Item 299/2026
Final
City of Garden Grove
INTER-DEPARTMENT MEMORANDUM
To:
Lisa L. Kim From: Matt West
Dept:
City Manager Dept: City Manager
Date: 8/11/2026
Subject: Approval to submit a response to the Grand Jury Report, California Housing Mandates The Unintended Reshaping of Orange County Neighborhoods. (Action Item)
OBJECTIVE
The purpose of this report is for the City Council to approve the attached response to the 2025-26 Grand Jury Report, California Housing Mandates, The Unintended Reshaping of Orange County Neighborhoods and authorize submittal to the Orange County Grand Jury.
BACKGROUND
On May 27, 2026 the Orange County Grand Jury released its 2025 -26 Grand Jury Report, California Housing Mandates, The Unintended Reshaping of Orange County Neighborhoods .
The purpose of the report was to evaluate both the intended and unintended consequences of Housing Mandates as they are applied within Orange County in order to identify where state requirements conflict with local capacity and community needs, and assess how recent legislative changes have shifted the balance between state authority and local governance.
The report also seeks to establish a strategic framework for influencing future housing allocations within Southern California Association of Governments ( SCAG) by strengthening the role and effectiveness of Orange County Council of Governments (OCCOG) in preparation for the next planning phase.
DISCUSSION
California’s State Housing Mandates, including Housing Element requirements and the Regional Housing Needs Allocation (RHNA) process , have significantly expanded state oversight of local housing planning in an effort to address housing shortages and affordability challenges. While intended to increase housing production, these mandates are characterized as imposing substantial administ rative, financial, and legal burdens on local governments, particularly in Orange County, where established development patterns, infrastructure limitations, environmental constraints, and high land costs present unique challenges.
Housing allocation targe ts are criticized as being derived from complex and insufficiently transparent methodologies that often fail to adequately account for local conditions, economic Item 299/2026
feasibility, or available funding sources. The elimination of redevelopment agencies further reduced local capacity to finance affordable housing, leaving jurisdictions responsible for meeting ambitious housing obligations without corresponding financial support. At the same time, state housing laws have reduced local discretion over land -use decisions, increased residential densities, and limited opportunities for public input, contributing to concerns regarding neighborhood character, infrastructure capacity, and local governance. As Orange County prepares for the next RHNA cycle, the analysis emp hasizes the need for greater transparency, stronger regional advocacy, enhanced public engagement, and housing policies that better align state objectives with local realities, infrastructure investments, and community priorities.
The Grand Jury report outlined 22 findings, 11 of which applied to Garden Grove.
Findings
F1. In recent years, the California Legislature has enacted an unusually large and burdensome volume of housing -related laws intended to strengthen complian ce with State Housing Mandates.
Response: The City of Garden Grove agrees with the above finding.
F2. Housing Mandates are implemented through a RHNA process that often lacks transparency and relies on complex methodologies that are difficult for local officials and the public to understand or meaningfully challenge.
Response: The City of Garden Grove agrees with the above finding.
F4. Meaningful participation by Orange County cities in both OCCOG and SCAG meetings is critical to ensuring that local perspectives are represented during the development and implementation of Housing Mandates policies.
Response: The City of Garden Grove agrees with the above finding.
F5. SCAG’s 6th Cycle RHNA assigned Orange County a questionable total of 183,861 housing units for the 2021-2029 planning period, with higher allocations concentrated in cities with major population and employment centers.
Response: The City of Garden Grove partially agrees with the above finding as SCAG’s methodology, in part, incorporated higher allocations to cities with employment centers, transit accessibility (High Quality Transit Areas), and cities considered high resource areas (non-Disadvantaged Communities - DAC).
F6. RHNA allocations are unrealistic and not attainable within the current planning cycle due to limit ed available land, built -out urban conditions, infrastructure constraints, environmental factors, and public health and safety requirements.
Response: The City of Garden Grove agrees with the above finding.
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F7. Residents in Orange County consistently express a desire for local planning decisions to reflect community priorities, including but not limited to neighborhood character, safety considerations, the environment and open-space preservation.
Response: The City of Garden Grove agrees with the above finding.
F8. California's regulatory construction costs (i.e. permitting fees) present substantial challenges for private housing developers—particularly those delivering affordable units.
Response: The City of Garden Grove partially agrees with the above finding. While city permit fees cover cost of service to developers, California regulatory requirements have added to the construction cost, such as the California Environmental Quality Act (CEQA), building material and energy efficiency requirements, among other state requirements.
F9. The cost of constructing a single affordable housing unit in California typically ranges from approximately $500,000 to $800,000 per unit when fully complying with current state regulations. New low -income housing is generally not financially f easible without public subsidy.
