Staff Responses to CEQA Related - Agenda Item No. 28

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The Village Santa Ana Specific Plan Project The Letter provides comments regarding affordable housing, the appropriate level of analysis under the California Environmental Quality Act (“CEQA”), and the appropriateness of a hotel use as part of the proposed Project. As explained in detail below, the Village Santa Ana Specific Plan Project (“Project”) contributes to the potential affordable housing production through the provision of in-lieu fees; appropriately and conservatively studied a maximum buildout with appropriate mitigation pursuant to CEQA; and included hotel uses as an appropriate use given the applicable General Plan Land Use Designation. I. The Project Provides In-Lieu Fees that Can Contribute to Affordable Housing Production within the City The commenter claims there is “uncertainty” regarding how the Project will contribute to affordable housing in the City. The Project contributes to Santa Ana’s affordable housing by providing significant in-lieu fees as permitted by the City’s Affordable Housing and Opportunity Creation Ordinance (“AHOCO”). The AHOCO generally applies to housing projects proposing five or more units that are also requesting an increase in allowable density or are located in certain sections of the City that were “up-zoned,” such as through a zone change or general plan amendment to allow additional residential development after November 28, 2011. As the Project is located in a section of the City that was “up-zoned” to allow for additional density capacity, the South Bristol Street Focus Area, (SBSFA), the Applicant’s request is subject to the AHOCO requirements of production of affordable housing or payment of in-lieu fees. Pursuant to Sections 41-1903 (Exempt Projects) and 41-1904 (Options to Satisfy Inclusionary Requirements) of the Santa Ana Municipal Code (SAMC), the Applicant has indicated intent to select the option to pay in-lieu fees at a rate of $5 per square foot of habitable residential area through the requested development agreement. The Project will provide in-lieu fees at a rate of five dollars per habitable square foot of residential area. As a result, City staff estimates the Project could generate approximately 7.1 million dollars in in-lieu fees based on the unit mix and square footage of the proposed 1,583 proposed dwelling units. As set forth under Sections 41-1090 (Inclusionary housing fund) of the SAMC, the 7.1 million dollars in fees will be deposited in an inclusionary housing fund and will be used by the City to target production of extremely low, very low, low, and moderate income housing units. Santa Ana’s Regional Housing Needs Allocation (RHNA) for the current General Plan Housing Element cycle (Sixth Cycle), which extends from 2021-2029, includes 3,137 housing units. This allocation is for housing units to be constructed to support the anticipated growth in the City over this period. The Project will provide 1,583 units towards total RHNA units, and the Project’s in-lieu fees can be utilized to target the affordable housing categories. In short, the City and the Project are not missing an opportunity to encourage affordable housing as stated by the commenter, but rather the Project’s in-lieu fees will be appropriately be allocated towards the City’s RHNA targets for extremely low, very low, low, and moderate income housing needs. As the commenter notes, the “AHOCO encourages new residential developments to include affordable housing units onsite or offsite \[\] or in-lieu fees…” (Letter, pg. 2.) Here, the Project elects to encourage housing both on site and through the use of in-lieu fees. II. The Project is Compatible with Applicable General Plan Policies City of Santa Ana September 2025 2 55394.00067\\44182451.1