Attachment 3 Revised Draft 2021-2029 Housing Element Update, February 2023 — Orange City Council, February 14, 2023 (part 1 of 2)

City of Orange
6th Cycle Housing Element Update
(2021-2029)
ADOPTED FEBRUARY 2022

TABLE OF CONTENTS
SECTION 1: INTRODUCTION
A. Role of the Housing Element .............................................................................................................. 1-2 B. State Policy and Authorization ............................................................................................................ 1-2

1. Background .................................................................................................................................... 1-2

2. State Requirements ....................................................................................................................... 1-2

3. Regional Housing Needs Assessment ........................................................................................... 1-4

4. Relationship to Other General Plan Elements ............................................................................... 1-5

5. Public Participation ......................................................................................................................... 1-6

6. Data Sources.................................................................................................................................. 1-6

7. Housing Element Organization ...................................................................................................... 1-7

SECTION 2: COMMUNITY PROFILE
A. Population Characteristics .................................................................................................................. 2-2

1. Population Growth .......................................................................................................................... 2-2

2. Age Characteristics ........................................................................................................................ 2-3

3. Race/Ethnicity Characteristics ....................................................................................................... 2-4 B. Economic Characteristics ................................................................................................................... 2-6

1. Employment and Wage Scale ........................................................................................................ 2-7 C. Household Characteristics ................................................................................................................ 2-10

1. Household Type and Size ............................................................................................................ 2-10

2. Household Income ....................................................................................................................... 2-12 D. Housing Problems ............................................................................................................................. 2-15

1. Overcrowding ............................................................................................................................... 2-16

2. Overpayment (Cost Burden) In Relationship to Income .............................................................. 2-18 E. Special Needs Groups ...................................................................................................................... 2-19

1. Seniors ......................................................................................................................................... 2-20

2. Persons with Physical and Developmental Disabilities ................................................................ 2-21

3. Large Households ........................................................................................................................ 2-24

4. Single-Parent Households ........................................................................................................... 2-25

5. Farmworkers ................................................................................................................................ 2-26

6. Extremely Low-income Households and Poverty Status ............................................................. 2-26

7. Persons Experiencing Homelessness ......................................................................................... 2-28

8. Students ....................................................................................................................................... 2-33 F. Housing Stock Characteristics .......................................................................................................... 2-33

1. Housing Growth ........................................................................................................................... 2-33

2. Housing Type ............................................................................................................................... 2-34

3. Housing Availability and Tenure................................................................................................... 2-35

4. Housing Age and Condition ......................................................................................................... 2-37

5. Housing Costs and Affordability ................................................................................................... 2-37

SECTION 3: HOUSING CONSTRAINTS, RESOURCES, AND FAIR HOUSING Housing Constraints ................................................................................................................................ 3-2 A. Nongovernmental Constraints ............................................................................................................ 3-2

1. Land Costs and Construction Costs .............................................................................................. 3-2

2. Availability of Financing .................................................................................................................. 3-3

3. Economic Constraints .................................................................................................................... 3-5 B. Governmental Constraints .................................................................................................................. 3-5

1. Land Use Controls ......................................................................................................................... 3-6

2. State Density Bonus Law ............................................................................................................... 3-8

3. Residential Development Standards ............................................................................................ 3-12

4. Planned Unit Developments ......................................................................................................... 3-19

5. Local Ordinances ......................................................................................................................... 3-20

6. Variety of Housing Types Permitted ............................................................................................ 3-22

7. Housing for Persons with Disabilities ........................................................................................... 3-33

8. Development Fees ....................................................................................................................... 3-35

9. On-/Off-Site Improvements .......................................................................................................... 3-40

10. Building Codes and Enforcement ................................................................................................ 3-41

11. Local Processing and Permit Procedures .................................................................................... 3-41

12. State Policies and Regulations .................................................................................................... 3-47 C. Infrastructure Constraints ................................................................................................................. 3-47

1. Dry Utilities ................................................................................................................................... 3-47

2. Water Supply and Wastewater Capacity ..................................................................................... 3-48

3. Fire and Emergency Services ...................................................................................................... 3-49

4. Police Services ............................................................................................................................. 3-50 D. Environmental Constraints ............................................................................................................... 3-51

1. Geologic and Seismic Hazards .................................................................................................... 3-51

2. Flooding ........................................................................................................................................ 3-51 Housing Resources ............................................................................................................................... 3-52 E. Regional Housing Needs Allocation ................................................................................................. 3-52

1. Residential Sites Inventory ........................................................................................................... 3-52

2. Above Moderate and Moderate Income Sites .............................................................................. 3-52

3. Sites Suitable for Lower Income Housing .................................................................................... 3-53

4. Development of Non-Vacant Sites and Converting to Residential Uses ..................................... 3-56 F. Financial Resources ......................................................................................................................... 3-62

1. Section 8 Housing Choice Voucher ............................................................................................. 3-62

2. Community Development Block Grants (CDBG) ......................................................................... 3-62

3. HOME Investment Partnership Program (HOME) ....................................................................... 3-63 G. Energy Conservation ........................................................................................................................ 3-63 Affirmatively Furthering Fair Housing (AFFH) .................................................................................... 3-64 H. Affirmatively Furthering Fair Housing ............................................................................................... 3-64 I. Needs Assessment ........................................................................................................................... 3-64

1. Fair Housing Issues ..................................................................................................................... 3-64

2. Fair Housing Enforcement and Outreach Capacity ..................................................................... 3-65

3. Fair Housing Laws……………………………………………………………………………………....3-67 J. Analysis of Federal, State, and Local Data and Local Knowledge ................................................... 3-69

1. Integration and Segregation Patterns and Trends ....................................................................... 3-69

2. Racially or Ethnically Concentrated Areas of Poverty (R/ECAP) ................................................. 3-73

3. Racially or Ethnically Concentrated Areas of Affluence (RCAA) ................................................. 3-75

4. Disparities in Access to Opportunity ............................................................................................ 3-81

5. Discussion of Disproportionate Housing Needs ......................................................................... 3-101

6. Displacement Risk ..................................................................................................................... 3-113

7. Local Knowledge and Data Relating to Fair Housing ................................................................ 3-121

8. Assessment of Contributing Factors to Fair Housing Issues in Orange .................................... 3-122 K. Analysis of Sites Pursuant to AB 686 ............................................................................................. 3-124 L. Analysis of Fair Housing Priorities and Goals ................................................................................ 3-134

SECTION 4: HOUSING PLAN
A. Housing Goals .................................................................................................................................... 4-2 B. Housing Policy Actions ....................................................................................................................... 4-3 C. Summary of Quantified Objectives ................................................................................................... 4-19

APPENDICES
Appendix A: Review of Past Performance
Appendix B: Candidate Sites Analysis
Appendix C: Summary of Community Engagement
Appendix D: Glossary of Housing Terms

Section 1: Introduction

Section 1: Introduction 1-2
2021-2029 Housing Element Update - Draft
Introduction
A. Role of the Housing Element
The Housing Element is one of the seven state mandated Elements of the City of Orange General Plan. The Housing Element analyzes and identifies the City’s existing and projected housing needs and contains a detailed outline and work program of the City’s goals, policies, quantified objectives, and programs for the preservation, improvement, and development of housing for a sustainable future. The Housing Element identifies available candidate housing sites and establishes the City’s official housing policies and programs to accommodate its fair share of the regional housing need as determined by the Southern California Association of Governments (SCAG). It also addresses maintenance and expansion of the housing supply to accommodate households currently living and expected to live in Orange.

B. State Policy and Authorization

1. Background
As a mandated chapter of the Orange General Plan, the Housing Element must meet all applicable requirements of existing state law when updated. Goals, programs and policies, and quantified objectives within the Housing Element consistent with state law are implemented within the housing cycle timeline to ensure the City accomplishes the identified actions.

2. State Requirements
California State Housing Element Law (California Government Code Article 10.6) establishes the requirements for the Housing Element. California Government Code Section 65580 requires that local governments review and revise the Housing Element of their comprehensive General Plans not less than once every eight years.

The California Legislature has adopted an overall housing goal for the State to ensure every resident has a decent home and suitable living environment. Section 65580 of the California Government Code states:
a. The availability of housing is of vital statewide importance, and the early attainment of decent housing and a suitable living environment for every Californian, including farmworkers, is a priority of the highest order.
b. The early attainment of this goal requires cooperative participation of government and the private sector in an effort to expand housing opportunities and accommodate the housing needs of Californians in all economic levels.
c. The provisions of housing affordable to low- and moderate-income households requires the cooperation of all levels of the government.
d. Local and State governments have a responsibility to use the powers vested in them to facilitate the improvement and development of housing to make adequate provision for housing needs of all economic segments of the community. The Legislature recognizes that in carrying out this responsibility, each local government also has the responsibility to consider economic,

Section 1: Introduction 1-3
2021-2029 Housing Element Update - Draft
environmental, and fiscal factors and community goals set forth in the general plan and to cooperate with other local governments and the state in addressing regional housing needs.

Table 1-1 summarizes State Housing Element requirements and identifies the location in this document where these requirements are addressed.

Table 1-1: Housing Element Requirements
Housing Element Requirement(s) Gov. Code Section Reference in Housing Element
Analysis of employment trends. Section 65583.a Section 2.B.1 Projection and quantification of existing and projected housing needs for all income groups. Section 65583.a Section 3.E Analysis and documentation of the City’s housing
characteristics, including cost for housing compared to ability to pay, overcrowding, and housing condition.

Section 65583.a Section 2.C, D, F
An inventory of land suitable for residential development including vacant sites and sites having redevelopment
potential.

Section 65583.a Section 3.E.1, 2, 3
Analysis of existing and potential governmental
constraints upon the maintenance, improvement or
development of housing for all income levels.

Section 65583.a Section 3.B
Analysis of existing and potential nongovernmental
(private sector) constraints upon
maintenance, improvement or development of
housing for all income levels.

Section 65583.a Section 3.A
Analysis concerning the needs of the homeless. Section 65583.a Section 2.E.7 Analysis of special housing needs: handicapped,
elderly, large families, farm workers, and female-headed households.

Section 65583.a Section 2.E
Analysis of opportunities for energy conservation
with respect to residential development. Section 65583.a Section 3.G Identification of Publicly Assisted Housing
Developments. Section 65583.a Section 3.J.5
Identification of Units at Risk of Conversion to
Market Rate Housing. Section 65583.a Section 3.J.5
Identification of the City’s goal relative to the
maintenance, improvement, and development of
housing.

Section 65583.a Section 4
Analysis of quantified objectives and policies
relative to the maintenance, improvement, and
development of housing.

Section 65583.b Section 4
Identification of adequate sites that will be made
available through appropriate action with
required public services and facilities for a variety
of housing types for all income levels.

Section 65583.c(1) Appendix B
Identification of strategies to assist in the
development of adequate housing to meet the Section 65583.c(2) Section 3.E.1, 2, 3

Section 1: Introduction 1-4
2021-2029 Housing Element Update - Draft
Table 1-1: Housing Element Requirements
Housing Element Requirement(s) Gov. Code Section Reference in Housing Element
needs of low and moderate-income households.

Description of the Public Participation Program in
the formulation of Housing Element Goals, Policies,
and Programs.

Section 65583.d Appendix C
Description of the Regional Housing Needs
Assessment (RHNA) prepared by the Southern
California Association of Governments.

Section 65583.e Section 3.E.1
Analysis of Fair Housing, including Affirmatively Furthering Fair Housing. Section 8899.50 Section 3.H, I, J, K, L
Review of the effectiveness of the past Element,
including the City’s accomplishments during the
previous planning period.

Section 65583.f Appendix A
Source: State of California, Department of Housing and Community Development.

The State of California began requiring in 1969 that all local governments plan for housing needs through Housing Elements within each jurisdiction’s General Plan. Housing Elements must be updated every eight years – this timeframe is also referred to as a cycle. This Housing Element is part of the 6th Cycle for 2021 to 2029.

Orange’s Housing Element was last adopted in January 2014 for the State’s 5th Housing Element cycle for the 2014-2021 planning period. Housing Elements are updated on eight year cycles, with each region across the state having the same start and end time. The 6th Cycle Housing Element, for the 2021-2029 planning period, is part of the new update cycle for jurisdictions within the SCAG (Southern California Association of Governments) region to allow for synchronization with the Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS). The Element sets forth an 8-year strategy to address the City’s identified housing needs, including specific implementing programs and activities.

Multiple amendments have been made to Housing Element law since the adoption of the City’s 5th Cycle Housing Element. These amendments and subsequent, new housing laws change the required analysis, reporting and policies contained in the Housing Element. The updated Housing Element complies with these amendments to state housing law and all other federal, state, and local requirements.

3. Regional Housing Needs Assessment
Section 65583 of the California Government Code sets forth the specific content requirements of a jurisdiction’s housing element. These requirements include obligations on the part of local jurisdictions to provide their “fair share” of regional housing needs. Local governments and Councils of Governments (COGs) are required to determine existing and future housing need and the allocation of this need must be approved by the California Department of Housing and Community Development (HCD). Orange is located in the SCAG regional planning area (but is not a member of SCAG). SCAG is the COG responsible for preparing the Regional Housing Needs Assessment (RHNA) for all jurisdictions within the SCAG region in coordination with HCD.

Section 1: Introduction 1-5
2021-2029 Housing Element Update - Draft
The RHNA allocation provides requirements for housing at all income levels within the community. The allocation is divided up between very low, low, moderate, and above moderate-income categories. Specific housing types and densities are generally associated with providing housing for each income category; the Housing Element must allow for the required number of units to be built throughout the City by facilitating and promoting certain housing types.

HCD established the planning period for the current RHNA from October 15, 2021 to October 15, 2029. For the 2021-2029 planning period the City is allocated a total of 3,927 units, including 1,064 units affordable to very low-income households, 603 units affordable to low-income, 676 units affordable to moderate- income, and 1,584 units affordable to above-moderate income households.

4. Relationship to Other General Plan Elements
The Housing Element is one Chapter of the City of Orange General Plan. The goals, policies, actions, and programs described in the Housing Element relate to, and are consistent with, the other Elements of the Orange General Plan. The City’s Housing Element focuses on programs and policies that support the preservation, improvement, and development of housing to meet the existing and projected future housing needs of its population.

The Housing Element supports and reinforces development policies contained in the Land Use Element, most recently amended in 2015. The Land Use Element establishes the location, type, intensity, and distribution of land uses throughout the City, and defines these land uses build-out potential. By designating residential development, the Land Use Element identifies limits for densities and types of housing units constructed in the City. The Land Use Element identifies lands designated for a range of other land uses, including employment-generating uses, open space, and public uses. The presence and potential for jobs affects the current and future local demand for housing at the various income levels in the City.

The Circulation and Mobility Element of the General Plan relates to the Housing Element. The Transportation Element establishes policies for a balanced circulation system in the City. Consequently, the Housing Element must include policies and incentives that consider the types of infrastructure essential for residential housing units in addition to mitigating the effects of growth in the City.

The Economic Development Element of the General Plan also relates to the Housing Element. The Economic Development Element establishes policies for preserving and maintaining a diverse economic base and increasing employment opportunities. The Housing Element correlates to the Economic Development Element as it must consider housing for the City’s current and future workforce, as well as include policies and incentives that support housing for all economic segments of the community.

The Housing Element has been reviewed for consistency with the City’s other General Plan Elements, and the policies and programs in the Housing Element’s policies and programs are consistent with the other Elements. As portions of the General Plan may be amended in the future, the Housing Element will be reviewed to ensure internal consistency is maintained.

Section 1: Introduction 1-6
2021-2029 Housing Element Update - Draft

5. Public Participation
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 discussion of citizen participation is provided below.

As part of the 6th Cycle Housing Element Update process, the City of Orange has conducted extensive public outreach activities beginning in 2019. These recent outreach efforts included workshops, stakeholder meetings, digital media, an online survey, and public noticing. 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 community, includes the following actions:
 Housing Element Update webpage with all housing materials and information, located at https://www.cityoforange.org/290/Current-Projects
 Virtual Community Workshops with recordings available on the webpage  Online Community Survey available from October 12, 2020 to December 1, 2020.

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.

Appendix C contains a summary of all public comments regarding the Housing Element received by the City during the update process.

6. Data Sources
The data used for the completion of this Housing Element comes from a variety of sources. These include, but are not limited to:
 2000 and 2010 Census
 American Community Survey
 Regional Analysis of Impediments to Fair Housing (AI)  Point-in-Time Homeless Census by the Regional Task Force on the Homeless, 2019  Home Mortgage Disclosure Act (HMDA) lending data
 California Department of Economic Development
 California Employment Development Division Occupational Wage data, 2020  Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy (CHAS), 2013-2017
The data sources represent the best data available at the time this Housing Element Update was prepared.

The original source documents contain the assumptions and methods used to compile the data.

Section 1: Introduction 1-7
2021-2029 Housing Element Update - Draft

7. Housing Element Organization
This Housing Element represents the City’s policy program for the 2021-2029 6th Planning Period. The Housing Element is comprised of the following Chapters:

Chapter 1: Introduction contains as summary of the content, organization, and statutory considerations of the Housing Element;
Chapter 2: Community Profile contains an analysis of the City’s population, household and employment base, and the characteristics of the housing stock;
Chapter 3: Housing Constraints and Resources examining governmental and non-governmental constraints on production, maintenance, and affordability of housing and provides a summary of housing resources, including sites identification and funding and financial considerations; Chapter 4: Policy Plan addresses Orange’s identified housing needs, including housing goals, policies, and programs.

Appendices provides various appendices with supplementary background resources including:
 Appendix A – Review of Past Performance of 5th Cycle Housing Element Programs  Appendix B – Adequate Sites Analysis
 Appendix C – Community Engagement Summary
 Appendix D – Glossary of Housing Terms
Section 2: Community Profile

Section 2: Community Profile 2-2
2021-2029 Housing Element Update - Draft
City of Orange Community Profile
The Community Profile for the City of Orange provides an overview of the City’s housing and population conditions. The community profile serves as a foundational component for the Housing Element’s policies by describing and assessing contributing factors and characteristics that influence the supply and demand for housing in Orange. Specifically, the community profile describes population, employment, economics and household characteristics in Orange. Special Needs groups and housing stock characteristics are also described.

The data in this community profile has been collected using the most current available sources from the Southern California Association of Governments (SCAG), 2000 and 2010 U.S. Census, 2013-2019 American Community Survey, the California Department of Finance, the California Employment Development Department, the California Department of Education and other real estate market data.

A. Population Characteristics
Population characteristics influence current and future housing demand in a community. Population growth, age compositions and race/ethnicity influence the type and extent of housing needed and the ability of the local population to afford housing costs. The following section describes and analyzes various population characteristics and local trends.

1. Population Growth
Table 2-1 displays actual and projected populations for the City of Orange and surrounding cities from 2000 to 2040. The 2010 U.S. Census reported a population of 136,416 persons in the City of Orange. This is a nearly six percent increase from the 2000 population. Orange’s rate of population increase between 2000 to 2010 is slightly lower than nearby cities Yorba Linda and Fullerton which both saw about a seven percent increase. Orange experienced a larger rate of population growth than Anaheim, Garden Grove and Santa Ana.

The SCAG Final Growth Forecast Report (2016-2040) bases population, economic and housing forecasts off U.S. Census data, projecting forecasted data through 2040. This data, shown in Table 1, forecast an 8,300- person population increase from 2020 to 2035 and another 1,600 person increase from 2035 to 2040. The City of Orange is estimated to experience an additional 10.5 percent growth in population from 2012 to 2040. The County of Orange, Fullerton, and Yorba Linda are forecast to experience over 16 percent growth rate, while Garden Grove and Santa Ana are forecast less than five percent growth through 2040. The City of Orange’s growth forecast indicates steady population growth through 2040.

Section 2: Community Profile 2-3
2021-2029 Housing Element Update - Draft

2. Age Characteristics
A community’s age composition is an important factor when evaluating housing needs because housing demand is often determined by the preferences of certain age groups. For example, young adults and seniors generally favor apartments, low to moderate-cost condominiums, and smaller or more affordable single-family units because they tend to live on smaller or fixed incomes and have smaller families. Middle- aged persons between 35 and 65, makes up the largest portion of home buyers and represents the greatest market demand for moderate and higher cost apartments and condominiums because they generally have higher incomes and larger families to accommodate. As the population ages and moves through different stages of life, housing needs must also be adjusted.

Figure 2-1: Age Distribution in Orange

Source: United States Census Bureau, 2000 and 2010; American Community Survey, 5-Year Estimates, 2019.

Under 5 5 to 19 20 to 34 35 to 44 45 to 64 65 and Above20008681 28610 30288 21604 26377 1240920108681 28553 31365 19491 33698 1462820198473 26322 34670 17705 35641 17076Percent Change-2.4% -8.0% 14.5% -18.0% 35.1% 37.6%0500010000150002000025000300003500040000 Table 2-1: Population Growth, 2000-2040
Jurisdictions
Population Percent Change
2000
Actual
2010
Actual
2012
Estimated
2020
Projected
2035
Projected
2040
Projected
1990-
2010
2012-
2040
Anaheim 328,014 336,265 345,300 358,600 382,000 403,400 2.5% 16.8% Fullerton 126,003 135,161 138,000 145,700 158,300 160,500 7.3% 16.3% Yorba Linda 59,918 64,234 66,200 69,300 70,400 70,500 7.2% 6.5% Orange 128,821 136,416 138,500 143,100 151,400 153,000 5.9% 10.5% Santa Ana 337,977 324,528 329,200 340,600 343,400 343,100 -4.0% 4.2% Garden Grove 165,196 170,883 172,900 176,100 178,400 178,200 3.4% 3.1% County of Orange 2,846,289 3,010,232 3,071,600 3,271,100 3,431,200 3,461,500 2.5% 16.8% Represents an estimate from the SCAG 2016-2040 Final Growth Forecast by Jurisdiction.

Sources: Bureau of the Census (2000-2010) and SCAG 2016-2040 Final Growth Forecast by Jurisdiction (2012).

Section 2: Community Profile 2-4
2021-2029 Housing Element Update - Draft
Figure 2-1 shows age composition in the City of Orange from 2000 to 2019 with the percent change over that period. Persons aged 65 and above experienced the largest growth at 37.6 percent. Persons aged 45 to 64 also experienced a large increase at 35.1 percent. Adults between 35 and 44 years experienced the greatest decrease at 18 percent.

Overall, the City of Orange shows a trend towards an aging population with steady population increases in persons over the age of 45 and a decreasing population of persons aged 19 and younger. An increasing aging population may require changes in housing needs including housing types, amenities, and access to specialized services.

Table 2-2 displays estimated 2019 American Community Survey age distribution for Orange, the County of Orange, and nearby cities. Orange’s largest population is between 20 to 44 years of age (37.5 percent). The population is comprised of 25.6 percent people ages 45 to 64 years and 12.2 percent ages 65 and over. 2019 age distribution estimates are similar to surrounding cities. The largest population group for cities shown in Table 2-2, excluding Yorba Linda, are persons age 20 to 44.

Table 2-2: Age Distribution Estimates, 2019
Jurisdiction Under 18 20 to 44 45 to 64 65 years +
Anaheim 24.0% 37.4% 24.3% 11.6%
Fullerton 21.8% 37.0% 24.9% 13.3%
Yorba Linda 23.1% 26.0% 31.1% 18.0%
Orange 21.3% 37.5% 25.6% 12.2%
Santa Ana 26.9% 39.2% 22.1% 9.0%
Garden Grove 21.4% 34.3% 27.5% 14.3%
County of Orange 22.2% 34.1% 26.7% 14.4%
Source: American Community Survey, 5-Year Estimates, 2019.

3. Race/Ethnicity Characteristics
Racial and ethnic composition may influence housing due to varying household characteristics, income levels, and cultural backgrounds that may affect housing needs, housing choice and housing types. Cultural influences may influence preference for specific types of housing and locational factors.

Figure 2-2 displays 2019 racial and ethnic composition for the City of Orange compared to the County of Orange. Figure 2-2 shows majority of the population was White in the City and County. The next largest population in the City of Orange was Asian. Represented racial groups in Orange include 72 percent identifying as White, 1.7 percent identifying as Black, and 11.8 percent identifying as Asian. Those who identify as American Indian/Alaska Native and Native Hawaiian/other Pacific Islander represent the smallest percentages of the population; both combined add up to under one percent of the population. About 39 percent of all races in Orange identify as Hispanic or Latino.

Section 2: Community Profile 2-5
2021-2029 Housing Element Update - Draft
Figure 2-2: Racial Ethnic Composition, 2019
Source: American Community Survey, 5-Year Estimates, 2019.

Table 2-3 compares racial and ethnic data for Orange and nearby cities. In all nearby cities, the largest population was White. The City of Orange has the second largest White population at 72 percent after Yorba Linda. The Cities of Anaheim and Fullerton both have larger Black populations than Orange with about one percent more. The Asian population of Orange is 8 percent below the County’s regional percentage, and similarly to Santa Ana, it represents the lowest amount of the surrounding cities. All the cities in this area, as well as the County of Orange, have American Indian/Alaska Native and Native Hawaiian/other Pacific Islander populations that represent less than one percent of the total populations.

Table 2-3: Racial/Ethnic Composition by Jurisdiction, 2019 Jurisdiction White Black
American
Indian
and
Alaska
Native
Asian
Native
Hawaiian
or Other
Pacific
Islander
Some
Other
Race
Two or
More
Races

Hispanic
or Latino
Origin (1)

Anaheim 66.42% 2.70% 0.51% 16.82% 0.42% 9.87% 3.26% 54.28% Fullerton 58.29% 2.49% 0.38% 24.28% 0.28% 9.19% 5.09% 37.14% Yorba
Linda 72.24% 1.37% 0.12% 20.71% 0.11% 1.52% 3.93% 16.46% Orange 72.0% 1.7% 0.4% 11.8% 0.4% 10.1% 3.5% 38.9%
Santa Ana 40.15% 1.14% 0.55% 11.76% 0.28% 44.06% 2.05% 76.76% Garden
Grove 40.28% 1.01% 0.50% 41.20% 0.33% 14.36% 2.32% 36.36% County of
Orange 61.0% 1.8% 0.5% 20.5% 0.3% 11.9% 4.1% 34.1%
Source: American Community Survey, 5-Year Estimates, 2019.

Note: (1) Persons of Hispanic or Latino Origin is an ethnicity that may be included in other racial groups.

White BlackAmericanIndian andAlaskaNativeAsianNativeHawaiianor OtherPacificIslanderSomeOther RaceTwo orMoreRacesHispanic orLatinoOrange72.0% 1.7% 0.4% 11.8% 0.4% 10.1% 3.5% 38.9%County of Orange61.0% 1.8% 0.5% 20.5% 0.3% 11.9% 4.1% 34.1%0%10%20%30%40%50%60%70%80%

Section 2: Community Profile 2-6
2021-2029 Housing Element Update - Draft
The Census and the 2019 ACS report changes in Orange’s racial and ethnic demographics from 2000 to 2019, as shown in Table 2-4. From 2000 to 2010, the White population decreased by about five percent and the American Indian and Alaska Native population decreased from 0.8 percent to 0.7 percent (12.5 percent overall decrease). During this same period other racial groups experienced significant increases.

The Asian population increased from 9.3 percent in 2000 to 11.3 percent in 2010 (21.5 percent increase).

The Black population experienced no population change. Persons identifying as Hispanic or Latino increased by 18.3 percent between 2000 and 2010.

Between 2010 and 2019, the White population increased by 7.3 percent, representing 72 percent of Orange’s population. The Black population experienced a 6.3 percent increase. Decreases were experienced by the American Indian and Alaska Native, Some Other Race, and Two or More Races populations. The Asian population showed a 4.4. percent increase from 2010-2019. Persons identifying as Hispanic or Latino experienced a 2.1 percent increase from 2010 to 2019.

Table 2-4: Changes in Racial/Ethnic Composition Between 2000 - 2019 Race/Ethnicity 2000 2010 2019
Percent
Change 2000
to 2010
Percent
Change 2010
to 2019
White 70.5% 67.1% 72.0% -4.8% 7.3%
Black 1.6% 1.6% 1.7% 0.0% 6.3%
American Indian and
Alaska Native 0.8% 0.7% 0.4% -12.5% -42.9%
Asian 9.3% 11.3% 11.8% 21.5% 4.4%
Native Hawaiian or
Other Pacific Islander 0.2% 0.3% 0.4% 50.0% 33.3%
Some Other Race 13.8% 15.1% 10.1% 9.4% -33.1%
Two or More Races 3.8% 4.0% 3.5% 5.3% -12.5%
Hispanic or Latino 32.2% 38.1% 38.9% 18.3% 2.1%
Source: United States Census Bureau, 2000 and 2010 and American Community Survey, 5-Year Estimates, 2019.

B. Economic Characteristics
Analysis of economic characteristics provides valuable data about a community’s accessibility to the housing market and financial restraints related to housing needs. These may include income associated with different types of employment and number of workers contributing to the household. To properly evaluate the balance between jobs and housing, employment characteristics should be considered. Local employment growth or decline is linked to local housing demand

Section 2: Community Profile 2-7
2021-2029 Housing Element Update - Draft

1. Employment and Wage Scale
The SCAG Growth Forecast Report estimates employment growth for the City of Orange and nearby cities.

Table 2-5 shows that from 2012 to 2040 the City of Orange is forecast to gain 11,200 jobs, a 12.1 percent increase. Nearby cities such as Garden Grove and Yorba Linda forecast similar growth increases (12.6 percent and 13.5 percent respectively). Other cities, such as Anaheim and Fullerton are projected much higher employment growth, at 38.1 percent in Anaheim and 54.8 percent in Fullerton.

Table 2-1 shows a forecasted 14,500-person population growth in Orange from 2012 to 2040. Given this anticipated growth, local job availability is important to allow residents the option to live and work in the same city. Just as employment opportunities may encourage households to move to Orange, a variety of available housing options may also encourage households to seek employment in the City.

Table 2-5: Employment Growth Trends, 2010-2050
Jurisdiction 2012 2020 2035 2040 % Change
2012-2040
Numeric Change
2012-2040
Anaheim 177,900 207,000 236,000 245,600 38.1% 67,700
Fullerton 60,800 78,000 91,600 94,100 54.8% 33,300
Yorba Linda 15,600 16,800 17,600 17,700 13.5% 2,100
Orange 94,100 100,700 104,700 105,500 12.1% 11,400
Santa Ana 154,800 160,600 165,200 166,000 7.2% 11,200
Garden Grove 51,700 56,600 58,200 58,200 12.6% 6,500
County of Orange 1,526,500 1,730,400 1,870,500 1,898,900 24.4% 372,400 Source: SCAG 2016-2040 Final Growth Forecast by Jurisdiction (2012).

Analyzing employment sectors helps in understanding growth changes, income and wages, access to different housing types, and overall housing demand. The City of Orange is a generally moderate-income community with a slightly higher than average median income compared to the County of Orange (see Table 2-13). Employment industry types associated with these income ranges include persons employed in education, professional, health care, and management industries (Table 2-6).

Table 2-6 displays the 2010 and 2019 ACS data for employment by sector in the City of Orange. In 2010, a majority of the working population was employed in education services, health care, and social assistance industries (18.5 percent). Professional, scientific, management, and administrative services, retail trade and manufacturing were the next largest employment sectors in Orange in 2010. In 2019, Education services, health care and social assistance jobs remained the largest employers in the City, reaching 22.6 percent, representing a 30.2 percent increase from 2010. Professional, scientific, management, and administrative services remained the second largest employment sector. However, these industries experienced an overall decrease of 0.5 percent. Arts, entertainment, recreation, accommodation, and food services experienced the largest growth rate, increasing from 8.6 percent in 2010 to 10.7 percent in 2019, a 32.8 percent increase.

Section 2: Community Profile 2-8
2021-2029 Housing Element Update - Draft
Table 2-6: Employment in Orange by Sector, 2010 - 2019
Industry Sector
2010 2019 Percent
Change
2010-
2017
# of
employed
persons
% of City
Employment
# of employed
persons
% of City
Employment
Agriculture, forestry, fishing and
hunting, and mining 488 0.7% 321 0.5% -34.22%
Construction 5,617 8.5% 5331 7.6% -5.09%
Manufacturing 7,736 11.7% 7809 11.1% 0.94%
Wholesale trade 2,692 4.1% 2056 2.9% -23.63%
Retail trade 6,852 10.3% 6656 9.4% -2.86%
Transportation and warehousing, and
utilities 1,779 2.7% 2394 3.4% 34.57%
Information 1,385 2.1% 1423 2.0% 2.74%
Finance and insurance, and real
estate and rental leasing 6,281 9.5% 5958 8.4% -5.14%
Professional, scientific, management,
and administrative services 9,454 14.3% 9407 13.3% -0.50% Education services, health care, and
social assistance 12,269 18.5% 15973 22.6% 30.19%
Arts, entertainment, recreation,
accommodation, and food services 5,681 8.6% 7542 10.7% 32.76% Other services (except public
administration) 3,890 5.9% 3348 4.7% -13.93%
Public Administration 2,216 3.3% 2303 3.3% 3.93%
Total 66,340 100% 70,521 100% 6.30%
Source: American Community Survey, 5-Year Estimates, 2010 and 2019.

Analyzing the unemployment rate contributes to understanding housing affordability and needs, as well as projected needs. According to the ACS survey data, (Table 2-7) Orange experienced a 4.4 percent unemployment rate, similarly to the County’s. Yorba Linda was the only city nearby that had a lower unemployment rate than Orange, with other cities’ rates ranging from 6.5 percent in Fullerton to 4.5 percent in Garden Grove.

Table 2-7: Unemployment Rates, 2019
Jurisdiction Unemployment rate*
Anaheim 5.2%
Fullerton 6.5%
Yorba Linda 3.6%
Orange 4.4%
Santa Ana 5.1%
Garden Grove 4.5%
County of Orange 4.6%
Source: American Community Survey, 5-Year Estimates, 2019. *Population 16 years and over

Section 2: Community Profile 2-9
2021-2029 Housing Element Update - Draft
Table 2-8 displays the 2019 average annual wage for occupations compile by the California Employment Development Department (EDD) for the Orange County Metropolitan Statistical Area. Professional and health services occupations, including management, legal services, healthcare practitioners and technical, architecture and engineering, and computer or mathematical services, were among the highest paying professions in the region. Additionally, occupations such as life, physical and social sciences and business or financial operations offer above median income pay. Educational occupations offer just below median income pay, and, referring to table 2-6 are the most common occupation in the City of Orange.

Table 2-8: Mean Salary by Occupation in Orange County, 2019 Occupation Salary
Management $124,158
Legal $111,887
Healthcare Practitioners and Technical $92,080
Architecture and Engineering $91,796
Computer and Mathematical $91,533
Life, Physical and Social Sciences $82,951
Business and Financial Operations $72,759
Education, Training and Library $60,130
Arts, Design, Entertainment, Sports and Media $55,157
Construction and Extraction $58,307
Protective Services $38,388
Community and Social Service $51,921
Installation, Maintenance and Repair $52,114
Sales $34,774
Office and Administration Support $42,964
Production $35,768
Transportation and Material Moving $31,774
Healthcare Support $30,171
Building, Grounds Cleaning, and Maintenance $31,603
Personal Care and Service $29,613
Farming, Fishing and Forestry $31,978
Food Preparation and Serving Related $27,895
Source: California Employment Development Division, Occupational Wage data, 2019.

Section 2: Community Profile 2-10
2021-2029 Housing Element Update - Draft
C. Household Characteristics
A household is defined by the U.S. Census Bureau as all persons who occupy a housing unit. This may include single persons living alone, families related through marriage, blood or adoption, domestic partnerships and unrelated individuals living together. Nursing facilities, residential care facilities, dormitories, and other group living are not considered housing units, and the persons living within them are not considered a household.

Analysis of household characteristics assists in understanding growth and determining housing needs of a community. Income and affordability are best measured at the household level, including special needs of certain groups. These may include large families, single parent households, or low and extremely low- income households.

1. Household Type and Size
Table 2-9 displays 2019 American Community Survey (ACS) household characteristics data for Orange and nearby cities. The ACS reported 43,075 households in the City of Orange in 2019. Of this total, 56 percent were married-couple family households, comparable to nearby cities with the exception of Yorba Linda which reported a significantly higher percent (71.3 percent). Compared to nearby cities, Orange had a slightly smaller percent of female headed households with no spouse present (11.9 percent). Non-family households made up 26.8 percent of all households in Orange, generally higher than nearby cities.

Table 2-9: Household Characteristics, 2019
Jurisdiction
Married-
Couple
Family
Households
% of Total
Households
Female
Householder,
No Spouse
Present
% of Total
Households
Non-Family
Household
% of Total
Households
Total
Households
Anaheim 52,747 51.90% 15,889 15.60% 26,539 26.10% 101,658 Fullerton 23,855 52.10% 5,588 12.20% 13,818 30.20% 45,814 Yorba Linda 16,142 71.30% 1,687 7.40% 3,907 17.30% 22,649 Orange 24,227 56.20% 5,114 11.90% 11,555 26.80% 43,075
Santa Ana 42,486 55.40% 13,137 17.10% 14,031 18.30% 76,624 Garden
Grove 26,255 55.00% 7,074 14.80% 10,396 21.80% 47,761
County of
Orange 569,260 24.90% 119,719 11.50% 293,481 28.30% 1,037,492 Source: American Community Survey, 5-Year Estimates, 2019.

Figure 2-3 depicts household composition in the City of Orange, including data for households with the householder age 65 or older. As previously noted in Table 2-9, Orange has a relatively low percentage of female householders with no spouse present, and even lower percentage of male householders with no spouse present (5.1 percent). A majority of Orange households are married couple families and 22.6 percent of all households have a householder of 65 years and over.

Section 2: Community Profile 2-11
2021-2029 Housing Element Update - Draft
Figure 2-3: Orange Household Characteristics in Percent, 2019

Source: American Community Survey, 5-Year Estimates, 2019.

Table 2-10 shows changes in household characteristics from 2000 to 2019. From 2000 to 2019, the City of Orange experienced a 5.2 percent increase in total households. Of those households in 2000, about 57 percent were married-couple family households. Married-couple family households decrease to about 56.2 percent in 2019. The percent of households with a householder 65 years and over increased by about 36.9 percent from 2000 to 2019. Additionally, the percent of female headed households with no spouse present increased from 4,743 persons in 2000 to 5,114 persons in 2019 (a 7.8 percent increase).

