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Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 2 of 17 For the reasons discussed herein,Local 11 respectfully urges the City to consider: 1. Removing hotel uses from the Village Specific Plan,which can be accomplished with minor edits to four pages of the current planning document(i.e.,pp. 73, 74, 83, 88).They are attached hereto as Exhibit A. 2. Requiring some portion of the housing to be affordable and/or workforce housing. 3. Implementing additional design features and mitigation measures to potentially significantly minimize potential impacts from vehicle miles traveled("VMT") and mobile emissions,which affect air quality and greenhouse gas ("GHG") emissions. Measures suggested by public agencies, such as the measures attached hereto as Exhibit B, can help achieve this goal. The remainder of this comment letter is in response to the SEIR and documents presented during the City's Planning Commission hearing held on August 11, 2025,including the Planning Commission staff report("PC Staff Report"),4 hearing video (`PC Video"),5 and other public documents. A. THE CITY MAY WANT TO RECONSIDER A PLAN THAT PROVIDES SOME AFFORDABLE UNITS In 2022,the City revised its now-known Affordable Housing Opportunity and Creation Ordinance ("AHOCO"). (See Santa Ana Municipal Code ("SAMC") §41-1900 et seq.) Generally,the AHOCO encourages new residential developments to include affordable housing units onsite or offsite (e.g., 5-15% depending on affordability) or in-lieu fees ($6- $15 per square foot depending on the number of units proposed),which may be reduced to $5.00 in some cases. (See SAMC§41- 1904.) Here, under section five of the proposed development agreement("DA"),6 the Project is paying the lowest$5.00 per square foot of each market-rate residential unit. Hence,the Project may provide zero affordable housing units (i.e., onsite) and pay an in-lieu fee into an Inclusionary Housing Fund that is intended to be utilized for the construction of an unknown number of affordable units at some unknown project site (i.e.,offsite) at some unknown date in the future. This level of uncertainty is among other potential drawbacks of in-lieu fee programs as compared to inclusionary housing requirements.? Hence, the Village Specific Plan could allow not a single affordable unit within the proposed plan (i.e., onsite)with unknown certainty of when, where, or how many potential affordable units will be built. 4 Inclusive of all Exhibits ("Exh.")attached thereto on the City's online agenda. (See Planning Commission (8/11/25) Item 1,https://santa-ana.primegov.com/Portal/Meeting?meetingTemplateId=23803.) 5 PC Video (8/11/25) appx.03:21:40-3:27:00,https://www.youtube.com/watch?v=7cY4_O7GAs8. 6 PC Staff Report,Exh.8 (DA),PDF p.17 (section 5.1.1),https://santa-ana.primegov.com/api/ compilemeetingattachmenthistory/historyattachment/?historyld=fadfe Oc8-cf6f-4ff5-b9d0-9d92 cdfb93b4. See e.g.,Urban Land Institute (May 2020) Determining In-Lieu Fees in Inclusionary Zoning Policies Considerations for Local Governments,p.5 (noting potential disadvantages like:fees being set too low, undermining inclusionary zoning policy,creation of lower quality offsite affordable units,concentration of low-income housing that defeats mixed-income development), https://www.urban.org/sites/default/files/publication/102230/determining-in-lieu-fees-in-inclusionary- zoning-policies_1.pdf.