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Chapter 3 Flndfngs Regarding Protect A/ternat)ves moderate income households than the proposed Developer Project This reduction in the number of affordable housing units eliminates an opportunity to provide affordable housing in furtherance of meeting the City's RHNA. It also eliminates the oppartunity to provide Special Needs housing through the Mercy House project. Similarly, Alternative 4 does not to meet the City's policy of "maximiz[ing] affordable housing on Agency-owned properties that is of high quality, sustainable, and available to various income levels." (See Santa Ana Housing Element [2006-2014], Policy HE-2.8.) Nor does it go fax enough to meet the City's policy to "encourage the construction of rental housing fox 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-2.3) ox 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). (See Santa Ana Housing Element [2006-2014].) Further, the City of Santa Ana currently has a shortage of rental units appropriately sized to accommodate families. As stated in the City's 2006-2014 Housing Element, while multiple-family housing comprises 41 % of all housing stock within the City, only 13% of multiple family and single- family rental units have three or more bedrooms. It is estiiiiated that 45% of all families who rent have five or more members. This translates into a shortage of 12,000 large family rental units. The Developer Project contains 78 two-bedroom units (two of which are manager units) and 67 three-bedroom units. In addition, the Mercy House project would provide one three-bedroom, five-one bedroom and five two- bedroom units (exclusive of manager's unit) of special needs housing. These units are appropriately sized to meet Santa Ana's identified demographic needs. Implementation of Alternative 4 would not further the City's policies relating to the need for rental housing suitable for families, nor would it achieve the project objectives described above. Moreover, the California Legislature has enacted Government Code section 65589.5, the "Housing 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 (d). The City is unable to make any of these fuidings at this time. Therefore, disapproval of the proposed Developer Project is legally infeasible. Additionally, Alternative 4 also affects the fixed ratio of construction costs but does not commensurately reduce construction costs. Therefore, although the total cost of this alternative to the City/Agency would be less than the proposed Developer Project, the cost/unit would be approximately $26,000 higher than the proposed Developer Project. This is attributable to the fact that smaller apartment projects would be developed under this alternative, which generate a higher per unit financial gap, according to the financial analysis prepared by Keyser Marston Associates (I{MA) for the City of Santa Ana (as updated on May 22, 2010) and included in Appendix J of the EIR. 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. 3-10 Transit Zoning Code (SD 84) EIR Findings of Fact/Statement of Overriding Considerations