Table 2-10: Changes in Household Characteristics, 2000-2019 2000 Percent 2010 Percent 2019 Percent
Married-couple
Family
Households
23,375 57.1% 23,572 54.4% 24,227 56.2%
Female
Household, No
Spouse Present
4,743 11.6% 5,260 12.1% 5,114 11.9%
Non-Family
Household 10,762 26.3% 12,111 27.9% 11,555 26.8%
Householder 65
Years and Over 7,125 17.4% 8,682 20.0% 9,753 22.6%
Total
Households 40,930 100.0% 43,367 100.0% 43,075 100.0%
Source: American Community Survey, 5-Year Estimates, 2017.

The SCAG 2012 to 2040 Final Growth Forecast estimates expected growth in the in the City of Orange and surrounding cities, shown below in Table 2-11. From 2012 to 2040 Orange is forecast to experience steady household growth, totaling 13.1 percent by 2040. Orange’s household growth forecast is about 2 percent Married-coupleFamily HouseholdsMale Householder,No Spouse PresentFemaleHouseholder, NoSpouse PresentNon-FamilyHouseholdHouseholder Age65 or AboveOrange56.2% 5.1% 11.9% 26.8% 22.6%0%10%20%30%40%50%60%70%80%90%100%

Section 2: Community Profile 2-12
2021-2029 Housing Element Update - Draft
below that of the County, but has a higher forecasted growth than Yorba Linda, Santa Ana, and Garden Grove. Anaheim and Fullerton have households growth forecasts greater than Orange by 10.5 percent and

8.2 percent (respectively).

Table 2-11: Household Growth Forecasts, 2012-2040
Jurisdiction 2012 2020 2035 2040 Percent Change
2012 - 2040
Anaheim 99,200 104,600 114,100 122,600 23.6%
Fullerton 45,500 48,800 54,300 55,200 21.3%
Yorba Linda 21,900 22,900 23,300 23,400 6.8%
Orange 43,600 45,300 48,500 49,300 13.1%
Santa Ana 73,300 76,600 77,700 78,000 6.4%
Garden Grove 46,200 47,300 48,000 48,200 4.3%
County of
Orange 999,500 1,074,700 1,135,300 1,152,300 15.3%
Source: SCAG 2016-2040 Final Growth Forecast by Jurisdiction (2012).

Table 2-11 displays average household size in Orange and nearby cities in 2019. The County of Orange has an average household size of 3.05 in 2019, slightly smaller compared to Orange’s average household size of 3.18. The Cities of Santa Ana and Garden Grove have larger average household sizes of 4.32 and 3.6 respectively. Orange’s average household is in the mid-range compared to surrounding cities.

Table 2-11: Average Household Size
Jurisdiction Average Persons
per Household
Anaheim 3.41
Fullerton 3.02
Yorba Linda 2.78
Orange 3.18
Santa Ana 4.32
Garden Grove 3.60
County of Orange 3.05
Source: American Community Survey, 5-Year
Estimates, 2019.

2. Household Income
Household income is directly connected to affordability. As household income increases, the ability to afford higher priced housing units increases. This may include access to larger sized units and/or ability to move from rental to ownership opportunities. However, as household income decreases, households will likely utilize a disproportionate amount of their income toward housing costs. This may influence incidences of overcrowding and substandard living conditions.

Section 2: Community Profile 2-13
2021-2029 Housing Element Update - Draft
The California State Department of Housing and Community Development (HCD) has identified the following income categories based on the Area Median Income (AMI) of Orange County;  Very Low-income: households earning between 0 and 50 percent of the AMI  Low-income: households earning between 51 percent and 80 percent of the AMI  Moderate Income: households earning between 81 percent and 120 percent of the AMI  Above Moderate Income: households earning over 120 percent of the AMI State law also defines extremely low-income as households earning 30 percent or less of the AMI and are considered a subset of the very low-income category. Combined, the extremely low, very low, and low- income groups are referred to as lower income.1
Comprehensive Housing Affordability Strategy (CHAS) estimates based on 2006-2017 American Community Survey (ACS) data are shown in Table 2-12. Households exhibit a near even split between renters and owners in Orange. There was a higher percentage of renters in the extremely low-income category, and a greater percentage of owners in the moderate- or above-moderate income level than renters. In 2017, a little over half of households had a moderate or above moderate income. Just under 20 percent of those household were in the low-income category. The very low and extremely low-income categories constitute about 24 percent of total households.

Table 2-12: Households by Income Category, 2017
Income Category (% of County
AMI) Owner Percent Renter Percent Total Percent
Extremely Low (30% AMI or less) 1,570 3.7% 3,920 9.2% 5,490 12.9% Very Low (31 to 50% AMI) 2,015 4.7% 2,975 7.0% 4,990 11.7% Low (51 to 80% AMI) 3,855 9.0% 4,550 10.7% 8,405 19.7% Moderate or Above Moderate
(over 80% AMI)
16,835 39.5% 6,905 16.2% 23,740 55.7%
Total 24,280 57.0% 18,345 43.0% 42,625 100.0%
Source: Department of Housing and Urban Development (HUD) Comprehensive Housing Affordability Strategy (CHAS), 2012- 2017.

Figure 2-4 shows median household income by cities in Orange County in 2019. The median household income for the Orange County was $90,234, the City of Orange had a slightly higher median household income of $91,793.

1 Federal housing and community development programs typically assist households with incomes up to 80 percent of the AMI and use different terminology. For example, the Federal Community Development Block Grant (CDBG) program refers households with incomes between 51 and 80 percent AMI as moderate income (compared to low-income based on State definition).

Section 2: Community Profile 2-14
2021-2029 Housing Element Update - Draft
Figure 2-4: Median Household Income by City, 2019
Source: American Community Survey, 5-Year Estimates, 2019.

Table 2-13 displays Orange and nearby cities’ median incomes and the percent above or below the county median income. As displayed in Figure 2-4, the City of Orange has a slightly higher median income than the County. Orange’s median household income was two percent higher than the County. The City of Orange and Yorba Linda had median incomes higher than the county.

Table 2-13: Median Household Income by Jurisdiction
Jurisdiction Median Income
Percent
Above/Below
Regional Median
Anaheim 71,763 -25.7%
Fullerton 79,978 -12.8%
Yorba Linda 129,995 30.6%
Orange 91,793 1.7%
Santa Ana 66,145 -36.4%
Garden Grove 69,278 -30.2%
County of Orange 90,234 --
Source: American Community Survey, 5-Year Estimates, 2019.

71,763 79,978 129,995 91,793 66,145 69,278 90,234 90,234 $- $20,000 $40,000 $60,000 $80,000 $100,000 $120,000 $140,000 Anaheim Fullerton Yorba Linda Orange Santa Ana Garden Grove Median IncomeOrange County Median Income

Section 2: Community Profile 2-15
2021-2029 Housing Element Update - Draft
Figure 2-5 displays income distribution in Orange. According to Figure 2-5, persons who make more than $50,000 per year have higher percentages than those who make less than $50,000 per year. Those who made over $150,000 composed the largest individual income category at 25.8 percent. Overall, majority of employed persons in the City of Orange fall into the moderate to above moderate-income categories, specifically, with higher percentages making over $100,000 per year.

Figure 2-5: Orange Income Distribution

Source: American Community Survey, 5-Year Estimates, 2019.

D. Housing Problems
The CHAS developed by the Census Bureau for HUD reports housing needs data by income level for different types of households in Orange. The most recent available CHAS data for Orange was published in August 2020 and was based on 2006-2017 ACS data. Housing problems considered by CHAS include:
 Units with physical defects (lacking complete kitchen or bathroom);  Overcrowded conditions (housing units with more than one person per room);  Housing cost burdens, including utilities, exceeding 30 percent of gross income; or  Severe housing cost burdens, including utilities, exceeding 50 percent of gross income.

The types of housing problems identified in CHAS data vary according to household income, type, and tenure (Table 2-14). These include:
 In general, owner-occupied households had a lower level of housing problems (30.6 percent) than renter-occupied households (58.4 percent).
 Approximately 13.5 percent of owner-occupied households report having a severe housing problem, whereas almost 39.6 percent of renters reported a severe housing problem. The four severe housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1.5 persons per room, and cost burden greater than 50%.  Overall, 42.6 percent of all households reported at least one housing problem and 24.7 percent of all households reported at least one severe housing problem.

Lessthan$5,000 $5,000to$9,999 $10,000to$14,999 $15,000to$19,999 $20,000to$24,999 $25,000to$34,999 $35,000to$49,999 $50,000to$74,999 $75,000to$99,999$100,000to$149,999$150,000or moreOrange2.3% 1.5% 2.5% 2.3% 2.8% 5.4% 8.9% 16.1% 12.8% 19.7% 25.8%0%5%10%15%20%25%

Section 2: Community Profile 2-16
2021-2029 Housing Element Update - Draft
Table 2-14: Housing Assistance Needs of Lower Income Households Housing Problem
Overview*
Owner Renter Total
Households Percent Households Percent Households Percent Household has at least 1 of
4 Housing Problems 7,420 30.6% 10,720 58.4% 18,140 42.6% Household has none of 4
Housing Problems 16,670 68.7% 7,365 40.1% 24,035 56.4%
Cost Burden not available,
no other problems 190 0.8% 260 1.4% 450 1.1%
Total 24,280 57% 18,345 43% 42,625 100%
Severe Housing Problem
Overview**
Owner Renter Total
Households Percent Households Percent Households Percent Household has at least 1 of
4 Severe Housing
Problems
3,270 13.5% 7,260 39.6% 10,530 24.7%
Household has none of 4
Severe Housing Problems 20,820 85.7% 10,825 59% 31,645 74.2% Cost Burden not available,
no other problems 190 0.8% 260 1.4% 450 1.1%
Total 24,280 57% 18,345 43% 42,625 100%
Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) 2012-2017.
* The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%.
** The four severe housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1.5 persons per room, and cost burden greater than 50%.

1. Overcrowding
“Overcrowding” is generally defined as a housing unit occupied by more than one person per room in housing unit (including living room and dining rooms, but excluding hallways, kitchen, and bathrooms). An overcrowding can be caused by lack of affordable housing (which forces more than one household to live together) and/or a lack of available, adequately sized housing units. Overcrowding is an indicator of inadequate supply of affordable housing, especially for large families.

Overcrowded and severely overcrowded households contribute to faster rates of deterioration due to more intensive use of individual housing units. The faster rates of deterioration are caused by excessive wear and tear, and the potential cumulative effect of overburdening infrastructure systems and exceeding service capacities. Furthermore, overcrowding in neighborhoods contributes to overall declines in social cohesion and environmental quality. Such decline can often spread geographically from housing units to neighborhoods and impact the overall quality of life and the economic vitality of a community.

Section 2: Community Profile 2-17
2021-2029 Housing Element Update - Draft
Table 2-15: Overcrowding by Tenure in Orange
Housing
Unit
Tenure
Overcrowded Housing Units
(1.0 to 1.50 persons/room)
Severely Overcrowded Housing
Units
(>1.51 persons/room)
Total Overcrowded Occupied
Housing Units
Number of
Units
Percent of
Total Occupied
Housing Units
Number of
Units
Percent of
Total Occupied
Housing Units
Number of
Units
Percent of
Total Occupied
Housing Units
Owner
Occupied 356 0.83% 180 0.42% 536 1.24%
Renter
Occupied 1825 4.24% 814 1.89% 2639 6.13%
Total 2181 5.06% 994 2.31% 3175 7.37%
Source: American Community Survey, 5-Year Estimates, 2019.

Table 2-15 displays incidents of overcrowding in the City of Orange. These data show that overcrowding disproportionately affects renters, with just over six percent of renter-occupied units overcrowded compared to 1.2 percent of owner-occupied units.

As shown in Table 2-16, renters were the primary group affected by overcrowding in nearby cities. In Santa Ana about 22 percent of all occupied units were overcrowded, renters-occupied units, compared to about 8 percent of owner-occupied units, a nearly tripled increase. In comparison to the City of Orange, Yorba Linda had the lowest percentage of overcrowded units for both renter and owner-occupied units showing under one percent overcrowding. Overall, the County of Orange shows under ten percent overcrowding, as well as predominantly renter-occupied overcrowded units.

Table 2-16: Overcrowded Housing Units by Tenure
Jurisdiction
Owner Occupied Overcrowded Units
(>1.0 persons/room)
Renter Occupied Overcrowded Units
(>1.0 persons/room)
Number of Units Percent of Total
Occupied Units Number of Units Percent of Total
Occupied Units
Anaheim 3018 2.97% 13370 13.15%
Fullerton 866 1.89% 3523 7.69%
Yorba Linda 143 0.63% 192 0.85%
Orange 536 1.24% 2639 6.13%
Santa Ana 6103 7.96% 16839 21.98%
Garden Grove 2261 4.73% 4838 10.13%
County of Orange 21886 2.11% 69796 6.73%
Source: American Community Survey, 5-Year Estimates, 2019.

Section 2: Community Profile 2-18
2021-2029 Housing Element Update - Draft

2. Overpayment (Cost Burden) In Relationship to Income
State and federal guidelines indicate that a household paying more than 30 percent of its income for housing is overpaying. Overpayment for housing can create an imbalance in a household’s overall budget.

Evaluating incidents of overpayment can influence the supply and demand of housing.

Per the Department Housing and Urban Development CHAS report (2012-2016), shown below in Table 2- 17, over half of households in Orange experience some type of cost burden or housing overpayment.

Households with an income less than or equal to 30 percent the County Area Median Income (AMI) experienced cost burdened at a higher overall percentage (19.1 percent). The data shows that as income increases, households are less likely to experience a cost burden. For example, households with an income of 80 percent of the AMI to 100 percent, made up just 10.9 percent of all households and just about 4.2 percent of households with a cost burden. Additionally, households with an income of 100 percent or above the AMI who experienced a housing cost burden made up 44.8 percent of all households and about five percent of households experiencing a cost burden. Overall, lower income renters were disproportionately affected by cost burdens; the data shows that for each income category.

Table 2-17: Summary of Housing Overpayment
Income by Cost
Burden
Owner Renter
Cost
Burden
> 30%
% of Tot.

HH (1)
Cost
Burden >
50%
% of
Tot. HH
Cost
Burden >
30%
% of Tot.

HH
Cost
Burden >
50%
% of
Tot. HH
Household Income
is less-than or =
30% AMI (2)
1,015 2.4% 770 1.8% 3,325 7.8% 3,025 7.1%
Household Income
>30% to less-than
or = 50% AMI
1,210 2.8% 830 1.9% 2,615 6.1% 1,315 3.1%
Household Income
>50% to less-than
or = 80% AMI
2,115 5.0% 705 1.7% 2,490 5.8% 515 1.2%
Household Income
>80% to less-than
or = 100% AMI
935 2.2% 285 0.7% 530 1.2% 40 0.1%
Household Income
>100% AMI 1,670 3.9% 110 0.3% 345 0.8% 0 0.0%
Total 6,945 16.3% 2,700 6.3% 9,305 21.8% 4,895 11.5%
Source: Source: U.S. Department of Housing and Urban Development, Comprehensive Housing Affordability Strategy 2012-2017.

Notes: (1) % of tot. HH = Percent of Total Households in Orange (2) AMI = Area Median Income, this is calculated by HUD for each jurisdiction, to determine Fair Market Rents (FMRs) and income limits for HUD programs. AMI will not necessarily be the same as other calculations of median incomes (such as a simple Census number), due to a series of adjustments that are made.
* Cost burden is the ratio of housing costs to household income. For renters, housing cost is gross rent (contract rent plus utilities).

For owners, housing cost is "select monthly owner costs", which includes mortgage payment, utilities, association fees, insurance, and real estate taxes.

Section 2: Community Profile 2-19
2021-2029 Housing Element Update - Draft
E. Special Needs Groups
State law identifies certain households that historically have more difficulty in finding adequate and affordable housing due to special needs. Special needs populations include seniors, persons with disabilities, female-headed households, large households, and farmworkers. Many persons within these special needs groups often have lower than average incomes because of their special needs.

Special needs may be related to a person’s employment and income, family characteristics, disability and household characteristics, or other factors. Consequently, certain residents in Orange may experience higher incidences of housing overpayment (cost burden), overcrowding, or other housing problems.

Special needs groups required to be analyzed in the Housing Element include the elderly, persons with physical and developmental disabilities, persons experiencing homelessness, single parents, large households, and farmworkers (Table 2-18). Many of these special needs groups overlap, for example, many farmworkers are migrant workers, and many elderly people have a self-care limitation of some type.

Table 2-18: Special Needs Groups in Orange
Special Needs Group Count Percent of Total
Households
Percent of Total
Population
Senior Headed
Households 9,753 households 22.6% --
Households with
Seniors (65 years and
over)
11,736
households 27.2% --
Seniors Living Alone 3,569 households 8.3% --
Persons with
Disabilities 10,974 persons -- 8.1%
Large Households (5
or more persons per
household)
5,946 households 13.8% --
Single-Parent
Households 3,053 households 7.1% --
Single-Parent, Female
Headed Households
with Children (under
18 years)
2,234 households 5.2% --
People Living in
Poverty 16,142 persons -- 12.1%
Farmworkers* 305 persons -- 0.4%
Homeless** 341 persons -- 0.2%
Source: American Community Survey, 5-Year Estimates, 2019; Orange County Point in Time Count, Everyone Counts Report 2019.
* Farmworker data is taken of the population 16 years and over, not total population. ** The Everyone Counts report is updated annually, therefore the most recent data is from 2019, and there is no percentage of total population available.

Section 2: Community Profile 2-20
2021-2029 Housing Element Update - Draft

1. Seniors
The senior population, generally defined as persons aged 65 years or older, traditionally have limited or fixed incomes, experience higher average health care costs, commonly have mobility and self-care limitations, are transit dependent, and live alone. Unique housing needs for the senior population include affordable housing, supportive housing (such as managed care facilities), group homes, and housing with a service component.

Incomes of many seniors often creates difficulty in finding affordable housing. Table 2-19 shows that 17,076 persons were age 65 and over in Orange in 2019, a total of 12.2 percent of the total population. This percentage is lower compared to neighboring cities and the region as a whole; the highest being 18 percent in Yorba Linda and the lowest being 9 percent in Santa Ana.

Table 2-19: Persons Age 65 and Over
Jurisdiction Population
Count Percent
Anaheim 40,694 11.6%
Fullerton 18,561 13.3%
Yorba Linda 12,165 18%
Orange 17,076 12.2%
Santa Ana 29,918 9%
Garden Grove 24,700 14.3%
County of Orange 455,105 14.4%
Source: American Community Survey, 5-Year Estimates, 2019.

Seniors also have varying housing needs, specifically those who are living alone. Figure 2-6 below displays housing characteristics for seniors living alone in Orange using 2019 ACS data. The data above shows that there is a total of 17,076 seniors living in the City, of those seniors, majority live in family households (about 72 percent). For seniors who live in non-family households, about 2 percent lived with non-relatives, 6.6 percent were Male householders who lived alone, and 14.3 percent were female households who lived alone. Additionally, about 2 percent of the population over 65 years of age lived in group quarters.

The City currently has eight total affordable housing developments for senior residents, as provided in Table 3-33b. This includes 192 deed-restricted affordable units ranging from one- to three-bedroom units. This Housing Element’s Section 4: Housing Plan includes Housing Policy Action 2D which establishes regulatory incentives to develop senior housing that may include independent living options and/or assisted living with on-site services and memory care facilities.

In addition, the City partners with the Orange Elderly Services, Inc. non-profit community-based organization to provide services (activities, events, meals, and transportation) to residents at the Orange Senior Center. The Senior Transportation Program is offered by the Orange Senior Center to subsidize taxi travels for seniors over 60 years of age to/from medical appointment, pharmacy, grocery store, or the Orange Senior Center.

Section 2: Community Profile 2-21
2021-2029 Housing Element Update - Draft
Figure 2-6: Household Characteristics, Percent of Population Aged 65 Years+

Source: American Community Survey, 5 Year Estimates, 2019.

In addition to overpayment problems faced by seniors, seniors have a higher incident of disabilities. In 2019, the American Community Survey reported 5,019 seniors having a disability. The most common reported disabilities were ambulatory disabilities, independent living disabilities and hearing disabilities.

2. Persons with Physical and Developmental Disabilities Physical and developmental disabilities may limit a person’s barrier-free access to traditionally designed housing units. Physical and/or developmental disabilities may influence a person’s ability to earn income, restrict mobility, or create self-care limitations. Lower income persons with disabilities commonly require housing assistance and services. Housing needs for disabled persons can be compounded by limitations imposed by building designs. Accessibility and transportation considerations and location factors can affect the cost and availability of housing. Special needs households with wheelchair-bound or semi-ambulatory individuals require American Disabilities Act (ADA) compliance and specific accommodations such as ramps, holding bars, special bathroom designs, wider doorways, lower cabinets, elevators, and other interior and exterior design features.

Housing opportunities for persons with disabilities can be addressed through the provision of affordable, barrier-free housing. Rehabilitation assistance can be targeted toward renters and homeowners with disabilities for unit modification to improve accessibility.

The 2019 ACS identifies six disability types: hearing disability, vision disability, cognitive disability, ambulatory disability, self-care disability and independent living disability. The Census and the ACS provide clarifying questions to determine persons with disabilities and differentiate disabilities within the In Family Households:72.1%Male Living alone6.6%Femaile Living alone14.3%In Group Quarters2.8%Living with Non Relatives2.2%72.1%6.6%14.3%2.8%2.2%0%10%20%30%40%50%60%70%80%

Section 2: Community Profile 2-22
2021-2029 Housing Element Update - Draft
population. The ACS defines a disability as a report of one of the six disabilities identified by the following questions:
 Hearing Disability: Is this person deaf or does he/she have serious difficulty hearing?  Visual Disability: Is this person blind or do they have serious difficulty seeing even when wearing glasses?
 Cognitive Difficulty: Because of a physical, mental, or emotional condition, does this person have serious difficulty concentrating, remembering, or making decisions?  Ambulatory Difficulty: Does this person have serious difficulty walking or climbing stairs?  Independent Living Difficulty: Because of a physical, mental, or emotional condition, does this person have difficulty doing errands alone such as visiting a doctor’s office or shopping? According to the 2019 ACS, about eight percent of Orange’s population reported a disability. Of that eight percent, ambulatory difficulty represented the highest at 48.9 percent of persons reporting a disability (Table 2-20). 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.

Table 2-20 also shows that persons age 65 or over had the highest percentage of disabilities.

Table 2-20: Disability Status
Disability Type
Under age
18 with a
Disability
Ages 18 to
64 with a
Disability
65 years
and Over
with a
Disability
Total
Percent of
Population
with
Disability
Percent of
Total
Population
Population
with a Hearing
Difficulty
182 985 1,999 3,166 28.9% 2.30%
Population
with a Vision
Difficulty
95 717 722 1,534 14.0% 1.10%
Population
with a
Cognitive
Difficulty
526 2,323 1,437 4,286 39.1% 4.20%
Population
with an
Ambulatory
Difficulty
204 1,926 3,236 5,366 48.9% 4.20%
Population
with a Self-care
Difficulty
293 864 1,633 2,790 25.4% 2%
Population
with an
independent
Living Difficulty
-- 1,811 2,399 4,210 38.4% 4.00%
Total 718 5,237 5,019 10,974* -- 8%
Source: American Community Survey, 5-Year Estimates, 2019. *This number may not reflect persons who have more than one reported disability.

Section 2: Community Profile 2-23
2021-2029 Housing Element Update - Draft
State law requires Housing Elements discuss housing needs for persons with developmental disabilities. As defined by federal law, a “developmental disability” means severe, chronic disability in an individual that:
 Is attributable to a mental or physical impairment or combination of mental and physical impairments;
 Is manifested before the individual attains age 22;
 Is likely to continue indefinitely;
 Results in substantial functional limitations in three or more of the following areas of major life activity: a) self-care; b) receptive and expressive language; c) learning; d) mobility; e) self-direction; f) capacity for independent living; or g) economic self- sufficiency; and  Reflects the individual’s need for a combination and sequence of special, interdisciplinary, or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated.

According to the U.S. Administration on Developmental Disabilities, an accepted estimate of the percentage of the population that can be defined as developmentally disabled is 1.5 percent. This equates to 2,104 persons in the City of Orange with developmental disabilities, based on the 2017 America Community Survey.

Per Section 4512 of the Welfare and Institutions Code a "developmental disability" means a disability that originates before an individual attains age 18 years, continues, or can be expected to continue, indefinitely, and constitutes a substantial disability for that individual which includes intellectual disability, cerebral palsy, epilepsy, and autism. This term also includes disabling conditions found to be closely related to intellectual disability or to require treatment like that required for individuals with intellectual disability but shall not include other handicapping conditions that are solely physical in nature.

As of November 2019, The State Department of Developmental Services (DDS) provides community-based services to approximately 331,999 persons with developmental disabilities and their families through a statewide system of 21 regional centers, four developmental centers, and two community-based facilities.

According to DDS, for fiscal year 2017 to 2018, the Regional Center for Orange County offered five Home and Community-Based Service centers including, the Anaheim Adult Day Cat Inc., Goodwill of Orange County, Hi Hopes Identity Discovery Foundation, Inc., Mayfair Adult Day Care, and Vocational Visions. As of June 2018, the Orange County Regional Center served 22,352 persons with developmental disabilities.

Sixty-five percent of the persons served by the OCRC were male. Persons from 0-2 years of age compromised 22 percent of OCRC’s clients, 41 percent of persons served were 3-21 years the largest age group served. The majority of the persons served (about 35 percent) were White, about 32 percent reported Hispanic, 15 percent reported Other, 14 percent reported Asian and persons who reported Black, Filipino, Native American and Polynesian each totaled under four percent.

Many people with developmental disabilities live and work independently within conventional housing environments. Individuals with more severe developmental disabilities may require a group living environment where supervision is provided. The most severely affected individuals may require an institutional environment where medical attention and physical therapy are provided. Because developmental disabilities exist before adulthood, the first issue in supportive housing for persons with

Section 2: Community Profile 2-24
2021-2029 Housing Element Update - Draft
developmental disabilities is the transition from the person’s living situation as a child to an appropriate level of independence as an adult.

There are several housing types appropriate for people living with a development disability: rent subsidized homes, licensed and unlicensed single-family homes, inclusionary housing, Section 8 vouchers, special programs for home purchase, HUD housing, and SB 962 (veterans) homes. The design of housing- accessibility modifications, the proximity to services and transit, and the availability of group living opportunities represent some of the types of considerations that are important in serving the needs of this group. Incorporating ‘barrier-free’ design in all, new multi-family housing (as required by California and Federal Fair Housing laws) is especially important to provide the widest range of choices for residents with disabilities. Special consideration should also be given to the affordability of housing, as people with disabilities may be living on a fixed income.

Section 4: Housing Plan of this Housing Element includes Housing Policy Action 4E which establishes the City’s support of persons with developmental disabilities to live in integrated community settings. Housing Policy Action 4F also includes an amendment to the City’s Municipal Code to be compliant with State law as it relates to zoning requirements of residential care facilities serving seven of more persons.

3. 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. It is common for lower income large households to reside in smaller units with an inadequate number of bedrooms. This frequently results in overcrowded conditions and can contribute to faster rates of deterioration.

Availability of large households is a greater challenge for renters, because multi-family rental units are typically physically smaller than single-family ownership units. While apartment complexes offering two and three bedrooms are common, apartments with four or more bedrooms are rare. Large households generally experience overcrowded conditions compared to smaller households. Additionally, throughout the region single-family homes with higher bedroom counts, whether rental or ownership units, are rarely affordable to lower income households.

Table 2-21 displays the American Community Survey’s 2019 data for Large Households broken down by tenure. According to the data large households made up 13.8 percent of all households in the City. Among the large households, five-person households were most common (7.99 percent) and six and seven-person households were both just over five percent. When divided up by tenure, the data shows that renter and owner-occupied large households had similar percentages.

Table 2-21: Large Households (by Tenure)
Household Size Owner Renter Total
Households Percent Households Percent Households Percent 5-Person Household 1,924 4.47% 1,516 3.52% 3,440 7.99%
6-person household 601 1.40% 882 2.05% 1,483 3.44%
7-or-more person
Households 472 1.10% 551 1.28% 1,023 2.37%
Total 2,997 6.96% 2,949 6.85% 5,946 13.80%
Source: American Community Survey, 5-Year Estimates, 2019.

Section 2: Community Profile 2-25
2021-2029 Housing Element Update - Draft
According to the American Community Survey’s 2019 data, there are approximately 21,564 total housing units with 6 or more bedrooms. Large housing units with 6 or more bedrooms represent half of the City’s existing housing stock.

In addition, Section 4: Housing Plan of this Housing Element includes Housing Policy Action 2C which establishes the City’s continued outreach to private and non-profit housing developers to encourage the development of rental and for-sale housing units for larger families.

4. Single-Parent Households
Single-parent households often require special consideration and assistance due to their greater need for affordable and accessible day care, health care, and other supportive services. Many female-headed households with children are susceptible to having lower incomes than similar two-parent households.

Single, female mothers may face social marginalization pressures that can limit their occupational choices and income earning potential, housing options and access to supportive services.

Table 2-22 displays data breakdown of single parent households in Orange. In total, single parent households make up 7.1 percent of total households. Of the single parent households in Orange, 819 were male headed with no spouse present and the remaining 2,234 were female headed with no spouse present.

Overall, nearly a quarter of single parent households were living below the poverty line (22 percent).

Table 2-22: Single Parent Households
Jurisdiction
Single Parent-
Male, No
Spouse Present
Single Parent-
Female, No
Spouse Present
Single Parent
Households
Living in Poverty
Single Parent
Households
Percent of Total
Households
Orange 819 2,234 671 3,053 7.1%
Source: American Community Survey, 5-Year Estimates, 2019.

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

Section 2: Community Profile 2-26
2021-2029 Housing Element Update - Draft

5. 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 United States Department of Agriculture, National Agriculture Statistics provides data on hired farm labor across the United States. The data is compiled at both a State and County level. Within Orange County, a total of 99 farms reportedly hired 1,772 workers in 2017. Permanent workers, those who work 150 days or more, represent the largest category of workers with 1,106 workers (62 percent). A total of 666 workers (38 percent) are considered seasonal and work less than 150 days. Orange County reported 340 migrant workers (19 percent) with full time hired labor in 2017. In addition, the County reported 176 unpaid workers.

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. Because of the low percentage of persons employed in the agriculture and farming industries, the City of Orange does not provide specific housing for this population.

Section 4: Housing Plan of this Housing Element includes Housing Policy Action 4I which will result in an update to the City’s Municipal Code to comply with the provisions for farmworker housing set forth in the Employee Housing Act.

6. Extremely Low-income Households and Poverty Status
The 2013-2017 CHAS data identifies 8,410 low-income households and 4,990 very 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). Table 2-23 below, includes data characterizing affordability and cost burden for various income groups.

According the 2019 ACS, 16,142 persons were reported to be living in poverty, about 12.1 percent of the population. Figure 2-7 below displays the percent on persons living in poverty by race or ethnicity and Hispanic or Latino origin, based on own race/ethnicity. The majority of persons living in poverty in Orange reported Hispanic or Latino (16.2 percent), Two or More Races (15.6 percent), and Some Other Race (13.9 percent). About 12 percent of person who reported White also reported living in poverty, and the Native Hawaiian and Other Pacific Islander population reported under five percent of persons living in poverty.

Section 2: Community Profile 2-27
2021-2029 Housing Element Update - Draft
Table 2-23: Housing Problems for All Households (by Tenure) Income Category Income by Housing
Problem
Owner Households
Household has at
least 1 of 4 Housing
Problems
Household has none
of 4 Housing
Problems
Cost Burden not
available, no
other Housing
Problem
Extremely Low-
Income
Household Income is
less-than or = 30% 1,025 355 190
Very Low-Income
Household Income >30%
to less-than or = 50%
AMI
1,215 800 --
Low-Income
Household Income >50%
to less-than or = 80%
AMI
2,205 1,655 --
Moderate-Income
Household Income >80%
to less-than or = 100%
AMI
1,060 1,300 --
Above Moderate-
Income
Household Income
>100% AMI 1,920 12,560 --
Total 7,420 16,670 190
Income Category Income by Housing
Problem
Renter Households
Household has at
least 1 of 4 Housing
Problems
Household has none
of 4 Housing
Problems
Cost Burden not
available, no
other Housing
Problem
Extremely Low-
Income
Household Income is
less-than or = 30% 3,355 305 260
Very Low-Income
Household Income >30%
to less-than or = 50%
AMI
2,695 280 --
Low-Income
Household Income >50%
to less-than or = 80%
AMI
3,220 1,330 --
Moderate-Income
Household Income >80%
to less-than or = 100%
AMI
775 1,520 --
Above Moderate-
Income
Household Income
>100% AMI 680 3,930 --
Total 10,720 7,365 260
Total Households (Owner and Renter) 18,140 24,035 450
Source: Source: U.S. Department of Housing and Urban Development (HUD), Comprehensive Housing Affordability Strategy (CHAS) 2013-2017.
* The four housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1 person per room, and cost burden greater than 30%.
** The four severe housing problems are: incomplete kitchen facilities, incomplete plumbing facilities, more than 1.5 persons per room, and cost burden greater than 50%.

Note: AMI = Area Median Income, this is the median family income calculated by HUD for each jurisdiction, to determine Fair Market Rents (FMRs) and income limits for HUD programs. AMI will not necessarily be the same as other calculations of median incomes (such as a simple Census number), due to a series of adjustments that are made.

Section 2: Community Profile 2-28
2021-2029 Housing Element Update - Draft
Figure 2-7: Percent below Poverty Level, by Race and Hispanic or Latino Origin

Source: American Community Survey, 5-Year Estimates, 2019.

Note: The chart reports percentage of own population who are reported to have incomes below poverty level.

The City currently has 34 total affordable housing developments, as detailed in Table 3-33b. This includes 1,524 deed-restricted affordable units ranging from studios to three-bedroom units available for lower- income households, seniors, and workforce housing. This Housing Element’s Section 4: Housing Plan includes a number of Housing Policy Actions which promote the development of affordable housing units throughout the City as well as resources for households in need.

7. Persons Experiencing Homelessness
Throughout the country and Orange County region, homelessness has become an increasingly important issue. Factors contributing to the rise in homelessness include, increased unemployment and underemployment, a lack of housing affordable to lower and moderate-income persons (especially extremely low-income households), reductions in public subsidies to the poor, and the de- institutionalization of the mentally ill.

State law mandates that municipalities address the special needs of homeless persons within their city’s boundaries. The following provides an updated description and new changes for “homelessness” as defined by the U.S. Department of Housing and Urban Development (HUD):
 People who are living in a place not meant for human habitation, in emergency shelter, in transitional housing, or are exiting an institution where they temporarily resided. The only significant change from existing practice is that people are now considered homeless if they are exiting an institution where they resided for up to 90 days (it was previously 30 days) and are in shelter or a place not meant for human habitation immediately prior to entering that institution.

12.3%9.1%6.8%9.8%4.3%13.9%15.6%16.2%0%2%4%6%8%10%12%14%16%18% White Black AmericanIndian andAlaska Native Asian NativeHawaiian andOther PacificIslander Some OtherRace Two or MoreRaces Hispanic orLatino

Section 2: Community Profile 2-29
2021-2029 Housing Element Update - Draft
 People who are losing their primary nighttime residence, which may include a motel or hotel or a doubled-up situation, within 14 days and lack resources or support networks to remain in housing.

HUD had previously allowed people who were being displaced within 7 days to be considered homeless. The proposed regulation also describes specific documentation requirements for this category.
 Families with children or unaccompanied youth who are unstably housed and likely to continue in that state. This is a new category of homelessness, and it applies to families with children or unaccompanied youth who have not had a lease or ownership interest in a housing unit in the last 60 or more days, have had two or more moves in the last 60 days, and who are likely to continue to be unstably housed because of disability or multiple barriers to employment.  People who are fleeing or attempting to flee domestic violence, have no other residence, and lack the resources or support networks to obtain other permanent housing. This category is similar to the current practice regarding people who are fleeing domestic violence.

This definition does not include persons living in substandard housing (unless it has been officially condemned); persons living in overcrowded housing (for example, doubled up with others); persons being discharged from mental health facilities (unless the person was homeless when entering and is considered to be homeless at discharge); or persons who may be at risk of homelessness (for example, living temporarily with family or friends.)
The Point in Time Count is conducted by the County of Orange in accordance with the U.S. Department of Housing and Urban Development guidelines. The count provides information on where homeless individuals are in the County. Over 1,000 volunteers across the County counted 6,860 individuals experiencing homelessness; of those, 2,899 were sheltered and 3,961 were unsheltered. The 2019 Count was conducted in April of 2019 and individual city results are shown in Table 2-24a. Santa Ana had the largest homeless population of the North Orange County cities and about 20 percent more than the City of Orange. Orange’s homeless population totaled 341 and five percent of the County’s total homeless population count. According to the Point in Time Count results, Orange County saw a 121 percent increase in the number of emergency shelter beds from 2017 to 2019, an increase in 1,390 beds in total.

Additionally, Table 2-24b shows the 2022 Count results – including a reduction of persons experiencing homelessness of about 27 percent since 2019 (a reduction of 91 persons experiencing homelessness). In comparison, the County as a whole also saw a decrease by about 17 percent (1,142 persons).

According to the County’s Point in Time Count, persons experiencing homelessness included 110 unsheltered families (152 adults and 244 children). Approximately half of families experiencing homelessness became unsheltered for the first time during the past 12 months and over 60 percent were living in a vehicle. A total of 275 transitional age youth were counted as experiencing homelessness countywide and about half identified as Hispanic or Latino. Approximately 12 percent of transitional age youth experiencing homelessness are chronically homeless compared to just under half of all adults experiencing homelessness. A total of 612 seniors and 311 veterans were counted countywide. Black or African American individuals and families represent just 2 percent of the County’s population, according to the U.S. Census Bureau; however, Black or African American individuals and families represented 8.41 percent of unsheltered homelessness and 15 percent of sheltered homelessness. Hispanic or Latino families

Section 2: Community Profile 2-30
2021-2029 Housing Element Update - Draft
were also overrepresented in the count and represented 57 percent of unsheltered homelessness and 49.8 percent of sheltered homelessness in the County.

