Orange City Council
February 14, 2023

The strategy considered below is to assist affordable housing projects in maintaining rental subsidy for residents of the three units at-risk in Adams Triplex I, 8 units at the Friendly Center, and 40 units in Casas Del Rio. To determine the subsidy needed, Fair Market Rents were compared to market rate rents.

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Table 3-39: Estimated Monthly Subsidy to Preserve “At-Risk” Units Unit Size
Monthly Rents Number of
Units At-Risk Difference Monthly Subsidy
Annual
Subsidy Fair Market
Rents1 Market Rate2
Efficiency $1,716 $2,297 0 $581 -- --
1-Bedroom $1,905 $2,422 313 $517 $16,027 $192,324
2-Bedroom $2,324 $2,989 203 $665 $13,300 $159,600
3-Bedroom $3,178 $3,414 0 $236 -- --
4-Bedroom $3,674 N/A 0 -- -- --
TOTAL $351,924
Source:

1. HUD FY 2022 Fair Market Rent Documentation System – Santa Ana-Anaheim-Irvine, CA HUD Metro FMR Area FMRs

2. Kimley-Horn and Associate Analysis – based on apartments listed for rent across 20 properties on October 4, 2021.

3. Adams Triplex I at-risk units are assumed one-bedroom units. Casas Del Rio at-risk units are assumed at 20 one-bedroom units and 20 two-bedroom units. Friendly Center at-risk units are assumed at 8 one-bedroom units.

Cost of Replacement of Units
The City of Orange can also consider the cost of replacing the units with new construction. Construction cost estimates include all hard and soft costs associated with construction in addition to per unit land costs. Square footage estimates are based on estimated size of units to be replaced and assume housing units are developed on multi-family zoned properties. Land costs have been determined on a per unit basis.

Table 3-40: Replacement Cost by Unit Type
Size of Unit Cost Per Square
Foot1
Average Square
Foot/Unit2
Replacement
Cost/Unit3
Number of
Units
Total
Replacement
Cost
Efficiency $131.24 566 $74,282 0 --
1-Bedroom $131.24 760 $99,742 313 3,092,014
2-Bedroom $131.24 1,106 $145,151 203 2,903,029
3-Bedroom $131.24 1,335 $175,205 0 --
4-Bedroom $131.24 N/A -- 0 --
TOTAL $5,995,043
Source:

1. International Code Council – August 2020 Report.

2. Kimley-Horn and Associate Analysis – based on apartments listed for rent across 20 properties on October 4, 2021. Includes financing and land acquisition costs of $30,000 per unit.

3. Adams Triplex I at-risk units are assumed one-bedroom units. Casas Del Rio at-risk units are assumed at 20 one-bedroom units and 20 two-bedroom units. Friendly Center at-risk units are assumed at 8 one-bedroom units.

Resources to Preserve At-Risk Units
A variety of programs exist to help cities acquire, replace, or subsidize at-risk affordable housing units.

The following summarizes financial resources available:
 Community Development Block Grant (CDBG) – CDBG funds are awarded to cities on a formula basis for housing activities. The primary objective of the CDBG program is the development of viable communities through the provision of decent housing, a suitable living environment and economic opportunity for principally low- and moderate-income persons. Eligible activities 772
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include administration, fair housing, energy conservation and renewable energy sources, assistance for economic development, public facilities and improvements and public services.  HOME Investment Partnership – Local jurisdiction can receive funds by formula from the Department of Housing and Urban Development (HUD) to increase the supply of decent, safe, sanitary, and affordable housing to lower income households. Eligible activities include housing acquisition, rehabilitation, and development, homebuyer assistance, and rental assistance.  Section 8 Rental Assistance Program – The Section 8 Rental Assistance Program provides rental assistance payments to owners of private, market rate units on behalf of very low-income tenants, senior citizens, disabled and/or handicapped persons, and other individuals for securing affordable housing.
 Section 202/811 Program – Non-profit and consumer cooperatives can receive no-interest capital advances from HUD under the Section 202 program for the construction of very low-income rental housing with the availability of supportive services for seniors and persons with disabilities. These funds can be used in conjunction with Section 811, which can be used to develop group homes, independent living facilities and immediate care facilities. The capital advance funding can also provide project rental assistance for the properties developed using the funds. Eligible activities include acquisition, rehabilitation, new construction, and rental assistance.  California Housing Finance Agency (CalHFA) Multifamily Programs – CalHFA’s Multifamily Programs provide permanent financing for the acquisition, rehabilitation, and preservation of new construction of rental housing that includes affordable rents for low- and moderate-income families and individuals. One of the programs is the Preservation Loan program which provides acquisition/rehabilitation and permanent loan financing designed to preserve or increase the affordability status of existing multifamily housing projects.  Low-Income Housing Tax Credit (LIHTC) – This program provides tax credits to individuals and corporations that invest in low-income rental housing. Tax credits are sold to those with high tax liability and proceeds are used to create housing. Eligible activities include new construction, rehabilitation, and acquisition of properties.
 California Community Reinvestment Corporation (CCRC) – The California Community Reinvestment Corporation is a multifamily affordable housing lender whose mission is to increase the availability of affordable housing for low-income families, seniors, and residents with special needs by facilitating private capital flow from its investors for debt and equity to developers of affordable housing. Eligible activities include new construction, rehabilitation, and acquisition of properties.

Qualified Entities to Preserve
The following organizations have the experience and capacity to potentially assist in preserving at-risk units:
 Orange Housing Development
Corporation
 Orange Senior Housing
 Jamboree Housing Corporation
 Irvine Housing Opportunities, Inc.
 Bridge Housing Corporation
 The Irvine Company
 Orange County Housing Authority
 Housing Corporation of America
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 Southern California Housing
Development Corporation
 Century Housing
Quantified Objectives
Housing Element law requires that cities establish the maximum number of units that can be preserved over the planning period. The City’s objective is to preserve the 3 affordable housing units “at-risk” of converting to market rate through policy programs provided in Section 4: Housing Plan.

Senate Bill 330
Effective January 1, 2020, Senate Bill 330 (SB 330) aims to increase residential unit development, protect existing housing inventory, and expedite permit processing. Under this legislation, municipal and county agencies are restricted in ordinances and polices that can be applied to residential development. The revised definition of “Housing Development” now contains residential projects of two or more units, mixed-use projects (with two-thirds of the floor area designated for residential use), transitional, supportive, and emergency housing projects. SB 330 sets a temporary 5-year prohibition of residential density reduction associated with a “housing development project”, from January 1, 2020, to January 1, 2025. For example, during this temporary prohibition, a residential triplex cannot be demolished and replaced with a duplex as this would be a net loss of one unit.

None of the housing strategy sites contain significant existing housing with low-income tenants who will be displaced if the sites redevelop. To the extent that there is existing housing, all housing must be replaced under SB 330's replacement housing provisions (Government Code Section 66300). SB 330 also provides relocation payments to existing low-income tenants. The State has also adopted just cause eviction provisions and statewide rent control to protect tenants from displacement. The City is committed to making diligent efforts to engage underrepresented and disadvantaged communities in studying displacement.

Local Knowledge and Data Relating to Fair housing
During the 1960s and 1970s socio-economic disadvantaged areas of the City were “up-zoned” in a manner that supported multi-family development that does not live up to today’s standards of quality and functionality. These areas generally tend to be along the State Route 55 corridor (east of Tustin and west of the freeway), in the El Modena neighborhood, the Cypress Barrio neighborhood, the Hoover-Wilson neighborhood south of Katella east of the railroad tracks and west of Glassell Street, and the Chalynn neighborhood generally located north of LaVeta, west of Cambridge, south of Culver, and east of Shaffer. Some of these areas were originally developed with single family residences. As redevelopment occurred with multi-family projects developed in a spotty manner, the overall quality and character of the neighborhoods deteriorated as a result of lower quality design and absentee landlords. Over the course of time, properties in these areas have experienced inconsistent maintenance and while some are in good condition, others are less well maintained. The City has a well-established working relationship with the local CHODO, Orange Housing Development Corporation (OHDC), and over the years has supported 774
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OHDC’s efforts to acquire multi-family properties in disadvantaged areas with higher minority populations. The subject properties are then rehabilitated, become well-managed and maintained by OHDC, and become income-restricted units. These projects have a proven track record of success. Support for this collaboration has come from different City sources, including some former Redevelopment Agency funding, CDBG, HOME funds, and other similar housing rehabilitation funding.

In addition to this OHDC collaboration for unit rehabilitation, the City has supported OHDC’s development of new income-restricted multi-family projects in various disadvantaged areas of Orange. There are multiple highly successful projects that have come to fruition in this manner; two are on sites that had previously been developed with light industrial use, one involves a site that had been underutilized church property, one involves a site that had been surplus property left vacant after a road widening project, and another is presently under development on a portion of the City’s corporation yard in proximity to the first two mentioned sites. There are a number of other OHDC projects in areas of the City that are not necessarily characterized as “low resource”, however much of the City’s population is characterized as modest, working-class households so the distribution of these projects has functioned to support the quality of the neighborhood environment for all.

Lastly, the City spends CDBG funds annually on public facility improvements in disadvantaged areas within Orange including sidewalk replacement, library building upgrades, and park/open space upgrades to contribute to a higher quality of life for residents.

Assessment of Contributing Factors to Fair Housing Issues in Orange Previously Identified Contributing Factors to Fair Housing The AI identifies the following regional goals for mitigating impediments to fair housing within jurisdictions in Orange County:
 Goal 1: Increase the supply of affordable housing in high opportunity areas.  Goal 2: Prevent displacement of low- and moderate-income residents with protected characteristics, including Hispanic residents, Vietnamese residents, other seniors, and people with disabilities.
 Goal 3: Increase community integration for persons with disabilities.  Goal 4: Ensure equal access to housing for persons with protected characteristics, who are disproportionately likely to be lower-income and to experience homelessness.  Goal 5: Expand access to opportunity for protected classes Within the Regional AI the City identified goals to address fair housing barriers and issue in the City of Orange, including the following:
 Continue to follow current State Density Bonus law and further its implementation through a Density Bonus ordinance update.
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 Prepare a Transfer of Development Rights Ordinance to provide opportunities for development rights transfers to accommodate higher density housing in transit and employment-rich areas of the city.
 Amend the City’s ADU Ordinance to be consistent with State Junior Accessory Dwelling Unit (JADU) and Accessory Dwelling Unit (ADU) laws.
 Prepare and adopt a Small Lot Subdivision ordinance to streamline entitlement processing of housing development projects.
 Continue providing CDBG funds to the Fair Housing Foundation to provide fair housing activities to the community.

Current Local Contributing Factors
The Housing Element programs incorporates these recommended goals as they relate to Orange. The analysis above regarding other fair housing issues within Orange yielded the following results:
 Educational Opportunities: Countywide, there are disparities across racial/ethnic groups in access to educational opportunities as measured by the index. Orange City, struggled with educational opportunity, all with scores in the 30s to 40s on the composite education index.  Environmental Opportunities: Countywide, there are disparities across racial/ethnic groups in access to environmental opportunities, measured as lower exposure to and effects from pollution. Across all tracts in Orange County, non-Hispanic Whites exhibit the highest access to environmentally healthy neighborhoods. Orange City in one of the least environmentally healthy, with index scores in the 20s.
 Economic Opportunities: In Orange County, there are significant disparities in access to economic opportunity. Non-Hispanic White residents have the greatest access to economic opportunity.

The City of Orange has relatively large disparities by protected class groups, where Hispanic residents have significantly lower access to economic opportunity than other racial/ethnic groups.  Regional Opportunity, Place: The City of Orange has two of census tracts which provide low resources, specifically low housing, and civic life resources. These census tracts do not provide appropriate or sufficient housing access for current residents and therefore create fair housing barriers.

There are a number of factors and elements that contribute to and may cause fair housing issues. Some of these are historical and referenced in the preceding section on local knowledge and data. The following lists contributing factors identified in the City of Orange:

Fair Housing Outreach and Enforcement – The City of Orange partners with the Fair Housing Foundation to assist households with fair housing-related issues, as well as provide informational resources to the community. The City currently allocated $24,522 to the Fair Housing Foundation to assist approximately 150 families. In 2019, the City assisted 161 residents; however, 16 fair housing complaints were filed involving housing discrimination in the City. Continued outreach including the availability of resources is necessary to ensure fair practices throughout the City. Fair housing is addressed through Housing Policy Action 4A, 4C, and 3D.
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K. Analysis of Sites Pursuant to AB 686
AB 686 requires that jurisdictions identify sites throughout the community in a manner that is consistent with its duty to affirmatively further fair housing. The site identification requirement involves not only an analysis of site capacity to accommodate the RHNA (provided in Appendix B), but also whether the identified sites serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity. Figures 3-16 through 3-21 below identify the sites to accommodate future housing, as identified in the adequate sites analysis, overlaid on demographic data using the 2018 American Community Survey 5-year Estimates.
 Figure 3-16 – Candidate Sites – Ethnicity Analysis, 2018  Figure 3-17 – Candidate Sites – Non-White Analysis, 2018  Figure 3-18 – Candidate Sites – Low/Moderate Income Block Group Analysis  Figure 3-19 – Candidate Sites – R/ECAP Areas
 Figure 3-20 – Candidate Sites – RCAAs Areas
 Figure 3-21 – Candidate Sites – TCAC Opportunity Areas Figure 3-24 shows the proposed candidate sites to meet the RHNA, at all income levels for Orange in relation to the location of residents of Hispanic origin. These sites take into consideration access to vital goods, services, and public transportation and are therefore ideal areas for the City to focus much of its future housing growth. It is anticipated that accessory dwelling unit (ADU) growth, including growth for affordable ADUs, will occur in the less dense areas of the community.

Figure 3-24 shows the following findings:
 9 proposed sites accommodate the RHNA allocation (totaling 114 potential units, or 2% of the total potential units) are located within block groups that have a percentage of the population that identifies as Hispanic greater than 56 percent. Of these, none are affordable to low and very low-income groups.
 11 proposed sites to accommodate the RHNA allocation (totaling 1,334 potential units, or 21% of the total potential units) are located within block groups that have a percentage of the population that identifies as Hispanic between 38 and 56 percent. Of these, 323 proposed units are affordable to low and very low-income groups.
 18 proposed sites to accommodate the RHNA allocation (totaling 2,567 potential units, or 40% of the total potential units) are located within block groups that have a percentage of the population that identifies as Hispanic between 24 and 38 percent. Of these, 621 proposed units are affordable to low and very low-income groups.
 0 proposed sites to accommodate the RHNA allocation are located within block groups that have a percentage of the population that identifies as Hispanic between 13 and 24 percent.  9 proposed sites to accommodate the RHNA allocation (totaling 2,470 potential units, or 38% of the total potential units) are located within block groups that have a percentage of the population that identifies as Hispanic below 13 percent. Of these, 615 proposed units are affordable to low and very low-income households.
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Figure 3-24: Candidate Sites – Ethnicity Analysis
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Figure 3-25 shows the proposed candidate sites to meet the RHNA, at all income levels, for Orange in relation with census data showing the percentage of the population within each block group that is NonWhite.

Figure 3-25 shows the following findings:
 26 proposed sites accommodate the RHNA allocation (totaling 2,626 potential units, or 40% of the total potential units) are located within block groups that have a percentage of the population that identifies as Non-White greater than 40 percent. Of these, 621 are affordable to low and very low-income groups.
 12 proposed sites to accommodate the RHNA allocation (totaling 2,917 potential units, or 45% of the total potential units) are located within block groups that have a percentage of the population that identifies as Non-White between 29 and 40 percent. Of these, 726 proposed units are affordable to low and very low-income groups.
 4 proposed sites to accommodate the RHNA allocation (totaling 375 potential units, or 6% of the total potential units) are located within block groups that have a percentage of the population that identifies as Non-White between 24 and 29 percent. Of these, 92 proposed units are affordable to low and very low-income groups.
 5 proposed sites to accommodate the RHNA allocation (totaling 567 potential units, or 9% of the total potential units) are located within block groups that have a percentage of the population that identifies as Non-White between 15 and 24 percent. Of these, 120 proposed units are affordable to low and very low-income households.
 0 proposed sites to accommodate the RHNA allocation are located within block groups that have a percentage of the population that identifies as Non-White below 15 percent.

The data shows that the proposed candidate sites to meet the RHNA allocation are dispersed throughout the community with an emphasis on locating units where there is a high level of access to important public services and transit. Sites are identified based on availability of land and realistic potential for future residential development. While Figure 3-17 identifies 40 percent of sites in block groups with more than 40 percent Non-White population and 45 percent of sites in block groups with 29 to 40 percent Non-White population, these sites may provide for future affordable housing to existing lower income residents without resulting in community displacement. Future developments may also bring about additional community resources and services to existing neighborhoods and communities. The City recognizes the larger percentage of sites identified within these areas and is committed to providing resources to facilitating appropriate development and facilitating improved access to resources and opportunities for existing and future residents. Housing Policy Actions 1E, 2B, 2G, 2M, 3A, 3D, and 4A all provide actions which seek to facilitate affordable housing development, outreach to the community, partner with community organizations and affordable housing developers, as well as identify funding sources for household assistance and housing development.
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Figure 3-25: Candidate Sites – Non-White Analysis
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Figure 3-26 shows the location of proposed candidate sites to meet the City’s RHNA allocation in comparison with census dating showing Low/Moderate Income (LMI) block groups within the City of Orange. Figure 3-26 displays the following results:
 4 proposed sites accommodate the RHNA allocation (totaling 375 potential units, or 6% of the total potential units) are located within block groups that have a percentage of the population that is low- and moderate-income greater than 73 percent. Of these, 92 are affordable to low and very low-income groups.
 21 proposed sites to accommodate the RHNA allocation (totaling 2,985 potential units, or 46% of the total potential units) are located within block groups that have a percentage of the population that is low- and moderate-income between 54 and 73 percent. Of these, 732 proposed units are affordable to low and very low-income groups.
 10 proposed sites to accommodate the RHNA allocation (totaling 169 potential units, or 3% of the total potential units) are located within block groups that have a percentage of the population that is low- and moderate-income between 27 and 54 percent. Of these, 0 proposed units are affordable to low and very low-income groups.
 12 proposed sites to accommodate the RHNA allocation (totaling 2,956 potential units, or 46% of the total potential units) are located within block groups that have a percentage of the population that is low- and moderate-income below 25 percent. Of these, 735 proposed units are affordable to low and very low-income households.

