Orange City Council
February 10, 2023

Apartment building is a podium product
involving a development agreement to
allow a transfer of development rights
from an adjacent City water well site to
exceed the General Plan’s maximum 60
du/acre density. This project was entitled
at 85 dwelling units per acre. Final
certificate of occupancy pending.
702-1078 Town and
Country Road/
04121305
709 (635
Apartments
& 74
Townhomes)
UMU
Low-rise office
park with surface
parking lot
Fairfield Apartments and Tri-Point
Townhomes. Developed at 60 du/ac.

Apartments are developed in two separate
buildings; one with 295 units and the other
with 358 units. Both apartment buildings
wrap multi-level parking structures.

These projects demonstrate that there is a recent history of successfully developing residential units within the Urban Mixed Use within Orange. Three of the five projects shown developed at the maximum density permitted of 60 dwelling units per acre while one developed above that density at 85 du/ac. While these horizontal mixed-use projects were originally proposed at densities lower than permitted, the City averages the density over the entire horizontal mixed use site in order to accommodate the residential infill. Additionally, the City requires access easements for parking and emergency access in perpetuity in order to justify the properties as integrated mixed use sites. Based on the size of the parcel that is created for the residential component of these projects, all mixed-use projects exceed the allowable density. The City does not receive applications to develop at densities below that permitted. The remaining project listed in Table B-2 developed under the maximum density at 44 dwelling units per acre due to retaining 263

Appendix B: Candidate Sites Analysis B-7
2021-2029 Housing Element Update - Draft
existing office uses onsite. A workforce housing study determined that all of the sample projects shown in Table B-2 were affordable at the moderate income level.

Furthermore, only one non-residential project was submitted during the 5th Planning Cycle. This included 60,000 square feet of commercial space, parking, and valet. When compared to the six residential projects listed in Table B-2, the City shows a high likelihood of developing residential uses in the UMU zone.

To accommodate the potential for lower densities due to a mixture of uses onsite, the City has made assumptions based on a reduced 55 dwelling units per acre as described previously in this appendix. This is a conservative estimate as the examples show that most projects developed in the UMU zone do so at or above the maximum density. The Housing Plan section outlines actions the City will take to promote the development of affordable units within the mixed used areas.

Non-Vacant Development Scenarios
The City has confidence that infill housing has great potential to come to fruition on the identified sites due to the fact that they have experienced successful “horizontal” mixed use development on surface parking lots associated with existing office development on Town and Country Road. As indicated previously, hundreds of housing units were developed on Town and Country Road in the span of two city blocks in this manner. The residential projects approved around the Outlets at Orange involved “opportunity sites” that were surface lots and would have accommodated hundreds of units. The sites identified for the 6th Cycle continue to have this potential with the coming together of the right property transaction and stabilization of construction costs. City staff continues to receive inquiries about the development potential of the identified sites, and is also actively making contact and developing an outreach program to encourage infill housing on the subject sites. Furthermore, with significant development and employment planned in the immediate future across the City boundary in Anaheim (OCVibe), we expect this to serve as a catalyst for more residential development in Orange. We have been planning for this type of development since 2010. It has come to fruition in some areas of the City more rapidly than others. Where it has been slower to emerge is where there is interest, but property ownership or lease arrangements that have been slower to reach a point of “readiness”. City staff continues to offer creative zoning code interpretations for site redevelopment that includes housing as property owners and developers come forward with inquiries. As indicated in our previous responses to HCD, here are some specific examples of how we have seen our “opportunity sites” develop and why we know this approach works and is realistic:
 Cameo Apartments: The project involved development of a horizontal mixed-use development project by constructing (1) a new five-story, 262-unit residential apartment building surrounding a six-level parking structure, (2) a new five-level parking structure to serve an existing office building, and (3) related site improvements providing landscaping and resident amenities on a six- acre project site. The apartments and office parking structure infilled surface parking that had served the original office building. In the case of the apartment footprint, if taken as a stand- alone parcel, the apartment density would have exceeded the maximum allowed in the City’s General Plan. Therefore, the city established a practice of averaging the residential density over the overall site (encompassing the office, apartment, and parking structure) to achieve a condition where the residential density was averaged over the entire site to avoid the density conflict. Since 264

Appendix B: Candidate Sites Analysis B-8
2021-2029 Housing Element Update - Draft
its completion, a portion of the units have become income-restricted to moderate income households.

 Eleven10 Apartments: The project involved residential infill on a portion of a 5.75-acre site that was already developed with a 16-story office building constructed in the late 1980’s. The development footprint consisted of 2.76 acres of the site that had been prepared for construction of a second office tower that was never developed. The 260 units of infill apartments was built as a podium type project, with four residential levels of living space situated over a two and one- half level parking structure. As with the Cameo Apartments project, the residential density was averaged over the larger horizontal mixed-use site to achieve a density condition that complied with the General Plan. Otherwise the project density would have exceeded the maximum allowed in the General Plan.

 Fairfield Apartments and Trio Townhomes: The project involved redevelopment of an underutilized office complex with a 727-unit apartment and townhome development (653 apartments and 74 townhomes). The apartment units are configured around multi-level parking structures. This site was originally not contemplated for the scale of development that came forward. The development potential that was realized is a reflection of the job-rich context of the location, being within walking distance of high-rise office development and within a short distance of the Children’s Hospital of Orange County and St. Joseph Medical Center campuses, as well as the Orange County Transportation Authority headquarters.

 Branch West (Garrison) Apartments: This project involved the redevelopment of a light- industrial complex with a 94-unit apartment complex with podium parking. Due to the fact that the density proposed by the applicant exceeds the allowable density under the General Plan, the application includes a development agreement involving the transfer of development rights for 28 of the 94 units from a portion of the adjacent City water well property to the subject site. In exchange for this development rights transfer the applicant provided public benefits in the form of traffic signal, sidewalk, and streetscape improvements in the immediate project vicinity. Since the project’s completion, it a portion of the units have become income restricted for moderate income households.

These examples demonstrate that City’s experience in developing UMU zoned sites that were previously parking lots as well as existing commercial and office developments. These are all in close proximity to the majority of the candidate housing sites and share common characteristics. Combined with developer interest in the identified parcels, the City anticipates significant growth in housing opportunity at all income levels on the identified candidate housing sites within the housing element inventory. For further analysis, see the individual projects notes within Table B-3.

Development of Large Site Parcels
Supplemental to the sites identified to meet the City’s lower income RHNA allocation which fall within AB 1397 criteria, the City has identified two parcels which are larger than 10 acres. 265

Appendix B: Candidate Sites Analysis B-9
2021-2029 Housing Element Update - Draft
Parcel 23113140 (1 City Blvd. West) is located adjacent to the Outlets property and has an existing DA agreement which is set to expire in 2021. The City has previously processed a mixed-use application on this site with a proposed 300+ residential units; the application is currently on hold. The City assumes that a net acreage of approximately 9.95 acres of this property will redevelop and that some portion of the existing development may remain for existing or non-residential uses.

Parcel 37530116 (1547 W Katella Ave.) includes an existing shopping center with a movie theatre, restaurants, and smaller commercial shops. The majority of the center is made up of surface parking that goes unused as the surrounding uses contain dedicated parking. The Housing Element proposes to maintain the existing uses and incorporate residential units in a mixed-use fashion in the existing parking lot area only.

The City has recently approved two projects with income-restricted units on lots greater than 10 acres.

These include:
 Terrace Apartments Expansion – 167 units on 16.9 acres  Fairfield – 727 units on 12.13 acres
The City has approved 4 addition project with income-restricted units on 1.1 to 8.94 acres lots and 4 affordable housing projects on 0.5 to 3.54 acre lots.

Lease Analysis
Existing lease agreements on infill and non-vacant properties present a potential impediment that may prevent residential development within the planning period. State law requires the City to consider lease terms in evaluating the use of non-vacant sites, however the City does not have access to private lease agreements or other contractual agreements amongst parties because they are private documents.

Therefore, the City has conducted an analysis to identify sites that show characteristics indicating they are likely to redevelop within the planning period, including past performance, an on-the ground existing use analysis and a market analysis to understand cost of land, construction, and development trends in Orange.

Existing Uses on Candidate Sites and Redevelopment Opportunity The City has identified and analyzed existing use on candidate sites in Table B-3 below. As the City is a built-out community, consisting mainly of commercial retail, industrial and single-family housing, a primary goal was to identify sites compatible for the development of multifamily and mixed-use housing as well as to not displace existing residents. Therefore, the City identified the best possible sites with the most feasible opportunity for redevelopment over the next eight years. In addition to the analysis in Table B-3 the City utilized locally available SCAG data to identify the following key indicators that the sites included for low and very low-income opportunity are the most appropriate:
 On average, there are 106 healthcare facilities within a one-mile drive from each of the identified sites
 On average, there are .5 to 1 grocery stores or markets within a one-mile drive from each of the identified sites
 On average, there are 13 open space areas within a one-mile drive from each os the identified sites
266

Appendix B: Candidate Sites Analysis B-10
2021-2029 Housing Element Update - Draft
 98 percent of the sites identified are within a High-Quality Transit area, meaning the 98 percent of sites are within one half-mile of a well-serviced transit stop or a transit corridor with 15-minute or less service frequency during peak commute hours.

Housing Market Analysis
In addition to an on-the-ground existing use analysis, the City of Orange has market conditions to facilitate the redevelopment of non-vacant sites for residential. Table B-2 above shows that a total of 1,659 dwelling units have been constructed through redevelopment in the City. Additionally, a California Association of Realtors report for Historic Housing trends shows that the average time a unit spends on the market in Orange County is just 18.6 days in the last four years (2017-2021) and just 13.3 days in the last two years.1 Specifically in Orange, homes spent about 50 days on the market and the sale-to-list price ratio was 100.27%, indicating a sellers’ market and the need for more housing.2 According to the New Homes Directory (online resource), Historical Housing Market Data, the average price for an attached unit, 1,500 to 2,000 square feet or less, increased by 52 percent over the last planning cycle ($456,127 in 2014 to $695,110 in 2021).3 The price for a detached unit increase by 59 percent during this same period from $584,390 in 2014 to $930,307 in 2021.4 Additionally, the according to the CAR Current Sales and Price Statistical Survey, the median cost of a home for sale in Orange County increased by 20 percent from 2020-2021 (from $930,000 in October 2020 to $1,120,000 in October 2021).5 The indicators above signify an increased market demand for new housing.

Infrastructure Availability
As discussed in Section 3, each site has been evaluated to ensure there is adequate access to water and sewer connections. Each site is situated adjacent to a public street that has the appropriate water and sewer mains and other infrastructure to service the candidate site.

1 Median time on Market of Existing Detached Homes, Historical Data, California Association of Realtors (CAR), Accessed online:

December 15, 2021. https://www.car.org/marketdata/data
2 Realtor.com, Housing Market Summary, Orange. Accessed Online: December 15, 2021. https://www.realtor.com/realestateandhomes-search/Orange_CA/overview 3 New Homes Directory.com, Historical Housing Report in Orange, Accessed Online: December 15, 2021. https://www.newhomesdirectory.com/California/Orange/historical-housing-report 4 IBID.
5 Current Sales and Price Statistics, California Association of Realtors (CAR), Accessed online: December 15, 2021. https://www.car.org/marketdata/data
267

Appendix B: Candidate Sites Analysis 3-11
2021-2029 Housing Element Update - Draft
Figure B-1: Map of Identified Sites (All Income Levels) 268

Appendix B: Candidate Sites Analysis 3- 12
2021-2029 Housing Element Update - Draft
C. Moderate and Above Moderate Sites Inventory
This section contains a description and listing of the candidate sites identified to meet the City of Orange’s moderate and above moderate income RHNA need.

Calculation of Unit Capacity
The capacity for sites identified to meet the City’s moderate and above moderate RHNA need was determined by multiplying the net parcel size by the reasonably achievable density (consistent with the assumptions within the City’s adopted Land Use Element) for that zoning designation and rounding down to the nearest whole dwelling unit. In taking this approach, the City is using a conservative methodology.

In many instances, future development may occur at a density greater than assumed within this analysis, up to the maximum density allowed by the individual zone. Where information is known, acreage has been netted out for potential constraints to development.

Selection of Sites
This appendix contains a selection of those sites that are most likely to be developed for moderate and above-moderate income housing. For the purpose of identifying sites with the potential to be redeveloped within the planning period, this analysis considered existing zoned parcels that permit residential as a standalone use within the following zones based on reasonable assumptions for densities within those zones, consistent with the City’s Land Use Element:
 Moderate:
o UMU, Urban Mixed Use
o NMU-24, Neighborhood Mixed Use District – 24 du/ac
 Above Moderate
o UMU, Urban Mixed Use
The City understands that multi-family projects often develop at above moderate or moderate levels with an affordable component. Some of the sites identified below were also identified to meet the City’s lower income RHNA needs. The City calculated a maximum achievable density based on reasonable assumptions of density and then determined the affordable component as described in Section B of this appendix. Units were not double-counted and the sum of the affordable and market-rate units does not exceed the maximum number of units permitted for any candidate site.

For the purposes of this analysis, accessory dwelling unit potential was calculated separately as outlined within the Candidate Sites Analysis Overview section above. ADUs represent additional potential units to meet the City’s RHNA.

269

Appendix B: Candidate Sites Analysis 3-13 2021-2029 Housing Element Update - Draft
Table B-3: Sites to Accommodate the RHNA
APN Area
(Ac) Zoning GPLU Expected
Density Address Ownership 5th
Cycle Net Units Affordable
Units
Market
Rate
Units
Very
Low
Units
Low
Units
Moderate
Units
Above
Moderate
Units
Existing Uses and Redevelopment Analysis
Existing
Building
SF
Max
Building
SF
Percent
Utilized
37530116 9.95 UMU UMIX 55
1547 W

KATELLA AVE

STADIUM

PROMENADE LLC

BRECKENRIDGE
GROUP INC 547 136 411 92 43
Existing shopping center with movie theater
and small out parcel uses, including restaurants
and small commercial shops. The vast majority
of the site is surface parking that goes unused
as the surrounding uses contain dedicated
parking. The Housing Element analyzes the
potential redevelopment of the area while
maintaining the existing uses or incorporating
them in a mixed-use fashion and only considers
the existing parking lot area. 136,005 1,300,266 10%
23113140 9.95 UMU UMIX 55
1 CITY BLVD
WEST

WALTON/GREENLAW

CITY PLAZA
HOLDINGS VI LLC 547 136 411 92 43 412
Existing 19-story office building with large older
surface parking lot. Located directly adjacent
to Outlets property. Existing DA expires this
year and City has previously processed an
application for mixed-use development on this
site, including residential units. That
application is currently on hold. The City
assumes that a net acreage of approximately

9.95 acres of this property will redevelop. 19,710 1,300,266 2% 37531125 9.56 UMU UMIX 55
1701 W

KATELLA AVE

STADIUM

PROMENADE LLC

BRECKENRIDGE
GROUP INC 526 131 395 89 42 See explanation for Parcel 37530116. 136,005 1,249,875 11%

09314149 9.17 R-1-7 PFI 6
515 N Rancho
Santiago Blvd

SCHOOL ORANGE
UNIFIED DIST 55 0 55 9 4 55
Largely vacant lot with some agricultural uses
and one small structure. #N/A 1,198,336 #N/A
37537105 8.32 UMU UMIX 55
1600 W STRUCK
AVE

ORANGELAND

RECREATION
VEHICLE PARK 457 114 343 77 36
Existing RV parking lot. City has recently
rezoned the W Katella Ave corridor as it has
been identified as a large opportunity area for
mixed-use development, including multi-family
residential. 48,902 1,087,854 4%
37501119 7.61 UMU UMIX 55
1350 W
KATELLA AVE WILSON DAVID W TR 418 104 314 71 33
Existing car dealership on large parcel. Parcel is
primarily surface parking and display area. City
has recently rezoned the W Katella Ave
corridor as it has been identified as a large
opportunity area for mixed-use development,
including multi-family residential. 83,558 994,702 8% 270

Appendix B: Candidate Sites Analysis 3-14 2021-2029 Housing Element Update - Draft
Table B-3: Sites to Accommodate the RHNA
APN Area
(Ac) Zoning GPLU Expected
Density Address Ownership 5th
Cycle Net Units Affordable
Units
Market
Rate
Units
Very
Low
Units
Low
Units
Moderate
Units
Above
Moderate
Units
Existing Uses and Redevelopment Analysis
Existing
Building
SF
Max
Building
SF
Percent
Utilized
23106152 5.91 UMU UMIX 55 LEWIS ST

REGENTS OF THE

UNIVERSITY OF
CALIFORNIA Yes 324 81 243 55 25 244
Existing UCI MDA ALS Clinic with very large
surface parking lot. Development potential
considers the potential for existing use to
remain and residential added in a mixed-use
fashion. 20,044 772,135 3%
39062104 5.78 UMU UMIX 55 763 S MAIN ST

TOWN & COUNTRY
SPE Yes 317 79 238 53 25 239
Commercial shopping center with large big box
stores and large surface parking lot. Pier 1
Imports building and one smaller tenant
currently vacant. Directly adjacent to new
multi-family residential development and
across from the MainPlace mall (Santa Ana)
analyzed in the Housing Element. 66,917 755,281 9%
23113132 5.10 UMU UMIX 55 LEWIS ST

ORANGE CITY MILLS

III LIMITED
PARTNERSHIP Yes 280 70 210 47 22 211 See explanation for Parcel 23107129. 0 666,158 0% 09351127 4.40 R-1-7 PFI 6
4100 E

WALNUT AVE

CUMMINS KENNETH

J TR GLORY B

LUDWICK REVOC
LIVING TR 26 0 26 4 2 26
Single-story charter school with large open
space area. 47,964 574,992 8%
23126207 4.33 UMU UMIX 55
625 THE CITY
DR S

THE REALTY

ASSOCIATES FUND XI
PORTFOLIO L P Yes 238 59 179 40 19 179
Existing older 4-story office building with ample
surface parking. Large site with potential for
joined redevelopment with adjacent parcels
and accessibility to walking/biking trails. 37,089 566,362 7% 13747134 3.99 UMU UMIX 55 LEWIS ST

CITY TOWN CENTER L
P 219 54 165 37 17 165
Best Buy big box store and surrounding
parking. Adjacent to multi-family residential
across the street and has the potential to
redevelop due to market trends away from
large retail big box stores. Similar parcels in
the area such as the ones analyzed have
redeveloped for higher density residential uses. 45,438 521,520 9% 23108156 3.98 UMU UMIX 55
3901 W

METROPOLITAN
DR

ORANGE CITY MILLS
LTD PTNSHP 219 54 165 37 17 165 See explanation for Parcel 23107129. 32,385 520,715 6% 23126208 3.53 UMU UMIX 55
765 THE CITY
DR S AG CITY OWNER L P Yes 194 48 146 32 15 147
Existing older 4-story office building with ample
surface parking. Large site with potential for
joined redevelopment with adjacent parcels
and accessibility to walking/biking trails. 23,681 461,245 5% 37536102 3.51 UMU UMIX 55
1900 W
KATELLA AVE COUNTY OF ORANGE 193 48 145 32 15
Existing County of Orange training bureau and
surface parking lot. City has recently rezoned
the W Katella Ave corridor as it has been
identified as a large opportunity area for 55,479 458,950 12% 271

Appendix B: Candidate Sites Analysis 3-15 2021-2029 Housing Element Update - Draft
Table B-3: Sites to Accommodate the RHNA
APN Area
(Ac) Zoning GPLU Expected
Density Address Ownership 5th
Cycle Net Units Affordable
Units
Market
Rate
Units
Very
Low
Units
Low
Units
Moderate
Units
Above
Moderate
Units
Existing Uses and Redevelopment Analysis
Existing
Building
SF
Max
Building
SF
Percent
Utilized
mixed-use development, including multi-family
residential.
23107154 2.67 UMU UMIX 55
3400

METROPOLITAN

ORANGE CITY MILLS

II LIMITED
PARTNERSHIP 146 36 110 24 11 See explanation for Parcel 23107129. 0 348,939 0% 23107131 2.40 UMU UMIX 55 THE CITY DR S

ORANGE CITY MILLS
LTD PARTNERSHIP Yes 132 33 99 22 10 See explanation for Parcel 23107129. 11,775 314,243 4% 23107153 2.08 UMU UMIX 55
W

METROPOLITAN
DR

ORANGE CITY MILLS
LTD PARTNERSHIP 114 28 86 19 9 See explanation for Parcel 23107129. 0 272,454 0% 39027412 1.90
NMU-
24 NMIX24 16.3 310 S MAIN ST

MAIN STREET
PROPERTIES 30 0 30 5 2 30
Small older commercial shopping center with
potential to redevelop for mixed-use. 31,163 247,944 13% 23107126 1.84 UMU UMIX 55 THE CITY DR S

ORANGE CITY MILLS
LTD PARTNERSHIP Yes 101 25 76 17 8
Surface parking lot/outparcel for the Outlets at
Orange shopping center. The Housing Element
analysis looks at a potential redevelopment of
a portion of the Outlets to include residential
uses and structured parking. The analysis
assumes that the existing mall core building
remains intact and looks at multiple examples
of nearby mall redevelopment plans. There are
currently no public planning efforts to
redevelop the mall though the zoning would
permit it and the large surface parking lots
provide ample opportunity without impacting
the City's tax base and existing uses on-site. 0 240,394 0% 23107133 1.69 UMU UMIX 55 THE CITY DR S

ORANGE CITY MILLS
LTD PARTNERSHIP Yes 92 23 69 15 7 See explanation for Parcel 23107129. 10,152 220,770 5% 13747143 1.68 UMU UMIX 55
3737 W
CHAPMAN AVE F H A LP 92 23 69 15 7 70
Existing ALO hotel and one-story restaurant
with surrounding surface parking lot. Potential
to redevelop either restaurant portion or entire
site. 20,437 219,895 9%
23106146 1.66 UMU UMIX 55 4125 LEWIS ST

WALWORTH
RICHARD R TR Yes 91 22 69 15 7 69
Several single-family residences on a single lot
with storage and large surface parkign areas.

Existing units have been accounted for and
property is directly adjacent to newer multi-
family residential uses. 12,765 216,830 6%
272

Appendix B: Candidate Sites Analysis 3-16 2021-2029 Housing Element Update - Draft
Table B-3: Sites to Accommodate the RHNA
APN Area
(Ac) Zoning GPLU Expected
Density Address Ownership 5th
Cycle Net Units Affordable
Units
Market
Rate
Units
Very
Low
Units
Low
Units
Moderate
Units
Above
Moderate
Units
Existing Uses and Redevelopment Analysis
Existing
Building
SF
Max
Building
SF
Percent
Utilized
23107143 1.44 UMU UMIX 55
450 THE CITY
DR S

SCHIFFMAN TODD I

TR CARL KARCHER
ENTERPRISES INC 79 19 60 13 6 See explanation for Parcel 23107129. 5,803 188,046 3% 23107140 1.39 UMU UMIX 55 THE CITY DR S

ORANGE CITY MILLS
LTD PARTNERSHIP 76 19 57 12 6 58 See explanation for Parcel 23107129. 0 181,362 0% 23106153 1.30 UMU UMIX 55
4050 W

CHAPMAN AVE

BARD ASSOCIATES
CO Yes 71 17 54 12 5 54
Older restaurant building (Lucille's BBQ) with a
large surface parking lot. Potential to
redevelop for mixed-use and retain capacity for
the existing use and additional commercial. 7,153 169,279 4% 23107147 1.29 UMU UMIX 55 THE CITY DR S

ORANGE CITY MILLS
LTD PARTNERSHIP 70 17 53 11 5 54 See explanation for Parcel 23107129. 0 168,604 0% 39062103 1.27 UMU UMIX 55 745 S MAIN ST

ORANGE TOWN &
COUNTRY #3 LLC Yes 69 17 52 11 5 53
Commercial shopping center with multiple
tenants and large surface parking lot. Directly
adjacent to new multi-family residential
development and across from the MainPlace
mall (Santa Ana) analyzed in the Housing
Element. 16,221 165,630 10%
39062105 1.25 UMU UMIX 55 791 S MAIN ST

WANG CHARLES S C
TR WANG FAMILY TR Yes 68 17 51 11 5 52 See explanation for Parcel 39062104. 19,249 162,997 12% 23107132 1.19 UMU UMIX 55
330 S THE CITY
DR

ORANGE CITY MILLS
LTD PARTNERSHIP Yes 65 16 49 11 5 See explanation for Parcel 23107129. 4,616 155,612 3% 37537110 1.16 UMU UMIX 55
1748 W

KATELLA AVE

ORANGE KATELLA
LLC 63 15 48 10 5
Existing standalone surface parking lot. City
has recently rezoned the W Katella Ave
corridor as it has been identified as a large
opportunity area for mixed-use development,
including multi-family residential. 0 152,032 0%
23109201 1.15 UMU UMIX 55 THE CITY DR S

THE REALTY

ASSOCIATES FUND XI
PORTFOLIO L P Yes 63 15 48 10 5 48
Surface parking lot adjacent to older multi-
tenant office building. Large site with potential
for joined redevelopment with adjacent parcels
and accessibility to walking/biking trails. 0 150,094 0% 39028537 1.13
NMU-
24 NMIX24 16.3 480 S MAIN ST MP-LAVETA LLC Yes 18 0 18 3 1 18 Small older commercial shopping center with
potential to redevelop for mixed-use. 17,089 148,098 12% 37537402 0.98 UMU UMIX 55
1095 N MAIN
ST
HARVARD 826
PROPERTY LLC 53 13 40 9 4
Older 2-story commercial office building
currently signed available for sale. 15,307 128,241 12% 273

Appendix B: Candidate Sites Analysis 3-17 2021-2029 Housing Element Update - Draft
Table B-3: Sites to Accommodate the RHNA
APN Area
(Ac) Zoning GPLU Expected
Density Address Ownership 5th
Cycle Net Units Affordable
Units
Market
Rate
Units
Very
Low
Units
Low
Units
Moderate
Units
Above
Moderate
Units
Existing Uses and Redevelopment Analysis
Existing
Building
SF
Max
Building
SF
Percent
Utilized
23113133 0.91 UMU UMIX 55 LEWIS ST

ORANGE CITY MILLS

III LIMITED
PARTNERSHIP 50 12 38 8 4 38 See explanation for Parcel 23107129. 0 119,533 0% 39028534 0.83
NMU-
24 NMIX24 16.3 424 S MAIN ST MP-LAVETA LLC Yes 13 0 13 2 1 13 Small older commercial shopping center with
potential to redevelop for mixed-use. 19,731 109,044 18% 37537403 0.82 UMU UMIX 55
1085 N MAIN
ST
HARVARD 826
PROPERTY LLC 45 11 34 7 3
Older 2-story commercial office building.

Common ownership and could be redeveloped
in conjunction with Parcel 37537402 or
independently. 13,014 106,990 12%
13747132 0.76 UMU UMIX 55
3743 W

CHAPMAN AVE

CITY TOWN CENTER L
P Yes 41 10 31 6 3 32
Existing commercial shopping center and
surface parking lot containing a bank,
Starbucks, and Quiznos Subs. Opportunity to
develop in a mixed-use fashion similar to
adjacent parcel which contains hotel and
restaurant uses. 9,974 98,958 10%
39028532 0.68
NMU-
24 NMIX24 16.3 402 S MAIN ST MP-LAVETA LLC Yes 11 0 11 1 0 11 Small older commercial shopping center with
potential to redevelop for mixed-use. 3,909 89,513 4%
39028536 0.60
NMU-
24 NMIX24 16.3 MAIN ST MP-LAVETA LLC Yes 9 0 9 1 0 9
Small older commercial shopping center with
potential to redevelop for mixed-use. 17,089 77,922 22% 39028535 0.57
NMU-
24 NMIX24 16.3 468 S MAIN ST MP-LAVETA LLC Yes 9 0 9 1 0 9 Small older commercial shopping center with
potential to redevelop for mixed-use. 2,472 74,913 3%
39027411 0.57
NMU-
24 NMIX24 16.3 356 S MAIN ST WONG WAI PING INC Yes 9 0 9 1 0 9 Small older commercial shopping center with
potential to redevelop for mixed-use. 8,589 74,761 11% 13747133 0.57 UMU UMIX 55
3739 W

CHAPMAN AVE

CITY TOWN CENTER L

P WENDYS
INTERNATIONAL INC Yes 31 7 24 5 2 24
Existing Wendy's restaurant and surface
parking lot. Opportunity to develop in a mixed-
use fashion similar to adjacent parcel which
contains hotel and restaurant uses. May also
be developed with 13747132 due to common
ownership. 3,964 74,730 5%
39027410 0.57
NMU-
24 NMIX24 16.3 370 S MAIN ST HOU MARVIN L S Yes 9 0 9 1 0 9 Small older commercial shopping center with
potential to redevelop for mixed-use. 6,444 74,572 9%
23107129 0.51 UMU UMIX 55 THE CITY DR S

ORANGE CITY MILLS
LTD PARTNERSHIP Yes 28 7 21 4 2 See explanation for Parcel 23107129. 0 66,759 0% 274

Appendix B: Candidate Sites Analysis 3-18 2021-2029 Housing Element Update - Draft
Table B-3: Sites to Accommodate the RHNA
APN Area
(Ac) Zoning GPLU Expected
Density Address Ownership 5th
Cycle Net Units Affordable
Units
Market
Rate
Units
Very
Low
Units
Low
Units
Moderate
Units
Above
Moderate
Units
Existing Uses and Redevelopment Analysis
Existing
Building
SF
Max
Building
SF
Percent
Utilized
37505101 0.50 UMU UMIX 55
1212 STRUCK
AVE B & B GARDNER LP 27 6 21 4 2
Older single-story office structures and
maintenance sheds surrounded by large
surface parking lot. 3,757 65,011 6%
39028533 0.41
NMU-
24 NMIX24 16.3 MAIN ST MP-LAVETA LLC Yes 6 0 6 1 0 6
Small older commercial shopping center with
potential to redevelop for mixed-use. 19,731 54,039 37% 1054 488 732 1777
275
Appendix C: Summary of Community
Engagement

276

Appendix C: Summary of Community Engagement C-2
2021-2029 Housing Element Update
Summary of Community Engagement
Section 65583 of the Government Code states 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 6
th Cycle Housing Element Update process, the City of Orange has conducted public outreach activities beginning in the fall of 2020. These recent outreach efforts included Community Workshops, City Council and Planning Commission workshops, digital media and engagement, and noticed Public Hearings. Project materials, including summaries from community workshops and public meetings, notices, and draft public review documents are available on the City’s website:
https://www.cityoforange.org/290/Current-Projects.

