Appendix C: Summary of Outreach C-1
Appendix C
Community Outreach and Engagement
Appendix C: Summary of Outreach C-2
Appendix C: Community Outreach and
Engagement
Section 65583 of the Government Code s tates that, “the local government shall make diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort.” Meaningful community participation is also required in connection with the City’s Assessment of Fair Housing (AFH). A summary of citizen participation is provided below.
As part of the Sixth Cycle Housing Element Update process, the City of Anaheim has conducted extensive public outreach activities beginning in early 2021, including a series of Community Workshops. The goal of Community Workshops was to hear from a broad spectrum of community members on community values, assess the current Housing Element, and recommendations goals and policies of the Sixth Cycle Housing Element. Advertising and promotion of the workshops was done to increase participation by a variety of stakeholders representing a diverse cross -section of the Anaheim community, and included emails to the City’s distribution list, social media posts, creating an item on the City’s calendar, distribution of event flyers , which were in both English and Spanish, at libraries and community events and/or announcing the event on the project website. All three workshops were conducted in both English and Spanish. Summary of the Community Workshops are as follows:
• Community Workshop #1 – March 24, 2021, 6:00 p.m. to 7:30 p.m. via Zoom: Approximately 59 members of community attended this workshop. They received an overview of the Housing Element Update process and community and housing characteristics, and participated in engagement activities.
• Community Workshop #2 – June 30, 2021, 6:00 p.m. to 7:30 p.m. in person at the Downtown Anaheim Community Center: Approximately 24 members of the community attended this workshop. Opportunity sites and policy strategies for the Housing Element were discussed, and opportunities for the public to discuss options and provide feedback were provided. • Community Workshop # 3 – September 2, 2021, 6:00 p.m. to 7:30 p.m. in person at the Downtown Anaheim Community Center: Approximately 10 members of the community attended this workshop. Access and review of the draft Housing Element Update document and ideas and feedback on the document were discussed.
Refer to Sections C.1 through C.3 of this document for workshop materials, such as flyers, presentations and meeting summaries. These materials , along with a video recording of the Community Workshop #1, are also available on the City’s webpage at:
http://www.anaheim.net/5876/Community-Workshops.
Appendix C: Summary of Outreach C-3
The City also led additional focused community outreach. These outreach efforts included Housing Element Update Committee (HEUC) Meetings, Technical Focus Group interviews, an Online Community Survey, Planning Commission Workshops, a Housing and Community Development Commission Workshop, City Council Workshop s, and a dedicated website . HEUC meetings, Community Workshops, and the Online Community Survey were offered in both English and Spanish to achieve broad public input.
A summary of the additional community outreach efforts is below:
• Housing Element Update Committee (HEUC) Meetings – The City established a Housing Element Update Committee , which was comprised of a variety of stakeholder groups and Anaheim residents. The purpose of HEUC was to:
o Advise and provide input to the City's project team, based on their expertise, experience, and knowledge;
o Review draft documents for potential housing sites and housing policies; and o Be an advocate for the Housing Element Update process to the Anaheim community.
HEUC held monthly meetings from March 2021 to September 2021, and held an additional meeting in month 2022 (to be updated), prior to Council consideration for adoption . All HEUC meetings were open to the public. The list of all HEUC meetings is below:
o Meeting #1: March 18, 2021, 5:30 p.m. to 7:00 p.m. via Zoom o Meeting #2: April 15, 2021, 5:30 p.m. to 7:00 p.m. via Zoom o Meeting #3: May 20, 2021, 5:30 p.m. to 7:00 p.m. via Zoom o Meeting #4: June 17, 2021, 5:30 p.m. to 7:00 p.m. via Zoom o Meeting #5: July 15, 2021, 5:30 p.m. to 7:00 p.m. in person at Downtown Anaheim Community Center
o Meeting #6: August 12, 2021, 5:30 p.m. to 7:00 p.m. via Zoom o Meeting #7: September 9, 2021, 5:30 p.m. to 7:00 p.m. via Zoom o Planning Commission Workshop: February 24, 2025, at 5:00 p.m. in person in City Council Chambers
Refer to Section C.4 of this document for meeting materials, such as agendas, presentations and meeting summaries. The meeting materials, including meeting recordings for meetings conducted via Zoom, are also available on the City’s webpage at: https://www.anaheim.net/5877/Housing- Element-Update-Committee.
• Technical Focus Group Interviews – The City conducted five informal Technical Focus Group interviews to draw upon the technical expertise of certain groups that have worked with the City of Anaheim. The goal of the Technical Focus Group interviews was to have a listening session to broadly collect information and actionable steps the City can use with the end goal of creating programs that promote the development of housing at all income levels. The Technical Focus Group participants consisted of housing advocates , and representatives from community organizations, housing and real estate organizations, and major employers in the City . The five interview sessions held with the Technical Focus Groups are as follows:
Appendix C: Summary of Outreach C-4
o Interview #1: June 24, 2021 with major employers in the City o Interview #2: July 8, 2021 with housing advocates and community organizations o Interview #3: July 19, 2021 with housing advocates and community organizations o Interview #4: July 19, 2021 with housing and real estate organizations o Interview #5: July 24, 2021 with major employers in the City Refer to Section C.5 of this document for summary of Technical Focus Group interviews. • Online Community Survey – The City of Anaheim launched an Online Community Survey to gather additional feedback regarding the Housing Element Update. The Online Community Survey was available to the public from March 24 to June 13, 2021 in both English and Spanish. Participants were asked to consider potential policies and programs to include in the Housing Element, as well as potential housing types and opportunities for housing in the City. The survey also solicited feedback regarding potential barriers t o housing access and constraints to the development of housing.
Refer to Section C.6 of this document for survey materials, such as survey questions and summary of survey results. The survey materials are also available on the City’s webpage at:
http://www.anaheim.net/5883/Community-Survey.
• Planning Commission Workshops –The City held two Planning Commission Workshops on August 16, 2021 and September 27 , 2021. During the first workshop, the project team provided an overview of the Housing Element update process , polices and site analysis, and at the second workshop, the Public Review Draft Housing Element . Community members had the opportunity to give public comments. The final Planning Commission Workshop was held in February 24, 2025, at 5:00 p.m. in person in City Council Chambers . The fina l Planning Commission Workshop was held to provide Planning Commissioners with an update of the final Housing Element Update that would be up for consideration at the next Planning Commission meeting.
Refer to Section C -7 of this document for Planning Commission Workshop presentations. In addition, all recordings, agendas, and minutes of the Planning Commission Workshops can also be found on the City’s website at:
http://records.anaheim.net/CityClerk/Browse.aspx?startid=429083&dbid=0. • Housing and Community Development Commission Workshops – The City held two Housing and Community Development Commission Workshops on August 18, 2021 and September 15, 2021.
At the first workshop, the Housing and Community Development Commission was provided with an overview of the Housing Element, community input received, adequate sites analysis, sites to accommodate RHNA, and Sixth Cycle policy considerations , and at the second workshop, the Public Review Draft Housing Element . Community members had the o pportunity to give public comments.
Refer to Section C -8 of this document for Housing and Community Development Commission Workshop presentations. In addition, meeting recording s, agendas, and minutes of the Housing and Community Development Commission Workshop can also be found on the City’s website at:
Appendix C: Summary of Outreach C-5
http://www.anaheim.net/AgendaCenter/Search/?term=&CIDs=16,&startDate=&endDate=&dat eRange=&dateSelector=.