The data shows that the proposed candidate sites to meet RHNA allocation are evenly dispersed throughout the community with an emphasis on locating units where there is a high level of access to important public services and transit. The distribution of potential units provides increased opportunities for low income housing in areas with higher rates of low-income persons. 781
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Figure 3-26: Candidate Sites – Low/Moderate Income Block Group Analysis 782
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Figure 3-27 shows proposed candidate sites to meet RHNA for Orange in relation with data showing R/ECAP areas within the City. R/ECAPs are racially or ethnically concentrated areas of poverty; they are marked in red hatchings. The goal of the AB 686 analysis is to analyze how the sites identified to accommodate the RHNA allocation may exacerbate or mitigate existing fair housing issues. Figure 3-27 shows there are no R/ECAPs located within the City of Orange; therefore, no proposed candidate sites are located in a R/ECAP.

Figure 3-28 shows proposed candidate sites to meet RHNA for Orange in relation with data showing RCAA areas within the City. RCAAs are racially or ethnically concentrated areas of affluence; there are identified as areas with a median household income greater than $125,000 and a White population greater than 80 percent. Figure 3-28 shows there are no RCAAs located within the City of Orange; therefore, no proposed candidate sites are located in an RCAA.

Figure 3-29 shows proposed candidate sites to meet RHNA for Orange in relation with the TCAC/HCD Opportunity areas within the City. TCAC is the California Tax Credit Allocation Committee/Housing and Community Development Opportunity Area Maps which show how resources are spatially distributed throughout the City.

Figure 3-29 shows the following findings:
 33 proposed site to accommodate the RHNA allocation (totaling 5,843 potential units, or 90% of the total potential units) are located within the Low Resource areas. Of these, 1,448 are affordable to low and very low-income groups.
 14 proposed site to accommodate the RHNA allocation (totaling 642 potential units, or 10% of the total potential units) are located within the Moderate Resource areas. Of these, 1,448 are affordable to low and very low-income groups.
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Figure 3-27: Candidate Sites – R/ECAP Areas
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Figure 3-28: Candidate Sites – RCAA Areas
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Figure 3-29: Candidate Sites – TCAC/HCD Opportunity Areas 786
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L. Analysis of Fair Housing Priorities and Goals
To enhance mobility and promote inclusion for protected classes, the chief strategy included in this Housing Element is to provide sites suitable for affordable housing in high-resource, high opportunity areas, as demonstrated by the analysis of the housing resource sites contained in Appendix B of this Housing Element. Other programs that affirmatively further fair housing and implement the AI's recommendations include:
 Housing Policy Action 1B: Monitoring and Preservation of “At-Risk” units  Housing Policy Action 2B: Promotion of Affordable Housing  Housing Policy Action 2C: Development of Housing for Large Families  Housing Policy Action 2D: Provision of Senior Housing Opportunities  Housing Policy Action 4A: Affirmatively Further Fair Housing  Housing Policy Action 4B: Homeless Services
 Housing Policy Action 4C: Support Fair Housing Services  Housing Policy Action 4D: Section 8 Rental Assistance  Housing Policy Action 4E: Support for Persons with Developmental Disabilities  Housing Policy Action 4F: Emergency, Transitional and Supportive Housing and Lower Barrier Navigation Centers
Table 3-40 provides a summary of fair housing issues identified through this Housing Element and programs included in the Housing Plan that address each. 787
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Table 3-40: Affirmatively Furthering Fair Housing Programs Matrix Fair Housing Issue Contributing Factors Priority Programs Opportunity Areas 1. Census tracts with “Low Resource”
TCAC Opportunity Areas

2. Four census tracts with “Less
Positive Education Outcomes”

3. Four census tracts with “Less
Positive Economic Outcomes”
High Housing Policy Action 1E: Blight Removal
on Public Property – The City will
continue to utilize the Public Works and
Community Services Departments for the
as-needed removal of graffiti and other
deferred maintenance issues on public
property, including sidewalks, parks, bus
shelters signs and other structures
adjacent to the public right-of-way, to
enhance the quality of Orange’s
residential neighborhoods.

Housing Policy Action 3A: Public
Education – Provide public information
related to housing development and how
the provisions of affordable housing
benefits the community.

Housing Policy Action 3D: Community
Outreach – The City will continue
gathering community input on affordable
housing, housing for special needs
populations, and ADUs. The continued
outreach will be City-wide with a focus on
traditionally under-represented
communities.

Housing Policy Action 4A: Affirmatively
Further Fair Housing – The City will
implement the following goals:
 Continue to follow current State
Density Bonus law and further its
implementation through a
Density Bonus ordinance update.
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Table 3-40: Affirmatively Furthering Fair Housing Programs Matrix Fair Housing Issue Contributing Factors Priority Programs  Prepare a Transfer of
Development Rights Ordinance
to provide opportunities for
development rights transfers to
accommodate higher density
housing in transit and
employment-rich areas of the
city.
 Prepare and adopt a small lot
subdivision ordinance to
streamline entitlement
processing of housing
development projects.
 Continue providing CDBG funds
to the Fair Housing Foundation to
provide fair housing activities to
the community.

Environmental Burdens 1. Very low HUD Environmental
Health Index scores for all races and
ethnicities

2. Areas of moderate to high
CalEnviroScreen 4.0 environmental
burdens
Housing Policy Action 1E: Blight Removal
on Public Property – The City will
continue to utilize the Public Works and
Community Services Departments for the
as-needed removal of graffiti and other
deferred maintenance issues on public
property, including sidewalks, parks, bus
shelters signs and other structures
adjacent to the public right-of-way, to
enhance the quality of Orange’s
residential neighborhoods.

Housing Policy Action 3C: Safety Element
Update and adoption of an
Environmental Justice Element – The City
will review and update its Safety and
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Table 3-40: Affirmatively Furthering Fair Housing Programs Matrix Fair Housing Issue Contributing Factors Priority Programs Environmental Justice Elements and
related policies.

Housing Policy Action 3D: Community
Outreach – The City will continue
gathering community input on affordable
housing, housing for special needs
populations, and ADUs. The continued
outreach will be City-wide with a focus on
traditionally under-represented
communities.

Housing Policy Action 4A: Affirmatively
Further Fair Housing – The City will
implement the following goals:
 Prepare a Transfer of
Development Rights Ordinance
to provide opportunities for
development rights transfers to
accommodate higher density
housing in transit and
employment-rich areas of the
city.

Need for Affordable Housing in
New Developments

1. The City has six racially or ethnically
concentrated areas of affluence

2. Low Regional Opportunity Index
scores for housing in 4 census tracts

3. Areas of “Stable/Advanced
Exclusivity”

4. 51 units with affordability
covenants at risk of converting to
market-rate
Housing Policy Action 1B: Monitoring and
Preservation of “At-Risk” Units – The City
will assist in preserving at-risk units by,
but not limited to, supporting non-profit
applications for funding to purchase atrisk units, work with property owners to maintain affordability and develop
preservation strategies, and assist with
funding when available.
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Table 3-40: Affirmatively Furthering Fair Housing Programs Matrix Fair Housing Issue Contributing Factors Priority Programs Housing Policy Action 2G: Support
Community Housing Development
Organization New Construction Projects –
The City will continue to seek qualified
non-profit organizations for acquisition,
construction and rehabilitation of
affordable housing. Funds will be made
available on an annual basis, contingent
on funding availability.

Housing Policy Action 2B: Promotion of
Affordable Housing – The City will
continue to encourage through outreach
to private and non-profit housing
developers, the development of rental
and for-sale housing for larger (5 or more
persons) families. The City will support
developers/builders that incorporate
larger bedroom counts (3 or more
bedrooms) to accommodate the needs of
larger families and reduce incidents of
overcrowding in the existing housing
stock. The City will evaluate providing
regulatory incentives such as density
bonuses that encourage and support the
development of housing for large families
on a project-by-project basis.

Housing Policy Action 2M: Development
of Housing for Extremely Low and LowerIncome Households – The City will develop a program to subsidize
application processing fees, when funding
is available, for qualifying developments
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Table 3-40: Affirmatively Furthering Fair Housing Programs Matrix Fair Housing Issue Contributing Factors Priority Programs where all units affordable to 80% AMI or
lower. The City will also 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.
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Section 4: Housing Plan

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2021-2029 Housing Element Update - Draft
Housing Plan
The Housing Plan describes the City of Orange 2021-2029 policy program. The Housing Plan describes the specific goals and policy actions to assist City decision makers to achieve the long-term housing objectives set forth in the Orange Housing Element. This Plan identifies goals and policy actions aimed at providing additional housing opportunities, addressing governmental constraints to affordable housing, improving the condition of existing housing, and providing fair housing opportunities for all residents.

Regional Housing Needs Assessment
As described in previous sections of this Housing Element SCAG has conducted a RHNA to determine the City’s share of the affordable housing needs for the Orange County region. The RHNA quantifies Orange local share housing needs for the region by income category. Income categories are based on the most current Median Family Income (MFI) for Orange County. The City’s 2021-2029 RHNA growth need is as follows:
 1,067 units - Very low income (0-50% County MFI)
 604 units - Low income (51-80% of County MFI)
 677 units - Moderate income (81-120% of County MFI)
 1,588 units - Above moderate income (120% or more of County MFI) 3,936 units - Total
A. Housing Goals
The City of Orange has identified the following housing goals as part of this Housing Element Update:

Housing Goal #1: High quality neighborhoods and housing stock.

Housing Goal #2: Accommodate Orange’s RHNA Allocation at all income levels.

Housing Goal #3: Effective maintenance, preservation, improvement and development of housing citywide.

Housing Goal #4: Equal housing opportunity for all persons regardless of race, religion, sex, marital status, ancestry, national origin or color.

The goals listed above are described below and on following pages with accompanying policy actions to achieve them.

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B. Housing Policy Actions
This Housing Element expresses the Orange community’s overall housing goals, supporting policy actions, and quantified objectives. The stated policy actions are based on a review of past performance of the prior Housing Element, analysis of current constraints and resources, requirements of State law, and input from Orange residents and stakeholders.

Housing Goal #1: High quality neighborhoods and housing stock.

Housing Policy Action 1A: Acquisition/Rehabilitation of Multi-Family Residential Development The City will identify and pursue potential financing sources, as well as identify and implement regulatory incentives and other in-kind technical assistance to non-profits, affordable housing developers and property owners for the rehabilitation/acquisition of multi-family properties for affordable housing which is subject to available funding sources annually. The City will work with property owners to determine the most appropriate method to maintain affordability of housing units through restriction and/or covenants and prioritize and target buildings that exhibit the highest levels of deferred maintenance.

Objectives:
 Annually identify and pursue funding sources, as well as adopt and implement regulatory incentives and technical assistance for property owners and housing developers.  Annually outreach to property owners to collaborate in preserving affordable units at-risk of converting to market rate. The City will outreach to property owners whose deed restriction expires within the next three years to discuss an agreement to maintain the affordability of the units in question with final decision by the property owner.

Timeframe: Annually identify and pursue funding sources and additional incentives. Annually conduct outreach to property owners.

Responsible Agency: City of Orange Community Development Department Funding Source: State HCD, CDBG and HOME funds

Housing Policy Action 1B: Monitoring and Preservation of “At-Risk” Units The City shall provide for regular monitoring of deed-restricted units that have the potential of converting to marketrate during the planning period. The City may provide technical assistance for owners of these units seeking funding and other opportunities to extend and/or renew deed restrictions and/or covenants. The City will assist in preserving at-risk units by, but not limited to, supporting non-profit applications for funding to purchase at-risk units, work with property owners to maintain affordability and develop preservation strategies, and assist with funding when available.

The City will continue to comply with noticing requirements and coordinate with qualified entities to preserve at-risk units.

As shown in Section 3, the following properties are at-risk of converting to market-rate within the planning period:
 Three (3) units at Adams Triplex I (1837-1841 E. Adams) are identified as at-risk of converting to market rate units. There units are being preserved through the Section 8 Annual Renewal Program. The current contract runs through 2027.
 Eight (8) units at the Friendly Center (451-453 N. Lemon Street) are identified as at-risk of converting to market rate units. These units are being preserved through the Section 8 Annual Renewal Program. The current contract runs through May 2021. Discussions with the Friendly Center have resulted in an understanding that they intend to continually renew each year. 795
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 Forty (40) units at Casas Del Rio (1740 E. La Veta Avenue) were at risk of converting in 2017. The owner obtained a new five-year Housing Assistance Payments (HAP) contract effective October 26, 2017 through October 26, 2022.

Objectives:
 Coordinate with property owners in identifying methods and funding sources to maintain the affordability of units at-risk of converting to market-rate.

Timeframe: Outreach and coordinate with property owners annually, or until affordability is maintained.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 1C: Evaluation of Planning and Development Review Process The City will conduct annual internal reviews of the planning and development review process. The City will look for opportunities to create efficiency in the review of residential projects to reduce the holding, development and labor costs assumed by the project applicant.

Objectives:
 Annual review of the planning and development review process.

Timeframe: Annual review; changes to be made within six months, as need identified.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 1D: Proactive Code Enforcement
The City will continue to address code violations and deferred maintenance issues on a case-by-case basis, provide information on resources available and seek grants and other funding mechanisms for maintenance of existing neighborhoods.

Objectives:
 Maintain informational material(s) on the City’s website regarding code violations and resources for maintenance of existing neighborhoods.
 Seek grants and other funding mechanisms for maintenance of existing neighborhoods.  Annually review the number and types of code violations and identify additional resources in areas demonstrating additional need through an increase in code enforcement cases year over year.

Timeframe: Maintain updated information online throughout the Planning Period and annually review code violations and seek funding opportunities.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund, CDBG

Housing Policy Action 1E: Blight Removal on Public Property The City will continue to utilize the Public Works and Community Services Departments for the removal of graffiti and other deferred maintenance issues on public property, including sidewalks, parks, bus shelters signs and other structures adjacent to the public right-of-way, to enhance the quality of Orange’s residential neighborhoods. 796
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Objectives:
 Maintain informational material(s) on the City’s website regarding City resources for public property maintenance.
 Annually review City-provided resources for graffiti and other deferred maintenance issues on public property, and if issues increase, identify and implement solutions and/or adopt new programs, including, but not limited to, changes to landscaping and streetscape, outreach to local residents or businesses, or increased security presence.

Timeframe: Maintain updated information online throughout the Planning Period; Annually review resources and implement new solutions or adopt new programs if additional issues arise.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 1F: Preservation of Historic Residential Structures The City places high priority to the conservation, preservation and enhancement of the City’s historic residential neighborhoods. The City will continue to implement the goals and objectives contained in the Cultural Resources and Historic Preservation Element of the General Plan, the Historic Preservation Design Standards for Old Towne, and the Orange Eichler Design Standards to promote the continued quality of the City’s historic residential resources and maintenance of the City’s existing housing stock. In addition, the City will continue to promote the Mills Act Program and create public information and outreach materials.

Objectives:
 Promote informational materials on historical preservation and the Mills Act Program on the City’s website and at City Hall. Provide materials at community outreach events.

Timeframe: Maintain updated information online throughout the Planning Period.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Goal #2: Accommodate Orange’s RHNA Allocation at all income levels.

Housing Policy Action 2A: Annual Review of Housing Element The 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.

Objectives:
 Annually complete and submit the Annual Progress Report (APR) to HCD. Assess the Housing Element sites and programs every two years and, as needed, make revisions.

Timeframe: Annually complete and submit the City’s APR and adopt changes to the Housing Element sites and programs as necessary every two years if development does not occur as detailed within this Housing Element.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

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Housing Policy Action 2B: Promotion of Affordable Housing The City recognizes the need for housing affordable to all income segments of the population, especially LowerIncome households. The City will continue to support and encourage the development of housing affordable to LowerIncome households through incentives such as density bonusesa variety of incentives. Additionally, the City will continue to outreach to the development community, seek partnerships and provide in-kind assistance in developing new affordable housing.

Objectives:
 Annually outreach to and meet with the development community to promote the development of affordable housing and seek partnerships. The City has established a goal to develop 65 affordable housing units through partnerships and outreach.
 Continue to proactively build relationships with the building community, including nonprofits, and establish an array of regulatory and financial tools to assist residential development with a nonprofit, including utilizing funds available to the City such as former redevelopment agency set aside funds and other local financial resources, donating land, supporting funding applications, assisting entitlements and expediting permit processing.
 Adopt an amendment to the Density Bonus Ordinance in compliance with Government Code Section 65915 and develop an outreach program to ensure its successful implementation.  Continue to pro-rate adjustments to ADUs over 800 square feet based on the level of impacts.  Continue to provide reduced parking standards for senior housing developments and additional reductions when they include affordable units.

