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Local 11 Comments RE: Village Santa Ana Specific Plan
<br /> September 8,2025
<br /> Page 6 of 17
<br /> • POLICY HE-2.7 AFFORDABLE COMPONENT: Pursuant to the Affordable Housing Opportunity
<br /> and Creation Ordinance (AHOCO), require eligible rental and ownership housing projects to
<br /> include at least 15 percent of the rental housing units as affordable for low-income households,-
<br /> or 10 percent of the rental units affordable to very low-income households; or 5 percent of
<br /> rental units affordable to lower income households(5 percent to low-income, 3 percent to very
<br /> low-income, and 2 percent to extremely low-income households); or at least 5 percent of the
<br /> units ineligible ownership projects affordable to moderate-income households. Implement
<br /> various strategies using the in-lieu fees generated by AHOCO to provide a wide array of
<br /> affordable housing options.
<br /> • GOAL HE-4 SPECIAL NEEDS: Provide sufficient rental and ownership housing opportunities
<br /> and supportive services for seniors, people with disabilities, families with children, and people
<br /> experiencing homelessness.
<br /> • POLICY HE-4.1 SENIOR HOUSING: Support development of affordable senior rental and
<br /> ownership housing,readily accessible to support services; provide assistance for seniors to
<br /> maintain and repair their homes to facilitate the maximum independent living.
<br /> • POLICY HE-4.2 FAMILY HOUSING: Facilitate and encourage the development of larger rental
<br /> and ownership units for large families,including extremely low-, very low-, and low-income
<br /> families as well as the provision of childcare, after-school care, and other services on-site
<br /> when feasible.
<br /> • POLICY HE-5.6 PRESERVE HOUSING Seek to preserve housing opportunities for all residents
<br /> through actions aimed at limiting displacement, preserving affordable housing, and
<br /> expanding
<br /> Economic Prosperity Element(emphasis added :14
<br /> • POLICY EP-3.4 COMPLETE COMMUNITIES: Encourage the development of"complete
<br /> communities"that provide a range of housing,services, amenities, and transportation options
<br /> to support the retention and attraction of a skilled workforce and employment base.
<br /> 3. THE SEIR MAY NOT ADEQUATELY CONSIDER POTENTIAL INCONSISTENCIES WITH
<br /> APPLICABLE SCAG RTP/SCS COMMUNITY POLICIES
<br /> The SEIR suggests the Village Specific Plan and Project is consistent with the SEIR,which
<br /> cites goals/policies from the Southern California Association of Governments ("SCAG") 2020-2045
<br /> Regional Transportation Plan/Sustainable Community Strategy("RTP/SCS"or"Connect SoCal").
<br /> (See e.g., SEIR, PDF pp. 266, 327-328, 347-349, 351 [SCAG RTP/SCS Goal 9 and Strategy-Promote
<br /> Diverse Housing Choices].) However, as noted in the SEIR, SCAG has adopted its 2024-2050
<br /> RTP/SCS. (Id., at PDF pp. 129, 245, 584.) The 2024 RTP/SCS15 has four primary goals (i.e.,mobility,
<br /> communities,environment, economy) (pp. 9-12),each with respective subgoals (p. 85) and
<br /> categories of policies (pp. 88-112),which totals nearly 90 regional planning policies (pp. 114-121),
<br /> and other implementation strategies where local governments play a partner/supporting role (pp.
<br /> 124-135). Providing affordable and sustainable housing is a major cross-cutting theme in the 2024
<br /> RTP/SCS (pp. 8,9, 10, 27, 28, 54, 56, 66, 100, 106, 112, 117, 135, 193, 197).As discussed above,the
<br /> Village Specific Plan may result in solely market-rate residential units without a single affordable
<br /> unit built onsite within the plan area, despite the compelling need for affordable units. This could be
<br /> inconsistent with a variety of 2024 RTP/SCS Community provisions,such as those listed below:
<br /> 14 See City Economic Prosperity Element,PDF pp.8-15,https://general-plan-santa-ana-
<br /> ca.proudcity.com/documents/e conomic-prosperity/.
<br /> 15 See 2024 RTP/SCS,https://scag.ca.gov/sites/default/files/2024-05/23-2987-connect-socal-2024-final-
<br /> complete-040424.pdf.
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