Table 2-24a: Homeless Count by Jurisdiction (2019)
Jurisdiction Unsheltered Sheltered Total % of County
Anaheim 694 508 1,202 17.5%
Fullerton 308 165 472 6.8%
Yorba Linda 1 0 1 0.01%
Orange 193 148 341 5.0%
Santa Ana 830 939 1,769 25.8%
Garden Grove 163 62 225 3.3%
County of Orange 3,961 2,899 6,860 100%
Source: Orange County Point in Time Count, Everyone Counts Report 2019.

Table 2-24b: Homeless Count by Jurisdiction (2022)
Jurisdiction Unsheltered Sheltered Total % of County % Change 2019-2022
Anaheim 485 589 1,074 18.8% -10.6%
Fullerton 202 70 272 4.8% -42.4%
Yorba Linda 4 0 4 0.1% 300.0%
Orange 134 116 250 4.4% -26.7%
Santa Ana 508 482 990 17.3% -44.0%
Garden Grove 278 113 391 6.8% 73.8%
County of Orange 3,057 2,661 5,718 100.0% -16.6%
Source: Orange County Point in Time Count, Everyone Counts Report 2022.

Partnerships and Initiatives
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

Section 2: Community Profile 2-31
2021-2029 Housing Element Update - Draft
assists in providing resources and assistance through collaborations with local community organizations and agencies such as:
 Orange County Homeless Services, Orange County Health Care Agency, Orange County Shelter Programs - The County of Orange coordinates a comprehensive regional Continuum of Care (CoC) strategy that includes the participation of all thirty-four cities in Orange County, County Agencies, the County’s homeless housing and service providers, and other community groups (including non- profits, local governmental agencies, faith-based organizations, the homeless and formerly homeless, interested business leaders, schools, and many other stakeholders) to identify the gaps and unmet needs of the County’s homeless. In addition to organizing, delivering and reporting on housing and services for people who are experiencing homelessness, CoCs are required to complete a Point-In-Time (PIT) count of unsheltered homeless at least once every two years & sheltered annually during the last ten days in January. Data from the one-night PIT count and the longitudinal data collected by the Homeless Management Information System (HMIS) are the primary sources used to measure the progress in meeting the national strategic goal of preventing and ending homelessness. The County also contracts to operate shelter programs in the County, including Bridges at Kraemer Place, Cold Weather Shelter in Santa Ana, and Yale Navigation Center.  Food Pantries by Waste Not OC – Second Harvest Food Bank of Orange County and Community Action Partnership of Orange County Food Bank collect food and distribute it to those in need throughout the community.
 Lutheran Social Services - Located in the city of Fullerton, LSS Orange County, serves more than 200 families and individuals per month with emergency and social services. LSS Orange County offers a weekly food pantry and senior grocery program, clothing, hygiene packs, emergency vouchers for hotel, bus, gas and utilities motel/hotel vouchers. Clients are able to receive housing assistance, in depth case management and ongoing support while they navigate to a more stable situation. They also provide specialized counseling and supportive services for women that have been victims of crime.
 Homeless Intervention Services of OC (HIS-OC) – HIS-OC runs four programs that assist people who are homeless or at risk of being homeless – 1) Transitional housing program, 2) Combining Housing Education and Skills for Students (CHESS) Program, 3) Home Share OC, 4) Housing Connection Program.
 Pathways of Hope Food Pantry - Pathways of Hope leads community efforts to end homelessness in North Orange County. Through different types of housing programs – including shelter, rapid re- housing, permanent supportive housing, and prevention – the agency assists in addressing homelessness for hundreds of community members and neighbors in need each year.  Saint Andrew’s Episcopal Church – Saint Andrew’s provides a range of community services such as - free dinner every Friday night to over 100 people, offering Friday dinner guests with the opportunity to select clean clothes, collecting canned food for the Pathways of Hope food pantry, providing foster children at Orangewood Children’s Home with jeans, blankets, and toiletries, providing diapers, pajamas, and other essential needs for homeless families served by Project Hope, maintaining an urban garden for three local food banks, and assisting women seeking refuge from abusive relationships.
 Seventh Day Adventist Church – Providing food bags, clothing, small appliances, and toiletries.  The Storehouse – Providing hot meals and Thursday evenings and a food pantry weekly.

Section 2: Community Profile 2-32
2021-2029 Housing Element Update - Draft
 Southlands Church – Southlands distributes food to families in need on the last Saturday of even months.
 Christ Cathedral – Providing kitchen and food pantries.  Southwest Community Center - Providing the basic needs of food, clothing, shelter, household items, referral services and other support services to the homeless, low-income, and economically disadvantaged in an effort to enable them to become or retain self-sufficiency.  Someone Care Soup Kitchen - Providing a daily nutritional meal to homeless, unemployed, working poor families, senior citizens, the unemployed or under-employed, the mentally and physically challenged and children. The Soup Kitchen provides meals seven days per week at the facility in Orange County.
 Welcome Home Ministry - WelcomeHomeOC is the ﬁrst housing assistance program tailored to Orange County property owners as well as qualified families, Veterans, foster youth, and seniors in need of permanent housing. Every aspect of this program to end homelessness provides greater ease and control, while treating landlords as equal partners and maximizing opportunities for all.  We Care of Los Alamitos - WE CARE is a non-profit organization that pools the resources of the community to meet the emergency needs of families and individuals such as rental assistance, utility assistance, therapy services, food, personal care items, and more. WE CARE of Los Alamitos is a family support center sponsored by local churches, community groups, corporations and concerned citizens.

The HUB OC
The City had previously relied on Mary’s Kitchen to provide food, resources, showers, laundry, and other resources for persons experiencing homelessness. The City ended its license agreement with the nonprofit in 2021 due to rising crime and safety concerns. To replace the soup kitchen, as of June 2022, the City set up a new hub of homelessness services which was mandated by a federal judge in May 2022 through May 2023. “The HUB OC” oversees continuum of care services on behalf of the City of Orange and manages rental facilities including laundry machines, portable showers, hand washing stations, and portable restrooms to help with personal hygiene – in an effort to reduce the transmission of COVID-19. The HUB OC manages the recruiting, training, and mobilizing the team of volunteers from local churches and the community to help meet the needs of homeless residents in partnership with the City of Orange, the HEART team, and LOVE Orange. A summary of services provided by the HUB OC is listed below:
 Provide initial contact with homeless individuals for intake information;  Coordinate with the HEART team for entry into Coordinated Entry System (CES) and Homeless Management Information System (HMIS);
 Coordinate efforts with local non-profits to recruit volunteers;  Provide training to volunteers as listed below:
o Manage and provide homeless individuals with referrals to shelters o Distribute hygiene supplies to homeless individuals
o Manage the on-site hygiene resources that include laundry, showers, wash stations, and restrooms
o Manage and provide homeless individuals with access to phone charging stations o Provide homeless individuals with referrals to mental, medical, vision, dental, and health care services;

Section 2: Community Profile 2-33
2021-2029 Housing Element Update - Draft
o Provide homeless individuals with referrals to veterinary care services o Provide homeless individuals with referrals to COVID-19 vaccines o Provide homeless individuals with referrals to clothes providers including resources from Full Circle
o Provide homeless individuals with voucher assistance and referrals to bus or other modes of transportation
o Provide the children of homeless individuals with referrals to free after school care through the Youth Centers of Orange
The goal of the HRC in the long run is to continue to offer the same services it does now, but adjust meals to a more nutritional, medical, and supplemental based service. Current services such as showers and laundry will continue to be offered and will encourage the clients to attend a class, workshop, or other empowering services offered at the site through one of its partners or volunteers. Currently, the HUB OC has over 40 partners and is continuously seeking out additional partners to expand services and resources for the homeless community at no additional cost. The HUB OC develops it partnerships by reaching out to schools, non-profits, and local businesses and donors directly and sharing the mission and vision of the HRC with the goal of receiving continuous or one-time financial or in-kind donations. Partnerships are also developed through word of mouth from volunteers and current partner organizations already providing services at the site. If the outreach results in a long-term partnership, the HUB OC will create agreements for the service or donation to be provided at no-cost at the HRC, including those services already being offered.

The HRC has already started to secure partnerships for the classes, workshops, and other empowering services it will offer at the site in the long-term. Examples include:
 Work Program focused on creating healthy work ethics and facilitating project participation throughout the City to develop workforce skills;
 Classes on health care for individuals living on the streets by nurses from local state university.  Support classes for mothers including lactation and birthing that will also offer essential items that can be purchased using EBT and WIC onsite;
 Resume building and application assistance by professionals and volunteers in our community;  Drug and addiction programs through Celebrate Recovery/AA that offers video and workbook curriculum, sponsors, and success chips;
 Men’s and Women's support groups for holistic well-being;  Associate Degree Program through a local college that clients will be able to complete at the HRC through the use of donated computers;
 Nutritional courses by a food scientist;
 Outreach courses for volunteers and local businesses wanting to understand the difficulties of the homeless population and discover ways in which they can help.

Investments
The City is amending the 2019 Action Plan to appropriate $1,108,070 in Community Development Block Grant funds from the Coronavirus Aid, Relief, and Economic Security Act for the Homeless Outreach Program. The Homeless Outreach Program will conduct outreach to the homeless population in Orange

Section 2: Community Profile 2-34
2021-2029 Housing Element Update - Draft
and refer them to homeless-related services including case management and housing navigation centers.

The program will complement the homeless outreach efforts undertaken by the HEART and Bike Teams.

Section 4: Housing Plan of this Housing Element includes Housing Policy Action 4B establishing the City’s continued support of local and inter-jurisdictional efforts to reduce temporary and chronic homelessness.

Additionally, the City plans to distribute HOME-ARP funds in accordance with the priority needs identified in its need assessment and gap analysis. Consistent with the needs of the homeless community, the City will distribute approximately 95% of the funds to The HUB OC to serve the needs of the homeless on a reimbursement basis. The balance of the funds (5%) will be used for administration purposes.

The City will enter into a new subrecipient agreement with the HUB OC to fund its operation until the funds are fully exhausted. In order to more efficiently and effectively provide services, the HRC will move from its temporary location on the sidewalk of Struck Avenue to the site of where the previous homeless service provider was located. The City will be relocating a mobile office unit to the newly renovated site that will provide continuum of care providers space to meet with clients and allow for more privacy, a need expressed by service providers at the HRC.

Once the HOME-ARP funds are exhausted, the HRC is planning to modify the current operations of the site as part of the long-term plan to avoid interruption in services and reduce operational costs. The HUB endeavors to work strategically with partners in the local and global communities and organizations to provide services free of charge and is working to acquire donations for resources. Additionally, partnerships are being developed in order to offer classes and workshops at the site to help clients towards long term employment and housing stability. The HUB and the City will work collaboratively to seek grant funding to continue the ongoing operation of the facility.

8. Students
There are multiple colleges and universities located in and around the City of Orange, including Chapman University, California State University Fullerton, and Santiago Canyon College. According to the 2019 ACS,

38.8 percent of Orange’s population was enrolled in college or graduate school. Of those between ages 18 and 24 enrolled in a college program, 66 percent are female. Housing may be provided on campus, but students often seek alternate housing options within the same City. Considering the number of students enrolled in school – over 10,000 at Chapman University – students contribute an important segment of the population. Students can be low-income and may be affected by a lack of affordable housing options, especially within easy commuting distances from campus. Students may seek shared housing situations to lower expenses contributing to overcrowding. The access to affordable housing may influence a student’s choice to stay or leave after graduating, which can in turn affect the region’s economy. College students offer specialized skills that contribute to the health of the local economy. A lack of affordable housing may contribute to their departure and the City’s loss of additional participation in the labor force.

Section 4: Housing Plan of this Housing Element includes Housing Policy Action 2I establishing the City coordination with Chapman University to respond to housing needs of students in the City and encouraging the development of on-campus housing.

Section 2: Community Profile 2-35
2021-2029 Housing Element Update - Draft
F. Housing Stock Characteristics
Housing needs for a community are determined by characteristics of the housing stock, including growth, type, availability and tenure, age and condition, housing costs, and affordability. This section details the housing stock characteristics of Orange and identifies how the current housing stock meets the needs of its current and future residents.

1. Housing Growth
According to the 2010, 2015, and 2019 ACS, the Orange housing stock grew from 44,217 to 44,229 (Table 2-25). The ACS data provides estimates based on the U.S. Census and surveys and may therefore not reflect the exact unit count of jurisdictions. Through 2019, Orange’s housing grew by about 1 percent. The County of Orange grew 5.5 percent between 2010 and 2019; 4 percent more than the City of Orange. The housing stock growth for Orange from 2010 to 2019 is comparable to surrounding cities, except for Yorba Linda and Garden Grove, where most experienced an increase of about 1 percent. Yorba Linda experienced the largest housing unit increase at 8.1 percent and Orange experienced the lowest growth.

Table 2-25: Housing Unit Growth Trends by Jurisdiction, 2010-2019 Jurisdiction 2010 2015 2019
Percent
Change 2010
to 2015
Percent
Change 2015
to 2019
Anaheim 105,050 104,812 106,708 -0.23% 1.81%
Fullerton 47,956 47,319 48,120 -1.33% 1.69%
Yorba Linda 21,665 22,592 23,452 4.28% 3.81%
Orange 44,217 44,229 44,664 0.03% 0.98%
Santa Ana 77,796 77,192 79,024 -0.78% 2.37%
Garden Grove 47,454 48,385 49,061 1.96% 1.40%
County of Orange 1,042,254 1,064,642 1,100,449 2.15% 3.36% Source: American Community Survey, 5-Year Estimate, 2010, 2015, 2019.

2. Housing Type
Table 2-26 provides of the Orange housing stock by type in comparison to the County of Orange. Per the 2019 ACS, single-family detached housing units are the most common type of housing in both the City of Orange and the County (54.9 percent and 50.6 percent, respectively). Multi-family housing units made up

33.1 percent of units in the City and just over 34 percent in the County. Additionally, mobile homes made up under three percent of housing units in both the City and the County.

Table 2-26: Total Housing Units by Type
Jurisdiction Single- Family
Detached
Single-Family
Attached Multi-Family Mobile
Homes Total Units1
Orange 54.9% 9.6% 33.1% 2.4% 44,664
County of
Orange 50.6% 12.3% 34.3% 2.7% 1,100,449
Source: American Community Survey, 5-Year Estimates, 2019. 1Note: The data shows the percent of total units in structure.

Section 2: Community Profile 2-36
2021-2029 Housing Element Update - Draft

3. Housing Availability and Tenure
Housing tenure and vacancy rates generally influence the supply and cost of housing. Housing tenure defines if a unit is owner-occupied or renter occupied. The tenure characteristics in a community can indicate affordability, household stability, and availability of unit types. Tenure distribution may correlate with household income, composition, and age of the householder.

In 2019, Orange’s occupied housing included a higher percentage of renter occupied units at 55.8 percent.

The majority of owners resided in single-family detached units, whereas the majority of renters resided in multi-family units. Just 6.9 percent of multi-family homes were occupied by owners and about 21 percent single family units were occupied by renters. Mobile homes were more likely to be occupied by owners (2.9 percent) whereas 2 percent were occupied by renters.

Table 2-27: Occupied Housing Units by Type and Tenure
Tenure
Single-
Family
Detached
Single-
Family
Attached
Multi-
Family
Mobile
Homes
Total
Occupied
Units1
Owner
Occupied 80.1% 10.0% 6.9% 2.9% 24,939
Renter
Occupied 21.1% 9.1% 67.9% 2.0% 18,136
Total 54.9% 9.6% 33.1% 2.4% 44,664
Source: American Community Survey, 5-Year Estimates, 2019. 1Note: The data shows the percent of total occupied units.

A shown in Table 2-28, owner-occupied households and renter-occupied households were about the same average size, a common trend in nearby cities. Owner-occupied households in Orange had a slightly smaller household size than renters (3 and 3.2, respectively). Overall, in the County of Orange, owner households were smaller than renter households. Of the nearby cities, the average household sizes stayed below 3.6 persons, with the exception of Santa Ana where the average household size was 4.3 persons.

Table 2-28: Average Household Size by Tenure
Jurisdiction Owner Occupied
Household Size
Renter Occupied
Household Size
Average
Household Size
Anaheim 3.38 3.41 3.39
Fullerton 2.93 3.02 2.97
Yorba Linda 3.02 2.78 2.98
Orange 3 3.18 3.08
Santa Ana 4.25 4.32 4.28
Garden Grove 3.57 3.6 3.58
County of Orange 2.98 3.05 3.01
Source: American Community Survey, 5-Year Estimates, 2019.

Vacancy rates indicate the degree of available choice. High vacancy rates usually indicate low demand and/or high supply conditions in the housing market. Too high of a vacancy rate can be difficult for owners trying to sell or rent. Low vacancy rates usually indicate high demand and/or low supply conditions in the

Section 2: Community Profile 2-37
2021-2029 Housing Element Update - Draft
housing market. Too low of a vacancy rate can force prices up and make it more difficult for lower and moderate-income households to find housing. Vacancy rates of between two to three percent are usually considered healthy for single-family or ownership housing, and rates of five to six percent are usually considered healthy for multi-family or rental housing.

The data displayed in Figure 2-8 shows that Orange has a vacancy rate of 3.6 percent, a generally healthy rate and comparable to many surrounding communities. Orange’s vacancy rate is lower than the County’s rate by 2.1 percent.

Figure 2-8: Vacant Rate by Jurisdiction

Source: American Community Survey, 5-Year Estimates, 2019.

Table 2-30 below displays a breakdown of vacancy types for units in Orange. Units currently available for rent have the highest vacancy count at 673 units. In 2019 there were 117 rented but unoccupied units and 94 sold but unoccupied units. There were zero units available for migrant workers and 226 units available for sale in 2019.

Table 2-30: Vacant Housing Units by Type
Type of Housing Estimate Percent
For rent 673 42.4%
Rented, not occupied 117 7.4%
For sale only 226 14.2%
Sold, not occupied 94 5.9%
For seasonal, recreational or occasional use 77 4.8%
For migrant workers 0 0.0%
Other vacant 402 25.3%
Total 1,589 100%
Source: American Community Survey, 5-Year Estimates, 2019.

OrangeCountyAnaheim FullertonGardenGroveOrange Santa Ana Yorba LindaVacancy Rate5.7% 4.7% 4.8% 2.6% 3.6% 3.0% 3.4%0.0%1.0%2.0%3.0%4.0%5.0%6.0%

Section 2: Community Profile 2-38
2021-2029 Housing Element Update - Draft

4. Housing Age and Condition
Housing age can be an indicator of housing condition within a community. For example, housing that is over 30 years old is typically in need of some major rehabilitation, such as a new roof, foundation, plumbing, etc. Many federal and state programs also use the age of housing as one factor in determining housing rehabilitation needs.

According to the data displayed in Figure 2-9, there was a housing stock boom from 1960 to 1979 that resulted in the creation of 47 percent of Orange’s housing units. Between 1950 and 1959, a smaller number of homes were built (14.6 percent) and another 11.6 percent from 1980 to 1989. Overall, a large percentage of homes were built during the mid to late 20th century. Only about 9.5 percent units in Orange were built after 2000 and one percent in 2014 or later. A large proportion of older housing could indicate that most of the City’s housing stock could require major rehabilitation. This proportion may also be a reflection of the large number of units which are located in the City’s four historic districts. These units were built prior to 1940 and up until the 1960s. Historic structures are protected and maintained and would not fall into the category of older units needing rehabilitation.

Figure 2-9: Housing Stock Age

Source: American Community Survey, 5-Year Estimates, 2019.

5. Housing Costs and Affordability
Housing costs reflect the supply and demand of housing in a community. This section summarizes the cost and affordability of the housing stock to the City of Orange’s residents.

Table 2-31 show the median home value in Orange was $665,000 in 2019. Homes in Orange were comparable to the median cost of a home in the County and were less expensive than homes in Yorba Linda ($878,800) or the County as a whole ($694,200). Homes in the City of Orange were valued slightly higher than homes in Santa, Anaheim and Garden Grove.

Built 1939or earlierBuilt 1940to 1949Built 1950to 1959Built 1960to 1969Built 1970to 1979Built 1980to 1989Built 1990to 1999Built 2000to 2009Built 2010to 2013Built 2014or laterOrange5.5% 1.8% 14.6% 24.2% 22.9% 11.6% 9.9% 7.1% 1.3% 1.1%0%5%10%15%20%25%30%

Section 2: Community Profile 2-39
2021-2029 Housing Element Update - Draft
Table 2-31: Median Home Value by Community
Jurisdiction Median Home Value
Anaheim $583,700
Fullerton $660,300
Yorba Linda $878,800
Orange $665,000
Santa Ana $501,400
Garden Grove $561,600
County of Orange $694,200
Source: American Community Survey, 5-Year Estimates, 2019.

Table 2-32 shows that between 2017 and 2020 rent for a one-bedroom unit in Orange increased by 4.8 percent from $1,819 to $1,906. Two-bedroom rentals saw the highest percent change from 2017 to 2020 at five percent and 3-bedroom units experienced a 3.5 percent increase in cost. There is no data available for 4-bedroom rentals in 2020, but from 2017 to 2019 the cost of rent increased by 2.9 percent.

Table 2-32: Average Monthly Rental Rates, 2017-2020
Unit Type
January 2017
Average
Monthly Rent
January 2018
Average
Rent/Sq. Foot
January 2019
Average
Monthly Rent
January 2020
Average
Monthly Rent
Percent Change
from 2017 to
2020
1 Bedroom $1,819 $1,919 $1,941 $1,906 4.8%
2 bedrooms $2,237 $2,279 $2,321 $2,349 5.0%
3 Bedrooms $2,722 $2,738 $2,767 $2,816 3.5%
4+ Bedrooms $2,943 $2,989 $3,000 -- 2.9%*
Source: Zillow, Orange Rentals Zillow Rent Index, accessed May 2020. *Percent Change from 2019 to 2019, 2020 rental data not available.

Housing affordability can be inferred by comparing the cost of renting or owning a home in the City with the maximum affordable housing costs for households at different income levels. Taken together, this information can generally show who can afford what size and type of housing, as well as indicate the type of households most likely to experience overcrowding and overpayment.

HUD conducts annual household income surveys nationwide to determine a household’s eligibility for federal housing assistance. Based on this survey, HCD developed income limits using on the AMI to determine the maximum affordable price by households in the upper range of their respective income category. Households in the lower end of each category can afford less by comparison than those at the upper end. The maximum affordable home and rental prices for residents in Orange County are shown in Table 2-33 and Table 2-34.

The data shows the maximum amount that a household can pay for housing each month without incurring a cost burden (overpayment). This amount can be compared to current housing asking prices (Table 2-31) and market rental rates (Table 2-32) to determine what types of housing opportunities a household can afford.

Section 2: Community Profile 2-40
2021-2029 Housing Element Update - Draft
Extremely Low-income Households
Extremely low-income households earn less than 30 percent of the County AMI – up to $26,950 for a one- person household and up to $41,550 for a five-person household in 2020. Extremely low-income households cannot afford market-rate rental or ownership housing in Orange without assuming a substantial cost burden.

Very Low-income Households
Very low-income households earn between 31 percent and 50 percent of the County AMI – up to $44,580 for a one-person household and up to $69,200 for a five-person household in 2020. A very low-income household can generally afford homes priced between $183,000 and $259,000, adjusting for household size. A very low-income household at the maximum income limit can afford to pay approximately $1,121 to $1,730 in monthly rent, depending on household size. Given the high cost of housing in Orange, persons or households of very low-income could not afford to rent or purchase a home in the City.

Low-income Households
Low-income households earn between 51 percent and 80 percent of the County’s AMI - up to $71,750 for a one-person household and up to $110,650 for a five-person household in 2020. The affordable home price for a low-income household at the maximum income limit ranges from $308,500 to $452,000.

Ownership housing would not be affordable to low-income households. A one-person low-income household could afford to pay up to $1,794 in rent per month and a five-person low-income household could afford to pay as much as $2,766. Low-income households in Orange would not be able to find adequately sized affordable apartment units (Table 32).

Moderate income Households
Persons and households of moderate income earn between 81 percent and 120 percent of the County’s AMI – up to $133,500, depending on household size in 2020. The maximum affordable home price for a moderate-income household is $377,000 for a one-person household and $558,600 for a five-person family. Moderate income households in Orange would not be able to purchase a home in the City. The maximum affordable rent payment for moderate income households is between $2,163 and $3,338 per month. Appropriately sized market-rate rental housing is generally affordable to households in this income group.

Section 2: Community Profile 2-41
2021-2029 Housing Element Update - Draft
Table 2-33: Affordable Monthly Housing Cost for Renters in Orange County, 2020 Annual Income Rent Utilities
Total Affordable
Monthly Housing
Cost
Extremely Low-Income (30% of AMI)
1-Person $26,950 $556 $118.00 $674
2-Person $30,800 $619 $151.00 $770
3-Person $34,650 $669 $197.00 $866
4-Person $38,450 $718 $243.00 $961
5-Person $41,550 $750 $289.00 $1,039
Very Low-Income (50% of AMI)
1-Person $44,850 $1,003 $118.00 $1,121
2-Person $51,250 $1,130 $151.00 $1,281
3-Person $57,650 $1,244 $197.00 $1,441
4-Person $64,050 $1,358 $243.00 $1,601
5-Person $69,200 $1,441 $289.00 $1,730
Low-Income (80% AMI)
1-Person $71,750 $1,676 $118.00 $1,794
2-Person $82,000 $1,899 $151.00 $2,050
3-Person $92,250 $2,109 $197.00 $2,306
4-Person $102,450 $2,318 $243.00 $2,561
5-Person $110,650 $2,477 $289.00 $2,766
Moderate-Income (120% AMI)
1-Person $86,500 $2,045 $118.00 $2,163
2-Person $98,900 $2,322 $151.00 $2,473
3-Person $111,250 $2,584 $197.00 $2,781
4-Person $123,600 $2,847 $243.00 $3,090
5-Person $133,500 $3,049 $289.00 $3,338
Source: Orange County Housing Authority, 2020 Utility Allowance Schedule and California Department of Housing and Community Development, 2020 Income Limits and Kimley Horn and Associates Assumptions: 2020 HCD income limits; 30% gross household income as affordable housing cost; 15% of monthly affordable cost for taxes and insurance; 10% down payment; and 4.5% interest rate for a 30- year fixed-rate mortgage loan. Utilities based on Orange County Utility Allowance.

1. Utilities includes basic electric, water, sewer/trash, refrigerator, and stove.

Section 2: Community Profile 2-42
2021-2029 Housing Element Update - Draft
Table 2-34: Affordable Monthly Housing Cost for Homeowners in Orange County, 2020 Annual Income Mortgage Utilities Tax and
Insurance
Total
Affordable
Monthly
Housing Cost
Affordable
Purchase Price
Extremely Low-Income (30% of AMI)
1-Person $26,950 $455 $118 $101 $674 $99,990
2-Person $30,800 $504 $151 $116 $770 $110,500
3-Person $34,650 $539 $197 $130 $866 $118,000
4-Person $38,450 $574 $243 $144 $961 $125,800
5-Person $41,550 $594 $289 $156 $1,039 $130,200
Very Low-Income (50% of AMI)
1-Person $44,850 $835 $118 $168 $1,121 $183,000
2-Person $51,250 $938 $151 $192 $1,281 $205,500
3-Person $57,650 $1,028 $197 $216 $1,441 $225,400 4-Person $64,050 $1,118 $243 $240 $1,601 $245,000 5-Person $69,200 $1,182 $289 $260 $1,730 $259,000 Low-Income (80% AMI)
1-Person $71,750 $1,407 $118 $269 $1,794 $308,500 2-Person $82,000 $1,592 $151 $308 $2,050 $349,100 3-Person $92,250 $1,763 $197 $346 $2,306 $386,500 4-Person $102,450 $1,934 $243 $384 $2,561 $424,000 5-Person $110,650 $2,062 $289 $415 $2,766 $452,000 Moderate-Income (120% AMI)
1-Person $86,500 $1,720 $118 $324 $2,163 $377,000 2-Person $98,900 $1,951 $151 $371 $2,473 $427,800 3-Person $111,250 $2,167 $197 $417 $2,781 $475,000 4-Person $123,600 $2,384 $243 $464 $3,090 $522,700 5-Person $133,500 $2,548 $289 $501 $3,338 $558,600 Source: Orange County Housing Authority, 2020 Utility Allowance Schedule and California Department of Housing and Community Development, 2020 Income Limits and Kimley Horn and Associates Assumptions: 2020 HCD income limits; 30% gross household income as affordable housing cost; 15% of monthly affordable cost for taxes and insurance; 10% down payment; and

4.5% interest rate for a 30-year fixed-rate mortgage loan. Utilities based on Orange County Utility Allowance.

1. Utilities includes basic electric, water, sewer/trash, refrigerator, and stove.

Section 3: Housing Constraints, Resources, and Fair Housing 3-1 2021-2029 Housing Element Update - Draft
Section 3: Housing Constraints, Resources,
and Fair Housing

Section 3: Housing Constraints, Resources, and Fair Housing 3-2 2021-2029 Housing Element Update – Draft
Housing Constraints
As common in many communities, a variety of constraints affect the provisions and opportunities for adequate housing in the City of Orange. Housing constraints consist of both governmental constraints, including but not limited to development standards and building codes, land use controls, and permitting processes; as well as, nongovernmental or market constraints, including but not limited to land costs, construction costs, and availability of finances. Combined, these factors create barriers to availability and affordability of new housing, especially for lower and moderate-income households.

A. Nongovernmental Constraints
Nongovernmental constraints largely affect the cost of housing in the City of Orange and can produce barriers to housing production and affordability. These constraints include the availability and cost of land for residential development, the demand for housing, financing and lending, construction costs, and the availability of labor, which can make it expensive for developers to build any housing, and especially affordable housing. The following highlights the primary market factors that affect the production of housing in Orange.

Land Costs and Construction Costs
Construction costs vary widely according to the type of development, with multi-family housing generally less expensive to construct than single-family homes. However, there is wide variation within each construction type, depending on the size of the unit and the number and quality of amenities provided.

An indicator of construction costs is Building Valuation Data compiled by the International Code Council (ICC). The ICC provides estimates for the average cost of labor and materials for typical Type VA wood- frame housing. Estimates are based on “good-quality” construction, providing for materials and fixtures well above the minimum required by state and local building codes. In February 2020, the ICC estimated that the average per square-foot cost for good-quality housing was approximately $117.40 for multi- family housing and $130.04 for single-family homes. Construction costs for custom homes and units with extra amenities, run even higher. Although construction costs are a significant portion of the overall development cost, they are consistent throughout the region and, especially when considering land costs, are not considered a major constraint to housing production in Orange.

Land costs can also pose a significant constraint to the development of affordable and middle-income housing and represents a significant cost component in residential development. Land costs may vary depending on whether the site is vacant or has an existing use that must be removed. Similarly, site constraints such as environmental issues (e.g., steep slopes, soil stability, seismic hazards, flooding) can also be factored into the cost of land. A quick May 2020 web search for lots for sale in the City of Orange returned three lots for sale ranging in size from 0.65 acres at $620,000 to 1.14 acres at $790,000. Based current prices of for sale lots, the vacant lots cost an estimated average price per square foot of $21 or an estimated cost of $700,000 for about one acre.

Section 3: Housing Constraints, Resources, and Fair Housing 3-3 2021-2029 Housing Element Update – Draft
Availability of Financing
The availability of financing in a community depends on a number of factors, including the type of lending institutions active in a community, lending practices, rates and fees charged, laws and regulations governing financial institutions, and equal access to such loans. Additionally, availability of financing affects a person’s ability to purchase or improve a home. Under the Home Mortgage Disclosure Act (HMDA), lending institutions are required to disclose information on the disposition of loan applications and the income, gender, and race of loan applicants. The primary concern in a review of lending activity is to determine whether home financing is available to residents of a community. The data presented in this section include the disposition of loan applications submitted to financial institutions for home purchase, home improvement, and refinancing in Orange.

Table 3-1 below displays the disposition of loan applications for the County of Orange, per the 2019 Home Mortgage Discloser Act report from the Consumer Finance Protection Bureau. According to the data, applicants in the 120 percent median income or more had the highest rates of loans approved. Of that category, applicants who reported White had the highest percentage of approval and the number of applications. Applicants in the less than 50 percent of the MSA/MD median income categories were showed higher percentages of denied loans than loans originated. According to the data, applicants who reported white were, on average, more likely to be approved for a loan than another race or ethnicity.

The Given the relatively high rates of approval for home purchase, improvement, and refinance loans, home financing is generally available and not considered to be a significant constraint to the provision and maintenance of housing in Orange.

Section 3: Housing Constraints, Resources, and Fair Housing 3-4 2021-2029 Housing Element Update – Draft
Table 3-1: Disposition of Loan Applications by Race/Ethnicity– Anaheim-Santa Ana-Irvine MSA/MD Applications by Race/Ethnicity Percent
Approved
Percent
Denied
Percent
Other
Total
(Count)
LESS THAN 50% OF MSA/MD MEDIAN
American Indian and Alaska Native 26.2% 52.3% 23.1% 65
Asian 33.9% 42.5% 26.7% 1,382
Black or African American 41.6% 33.7% 25.8% 89
Native Hawaiian or other Pacific Islander 25.0% 44.2% 30.8% 52 White 45.6% 31.2% 26.1% 5,240
Hispanic or Latino 37.9% 38.2% 26.8% 1,566
50-79% OF MSA/MD MEDIAN
American Indian and Alaska Native 38.1% 34.0% 29.9% 97
Asian 53.3% 25.3% 29.4% 3,153
Black or African American 43.4% 19.1% 41.4% 152
Native Hawaiian or other Pacific Islander 49.4% 39.8% 16.9% 83 White 54.5% 23.3% 27.6% 8,677
Hispanic or Latino 47.6% 27.7% 29.3% 3,245
80-99% OF MSA/MD MEDIAN
American Indian and Alaska Native 51.4% 25.7% 31.4% 35
Asian 59.5% 19.2% 29.3% 1,495
Black or African American 52.9% 22.1% 30.9% 68
Native Hawaiian or other Pacific Islander 43.5% 13.0% 43.5% 23 White 61.9% 17.2% 26.1% 3,873
Hispanic or Latino 54.0% 21.4% 29.1% 1,347
100-119% OF MSA/MD MEDIAN
American Indian and Alaska Native 48.9% 22.7% 29.5% 88
Asian 62.3% 15.6% 28.8% 4,820
Black or African American 55.6% 20.1% 28.6% 234
Native Hawaiian or other Pacific Islander 49.4% 27.6% 31.0% 87 White 66.2% 13.8% 25.1% 12,607
Hispanic or Latino 60.8% 16.4% 26.8% 3,398
120% OR MORE OF MSA/MD MEDIAN
American Indian and Alaska Native 59.2% 13.0% 32.0% 169 Asian 62.8% 12.9% 29.0% 17,800
Black or African American 57.7% 17.3% 27.2% 624
Native Hawaiian or other Pacific Islander 64.2% 11.4% 26.8% 254 White 68.3% 11.3% 24.9% 49,811
Hispanic or Latino 64.6% 13.3% 26.7% 6,095
Source: Consumer Financial Protection Bureau, Disposition of loan applications, by Ethnicity/Race of applicant, 2019.

Section 3: Housing Constraints, Resources, and Fair Housing 3-5 2021-2029 Housing Element Update – Draft
Economic Constraints
Market forces on the economy and the trickle-down effects on the construction industry can act as a barrier to housing construction and especially to affordable housing construction. It is estimated that housing price growth will continue in the city and the region for the foreseeable future.

A 2020 California Association of Realtors (CAR) report found that:
 Single-family homes on the market in Orange County experienced a nine percent year to year increase and cost an average of $880,000 in February 2020  This was almost $300,000 higher than the State median home price in the same month ($579,770).

According to the CAR First Time Buyer Housing Affordability Index:
 From 2018 to 2019 the median value of a single-family home in Orange County was $703,800  This estimates monthly payments (including taxes and insurance) of about $3,630,  Which requiring an average qualifying income of $108,900.

Additionally, single-family homes and cost of living in Orange was reported slightly higher than the State median housing and living costs. According to April 2020 data from Zillow:
 The median cost of a single-family home on the market in Orange is $731,260.  Home values in the City have gone up 3.5 percent over the past year (2019-2020) and Zillow predicts they will fall -1.2 percent within the next year.  The same report found that in January of 2020 the median list price per square foot in Orange is $395, which is lower than the County of Orange average of $441.

Orange’s single-family home value index ($757,000) has been on a steady rise since early 2019, however, according to March 2020 data, they are expected to dip slightly (estimated $752,000) in 2021. The cost of land and home prices in Orange are considered a potential constraint to the development of and access to housing, particularly the development of and access to affordable housing.

B. Governmental Constraints
In addition to market constraints, local policies and regulations also affect the price and availability of housing and the provision of affordable housing. For example, State and Federal regulations affect the availability of land for housing and the cost of housing production, making it difficult to meet the demand for affordable housing and limiting supply in a region. Regulations related to environmental protection, building codes, and other topics have significant, often adverse, impacts on housing cost and availability.

While the City of Orange has no control over State and Federal Laws that affect housing, local laws including land use controls, site improvement requirements, fees and exactions, permit processing procedures, and other factors can constrain the maintenance, development, and improvement of housing and create barriers to housing.

Section 3: Housing Constraints, Resources, and Fair Housing 3-6 2021-2029 Housing Element Update – Draft
Land Use Controls
In the State of California, cities are required to prepare a comprehensive, long term General Plan to guide future development. The Land Use Element of the General Plan establishes land uses and density of development within the City of Orange. The Land Use Element sets forth policies and regulations for guiding local development. These policies, together with existing zoning regulations, establish the amount and distribution of land to be allocated for different uses within the City. The Land Use Element of the General Plan identifies the following residential categories and their existing allowed densities:
 Estate Low Density Residential (ESTR) – 0 - 2.0 dwelling units per acre  Low Density Residential (LDR) – 2.1 - 6.0 dwelling units per acre  Low Medium Density Residential (LMDR) – 6.1 - 15.0 dwelling units per acre  Medium Density Residential (MDR) 15.1 - 24.0 dwelling units per acre In addition to residential categories, Orange also allows residential uses in mixed use zones and senior housing in commercial and public institution zones with a conditional use permit (CUP). the General Plan provides three designations for mixed-use activity centers. All of these designations promote creative mixes of commercial retail, office, housing, civic, and entertainment uses that vary in composition and intensity based upon location, accessibility, and the surrounding development context. Mixed Use designations that allow residential uses include the following:
 Neighborhood Mixed-use (NMX) – Max. 24 dwelling units per acre  Old Towne Mixed-Use (OTMX) 15 – Max. 15 dwelling units per acre  Old Towne Mixed Use (OTMX) 24 – Max. 24 dwelling units per acre  Old Towne Mixed Use Spoke – 6.0 - 15.0 dwelling units per acre  Urban Mixed Use (UMX) – 30.0 - 60.0 dwelling units per acre Senior housing is permitted in the C2 and C3 commercial zone districts. Residential uses within these districts do not have a maximum dwelling units per acre. The total number of units is determined by the maximum FAR, height, and story requirements.