• City Council Workshops –The City held two City Council Workshops on August 24 , 2021 and September 28, 2021. At the first workshop, the City Council reviewed draft RHNA accommodation scenarios and provided input and direction in consideration of community comments received , and at the second workshop, the proposed strategies and the Community and Planning Commission’s input on the Draft Housing Element. Community members had the opportunity to give public comments.
Refer to Section C -9 of this document for City Council Workshop presentations. In addition, meeting recordings, agendas, and minutes of the City Council Workshop can be found on the City’s website at https://anaheim.net/2142/View-City-Council-Meetings. • Housing Element Update Website – A dedicated website was developed for public use and can be accessed at https://www.anaheim.net/5848/2021-2029-Housing-Element-Update. The website provided relevant information about the update process, key features of the housing element, project timeline , and a calendar of events for outreach activities. The website also provided a link to the community survey tool, past recorded meetings and summaries, as well as the contact information of the City for residents and community members to send additional comments or request additional information.
• Planning Commission Public Hearing – The City held a Planning Commission Public Hearing on March 10, 2025, to consider recommending that the City Council adopt the Sixth Cycle Housing Element Update . Community members had the opportunity to provide public comments. The Planning Commission passed a resolution to recommend that the City Council adopt the Sixth Cycle Housing Element Update.
• City Council Public Hearing – The City held a City Council Public Hearing on April 22, 2025, to consider adopting the Sixth Cycle Housing Element Update. Community members had the opportunity to provide public comments. The City Council adopted the Sixth Cycle Housing Element Update.
Public Review
The City released the Draft Sixth Cycle Housing Element for a 30 -day public review period that began on August 26, 2021 and ended on September 24, 2021. Refer to Section C -10 for a summary of public comments received by the City during this initial Public Review Draft period.
The revised draft of the Sixth Cycle Housing Element was posted on the City’s website and the link to the revised draft of the Housing element was emailed to all individuals and organizations that have previously provided written comments including those that requested notices. The draft was made available to the public for at least seven days prior to the City’s resubmittal of the document to HCD. As such, the City is compliance with Government Code Section 65585(b)(1). Lastly, as required by Government Code Section 65585(b)(2), all written comments regarding the Housing Element made by the public have been provided to each member of the City Council.
Appendix C: Summary of Outreach C-6
C.1 Community Workshop #1
This section contains related materials from the virtual Community Workshop #1. The link below includes the outreach flyer, presentation, workshop summary , and activity results . Video recording of the workshop and verbal comments are also available at : https://www.anaheim.net/5876/Community- Workshops.
Appendix C: Summary of Outreach C-7
C.2 Community Workshop #2
This section contains related materials from the Community Workshop #2. The link below includes the outreach flyer, presentation, workshop summary, public comments received, discussion notes, and activity maps: https://www.anaheim.net/5876/Community-Workshops.
Appendix C: Summary of Outreach C-8
C.3 Community Workshop #3
This section contains related materials from the Community Workshop #3. The link below includes the outreach flyer, presentation, and workshop summary: https://www.anaheim.net/5876/Community- Workshops.
Appendix C: Summary of Outreach C-9
C.4 Housing Element Update Committee
Meetings
This section contains the meeting materials, such as agendas, presentations, videos recordings, if available, and meeting summaries, for the Housing Element Update Committee meetings can be found on the City’s website at: https://www.anaheim.net/5877/Housing-Element-Update-Committee.
Appendix C: Summary of Outreach C-10
C.5 Technical Focus Group Interviews
This section contains a summary of the Technical Focus Group Interviews.
The City conducted four informal Technical Focus Groups meetings to draw upon the technical expertise of certain groups that have worked with the City of Anaheim to gather comments and considerations to develop effective housing policy. The goal of the Technical Focus Group meetings was to have a listening session to broadly collect information and actionable steps the City can use with the end goal of creatng programs that promote the development of housing at all income levels. The Technical Focus Groups participants consisted of representative from:
• Major Employers in the City- July 8, 2021
• Housing Advocates and Community Organizations-July 19, 2021 • Housing and Real Estate Organizations -July 19, 2021
The purpose of the Technical Focus Group Meetings was to discuss potential constraints to the development of housing at all income levels in Anaheim as well as Policies/Programs/Actions within the Housing Element that may effectively promote housing growth in the 6th Cycle.
Discussions began with the City and Consultant team sharing key Housing Element Features. Key features discussed include: evaluation of current adopted programs and policies; demographics, population, and housing profile; analysis of housing constraints an d funding resources; analysis of potential sites to accommodate Anaheim's Regional Housing Needs Assessment (RHNA) allocation; policies, programs, and objectives to support identified housing goals for Anaheim; and certification requirements by the State Department of Housing and Community Development (HCD).
After providing key Housing Element information, discussion questions were posed to the Focus Groups.
Those questions are listed below:
• What are some challenges to housing in the community? • What should the City consider when creating housing policies? • Are there initiatives/programs the City should consider to help create housing opportunities? • What are ways the City can increase housing options for Anaheim workforce and low -income households?
• What are some housing types/projects that best meet the community's needs? • What is successful elsewhere?
• Are there programs/opportunities in other Cities that Anaheim should review? Key findings from discussions and responses are summarized below:
Major Employers in the City – July 8, 2021
o Housing opportunities for workers, including entry level to executive. o Many employees travel from far due to housing challenges. o Integrating housing close to work is ideal.
Appendix C: Summary of Outreach C-11
o Need to preserve existing employer properties to preserve job growth/expansion, but integrated development may be appropriate in some circumstances.
o Strong collaboration needed with housing developers and employers to understand needs. o Match local housing options to local employee ability to afford them. o Resort area workforce should have opportunities for local housing, access to transportation and services.
Housing Advocates and Community Organizations – July 19, 2021 o Great opportunities for higher density and mixed-use developments as long as they’re in the right areas.
o Opportunities to redevelop underutilized properties.
o Opportunities to redevelop industrial areas.
o It’s possible to preserve the single -family character or many Anaheim neighborhoods while still developing higher density housing.
o Need for longer affordability covenants.
o Need for senior housing with services close by.
Housing and Real Estate Organizations – July 19, 2021
o City should identify which sites have infrastructure (sewer) deficiencies to make it easier for developers in site selection process.
o City should prioritize HEU site selection in areas that can take advantage of TCAC and other state and federal programs.
o City staff support is vital to getting a project through the process and staff will usually find the resources to help projects they support.
o City should help disseminate information to combat stereotypes of affordable housing since community opposition and NIMBYism is a constraint to housing development. o Dissemination of information at the decision-making process. o Have EIS, EIS sites already identified to make it easier for developers by reducing cost burden. o City staff should be upfront about sites that may not work in order to save time and money.
Technical Focus Group Sessions were important in gathering information and ideas for actionable steps.
Input from discussions helped inform City Staff and the consultant team on possible Housing Plan Policies and what priorities Technical Groups have.
Appendix C: Summary of Outreach C-12
C.6 Online Community Survey
This section contains survey questions, vision comments and summary of survey results. The Online Community Survey was live from March 24 to June 13, 2021. These materials can also be found at:
https://www.anaheim.net/5883/Community-Survey.