Outreach for the 6th Cycle Housing Element to the Orange community includes the following actions:
• Virtual Workshop Presentation – On October 12, 2020, the City launched the Housing Element Virtual Workshop Presentation. This included a recorded informational presentation available on the Housing Element Update webpage and a fast sheet.
• Community Workshop – The City conducted a virtual community workshop on May 26, 2021. This workshop provided attendees with information about the Public Review Draft and opportunities for public participation. The workshop was advertised on the City’s webpage and on social media platforms. Spanish translation services were available for the meeting. • Online Community Survey – With the release of the Virtual Workshop Presentation on October 12, 2020, the City also launched an Online Community Survey available through November 15, 2020. There was a total of 148 persons who participated in the survey. Participants were asked to consider potential policies and programs to include in the Housing Element. • Stakeholder Meeting s – On December 1, 2020, the City held two stakeholder meetings with affordable and market -rate housing developers and with housing advocates and community groups. The purpose of these meetings was to solicit feedback about housing constraints, methods of promoting affordable housing, new or innovative housing trends, and engaging the faith-based community.
• Housing Element Update Webpage – A webpage developed for public consumption is available at this address: https://www.cityoforange.org/290/Current-Projects . The webpage provides
relevant information about the update process, key features of the Housing Element, project timeline, and upcoming outreach events. The website also provides access to each virtual outreach event and the survey while it was ongoing.

• Public Comments – Through the update process, the City received a variety of comments and input from the public. Public participation and feedback help to guide the development of the 277

Appendix C: Summary of Community Engagement C-3
2021-2029 Housing Element Update
Housing Element, all public comments r eceived by the Housing Element update team are compiled in this appendix.

As required by Government Code Section 65585(b)(2), all written comments regarding the Housing Element made by the public have previously been provided to each member of the City Council.

This appendix contains a summary of all public comments regarding the Housing Element received by the City during development of the Public Review Draft Housing Element. This includes feedback from the first virtual Community Workshop. This section will be updated following the second virtual Community Workshop prior to submittal to the State Department of Housing and Community Development (HCD) for review.

Outreach to Underreprese nted Portions of the Community The City of Orange understands the importance of engaging all segments of the community, especially those who traditionally are underrepresented within long-range planning processes and those who may experience some sort of barrier to participation. This may be a language barrier, comfort level, or other responsibilities which conflict with public meetings/engagement efforts by the City. In the City of Orange, these groups are mostly comprised of residents living in disadvantaged areas such as the North Tustin Street corridor or non-English speaking residents throughout the City.

In order to reach those segments of the population, the City felt is was important to be strategic in outreaching to the organizations that are most engaged with the identified populations. For all workshops and draft documents, the City extended notifications to churches and service organizations that are engaged with the disadvantaged and/or non-English speaking segments of our population that may not have internet access or are adept at the use of electronic devices. The City made efforts to reach out to those groups early on in the Housing Element update process when conducting stakeholder meetings as well as s ome of the participants represented those contacts and were able to provide feedback as described in this appendix.

As noted below, all materials were provided in English and Spanish with translation services available in virtual meetings. The City received approximately five comments on the Public Review Draft in Spanish and translated them to review and consider. Understanding that the public workshop times do not work for everyone, the City recorded them and placed them on the City’s website as well as made the community survey available for a month to promote as much engagement as possible. City staff was available at the planning counter to assist residents in taking the survey and translation services were available.

Additionally, direct feedback was obtained from the following groups. The City engaged additional church groups and local organizations but did not receive feedback during the housing element preparation period.
278

Appendix C: Summary of Community Engagement C-4
2021-2029 Housing Element Update
• Community Health Investment Department at St. Joseph Hospital whose mission includes ensuring that residents, particularly the most vulnerable and low-income families, have access to adequate and affordable housing.
• Planners for Health OC who work to address the needs of lower income residents, primarily through advocating for housing availability at all levels.

As part of the North Tustin Specific Plan focused outreach to underrepresented portions of the community, the City completed the following:
• In December 2021, staff conducted the first community workshop to introduce the initiation of the project and solicit input from the community. An online survey was conducted for this workshop. This first survey was made public on December 22nd and by February 12th had collected 762 responses.
• On March 4, 2021, staff conducted a second community workshop to solicit support for preferred environments and development within the plan area. A total of 91 persons attended this meeting and completed a survey.
• On July 20, 2021, staff conducted a third workshop to further involve the community in refining the vision of the project. Over 65 community members attended this in-person workshop and 58 survey responses were received by August 23, 2021.
• On June 16, 2022, staff conducted a scoping meeting kicking off the project EIR. The scoping session turned into a question and answer session to a full Council chambers. • For each of the workshops, mailers and notices went out to over 4,000 property owners and businesses within t he plan area and extending 300 feet beyond. The workshops were also advertised on the City’s website and on social media.
• City Staff also conducted 11 one-on-one meetings with major land developers, property owners, and major business interests.

How Public Comments Were Considered and Incorporate d
Appendix C contains either summaries or direct comments received by the City from the initial stages of development for the housing element update to the public review draft. Public input on the process at all stages was important to producing a plan for the City which met the local community needs and addressed State housing requirements. At each of the milestones below, the City provided opportunity for community input and then subsequently received, considered, and incorporated (if applicable) all public comments.
• Initial Document Development , including public workshop, community survey, and direct outreach to local stakeholders.
• Public Review Draft Release, including notification of interested parties and local organizations. • HCD Review Draft Release, including notification of interested parties and local organizations. • Planning Commission and City Council Consideration and Adoption, including options for required public comment and notification through posting of staff reports through all of the City’s typical 279

Appendix C: Summary of Community Engagement C-5
2021-2029 Housing Element Update
posting methods. Hearings are televised and virtual participation is an option for those unable to attend.

Through the community survey, the City learned that participants recommended prioritization of:

Housing in close
proximity to
transit and in
mixed-use or infill
areas
The City prioritized future housing development within the Urban Mixed Use zoned areas as it provides the greatest flexibility for both higher density housing and mixed-use housing opportunities. These are also along major corridors within the City with the highest levels of access to public transit and in close proximity to local highways/freeways for regional access to jobs.

Accessory
dwelling units
The City included ADUs as part of the candidate housing sites strategy and included a program which commits the City to updating the Municipal Code to permit ADUs and JADUs in all zones which allow residential uses and update Section 17.13.030 Permitted Uses table to clarify where ADUs and JADUs are permitted in compliance with State law. The City is also developing informational materials and train staff to work with residents on permitting and building ADUs.

Inclusionary
Housing
The City considered inclusionary housing policies and made the determination not to develop them at this time.

Keeping existing
affordable
housing units
This City conducted a review of at-risk units (Table 3-38) and determined that only one development is at risk of converting to market rate. Housing Policy Action 1A commits to working with existing property owners and operators to maintain affordable units.

Property
maintenance of
older housing
stock
The City committed to Housing Policy Action 3E to conduct annual assessments of housing stock potentially in need of rehabilitation. The City will consider promoting funding opportunities and community outreach/education on available resources.

Streamline
development
processes
The City has identified candidate housing sites which are priority for future housing development of affordable housing. Housing Policy Action 2E also addresses review of the City’s development processes for methods to provide regulatory relief, including potentially creating additional efficiencies in some processes.

Lack of
informational
resources
The City already has information materials available relating to ADUs, various development processes, and other housing-related resources available to residents either through the City or through other organizations/agencies.

Through several policy actions, the City will continue to develop informational materials and resources as they are needed and make those available in multiple media formats and languages for accessibility.

Access to funding The City continues to pursue funding sources through various local, regional, and state grants. Several policy actions within the housing element address pursuing funding available to address housing availability and fair housing issues. 280

Appendix C: Summary of Community Engagement C-6
2021-2029 Housing Element Update
Virtual Workshop Presentation
This section contains all Virtual Workshop Presentation materials and handouts. The recorded presentation is available on the City’s Housing Element Update webpage at:
https://www.cityoforange.org/290/Current-Projects
281
The City of Orange is in the process of updating the 2021-2029 Housing Element.

This Fact Sheet provides information about the Housing Element and the City’s update process.

What is a Housing Element?
The Housing Element is a chapter of the City’s General Plan. It is a policy document initiated by the City that identifies policies and programs to meet existing and projected future housing needs for all economic segments of Orange residents. The 2021-2029 Housing Element identifies specific actions to address local housing needs.

Key Features of the 2021-2029 Housing Element:
• Population and housing characteristics of Orange
• Evaluation of housing constraints and resources
• Evaluation of existing housing programs and policies
• Identification of sites to accommodate housing at all income levels
• Policies, programs & quantified objectives
What is the Regional Housing Needs Assessment
(RHNA)?
The RHNA process is required by State law to quantify projected future housing need at various income levels within a community. The RHNA process informs the City of Orange planning processes by identifying future housing need resulting from projected growth in population, employment and households. For the 2021-2029 planning period, the City of Orange is allocated a number of housing units to accommodate this growth by income category. The Housing Element must identify sites that have the potential to accommodate projected future growth. 2021 - 2029 City of Orange Draft RHNA Housing Needs Allocation Income
Category
% of Median
Family Income
Income
Range1
RHNA Allocation
(Housing Units)
Min. Max.

Very Low Income 0 – 50% MFI -- $51,500 1,064 units
Low Income 51 – 80% MFI $51,501 $82,400 603 units
Moderate Income 81 – 120% MFI $82,401 $123,600 676 units Above Moderate Income > 120% MFI $123,601 >$123,601 1,585 units Total: 3,927 units
Notes: 1 Income range is based on the 2020 HUD Median Family Income (MFI) for Orange County of $103,000. 282
Why is the City Updating the Housing Element?
The City of Orange is required by State law to update its Housing Element every eight years. The current adopted Housing Element covers the 2013-2021 planning period. The City is now planning for the 2021-2029 planning period.

Importance of Updating the Housing Element:
• Allows the City to plan for the housing needs of the community • Demonstrates the ability to meet future housing growth needs • Allows the community to participate in the planning process • Allows the City to be eligible for some State grants and funding sources
• Ensures the City complies with State housing law
What is Included in the Update Process?
The update process includes a variety of analyses, as well as multiple activities and opportunities for the Orange community to be involved.

Key features include:
• Opportunities, both virtually and in-person, for community participation
• Comprehensive review of demographics in the community • Identification of housing sites to meet the City’s projected housing need • Hearings before the Planning Commission and City Council How Can You Participate in the Update Process?
An online Community Survey will be available on the City’s website that will allow residents to provide the City with comments, preferences, and additional feedback. The City anticipates hosting a virtual workshop in Summer 2020 and Community Workshop in Spring of 2021 to provide the public with an additional opportunity for input prior to the completion of the Housing Element update. There will also be Planning Commission and City Council hearings which will be open to the public in 2021.

Please visit the Housing Element Update page on the City’s website (https://www.cityoforange.org/1956/Housing-Element-Update) for the most up-to-date information.

Schedule:
• Community Survey – Summer 2020
• Stakeholder Study Session – Fall 2020
• City Council Briefing Sessions – Winter 2021
• Public Review Draft – Spring 2021
• Community Workshop - Late Spring 2021
• Planning Commission Hearing – Summer 2021
• City Council Hearing – Late Summer 2021
For information, contact:

Ms. Ashley Brodkin, Associate Planner, City of Orange
Email [email protected] or at call directly at (714) 744-7238 283
La Ciudad de Orange está en proceso de actualizar en Elemento Vivienda 2021-2029. Esta hoja informativa pro- porciona información sobre el Elemento Vivienda y el proceso de actualización de la ciudad. ¿Qué es un Elemento Vivienda?
El Elemento Vivienda es un capítulo del Plan General de la Ciudad. Es un documento de procedimientos iniciado por la ciudad que identifica los métodos y los programas para lograr cumplir con las necesidades de vivienda existentes y proyectadas para el futuro para todos los segmentos económicos de los residentes de Orange. El Elemento Vivienda 2021-2029 identifica acciones específicas para afrontar las necesidades de vivienda locales.

Características Clave del Elemento Vivienda 2021-2029:
• Características de población y vivienda de Orange
• Evaluación de las limitaciones y los recursos de la vivienda • Evaluación de los programas y procedimientos de vivienda existentes • Identificación de sitios para proporcionar vivienda a todos los niveles de ingreso
• Procedimientos, programas y objetivos cuantificados
¿Qué es la Evaluación de las Necesidades de Vivienda
Regionales (Regional Housing Needs Assessment
-RHNA)?:

La ley estatal requiere que el proceso (RHNA) cuantifique la necesidad de vivienda proyectada a un futuro en varios niveles de ingresos dentro de una comunidad. El proceso (RHNA) proporciona información acerca de los procesos de planificación de la Ciudad de Orange al identificar la necesidad de vivienda futura como resultado del crecimiento proyectado de población, empleo y hogares. Para el periodo de planificación 2021-2029, a la Ciudad de Orange se le asigna una cantidad de unidades de vivienda para adaptarse a este crecimiento por categoría de ingresos. El Elemento Vivienda debe identificar los sitios que tienen el potencial para adaptarse al futuro crecimiento proyectado.

Borrador de la Distribución de Necesidades de Vivienda (RHNA) de la Ciudad de Orange 2021 – 2029
Categoría de Ingresos % de Ingreso Familiar
Rango Medio Escala de Ingresos1 Distribución del RHNA
(Unidades Habitacionales)
Min. Max.

Ingresos muy bajos 0 – 50%(IFP) -- $51,500 1,064 unidades Ingresos bajos 51 – 80%(IFP) $51,501 $82,400 603 unidades Ingresos moderados 81 – 120%(IFP) $82,401 $123,600 676 unidades Ingresos por encima de
Ingresos Moderados > 120%(IFP) $123,601 >$123,601 1,584 unidades Total: 3,927 unidades

1. El rango de ingresos se basa en el Ingreso Familiar Promedio (IFP)=(Median Family Income: MFI) para el Condado de Orange de $103,000
284
¿Por qué la Ciudad está Actualizando el Elemento Vivienda? La ley estatal requiere que la Ciudad de Orange actualice su Elemento Vivienda cada ocho años. El Elemento Vivienda adoptado actualmente cubre el periodo de planificación 2013-2021. La Ciudad está preparando ahora el periodo de planificación 2021-2029
.

La importancia de Actualizar el Elemento Vivienda:
• Permite a la Ciudad planificar las necesidades de vivienda de la comunidad
• Demuestra la capacidad para satisfacer las necesidades futuras de crecimiento de vivienda
• Permite que la comunidad participe en el proceso de planificación • Permite que la Ciudad sea elegible para recibir algunas subvenciones y fondos estatales
• Garantiza que la Ciudad cumpla con la ley estatal de vivienda ¿Qué se incluye en el Proceso de Actualización?
El proceso de actualización incluye una variedad de análisis, así como múltiples actividades y oportunidades para que la comunidad de Orange participe.

Las características clave incluyen:
• Oportunidades, tanto virtuales como en persona, para la participación de la comunidad • Una revisión integral de la demografía en la comunidad • La identificación de sitios de vivienda para satisfacer la necesidad de vivienda proyectada de la Ciudad • Audiencias ante la Comisión de Planificación y el Ayuntamiento de la Ciudad ¿Cómo puede usted participar en el Proceso de Actualización? Una Encuesta Comunitaria en línea estará disponible en el sitio web de la Ciudad que permitirá a los residentes proporcionar a la Ciudad sus comentarios, preferencias y sugerencias adicionales. La Ciudad anticipa organizar un taller virtual en el verano del 2020 y un Taller Comunitario en la primavera del 2021 para darle al público una oportunidad adicional de proporcionar sus comentarios antes de completar la actualización del Elemento Vivienda. También habrá audiencias de la Comisión de Planificación y el Ayuntamiento de la Ciudad que estarán abiertas al público en el 2021 Por favor visite la página de Actualización del Elemento Vivienda en el sitio web de la Ciudad (https://www.cityoforange.org/1956/Housing-Element-Update) fpara obtener la información más reciente.

Schedule:
• Encuesta Comunitaria – Otoño 2020
• Sesión de Estudio de Partes Interesadas – Otoño 2020
• Sesiones Informativas del Ayuntamiento - Invierno 2021 • Borrador de la Revisión Pública – Primavera 2021
• Taller Comunitario – Finales de la Primavera 2021
• Audiencia de la Comisión de Planificación – Verano 2021 • Audiencia del Consejo Municipal – Finales del verano 2021 Para obtener información, comuníquese con:

Sra. Ashley Brodkin, Planificadora Asociada, Ciudad de Orange Correo electrónico [email protected] o llamando directamente al (714) 744-7238 285
1 2021-2029 Housing Element Update
2021-2029Housing Element UpdateCommunity Workshop #1City of Orangewww.cityoforange.org/1956/Housing-Element-Update 2021-2029 Housing Element UpdateAgendaI. Overview of OrangeII. Overview of Housing ElementIII. Regional Housing Needs Assessment (RHNA) IV.Update Process and OutreachV. Project ScheduleVI.Next Steps2 2021-2029 Housing Element Update
Overview of Orange3
2021-2029 Housing Element UpdateHispanic or Latino39%4Source: American Community Survey, 5-Year Estimates 2017Actual 2000 Actual 2010 Projected 2012 Projected 2020 Projected 2035 Projected 2040Orange128,821 136,416 138,500 143,100 151,400 153,000115,000120,000125,000130,000135,000140,000145,000150,000155,000Population in Orange, 2000 – 2040The Orange CommunityWhite70%Black1%American Indian and Alaska Native1%Asian12%Native Hawaiian or Other Pacific Islander0%Some Other Race13%Two or More Races3%Population in Orange by Race or Ethnicity 2021-2029 Housing Element UpdateThe Orange Community5Source: American Community Survey, 5-Year Estimates 2017Married-couple Family Households44%Male Householder, No Spouse 5%Female Householder, No Spouse Present11%Non-Family Household22%Householder Age 65 or Above18%Household by Type in OrangeOwner57%Renter43% 2021-2029 Housing Element Update
Built2014 orlaterBuilt2010 to2013Built2000 to2009Built1990 to1999Built1980 to1989Built1970 to1979Built1960 to1969Built1950 to1959Built1940 to1949Built1939 orearlierOrange0.1% 0.8% 7.3% 9.8% 12.3% 23.3% 24.7% 14.5% 1.6% 5.5%0.1%0.8%7.3%9.8%12.3%23.3%24.7%14.5%1.6%5.5%0%5%10%15%20%25%30%Housing in Orange6Source: American Community Survey, 5-Year Estimates 2017 Housing by Type in OrangeHousing by Year Built
1 23 45 6
286
2 2021-2029 Housing Element Update
Overview of the Housing Element7
2021-2029 Housing Element UpdateWhat is a Housing Element8Required Section of the Orange General PlanProvides Goals, Policies, Programs, and Objectives to guide future housing growth to meet the needs of residents of all income levels in OrangeIdentifies projected housing needs by income categoryRequires certification by the State Department of Housing and Community Development (HCD) for compliance with State housing laws 2021-2029 Housing Element UpdateWhy are Housing Elements Updated?• Plan for the housing needs of all segments of the Community• Demonstrates Orange’s ability to meet the future housing growth needs• Allows the community to further engage in the planning process• Ensures the City complies with State housing laws• Allows the City to become eligible for State grants and funding sources9 2021-2029 Housing Element UpdateA “Certified” Housing Element10What Does it Mean to Have a “Certified” Housing Element?• Demonstrates substantial compliance with State law• Certified by the Department of Housing and Community Development (HCD)Benefits of Certification• Eligibility for State assistance programs• Demonstrates ability to meet future growth and un-met needs• Eligibility for State grants and alternative funding sources 2021-2029 Housing Element UpdateHousing Element Features11Population and housing profileAnalysis of sites to accommodate the City’s RHNA AllocationEvaluation of existing programs and policies Evaluation of housing constraints and resources Policies, programs and quantified objectives to achieve the City’s housing goals 2021-2029 Housing Element Update
Regional Housing Needs Assessment12
7 89 1011 12
287
3 2021-2029 Housing Element UpdateWhat is RHNA?• Regional Housing Needs Assessment• Quantifies the need for housing within each City/County in California• Based on future growth in population, employment and households13 City of OrangeRHNA 2021-20293,927 units
Southern California Association of GovernmentsSCAG develops methodology to determined “fair share” distribution of the region’s housing need to local jurisdictions Department of Housing and Community DevelopmentHCD determines and distributes the State’s housing need to all the regional councils of government 2021-2029 Housing Element UpdateRHNA Draft Allocation: 2021 – 2029 Planning Period14Income Category% of Area Median Income (AMI)Income Range*RHNA Allocation(Housing Units)**Min. Max.Very Low Income 0 - 50% AMI -- $51,500 1,064 unitsLow Income 51 – 80% AMI$51,501 $82,400 603 unitsModerate Income 81 – 120% AMI $82,401 $123,600 676 unitsAbove Moderate Income >120% AMI $123,601 >$123,601 1,585 unitsTotal: 3,927 units*Income range is based on the 2020 HUD Median Family Income (MFI) for Orange County of $103,000.**RHNA Allocation is in draft form and subject to change pending final approval by SCAG. 2021-2029 Housing Element Update
Update Process and Outreach 15
2021-2029 Housing Element UpdateWhat is Included in the Update Process? 16Community Outreach Process (Workshops and Online Survey)Update of the City’s demographic conditionsReview and Analysis of sites to meet the City’s RHNA housing growth needCreation of policies and programs for existing and future housing needsPublic Hearings before Planning Commission and City Council 2021-2029 Housing Element Update
Next Steps17
2021-2029 Housing Element UpdateHousing Element Update Schedule18Community Survey –Summer 2020Stakeholder Study Session – Fall 2020City Council Briefing Sessions -Winter 2021Public Review Draft – Spring 2021Community Workshop -Late Spring 2021Planning Commission Public Hearing –Summer 2021City Council Public Hearing –Late Summer 2021 13 1415 1617 18
288
4 2021-2029 Housing Element UpdateWe Want Your InputParticipate in the Housing Element Survey!Go to: www.cityoforange.org/1956/Housing-Element-UpdateClick the link titled “Housing Element Survey” to begin.19 2021-2029 Housing Element UpdateHow to Use the Survey20The survey provides the City with important community feedback to help shape goals and policies within the Housing Element. Your input is very important!1. Click the link provided on the City’s website using either your phone or a desktop/laptop2. Click “Begin” to start the survey3. Carefully read the instructions on each slide4. Respond to the provided prompts with your ideas and input5. Complete slide five and click “Submit Final Questions” to complete the survey and submit all responses 2021-2029 Housing Element UpdateThank you!Questions?Contact Ashley Brodkin, Associate PlannerPhone: 714-744-7238Email: [email protected] Housing Element webpage: www.cityoforange.org/1956/Housing-Element-Update2119 2021 289

Appendix C: Summary of Community Engagement C-7
2021-2029 Housing Element Update
Community Workshop
This section contains all workshop materials and handouts, flyers, and all available public comments provided verbally and in the chat during the workshop. A video recording of the workshop is available on the City’s Housing Element Update webpage at:
https://www.cityoforange.org/2226/2021-2029-Housing-Element-Update

290
For questions, please contact Anna Pehoushek, Assistant Community Development Director by email at [email protected]
The City of Orange is preparing to release the Public Review Draft of the 2021-2029 Housing Element. Please join us for a virtual workshop to learn about the different parts of the draft document as well as how you can provide feedback during the public review period.

The City’s General Plan establishes a long-term vision for growth and change in the community.

The Housing Element is a required component of the General Plan and guides future decisions regarding housing, goals, policies, and programs. It is required to be updated every 8 years by the State Department of Housing and Community Development (HCD). This update is the 6th Cycle Housing Element update and will plan for the period from 2021-2029.

WHEN: May 26, 2021, 6-8 p.m.

WHERE: Online Meeting Via Zoom, The link is located on the City’s Website under Current Projects:
www.cityoforange.org/housingelement
City of Orange
2021-2029 Housing Element Update
Community W orkshop #2
291
Si tiene alguna pregunta, por favor comuníquese con Anna Pehoushek, Subdirectora de Desarrollo Comunitario, por correo electrónico a [email protected] La ciudad de Orange se está preparando para publicar el Borrador de Revisión Pública del Elemento de Vivienda 2021-2029. Únase a nosotros en un taller virtual para aprender sobre las diferentes partes del borrador del documento y cómo puede proporcionar comentarios durante el período de revisión pública.

El Plan General de la Ciudad establece una visión a largo plazo para el crecimiento y el cambio en la comunidad. El Elemento de Vivienda es un componente obligatorio del Plan General y sirve como guía para las decisiones futuras con respecto a la vivienda, las metas, las políticas y los pro- gramas. El Departamento de Vivienda y Desarrollo Comunitario del Estado (HCD) debe actualizarlo cada 8 años. Esta actualización es la actualización del elemento de vivienda del 6o Ciclo y planifi- cará para el período 2021-2029.

FECHA Y HORA: 26 de mayo del 2021, 6-8 p.m.

LUGAR: Reunión en línea a través de Zoom, el enlace se encuentra en el sitio web de la ciudad en Proyectos Actuales:
www.cityoforange.org/housingelement
Ciudad de Orange
Actualización del Elemento de Vivienda 2021-2029
Taller Comunitario #2
292
City of Orange
Community Workshop #2 Summary
May 26, 2021
Community Workshop #2
The City of Orange held a second public community workshop for the 2021-2029 6th Cycle Housing Element Update on Wednesday May 26, from 6-7:30 PM. The purpose of the meeting was to provide information on the release of the City’s Public Review Draft of the Housing Element, which was made available on the City’s website for community review for 30 days. This workshop included a presentation which discussed the following topics:
• The City’s efforts to date on the project
• A brief review of the Housing Element update process, with the full detailed first workshop available on the City’s website.
• A walkthrough of the different sections and how to read and understand the Housing Element document
• A discussion of the City’s sites analysis approach to identifying housing opportunity • The ways in which workshop participants and community members could provide comments, including live during the workshop, by email directly to City staff, or through a community survey designed specifically to make it easy to provide feedback on each section. • Next steps in the update process
Following the presentation, the City allowed time for open questions from the public regarding the Public Review Draft of the City’s Housing Element. A video of the full presentation in English and Spanish are available on the City’s Housing Element Update webpage here, https://www.cityoforange.org/2226/2021-2029-Housing-Element-Update Spanish translation services were provided for the workshop, though no participants chose to use that option. The City recorded the Spanish presentation anyway and provided it to the community.

Text Comments Received
In addition to verbal comments, the City also received some comments using the “chat” function in zoom. Those questions/comments are provided word for word below:
• When is the last day to provide feedback?
• Does the lack of an Inclusionary Housing Ordinance preclude an applicant from invoking state density bonus on a particular project?
• Will there be another meeting before sending the draft to HCD? • Thank you for presenting this workshop and responding to questions! Staff was available to provide direct responses in the chat during the meeting and was able to respond to all questions.