These categories accommodate development of a wide range of housing types in Orange. Furthermore, maintaining the existing residential categories is important for ensuring compatibility between new and existing housing. The City’s Land use controls, development standards and regulations are available for review by the public online in the City of Orange Municipal and Development code.

Historic Districts
The City Council has determined that the spirit, character and history of the City, State, and Nation are reflected in the historic structures, improvements, natural features, sites, and areas of significance located within the City, and that in the face of ever-increasing pressures of modernization, cultural historic resources and historic districts located within the City are threatened with alteration, removal or demolition. The City believes these structures and districts represent the City's unique historical, social and cultural foundations, and historic districts aim to preserve the structures as living parts of community

Section 3: Housing Constraints, Resources, and Fair Housing 3-7 2021-2029 Housing Element Update – Draft
life and development in order to build a greater understanding of the City's past and to give future generations the opportunity to appreciate, understand and enjoy the City's rich heritage.

Currently, four districts have been established that cover historic residences. These are the Old Towne District, Fairhills Eichler Tract, Fairhaven Eichler Tract, and Fairmeadow Eichler Tract. New districts may be established provided an application, which complies with the zoning amendment procedure for a change in zoning district, is submitted and the district meets criteria established in Title 17 Chapter

17.15.050 of the City’s Municipal Code. Any district designated historic includes additional regulations and uses over base zoning of an area to encourage historic preservation and complementary new development. To promote orderly development and preservation within historic districts the following standards and their amendments shall apply: the Historic Preservation Design Standards, the Santa Fe Depot Specific Plan, the Orange Eichler Design Standards, the General Plan's Historic Preservation Element, and the Secretary of the Interior's Standards for the Treatment of Historic Properties.

Flood Plain Overlay
The Flood Plain overlay districts (FP-1 and FP-2) are intended to be applied to those areas of the City which, under present conditions, are subject to periodic flooding and the hazards associated with flooding. The objectives of the flood plain districts shall be:
 To prevent loss of life and property and to minimize economic loss caused by flood flows;  To establish criteria for land management and use in flood prone areas consistent with criteria promulgated by the Federal Insurance Administration for the purpose of providing flood insurance eligibility for property owners
 To prohibit encroachments, new construction, or other improvements or development that would obstruct the flow of floodwaters within a regulatory floodway; and  To regulate and control uses below the elevation of the design flood flow with the remainder of the flood plain.

Single Story Overlay Zone
The Single Story (A) overlay is established to maintain the character of existing single-story residential neighborhoods by limiting building height to one story. The height of all buildings within the Single Story Overlay District shall be limited to one story or 20 feet, whichever is less. All other development standards applicable to the underlying district and not in conflict with this section will apply. The following residential districts are subject to the Single-Story Overlay, R1-6 (A), R-2-6 (A), and R-3(A). The Single Story Overlay is established in limited locations and is not a widespread requirement, it is therefore not considered a constraint to the development of housing in Orange.

Parking Overlay
The Parking (P) Overlay District is established to allow residentially zoned properties to be used to provide off-street parking facilities for adjacent land uses. The Parking overlay is applied only to residential properties and only when it can be demonstrated that the use of the residential lot for parking purposes will not adversely affect the surrounding residential neighborhood. The Parking Overlay may be a

Section 3: Housing Constraints, Resources, and Fair Housing 3-8 2021-2029 Housing Element Update – Draft
constraint to the development of housing, as it permits the use of nonresidential projects (parking) on residentially zoned properties. The Parking Overlay applies to one residential block in the City of Orange and is therefore not considered a constraint or barrier to the development of housing.

State Density Bonus Law
Density bonuses are another way to increase the number of dwelling units otherwise allowed in a residentially zoned area. The City’s Zoning Ordinance identifies the purpose of the Density Bonus Ordinance is to grant a density bonus and regulatory concessions and incentives to a developer of a housing development, child care facilities, or for the donation of land for housing, where the developer agrees to construct a specified percentage of housing for lower income households, very low-income households, moderate income households or qualifying residents. Title 17 Chapter 15 of the City’s municipal code outlines all regulatory requirements and standards for projects eligible for Density Bonus.

Density bonuses are available to five categories of housing developments, all are detailed below.

Effective January 1, 2021, California State Assembly Bill 2345 amends the Density Bonus Law to expand and enhance development incentives for projects with affordable and senior housing components. AB 2345 amends the Density Bonus Law to increase the maximum density bonus from 35 percent to 50 percent. To be eligible for the maximum bonus, a project must set aside at least (i) 15 percent of total units for very low income households, (ii) 24 percent of total units for low income households, or (iii) 44 percent of for-sale units for moderate income households. Levels of bonus density between 35 percent and 50 percent are granted on a sliding scale. The City’s currently adopted Density Bonus Ordinance is no longer consistent with State law and must be amended to comply with new statutory requirement.

Section 4: Housing Plan outlines the City’s plan to maintain compliance with State legislation.

Affordable Housing
The City’s Municipal Code follows State density bonus standards, processes and requirements for proposed affordable housing projects or units. All housing developments consisting of five or more dwelling units (excluding any units permitted by the density bonus awarded pursuant to Chapter 15 of the Zoning Ordinance) are eligible for one density bonus (calculations detailed in Table 3-2) and concessions and incentives.

These required percentages of affordable units apply only to the housing development without any density bonus units, not the entire housing development. For example, assume that a one hundred (100) unit housing development is entitled to a twenty (20) percent density bonus, giving a total of one hundred twenty (120) units. To qualify for the twenty (20) percent density bonus, the housing development need only provide five units affordable to very low-income households (five percent of one hundred (100)) or ten units affordable to lower income households (ten percent of one hundred (100)).

Senior Citizen Housing Development or Mobile home Park
The City’s Municipal Code follows State density bonus standards, processes and requirements for Senior Housing developments. A senior citizen housing development or a mobile home park are eligible for

Section 3: Housing Constraints, Resources, and Fair Housing 3-9 2021-2029 Housing Element Update – Draft
a density bonus, as calculated in Table 3-2 below, even if none of the units are affordable.

The density bonus for a senior citizen housing development or a mobile home park is permitted in geographic areas of the housing development other than the areas where the qualifying resident or mobile home units are located.

Donations of Land
The City’s Municipal Code follows density bonus standards, processes and requirements for donations of land. An applicant for a tentative tract map, parcel map, or other residential development approval, who donates land to the City in accordance with this subsection, shall be entitled to a density bonus for the entire housing development, as calculated in Table 3-2 below, provided the parcel is large enough to accommodate at least ten percent of the market rate units at densities suitable for housing affordable to very low-income households.

In other words, a five hundred (500) unit market rate housing development is eligible to receive a density bonus by donating land zoned at densities that can accommodate, and are suitable for, fifty (50) units of housing affordable to very low-income households.

Eligibility for Increase Density Bonus
An applicant shall be eligible for the increased density bonus described in this subsection if all of the following conditions are met:
 The applicant donates and transfers the land no later than the date of approval of the final subdivision map, parcel map or residential development application.  The land being transferred has all permits and approvals, other than building permits necessary for the development of housing units affordable to very low-income households.  The developable acreage and zoning classification of the land being transferred are sufficient to permit construction of units affordable to very low-income households in an amount not less than ten percent of the number of residential units of the proposed housing development.  The transferred land is at least one acre in size or of sufficient size to permit development of at least forty (40) units, has the appropriate General Plan designation, is appropriately zoned for development as affordable housing, and is or will be served by adequate public facilities and infrastructure. The land shall have appropriate zoning and development standards to make the development of the units affordable to very low-income households feasible. No later than the date of approval of the final tract map, parcel map, or of the residential development, the transferred land shall have all of the permits and approvals, other than building permits, necessary for the development of the units affordable to very low income households on the transferred land, except that the City may subject the proposed housing development to subsequent design review to the extent authorized by subdivision "(i)" of Section 65583.2 of the California Government Code if the design is not reviewed by the City prior to the time of transfer.  The land is transferred to the City or to a housing developer approved by the City. The City may require the applicant to identify and transfer the land to the developer.

Section 3: Housing Constraints, Resources, and Fair Housing 3-10 2021-2029 Housing Element Update – Draft
 The transferred land shall be within the boundary of the proposed housing development or, if the City agrees, within one-quarter mile of the boundary of the proposed housing development.  The transferred land and the affordable units shall be subject to a Density Bonus Housing Agreement ensuring continued affordability of the affordable units, which Density Bonus Housing Agreement (or a memorandum thereof) shall be recorded in the Official Records of the County of Orange prior to final map approval or, where a map is not being processed, prior to the issuance of building permits for such affordable units.

Condominium Conversions
The City’s Municipal Code follows State density bonus standards, processes and requirements for condo conversions. A condominium conversion is eligible for either:
 A density bonus of twenty-five (25) percent over the number of apartments to be provided within the existing structure or structures proposed for conversion (meaning that additional units must be added on the site either by subdividing existing units or adding units on the site), or  Other incentives of equivalent financial value

The City may place such reasonable conditions on the granting of a density bonus or other incentives of equivalent financial value as it finds appropriate, including, but not limited to, conditions which assure continued affordability of units to subsequent purchases who are lower income households or moderate- income households.

Calculations for Density Bonus
For the purpose of calculating the amount of the density bonus, an applicant requesting a density bonus shall elect whether the density bonus shall be awarded on the basis of the particular affordability category. The amount of the density bonus is calculated as show in Table 3-2 below. The amount of the density bonus to which the applicant is entitled shall vary according to the amount by which the percentage of affordable units exceeds the percentage.

Additionally, all density calculations resulting in fractions shall be rounded up to the next whole number.

For example, a housing development with 102 units, ten percent of which are affordable to lower income households, is entitled to 21 bonus units. The number of affordable units must also be rounded up. In a 102-unit housing development, an applicant would need to provide eleven units to meet the ten percent requirement. If they so choose, the applicant may elect to accept a lesser percentage of density bonus.

Section 3: Housing Constraints, Resources, and Fair Housing 3-11 2021-2029 Housing Element Update – Draft
Table 3-2: Density Bonus Calculations1
Affordable Units or
Category
Minimum %
Units in
Category
Bonus Granted
Additional Bonus
for each 1%
increase in
Affordable Units in
category
% Units in category
required for
Maximum 35%
Bonus
Very Low Income 5% 20% 2.5% 11%
Lower Income 10% 20% 1.5% 20%
Moderate Income
(ownership only) 10% 5% 1% 40%
Senior Citizen Housing
Development or Mobile
home Park (no affordable
units required)
Entire
development 20% No sliding scale
provided —
Land Donation for Very-
Low Income Housing
0% of market
rate units 15% 1% 30%
Condominium Conversion
– Moderate Income 33% 25% — —
Condominium Conversion
– Lower Income 15% 25% — —
Child Care Facilities — Sq. ft. in day
care center — —
Notes:
(1) This table reflects the current Orange Municipal Code. The City of Orange defaults to State law regarding Density Bonus calculations and requirements.

Source: City of Orange, Municipal Code accessed May 4, 2020.

Concessions and Incentives
The City’s Municipal Code also permits the request of additional incentives and concessions; types of permitted requests are detailed below.

In addition to an increase in units, a development eligible for a density bonus is also eligible for three types of regulatory concessions as follow, (a) concessions and incentives, (b) waivers and reductions, and (c) reduced parking standards. An applicant for a density bonus may submit to the City a proposal for one to three concessions and incentives depending upon the percentage of affordable units provided.

Waivers and Reductions
In addition to requesting concessions and incentives, an applicant for a density bonus may submit to the City a proposal for the waiver or reduction of an unlimited number of development standards that would otherwise preclude or inhibit construction of a housing development with the density bonus and concessions and incentives to which the housing development is entitled and that are needed to make the housing development economically feasible. Waivers and reductions may also be requested by any applicant requesting a density bonus for a senior citizen housing development, a mobile home park, a condominium conversion or a childcare facility.

Section 3: Housing Constraints, Resources, and Fair Housing 3-12 2021-2029 Housing Element Update – Draft
Reduced Parking Standards
Upon the request of an applicant for a housing development that qualifies for a density bonus because it is a senior housing development or provides affordable units, the City must reduce the required parking for the entire housing development, including the market rate units, to the following:
 Zero to one bedroom, one on-site parking space
 Two to three bedrooms, two on-site parking spaces
 Four or more bedrooms, two and one-half on-site parking spaces Additional and in detail standards, requirements, review processes and application information for projects which qualify for density bonus can be found in the City’s Municipal Code.

Residential Development Standards
The City of Orange Zoning establishes sixteen residential districts to provide a range of housing types and lifestyles. The Zoning Ordinance also contains provisions to establish use regulations and development standards, which are intended to create the highest quality residential development, minimize land use conflicts, encourage the rehabilitation and maintenance of residential neighborhoods and implement the goals of the City's General Plan. The standards for the districts are shown in Table 3-3 and are available on the City’s website. The districts are as follows:
 R1-5 (Single-Family Residential) - A single-family residential district with a minimum lot area of five thousand (5,000) square feet. The R1-5 district is created to implement the East Orange General Plan where policies have been established to ensure functional and attractive single- family neighborhoods.
 R1-6 Single-Family Residential) - A single-family residential district with a minimum lot area of six thousand (6,000) square feet.
 R1-7 (Single-Family Residential) - A single-family residential district with a minimum lot area of seven thousand (7,000) square feet.
 R1-8 (Single-Family Residential) - A single-family residential district with a minimum lot area of eight thousand (8,000) square feet.
 R1-10 (Single Family Residential) - A single family residential district with a minimum lot area of ten thousand (10,000) square feet.
 R1-12 (Single-Family Residential) - A single-family residential district with a minimum lot area of twelve thousand (12,000) square feet.
 R1-15 (Single-Family Residential) - A single-family residential district with a minimum lot area of fifteen thousand (15,000) square feet.
 R1-20 (Single-Family Residential) - A single-family residential district with a minimum lot area of twenty thousand (20,000) square feet.
 R1-40 (Single-Family Residential) - A single-family residential district with a minimum lot area of one acre (forty-three thousand five hundred sixty (43,560) square feet).  R1-R (Single-Family Residential) - A single-family rural residential district with a minimum lot area of two and one-half acres (one hundred eight thousand nine hundred (108,900) square feet). The purpose of this district is to allow for low density rural residential use in a manner which will

Section 3: Housing Constraints, Resources, and Fair Housing 3-13 2021-2029 Housing Element Update – Draft
eliminate or minimize modifications to significant riparian habitat, oak woodlands and prominent landforms located within the areas encompassed by this land use designation.  R2-6 (Duplex Residential) - A residential district that provides opportunities for duplex development on lots containing a minimum area of six thousand (6,000) square feet. This district recognizes the need to provide multiple-family housing in the form of duplexes, detached dwellings, or small apartment buildings.
 R2-7 (Duplex Residential) - A residential district that allows duplex housing on lots containing a minimum area of seven thousand (7,000) square feet.
 R2-8 (Duplex Residential) - A residential district that allows duplex housing on lots containing a minimum lot area of eight thousand (8,000) square feet.  R-3 (Multiple-Family Residential) - A multiple-family residential district which allows apartments, condominiums, and townhomes. The purpose is to provide a minimum of ground area coverage and a maximum of open space within higher density developments.  R-4 (Multiple-Family Residential) - A multiple-family residential district which allows apartments, condominiums, and townhomes.
 MH (Mobile Home Residential) - A mobile home district which allows for the preservation and construction of mobile home parks. The district recognizes the need to provide the unique setting and services of a mobile home park.

Table 3-3 below displays the development standards for each of the above zones, which permit residential development. Title 17, Chapter 14 outlines the complete development standards for residential uses in the City of Orange.

Table 3-3: Residential Development Standards in Orange - Dimensions District
Dimensions Min. Yard Setbacks (ft) Construction Standards Min. Lot
Size (sf)
Min. Lot
Frontage
(ft)
Min. Lot
Depth (ft) Front Side Rear Max.

Height* Max. FAR
Min.

Usable
Open
Space (sf)
R1-5 5,000 50 90 Bld-15,
Gar-20 v.21 (v.2) 32’ – 2
stories
Based on
bldg. 875
R1-6 6,000 60 100 20 5 1 20 1 32’ – 2
stories1 (4) 900
R1-7 7,000 60 100 20 5 1 20 1 32’ – 2
stories (4) 950
R1-8 8,000 60 100 20 5 1 20 1 32’ – 2
stories (4) 1,000
R1-10 10,000 80 100 20 5 1 20 1 32’ – 2
stories (4) 1,000
R1-12 12,000 80 100 20 5 1 20 1 32’ – 2
stories (4) 1,000
R1-15 15,000 80 100 20 5 1 20 1 32’ – 2
stories (4) 1,200

Section 3: Housing Constraints, Resources, and Fair Housing 3-14 2021-2029 Housing Element Update – Draft
Table 3-3: Residential Development Standards in Orange - Dimensions District
Dimensions Min. Yard Setbacks (ft) Construction Standards Min. Lot
Size (sf)
Min. Lot
Frontage
(ft)
Min. Lot
Depth (ft) Front Side Rear Max.

Height* Max. FAR
Min.

Usable
Open
Space (sf)
R1-20 20,000 100 100 20 5 1 20 1 32’ – 2
stories (4) 1,500
R1-40 43,560 100 100 20 5 1 20 1 32’ – 2
stories 0.40 FAR 2,000
R1-R 108,900 100 100 20 5 1 20 1 32’ – 2
stories 0.40 FAR 2,000
R2-6 6,000 60 N/R 15 2 51 10 1 32’ – 2
stories1 0.70 FAR 350/unit
R2-7 7,000 60 N/R 15 5 1 10 1 32’ – 2
stories 0.70 FAR 350/unit
R2-8 8,000 60 N/R 15 5 1 10 1 32’ – 2
stories 0.70 FAR 350/unit
R-3
7,000
Interior,
8,000
Corner
70 Interior,
80 Corner
100 15 2 5 1 10 32’ – 2
stories1
45%: 2-
story
55%: 1-
story
250/unit
R-4
6,000
Interior,
7,000
Corner
60 Interior,
70 Corner
N/R 10(z) 5 1 10 32’ – 2
stories1 60% 150/unit
MH N/R N/R N/R (3) (3)
75% of
MH
Space
200 sf
space1 MH (3)
OTMU-
155 10,000 N/R 50 (6) (6) 0 6 32’ – 2
stories 0.6 N/R
OTMU-
15 10,000 N/R 50 (6) 0 6 0 6 32’ – 2
stories 0.5 -1.0 N/R
OTMU-
24 10,000 N/R 50 (6) 0 6 0 6 32’ – 2
stories 1.0 -1.5 N/R
NMU-24
40,000 N/R 100 10 0 6 0 6 45’ – 3
stories 1.0-1.5 N/R
UMU 40,000 N/R 50 10 0 6 0 6 45’ – 3
stories 1.5 - 3.0 N/R
OP 7,000 N/R 70 -- 7 -- 7 -- 7 32’ – 2
stories 0.5 N/R
CP/C1 40,000 100 N/R -- 7 -- 7 -- 7 32’ – 2
stories 1.0 N/R
CTR 40,000 100 N/R -- 7 -- 7 -- 7 32’ – 2
stories 1.0 -- 7

Section 3: Housing Constraints, Resources, and Fair Housing 3-15 2021-2029 Housing Element Update – Draft
Table 3-3: Residential Development Standards in Orange - Dimensions District
Dimensions Min. Yard Setbacks (ft) Construction Standards Min. Lot
Size (sf)
Min. Lot
Frontage
(ft)
Min. Lot
Depth (ft) Front Side Rear Max.

Height* Max. FAR
Min.

Usable
Open
Space (sf)
C2 40,000 100 N/R -- 7 -- 7 -- 7 32’ – 2
stories 1.0 -- 7
C3 40,000 100 N/R -- 7 -- 7 -- 7 32’ – 2
stories 1.0 -- 7
PI 6,000 N/R N/R 10 1 0 0 32’ – 2
stories1 2.0 N/R
FAR= Floor Area Ratio
(*) Feet or Stories whichever is less
N/R = No Requirement
Notes:

1. Additional exceptions or requirements apply and can be found in Chapter 17.40. of the City’s Municipal Code.

2. All buildings located within the Old Towne residential quadrants shall have a minimum front yard setback of 20 feet.

3. Mobile Home Requirements vary based on Chapter 17.14 of the City’s Municipal Code.

4. Floor area ratio (FAR) shall vary according to lot area per the table below.

5. Additional exceptions or requirements apply and can be found in Chapter 17.18. of the City’s Municipal Code.

6. Specific requirements and additional exceptions or requirements apply and can be found in Chapter 17.19 of the City’s Municipal Code.

7. Senior housing developed in commercial zones is subject to NMU development standards.

Lot Area in Square
Feet
Maximum
FAR
<10,000 0.60
10,000—39,999 0.50
>40,000 0.40

Section 3: Housing Constraints, Resources, and Fair Housing 3-16 2021-2029 Housing Element Update – Draft
Yard Requirements
Yards shall provide for light and air, pedestrian and vehicular circulation, emergency access, and general aesthetic improvements. Minimum yard requirements vary among the residential districts. The primary purposes of imposing yard requirements to ensure adequate air and light between properties, to ensure adequate on-site access and circulation, to provide opportunities for private open space areas (yards), and to separate uses between properties to minimize conflicts and potential life/safety hazards. Yard requirements are generally tied to lot size, meaning smaller lots have lower minimum setbacks, and larger lots require larger “yards.” While it is possible that setback requirements may inhibit maximum density from being realized in some cases, there is enough flexibility in the current ordinances that setback requirements do not constitute a significant constraint on residential development. Setback requirements have been considered in the City's calculation of realistic site capacity.

Lot Coverage and FAR
Lot coverage and floor area ratio (FAR) standards are intended to control bulk, mass, and intensity of a use. Lot coverage limits a building’s footprint and is defined as the percentage between the ground floor area of building(s) and the net area of a lot. FAR limits the total usable floor area and is expressed as a ratio between the bulk floor area of building(s) and gross lot area. Floor area ratio is a supplementary device that under some conditions improves upon (but does not necessarily replace) the traditional means of relating bulk of building to land, to other buildings in the vicinity, and to public facilities. It permits variable dimensions within an over-all volume limit and it offers a way of predicting the ratio of persons to a unit of land in office building districts of high land use intensity.

In the residential-only zones maximum floor area ration ranges depending on desired density and requirements. For example, in the R1-6 through R1-20 districts maximum lot coverage ranges depending on the size of the lot area. For a lot are of less than 10,000 square feet, the FAR is 0.60, meaning that the building area may not be larger than 6,000 square feet. However, in districts aiming to achieve higher densities such as the R2-6 district maximum FAR increases to 0.07, allowing for more building coverage, accompanied by a small square footage requirement per unit (6,000 sf) providing for the potential of higher density developments. As applied to residential development, these standards may only limit the size of dwelling units, and do not limit the number of units, which is an expression of density (that is, zoning). FAR, combined with height limitations, can potentially prevent maximum density from being achieved in certain cases.

In evaluating recent residential projects within the City, lot coverage and FAR do not typically pose constraints to development at the maximum density.

Maximum Building Height
Maximum building height standard are often in place to maintain community compatibility for new and proposed developments. In the City of Orange, the maximum allowable building height for residential zones is 32 feet or two stories and defaults the lesser of the two. However, greater height than the height limit established for a district or additional height and stories for habitable space in the R-3 and R-4

Section 3: Housing Constraints, Resources, and Fair Housing 3-17 2021-2029 Housing Element Update – Draft
districts, may be considered by a Conditional Use Permit before the Planning Commission. In reviewing such a request, the Commission shall consider:
 Siting buildings or structures so as to achieve greater usable open space area than could be achieved with two story construction.
 Siting buildings or structures so as to consider shadows, solar orientation, and noise impacts, as well as respecting the terrain.
 Designing and/or screening all roof-top mechanical and electrical equipment as an integral part of the building design.
 Illustrating a design compatibility with both the existing and desired character of the surrounding area and uses.

Usable Open Space
The City’s Zoning Code defines Usable Open Space as an open area or an indoor or outdoor recreational facility which is designed and intended to be used for outdoor living and/or recreation. Open space provides areas for recreation and activity, it promotes the health of the community, green relief and urban cooling within a development. The City requires that all residential developments in the R-l, R-2, R-3, R-4 and Mixed Use zone districts shall provide a landscaped, unified, and usable open recreational and leisure area. For multifamily developments, each unit is required to have at least one area of private usable open space accessible directly from the living area of the unit, in the form of a fenced yard or patio, a deck or balcony. The City’s open space requirements are not an undue constraint to the development of housing and often provide the necessary outdoor/open space resources for future residents.

Parking Standards
In addition to the development standards identified in Table 3-4, Orange requires all spaces to be covered spaces for single family dwellings and a certain number of enclosed spaces for duplex and multifamily apartments as well as an additional space for all accessory living units. Guest parking is also required for multi-family housing at a ratio of 0.2 spaces for every unit. The City of Orange Zoning code provides additional direction for parking standards and regulation, such as additional standards for supportive and transitional housing. The City of Orange complies with density bonus parking rates established by the State for projects that meet density bonus requirements.

Section 3: Housing Constraints, Resources, and Fair Housing 3-18 2021-2029 Housing Element Update – Draft
Table 3-4: Parking Requirements for Residential Uses
Unit Type Number of Spaces Required
Single-family
Dwelling
2 enclosed garage spaces/unit up to 4 bedrooms.

For 5 or more bedrooms, 1 additional enclosed space.

For PUDs, units with 3 or more bedrooms must provide an additional 1.5 guest parking spaces per dwelling unit.

One unenclosed parking space must be provided in excess of the code parking requirement for the existing residential use and no parking spaces are required for an accessory dwelling unit in any of the following instances:
 The accessory dwelling unit is located within one-half mile of public transit.  The accessory dwelling unit is located within an architecturally and historically significant district.
 The accessory dwelling unit is part of the existing primary residence or an existing accessory structure.
 When on-street parking permits are required but not offered to the occupant of the accessory dwelling unit.
 When there is a car share vehicle located within one block of the accessory dwelling unit.

Duplex, Duplex
Residential 2 parking spaces per unit, one of which shall be in an enclosed garage.

Multifamily
Residential (3 units
or more)*
Development Size—3 units to 50 units Development Size—51+ Units Unenclosed resident
parking is provided
(e.g. parking
structure, surface
parking lots,
carports):

If enclosed resident
parking is provided:

If unenclosed resident
parking is provided
(e.g. parking
structure(s), surface
parking lots,
carports):

If enclosed resident
parking is provided:

Studio* 1.3 spaces/unit 1.4 spaces/unit 1.2 spaces/unit 1.4 spaces/unit One Bedroom* 1.8 spaces/unit 1.9 spaces/unit 1.7 spaces/unit 1.9 spaces/unit Two Bedroom* 2.3 spaces/unit 2.3 spaces/unit 2.0 spaces/unit 2.3 spaces/unit Three Bedrooms* 2.6 spaces/unit 2.6 spaces/unit 2.4 spaces/unit 2.6 spaces/unit Each add’l bedroom
above three*

0.4 spaces/bedroom/unit

0.5 spaces/bedroom/unit

0.3 spaces/bedroom/unit

0.5 spaces/bedroom/unit
Boarding house, bed
and breakfast inns 1 space/rentable room, plus any other additional spaces required by the underlying zone Supportive Housing,
Transitional Housing
For Transitional Housing or Supportive Housing configured as group quarters (i.e. where beds are provided in individual rooms, but kitchen and/or bathroom facilities are shared), 1 space per bed, plus one space per onsite staff person.

Emergency Shelter
Parking 1 space per six beds, plus one space per staff person.

Student Housing 0.5 space/student resident, plus 1 space/each resident staff person Trailer park, mobile
home park
2 spaces/unit, (1 of which is covered, at least 2 sides of the carport shall be at a minimum 50% open and unobstructed)
1 guest space/3 trailers or mobile homes must be easily accessible and distinguishable guest parking. Tandem parking is permitted for the mobile home.

Source: City of Orange, Municipal Code, accessed May 4, 2020.

Section 3: Housing Constraints, Resources, and Fair Housing 3-19 2021-2029 Housing Element Update – Draft
Table 3-4: Parking Requirements for Residential Uses
Unit Type Number of Spaces Required
* Of the above requirements a minimum of one must be covered and a minimum of 0.2 spaces per unit shall (with a minimum of two guest spaces in a multifamily development) be provided as easily accessible and distinguishable guest parking in addition to the required parking for each unit.

Typically, the cost associated with garage parking construction can be viewed as a constraint to affordable housing development, particularly for multi-family housing. However, the City’s parking regulations are not a significant constraint because the number of required parking spaces for duplexes and multi-family projects varies by the number of bedrooms. Furthermore, affordable housing projects that qualify for a density bonus can request application for additional incentives which can be provided in the form of reduction of parking requirements. While off-street parking standards can affect planned residential density, especially for small lots and in-fill areas, this potential constraint is mitigated by the incentives and flexible standards described above.

Planned Unit Developments
The Planned Unit Development (PUD) is established to provide an alternative to standard residential development wherein the existing General Plan densities are preserved but flexibility is provided by allowing the clustering of units and combining of open space, recreation areas and roadways under common ownership. In order to qualify for a PUD, the following findings must be made by the reviewing body to justify the approval:
 The project conforms to the General Plan in regard to land use designation and density.  The project utilizes creative and imaginative planning and design features to create a quality living environment, equal to or better than what might be accomplished under the base zone designation.
 The project preserves unique physical, topographical or environmental features, where applicable.

A Conditional Use Permit before the Planning Commission and City Council is required for the establishment of a PUD. Additionally, a PUD must be adopted by Ordinance and indicated on the zoning map by the base zoning designation and the Conditional Use Permit number applicable to that PUD. A Planned Unit Developments may be located in any zone district zoned for residential use. The City plans to develop a Small Lot Subdivision Ordinance and Design Guidelines to increase the feasibility of residential developments.

Development Standards
The City of Orange Municipal Code (Title 17 Chapter 17.16.060) establishes development standards for all PUDs. The reviewing body for a PUD may require more stringent standards to ensure compatibility with surrounding uses, quality of life for future residents and protection of public health, safety, and general welfare.

Section 3: Housing Constraints, Resources, and Fair Housing 3-20 2021-2029 Housing Element Update – Draft
Table 3-5: PUD, Development Standards
Type Standards/Requirements
Density
The total number of dwelling units permitted shall not exceed the number allowed by the General Plan. In establishing the density, the reviewing body shall consider compatibility with surrounding land uses and densities on adjacent parcels.

Building
Height
The underlying zone district shall govern the maximum permitted building heights for all structures within a PUD.

Building
Separation
Number
of
Structures
Front/Any Other Building Wall All Other
Configurations
Minimum Distance
Between Principal and
Accessory Structure
One N/A N/A 6 feet
Two to
Four 15 feet 8 feet 6 feet
Five or
More
25 feet from view allowing windows in any adjacent
structure. 15 feet minimum between solid facing walls,
or when windows are located on only one facing wall.
6 feet
Setback from
Public Right
of Way
All structures (including walls or fences exceeding 42″ in height) shall be setback a minimum of 20 feet from a public right-of-way. The required setback area shall be landscaped.

Project Area
Boundary
Setback
All habitable structures shall be set back a minimum of ten feet from any project boundary not abutting a street. Buffer of trees or hedges shall be provided as appropriate to ensure compatibility with adjacent uses.

Interior
Street
Setbacks
All structures shall be set back a minimum of ten feet from any interior street. Garage door openings shall be set back a minimum of 20 feet from any interior street, unless one additional parking space is provided for all units containing garages with driveways less than 20 feet in length. Such space must be conveniently located to the units.

Local Ordinances
Growth Management Measures
Growth management measures are techniques used by a government to regulate the rate, amount and type of development. Growth management measures allow cities to grow responsibly and orderly, however, if overly restricted can produce constraints to the development of housing, including accessible and affordable housing.

The Growth Management Element, a part of the City of Orange’s General Plan, intends to mandate growth and development in Orange be based on the City’s ability to meet the requirements of the Orange County voter-approved Revised Traffic Improvements and Growth Management Ordinance, Measure M. The Growth Management Element applies to all new development within Orange; however, the City may consider future project exemptions to encourage the development of affordable housing.

In 1990, Orange County voters approved Measure M authorizing a half-cent retail sales tax increase for a period of 20 years effective April 1,1991. County voters approved the renewal of Measure M, extending the tax increase through 2031. Revenue generated by Measure M is returned to local jurisdictions for use on local and regional transportation improvements and maintenance projects. To qualify for this revenue,

Section 3: Housing Constraints, Resources, and Fair Housing 3-21 2021-2029 Housing Element Update – Draft
each jurisdiction must comply with the Countywide Traffic Improvement and Growth Management Program; requirements include:
 Adoption of a Growth Management Element that includes:
o Traffic LOS standards,
o A development mitigation program; and
o A development phasing and annual monitoring program.
 Participation in interjurisdictional planning forums.  Development of a 7-year CIP.
 Addressing housing options and job opportunities and,  Adoption of a Transportation Demand Management Ordinance.

Implementation of the Growth Management Element is incorporated throughout the City’s established development review and monitoring process where possible. Specific goals and policies addressed in the Growth Management Element, that may be considered a constraint to the development of housing include the following:
 Policy 1.1: Establish LOS D as the level of service standard for traffic circulation within the City for both roadway segments and peak-hour signalized intersection movements.  Policy 1.3: Ensure completion of transportation improvements as agreed upon by the City and developer prior to completion of a development project.  Policy 1.4: Continue to collect transportation impact fees for improvements within the City boundaries and work with adjacent jurisdictions to determine that an appropriate level of transportation impact fees are maintained within the established County GMAs.  Policy 1.10: Apply traffic calming measures, where appropriate, to residential neighborhoods affected by cut-through traffic in accordance with the City’s Residential Neighborhood Traffic Management Program.

The policies mentioned above, include measures to maintain traffic level of service when new developments are established, measures to ensure traffic improvements are made and fees are collected from developers, and traffic calming measures in residential area. The mentioned policies produce potential financial constraints on new developments through implementing potential infrastructure updates and fees to reduce congestion in Orange. While the policy may produce potential financial constraints, they ensure the existing fees are collected, and provide for a reasonable level of infrastructure maintenance in the City. The measure also states, the City may consider exemptions for affordable housing developments. Since adoption, Measure M has not proven to be a constraint on development and the City has continued to successfully receive and process applications for residential projects at all income levels.

Short Term Rental (STR) Ordinance
The City of Orange defines a short term rental as the rental of a residential unit for 30 days or less. As established by Ordinance No. 05-21 (adopted on May 11, 2021) any owner of a property in a zone that allows residential uses, except in mobile home parks, who wishes to rent all or a portion of a property for

Section 3: Housing Constraints, Resources, and Fair Housing 3-22 2021-2029 Housing Element Update – Draft
a period of 30 days or less is required to obtain a short term rental permit, business license, and proof of liability insurance.

Short term rentals must have a minimum 300 foot buffer between one-another, as measured from property line to property line. In addition, a maximum of two occupants are permitted and must stay for a minimum of two nights. Off-street parking is required on the property. The City provides information and short term rental permitting conditions online for interested homeowners.

Short term rentals may pose a constraint to housing access and may hinder the City from meeting its RHNA allocation; however, the City of Orange’s permitting process allows for the monitoring of short term rentals to avoid potential conflicts. Therefore, the City’s Short Term Rental Ordinance is not considered a constraint to housing.

Variety of Housing Types Permitted
Housing Element law specifies that jurisdictions must identify adequate sites to be made available through appropriate zoning and development standards to encourage the development of a variety of types of housing for all income levels. Table 3-6 below summarizes the City’s zoning provisions for various types of housing, as provided in the City’s Municipal Code available online. Permitted, conditional, and prohibited residential uses are indicated as follows:
 P = Permitted use.
 C = Conditional use permit required.
 - = Not permitted.
 A = Accessory use.
 * = Use subject to special provisions contained in the Master Land Use Chapter of the City’s Zoning Code.
 + = Use subject to conditional use permit regulations.  # = Use subject to special provisions contained in the Residential Chapter of the City’s Zoning Code.

Section 3: Housing Constraints, Resources, and Fair Housing 3-23 2021-2029 Housing Element Update - Draft

Table 3-6: Permitted Residential Uses by Zone
Zoning Residential Zones Commercial Zones Mixed Use Zones Indus- trial Zones
Agricultural
Open Space Zones
Pub.

Inst.