Appendix C: Summary of Outreach C-13
C.7 Planning Commission Workshops
This section contains the presentation for the Planning Commission Workshops. All recordings, agendas, and minutes of the Planning Commission Workshops can be found on the City’s website at:
http://records.anaheim.net/CityClerk/Browse.aspx?startid=429083&dbid=0
Appendix C: Summary of Outreach C-14
C.8 Housing and Community Development
Commission Workshop
This section contains the presentation for the Housing and Community Development Commission Workshop. Meeting recording, agenda, and minutes of the Housing and Community Development Commission Workshop can be found on the City’s website at:
http://www.anaheim.net/AgendaCenter/Search/?term=&CIDs=16,&startDate=&endDate=&dateRange= &dateSelector=
Appendix C: Summary of Outreach C-15
C.9 City Council Workshop
This section contains the presentations for the City Council Workshop . Meeting recording, agenda, and minutes can be found on the City’s website at https://anaheim.net/2142/View-City-Council-Meetings.
Appendix C: Summary of Outreach C-16
C.10 Public Comments
This section contains the public comments received by the City during the Public Review Draft period.
DRAFT
1.What is your
association to
the City of
Anaheim?
Please submit comments on Section
1 (Introduction) here.
Please submit comments on Section 2
(Community Profile) here.
Please submit comments on Section 3 (Constraints,
Resources, and Fair Housing) here.
Please submit comments on Section 4 (Housing Plan)
here.
Please submit comments on the
Appendices here.
Ple
ase submit any additional
comments you would like to send to
the project team here.
I am a resident
RHNA allocations to Anaheim is not
done by any measurable method. These
numbers are not reasonable and when
compared to adjacent cites / counties
to Anaheim. While this draft plan does a
reasonable good effort to meet the
latest RHNA, the residents and
contributors to this plan will be out of
th
e loop on its progress.
The city staff was very good in their
presentation, addressing public
requests (Having Spanish translation),
and capturing all public comments
without bias. The City Staff did
everything possible to share and
communicate zoom meetings and in
person meetings. Unfortunately Public
Participation was quite lo w. We need
more neighborhood advocates to get
the residents involved.
Housing cost values on Table 2‐33 are
way off.
If you get the absolute current housing
cost, 75% of all residents cannot afford a
house.
Need more efforts on socializing "ADUs"
to the community.
ADUs should apply to large lots wi th a
small bungalow or smaller sized house.
A conversation with the Church
community to leverage parking lots for a
few ADUs should be considered. Please
keep this conversation active.
Recently passed SB9 and SB10 concerns are not
addressed in the draft plan. In general a process to
address all in SB or ch anges throughout the this time period is needed.
Addressing home affordability for civil service
professions such as teachers and public service needs
to have a vision plan. Many of these folks are critical to the city but are underpaid to afford local housing.
Not all 6 Districts are getting equal affordabl e housing distribution.
We need affordable, ADA compliant, transitional /
halfway / reform housing in every 6 Districts.
This HECU addresses future housing plans but not
address existing housing condition upgrades on
existing units. Do residents in lower condition housing get a priority on new affordable housing units?
Part of the probl em with many people is seeing older
affordable housing units decaying or not kept up.
The plan in itself is decent. This document is way too big for the average public reader to comment. All previous
meetings to be referenced through a link.
An abstract should be present in this document to gu ide the reader.
It would be appropriate to show what was present prior to an affordable housing development. Especially on a blight or outdated building being redevelop into a new housing unit.
Since once the plan is approved to the the 8 years, I would highly suggest that the City Staff ret
ain a few Committee
members (Voluntarily) to continue to get updates and
changes beyond this plan.
Very good work by the City Staff. I do
appreciate everyone's professionalism.
I am a resident
It seems that the data from the 5th
Cycle indicates that there was a plan
and no efforts to ensure th e plan was
on course to meet the intended housing
goals. From the previous 5th cycle
results, there needs to be a better plan
for quarterly communications to
everyone and a plan course correction.
A continued population growth seems
unrealistic; sooner of later the rate of
the increase will slow as th e entire city
will be saturated.
I understand this is about housing but
planning an increase in low income and
Poverty status and Homelessness is ok
but more efforts should be made to
ensure a reduction in those areas with
assistance.
If any affordable housing is developed and the area
that is al ready impacted with parking, the surrounding areas should have permit parking for the
neighborhood residents for X years paid by the City.
The housing plan indicates the housing goals and the
potential locations. Once this plan is approved, there are no additional or deletions of any locations of the for ne xt 8 years. How would this plan address emerging available
properties or properties that are no longer under
consideration?
C‐1
It was great that the City Staff
captured the public comments exactly
as stated.
Still a very noticeable lack of public
participation.
We all need to figure out a good
communications pl an for all City
meetings. Unfortunately this HEUC
effort faces the same issues as other
departments with a lack of public
participation.
But overall, this HEUC City Staff did an
outstanding job.
Thank You!!
DRAFT
1.What is your
association to
the City of
Anaheim?
Please submit comments on Section
1 (Introduction) here.
Please submit comments on Section 2
(Community Profile) here.
Please submit comments on Section 3 (Constraints,
Resources, and Fair Housing) here.
Please submit comments on Section 4 (Housing Plan)
here.
Please submit comments on the
Appendices here.
Ple
ase submit any additional
comments you would like to send to
the project team here.
resident and
student
I appreciate the inclusion of all the
Elements of the General Plan for the
city because it gave me a better sense
of the City's values. It states later that
the RHNA proposed a total of 17,453
housing units; Almost 50% of those
units have been designated to be of use
for abov
e‐moderate income housing at
market value. Based on the income
ranges of Anaheim's population in
Section 2, I suggest a reconsideration of
the housing units committed to very
low‐income and low‐income housing
and inclusion of a physical map of
where these proposed sites will be wi th
the income value labeled as well in
appendices.
The census data was well presented, but
the community demographics compiled
in section 2 should be provided with
some context on a map to see the areas
that have lower and higher‐income
ranges. It would also be effective to see
th
e areas that have households with
housing issues between renters and
homeowners on a map to give the
council a better notion of the areas that
need improvement in their housing
since conservation and preservation is a
core policy strategy area. Incorporating
the special needs populations into
housing was also hi ghlighted, but there
were no specifically proposed housing
opportunities that would be offered;
rather they are considered.
Most of the section felt like it was an explanation of
definitions and policy constraints that would be
difficult to understand without prior knowledge of
housing policy. It should also be highlighted that
throughout th e discussion on the variety of housing
types allowed there was not a proposal, assessment,
or explanation on how many housing units should be
provided by each and for which demographics. It is
especially concerning, personally, that there are no
proposed plans for houseless populations throughout
the housing element but is m entioned as a population
of concern. Based on the maps provided that
distinguish ethnicity and income range populations
with the proposed sites labeled, it's evident there are concentrated areas for low and moderate‐income
housing. Is this in alignment with the Fair Housing Act? Are there other factors at play, suc h as constraints and resources being evaluated, when proposing these
concentrated areas?