Response: The City of Garden Grove agrees with the above finding.
F10. Prior to their dissolution in 2012, redevelopment agencies served as a primary mechanism for cities and counties to finance affordable housing and related infrastructure.
The loss of redevelopment has reduced cities' ability to support con struction of affordable units.
Response: The City of Garden Grove agrees with the above finding.
F11. Because public subsidy is limited an d highly competitive, cities seeking to produce meaningful quantities of low -income housing must rely in part on private development incentives, often resulting in higher overall development densities and unit c ounts than the RHNA allocation.
Response: The City of Garden Grove partially agrees with the above finding as private develop incentives may result in an exceedance of the RHNA allocation for a specific site, but the city has not experienced an exceedance of its overall RHNA allocation through private developer incentives.
F12. The 6 th Cycle RHNA methodology included numerous technical inputs published by SCAG and HCD; however, these inputs were highly complex and difficult for cities to interpret or independently verify.
Response: The City of Garden Grove agrees with the above finding.
The Grand Jury report also outlined 20 recommendations, eight of which applied to Garden Grove.
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Recommendations
R7. OCCOG, all Orange County cities and the County of Orange should reassess the current dues structure, by September 30, 2026, to ensure that OCCOG has the resources necessary to effectively represent Orange County jurisdictions in SCAG processes, including RHNA methodology development and appeals. (F3, F15)
Response: The recommendation has not been implemented, and will require further analysis.
R8. By December 31, 2026, the Orange County Board of Supervisors should partner with cities to evaluate countywide infrastructure capacity —including water, wastewater, flood control, transportation, and public-safety systems—and develop a coordinated regional plan capable of supporting the level of housing growth required under state law. (F6)
Response: The recommendation has not been implemented, and will require further analysis.
R9. By September 30, 2026, the Orange County Board of Supervisors should strengthen its engagement with OCCOG and increase staff support to develop a shared, countywide database of potential housing sites and key development-feasibility factors. (F15)
Response: The recommendation has not been implemented, and will require further analysis.
R11. The County of Orange and each city should ensure consistent participation in SCAG and OCCOG committees by September 30, 2026, including the Technical Advisory Committee (TAC), to strengthen regional representation during RHNA -methodology development. (F3, F4, F15)
Response: The recommendation has been implemented. The City has assigned a dedicated staff member to regularly attend the OCCOG TAC meetings and participate in the SCAG RHNA Subcommittee meetings, ensuring consistent participation.
R12. The County of Orange and each city should designate a single technical representative, by September 30, 2026, along with an alternate, for all RHNA -related SCAG and OCCOG committees to ensure continuity of participation and eliminate gaps in representation across multiple decision-making bodies. (F4)
Response: The recommendation has been implemented. The City has assigned a dedicated staff member as the single technical representa tive, along with an alternate, for all RHNA - related SCAG and OCCOG committees to ensure continuity of participation and eliminate gaps in representation across multiple decision-making bodies.
R14. By April 30, 2027, the County of Orange and each city should publish annual monitoring dashboards showing (a) entitlement pipeline conditions, (b) realistic site yield, (c) assembled funding sources for affordable units, and (d) conversion rates from planned capacity to issued permits and completed units, ensuring that County and city-determined capacity assumptions remain aligned with actual production. (F13)
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Response: The recommendation has been partially implemented with information av ailable on the city’s webpage.
R15. By September 30, 2026, and ongoing, the County Board of Supervisors and all city councils should make a coordinated and sustained effort to educate their constituents about the RHNA process—its requirements, its impact on local planning and community character, and the role residents can pla y in shaping outcomes. Public education efforts should also include guidance on how community members can effectively engage with the California Legislature and advocate for more realistic, data-driven housing policies. (F1, F7)
Response: The recommendation has been partially implemented with information available on the city’s webpage.
R16. By December 31, 2026, all cities should look to enhance their relationships with not - for-profit affordable housing developers to increase the opportunity to develop more affordable housing. (F8, F10, F12)
Response: The recommendation has been implemented as the city continues to maintain strong partnerships with not -for-profit housing developers and actively engages and collaborates on housing projects to increase production of affordable housing.
FINANCIAL IMPACT
There is no financial impact.
RECOMMENDATION
It is recommended that the City Council:
Approve the attached response and authorize submittal to the Orange County Grand Jury.
By: Shawn Park, Assistant to the City Manager
ATTACHMENT(S)
Letter - Response to the Grand Jury Report, California Housing Mandates The Unintended Reshaping of Orange County Neighborhoods