Zone
Overlay
Zones
Sand &
Gravel
Zones
Accessory dwelling unit
(detached and
attached)
A/
P*/
C+
A/
P*/
C+
A/
P*/
C+
A/
P*/
C+
A/
P*/
C+
A/
P*/
C+
A/
P*/
C+
- - - - - - - - - - - - - - - - - - - -
Bed and breakfast inn - - - C+ C+ C+ - C+ C+ - C+ - - C+ C+ C+ - - - - - - - - - - - Boarding and lodging
houses
- - - - C C - - - - - - - - - - - - - - - - - - - - -
Caretaker
residence/caretaker
mobile home
- - - - - - - A* A* A* A* A* - - - - - - A* A* A* A* - A* - - A* Condominiums - - - P* P* P* - - - - - - - - - - - - - - - - - - - - - Congregate care
(assisted living) home
health facility (6 or
fewer persons)
P* P* P* P* P* P* P* - - - - - - - - - P P - - - - - - - - - Convalescent facility,
skilled nursing facility
- - - - - - - - - - - - - - - - P P - - - - - - - - -
Convalescent hospital - - - - C C - C C C C C - - - - - - - - - - - - - - - Conversion of multi-
family units
(condominium
conversion)
- - - - - - - - - - - - - P* P* P* P* P* - - - - - - - - - Duplex - - - P* P* P* - - - - - - - - - - - - - - - - - - - - - Fraternity, sorority - - - - C C - C - - - - - - - - - - - - - - - - - - -

Section 3: Housing Constraints, Resources, and Fair Housing 3-24 2021-2029 Housing Element Update – Draft
Guest house - - - - - - - - - - - - - - - - - - - - A - - - - - - Home for elderly, or
mentally, or physically
disabled persons (6 or
fewer persons)
P* P* P* P* P* P* P* - - - - - - - - - - - - - - - - - - - - Homeless shelter - - - - - - - - - - - - - - - - - - P* P* - - - - - - - Hotels - - - - - - - - C+ C+ C+ C+ P C+ C+ C+ C+ C+ - - - - - - - - - Motels - - - - - - - - C+ C+ C+ C+ P - - - - - - - - - - - - - - Housing related to
church, college or
hospital
- - - - - - - - - - - - - - - - - - - - - - - A* - - -
Live/work units - - - - - - - - - - - - - P* P* P* P* P* - - - - - - - - - Mixed
use development
- - - - - - - - - - - - P* P* P* P* P* - - - - - - - - - Mobile home park C C C C C C C - - - - - - - - - - - - - - - - - - - - Mobile home,
modular, or
manufactured housing
unit with permanent
foundation
P P P P P P P - - - - - - - - - - - - - - - - - - C+ -
Mobile home,
modular, or
manufactured housing
unit without
permanent foundation
- - - - - - P - - - - - - - - - - - P* P* - - - - - C+ - Multi-family housing as
a stand alone
development not in
conjunction with a
mixed
use development
- - - - - - - - - - - - - P* P* P* P* P* - - - - - - - - -

Section 3: Housing Constraints, Resources, and Fair Housing 3-25 2021-2029 Housing Element Update – Draft
Multi-family housing in
conjunction with a
mixed
use development
- - - - - - - - - - - - - P* P* P* P* P* - - - - - - - - - Multiple-family
dwelling
- - - P* P* P* - - - - - - - - - - - - - - - - - - - - - Planned unit
developments
C+ C+ C+ C+ C+ C+ - - - - - - - C+ C+ C+ C+ C+ - - - - - - - - - Residential structure - - - - - - - - - - - - - - - - - - - - - - - - - C - Rest home - - - C C - C C C C C - - - - - - - - - - - - - - - Sanitarium - - - - C C - - - - - - - - - - - - - - C - - - - - - Senior citizen housing
development
- - - - C+ C+ - C+ C+ C+ C+ C+ - C+ C+ C+ C+ C+ - - - - - - - - - Senior housing P P P P P P P C+ C+ C+ C+ C+ - P P P P P - - - - - - - - - Single-family dwelling P# P P P P P - P - - - - - P* P* P* - - - - P - - - - - - Single-family dwelling
(Created pursuant to
SB 9)
P* P* P* - - - - - - - - - - - - - - - - - - - - - - - - Sober living facility P* P* P* P* P* P* P* - - - - - - - - - - - - - - - - - - - - Supportive housing (6
or fewer persons)
P* P* P* P* P* P* P* - - - - - - P* P* P* - - - - - - - A* - - - Supportive housing (7
or more persons)
- - - - C+ C+ - - - - - - - P* P* P* - - - - - - - A* - - - Transitional housing (6
or fewer persons)
P* P* P* P* P* P* P* - - - - - - P* P* P* - - - - - - - A* - - - Transitional housing (7
or more persons)
- - - - C+ C+ - - - - - - - P* P* P* - - - - - - - A* - - -

Section 3: Housing Constraints, Resources, and Fair Housing 3-26 2021-2029 Housing Element Update – Draft

Farmworker housing
(3)
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Emergency Shelters (2) - - - - - - - - - - - - - - - - - - - - - - - - - - - Single-Room
Occupancy (3)
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Low-Barrier Navigation
Housing (3)
- - - - - - - - - - - - - - - - - - - - - - - - - - -
Notes:
(1) Permitted as an accessory to an allowed use
(2) Emergency shelters permitted within the M1 and M2 zones. Emergency Shelters fall under “Homeless Shelters” within the City’s Municipal Code currently. (3) These uses do not currently exist within the City’s Municipal Code. Programs have been added within the Housing Plan section to address Municipal Code amendments for each. The following programs address Farmworker Housing (Program 4H), Emergency Shelters (Program 4F), Single Room Occupancy (Program 4G), and Low-Barrier Navigation Centers (Program 4F).

Source: City of Orange, Zoning Ordinance, accessed April 2020.

Section 3: Housing Constraints, Resources, and Fair Housing 3-27 2021-2029 Housing Element Update - Draft
Housing types are defined in the Orange Municipal Code as follows:

Single-family
An attached or detached building not to contain more than one kitchen wherein the occupants of the dwelling unit are living and functioning together as a single housekeeping unit, meaning that they have established ties and familiarity with each other, jointly use common areas, interact with each other, share meals, household activities, expenses and responsibilities, membership in the single housekeeping unit is fairly stable as opposed to transient, and members have some control over who becomes a member of the single housekeeping unit. The City of Orange allows single family dwelling in the R1-5, R1-6, R-15 to R1-20, R-140, R1-R, R2-6 to R2-8, R-3, and R-4 zoning districts, as well as an accessory in the City’s Mixed Use zoning districts.

Duplex
Any attached or detached building containing two dwelling units wherein the occupants of each individual dwelling unit are living and functioning together as a single housekeeping unit, meaning that they have established ties and familiarity with each other, jointly use common areas, interact with each other, share meals, household activities, expenses and responsibilities, membership in the single housekeeping unit is fairly stable as opposed to transient, and members have some control over who becomes a member of the single housekeeping unit. The City of Orange allows duplexes in the R2-6-R2-8, R-3, R-4, and MH districts with special provisions contained in the Master Land Use Chapter of the City’s Zoning Code.

Multi-family
Any structure designed for human habitation that has been divided into two or more legally created independent living quarters. Currently, Multi-family housing is permitted with special provisions in all Mixed-Use Districts (either part of a mixed-use development or as a stand-alone use), and in the R2-6 to R2-8, R-3 and R-4 districts as stand-alone developments.

Condominium
A building or group of buildings owned on a proportional basis with a specific benefit of ownership being the right to occupy an individual unit located within the structures. Condominiums are permitted in the R2-6-R28, R-3 and R-4 zones as an accessory use to a permitted use.

Communal Housing
For nonfamily groups with common kitchen and dining facilities but without medical, psychiatric or other care including boardinghouses, lodging houses, dormitories, fraternity/sorority houses, communes, and religious homes. Communal Housing is written as fraternity or sorority and is permitted with conditions in the R-3 and R-4 districts.

Residential/Mixed Use Buildings
The development of a tract of land or building or structure with two or more different uses such as, but not limited to, residential, office, manufacturing, retail, public, or entertainment, in a compact urban form.

Section 3: Housing Constraints, Resources, and Fair Housing 3-28 2021-2029 Housing Element Update - Draft
The City recognizes both Horizontal Mixed-Use and Vertical Mixed-Use. Currently, five Mixed-Use districts exist in the City and allow for a range of housing types. Within Mixed Use zones, housing is permitted as part of mixed use development or as a stand-alone product.

Congregate (Community) Care Facilities
Any facility, place or building where non-medical care and supervision are provided for six or fewer persons (does not include the licensee or members of the licensee's family or persons employed as facility staff). Congregate care facilities are permitted with special requirements in all of the residential districts.

However, per California State law, care facilities for six or fewer persons must be permitted under the same standards as ordinary residential uses.

Boarding/Lodging Houses
A residence or dwelling, other than a hotel, wherein three or more rooms are rented under three or more separate written or oral rental agreements, leases or subleases or combination thereof, whether or not the owner, agent or rental manager resides within the residence. Boarding and Lodging Houses are permitted conditionally in the R-3 and R-4 zones.

Farmworker Housing
The City of Orange currently does not have specific definitions or requirements for farmworker housing.

Convalescent Facility/Hospital
A use providing bed care and in-patient services for persons requiring regular medical attention, and persons aged or infirm unable to care for themselves, excluding surgical or emergency medical services.

A Convalescent Hospital is a facility providing long-term nursing, dietary and other medical services to convalescents or invalids but not providing surgery or primary treatments such as are customarily provided in a hospital. A convalescent hospital must be licensed by the State as such.

Senior Housing and Senior Housing Development
Housing intended and operated for occupancy by persons 55 years of age or older that also meet the following criteria:
 At least 80 percent of the units must have at least one occupant who is 55 years of age or older; and
 The facility or community must publish and adhere to policies and procedures that demonstrate the intent to operate as "55 or older" housing; and
 The facility or community must comply with HUD's regulatory requirements for age verification of residents.

Senior Housing Development is defined the City’s Code as a residential development developed, substantially rehabilitated, or substantially renovated for, qualifying residents that has at least 35 dwelling units and otherwise meets the requirements of Section 51.3 of the California Civil Code.

Section 3: Housing Constraints, Resources, and Fair Housing 3-29 2021-2029 Housing Element Update - Draft
The City of Orange permits Senior Housing in all Residential and Mixed-Use districts and conditionally permits it in all Commercial districts. Senior Housing Developments are conditionally permitted in the R- 3 and R-4 Residential districts, all Mixed-Use districts and OP, CP/C1, CTR, C2, C3 Commercial districts.

Mobile Homes/Manufactured Housing and Mobile Home Parks The Orange Municipal code defines Mobile/Manufactured Homes as a structure designed for human habitation and for being moved on a street or highway under permit. Mobile home includes a manufactured home but, except as provided in subdivision (b) of Section 798.3 of the California Vehicle Code for certain specified trailers and recreational vehicles, does not include a recreational vehicle or a commercial coach or commercial modular. A Mobile home Park is defined as any area or tract of land where two or more lots are rented or leased, held out for rent or lease, or were formerly held out for rent or lease and later converted to a subdivision, cooperative, condominium, or other form of resident ownership, to accommodate manufactured homes or mobile homes used for human habitation. Mobile homes with a permanent foundation are currently permitted in all residential districts and mobile homes without a permanent foundation are only permitted in the MH district.

Guest House
The City of Orange defines Guest Houses as any rented or leased room which is used or designed to provide sleeping accommodations for one or more guests in apartments, hotels, motels, private clubs, lodges, and fraternal organizations. Guest Houses are permitted and considered an accessory use in the Agriculture District.

Accessory Dwelling Units
An attached or detached permanent residential dwelling unit that provides complete independent living facilities for one or more persons and is located on a lot with a proposed or existing primary residence.

An ADU shall be accessory to the primary residence. It shall include permanent provisions for living, sleeping, eating, cooking and sanitation on the same parcel as the single-family or multifamily dwelling is or will be situated and shall include a common living area. The kitchen and common living area shall be of sufficient size to accommodate at least one person per bedroom. An ADU has the attributes of a private residence and not a boarding house or dormitory, e.g. shall not have microwaves, sinks and/or refrigerators in each bedroom; shall not have exterior access to each 2 bedrooms; shall not advertise individual rooms. An accessory dwelling unit also includes the following:

1. An efficiency unit, as provided under Health and Safety Code Section 17958.1; and

2. A manufactured home, as provided under Health and Safety Code Section 18007.

ADUs are limited to properties zoned to allow single-family or multifamily dwellings when the property includes a proposed or existing primary residence in the form of a single-family or multifamily dwelling.

Properties zoned to allow residential uses exclusively as an accessory use, or as a use that is not permanent long-term housing, shall not be eligible for an ADU or JADU unless the property is exclusively developed with a primary, legal-nonconforming, long-term, permanent residential use. JADUs are limited to properties zoned to allow single-family dwellings when the property includes a proposed or existing

Section 3: Housing Constraints, Resources, and Fair Housing 3-30 2021-2029 Housing Element Update - Draft
primary residence in the form of a single-family dwelling. ADUs and JADUs shall be an accessory use only, as defined herein. JADUs shall be located in a portion of a proposed or existing primary residence in the form of a single-family dwelling.

A program is included in the Section 4: Housing Plan to update the Municipal Code to permit ADUs and JADUs in zones which allow residential uses and to update the Section 17.13.030 Permitted Uses table to clarify where ADUs and JADUs are permitted in compliance with State law.

Live/Work Uses
Live/work units are structures or spaces within structures that are used jointly for commercial and residential purposes. Allowed uses include:
 The nonresidential component of a live/work unit shall only be a nonresidential use allowed within a mixed-use zoning district, except that certain uses are determined to be not appropriate within a residential environment and are therefore prohibited as provided below.  The residential component of a live/work unit shall only be a residential use allowed within a mixed-use zoning district.

Additional regulations and standards can be found in the City’s Municipal Code Chapter 17.19.100.

Homeless Shelter
A building that provides immediate and short-term overnight sleeping accommodations for homeless persons or families, with limited onsite supporting services. No person or family may be denied shelter at this facility due to the inability to pay. Temporary shelters established in response to an emergency or disaster (such as flood, fire or cold-weather occurrences), or temporary shelters ancillary to a church use do not fall within this definition. Notwithstanding, these uses shall comply with Federal, State and local regulations as applicable. Homeless Shelters are permitted in the M1 and M2 Industrial districts. The City currently has approximately 967 parcels zoned as M1 and M2 totaling about 968 acres. Of these, approximately 44 parcels over approximately 30.5 acres are currently vacant or underutilized. Homeless shelters are permitted to be developed on both vacant and nonvacant M1 and M2 parcels, with the potential for rehabilitation of existing structures.

These sites are located within close proximity to a number of public transportation stops, including bus routes 153, 59, 42, 46, 50, and 53. Homeless shelters are currently subject to the development standards of the underlying zoning district and the following requirements as established in Section 14.13.040 of the City’s Municipal Code (as of adoption of the 2021-2029 Housing Element):
 Homeless shelters shall be located at least five hundred (500) feet from any residential use or residentially-zoned property, public or private park, or public or private kindergarten through 12th grade curriculum school, as measured from the closest property line. In addition, homeless shelters shall be located at least two hundred seventy-five (275) feet from any other homeless shelter, as measured from the closest property line. Homeless shelters shall be located within ½- mile of a transit stop. As these siting requirements fall outside the scope of allowable standards relating to siting of homeless/emergency shelters per Government Code section 65583,

Section 3: Housing Constraints, Resources, and Fair Housing 3-31 2021-2029 Housing Element Update - Draft
subdivision (a)(4)(A), the City has included Housing Policy Action 4J in the Housing Plan to ensure compliance with State law.
 Overnight occupancy shall be limited to one bed per seventy (70) square feet of sleeping area and shall be in accordance with Building Code requirements. Maximum occupancy per facility shall be limited to one hundred fifty (150) beds or fewer. For purposes of determining maximum occupancy, one shelter client per bed is assumed.
 Services and facilities shall be provided for homeless shelters as follows o A client intake and waiting area shall be provided and shall be adequately sized to accommodate waiting clients. The intake area may be indoors or outdoors. If outdoors, the location shall not be adjacent to the public right-of-way, shall be visually screened, and shall provide protection from the sun/rain.
o The facility shall provide a sleeping area, and separate restrooms and showers for males and females. A minimum of one restroom and one shower for every twenty (20) clients shall be provided, and shall comply with Building Code requirements. o Other on-site services that are permitted include: laundry facilities; kitchen, food preparation, and dining areas; storage areas to secure client belongings; a private area for providing referral services to assist shelter clients in entering programs aimed at obtaining permanent shelter and income; other similar services for homeless clients, as determined by the Community Development Director.
 Prior to occupancy, a written operational plan for the facility shall be submitted to the Community Development Director for approval. If site plan review and/or design review applies, then the operational plan should be submitted and reviewed concurrently with those applications. The operational plan shall contain and comply with the requirements identified in the Section

14.13.040 of the City’s Municipal Code.
 Exterior security lighting shall be provided. Building lighting shall comply with the City's Building Security Ordinance No. 7-79, Section 15.52.090J.2. Parking lots shall be lit in compliance with Section 15.52.090J.3.
 Required Off-street Parking and Bike Racks. One parking space per six beds, plus one space per staff person. Parking stalls shall be striped and bike racks shall be provided as specified in Chapter

17.34.  The facility shall comply with all other laws, rules and regulations that apply, including building and fire codes and shall be subject to City inspections prior to operational plan approval. In addition, the City may inspect the facility at any time for compliance with the facility's operational plan and other applicable laws and standards.
 Minor Site Plan Review Required. Minor site plan review is required if the project meets the criteria established in Section 17.10.060.D or E. The Community Development Director's discretion in requiring conditions of approval and approving homeless shelters under minor site plan review is limited to ensuring that the site plan complies with applicable site design-related standards.
 Design Review Required. Design review is required if the project meets the criteria established in Section 17.10.070. DRC's discretion in requiring conditions of approval and approving homeless

Section 3: Housing Constraints, Resources, and Fair Housing 3-32 2021-2029 Housing Element Update - Draft
shelters is limited to ensuring compliance with applicable design-related standards and guidelines.

Transitional Housing and Supportive Housing
Transitional Housing is defined to be buildings configured as rental housing developments occupied by the state-defined "target population," but operated under program requirements that call for termination of assistance and recirculation of the assisted unit to another eligible program recipient at some predetermined future point in time, which shall be no less than six months. Transitional housing programs typically have specific criteria/thresholds for participation, include onsite staff and supportive services, and facilitate movement of tenants to permanent housing within two years.

Supportive Housing is defined to be buildings configured as rental housing developments with no limit on length of stay, that is occupied by the state-defined "target population," and that is linked to on- or off- site 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. (Ref:

Health and Safety Code § 50675.14(b)) Supportive housing is intended to be permanent housing and is typically rented under legal lease agreements. Typically, on- or off-site supportive services are offered to tenants, but participation is not required to maintain tenancy.

Target population is defined as persons or families who are "homeless," or who are "homeless youth," or persons who are homeless with a disability as that term is defined in State and Federal law.

The City of Orange permits Supportive and Transitional Housing for six persons or fewer in all residential districts. Transitional and Supportive Housing for seven or more persons is conditionally permitted in the R-3 and R-4 districts.

Farmworker Housing
Farmworkers are considered a special needs interest group by HCD. Farmworkers are traditionally defined as people whose primary incomes are earned through permanent or seasonal agricultural labor.

Farmworkers are generally considered to have special housing needs due to their limited income and the often-unstable nature of their employment. In addition, farmworker households tend to have high rates of poverty, live disproportionately in housing that is in the poorest condition, have extremely high rates of overcrowding, and have low homeownership rates. There is a total of 1,772 farmworkers in the County of Orange. Though few may reside in the City of Orange, the City must consider the housing needs of this community. The City of Orange Municipal Code does not explicitly define Farmworker Housing or outline it as a permitted use in residential or nonresidential zones. Section 4: Housing Plan outlines the City’s strategy to update the Municipal Code in accordance with state legislation.

Low Barrier Navigation Centers
AB 101 states that “The Legislature finds and declares that Low Barrier Navigation Center developments are essential tools for alleviating the homelessness crisis -.” Low Barrier Navigation Centers are defined as

Section 3: Housing Constraints, Resources, and Fair Housing 3-33 2021-2029 Housing Element Update - Draft
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 Navigation Centers are required as a use by right in areas zoned for mixed uses and nonresidential zones permitting multi-unit uses if it meets specified requirements. The City has approved 6 Low Barrier Navigation Centers since 2012. Additionally, the City provides financial support for operation of the North County navigation centers in Buena Park and Placentia.

The City of Orange’s Municipal Code does not address Low Barrier Navigations Centers by definition.

Program 4F is included to ensure the City’s development standards allow Low Barrier Navigation Centers by-right in all zones that permit mixed-uses and non-residential uses. Section 4 outlines the City’s strategy to update the Municipal Code in accordance with state legislation.

Emergency Shelters
State Law existing law authorizes a political subdivision to allow persons unable to obtain housing to occupy designated public facilities, as defined, during the period of a shelter crisis. Existing law provides that certain state and local laws, regulations, and ordinances are suspended during a shelter crisis, to the extent that strict compliance would in any way prevent, hinder, or delay the mitigation of the effects of the shelter crisis. The City of Orange permits Emergency shelters in the M1 and M2 zoning districts.

Single-Room Occupancy
As required in California Government Code Section 65583(c)(1), the City of Orange must identify sites which facilitate and encourage the development of a variety of types of housing for all income levels, including single-room occupancy. Currently, the City of Orange does not identify single-room occupancy units as a permitted use in the Municipal code, a program is included In Section 4 to address this.

As defined by HUD, single-room occupancy units can provide affordable housing options for single persons living alone, young professionals, persons looking to transition into permanent housing or seniors looking to age in place in the community. Per HUD regulation, the unit must contain either food preparation or sanitary facilities (and may contain both) if the project consists of new construction, conversion of non- residential space, or reconstruction.

Housing for Persons with Disabilities
Both the Federal Fair Housing Amendment Act (FHAA) and the California Fair Employment and Housing Act direct require governments to make reasonable accommodations (that is, modifications or exceptions) in their zoning laws and other land use regulations to afford disabled persons an equal opportunity to housing. State law also requires cities to analyze potential and actual constraints to the development, maintenance, and improvement of housing for persons with disabilities.

The Housing Element Update must also include programs that remove constraints or provide reasonable accommodations for housing designed for persons with disabilities. The analysis of constraints must

Section 3: Housing Constraints, Resources, and Fair Housing 3-34 2021-2029 Housing Element Update - Draft
touch upon each of three general categories: 1) zoning/land use; 2) permit and processing procedures; and 3) building codes and other factors, including design, location and discrimination, which could limit the availability of housing for disabled persons.

Reasonable Accommodation
Persons with mobility disabilities may require modifications to their living quarters such as access ramps, wider doors and hallways, larger bathrooms, and lowered countertops. The City enforces the California Building Standards Code which provides flexibility in the design of housing for persons with disabilities.

Both the Federal Fair Housing Act and the California Fair Employment and Housing Act require local governments to make reasonable accommodations in their zoning laws and other land use regulations and practices when such accommodations are necessary to afford disabled persons with an equal opportunity to use and enjoy a dwelling.

Reasonable accommodation in the land use and zoning context means providing individuals with disabilities or developers of housing for people with disabilities, flexibility in the application of land use and zoning and building regulations, policies, practices and procedures, or even waiving certain requirements, when it is necessary to eliminate barriers to housing opportunities. For example, it may be reasonable to accommodate requests from persons with disabilities to waive a setback requirement or other standard of the Zoning Ordinance to ensure that homes are accessible for the mobility impaired.

Whether a particular modification is reasonable depends on the circumstances.

The City of Orange has a Reasonable Accommodation Ordinance (17.10.045) which provides a procedure and sets standards for disabled persons seeking a reasonable accommodation in the provision of housing and is intended to comply with federal and state fair housing laws. A reasonable accommodation is defined as relief from the strict application of the City's zoning and land use regulations, policies, and practices when such an accommodation is found to be reasonably necessary to provide an individual with a disability an equal opportunity to use and enjoy a dwelling. An accommodation is not reasonable if: (1) it will fundamentally alter the City's zoning scheme or program; (2) the benefits provided by the accommodation are outweighed by the costs and administrative burden created; or (3) it would create a direct threat to the health and safety of other individuals or physical damage to the property of others.

Any person with a disability, their authorized written representative, or a developer or provider of housing for individuals with a disability may submit a request for a reasonable accommodation. A reasonable accommodation may be approved only for the benefit of one or more individuals with a disability. An application for a reasonable accommodation shall be made on a form provided by the Planning Department and the applicable processing fee (administrative adjustment fee shall apply to determinations of the Director) paid. The application shall include, but not necessarily be limited to the following information:
 Documentation that the applicant is: an individual with a disability; applying on behalf of one or more individuals with a disability; or a developer or provider of housing for one or more individuals with a disability.

Section 3: Housing Constraints, Resources, and Fair Housing 3-35 2021-2029 Housing Element Update - Draft
 The specific exception or modification to the zoning code section, policy or practice that is being requested.
 An explanation that the accommodation requested is necessary to provide one or more individuals with a disability an equal opportunity to use and enjoy the dwelling.  Any other information that the Director reasonably concludes is necessary to determine whether the findings required by this Chapter can be made.

Occupancy Standards
Currently, the Zoning Ordinance defines a “family” as “One or more persons related by blood or legal status or persons not so related who are functioning as a family or single-housekeeping unit, meaning that they have established ties and familiarity with each other, jointly use common areas, interact with each other, share meals, household activities, expenses and responsibilities, membership in the family is fairly stable as opposed to transient and members have some control over who becomes a member of the family.”

California law requires local governments to treat licensed group homes and residential care facilities with six or fewer residents no differently than other by-right single-family housing uses. “Six or fewer persons” does not include the operator, the operator’s family or persons employed as staff. The City must allow these licensed residential care facilities in any area zoned for residential use and may not require licensed residential care facilities for six or less to obtain conditional use permits or variances that are not required of other family dwellings. Currently, the City permits, with special requirements, congregate care facilities in all residential zones, however, the City’s definition of family and restrictions which accompany permitting care facilities in residential zones may produce potential constraints in providing access to care facilities or housing opportunities and may not be in compliance with State law. Section 4 of this Housing Element includes a Housing Policy Action to address the City’s code language and update the term “Family” for compliance with state law.

Development Fees
Residential developers are subject to a variety of fees and exactions to process permits and provide necessary services and facilities as allowed by State law. In general, these development fees can be a constraint to the maintenance, improvement, and development of housing because the additional cost borne by developers contributes to overall increased housing unit cost. However, the fees are necessary to maintain adequate planning services and other public services and facilities in the City. The current fee schedule became effective July 1, 2021 and is summarized in Table 3-7 and available on the City’s website.

Under the fee schedule, the City recovers a portion but not all of the City’s administrative costs for processing development applications. The City’s Development Impact fees, effective July 1, 2019 and remain in effect Until June 30, 2020, are summarized in Table 3-8.

The development fees associated with each project is dependent on the housing type, density, intensity of use, and location. In addition to these direct fees, the total cost of entitlement processing is contingent on the project meeting the City’s policies and standards, as well as the project applicant submitting

Section 3: Housing Constraints, Resources, and Fair Housing 3-36 2021-2029 Housing Element Update - Draft
necessary documents and plans in a timely manner. An applicant may also request to have fees waived by the City Council.

The estimated total development and impact fees for a typical single-family residential project, assuming it is not part of a subdivision and is consistent with existing city policies and regulations, can range from $22,090 to $27,090. Estimated total development and impact fees for a typical multi-family residential project with ten units, assuming it is consistent with existing city policies and regulations range from $81,913 to $86,913.

These estimates are illustrative in nature and that actual costs are contingent upon unique circumstance inherent in individual development project applications. Considering the cost of land in Orange, and the International Code Council (ICC) estimates for cost of labor and materials, the combined costs of permits and fees range from approximately 3.79% percent to 4.65% percent of the direct cost of development for a single-family residential project and 1.62% percent to 1.72% percent for a multi-family residential project. Direct costs do not include, landscaping, connection fees, on/off-site improvements, shell construction or amenities, therefore the percentage of development and impact fees charged by the City may be smaller if all direct and indirect costs are included.

Table 3-7: Planning and Land Use Fees (2021 Fee Schedule) Type Fee Type Fee
Sober Living Permit Fee $2,079.00

Major Site Plan Review $15,000.00
Mills Act Program Original
Application Fee $1,000.00 Tentative Tract Map $2,000.00 Mills Act Program
Inspection/ Annual Report $30.00 Zone Change Applications $10,000.00 Zone Clearance, Over the
Counter Review $41.00 Negative Declaration $6,000.00
Staff research, information
requests - per hour $116.00 Mitigation Monitoring $3,000.00 Temporary Use Permit
(recurring) $369.00 General Plan Amendment $10,000.00
Temporary Use Permit (non-
recurring uses) $791.00 Environmental Impact Report $10,000.00 Zoning Verification Letter $316.00 Appeals to City Council or Planning Commission $1,000.00
Administrative Design
Review $500.00
Planning Commission
Modification to CUP, Major
Site Plan or Variance
$3,000.00
Design Review, Historic
Districts Residential $1,500.00 Minor Site Plan Review - Staff $1,000.00 Signs and Sign Programs $500.00 Pre-Application Review $500.00 Design Review, Outside
Historic Districts $1,500.00 Administrative Adjustments $1,000.00 CUP / Variance - Zoning $3,000.00 Time Extension $1,000.00

Section 3: Housing Constraints, Resources, and Fair Housing 3-37 2021-2029 Housing Element Update - Draft
Table 3-7: Planning and Land Use Fees (2021 Fee Schedule) Type Fee Type Fee
CUP / Variance - Planning
Commission $3,000.00
Source: City of Orange, Master Schedule of Fees, Updated 7/1/2021.

Table 3-8: Engineering and Development Services Fees (2021 Fee Schedule) Type Fee Type Fee
Lot Line Adjustment $1,956.00

Utility Lateral for house
connection on residential streets $760.00
Certificate of Compliance $1,956.00 Fire Service Connection $1,444.00 Certificate of Correction / Amended
Map $1,956.00 Flood Zone Written Notice $268.00
Process Grading Application $225.00 Street Addressing $583.00 Encroachment Permits Summary Abandonment $1,416.00
Process Encroachment Application $201.00 Full Abandonment $1,416.00 Driveways - non-arterial $416.00 Quit Claims $1,416.00
Driveways - arterial $873.00 Simple Research & CD Prep $152.00 Sidewalk $404.00 Map Sheets $118.00
Street work / Trench Repair Sewer Frontage Charges - per l.f. $128.00 0-100 feet $697.00 Tract Development $10,000.00
101-300 feet $988.00 Tract or Parcel Map (Map Only) $2,000.00 301-500 feet $1,586.00
Non-Priority Water Quality
Management Plan (WQMP)
Review
$500.00
501-1000 feet $2,275.00
Priority Water Quality
Management Plan (WQMP)
Review
$1,000.00
1,001-1,500 feet $2,838.00 Grading Plan Review & Inspection $3,000.00 1,501-2,000 feet $3,307.00
Large Encroachment Projects or
Street work / Trenchwork 2,001 ft.
or greater
$5,000.00
Minor Encroachment Permit $289.00 Extensive Research $500.00 Source: City of Orange, Master Schedule of Fees, Updated 7/1/2021.

Development Impact Fees
In addition to City fees charged at the time building permits are issued, developers are required to pay a number of impact fees (shown in Table 3.9), including the following.

Transportation System Improvement Programs Fee
The Transportation System Improvement Programs Fee provides for the construction of the traffic circulation system improvements identified by the City Council and made necessary by increased transportation demands in the City. The fees charged are dependent on geographic locations and the fees

Section 3: Housing Constraints, Resources, and Fair Housing 3-38 2021-2029 Housing Element Update - Draft
collected for pre-identified improvements must be used in the respective geographic regions. Regions (geographic indicators) include the following:
 Area A – Bound by Chapman to the north, Town and Country Road to the south, Flower Street to the west, and Montgomery Place to the East
 Area B – Bound by the Santa Ana River to the north and northwest, reaching Lewis Street to the west, bound by State Route 55 to the east, and State Route 22 to the south.  Area C – Bound by the north Orange border adjacent to the City of Anaheim to the north, east Orange border to the east, Fairhaven Avenue to the south, and State Route 55 to the west.

Fees based on the geographic regions above are displayed in Table 3-9.

Table 3-9: Transportation System Improvement Program Fees (Residential Only) Development Type Area A Fee Area B Fee Area C Fee
Single-Family; Condo & Townhome
Residential (per unit)
$817.00 $1,445.00 $804.00
Residential – Apartments (per unit) $712.00 $1,015.00 $564.00 Foothill/Eastern Transportation Corridor Agency (Zone B – 55 to Weir Canyon Road) Development Type Fee
Single Family Dwelling (per unit) $1,260.72
Multi-Family, Apts. /Condos (per unit) $867.88
Source: City of Orange Development Fee Schedule, July 1, 2021.

Capital Facilities Capacity Charges (Residential)
Capital Facilities Capacity charges are categorized housing type (single-family and multi-family) and number of bedrooms per unit. The base charges for residential developments are displayed in Table 3-10.

Table 3-10: Capital Facilities Capacity Charges (Residential) Single Family Residential Base Charge
5+ Bedrooms $6,395.00
4 Bedrooms $5,475.00
3 Bedrooms $4,601.00
2 Bedrooms $3,727.00
1 Bedroom $2,852.00
Multi-Family Residential Base Charge
4+ Bedrooms $4,969.00
3 Bedrooms $4,095.00
2 Bedrooms $3,221.00
1 Bedroom $2,300.00
Studio $1,472.00
Source: City of Orange Development Fee Schedule, July 1, 2019.

Historically, where a single-family unit has an accessory dwelling structure/unit that connect to the sewer, the non-residential average demand base rate of $2,078.00 per 1,000 square feet has applied. As of May

Section 3: Housing Constraints, Resources, and Fair Housing 3-39 2021-2029 Housing Element Update - Draft
21, 2021, the Orange County Sewer District (OCSD) is not collecting sewer fees for ADUs smaller than 1,200 square feet. The maximum size for an ADU permitted by the City of Orange’s ordinance is 1,000 square feet, so sewer fees currently do not apply to ADUs within the City of Orange.

Additionally, live/work units will be charges at both the residential rate for the living quarters and at the nonresidential rate for the work portion square footage. The City continues to evaluate these fees. These are subject to change and the City will provide updated fees to the public if they change.

Park Infill Fee and Park Dedication and In-Lieu Fee
Park Dedication and In-lieu fees are required for residential subdivision developments only and Park Dedication and In-lieu Fees provide for residential development projects to finance the cost of park facilities and improvements required by new residential development. The fees are described below in Table 3-11.

Table 3-11: Park Dedication and In-Lieu Fees (Residential) District 1 District 2
Density Classification
(Dwelling Units/Gross Acre)
Density Classification
(Dwelling Units/Gross Acre)
< or equal to 6 du/ga $7,994.00/unit < or equal to 6 du/ga $8,894.00/unit > 6 to < or equal to 15 du/ga $9,434.00/unit > 6 to < or equal to 15 du/ga $10,469.00/unit >15 du/ga $9,506.00/unit >15 du/ga $10,546.00/unit
Source: City of Orange Development Fee Schedule, July 1, 2019.

Public Service Development Impact Fees
Additional Public Service Impact Fees include library facilities impact fees, fire and police protection impact fees and school impact fees. The library facilitates development impact fee provides for new library facilities and other capital acquisition costs required, incrementally, by new residential development within the City. According to the Annual Financial Report for development impact fees for the fiscal year 2018 to 2019, the library facilities impact fee provided a total of $294,662 in revenue.

Table 3-12: Library Facilities Development Impact Fees (Residential) Citywide
Density Classification (Dwelling Units/Gross Acre)
< or equal to 6 du/ga $742.52/unit
> 6 to < or equal to 15 du/ga $769.30/unit
>15 du/ga $642.71/unit
Source: City of Orange Development Fee Schedule, July 1, 2019.

Section 3: Housing Constraints, Resources, and Fair Housing 3-40 2021-2029 Housing Element Update - Draft
Table 3-13: Fire and Police Protection Facility Fee (Residential) Land Use Fee
Detached Residential $1,200.00/unit
Attached Residential $601.00/unit
College University Dorm $971.00/unit
Group Congregate Units $2,306.00/unit
Commercial Lodging $955.00/unit
Single Family Dwelling $354.89/unit
Source: City of Orange Development Fee Schedule, July 1, 2019.

Code and Fee Transparency
California Government Code Section 659401(a)(1) requires that every city or county make information regarding development processing applications, regulations, and fees readily available to the public. All such information is readily available to potential applicants, property owners, and the general public on the City of Orange website. The website is regularly maintained, and information is updated as needed.

On-/Off-Site Improvements
Site improvements in the City consist of those typically associated with development for on-site improvements (fronting streets, curbs, gutters, sewer/water, and sidewalks), and off-site improvements (drainage, parks, traffic, schools, and sewer/water). Residential developments utilize the following standards for local streets found in the 2010 General Plan Circulation and Mobility Element:
 Collector Streets- 66 feet right of way (46 feet pavement width)  Secondary Arterial Highways- 86 feet right of way (70 feet pavement width)  Primary Arterial Highways- 100 feet right of way (84 feet pavement width)  Major Arterial Highways- 120 feet right of way (104 feet pavement width)  Principal Arterial Highways and Smart Streets- 134 to 144 feet right of way (118 feet  pavement width)

Payment in Lieu of Making Public Infrastructure Improvements Normally, the owner, lessee or agent of the property will post the required security for the public infrastructure improvements, obtain the building permit and then proceed with making the improvements as the construction project for which the building permit was issued progresses. When the construction project is completed, and the improvements are done and accepted by the City, the security is then released. There is an exception to this procedure, however, which requires full payment of the estimated cost of the improvements instead.

The Director of Public Works may require full payment of the estimated cost of the public infrastructure improvements when he has determined that the safe and orderly development of the adjacent street can be accomplished best when the public infrastructure improvements for more than just one lot are made or when allowing individual owners to make the public infrastructure improvements as single lots are developed may create unsafe traffic, drainage or other problems.

Section 3: Housing Constraints, Resources, and Fair Housing 3-41 2021-2029 Housing Element Update - Draft
In that case, the owner, lessee or agent of the property shall make full payment of the estimated cost of the improvements to the City, which payment shall be maintained in a separate fund. When the improvements can be made safely, the City will cause the improvements to be made, financed in whole or in part with the money received from the various owners who have contributed to that fund. When an owner, lessee or agent of the property pays the estimated cost of improvements in full, he or his heirs, assigns and successors in interest to the property shall not be required to make additional payments to accomplish the same improvements.

Building Codes and Enforcement
The City of Orange’s construction codes are based upon the California Code of Regulations, Title 24 (Building, Plumbing, Mechanical, Electrical and Housing Codes) and are considered to be the minimum necessary to protect the public health, safety and welfare of the City’s residents. In compliance with State law, the California Building Standards Code is revised and updated every three (3) years. The newest edition of the California Building Standards Code is the 2019 edition with an effective date of January 1, 2020. The City of Orange is required by State law to enforce the new code.