The Housing policy considerations are well‐intended, but broad language used in policy allows free room for
accountability not to be taken. Although there are many factors being considered in the policy, there is no
accountability or security in th e descriptions to ensure that it will be advised before the council. A proposal of an inclusionary housing ordinance could incentivize the
council and contractors to reconsider the allocation of housing units, similar to the City of Santa Ana's Housing Opportunity Ordinance. As well as incentivizing existing programs, such as Se ction 8 voucher programs, so that waiting lists for housing and financing is addressed. It was mentioned very briefly that previous Housing cycles that did not fulfill the units proposed by the RHNA could be used under certain conditions it met for lower‐income
housing. Do the previous cycle RHNA housing uni ts add onto the new RHNA units proposed? How are they
accounted for? The quantified objective of the housing
units at the end is helpful, but a breakdown of where the number of units are coming from should be included when explaining the policy strategy to ensure accountability.
Based on th e maps provided, many
sites are designated as needing an
amendment to the General Plan to
permit residential use. Will these
amendments be in place or decided
by the council? Are these sites
guaranteed an amendment to the
General Plan or is it dependent on the
council to approve?
I would lik e to thank you for the work
putting this together because it is not
easy. It is also great to see the input of
the community be considered; it makes
us feel heard.
I am a
community
organizer
In the this document you state that
about 56% of the population is in th e
low, very & extremely low income. Yet
you are planning on only allocating
about 10% of each of the respective
categories and more than half of the
proposed projects are going to be for
market price.Seeing that a grand
majority of the Anaheim residents are
working minimum wage pay ing jobs,
there needs to be in my opinion a bigger
percentage of Affordable Housing. Not
just 10%.
It was very concerning to see that a
grand majority of the proposed
projects where highly concentrated in
Districts 4 & 5 and there was almost
no plans for there to be projects in
di
strict 6. I definitely think that these
project should be spread out through
out all the districts.
One of the thing that should be
considered is insuring that this
document is accessible in other
languages. Especially since about 54.3%
of the population is Hispanic/Latino.
Also in this process I found it personal ly
difficult to find some of meetings that
where held via Zoom. So I'd hardly say
there was a good community outreach.
DRAFT
1.What is your
association to
the City of
Anaheim?
Please submit comments on Section
1 (Introduction) here.
Please submit comments on Section 2
(Community Profile) here.
Please submit comments on Section 3 (Constraints,
Resources, and Fair Housing) here.
Please submit comments on Section 4 (Housing Plan)
here.
Please submit comments on the
Appendices here.
Ple
ase submit any additional
comments you would like to send to
the project team here.
I am a resident
Anaheim didn't build nearly enough low‐
income and very low‐income housing in
the last RHNA cycle, and there is little in
this report to assure the city's residents
that the city will do a better job during
the new 8‐year cycle. As a member of
the HEUC, i heard far too much
acquiescence to "market forc es" among
the committee's discussions. The
market isn't going to build housing
that's affordable to all city residents.
The city has to do more than just
"suggest" or "encourage" such
developments. We all know that this
report is merely aspirational and does
not guarantee that a single dwelling
unit will get b uilt. Fortunately, the state
now has more tools at its disposal to
ensure Anaheim's housing needs are
actually met. Everyone in Anaheim
should be watching what the city
leaders are doing about housing
throughout this new RHNA cycle and
vote accordingly.
DRAFT
P: (626) 314-3821
F: (626) 389-5414
E: [email protected]
Mitchell M. Tsai
Attorney At Law
139 South Hudson Avenue
Suite 200
Pasadena, California 91101
VIA E-MAIL
May 2, 2023
Christine Nguyen, Senior Planner
Planning and Building Department
200 South Anaheim Boulevard, Suite 162
Anaheim, CA 92805
Em: [email protected]
RE: City of Anaheim’s Housing Element Update
Dear Christine Nguyen,
On behalf of the Southwest Mountain States Regional Council of Carpenters (“Southwest Carpenters” or “SWMSRCC”), my Office is submitting these comments for the City of Anaheim’s (“City”) April 2023 Draft Housing Element (“Project”).
The Southwest Carpenters is a labor union representing over 63,000 union carpenters in 10 states, including California, and has a strong interest in well-ordered land use planning and in addressing the environmental impacts of development projects.
Individual members of the Southwest Carpenters live, work, and recreate in the City and surrounding communities and would be directly affected by the Project’s environmental impacts.
The Southwest Carpenters expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project. Gov. Code, § 65009, subd. (b); Pub. Res. Code, § 21177, subd. (a); see Bakersfield Citizens for Local Control v. Bakersfield (2004) 124 Cal.App.4th 1184, 1199- 1203; see also Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal.App.4th 1109, 1121.
The Southwest Carpenters incorporates by reference all comments raising issues regarding the Environmental Impact Report (EIR) submitted prior to certification of the EIR for the Project. See Citizens for Clean Energy v City of Woodland (2014) 225 DRAFT
City of Anaheim – 2019-2029 Housing Element
May 2, 2023
Cal.App.4th 173, 191 (finding that any party who has objected to the project’s environmental documentation may assert any issue timely raised by other parties).
Moreover, the Southwest Carpenters requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act (CEQA) (Pub. Res. Code, § 21000 et seq.), and the California Planning and Zoning Law (“Planning and Zoning Law”) (Gov. Code, §§ 65000–65010). California Public Resources Code Sections 21092.2, and 21167(f) and California Government Code Section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency’s governing body.
I. THE CITY SHOULD INCORPORATE LANGUAGE THAT
REQUIRE THE USE OF A LOCAL WORKFORCE TO BENEFIT
THE COMMUNITY’S ECONOMIC DEVELOPMENT AND
ENVIRONMENT
The City should incorporate language into the proposed Project requiring residential developments to be built using local workers who have graduated from a Joint Labor- Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a state-approved apprenticeship training program, or who are registered apprentices in a state-approved apprenticeship training program.
Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impact of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction-related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.
DRAFT
City of Anaheim – 2019-2029 Housing Element
May 2, 2023
Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board and the University of California, Berkeley Center for Labor Research and Education concluded:
[L]abor should be considered an investment rather than a cost and investments in growing, diversifying, and upskilling California’s workforce can positively affect returns on climate mitigation efforts. In other words, well-trained workers are key to delivering emissions reductions and moving California closer to its climate targets.1
Furthermore, workforce policies have significant environmental benefits given that they improve an area’s jobs-housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas (GHG) emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District found that that the “[u]se of a local state-certified apprenticeship program” can result in air pollutant reductions. 2 Locating jobs closer to residential areas can have significant environmental benefits.
As the California Planning Roundtable noted in 2008:
People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.
3 Moreover, local hire mandates and skill-training are critical facets of a strategy to reduce vehicle miles traveled (VMT). As planning experts Robert Cervero and
1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan for 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/uploads/2020/09/Putting-California-on-the-High-Road.pdf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 – Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.aqmd.gov/docs/default- source/Agendas/Governing-Board/2021/2021-May7-027.pdf?sfvrsn=10. 3 California Planning Roundtable (2008) Deconstructing Jobs-Housing Balance at p. 6, available at https://cproundtable.org/static/media/uploads/publications/cpr-jobs- housing.pdf
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City of Anaheim – 2019-2029 Housing Element
May 2, 2023
Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must match those held by local residents.4 Some municipalities have even tied local hire and other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:
In nearly built -out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city’s First Source program encourages businesses to hire local residents, especially for entry- and intermediate-level jobs, and sponsors vocational training to ensure residents are employment -ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.
Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (“AB2011”). AB2011 amended the Planning and Zoning Law to allow ministerial, by-right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.
The City should consider utilizing local workforce policies and requirements to benefit the local area economically and to mitigate greenhouse gas, improve air quality, and reduce transportation impacts.
II. THE CITY SHOULD INCORPORATE LANGUAGE IMPOSING
TRAINING REQUIREMENTS FOR CONSTRUCTION ACTIVITIES
TO PREVENT COMMUNITY SPREAD OF COVID-19 AND OTHER
INFECTIOUS DISEASES INTO THE PROJECT.
Construction work has been defined as a Lower to High-risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several
4 Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs- Housing Balance or Retail-Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.pdf.
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City of Anaheim – 2019-2029 Housing Element
May 2, 2023
construction sites have been identified as sources of community spread of COVID-
19.5 Southwest Carpenters recommend that the City adopt additional requirements to mitigate public health risks from various residential development construction activities. Southwest Carpenters requests that the City require safe on-site construction work practices as well as training and certification for any construction workers on residential developments.
In particular, based upon Southwest Carpenters’ experience with safe construction site work practices, Southwest Carpenters recommends that the City require that while construction activities are being conducted at residential development sites (“Project Site”):
Construction Site Design:
• The Project Site will be limited to two controlled entry points.
• Entry points will have temperature screening technicians taking temperature readings when the entry point is open. • The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics for conducting temperature screening.
• A 48-hour advance notice will be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6 -foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.
• There will be clear signage posted at the project site directing you through temperature screening.
5 Santa Clara County Public Health (June 12, 2020) COVID-19 CASES AT
CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at https://www.sccgov.org/sites/ covid19/Pages/press-release-06-12-2020-cases-at-construction-sites.aspx.
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City of Anaheim – 2019-2029 Housing Element
May 2, 2023
• Provide hand washing stations throughout the construction site.
Testing Procedures:
• The temperature screening being used are non -contact devices.
• Temperature readings will not be recorded.
• Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before
temperature screening.
• Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be
refused access to the Project Site.
• Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ZONE 1] and personnel gate
[ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors.
• If the digital thermometer displays a tem perature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.
• If the second reading confirms an elevated temperature, DHS will instruct the individual that he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/her supervisor and his/her human resources (HR) representative and provide them with a copy of Annex A.
Planning
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City of Anaheim – 2019-2029 Housing Element
May 2, 2023
• Require the development of an Infectious Disease
Preparedness and Response Plan that will include basic
infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no more than 10
people including all- hands meetings and all -hands lunches) communication and training and workplace controls that
meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health
Administration, Cal/OSHA, California Department of
Public Health or applicable local public health agencies. 6 The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The City should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.
Southwest Carpenters has also developed a rigorous Infection Control Risk Assessment (“ICRA”) training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.
7 ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities.
ICRA protocols prevent cross contamination, minimizing the risk of secondary infections in patients at hospital facilities.
6 See also The Center for Construction Research and Training, North America’s Building Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available at https://www.cpwr.com/sites/default/files/NABTU_ CPWR_Standards_COVID-19.pdf; Los Angeles County Department of Public Works (2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at https://dpw.lacounty.gov/building-and-safety/docs/pw_guidelines-construction-sites.pdf. 7 For details concerning Southwest Carpenters’s ICRA training program, see https://icrahealthcare.com/.
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City of Anaheim – 2019-2029 Housing Element
May 2, 2023
The City should require the residential developments related to the Project be built using a workforce trained in ICRA protocols.
Sincerely,
__________
______________
Mitchell M. Tsai
Attorneys for Southwest Regional
Council of Carpenters
Attac
hed:
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); and Air Quality and GHG Expert Matt Hagemann CV (Exhibit C).
Note: Copies of the Exhibits A, B and C listed above can be made available by contacting the City of Anaheim Planning & Building Department or by accessing the City of Anaheim 6th Cycle Housing Element (https://www.anaheim.net/DocumentCenter/View/67118/Final-City-of-Anaheim- HEU-2021-2029_05012025_CLEAN). Contact Christine Nguyen at [email protected] for more information.
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From: Steve
To: Housing Element
Subject: [EXTERNAL] Housing Element
Date: Tuesday, April 25, 2023 1:07:13 PM
Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message.
Sirs:
I believe little or no progress will be made in Anaheim in meeting low or very low RINA targets unless mandatory inclusion is required for all projects.
Steve
Sent from my iPhone
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From:
To: Housing Element
Cc: [email protected]
Subject: [EXTERNAL] Comments on Anaheim"s May 2024 Draft Housing Element Date: Wednesday, May 15, 2024 4:45:06 PM
Attachments: Anaheim Median Income.png
Anaheim Housing Sites Analysis.pdf
You don't often get email from [email protected]. Learn why this is important Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message.
Thank you for this opportunity for the public to review and comment on the May 2024 draft Housing Element, which was released May 9th. Since this was the City's first new draft in over a year, I was hopeful that we'd see a substantial revision to address all of HCD's previous comments, as well as the comments to the previous draft that I provided to Ted White last year while I was a planning commissioner. Unfortunately, many of those comments seem to have gone unaddressed. The primary areas where Anaheim falls short in this most recent draft of the Housing Element fall under three categories: Affirmatively Furthering Fair Housing; Sites Inventory; and Public Participation.
Affirmatively Furthering Fair Housing
The City is not meeting its requirements to Affirmatively Further Fair Housing in this draft of the Housing Element. While the Housing Element identifies significant patterns of income segregation, it does not provide any programs to address those existing patterns of development. Furthermore, the City is using old and outdated information, which further hinders its ability to identify current needs within our neighborhoods.
Figure 3-36 clearly shows a distinct pattern of income segregation between the eastern and western half of the city. This figure uses 2015-2019 ACS data. Updating this data to 2022 ACS data, it shows that the income segregation is even greater than is shown in the Housing Element, with every tract east of SR-55 having a median household income over $100,000/year, and all but nine tracts west of SR-55 having a median household income of less than $100,000/year. I've prepared a map showing this more recent data, which is included below.
In fact, not only does the Housing Element not include any programs to address this pattern of income segregation, the
vast majority of proposed RHNA sites are located in tracts with high percentages of lower- and moderate-income households, as shown in Figure 3-45 of the draft Housing Element.
Furthermore, in Section 2.F.4, Housing Age and Condition, the City is using neighborhood survey data from 2013, more than a decade ago. The Housing Element uses this data to focus on specific neighborhoods that are in need of additional investment, and highlights the investments the City has made in these neighborhoods over the past decade. The City does not identify neighborhoods that have suffered from a lack of investment over the same time
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period. The City must conduct an updated survey of neighborhood characteristics to determine which neighborhoods are in need of additional attention today.
Finally, Section 3 of the draft Housing Element includes a discussion of Anaheim’s homeless population using 2022 Point-in-Time count number. The 2024 Point-in-Time count was released on May 8, 2024, prior to the revised draft of the Anaheim Housing Element being released for public review. The 2024 Point-in-Time count indicates a 32% increase in homelessness in Anaheim compared to the 2022 Point-in-Time count, from 1,074 individuals to 1,417. Anaheim should be using the latest homelessness data to determine their emergency shelter needs. Some of the figures in the draft Housing Element, such as Figure 3-35, use even older data and don't include any data more recent than 2019. This section and all of the figures should be updated to include the most recent Point-in-Time count data.