Community Response Survey
Additionally, the City launched an online community survey on May 26, 2021. The survey was the second survey created and distributed to gather feedback on the Housing Element and focused on obtaining feedback on the Draft Housing Element document. Direct responses to the survey are provided in Appendix C under “Public Comments”.
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May 26, 2021
The survey was available on the City’s Housing Element Update webpage. The City promoted the survey at the workshop and through social media, email and community announcements. The survey was live through the end of the public review period.
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file:///kimley-horn.com/...20of%20Orange%20-%206th%20Cycle%20HE/Community%20Outreach/Workshop%20%232/Recordings/chat.txt[10/4/2021 9:20:49 AM] 18:41:24 From Maria Zacarias Torres : when is the last day to provide feedback? 18:43:47 From Molly Mendoza : Link to Public Review Draft:
https://www.cityoforange.org/DocumentCenter/View/12889/Housing-Element-Public-Review-Draft_May-2021 18:55:04 From Byron de Arakal : Does the lack of an Inclusionary Housing Ordinance prelude an applicant from invoking state density bonus on a particular project?
18:56:15 From Maria Zacarias Torres : will there be another meeting before sending the draft to HCD? 18:56:23 From Byron de Arakal : *preclude*
18:58:44 From Molly Mendoza : Hi Maria, the City will not host an additional meeting, however you can comment on the draft document and share your ideas by sending your comments to the City. Thanks for participating! 19:17:20 From Molly Mendoza : Link to Public Review Draft:
https://www.cityoforange.org/DocumentCenter/View/12889/Housing-Element-Public-Review-Draft_May-2021 19:18:34 From soraya to Ines Galmiche(Direct Message) : Thank you Ines. Great job. 19:22:01 From Maria Zacarias Torres : yes, that would be very helpful! 19:22:09 From Bonnie Robinson : Thank you for presenting this workshop and responding to questions! 295
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1 2021-2029 Housing Element Update
2021-2029Housing Element UpdateCommunity Workshop #2Taller Comunitario #2City of Orangewww.cityoforange.org/housingelement 2021-2029 Housing Element UpdateAgendaI. Housing Element Efforts to DateII. Housing Element Update ProcessIII. Public Review Draft –Sites and PoliciesIV. Community Review/FeedbackV. Next Steps2I. Sala de Reunión en EspañolII. Esfuerzos del Elemento de Vivienda hasta la FechaIII. Proceso de Actualización del Elemento de ViviendaIV. Borrador de Revisión Pública –Sitios y PolíticasV. Revisión/Comentarios de la ComunidadVI. Próximos Pasos 2021-2029 Housing Element Update
Spanish Breakout Room3
2021-2029 Housing Element Update
Spanish Breakout Room4
2021-2029 Housing Element Update
Spanish Breakout Room5
2021-2029 Housing Element Update
Housing Element Efforts to Date6
1 23 45 6
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2 2021-2029 Housing Element UpdateOverview of Orange’s Housing Element Update• City began the Housing Element Update process in late 2019• Community Workshop #1 (Summer 2020)• Community Survey (Summer 2020)• Stakeholder Meetings (Winter 2020)• Public Review Draft Release: May 21, 2021• Project website with the available Public Review Draft: www.cityoforange.org/housingelement7 2021-2029 Housing Element UpdateWorkshop #1• The City held a virtual recorded workshop for the Housing Element Update• Overview of the Housing Element Update process, Regional Housing Needs Assessment (RHNA), project timeline• A recording of Workshop #1 (posted to YouTube) and Fact Sheet #1 (English and Spanish) are available on the City’s Website: www.cityoforange.org/housingelement8 2021-2029 Housing Element UpdateCommunity Housing Survey• Survey focused on: • Housing Opportunity Programs• Potential Housing Locations• Removing Potential Constraints• Available for approximately two months in English and Spanish• 148 participants, 3,433 data points, and 256 comments9 2021-2029 Housing Element UpdateStakeholder Meetings• Two stakeholder meetings held in December 2020• Housing advocates and community groups• Affordable and market-rate housing developers• Summary of feedback received:• Clarity on the process, requirements, and timing is important for housing projects• Informational housing materials should be made available to the public• Explore policies aimed at streamlining affordable housing• Community is leaving – can’t afford to live in Orange• Full Summary of stakeholder meeting notes found in Appendix C of the Public Review Draft Housing Element10 2021-2029 Housing Element Update
Housing Element Update Process11
2021-2029 Housing Element UpdateWhat is a Housing Element12Required Section of the Orange General PlanProvides Goals, Policies, Programs, and Objectives to guide future housing growth to meet the needs of residents of all income levels in OrangeIdentifies projected housing needs by income categoryRequires certification by the State Department of Housing and Community Development (HCD) for compliance with State housing laws 7 89 1011 12
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3 2021-2029 Housing Element UpdateHousing Element Features13Population and housing profileAnalysis of sites to accommodate the City’s RHNA AllocationEvaluation of existing programs and policies Evaluation of housing constraints and resources Policies, programs and quantified objectives to achieve the City’s housing goals 2021-2029 Housing Element Update
Public Review Draft –Sites and Policies14
2021-2029 Housing Element UpdateSites Strategy• The Public Review Draft Housing Element identifies candidate sites under existing zoning that can accommodate the City’s 2021-2029 Regional Housing Needs Assessment (RHNA) need.• The proposed candidate sites are focused in areas of the City with existing resources and transportation and include estimated projections of Accessory Dwelling Units (ADU). • Much of the City’s lower income need is planned to be accommodated in the Urban Mixed-Use (UMU) zone. 15 2021-2029 Housing Element Update16
2021-2029 Housing Element UpdateUrban Mixed-Use (UMU) Zone• Intended to provide urban, high intensity, regionally-oriented activity centers with a mixture of housing, commercial, professional office and civic uses• Permits residential either as part of a mixed-use project or as a freestanding use• Permits development up to 60 dwelling units per acre (du/ac)• HCD’s default density for identifying affordable housing in Orange in 30 du/ac• Places potential future housing close to services, jobs, and transportation 17 2021-2029 Housing Element UpdateAssumption of Affordability• Conservative assumption that projects will not develop at 60 du/ac, but rather 48 du/ac consistent with the City’s Land Use Element • This accommodates commercial, office, or other types of housing• Assume that up to 25% of units on candidate sites may develop at the very-low and low affordability level. The rest are assumed to be market-rate.18 13 1415 1617 18
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4 2021-2029 Housing Element UpdateProposed Housing Policy Actions• The Review of Past Performance showed that the City has been successful in implementing its 5thCycle policy actions.• Some proposed 6thCycle housing policy actions are from the City’s current Housing Element that are working well• New policy actions have been added to accommodate new provisions in State law• Additional policy actions have been added based on fair housing analysis19 2021-2029 Housing Element UpdateProposed Housing Goals•Goal 1: High quality neighborhoods and housing stock.•Goal 2: Accommodate Orange’s RHNA need at all income levels.•Goal 3: Effective maintenance, preservation, improvement, and development of housing citywide.•Goal 4: Equal housing opportunity for all persons regardless of race, religion, sex, marriage status, ancestry, national origin, or color. 20 2021-2029 Housing Element UpdateSample Housing PolicyHousing Policy Action 2A:Annual Review of Housing ElementThe City will continue to conduct an annual implementation review of the Housing Element consistent with HCD’s annual reporting requirements. The review includes the following information: a log of new residential development permits and completion reports; inventory of units built in the Extremely Low-, Very Low- and Low-income categories, an update or inventory of approved projects; an annual estimate of population from the State Department of Finance; and available vacant land and zoning survey. Timeframe:AnnuallyResponsible Agency: City of Orange Community Development DepartmentFunding Source:General fund21 2021-2029 Housing Element Update
Community Review/Feedback22
2021-2029 Housing Element UpdateCommunity Survey• One method of providing comments to the project team is to complete the Public Review Draft Response Survey• Please go to the following link (also on the City’s website) to input comments in the survey: https://forms.office.com/r/CE5KFqh1cr23 2021-2029 Housing Element UpdateEmail Comments/Questions to the Project Team• If you would like to send attachments, letters, or free response comments to the Project Team, please email those directly to Anna Pehoushek at [email protected]• The City welcomes additional resources or materials related to the Housing Element. If you would like to send those, please email those directly as well. 24 19 2021 2223 24
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5 2021-2029 Housing Element UpdateLive Question & Answer• The purpose of tonight’s question and answer is to gather initial feedback and answer questions on how to read the City’s Draft Housing Element• Please use the “Raise Hand” function through Zoom and staff will call on you in order to unmute• Questions can also be submitted to the Project Team through typing in the “chat” function • Frequently Asked Questions (FAQ) on the Draft Housing Element available on the City’s website: www.cityoforange.org/housingelement25 2021-2029 Housing Element Update
Next Steps26
2021-2029 Housing Element UpdateHousing Element Update Schedule27Public Review Draft – Spring 2021Community Workshop -Spring 2021Planning Commission/City Council Briefings – Summer 2021HCD Review Draft – Late Summer 2021 2021-2029 Housing Element UpdateThank you!Questions?Contact Anna Pehoushek, Assistant Community Development DirectorEmail: [email protected] Housing Element webpage: www.cityoforange.org/housingelement2825 2627 28 301

Appendix C: Summary of Community Engagement C-8
2021-2029 Housing Element Update
Online Community Survey
This section contains an outline of the community survey and a summary of the survey results. The online community survey received 148 responses from the public. 302
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Draft Community Survey Summary
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Community Survey
October 12, 2020 to November 30, 2020 the City of Orange launched an online community survey in order to gather feedback regarding 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 to housing access and constraints to the development of housing. Below is a summary of the survey’s results.

Slid e 1: Housing Program Opportunities
Participants were provided a variety of housing programs opportunities, categor ized into four groups:

Affordable Housing programs, Community Assistance programs, Fair Housing programs, and Streamlining Development Processes. Participants were asked to rank each potential program or policy based on applicability, as well as what they would most like to see implemented. The scale was set from one to five, one being the least appealing and five being the most appealing.

Affordable Housing Programs - Figure C-1 displays data results for participant interest in a variety of affordable housing programs. Overall, participants showed little interest in affordable housing programs provided by the survey, as all programs had a majority rating of one star. However, based on the five-star data, participants were most interested in programs to create inclusionary housing, while programs and policies to incentivizing accessory and second dwelling units were identified as the least appealing.

Participants also showed the highest interest in keeping existing affordable housing.

Figure C-1: Affordable Housing Program Opportunities

Community Assistance Programs – Figure C-2 displays survey results for participant interest in different community assistance programs. Overall, participants showed a high interest in all the potential community assistance programs. The figure shows that participants were most interested in the City providing housing information, participants also identified assistance funding for first-time homebuyers 0 10
20 30
40 50
60 70
Accessory Dwelling
Unit s
Housing
Partnerships
Inclusionary
Housing
Keep Affordable
Housing
MixedUse
Opport unities
1 2
3 4
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as a priority. The data shows a split in interest between one a nd five stars for property maintenance assistance, as well as a split interest for rental assistance.

Figure C-2: Community Assistance

Fair Housing Programs – Figure C-3 displays survey results for participant interest i n fair housing programs. Fair housing is access to housing for all persons in Orange, regardless of age, disability, race, religion, familial status, or gender. The data shows that majority of participants were interested in a variety of fair housing programs and policies. Programs and policies to promote, support and increase fa ir housing were most appealing to participant s, followed by programs to encourage the development of housing for persons with disabilities. The data shows a split interest in support ive housing to provide emergency, short- and long-term housing.

Figure C-3: Fair Housing
0 10
20 30
40 50
60 Homebuyer Assistance Housing Rental
Assistance
Property Maint enance Provide Housing Info
1 2
3 4
5 304
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Streamlining Processes – Figure C-4 displays survey results for participants interest in programs and policies to streamline the development process. Overall, participants showed little interest in streamlining the development process, including little interest in decreasing developments fees, expediting review process and streamlining the permit timeline.

Figure C-4: Streamlining Processes

Slid e 2: Potential Housing Locations
Survey participants were provided a list of areas for housing opportunities in Orange and asked to rank the areas based upon where they would most like to see housing in the City. Participants placed their highest priority area as number one at the top of the list, their second priority as number two, and so on.

The potential areas included the following:
0 10
20 30
40 50
60 70
Persons with Disabilities Promote Fair Housing Senior Housing Support ive Housing 1 2
3 4
5 0
10 20
30 40
50 60
70 80
Development Fees Development Process Project Processing 1 2
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• Transit Center: Opportunities to develop a variety of housing types within proximity to Orange's Transportation Center, creating increased mobility for residents and accessibility to a transit system.
• Mixed-Use Areas: The development of housing in conjunction with other types of uses, such as commercial, retail, or office developments. This could include areas similar to Uptown Orange, Town and Country, West Katella, and South Main.
• Residential Infill: The development of land within existing neighborhoods provides the opportunity for new housing that complements the existing character and type of housing currently found.
• City-Owned Properties: Potential to develop a range of housing types on underutilized City owned-property.
• Commercial Corridors: Development of housing in commercial corridors, which are easily accessible and provide close access to goods, services, transportation, and other amenities. This could include the West Chapman and North Tustin Street Corridors, as well as the Lincoln Avenue corridor and the section of Katella between Tustin and Glassell. • Industrial Areas: The potential for housing developments in areas currently used for industrial purposes.

Figure C-5 displays the data for participant prioritization of potential housing opportunities i n Orange.

The line chart identifies each listed location’s average ranking, the closer to one the ranking, the more important it was to participants. The survey results showed that new housing communities and residential in Transit Center Area the highest priority housing opportunities for participants. Participants were least interested in housing in underutilized industrial areas. It was also observed that participants were also interested in utilizing mixed-use areas for housing and residential infill as an opportunity for creating housing.

Figure C-5: Housing Areas

Transit
Center Area
Mixed-Use
Areas
Residential
Infill
City-Owned
Properties
Commercial
Corridors
Industrial
Areas
Average Rank 2.43 2.61 2.93 3.02 3.21 3.7

2.43 2.61

2.93 3.02 3.21

3.7 1

1.5 2

2.5 3

3.5 4

4.5 5
Highest Priority
Lowest Priority
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Slid e 3: Priority Programs to Remove Constraints to Housing Participants were asked to identify barriers or constraints to the development of and access to housing within the City of Orange. The following constraints were provided:
• Lack of Informational Resources: Is it difficult to find informational resources on affordable housing within the City?
• Housing Availability: Is it difficult to identify and get access to affordable housing? • Permit Streamlining: Do you believe the current development process could be expedited to encourage the development of housing?
• Flexible Development Standards: Would additional flexibility in development standards help to further the development of housing?
• Housing Fees: Is the cost of permits to build housing or ADUs an impact on the development of housing in Orange?
• Access to Funding: Is funding assistance availability an issue in obtaining and/or developing affordable housing in Orange?
Participants were provided stars to allocate among the listed potential barriers, prioritizing the barriers they would most like the City to focus on removing by increasing the allocation of stars. Figure C-6 displays the results of participant’s priorities for removing barriers to housing. According to the data, participants would most like the City to focus of providing information regar ding housing resources, funding opportunities and housing programs, closely followed by interest in having the City focus of housing availability and access to housing affordable to different income levels. Participants showed interest in having the City p rovide more funding opportunities; however, participants were least interest ed in removing barriers associated with the development process (permit streamlining, flexible development standards, and housing fess).

Figure C-6: Constraints to Housing

356 352
170
127
157
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100
150
200
250
300
350
400
L ack of
Informational
Resources
Housing
Availab ility
Permit
Strea mlining
Flexible
Development
Standards
Housing Fees Access to Funding
Stars Allocated
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Appendix C: Summary of Community Engagement C-9
2021-2029 Housing Element Update
Stakeholder Meetings
This section contains all available meeting materials, including combined notes from both of the stakeholder meetings.
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Stakeholder Meeting Notes – December 1, 2020
Housing Constraints
Entitlement Process
Amount of upfront work on tentative maps has gone up - most of the work is required up front now. Lengthens entitlement period
Not requiring affordable or on-site affordable
Tough line to walk on entitlement process - requirements vs. community character
Tentative maps determine feasibility of the work, so certain details could be pushed off to post-entitlement period to lower upfront costs Lowering fees (park fees, development fees) - upfront cost Not necessarily easing up on process - maybe it's addressing the timing of review/entitlement process
Needed application and project components should be known up front City staff as partners to the community - partnerships is the goal Offer fees in the form of a loan that could be paid over time Review the level of detail needed up front. Determining feasibility is important
Cost issue of requiring details that may change as the building permit process gets closer
Standard ministerial Design guidelines
Lack of specific policies or programs to prioritize affordable housing - Density bonuses and incentives do not match existing zoning & ordinances Are local zoning & ordinances blocking the dev. of affordable housing? Specific Policy - Streamline development process to proceed by-right in some cases

1. staff review process is longer than it needs to be for new development - no opportunity for discussion & conflicting comments between departments (Live interaction needed between all those who made comments on project)

2. Current role of Design Review Committee - Density Bonus Development knowledge (DRC shouldn’t have a role in density bonus applications) Cost and length of the process
Density Bonus projects - time consuming to get revisions to State law synced with local procedures - streamlined approach?
Very specific code to increase ministerial review and reduce PC & CC review Neighborhood
Opposition
Inviting supporters to the room to change the atmosphere at Council meetings
Community members who do not understand what is being built Community outreach - door knocking
-Showing the community differences in what densities look like Not in my backyard
-traffic
Recommendation letters from past partners to hand out to the community Start with reaching out to community members in little neighborhoods Inform community of opportunity sites
Land Price Addressing developer fees and processing time of projects

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Promoting Affordable Housing
Incentives &
Subsidies
Financial incentives
-loans
Work with tweezers and not a blunt spoon - not necessarily need to create citywide policies/impacts
City grants to help first time homebuyers with down payments to help fill the gap for affordable units
Land use as a way to incentivize - up zoning increases value If up zone, asking for help to meet the City's requirements is reasonable -Discount factor to address market rate units taking on additional cost from affordable units
Micro Units/Tiny
Homes
Room in Orange's Code for smaller studio units (250 SF) for seniors and special needs populations tied with affordability, amenities/services City to provide CDBG/HOME funds for ADUs and add deed restriction to ensure affordability for a number of years
Pre-approved ADU plans / Permit ready ADU programs
Other
Specific policies to streamline and incorporate affordable housing addressing affordable housing through City resources & land storage requirements outside the units - non-code required closets in units count towards storage requirements
No net loss - build in a potential buffer of available sites

What can the City do to Provide Access to Affordable Housing? Communication and
Education
Communicating the long-term value of affordable housing in a community Educational materials year round rather than affordable housing being tied to a particular project
Communicating that people benefiting from affordable housing are those who already work in the community
Show example of other work that has been done in another community Workforce housing - wording is important for perception Council and City Staff sharing that housing opportunities may benefit the children of people already living in the City
Changing the narrative away from affordable housing being negative to a community
Understanding the importance of stable housing for families/households and what it looks like
Other
Spending 30% of income on housing v 60-70% impacts how people live their lives and contribute
Local community is moving out due to high cost of living Courage to approve affordable housing - subsidies/zoning are there Approval of projects is encouraging for future development Ordinance to rent out empty rooms in your house
Increase supply of (affordable) housing - only 25% of those eligible for assistance receive it
Inclusionary Housing Policy
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New and Innovative Trends
Redevelopment
Areas
Existing retail areas that may benefit from conversion to housing due to economic changes
Church properties - housing on the property
Keep Church use
Aging church properties that could serve as good partnership locations Looking at underutilized institutional properties
Continuing platinum triangle down Katella and continuing that pattern (redeveloping parking lot areas)
ADUs Financing programs to help homeowners afford ADUS
Buying incentives
Mixed Use
Little shops, medical clinics on first floor and residential above Less trips and helps the environment. Near mass transit/public transportation
TODs - Transit Oriented Developments
Horizontal mixed-use - housing with medical
Modular/Pre-Fab ADU pre-fab units
How is this handled in the City code?
Other
Co-living - 2 bedroom senior housing where occupants can split the rent Work with developers on this
Housing Advocacy program - training of residents on how to give effective public comment
Capacity buffer to catch "lost" units
Look at unintended consequences of planning just to meet the City's RHNA Ensuring people are not displaced and priced out of current homes for newer upzone
Equitable upzoning / growth

Engaging the Faith Based Community
Communicating and
Partnership
Get to know faith-based community through specific contacts Churches very involved in helping people experiencing homelessness

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2021-2029Housing Element UpdateStakeholder MeetingDecember 1, 2020 City of Orangewww.cityoforange.org/HousingElement 2021-2029 Housing Element UpdateAgendaI. Housing Element Update ProcessII. Stakeholder DiscussionIII. Next Steps2 2021-2029 Housing Element Update
Housing Element Update Process3
2021-2029 Housing Element UpdateHousing Element Features4Population and housing profile Evaluation of existing programs and policies
Evaluation of housing constraints and resources
Analysis of sites to accommodate the City’s RHNA Allocation Policies, programs and quantified objectives to achieve the City’s housing goals 2021-2029 Housing Element UpdateRHNA Draft Allocation: 2021 – 2029 Planning Period5Income Category% of Area Median Income (AMI)Income Range*RHNA Allocation(Housing Units)**Min. Max.Very Low Income 0 - 50% MFI -- $51,500 1,064 unitsLow Income 51 – 80% MFI $51,501 $82,400 603 unitsModerate Income 81 – 120% MFI$82,401 $123,600 676 unitsAbove Moderate Income >120% MFI $123,601 >$123,601 1,585 unitsTotal: 3,927 units*Income range is based on the 2020 HUD Median Family Income (MFI) for Orange County of $103,000.**RHNA Allocation is in draft form and subject to change pending final approval by SCAG. 2021-2029 Housing Element UpdateHousing Element Update Schedule6Community Survey –Fall 2020Stakeholder Study Session – Fall 2020City Council Briefing Sessions -Winter 2021Public Review Draft – Spring 2021Community Workshop -Late Spring 2021Planning Commission Public Hearing –Summer 2021City Council Public Hearing –Late Summer 2021 1 23 45 6
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Stakeholder Discussion7
2021-2029 Housing Element UpdateWhat are the Top 3 constraints to Housing?8 2021-2029 Housing Element UpdateWhat can the City do to promote affordable Housing?9 2021-2029 Housing Element UpdateAre there any new or innovative practices when it comes to building affordable housing?10 2021-2029 Housing Element Update
Next Steps11
2021-2029 Housing Element UpdateThank you!Questions?Contact Ashley Brodkin, Associate PlannerPhone: 714-744-7238Email: [email protected] Housing Element webpage: www.cityoforange.org/1956/Housing-Element-Update12 7 89 1011 12
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Appendix C: Summary of Community Engagement C-10
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Public Comments
This section contains all available public comments received by the City relating to the Housing Element update process. Pe rsonal information such as emails and addresses have been redacted for privacy reasons.
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Public Review Draft - Community Comments
Public Comment Response to Comments
Section 1 (Introduction)
Ya no puedo seguir pagando donde vivo Comment has been noted.

The good news in our draft Element is Orange has more than enough capacity to meet our RHNA obligation. This means the North Tustin Specific plan area, the Trails at Santiago Creek site, or the Chandler site are under any obligation to be a housing opportunity sites for this cycle of RHNA.

Comment has been noted.

Section 2 (Community Profile)
Necesito ayuda para poder rentar un lugar más digno con mis dos hijas mi novio Comment has been noted.

Provide more data on the number of senior living-alone in Orange. Note the % of male and female.

Break down the demographics by voting district to see and compare current and future needs for each of the 6 districts in Orange.

Section 2.E.1 provides a
breakdown of seniors living alone
in Orange. See Figure 2-6 for
male and females living alone in
Orange.

Special Needs Groups 7. Homeless Page 2-6:

You have misrepresented the truth when listing the factors contributing to homelessness. Unemployment and
underemployment and a lack of affordable housing is very low on the list of factors contributing to homelessness. Mental illness and/or substance use disorder is the major reason for existence of the OC the homeless population. Surveys have shown about 67% of our homeless population have either a mental illness and/or a substance use disorder. Unsanitary conditions and misconduct is a verifiable sign of this factor. Certainly deinstitutionalizing the mentally ill was a factor beginning in the early 1970s California when had moved most mentally ill patients out of its State hospitals and, by passing Lanterman-Petris-Short Act (LPS), had made it very difficult to get them back into a hospital if they relapsed and needed additional care

Comment has been noted.

Soy una persona que necesita apoyo para seguir trabajando. Pero parte oportunidad de vivir Comment has been noted.

Section 3 (Housing Constraints, Resources, and AFFH)
Yo no quiero vivir en la calle y perder más de lo que e perdido en año y medio Comment has been noted.

Explains constraints better in this section on reality that Orange is nearly built out and that available land (vacant or developed) is scarce, costly, and privately owned. Government constraints are not the true barrier of development rather its the cost of the Comment has been noted.
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land. Infrastructure capacity is a major need for new
development. New development must provide for their share of the increased load to the system.

A. Nongovernmental Constraints 3. Economic Constraints
The words, “home” and “homes,” found in various terms such as “homes on the market,” “median value of a home,” “cost of a home,’ and “home value index,” need to be defined. Are they referring to single family residences only? Or are they referring to any type of housing, and if so, this needs to be clarified.

The distinction has been added
to the section.

Section 4 (Housing Plan)
Necesito ayuda ya que solo recibo incapacidad por 300 dólares a la semana y con eso no puedo pagar alimentos y renta Comment has been noted.

Adopt a program for ADU development and assistance when the property owner enters into city affordable housing agreements for 55 years. Said program could offer incentives to reduce city fees including a reduced impact fee option (a defined formula) but no further reductions to setbacks, off-street parking, use for student housing, STRs, or other development code deviations.

Comment has been noted.

Adopt a program to facilitate partnerships that integrated market and non-profit affordable housing developers who will build market and affordable housing together. Projects for seniors, veterans, teachers, front-line and essential workers employed in Orange, or others, especially families, that are at risk of being homeless should be explored as part of any new residential development proposal above 20 units or those identified in our housing sites inventory.

Section 4 includes a number of
policy actions addressing ADU
development.

Develop a program to examine the safety status and a full inventory of our older apartment complexes in town. These complexes are often more affordable and at risk of being lost due to their age. There should a priority for them to reinvestment support to ensure their preservation and no loss of this needed housing stock.

Comment has been noted.

Develop a program to assist seniors living alone match with roommates or caretakers that are in need of housing assistance and care with daily living.

Comment has been noted.

Develop a program to facilitate private development of age qualified ownership communities with one-story design on standard and small lots. Program should prioritize creative development concepts such as paired housing units, micro units arranged around a common courtyard and or needed amenities, and condominiums with elevators and robust services and open space provided.

Comment has been noted.
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Restructure and refine a better toolkit for senior market rate and affordable senior housing development in our commercial zones when the subject site is adjacent to single-family neighborhoods.

Such projects should continue to require a Conditional Use Permit with expanded legal findings to protect surrounding properties.

The improved development standards should establish a lower FAR, level of intensity and max level of density, expanded setbacks in line with our multi-family residential zones, as well as height, minimum vehicle access, infrastructure, lighting, noise, taller perimeter wall heights, robust landscaping and trees, and privacy should all be included in a new set of objective development standards.

Comment has been noted.

Housing Policy Action 2H for Urban Mixed Use needs to be taken a step further with an Inclusionary Housing Ordinance that would require that all high density housing have a requirement of a percentage of affordable housing production at extremely low, very low and low income categories. This would provide for more equitable housing diversity in income levels throughout Orange.

In addition it is important to make sure opportunity sites are not upzoned or rezoned without including affordable housing policies that will capture the financial and land use incentives being given to property owners and market rate developers. Developers are taking advantage of density bonuses without providing the affordable housing element that should be included. On page 4-9 it states "Continue to follow current State Density Bonus Law and further its implementation through a Density Bonus ordinance update." That update should include an Inclusionary Housing Ordinance to make sure good intentions actually result in housing built for extremely low, very low and low income levels at a commensurate rate with above moderate and market rate
housing as our RHNA requires.

Comment has been noted.

SB1000 Environmental Justice Component Review should include multiple community engagement workshops in the communities of need in languages spoken in those communities.

Comment has been noted.

I would check the draft to make sure our mobile home parks are fully discuss in this section. These units are likely to be affordable and how will these units be preserved during this RHNA cycle.

The complex off Rampart is worried the property owner will close the complex and sell the land to a developer. Maybe this needs to be a program in Section 4.

Mobile home parks are assessed
in Section 2 and 3.

Appendix A (Review of Past Performance)
Appendix A: Although Orange had exceeded 5th Cycle targets for low, moderate, and above moderate housing units, there was an unbalanced production of moderate and above moderate units, as opposed to extremely low, very low and low. This imbalance indicates that Orange's affordable housing policies have not been effective in incentivizing and producing housing for lower income Comment has been noted.
317
City of Orange
2021-2029 Housing Element Update
Public Rev iew D raft Comments 10/4/2021
households. Although several areas were zoned Urban Mixed Use to encourage density, that density did not result in a significant amount of affordable housing. A great example of a missed opportunity are the large developments in the Town and Country area that don't include housing for low and very low income levels.

Appendix B (Sites Analysis)
Appendix B: Concerns about specific sites: The site at 1212 Struck Avenue, located behind sites at 1085 and 1095 N. Main, would also need to be developed in order for the Main Street sites to be appropriate for housing.

Comment has been noted.

The 1212 Struck Avenue Site may need soil testing for safety of housing units on the site. Comment has been noted.

The Orangeland Recreation Vehicle Park at 1600 W. Struck Ave. is not an RV Parking lot; it serves as a short and long term home for several families, much as a motel would with some guests staying overnight, others for a few weeks, some much longer. It appears to be well maintained and filled to capacity. If this site were to be developed into housing, it likely would displace some people who are currently using it for housing.

Comment has been noted.

Markets, pharmacies, parks and other amenities need to be available within or in close proximity to the UMU proposed housing sites.

Comment has been noted.

The City's current density policies and incentives should be modified for the Urban Mixed Use Sites on Table B-3 to require each development approval to include the number of affordable units listed on Table B-3 at the very low and low income levels on each site to ensure that the RHNA requirements are met
equitably.

Comment has been noted.

How does the Housing Element want to cover the likely change to development options and site configuration to the Irvine companies holdings near Jamboree and the toll roads. The opportunity to bring affordable units to this area may still be possible.

Comment has been noted.

The North Tustin Corridor should also be used to accommodate affordable housing. In addition to the Village Mall, there are other sites on Tustin which could accommodate tastefully designed, good quality housing for a mixture of income levels, as well as supportive and senior housing in close proximity to services, markets, stores, pharmacies and restaurants. Thank you for your work and serious consideration of the submitted comments. Bonnie Robinson
Comment has been noted.

