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Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 3 of 17 However, as discussed below,there seems to be: (i) substantial evidence from state data showing the City has a compelling need for affordable housing to meet its RHNA obligation (infra section A.1); (ii) the SEIR may not adequately consider potential inconsistencies with various policies under its General Plan(infra section A.2); and (iii)the SEIR did not consider potential inconsistencies with adopted regional housing policies (infra section A.3).Under the circumstances, the City may want to reconsider a Village Specific Plan that ensures some affordable housing units onsite. So too,failure to adequately consider potential conflicts/inconsistencies with applicable land use plans, policy,or regulation may run afoul of CEQA.8 1. HCD DATA SHOWS COMPELLING NEED FOR AFFORDABLE UNITS The California Department of Housing and Community Development("HCD") oversees local municipalities' compliance with various state housing laws, including those relevant to Housing Element updates to accommodate local RHNA numbers.9 Cities and counties provide self-reported Annual Progress Reports ("APR(s)") to HCD regarding their progress on these efforts,and HCD provides summaries of these"self-reported"APRs on its Housing Element&APR Data Dashboard ("Dashboard").10 The Dashboard displays various data across 18 sheets, allowing the user to focus on multiple jurisdictions,years,housing cycles, and other filters. Based on the APR Dashboard for the City of Santa Ana, one can make the following observation,which references the figures below: • Santa Ana is in its Sixth Housing Element Cycle (2021 - 2029),has a total RHNA obligation of 3,137 units,of which roughly 48.2%are to be affordable at moderate levels or lower. (See Fig. 1 below.) • Through 2024,the City was 37.5%through the cycle;while it has made significant strides,it has developed an excess of above-moderate income units (i.e., approximately 180%above its 1,624 RHNA obligation) as compared to its affordable units (i.e., approximately 52%of its 1,513 RHNA obligation). (See figure 2 below.) 8 The CEQA Initial Study Checklist,used to determine whether a project may have significant environmental impacts,includes the question of whether a project may"[c]onflict with any applicable land use plan,policy, or regulation ...adopted for the purpose of avoiding or mitigating an environmental effect." (CEQA Guidelines,Appendix G;Pocket Protectors v.City of Sacramento (2004) 124 Cal.AppAth 903,929 [EIR required to analyze project's inconsistency with City land use ordinance for planned developments].) A project is inconsistent if it conflicts with a fundamental,mandatory and specific land use policy. (Families Unafraid to Uphold Rural etc. County v.Board of Supervisors(1998)62 Cal.AppAth 1332, 1342.)Furthermore, a project that causes a loss of housing stock,land available for housing,or violates zoning laws designed to encourage housing,can pose a potentially significant impact that must be considered under CEQA. (Concerned Citizens v.Los Angeles Unified School District(1994) 24 Cal.App.4th 826,838 [SEIR acknowledged significant adverse impact on affordable housing stock];Sacramento Old City Assn. v.City Council(1991)229 Cal.App.3d 1011, 1038-39 [loss of housing can constitute a potentially significant impact necessitating adequate mitigation measures].) 9 See e.g.,HCD Housing Element,https://www.hcd.ca.gov/planning-and-community-development/housing- elements;HCD RHNA,https://www.hcd.ca.gov/planning-and-community-development/regional-housing- needs-allocation;HCD Annual Progress Reports,https://www.hcd.ca.gov/planning-and-community- development/annual-progress-reports. 10 HCD,Housing Element&APR Dashboard,https://www.hcd.ca.gov/planning-and-community- development/housing-element-implementation-and-apr-dashboard.