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Orange City Council
February 10, 2023

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Public Comments
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February 10, 2023
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February 10, 2023
City Council Meeting
Written Public Comments
Item 2.1
Housing Element
Update
Jennifer Connally
From: Regina Mundekis
Sent: Wednesday, February 8, 2023 8:35 AM
To: City Council Public Comment
Subject: February 10 City Council Special Meeting Comment Dear Mayor and City Council,
I have questions regarding the adoption of the Housing Element which pertain to the Builder's Remedy.

The Builder's Remedy was created in SB 330 Housing Crisis Act of 2019 and is contained in Government Code Section 65589.5.

Builder's Remedy applies when a city has not adopted a revised Housing Element in compliance with state law. The city cannot deny a housing development which qualifies under the terms of the Builder's Remedy even if the housing development does not comply with the city's general plan and zoning ordinance.

Questions

1. Does adoption of the Housing Element approved by the state end the possible use of the Builder's Remedy for this RHNA cycle?

2. Has the City of Orange (City) received applications to use the Builder's Remedy?

3. If the City has received applications to use the Builder's Remedy, who submitted the applications? What are the proposed projects?
Thank you for your interest in this matter,
Reggie Mundekis
Jennifer Connally
From: Barry Ross
Sent: Thursday, February 9, 2023 8:52 AM
To: City Council Public Comment
Subject: February 10, 2023 Item 2.1 Housing Element
Dear Mayor Slater and City Councilmembers,
My name is Barry Ross. I serve as Executive Director, Justice Partnerships for the Sisters of St. Joseph of Orange. I want to thank the City of Orange for your partnership and tremendous support of Villa St. Joseph, which will create affordably housing for persons experiencing homelessness, veterans and seniors is the Sisters former Motherhouse. I commend you and your staff for developing a Housing Element that has informal approval by HCD.

As in most of California, in the City of Orange 54% of renter households spend 30% or more of gross income on housing costs and 26.8% of renter households spend fifty percent or more of gross income on housing costs. In the 5th cycle housing element period, the City saw only 9 very low and 72 low housing units built. The 6t cycle RHNA targets for the City are 1,067 very low and 601 low housing units to be built.

The housing element that you are considering today does not include policies that significantly improve the chances of meeting the housing needs of the most vulnerable populations in the City. I request that the City Council consider the following policies to make more affordable housing a reality in the 6* cycle:

1. Adopt an Inclusionary Housing Ordinance with a 15% requirement of affordable housing production at extremely low, very low-and low-income categories.

2. Prioritize affordable housing funding and programs to increase affordable housing options for families of lower incomes, especially at very low and extremely low-income.

3. Identify city-owned sites and prioritize these sites for the development of affordable housing in Orange.

4. Ensure that development sites being identified and discussed in the initial drafts are realistic and available during the planning period.

5. Ensure opportunity sites are not simply 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. An Affordable Housing program is also needed.

Thank you for your consideration.

Barry Ross
Executive Director, Justice Partnerships
Sisters of St. Joseph Healthcare Foundation
Sisters of St. Joseph of Orange Fund
Sisters of St. Joseph of Orange
440 South Batavia Street, Orange, CA 92868-3998
www.csjorange.org

CHAPMAN YORBA VIII, LLC
1601 Dove Street Suite 175
Newport Beach, CA 92660 2023 FEB -9 P. 1: 3*
February 9, 2023
Mr. Dan Slater, Mayor
City of Orange
300 E Chapman Avenue
Orange CA 92866
Re: Adoption of Resolution No 11431; 2021-2029 Housing Element Dear Mayor Slater and Fellow Council Members
Chapman Yorba VIII, LLC, hereby objects to the proposed adoption of Resolution No. 11431 approving the 2021-2029 Housing Element for the reasons stated in the letters submitted on its behalf to Ms.

Pehoushek, Assistant Community Development Director dated 11/18/2022 by the law office of Loeb & Loeb LLP (a copy of which is attached for ease of reference).

In addition to the foregoing objections, Chapman Yorba VIII, LLC incorporates, without limitation, the objections contained in the Department of Housing and Community Development's letter of April 12, 2022 (a copy of which is also attached for ease of reference).

Chapman Yorba VII's renews its request that its eight-acre vacant site, which is available and suitable for residential development during the Housing Element's Planning Period, and which - since 2020 - has been proposed for a 158-unit mixed-use senior apartment project with 10% of its units to be set aside for moderate income senior households, be added to the inventory of available sites for residential development in the Housing Element.

Because the City's proposed 2021-2029 Housing Element does not comply with the requirements of State law, the City Council should refrain from adopting Resolution No. 11431.

Sincerel
Neil Morrison, P. E
Assistant Project Manager
Cc: Phil Becker, Manager
Robert Pack, Project Manager
Allan J. Abshez, Esq.

Attachments Attachments available in the City Clerk's Office for review:

November 18, 2022 Letter to City from Loeb &
Loeb LLP
April 12, 2022 HCD Housing Element Letter to City
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