318
From: Chen, Nick
Sent: Wednesday, May 19, 2021 4:52 PM
To: Galmiche, Ines
Subject: FW: [EXTERNAL] City of Orange Housing Element Update - Virtual Workshop
Attachments: Housing Element Strategy Letter by SJO2020 (5)CityOfOr ange.pdf

Nicholas Che n, AICP
Kimley-Horn |

In
stagram | Kimley-Horn.com
Celebrating 13 years as one of FORTUNE’s 100 Best Companies to Work For

Fr
om: Ashley Brodkin
Sent: Tuesday, October 13, 2020 1:20 PM
To: Chen, Nick
Cc: Mendoza, Molly <
Subject: FW: [EXTERNAL] City of Orange Housing Element Update - Virtual Workshop

Hi Nick,
Wo
uld it be helpful for us to forward any comment letters we receive from the public and stakeholders? Or we can just share a list at the end. Let me know what would be best.

Thanks,

Ashley Brodkin

From: Bustamante-Pixa, Cecilia
Sent: Monday, October 12, 2020 2:27 PM
To: Ashley Brodkin
Cc: Ross, Barry < ; Z och, Jeremy S ; Abushawish, Jordan A <
Subject: Re: [EXTERNAL] City of Orange Housing Element Update - Virtual Workshop

De
ar Ms. Brodkin,
Thank you for including St. Joseph Hospital in the City of Orange Housing Element Update process. As a major employer in the City of Orange, we have a great interest in ensuring that our residents, particularly the most vulnerable and low-income families, have access to adequate and affordable housing.

319
As you may recall, earlier in the summer, St. Joseph Hospital sent the City of Orange a letter with recommended inclusions for public participation as well as recommendations to be incorporated into the policy. I've attached that communication for your review. St Joseph Hospital will complete the online Housing Element Survey. In addition, I would like to request that the City of Orange consider St. Joseph Hospital's participation in the Stakeholder Study Session in the Fall of 2020.

Thank you once again,
Cecilia

Cecilia Bustamante Pixa, MPH, MHCML
Director, Community Health Investment

St. Joseph Hospital of Orange

www.sjo.org

I love Love and I let Love, love through me. Father Jean-Pierre Medaille

From: Ashley Brodkin
S
ent: Monday, October 12, 2020 10:36 AM
Sub
ject: [EXTERNAL] City of Orange Housing Element Update - Virtual Workshop

Good morning,
The
City of Orange is updating the Housing Element and you are invited to be part of the process. In order for the Housing Element to serve the community well, we can't do this alone. We need to hear from service providers like you. Please join us in planning for the future housing in Orange. Visit the City's Housing Element Update webpage (https://www.cityoforange.org/1956/Housing-Element- Update) to learn more and for opportunities to share your ho using priorities and experiences.

320
Since the pandemic makes it difficult to meet in person, we’ve developed a survey to begin the conversation community, which you can access on the City's Housing Element Update webpage. There is also an informational presentation on the 2021-2029 Housing Element Update, as well as a Fact Sheet to provide you information about the Housing Element and the City’s update process.

We welcome input from service providers, community organizers, and advocacy groups that are actively working on furthering housing solutions for those with life circumstances that make housing access and stability hard to achieve. We anticipate reaching out again next month to engage in focused stakeholder meetings.

We hope you pass along this information to others you think would want to provide input on the future of housing in the City of Orange and we look forward to hearing from you.

Regards,

Ashley Brodkin
Associate Planner
Community Development Department

E-mail correspondence, along with any attachments, may be subject to the California Public Records Act; and as such may be subject to public disclosure unless otherwise exempt under the Act.

E-mail correspondence, along with any attachments, may be subject to the California Public Records Act; and as such may be subject to public disclosure unless otherwise exempt under the Act.
321
From: Chen, Nick
Sent: Wednesday, May 19, 2021 4:52 PM
To: Galmiche, Ines
Subject: FW: Additional Comments Regarding Housing Element Survey

Nicholas Che n, AICP
Kimley-Horn |

Co
nnect with us: Twitter | LinkedIn | Facebook | Instagram | Ki mley-Horn.com Celebrating 13 years as one of FORTUNE’s 100 Best Companies to Work For

Fr
om: Ashley Brodkin
Sent: Wednesday, November 18, 2020 7:51 AM
To: Chen, Nick
Cc: Mendoza, Molly
Subject: FW: Additional Comments Regarding Housing Element Survey

Public comment on Housing Element.

As
hley Brodkin

From: Bonnie Robinson < >
S
ent: Sunday, November 15, 2020 5:13 PM
To
: Ashley Brodkin >
Subject: Additional Comments Regarding Housing Element Survey

De
ar Associate Planner Brodkin,

I completed the city's Housing Element Survey a few days ago, along with some comments. I have a few additional comments that I would like to make and have considered when the Housing Element is updated.

It is briefly mentioned in the current Housing Element Document that, "The City will work to improve the quality of life for all residents by providing residential, commercial, industrial, and public uses that exist in harmony with the surrounding urban and natural environments." It also states, #5. "Environmental Protection. All projects shall be evaluated in accordance with the provisions of the California Environmental Quality Act. #5a Projects shall minimize the disruption of existing natural features such as vegetation, topography and ground features." The Housing Element Plan also goes on to address flooding and wildfire issues.

322
These continue to be extremely important issues that should be included in the updated Housing Element Plan and the guidelines followed by our City Planners, Planning Commissioners and City Council. With the continued development and infill throughout Orange and adjacent communities, it is imperative that we protect the remaining open space and natural resources we have in Orange. Areas that are currently zoned Resource/Agricultural, but designated Open Space in our City Plans need to be maintained as Open Space to balance out the needs of the wild species that inhabit them and the recreational and natural space needs of the residents of Orange. Just as the former Sully Miller property should not serve as a site for housing, except where previously zoned (28 homes), the area downstream from that site at 1425 N. Santiago Blvd should not be subjected to an engineered fill and grading that would destroy the natural and treasured habitat of that site. It is not an appropriate site for future housing and nothing should be done to threaten its current natural state.

There was one question on the survey regarding flexibility. I would like to clarify my response. In regards to building standards, I don't believe there should be flexibility. The standards have been written for the safety of future residents and businesses. As far as Mixed Use Developments, some flexibility is required in the types of buildings allowed to accomodate the needs of a site that mixes businesses with homes or offices.

Finally, the City of Orange should be doing everything in its power to build homes that are sustainable and that will contribute to improving our climate environment such as requiring solar on all new construction, using proper insulation that assists us in conserving resources and using sustainable, non polluting building materials, as well as including infrastructure that supports the use of renewable energy.

Thank you for the opportunity to provide input for the update of the Housing Element through the survey and these comments. I hope survey responses and comments will be seriously considered to help our community move forward in a way that is healthy, inviting and sustainable.

Sincerely,
Bonnie Robinson

E-mail correspondence, along with any attachments, may be subject to the California Public Records Act; and as such may be subject to public disclosure unless otherwise exempt under the Act.
323
From: Chen, Nick
Sent: Wednesday, May 19, 2021 4:52 PM
To: Galmiche, Ines
Subject: FW: City of Orange Housing Element Update - Virtual Workshop

Nicholas Che n, AICP
Kimley-Horn |

Co
nnect with us: Twitter | LinkedIn | Facebook | Instagram | Ki mley-Horn.com Celebrating 13 years as one of FORTUNE’s 100 Best Companies to Work For

Fr
om: Ashley Brodkin
Sent: Wednesday, October 14, 2020 8:16 AM
To: Chen, Nick
Cc: Mendoza, Molly
Sub
ject: FW: City of Orange Housing Element Update - Virtual Workshop

Please see below for correspondence with Elizabeth Handsburg from People for Housing.

As
hley Brodkin

From: Elizabeth Hansburg P4H
S
ent: Tuesday, October 13, 2020 4:58 PM
To
: Ashley Brodkin
Subject: Re: City of Orange Housing Element Update - Virtual Workshop

Sur
e, please put me on the list for stakeholder meetings. I would like to participate.

As far as general feedback, I am sure you and your staff know this, but for the record, California has a housing shortage. There are not enough homes available that low-income families, service- sector workers, and middle class professionals can afford. Only 25% of the people entitled to housing assistance in OC actually receive any. There is very little "naturally occurring affordable housing" (NOAH), older housing stock that becomes cheaper because it is old) because we have failed to allow enough new housing to be built.

The answer is to build more housing at higher densities, not just for low income people but for moderate income people, like young professionals who want to buy their first home. NIMBYism is the single greatest barrier to getting more housing built. Existing residents are resistant to new housing, density, and poor people. Housing elements (and their aligned zoning codes) need to identify places and where townhomes, apartments, and condos can be built with 324
minimal discretionary review. A good housing element can facilitate development in a way that minimizes opportunities for NIMBYism. It's in the city's own interest to make it's housing element, land use policies, and zoning code align to depoliticize the approval of housing development.

That's my general feedback.

On Tue, Oct 13, 2020 at 4:08 PM Ashley Brodkin wrote:

Hello Elizabeth,
Thank you for your follow up. At this time we are looking for some general information about housing needs. There is a housing survey available on our Housing Element Update webpage (https://www.cityoforange.org/1956/Housing-Element-Upda te) to provide us with information.

Additionally, we are anticipating holding stakeholder meetings next month if your organization would be interested in participating.

We anticipate additional community meetings in Spring 2021, once we complete the Public Review Draft of the Housing Element.

I look forward to hearing back from you and please let me know if I can answer any additional questions.

Regards,

Ashley Brodkin

From: Elizabeth Hansburg P4H <
Sent: Tuesday, October 13, 2020 3:36 PM
To: Ashley Brodkin <
Subject: Re: City of Orange Housing Element Update - Virtual Workshop

325
Hello, Thanks for reaching out. Are you collecting comments on a specific document, or you want a letter with our organization's priorities in general, but not in response to a specific proposal? Are you planning another community meeting?

Thank you,
--
Elizabeth Hansburg
Co-Founder & Executive Director

e.

On Mon, Oct 12, 2020 at 10:37 AM Ashley Brodkin < wrote:

Good morning,
The City of Orange is updating the Housing Element and you are invited to be part of the process.

In order for the Housing Element to serve the community well, we can't do this alone. We need to hear from advocacy groups like yours. Please join us in planning for the future housing in Orange. Visit the City's Housing Element Update webpage (https://www.cityoforange.org/1956/Housing-Element-Upda te) to learn more and for opportunities to share your housing priorities and experiences.

Since the pandemic makes it difficult to meet in person, we’ve developed a survey to begin the conversation community, which you can access on the City's Housing Element Update webpage.

There is also an informational presentation on the 2021-2029 Housing Element Update, as well as a Fact Sheet to provide you information about the Housing Element and the City’s update process.
326
We welcome input from service providers, community organizers, and advocacy groups that are actively working on furthering housing solutions for those with life circumstances that make housing access and stability hard to achieve. We anticipate reaching out again next month to engage in focused stakeholder meetings.

We hope you pass along this information to others you think would want to provide input on the future of housing in the City of Orange and we look forward to hearing from you.

Regards,

Ashley Brodkin
Associate Planner
Community Development Department

E-mail correspondence, along with any attachments, may be subject to the California Public Records Act; and as such may be subject to public disclosure unless otherwise exempt under the Act.

E-mail correspondence, along with any attachments, may be subject to the California Public Records Act; and as such may be subject to public disclosure unless otherwise exempt under the Act.
327

E-mail correspondence, along with any attachments, may be subject to the California Public Records Act; and as such may be subject to public disclosure unless otherwise exempt under the Act.
328

August 17, 2020

Dear City of Orange:

St. Joseph Hospital is an acute-care not-for-profit faith-based hospital founded in 1929 by the Sisters of St. Joseph of Orange, located in the City of Orange, California. St. Joseph Hospital has 465 licensed beds, 379 of which are currently available, and a campus that is approximately 38 acres in size. The hospital’s Primary Service Area includes the cities of Orange, Santa Ana, Tustin, Anaheim, Garden Grove, Villa Park, and Westminster. Major programs and services include cardiac care, critical care, diagnostic imaging, emergency medicine, obstetrics and behavioral/psychiatric services. St.

Joseph Hospital dedicates resources to improve the health and quality of life for the communities it serves, with special emphasis on the needs of the economically poor and vulnerable.

Over the past two years, St. Joseph Hospital along with 13 other Community-based Organizations have been working together to address the issues of Economic Development, Housing, and Mental Health. In Central Orange County. The goal is to impact systemic change and determinants of health. In addition, St. Joseph Hospital has identified Homeless & Housing as one its key priorities of focus over the next three years. We will develop strategies to address lack of affordable housing under the framework of equity and racial disparities. We firmly believe that in order for communities to thrive, there must be equitable systems in place that support social consciousness, economic stability, and diverse development.

As you are aware, Housing Elements for the 6
th cycle period (2021-29) are due to the California Department of Housing and Community Development by October 2021. St. Joseph Hospital understands the importance of each city’s Housing Element in guiding housing programs, policies, zoning, and funding, as well as in reducing current obstacles to affordable housing development. We also understand the importance of Housing Elements in addressing racial equity in housing, particularly with the new statutory requirements mandating the inclusion of programs that affirmatively further fair housing in 6
th cycle Housing Elements.¹ Together with local housing advocate groups, we support their efforts on ensuring that each jurisdiction increases affordable housing opportunities by implementing proven strategies, policies, and incentives that encourage affordable housing development.

St. Joseph Hospital seeks to ensure that jurisdictions engage the public in revising their Housing Elements. Public engagement is a necessary component of the Housing Element process as California Housing Element law states: “The local government shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element…” Broad participation and true engagement of the public increases the likelihood that the community members involved in the discussion and planning processes will support new housing strategies and housing developments. Public engagement should include participation from residents of diverse communities, housing consumers, service providers, and advocates.

As the City embarks upon the 2021-29 Housing Element update, St. Joseph Hospital requests that the City include us and our local housing advocates in the upcoming Housing Element review and evaluation of the current 5 th cycle planning
period goals, policies, and accomplishments.

St. Joseph Hospital further requests that the City conduct a robust public participation process for the 6th cycle Housing Element update and that it incorporate St. Joseph Hospital, affordable housing advocates, and residents of low-income communities in this process. We believe that you will achieve a stronger Housing Element update through diverse community participation, outreach and community planning process.

329
To ensure adequate public participation St. Joseph Hospital recommends the following:

1. The City should engage community participation and feedback at all stages of the Housing Element review and update. Participation should not be limited to public hearings.

2. The City should allow for various methods of engagement to encourage public participation. For instance, for members of the public who may not have access to the internet or a computer, or who are unable to use video applications, consistently provide an adequate telephone option – available in multiple languages – and generally ensure that members of the community who lack adequate technology can participate in meetings about the Housing Element review.

3. The City’s public participation and outreach opportunities should be meaningful and create various platforms (for example, virtual, written, workshops, webinars, community meetings, and public hearings) for the engagement of community members who reside in lower-income communities, affordable housing partners, Legal Aid organizations, and advocates.

4. The City should create a diverse Housing Element Working Group to evaluate the current Housing Element policies and accomplishments. This Working Group could help create policies and recommendations for the new Housing Element update to ensure that you meet the housing needs of those who are most vulnerable in the City.

5. The City should include affordable housing advocates in any anticipated Housing Element Work Group and provide the opportunity for them to provide their analysis on 5 th cycle RHNA progress and be a part of
developing policy recommendations on the 6th cycle update.

6. The City should engage community organizations representing and advocating for families and individuals residing in lower-income communities to ensure that members of these communities can directly participate and that the City considers their perspective as part of the evaluation and creation of policies that create affordable housing.

We would appreciate the City giving us notice of any public meetings regarding the Housing Element. We look forward to working with the City 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
Sincerely,

Cec
ilia Bustamante Pixa, MPH, MHCML
Director, Community Health Investment

¹California Government Code § 8899.50 (Assembly Bill 686). 330
Appendix D: Glossary of Housing Terms
331

Appendix D: Glossary of Housing Terms D-2
2021-2029 Housing Element Update - Draft
Glossary of Housing Terms
Above-Moderate-Income Household. A household with an annual income usually greater than 120% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available legibility limits established by the U.S. Department of housing and Urban Development (HUD) for the Section 8 housing program.

Affirmatively Furthering Fair Housing (AFFH): Affirmatively Furthering Fair Housing (AFFH) is a legal requirement that federal agencies and federal grantees further the purposes of the Fair Housing Act. AFFH means "taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. Specifically, affirmatively furthering fair housing means taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws.

Apartment. An apartment is one (1) or more rooms in an apartment house or dwelling occupied or intended or designated for occupancy by one (1) family for sleeping or living purposes and containing one (1) kitchen.

Assisted Housing. Generally multi-family rental housing, but sometimes single-family ownership units, whose construction, financing, sales prices, or rents have been subsidized by federal, state, or local housing programs including, but not limited to Federal state, or local housing programs including, but not limited to Federal Section 8 (new construction, substantial rehabilitation, and loan management set-asides), Federal Sections 213, 236, and 202, Federal Sections 221 (d) (3) (below-market interest rate program), Federal Sections 101 (rent supplement assistance), CDBG, FmHA Sections 515, multi-family mortgage revenue bond programs, local redevelopment and in lieu fee programs, and units developed pursuant to local inclusionary housing and density bonus programs.

Below-Market-Rate (BMR). Any housing unit specifically priced to be sold or rented to low- or moderate-income households for an amount less than the fair-market value of the unit. Both the State of California and the U.S. Department of Housing and Urban Development set standards for determining which households qualify as “low income” or “moderate income.” (2) The financing of housing at less than prevailing interest rates.

Build-Out. That level of urban development characterized by full occupancy of all developable sites in accordance with the General Plan; the maximum level of development envisioned by the General Plan. Build-out does not assume that each parcel is developed to include all floor area or housing units possible under zoning regulations.
332

Appendix D: Glossary of Housing Terms D-3
2021-2029 Housing Element Update - Draft
Community Development Block Grant (CDBG). A grant program administered by the U.S.

Department of Housing and Urban Development (HUD) on a formula basis for entitled communities and administered by the State Department of Housing and Community Development (HCD) for non-entitled jurisdictions. This grant allots money to cities and counties for housing rehabilitation and community development, including public facilities and economic development.

Condominium. A structure of two or more units, the interior spaces of which are individually owned; the balance of the property (both land and building) is owned in common by the owners of the individual units. (See “Townhouse.”)
Covenants, Conditions, and Restrictions (CC&Rs). A term used to describe restrictive limitations that may be placed on property and its use, and which usually are made a condition of holding title or lease.

Deed. A legal document which affects the transfer of ownership of real estate from the seller to the buyer.

Density Bonus. The allocation of development rights that allow a parcel to accommodate additional square footage or additional residential units beyond the maximum for which the parcel is zoned, usually in exchange for the provision or preservation of an amenity at the same site or at another location.

Density, Residential. The number of permanent residential dwelling units per acre of land. Densities specified in the General Plan may be expressed in units per gross acre or per net developable acre.

Developable Land. Land that is suitable as a location for structures and that can be developed free of hazards to, and without disruption of, or significant impact on, natural resource areas.

Down Payment. Money paid by a buyer from his own funds, as opposed to that portion of the purchase price which is financed.

Duplex. A detached building under single ownership that is designed for occupation as the residence of two families living independently of each other.

Dwelling Unit (DU). A building or portion of a building containing one or more rooms, designed for or used by one family for living or sleeping purposes, and having a separate bathroom and only one kitchen or kitchenette. See Housing Unit.

Elderly Housing. Typically, one- and two-bedroom apartments or condominiums designed to meet the needs of persons 62 years of age and older or, if more than 150 units, persons 55 years of age and older, and restricted to occupancy by them.

Emergency Shelter. A facility that provides immediate and short-term housing and supplemental services for the homeless. Shelters come in many sizes, but an optimum size is considered to be 20 333

Appendix D: Glossary of Housing Terms D-4
2021-2029 Housing Element Update - Draft
to 40 beds. Supplemental services may include food, counseling, and access to other social programs. (See “Homeless” and “Transitional Housing.”)
Extremely Low-Income Household. A household with an annual income equal to or less than 30% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Fair Market Rent. The rent, including utility allowances, determined by the United States Department of Housing and Urban Development for purposed of administering the Section 8 Program.

Family. (1) Two or more persons related by birth, marriage, or adoption [U.S. Bureau of the Census]. (2) An Individual or a group of persons living together who constitute a bona fide single-family housekeeping unit in a dwelling unit, not including a fraternity, sorority, club, or other group of persons occupying a hotel, lodging house or institution of any kind [Governor’s Office of Planning and Research, General Plan Guidelines].

General Plan. A comprehensive, long-term plan mandated by State Planning Law for the physical development of a city or county and any land outside its boundaries which, in its judgment, bears relation to its planning. The plan shall consist of seven required elements: land use, circulation, open space, conservation, housing, safety, and noise. The plan must include a statement of development policies and a diagram or diagrams illustrating the policies.

Goal. A general, overall, and ultimate purpose, aim, or end toward which the City will direct effort.

Green Building. Green or sustainable building is the practice of creating healthier and more resource-efficient models of construction, renovation, operation, maintenance, and demolition. (US Environmental Protection Agency)
Historic Preservation. The preservation of historically significant structures and neighborhoods until such time as, and in order to facilitate, restoration and rehabilitation of the building(s) to a former condition.

Historic Property. A historic property is a structure or site that has significant historic, architectural, or cultural value.

Household. All those persons—related or unrelated—who occupy a single housing unit. (See “Family.”)
Housing and Community Development Department (HCD). The State agency that has principal responsibility for assessing, planning for, and assisting communities to meet the needs of low-and moderate-income households.

Housing Element. One of the seven State-mandated elements of a local general plan, it assesses the existing and projected housing needs of all economic segments of the community, identifies 334

Appendix D: Glossary of Housing Terms D-5
2021-2029 Housing Element Update - Draft
potential sites adequate to provide the amount and kind of housing needed, and contains adopted goals, policies, and implementation programs for the preservation, improvement, and development of housing. Under State law, Housing Elements must be updated every five years.

Housing Payment. For ownership housing, this is defined as the mortgage payment, property taxes, insurance and utilities. For rental housing this is defined as rent and utilities.

Housing Ratio. The ratio of the monthly housing payment to total gross monthly income; also called Payment-to-Income Ratio or Front-End Ratio.

Housing Unit. The place of permanent or customary abode of a person or family. A housing unit may be a single-family dwelling, a multi-family dwelling, a condominium, a modular home, a mobile home, a cooperative, or any other residential unit considered real property under State law.

Housing and Urban Development, U.S. Department of (HUD). A cabinet-level department of the federal government that administers housing and community development programs.

Implementing Policies. The City’s statements of its commitments to consistent actions.

Implementation. Actions, procedures, programs, or techniques that carry out policies.

Infill Development. The development of new housing or other buildings on scattered vacant lots in a built-up area or on new building parcels created by permitted lot splits.

Jobs-Housing Balance. A ratio used to describe the adequacy of the housing supply within a defined area to meet the needs of persons working within the same area. The General Plan uses SCAG’s definition which is a job total equal to 1.2 times the number of housing units within the area under consideration.

Land Use Classification. A system for classifying and designating the appropriate use of properties.

Live-Work Units. Buildings or spaces within buildings that are used jointly for commercial and residential purposes where the residential use of the space is secondary or accessory to the primary use as a place of work.

Low-Income Household. A household with an annual income usually no greater than51%-80% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Low-income Housing Tax Credits. Tax reductions provided by the federal and State governments for investors in housing for low-income households.

Manufactured Housing. Residential structures that are constructed entirely in the factory, and which since June 15, 1976, have been regulated by the federal Manufactured Home Construction 335

Appendix D: Glossary of Housing Terms D-6
2021-2029 Housing Element Update - Draft
and Safety Standards Act of 1974 under the administration of the U.S. Department of Housing and Urban Development (HUD). (See “Mobile home” and “Modular Unit.”) Mixed-Use. Properties on which various uses, such as office, commercial, institutional, and residential, are combined in a single building or on a single site in an integrated development project with significant functional interrelationships and a coherent physical design. A “single site” may include contiguous properties.

Moderate-Income Household. A household with an annual income usually no greater than 81%- 120% of the area median family income adjusted by household size, as determined by a survey of incomes conducted by a city or a county, or in the absence of such a survey, based on the latest available eligibility limits established by the U.S. Department of Housing and Urban Development (HUD) for the Section 8 housing program.

Monthly Housing Expense. Total principal, interest, taxes, and insurance paid by the borrower on a monthly basis. Used with gross income to determine affordability.

Multiple Family Building. A detached building designed and used exclusively as a dwelling by three or more families occupying separate suites.

Ordinance. A law or regulation set forth and adopted by a governmental authority, usually a city or county.

Overcrowded Housing Unit. A housing unit in which the members of the household, or group are prevented from the enjoyment of privacy because of small room size and housing size. The U.S.

Bureau of Census defines an overcrowded housing unit as one which is occupied by more than one person per room.

Parcel. A lot or tract of land.

Planning Area. The area directly addressed by the general plan. A city’s planning area typically encompasses the city limits and potentially annexable land within its sphere of influence.

Policy. A specific statement of principle or of guiding actions that implies clear commitment but is not mandatory. A general direction that a governmental agency sets to follow, in order to meet its objectives before undertaking an action program. (See “Program.”) Poverty Level. As used by the U.S. Census, families and unrelated individuals are classified as being above or below the poverty level based on a poverty index that provides a range of income cutoffs or “poverty thresholds” varying by size of family, number of children, and age of householder. The income cutoffs are updated each year to reflect the change in the Consumer Price Index.

Program. An action, activity, or strategy carried out in response to adopted policy to achieve a specific goal or objective. Policies and programs establish the “who,” “how” and “when” for carrying out the “what” and “where” of goals and objectives. 336

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Redevelop. To demolish existing buildings; or to increase the overall floor area existing on a property; or both; irrespective of whether a change occurs in land use.

Regional. Pertaining to activities or economies at a scale greater than that of a single jurisdiction and affecting a broad geographic area.

Regional Housing Needs Assessment. A quantification by the local council of governments of existing and projected housing need, by household income group, for all localities within a region.

Rehabilitation. The repair, preservation, and/or improvement of substandard housing.

Residential. Land designated in the General Plan and zoning ordinance for building consisting of dwelling units. May be improved, vacant, or unimproved. (See “Dwelling Unit.”) Residential Care Facility. A facility that provides 24-hour care and supervision to its residents.

Residential, Multiple Family. Usually three or more dwelling units on a single site, which may be in the same or separate buildings.

Residential, Single-Family. A single dwelling unit on a building site.

Retrofit. To add materials and/or devices to an existing building or system to improve its operation, safety, or efficiency. Buildings have been retrofitted to use solar energy and to strengthen their ability to withstand earthquakes, for example.

Rezoning. An amendment to the map to effect a change in the nature, density, or intensity of uses allowed in a zoning district and/or on a designated parcel or land area.

Second Unit. A self-contained living unit, either attached to or detached from, and in addition to, the primary residential unit on a single lot. “Granny Flat” is one type of second unit.

Section 8 Rental Assistance Program. A federal (HUD) rent-subsidy program that is one of the main sources of federal housing assistance for low-income households. The program operates by providing “housing assistance payments” to owners, developers, and public housing agencies to make up the difference between the “Fair Market Rent” of a unit (set by HUD) and the household’s contribution toward the rent, which is calculated at 30% of the household’s adjusted gross monthly income (GMI). “Section 8” includes programs for new construction, existing housing, and substantial or moderate housing rehabilitation.

Shared Living Facility. The occupancy of a dwelling unit by persons of more than one family in order to reduce housing expenses and provide social contact, mutual support, and assistance.

Shared living facilities serving six or fewer persons are permitted in all residential districts by Section 1566.3 of the California Health and Safety Code.

Single-Family Dwelling, Attached. A dwelling unit occupied or intended for occupancy by only one household that is structurally connected with at least one other such dwelling unit. (See “Townhouse.”)
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Single-Family Dwelling, Detached. A dwelling unit occupied or intended for occupancy by only one household that is structurally independent from any other such dwelling unit or structure intended for residential or other use. (See “Family.”)
Single Room Occupancy (SRO). A single room, typically 80-250 square feet, with a sink and closet, but which requires the occupant to share a communal bathroom, shower, and kitchen.

Subsidize. To assist by payment of a sum of money or by the granting to terms or favors that reduces the need for monetary expenditures. Housing subsidies may take the forms or mortgage interest deductions or tax credits from federal and/or state income taxes, sale or lease at less than market value of land to be used for the construction of housing, payments to supplement a minimum affordable rent, and the like.

Substandard Housing. Residential dwellings that, because of their physical condition, do not provide safe and sanitary housing.

Supportive Housing. Housing with no limit on length of stay, that is occupied by the target population as defined in California Health and Safety Code Section 53260(d), and that is linked to onsite or offsite services that assist the supportive housing resident in retaining the housing, improving his or her health status, and maximizing his or her ability to live and, when possible, work in the community. “Target population" means adults with low incomes having one or more disabilities, including mental illness, HIV or AIDS, substance abuse, or other chronic health conditions, or individuals eligible for services provided under the Lanterman Developmental Disabilities Services Act and may, among other populations, include families with children, elderly persons, young adults aging out of the foster care system, individuals exiting from institutional settings, veterans, or homeless people. [California Health and Safety Code Sections 50675.14(b) and 53260(d)]
Target Areas. Specifically, designated sections of the community where loans and grants are made to bring about a specific outcome, such as the rehabilitation of housing affordable by Very- Low and Low-income households.