All existing approved tract plans will expire and become null and void at 180 days from the date of enforcement (January 1, 2020) for the new 2019 California Codes, which will be July 1, 2020, or unless otherwise expired in accordance with other provisions of the codes. All tract plans will need to be updated to comply with the new 2019 CBSC and submitted for a new plan check. The Chief Building Official may extend the time for action by the applicant for a period not exceeding 180 days on request by the applicant showing circumstances beyond control of the applicant that prevented action from being taken (January 1, 2020). No building permit application shall be extended more than once (CBC Section 106.4.4).

Code enforcement is conducted by the City and is based on systematic enforcement in areas of concern and on a complaint basis throughout the city. The Code Compliance Division of the Community Development Department works with property owners and renters to assist in meeting state health and safety codes. The Code Compliance Division investigates complaints regarding violations of the Orange Municipal Codes. The City’s caseload is complaint-based, and deals with issues such as inoperable vehicles, poor property maintenance, debris accumulation, and inappropriate storage of vehicles or materials with the intention and goal of working with the community to help resolve issues through voluntary compliance.

Local Processing and Permit Procedures
The processing time for entitlement applications and permits varies in Orange based upon the scope and type of project and the applicant’s compliance with the City’s ordinances and completeness of applications. Certain types of applications/permits are discretionary and require a public hearing, while others are processed administratively. For a typical single-family residence, permit processing time can take around 3-5 months for staff-level review of Administrative Design Review and around 3 months for Building plan check and permit issuance. For a typical multi-family project on a site that has a General Plan

Section 3: Housing Constraints, Resources, and Fair Housing 3-42 2021-2029 Housing Element Update - Draft
Land Use and Zoning that allow multi-family developments, Planning review and entitlement can take around 6 to 8 months and 5 to 6 months for Building plan check and permit issuance. The process for projects requiring administrative review is outlined below. 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 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).

Given the review period for each step of the review process is in compliance with State law requirements, the City’s permit review process is not found to be a constraint to the development of housing, nor does it impact the cost of development.

Development Agreements
The Community Development Director shall prescribe the form of each application, notice and documents provided for or required under this chapter for the preparation, processing and implementation of development agreements. The following sections outlines the process for development agreements within the City. Projects within Orange do not frequently involve development agreements.

Filing and Review of Application
The application and proposed development agreement are forwarded to the Community Development Director and a staff review committee as designated by the City Manager. The Director and staff then review the application and determine the additional requirements necessary to complete the agreement.

The Director may reject the application if it is not completed in the manner required by this chapter. After receiving the required information, the Director prepares a staff report which analyzes the proposed development and contains a recommendation as to whether or not the development agreement proposed, or in an amended form, would be consistent with the general plan or any applicable specific plan.

Notice of Intention
Upon completion of the staff report, in addition to any other notice required by law, the Director gives notice of intention to consider adoption of a development agreement. The notice shall contain:
 The time and place of the public hearing before the Planning Commission;

Section 3: Housing Constraints, Resources, and Fair Housing 3-43 2021-2029 Housing Element Update - Draft
 A general explanation of the development agreement, including a general description of the property proposed to be developed.

Hearing and Recommendation of Planning Commission and Decision by City Council The Planning Commission must make its recommendation to the City Council in writing within thirty (30) days of the public hearing. After the recommendation of the Planning Commission, the City Council completes the public hearing and considers any recommendation of the Planning Commission, the Council may accept, modify, or deny the proposed development agreement. The development agreement may not be approved unless the City Council finds that the development agreement is consistent with the General Plan and any applicable specific plan.

Site Plan Review
The site plan review process provides a process to review development projects to ensure that projects reflect the highest quality of land planning and design, that projects conform to City development standards, that new projects are compatible with surrounding development and neighborhoods in terms of scale, style and construction materials, that on and off-site circulation is adequate to support the project; that City services are adequate and available, and to ensure the maintenance, restoration, enhancement and protection of the environment. Site plan review is a common step in entitlement of residential development projects.

Site plan review is required for the following:
 Any new use of previously vacant land
 New construction
 Rehabilitation or expansion of existing structures in all zones  It is not required for single family residence or rehabilitation of existing single-family residence

In addition to project review for compliance with the development standards of the underlying zoning district and other applicable ordinance provisions, site plan review will include review of those development qualities which are not subject to precise definition in the regulations of each zone. The following criteria are listed to illustrate the issues to be considered by the Community Development Director and/or Planning Commission in project review and determination:
 Compatibility of the project with surrounding development and neighborhoods  Building/Site planning issues
 Circulation/Traffic safety, on and off-Site
 City Services
 Environmental Protection - All projects shall be evaluated in accordance with the provisions of the California Environmental Quality Act

The following findings may be made after site plan review:
 That the project design is compatible with surrounding development and neighborhoods.

Section 3: Housing Constraints, Resources, and Fair Housing 3-44 2021-2029 Housing Element Update - Draft
 That the project conforms to City development standards and any applicable special design guidelines or specific plan requirements.
 That the project provides for safe and adequate vehicular and pedestrian circulation, both on- and off-site.
 That City services are available and adequate to serve the project.  That the project has been designed to fully mitigate or substantially minimize adverse environmental effects.

Design Review
The design review process provides a means of reviewing development projects to ensure that these projects are compatible with community aesthetics including architectural design, massing and scale, context, color palette, signage and landscaping. The design review process serves a primary role in the implementation of adopted design standards. The City's design objective is to enhance the community character and identity of the City by promoting diversity, creativity and cohesiveness in the development of property, building structures, site relationships and landscape through quality design. Design review is required for all projects listed below:
 Development projects requiring Planning Commission or City Council approval  Any project requiring major site plan review.
 All projects within Old Towne or other historic districts as established, except where otherwise exempted by adopted design standards and/or adopted specific plan  External remodeling of commercial, industrial, institutional and large scale multiple family developments, except where otherwise exempted by City codes, including adopted design standards and/or adopted specific plans.
 Projects subject to Minor Site Plan Review that also involve exterior remodeling of residential, commercial, industrial, and institutional development that is visible from the public right-of-way.

The design review requires projects have an internally consistent, integrated design theme which is reflected in the following elements:
 Architectural Features
o The architectural features shall reflect a similar design style or period. o Creative building elements and identifying features should be used to create a high quality project with visual interest and an architectural style.  Landscape
o The type, size and location of landscape materials shall support the projects overall design concept.
o Landscaping shall not obstruct visibility of required addressing, nor shall it obstruct the vision of motorists or pedestrians in proximity to the site. o Landscape areas shall be provided in and around parking lots to break up the appearance of large expanses of hardscape.
 Signage

Section 3: Housing Constraints, Resources, and Fair Housing 3-45 2021-2029 Housing Element Update - Draft
o All signage shall be compatible with the building(s) design, scale, colors, materials and lighting.
 Secondary Functional and Accessory Features.
o Trash receptacles, storage and loading areas, transformers and mechanical equipment shall be screened in a manner which is architecturally compatible with the principal building(s).

The administrative design review process is established to allow for a simplified review process for specific types of new development, exterior building alterations, and sign modifications which the City anticipates will not adversely affect surrounding properties. The following types of projects are eligible for Administrative Design Review:
 Projects subject to Minor Site Plan Review that also involve exterior remodeling of residential, commercial, industrial, and institutional development that is not visible from the public right-of- way.
 Projects that involve exterior remodeling of an individual free-standing commercial, industrial, or institutional building on an individual parcel that is not part of a larger center or campus, including changes in exterior building material, roof form, and window or door openings.  Infill residential development as specified in the City of Orange Infill Residential Design Guidelines.  Modifications to existing sign programs that involve changes in color, font style, height, width, method of illumination or sign area that are otherwise in compliance with the provisions of Section 17.36.

The Design Review Committee makes a recommendation or final determination as authorized by Section

17.08.020(D) of the Orange Zoning Ordinance to approve, approve with conditions or deny a project at a public meeting. The reviewing body shall make findings for all projects based upon design criteria stated above. A specific finding shall be made for projects as follows:
 In the Old Town Historic District, the proposed work conforms to the prescriptive standards and design criteria referenced and/or recommended by the Design Review Committee or other reviewing body for the project.
 In any National Register Historic District, the proposed work complies with the Secretary of the Interior's standards and guidelines.
 The project design upholds community aesthetics through the use of an internally consistent, integrated design theme and is consistent with all adopted specific plans, applicable design standards and their required findings.
 For infill residential development, as specified in the City of Orange infill residential design guidelines, the new structure(s) or addition are compatible with the scale, massing, orientation, and articulation of the surrounding development and will preserve or enhance existing neighborhood character.

Section 3: Housing Constraints, Resources, and Fair Housing 3-46 2021-2029 Housing Element Update - Draft
The City has analyzed the required findings listed above applicable to residential project for problematic or potential unclear language which may present a constraint to the development of housing. The City a streamlined set of findings for both the Site Plan Review and Design Review processes and the processes and expectations are clearly outlined. Furthermore, the City conducts pre-application meetings with applicants to walk through the entitlement process and explain the required findings. City Staff has printed and online materials to give guidance on how to navigate the entitlement process for residential projects and is available during business hours at the counter to provide assistance. City Staff communicates expectations to applicants so that they may be fully aware of the requirements and findings which need to be met for different types of residential projects. Within the planning period, the City has not denied any projects on the basis of not being able to meet the current findings for either Site Plan Review or Design Review.

While the current findings and processes do not present a constraint, the City has included Housing Policy Actions 2E and 2L in Section 4: Housing Plan to evaluate processing procedures and review the feasibility of additional regulatory relief – such as adopting objective development standards.

Senate Bill 35
California Senate Bill 35 (SB 35), codified at Government Code Section 65913.41, was signed on September 29, 2017, and became effective January 1, 2018. SB 35 will automatically sunset on January 1, 2026 (Section 65913.4(m)). The intent of SB 35 is to expedite and facilitate construction of affordable housing. SB 35 applies to cities and counties that have not made sufficient progress toward meeting their affordable housing goals for above moderate- and lower-income levels as mandated by the State. In an effort to meet the affordable housing goals, SB 35 requires cities and counties to streamline the review and approval of certain qualifying affordable housing projects through a ministerial process.

A project must meet the following criteria to be eligible for SB 35 approval:
 A multifamily housing development (at least two residential units) in an urbanized area, an urban cluster, or on a legal parcel(s) within the boundaries of an urbanized area or urban cluster;
 Located where 75% of the perimeter of the site is developed;  Zoned or designated by the general plan for residential or mixed use residential, with at least two-thirds of the square footage of the development designated for residential use;  In a location where the locality’s share of regional housing needs have not be satisfied by building permits previously issued;
 One that includes affordable housing in accordance with SB 35 requirements; and  Consistent with the local government’s objective zoning and design review standards.

A project does not qualify for SB 35 streamline processing if:
 A coastal zone, conservation lands, or habitat for protected species;  Prime farmland or farmland of statewide importance;
 Wetlands or lands under conservation easement;
 A very high fire hazard severity zone;
 Hazardous waste site;

Section 3: Housing Constraints, Resources, and Fair Housing 3-47 2021-2029 Housing Element Update - Draft
 Earthquake fault zone;
 Flood plain or floodway;
 Lands identified for conservation in an adopted natural community conservation plan;  Habitat for protected species;
 Land under conservation easement;
 A site with existing multi-family housing that has been occupied by tenants in the last ten years or is subject to rent control;
 A site with existing affordable housing; or
 The development would require the demolition of a historic structure.

According to HCD’s 2021 SB 35 Statewide Determination Summary, the City of Orange has not made sufficient progress towards its Lower Income RHNA and is therefore subject to streamlined ministerial approval process (SB 35 (Chapter 366, Statutes of 2017) streamlining) for proposed developments with at least 50 percent affordability. The City is subject to streamlined ministerial approval review for proposed developments with at least 50 percent affordability.

State Policies and Regulations
State policies and regulations may also serve to constrain housing development in local communities.

Environmental Protection
State regulations require environmental review of proposed discretionary projects (e.g., subdivision maps, use permits, etc.). Costs resulting from fees charged by local government and private consultants needed to complete the environmental analysis, and from delays caused by the mandated public review periods, are also added to the cost of housing. However, the presence of these regulations helps preserve the environment and ensure environmental safety to Orange residents.

C. Infrastructure Constraints
Another factor that could constrain new residential construction is the requirement and cost to provide adequate infrastructure (major and local streets; water and sewer lines; and street lighting) needed to serve new residential development. In most cases, where new infrastructure is required, it is funded by the developer and then dedicated to the City, which is then responsible for its maintenance. Because the cost of these facilities is generally borne by developers, it increases the cost of new construction, with much of that increased cost often “passed on” in as part of home rental or sales rates.

Dry Utilities
Dry utilities are the installation of the electric, telephone, TV, internet, and gas in a community. Of the utilities, the City must plan to provide the necessary resources, such as electric and gas, to new housing units.

Dry utilities in Orange are serviced by contracted private agencies, including Southern California Edison Company, Southern California Gas Company, AT&T, Time Warner Cable and Cox Communications Orange County.

Section 3: Housing Constraints, Resources, and Fair Housing 3-48 2021-2029 Housing Element Update - Draft
Electricity
Southern California Edison (SCE), an independently owned utility, provides electrical power service to the Orange planning area. SCE distributes electricity purchased through the California Power Exchange, which is the electricity marketplace for about 80 percent of California’s electricity customers. SCE is regulated by the California Public Utilities Commission (CPUC) and the Federal Energy Regulatory Commission (FERC) and includes 50,000 square miles of SCE service area across Central, Coastal, and Southern California.

In order to meet future energy needs, SCE has developed several energy-efficiency programs for residential, non-residential, new construction, and low-income subscribers. These include rebate and cash incentive programs for completion of energy-efficiency projects in residences and businesses, providing energy-efficient solutions for new developments as well as programs that aid low-income customers to purchase energy-efficient refrigerators and outdoor lighting. The City supports these strategies by SCE to encourage energy conservation, and applies the Green Building Code.1 Natural Gas
The Southern California Gas Company (The Gas Company) supplies natural gas to both businesses and residents within the Orange planning area. The SoCal Gas 2020 utility report projects total gas demand to decline at an annual rate of 1 percent from 2020-2035. From 2020-2035, residential demand is expected to decline from 230 Bcf to 198 Bcf. The decline is approximately 1 percent per year, on average. The decline is due to declining use per meter—primarily driven by very aggressive energy efficiency goals and associated programs— offsetting new meter growth.2

SoCalGas engages in several energy efficiency and conservation programs designed to help customers identify and implement ways to benefit environmentally and financially from energy efficiency investments. Programs administered by SoCalGas include services that help customers evaluate their energy efficiency options and adopt recommended solutions, as well as simple equipment-retrofit improvements, such as rebates for new hot water heaters.

Water Supply and Wastewater Capacity
The Water Division of the City of Orange’s Public Works Department is responsible for providing a clean, safe, potable water supply to the City of Orange. The Division designs, constructs, and maintains wells, water lines, booster pumps, and reservoirs that serve the residents and businesses with water for domestic use and for fire protection.

Water Supply
According to the City’s 2015 Urban Water Management Plan (UWMP), the City of Orange obtains approximately 75 percent of its water from ground water sources via 12 active wells. The ground water basin is managed by the Orange County Water District. The City of Orange also imports water from

1 City of Orange Infrastructure Chapter, General Plan.
2 SoCal Gas 2020 California Gas report, Prepared in Compliance with California Public Utilities Commission Decision D .95-01-039

Section 3: Housing Constraints, Resources, and Fair Housing 3-49 2021-2029 Housing Element Update - Draft
the Colorado River and Northern California from the Metropolitan Water District of Southern California (Metropolitan) through the Municipal Water District of Orange County.

Historically, local groundwater has been the cheapest and most reliable source of supply for the City. The City currently relies on approximately 20,623 acres feet per year (AFY) of groundwater from the OC Basin.

The City supplements its local groundwater with imported water purchased from Metropolitan through MWDOC. Imported water represents approximately 30 percent of the City’s total water supply.

Supply Reliability
The City’s UWMP assesses the reliability of water service to customers under normal, dry, and multiple dry water years. The City depends on a combination of imported and local supplies to meet its water demands and has taken multiple steps to ensure it has adequate supplies. Increased residential and commercial development of can augment the reliability of the imported water system. There are various factors that may impact reliability of supplies such as legal, environmental, water quality and climatic which are discussed below. The water supplies are projected to meet full-service demands; Metropolitan’s 2015 UWMP finds that Metropolitan is able to meet, full-service demands of its member agencies starting 2020 through 2040 during normal years, single dry year, and multiple dry years.

The City meters all service customer connections and bills its customers bi-monthly based on water consumption. The City has a meter replacement and calibration program and plans to implement radio read metering.

Wastewater Capacity
The City operates and maintains 308 miles of local sewer collection pipes that feed into the Orange County Sanitation District's (OCSD) trunk sewer system to convey wastewater to OCSD's treatment plants. OCSD has an extensive system of gravity flow sewers, pump stations, and pressurized sewers. OCSD’s Plant No. 1 in Fountain Valley has a capacity of 320 million gallons per day (MGD) and Plant No. 2 in Huntington Beach has a capacity of 312 MGD. Both plants share a common ocean outfall, but Plant No. 1 currently provides all of its secondary treated wastewater to OCWD’s Groundwater Replenishment System (GWRS) for beneficial reuse.

Fire and Emergency Services
The City of Orange’s Fire Department aims to prevent or minimize the loss of life, damage to the environment, and loss of property from fire, medical emergencies, and hazardous conditions. Beyond fire suppression, public safety, and emergency medical services, the department offers a Fire Explorer program, smoke detector installation, and public education.

Fire Prevention
The first priority of the Fire Prevention Section of the Orange City Fire Department is to prevent loss of life and property, and to prevent damage to the environment. The second goal is to build safety into buildings and processes, in order to contain or limit the spread of a potential emergency.

Section 3: Housing Constraints, Resources, and Fair Housing 3-50 2021-2029 Housing Element Update - Draft
The activities of the Fire Prevention Section can be classed into 1) Environmental Safety and 2) Fire and Life Safety. Environmental Safety encompasses vegetation management, hazardous materials disclosure, and underground storage tanks. Fire and Life Safety includes planning and development, annual occupancy inspections, special events permitting, and fire cause investigation.

In addition to responding to urban fires, the department also responds to wildfire and provides education and safety plans for the community in the event of a wildfire.

Emergency Operations
The Emergency Operation Section prepares for and responds to emergencies of all types. In addition to planning and training for emergency responses, the Section also works to ensure sufficient facilities, fire vehicles, equipment and other infrastructure are acquired and maintained before they are needed for emergency incidents.

Three battalion chiefs report to the Operations Deputy Chief. They command three shifts of 35 emergency responders who are on duty around the clock. The battalion chiefs spend the bulk of their time working on special projects to plan for emergencies. All three battalion chiefs lead departmental committees and other efforts related to emergency preparedness and response.

According the Departments annual reports, in 2018, Orange City Fire Department responded to over 15,500 calls for service for the third year running and responded to over 16,000 for 2019. The departments have an extensive network, and preparedness, therefore, it is not anticipated that any new fire or emergency facilities would be required as a result of new development. Additionally, any new developments would be provided full services by one of the department’s eight districts with a station.

Police Services
The City of Orange Police Department is in charge of police services for all areas within the City boundary.

The department’s jurisdiction covers nearly 27 square miles and is bordered by Santa Ana, Garden Grove, Anaheim, Tustin, and unincorporated County areas. The Police Department handles a variety of public services through different divisions. The department’s mission is to perform law enforcement duties with innovative leadership, accountable to the residents of Orange, in order to ensure their safety and improve the quality of life in a diverse community. The Supportive Services Division provides personnel, training, fiscal affairs, crime prevention, and facility maintenance functions.

The Investigative Services Division investigates and prepares cases for a successful prosecution by the Orange County District Attorney's Office. Each unit focuses on specific types of crimes. The Field Services Division consists of uniformed personnel who are primary responders when the department receives calls for service. There are several specialized units, including the Bike Team, Canine Unit, Homeless Engagement Assistance and Resource Team (HEART), SWAT Team, and Traffic Bureau.

Section 3: Housing Constraints, Resources, and Fair Housing 3-51 2021-2029 Housing Element Update - Draft
The department has an extensive network, and preparedness, therefore, it is not anticipated that any new police facilities would be required as a result of new development. Any new developments would be provided full services in any part of Orange.

D. Environmental Constraints
Geologic and Seismic Hazards
The most significant environmental hazards that may affect land use in Orange are seismic and geologic hazards. Earthquakes and their related effects have the greatest potential to affect a large portion of the population. Other geologic hazards such as landslides and ground subsidence could have more localized effects. The combination of sound planning practices and continued public education will minimize risks to the community from seismic and geologic hazards, and will protect the health, safety, and welfare of Orange residents.

Flooding
Portions of Orange are susceptible to flood events from either a major storm or a dam failure resulting from a significant earthquake. Dams are present along Santiago Creek at two locations: Villa Park Dam and Santiago Dam (Irvine Lake). Both are located in the foothills of east Orange. Peters Canyon Dam is located within Peters Canyon about two miles west of Irvine Lake. Unlike Santiago Creek, which flows generally northwest, Peters Canyon drains to the south in this area. Prado Dam is located in Corona, approximately seven miles northeast of the eastern portions of the planning area. Areas downstream from these dams, including large areas within the City of Orange, have high potential for inundation in the unlikely event of catastrophic dam failure (maps showing dam inundation areas are available for public review at the Community Development Department). These dams and their reservoirs prevent periodic flooding that would be expected to occur in a natural setting. Recognizing and preparing for floods allows the community to avoid associated dangers.

Section 3: Housing Constraints, Resources, and Fair Housing 3-52 2021-2029 Housing Element Update - Draft
Housing Resources
E. Regional Housing Needs Allocation
This section of the Housing Element provides an overview of the resources available to the City to meet its Regional Housing Needs Allocation (RHNA).

Residential Sites Inventory
Appendix B of the Housing Element includes the required site analysis and site information for the parcels identified to accommodate the City’s RHNA need through the 2021-2029 planning period. The following discussions summarize the City’s site inventory, including the City’s past experience in redeveloping non- vacant sites and sites within non-residential zones. Sites with these characteristics comprise the majority of Orange’s site analysis strategy.

The City of Orange has identified sites currently zoned for residential and mixed-use which can accommodate its 6th cycle RHNA need.

Above Moderate and Moderate Income Sites
For the 2021-2029 planning period, the City’s RHNA allocation is 677 for moderate income units and 1,588 for above moderate-income units. The City anticipates the ability to meet the moderate and above moderate income housing unit need through a mixture of existing residentially zoned areas as well as some of the mixed use areas within the community. Furthermore, approximately 103 accessory dwelling units (ADUs) are anticipated to be developed within the moderate and above moderate income RHNA categories.

ANALYSIS OF THE CITY’S EXISTING CAPACITY AND ZONING
The Housing Element must demonstrate the City’s ability to accommodate the RHNA either through production or the availability of properly zoned land that can accommodate additional growth. The City of Orange is able to accommodate all of its moderate and above moderate income RHNA need through available land with existing zoning classifications that permit residential as a primary use, as well as through the anticipated development of accessory dwelling units.

Appendix B in this document contains a list and description of the sites designated to meet the City’s moderate and above-moderate need. Table 3-14 below summarizes the capacity of the sites by current zoning classification which can accommodate 732 moderate income and 1,777 above moderate-income dwelling units. In conjunction with ADU development, these amounts exceed the City’s 2021-2029 RHNA allocation as shown in Table 3-17.

Section 3: Housing Constraints, Resources, and Fair Housing 3-53 2021-2029 Housing Element Update - Draft
Table 3-14: Residential Capacity for Moderate and Above Moderate Income Sites Max Density
du/acre
Reasonable
Density
du/acre
Number of
Parcels Acreage Potential Units
Above Moderate Income Sites
R-1-7 8 6 2 13.57 81
UMU 60 55 15 40.88 1,696
Subtotal -- -- 17 54.45 1,777
Moderate Income Sites
NMU-24 24 16.3 9 7.28 114
UMU 60 55 4 14.92 618
Subtotal -- -- 13 22.20 732
Total -- -- 56 76.64 2,509

REASONABLE CAPACITY ASSUMPTIONS
This section describes the methodology developed to determine the site capacity for the moderate and above moderate-income sites. Reasonable capacity for sites identified to meet the City’s above moderate need was calculated based on a number of factors, including site size, existing zoning requirements, and the maximum density achievable for projects within all residential and mixed-use zones. Based on the analysis conducted, it was determined that the identified sites within the existing R-1-7, NMU-24, and UMU zones and projected ADU production could accommodate the City’s moderate and above moderate income RHNA need without any changes to the existing zoning.

Reasonable capacity for sites identified to meet the City’s moderate need was calculated based on the same methodology described above, however the methodology assumed development of sites at reasonable density assumptions (identified in Table 3-14 above) consistent with the City’s Land Use Element. These densities are below the maximum density permitted in each zone and provide a conservative estimate on potential development yield on the identified sites.

Potential constraints, to the extent they are known, such as environmentally sensitive areas and steep slopes were considered and deductions made where those factors decreased the net buildable area of a parcel. Additionally, existing units on non-vacant parcels were analyzed to determine the number of existing units currently on the parcel. Replacement of existing units was included as a factor within the City’s analysis and existing residential units were factored out of the anticipated development yield.

Sites Suitable for Lower Income Housing
The City of Orange has a RHNA need of 1,067 very-low income units and 604 low-income units. The City has identified mixed-use zoned parcels that permit development at up to 60 dwelling units per acre which can accommodate 1,522 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 68 units, or an additional 4 percent. As demonstrated in this section, the City of Orange

Section 3: Housing Constraints, Resources, and Fair Housing 3-54 2021-2029 Housing Element Update - Draft
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:

 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 percent 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 percent affordable component, the City has a history of building 100 percent 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 land and included those parcels within the sites inventory located in Appendix B. As shown in Table 3-15, 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 3-18, shown later in this section, 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.

The very-low and low-income sites inventory within Appendix B 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 be required to permit ‘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.

Table 3-15: Residential Capacity for Very Low- and Low-Income Sites Max Density Reasonable
Density Number of Parcels Acreage Potential
Units
Urban Mixed
Use (UMU) 60 55 36 56.25 1,522
Total -- -- 36 56.25 1,522

EXISTING OR PLANNED POLICIES AND PROGRAMS
The City of Orange has several mixed-use districts oriented towards introducing residential uses into historically commercial/office/industrial areas of the community at higher densities than the single-family neighborhoods found throughout the city. The Urban Mixed Use (UMU) zone was established to provide

Section 3: Housing Constraints, Resources, and Fair Housing 3-55 2021-2029 Housing Element Update - Draft
urban, high-intensity, regionally-oriented activity centers. Per the City’s zoning code, 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 for development within the UMU zone. Permitted densities within this zone range from 30-60 du/ac, well above the default density for Orange.

REGIONAL HOUSING NEEDS ALLOCATION
Future Housing Needs
Future housing need refers to the share of the regional housing need that has been allocated to the City.

HCD supplies a regional housing goal number to the SCAG. SCAG is then mandated to allocate a portion of the overall housing units for the region to each city and county jurisdictions in the region through a RHNA Plan. In allocating the region’s future housing needs to jurisdictions, SCAG is required to take the following factors into consideration pursuant to Section 65584 of the State Government Code:
 Market demand for housing;
 Employment opportunities;
 Availability of suitable sites and public facilities;  Commuting patterns;
 Type and tenure of housing;
 Loss of units in assisted housing developments;
 Over-concentration of lower income households; and
 Geological and topographical constraints.

SCAG adopted its RHNA in March 2021. This RHNA covers an 8-year planning period (starting in 2021) and addresses housing issues that are related to future growth in the region. The RHNA allocates to each city and county a “fair share” of the region’s projected housing needs by household income group. The major goal of the RHNA is to assure a fair distribution of housing among cities and counties within the Orange County region.

The City of Orange’s share of the SCAG regional growth allocation is 3,936 new units for the current planning period (2021-2029). Table 3-16, Housing Needs for 2021-2029, indicates the City’s RHNA need for the stated planning period.

Table 3-16: City of Orange Housing Needs for 2021-2029
Income Category (% of County AMI) Number of Units Percent Extremely Low (30% or less) 534
Very Low (31 to 50%)1 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 3,936 100.0%

Section 3: Housing Constraints, Resources, and Fair Housing 3-56 2021-2029 Housing Element Update - Draft
Note 1: Pursuant to AB 2634, local jurisdictions are also required to project the housing needs of extremely low income households (0-30% AMI). In estimating the number of extremely low income households, a jurisdiction can use 50% of the very low income allocation or apportion the very low income figure based on Census data.

Source: Final Regional Housing Needs Allocation, SCAG, 2021

ADEQUACY OF SITES FOR RHNA
The City of Orange has a total 2021-2029 RHNA allocation of 3,936 units as show in Table 3-17. The Housing Element update lists sites, including accessory dwelling units, that can accommodate approximately 4,352 additional units, 416 units in excess of the required 3,936 units. As described in this section, the City believes that due to recent State legislation and local efforts to promote accessory dwelling unit production, the City can realistically anticipate the development of 320 ADUs within the 8- year planning period. Overall, the City has adequate capacity to accommodate its 2021-2029 RHNA with a five percent buffer in excess of the City’s very-lower income RHNA need and a 2 percent buffer in excess of the City’s lower income RHNA. The City of Orange believes that due to the realistic assumptions outlined in this section, this buffer will be adequate to accommodate sites within the inventory that may not develop at the anticipated affordability level.

Table 3-17: Summary of RHNA Status and Sites Inventory

Extremely Low/
Very Low
Income
Units*
Low Income
Units
Moderate
Income
Units
Above
Moderate
Income
Units
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
Sites Surplus +54 +15 +151 +196 +416
Note: *Extremely Low Income is calculated as 50% of the City’s Very Low Income RHNA need.

Development of Non-Vacant Sites and Converting to Residential Uses The City has designated primarily non-vacant sites to meet their lower income 6th Cycle RHNA need, as well as a portion of the moderate and above moderate need. The City is reliant on infill development on non-vacant parcels to meet its RHNA need. Parcels designated to meet the two remaining categories (very low and low-income) are on mixed-use zoned parcels within the UMU zone. These parcels have a mixture of existing uses, which are described in detail in Appendix B.

Section 3: Housing Constraints, Resources, and Fair Housing 3-57 2021-2029 Housing Element Update - Draft
State law requires that the City analyze:
 the extent to which existing uses may constitute an impediment to the future residential development within the planning period,
 the City’s past experience with converting existing uses to higher density residential uses,  current market demand for the existing use,
 analysis of leases that would prevent redevelopment of the site,  development trends,
 market conditions, and
 regulations or incentives to encourage redevelopment.

Past Experience Developing Non-Vacant Sites for Residential Uses The following approved projects illustrate the viability of developing non-vacant, non-residentially zoned sites within Orange. These projects are all zoned Urban Mixed Use (UMU) consistent with the projects identified within the City’s sites analysis to meet the lower income RHNA need. The UMU zone is intended to promote an urban, high-intensity mixed-use area with integrated commercial retail/office, high-density housing, and civic uses. This zone permits residential development at up to 60 dwelling units per acre, though the City has assumed development at 50 dwelling units per acre for the analysis.

The projects below were developed with a mixture of uses and the square footage of non-residential uses has been provided where available.

Table 3-18: 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
Branch West (aka Garrison Apartments).

Apartment building is a podium product
involving a development agreement to

Section 3: Housing Constraints, Resources, and Fair Housing 3-58 2021-2029 Housing Element Update - Draft
Table 3-18: Example Development of Non-Vacant Sites for Residential Uses Project Address/
APN
Dwelling
Units Zoning Use Prior to
Redevelopment Project Analysis
building with
surface parking lot
allow a transfer of development rights
from an adjacent City water well site to
exceed the General Plan’s maximum 60
du/acre density. 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. The project is currently under
construction.

These projects demonstrate that there is a recent history of successfully developing residential units within the Urban Mixed Use zones in 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 remaining project developed under the maximum density at 44 dwelling units per acre due to retaining existing office uses onsite. A workforce housing study determined that all of the sample projects shown in Table 3-18 were affordable at the moderate income level.

To accommodate the potential for a lower number of residential units due to a mixture of uses onsite, the City has made assumptions within the sites analysis which base development production on a 48 dwelling units per acre density 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 due to the City’s actions to address development constraints. The Housing Plan section outlines actions the City will take to promote the development of affordable units within the mixed used areas.

Existing Uses on Candidate Sites
Table B-3 shows the existing uses on each of the candidate sites identified to meet Orange’s low and very- low income RHNA need. These sites range from commercial and office to underutilized surface parking lots. Where it is known that there are either temporarily or permanently closed or actively for lease/sale sites, this has been indicated within the individual parcel analysis.

The City is continuing to outreach to property owners of the identified candidate sites and the development community to collect letters of interest in residential development. Letters received are included within Appendix A.

Section 3: Housing Constraints, Resources, and Fair Housing 3-59 2021-2029 Housing Element Update - Draft
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 party lease agreements or other contractual agreements amongst private parties. As part of the sites analysis for very-low and low-income sites, the City notified property owners whose properties were identified as part of the sites analysis. As the City is not proposing to rezone or change the zoning on properties, this notification was purely informative to let property owners know why their parcel was identified and gather feedback.

Regulatory Incentives
The City of Orange does not currently have any regulatory incentives aimed at the development of lower income housing. Density bonus is a Statewide program which provides concessions to developers who propose a certain percentage of affordable units as part of their project. By right, developers who meet any level of density bonus requirements are permitted additional density and a lowered parking ratio.

Additional concessions may be available depending on the type of project, such as lowered requirements for certain development standards such as FAR, open space, or others.

The City has created Programs 2B and 2G which are written to address actions the City will take which may promote development of affordable housing.

Current Market Demand for Existing Uses
The areas within Orange identified as the most likely to redevelop at densities suitable for lower income housing are primarily in areas with existing commercial and office uses. Due to the pandemic, these markets have seen a large decrease in demand as companies shrink their physical footprint, introduce flexibility to workers through work from home options, or hasten the transition to a focus on virtual sales.

A November 2020 report by HughesMarino3 on the Orange County commercial real estate market and the impacts of COVID-19 showed a 34 percent increase in sublease office space from a year ago. Sublease inventory occurs at cheaper rents and shorter terms than typical leases and indicates a hesitancy on the part of office space users. The report goes on to say that “many office tenants that have had leases expire since the pandemic started have not renewed their leases and have elected to operate until post-COVID without any office space, essentially foregoing having any significant office space until they can reassess their needs in the post pandemic reality. Further, many office tenants with lease expirations in the next six months are also choosing not to renew their lease for the same reason. This is more common for smaller companies with 50 or fewer employees that are working fully remote and have determined that eliminating the expense of office space is to their benefit. This has caused an uptick in Orange County office space availability, where the availability of office space in the county has gone up from

3 https://hughesmarino.com/orange-county/blog/2020/11/10/who-is-hurting-who-is-thriving-in- orange-county-commercial-real-estate/

Section 3: Housing Constraints, Resources, and Fair Housing 3-60 2021-2029 Housing Element Update - Draft
approximately 17.6M square feet last year to about 24M square feet today—a 36 percent increase.” This trend is reflected throughout southern California with many employers having developed the infrastructure to work primarily remotely.

Additionally, the 2021 Emerging Trends in Real Estate Report4, prepared by PwC and the Urban Land Institute (ULI), discusses the decline in demand for retail space that has been occurring far before COVID- 19 hit. The report sites greater debt among millennials and Gen X along with a shift to online sales.

Further, the report states that “retailers announced more than 5,800 closures in 2018, jumping to over 9,300 in 2019. Rising retail bankruptcies account for only part of the story. Of greater importance, retail chains are downsizing their store counts and closing underperforming stores…” This all points to a need to diversify traditionally retail corridors and other areas by bringing in new users who can help to revitalize retail uses.

Development Trends
In addition to commercial office and smaller retail centers, the City has identified sites in and around The Outlets at Orange property, which is zoned UMU and permits residential development, as sites with the potential to redevelop for residential uses.

The Outlets at Orange located in the Uptown Orange area of the city is a 57 acre outdoor mall with approximately 860,000 square feet of commercial uses, including restaurants, shops and entertainment uses surrounded by concentrated medical and office activity. As the dynamic of retail changes, there is a push towards creating lifestyle centers with a mixture of using, including higher density residential uses to draw in more potential buyers and locate them on-site. While the Outlets is a well-performing retail center, in recent years multi-family residential projects have been constructed or entitled on surrounding infill sites, incrementally having the resulting effect of a horizontal mixed-use urban district.

The following regional malls within Orange County, which have similar development characteristics to the Outlets at Orange, have completed planning and entitlement efforts to permit residential uses.  MainPlace Mall, Santa Ana, CA – In 2019, MainPlace Mall completed a Specific Plan which permits the development of up to 1,900 residential units at densities up to 90 dwelling units per acre.

Anticipated development also includes up to 400 hotel rooms, a total of 1,400,000 square feet of commercial uses, and up to 750,00 square feet of office space. MainPlace Mall is smaller than the Outlets at Orange at approximately 49 acres. The two malls are roughly 1.5 miles apart in adjacent cities. These malls share the following characteristics:
o Location and local/regional context. The two malls are roughly 1.5 miles apart. Both malls serve a market area that is close to freeways for regional access and provide needed housing at an easily accessible location.

4 https://www.pwc.com/us/en/asset-management/real-estate/assets/pwc-emerging-trends-in-real- estate-2021.pdf

Section 3: Housing Constraints, Resources, and Fair Housing 3-61 2021-2029 Housing Element Update - Draft
o Existing Character. MainPlace and The Outlets are both surrounded primarily by surface parking lots with opportunity for redevelopment.
 Westminster Mall, Westminster, CA – The City of Westminster is currently working with property owners on the Westminster Mall Specific Plan which is anticipated to provide guidelines for mixed commercial, professional office, hotel, and residential development (which would vary in housing type and affordability). A maximum of 3,000 dwelling units, 425 hotel rooms, 1.2 million square feet of non-residential uses (retail and office), and a maximum height of 10 stories are being analyzed as part of the project’s EIR.5 These malls share the following characteristics:
o Location/local market. Westminster Mall is located directly adjacent to I-405 and in close proximity to Beach Boulevard and a number of job-creating uses. Similarly, the Outlets at Orange are at the intersection of two major freeways (I-5 and SR-22) and in close proximity to job creating use corridors along Main Street and Chapman Avenue. o Character. Westminster Mall is surrounded by parking, most of which remains largely unused. This parking could be easily accommodated within a structure as is planned in the specific plan.
 Village at Laguna Hills, Laguna Hills, CA – In 2016, Laguna Hills Mall began a transformation to add approximately 1,500 residential units, 150 hotel rooms, and 465,000 square feet of office to the existing mall. A portion of the units have been constructed to date. These malls share the following characteristics:
o Character. Similar to the Outlets, Laguna Hills Mall is a partially outdoor mall/lifestyle center with parking completely surrounding commercial uses. Both malls are directly adjacent to large job creating uses in the form of major medical centers. o Location. Laguna Hills Mall is directly adjacent to the I-5 freeway and regionally serving.

