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UDF <br />Jun 23, 2025 <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />Re: Proposed Housing Development Project at 2130 East Fourth Street <br />By email: PBAecommentsesantaana.org <br />CC: scarvalhocasanta-ana.org; cityclerk(asanta-ana.org; Planning(asanta-ana.org; <br />ANunez@santa-ana.org <br />Dear Santa Ana Planning Commission, <br />The California Housing Defense Fund ("Ca1HDF") submits this letter to remind the City of its <br />obligation to abide by all relevant state housing laws when evaluating the proposed 15-unit <br />housing development project at 2130 East Fourth Street, which includes three very <br />low-income units. These laws include the Housing Accountability Act CHAR" ), the Density <br />Bonus Law ("DBL"), and California Environmental Quality Act ("CEQA') guidelines. <br />The HAA provides the project legal protections. It requires approval of zoning and general <br />plan compliant housing development projects unless findings can be made regarding <br />specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subds. (d), (j).) <br />The HAA also bars cities from imposing conditions on the approval of such projects that <br />would reduce the project's density (id. at subd. (j)) or render the project infeasible (id. at subd. <br />(d)) unless, again, such written findings are made. As a development with at least two-thirds <br />of its area devoted to residential uses, the project falls within the HAAs ambit, and it <br />complies with local zoning code and the City's general plan. The City must therefore approve <br />the project unless it makes written findings regarding health and safety as mentioned <br />above - which it cannot do since the preponderance of the evidence in the record does not <br />support such findings. (Ibid.) Increased density, concessions, and waivers that a project is <br />entitled to under the DBL (Gov. Code, § 65915) do not render the project noncompliant with <br />the zoning code or general plan, for purposes of the HAA. (Gov. Code, § 65589.5, subd. (j)(3).) <br />Furthermore, if the City rejects the project or impairs its feasibility, it must conduct "a <br />thorough analysis of the economic, social, and environmental effects of the action:' (Id. at <br />subd. M.) <br />360 Grand Ave #323, Oakland 94610 <br />www.calhdf.org <br />