Nor would it meet the objective of providing an economically viable redevelopment scenario for Agency -owned properties, as explained above or the objective oLpIQ=yi=di=ng new affordable housing for families in furtherance of the City's affordable housing foals to the same extent as the proms p raject. 134 City of Santa Ana Transit Zoning Code (SD 84A and SD 84B) EIR