Tax Increment. Additional tax revenues that result from increases in property values within a redevelopment area. State law permits the tax increment to be earmarked for redevelopment purposes but requires at least 20 percent to be used to increase and improve the community’s supply of very low- and low-income housing. Anaheim currently allocates 30 percent of its tax increment to increase and improve the community’s supply of very low- and low-income housing.

Tenure. A housing unit is owner-occupied if the owner or co-owner lives in the unit, even if it is mortgaged or not fully paid for. A cooperative or condominium unit is owner-occupied only if the owner or co-owner lives in it. All other occupied units are classified as renter-occupied including units rented for cash rent and those occupied without payment of cash rent.

Townhouse. A townhouse is a dwelling unit located in a group of three (3) or more attached dwelling units with no dwelling unit located above or below another and with each dwelling unit having its own exterior entrance.
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Transitional Housing. Shelter provided to the homeless for an extended period, often as long as 18 months, and generally integrated with other social services and counseling programs to assist in the transition to self-sufficiency through the acquisition of a stable income and permanent housing. (See “Homeless” and “Emergency Shelter.”)
Undevelopable. Specific areas where topographic, geologic, and/or superficial soil conditions indicate a significant danger to future occupants and a liability to the City.

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Acronyms Used
ACS: American Community Survey
BMPs: Best Management Practices
CALTRANS: California Department of Transportation
CEQA: California Environmental Quality Act
CHAS: Comprehensive Housing Affordability Strategy
CIP: Capital Improvement Program
DDS: Department of Developmental Services
DIF: Development Impact Fee
DU/AC: Dwelling Units Per Acre
EDD: California Employment Development Department
FAR: Floor Area Ratio
FEMA: Federal Emergency Management Agency
HCD: Department of Housing and Community Development
HOA: Homeowners Association
HUD: Department of Housing and Urban Development
LAFCO: Local Agency Formation Commission
MFI: Median Family Income
NPDES: National Pollutant Discharge Elimination System
RTFH: Regional Task Force on the Homeless
RTP: Regional Transportation Plan
SCAG: Southern California Association of Governments
SPA: Sectional Planning Area
STF: Summary Tape File (U.S. Census)
TOD: Transit-Oriented Development
TDM: Transportation Demand Management
TSM: Transportation Systems Management
WCP: Water Conservation Plan

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Housing Needs, Resources, and Constraints
Affirmatively further[ing] fair housing in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A)) Enforcement and Outreach: While the element includes
key themes from outreach efforts, it must still provide data related to the number of lawsuits, enforcement
actions, settlements, or judgements related to fair
housing or civil rights. This data should be analyzed for any patterns or trends by community area or census tract and include additional local knowledge, relevant factors, and a conclusion of summary of issues. In addition, the element states that the City works with the Fair Housing Foundation to provide fair housing services. However, the analysis must also describe compliance with existing fair housing laws and regulations and include information on fair housing outreach capacity.

Section 3.I.2

Table 4-1 added to
establish goals/policies
organized by contributing
factors

Section 3.I.3
Regional information on County-wide services and fair
housing cases has been added.

Information on outreach events and resources to the
Orange community and provided in Section 3.I.2.

Added statement confirming no current and active
lawsuits, enforcement actions, settlements, or
judgments related to fair housing or civil rights.

Text Added: During the 2015-2019 reporting period, the
FHCOC staff regionally received 363 allegations of
housing discrimination and opened 179 cases where the
allegations seemed sufficiently meritorious to warrant
further investigation and/or action. FHCOC held 32
training sessions for rental property owners/managers
and also presented 16 fair housing seminars and 70
general fair housing workshops.

Text added on County Fair Housing Foundation which
handles the City’s fair housing cases and ensures the City operates consistent with State law. Services, including fair housing outreach, have been updated

A new section has been added identifying state and local fair housing laws and ways the City complies with each.

Integration and Segregation: While the element discusses its dissimilarity index and includes some information on Section 3.J Diversity index mapping has been added. Data and mapping on income, familial status, and persons with
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familiar status and persons with disabilities and does not analyze levels of segregation and integration for race and ethnicity, income, familial status, persons with disabilities for patterns and trends over time. For example, in order to the groups that experience the highest levels of
segregation, the element could provide a more detailed
categorization of potential concentrations at the block group, census track, or neighborhood level. Additionally, the element must provide regional comparison and
analyze for patterns and trends over time.
disabilities is included within the AFFH subsection of
Section 3. Additional mapping has been added to
provide trend comparisons between 2014 and 2019
(based on what is available on HCD’s AFFH Data Viewer).

Racially Concentrated Areas of Affluence (RCAAs): While the element outlines six potential RCAAs (block groups) in the City, it must provide a regional comparison and a
concluding discussion of the data to inform policies,
goals, actions, and programs.

Section 3.J.1 Regional data for Orange County has been added to Table 3-20. Policy program comparison is added in the
Section 3.L matrix.

Access to Opportunity: While the element indicates that the city is a mix of low and moderate resource to high
resource, the analysis and discussion must include
overlaps with socioeconomic patterns. For example, the
city could analyze whether low resource census tracts
overlap with higher concentrations of racial/ethnic
minorities, lower-income households, persons with
disabilities, or female-headed households.

Additionally, while the element includes tables for ROI Opportunity Indicators in the City compared to the state, it must show a regional comparison (e.g., to Orange
County and/or neighboring cities).

Lastly, the analysis must still independently address
access to opportunity for education, transportation,
economic development and environmental components.

This more complete understanding of what types of
Section 3.J.2

Section 3.L

Appendix C

Section 3.J.5

Additional analysis on demographics and housing
conditions in relation to the low opportunity census
tracts has been added. Housing Policy Action 4A
addresses the issues identified in the analysis.

County data does not exist for the ROI data. ROI data on neighboring jurisdictions has been added for
comparison.

Data and mapping on education, transportation,
economic opportunities, and environmental burdens has
been added.

A table of identified fair housing issues and relevant
policies has been added. Programs are included in the
Housing Plan that address the community’s access to
opportunities and resources.
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disparities in access to opportunity exist for what
populations and in what geographies is necessary to
identify and prioritize contributing factors to fair housing issues and formulation of goals and actions. This analysis must be conducted at a regional and local level and
should address substantial differences in access to
education, transportation, economic, environment and
other important opportunities based on socio-economic
characteristics (e.g., race, income, familial status,
disability, income, poverty). Patterns over time should be discussed as well as policies, practices, and investments that affect access to opportunity. Local data and
knowledge and other relevant factors must be
considered, including incorporating public outreach and targeted community engagement (page 34 of
affirmatively furthering fair housing (AFFH) Guidance
Memo).

Specifically, as mentioned in stakeholder comments, the City should examine low income neighborhoods and
opportunities for investment to improve the quality of life and enhance housing options in those neighborhoods and
analyze high opportunity areas and provide incentives
and programs to encourage affordable housing to be built in areas that have more amenities such as transportation, schools, parks, and healthy food options.

Appendix C includes a matrix of public comments which
identify how public comments have been addressed and
incorporated.

Section 3.J.5 added robust historical information on the City’s development patterns in disadvantaged areas as
well as past and current efforts to reinvest in these areas through use of applicable funding sources and long-
range planning efforts.

Disproportionate Housing Need: The discussion on
homelessness must be expanded to discuss local or
regional factors that have contributed to the homeless
population and assess changes over time. The analysis
does not currently consider the increase in the homeless population in the city compared to the region at large.

While the element mentions two regional shelters the
Section 2.E.7 A table with the 2022 PIT Count data has been added to Section 2: Community Profile. This shows a reduction in the number of persons experiencing homelessness for
the City and the County.

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city helps fund through the North SPA, (Buena Park
Center and Placentia Center), there is no discussion on how many beds are available to the City of Orange. The
element lists its collaboration with the police department to assist the homeless population but does not quantify or describe how this program that has been operating
since 2013 has helped persons experiencing
homelessness obtain services or long-term care towards
housing.

No beds are available in Orange. The analysis specifies that the City’s partnership helps to provide beds at the Buena Park and Placentia Centers.

Additional language and details has been added
regarding the City’s termination of its agreement with
Mary’s Kitchen and the development of a new City-run
services hub. The hub has been reviewed and approved
by a federal judge in May 2022, and it will begin food
distribution in June 2022. Additional details on funding for the Homeless Outreach Program has also been
added.

Sites Inventory: While the element was revised to
indicate where regional housing needs allocation (RHNA) sites are located relative to some socio-economic
concentrations, there is no discussion to discuss the
magnitude of the impact including the number of units by income group relative to locations or neighborhoods
within the City, including any isolation of the RHNA and then address whether sites exacerbate or improve
segregation and integration. It appears there are multiple discrepancies in this section as well that impact a
meaningful analysis of sites. For example, the element
states that 90 percent of total potential RHNA units are located within Low Resource areas (pp. 3-117) and that
much of the low and very-low income sites are in areas
with greater than 40 percent Non-White. This contradicts statements on pp. 3-111 and 3-114 where the element
states that the distribution of potential units does not disproportionately impact areas with larger
concentrations of Non-White populations and that the
proposed candidate sites are evenly dispersed which an
emphasis on locating units where there is a high level of access to public transit and services.

Section 3.J.2

Section 3.K
Language has been added noting that sites have been
identified based on availability of land and zoning and potential for future development – future development
which may also bring about additional community
resources and services to existing neighborhoods and
residents. Additionally, new affordable units in such
areas provide new housing opportunities for existing
residents without resulting in displacement.

While 90% of sites are identified within low opportunity areas, it is important to note that a majority of the City is identified as low opportunity, specifically including
denser and more developer areas of the City. Lower
income units are also included in areas with 29 to 40
percent Non-White population, in additional to greater
than 40 percent. This will provide increased access to
affordable housing for existing residents and may
provide for improved community resources and services.

Language has been revised throughout the section to
detail this, including mention of Housing Policy Actions 344
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which seek to facilitate appropriate development and
community involvement.

Contributing Factors: While the element lists contributing factors as identified by the City, these must be prioritized, giving highest priority to those factors that most limit or deny fair housing choice or access to opportunity or
negatively impact fair housing or civil rights compliance.

Section 3.L A matrix of fair housing issues and related programs, ranked by priority, has been added to the AFFH analysis.

Local Data, Knowledge, and Other Relevant Factors: The
element still lacks local knowledge and relevant factors in each of the fair housing analysis sections. Historical
governmental and nongovernmental actions must still be
analyzed. The historical context would help explain
disparities in each of the contributing factors described on pp. 3-104 and 3-105.

Section 3.J.5 Section 3.J.5 added robust historical information on the City’s development patterns in disadvantaged areas as
well as past and current efforts to reinvest in these areas through use of applicable funding sources and long-
range planning efforts.

Goals, Priorities, Metrics, and Milestones: The element did not address this finding. The element must be revised to add programmatic actions based on outcomes from a
complete analysis. Goals and actions must specifically
respond to the analysis such as addressing barriers to
integration and segregation patterns in the City and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful
enough to overcome identified patterns and trends.

Programmatic actions must have metrics and milestones
to evaluate what fair housing results will be achieved and concrete timelines for assessing progress. Actions must address housing mobility enhancement, new housing
choices and affordability in high opportunity areas, place- based strategies for community preservation and
revitalization and displacement protection. For more
guidance, please refer to the AFFH guidebook pp. 53-56.

Section 4 Programs have been updated to include specific objectives and timelines.
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Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).) The element must still be revised to include an estimation of numbers of units in need of rehabilitation of
replacement. A statement about the City’s lack of
ongoing code enforcement cases is insufficient to address this finding. The analysis could provide estimates from a recent windshield survey or sampling, estimates from
code enforcement agency, or information from
knowledgeable builders/developers, including nonprofit
housing developers and organizations.

Section 4 A total of 16 units are in need of rehabilitation, as identified in the Summary of Quantified Objectives. No
further data is available based on windshield surveys or sampling, as such a new Housing Policy Action 3E has
been added committing the City to implement a yearly
housing rehabilitation survey with potential actions
should it be deemed necessary.

An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).) The City has a regional housing need allocation (RHNA) of 3,936 housing units, of which 1,671 are for lower-income households. To address this need, the element relies on sites that are residentially zoned or in a mixed-use zone that permits residential uses. To demonstrate the
adequacy of these sites and strategies to accommodate
the City’s RHNA, the element must include complete
analyses:

General language, requirement below.

Realistic Capacity: While the element was revised to
include language from the City’s municipal code which
states that residential development is allowed in the
Urban Mix Use (UMU) zone, either as part of a mixed-use project or as a freestanding use, the capacity
methodology must still account for the likelihood of
residential development on sites proposed in the UMU
zone. For example, the analysis could evaluate the
number of 100 percent commercial projects proposed in
Appendix B.B The City has had one non-residential project in the UMU zone throughout the 5th Cycle, compared to six
residential projects. Language to that effect has been
added to note the high likelihood of developing future
residential projects in the UMU zone.
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the last planning period in the UMU zone and compare to the number of projects with residential.

Suitability of Nonvacant Sites: Additionally, while the element was revised to detail the existing uses on the
site, the analysis must still demonstrate the site potential for redevelopment. While the element indicates key
indicators for consideration of appropriateness of sites, it does not support reasons why these indicators were
selected and how they demonstrate the potential for new residential development on the selected sites. In addition, these factors all related to potential market factors but do not relate to whether the existing uses on selected
sites are likely to impede new residential development.

For example, the element could analyze and discuss why
the charter school is likely to redevelop into residential or expand data and discussion on market trends regarding
the discontinuation of existing uses for big box retail stores like Best Buy. The element could also relate the characteristics of the projects listed on Table B-2 to the characteristics of sites within the inventory. As stated in the previous review, the element could also consider
indicators such as age and condition of the existing
structure expressed developer interest, low improvement to land value ratio, and other factors. For existing malls, while the element lists regional malls within the County that have recently completed planning and entitlement
efforts to permit residential uses, the element must still clarify what similar characteristics these malls have with the Outlets at Orange that make such a comparison
meaningful. Lastly, while the City stated it removed all UC Regent’s owned cites, the UCI MDA ALS Clinic still remains in the sites inventory. If the site remains, the element must indicate whether this site is expected to be put on a Section 3.E.4

Appendix B, Section B.B
UCI MDA ALS Clinic site has been removed.

Non-Vacant Development Scenarios analysis added with
four project examples and descriptions.

Updated to include additional analysis and comparative
characteristics for the Outlets property as well as
information on recent development activity for
residential uses and local developer interest.

ADD TO RESOLUTION:

WHEREAS, based on a variety of factors including
development trends, property owner
interest, structure age, property valuation, and
development capacity, the existing uses on the
sites identified in the site inventory to accommodate
the lower-income RHNA are likely to be
discontinued during the planning period, and
therefore do not constitute an impediment to
additional residential development during the period
covered by the Housing Element; and

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surplus list or if conversations with the Regents has
occurred related to potential residential development.

The housing element relies upon nonvacant sites to
accommodate more than 50 percent of the RHNA for
lower-income households, therefore the element must
demonstrate that the existing uses are not an
impediment to additional residential development in the planning period. (Gov. Code, § 65583.2, subd. (g)(2).)
Absent findings (e.g., adoption resolution) based on
substantial evidence, the existing uses will be presumed to impede additional residential development and will
not be utilized toward demonstrating adequate sites to
accommodate the regional housing need allocation. HCD
is not aware that the City has made the appropriate
finding. Any future re-adoption of the housing element
must include the appropriate finding as part of the
adoption resolution.

Emergency Shelters: While the element was
revised to provide information on Section

17.13.040 of the City’s municipal code as it
relates to emergency shelters, these standards
must be thoroughly analyzed for constraints and
an assessment should be made whether these
hinder the development of emergency shelters in
the M-1 and M-2 zones and for consistency with
Government Code section 65583, subdivision
(a)(4)(A). For example, the requirement that
emergency shelters be at least 500 feet from any
public institutions, not near parks, and must be
located within half mile of a transit stop are
outside the scope of allowable standards relating
to siting of emergency shelters. The element
Section 4 Housing Policy Action 4J has been added to updated the Homeless Shelter siting requirements in accordance with State law. Language has also been added to Section

3.B.6 noting the addition of the program to ensure
compliance with State law.
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must include a program to amend the zoning
ordinance to ensure consistency with state law.

Accessory Dwelling Units: The element did not address
this finding. The element shows that accessory dwelling units (ADUs) are conditionally permitted in R-1 through R- 5 zones, but ADUs should be permitted in all zones that allow residential.

Section 4

Section 3.B.6
Policy Action 2J has been updated to include the update of the City’s Municipal Code to permit ADUs and JADUs
in all zones which permit residential uses.

A note has been included in Section 3.B.6 noting where
ADUs and JADUs are currently permitted and how Policy
Action 2J will update this.

An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures.(Gov. Code, § 65583, subd. (a)(5).) Processing and Permit Procedures: While the element
was revised to include general permit processing
timeframes for single and multi-family projects on pp. 3- 42, it must still analyze this process for constraints by discussing the approval procedure and considerations, as well as discuss types of permitting, level of reviews, and an analysis on impacts on the cost of housing affordability and supply. Please see HCD’s prior review dated
September 13, 2021 for more information.

Section 3.B.11 Additional data on the City’s review processes and procedures has been added and found not to be a
constraint.

The following lists out the permitting process and review periods:

1. Application submitted;

2. Staff Review Committee provides comments or
application deemed complete (30 days or less);

3. Staff Review Committee reviews response to
comments, if applicable (30 days or less);

4. Design review Committee meeting scheduled
and staff report prepared. Oversight is limited to
confirmation objective design standards for
applicable projects under State law (30 days or
less);

5. Planning Commission meeting scheduled, staff
report and resolution prepared. Oversight is
limited to confirmation of objective design
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standards for applicable projects under State
law (30 days or less);

6. Building plan check submittal – may occur at-risk
subsequent to Design Review Committee
meeting or sooner if authorized by the
Community Development Director; followed by,

7. Staff review of building plans and corrections
provided (20 working days or less per
submittal/resubmittal).

Design Review: While the element was revised to state
that Housing Policy Actions 2E and 2L include provisions to evaluate current processing procedures and review the feasibility of additional regulatory relief such as objective development standards, the element must still describe
and analyze the current design review guidelines and
process. Please see HCD’s prior review dated September
13, 2021 for more information.

Section 3.B.11

Language added on findings analysis added.

Additional information on the design review process and findings have been added. No proposed projects going
through the site plan and design review processes have
been denied based on not being able to meet the stated
findings within the last planning period.

Added text: Design review Committee meeting
scheduled and staff report prepared. Oversight is limited to confirmation objective design standards for applicable projects under State law (30 days or less);
Zoning and Fees Transparency: This finding was not met.

Please see HCD’s prior review dated September 13, 2021
for more information.

Previous Text: The element must clarify its compliance
with new transparency requirements for posting all
zoning and development standards for each parcel on the jurisdiction’s website pursuant to Government Code
section 65940.1, subdivision (a), paragraph (1).

Section 3.B.3 and 3.B.8

Added statement that development standards are
posted site inventory on website with zoning
information. Statement saying City is complying with
state posting law.

 Table 3-3 listing all applicable development
standards from City’s code posted on their
website as well as explanation of each
development standard
 Table 3-4 lists all parking requirements
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 Table 3-5 lists PUD development standards (not
being proposed here but may be applicable on a
future site
 Table 3-6 lists all permitted uses

An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).) The element did not address this finding. The element
must be revised to include analysis of requests to develop housing at densities below those anticipated, and the
length of time between receiving approval for a housing development and submittal of an application for building permits that potentially hinder the construction of a
locality’s share of the regional housing need. The analysis must also include an analysis regarding local efforts to address nongovernmental constraints.

Section 3. B.11

Appendix B
Information and examples of projects developing above
densities are included in the Appendix B. Timelines have also been added to Section 3.

Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov. Code, § 65583, subd. (a)(7).) While the element was revised to expand discussion on
challenges faced by the various special needs'
populations, identified resources available, and lists
organizations and agencies in the community to assist
persons experiencing homelessness, it must still state
what each of these entities' offers in terms of services and resources for persons experiencing homelessness.

Lastly, the element noted that the only shelter within city limits is a family shelter. The element should discuss
Section 2.E.7 Descriptions of each entity’s resources and services has been added. The Element includes a number of entities,
resources, and services provided for persons
experiencing homelessness.
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resources available for persons experiencing
homelessness who do not have families and could discuss adoption of policies to increase services – particularly for unaccompanied adults with disabilities or seniors.

Housing Programs
Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the Housing Element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).) Programs must still be revised to demonstrate that they will have a beneficial impact within the planning period.

Beneficial impact means specific commitment to
deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. All programs must be evaluated to ensure specific action
steps to implement policies and attain the set objectives and metrics. Programs containing unclear language (e.g., “Evaluate”; “Consider”; “Encourage”; etc.) should be
amended to include more specific and measurable
actions and deliverables should occur early in the
planning period to ensure actual housing outcomes.

Please see HCD’s prior review dated September 13, 2021
for more information.

Section 4 Specific objectives have been added to each program.

Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy units, emergency shelters, and transitional housing. (Gov. Code, § 65583, subd. (c)(1).) 352
City of Orange – HCD Response Matrix
April 2022 HCD Response Letter
HCD Comments Section/Page Number Notes
As noted in Finding A3, the element does not include a
complete site analysis, therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City must
revise programs to address zoning available to encourage a variety of housing types.

Programs have been added/modified as appropriate and
included in the notes above.

Housing Policy Action 2J and 2K: Development of ADUs:

The element is assuming production of 40 ADUs per year
for a total of 320 units within the planning period. This projection is more that the average production for the
previous four years of 29 per year. Housing Policy Action 2K monitors the production of ADUs throughout the
planning period, in order to support the increase in
production levels, Housing Policy Action 2J should include additional resources and incentives to facilitated ADU
production. As stated in the previous review this can take the form of flexible zoning requirements, development
standards, or processing and fee incentives that facilitate the creation of ADUs, such as reduced parking
requirements, fee waivers and more. Other strategies
could include developing information packets to market
ADU construction, targeted advertising of ADU
development opportunities or establishing an ADU
specialist within the planning department.

Appendix B.A Data has been added on the number of ADUs permitted in 2021 and to-date in 2022 (as of May 2022) showing
the City has received and approved an increasing
number of ADUs. Additionally, language has been added
citing all the actions taken by the City to promote and facilitate ADU development. As such, the City believes a projection of 40 ADUs annually is appropriate and well
within reach.

Program 2K commits to tracking ADUs by affordability
The Housing Element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).) The element did not address this finding. While the
element includes a number of policy actions that seek to encourage development of lower-income and special
needs housing, the element indicate projects will be
assisted primarily by applying state density bonus law
(SDBL). As stated in the prior review, the element must include a program(s) describing specific actions the City Section 4 Policy Action 4A includes the following: “Continue to follow current State Density Bonus law and further its
implementation through a Density Bonus ordinance
update.”

Housing Policy Action 2M includes actions to assist in the development of ELI units.
353
City of Orange – HCD Response Matrix
April 2022 HCD Response Letter
HCD Comments Section/Page Number Notes
will take to assist in the development of housing
affordable to lower- and moderate-income households,
including extremely low-income households (ELI). In
addition, as noted in stakeholder comments, the City
should ensure that it complies with the most current
version of State Density Bonus Law. Please see HCD’s
prior review dated September 13, 2021 for more
information.

Statement added to Table 3-17:

Note: *Extremely Low Income is calculated as 50% of the City’s Very Low Income RHNA need.

Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)
As noted in Finding(s) A4 and A5, the element requires a complete analysis of potential governmental and
nongovernmental constraints. Depending upon the
results of that analysis, the City may need to revise or add programs and address and remove or mitigate any
identified constraints.

Programs have been added/modified as appropriate and
included in the notes above.

Constraints on Housing for Persons with Disabilities:

While the element was revised to include Housing Policy Action 4F: Housing for Persons with Disabilities to be in compliance with state law, the program should specify
that revisions to the zoning ordinance will ensure barrier- free housing choices for persons with disabilities.

Section 4 – Action 4F Policy Action 4F has been updated accordingly.

Promote and affirmatively further fair housing opportunities and promote housing throughout the community or communities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability, and other characteristics protected by the California Fair Employment and Housing Act (Part 2.8 (commencing with Section 12900) of Division 3 of Title 2), Section 65008, and any other state and federal fair housing and planning law. (Gov. Code, § 65583, subd. (c)(5).) As noted in Finding A1, the element must include a
complete assessment of fair housing. Based on the
outcomes of that analysis, the element must add or
modify programs.

Programs have been added/modified as appropriate and
included in the notes above.

Public Participation
354
City of Orange – HCD Response Matrix
April 2022 HCD Response Letter
HCD Comments Section/Page Number Notes
Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the Housing Element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(9).) While the element was to include Housing Policy Action
3D (Community Outreach) to continue public outreach
throughout the planning period, it was not revised to
address this finding. As stated in the previous review, the element must include a description of how the City made a diligent effort to achieve public participation from all economic segments of the community, especially low-
and moderate-income households. The element could
describe the efforts to circulate the housing element
among low- and moderate-income households and
organizations that represent them and to involve such
groups and persons in the element throughout the
process. In addition, while the element summarizes the
public comments, it must still describe how comments
were considered and incorporated into the element.

Appendix C A table of public comments and how they have been incorporated into the document is included in Appendix
C. The appendix also includes detailed information on
what outreach was done and organizations and groups
that participated in the stakeholder outreach.

Section added on City collective efforts to outreach to low- and moderate-income households and
organizations as well as disadvantaged communities.

355
RESOLUTION NO. 11378

A RESOLUTION OF THE CITY COUNCIL
APPROVING GENERAL PLAN AMENDMENT NO.
2022- 0001 ADOPTING THE CITY OF ORANGE
2021- 2029 GENERAL PLAN HOUSING ELEMENT
APPLICANT: CITY OF ORANGE
WHEREAS, the Housing Element is one of the required chapters of the City' s General Plan, required by State law; and
WHEREAS, the City previously adoptedits 2014-2021 General Plan Housing Element in January2014; and
WHEREAS, the California Government Code( commencing with Section 65580) requires cities to review and updatetheir HousingElementsaccordingto a scheduleset forth by the California Department of Housing and Community Development( HCD); and WHEREAS, theCity alsodesirestoupdateitsHousingElementto ensurethatit accurately reflects the City' s housing policy and addressescommunity needs; and WHEREAS, the City has prepared the 2021-2029 Housing Element as an update to its previously approved Housing Element in compliance with Statelaw; and WHEREAS, thePlanningCommissionconductedoneduly advertisedpublic hearingon January3, 2022, atwhichtimeinterestedpersonshadanopportunityto testify eitherin supportof, , or opposition to, the 2021-2029 Housing Element update and recommendedunanimous approval to the City Council thereof.

NOW, THEREFORE, BE IT RESOLVED that the City Council approvesGeneral Plan Amendment No. 2022-0001, adopting the 2021-2029 General Plan Housing Element attached heretoand incorporatedherein as Exhibit A and directsstaff to implementthe policy action programs identified in the 2021-2029 Housing Element.

SECTION 1 — FINDINGS

1. TheGeneralPlan HousingElementmeetsthe requirementsof the California Government Code.

The Housing Element contains a housing needs assessment, resources and constraints analysis,reviewof pastperformance,housingpolicy actions,adequatesitesanalysis, andfair housinganalysis, consistentwith Staterequirements. The contentof the HousingElement addressescommentsprovided by the State of California Departmentof Housing and Community Development ( HCD) on the City' s 2021- 2029 Draft Housing Element. 356
Following City adoption of the 2021-2029 Housing Element, a copy will be submitted to HCD for final certification.

2. The Housing Element is generally consistent with the goals and policies stated within all othe elementsof the City' s General Plan.

TheHousingElementis consistentwith the City' s land useplan andis consistentwith the goals and policies of the remaining elementsof the GeneralPlan.

3. The Housing Element advancesthe State's housing goal of" decent housing and a suitable living environmentfor all membersof the community".

The Housing Element containsa needsassessmentdocumenting housing needsin the Orange community and establishes policy actions to meet those needs through the preservation, conservation, improvement and production of housing units in Orange. The housing policy actionsaimto provideopportunitiesfor productionof newhousingunitsfor all incomelevels, further fair housing, and also addresshousing for specialneedsgroups including seniors and largefamilies. As such, City adoptionof the HousingElementandimplementationof the housingpolicy actionsadvancethe State'shousinggoalof providing "decenthousinganda suitable living environment for all members of the community." SECTION 2 — ENVIRONMENTAL REVIEW
TheHousingElementupdateis exemptfrom the CaliforniaEnvironmentalQuality Act (CEQA) as follows: ( i) pursuantto Section15061(b)(3) of the StateCEQA Guidelines (CommonSense Exemption) becauseit canbe seenwith certainty that thereis no possibility that the proposed2021- 2029HousingElementUpdatewouldhaveasignificanteffectontheenvironment; (ii) noproperty re-zoningis neededto accommodatetheCity' sRegionalHousingNeedsAllocation, andpotential residential development densities have already been analyzed and mitigated in an earlier Environmental Impact Report (the Program Environmental Impact Report prepared for the 2010 Comprehensive General Plan Update, State Clearinghouse No. 2006031117); and( iii) pursuant to Guideline 15283, CEQA does not apply to Regional Housing Needs determinations made by a city. Forthesereasons,no furtherCEQAdocumentationis required.