Sites Inventory
The City of Anaheim has identified a large number of sites that can be used to accommodate its RHNA requirement. However, the majority of these sites are non-vacant, and therefore the City must assume that the existing uses on these sites impede additional residential development, unless the housing element describes findings based on substantial evidence that the use will likely be discontinued during the planning period. I have reviewed the first 50 of the 446 sites identified in Table B-9 of the draft Housing Element. All but 18 of these sites have existing uses but do not include substantial evidence as to why these specific existing uses will discontinue during the planning period. I've attached a spreadsheet with notes regarding my review of these first 50 sites and why the evidence provided is inadequate. I plan to continue reviewing the sites identified in Table B-9, I simply haven't had a chance to finish my review.
In addition, the City provides a table of pipeline projects, Table B-2. This table includes a number of updates from the prior draft from a year ago. However, there are a number of projects where the status of the project has not changed in more than a year. For instance, Site P-21, the LT Platinum Center, was approved back in 2016 and the property has been sold at least once since then. The new owner does not intend to build what was previously entitled on this site, and therefore this is an example of a pipeline project that will not come to fruition.
The City should explain why these projects are not continuing to move through the approval and development process to ensure that they are still viable projects that the City can rely upon to provide future housing units. These types of timing delays provide a significant constraint on the development of new housing.
Furthermore, some of the identified pipeline projects provide either outdated or incorrect information. For example, Site P-70 is identified as providing 600 above moderate income units. However, the developer’s letter of request (available on the City’s website here:
https://www.anaheim.net/DocumentCenter/View/51811/
) indicates that only 270 units are
being proposed.The City must go through each of the pipeline projects to ensure that the number of projected units matches what the developers are currently proposing on these sites.
The City must provide an updated list of sites to accommodate the City's RHNA requirements that include substantial evidence that existing uses will discontinue during the planning period.
Given my review of the first 50 of the sites identified in Table B-9 and the inaccuracies in Table B-2, I doubt that the City has sufficient sites necessary to accommodate its RHNA.
Public Participation
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While I appreciate this opportunity for the public to comment on this draft of the Housing Element, as is required by State law, it appears that the City has not done any other public outreach for the Housing Element over the past year. In fact, the draft Housing Element does not indicate that there has been any public input since October 2021. As HCD said in their June 28, 2023 comment letter to the prior draft of the Housing Element, "During the housing element revision process, the City must continue to engage the community, including organizations that represent lower-income and special needs households, by making information regularly available while considering and incorporating comments where appropriate." The City must do better, at a minimum discussing the revisions to the Housing Element at a public meeting of the City Council and Planning Commission. The City holds regular community meetings in each City Council district. It would be preferable for the City to include discussions of the Housing Element at these meetings throughout the year to ensure continued public participation.
Overall, this draft of the Housing Element falls far short of what is necessary to be compliant with State law. I highly encourage the City to substantially revise this draft prior to submitting it to HCD for their review.
With kindest regards,
Anaheim Resident
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1 June 7, 2024
Mr. Ted White, Director
Planning and Building Department
City of Anaheim
200 S. Anaheim Blvd., Suite 162
Anaheim, CA 92805
RE: City of Anaheim Draft Housing Element May 16, 2024
Mr. White,
Thank you for the opportunity to review and comment on the City of Anaheim’s 2021-2029 draft Housing Element dated May 16, 2024. The Kennedy Commission (the Commission) is a broad- based coalition of residents and community organizations that advocates for the production of homes affordable for families earning less than $30,000 annually in Orange County. Formed in 2001, the Commission has been successful in partnering and working with Orange County jurisdictions to create effective housing and land-use policies that have led to the construction of homes affordable to lower-income working families.
We are writing today to comment on the City of Anaheim’s Housing Element Draft (May 2024) and request that the City strengthen its proposed affordable housing policies, programs and opportunity sites identified for lower income needs in their 6th Cycle Housing Element draft to ensure that the City will effectively produce affordable housing at the acutely low, extremely low, very low-, and low-income level.
This is important, since in the 2014-2021 Housing Element Planning Period the city’s plans and programs failed to facilitate the necessary affordable units to meet the needs of the low and very low income residents in Anaheim. The city’s lack of affordable housing policies and programs led to a robust housing production that greatly exceeded the above moderate-income level of RHNA, but resulted in minimal production of lower income housing that only met a fraction of the city’s lower income housing needs. In addition, the lack of affordable housing policies led to a deficit of affordable housing sites for lower income RHNA in the 5th cycle, since market rate housing was developed on affordable housing opportunity sites.
In the current 6th cycle planning period, the city has a RHNA of 3,767 units for very low income and 2,397 units for lower income households. While the City continues to work on its RHNA goals, it has been prioritizing Above Moderate over Low and Very low families housing needs. The City’s current progress is 1,175 units for above moderate and only 137 deed restricted units for Very Low and 18 deed restricted units for Low (Anaheim 2024 Housing Element Annual Progress Report). The majority of these very low income units are special news housing for those formerly homeless as Permanent Supportive Housing.
www.kennedycommission.org 17701 Cowan Ave., Suite 200 Irvine, CA 92614 949 250 0909
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City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
2 The City of Anaheim’s draft Housing Element provides examples in their Adequate Sites Analysis of residential developments that utilized land recycling to create more housing. However, these examples have resulted exclusively in the development of market-rate housing on these sites. Similar land recycling strategies may not be feasible or effective for affordable housing developments or may need a specific affordable housing policy. In Table B-2, out of the 56 pipeline projects currently in development in Anaheim, only 7 include an affordability component through a Density Bonus Agreement or Affordable Housing Covenant. This limited number of affordable housing projects is inadequate to address the city's severe lack of affordable housing. The majority of these pipeline projects cater to market-rate housing, which does little to meet the urgent demand for affordable housing options among low and very low-income residents in Anaheim.
Lower Income Sites in District 6
The city is identifying multiple opportunity sites in District 6 in industrial areas north of the 91 freeway. These sites are not immediately surrounded by housing and residential amenities. The city does not identify any affordable housing opportunities south of the 91 freeway in the more residential established and higher opportunity area of Anaheim Hills, which includes greater amenities like transportation, markets, and parks and recreations.
Our preliminary review shows that many of the identified sites in the industrial areas have existing thriving uses or potential land use and environmental constraints that may prevent transition to residential or mixed uses.
A more specific analysis is needed to understand how these existing commercial uses will be incentivized to transition to low, very low housing opportunities for the sites listed in the Full Sites Inventory (Table B-9).
Some examples from our preliminary analysis show:
The sites 356, 382, 377, 379, 350, 373, 366, 380, 381, 362, 386, and 383 (Table B-9) that are being proposed as being potential sites to accommodate lower income housing are currently being utilized by an Amazon distribution center. The logistics and parking lots are very active and don’t show to be underutilized. The City needs to provide an analysis to better understand how these sites will transition and what incentives and policies will create affordable housing for lower income.
In addition, the sites 471, 472, 467, 466, 459, 462, 470, 465, 468, 469, 464 show to have active industrial uses, accessory structures for auto storage, and car auction buildings in a commercial area.