Timeframe: Annually outreach to and meet with the development community with target goal to develop 65 new affordable housing units over the 6th cycle.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 2C: Development of Housing for Large Families The City will continue to encourage the development of rental and for-sale housing for larger (5 or more persons) families through outreach to private and non-profit housing developers. The City will support developers/builders that incorporate larger bedroom counts (3 or more bedrooms) to accommodate the needs of larger families and reduce incidents of overcrowding in the existing housing stock. The City will identify and adopt regulatory incentives, such as density bonuses, that encourage and support the development of housing for large families.

Objectives:
 Annually outreach to and meet with the development community to promote the development of units for large families and receive feedback on potential constraints or resources.  Promote density bonuses to encourage and support the development of housing for large families.  Identify and adopt regulatory incentives to encourage and support the development of housing for large families.

Timeframe: Annually outreach and meet with the development community; promote density bonuses on a project-by-project basis; identify and adopt regulatory incentives by December 2024.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
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Housing Policy Action 2D: Provision of Senior Housing Opportunities The City recognizes the unique needs of its elderly residents and will continue to encourage, through regulatory incentives, the development of senior housing that offers a wide range of housing choices from independent living to assisted living with on-site services and memory care facilities. The City shall analyze the existing provisions in the Zoning Code and then identity and implement additional ability for regulatory relief.

Objectives:
 Annually outreach to and meet with the development community to promote the development of senior housing and receive feedback on potential constraints or resources.  Evaluate the provisions of the Zoning Code and identify amendments to adopt that further incentivize the development of a variety of senior housing choices.

Timeframe: Annually outreach and meet with the development community; evaluate the Zoning Code for potential amendments by December 2023 and adopt by June 2024.

Responsible Agency: City of Orange Community Development Department Funding Sources: General Fund
Housing Policy Action 2E: Facilitate Infill Construction The City will encourage infill development within feasible development sites for homeownership and rental units. The City will continue to facilitate infill development through implementation of its General Plan and Zoning Code, allowing for higher density housing in appropriate areas of the City where potential exists for infill or site redevelopment and employment and transit are concentrated. The City will also encourage compatible residential development integrated into existing neighborhoods and districts where appropriate.

Objectives:
 Within 12 months of adoption of the Housing Element, the City shall evaluate the existing provisions in the Zoning Code for feasibility of providing additional regulatory relief (i.e., streamlined review, reduced and objective development standards, lot consolidation, and other methods deemed appropriate) to further encourage infill housing development.
 Identify and adopt an inventory of potential infill sites utilizing the site analysis found in Appendix B of the Housing Element.
 Seek partnerships with and provide informational material including a copy of the inventory and listing of City incentives and programs to housing developers.
 Monitor the development of infill candidate housing sites as it relates to the provision of housing affordable to lower-income households. If development does not occur as projected, the City will identify and adopt new incentives, actions, or additional sites to continue maintain compliance with Housing Element requirements for RHNA.

Timeframe: Evaluate the Zoning Code by December 2023, and monitor and review candidate housing infill sites annually. Identify and adopt changes within 6 months of identifying a gap between projections and actual development occurring.

Responsible Agency: City of Orange Community Development Department Funding Sources: General Fund
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Housing Policy Action 2F: Pursue Alternative Funding and Financing Sources The City will continue to use federal HOME Investment Partnerships Program (HOME) and Community Development Block Grant Program (CDBG) funds and pursue alternative funding and financing sources such as public-private partnerships in order to maximize the opportunities for new housing development.

Objectives:
 Seek out and pursue funding opportunities for new housing development.

Timeframe: Annually seek for and explore funding opportunities.

Responsible Agency: City of Orange Community Development Department Funding Sources: Federal HOME Investment Partnership funds, Low and Moderate Income Housing Asset funds, Community Development Block Grant funds, and CalHome funds Housing Policy Action 2G: Support Community Housing Development Organization New Construction Projects Section 3.J.6 of this Housing Element lists resources and qualified entities to preserve affordable units at risk of converting to market-rate. The City will continue to seek qualified non-profit organizations for acquisition, construction and rehabilitation of affordable housing. Funds will be made available on an annual basis, contingent on funding availability.

Objectives:
 Partner with non-profit organizations for future affordable housing development and preservation of at-risk units.
 Promote available funding opportunities.

Timeframe: Annually outreach to non-profit organizations and annually maintain updated funding opportunities on the City’s website.

Responsible Agency: City of Orange Community Development Department Funding Sources: HOME funds
Housing Policy Action 2H: Monitoring Adequate Sites for Housing Development The City will continue to require non-residential and mixed use projects in the Urban Mixed Use (UMU) zoning districts only be approved when a finding can be made that the project will not reduce UMU-zoned land available for residential development such that the City can no longer accommodate its remaining RHNA need. The City will continue to track the availability of UMU-zoned sites greater than one half-acre in size through its RHNA Housing Sites Monitoring System.

Objectives:
 Annually track development in the UMU zone and availability of sites.

Timeframe: Annually track non-residential and mixed-use development and availability of sites to maintain the City’s ability to accommodate the remaining RHNA.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 2I: Coordinate with Chapman University to Address Student Housing The City will coordinate with Chapman University to respond to the housing needs of the growing student population and challenges relating to integration of student-oriented housing in existing residential neighborhoods. As part of 800
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this effort, the City will encourage development of on-campus housing through the University’s campus master planning process.

Objectives:
 Work with the Chapman University to undertake activities that may include, but are not limited to, surveying students to understand off-campus housing needs, identifying appropriate locations for and types of offcampus student housing, and establishing policies and procedures to address any issues with neighborhood integration.

Timeframe: Annually coordinate with Chapman University.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 2J: Development of Accessory Dwelling Units 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 work with property owners who come forward with interest in developing ADUs and/or questions regarding ADUs.

Objectives:
 Update 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.

Timeframe: Program feasibility analyzed within one year, with one additional year for implementation Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 2K: Create Accessory Dwelling Unit and Junior Accessory Dwelling Unit Monitoring Program The City will create a monitoring program to track ADU creation by RHNA affordability levels throughout the planning period. This will allow the City to monitor the development of accessory units at all income levels in relation to the anticipated development within the Housing Element. Additionally, the City will conduct an evaluation of ADU development within 2 years of the adoption of the 6th cycle Housing Element. If ADU development falls below what was assumed in the Housing Element, the City will take action within 6 months of completion of the ADU review to ensure that adequate capacity at each income level in maintained to meet the City’s RHNA needs.

Objectives:
 Create a monitoring program to track ADU creation by RHNA affordability levels throughout the planning period.

Timeframe: Adopt Monitoring Program by December 2023, review conducted every two years during the planning period
Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
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Housing Policy Action 2L: Candidate Sites Used in Previous Housing Elements Pursuant to State Housing law, candidate sites identified in this Housing Element to accommodate a portion of the City’s low- and very low -income RHNA that were identified in previously adopted Housing Elements must be rezoned to allow residential use by right at specified densities for housing developments in which at least 20 percent of the units are affordable to lower income households. By right shall mean the jurisdiction may not require any of the following discretionary actions, except if the project requires a subdivision:
 A conditional use permit
 A planned unit development permit
 Other discretionary, local-government review or approval that would constitute a “project” as defined in Section 21100 of the Public Resources Code (California Environmental Quality Act “CEQA”).

The City may impose objective design review standards on projects. The City has identified as part of this Housing Element update vacant and nonvacant sites that were used in previous Housing Elements to meet the current RHNA need. To accommodate the provisions of State law, the City shall streamline development review for projects on all nonvacant sites included in a prior Housing Element and all vacant sites included in two or more consecutive planning periods that meet the requirements of State housing law. These sites are identified in Appendix B.

Timeframe: By December 2024.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 2M: Development of Housing for Extremely Low and Lower-Income Households The City recognizes the importance of supporting the development of housing for low and extremely low income households. While the City is not a developer, 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:
 The City will adopt a program to subsidize application processing fees, when funding is available, 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.  The City will annually invite nonprofit developers to discuss the city’s plans, resources, development opportunities, and requests-for-quotes.
 The City will assist in the application for state and federal financial resources.  Promote the development of 535 units for extremely low income housing units throughout the planning period.

Timeframe: By December 2023; annually promote benefits of this program.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Goal #3: Effective maintenance, preservation, improvement and development of housing citywide.

Housing Policy Action 3A: Public Education
The City shall continue to provide the public information related to the development of housing through the continued promotion of educational materials. The information may describe incentives in the Orange Municipal Code that support the development of affordable housing and how the provisions of affordable housing benefits the community. 802
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This may take the form of community newsletter articles, information posted on the City’s website that is available to the public, and staff available to respond to inquiries.

Objectives:
 Annually outreach to the community with information on affordable housing development.

Timeframe: Maintain updated information online and annually outreach to the community.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 3B: Water and Sewer Purveyors
Pursuant to Chapter 727, Statues of 2005 (SB 1087), the City of Orange is required to deliver its adopted Housing Element and any amendments thereto to local water and sewer service providers, including the City’s own water provider services, Metropolitan Water District (MWD) and the Orange County Sanitation District (OCSD). This legislation allows for coordination between the City and water and sewer providers when considering approval of new residential projects.

Additionally, cooperation with local service providers will support the prioritization of water and sewer services for future residential development, including units affordable to lower-income households. The City will submit the adopted Housing Element to local water and sewer service providers for their review and consideration when reviewing new residential projects.

Objectives:
 Deliver the adopted Housing Element to local water and sewer service providers.

Timeframe: Immediately upon adoption of the 6th Cycle Housing Element Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 3C: Safety Element Update and adoption of an Environmental Justice Element SB 1035 requires that the City, after the initial revision of the Safety Element to identify flood hazards and address the risk of fire in certain lands upon each revision of the Housing Element, review and, if necessary, revise the Safety Element to identify new information relating to flood and fire hazards that was not previously available during the previous revision of the Safety Element. The City is currently in the process of revising the Safety Element and will take the document to City Council for adoption within 12 months of adoption of the 6th Cycle Housing Element.

SB 1000 (2018) requires that the City include an environmental justice component to the General Plan during the 6th Cycle update of the City’s Housing Element. The City is currently planning to perform a review of the existing General Plan to determine where environmental justice is currently addressed and where additional language is needed within the appropriate elements. The City will modify the General Plan to include additional Environmental Justice policies within 24 months of adoption of the 6th Cycle Housing Element.

Objectives:
 Update the Safety and Environmental Justice Elements.

Timeframe: Safety Element Update by June 2024, Environmental Justice policy update by June 2024 Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 3D: Community Outreach
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The City has hosted workshops and public meetings throughout the 2021-2029 Housing Element Update to gather public input and feedback as it relates to development of and access to housing. The City will extend outreach efforts throughout the planning period to continue gathering community input on, but not limited to, affordable housing, housing for special needs populations, and ADUs. The continued outreach will be City-wide with a focus on traditionally under-represented communities.

Objectives:
 Annually outreach and host a community meeting to discuss housing.

Timeframe: A minimum of one meeting held annually
Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 3E: Housing Rehabilitation Survey In order to ensure the maintenance, preservation, and improvement of housing throughout the City, an estimate of the number of units in need of rehabilitation is necessary.

Objectives:
 Yearly implement and assess a survey of the City’s housing stock to identify potential rehabilitation needs.

Based on the results, the City shall adopt additional policy actions such as, but not limited to, promoting funding opportunities and community outreach and education on available resources.

Timeframe: Survey conducted annually; potential follow-up policy actions to be adopted and implemented within 6 months of identifying a need
Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Goal #4: Equal housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin or color.

Housing Policy Action 4A: Affirmatively Further Fair Housing Pursuant to AB 686, the City will affirmatively further fair housing by taking meaningful actions in addition to resisting discrimination, that overcomes patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristic, as defined by California law.

The Housing Element contains analysis of regional and local contributing factors to fair housing issues within Orange and determined the following factors were applicable:
 Educational Opportunities: Countywide, there are disparities across racial/ethnic groups in access to educational opportunities as measured by the index. The City of Orange showed lower scores in educational opportunity, all with scores in the 30s to 40s on a scale of 100 for the composite education index, signifying low opportunity and resources.
 Environmental Opportunities: Countywide, there are disparities across racial/ethnic groups in access to environmental opportunities, measured as lower exposure to and effects from pollution. Across all tracts in Orange County, non-Hispanic Whites exhibit the highest access to environmentally healthy neighborhoods.

Orange City in one of the least environmentally healthy, with index scores in the 20s on a scale of 100 for the environmental opportunity index, signifying low opportunity and resources. 804
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 Economic Opportunities: In Orange County, there are significant disparities in access to economic opportunity. Non-Hispanic White residents have the greatest access to economic opportunity. The City of Orange has relatively large disparities by protected class groups, where Hispanic residents have significantly lower access to economic opportunity (economic access includes job access and opportunity, and other economic upward mobility opportunities) than other racial/ethnic groups.  Regional Opportunity, Place: The City of Orange has two census tracts which have low resources and are considered low access to opportunities for upward mobility of residents. Specifically, these areas have low opportunity for housing and civic life resources. These census tracts do not provide appropriate or sufficient housing access for current residents and therefore create fair housing barriers.

The City has identified specific goals to address fair housing issues, as contained in the Orange County Regional Analysis of Impediments to Fair Housing, 2020-25. The City’s stated fair housing goals include the following:

Table 4-1: AFFH Actions
Contributing
Factor Specific Commitments Timeframe Geographic Target Metrics Housing Mobility
Educational
Opportunities

1. Collaborate with high performing
school districts to promote a
diversity of students and staff to
serve lower income students and
identify potential resources for
students in-need.

Medium Priority –
Implement within 12
months of adoption
of the 2021-2029
Housing Element.

Annual outreach.

Regional The City has little
involvement in the
functioning of the local
School District’s
operations. The City can
commit to promoting
resources available to
lower scoring schools in an
effort to increase
educational opportunity
scores.
1Aim to assist a
minimum of 10
households, throughout
the 6th cycle, in accessing
available resources.

2. Collaborate with schools to
gather input and feedback from
parents on potential resource
and after-school program needs.

Medium Priority –
Implement within 12
months of adoption
of the 2021-2029
Housing Element.

City-wide The City’s Community
Services Department
offers an educational
after-school program in
collaboration with the
Youth Centers of Orange.

The City will engage with
members in relation to
programming and student
needs and continue the
program provided funding
remains available.1
Identify and pursue new
funding sources if needed.

Aim to assist a minimum
of 25 households
throughout the 6th cycle.
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Table 4-1: AFFH Actions
Contributing
Factor Specific Commitments Timeframe Geographic Target Metrics Regional
Opportunity,
Place

1. Collaborate with community land
trusts, and other relevant
affordable housing developer
and organizations, as a
mechanism to develop
affordable housing in highopportunity areas.

Medium Priority –
Implement within 12
months of adoption
of the 2021-2029
Housing Element.

Host one meeting
annually.

City-wide The City has good working
relationships with Orange
Housing Development
Corporation, Orange
Senior Housing, and
HomeAid, and will develop
outreach materials related
to housing opportunity
sites by December
2023. These entities each
have an affordable
housing project in the
works, all of which are
located in areas with high
concentrations of
employment and transit
service. The City will
continue coordination
with these groups to work
towards meeting
affordable housing needs
within the community.

Aim to develop 5
residential projects with
affordable housing units
from these relationships
and in high-opportunity
areas.

Housing Choice and Affordability in Areas of Opportunity Economic
Opportunities

1. Prepare a Transfer of
Development Rights Ordinance
to provide opportunities for
development transfers to
accommodate higher density
housing in transit- and
employment-rich areas of the
City. This will provide all
segments of the community with
improved economic
opportunities and access.

High Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide The City initiated work on
the Transfer of
Development Rights
Ordinance in July 2022. A
feasibility study was
completed for the
ordinance in early
2022. Adopt the
ordinance in late 2023.

2. Once the Transfer of
Development Rights Ordinance is
adopted, the City will promote it
to the development community
and relevant property owners.

Low Priority -
Implement following
the adoption of the
Ordinance. Outreach
annually.

City-wide Promote informational
materials annually once
the Ordinance is adopted.

Aim for outreach to result
in at least one transfer of
development rights
project for affordable
housing development over
the 6th cycle.
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Table 4-1: AFFH Actions
Contributing
Factor Specific Commitments Timeframe Geographic Target Metrics Regional
Opportunity,
Place

1. Continue to follow current State
Density Bonus law and further its
implementation through a
Density Bonus Ordinance
update.

Medium Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide Amend the Density Bonus
Ordinance by FY 23/24.

2. Prepare and adopt a Small Lot
Subdivision Ordinance to
streamline entitlement
processing of housing
development projects.

Medium Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide The City adopted a Small
Lot Subdivision Ordinance
in November
2021. Planning staff will
promote the ordinance to
housing developers as an
alternative development
type for housing in
Orange. Aim for outreach
to result in at least one
SLO project with an
affordable housing
component over the 6th
cycle.

Place-Based Strategies – Conservation and Revitalization Educational
Opportunities

1. Seek funding opportunities for
community assets and promote
available resources to schools
and relevant agencies and
organizations.

