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I L UDF <br />Jul 15, 2025 <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />Re: Proposed Housing Development Project at 2130 E 4th Street <br />To: eComment(asanta-ana.org <br />CC: scarvalho(asanta-ana.org,; cityclerkasanta-ana.org; Planning(asanta-ana.org; <br />ANunez(casanta-ana.org <br />Dear Santa Ana City Council, <br />The California Housing Defense Fund ("Ca1HDF") submits this letter to remind the City of its <br />obligation to abide by all relevant state laws when evaluating the proposed 15-unit housing <br />development project at 2130 E 4th Street, which includes 3 very low-income units. These <br />laws include the Housing Accountability Act ("HAA'), the Density Bonus Law ("DBL"), AB 130 <br />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).) The <br />HAA also bars cities from imposing conditions on the approval of such projects that would <br />render the project infeasible (id. at subd. (d)) or reduce the project's density (id. at subd. (j)) <br />unless, again, such written findings are made. As a development with at least two-thirds of <br />its area devoted to residential uses, the project falls within the HAA's ambit, and it complies <br />with local zoning code and the City's general plan. Increased density, concessions, and <br />waivers that a project is entitled to under the DBL (Gov. Code, § 65915) do not render the <br />project noncompliant with the zoning code or general plan, for purposes of the HAA (Gov. <br />Code, § 65589.5, subd. (j)(3)). The HAA's protections therefore apply, and the City may not <br />reject the project except based on health and safety standards, as outlined above. <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. (b).) <br />2201 Broadway, PH1, Oakland, CA 94612 <br />www.calhdf.org <br />