No additional information is provided on the desire of owners to transition to housing or programs and incentives that the city is proposing for affordable housing developments.
The two sites, 474 and 473, are listed as vacant sites with potential to accommodate future housing development for low and very low income levels. These sites are clustered together with two other sites, 361 and 372 that the city identified as desirable for housing development, however 361 is occupied as an oil field with oil wells and oil lines and 372 has a property management office on site. No analysis is provided for environmental constraints or clean-up. These 9.47 acres present DRAFT
City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
current challenges, so the city needs to provide more information on these parcels to understand environmental and topography constraints to build affordable housing.
Furthermore, the city also identifies 374, 378, 367, 359, 347, 353, 370, 385, and 352 as potential sites to redevelop to accommodate housing. While these sites are commercial, they are closer to residential activities which increases the potential for affordable housing. Based on visual inspection and aerial views there are thriving commercial uses like McDonald’s, In n Out, and Shell. These sites need a greater analysis of the likelihood of transitioning due to the new chain developments and what incentives will be provided to create affordable housing for lower incomes.
District 6 currently has pipeline projects that are only market rate and above moderate. An example is Project Pipeline P-70 (Table B-2), a 600 unit multiple-family residential development but does not propose any affordable housing units. The analysis on these sites previously mentioned will provide a greater insight into how those sites can be redeveloped or created into affordable housing, identifying potential barriers, exploring financing options, and evaluating the feasibility of incorporating affordable units into existing and new developments. This comprehensive approach will ensure a more inclusive and diverse housing strategy that addresses the needs of all residents in the community.
It is imperative that the sites identified for lower income provide opportunities for development of affordable housing and improve quality of life. The deficit of affordable housing in the city is unfortunate given that Anaheim residents are in urgent need for housing at the lower income levels.
While the City claims that the low-income median household for Anaheim residents is $71,763, many families do not reach this and fall within 57% of low, very low-income households (Table 2- 18). Low-income renters in the city cannot afford the median rents of 1- and 2- bedroom apartments ranging between $2,500-$3,000, respectively. In fact, there are a total of 56,042 renter-occupied households in Anaheim with 31.7% of renter households experiencing a cost burden in paying for their housing (Table 2-18). With the current 155 deed-restricted low- and very low-income affordable housing units available in the city, and the majority of families in Anaheim falling into the extremely low, very low-, and low-income category, the development of affordable housing units does not come close to meeting the needs of Anaheim residents.
The Kennedy Commission Recommendations for Affordable Housing
For the 2021-2029 Anaheim Draft Housing Element (May 2024), the Commission recommends that the City adopt new affordable housing priorities and policies that will help develop affordable housing for the City’s lower income families and create balanced housing opportunities in the city.
The Commission has the following policy recommendations as part of their 6th RHNA cycle:
1. Inclusionary Housing Ordinance - To ensure that housing is being equitable and meets the current and future needs of Anaheim’s residents, The Commission strongly recommend the city adopt an Inclusionary Housing Ordinance that requires 20% of units in all citywide residential project be set aside for extremely low (7.5%), very low (7.5%), and low-income levels (5%).
This ordinance will help the city create a balanced housing development along with market-rate housing that has been successful in cities such as Santa Ana and Irvine. We recommend that the DRAFT
City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
4 Inclusionary Housing Ordinance should be implemented no later than six months from the adoption of the 6th Cycle Housing Element.
2. City-Owned Sites and Housing Authority/Successor Agency Site - The City has committed to rezoning the 14 locally owned sites by December 2025, but has identified 392 residential units consisting of 98 affordable units, 286 moderate income units, and 8 above moderate units. The Commission recommends that sites owned by housing authorities and successor agencies should be exclusively developed for extremely low, very low-, and low- income housing. Moderate and above moderate housing units are appropriately being addressed by pipeline projects and market developers. Not using these 98 sites to maximize affordable units would be a huge missed opportunity and would not assist developments that are 100% affordable, since the cost of land and market rate development is one of the biggest impediments to affordable housing development.
3. Rezone Policy Actions to Accommodate Lower RHNA Capacity (Site Rezoning):
The city should ensure that proper zoning is implemented as well as a program that will encourage the production of affordable housing to meet the needs of lower income residents on identified opportunity sites. The City must rezone identified sites for affordable housing to meet site capacity for low, very low, extremely low, and acutely low-income households immediately. As part of the 6th housing cycle, the City must adopt a by right rezoning program to accommodate lower income needs. The program should include at least 20% of units affordable to low, very-low, extremely low income, and acutely low-income residents. The program should also accommodate a minimum of 16 units per site, a minimum density of 30 units per acre, and meet the lower housing needs amongst opportunities in residential and mixed-use projects. The rezone program needs to apply to all sites identified for rezoning, all sites identified and being reused from the 5th cycle and sites proposed to adopt a new zoning code change to accommodate lower income housing needs.
4. Platinum Triangle Master Land Use Plan (PTMLUP):
City owned sites also must be identified within the Platinum Triangle Master Use plan to prioritize affordable housing developments. Since the creation of the PTMLUP in 2004, the city has approved over 12,642 market rate luxury housing units within the plan and no affordable housing has been created in the Platinum Triangle.
The city needs to prioritize affordable housing policies in developments in the Platinum Triangle and the city-owned land in the Angel stadium to support Housing Production Strategy 1G to ensure significant affordable housing production in this city-owned land, prioritizing affordability at the low, very-low, extremely low, and acutely low-income levels.
5. Residential Opportunities (RO) Overlay Zone - Housing Production Strategy 1J creates the perfect opportunity for the city to create housing units necessary for fulfilling its RHNA goal. With 12,885 units projected to be created, we believe that it is imperative for the city to use the opportunity to create incentives on the RO Zone to create 100% affordable units such as implementing:
a. Density Bonus
b. Fee waivers/reductions
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City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
c. Expedited Review for 100% affordable housing sites on the Residential Overlay Zone.
6. SB 4 Affordable Housing on Religious Land - The Passing of SB 4 in 2023 allows for the planning for the use, lease, or sale of land to support affordable housing. The strategies from this can take on many forms:
a. Identifying suitable sites for affordable housing and making them available at a subsidy to developers and preparing sites for development
b. Implementing a local ordinance that aligns with SB 4 and the Surplus Land Act c. Disposing sites at market price and using the proceeds to support other affordable housing efforts
This approach addresses housing shortages and long term affordability, while also creating partnerships between religious organizations and developers. It is a collaborative effort to meet the city’s needs by creating more affordable housing. With the implementation of SB4, the Commission is open to partnering with the City to provide a list of church sites and religious organizations that have the potential to develop affordable housing.
7. Affordable Housing Development Fee:
The Commission recommends that if the city elects an affordable housing fee program it should consider the following:
- The policy should be part of a comprehensive approach to address the production of affordable housing in sites identified to create affordable housing, such as implementing an Inclusionary Housing requirement as outlined above.
- An in-lieu fee instead of affordable housing should help the city achieve the affordable housing opportunity not realized on the sites. The fee needs to be calculated based on the true cost to develop affordable housing units and other financial and market factors. The affordable housing fee the City is exploring in Program 1A(i) and 1(ii) is not strong enough to produce the amount of affordable housing needed by Anaheim residents. Given the high cost of land, market rate housing competing for the same sites, construction cost, and the land use and zoning limitations on where affordable housing can realistically be developed, funding generated from this fee would likely have limited success.