Medium Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide The City of Orange does
not provide direct funding
to the local School District
but does offer and
promote an after school
program in collaboration
with the Youth Centers of
Orange. The City’s Library
also offers free lunches
through the Summer Food
Service Program
administered by the
California Department of
Education for children and
teens under the age of

18. The Library also offers
a Homework Center for
children and teens.

The City will continue to
provide these programs
(contingent on funding
availability) to the
community which benefit
community assets and
promote equitable access
to community resources.
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Table 4-1: AFFH Actions
Contributing
Factor Specific Commitments Timeframe Geographic Target Metrics Environmental
Opportunities

1. Seek funding opportunities for
improving environmental
opportunities and promoting
sustainable transportation.

Medium Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

Annually review
available funding and
pursue new potential
opportunities.

City-wide The Public Works
Department and
Community Services
Department regularly seek
funding for park and trail
improvements, and
transportation
improvements that
support bicyclists and
pedestrians. Community
Development staff also
pursues funding
opportunities for longrange planning efforts that
incorporate policies and
actions designed to
retrofit the suburban
environment to be more
conducive to sustainable
transportation and
alternative modes.

Continue to monitor
available funding and
pursue additional funds.

Regional
Opportunity,
Place

1. Encourage residents from areas
of low resources to serve on
boards, committees, task forces,
and other local government
decision-making bodies.

High Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

Annually outreach to
target areas.

Low
resource
census
tracts
Engage City Council
Members in an effort to
outreach to target areas
identified as low resource
within their districts. Seek
to have a minimum of 2
individuals from target
areas serve on local
government decisionmaking bodies by the end
of the planning period.

2. Host an annual community
meeting with targeted outreach
to areas of low opportunities to
gather input and feedback from
residents and promote ways for
the community to remain
engaged.

Medium Priority -
Implement within 12
months of adoption
of the 2021-2029
Housing Element.

Host one meeting
annually.

Low
resource
census
tracts
Engage City Council
members to gather input
and feedback on
community engagement
opportunities within City
boards. Seek to improve
overall access to
opportunities and increase
civic engagement from
underrepresented
communities.1
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Table 4-1: AFFH Actions
Contributing
Factor Specific Commitments Timeframe Geographic Target Metrics

3. Expand access to community
meetings, including addressing
language barriers and meeting
times and access.

High Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide Provide Spanish language
translation services and
establish virtual
broadcasting and
participation for public
meetings by FY 23/24.

Protection from Displacement
Economic
Opportunities

1. Establish a small business
advocate office and/or a single
point of contact for small
business owners.

Low Priority –
Ongoing throughout
the 2021-2029
Housing Element.

City-wide The City’s Economic
Development staff is the
point of contact for small
and large business owners
and plays a role in
facilitating City
department coordination
and processes. This
organization has been
successful and the City will
continue to function in
this role during the
planning period.

2. Engage local small businesses to
hear and consider their needs
Medium Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide The City’s Economic
Development staff have a
very interactive
relationship with the
Chamber of Commerce
and local businesses. The
City will establish a small
business outreach
program with the
Chamber of Commerce.

3. Promote local small business on
the City’s website to increase
visibility and promote assistance
programs available to small
business owners.

Low Priority -
Implement within 24
months of adoption
of the 2021-2029
Housing Element.

City-wide Establish a small
businesses page on the
City’s website by FY 23/24.

Regional
Opportunity,
Place

1. Continue providing CDBG funds
to the Fair Housing Foundation to
provide fair housing activities to
the community.

High Priority –
Annually monitor
and pursue funding.

City-wide Annually monitor available
funding and pursue
additional funds.

Notes:

1. Action outcomes are difficult to quantify, but the City is dedicated to 1) providing quality education and supporting local students in accessing higher education and employment and 2) improving access to opportunities and civic engagement from underrepresented communities.

Timeframe: Monitor individual actions and timeframes annually Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
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Housing Policy Action 4B: Homeless Services
The City will continue to support local and inter-jurisdictional efforts to reduce temporary and chronic homelessness.

The City shall continue to promote a comprehensive approach to addressing homelessness consistent with the Continuum of Care model. Additionally the City provides support for the Navigation Centers in Buena Park and Placentia in the form of financial assistance for operations.

Objectives:
 Coordinate with 2-1-1 Orange County, non-profit entities, the Orange County Housing Authority and other applicable government agencies to provide a range of services and housing opportunities for homeless persons in Orange.

Timeframe: Annually coordinate with local organizations and entities.

Responsible Agency: City of Orange Community Development Department Funding Source: Former Redevelopment, CDBG, and PLHA funds

Housing Policy Action 4C: Support Fair Housing Services The City of Orange currently contracts with the Fair Housing Foundation which provides community education, individual counseling, mediation, and low-cost advocacy with the expressed goal of eliminating housing discrimination and guaranteeing the rights of all people to freely choose the housing for which they qualify in the area they desire.

The City refers all inquiries for these services to the Fair Housing Foundation and maintains literature and informational brochures at City Hall available for public distribution.

Objectives:
 Provide informational brochures at the City library, Senior Center and other locations frequented by the public.
 Continue the provision of fair housing assistance including landlord/tenant counseling and amelioration or removal of identified impediments and work with the Fair Housing Foundation to provide community education on fair housing throughout the year.
 Continue to contract with the Fair Housing Foundation or a similar agency for these services.

Timeframe: Annually promote information and maintain updated information; review fair housing assistance annually and on a case-by-case basis.

Responsible Agency: City of Orange Community Development Department Funding Source: CDBG funds
Housing Policy Action 4D: Section 8 Rental Assistance
On behalf of the City, the Orange County Housing Authority currently administers the Section 8 Rental Assistance program which assists renter households in the City. The City of Orange will continue to provide referral services and information to the City’s residents.

Objectives:
 Assist 484 households annually through the planning period.

Timeframe: Annually assist households; maintain updated information and outreach annually; and implement changes based on feedback from outreach.

Responsible Agency: Orange County Housing Authority
Funding Source: General Fund
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Housing Policy Action 4E: Support for Persons with Developmental Disabilities The City Staff will support the ability of persons with developmental disabilities to live in integrated community settings. The City will work with the Regional Center of Orange County to identify the housing needs of persons served by the Center, promote opportunities for supportive living services and support efforts to eliminate barriers to housing for persons with developmental disabilities.

Objectives:
 Annually outreach to and partner with the Regional Center of Orange County to identify the housing needs of persons served by the Center, promote opportunities for supportive living services and support efforts to eliminate barriers to housing for persons with developmental disabilities.

Timeframe: Annually outreach to and partner with the Regional Center of Orange County.

Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 4F: Housing for Persons with Disabilities The City will amend the Orange Municipal Code to be compliant with State law regarding residential care facilities serving seven (7) or more persons in all residential zones, as well as ensure barrier-free housing choices for persons with disabilities. The City will also provide information online and at City Hall on reasonable accommodation with respect to zoning, permit processing, or building laws.

Objectives:
 Update the Orange Municipal Code to comply with State law.  Provide information online and at City Hall on reasonable accommodation with respect to zoning, permit processing, or building laws.

Timeframe: Adopt Municipal Code amendment by December 2023; maintain update information online and at City Hall
Responsible Agency: City of Orange Community Development Department Funding Source: General Fund
Housing Policy Action 4G: Emergency, Transitional and Supportive Housing and Lower Barrier Navigation Centers The City will update the Orange Municipal Code to permit Low Barrier Navigation Center development as a matter of right in appropriate zoning districts, subject to requirements of state law. Per California Government Code Section 65660, low barrier navigation centers are defined as a Housing First, low-barrier, service-enriched shelter focused on moving people into permanent housing that provides temporary living facilities while case managers connect individuals experiencing homelessness to income, public benefits, health services, shelter, and housing. "Low Barrier" means best practices to reduce barriers to entry. These requirements include implementing standards, provisions and limitations governing the permitting, development, siting and management of Low Barrier Navigation Centers.

The City of Orange will continue to identify revisions and adopt amendments to the Municipal Code to comply with State law updates.

Objectives:
 Adopt an amendment to the Orange Municipal Code to permit Low Barrier Navigation Center in compliance with State law.
 Update the Orange Municipal Code to comply with State law. 811
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Timeframe: By December 2023, Reviewed Annually for updates in response to changes in State law Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 4H: Single Room Occupancy Units
The City will update the Orange Municipal Code to permit Single-Room Occupancy units in appropriate zoning districts, subject to requirements of state law. These requirements include implementing standards, provisions and limitations governing the permitting, development, siting, and management of Single-Room Occupancy units. The City of Orange will continue to make the appropriate revisions the Municipal Code to comply with California Government Code Section 65583(c)(1).

Objectives:
 Update the Orange Municipal Code to comply with State law.

Timeframe: By December 2023, Reviewed Annually for updates in response to changes in State law Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 4I: Farmworker and Employee Housing Act Compliance The City of Orange will update the Orange Municipal Code to comply with provisions for farmworker housing in compliance with the Employee Housing Act (Sections 17000-17062.5 of the California Health and Safety Code).

Objectives:
 Update the Orange Municipal Code to comply with State law.

Timeframe: By December 2023
Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

Housing Policy Action 4J: Emergency Shelter Development Standards The City of Orange Municipal Code currently requires emergency shelters to be located at least five hundred feet from any residential use or residentially-zoned property, public or private park, or public or private kindergarten through 12th grade curriculum school, as measures from the closest property line, as well as be located within half-a-mile of a transit stop. These requirements fall outside the scope of allowable standards relating to siting of homeless/emergency shelters per Government Code section 65583, subdivision (a)(4)(A).

Objectives:
 Amend the Municipal Code to be consistent with State law.

Timeframe: By December 2023
Responsible Agency: City of Orange Community Development Department Funding Source: General Fund

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C. Summary of Quantified Objectives
Table 4-2: Summary of Quantified Objectives
Income Group Extremely
Low1
Very Low Low Moderate Above
Moderate Total
New Construction (RHNA)2 1,671 units 677 units 1,588 units 3,936 units Accessory Dwelling Units 217 units 96 units 7 units 320 units Conservation/Preservation 51 units -- -- 51 units
Rental Subsidy -- -- -- --
Rehabilitation 16 units -- -- 16 units
Notes:
(1) Extremely Low Units are defined by HCD as half of the City’s Very-Low Income need. (2) New construction (RHNA) quantified objectives are inclusive of the Accessory Dwelling Unit production. 813
Appendix A: Review of Past Performance
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Review of Past Performance
Program Evaluation for Households with Special Needs
The City of Orange has demonstrated a significant effort in working towards accomplishing many of the objectives set for the programs of the past cycle. During the fifth cycle, the City completed a number of key programs to support housing opportunity and made substantial progress towards many of its programs. The City’s successful programs have been identified as continued for the sixth cycle, due to their success in the fifth cycle.

As a part of analyzing prior programs, the element must provide an explanation of the effectiveness of goals, policies, and related actions in meeting the housing needs of special needs populations. The table below provides an overview of the City’s prior program accomplishments; achievements related to special needs populations are summarized below:

Seniors
Section 2 shows that 17,076 persons were age 65 and over in Orange in 2019, a total of 12.2 percent of the total population. Senior Housing is permitted “by right” in all Residential and Mixed Use Zoning districts. In addition, OMC Chapter 17.15 provides for density bonuses and other incentives for Senior Housing.

The following projects either received final building inspections or were entitled during the planning period.  2016 – Code amendments adopted that allow senior housing in commercial districts  2017 - Final building inspections were completed for Encore Hewes Senior Apartments (12 age qualified multiple family rental units)  2018 - Final Building inspections were completed for Oakmont (98 assisted living units) and Prospect Senior Apartments (28 age-qualified multiple-family rental units)
 2019 - Project entitlements were completed for Orange Senior Housing (74 age-qualified low-income multiple-family rental units), Orange Sky Villas (23 age-qualified multiple-family rental units), and Sunrise Senior (93-unit, 120 bed senior assisted living and memory care facility). Additionally the City approved/is processing the ActivCare (under construction) and Park Plaza Memory Care (going through entitlement) facilities.
815
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2021-2029 Housing Element Update - Draft
Persons with Disabilities
According to the 2019 ACS, about eight percent of Orange’s population reported a disability. Of that 8 percent, ambulatory difficulty represented the highest at 48.9 percent of persons reporting a disability. Hearing and self-care disabilities totaled about 54.3 percent of the population with a disability, cognitive disabilities represented 39.1 percent and independent living difficulties represent 38.4 percent.

The City annually pursued focused outreach efforts with the Regional Center of Orange County to identify the needs of persons with development disabilities and to promote opportunities and eliminate barriers for housing.

During the planning period, the Orange County Housing Authority (OCHA) assisted the following number of renter households within Orange through the Section 8 Housing Choice Voucher (Rental Assistance) Program:
 FY 2013-14 - 455 Total (132 families, 217 elderly, 106 disabled households.  FY 2014-15 - 597 Total (177 families, 206 elderly, 153 disabled households.  FY 2015-16 - 454 Total (123 families, 218 elderly, 112 disabled households.  FY 2016-17 - 436 Total (110 families, 222 elderly, 104 disabled households.  FY 2017-18 - 460 Total (116 families, 236 elderly, 108 disabled households.  FY 2018-19 - 439 renter households.

OCHA also administered the rental assistance component of the Family Self-Sufficiency (FSS) Program, Family Unification Program (FUP), and Housing and Urban Development-Veterans Affairs Supportive Housing (HUD-VASH) Program. Each of these programs rental assistance for various at-risk groups with the intention of providing safe and sounds housing for all vulnerable members of the Orange population.

Large Households
Large households are defined as those consisting of five or more members. Large households typically have a limited supply of locally available, adequately sized and affordable housing units. According to the data large households made up 13.8 percent of all households in the City. Policy Action 5 below lists the City’s accomplishments in developing housing for large households, including over 1,800 residential units; many of which can accommodate large households.

In 2015, construction began on the Lemon Grove affordable housing project (82 affordable units) which included floor plans oriented towards large families. The development includes 58 units with 3 bedrooms and 2 bathrooms and was constructed during the planning period. 816
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2021-2029 Housing Element Update - Draft
Farmworkers
Farmworkers are defined as persons whose primary incomes are earned through seasonal agricultural work. Farmworkers have special housing needs because they earn lower incomes than many other workers and move throughout the year from one harvest location to the next. The 2019 ACS data reported that there were 5,407 persons employed in natural resources, construction, and maintenances occupations; of those, 205 persons were employed in the farming, fishing, and forestry industries.

As previously discussed, farm workers are not a significant portion of the Orange community. Their needs are accommodated through housing programs and policies that assist lower-income households in general rather than specialized programs, such as:
 Policy Action 4: Support and Outreach for Affordable Housing Production.  Policy Action 9: Support Community Housing Development Organization New Construction Projects  Policy Action 12: Affordable Housing Resource “Toolkit”  Policy Action 15: Acquisition/Rehabilitation of Multi-Family Residential Development Single-Parent Households
As shown in Section 2, single parent households make up 7.1 percent of total households. The City of Orange provides a number of community programs and resources for children which may assist single-parent households. The City of Orange, in partnership with the Youth Centers of Orange, offers after-school enrichment for children Kindergarten to 8th Grade. This after-school program includes group activities, homework help, a nutritional program, and a special focus on Character Development for a nominal fee. All scheduled programs are in conjunction with the OUSD academic calendar. After-school recreation programs are offered throughout the community at El Camino Real Park, Grijalva Park, and Killefer Park. The Teen Action Committee (T.A.C.) also offers activities and community projects for teens entering the 7th grade through 15 years of age.

Other community organizations and schools that provide resources for children in the City include:
 Youth Centers of Orange
 St. John’s Lutheran School District
 Orange Unified School District
 Covenant Christian School
 Oakridge Private School
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Persons Experiencing Homelessness (Unhoused)
According to the County’s Point in Time Count, persons experiencing homelessness included 193 unsheltered and 148 sheltered individuals.

In collaboration with a number of neighboring Orange County cities, the City of Orange participates in the North Services Planning Area (SPA) partnership. The North SPA Partnership is a joint collaboration that includes two full-service Navigation Centers to provide help to the region’s homeless. The Buena Park Center and the Placentia Center will provide homeless individuals a total of 250 beds, health resources, job skill training, and the ability to reconnect with lost family. These facilities join the two shelters already built by the City of Anaheim, which house another 326 beds.

In addition to participating in the North SPA, Orange has undertaken several other initiatives over the past few years to address local homelessness issue; including partnering with HomeAid of Orange County to develop the Orange Family Care Center. The Orange Family Care Center specializes in serving the needs of families who are experiencing homelessness and has over 55 beds.

The Orange Police Department’s Homeless Engagement, Assistance & Resource Team (HEART) program has been operating since 2013. HEART Officers engage daily with local homeless individuals, working with them one-on-one to help facilitate their re-entry back into mainstream society.

The Police Department also assists in providing resources and assistance through collaborations with local community organizations and agencies listed in Section 2.

Extremely Low Income Households
Very low-income households are those households that earn 50 percent or less of the median family income (MFI) for Orange County. Extremely low-income households are those households which earn less than 30 percent of the MFI. There are approximately 5,490 extremely low-income households in Orange (renters and owners).

The City currently has 34 total affordable housing developments. This includes 1,524 deed-restricted affordable units ranging from studios to three-bedroom units available for lower-income households, seniors, and workforce housing.

Review of Past Performance
The following Table A-1 is a review of the City of Orange’s housing project and program performance in the 2014-2021 Planning cycle. It is an evaluation of the 5th cycle’s Policy Program and considers all current and existing programs and projects as well as the most current accomplishments and effectiveness and appropriateness.
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 1: Processing Annexation of
East Orange General Plan Area
To maximize future residential
development potential in the City, the City
is in the process of annexing the East
Orange area into the City. This process
began in 2006 and shall continue until the
remaining portions of the area are included
within the City’s legal boundaries.

