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Community Development Agency <br />www.santa-ana.org/cd <br />Item # 21 <br />City of Santa Ana <br />20 Civic Center Plaza, Santa Ana, CA 92701 <br /> Staff Report <br />November 4, 2025 <br />TOPIC: Adopt an Amendment to the Affordable Housing Funds Policies and Procedures <br />AGENDA TITLE <br />Adopt an Amendment to the Affordable Housing Funds Policies and Procedures <br />RECOMMENDED ACTION <br />Approve recommended changes to the Affordable Housing Funds Policies and <br />Procedures. <br />GOVERNMENT CODE §84308 APPLIES: No <br />DISCUSSION <br />Staff recommends that the City Council approve revisions to the City’s adopted <br />Affordable Housing Funds Policies and Procedures (“Policies”) to prevent situations in <br />which the Council is asked to approve a “pre-loan commitment” or “pre-loan <br />commitment letter” if the project is not consistent with the City’s General Plan Land Use <br />Element and Zoning Classification. The proposed revisions aim to ensure that funding <br />decisions occur only if the project is consistent with these foundational regulatory <br />frameworks, thereby avoiding the appearance that project outcomes are predetermined <br />and strengthening the transparency and integrity of the City’s review and decision- <br />making process. <br />This recommendation is responsive to a conflict situation highlighted by a recent <br />proposal submitted to the Community Development Agency (“CDA”) by Habitat for <br />Humanity of Orange County (“Habitat”). The Habitat proposal requests a pre-loan <br />commitment by the City to a housing project with more units proposed on a property <br />than permissible under the existing General Plan Land Use Element and Zoning <br />Classification, thereby requiring Planning Commission and City Council approval of a <br />zone change and general plan amendment. Even though the pre-loan commitment is <br />consistent with past practices and the approval would have a condition that the project <br />developer must obtain all necessary land use approvals and entitlements from the City, <br />in this situation, the pre-loan commitment puts the City Council in a position of having to <br />approve funding even though the project is not consistent with the General Plan Land <br />Use Element and the Zoning Classification and has not undergone the public decision- <br />making process.