Similarly, the Outlets at Orange are at the intersection of two major freeways (I-5 and SR- 22).

Multi-family housing development that has occurred on parking lot sites within the City of Orange has been successful, including multiple apartment buildings directly west of the Outlets. While there were three infill housing projects approved in the vicinity of the Outlets, also infill on surface parking lots, it is the City’s understanding that the projects did not move forward due to economic uncertainties due to the pandemic. The City is optimistic that these projects will come back in some form in the future. The mall ownership has also indicated that it is contemplating future housing integration into its site as the housing the did get built has proven to be a positive addition to their patron mix. The Outlets property remains an ideal location for future housing opportunities as malls become mixed-use, walkable lifestyle centers with a focus on the synergy between residential, commercial, and office uses.

ACCESSORY DWELLING UNIT PRODUCTION
One of the proposed methods for meeting the City’s moderate and above moderate RHNA is through the promotion and development of ADUs. A number of State Assembly and Senate Bills were passed in 2019 and 2020 that promote and remove barriers that may inhibit the development of ADUs within

5 https://www.westminster-ca.gov/Home/ShowDocument?id=1568

Section 3: Housing Constraints, Resources, and Fair Housing 3-62 2021-2029 Housing Element Update - Draft
communities. These bills, as well as other significant legislation relating to ADUs creates a development environment that is likely to increase the number of ADUs developed within Orange over the 2021-2029 planning period. Orange, with a large proportion of single-family residential properties (many on larger lots), is well-oriented for the development of ADUs.

The City saw an increase in ADU approvals in 2020. The City had 27 ADUs approved for development between January 1, 2020 and December 31, 2020, an 170 percent increase from the 10 ADUs the City permitted in 2019. HCD guidance states that ADUs may be calculated based on the City’s production since January 1, 2018. In 2018 and 2019, the City of Orange approved 15 and 10 ADUs respectively. 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.

F. Financial Resources
Providing an adequate supply of decent and affordable housing requires funding from various sources, the City has access to the following finding sources.

Section 8 Housing Choice Voucher
The Section 8 Housing Choice Voucher program is a Federal government program to assist very low- income families, the elderly, and the disabled with rent subsidy payments in privately owned rental housing units. Section 8 participants are able to choose any housing that meets the requirements of the program and are not limited to units located within subsidized housing projects. They typically pay 30 to 40 percent of their income for rent and utilities. The Orange County Housing Authority currently administers Section 8 Housing Choice vouchers within the City of Orange. The City’s goal is to assist 483 households each year.

Community Development Block Grants (CDBG)
The Community Development Block Grant (CDBG) program provides annual grants on a formula basis to cities to develop viable urban communities by providing a suitable living environments and by expanding economic opportunities, principally for low- and moderate-income persons (up to 80 percent AMI).

CDBG funds can be used for a wide array of activities, including:
 Housing rehabilitation;
 Lead-based paint screening and abatement;
 Acquisition of buildings and land;
 Construction or rehabilitation of public facilities and infrastructure, and:
 Public services for low income households and those with special needs.

Section 3: Housing Constraints, Resources, and Fair Housing 3-63 2021-2029 Housing Element Update - Draft
HOME Investment Partnership Program (HOME)
The HOME program provides federal funds for the development and rehabilitation of affordable rental and ownership housing for households with incomes not exceeding 80 percent of area median income.

The program gives local governments the flexibility to fund a wide range of affordable housing activities through housing partnerships with private industry and non-profit organizations. HOME funds can be used for activities that promote affordable rental housing and homeownership by low income households.

The City of Orange receives HOME funds from HUD annually. The City qualifies as an entitlement jurisdiction and the Community Development Departments serves as the grantee to administer CDBG and HOME funds in accordance with the pertaining statutory and regulatory requirements. Table 3-19 below identifies the funding allocated to different services and persons assisted, based on the City’s 2015-20 Consolidated Plan. Additionally the City is utilizing HOME funds to assist in development of the Corp Yard Housing Project.

Table 3-19: 2015-20 HOME and CDBG Allocation
2015-2020 Goal Name
and Category
CDBG and HOME Funds Goals (Persons Assisted) 2015-2018
Accomplishments
Affordable Housing $1.5 million 1,800 1,349
Homeless $61,000 30 12
Public Facilities $4.1 million 57,870 12,651
Public Services $845,000 231,800 230,698
G. Energy Conservation
The primary uses of energy in urban areas are for transportation lighting, water heating, and space heating and cooling. The high cost of energy demands that efforts be taken to reduce or minimize the overall level of urban energy consumption. Energy conservation is important in preserving non-renewable fuels to ensure that these resources are available for use by future generations. There are also a number of benefits associated with energy conservation including improved air quality and lower energy costs.

The City of Orange is collaborating with Southern California Edison and SoCalGas through the North Orange County Cities Energy Partnership (NOCC) to help the City achieve its energy reductions goals.

Section 3: Housing Constraints, Resources, and Fair Housing 3-64 2021-2029 Housing Element Update - Draft
Affirmatively Furthering Fair Housing (AFFH)
H. Affirmatively Furthering Fair Housing
All Housing Elements due on or after January 1, 2021 must contain an Assessment of Fair Housing (AFH) consistent with the core elements of the analysis required by the federal Affirmatively Further Fair Housing Final Rule of July 16, 2015.

Under State law, affirmatively further fair housing means “taking meaningful actions, in addition to combatting discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. These characteristics can include, but are not limited to race, religion, sex, marital status, ancestry, national origin, color, familiar status, or disability.

The Draft Regional Analysis of Impediments (AI) to Fair Housing Choice for FY 2020-25 was made available for public review and finalized on May 5, 2020. The Fair Housing Council of Orange County works under the direction of a volunteer board of directors and staff to fulfill a mission of protecting the quality of life in Orange County by ensuring equal access to housing opportunities, fostering diversity and preserving dignity and human rights. The agency is a HUD Approved Housing Counseling Agency and provides one- on-one education, mediation, and counseling for individuals and families throughout the Orange County region.

The AI identifies impediments that may prevent equal housing access and develops solutions to mitigate or remove such impediments. Orange’s 6th Cycle Housing Element references analysis from the regional FY 2020-2025 AI in order to identify potential impediments to housing that are specific to Orange. The City also completed its FY 2020-24 Consolidated Plan, as an entitlement city for Community Development Block Grant (CDBG) funding, which identifies housing problems within the community, specifically among low and very-low income households. Fair housing is identified as a priority within the Consolidated Plan.

I. Needs Assessment
The AI contains a Countywide analysis of demographic, housing, and specifically fair housing issues for all of the cities in Orange County, including Orange. The City's demographic and income profile, household and housing characteristics, housing cost and availability, and special needs populations were discussed in the previous Section 2: Community Profile.

Fair Housing Issues
As a part of the development of the FY 2020-25 AI and in order to ensure that the analysis accurately reflected the conditions in the community, extensive outreach and testing was done, including interviews, community meetings, focus groups and workshops and public hearings. In order to gather input and participation, the County reached out to tenants, landlords, homeowners, fair housing organizations, civil

Section 3: Housing Constraints, Resources, and Fair Housing 3-65 2021-2029 Housing Element Update - Draft
rights and advocacy organizations, legal services provers, social services providers, housing developers, and industry groups to hear directly about fair housing issues affecting residents of Orange County.

Public hearings and City Council meetings were held throughout the County during the Spring. Due to the prohibition of gatherings because of COVID-19, hearings and meetings were held remotely. All community meetings had translation services available if requested in Spanish and Vietnamese. Public hearings and City Council meetings were held throughout the County during the Spring. Due to the prohibition of gatherings due to COVID, hearings and meetings were held remotely.

The City does not regularly conduct fair housing testing; however the regional AI identified the following fair housing issues in the City:
 Educational Opportunities: The City of Orange struggled with 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. This analysis is explained in more detail in this section relating to disparities in access to opportunity.
 Environmental Opportunities: 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.
 Economic Opportunities: 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 of census tracts which have low resources and 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.

Fair Housing Enforcement and Outreach Capacity
City of Orange
Currently, the Fair Housing Foundation (FHF) provides fair housing services to the City of Orange. This includes offering fair housing counseling and landlord/tenant mediation services which are available for tenants, realtors, apartment owners and managers, lending institutions and other interested parties.

Specifically, the FHF promotes services and educational activities via social media, twitter, Instagram, Facebook, and online. FHF uses USPS Door-to-Door service to reach the community directly. Through the USPS website they are able search for neighborhoods/zip codes, filters target customers by specific demographics such as age, household size, and income, etc. FHF targets lower income areas, and the Postal Service carrier delivers FHF information mailers to every address while delivering the day's mail.

Additionally, the FHF mails flyers to local public departments such as library, city hall, and community organizations they have built relationships with. The City of Orange annually allocates $24,522 in CDBG

Section 3: Housing Constraints, Resources, and Fair Housing 3-66 2021-2029 Housing Element Update - Draft
funds for the Fair Housing Foundation in an effort to assist an estimated 150 families and to perform the following services, at no cost:
 Responding to discrimination inquiries and complaints, documenting and investigating discrimination complaints, and resolving or mediating discrimination complaints  A comprehensive, extensive and viable education and outreach program, including:
o Fair Housing Workshop
o Certificate Management Training
o Walk-In Clinics
o Rental Housing Counseling Workshop
o Community presentations, staff training, and workshops o Community events, booths, networking, etc.
 Landlord and tenant counseling on responsibilities and rights  Rental counseling

In FY 2019 the Fair Housing Foundation provided services to 161 residents of the City of Orange. The Fair Housing Foundations offers regular walk-in counseling sessions, in addition to resources fairs, informational workshops (accessible in multiple languages), landlord and tenant workshops, and other outreach efforts. The City has confirmed with the Fair Housing Foundation that there are no current lawsuits, enforcement actions, settlements, or judgments related to fair housing or civil rights as of the adoption of this document. Furthermore, the City of Orange has no active cases relating to fair housing issues.

As part of the FY 2020-25 Consolidated Plan for Orange, the City has set an annual goal of assisting 150 families or households with fair housing issues, within the five-year period this equates to a goal of 750 families or households. Orange has also set a goal of retaining a Fair Housing provider to promote fair housing education and outreach within the community. HUD maintains a record of all housing discrimination complaints filed in local jurisdictions. These grievances can be filed on the basis of race, color, national origin, sex, disability, religion, familial status and retaliation. In 2019, 16 fair housing complaints were filed involving housing discrimination in the City of Orange.

Orange County
The Fair Housing Council of Orange County (FHCOC), a private non-profit fair housing group, is under contract to the County to administer a wide variety of fair housing services to residents of Orange County.

The FHCOC provides the following services to Orange County residents:
 Serving as a fair housing resource for the region, including implementation of an affirmative fair housing marketing plan, testing, and complaint verification;  Responding to all citizen complaints regarding violation of fair housing laws;  Providing tenant-landlord counseling to all inquiring citizens;  Promoting community awareness of tenant-landlord rights and responsibilities;  Reporting monthly on complaint processing;
 Providing fair housing education to residents, County staff, community organizations, agencies, and service providers;

Section 3: Housing Constraints, Resources, and Fair Housing 3-67 2021-2029 Housing Element Update - Draft
 Increasing the supply of affordable housing in high opportunity areas;  Preventing displacement of low- and moderate-income residents, seniors, and people with disabilities;
 Increasing community integration for persons with disabilities;  Ensuring equal access to housing for persons with protected characteristics, who are disproportionately likely to be lower-income and to experience homelessness; and  Expanding access to opportunities for protected classes.

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.

The FHCOC ensures that the City’s fair housing practices are consistent with State law and that residents have the tools and resources they need to address fair housing issues appropriately. The City relies on the FHCOC to track, monitor, and investigate fair housing cases as well as hold training sessions for property owners/managers.

Housing Element Update Outreach
Additionally, as a part of the Housing Element update the City hosted of variety of workshops and other engagement opportunities to gather input on housing needs, challenges, opportunities, and other feedback regarding housing in Orange. The City’s outreach strategies and summaries of all events and surveys is available for review in Appendix C of this Housing Element.

Throughout the outreach and engagement process the City identified the following key themes:
 Community participants are interested in mixed use opportunities in Orange.  Community participants opined an overall lack of affordable housing options in the City.  Community participants would like to see and have more housing information and educational resources about housing opportunities and programs.
 Community participants opined transit centers and mixed-use areas as having the most potential for new housing opportunities.
 Community participants opined a lack of information about housing resources and an overall lack of housing availability were primary concerns they would like the City to focus on mitigating.

The themes identified above informed the direction of the data analysis for the Housing Element, as well as areas of focus for the Fair Housing analysis and the development of the Housing Plan (Section 4).

Fair Housing Laws
The following lists State and local fair housing laws and specifies how the City complies:

State
 California Fair Employment and Housing Act (FEHA): The City continues to implement and update programs that promote fair and equal access to housing. The City continues to review standards

Section 3: Housing Constraints, Resources, and Fair Housing 3-68 2021-2029 Housing Element Update - Draft
and requirements that may constrain equal access to housing and the development of affordable housing.
 Government Code section 65008: The City continues to implement programs that encourage affordable housing development. Policy Actions 2B, 2G, 2M, 4A, are programs in the City that comply with the State’s requirement for fair review of affordable housing development.  Government Code section 8899.50: The City implements programs and actions in compliance with State law that affirmatively furthers fair housing. As detailed in in this Section 3, the City administers programs to promote equal housing access and affordable resources.  Government Code section 11135: The City promotes state-funded programs, such as the First- Time Homebuyer Loan Program, on the City’s website and at the public counter. The City continues to implement and encourages programs that promote full and equal access to all programs and activities.
 Density Bonus Law: The City establishes regulations for implementing the City’s Density Bonus Ordinance. The City provides incentives to developers to produce affordable housing to very low- income households, low-income households, moderate-income households, senior citizens, transitional foster youth, disabled veterans, and persons experiencing homelessness, as well as for the development of childcare facilities. Section 3.B.2 details the City’s compliance with the State Density Bonus Law.
 Housing Accountability Act: The City implements programs such as fee incentives, funding, and review of zoning procedures to facilitate and encourage housing development.  No-Net-Loss law: Section 4: Housing Plan, and Appendix B: Candidate Sites Analysis, details how the City maintains adequate sites to accommodate all income categories for RHNA.  Excessive Subdivision standards: The City continues to update its zoning code, waive certain development fees, and offer incentive packages to facilitate housing development.  Limits on growth controls: The City identifies sites by income category in Appendix B: Candidate Sites Analysis, to meet the City’s RHNA. None of the sites identified as part of the analysis have known constraints.
 Housing Element Law: The City identifies and includes an analysis of existing and projected housing needs and a statement of goals, policies, quantified objectives, financial resources, and scheduled programs.

Local
 Local Ordinances: The City has a number of local ordinances that establishes procedures for rezoning, development permit processing, affordable housing fees, and other programs that encourage fair housing practices.
 Housing Plan Programs: Section 4: Housing Plan details the City’s goals, policies, programs, and objectives. The City addresses the need for additional housing opportunities, remove constraints to affordable housing, improving the existing housing stock, and provide equal opportunities for current and future residents of Orange.

Section 3: Housing Constraints, Resources, and Fair Housing 3-69 2021-2029 Housing Element Update - Draft
J. Analysis of Federal, State, and Local Data and Local Knowledge Integration and Segregation Patterns and Trends
The dissimilarity index is the most commonly used measure of segregation between two groups, reflecting their relative distributions across neighborhoods (as defined by census tracts). The index represents the percentage of the minority group that would have to move to new neighborhoods to achieve perfect integration of that group. An index score can range in value from 0 percent, indicating complete integration, to 100 percent, indicating complete segregation. An index number above 60 is considered to show high similarity and a segregated community.

It is important to note that segregation is a complex topic, difficult to generalize, and is influenced by many factors. Individual choices can be a cause of segregation, with some residents choosing to live among people of their own race or ethnic group. For instance, recent immigrants often depend on nearby relatives, friends, and ethnic institutions to help them adjust to a new country.6 Alternatively, when white residents leave neighborhoods that become more diverse, those neighborhoods can become segregated.

Other factors, including housing market dynamics, availability of lending to different ethnic groups, availability of affordable housing, and discrimination can also cause residential segregation.

Figure 3-1 shows the dissimilarity between each if the identified race and ethnic groups and Orange’s White population. The higher scores indicate higher levels of segregation among those racial and ethnic group. According to the data, there are highest dissimilarity rates among the Native Hawaiian and those who identified as Hispanic. Specifically, 45.8 percent of the Native Hawaiian population in Orange would need to move into predominantly White neighborhoods for perfect integration and 46.3 percent of persons who identified as Hispanic in Orange would need to move into predominantly White neighborhoods for perfect integration.

Additionally, Figure 3-2 and 3-3 show the City’s Diversity Index for 2010 and 2018. In 2010, the City had low diversity towards the center and in the eastern region. By 2018 diversity had increased throughout the City and predominantly in areas that previously had lower diversity. Areas of lower diversity still exist towards the City’s eastern region and the center, but the City shows a diversifying trend.

6 Allen, James P. and Turner, Eugene. “Changing Faces, Changing Places: Mapping Southern California”. California State University, Northridge, (2002).

Section 3: Housing Constraints, Resources, and Fair Housing 3-70 2021-2029 Housing Element Update - Draft
Figure 3-1: Dissimilarity Index with Whites – Orange

Source: Census Scope, Social Science Data Analysis Network, *Not Hispanic or Latino

0 5 10 15 20 25 30 35 40 45 50Black*American Indian*Asian*Native Hawaiian*Other*Two or More Races*HispanicBlack*AmericanIndian*Asian*NativeHawaiian*Other*Two orMoreRaces*HispanicDissimilarity Index with Whites39.2 33.6 30.6 45.8 45.3 18.9 46.3

Section 3: Housing Constraints, Resources, and Fair Housing 3-71 2021-2029 Housing Element Update - Draft
Figure 3-2: Diversity Index, Orange (2010)

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 3-72 2021-2029 Housing Element Update - Draft
Figure 3-3: Diversity Index, Orange (2018)

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 3-73 2021-2029 Housing Element Update - Draft
Racially or Ethnically Concentrated Areas of Poverty (R/ECAP) To assist communities in identifying racially/ethnically concentrated areas of poverty (R/ECAPs), HUD has developed a census tract-based definition of R/ECAPs. The definition involves a racial/ethnic concentration threshold and a poverty test. The racial/ethnic concentration threshold is straightforward:

RECAPs must have a non-white population of 50 percent or more. Regarding the poverty threshold, Wilson (1980) defines neighborhoods of extreme poverty as census tracts with 40 percent or more of individuals living at or below the poverty line. Because overall poverty levels are substantially lower in many parts of the country, HUD supplements this with an alternate criterion. Thus, a neighborhood can be a RECAP if it has a poverty rate that exceeds 40 percent or is three or more times the average tract poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

Location of residence can have a substantial effect on mental and physical health, education opportunities, and economic opportunities. Urban areas that are more residentially segregated by race and income tend to have lower levels of upward economic mobility than other areas. Research has found that racial inequality is thus amplified by residential segregation.7 However, these areas may also provide different opportunities, such as ethnic enclaves providing proximity to centers of cultural significance, or business, social networks and communities to help immigrants preserve cultural identify and establish themselves in new places. Overall, it is important to study and identify these areas in order to understand patterns of segregation and poverty in a City. The 2020 AI performed an analysis of R/ECAPs within Orange County and found four R/ECAPs, none of which were found in Orange. Figure 3-4 below displays the results of the analysis.

7 Orange County, Analysis of Impediments to Fair Housing Choice, April 2020 DRAFT.

Section 3: Housing Constraints, Resources, and Fair Housing 3-74 2021-2029 Housing Element Update - Draft
Figure 3-4: Low Poverty Index with Race/Ethnicity and R/ECAPs, Orange

Source: HUD Affirmitaevly Furthering Fair Housing Data and Mapping Tool, Data Versions: AFFHT0006, July 10, 2020

Section 3: Housing Constraints, Resources, and Fair Housing 3-75 2021-2029 Housing Element Update - Draft

Racially or Ethnically Concentrated Areas of Affluence (RCAA) The City has gathered demographic information regarding race/ethnicity concentration and income distribution in the City. The racial and ethnic makeup of the various neighborhoods are of critical importance in the formation of the City’s voting districts and the City has engaged a demographer to plot the racial and ethnic concentrations in the City based on the 2020 census. The 2020 census provides the most up to date statistics upon which to base the RCAA analysis. In addition, the 2012-2016 American Community Survey (ACS) provides additional data measured at the census track level covering such areas as social characteristics, economic characteristics, and housing characteristics.

An RCAA has been variously defined as a census tract in which 80 to 90 percent or more of the population is White and has a median income of at least $125,000. The nationwide RCAA analysis identifies the following:
 RCAA tracts have more than twice the median household income of the average tract in their metro area.
 Poverty rates in RCAAs are significantly lower and are, on average about 20 percent of a typical tract.
 RCAAs tracts are more income homogenous than a typical tract.  The average RCAA is about 57 percent affluent.
 The typical RCAA tract has a rate of affluence 3.2 times that of a typical tract.

Figure 3-5 shows census tracts with a majority White population. As the figure shows, the City has higher gaps between the White population and other Races on the east side. A number of census tracts report majority White populations between 67 and 77 percent. Most candidate housing sites identified as part of the Sites Analysis are located in areas without a gap between the Non-White and White populations.

Figure 3-6 shows the breakdown on median income throughout the City. A number of census tracts in the eastern and southern region of the City report a median income greater than $125,000. When overlayed with a majority White population, six block groups are identified as RCAAs. These are detailed in Table 3-

20. No candidate housing sites are identified within RCAAs.

Table 3-20: RCAAs by Block Group
Block Group Percent Population White Median Income
Block Group 3, Census Tract 219.17 77% $172,969
Block Group 2, Census Tract 219.17 77% $143,333
Block Group 2, Census Tract 756.05 67.7% $177,593
Block Group 5, Census Tract 756.05 67.7% $134,116
Block Group 4, Census Tract 756.04 74% $128,063
Block Group 5, Census Tract 756.04 74% $149,762
Regional Context
Orange County 61% $90,234
Source: California Department of Housing and Community Development – AFFH Data Viewer; American Community Survey, 5- Year Estimates, 2019

Section 3: Housing Constraints, Resources, and Fair Housing 3-76 2021-2029 Housing Element Update - Draft

Figure 3-5: White Majority Population, Orange

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 3-77 2021-2029 Housing Element Update - Draft

Figure 3-6: Median Income by Block Group, Orange (2019)

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 3-78 2021-2029 Housing Element Update - Draft

Additionally, Table 3-21 below shows local and regional context for the median household income of White households compared to all households.

Table 3-21: Median Household Income by Race
Race
Orange Orange County
Median Income Percent of
Population Median Income Percent of
Population
White $92,489 1 72% $94,082 1 61%
All Households $91,793 -- $90,234 --

1. Median household income in the past 12 months (in 2019 inflation-adjusted dollars).

Source: American Community Survey, 5-Year Estimates, 2019.

Figure 3-7 shows the City’s current (as of February 2022) voting districts (1 through 6), formed in accordance with the California Voting Rights Act of 2001 (CVRA) and approved by the Orange County Superior Court. The CVRA does not take income levels into account in forming voting districts. As of the time of adoption of this Housing Element, the City is in the process of redrawing the six districts based on the results of the 2020 census.

Table 3-22 shows the City’s current (as of February 2022) ethnic and income makeup in voting districts 1 through 6
Figure 3-7: City of Orange Voting Districts

Source: City of Orange

Section 3: Housing Constraints, Resources, and Fair Housing 3-79 2021-2029 Housing Element Update - Draft

Table 3-22: City of Orange Demographics by Voting District Total
Population
Voting Districts
1 2 3 4 5 6
Race and Ethnicity
White 55,395 12,177 5,458 9,704 10,381 6,421 11,263
Hispanic 57,728 9,274 13,816 8,843 6,448 13,377 5,970
Black 4,062 872 1,120 636 470 573 391
Asian 22,066 3,128 3,796 3,731 4,814 2,390 4,207
Native 4,505 877 945 681 573 889 540
Pacific Islander 988 231 181 161 127 158 130
Total 140,191 25,715 24,162 23,096 22,305 22,829 22,084 Household Income
Up to $25K 4,904 1,363 1,104 697 434 841 465
$25K to $50K 6,084 1,088 1,171 995 839 1,103 888
$50K to $75K 6,863 1,615 1,503 985 854 890 1,016
$75K to $200K 19,511 3,401 2,620 3,752 2,993 2,817 3,929 $200K plus 5,858 687 313 934 1,704 739 1,480
Total 140,191 25,715 24,162 23,096 22,305 22,829 22,084 Source: City of Orange

Figure 3-8 shows the median income for the City of Orange by Block Group in 2014. Block groups towards the center of the City and to the south and east are shown to have incomes between $80,000 and $100,000. In comparison to 2019 (Figure 3-6), the City now has more areas of high incomes over $125,000 and some patches of incomes between $30,000 and $55,000. The areas including lower incomes in 2019 are largely made up of industrial and commercial uses, and some residential neighborhoods. Overall, the City is showing trends of increased household incomes.

Section 3: Housing Constraints, Resources, and Fair Housing 3-80 2021-2029 Housing Element Update - Draft

Figure 3-8: Median Income by Block Group, Orange (2014)

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 3-81 2021-2029 Housing Element Update - Draft

Disparities in Access to Opportunity
Regional Opportunity Index (ROI)
The UC Davis Center for Regional Change and Rabobank partnered to develop the Regional Opportunity Index (ROI) intended to help communities understand local social and economic opportunities. The goal of the ROI is to help target resources and policies toward people and places with the greatest need to foster thriving communities. The ROI incorporates both “people” and “place components, integrating economic, infrastructure, environmental, and social indicators into a comprehensive assessment of the factors driving opportunity.”

“People” is a relative measure of people's assets in education, the economy, housing, mobility/transportation, health/environment, and civic life as follows:
 Education Opportunity: Assesses people’s relative success in gaining educational assets, in the form of a higher education, elementary school achievement, and regular elementary school attendance.
 Economic Opportunity: Measures the relative economic well-being of the people in a community, in the form of employment and income level.
 Housing Opportunity: Measures the relative residential stability of a community, in the form of homeownership and housing costs.
 Mobility/Transportation Opportunity: Contains indicators that assess a community’s relative opportunities for overcoming rural isolation.
 Health/Environment Opportunity: Measures the relative health outcomes of the people within a community, in the form of infant and teen health and general health.  Civic Life Opportunity: A relative social and political engagement of an area, in the form of households that speak English and voter turnout.
“Place” is a relative measure of an area's assets in education, the economy, housing, mobility/transportation, health/environment, and civic life.  Education Opportunity: Assesses a census tract's relative ability to provide educational opportunity, in the form of high-quality schools that meet the basic educational and social needs of the population.
 Economic Opportunity: Measures the relative economic climate of a community, in the form of access to employment and business climate.
 Housing Opportunity: Measures relative availability of housing in a community, in the form of housing sufficiency and housing affordability.
 Health/Environment Opportunity: A relative measure of how well communities meet the health needs of their constituents, in the form of access to health care and other health-related environments.
 Civic Life Opportunity: Measures the relative social and political stability of an area, in the form of neighborhood stability (living in same residence for one year) and US citizenship

As shown in Figures 3-6 and 3-7 below, the City is a mix of low and moderate resource to high resource depending on the census tract. Figure 3-6 displays the data for level or range of assets a population has,

Section 3: Housing Constraints, Resources, and Fair Housing 3-82 2021-2029 Housing Element Update - Draft

by census tract. The figure shows that while most people in Orange have high opportunity based on employment, economics, education, housing and civic life, there are four census tracts which show low opportunity. Census Tract A (762.04) shows high levels of access to mobility and transportation; however, it shows low civic life, health and environment, housing, economic and educational assets of this population. Census Tract B (761.01) also shows low civic life, low housing and moderately low educational assets; however, Census Tract B population has high health, high mobility, and economic assets. Census Tract C (759.02) shows similar stats with low civic life housing and educational assets of the population but higher health, mobility/transportation, and economic opportunities. Census Tract D (759.01) aligns with Census Tract A, its population has primarily high access to mobility and transportation options with low resources or assets for civic life health, housing, economics, and education.

Figure 3-7 below displays the level or range of opportunity that a census track can provide the population.

The figure shows that majority of the census tracts in the City are high or very high resources, with the exception of two census tracts which are considered low resources opportunity. Census Tract A shows that that area provides high economic or job opportunity and high education al opportunities, however this area shows low civic life, low health and environment and low housing opportunities or resources.

Additionally, Census Tract C shows moderate economic or job opportunity and high educational resources and opportunity however, similar to Census Tract A it shows low resource and opportunities for civic life, health and environment and housing. Increasing housing opportunities in the City can supplement the areas where residents have access to transportation, economic opportunity and jobs, and education but no stable or affordable housing options. In doing so, increased housing creates a more balanced community with more asset and resource opportunity for residents.

In both Figures 3-9 and 3-10, Census Tract A has the lowest opportunity levels. In comparison to demographic data, the area reports the following information:
 68.8 percent Hispanic population
 20-30 percent population whose income in the past 12 months is below the poverty line  50-75 percent low to moderate income population
 Over 20 percent overcrowded households
As such, Housing Policy Action 4A is included in Section 4: Housing Plan to affirmatively further fair housing and improve access to resources and housing in Census Tract A and across the City. Additionally, a number of sites have been identified within this Census Tract as part of the candidate sites analysis due to availability of land and potential for future development. The development of new, affordable housing units in this area may help to provide accessible housing to the residents of the area without resulting in displacement. In addition, new development may also result in additional resources and community services to existing residents of the area – ultimately resulting in improved conditions and diversity.

Section 3: Housing Constraints, Resources, and Fair Housing 3-83 2021-2029 Housing Element Update - Draft
Figure 3-9: Regional Opportunity Index: People, 2014

Source: UC Davis Center for Regional Change and Rabobank, 2014.

Section 3: Housing Constraints, Resources, and Fair Housing 3-84 2021-2029 Housing Element Update - Draft
Figure 3-10: Regional Opportunity Index: Place, 2014

Source: UC Davis Center for Regional Change and Rabobank, 2014.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-85
Additionally, Table 3-23 and Figure 3-11 below display the data for Regional Opportunity Index for the City of Orange overall compared to the State of California. The data shows the following key findings:
 The City of Orange has a higher percentage of college educated adults age 25 or older, but a lower percentage of UC/CSU eligibility among high school graduates. High school graduation rates are higher in Orange, but the City has lower percentages of math and English proficiency. The elementary school truancy rate in Orange is 20 percent lower than that of the State.  Economic opportunities are high in the City of Orange compared to the State. There are high employment rates with a higher minimum basic income. The City also has a high availability of quality jobs.
 Housing opportunities in Orange and the State are fairly similar – both have the same cost burden of 52%. Orange has a homeownership rate of 53%, and housing adequacy is rated slightly lower than the State at 89%.
 Orange residents have relatively high access to mobility with greater access to vehicles and internet, but they do have slightly longer commutes than residents across the State.  Environmental and health indicators in the City of Orange are good. Infant health, prenatal care, and access to health care is rated higher than across the State, and teenage birth rates and years of life lost are lower in the City.
 The City has very similar rates of civic life participation as the State.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-86
Table 3-23: Opportunity Indicators - Orange and California ROI Indicator Orange Villa Park Anaheim Santa Ana California Education
People
College Educated Adults – Percentage of adults (age 25
and over) who have completed a post-secondary
certificate/degree.
40% 63% 29% 16% 38%
Math Proficiency – Percentage of 4th graders who scored proficient or above on the English Language Arts portion of California’s Standardized Testing and Reporting (STAR) test.
66% 87% 69% 72% 70%
English Proficiency – Percentage of 4th graders who
scored proficient or above on the math portion of
California’s Standardized Testing and Reporting (STAR)
test.
62% 89% 60% 54% 65%
Elementary Truancy – Percentage of students who have
missed more than 30 minutes of instruction without an
excuse at least three times during the school year.
4% 3% 16% 8% 24%
Place
High School Graduation Rate – Percentage of 9th grade
cohort that graduated from high school 4 years later. 93% 93% 86% 88% 83% UC/CSU Eligibility – Percentage of high school graduates who completed UC/CSU a-g course requirements. 38% 39% 38% 43% 41% Teacher Experience – Percentage of teachers at the
three closest public elementary schools with more than 5 years of teaching experience and at least one year of
education beyond a BA.
52% 61% 67% 54% 36%
High School Discipline Rate – Percentage of high school students in the school district who were suspended or
expelled.
5% 5% 4% 6% 6%
Economic
People
Employment Rate – Percentage of adults age 20-64
employed. 91% 90% 90% 91% 89%
Minimum Basic Income – Percentage of people with
income over 200% of the federal poverty level. 69% 90% 59% 46% 64% Place
Job Availability – Number of jobs per 1,000 people,
within a 5-mile radius. 1,014.28 1086.14 787.52 1090.41 701.75 Job Quality – Percentage of jobs that are in high-paying industries, within a 5-mile radius. 41% 41% 38% 45% 40% Job Growth – Percentage 1-year change in the number of
jobs, within a 5-mile radius. 3% 4% 2% 2% 3%
Bank Accessibility – Number of banks and credit unions
per 1000 people, within a 5-mile radius. 0.21 0.27 0.2 0.24 0.24 Housing
People
Home Ownership – Percentage of housing units owned
by their occupants. 53% 93% 47% 47% 55%
Housing Cost Burden – Percentage of households paying
less than 30% of household income on housing costs. 52% 63% 46% 45% 52% Place
Housing Adequacy – Percentage of households with no
more than 1 occupant per room. 89% 99% 81% 66% 91%

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-87
Table 3-23: Opportunity Indicators - Orange and California ROI Indicator Orange Villa Park Anaheim Santa Ana California Housing Affordability – Ratio of median income of census tract to median value of dwellings in census tract. 0.15 0.16 0.15 0.19 0.19 Mobility
People
Vehicle Availability – Percentage of households with at least 1 vehicle, or 1 vehicle per worker. 90% 99% 85% 81% 86% Commute Time – Percentage of workers whose
commute time is less than 30 minutes. 65% 68% 58% 65% 60% Internet Access – Number of households per 1,000 with
high-speed internet. 4.88 5 4.42 4.17 4
Health/Environmental
Place
Infant Health – Percentage of births at or above healthy weight, or 2500 grams/5.5 pounds. 96% 98% 95% 95% 95%
Birth to Teens – Percentage of all births to teens. 6% 0% 8% 11% 7% Years of Life Lost – Years of potential life lost. 25.62 20.35 26.38 26.29 29.84 Place
Air Quality – Annual mean concentration of PM2.5. 11.46 11.72 11.77 10.49 10.01 Prenatal Care – Percentage of mothers who received
prenatal care in first trimester. 90% 90% 87% 86% 83%
Access to Supermarket – Percentage who live within 0.5
miles (urban) or 10 miles (rural) of supermarket. 43% 20% 58% 75% 53% Health Care Availability – Number of providers of basic medical services per 1,000 population within 5 mile
radius

2.29 2.96 1.58 2.49 1.76
Civic Life
People
Voting Rates – Percentage of citizen, voting age
population that voted the 2010 general election. 31% 55% 25% 26% 31% English Speakers – Percentage of population age 18-64
that speaks only English or speaks English "well" or "very well".
88% 95% 81% 66% 88%
Place
US Citizenship – Percentage of adults who are U.S.
citizens. 82% 96% 73% 58% 83%
Neighborhood Stability – Percentage of citizens, over age 1, who live in the same residence as the previous year. 84% 90% 85% 88% 85% Source: UC Davis Center for Regional Change and Rabobank, 2014.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-88
Figure 3-11: Regional Opportunity Index, Orange and California

Source: UC Davis Center for Regional Change and Rabobank, 2014.

As Orange is considered a high opportunity region, the City is committed to implementing policies and programs to encourage new housing opportunities for existing and future residents. Section 4: Housing Plan identifies the strategies the City will explore in order to provide opportunity and housing for persons within the Orange/Orange County region.

0102030405060708090100
Orange AverageStatewide Average

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-89
California Tax Credit Allocation Committee (TCAC) Opportunity Area Map HCD together with the California Tax Credit Allocation Committee established the California Fair Housing Task Force to provide research, evidence-based policy recommendations, and other strategic recommendations to HCD and other related state agencies/departments to further the fair housing goals (as defined by HCD). The Task force developed the TCAC/HCD opportunity Area Maps to understand how public and private resources are spatially distributed. The Task force defines opportunities as pathways to better lives, including health, education, and employment. Overall, opportunity maps are intended to display which areas, according to research, offer low-income children and adults the best chance at economic advancement, high educational attainment, and good physical and mental health.

According to the Task Force’s methodology, the tool allocates the 20 percent of the tracts in each region with the highest relative index scores to the “Highest Resource” designation and the next 20 percent to the “High Resource” designation. Each region then ends up with 40 percent of its total tracts as “Highest” or “High” resource. These two categories are intended to help State decision-makers identify tracts within each region that the research suggests low-income families are most likely to thrive, and where they typically do not have the option to live—but might, if given the choice. Figure 3-12 below geographically displays data results for the City of Orange. Overall, the City is considered low to moderate resource, with the exception of some high resource areas to the southeast and northeast. The City’s west side is considered low resources, similar to surrounding jurisdictions such as Anaheim and Santa Ana. Given the extent of the City’s low and moderate resource areas, lower income and moderate income candidate housing sites have been identified in areas of low to moderate resources. The potential development of affordable housing units and mixed-use developments in these areas may create opportunities for additional resources to the existing community.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-90

Figure 3-12: TCAC Opportunity Areas, Orange
Source: California
Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-91

For many households, access to neighborhoods with higher levels of opportunity can be more difficult due to discrimination and when there may not be a sufficient range and supply of housing in such neighborhoods. In addition, the continuing legacy of discrimination and segregation can impact the availability of quality infrastructure, educational resources, environmental protections, and economic drivers, all of which can create disparities in access to opportunity.