Annexation of
East Orange
Area
Annexation and residential construction in
East Orange was not pursued by the property
owner. The property owner has dedicated the
property to the County of Orange as
permanent open space. Residential
development is no longer anticipated for this
property.

Removed. Annexation of
this property is no longer
being considered at this
time. The City is continuing
to look for ways to
maximize future residential
development potential
within the City through the
6th Cycle Policy Actions
and Sites Inventory.

Policy Action 2: Annual Review of Housing
Element
Pursuant to HCD Requirements, the City
will continue to conduct an annual
implementation review of the Housing
Element. 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.

Annual Housing
Element Review
The City has completed an annual review of its
5th Cycle Housing Element as part of the
Annual Progress Reports (APRs) provided to
HCD yearly. The City has completed APRs
through 2019.

On-going. As required by
state law, the City will
continue to review the
current Housing Element
through the timely
completion of their Annual
Progress Reports.

Policy Action 3: Promotion of Affordable
Housing
The City recognizes the need for housing
Support and
encourage the
development of
42 ExtremelyWith the dissolution of Redevelopment
Agencies in 2011/2012, the City could no
longer promote affordable housing through
financial assistance programs through the
On-going. The City will
continue to promote the
development of affordable
housing through
819
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2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle affordable for all income segments of the
population, especially Lower-Income
households. The City will continue to
support and encourage the development of
housing affordable to Lower-Income
households through incentives such as
density bonuses.

Low Income
Housing Units,
41 Very LowIncome Housing
Units, 59 LowIncome Housing
Units
Orange Redevelopment Agency. The City
maintained efforts to promote affordable
housing through outreach, density bonus,
regulatory incentives and some limited funding
when available.

Housing Development accomplishments within
the 5th Cycle planning period include:
2014 - The City issued building permits for 336
moderate income and 12 above moderate
income units.
2015 - The City issued building permits for 264
moderate income and 3 above moderate
income units.
2016 - the City issued building permits for 9
deed-restricted very-low income units, 72
deed-restricted low income units, 4 moderate
income units, and 22 above moderate income
units.
2017 - The City issued building permits for 4
moderate income units and 75 above
moderate income units.
2018 - The City issued building permits for 10
moderate income units and 19 above
moderate income units.
community outreach,
education, density bonus,
regulatory incentives and
funding when possible.

Additionally, the City has
been successful in
partnering with local
organizations to promote
the development of
affordable housing. The
City will continue to
partner with the Orange
Housing Development
Corporation (OHDC) on the
development of affordable
housing units within the
City and seek out additional
opportunities to partner
with non-profit
organizations.

The City currently is
processing entitlement
applications for a joint
partnership affordable
housing projects with
Sisters of St. Joseph of
Orange and Mercy Housing.

The proposed project
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle 2019 - The City issued building permits for 662
moderate income units and 418 above
moderate income units.

The City has been very successful in permitting
and constructing housing at all income levels
over the 5th Cycle RHNA planning period. In
addition to the building permits discussed, the
City has a number of other projects currently
in various stages of the entitlement process.

While most projects have not defined levels of
affordability for their units, some are on
"housing opportunity sites" and units are
anticipated to be accessible to households
with a range of income levels, some of which
may fall into affordable categories.

In 2019, the City began a new project,
continuing its partnership with the Orange
Housing Development Corporation (OHDC) to
develop supportive housing. OHDC is a
nonprofit organization dedicated to providing
secure, clean and attractive housing for
families of low and moderate incomes. The
partnership with OHDC has successfully
resulted in the Citrus Grove and Lemon Grove
(82 affordable units) projects.
includes senior housing
units and affordable rental
units for homeless families.

Additionally the City will
continue to process
projects with OHDC in the
future.

Policy Action 4: Support and Outreach for
Affordable Housing Production
Support and
outreach for
With the dissolution of Redevelopment
Agencies in 2011/2012, the City could no
On-going. The City
continues to promote
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Continue to promote the development of
new housing affordable to Extremely Low-,
Very Low and Low-Income households
where such development will promote a
balanced inventory of housing types. The
City shall continue to outreach to the
development community, seek
partnerships and provide in-kind assistance
in developing new affordable housing.
development of
affordable
housing units
longer promote affordable housing through
financial assistance programs through the
Orange Redevelopment Agency. The City
maintained efforts to promote affordable
housing through outreach, density bonus,
regulatory incentives and some limited funding
when available.

In 2017, an affordable housing toolkit, which
provides internet-based resources for the
public and development community was
completed and posted on the City’s website.

The City has a long standing relationship with
the Orange Housing Development Corporation
(OHDC) to develop supportive housing. OHDC
is a nonprofit organization dedicated to
providing secure, clean and attractive housing
for people of low and moderate incomes.

OHDC was founded in 1990 and has partnered
with the City of Orange for years to develop
affordable housing projects, including Serrano
Woods, Citrus Grove, Alice Clark Orange
Blossom, Esplanade Apartments and more.

Refer to Policy Action 3 for a list of Orange's
successful progress in permitting units at a
range of affordability levels, including low and
very-low income units.
affordable housing through
outreach, density bonus,
regulatory incentives and
some limited funding when
possible. The City will
continue in the 6th Cycle
planning period to pursue
methods of outreaching to
the local development
community, including nonprofit developers, to
explore partnerships and
provide in-kind assistance
in developing affordable
housing within Orange.
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 5: Development of Housing
for Large Families
Continue to encourage and support
through outreach to private and non-profit
housing developers, the development of
rental and for-sale housing for larger (5 or
more persons) families. Encourage
developers/builders to incorporate larger
bedroom counts (3 or more bedrooms) to
accommodate the needs of larger families
and reduce incidents of overcrowding in
the existing housing stock. The City will
evaluate providing regulatory incentives
such as density bonuses that encourage
and support the development of housing
for large families on a project-by-project
basis.

Support and
encourage the
development of
New Housing
Units for Large
Families
The following is the City's progress during the
5th Cycle RHNA planning period in developing
housing suitable for large families (3+
bedrooms). With the exception of the age- or
health-qualified projects and ADUs, all
residential units shown below included floor
plans that may facilitate large families in the
unit mix.
2014 - The City constructed two housing units
which may accommodate large families.
2015 - The City finaled 9 new residential units,
5 of which may accommodate large families.

Construction began on the Lemon Grove
affordable housing project (82 affordable
units) which included floor plans oriented
towards large families.
2016 - The City finaled 5 residential units,
three of which could accommodate large
families.
2017 - The City issued final building inspections
on 474 residential units. Not all units were
specifically for large families.
2018 - The City received final inspections on
343 residential units. Not all units were
specifically for large families.

On-going. The City will
continue to promote the
development of housing
suitable for large families.

In recent years Orange has
seen a number of large
apartment projects
constructed, most of which
have a portion of their unit
mix dedicated to 3+
bedroom units.

Additionally, there have
been a number of new
single-family residences
constructed within Orange
during the planning period,
the majority of which may
accommodate large
families.
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle 2019 - The City issued 1,008 building permits,
the majority of which were apartments and
single-family homes. Not all units were
specifically for large families.

Policy Action 6: Provision of Senior
Housing Opportunities
The City recognizes the unique needs of its
elderly residents. Seniors typically have
fixed incomes and unique housing needs
such as physical limitations requiring
accessibility features that are not typically
included in market rate housing. The City
shall continue to encourage through
regulatory incentives the development of
senior housing that offers a wide range of
housing choices from independent living to
assisted living with on-site services. The
City currently has
special incentives for senior housing, as
provided in Section 17.15 of the Zoning
Code.

To further encourage development of
housing for seniors, the City shall evaluate
the existing provisions in the Zoning Code
for additional opportunities for regulatory
relief on a project-by project basis.

Senior Housing
Development
Senior Housing is permitted “by right” in all
Residential and Mixed Use Zoning districts. In
addition, OMC Chapter 17.15 provides for
density bonuses and other incentives for
Senior Housing. Senior housing is also
permitted, subject to Conditional Use Permit
approval within commercial zones. The
Commercial Code includes development
standards (Urban Mixed Use zoning standards)
designed to encourage and facilitate infill
senior housing development close to goods
and services.

The following projects either received final
building inspections or were entitled during
the planning period.
2016 – Code amendments adopted that allow
senior housing in commercial districts
2017 - Final building inspections were
completed for Encore Hewes Senior
Apartments (12 age qualified multiple family
rental units)
On-going. The City has
been extremely successful
in permitting and
constructing a number of
Senior Housing projects.

The City will continue to
promote the development
of senior housing
opportunities at all income
levels.
.
824
Appendix A: Review of Past Performance A-12
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle 2018 - Final Building inspections were
completed for Oakmont (98 assisted living
units) and Prospect Senior Apartments (28
age-qualified multiple-family rental units)
2019 - Project entitlements were completed
for Orange Senior Housing (74 age-qualified
low-income multiple-family rental units),
Orange Sky Villas (23 age-qualified multiplefamily rental units), and Sunrise Senior (93- unit, 120 bed senior assisted living and
memory care facility). Additionally the City
approved/is processing the ActivCare (under
construction) and Park Plaza Memory Care
(going through entitlement) facilities.

Policy Action 7: Facilitate Infill
Construction
The City has a 2014-2021 RHNA need of
363 housing units for Extremely Low-, Very
Low-, Low and Moderate-Income
households. The City has limited vacant
land available for residential development
and no vacant land zoned at densities to
support affordable housing. Therefore, the
City will continue to encourage infill
development within feasible development
sites for homeownership and rental units
Support and
facilitate the
development of
363 infill
housing units
In 2017, the City developed a parcel list and
maps highlighting properties that were
identified in the Housing Element as "housing
opportunity sites". This list is available to the
public and intended to facilitate the
development of affordable housing on infill
sites. Previously this list was available to the
public through the adopted 5th Cycle Housing
Element.

In 2019, the City completed actions that
brought W. Katella Zoning into consistency
with the General Plan for Urban Mixed-Use.

On-going. The City has
been successful in
developing housing on infill
sites as much of the land
within the city limit is
developed and little viable
vacant land exists. The
majority of this
development has been
within the low-, moderateand above moderateincome categories. 825
Appendix A: Review of Past Performance A-13
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle affordable to Extremely Low-, Very Low-,
Low- and Moderate-Income households.

The City will continue to facilitate infill
development through implementation of
its General Plan and Zoning Code, which
allows for higher density housing in
appropriate areas of the City where
potential exists for site redevelopment. In
addition, the City will encourage
compatible residential development
integrated into existing neighborhoods and
districts where appropriate.

To further encourage infill housing
development, the City shall evaluate the
existing provisions in the Zoning Code for
feasibility of providing additional regulatory
relief (i.e., streamlined review, reduced
development standards, lot consolidation,
and other methods deemed appropriate).

The City will identify and develop an
inventory of potential infill sites utilizing
the site analysis found in Appendix B of the
Housing Element. The City will seek
partnerships with and provide
informational material including a copy of
the inventory and listing of City incentives
and programs to housing developers.

The following new dwelling units were
received building permits on infill sites during
the planning period:
2014 - 3 new infill units
2015 - 9 new infill units
2016 - 5 new infill units
2017 - 474 new infill units
2018 - 343 new infill units
2019 - 1,051 new infill units
The City continues to
evaluate their zoning code
to encourage the
development of infill
housing and remove
potential constraints to
infill development.
826
Appendix A: Review of Past Performance A-14
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 8: Explore Alternative
Funding and Financing Sources
The City of Orange currently has limited
funding and financing sources to incentivize
new affordable housing development.

Previously, the City utilized Redevelopment
funds and Federal HOME funds to assist in
the development of new housing. In order
to maximize the opportunities for new
housing development, the City will
continue to use HOME funds, and explore
alternative funding and financing sources
such as public-private partnerships.

Funding and
Financing for
Housing
Development
With the dissolution of the Orange
Redevelopment Agency (ORA), funding sources
for housing development continue to be
limited. Federal HOME Investment
Partnerships funds and Low and Moderate
Income Housing Asset Funds (LMIHAF)
[program income from former ORA Housing
Set-Aside funds] are the City’s only remaining
funding sources for housing development and
are very limited.

The City also has limited Community
Development Block Grant (CDBG) funds, which
could be allocated for housing rehabilitation.

However, these funds are typically allocated to
City and nonprofit agency public services and
public facilities, and City infrastructure
projects in low income residential areas.

In 2014, the City began negotiations with a
partnership of the Orange Housing
Development Corporation (OHDC) and C&C
Development Co. to provide financial
assistance for the Lemon Grove Apartment
Projects (affordable rental housing). This
project was entitled in 2015 and later
constructed. “Additionally, the City completed
the OHDC Corp Yard Project and the Orange
Senior Housing project (financed in part by the
sale of Triangle Terrace, the sale of which was
On-going. No applications
were received for any
income-restricted projects
in recent years, however
the City continues to
explore creative
opportunities to provide
funding and other
resources to developers
and organizations looking
to build affordable housing
with Orange.

In the 6th Cycle RHNA
planning period, the City
intends to explore
alternative funding options
for new housing
development.
827
Appendix A: Review of Past Performance A-15
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle leveraged by the city for construction of more
senior affordable units.

Policy Action 9: Support Community
Housing Development Organization New
Construction Projects
Provide funding for qualified CHDO’s to
develop affordable housing. (Currently the
City’s only qualified CHDO is the Orange
Housing Development Coordination.) The
City will continue to seek qualified nonprofit organizations for acquisition, construction and rehabilitation of
affordable housing. Funds will be made
available on an annual basis, contingent on
funding availability.

CHDO Support Although no CHDO applications are currently in processing, the City partnered with Orange
Housing Development Corporation (OHDC) on
the development of the affordable 82-unit
Lemon Grove Apartments project, which was
completed in October 2017. OHDC is the only
CHDO in the City of Orange currently.

The City provided a $1.3 million loan of HOME
funds to cover a portion of the project costs in
return for 55-year affordability covenants.

On-going. This City
successfully worked with
OHDC, the only CHDU
within the City or Orange
during the 5th Cycle RHNA
planning period. The City
will continue to seek
opportunities to work with
non-profit organizations for
the development of
affordable housing during
the 6th Cycle RHNA
planning period.

Policy Action 10: Monitoring Adequate
Sites for Housing Development
The City has a 2014-2021 RHNA need of
363 housing units for Extremely Low-, Very
Low-, and Low-Income households. To
ensure the availability of adequate sites
within the Urban Mixed Use zoning districts
to accommodate the remaining RHNA need
for Lower-Income households, the City of
Orange shall continue to require nonresidential and mixed use projects in the Urban Mixed Use (UMU) zoning districts
only be approved when a finding can be
Adequate Sites
for Housing
The City adopted the Orange General Plan
update in March 2010. Approximately 426
acres are General Planned Urban Mixed Use
(UMU). Mixed Use Zoning was adopted in July
2011. To date, 292 acres (this includes the
2017 approved Zone Change from Commercial
Recreation (C-R) to Urban Mixed Use (UMU)
for the Branch West Apartments project) have
been zoned Urban Mixed Use.

The Urban Mixed Use zone allows for 30 to 60
dwelling units per acre, thus providing
opportunities for development of affordable
housing. In order to approve non-residential
Completed. The City was
successful in monitoring
the development of
housing at all income levels
within the 5th Cycle RHNA
Planning Period through
the frequent updating of
their RHNA Sites
Monitoring Database.

SB 6 requires the City to
create a process for and
maintain and internet
accessible database of land
828
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle made that the project will not reduce
UMU-zoned land available for residential
development such that the City can no
longer accommodate its remaining RHNA
need. The City will continue to track the
availability of UMU-zoned sites greater
than one half-acre in size through its RHNA
Housing Sites Monitoring System to ensure
a minimum of 12.1 acres of UMU-zoned
land is available for residential
development. The monitoring system will
adjust the acreage needed based upon the
City’s remaining need for Lower-Income
housing units on a project-by-project basis.

The monitoring system shall be updated on
a project-by-project basis and an annual
monitoring report shall be provided to the
City Council in conjunction with annual
progress reporting requirements pursuant
to Government Code section 65400.
and mixed-use projects in Urban Mixed Use
zones, the decision-making body must first
make the finding that the project will not
reduce the amount of land available that is
designated Urban Mixed Use such that the
City's RHNA goals cannot be met.
in 2014, the City established a RHNA Sites
Monitoring Database. The database is
maintained by City staff as development
occurs.
suitable for residential
development as identified
in the City's Housing
Element. The City will
include a program in the
6th Cycle Housing Element
that meets the sites
monitoring requirements
of State law.

Policy Action 11: Review and Amendment
of Residential Development Standards
To respond to changing market trends and
encourage continued provision of housing
opportunities for Orange residents, the City
will review and revise the existing Zoning
Code, including residential development
standards, as appropriate. The City shall
evaluate modifications and/or revisions
Review and
Revise Zoning
Code
Zoning Code updates focusing on streamlining
the process and clarifying development
standards for residential development were
initiated in 2015, and adoption occurred in
2016. Specifically, the Code was amended to
provide greater accommodation of certain
types of housing in the Public Institutions zone
and to be of greater accommodation to and
incentive for senior housing development in
commercial zones. The intent of the Code
Completed. The City
completed a number of
Zoning Code updates
during the 5th Cycle, many
of which promote the
development of residential
development by expanding
the areas in which
residential development
can occur, increased
829
Appendix A: Review of Past Performance A-17
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle that further increase the feasibility of
residential development while maintaining
safety and quality of life standards.

