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Section 2. No boardinghouse, lodging house, rooming house uses, or multiple tenant occupancy within a single apartment unit is permitted within any residential zoning districts as defined in Article 11 of Chapter 41 of the Code. Section 5. It shall be unlawful and a misdemeanor for any person to violate or fail to comply with any provision of the ordinance. The violation of any provision of this ordinance shall be punished as provided in Section 1-8 of the Code Our first observation is that these provisions will make illegal an unknown number of lease and rental agreements that likely exist in the city at present, and that are perfectly legal under current law. Lease agreements confer certain rights upon tenants, and obligations upon lessors, under California law. The above provisions would bring about a conflict of laws, whereby a lessor cannot comply with state law without violating the new provisions of this city ordinance. The language also threatens the housing security of an unknown number of tenants, many of whom may have no other housing options. Nothing in the material presented in the staff recommendations or the ordinance suggests that the City has sought to determine the number of tenants that will be affected. Language in the ordinance and in the recommendations of the Planning and Building Agency, discusses objections to multiple leases in multifamily units. Many low-income and disabled residents of Santa Ana receive housing assistance that may require them to have separate leases, even in shared housing. The failure to provide relief for disabled individuals whose housing expenses are paid by agencies requiring separate leases ignores the state policy (Mental Health Services Act) that established the individual lease provision. The same objection applies to veterans' housing programs such as VASH, which also require beneficiaries to have individual leases in order to qualify for their housing benefits. The provisions of this law will displace those individuals from their housing, and deprive others of being able to access that type of housing. We are particularly concerned about the focus on leases in households of disabled individuals, including the individuals in sober living homes. At least with respect to disabled residents, local requirements for single written rental agreements have been found illegal elsewhere. These requirements are considered to be, and are often used to create, barriers to access to housing for persons with disabilities, and are often used against households of individuals in recovery from substance use disorders (a protected class under both California and Federal law). Lease provisions were factors in the Newport Beach "sober living' ordinance, litigation and subsequent decision at the Ninth District Federal Court of Appeals that resulted in a substantial monetary settlement by the city in favor the plaintiffs. The City of Los Angeles briefly considered a similar feature in deliberations a few years ago, when it too sought to update its definition of "Boarding or Rooming House." They abandoned that approach after receiving Page 2 of 3