Opportunity Areas – Education
The TCAC/HCD Opportunity Area Maps include education data, as illustrated in Figure 3-13. This data represents opportunity levels based on the following four factors:
 Math proficiency – Percentage of 4th graders who meet or exceed math proficiency standards.  Reading proficiency – Percentage of 4th graders who meet or exceed literacy standards.  High school graduation rates – Percentage of high school cohort that graduated on time.  Student poverty rate – Percentage of students not receiving free or reduced-price lunch.

Figure 3-13 shows areas of less positive education outcomes in the City’s center and western half. Areas of more positive education outcomes exist the west of the City.

Title I was established to provide all children with the opportunity to receive a fair, equitable, and high quality education as well as to help close the achievement gaps. Title I uses federal monies that are supplemental, meaning outside the general fund to help meet the needs of low-achieving students in the highest-poverty schools. Schools that qualify for these funds deliver supplemental services through a comprehensive school-wide plan required by the law. The main goal is to close the achievement gap and equalize education for all students. Within Orange Unified School District there are 13 Title I Elementary Schools, 2 Title I Middle Schools, and one Title I high School:
 California Elementary
 Cambridge Elementary
 Esplanade Elementary
 Fairhaven Elementary
 Handy Elementary
 Jordan Elementary
 Lampson Elementary
 Palmyra Elementary
 Prospect Elementary
 Sycamore Elementary
 Taft Elementary
 West Orange Elementary
 Community Day School (Targeted Title
I)
 Portola Middle School
 Yorba Middle School
 Orange High School

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-92

Figure 3-13: TCAC Education Opportunity Areas, Orange

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-93

Opportunity Areas – Economy
The TCAC/HCD Opportunity Area Maps include economic data, as illustrated in Figure 3-14. This data represents opportunity levels based on the following five factors:
 Poverty – Percent of population with income above 200 percent of federal poverty line.  Adult Education – Percent of adults with a bachelor's degree or above.  Employment – Percent of adults aged 20-64 who are employed in the civilian labor force or in the armed forces.
 Job Proximity – Number of jobs filled by workers with less than a Bachelor of Arts degree that fall within a given radius (determined by the typical commute distance of low-wage workers in each region) of each census tract population-weighted centroid.  Median Home Value - Value of owner-occupied units.

Figure 3-14 shows economic opportunity scores for Orange and the surrounding region. As illustrated, the City has fairly moderate to high positive economic outcome areas, with some areas of less positive outcomes to the north west and center of the City.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-94

Figure 3-14: TCAC Economy Opportunity Areas, Orange
Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-95

HUD developed the opportunity indicators to help inform communities about disparities in access to opportunity, the scores are based on nationally available data sources and assess resident’s access to key opportunity assets in the City. Table 3-24 provides the index scores (ranging from zero to 100) for the following opportunity indicator indices:

 Low Poverty Index: The low poverty index captures poverty in a given neighborhood. The poverty rate is determined at the census tract level. The higher the score, the less exposure to poverty in a neighborhood.
 School Proficiency Index: The school proficiency index uses school-level data on the performance of 4th grade students on state exams to describe which neighborhoods have high-performing elementary schools nearby and which are near lower performing elementary schools. The higher the score, the higher the school system quality is in a neighborhood.  Labor Market Engagement Index: The labor market engagement index provides a summary description of the relative intensity of labor market engagement and human capital in a neighborhood. This is based upon the level of employment, labor force participation, and educational attainment in a census tract. The higher the score, the higher the labor force participation and human capital in a neighborhood.
 Transit Trips Index: This index is based on estimates of transit trips taken by a family that meets the following description: a three-person single-parent family with income at 50 percent of the median income for renters for the region (i.e. the Core-Based Statistical Area (CBSA). The higher the transit trips index, the more likely residents in that neighborhood utilize public transit.  Low Transportation Cost Index: This index is based on estimates of transportation costs for a family that meets the following description: a three-person single-parent family with income at 50 percent of the median income for renters for the region/CBSA. The higher the index, the lower the cost of transportation in that neighborhood.
 Jobs Proximity Index: The jobs proximity index quantifies the accessibility of a given residential neighborhood as a function of its distance to all job locations within a region/CBSA, with larger employment centers weighted more heavily. The higher the index value, the better the access to employment opportunities for residents in a neighborhood.  Environmental Health Index: The environmental health index summarizes potential exposure to harmful toxins at a neighborhood level. The higher the index value, the less exposure to toxins harmful to human health. Therefore, the higher the value, the better the environmental quality of a neighborhood, where a neighborhood is a census block-group.

Table 3-24 below displays the opportunity indices by race and ethnicity for persons in Orange. According to the data, there is low poverty among the population of Orange, with the exception of the population who identified as black, with the lowest poverty score at 32.85. Additionally, the access to quality education system is moderate among all racial/ethnic groups (each group has an opportunity index score above 45 but not surpassing 65). The data shows the following:
 The City offers moderate labor and economic opportunity as well as sufficient access to transportation.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-96

 Transportation is considered affordable among all race and ethnic groups in the City (all scoring above 70).
 Very low environmental health index scores, meaning there is high exposure to harmful pollutants for all race and ethnic groups in the City. Each group has a score below 15, indicating poor environmental quality across the City, this can be due in part to high levels of traffic, proximity to industrial development or other natural environmental risks.

Table 3-24: Opportunity Indicators by Race/Ethnicity in the City of Orange (Orange, CA
CDBG)
Jurisdiction
Low
Poverty
Index
School
Proficiency
Index
Labor
Market
Index
Transit
Index
Low
Transportation
Cost Index
Jobs
Proximity
Index
Environmental
Health Index
Total Population
White, Non-
Hispanic 59.85 60.76 61.19 87.39 72.03 69.31 10.04
Black, Non-
Hispanic 52.12 48.57 51.47 89.40 77.99 78.41 8.77
Hispanic 48.30 50.65 52.77 88.89 76.83 76.42 9.01
Asian or
Pacific
Islander,
Non-Hispanic

59.06 58.78 59.94 87.51 72.50 67.82 9.94
Native
American,
Non-Hispanic

54.37 55.48 56.10 88.33 74.75 73.95 9.39
Population below federal poverty line
White, Non-
Hispanic 57.04 52.92 58.45 89.18 76.75 78.49 9.16
Black, Non-
Hispanic 32.85 42.16 41.19 83.58 78.05 89.55 9.52
Hispanic 45.47 53.35 53.02 89.09 76.93 73.57 9.08
Asian or
Pacific
Islander,
Non-Hispanic

52.82 43.86 48.07 89.57 79.90 81.30 8.42
Native
American,
Non-Hispanic

64.21 51.31 53.78 90.52 79.37 86.78 8.55
Source: Department of Housing and Urban Development, Fair Housing Maps, Accessed March 2021.

Access to Transit
Transit explores metrics that reveal the social and economic impact of transit, specifically looking at connectivity, access to jobs, and frequency of service. According to the data provided, Orange scored a

5.1 AllTransit performance score, illustrating a moderate combination of trips per week and number of jobs accessible that enable a moderate number of people to take transit to work. In comparison to neighboring cities – Santa Ana scored a 6.6, Anaheim scored a 4.9, Villa Park scored a 1.4, and Tustin

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-97

scored a 4.8. Access to transportation increases both the economic and environmental/health opportunities. Additionally, AllTransit provides the following data for Orange transportation:
 99% of jobs are located within ½ of transit.
 78,470 customer households have access to a business within a 30-minute transit commute.  3.35% of workers walk to work and 0.96% bike to work
 There are no households within a ½ miles of high frequency transit.  On average, there are 5 transit routes within ½ of a block group on average.

Table 3-25: Opportunity Indicator – Transit
Jurisdiction
AllTransit
Performance
Score
Transit Trips
Per Week
within 1/2 Mile
Jobs Accessible
in 30-min trip
Commuters Who
Use Transit
Transit Routes
within 1/2 Mile
Orange 5.1 775 224,776 2.9% 5
Orange
County 4.2 528 172,595 2.28% 4
Source: AllTransit Fact Sheet, Orange, 2022.

Figure 3-15: AllTransit Performance Score – Orange

Source: AllTransit Fact Sheet, 2021.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-98

Environmental Burdens
The California Office of Environmental Health Hazard Assessment (OEHHA) developed a screening methodology to help identify California communities disproportionately burdened by multiple sources of pollution called the California Communities Environmental Health Screening Tool (CalEnviro Screen). In addition to environmental factors (pollutant exposure, groundwater threats, toxic sites, and hazardous materials exposure) and sensitive receptors (seniors, children, persons with asthma, and low birth weight infants), CalEnviro Screen also takes into consideration socioeconomic factors. These factors include educational attainment, linguistic isolation, poverty, and unemployment. Research has shown a heightened vulnerability of people of color and lower socioeconomic status to environmental pollutants.

Figure 3-16 below displays mapped results for the CalEnviro Screen in Orange and the Orange County region. The map shows that Orange is made up of mostly moderate to low percentile census tract – reflecting a community that is not overly burdened by environmental factors.

Table 3-26 and 3-27 below identifies the CalEnviro Screen scores for the highest and lowest scoring census tracts in Orange, respectively. Table 3-26 shows the City’s most environmentally burdened census tract (CalEnviroScreen 4.0 Percentile: 76) which has a population made up of 79.8 percent Hispanic, 9.5 percent White, 6.4 percent Asian American, 2.2 percent Native American, 1.3 percent Other, and 0.8 percent African American. Table 3-27 shows the City’s least environmentally burdened census tract (CalEnviroScreen 4.0 Percentile: 7) which has a population made up of 71.8 percent White, 20 percent Hispanic, 5.4 percent Asian American, and 2.5 precent Other.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-99

Table 3-26: CalEnviro Screen 4.0 – Highest Scoring Census Tract (6059076204) Pollutant Percentile* Health Risk/Burden Percentile*
Ozone 54 Asthma 30
Particulate Matter 2.5 83 Low Birth Weight 12
Diesel Particulate Matter 74 Cardiovascular Rate 34
Pesticides 20 Education 90
Toxic Releases 99 Linguistic Isolation 79
Traffic 37 Poverty 77
Drinking Water 55 Unemployment 47
Cleanup Sites 99 Housing Burden 68
Groundwater Threats 70
Hazardous Waste 99
Impaired Waters 0
Solid Waste 93
*Percentile derived using a weighted scoring system to determine average pollution burden/ socioeconomic scores relative to other census tracts.

Source: CalEnviro Screen 4.0 Map Tool. Accessed May 23, 2022.

Table 3-27: CalEnviro Screen 4.0 – Highest Scoring Census Tract (6059075808) Pollutant Percentile* Health Risk/Burden Percentile*
Ozone 58 Asthma 10
Particulate Matter 2.5 69 Low Birth Weight 1
Diesel Particulate Matter 68 Cardiovascular Rate 6
Pesticides 1 Education 15
Toxic Releases 88 Linguistic Isolation 6
Traffic 87 Poverty 29
Drinking Water 55 Unemployment 28
Cleanup Sites 44 Housing Burden 3
Groundwater Threats 50
Hazardous Waste 10
Impaired Waters 0
Solid Waste 76
*Percentile derived using a weighted scoring system to determine average pollution burden/ socioeconomic scores relative to other census tracts.

Source: CalEnviro Screen 4.0 Map Tool. Accessed May 23, 2022.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-100

Figure 3-16: CalEnviroScreen 4.0 – Orange

Source: AllTransit Fact Sheet, 2021.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-101

Discussion of Disproportionate Housing Needs
The analysis of disproportionate housing needs within Orange evaluated existing housing need, need of the future housing population, and units within the community at-risk of converting to market-rate.

Future Growth Need
The City’s future growth need is based on the RHNA production of 1,067 very low and 604 low income units within the 2021-2029 planning period. Appendix B of this Housing Element shows the City’s ability to meet its 2021-2029 RHNA need at all income levels. This demonstrates the City’s ability to accommodate the anticipated future affordable housing needs of the community.

Existing Need
As described in Section 3.F.1 of this Housing Element, the Orange County Housing Authority administers Section 8 Housing Choice vouchers within the City of Orange. Additionally, the City currently has a 206 household waitlist to receive Section 8 Housing Choice vouchers.

Housing Needs in Orange
A variety of factors affect housing needs for different households. Most commonly, disability, household income and households’ characteristics shape the type and size of housing units needed, as well as accessibility based on existing units in a City. Tables 3-28 through 3-35 displayed data for demographic characteristics of Orange, as compared to the County of Orange and the State of California. Additional detailed analysis of the Orange community demographics is outlined in Chapter 2: Community Profile of this Housing Element.

Table 3-28 displays the data for persons with disabilities in the City, County, and State. Overall, about 10 percent of the California population reported having at least one disability. In the City, about 8 percent of persons reported at least one disability. The County reported a slightly higher percentage than the City and the City at 8.5 percent. Of the 8 percent Orange residents who reported a disability, the majority were independent living and ambulatory difficulties, which could be tied to the City’s senior population. Ease of reasonable accommodation procedures and opportunity for accessible housing can provide increased housing security for the population with disabilities.

Figure 3-17 and 3-18 show the trend and propensity for persons having at least one disability throughout Orange. Between 2014 and 2019, the City has decreased in the census tracts reporting 10 to 20 percent of the population having at least one disability. Based on the two figures, the data may indicate a move towards neighborhoods north of the City.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-102

Table 3-28: Population by Disability Type, Compared by Geography, 2019 Disability City of Orange County of Orange California
Total with a Disability 8.1% 8.5% 10.6%
Hearing Difficulty 2.3% 2.5% 2.9%
Vision Difficulty 1.1% 1.5% 2%
Cognitive Difficulty 3.4% 3.4% 4.3%
Ambulatory Difficulty 4.2% 4.5% 5.8%
Self-care Difficulty 2.2% 2.2% 2.6%
Independent Living 4.0% 4.3% 5.5%
Source: American Community Survey, 5-Year Estimates, 2019.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-103

Figure 3-17: Population with a Disability, Orange (2014)

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-104

Figure 3-18: Population with a Disability, Orange (2019)

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-105

Table 3-29 displays household type and income data for the State, County and City. Overall, the City has a larger percentage of family households than the County and State; this includes family households, married-couple family households, and those with children. Of the three jurisdictions, the State has the largest percentage of non-family households at approximately 2 percent more than Orange County and about 6 percent more than the City. The City has a higher percentage of households with at least one senior over the age of 60 as compared to the state (29.2 percent) but a lower percentage than the County (39.9 percent).

Table 3-29: Population by Familial Status, Compared by Geography, 2019 Familial Status City of Orange County of Orange California Total Households 43,075 1,037,492 13,044,266
Family Households 73.1% 71.7% 68.7%
Married-Couple Family
Households 56.2% 54.9% 49.8%
With Children 23.7% 30.9% 34%
Non-Family Households 26.8% 28.3% 31.3%
Households with one or more
people 60 years+ 37.8% 39.9% 29.2%
Source: American Community Survey, 5-Year Estimates. 2019

Regarding household income, the City had a higher median household income than the County and State in 2019 ($91,793). As Table 3-30 shows, majority of the City’s households are higher earning; in total 45 percent (nearly half of the City’s households) earn $100,000 or more. In the state, nearly 38 percent of households earn $100,000 or more and 45.2 percent in the County of Orange. Just under 26 percent of City residents earn less than $50,000 annually, compared to 27 percent and 34 percent for the County and State, respectively.

Table 3-30: Households by Income, Compared by Geography, 2019 Households Income City of Orange County of Orange California Less than $10,000 3.7% 4.2% 4.8%
$10,000-$14,999 2.5% 2.7% 4.1%
$15,000-$24,999 5.1% 5.6% 7.5%
$25,000-$34,999 5.4% 6.0% 7.5%
$35,000-$49,999 8.9% 8.8% 10.5%
$50,000-$74,999 16.1% 14.6% 15.5%
$75,000-$99,999 12.8% 12.8% 12.4%
$100,000-$149,999 19.7% 18.6% 16.6%
$150,000-$199,999 12.2% 11.1% 8.9%
$200,000 or More 13.5% 15.5% 12.2%
Median Income $91,793 $90,234 $75,235
Source: American Community Survey, 5-Year Estimates, 2019

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-106

Figure 3-19 shows the percentage of married-couple households living throughout the City of Orange and neighboring communities. As the figure shows, married-couple households increase towards the east and decrease towards the west. The lowest percentages of married-couple households are surrounding the downtown Orange and Outlets at Orange areas. Figure 3-20 shows a similar trend for households with children living in married-couple family households.

Figure 3-21 shows children living in female households without a spouse present. The majority of the City has lower percentages, except for a few census tracts reporting 20 to 40 percent of children living in female-headed households. These few census tracts overlap with those that report lower percentages of married-couple family households.

Figure 3-22 shows the City of Orange has very little single-occupancy households. As is the trend with most neighboring communities, all census tracts in the City report less than 20 percent persons over 18 years of age in households living alone.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-107

Figure 3-19: Married-Couple Households, Orange

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-108

Figure 3-20: Children in Married-Couple Households, Orange

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-109

Figure 3-21: Children in Female-Headed Households, Orange

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-110

Figure 3-22: Persons Living Alone, Orange

Source: California Department of Housing and Community Development – AFFH Data Viewer

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-111

Table 3-31 displays data for households experiencing overpayment or cost burden in the State, County and City. Housing Cost burden has a number of consequences for a household, mainly displacement from their existing living situation creating limited access essential goods and often employment by potentially increasing commute times. Overall, the percentage of households that experience a cost burden greater than 30 percent is similar amongst the City, County, and State with all three reporting about 20 percent.

The City has a slightly lower percentage of households that have a high cost burden over 50 percent (17.8 percent in the City, compared to about 19 percent in the County and State). Increased opportunity for affordable housing and housing assistance funds help to prevent cost burden on households.

Table 3-31: Households by Overpayment, Compared by Geography Overpayment/Cost Burden City of Orange County of Orange California Cost Burden > 30% 20.3% 21.2% 20.67%
Cost Burden > 50% 17.8% 19.3% 19.4%
Cost Burden Not Available 1.1% 1.4% 1.4%
Source: Consolidated Planning/CHAS Data, 2013- 2017.

Table 3-32 displays data for household tenure (owner vs. renter) for the State, County and City.

Homeownership is a crucial foundation for helping families with low incomes build strength, stability and independence. The opportunity for transition into the homebuyer’s market is important for persons and households in different communities, homeownership allows for increased stability and opportunity to age in place. Table 3-32 shows that the City has a comparable rate of homeownership to the County and a slightly lower ownership rate that the State.

Additionally, Table 3-33 displays data for overcrowding in the State, County and City. Overcrowding is defined as between 1.01 and 1.5 persons per room in a household, and severe overcrowding is defined as more than 1.51 persons per room. Overcrowding often occurs when nonfamily members combine incomes to live in one households, such as college students and roommates, it also occurs when there is not enough size appropriate housing options for large or multigenerational families. The City experiences low rates of overcrowding in comparison to the County and the State. According to the data, overcrowding occurs more frequently in renter households rather than owner households. In Orange, owner households that are severely overcrowded represent 0.7 percent of all households, while severely overcrowded renter households represent 4.5 percent, a trend similar in the County and State.

Table 3-32: Households by Tenure, Compared by Geography, 2019 Household Tenure City of Orange County of Orange California Owner Households 57.9% 57.4% 66.0%
Renter Households 42.1% 42.6% 34.0%
Total Occupied Housing Units 43,075 1,037,492 13,044,266 Source: American Community Survey, 5-Year Estimates, 2019.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-112

Table 3-33: Households by Overcrowding, Compared by Geography Overcrowding and Tenure City of Orange County of Orange California Owner Households
Overcrowded 1.4% 2.6% 1.6%
Severely Overcrowded 0.7% 1.0% 0.6%
Renter Households
Overcrowded 10.1% 9.8% 3.6%
Severely Overcrowded 4.5% 6.0% 2.4%
Source: American Community Survey, 5-Year Estimates, 2019.

Housing Stock in Orange
Table 3-34 displays comparative housing stock data for the State, County and City. Table 3-34 below shows data for occupied housing units by type. A variety of housing stock provides increased opportunity in communities for different size and households types. The majority of housing stock in Orange is classified as one-unit, detached housing, or single-family housing. Just under 13 percent of Orange homes include 20 or more units, referred to as multi-family housing. In comparison to the County Orange has a greater amount of single-family homes, and an overall smaller number multi-family housing (2 or more units).

Table 3-34: Occupied Housing Units by Type, Compared by Geography Housing Unit Type City of Orange County of Orange California 1, detached 54.9% 50.6% 57.7%
1, attached 9.6% 12.3% 7.0%
2 units 3.0% 1.6% 2.4%
3 or 4 units 8.7% 6.9% 5.5%
5 to 9 units 5.2% 6.7% 6.0%
10 to 19 units 3.4% 5.4% 5.2%
20 or more units 12.8% 13.7% 12.3%
Mobile home or other type of housing 2.4% 2.7% 3.7%
Source: American Community Survey, 5-Year Estimates, 2019.

Table 3-35 below displays housing stock by year built or the City, County, and State. Older housing generally requires more upkeep, regular maintenance and can cause a cost burden on both renters and homeowners. Majority of Orange’s housing stock was built between 1950 and 1989, the City has a large number of historic homes and historic districts. When well maintained, historic homes can be energy efficient by design, they may also allow for subsidies in exchange for maintenance.

Majority of the County’s and State’s housing units were built between 1980 and 2009 whereas the distribution of development was more dispersed from 1950 to 1990 in the State. Overall, increased numbers of older housing which is not maintained can lead to cost burden and substandard living conditions.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-113

Table 3-35: Housing Unit by Type, Compared by Geography Year Built City of Orange County of Orange California Built 2014 or later 1.1% 2.7% 1.7% Built 2010 to 2013 1.3% 2.0% 1.7%
Built 2000 to 2009 7.1% 8.3% 11.2%
Built 1990 to 1999 9.9% 11.7% 10.9%
Built 1980 to 1989 11.6% 14.9% 15.0%
Built 1970 to 1979 22.9% 23.3% 17.6%
Built 1960 to 1969 24.2% 19.5% 13.4%
Built 1950 to 1959 14.6% 13.0% 13.4%
Built 1940 to 1949 1.8% 2.1% 5.9%
Built 1939 or earlier 5.5% 2.5% 9.1%
Source: American Community Survey, 5-Year Estimates, 2019.

Displacement Risk
The potential for economic displacement risk can result from a variety of factors, including large-scale development activity, neighborhood reinvestment, infrastructure investments, and changes in local and regional employment opportunity. Economic displacement can be an inadvertent result of public and private investment, where individuals and families may not be able to keep pace with increased property values and market rental rates.

Urban Displacement
The Urban Displacement Project (UDP) is a research and action initiative of the University of California Berkeley and the University of Toronto. UDP conducts community-centered, data-driven, applied research toward more equitable and inclusive futures for cities. UDP developed a neighborhood change database to map neighborhood transformations and identify areas vulnerable to gentrification and displacement, based on 2015 data from the American Community Survey. This data was developed to assist local decision makers and stakeholders better plan for existing communities and provide additional resources to areas in need or at-risk of displacement and gentrification.

Figure 3-15 shows there are large area of the City currently marked as Stable Moderate/Mixed Income and Stable/Advance Exclusive. Only a few census tracts are actively at risk or currently becoming exclusive.

Additionally, the City has one census tract which contains Chapman University and is identified as a High Student Population area. There currently are not any census tracts reporting ongoing displacement or gentrification in the City.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-114

Figure 3-23: Urban Displacement Project - Gentrification and Displacement

Source: Urban Displacement Project, University of California Berkeley (2021).

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-115

Table 3-36 is a key for Figure 3-23, pulled directly from the data source.

Table 3-36: Displacement Typology Criteria and Orange Census Tracts Modified Types and Criteria
Low-Income/Susceptible to Displacement
 Low or mixed low-income tract in 2018.

Ongoing Displacement of Low-Income Households
 Low or mixed low-income tract in 2018.
 Absolute loss of low-income households, 2000-2018.

At Risk of Gentrification
 Low or mixed low-income tract in 2018.
 Housing affordable to low or mixed low-income households in 2018.  Didn’t gentrify 1990-2000 OR 2000-2018.
 Marginal change in housing costs OR Zillow home or rental value increases in the 90th percentile between 2012-2018.
 Local and nearby increases in rent were greater than the regional median between 2012-2018 OR the 2018 rent gap is greater than the regional median rent gap.

Early/Ongoing Gentrification
 Low or mixed low-income tract in 2018.
 Housing affordable to moderate or mixed moderate-income households in 2018.  Increase or rapid increase in housing costs OR above regional median change in Zillow home or rental values between 2-12-2018.
 Gentrified in 1990-2000 or 2000-2018.

Advanced Gentrification
 Moderate, mixed moderate, mixed high, or high-income tract in 2018.  Housing affordable to middle, high, mixed moderate, and mixed high-income households in 2018.  Marginal change, increase, or rapid increase in housing costs.  Gentrified in 1990-2000 or 2000-2018.

Stable Moderate/Mixed Income
 Moderate, mixed moderate, mixed high, or high-income traact in 2018.

At Risk of Becoming Exclusive
 Moderate, mixed moderate, mixed high, or high-income tract in 2018.  Housing affordable to middle, high, mixed moderate, and mixed high-income households in 2018.  Marginal change or increase in housing costs.

Becoming Exclusive
 Moderate, mixed moderate, mixed high, or high-income traact in 2018.  Housing affordable to middle, high, mixed moderate, and mixed high-income households in 2018.  Rapid increase in housing costs.
 Absolute loss of low-income households, 2000-2018.
 Declining low-income in-migration rate, 2012-2018.
 Median income higher in 2018 than in 2000.

Stable/Advanced Exclusive
 High-income tract in 2000 and 2018
 Affordable to high or mixed high-income households in 2018.  Marginal change, increase, or rapid increase in housing costs.

High Student Population
Source: Urban Displacement Project, University of California Berkeley (2021).

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-116

Assisted Units “At-Risk” of Conversion
Appendix B of this housing Element outlines the City’s strategy to accommodate growth and future housing production in Orange. The RHNA accommodation strategy does not include plans or identifies land to accommodate new housing, which will replace current residents, specifically residents in affordable housing. Displacement can also occur as covenants for deed restricted affordable housing units expire. Affordable covenants help to ensure that certain housing units remain affordable for an extended period. Covenants help balance the housing market in a community and provide lasting affordable options to low and very low-income households. Table 3-37 below display the data for persons within the City of Orange who qualify for supported low income housing.

Table 3-37: Publicly Supported Housing Demographics, Orange Orange (City) White Black Hispanic Asian or Pacific Islander Housing Type # % # % # % # %
Project-Based
Section 8 89 49.17% 2 1.10% 76 41.99% 13 7.18%
HCV Program 221 35.25% 44 7.02% 218 34.77% 144 22.97%
LIHTC 943 39.03% 47 1.95% 1347 55.75% 104 4.30%
Total
Households 24,840 57.94% 430 1.00% 11,370 26.52% 5,535 12.91% 0-30% of AMI 2,880 50.79% 50 0.88% 1,880 33.16% 740 13.05% 0-50% of AMI 4,290 41.67% 65 0.63% 3,785 36.77% 1,270 12.34% 0-80% of AMI 8,130 45.70% 200 1.12% 6,635 37.30% 1,800 10.12% Source: County of Orange Analysis of Impediments to Fair Housing, 2020-2024.

Additionally, Table 3-38 below identifies all deed restricted projects in Orange. There is one current project with covenants which will expire in the 2021-2029 planning period.

Table 3-38: Affordable Housing Units in Orange with Covenants and Deed Restrictions Project Name/Address Tenant Type Number of Assisted Unit Number of
Bedrooms
Starting Years of
Restriction
Ending Year of
Restriction
Adams Triplex I
1837-1841 East Adams
Avenue Orange, CA 92867
Family 3 1, 2, and 3 1997 2027
Adams Triplex II 1915-1919 East Adams Avenue Orange, CA 92867 Family 3 1, 2, and 3 1998 2053 Adams Triplex III 1741-1745 East Adams Avenue Orange, CA 92867 Family 3 1, 2, and 3 1999 2054 Alice Clark Orange Blossom Apartments 141 East Walnut Avenue Orange, CA 92867 Elderly 4 1, 2, and 3 1997 2052
Allure Apartments 3099 West Chapman Avenue Orange, CA 92867 Workforce
Housing 265 0, 1, and 2 2021 2051
Cameo Apartments 1055 West Town and Country Road Orange, CA 92867 Workforce
Housing 262 0, 1, 2, and 3 2021 2051
Casas Del Rio 1740 E La Veta Avenue Orange, CA 92866 Elderly 40 1 and 2 N/A 2028*

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-117

Table 3-38: Affordable Housing Units in Orange with Covenants and Deed Restrictions Project Name/Address Tenant Type Number of Assisted Unit Number of
Bedrooms
Starting Years of
Restriction
Ending Year of
Restriction
Chestnut Place/Fairway Manor 1745 East Fairway Drive Orange, CA 92866 Elderly 49 1, 2, and 3 1996 2051
Citrus Grove Apartments 1120 North Lemon Street Orange, CA 92867 Family 56 1, 2, and 3 2010 2065 Esplanade Street Apartments 264-280 South Esplanade Street Orange, CA 92869 Family 27 1, 2, and 3 2001 2056 Friendly Center** 147 W Rose Avenue Orange, CA 92867 Family 8 1, 2, and 3 N/A 2021 Garrison Apartments 1725 West Katella Avenue Orange, CA 92867 Workforce
Housing 94 0, 1, and 2 2021 2051
Harmony Creek Senior Apartments 1616 East Rock Creek Drive Orange, CA 92866 Elderly 41 1, 2, and 3 1997 2052
Hoover Avenue Apartments I 108-118 West Hoover Avenue Orange, CA 92867 Family 20 1, 2, and 3 2006 2071 Hoover Avenue Apartments II 218-228 West Hoover Avenue Orange, CA 92867 Family 20 1, 2, and 3 2007 2072 Huang, Yu Ming 191 N. Parker Street; 628 &
642 W. Maple Avenue,
Orange, CA 92868
Family 2 1, 2, and 3 1991 In Perpetuity
The Knolls/Villa Santiago
3138 East Maple Avenue
Orange, CA 92869
Family 258 1 1996 2046
Lemon Grove Apartments 1148 North Lemon Street
Orange, CA 92867 Family 81 1, 2, and 3 2017 2072
Lemon Street Apartments
481-491 Lemon Street
Orange, CA 92866 Family 6 1, 2, and 3 2001 2056
OHDC/Orange Rotary Senior Plaza 235 West La Veta Avenue Orange, CA 92866 (nonprofit) Elderly 6 1, 2, and 3 2004 2059
Orange Garden Apartments
1931, 1941, & 2003 East
Quincy Avenue Orange, CA 92867
Family 24 1, 2, and 3 1997 2052
Orchid Gardens 1051 N. Glassell Street Orange, CA 92866 Elderly 17 1, 2, and 3 1989 In Perpetuity Parker Apartments 161 North Parker Street Orange, CA 92868 Family 2 1, 2, and 3 1995 2050 Pixley Arms 537 West Almond Avenue Orange, CA 92866 Elderly 15 1, 2, and 3 1995 In Perpetuity Plaza Garden Apartments Family 56 1, 2, and 3 1997 2052

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-118

Table 3-38: Affordable Housing Units in Orange with Covenants and Deed Restrictions Project Name/Address Tenant Type Number of Assisted Unit Number of
Bedrooms
Starting Years of
Restriction
Ending Year of
Restriction
1907, 1935, 1943, & 2003 East
Monroe Avenue 1934, 1942,
& 2002 East Quincy Avenue Orange, CA 92867 Rose Avenue Apartments 1743 East Rose Avenue Orange, CA 92867 Family 6 1, 2, and 3 1998 2053 Serrano Woods 1820 East Meats Avenue Orange, CA 92865 Family 62 1, 2, and 3 2013 2068 Stonegate Senior Apartments 170 North Prospect Street Orange, CA 92869 Elderly 20 1, 2, and 3 2004 2059 Villa Modena Apartments 4431 East Marmon Avenue Orange, CA 92869 Family 5 1, 2, and 3 2001 2056 Walnut Court 1519 East Walnut Avenue Orange, CA 92867 Family 7 1, 2, and 3 1995 In Perpetuity Walnut-Pixley 1519 E Walnut Avenue Orange, CA 92867 Family 22 1, 2, and 3 N/A 2049 Wilson Avenue Apartments I
1924 & 1934 East Wilson
Avenue Orange, CA 92867
Family 20 1, 2, and 3 2001 2056
Wilson Avenue Apartments II 1844 East Wilson Avenue Orange, CA 92867 Family 10 1, 2, and 3 2004 2069 Wilson Avenue Apartments III 1944 East Wilson Avenue Orange, CA 92867 Family 10 1, 2, and 3 2007 2062
*Casas Del Rio’s current affordability is tied to their loan which terminates in 2028; however, their mission is to preserve the affordability of the units in perpetuity
**The Friendly Center intends to take action to maintain its affordable housing component through Section 8 in 2022.

Source: City of Orange, Affordable Housing Resource Toolkit, Affordable Housing Compliance List, Accessed April 2021.

Cost of Preservation of Units
There are many options to preserving units, including providing financial incentives to project owners to extend lower income use restrictions, purchasing affordable housing units by a non-profit or public agency, or providing local subsidies to offset the difference between the affordable and market rate units.

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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-119

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 31 3 $517 $16,027 $192,324
2-Bedroom $2,324 $2,989 20 3 $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 31 3 3,092,014
2-Bedroom $131.24 1,106 $145,151 20 3 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.

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

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-120

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

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-121

 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

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-122

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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-123

 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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-124

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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-125

Figure 3-24: Candidate Sites – Ethnicity Analysis

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-126

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 Non- White.

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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-127
Figure 3-25: Candidate Sites – Non-White Analysis

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-128

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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-129

Figure 3-26: Candidate Sites – Low/Moderate Income Block Group Analysis

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-130
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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-131

Figure 3-27: Candidate Sites – R/ECAP Areas

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-132

Figure 3-28: Candidate Sites – RCAA Areas

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-133

Figure 3-29: Candidate Sites – TCAC/HCD Opportunity Areas

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-134
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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-135
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.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-136
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

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-137
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 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 at-
risk units, work with property owners to
maintain affordability and develop
preservation strategies, and assist with
funding when available.

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-138
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 Lower-
Income Households – The City will
develop a program to subsidize
application processing fees, when funding
is available, for qualifying developments

Section 3: Housing Constraints, Resources, and Fair Housing 2021-2029 Housing Element Update - Draft 3-139
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.

Section 4: Housing Plan

Section 4: Housing Plan 4-2
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.

Section 4: Housing Plan 4-3
2021-2029 Housing Element Update - Draft
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 market- rate 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.

Section 4: Housing Plan 4-4
2021-2029 Housing Element Update - Draft
 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.

Section 4: Housing Plan 4-5
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-6
2021-2029 Housing Element Update - Draft
Housing Policy Action 2B: Promotion of Affordable Housing The City recognizes the need for housing affordable to 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 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

Section 4: Housing Plan 4-7
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-8
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-9
2021-2029 Housing Element Update - Draft
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 off- campus 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

Section 4: Housing Plan 4-10
2021-2029 Housing Element Update - Draft
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.

Section 4: Housing Plan 4-11
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-12
2021-2029 Housing Element Update - Draft
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.

Section 4: Housing Plan 4-13
2021-2029 Housing Element Update - Draft
 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.1 Aim 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.

Section 4: Housing Plan 4-14
2021-2029 Housing Element Update - Draft
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 high-
opportunity 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.

Section 4: Housing Plan 4-15
2021-2029 Housing Element Update - Draft
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.

Section 4: Housing Plan 4-16
2021-2029 Housing Element Update - Draft
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 long-
range 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 decision-
making 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

Section 4: Housing Plan 4-17
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-18
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-19
2021-2029 Housing Element Update - Draft
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.

Section 4: Housing Plan 4-20
2021-2029 Housing Element Update - Draft
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

Section 4: Housing Plan 4-21
2021-2029 Housing Element Update - Draft
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.

Appendix A: Review of Past Performance

Appendix A: Review of Past Performance A-2
2021-2029 Housing Element Update - Draft
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.

Appendix A: Review of Past Performance A-3
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.

Appendix A: Review of Past Performance A-4
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.

Appendix A: Review of Past Performance A-5
2021-2029 Housing Element Update - Draft
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.

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.

Appendix A: Review of Past Performance A-6
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 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 Extremely-
With 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

Appendix A: Review of Past Performance A-7
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 Low-
Income Housing
Units, 59 Low-
Income 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

Appendix A: Review of Past Performance A-8
2021-2029 Housing Element Update - Draft
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

Appendix A: Review of Past Performance A-9
2021-2029 Housing Element Update - Draft
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 non-
profit developers, to
explore partnerships and
provide in-kind assistance
in developing affordable
housing within Orange.

Appendix A: Review of Past Performance A-10
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 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.

Appendix A: Review of Past Performance A-11
2021-2029 Housing Element Update - Draft
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.

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 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.

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-, moderate-
and above moderate-
income categories.

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.

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.

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 non-
profit 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 non-
residential 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

Appendix A: Review of Past Performance A-16
2021-2029 Housing Element Update - Draft
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

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 mixed-
use 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, city-
wide 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.

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 non-
traditional 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 internet-
based 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.

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.

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.

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 single-
family 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.

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 inter-
jurisdictional 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, 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.

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.

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.

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

Appendix A: Review of Past Performance A-25
2021-2029 Housing Element Update - Draft
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 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.
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.

Appendix A: Review of Past Performance A-26
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 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 Single-
Room 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.

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, deed-
restricted 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 at-
risk units
The City continues to monitor potential "At-
Risk" 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.

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.

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.

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.

Appendix B: Candidate Sites Analysis

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

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:

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),

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/very- low 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:

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.

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.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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.

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%

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%

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

METROPOLITAN

ORANGE CITY MILLS

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

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

METROPOLITAN
DR

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

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

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

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

Orange City CouncilFebruary 14, 2023

Orange City Council
February 14, 2023