ADOPTED this 8th day of February 2022.

Mark A. Murphy, Mayor, Ci of range
ATTEST:

PamelaColeman, City Clerk, City of Orange
Attachment: 6thCycleHousingElementUpdate (2021-2029)
Resolution No. 11378 2
357

STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.

CITY OF ORANGE
I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the foregoing Resolution was duly and regularly adoptedby the City Council of the City of Orange at a regular meeting thereof held on the 8th day of February 2022, by the following vote:

AYES: COiJNCILMEMBERS: Murphy, Nichols, Monaco, Barrios, Dumitru, Tavoularis, and Gutierrez
NOES: COUNCILMEMBERS: None
ABSENT: COLJNCILMEMBERS: None
ABSTAIN: COUNCILMEMBERS: None.

PamelaColeman, City Clerk, City of Orange
Resolution No. 11378 3
358
NorE
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CITY OF ORANGE
6th CYCLE HOUSING ELEMENT UPDATE
2021- 2029)
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AVAILABLE FOR REVIEW
at

CITY OF ORANGE
City Clerk Department
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300 E. Chapman Ave.

Orange, CA 92866
7l4) 744- 5500
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The above document is stored in a white binder labeled
Resolution iVo. 11378. The binder is located in the City Clerk vault, on Shelf No. 135.
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360
Agenda Item
City Council
Item #: 10.4. 2/8/2022 File #: 22-0024
TO: Honorable Mayor and Members of the City Council
THRU: Thomas R. Hatch, Interim City Manager
FROM: Susan Galvan, Interim Community Development Director

1. SUBJECT
Public Hearing to consider General Plan Amendment No. 2022-0001; City of Orange 2021-2029 Housing Element Update.

2. SUMMARY
A request to adopt an updated General Plan Housing Element in accordance with State law. The updated Housing Element replaces the 2014-2021 Housing Element in its entirety. The updated Housing Element identifies and analyzes existing and projected housing needs, plans for the long- term provision of housing for a variety of household income levels, and articulates the City’sofficial policies for the preservation, conservation, improvement, and production of housing within the City for the 2021 through 2029 planning period.

3. RECOMMENDED ACTION
Adopt City Council Resolution No. 11378. A Resolution of the City Council of the City of Orange approving General Plan Amendment No. 2022-0001 adopting the City of Orange 2021-2029 General Plan Housing Element.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community. c. Support and enhance attractive, diverse living environments.

6. DISCUSSION AND BACKGROUND
The Housing Element is one of the chapters or “elements”of the City’sGeneral Plan required by State law, establishing the City’sofficial policies related to housing. Pursuant to State law, it is also required to plan to accommodate new housing development consistent with the City’s Regional Housing Needs Assessment allocation.

The Housing Element was last updated in January 2014 and covered the 2014-2021 planning period.

State law requires the Housing Element be updated to cover the 2021-2029 planning period within 120 days of the October 15, 2021 deadline (February 12, 2022). If the City adopts the Housing Element Update by this deadline and it is certified by the State Department of Housing and City of Orange Printed on 2/3/2022Page 1 of 5
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Element Update by this deadline and it is certified by the State Department of Housing and Community Development (HCD) (i.e., deemed in compliance with State requirements) the Housing Element will not need to be updated for another eight years. If the City does not adopt the Housing Element by the deadline, or if the adopted Housing Element is not certified by the HCD, the City will continue to work with HCD to gain compliance.

If not adopted or certified, the City could be subject to legal challenges, become ineligible for certain State funding programs, be mandated to utilize a ministerial review process for entitling housing projects, or have its authority to issue building permits suspended.

Given the complex housing issues confronting California, the State has set forth high expectations for municipalities to put policies and programs in place that result in housing production at a range of affordability levels, with particular interest in housing for Very Low and Low Income households.

Draft Housing Element Content
The City of Orange 2021-2029 General Plan Housing Element identifies and analyzes the existing and projected housing needs of the Orange community and articulates the City’spolicy actions for the preservation, conservation, improvement, and production of housing units in the city. The City has been tasked by HCD through a process called the Regional Housing Needs Assessment (RHNA) to accommodate 3,936 dwelling units at varying affordability levels through new construction, development of Accessory Dwelling Units, and conservation of units at risk of converting from affordable to market rate units during the 2021-2029 timeframe. Details about the RHNA process are outlined in Attachment 3.

The Housing Element addresses State requirements as detailed in Attachment 3. The Housing Plan (Section 4) of the Housing Element update establishes four central goals supported by 31 policy actions to address the City’s housing needs. These goals include:
· Providing high quality housing stock and neighborhoods · Accommodating all income levels of the City’s RHNA allocation · Ensuring maintenance, preservation, and development of housing · Providing equal housing opportunities for all
Through implementation of the policy actions and the identification of candidate housing sites within the adequate sites analysis, the Housing Element demonstrates that the City is providing substantive opportunities and making a good-faith effort to address the housing needs of the community consistent with State law.

Key Policy Action Changes from Previous Housing Element Removed:

Certain policy actions from the 2014-2021 Housing Element have been deleted as they have either been accomplished or are no longer relevant including:
· Process annexation of the East Orange General Plan area (portions of Santiago Hills II Irvine Company property that is now dedicated open space).
· Develop an Affordable Housing Toolkit for the City’s website (completed). · Balance housing production with needs of local employers (completed through the entitlement City of Orange Printed on 2/3/2022Page 2 of 5
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· Balance housing production with needs of local employers (completed through the entitlement of hundreds of housing units within proximity to Children’sHospital Orange County, St. Joseph Hospital and UC Irvine Medical Center).

Added:
· Eliminate discretionary review process for projects on opportunity sites where at least 20% of units are affordable to low income households through establishing objective development and design standards for such projects.
· Subsidize application processing fees for residential development where all units are affordable to low and very low income households.
· Evaluate planning and development review process for streamlining opportunities. · Assist property owners with Accessory Dwelling Units (ADU). · Track ADU affordability.
· Provide local water and sewer service providers a copy of the adopted Housing Element, and collaborate on prioritizing services for new residential development. · Update the General Plan Safety Element to address updated State wildland fire and flood information.
· Integrate environmental justice content into the General Plan in compliance with SB 1000 in order to avoid concentrations of socio-economically disadvantaged populations in areas of the city with environmental challenges (exposure to sources of pollution such as transportation corridors and industrial uses).
· Conduct outreach efforts throughout the 2021-2029 timeframe to gather community input related to development of, and access to, housing with a focus on under-represented communities.
· Continue to further fair housing by taking actions to address barriers that restrict access to housing opportunities, and address discrimination and patterns of socio-economic segregation.
· Update the Density Bonus Ordinance to bring into alignment with current State law. · Update the Residential Care Facilities Ordinance to bring into alignment with current State law related to facilities with 7+ residents.
· Update the Orange Municipal Code to comply with the provisions of the State Farmworker and Employee Housing Act requirements.

Public Outreach
As part of the Housing Element Update process, the City conducted extensive public outreach activities beginning in 2019 including virtual stakeholder meetings and workshops, and an online survey. A public review draft of the Housing Element was made available from May 21 through June 21, 2021 prior to sending the document to HCD for its review and comment. More detailed City of Orange Printed on 2/3/2022Page 3 of 5
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21, 2021 prior to sending the document to HCD for its review and comment. More detailed information about the public outreach process and community feedback is provided in Attachment 3 and Appendix C of the draft Housing Element Update (Attachment 4).

7. ANALYSIS AND STATEMENT OF THE ISSUES
Issue 1: RHNA and Housing Opportunity Sites
For the 2021-2029 Housing Element cycle, the City of Orange is responsible for demonstrating the ability to construct 3,936 RHNA units, or 2% of the countywide allocation (183,861 units). The units do not have to be constructed if the market does not choose to do so, but the Housing Element must demonstrate that there is viable zoning capacity to build the allocated units. The RHNA also assigns the housing unit need by household income level. The affordability breakdown is provided below:

City of Orange Housing Needs 2021-2029
Income Category (% of County Area Median
Income)
Number of Units Percent
Very Low (21 to 50%) 1,067 27.1%
Low (51 to 80%) 604 15.3%
Moderate (81 to 120%) 677 17.2%
Above Moderate (over 120%) 1,588 40.4%
Total 3,936 100%
Note: The 2021 area median income in Orange County is $106,700.

Housing Opportunity Sites
The City’sGeneral Plan land use and zoning designations provide adequate development capacity to accommodate the RHNA in various locations of the city. All of the identified sites represent under- utilized property that either has the potential for infill development, or the possibility of entire site redevelopment. Many sites are located in areas with Urban Mixed Use or Neighborhood Mixed Use zoning (Uptown Orange, West Katella Avenue and South Main Street), while other sites are in transition with pending or active development applications that include housing. A number of housing units are also anticipated to be produced in the form of Accessory Dwelling Units or Junior Accessory Dwelling Units. Housing Opportunity Sites and likely development scenarios are presented in Appendix B of the Housing Element Update.

Summary of RHNA Status and Sites Inventory
Extremely Low/ Very Low
Income
Low Income Moderate
Income
Above
Moderate
Income
Total
2021-2029 RHNA1,067 604 677 1,588 3,936
RHNA Credit (Units Built)-- -- -- -- --
Total RHNA Obligations1,067 604 677 1,588 3,936
Sites Available
Residential Zones0 0 0 81 81
Neighborhood Mixed Use (NMU-24)16 4 114 0 134
Urban Mixed-Use (UMU)1,025 478 618 1,696 3,817
Total Potential Capacity Based on
Existing GP and Zoning
1,041 482 732 1,777 4,032
Accessory Dwelling Unit Production80 137 96 7 320
Total Sites Available1,121 619 828 1,784 4,352
Potential Unit Surplus+54 +15 +151 +196 +416
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Summary of RHNA Status and Sites Inventory
Extremely Low/ Very Low
Income
Low Income Moderate
Income
Above
Moderate
Income
Total
2021-2029 RHNA1,067 604 677 1,588 3,936
RHNA Credit (Units Built)-- -- -- -- --
Total RHNA Obligations1,067 604 677 1,588 3,936
Sites Available
Residential Zones0 0 0 81 81
Neighborhood Mixed Use (NMU-24)16 4 114 0 134
Urban Mixed-Use (UMU)1,025 478 618 1,696 3,817
Total Potential Capacity Based on
Existing GP and Zoning
1,041 482 732 1,777 4,032
Accessory Dwelling Unit Production80 137 96 7 320
Total Sites Available1,121 619 828 1,784 4,352
Potential Unit Surplus+54 +15 +151 +196 +416
The sites identified as candidate housing sites are anticipated to develop at a range of densities and affordability levels. The City anticipates continuing its work with local affordable housing developers to bring forward affordable/workforce housing projects meeting varied housing needs. Additionally, staff expects that the types of State and regional funding programs available for housing will continue to evolve, providing expanded creative financing options for affordable housing development.

Housing development, whether market rate or affordable, is largely dependent on the non-profit and private development community and the economy. The City will support and encourage the development of affordable and workforce housing projects on sites contemplated as candidate housing sites, as well as on parcels that had not been anticipated for infill residential development.

Issue 2: HCD Review
Staff submitted the Draft Housing Element for HCD review in July 2021. HCD provided comments to the City in September 2021 which are contained in Attachment 2 of the Planning Commission Staff Report (Attachment 3 to this report). Staff, with support from the City’sconsultant, has addressed these comments in the public hearing draft of the document. A matrix of HCD comments and City responses is provided in Attachment 3 of the Planning Commission Staff Report. The revised document will be re-submitted to HCD following City Council adoption in anticipation of a determination that the Housing Element Update is in compliance with State law.

7. ATTACHMENTS
· Attachment 1 Resolution No. 11378
· Attachment 2 Planning Commission Resolution No. PC 01-22 · Attachment 3 Planning Commission Staff Report and Draft Minutes, January 3, 2022 · Attachment 4 Draft 2021-2029 Housing Element Update
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Agenda Item
Planning Commission
Item #: 7.1. 1/3/2022 File #: 21-0583
TO: Chair and Members of the Planning Commission
FROM: Anna Pehoushek, Assistant Community Development Director

1. SUBJECT
Public Hearing: General Plan Amendment No. 2022-0001; City of Orange 2021-2029 Housing Element Update

2. SUMMARY
A request to adopt an updated General Plan Housing Element in accordance with state law. The updated Housing Element replaces the 2014-2021 Housing Element in its entirety. The updated Housing Element identifies and analyzes existing and projected housing needs, plans for the long- term provision of housing for a variety of household income levels and articulates the City’sofficial policies for the preservation, conservation, improvement, and production of housing within the City for the 2021 through 2029 planning period.

3. RECOMMENDED ACTION
Adopt Planning Commission Resolution No. 01-22 entitled:

A Resolution of the Planning Commission of the City of Orange recommending that the City Council approve General Plan Amendment No. 2022-0001 adopting the City of Orange 2021-2029 General Plan Housing Element.

4. AUTHORIZING GUIDELINES
Orange Municipal Code (OMC) Sections 17.08.020 and 17.10.010 authorize the Planning Commission to provide a recommendation to the City Council for amendments to the City’sGeneral Plan.

5. PROJECT BACKGROUND
The Housing Element is one of the chapters or “elements”of the City’sGeneral Plan required by State law. The Housing Element establishes the City’sofficial policies related to housing. Pursuant to state law, it is also required to plan to accommodate new housing development consistent with the City’s Regional Housing Needs Assessment allocation.

The Housing Element was last updated in January 2014 and covered the 2014 through 2021 planning period. State law requires the Housing Element be updated to cover the 2021 through 2029 planning period within 120 days of the October 15, 2021 deadline (February 12, 2022). If the City adopts the Housing Element Update by this deadline and it is certified by the State Department of Housing and Community Development (HCD) (i.e., deemed in compliance with state requirements) the Housing Element will not need to be updated for another eight years. If the City does not adopt the Housing Element by the deadline, or if the adopted Housing Element is not certified by the HCD, the City will continue to work with HCD to gain compliance. If additional edits are required, an City of Orange Printed on 12/23/2021Page 1 of 8
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the City will continue to work with HCD to gain compliance. If additional edits are required, an adopted Housing Element may need to be amended once compliance is gained.

If not adopted or certified, the City could be subject to legal challenges, become ineligible for certain state funding programs, be mandated to utilize a ministerial review process for entitling housing projects, or have its authority to issue building permits suspended.

Given the complex housing issues confronting California, the State has set forth high expectations for municipalities to put policies and programs in place that result in housing production at a range of affordability levels, with particular interest in housing for Very Low and Low Income households.

6. PROJECT DESCRIPTION
The City of Orange 2021-2029 General Plan Housing Element identifies and analyzes the existing and projected housing needs of the Orange community and articulates the City’spolicy actions for the preservation, conservation, improvement, and production of housing units in the City. The City has been tasked by HCD through a process called the Regional Housing Needs Assessment (RHNA) to show our viability to construct 3,936 dwelling units at varying affordability income levels. Details on the RHNA process are outlined in Issue 1 of the Analysis and Statement of Issues section of this staff report. The Quantified Objectives for the 2021-2029 planning period are to accommodate the City’s 3,936 RHNA unit allocation at varying affordability levels through new construction, development of Accessory Dwelling Units, and conservation of units at risk of converting from affordable to market rate units.

The Housing Element addresses the following content, in accordance with State requirements:
· Population and employment trends.
· Existing and projected housing needs for all income groups, including extremely low income households.
· City housing and household characteristics, including cost for housing compared to ability to pay, overcrowding, and housing conditions.
· An inventory of land reasonably viable for residential development. · Analysis of existing and potential constraints, governmental and non-governmental, upon maintenance, improvement, or development of housing for all income levels. · Housing needs of people experiencing homelessness, including identification of zoning where emergency shelters are allowed as a permitted use.
· Special housing needs: handicapped, elderly, large families, farm workers, and female-headed households.
· Opportunities for energy conservation with respect to residential development. · Identification of publicly assisted housing developments. · Units at risk of conversion to market rate housing.
· Maintenance, improvement, and development of housing. · Identification of adequate sites with required public services and facilities for a variety of housing types for all income levels.
· Strategies to assist in the development of adequate housing to meet the needs of Very Low, Low, and Moderate Income households.
· Public participation program in the formulation of Housing Element Goals, Policies, and Programs.
· Regional Housing Needs Assessment prepared by the Southern California Association of City of Orange Printed on 12/23/2021Page 2 of 8
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Governments.
· Analysis of Fair Housing, including Affirmatively Furthering Fair Housing. · Review of the effectiveness of the past Element, including the City’saccomplishments during the previous planning period.

The Housing Plan (Section 4) of the Housing Element update establishes four central goals supported by 31 policy actions to address the City’s housing needs. These goals include:
· Providing high quality housing stock and neighborhoods · Accommodating all income levels of the City’s RHNA allocation · Ensuring maintenance, preservation, and development of housing · Providing equal housing opportunities for all
Policy actions focus on:
· Acquisition/rehabilitation of housing units
· Monitoring and preserving affordable units at risk of converting to market rate units · Evaluating the housing development entitlement process · Addressing deferred property maintenance and code violations · Preserving of historic residential structures
· Promoting affordable housing
· Encouraging development of housing for large families and seniors · Facilitating infill development
· Exploring alternative funding and financing
· Providing funding support for non-profit community housing development organizations · Monitoring adequate sites for housing
· Coordinating with Chapman University to address student housing needs · Accommodating development of Accessory Dwelling Units/Junior Accessory Dwelling Units · Furthering fair housing
The complete collection of goals and policy actions is presented in Section 4 of the Housing Element update. Through implementation of the policy actions and the identification of candidate housing sites within the adequate sites analysis, the Housing Element demonstrates that the City is providing substantive opportunities and making a good-faith effort to address the housing needs of the community and fair access to housing. The policy framework and identified opportunity sites both encourage and accommodate new housing development in a manner that meets the City’sRHNA allocation and is consistent with state law.

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Public Outreach
As part of the Housing Element Update process, the City conducted extensive public outreach activities beginning in 2019. These efforts included:
· Establishing a Housing Element Update webpage with all housing element materials and information.
· Two stakeholder meetings (English and Spanish) on December 1, 2020 engaging service providers, housing advocacy groups, developers, church representatives, and similar entities that provide support services to individuals with housing needs. · Virtual Community Workshops on October 12, 2020 and May 26, 2021 with recordings available on the webpage.
· An online Community Survey available from October 12, 2020 to December 1, 2020.

A public review draft of the Housing Element was made available from May 21 through June 21, 2021 on the City’swebsite prior to sending the document to HCD for its review and comment. The content of the draft Housing Element considers the input provided during this process. More detailed information about the public outreach process and community feedback is provided in Appendix C of the draft Housing Element Update (Attachment 1).

7. ANALYSIS AND STATEMENT OF THE ISSUES
Issue 1: Regional Housing Needs Allocation
RHNA allocation is derived from a regional housing goal that HCD supplies to the Southern California Association of Governments (SCAG), the metropolitan planning agency that coordinates regional planning activity for the six counties comprising Southern California. Once HCD establishes the regional housing goal, SCAG is then required to allocate a portion of the overall housing units for the region to each city and county jurisdiction in the region based on a complex methodology that incorporates factors such as housing market demand, employment opportunities, community patterns, concentrations of low-income households, and more.

For the 2021-2029 Housing Element cycle, 183,861 RHNA units are allocated throughout all jurisdictions in Orange County. Of those units, the City of Orange is responsible for demonstrating the ability to construct 3,936 RHNA units, or 2% of the County allocation. The units do not have to be constructed if the market does not choose to do so, but our 2021-2029 Housing Element must demonstrate that we have viable zoning capacity to build our RHNA allocated units. The 3,936 units of this 2021-2029 RHNA cycle assigned to Orange represents a significant increase over the 2014- 2021 RHNA which required Orange to demonstrate the ability to accommodate only 363 units. In addition to identifying a total number of housing units needed during the planning period, the RHNA also assigns the housing unit need by household income level. The affordability breakdown for the City’s RHNA is provided below:

City of Orange Housing Needs 2021-2029
Income Category (% of County Area Median
Income)
Number of Units Percent
Very Low (21 to 50%) 1,067 27.1%
Low (51 to 80%) 604 15.3%
Moderate (81 to 120%) 677 17.2%
Above Moderate (over 120%) 1,588 40.4%
Total 3,936 100%
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City of Orange Housing Needs 2021-2029
Income Category (% of County Area Median
Income)
Number of Units Percent
Very Low (21 to 50%) 1,067 27.1%
Low (51 to 80%) 604 15.3%
Moderate (81 to 120%) 677 17.2%
Above Moderate (over 120%) 1,588 40.4%
Total 3,936 100%
Note: The 2021 area median income in Orange County is $106,700.

Housing Opportunity Sites
The City’sGeneral Plan land use and zoning designations provide adequate development capacity to accommodate the City’sRHNA in various locations of the City. All of the identified sites represent under-utilized property that either has the potential for infill development, or the possibility of entire site redevelopment. Many of the sites are located in portions of Orange with Urban Mixed Use or Neighborhood Mixed Use zoning, while others are sites in transition with pending or active development applications that include housing. The City also anticipates that a number of housing units will be produced in the form of Accessory Dwelling Units or Junior Accessory Dwelling Units.

Housing Opportunity Sites and likely development scenarios are presented in Appendix B of the Housing Element Update.

Summary of RHNA Status and Sites Inventory
Extremely Low/ Very Low
Income
Low Income Moderate
Income
Above
Moderate
Income
Total
2021-2029 RHNA1,067 604 677 1,588 3,936
RHNA Credit (Units Built)-- -- -- -- --
Total RHNA Obligations1,067 604 677 1,588 3,936
Sites Available
Residential Zones0 0 0 81 81
Neighborhood Mixed Use (NMU-24)16 4 114 0 134
Urban Mixed-Use (UMU)1,025 478 618 1,696 3,817
Total Potential Capacity Based on
Existing GP and Zoning
1,041 482 732 1,777 4,032
Accessory Dwelling Unit Production80 137 96 7 320
Total Sites Available1,121 619 828 1,784 4,352
Potential Unit Surplus+54 +15 +151 +196 +416
Housing Affordability
The sites identified as candidate housing sites are anticipated to develop at a range of affordability levels. Where sites have General Plan and Zoning designations that allow over 30 units per acre, HCD acknowledges that greater affordability can be achieved in projects developed at this “default density”or higher. Sites meeting the “defaultdensity”are located in Uptown Orange in the vicinity of City of Orange Printed on 12/23/2021Page 5 of 8
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the Outlets at Orange, and on West Katella Avenue.

In addition to the “defaultdensity”sites, the City of Orange benefits from long-standing relationships with local affordable housing developers who have a proven track record in Orange of bringing forward affordable housing units for families and senior citizens. Four such projects are currently in process, which the City anticipates will qualify with HCD towards fulfilling our 2021-2029 affordable RHNA categories. The proposed Housing Element Update anticipates continued work with these entities to continue to bring forward affordable/workforce housing projects meeting varied housing needs.

State and regional funding programs available for housing are presently expanding. Therefore, staff is speculating that tax incentives and a variety of creative funding sources will continue to evolve to encourage and facilitate affordable housing development. While the City receives relatively limited federal housing funds (HOME program), it will continue to accumulate its annual allocation in order to ultimately offer these funds to assist affordable housing projects in the community. Recent projects that have received HOME funds or involved creative financing include the entitled Corp Yard housing project on Struck Avenue and the Orange Senior Housing project on Katella Avenue.

During the 2014-2021 Housing Element cycle, 1,950 units were built in relation to the City’s393 unit RHNA. The constructed units satisfied the identified housing unit need at nearly all of the income levels except for Very Low Income, for which 74 of the 83 unit need remain unmet.

Because the City has limited funding available to offer to affordable housing developers, and cannot look to redevelopment funds to incentivize development of affordable housing, it is dependent on the non-profit or private development community to bring forward affordable housing projects. Similarly, because the City does not have significant surplus property, it is not typically able to incentivize affordable housing projects by providing land. Therefore, housing development, whether market rate or affordable, is largely dependent on the development community and the economy.

Staff anticipates that affordable and workforce housing projects will continue to materialize in coming years, and are likely to occur on both sites contemplated in the Housing Element Update as candidate housing sites, as well as on parcels that had not been anticipated for infill residential development.

Issue 2: Policy Document Review and Updates
Changes in state law require the City to review and update, as necessary, its policy documents to bring various development disciplines into alignment with each other. There are four areas where follow up work on various policy documents will be necessary. Specifically:
· SB 1035 requires the City to identify flood hazards and address fire risk on residential property. Staff is presently undertaking a review of the General Plan Safety Element and anticipates bringing the item forward for Council consideration in the first quarter of 2022. · SB 1000 requires that the City include an environmental justice component to its General Plan. Staff intends to perform a review of the existing General Plan to determine where environmental justice content is currently addressed and where amendments may be needed to integrate additional language that addresses state law. · In conjunction with furthering fair housing opportunities through outreach and education, the City will update its Density Bonus ordinance to be consistent with state law. · To facilitate housing production and create more opportunities for housing development, the City of Orange Printed on 12/23/2021Page 6 of 8
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· To facilitate housing production and create more opportunities for housing development, the City recently adopted a Small Lot Subdivision Ordinance, and is presently preparing a Transfer of Development Rights Ordinance that would allow development rights to be transferred from historic district properties to Urban Mixed Use districts for purposes of increasing density on the receiver site, and a specific plan for the North Tustin Street corridor that will provide strategic opportunities for the integration of housing in that district. · In response to any changes in state law related to emergency, transitional and supportive housing, the City will review and amend the Orange Municipal Code to ensure consistency with state law.

Issue 3: HCD Review
Staff submitted the Draft Housing Element for HCD review in July 2021. HCD provided comments to the City in September 2021 (Attachment 2). Staff with support from the City’s consultant has addressed these comments in the public hearing draft of the document. A matrix of HCD comments and City responses is provided in Attachment 3 to this report. The revised document will be re- submitted to HCD in anticipation of a determination that the Housing Element Update is in compliance with State law.

8. PUBLIC NOTICE
A Public Hearing notice was published in the Anaheim Bulletin newspaper on December 23, 2021 and posted at City kiosks. Project stakeholders were also notified.

9. ENVIRONMENTAL REVIEW
The project is exempt from the California Environmental Quality Act (CEQA) as follows: (i) pursuant to Section 15061(b)(3) of the state CEQA Guidelines (Common Sense Exemption) because it can be seen with certainty that there is no possibility that the proposed 2021-2029 Housing Element Update would have a significant effect on the environment; (ii) no property re-zoning is needed to accommodate the City’sRegional Housing Needs Allocation, and potential residential development densities have already been analyzed and mitigated in an earlier Environmental Impact Report (the Program Environmental Impact Report prepared for the 2010 Comprehensive General Plan Update, State Clearinghouse No. 2006031117); (iii) pursuant to Guideline 15283, CEQA does not apply to Regional Housing Needs determinations made by a city. For these reasons, no further CEQA documentation is required.

10. ADVISORY BOARD ACTION
Not applicable. The Planning Commission is advisory to the City Council for General Plan amendments.

11. ATTACHMENTS
· Attachment 1 Planning Commission Resolution No. PC 01-22 · Attachment 2 HCD Comment Letter
· Attachment 3 HCD Response Matrix
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· Attachment 4 Draft Housing Element Update
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GENERAL PLAN AMENDMENT NO. 2022-0001

HOUSING ELEMENT UPDATE

RESOLUTION NO. PC 01-22

A RESOLUTION OF THE PLANNING

COMMISSION OF THE CITY OF ORANGE

RECOMMENDING THAT THE CITY COUNCIL
APPROVE GENERAL PLAN AMENDMENT NO.
2022-0001 ADOPTING THE CITY OF ORANGE
2021-2029 GENERAL PLAN HOUSING

ELEMENT

APPLICANT: CITY OF ORANGE

Moved by Commissioner _______ and seconded by Commissioner _______ that the following Resolution be adopted:

WHEREAS, the Planning Commission has authority per California Government Code Section 65358 and Orange Municipal Code Sections 17.08.020 and 17.10.010 to review and make recommendations to the City Council for amendments to the City’s General Plan; and

WHEREAS, the Housing Element is one of the required chapters of the City’s General Plan, required by State law; and

WHEREAS, the City previously adopted its 2014-2021 General Plan Housing Element in January 2014; and

WHEREAS, the California Government Code requires Cities to review and update their Housing Elements according to a schedule set forth by the California Department of Housing and Community Development (HCD); and

WHEREAS, the City also desires to update its Housing Element to ensure that it accurately reflects the City’s housing policy and addresses community needs; and

WHEREAS, the City has prepared the 2021-2029 Housing Element as a n update to its previously approved Housing Element in compliance with State law; and

WHEREAS, the Planning Commission conducted one duly advertised public hearing on January 3, 2022, at which time interested persons had an opportunity to testify either in support of, or opposition to, the 2021-2029 Housing Element update;

NOW, THEREFORE, BE IT RESOLVED that the Planning Commission recommends that the City Council review, consider and make certain findings pursuant to CEQA and approve 25379
Planning Commission
Resolution No. PC 01-22

General Plan Amendment No. 2021-0001, adopting the 2021-2029 General Plan Housing Element based on the findings contained in Section 1 of this Resolution.