Amendments and modifications to the
existing Zoning Code may address mixeduse development standards, infill development standards, and multi-family
and single-family development standards.
changes are to accommodate housing that is
functionally related to an institutional use such
as assisted living and employee housing.

Zoning Code updates were completed in 2017
aimed at implementing changes in accordance
with the provisions of State Law, streamlining,
and improving zoning standards and
procedures. These updates included changes
to the Code to promote the development of
accessory dwelling units. Additional updates
addressed providing relief to parking and
loading requirements for multi-family
residential uses.

Zoning Code updates were completed in 2018
to expand the existing local Old Towne Historic
District and to create a historic district overlay
zone for three Eichler Tracts. The zoning code
was also updated to include a Master Land Use
Table and consolidate use standards. Staff
also began updates to sign standards, citywide parking standards, and density bonus regulations.

In 2019, staff updated the Homeless Shelter
Ordinance to decrease the separation
requirement and increase the number of beds
permitted at a shelter. Additionally, staff
worked on several Code updates, including
development of ADUs, and
relief from constraints to
development caused by
existing code requirements.

The City continues to
evaluate the current Zoning
Code on an annual basis
and has made updates
relating to the streamlining
of the development
process, improved
procedures, and the
promotion of accessory
dwelling units.
830
Appendix A: Review of Past Performance A-18
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle updates to sign standards and city-wide
parking standards. These updates are
expected to be completed in 2020.

The City is currently in the process of
preparing a Small Lot Subdivision Ordinance
which would provide a mechanism in the City’s
Municipal Code for accommodating nontraditional development formats and streamlining residential development on
smaller infill residential sites.

Policy Action 12: Affordable Housing
Resource “Toolkit”
To ensure the development community is
aware of the availability of State, Federal
and local funds as well as local in-kind
assistance, the City shall develop an
affordable housing resource “toolkit”.

The toolkit shall provide for dissemination
of information regarding funding/financing
options available at the Federal, State and
local level, incentives, partnership
opportunities and other resources that will
promote a well-informed citizenry. The
“toolkit” approach shall provide the public
with sources intended to educate and
inform. The “toolkit” will be an internetbased resource, allowing for easy update, Affordable
Housing
Resource
“Toolkit”
In 2014, the City began the development of an
affordable housing toolkit focused on
providing internet-based resources for the
public and development community. The
toolkit was completed and posted on the City’s
website in 2017.

The toolkit provides information on the City's
density bonus ordinance, development
incentives available to developers who provide
affordable housing through density bonus,
potential ability to defer impact fees which
makes projects more feasible, and various
funding sources that may be available to
developers who pursue affordable housing
components as part of their projects.

Completed. The City
successfully completed this
program in 2017 and the
Affordable Housing
Resource Toolkit is
available for use on the
City's website.
831
Appendix A: Review of Past Performance A-19
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle and contain information such as an
inventory of housing opportunity sites, a
contact list, and links to affordable housing
resources.

Policy Action 13: Balance Housing with
Needs of Local Employees
The City shall explore the housing needs of
people currently working in Orange to
maximize the potential for residents to live
and work in the City. The City shall
coordinate with the Chamber of
Commerce, local business entities and
stakeholder groups to analyze the current
needs of the business community and its
employees. Based upon the analysis of
these needs, the City will develop a
strategy to be used as a guidance tool for
future partnerships and policy and
regulatory revisions to facilitate housing
local employees.

Workforce
Housing
Strategy
Zoning that can accommodate development of
workforce housing was put in place in the
City’s Mixed Use Zoning districts in 2011. Code
changes were initiated in 2015 to provide
greater opportunities for the development of
housing in the Public Institutions zone.

Since 2014, the City has entitled or
constructed a number of projects within close
proximity to major employers including UC
Irvine Medical Center, St. Joseph Hospital,
Children's Hospital of Orange County, and the
Orange County Transit Authority. These
projects include AMLI (334 rental units),
Branch West Apartments (94 rental units), The
Orange Collection (821 rental units), Eleven 10
Apartments (260 rental units), 999 Town and
Country Apartments (250 rental units, and
Town and Country Townhomes and
Apartments (653 rental units and 74
ownership units).

New housing in the Urban Mixed Use district
are generally being developed or proposed for
development at a density of 60 units/acre.

Furthermore, in 2016, the City adopted
Completed. The City
successfully developed
hundreds of new
residential units in close
proximity to major
employment centers within
Orange. As employment
trends change, the City will
continue to promote the
development of housing
that provides the
opportunity for people to
live and work within
Orange.
832
Appendix A: Review of Past Performance A-20
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle provisions for the development of housing in
the Public Institutions zone, ancillary to
hospitals or other major medical uses which
may facilitate greater opportunities. These
industries are major employers in the City.

Policy Action 14: Coordinate with
Chapman University to Address Student
Housing
The City will coordinate with Chapman
University to respond to the housing needs
of the growing student population and
challenges relating to integration of
student-oriented housing in existing
residential neighborhoods. The City will
work with the University to undertake
activities that may include, but are not
limited to, surveying students to
understand off-campus housing needs,
identifying appropriate locations for and
types of off-campus student housing, and
establishing policies and procedures to
address any issues with neighborhood
integration.

Address Student
Housing within
Orange
Neighborhoods
In 2014, the City initiated preliminary
discussions regarding the impact of the
student population on rental housing costs
near Chapman University.

In late 2016, Chapman University purchased

2.14 acres of surplus land from the City of
Orange adjacent to Panther Village, an existing
Chapman University student housing facility.

In 2017, the Villa Park Orchards Dormitory
Project was approved, which is a 400-bed
multi-family residential project in close
proximity to the University. Building permits
were issued in 2018.

In 2018, the City did not receive an application
from Chapman University for development of
the Panther Village site with additional student
housing in that location; however there is
potential for future student housing on the
site. The City approved parking lot
improvements at the site that enable an
increase in the occupancy of the complex by
students.

On-going. The City will
continue to pursue
opportunities for
development adjacent to
Chapman University to
respond to the needs of the
growing student population
and work collaboratively
with the University to
ensure university
sponsored student housing
is developed in conjunction
with any increases in
student enrollment.
833
Appendix A: Review of Past Performance A-21
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 15:

Acquisition/Rehabilitation of Multi-Family
Residential Development
Subject to available funding sources
annually, the City will provide for financing,
regulatory incentives and other in-kind
technical assistance to non-profits,
affordable housing developers and
property owners for the
rehabilitation/acquisition of multi-family
properties for affordable housing. Ensure
affordability is maintained long-term
through restriction and/or covenants.

Prioritize and target those buildings
exhibiting the highest levels of deferred
maintenance.
4 units annually The Orange Redevelopment Agency provided financial assistance for
acquisition/rehabilitation projects for several
years. With the dissolution of the Orange
Redevelopment Agency in 2012, funding was
not available to assist these projects.

Specifically, in the past the City’s Home
Improvement Program offered grants and zero
percent loans to Low Income owner/occupants
of single-family homes and mobile homes for a
number of years.

The City terminated its Home Improvement
Program in FY 2012-13 due to the elimination
of the Redevelopment Agency in February
2012 and resulting lack of funding. The City will
not directly fund a City Home Improvement
Program for the foreseeable future. If
approached by a qualified nonprofit agency,
the City would consider funding rehabilitation
programs contingent on funding availability.

During FY 2013-14, the City provided a $20,000
subgrant of Community Development Block
Grant (CDBG) funds to Paint Your Heart Out,
Inc. for the Orange Paint Day Program. The
Program provided free home improvements to
five Low Income owner/occupants of singlefamily homes and three Low Income mobile home owner/occupants.

On-going. Due to a lack of
Redevelopment Agency
funds, the City provided
funds for the rehabilitation
of 8 total dwelling units.

The City will continue to
explore funding sources
and opportunities for the
potential acquisition and
rehabilitation of affordable
multi-family residential
units.
834
Appendix A: Review of Past Performance A-22
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 16: Homeless Services
Continue to support local and interjurisdictional efforts to reduce temporary and chronic homelessness. The City of
Orange shall continue to promote a
comprehensive approach to addressing
homelessness consistent with the
Continuum of Care model. The City shall
coordinate with 2-1-1 Orange County, nonprofit entities, the Orange County Housing Authority and other applicable government
agencies to provide a range of services and
housing opportunities for homeless
persons in Orange.

Coordination/Re
ferral
Throughout the planning period, the City
allocated CDBG funds to nonprofit agencies
that provided supportive housing and services
for the homeless or those at risk of becoming
homeless. Additionally, the City allocated
CDBG funds to nonprofit agencies that
provided public services programs. Although
not specifically designed to assist the
homeless, these intervention programs often
help to prevent homelessness. The City
assisted the following number of people
through various funding programs:

FY 2013-14 - Assisted over 3,800 people
FY 2014-15 - Assisted over 4,000 people
FY 2015-16 - Assisted over 5,780 people
FY 2016-17 - Assisted over 880 people
FY 2017-18 - Assisted over 1,930 people
In 2016, building permits were ministerially
approved for the “Citrus Family Shelter”, a 56
bed emergency shelter for homeless families.

In 2017, final building inspection was received
and the shelter is successfully in operation.

City Council adoption of Ordinance 06-12
pursuant to SB 2 facilitated the approval of the
shelter.

In 2018, the City worked with the shelter for
operational needs and promoted the shelter
On-going. The City was
successful in funding
multiple non-profit
agencies that provide
supportive housing and
services for community
members facing
homelessness through
CDBG grants. The City will
continue to assist these
and other organizations
provided CDBG funds
remain available. The City
continues to look for
alternative methods to
provide services and
housing opportunities for
homeless persons in
Orange.
835
Appendix A: Review of Past Performance A-23
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle via seeking and receiving an American
Planning Association, Orange County Chapter
Award. Additionally, the received recognition
by the Orange County Business Council (OCDC)
as a Leading Innovator in “Cutting Red Tape”
for its partnership with HomeAid of Orange
County for the development of the Orange
Family Care Center.

In 2019, the City passed an ordinance
amending the Orange Municipal Code to
modify the Special Use Regulations for
homeless shelters, reducing the distance
between shelter separation requirements from
300 feet to 275 feet and increasing the
maximum number of beds per facility from
100 to 150.

Policy Action 17: Support Fair Housing
Services
The City of Orange currently contracts with
the Fair Housing Foundation which
provides community education, individual
counseling, mediation, and low-cost
advocacy with the expressed goal of
eliminating housing discrimination and
guaranteeing the rights of all people to
freely choose the housing for which they
qualify in the area they desire. The City
refers all inquiries for these services to the
Coordination/
Referral
The City contracted with the Fair Housing
Foundation (FHF) in FY 2013-14 to provide fair
housing education, counseling, enforcement,
and related housing activities to affirmatively
further housing on behalf of the City to comply
with federal regulations. During the 6th Cycle
RHNA planning period, FHF has addressed the
following cases:

FY 2013-14 - 25 discrimination allegations and
289 landlord/tenant disputes
FY 2014-15 - 11 discrimination allegations and
269 landlord/tenant disputes
On-going. The City
successfully supported fair
housing services through
their partnership with FHF.

The City will continue to
contract with FHF to assist
in eliminating housing
discrimination within
Orange.
836
Appendix A: Review of Past Performance A-24
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Fair Housing Foundation and maintains
literature and informational brochures at
City Hall available for public distribution.

In order to more effectively outreach to the
community the City will also provide
informational brochures at the City library,
Senior Center and other locations
frequented by the public. The City will
continue the provision of fair housing
assistance including landlord/tenant
counseling and amelioration or removal of
identified impediments. The City will work
with the Fair Housing Foundation to
provide community education on fair
housing throughout the year. The City will
continue to contract with the Fair Housing
Foundation or a similar agency for these
services.

FY 2015-16 - 14 discrimination allegations and
287 landlord/tenant disputes
FY 2016-17 - 10 discrimination allegations and
223 landlord/tenant disputes
FY 2017-18 - 19 discrimination allegations and
224 landlord/tenant disputes
FY 2018-19 - 156 total households
Policy Action 18: Section 8 Rental
Assistance
The Orange County Housing Authority
currently administers the Section 8 Rental
Assistance program on behalf of the City.

Currently the program assists renter
households in the City of Orange. Based on
future congressional appropriations, the
County Housing Authority will apply for
additional funding which will enable the
Housing Authority to administer additional
483
households/
year
During the planning period, the Orange County
Housing Authority (OCHA) assisted the
following number of renter households within
Orange through the Section 8 Housing Choice
Voucher (Rental Assistance) Program:

FY 2013-14 - 455 Total (132 families, 217
elderly, 106 disabled households.

FY 2014-15 - 597 Total (177 families, 206
elderly, 153 disabled households.

FY 2015-16 - 454 Total (123 families, 218
elderly, 112 disabled households.

On-going. OCHA has not
received sufficient Housing
and Urban Development
(HUD) funding annually
throughout the planning
period to meet the goal of
483 households per year.

The City will continue to
support OCHA’s
applications for Section 8
vouchers as well as the
837
Appendix A: Review of Past Performance A-25
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle vouchers for families, elderly, and persons
with disabilities over the Housing Element
planning period. The City of Orange will
continue to provide referral services and
information to the City’s residents.

FY 2016-17 - 436 Total (110 families, 222
elderly, 104 disabled households.

FY 2017-18 - 460 Total (116 families, 236
elderly, 108 disabled households.

FY 2018-19 - 439 renter households.

OCHA also administered the rental assistance
component of the Family Self-Sufficiency (FSS)
Program, Family Unification Program (FUP),
and Housing and Urban DevelopmentVeterans Affairs Supportive Housing (HUDVASH) Program. Each of these programs rental assistance for various at-risk groups with the
intention of providing safe and sounds housing
for all vulnerable members of the Orange
population.
continuation of the FSS
Program, FUP, HUD-VASH
Program, and NED
Program.

Policy Action 19: Support for Persons with
Developmental Disabilities
Support the ability of persons with
developmental disabilities to live in
integrated community settings. The City
will work with the Regional Center of
Orange County to identify the housing
needs of persons served by the Center,
promote opportunities for supportive living
services and support efforts to eliminate
barriers to housing for persons with
developmental disabilities.

Housing for
Persons with
Developmental
Disabilities
The City annually pursued focused outreach
efforts with the Regional Center of Orange
County to identify the needs of persons with
development disabilities and to promote
opportunities and eliminate barriers for
housing.

On-going. The City will
continue to outreach to the
Regional Center of Orange
County to address and
eliminate barriers for
housing, provided
resources remain available
to do so.
838
Appendix A: Review of Past Performance A-26
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Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 20: Single Room Occupancy
Units
The City recognizes the opportunity for
Single Room Occupancy (SRO) units to
meet housing needs of the community,
especially Extremely-Low, Very-Low and
Low-Income households. The City shall
develop and implement a SRO ordinance
that amends the Zoning Code to include
definitions and development standards for
the use.

Implement SRO
Ordinance
The City began efforts in 2014 to draft and
adopt an Ordinance amendment concentrated
on identifying opportunities for supportive
housing and the homeless crisis in Orange
County.

In 2020, the City completed the SRO
ordinance. The SRO contains a menu of
options for addressing the homeless crisis in
the area.

Completed. The City
completed their SingleRoom Occupancy
Ordinance in early 2020.

Policy Action 21: Revise Ordinance to
Comply with State Law Regarding
Transitional and Supportive Housing
To accommodate transitional and
supportive housing, the City will amend its
zoning ordinance in accordance with
Government Code Section 65583(a)(5) to
consider transitional housing and
supportive housing as a residential use of
property, subject only to those
development standards that apply to other
residential dwellings of the same type in
the same zone.

In addition, definitions for “transitional
housing” and “supportive housing” will be
revised consistent with Government Code
Section 65582.

To
accommodate
the
development of
transitional and
supportive
housing in
compliance with
State law
The City began efforts in 2014 to draft and
adopt an Ordinance amendment to bring the
City in compliance with State law regarding
transitional and supportive housing.
in 2017, the "Citrus Shelter", a 56 bed
emergency shelter for homeless families
received final building inspections and
successfully began operation.

In 2019, the City discussed preparation of this
Ordinance Amendment but was unable to
focus on this effort due to limited staff
resources. The Ordinance remains a priority
and revisions are expected to be completed in
2020.

On-going. This program
has not yet been
completed.
839
Appendix A: Review of Past Performance A-27
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 22: Monitoring and
Preservation of “At-Risk” units
The City currently has 97 units that are at
risk of converting from affordable, deedrestricted units to market-rate units during the planning period. The City shall provide
for regular monitoring of deed-restricted
units that have the potential of converting
to market-rate during the planning period.

Additionally, the City will provide technical
assistance for owners of these units
seeking funding and other opportunities to
extend and/or renew deed restrictions
and/or covenants.

Monitor and
preserve 97 atrisk units
The City continues to monitor potential "AtRisk" units. From 2014 to present, the following units were at-risk of converting to
market rate:

Eight (8) units at the Friendly Center (451-453
N. Lemon Street) are identified in the Housing
Element as at-risk of converting to market rate
units. These units are being preserved through
the Section 8 Annual Renewal Program. The
current contract runs through May 2020.

Triangle Terrace is a 75 unit apartment project
located at 555 S. Shaffer Street. As recently as
2016, the apartments were at risk of
converting to market rate units. However, in
2017, the owner secured a 20 year housing
Assistance payments contract with HUD for
Section 8 project-based rental assistance to
extend affordability through November 2036.