- The proposed fee does not clearly focus on evaluating and quantifying the lost opportunity to create affordable housing on these opportunity sites and actual cost to develop affordable housing elsewhere.
- The fee should be in the range of $15,000 - $30,000 per unit to allow the city to leverage state, federal and other affordable housing funds and be able to develop 100% affordable housing developments.
- Establish a mechanism for the regular review from community stakeholders and nonprofits of how the funds from the Housing Trust Fund are being utilized and adjustment of the Affordable Housing Development Fee to reflect changes in the housing market and development costs. - Expedite implementation timeline by December 2024 and target the development of housing units for Anaheim’s low and very low income households.
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City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
6 - Following the HR&A recommendations the City should establish a Housing Trust fund to administer it's AH fee and leverage additional federal, state, and local funding for the creation of affordable housing
As analyzed, one of the biggest issues in the lack of production of affordable housing in Anaheim is that market rate housing has been developed on affordable housing opportunity sites leading to a deficit on opportunity sites for affordable housing. This proposed fee will continue to prioritize market rate housing on opportunity sites and not prioritize lower income affordable housing.
An in-lieu fee should be studied and implemented no later than six months from the adoption of the 6th-Cycle Housing Element. We recommend that the fee be utilized specifically for the creation of new affordable housing units for low, very-low, extremely low, and acutely low-income families.
HR&A Recommendations for Affordable Housing
In addition, on February 15, 2024 the city hired a consultant to create an inventory of potential Affordable Housing policies and programs, of those programs, the Commission also recommends that many of the strategies outlined by the consultant be implemented as part of the programs and policies to increase affordable housing.
Our recommendations are reflective of some of the ones included in the HR&A Report: we recommend that the city adopt the HR&A recommendations and strengthen the language in each policy to make them effective for affordable housing for lower income. The list of policies recommended by the consultant to the city council include the following and can be elaborated through here.
1) Workforce Housing Incentive Program - Creates a zoning designation that allows developers the opportunity to build projects under alternative standards in exchange for affordable units in areas close to public transportation and job centers.
The Kennedy Commission Recommendation: Although this program can foster inclusive communities by integrating affordable units within diverse neighborhoods, which can enhance social cohesion and reduce economic segregation. The Commission asks the City to explore the feasibility of this program in creating supporting the economic opportunities it could present to low and very low income households. Therefore, we ask that the city expand the program to include those that fall below 80% AMI. For a program aimed to create housing near public transportation and job centers, Anaheim should take into consideration that 57% of Anaheim’s households are within the low, very low and extremely low income categories. The program should therefore be expanded to include the low, very low, and extremely low income categories in order to adequately give Anaheim’s workforce access to transportation and job opportunities.
2) Incentive Zoning - Policies to require or incentivize developers to include affordable homes as part of market-rate developments in exchange for incentives like density bonus, fee reductions/waivers, or expedited review
The Kennedy Commission Recommendation: Incentive zoning can significantly increase affordable housing availability in high-opportunity areas, offering low to moderate-income families DRAFT
City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
access to better resources and opportunities. However, if not carefully managed, it might lead to increased development costs that could be passed on to market-rate tenants, potentially raising overall housing prices. Therefore, The Commission recommends that the City explore options that incentivizes unit production in an equitable manner such as:
a) Inclusionary Ordinance
b) Density Bonuses
c) Tax abatements and fee reductions
d) CEQA exemptions and expedited reviews
The Commission recommends that the City determines which residential developments would be subject to the policy by prioritizing low and very low income units to increase access to high opportunities areas; especially, for those developments that are currently or beginning construction to expedite the number of units.
3) Office, Hotel, and Retail Conversion - Conversion of office, hotel, or retail spaces to fill underutilized buildings and create much-needed housing opportunities. The process for conversion would be streamlined to approve the appeal of conversion.
The Kennedy Commission Recommendation: Converting underutilized office, hotel, and retail spaces into housing can efficiently address housing shortages and revitalize vacant properties, promoting density. Considering the expansion of Disneyland, it is imperative that Anaheim utilizes as many available land opportunities as possible to adequately address the shortfall of affordable housing.
4) Housing Trust Fund - A source of flexible local grant and loan funding that does not carry federal restrictions and can be used to support affordable housing activities determined by local priorities.
The Kennedy Commission Recommendation: Although the Commission strongly supports the implementation of a Housing Trust Fund, we would recommend the City implement a provision to ensure that the capital from a Housing Trust Fund supports the creation of housing that supports the development of units supporting low, very low, and extremely low income families. We also ask that The City implements a Housing Trust Fund as soon as the Housing Element is certified by the Department of Housing and Community Development. In the wake of the Disneyland Forward decision, we believe that it is necessary to establish a Housing Trust Fund sooner than December 2024 to properly utilize the $30 million affordable housing funds promised by the Walt Disney Company. Finally we ask that the city explore the following options to ensure the Housing Trust Fund has the constant flow of capital that is necessary to adequately fund the production of affordable housing:
a) Sale of Public Assets
b) Private capital donations
c) Local bonds and/or tax measures
d) Using the revenue created through the repayment of the Housing Trust’s low-interest loans to create a cyclical pool of capital for the future development of affordable housing.
DRAFT
City of Anaheim’s Draft Housing Element 5/2024
The Kennedy Commission Comments
June 7, 2024
8 5) Standardized Development Agreements - To streamline the approval process and provide clear guidance to developers, through a standardization of development agreements. This is a helpful measure for developers to have a baseline expectation of the community benefits of affordable housing projects.
The Kennedy Commission Recommendation: The Commission recommends that the City prioritize low and very low households in the community benefits, so that individuals/families receive maximum advantages through the agreement. Furthermore, some of the community benefits that should be included in the development agreement should be:
a) On-site affordable housing
b) In-Lieu fee
c) Open Space
d) Land donation
e) Workforce Investment
6) Land Bank - Property held and run by a local government or nonprofit to acquire, hold, manage, and redevelop property. Land banks typically receive land through tax foreclosure and auction, purchase on the market, or through a transfer from private or municipal owners.
The Kennedy Commission Recommendation: The Commission supports the establishment of a land bank as a means for the City to reserve sites for the creation of multi-family or multi-use housing for residents of all income levels. Should the city accept the recommendation made by HR&A, the governance of the land bank should be through a board made up of city appointed community members, affordable and market rate developers, and nonprofit organizations. 7) Housing Dashboard - The final recommendation from HR&A is for the city to establish a platform to provide up-to-date housing metrics and analysis, so The City could have a way to communicate progress in achieving affordable housing goals.
The Kennedy Commission Recommendation: The Commission supports the creation of a Housing Dashboard. Anaheim has a massive need for affordable housing and providing community members and stakeholders an up-to-date platform of housing metrics and analysis, providing a way for local governments to communicate progress in achieving affordable housing goals.
We look forward to working with the City of Anaheim to encourage effective housing policies that will help create balanced housing development and create much-needed affordable housing in our local communities. If you have any questions, please feel free to contact me at (949) 250-0909 or [email protected].
Sincerely,
Cesar Covarrubias
Executive Director