BE IT FURTHER RESOLVED that the Planning Commission re commends that the City Council direct staff to implement the policy action programs identified in the 2021-2029 Housing Element.

SECTION 1 – FINDINGS

1. The General Plan Housing Element meets the requirements of the California Government Code.

The Housing Element contains a housing needs assessment, resources and constraints analysis, review of past performance, housing policy actions, adequate sites analysis , and fair housing analysis, consistent with State requirements. The content of the Housing Element addresses comments provided by the State of California Department of Housing and Community Development Department (HCD) on the City’s 2021-2029 Draft Housing Element. Following City adoption of the 20 21-2029 Housing Element, a copy will be submitted to HCD for final certification.

2. The Housing Element is generally consistent with the goals and policies stated within all other elements of the City’s General Plan.

The Housing Element is consistent with the City’s land use plan and is consistent with the goals and policies of the remaining elements of the General Plan.

3. The Housing Element advances the State’s housing goal of “decent housing and a suitable living environment for all members of the community”.

The Housing Element contains a needs assessment doc umenting housing needs in the Orange community and establishes policy actions to meet those needs through the preservation, conservation, improvement and production of housing units in Orange . T he housing policy actions aim to provide opportunities for production of new housing units for all income levels, further fair housing, and also address housing for special needs groups including seniors and large families. As such, City adoption of the Housing Element and implementation of the housing policy actions advances the State’s housing goal of providing “decent housing and a suitable living environment fo r all members of the community.”
SECTION 2 – ENVIRONMENTAL REVIEW
The Housing Element update is exempt from the California Environmental Quality Act (CEQA) as follows: (i) pursuant to Section 15061(b)(3) of the State CEQA Guidelines (Common Sense Exemption) because it can be seen with certainty that there is no possibility that the proposed 2021-2029 Housing Element Update would have a signific ant effect on t he environment; (ii) n o property re -zoning is needed to accommodate the City’s Re gional Housing Needs Allocation, and potential residential development densities have already been analyzed and mitigated in an 26380
Planning Commission
Resolution No. PC 01-22

earlier Environmental Impact Report (the Progra m Environmental Impact Report prepared for the 2010 Comprehensive General Plan Update, State Clearinghouse No. 2006031117) ; (iii) pursuant to Guideline 15283, CEQA does not apply to Regional Housing Needs determinations made by a city. For these reasons, no further CEQA documentation is required.

I hereby certify that the foregoing Resolution was adopted on January 3, 2022 by the Planning Commission of the City of Orange by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:

Dave Simpson, Planning Commission Chair

Date
27381
STATE OF CALIFORNIA - BUSINESS, CONSUMER SERVICES AND HOUSING AGENCY GAVIN NEWSOM, Governor

DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT

DIVISION OF HOUSING POLICY DEVELOPMENT
2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
(916) 263-2911 / FAX (916) 263-7453
www.hcd.ca.gov
September 13, 2021

Anna Pehoushek, Assistant Community Development Director Planning Division
City of Orange
300 E. Chapman Ave.

Orange, CA 92866

Dear Anna Pehoushek:

RE: Review of the City of Orange’s 6
th Cycle (2019-2021) Draft Housing Element

Thank you for submitting the City of Orange’s draft housing element received for review on July 15, 2021. Pursuant to Government Code section 65585, subdivision (b), the California Department of Housing and Community Development (HCD) is reporting the results of its review. Our review was facilitated by a telephone conversation on September 9, 2021 with you, Senior Planner Chad Ortlieb, and the City’s consultants Nick Chen and Ines Galmiche of Kimley-Horn. In addition, HCD considered comments from the Kennedy Commission; the Law Office of Richard L. Spix; and Elder Law & Disability Rights Center pursuant to Government Code section 65585, subdivision (c).

The draft element addresses many statutory requirements; however, revisions will be necessary to comply with State Housing Element Law (Article 10.6 of the Gov. Code). The enclosed Appendix describes these, and other revisions needed to comply with State Housing Element Law.

To re
main on an eight-year planning cycle, the City must adopt its housing element within 120 calendar days from the statutory due date of October 15, 2021 for Southern California Association of Governments (SCAG) localities. If adopted after this date, Government Code section 65588, subdivision (e)(4), requires the housing element be revised every four years until adopting at least two consecutive revisions by the statutory deadline. For more information on housing element adoption requirements, please visit HCD’s website at:
http://www.hcd.ca.gov/community-development/housing-element/housing-element- memos/docs/sb375_final100413.pdf.

For your information, some general plan element updates are triggered by housing element adoption. HCD reminds the County to consider timing provisions and welcomes the opportunity to provide assistance. For information, please see the Technical Advisories issued by the Governor’s Office of Planning and Research at:
28382
Anna Pehoushek, Assistant Community Development Director

http://opr.ca.gov/docs/OPR_Appendix_C_final.pdf and
http://opr.ca.gov/docs/Final_6.26.15.pdf.

Public participation in the development, adoption and implementation of the housing element is essential to effective housing planning. Throughout the housing element process, the City should continue to engage the community, including organizations that represent lower- income and special needs households, by making information regularly available and considering and incorporating comments where appropriate.

Pursuant to Government Code section 65583.3, subdivision (b), the City must utilize standards, forms, and definitions adopted by HCD when preparing the sites inventory. Please see HCD’s housing element webpage at
https://www.hcd.ca.gov/community-
development/housing-element/index.shtml for a copy of the form and instructions. The City can reach out to HCD at [email protected] for technical assistance. Upon adoption of the housing element, the City must submit an electronic version of the sites inventory with its adopted housing element to [email protected].

Several federal, state, and regional funding programs consider housing element compliance as an eligibility or ranking criteria. For example, the CalTrans Senate Bill (SB) 1 Sustainable Communities grant; the Strategic Growth Council and HCD’s Affordable Housing and Sustainable Communities programs; and HCD’s Permanent Local Housing Allocation consider housing element compliance and/or annual reporting requirements pursuant to Government Code section 65400. With a compliant housing element, the City meets housing element requirements for these and other funding sources.

We are committed to assisting the City in addressing all statutory requirements of State Housing Element Law. If you have any questions or need additional technical assistance, please contact Mashal Ayobi, of our staff, at [email protected] or (916) 776-7421.

Sincerely,

Shannan West
Land Use & Planning Unit Chief

Enclosure
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APPENDIX

CITY OF ORANGE

The following changes are necessary to bring the City’s housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change, we cite the supporting section of the Government Code.

Housing element technical assistance information is available on HCD’s website at http://www.hcd.ca.gov/community-development/housing-element/housing-element- memos.shtml. Among other resources, the housing element section contains HCD’s latest technical assistance tool, Building Blocks for Effective Housing Elements (Building Blocks), available at http://www.hcd.ca.gov/community-development/building-blocks/index.shtml and includes the Government Code addressing State Housing Element Law and other resources.

A. Review and Revision

Review the previous element to evaluate the appropriateness, effectiveness, and progress in implementation, and reflect the results of this review in the revised element. (Gov. Code, § 65588 (a) and (b).)

As part of the evaluation of programs in the past cycle (Appendix A: 5th Cycle Review), the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness).

B. Housing Needs, Resources, and Constraints

1. Affirmatively further[ing] fair housing (AFFH) in accordance with Chapter 15 (commencing with Section 8899.50) of Division 1 of Title 2…shall include an assessment of fair housing in the jurisdiction (Gov. Code, § 65583, subd. (c)(10)(A))

The element includes information on pages H-79 to H-85 on AFFH. However, additional information is required as follows:

Enforcement and Outreach: The element must include the City’s ability to provide enforcement and outreach capacity at a geographic level. Page 28 of the AFFH Guidance Memo1 states, “Wherever possible, the summary should include a discussion of fair housing enforcement and outreach (FHEO) at a geographic level appropriate to better determine any locational trends—simply reporting information at a city-wide level will not fully display patterns and impacts on protected characteristics. Examples of appropriate geographic levels include census tracts, block groups, neighborhoods, housing development, or any other sub-section of a locality.” Additionally, there are some missing required pieces of the FHEO section:

• Lawsuits

1 HCD’s AFFH Guidance Memo: https://hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 30 384

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• Enforcement actions
• Settlements
• Judgments related to fair housing or civil rights

Pursuant to page 29 of the AFFH Guidance Memo, the element should include a description of state and local fair housing laws and how the locality complies with these laws. This page gives an example list of state and local fair housing laws.

Integration and Segregation: The housing element only analyzes integration/segregation patterns & trends for race and ethnicity. Per page 31 of the AFFH Guidance Memo, “At minimum, the analysis must discuss levels of segregation and integration for race and ethnicity, income, familial status, persons with disabilities, and identify the groups that experience the highest levels of segregation.”

Racially/Ethnically Concentrated Areas of Poverty (R/ECAP): While there are no R/ECAPs in the jurisdiction, the element must describe whether there are any Racially Concentrated Areas of Affluence (RCAAs). Page 33 of the AFFH Guidance Memo gives more information about RCAAs.

Disproportionate Housing Needs: The element needs a disproportionate housing needs analysis on homelessness. Please refer to page 39 of the AFFH Guidance Memo for more information on this.

Access to Opportunity: The element discusses the overall high/low opportunity indicators based on census tract but doesn’t give an in-depth discussion of the opportunity variables nor compare to Opportunities at a regional level. Please refer to page 35 of the AFFH Guidance Memo for more info to include to strengthen this section.

In addition, the element is missing an analysis on Disparities in Access to Opportunity for Persons with Disabilities. Pages 36-38 of the AFFH Guidance Memo give more information on what’s required for this part of the analysis.

Contributing Factors: On pages 3-82 of the housing element, it mentions that the County’s Analysis of Impediments (AI) identifies the regional goals for mitigating impediments to fair housing. However, the City must create its own list of contributing factors resulting from the AFFH analysis and must prioritize them. Per page 49 of the AFFH Guidance Memo, “The housing element must include an identification and prioritization of significant contributing factors to segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing needs.”

Local Data and Knowledge and Other Relevant Factors: The element generally does not address this requirement. Although the element provides some data in the areas of Fair Housing Enforcement and Capacity, Segregation and Integration, Racially/Ethnically Concentrated Areas of Poverty (R/ECAP), Access to Opportunity, and Disproportionate Housing Needs and Displacement Risk, the City’s analysis for each of these areas must also be informed by regional and local data and knowledge 31385

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from stakeholders within the City. For example, the analysis could utilize outreach as described above through surveys, interviews, etc. from local non-profit organizations and advocacy groups engaged in housing issues. In addition, the element must include other relevant factors that contribute to fair housing issues in the jurisdiction.

For instance, the element can analyze historical governmental and nongovernmental land use, zoning, and investment practices (e.g., infrastructure) or other information and demographic trends.

Sites Inventory: The element discusses the proposed number of sites and units relative to racial segregation (p. 3-84) but must also address other components of the assessment of fair housing (e.g., R/ECAP, Access to Opportunity, Disproportionate Housing Need, including Displacement). The analysis must also include discussion of all regional housing needs allocation (RHNA) categories, including above moderate- income households, in relation to areas with a higher proportion of white residents and higher median incomes and address how the sites are identified to improve conditions (or if sites exacerbate conditions, how a program can mitigate the impact), whether the sites are isolated by income group and should be supported by local data and knowledge.

Goals, Priorities, Metrics, and Milestones: The element must be revised to add or modify goals and actions based on the outcomes of a complete analysis. Goals and actions must specifically respond to the analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and trends. Actions must have metrics and milestones as appropriate and must address housing mobility enhancement, new housing choices and affordability in high opportunity areas, place-based strategies for community preservation and revitalization and displacement protection.

2. Include an analysis and documentation of household characteristics, including level of payment compared to ability to pay, housing characteristics, including overcrowding, and housing stock condition. (Gov. Code, § 65583, subd. (a)(2).)

The element identifies the age of the housing stock (p. 2-32). However, this data is insufficient to estimate the number of units in need of rehabilitation and replacement.

The analysis could supplement this information with estimates from a recent windshield survey or sampling, estimates from the code enforcement agency, or information from knowledgeable builders/developers, including non-profit housing developers or organizations. For additional information, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing- needs/housing-stock-characteristics.shtml.

3. An inventory of land suitable and available for residential development, including vacant sites and sites having realistic and demonstrated potential for redevelopment during the planning period to meet the locality’s housing need for a designated income level, and an analysis of the relationship of zoning and public facilities and services to these sites. (Gov. Code, § 65583, subd. (a)(3).)

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The City has a RHNA of 3,936 housing units, of which 1,671 are for lower-income households. To address this need, the element relies on sites that are residentially zoned or in a mixed-use zone that permits residential uses. To demonstrate the adequacy of these sites and strategies to accommodate the City’s RHNA, the element must include complete analyses:

Realistic Capacity: For sites in commercial and mixed-use zones, the element must consider the likelihood of residential development of the estimated number of residential units determined for each site. To demonstrate the likelihood for residential development in nonresidential zones, the element could describe any performance standards mandating a specified portion of residential and any factors increasing the potential for residential development such as incentives for residential use, and residential development trends in the same nonresidential zoning districts.

For additional information, see the Building Blocks at
http://www.hcd.ca.gov/community-development/building-blocks/site-inventory- analysis/analysis-of-sites-and-zoning.shtml#zoning.

Suitability of Nonvacant Sites: While the element provides a description of existing uses on nonvacant and underutilized sites, the element needs to also analyze the extent that existing uses may impede additional residential development. For example, the element includes sites owned by the Regents of the University of California, shopping and commercial centers with active retail, and an Outlet Mall.

The element can summarize past experiences converting existing uses to higher density residential development, include current market demand for the existing use, provide analysis of existing leases or contracts that would perpetuate the existing use or prevent additional residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The element could also consider indicators such as age and condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors. In addition, the element should indicate if the sites owned by the Regents of the University of California are expected to be put on a surplus list or if conversations with the Regents have occurred related to potential residential development of this site.

For your information, if the housing element relies upon nonvacant sites to accommodate more than 50 percent of the RHNA for lower-income households, the housing element must demonstrate that the existing use is not an impediment to additional residential development in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). This can be demonstrated by providing substantial evidence that the existing use is likely to be discontinued during the planning period (Gov. Code, § 65583.2, subd. (g)(2).

Large Sites: The 1547 W Katella Ave site is 13.37 acres, and 1 City Blvd West is

11.30 acres. Sites larger than ten acres in size are deemed inadequate to accommodate housing for lower-income housing unless it is demonstrated that sites of equivalent size were successfully developed during the prior planning period for an equivalent number of lower-income housing units as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to 33387

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accommodate lower-income housing (Gov. Code, § 65583.2, subd. (c)(2)(A).). As part of this analysis the element could indicate if a part or whole of the site will be developed and how the site is expected to be redeveloped.

Accessory Dwelling Units (ADU): The element projects 320 ADUs over the planning period or approximately 40 ADUs per year over the eight-year planning period.

According to HCD records, ten units were permitted in 2018, ten were permitted in 2019, and 39 permitted in 2020. These trends do not support an assumption of 40 ADUs per year. To support assumptions for ADUs in the planning period, the element should reconcile trends with HCD records, adjust assumptions as appropriate and include additional information such as more recent permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate.

Sites with Zoning for a Variety of Housing Types:

Emergency Shelters: While the element notes emergency shelters are allowed in the M-1 and M-2 zones, it must demonstrate the City still has sufficient capacity to accommodate the identified housing need for emergency shelters and evaluate the available acreage for characteristics like parcel size or potential redevelopment or reuse opportunities, proximity to services and describe development standards.

Accessory Dwelling Units: The element should clarify whether ADUs are permitted in all zones that allow residential uses. Table 3-6 on page 3-22 appears to indicate that ADUs are only allowed in single family residential zones.

4. An analysis of potential and actual governmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the types of housing identified in paragraph (1) of subdivision (c), and for persons with disabilities as identified in the analysis pursuant to paragraph (7), including land use controls, building codes and their enforcement, site improvements, fees and other exactions required of developers, and local processing and permit procedures. The analysis shall also demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need in accordance with Government Code section 65584 and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters identified pursuant to paragraph (7). Transitional housing and supportive housing shall be considered a residential use of property and shall be subject only to those restrictions that apply to other residential dwellings of the same type in the same zone. (Gov. Code, § 65583, subd. (a)(5).)

Processing and Permitting Procedures: While the element describes the application process, it must describe and analyze the City permit processing and approval procedures by zone and housing type (e.g., multifamily rental housing, mobilehomes, housing for agricultural employees, supportive housing). The analysis must evaluate the processing and permit procedures’ impacts as potential constraints on housing supply and affordability. For example, the analysis should consider processing and approval procedures and time for typical single- and multi-family developments, 34388

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including type of permit, level of review, approval findings and any discretionary approval procedures.

Design Review: The element must describe and analyze the design review guidelines and process, including approval procedures and decision-making criteria, for their impact as potential constraints on housing supply and affordability. For example, the analysis could describe required findings and discuss whether objective standards and guidelines improve development certainty and mitigate cost impacts. The element must demonstrate this process is not a constraint or it must include a program to address this permitting requirement, as appropriate.

Zoning and Fees Transparency: The element must clarify its compliance with new transparency requirements for posting all zoning and development standards for each parcel on the jurisdiction’s website pursuant to Government Code section 65940.1, subdivision (a), paragraph (1).

Constraints on Housing for Persons with Disabilities: The element currently details that residential care facilities serving six or fewer persons are permitted in all residential zones. However, residential care facilities serving seven or more persons are limited to the same zones with the approval of a conditional use permit. The element should analyze the process as a potential constraint on housing for persons with disabilities and add or modify programs as appropriate to ensure zoning permits group homes objectively with approval certainty.

Local Ordinances: The element must specifically analyze locally adopted ordinances such as inclusionary ordinances or short-term rental ordinances that directly impact the cost and supply of residential development. The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from meeting its share of the regional housing need and from meeting the need for housing for persons with disabilities, supportive housing, transitional housing, and emergency shelters.

5. An analysis of potential and actual nongovernmental constraints upon the maintenance, improvement, or development of housing for all income levels, including the availability of financing, the price of land, the cost of construction, the requests to develop housing at densities below those anticipated in the analysis required by subdivision (c) of Government Code section 65583.2, and the length of time between receiving approval for a housing development and submittal of an application for building permits for that housing development that hinder the construction of a locality’s share of the regional housing need in accordance with Government Code section 65584. The analysis shall also demonstrate local efforts to remove nongovernmental constraints that create a gap between the locality’s planning for the development of housing for all income levels and the construction of that housing. (Gov. Code, § 65583, subd. (a)(6).)

The element must be revised to include analysis of requests to develop housing at densities below those anticipated, and the length of time between receiving approval for a housing development and submittal of an application for building permits that 35389

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potentially hinder the construction of a locality’s share of the regional housing need.

The analysis must also include an analysis regarding local efforts to address nongovernmental constraints.

6. Analyze any special housing needs such as elderly; persons with disabilities, including a developmental disability; large families; farmworkers; families with female heads of households; and families and persons in need of emergency shelter. (Gov.

Code, § 65583, subd. (a)(7).)

While the element quantifies the City’s special needs populations, it must also analyze their special housing needs. The element does not include analysis of available resources nor draw any conclusions on housing need that would lead towards programs. For a complete analysis of each population group, the element should discuss challenges faced by the population, the existing resources to meet those needs (e.g., availability senior housing units, number of large units, number of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. In particular, the element should analyze and address how the City is addressing the housing and service needs of the 341 persons identified as experiencing homelessness. It is HCD’s understanding that the City is terminating its contract with Mary’s Kitchen which provides meals and other services within the City of Orange. The element should discuss how the City will be replacing these services or filling the needs gap resulting from the of loss of Mary’s Kitchen within the City.

7. Analyze existing assisted housing developments that are eligible to change to non- low-income housing uses during the next ten years due to termination of subsidy contracts, mortgage prepayment, or expiration of use restrictions. (Gov. Code, § 65583, subd. (a)(9) through 65583(a)(9)(D).)

According to the California Housing Partnership, four properties that are at-risk:

Friendly Center (8 units), Casas Del Rio (40 units), Walnut-Pixley (Site A) (22 units), and the Knolls Apartments (260 units) of converting to market rate within a ten-year period. As a result, the element must provide an analysis on units identified as at-risk of converting to market-rate housing. The analysis of “at-risk” units must include the following (Gov. Code, § 65583, subd. (a)(9).):

• Listing of each development by project name and address • Type of governmental assistance received
• Earliest date of change from low-income use
• Total number of elderly and non-elderly units
• Estimated total cost for producing, replacing, and preserving the units at-risk • Identification of public and private non-profit corporations known to the City to have the legal and managerial capacity to acquire and manage at-risk units • Identification and consideration of use of federal, state, and local financing and subsidy programs.

For additional information and sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-development/building-blocks/housing- needs/assisted-housing-developments.shtml and for more information on identifying 36390

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units at-risk, see the California Housing Partnership Corporation at http://www.chpc.net.

C. Housing Programs

1. Include a program which sets forth a schedule of actions during the planning period, each with a timeline for implementation, which may recognize that certain programs are ongoing, such that there will be beneficial impacts of the programs within the planning period, that the local government is undertaking or intends to undertake to implement the policies and achieve the goals and objectives of the housing element through the administration of land use and development controls, the provision of regulatory concessions and incentives, and the utilization of appropriate federal and state financing and subsidy programs when available. The program shall include an identification of the agencies and officials responsible for the implementation of the various actions. (Gov. Code, § 65583, subd. (c).)

Programs must demonstrate that they will have a beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables, measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Programs containing unclear language (e.g., “Evaluate”; “Consider”; “Encourage”; etc.) should be amended to include more specific and measurable actions. Deliverables should occur early in the planning period to ensure actual housing outcomes.

To address the program requirements of Government Code section 65583, subdivision (c)(1-6), and to facilitate implementation, all programs should be revised to include: (1) a description of the City’s specific role in implementation including meaningful actions the city will take to achieve the identified goals, policies, and program objectives; (2) definitive implementation timelines (e.g., December 31, 2024); (3) objectives, quantified where appropriate; and (4) identification of responsible agencies and officials (e.g., Planning Assistant, Community Development, etc.). For example, Policy Action 1A (Acquisition/Rehabilitation of Multifamily Residential Development), Policy Action 2C (Development of Housing for Large Families), 2L (Candidate Sites Used in Previous Housing Elements) all requires specific timeframes for identified actions. In addition, the following programs require additional information:

Policy Action 2G (Support Community Housing Development Organization New Construction Projects): The element must describe how the City will seek qualified organizations and more general information on this program.

Policy Action 4B (Homeless Services). The Policy Action states the City provides support for navigation centers in Buena Park and Placentia. The element must describe how the City supports these navigation centers and how these navigation centers address and support the housing and service needs of those individuals experiencing homelessness in the City of Orange.

Policy Action 4E (Support for Persons with Disabilities): Describe how the City will support housing for persons with disabilities and work with the regional center to promote opportunities for supportive living services.

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2. Identify actions that will be taken to make sites available during the planning period with appropriate zoning and development standards and with services and facilities to accommodate that portion of the city’s or county’s share of the regional housing need for each income level that could not be accommodated on sites identified in the inventory completed pursuant to paragraph (3) of subdivision (a) without rezoning, and to comply with the requirements of Government Code section 65584.09. Sites shall be identified as needed to facilitate and encourage the development of a variety of types of housing for all income levels, including multifamily rental housing, factory-built housing, mobilehomes, housing for agricultural employees, supportive housing, single-room occupancy (SRO) units, emergency shelters, and transitional housing.
(Gov. Code, § 65583, subd. (c)(1).)

As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as follows:

Policy Action 2E (Facilitate Infill Construction): Provide a specific timeline for evaluating provisions in the Zoning Code for feasibility of providing additional regulatory relief (i.e., streamlined review, reduced and objective development standards, lot consolidations, etc.) In addition, this program could be expanded to provide specific provisions to support development of housing on the sites identified in the inventory including the redevelopment of sites with existing uses identified to accommodate the lower-income RHNA. As existing leases have been identified as a potential constraint to developing the nonvacant sites for the lower-income RHNA, the program could also monitor development on sites with existing leases as it relates to the provision of housing affordable to lower-income households and commit to the provision of additional actions as necessary to facilitate development or identify additional sites.

Policy Action 2K (Create ADU Monitoring Program): The program states that the City will monitor ADU development progress after 2 years of adopting the 6 th cycle
housing element and will take action within six months to ensure adequate capacity at each income level. The program should also commit to monitor by affordability assumptions.

3. The housing element shall contain programs which assist in the development of adequate housing to meet the needs of extremely low-, very low-, low- and moderate-income households. (Gov. Code, § 65583, subd. (c)(2).)

Policy Action 2B (Promotion of Affordable Housing) indicates the development of housing for lower- and moderate-income households will be assisted primarily by applying state density bonus law (SDBL). However, in addition to complying with SDBL, the element must include a program(s) describing specific actions the City will take to assist in the development of housing affordable to lower- and moderate- income households, including extremely low-income households (ELI). For 38392

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example, programs could prioritize some funding for the development of housing affordable to ELI households and offer financial incentives or regulatory concessions to encourage the development of a variety of housing types, such as multifamily, SRO units, and supportive housing, to address the identified housing needs for ELI households. The inclusion of specific programs to assist in the development of housing affordable to lower-income households is critical as, per third party comments received from the Kennedy Commission, the number of units affordable to moderate- and above moderate-income households approved in the last seven years was 23 times greater than those approved for low- and very low- income households.

4. Address and, where appropriate and legally possible, remove governmental and nongovernmental constraints to the maintenance, improvement, and development of housing, including housing for all income levels and housing for persons with disabilities. The program shall remove constraints to, and provide reasonable accommodations for housing designed for, intended for occupancy by, or with supportive services for, persons with disabilities. (Gov. Code, § 65583, subd. (c)(3).)

As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and nongovernmental constraints. Depending upon the results of that analysis, the City may need to revise or add programs and address and remove or mitigate any identified constraints.

8. The housing program shall preserve for low-income household the assisted housing developments identified pursuant to paragraph (9) of subdivision (a). The program for preservation of the assisted housing developments shall utilize, to the extent necessary, all available federal, state, and local financing and subsidy programs identified in paragraph (9) of subdivision (a), except where a community has other urgent needs for which alternative funding sources are not available. The program may include strategies that involve local regulation and technical assistance. (Gov.

Code, § 65583, subd. (c)(6).)

The element includes Policy Action 1B (Monitoring and Preservation of “at-risk” Units) to monitor the units and provide technical assistance. However, the element must include specific and proactive actions to preserve the at-risk units. For example, the program could support applications by non-profits for funding to purchase at-risk units, strengthen relationships with the listed non-profits and develop a plan or strategy for quickly moving forward in the case units are noticed to convert to market-rate uses in the planning period, and consider pursuing funding on at least an annual basis. The program could also commit to contacting non- profits immediately to develop a preservation strategy by a date certain and be ready to quickly act when notice of conversion is received and monitoring the units to ensure tenants receive proper notifications.

9. Develop a plan that incentivizes and promotes the creation of ADUs that can be offered at affordable rent, as defined in Section 50053 of the Health and Safety Code, for very low, low-, or moderate-income households. For purposes of this 39393

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paragraph, “accessory dwelling units” has the same meaning as “accessory dwelling unit” as defined in paragraph (4) of subdivision (i) of Section 65852.2. (Gov. Code, § 65583, subd. (c)(7).)

The element is required to include a program that incentivizes or promotes ADU development for very low-, low-, and moderate-income households. This can take the form of flexible zoning requirements, development standards, or processing and fee incentives that facilitate the creation of ADUs, such as reduced parking requirements, fee waivers and more. Other strategies could include developing information packets to market ADU construction, targeted advertising of ADU development opportunities or establishing an ADU specialist within the planning department.

D. Quantified Objectives

Establish the number of housing units, by income level, that can be constructed, rehabilitated, and conserved over a five-year time frame. (Gov. Code, § 65583, subd. (b)(1 & 2).)

The element must include quantified objectives to establish an estimate of housing units by individual income category that can be constructed, rehabilitated, and conserved over the planning period.

E. Public Participation

Local governments shall make a diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the element shall describe this effort. (Gov. Code, § 65583, subd.(c)(8).)

While the element includes a general summary of the public participation efforts, it must also demonstrate diligent efforts were made to involve all economic segments of the community in the development of the housing element. The element should be revised to discuss outreach to lower-income and special needs groups during the public participation efforts, solicitation efforts for survey responses, and participation in community workshops. In addition, the element should also summarize the public comments and describe how they were considered and incorporated into the element.

For additional information, see the Building Blocks at http://www.hcd.ca.gov/community- development/building-blocks/getting-started/public-participation.shtml. 40394
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Review and Revision
A. As part of the evaluation of programs in the past cycle (Appendix A: 5th Cycle Review), the element must
provide an explanation of the effectiveness of goals,
policies, and related actions in meeting the housing needs of special needs populations (e.g., elderly, persons with disabilities, large households, female headed households, farmworkers and persons experiencing homelessness).