Because the owner has a 20 year Housing
Assistance payments contract with HUD
through November 2036, this project is no
longer an at risk project.

Forty (40) units at Casas Del Rio (1740 E. La
Veta Avenue) were at risk of converting in
2017. The owner obtained a new five-year
Housing Assistance Payments (HAP) contract
effective October 26, 2017 through October
On-going. The City has
successfully worked with
property owners managing
affordable rental units
within Orange that have
recently been at risk of
converting to market-rate
units and successfully
negotiated funding for both
short- and long-range
extensions to keep these
units affordable.

Long-term solutions are
being sought for all sites.

The City will continue to
seek opportunities to
preserve "At-Risk" housing
units during the 6th Cycle
RHNA planning period.
840
Appendix A: Review of Past Performance A-28
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle 26, 2022. The City is currently working on an
extended agreement for these units.

Seventy-five units at Casa Ramon (840 West
Walnut) were at risk of converting. The owner
had a multi-year HAP contract with HUD for
Section 8 project-based rental assistance that
was scheduled to expire in 2020. The owner
requested a new multi-year contract with HUD
to extend the contract. In 2016 the City
authorized the issuance of tax exempt bonds
and supported a tax credit application for the
project. The owner obtained a new 20-year
HAP contract effective March 1, 2017 through
March 1, 2037. The tax credits require a 55-
year affordability term for all of the units,
which is secured by recorded covenants.

Community Garden Towers is a 332 unit
apartment project located at 3919 and 4001
West Garden Grove Boulevard. The units were
at risk of converting to market rate units in
2022. However, in 2017, the property was
refinanced and a new 20 year Housing
Assistance Payment (HAP) contract with HUD
will extend the Section 8 project-based rental
assistance through January 26, 2037. Because
the owner has a 20 year HAP contract with
HUD through January 26, 2037, this project is
no longer an at risk project.
841
Appendix A: Review of Past Performance A-29
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle Policy Action 23: In-Kind Technical
Assistance
Continue to offer in-kind technical
assistance on a request basis for property
owners pursuing improvements that
enhance the quality of the City’s housing
stock.

Technical
Assistance
City staff continues to offer Planning, Building,
and Economic Development technical
assistance at the public counter for housing
development and enhancement projects.

On-going. City staff will
continue to provide
technical assistance to the
community. As
technological advances and
social practices change, the
City will adapt to be able to
continue to provide these
services.

Policy Action 24: Proactive Code
Compliance for Private Property
Continue to address code violations and
deferred maintenance and encourage
continued maintenance of existing
neighborhoods.

Monitor
Neighborhoods
and Address
Code Violations
Code Enforcement staff continue to partner
with the Orange Police Department on annual
programs addressing areas where housing
conditions and deferred maintenance are of
concern.

During the 5th Cycle RHNA planning period,
thousands of cases involving property
maintenance, inoperable vehicles, and general
code enforcement complaints and violations
were opened annually.

On-going. Code
Enforcement staff and the
Orange Police Department
successfully investigated
and addressed hundreds of
complaints and violations
over the course of the
planning period.

Policy Action 25: Blight Removal on Public
Property
To enhance the quality of Orange’s
residential neighborhoods, the City will
continue to utilize the Public Works and
Community Services Departments for the
as-needed removal of graffiti and other
deferred maintenance issues on public
property, including sidewalks, parks, bus
As needed The City's Public Works and Community
Services Departments continue to maintain
public property and address deferred
maintenance issues, including on sidewalks,
parks, bus shelters and signs. City staff strives
to remove graffiti within 48 hours.

Since the beginning of the planning period, the
City has removed an average of 110,000
Completed. The City's
Public Works and
Community Services
Departments have
successfully addressed
deferred maintenance and
vandalism issues
throughout the planning
period.
842
Appendix A: Review of Past Performance A-30
2021-2029 Housing Element Update - Draft
Table A-1: Review of 5th Cycle Programs
Policy Action Objective Program Accomplishments Status for Sixth Cycle shelters signs and other structures adjacent
to the public right-of-way.
square feet of graffiti from areas visible from
the public right-of-way and public parks.

Policy Action 26: Preservation of Historic
Residential Structures
The City places high priority to the
conservation, preservation and
enhancement of the City’s historic
residential neighborhoods. The City will
continue to enforce the goals and
objectives contained in the Cultural
Resources and Historic Preservation
Element of the General Plan and the
Historic Preservation Design Standards for
Old Towne to ensure the continued quality
of the City’s historic residential resources
and maintenance of the City’s existing
housing stock. In addition, the City will
continue to promote the Mills Act Program
and develop public information and
outreach materials.

Preserve historic
residential
structures
The City continues to incentivize preserving
historic residential structures through our Mills
Act program and enforcement of the Old
Towne Design Standards for projects located
within the Old Towne Orange Historic District.

The City does not currently limit the number of
annual Mills Act applications.

Since the beginning of the planning period, the
City has approved 100 new Mills Act Contracts.

Most recently in 2019, the City approved 54
new Mills Act Contracts.

In 2017, the City updated and adopted the Old
Towne Design Standards to further preserve
and protect the historic nature of the Old
Towne area.

In 2018, the City adopted the Orange Eichler
Design Standards and created a historic
overlay district overlay zone for the three
midcentury modern Eichler Homes Tracts.

Contributing homes in the Eichler historic
overlay district zone will be able to submit
Mills Act applications beginning in 2019.

On-going. The City has
been incredibly successful
at taking action to preserve
the historic nature for the
community. The City will
continue to promote the
Mills Act Program in the
6th Cycle RHNA planning
period.
843
Appendix B: Candidate Sites Analysis
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Appendix B: Candidate Sites Analysis B-2
2021-2029 Housing Element Update - Draft
Candidate Sites Analysis
A. Candidate Sites Analysis Overview
The Housing Element is required to identify sites by income category to meet the City’s RHNA Allocation.

The sites identified within the Housing Element represent the City of Orange’s ability to develop housing at the designated income levels within the planning period (2021-2029). These sites are either residentially zoned or within a mixed-use zone that permits residential uses.

Table B-1 shows the City’s 2021-2029 RHNA need by income category as well as a breakdown of the sites identified to meet that need. The analysis within Appendix B shows that the City of Orange has the capacity to meet their 2021-2029 RHNA allocation through a variety of methods, including:
 Identification of additional capacity on existing residentially and mixed-use zoned sites. Sites identified to meet the lower income need are identified on sites that permit at least 30 dwelling units per acre.
 Future development of accessory dwelling units (ADUs) Water, Sewer, And Dry Utility Availability
Each site has been evaluated to ensure there is adequate access to water and sewer connections as well as dry utilities. Each site is situated with a direct connection to a public street that has the appropriate water and sewer mains and other infrastructure to service the candidate site.

Accessory Dwelling Units (ADUs)
As a result of new legislation and an increased effort by the City to promote ADUs, the City has seen an increase in ADU permitting and applications over the past couple of years. The City had 27 ADUs approved for development in 2020, 111 approved in 2021, and 112 approved in 2022. The City has taken the following actions to promote and facilitate the development of ADUs:
 Dedicated expert staff for processing all ADU and JADU applications, and to offer pre-application assistance
 Dedicated staff to maintaining ordinances consistent with ADU State Law and to monitor HCD guidance documents
 Utilization of an ADU/JADU application with clear instructions on required application materials and necessary plan content
 Compliance with administrative approval of ADU/JADU applications withing required timelines  Creation of ADU scenario site plans that will be offered as counter handouts and will be placed on the City website in 2022
 Omitted or reduced impact fee collection, consistent with State ADU Law  Providing deed restriction assistance through providing required language  Initiating affordability surveying beginning in 2022
 Waiving parking requirements for most ADUs, consistent with State ADU Law 845

Appendix B: Candidate Sites Analysis B-3
2021-2029 Housing Element Update - Draft
In accordance with State law, ADUs are allowed in all zones that allow single dwelling unit or multiple dwelling unit development. Junior Accessory Dwelling Units (JrADUs) are permitted only in single dwelling unit zones.

The City of Orange has determined based on past performance and HCDs approved methodology that it is appropriate to anticipate the development of 40 accessory dwelling units per year from 2021 to 2029 for a total of 320 ADUs. Housing Program 2J and 2K in Section 4: Housing Plan of this Housing Element establish the monitoring of ADU development and continued compliance with State laws. The City will evaluate the production of ADUs within two years of adoption of the Housing Element and take action within 6 months to ensure adequate capacity at each income level to meet the City’s RHNA.

Table B-1: Summary of RHNA Status and Sites Inventory

Extremely
Low/ Very
Low Income
Low Income Moderate
Income
Above
Moderate
Income
Total
2021-2029 RHNA 1,067 604 677 1,588 3,936
RHNA Credit (Units Built) -- -- -- -- --
Total RHNA Obligations 1,067 604 677 1,588 3,936
Sites Available
Residential Zones 0 0 0 81 81
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 Production 80 137 96 7 320
Total Sites Available 1,121 619 828 1,784 4,352
Potential Unit Surplus +54 +15 +151 +196 +416
B. Sites Inventory – Realistic Capacity
This section contains a description and listing of the candidate sites identified to meet the Orange’s very low and low income RHNA need. A full list of these sites is presented in Table B-3.

The City of Orange has identified sites with capacity to accommodate the City’s 2021-2029 RHNA. This capacity is based on existing zoning and does not require the City to complete rezones in order to add capacity to what currently exists. The City has identified mixed-use zoned parcels that permit development at up to 60 dwelling units per acre which can accommodate 1,503 dwelling units. The City also anticipates the development of 217 affordable ADUs based on the methodology described in this section. This is in excess of the City’s 1,671 unit low and very-low RHNA need by 69 units, or an additional 4%. As demonstrated in this section, the City of Orange has the capacity to accommodate their RHNA need and believes based on past performance of developing affordable projects that this is an appropriate buffer should some sites not develop as anticipated. In addition, the City has made conservative unit yield assumptions, including:
846

Appendix B: Candidate Sites Analysis B-4
2021-2029 Housing Element Update - Draft
 An assumption that projects within the Urban Mixed Use (UMU) zone, which is anticipated to accommodate the City’s lower income RHNA need, will develop at 55 dwelling units per acre.

Projects in this zone are permitted up to 60 dwelling units per acre and may go higher if they incorporate density bonus provisions.
 An assumption that only 25% of units included within a project will develop at the affordable levels. While it is likely that not all projects will develop with a 25% affordable component, the City has a history of building 100% affordable projects which can offset a potential deficit.

Orange is a primarily built out City with little available vacant land that can be developed for residential uses. Where possible, the City has identified vacant parcels as identified in Table B-3. As shown in Table B-1, all of the City’s lower income RHNA need is anticipated to be accommodated within the UMU zone, which can accommodate development at up to 60 dwelling units per acre. Table B-2 describes recent residential projects developed in the UMU zone, including the use prior to developing for housing and a project analysis which shows why these types of projects are good comparative examples of the types of residential the City anticipates in this zone during the 6th cycle planning period.

Chapter 17.19.010 of the City’s Municipal Code states:

It is the intent of this chapter to establish use regulations and development standards for the provision of adequate sites for the development for affordable housing in compliance with General Plan Policy D.17: Provide Adequate Sites of Housing Development.

The definition of Urban Mixed Use within the City’s zoning code is as follows:

The UMU zoning district is intended to provide urban, high-intensity, regionally-oriented activity centers.

This zoning district provides for integrated commercial retail, professional office, residential, and civic uses. Commercial retail uses are the preferred uses allowed on the ground floor. Residential development is allowed, either as part of a mixed-use project or as a freestanding use. Convenient transit access, innovative housing options, and pedestrian-oriented design are key considerations.

The City does not currently have performance standards within the UMU zone which require residential, however, the City does have a process in place within Chapter 17.19.060 of the Zoning Code to ensure identified land remains available to meet the City’s RHNA need. See below for full text of the Site Plan and Design Review Required within the UMU Zone.

Depending on the nature of the development, a proposed project, including residential projects, may require review and approval in compliance with Sections 17.10.060 (Site Plan Review) and 17.10.070 (Design Review). However, residential projects are not subject to other non-design related discretionary review in compliance with Policy D.17 of the General Plan Housing Element.

For nonresidential and mixed-use projects within the UMU zoning district subject to site plan and/or design review, the reviewing body shall make the additional finding that approval of the project will not reduce the amount of land available in mixed use zoning districts to a point where the City's affordable housing needs under the Regional Housing Needs Assessment (RHNA) cannot be met. In compliance with Policy D.17 of the General Plan Housing Element (Policy Action 2H of the 2021-2029 Housing Element), 847

Appendix B: Candidate Sites Analysis B-5
2021-2029 Housing Element Update - Draft
at no time shall the capacity of available sites for affordable residential development be exceeded by the adjusted RHNA need.

As shown in Table B-2, the City of Orange has primarily seen development within the Urban Mixed-Use zone occur as fully residential projects, including the 1,659 units approved within the five sample projects shown. While the UMU zone does permit fully non-residential projects, the City rarely sees applications for projects which do not contain a residential component.

The very-low and low-income sites inventory within this appendices describes each of these sites, with information provided per the HCD required data tables. Dwelling unit yield for each of the parcels within this inventory were analyzed to determine a net parcel size based on the City’s established definition of net acreage and known physical and environmental constraints.

Non-vacant sites designated to meet the very-low and low-income RHNA need that have been identified in a previous Housing Element and vacant sites designated to meet the very-low and low-income RHNA need that have been identified in two previous Housing Elements will also allow ‘by-right’ approval for any project with 20 percent low income housing that does not involve a subdivision per State law. This is described in Program 2L within the Housing Plan.

Redevelopment of Non-Vacant Sites for Residential Uses
The City’s does not have sufficient vacant land available to accommodate fifty percent of their low/verylow income RHNA. To accommodate the need at those income levels, the City has analyzed sites within the Urban Mixed Use (UMU) zone. The City has evaluated recent projects that have redeveloped within the UMU zone that included residential units. Those projects, including the use prior to redevelopment and a project analysis of the approved development plan, are shown in Table B-2. The City’s analysis shows that prior uses on these redeveloped sites were similar in nature to the existing uses on sites identified within the sites inventory in Table B-3.

The City has also conducted a parcel specific analysis of existing uses for each of the identified sites. This analysis of existing uses, including indicators of a likelihood that the existing use will redevelop within the next eight years, are provided in Table B-3. This analysis is based on information readily available to the City and research that can be found through online research.

The following residential development projects have been constructed within the City’s Urban Mixed Use zone:

848

Appendix B: Candidate Sites Analysis B-6
2021-2029 Housing Element Update - Draft
Table B-2: Example Development of Non-Vacant Sites for Residential Uses Project Address/
APN
Dwelling
Units Zoning Use Prior to Redevelopment Project Analysis 3537 The City Way/
23106137 334 UMU
Surface parking lot
for medical, hotel
and office
buildings.

AMLI Apartments. 4-story wrap
apartment project developed at 60 du/ac.

The project was completed in 2017 and
achieved the maximum density.

Developed directly adjacent to the
Outlets at Orange
1110 Town and
Country Road/
39062102
260 UMU
Vacant lot adjacent
to an existing
office tower
(underdeveloped
office tower Phase
II)
Eleven10 Apartments. 5-story podium
apartment project developed at 60 du/ac.

Project site is adjacent to existing office
and commercial uses. The project was
completed in 2018 and achieved the
maximum density. The project was
developed as horizontal mixed-use with
existing office uses.
1055 Town and
Country Road/
04121405
262 UMU
Surface parking lot
for existing office
building.

Cameo Apartments. 5-story apartment
project developed at 44 du/ac. Recently
completed in 2020. The project was
developed as horizontal mixed-use with
existing office uses.
1725 W. Katella/
27530106 94 UMU
Low-rise light
industrial/office
building with
surface parking lot
Branch West (aka Garrison Apartments).

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 849

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 sixacre 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 standalone 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 850

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 onehalf 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 lightindustrial 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. 851

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
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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
853
Appendix B: Candidate Sites Analysis 3-11
2021-2029 Housing Element Update - Draft
Figure B-1: Map of Identified Sites (All Income Levels) 854

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.
855

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%
856

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% 857

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
NMU24 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 multifamily residential uses. 12,765 216,830 6% 858

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 multitenant 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
NMU24 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% 859

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
NMU24 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
NMU24 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
NMU24 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
NMU24 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
NMU24 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 mixeduse 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
NMU24 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% 860

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
NMU24 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
861
Appendix C: Summary of Community
Engagement
862
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 6th 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 totalof 148 persons who participated in the survey. Participants were asked to consider potential policies and programs to include in the Housing Element. • Stakeholder Meetings – 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 863
Appendix C: Summary of Community Engagement C-3
2021-2029 Housing Element Update
Housing Element, all public comments received 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 Underrepresented 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 some 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.
864
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 the 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 Incorporated
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 865
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. 866
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
867
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. 868
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 869
La Ciudad de Orange está en proceso de actualizar en Elemento Vivienda 2021-2029. Esta hoja informativa proporciona 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
870
¿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 871
1 2021-2029 Housing Element Update
2021-2029
Housing Element
Update
Community Workshop #1
City of Orange
www.cityoforange.org/1956/
Housing-Element-Update
2021-2029 Housing Element Update Agenda
I. Overview of Orange
II. Overview of Housing Element
III.Regional Housing Needs Assessment (RHNA)
IV.Update Process and Outreach
V. Project Schedule
VI.Next Steps 2
2021-2029 Housing Element Update Overview of
Orange 3
2021-2029 Housing Element Update Hispanic or Latino
39%
4 Source: American Community Survey, 5-Year Estimates 2017 Actual 2000 Actual 2010 Projected 2012 Projected 2020 Projected 2035 Projected 2040 Orange 128,821 136,416 138,500 143,100 151,400 153,000 115,000
120,000
125,000
130,000
135,000
140,000
145,000
150,000
155,000 Population in Orange, 2000 – 2040 The Orange Community White 70% Black 1% American Indian and Alaska Native 1%
Asian
12%
Native Hawaiian or Other Pacific Islander 0%
Some Other Race 13%
Two or More Races 3%
Population in Orange by Race or Ethnicity
2021-2029 Housing Element Update The Orange Community
5 Source: American Community Survey, 5-Year Estimates 2017 Married-couple Family Households 44% Male Householder, No Spouse 5% Female Householder, No Spouse Present 11%
Non-Family Household
22%
Householder Age 65 or Above 18%
Household by Type in Orange Owner 57%
Renter 43%
2021-2029 Housing Element Update
Built 2014 or
later Built 2010 to2013 Built 2000 to2009 Built 1990 to1999 Built 1980 to1989 Built 1970 to1979 Built 1960 to1969 Built 1950 to1959 Built 1940 to1949 Built 1939 or earlier Orange 0.1% 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 Orange
6 Source: American Community Survey, 5-Year Estimates 2017 Housing by Type in Orange Housing by Year Built 1 2
3 4
5 6
872
2 2021-2029 Housing Element Update Overview of the
Housing Element 7
2021-2029 Housing Element Update What is a Housing Element 8 Required Section of the Orange General Plan
Provides Goals, Policies, Programs, and Objectives to guide future housing growth to meet the needs of residents of all income levels in Orange Identifies projected housing needs by income category
Requires certification by the State Department of Housing and Community Development (HCD) for compliance with State housing laws 2021-2029 Housing Element Update Why 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 sources 9
2021-2029 Housing Element Update A “Certified” Housing Element 10 What 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 Update Housing Element Features 11Population and
housing profile Analysis of sites to accommodate the City’s RHNA Allocation Evaluation 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
Assessment 12
7 8
9 10
11 12
873
3 2021-2029 Housing Element Update What 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 households 13 City of Orange RHNA 2021-2029
3,927 units Southern California Association of Governments SCAG develops methodology to determined “fair share” distribution of the region’s housing need to local jurisdictions Department of Housing and Community Development HCD determines and distributes the State’s housing need to all the regional councils of government 2021-2029 Housing Element Update RHNA Draft Allocation: 2021 – 2029 Planning Period 14 Income Category % of Area Median Income (AMI) Income Range* RHNA Allocation (Housing Units)** Min. Max. Very Low Income 0 - 50% AMI -- $51,500 1,064 units Low Income 51 – 80% AMI $51,501 $82,400 603 units Moderate Income 81 – 120% AMI $82,401 $123,600 676 units Above Moderate Income >120% AMI $123,601 >$123,601 1,585 units Total: 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 Update What is Included in the Update Process? 16 Community Outreach Process (Workshops and Online Survey) Update of the City’s demographic conditions
Review and Analysis of sites to meet the City’s RHNA housing growth need Creation of policies and programs for existing and future housing needs Public Hearings before Planning Commission and City Council 2021-2029 Housing Element Update Next Steps 17 2021-2029 Housing Element Update Housing Element Update Schedule 18 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 Public Hearing – Summer 2021 City Council Public Hearing –
Late Summer 2021
13 14
15 16
17 18
874
4 2021-2029 Housing Element Update We Want Your Input
Participate in the
Housing Element
Survey!
Go to:
www.cityoforange.org/1956/
Housing-Element-Update
Click the link titled
“Housing Element
Survey” to begin. 19
2021-2029 Housing Element Update How to Use the Survey
20The 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/laptop

2. Click “Begin” to start the survey

3. Carefully read the instructions on each slide

4. Respond to the provided prompts with your
ideas and input

5. Complete slide five and click “Submit Final Questions” to complete the survey and submit all responses 2021-2029 Housing Element Update Thank you! Questions?
Contact Ashley Brodkin, Associate Planner
Phone: 714-744-7238
Email: [email protected]
City Housing Element webpage:
www.cityoforange.org/1956/Housing-Element-Update
21 19 20
21 875
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 876
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 Workshop #2
877
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 programas. 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 planificará 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
878
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”.
879
City of Orange
Community Workshop #2 Summary
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.
880
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! 881
882
1 2021-2029 Housing Element Update
2021-2029
Housing Element
Update
Community Workshop #2
Taller Comunitario #2
City of Orange
www.cityoforange.org/
housingelement
2021-2029 Housing Element Update Agenda
I. Housing Element Efforts
to Date
II. Housing Element
Update Process
III. Public Review Draft –
Sites and Policies
IV. Community
Review/Feedback
V. Next Steps 2
I. Sala de Reunión en Español
II. Esfuerzos del Elemento de
Vivienda hasta la Fecha
III. Proceso de Actualización del
Elemento de Vivienda
IV. Borrador de Revisión Pública –
Sitios y Políticas
V. Revisión/Comentarios de la
Comunidad
VI. Próximos Pasos 2021-2029 Housing Element Update
Spanish Breakout Room
3 2021-2029 Housing Element Update
Spanish Breakout Room
4 2021-2029 Housing Element Update
Spanish Breakout Room
5 2021-2029 Housing Element Update Housing Element Efforts to Date 6
1 2
3 4
5 6
883
2 2021-2029 Housing Element Update Overview 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/housingelement 7
2021-2029 Housing Element Update Workshop #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/housingelement 8
2021-2029 Housing Element Update Community 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 comments 9
2021-2029 Housing Element Update Stakeholder 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 Element 10 2021-2029 Housing Element Update Housing Element Update Process 112021-2029 Housing Element Update What is a Housing Element 12 Required Section of the Orange General Plan
Provides Goals, Policies, Programs, and Objectives to guide future housing growth to meet the needs of residents of all income levels in Orange Identifies projected housing needs by income category
Requires certification by the State Department of Housing and Community Development (HCD) for compliance with State housing laws 7 8
9 10
11 12
884
3 2021-2029 Housing Element Update Housing Element Features 13Population and
housing profile
Analysis of sites to accommodate the City’s RHNA Allocation Evaluation 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 Policies 14 2021-2029 Housing Element Update Sites 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 Update
16 2021-2029 Housing Element Update Urban Mixed-Use (UMU) Zone • Intended to provide urban, high intensity, regionallyoriented 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 Update Assumption 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 14
15 16
17 18
885
4 2021-2029 Housing Element Update Proposed Housing Policy Actions • The Review of Past Performance showed
that the City has been successful in
implementing its 5th Cycle policy actions.
• Some proposed 6th Cycle 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 analysis 19
2021-2029 Housing Element Update Proposed 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 Update Sample Housing Policy
Housing Policy Action 2A: Annual Review of Housing Element The 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: Annually Responsible Agency: City of Orange Community Development Department Funding Source: General fund
21 2021-2029 Housing Element Update
Community Review/Feedback 22 2021-2029 Housing Element Update Community 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/
CE5KFqh1cr 23
2021-2029 Housing Element Update Email 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 20
21 22
23 24
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5 2021-2029 Housing Element Update Live 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/housingelement 25
2021-2029 Housing Element Update Next Steps 26 2021-2029 Housing Element Update Housing Element Update Schedule 27 Public Review Draft – Spring 2021 Community
Workshop -
Spring 2021
Planning
Commission/City
Council Briefings – Summer 2021 HCD Review Draft – Late Summer 2021 2021-2029 Housing Element Update Thank you!
Questions?
Contact Anna Pehoushek, Assistant Community
Development Director
Email: [email protected]
City Housing Element webpage:
www.cityoforange.org/housingelement 28
25 26
27 28
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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. 888
City of Orange
2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 1
Community Survey
October 12, 2020 to November 30, 2020 the Cityof 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.

Slide 1: Housing Program Opportunities
Participants were provided a variety of housing programs opportunities, categorized 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 highestinterest 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
Units
Housing
Partnerships
Inclusionary
Housing
Keep Affordable
Housing
MixedUse
Opportunities
1 2
3 4
5 889
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2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 2
as a priority. The data shows a split in interest between one and 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 in 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 fair housing were most appealing to participants, followed by programs to encourage the development of housing for persons with disabilities. The data shows a split interest in supportive 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 Maintenance Provide Housing Info
1 2
3 4
5 890
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2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 3
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
Slide 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 Supportive Housing 1 2
3 4
5 0
10 20
30 40
50 60
70 80
Development Fees Development Process Project Processing 1 2
3 4
5 891
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Draft Community Survey Summary
Page | 4
• 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 in 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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Draft Community Survey Summary
Page | 5
Slide 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 regarding 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 provide more funding opportunities; however, participants were least interested 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
274
0 50
100
150
200
250
300
350
400
Lack of
Informational
Resources
Housing
Availability
Permit
Streamlining
Flexible
Development
Standards
Housing Fees Access to Funding
Stars Allocated
893
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.
894
City of Orange
Housing Element Update 2021-2029
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 partnersto 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 895
City of Orange
Housing Element Update 2021-2029
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
896
City of Orange
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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 897
1 2021-2029 Housing Element Update
2021-2029
Housing Element
Update
Stakeholder Meeting December 1, 2020 City of Orange
www.cityoforange.org/HousingElement 2021-2029 Housing Element Update Agenda I. Housing Element Update Process
II. Stakeholder Discussion
III.Next Steps 2
2021-2029 Housing Element Update Housing Element Update Process 32021-2029 Housing Element Update Housing Element Features 4 Population 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 Update RHNA Draft Allocation: 2021 – 2029 Planning Period 5 Income Category % of Area Median Income (AMI) Income Range* 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 *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 Housing Element Update Schedule 6 Community Survey –
Fall 2020
Stakeholder Study Session – Fall 2020 City Council Briefing Sessions - Winter 2021 Public Review Draft – Spring 2021 Community Workshop - Late Spring 2021 Planning Commission Public Hearing – Summer 2021 City Council Public Hearing –
Late Summer 2021
1 2
3 4
5 6
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2 2021-2029 Housing Element Update
Stakeholder
Discussion
7 2021-2029 Housing Element Update What are the Top 3 constraints to Housing? 8 2021-2029 Housing Element Update What can the City do to promote affordable Housing?
9 2021-2029 Housing Element Update Are there any new or innovative practices when it comes to building affordable
housing?
10 2021-2029 Housing Element Update Next Steps 112021-2029 Housing Element Update Thank you! Questions?
Contact Ashley Brodkin, Associate Planner
Phone: 714-744-7238
Email: [email protected]
City Housing Element webpage:
www.cityoforange.org/1956/Housing-Element-Update
12 7 8
9 10
11 12
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Appendix C: Summary of Community Engagement C-10
2021-2029 Housing Element Update
Public Comments
This section contains all available public comments received by the City relating to the Housing Element update process. Personal information such as emails and addresses have been redacted for privacy reasons.
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City of Orange
2021-2029 Housing Element Update
Public Review Draft Comments 10/4/2021
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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City of Orange
2021-2029 Housing Element Update
Public Review Draft Comments 10/4/2021
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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City of Orange
2021-2029 Housing Element Update
Public Review Draft Comments 10/4/2021
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.
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2021-2029 Housing Element Update
Public Review Draft 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 OrangelandRecreation 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.
904
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)CityOfOrange.pdf Nicholas Chen, AICP
Kimley-Horn |
Instagram | Kimley-Horn.com
Celebrating 13 years as one of FORTUNE’s 100 Best Companies to Work For From: 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,
Would 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 < ; Zoch, Jeremy S ; Abushawish, Jordan A <
Subject: Re: [EXTERNAL] City of Orange Housing Element Update - Virtual Workshop Dear 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.
905
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
Sent: Monday, October 12, 2020 10:36 AM
Subject: [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-ElementUpdate) to learn more and for opportunities to share your housing priorities and experiences.

906
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.
907
From: Chen, Nick
Sent: Wednesday, May 19, 2021 4:52 PM
To: Galmiche, Ines
Subject: FW: Additional Comments Regarding Housing Element Survey Nicholas Chen, AICP
Kimley-Horn |
Connect with us: Twitter | LinkedIn | Facebook | Instagram | Kimley-Horn.com Celebrating 13 years as one of FORTUNE’s 100 Best Companies to Work For From: 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.

Ashley Brodkin
From: Bonnie Robinson < >
Sent: Sunday, November 15, 2020 5:13 PM
To: Ashley Brodkin >
Subject: Additional Comments Regarding Housing Element Survey Dear 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. 908
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.
909
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 Chen, AICP
Kimley-Horn |
Connect with us: Twitter | LinkedIn | Facebook | Instagram | Kimley-Horn.com Celebrating 13 years as one of FORTUNE’s 100 Best Companies to Work For From: Ashley Brodkin
Sent: Wednesday, October 14, 2020 8:16 AM
To: Chen, Nick
Cc: Mendoza, Molly
Subject: FW: City of Orange Housing Element Update - Virtual Workshop Please see below for correspondence with Elizabeth Handsburg from People for Housing.

Ashley Brodkin
From: Elizabeth Hansburg P4H
Sent: Tuesday, October 13, 2020 4:58 PM
To: Ashley Brodkin
Subject: Re: City of Orange Housing Element Update - Virtual Workshop Sure, 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, servicesector 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 910
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-Update) 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

911
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-Update) 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.
912
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.
913
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.
914
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 6th 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 6th 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 5th 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. 915
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 5th 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,
Cecilia Bustamante Pixa, MPH, MHCML
Director, Community Health Investment

¹California Government Code § 8899.50 (Assembly Bill 686). 916
Appendix D: Glossary of Housing Terms
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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.
918
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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 20 919
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 920
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 921
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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. 922
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2021-2029 Housing Element Update - Draft
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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2021-2029 Housing Element Update - Draft
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 VeryLow 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. 925
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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
926
City of Orange – HCD Response Matrix
April 2022 HCD Response Letter
HCD Comments Section/Page Number Notes
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 longrange 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 930
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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 longrange 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, placebased 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 R5 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).) 938
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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.
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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 barrierfree 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
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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 lowand 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.
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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 adopted its 2014- 2021 General Plan Housing Element in January 2014; and
WHEREAS, the California Government Code( commencing with Section 65580) 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 an 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 and recommended unanimous approval to the City Council thereof.

NOW, THEREFORE, BE IT RESOLVED that the City Council approves General Plan Amendment No. 2022- 0001, adopting the 2021- 2029 General Plan Housing Element attached hereto and incorporated herein as Exhibit A and directs 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 ofpast 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 ( HCD) on the City' s 2021- 2029 Draft Housing Element. 942
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 elements ofthe 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 ofthe community".

The Housing Element contains a needs assessment documenting 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. The housing policy actions aim to provide opportunities for production ofnew 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 advance the State' s housing goal of providing " decent housing and a suitable living environment for all members ofthe 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 significant effect on the environment; (ii) no property re-zoning is needed to accommodate the City' s Regional 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); and( 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.

ADOPTED this 8th day of February 2022.

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

Pamela Coleman, City Clerk, City of Orange
Attachment: 6th Cycle Housing Element Update ( 2021- 2029) Resolution No. 11378 2
943

STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss.

CITY OF ORANGE
I, PAMELA COLEMAN, City Clerk ofthe City of Orange, California, do hereby certify that the foregoing Resolution was duly and regularly adopted by 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.

Pamela Coleman, City Clerk, City of Orange
Resolution No. 11378 3
944
NorE
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CITY OF ORANGE
6th CYCLE HOUSING ELEMENT UPDATE
2021-2029)
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AVAILABLE FOR REVIEW
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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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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 longterm provision of housing for a variety of household income levels, and articulates the City’s official 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’s General Plan required by State law, establishing the City’s official 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 Page 1 of 5 Printed on 2/3/2022
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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’s policy 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 Page 2 of 5 Printed on 2/3/2022
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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’s Hospital 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 Page 3 of 5 Printed on 2/3/2022
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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’s General 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 underutilized 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 Obligations 1,067 604 677 1,588 3,936
Sites Available
Residential Zones 0 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 Production 80 137 96 7 320
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Total RHNA Obligations 1,067 604 677 1,588 3,936
Sites Available
Residential Zones 0 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 Production 80 137 96 7 320
Total Sites Available 1,121 619 828 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’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 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 longterm provision of housing for a variety of household income levels and articulates the City’s official 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’s General Plan.

5. PROJECT BACKGROUND
The Housing Element is one of the chapters or “elements” of the City’s General Plan required by State law. The Housing Element establishes the City’s official 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 Page 1 of 8 Printed on 12/23/2021
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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’s policy 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 Page 2 of 8 Printed on 12/23/2021
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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’s accomplishments 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’s RHNA 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’s website 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%
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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’s General Plan land use and zoning designations provide adequate development capacity to accommodate the City’s 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 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 Obligations 1,067 604 677 1,588 3,936
Sites Available
Residential Zones 0 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 Production 80 137 96 7 320
Total Sites Available 1,121 619 828 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 “default density” are located in Uptown Orange in the vicinity of City of Orange Page 5 of 8 Printed on 12/23/2021
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the Outlets at Orange, and on West Katella Avenue.

In addition to the “default density” 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’s 393 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 Page 6 of 8 Printed on 12/23/2021
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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 resubmitted 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’s Regional 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 an 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 96525
Planning Commission
Resolution No. PC 01-22