Appendix A, various Policy
Actions
The following listed Policy Actions provide specific
quantified accomplishments completed by the City
between 2016 and 2020. There is no additional
information available for the following programs outside of what has been included in the document.
 Policy Action 5: Development of Housing for
Large Families
 Policy Action 6: Provision of Senior Housing
Opportunities
 Policy Action 14: Coordinate with Chapman
University to Address Student Housing
 Policy Action 16: Homeless Services
 Policy Action 18: Section 8 Rental Assistance
 Policy Action 19: Support for Persons with
Developmental Disabilities
 Policy Action 20: Single Room Occupancy Units
 Policy Action 21: Revise Ordinance to Comply
with State Law Regarding Transitional and
Supportive Housing
Housing Needs, Resources, and Constraints
B1. The element includes information on pages H-79 to H- 85 on AFFH. However, additional information is required as follows:

Enforcement and Outreach: The element must include
the City’s ability to provide enforcement and outreach
capacity at a geographic level. Page 28 of the AFFH
Guidance Memo1 states, “Wherever possible, the
summary should include a discussion of fair housing
enforcement and outreach (FHEO) at a geographic level
appropriate to better determine any locational trends—
Section 3.J (1,2, and 3)

Additional Housing Element outreach details have been
added to the Fair Housing Enforcement and Outreach
Capacity.

A statement has been added noting there are no current
fair housing cases in the City, and no data is available from the Fair Housing Foundation.

Mapping of candidate sites in relation to AFFH overlays (R/ECAP, RCAAs, and TCAC) has been added to Section
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simply reporting information at a city-wide level will not fully display patterns and impacts on protected
characteristics. Examples of appropriate geographic levels include census tracts, block groups, neighborhoods,
housing development, or any other sub-section of a
locality.” Additionally, there are some missing required pieces of the FHEO section:
 Lawsuits
 Enforcement actions
 Settlements
 Judgments related to fair housing or civil rights
Pursuant to page 29 of the AFFH Guidance Memo, the
element should include a description of state and local fair housing laws and how the locality complies with
these laws. This page gives an example list of state and local fair housing laws.

3.K – Analysis of Sites Pursuant to AB 686 – providing
geographic-level trends.

Table 1-1 includes a list of Housing Element
requirements, including AFFH requirements, and where
they are referenced throughout the Document.

B1. Integration and Segregation: The housing element
only analyzes integration/segregation patterns & trends for race and ethnicity. Per page 31 of the AFFH Guidance Memo, “At minimum, the analysis must discuss levels of
segregation and integration for race and ethnicity,
income, familial status, persons with disabilities, and identify the groups that experience the highest levels of segregation.”
Section 3.J.1 and 3.J.3

Segregation analysis is provided within Section 3.J.1.

Additional mapping and analysis has been added to
show percentages of persons with disabilities, familial statuses, and income.

B1. Racially/Ethnically Concentrated Areas of Poverty
(R/ECAP): While there are no R/ECAPs in the jurisdiction, the element must describe whether there are any Racially Concentrated Areas of Affluence (RCAAs). Page 33 of the AFFH Guidance Memo gives more information about
RCAAs.

Section 3.K A section on RCAAs has been added; it includes background, analysis, and maps illustrating ethnicity
concentrations and Median Income. RCAAs have been
identified in the City of Orange and the requisite analysis with identified census tracts has been added.

Local and regional context has also been added by
comparing the median income and population
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representation of White households versus all
households, for both the City and the County.

B1. Disproportionate Housing Needs: The element needs
a disproportionate housing needs analysis on
homelessness. Please refer to page 39 of the AFFH
Guidance Memo for more information on this.

Section 2.E.7 This analysis is included in the Community Profile Section 2.E.7. The existing section includes background on homelessness as well as local and regional context
based on the County’s Point in Time study.

Data has been added to this section to provide
demographic background on persons experiencing
homelessness – count of families, transitional age youth, race and ethnicity, and sheltered or unsheltered
homelessness.

B1. Access to Opportunity: The element discusses the
overall high/low opportunity indicators based on census tract but doesn’t give an in-depth discussion of the
opportunity variables nor compare to Opportunities at a regional level. Please refer to page 35 of the AFFH
Guidance Memo for more info to include to strengthen
this section.

In addition, the element is missing an analysis on
Disparities in Access to Opportunity for Persons with
Disabilities. Pages 36-38 of the AFFH Guidance Memo give more information on what’s required for this part of the analysis.

Section 3, Table 3-22 and
Figure 3-5

Section 3.J.5

Data and analysis has been added (Table 3-22 and Figure 3-5) providing a regional and local comparison to
opportunities.

Housing needs for persons with disabilities is detailed in depth in the Community Profile pages 2-21 to 2-24.

Additional information and mapping is provided in the
Discussion of Disproportionate Housing Needs section
on pages 3-80 to 3-81.

B1. Contributing Factors: On pages 3-82 of the housing
element, it mentions that the County’s Analysis of
Impediments (AI) identifies the regional goals for
mitigating impediments to fair housing. However, the City must create its own list of contributing factors resulting from the AFFH analysis and must prioritize them. Per
page 49 of the AFFH Guidance Memo, “The housing
element must include an identification and prioritization Section 3.H.7 Additional information on contributing factors has been added to the Affirmatively Furthering Fair Housing
Section 3.H.7. This includes the identification of 4
contributing factors.
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of significant contributing factors to segregation, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, and disproportionate housing
needs.”
B1. Local Data and Knowledge and Other Relevant
Factors: The element generally does not address this
requirement. Although the element provides some data
in the areas of Fair Housing Enforcement and Capacity,
Segregation and Integration, Racially/Ethnically
Concentrated Areas of Poverty (R/ECAP), Access to
Opportunity, and Disproportionate Housing Needs and
Displacement Risk, the City’s analysis for each of these areas must also be informed by regional and local data
and knowledge from stakeholders within the City. For
example, the analysis could utilize outreach as described above through surveys, interviews, etc. from local non- profit organizations and advocacy groups engaged in
housing issues. In addition, the element must include
other relevant factors that contribute to fair housing
issues in the jurisdiction. For instance, the element can analyze historical governmental and nongovernmental
land use, zoning, and investment practices (e.g.,
infrastructure) or other information and demographic
trends.

Section 3.H.2

Appendix C
Section 3.H.2 includes an overview on outreach that
informed the data and information used in the Housing
Element. Additional details on the outreach is provided in Appendix C.

Additional analysis on contributing factors has been
added.

B1. Sites Inventory: The element discusses the proposed number of sites and units relative to racial segregation (p. 3-84) but must also address other components of the
assessment of fair housing (e.g., R/ECAP, Access to
Opportunity, Disproportionate Housing Need, including
Displacement). The analysis must also include discussion of all regional housing needs allocation (RHNA)
categories, including above moderate-income
households, in relation to areas with a higher proportion Section 3.J.2 References to candidate sites in relation to R/ECAP, RCAAs, and Opportunity areas has been added.
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of white residents and higher median incomes and
address how the sites are identified to improve
conditions (or if sites exacerbate conditions, how a
program can mitigate the impact), whether the sites are isolated by income group and should be supported by
local data and knowledge.

B1. Goals, Priorities, Metrics, and Milestones: The
element must be revised to add or modify goals and
actions based on the outcomes of a complete analysis.

Goals and actions must specifically respond to the
analysis and to the identified and prioritized contributing factors to fair housing issues and must be significant and meaningful enough to overcome identified patterns and
trends. Actions must have metrics and milestones as
appropriate and must address housing mobility
enhancement, new housing choices and affordability in
high opportunity areas, place-based strategies for
community preservation and revitalization and
displacement protection.

Section 4, Policy Action 4A

Section 3.J.7
Section 4 includes programs which address the fair
housing issues identified in Section 3.

Contributing factors to fair housing have been identified and added in Section 3.J.7. Including the housing policy actions which address each fair housing issue.

B2. The element identifies the age of the housing stock (p. 2-32). However, this data is insufficient to estimate the number of units in need of rehabilitation and
replacement. The analysis could supplement this
information with estimates from a recent windshield
survey or sampling, estimates from the code enforcement agency, or information from knowledgeable
builders/developers, including non-profit housing
developers or organizations. For additional information, see the Building Blocks at
http://www.hcd.ca.gov/community-
development/building-blocks/housing-needs/housing-
stock-characteristics.shtml.

Section 2.F.4 A statement has been added to Section 2.F.4 noting there are currently no ongoing code enforcement cases
for units needing rehabilitation or replacing.
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B3. The City has a RHNA of 3,936 housing units, of which 1,671 are for lower-income households. To address this
need, the element relies on sites that are residentially zoned or in a mixed-use zone that permits residential
uses. To demonstrate the adequacy of these sites and
strategies to accommodate the City’s RHNA, the element
must include complete analyses:

Realistic Capacity: For sites in commercial and mixed-use zones, the element must consider the likelihood of
residential development of the estimated number of
residential units determined for each site. To
demonstrate the likelihood for residential development in nonresidential zones, the element could describe any
performance standards mandating a specified portion of
residential and any factors increasing the potential for residential development such as incentives for residential use, and residential development trends in the same
nonresidential zoning districts. For additional
information, see the Building Blocks at
http://www.hcd.ca.gov/community-
development/building-blocks/site-inventory-
analysis/analysis-of-sites-and-zoning.shtml#zoning.

Appendix B, Table B-2

Appendix B, Section B
Table B-2 describes past residential development on
Urban Mixed Use sites. Mixed-use zoned sites comprise
all of the City’s identified capacity for the lower income RHNA categories.

Added UMU zoning code language in support of
residential development for affordable units and
supporting residential as a freestanding use.

Added Chapter 17.19.060 language which requires
findings to be made for development in the UMU zone
which will maintain the City’s inventory of sites to meet its RHNA.

B3. Suitability of Nonvacant Sites: While the element
provides a description of existing uses on nonvacant and underutilized sites, the element needs to also analyze the extent that existing uses may impede additional
residential development. For example, the element
includes sites owned by the Regents of the University of California, shopping and commercial centers with active retail, and an Outlet Mall. The element can summarize
past experiences converting existing uses to higher
density residential development (Table B-2), include
Appendix B, Table B-2

Appendix B, Section B &
Table B-3
Removed UC Regents sites from sites inventory

Table B-2 contains an analysis of the City’s past
experiences converting existing uses to higher density
residential development, including the use prior to
redevelopment and a project analysis of the approved
and/or constructed project.

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current market demand for the existing use, provide
analysis of existing leases or contracts that would
perpetuate the existing use or prevent additional
residential development and include current information on development trends and market conditions in the City and relate those trends to the sites identified. The
element could also consider indicators such as age and
condition of the existing structure expressed developer interest, low improvement to land value ratio, and other factors. In addition, the element should indicate if the sites owned by the Regents of the University of California are expected to be put on a surplus list or if conversations with the Regents have occurred related to potential
residential development of this site.

For your information, if the housing element relies upon nonvacant sites to accommodate more than 50 percent
of the RHNA for lower-income households, the housing
element must demonstrate that the existing use is not an impediment to additional residential development in the planning period (Gov. Code, § 65583.2, subd. (g)(2).). This can be demonstrated by providing substantial evidence
that the existing use is likely to be discontinued during the planning period (Gov. Code, § 65583.2, subd. (g)(2).

Revised assumed density in UMU area to 55 du/ac per
analysis in Table B-2 of past development of non-vacant sites within UMU.

Added Lease Analysis, Existing Uses on Candidate Sites
and Redevelopment Opportunity, Housing Market
Analysis to Appendix B, Section B
Added analysis of improvement to land value ratio and
buildable area analysis – most sites showed lower than
10% utilization of full site based on max FAR and current use

B3. Large Sites: The 1547 W Katella Ave site is 13.37
acres, and 1 City Blvd West is 11.30 acres. Sites larger than ten acres in size are deemed inadequate to
accommodate housing for lower-income housing unless it
is demonstrated that sites of equivalent size were
successfully developed during the prior planning period for an equivalent number of lower-income housing units
as projected for the site or unless the housing element describes other evidence to HCD that the site is adequate to accommodate lower-income housing (Gov. Code, §
Appendix B, Table B-4 1547 W Katella Avenue site: Analysis at 13.37 is the net acreage (23.01 gross acres). Only considers existing
surface parking which may be put into a parking
structure to accommodate residential uses. Existing
commercial uses anticipated to remain. Anticipated net yield adjusted to be based on 9.95 acres.

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65583.2, subd. (c)(2)(A).). As part of this analysis the element could indicate if a part or whole of the site will be developed and how the site is expected to be
redeveloped.
is a past DA on this site. Anticipated net yield adjusted to be based on 9.95 acres.

Summary tables updated to reflect

B3. Accessory Dwelling Units (ADU): The element projects 320 ADUs over the planning period or approximately 40
ADUs per year over the eight-year planning period.

According to HCD records, ten units were permitted in
2018, ten were permitted in 2019, and 39 permitted in
2020. These trends do not support an assumption of 40
ADUs per year. To support assumptions for ADUs in the
planning period, the element should reconcile trends with HCD records, adjust assumptions as appropriate and
include additional information such as more recent
permitted units and inquiries, resources and incentives, other relevant factors and modify policies and programs as appropriate.

Appendix B, Section A Added the total permitted ADUs and applications for 2021.
 27 permitted in 2020
 56 permitted so far in 2021 / 64 total
applications
Also added reference in Appendix B to the Housing
Programs in Section 4.

B3. Sites with Zoning for a Variety of Housing Types:

Emergency Shelters: While the element notes emergency
shelters are allowed in the M-1 and M-2 zones, it must
demonstrate the City still has sufficient capacity to
accommodate the identified housing need for emergency
shelters and evaluate the available acreage for
characteristics like parcel size or potential redevelopment or reuse opportunities, proximity to services and describe development standards.

Accessory Dwelling Units: The element should clarify
whether ADUs are permitted in all zones that allow
residential uses. Table 3-6 on page 3-22 appears to
indicate that ADUs are only allowed in single family
residential zones.

Section 3.B.6, Table 3-6 Section 3.B.6 has been updated to include additional information on M1 and M2 zones, as well as the
requirements for emergency shelters.

ADUs updated in Table 3-6 – they are permitted in all
Residential zones.

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B4. Processing and Permitting Procedures: While the
element describes the application process, it must
describe and analyze the City permit processing and
approval procedures by zone and housing type (e.g.,
multifamily rental housing, mobilehomes, housing for
agricultural employees, supportive housing). The analysis must evaluate the processing and permit procedures’
impacts as potential constraints on housing supply and
affordability. For example, the analysis should consider processing and approval procedures and time for typical single- and multi-family developments, including type of permit, level of review, approval findings and any
discretionary approval procedures.

Section 3.B.11 General permit processing time for SFRs and MFRs has been added to Section 3.B.11.

Each housing type listed in Section 3.B.6 includes the
zones that permit the development and potential
permits required.

B4. Design Review: The element must describe and
analyze the design review guidelines and process,
including approval procedures and decision-making
criteria, for their impact as potential constraints on
housing supply and affordability. For example, the
analysis could describe required findings and discuss
whether objective standards and guidelines improve
development certainty and mitigate cost impacts. The
element must demonstrate this process is not a
constraint or it must include a program to address this permitting requirement, as appropriate.

Section 3.B.11 A statement has been added to Section 3.B.11 – Design Review to reference the programs in Section 4 noting
the City will be evaluating review procedures and
evaluate the feasibility of objective development
standards.

B4. Zoning and Fees Transparency: The element must
clarify its compliance with new transparency
requirements for posting all zoning and development
standards for each parcel on the jurisdiction’s website pursuant to Government Code section 65940.1,
subdivision (a), paragraph (1).

Section 3, Table 3-6 and
Table 3-7
A statement has been added stating the City’s Zoning is available in the Municipal Code online.

An existing statement noted the availability of
permitting fees on the City’s website.

B4. Constraints on Housing for Persons with Disabilities:

The element currently details that residential care
facilities serving six or fewer persons are permitted in all Section 4, Policy Action 4F A new Policy Action 4F has been added to amend the Municipal Code in compliance with State law.
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residential zones. However, residential care facilities serving seven or more persons are limited to the same
zones with the approval of a conditional use permit. The element should analyze the process as a potential
constraint on housing for persons with disabilities and add or modify programs as appropriate to ensure zoning
permits group homes objectively with approval certainty.

B4. Local Ordinances: The element must specifically
analyze locally adopted ordinances such as inclusionary ordinances or short-term rental ordinances that directly impact the cost and supply of residential development.

The analysis should demonstrate local efforts to remove governmental constraints that hinder the locality from
meeting its share of the regional housing need and from meeting the need for housing for persons with
disabilities, supportive housing, transitional housing, and emergency shelters.

Section 3.B.5 A new section on Local Ordinances has been added to include the existing Growth Management Measures
analysis and new analysis on the City’s Short Term
Rental Ordinance.

B5. The element must be revised to include analysis of
requests to develop housing at densities below those
anticipated, and the length of time between receiving
approval for a housing development and submittal of an
application for building permits that potentially hinder the construction of a locality’s share of the regional
housing need. The analysis must also include an analysis regarding local efforts to address nongovernmental
constraints.

Section 3.E.4 Additional information on developing at lower densities has been added to the analysis of non-vacant sites to be redeveloped for residential uses. This includes existing examples of projects proposed at lower densities but
developed at a high density due to the City’s assistance in facilitating mixed-use developments.

B6. While the element quantifies the City’s special needs populations, it must also analyze their special housing needs. The element does not include analysis of available resources nor draw any conclusions on housing need that would lead towards programs. For a complete analysis of each population group, the element should discuss
challenges faced by the population, the existing resources Section 2.E

Section 2.E.7
Additional information on resources has been added to
Section 2 for each identified special needs group.

Including City-provided resources and those provided by local community organizations.

Section 2.E.7 on persons experiencing homelessness
includes a list of organizations and agencies which
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to meet those needs (e.g., availability senior housing
units, number of large units, number of deed restricted units, etc.), an assessment of any gaps in resources, and proposed policies, programs, and funding to help address those gaps. In particular, the element should analyze and address how the City is addressing the housing and
service needs of the 341 persons identified as
experiencing homelessness. It is HCD’s understanding
that the City is terminating its contract with Mary’s
Kitchen which provides meals and other services within
the City of Orange. The element should discuss how the
City will be replacing these services or filling the needs gap resulting from the of loss of Mary’s Kitchen within the City.
provide assistance to persons experiencing
homelessness. These organizations are well suited to
cover services lost by the closure of Mary’s Kitchen.

B7. According to the California Housing Partnership, four properties that are at-risk: Friendly Center (8 units), Casas Del Rio (40 units), Walnut-Pixley (Site A) (22 units), and the Knolls Apartments (260 units) of converting to market rate within a ten-year period. As a result, the element must provide an analysis on units identified as at-risk of converting to market-rate housing. The analysis of “at- risk” units must include the following (Gov. Code, §
65583, subd. (a)(9).):
 Listing of each development by project name and
address
 Type of governmental assistance received
 Earliest date of change from low-income use
 Total number of elderly and non-elderly units
 Estimated total cost for producing, replacing, and
preserving the units at-risk
 Identification of public and private non-profit
corporations known to the City to have the legal
Section 3.J.6

Section 3, Table 3-32b
Updated the list of at-risk units. The following properties are not at-risk:
 Walnut-Prixley
 Knolls Apartments

A note has been added to Table 3-32b stating the
Friendly Center is planning on maintaining its
affordability.

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and managerial capacity to acquire and manage
at-risk units
 Identification and consideration of use of federal,
state, and local financing and subsidy programs.

For additional information and sample analysis, see the Building Blocks at http://www.hcd.ca.gov/community-
development/building-blocks/housing-needs/assisted-
housing-developments.shtml and for more information
on identifying units at-risk, see the California Housing Partnership Corporation at
http://www.chpc.net.

Housing Problems
C1. Programs must demonstrate that they will have a
beneficial impact within the planning period. Beneficial impact means specific commitment to deliverables,
measurable metrics or objectives, definitive deadlines, dates, or benchmarks for implementation. Programs
containing unclear language (e.g., “Evaluate”; “Consider”; “Encourage”; etc.) should be amended to include more
specific and measurable actions. Deliverables should
occur early in the planning period to ensure actual
housing outcomes.

To address the program requirements of Government
Code section 65583, subdivision (c)(1-6), and to facilitate implementation, all programs should be revised to
include:
(1) a description of the City’s specific role in
implementation including meaningful actions the city will take to achieve the identified goals, policies, and program objectives;
Section 4, multiple policy
actions.

Section 4, Policy Actions
2G, 4B, and 4E
Specific timeframes added to each program in Section 4.

Policy Action 2G has been updated with a reference to
the section containing the resources and entities that
may assist in preserving affordable units.

Policy Action 4B states the City provides financial
support to the Buena Park and Placentia navigation
centers for operations. This provides regional assistance to Orange County individuals experiencing
homelessness; individuals who may be from the City of
Orange and who may otherwise come to Orange in the
future.

The City assists local individuals experiencing
homelessness by coordinating with local organizations,
2-1-1 Orange County, Orange County Housing Authority
and other government agencies to provide services and
assistance directly to individuals.

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(2) definitive implementation timelines (e.g., December 31, 2024);
(3) objectives, quantified where appropriate; and
(4) identification of responsible agencies and officials (e.g., Planning Assistant, Community Development, etc.).

For example, Policy Action 1A (Acquisition/Rehabilitation of Multifamily Residential Development), Policy Action 2C (Development of Housing for Large Families), 2L
(Candidate Sites Used in Previous Housing Elements) all requires specific timeframes for identified actions. In addition, the following programs require additional
information:

Policy Action 2G (Support Community Housing
Development Organization New Construction Projects):

The element must describe how the City will seek
qualified organizations and more general information on this program.

Policy Action 4B (Homeless Services). The Policy Action states the City provides support for navigation centers in Buena Park and Placentia. The element must describe
how the City supports these navigation centers and how
these navigation centers address and support the housing and service needs of those individuals experiencing
homelessness in the City of Orange.

Policy Action 4E (Support for Persons with Disabilities):

Describe how the City will support housing for persons
with disabilities and work with the regional center to
promote opportunities for supportive living services.

Policy Action 4E – the support supports by working with the Regional Center of Orange County to identify the
housing needs of persons served by the Center,
promoting opportunities for supportive living services
and supporting efforts to eliminate barriers to housing for persons with developmental disabilities.

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C2. As noted in Finding B3, the element does not include a complete site analysis; therefore, the adequacy of sites and zoning were not established. Based on the results of a complete sites inventory and analysis, the City may
need to add or revise programs to address a shortfall of sites or zoning available to encourage a variety of housing types. In addition, the element should be revised as
follows:

Policy Action 2E (Facilitate Infill Construction): Provide a specific timeline for evaluating provisions in the Zoning Code for feasibility of providing additional regulatory relief (i.e., streamlined review, reduced and objective development standards, lot consolidations, etc.) In
addition, this program could be expanded to provide
specific provisions to support development of housing on the sites identified in the inventory including the
redevelopment of sites with existing uses identified to accommodate the lower-income RHNA. As existing leases
have been identified as a potential constraint to
developing the nonvacant sites for the lower-income
RHNA, the program could also monitor development on
sites with existing leases as it relates to the provision of housing affordable to lower-income households and
commit to the provision of additional actions as necessary to facilitate development or identify additional sites.

Policy Action 2K (Create ADU Monitoring Program): The
program states that the City will monitor ADU
development progress after 2 years of adopting the 6th
cycle housing element and will take action within six
months to ensure adequate capacity at each income
Section 4, Policy Actions
2E and 2K
See responses to B3 for additional justification and
revisions to the City’s Site Analysis. This did not result in the need for additional programs.

Policy Action 2E updated to include 12 month timeline.

The program has also been revised to include: “The City will monitor the development of infill sites with existing leases as it relates to the provision of housing affordable to lower-income households. The City will review and
establish additional actions or identify additional sites should it be deemed necessary when reviewing the
monitored sites annually.”

Policy Action 2K language clarified to track in relation to affordability assumptions within the Housing Element.
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level. The program should also commit to monitor by
affordability assumptions.

C3. Policy Action 2B (Promotion of Affordable Housing)
indicates the development of housing for lower- and
moderate-income households will be assisted primarily
by applying state density bonus law (SDBL). However, in addition to complying with SDBL, the element must
include a program(s) describing specific actions the City will take to assist in the development of housing
affordable to lower- and moderate-income households,
including extremely low-income households (ELI). For
example, programs could prioritize some funding for the development of housing affordable to ELI households and offer financial incentives or regulatory concessions to encourage the development of a variety of housing types, such as multifamily, SRO units, and supportive housing, to address the identified housing needs for ELI households.

The inclusion of specific programs to assist in the
development of housing affordable to lower-income
households is critical as, per third party comments
received from the Kennedy Commission, the number of
units affordable to moderate- and above moderate-
income households approved in the last seven years was
23 times greater than those approved for low- and very
low-income households.

Section 4, Policy Action
2M
Housing Policy Action 2M has been added. The program
stats:
“The City recognizes the importance of su pporting the
development of housing for low and extremely low income households. While the City does not build housing, it is a primary goal of the Housing Element to support developers and increase the feasibility of development of housing for extremely low and low income households. Actions for this program include the following:
 When funding is available, the City shall subsidize up to 100 percent of the City’s application processing fees
for qualifying developments where all units affordable
to 80% AMI or lower.
 Promote the benefits of this program to the
development community by posting information on its
webpage and creating a handout to be distributed with
land development applications.”

C4. As noted in Findings B4 and B5, the element requires a complete analysis of potential governmental and
nongovernmental constraints. Depending upon the
results of that analysis, the City may need to revise or add programs and address and remove or mitigate any
identified constraints.

See responses to B4 for additional analysis and programs relating to governmental and nongovernmental
constraints.
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C8. The element includes Policy Action 1B (Monitoring
and Preservation of “at-risk” Units) to monitor the units and provide technical assistance. However, the element
must include specific and proactive actions to preserve the at-risk units.

For example, the program could support applications by
non-profits for funding to purchase at-risk units,
strengthen relationships with the listed non-profits and develop a plan or strategy for quickly moving forward in the case units are noticed to convert to market-rate uses in the planning period, and consider pursuing funding on at least an annual basis. The program could also commit to contacting non-profits immediately to develop a
preservation strategy by a date certain and be ready to quickly act when notice of conversion is received and
monitoring the units to ensure tenants receive proper
notifications.

Section 4, Policy Action 1B Housing Policy Action 1B has been updated to include additional actions.

C9. The element is required to include a program that
incentivizes or promotes ADU development for very low-, low-, and moderate-income households. This can take the form of flexible zoning requirements, development
standards, or processing and fee incentives that facilitate the creation of ADUs, such as reduced parking
requirements, fee waivers and more. Other strategies
could include developing information packets to market
ADU construction, targeted advertising of ADU
development opportunities or establishing an ADU
specialist within the planning department.

Section 4, Policy Action 2J Housing Policy Action 2J has been updated to include provisions for the creation of an information packet on ADUs to be available at City Hall.

The program states: “The City of Orange will continue to permit construction of accessory dwelling units
consistent with State law. The City has incorporated new legislation regarding ADU development into the
Municipal Code and will continue to make updates to the City’s Municipal Code to reflect new State laws as
required.

The City will develop an informational packet to be
available to the public at City Hall. The packet will
include processes and key information regarding ADU
development opportunities. The City will continue to
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work with property owners who come forward with
interest in developing ADUs and/or questions regarding
ADUs.”

Quantified Objectives
D. The element must include quantified objectives to
establish an estimate of housing units by individual
income category that can be constructed, rehabilitated, and conserved over the planning period.

Section 4, Table 4-1 Quantified objectives are provided by income category in Table 4-1.

Public Participation
E. While the element includes a general summary of the
public participation efforts, it must also demonstrate
diligent efforts were made to involve all economic
segments of the community in the development of the
housing element. The element should be revised to
discuss outreach to lower-income and special needs
groups during the public participation efforts, solicitation efforts for survey responses, and participation in
community workshops. In addition, the element should
also summarize the public comments and describe how
they were considered and incorporated into the element.

For additional information, see the Building Blocks at
http://www.hcd.ca.gov/community-
development/building-blocks/getting-started/public-
participation.shtml.

Section 4, Policy Action 3D

Appendix C

Section 2.E
Housing Policy Action 3D has been added to extend
community outreach effort beyond the Housing Element
Update period with a focus on traditionally under-
represented communities.

A matrix of responses to public review draft comments
has been created and added to Appendix C.

In addition, outreach and resources for special needs
populations has been added to Section 2.

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5. COMMISSION BUSINESS
None

6. CONTINUED HEARINGS
None

7. NEW HEARINGS

7.1. Public Hearing: General Plan Amendment No. 2022-0001; City of Orange 2021-2029 Housing Element Update
Consultant Nick Chen of Kimley-Horn gave a presentation about the project process.

Chair Simpson opened the public hearing.

Bonnie Robinson, Je'net Kreitner and Adrienne Gladson expressed concerns about the Housing Element meeting affordable housing needs.

Chair Simpson closed the public hearing.

The Commissioners had questions about the following:
· Accessory Dwelling Unit development
· Affordable housing
· Certain Housing Policy Actions
· Transitional housing
· Student housing
· Quality of neighborhoods
· UCI Regents sites
· California Department of Housing and Community Development comments A motion was made by Commissioner Glasgow, seconded by Commissioner Trapesonian to adopt Planning Commission Resolution No. 01-22 entitled:

A Resolution of the Planning Commission of the City of Orange recommending that the City Council approve General Plan Amendment No. 2022-0001 adopting the City of Orange 2021-2029 General Plan Housing Element.

The motion carried by the following vote:

Simpson, Vazquez, Glasgow, Martinez, and TrapesonianAyes:

NoneNoes:

NoneAbsent: