Attachment 2 Revised Draft 2021-2029 Housing Element Update (tracked changes), October 2023 — Orange City Council, October 30, 2023 (part 2 of 2)

Appendix B: Candidate Sites Analysis B‐13
2021‐2029 Housing Element Update
 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.

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.

Parcel 23113140 (1 City Blvd. West) is located adjacent to the Outlets property The City has previously processed a mixed‐use application on this site with a proposed 300+ residential units; however, that application was put on hold by the developer and ultimately did not move forward. 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.

Appendix B: Candidate Sites Analysis B‐14
2021‐2029 Housing Element Update
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 additional projects 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 and other Agreement 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.

To analyze whether existing leases, CC&Rs, and other agreements may present an impediment to future development, the City conducted outreach to several local stakeholders with experience in developing or operating market rate and affordable housing projects in the City of Orange.   These individuals all have recent experience developing on infill sites within Orange and successfully worked through existing agreements on the properties in order to develop their projects.  They provided the following feedback on the process and how infill sites with existing uses often redevelop within the City:
 Given the built‐out nature of the City of Orange and many Southern California communities where their companies are active, there are very few, if any, sites suitable for housing development that don’t have some form of property encumbrances.   They are generally not discouraged by such conditions and structure the financing and construction phasing of the project to accommodate property negotiation, timing of lease agreements, and amendment of CC&Rs.   All three developers indicate they do not view CC&Rs as a problem when considering the redevelopment of a site.   In some instances they find that CC&Rs can actually be a helpful tool for guiding developers who are working with other tenants on the site.   This relates primarily to site designated with Development Scenario B.
 Oftentimes site encumbrances involve the surface parking lots surrounding buildings that are impacted by access and utility easements, or lease agreements that establish anchor tenant control of parking fields.  These factors have not been a source of discouragement.  To quote one of the developers, “(a)ny site with a ton of surface parking is a viable site.”  Even where existing CC&Rs entitle tenants to the continued use of surface parking, developers find that they are able to work with tenants on revisions to the CC&Rs that achieve a mutually agreeable arrangement.

This relates primarily to site designated with Development Scenarios A and B.  In general, site encumbrances can influence the land value and financial dynamics of a site in different ways. All developers indicate that the circumstances vary from site to site depending on

Appendix B: Candidate Sites Analysis B‐15
2021‐2029 Housing Element Update
the parties involved and the status of tenancy. Developers commonly factor in a 3‐5 year timeframe to work through these issues, often concurrently with a city entitlement process and expect the related costs as a typical aspect of residential development projects on urban infill sites. They indicated that there are advantages working with infill sites that can accommodate continued operation of existing businesses (e.g. new infill housing at an existing mall or commercial center). The ability to generate revenue on the site from remaining commercial uses while the housing is under entitlement and construction can help bring the project to fruition.

This relates primarily to site designated with Development Scenario A and B.  Where a property has established leases with major retail tenants, leases tend not to be an issue with respect to infill residential development on surface parking lots of mall sites (such as the Outlets of Orange) given that the residential uses do not compete with the retail uses, and in some cases complements them. Most big box tenants are quick and easy to work with. This relates primarily to site designated with Development Scenario A and B.  Existing long‐term leases and existing financing, such as Commercial Mortgage Backed Securities (CMBS) loans present a bigger impediment to phased or partial redevelopment of obsolete commercial properties than any encumbrances. That said, CMBS loans have relatively short terms (10 years maximum, and typical 5‐7 years), and even legacy long‐term retail leases typically have remaining terms that are within the time horizon of the City's Housing Element. The bigger challenge on retail sites can involve the reciprocal provisions of leases that many anchor tenants (Target, Sears, Kroger) used to be able to negotiate such as requirements that certain other complementary tenants operate in the center, minimum operating hours, etc. However, as many big box retailers move further into obsolescence, even these provisions can be negotiated away in most cases. These are challenges and considerations, but should not be viewed as impediments.

This relates primarily to site designated with Development Scenario B.  Commercial centers with multiple smaller tenant leases are more difficult to work with given the lack of alignment of the duration of the leases and the potential need to buy the individual tenants out of their leases. As an alternative to buying out the leases, developers also consider simply waiting until the leases reach the end of their term, which then adds time and cost to project development.
 Developer interest in opportunities for higher density projects are aligned with the allowable 60 unit per acre density accommodated in the Urban Mixed Use districts of the City where the majority of candidate housing sites are located, and indicated that the possibility of higher densities that support the economic viability of a project are always desirable. To that end, the City is in the process of preparing a Transfer of Development Rights Ordinance, expected to be adopted by early 2024 that would enable higher densities to be achieved in Urban Mixed Use districts.

In addition to the outreach to developers described above, 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. These factors all support the viability of the identified candidate housing sites to redevelop for housing within the planning period.

Appendix B: Candidate Sites Analysis B‐16
2021‐2029 Housing Element Update
Outreach to Infill Property Owners
As described in the housing element, the City relies on infill sites to meet their 6th cycle RHNA need. Some of these are mall and shopping center properties zoned Urban Mixed Use with existing uses currently in place. Orange recognizes that these uses exist and has proactively outreached to property owners at the Outlets at Orange, the shopping center located on Town & Country (763 S. Main Street), and the West Chapman Best Buy Center site (Lewis Street/3741 W. Chapman Avenue). At each of these sites, the property owners expressed that they do not see their existing developments as impediments to the future development of housing on each site and do not object to their site being identified as a candidate housing site within the Housing Element.

Additionally, the City has modified Policy Action 2E to include further incentives to promote the development of infill construction, including the adoption of Objective Design Standards by March 2024, adoption of a Transfer of Development Rights (TDR) ordinance by in early 2024, and providing staff guidance and consultation throughout the development process.

Pursuant to conversation with developers, the following were suggested actions by developers to help overcome constraints due to cost and timing of negotiating CC&Rs and Leases:
 Establish objective design guidelines that can be assessed and administered ministerially by staff  Establish a ministerial process to allow for the subdivision of existing large parcels, such as shopping centers or older apartment communities that have the potential to accommodate more intensive development, recognizing that these projects may need to be phased over 5‐10 year periods and that the resultant land parcels may be irregular in shape (i.e., allowing for multifamily development on a former big box store site while the rest of the center remains in use)  Target higher residential density on obsolete retail sites and existing residential sites where there is older development at a lower density than what is considered typical today, with particular attention paid to focus intensified density on sites where phased development is possible.  Additionally, there needs to be a sufficient increase in allowable density so as to allow for financially feasible phased redevelopment that can provide replacement housing for existing residents on the property.

Policy Analysis in Relation to Sites
The City of Orange has developed policies within the Housing Element to promote the development of housing, including Policy Actions specifically directed at the redevelopment of infill properties and addressing each of the developer suggestions identified above. The following is a summary of those policies (See Section 4 for full text and actionable objectives):
 Policy Action 1C: Evaluation of Planning and Development Review Process  Policy Action 2E: Facilitate Infill Construction
 Policy Action 2L: Candidate Housing Site Used in Previous Housing Elements (Includes development of Objective Design Standards)
 Policy Action 2N: Subdivision of Existing Large Parcels  Policy Action 3D: Community Outreach (Including outreach every two years to commercial shopping mall and office complex property owners in Urban Mixed Use zones)

Appendix B: Candidate Sites Analysis B‐17
2021‐2029 Housing Element Update
 The City has development standards allowing 60 units per acre and is in the process of drafting has begun preparation of a Transfer of Development Rights Ordinance for adoption by end of 2023. The ordinance would enable densities from other sites to be combined to achieve densities beyond 60 units per acre.
 The City is in the process of preparing Objective Design Standards to establish compliance with SB 330 and to streamline review of qualified affordable housing projects.  The element now includes Policy Actions 2N to ministerially approve the subdivision of existing large parcels.
 The Housing Element also includes Policy Actions 1C and 2B and 2E that demonstrate the City's commitment to reviewing standards and procedures with the goal of facilitating and encouraging infill development through streamlining project entitlement and providing targeted flexibility in development standards.

Existing Uses on Candidate Sites and Redevelopment Opportunity The City has identified and analyzed existing use on candidate sites in Table B‐4 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‐4 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 of the identified sites
 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.

With respect to mall properties identified within the inventory, it should be noted that the commercial centers or mall properties identified in the City of Orange candidate housing sites inventory do not generally involve multiple smaller tenants. They focus on sites with large surface parking lots around the perimeter of malls or office campuses, or commercial centers where there may be a "vulnerable" major (i.e., chain is contracting in size, reporting bankruptcy or financial restructuring, etc.) anchor that occupies a large footprint of a site with smaller in‐line tenants occupying separate buildings concentrated at the edges of the site (leaving a large field of parking associated with the anchor footprint as a potential infill development opportunity). Real estate market studies conclude that Orange has had an over‐saturation of retail and Class B office space for over a decade. This land use reality, combined with ongoing consumer preferences for on line shopping, pandemic‐related shifts, and local housing demand has proven to bring forward repeated instances in recent years of change on commercial and office sites where there had been an incorrect assumption that existing leases would preclude site redevelopment opportunities.

Appendix B: Candidate Sites Analysis B‐18
2021‐2029 Housing Element Update
City staff engages in regular dialogue with representatives of the Outlets at Orange who have expressed the benefits of a housing presence to their Orange location and other centers across the nation, whether that housing is adjacent to or integrated into their commercial centers. Representatives have expressed their interest and support for the adaptive reuse of the One City Plaza office tower that shares parking with the larger mall site to residential use, and remains open to considering future opportunities to further integrate housing and the mall.

Furthermore, Table B‐3b below presents information about in‐fill sites developed in Orange with housing or entitled during the 5th Cycle and beginning of the 6th Cycle. The table highlights identified agreements and easements in place at the time of entitlement. These did not present impediments to the development of these projects.

Table B‐3b: In‐Fill Residential Projects
Property Address Project Description Identified Agreements/Easements At Time of Entitlement
Timeline
for
Approvals
999‐1055 Town and
Country Road

Pre‐application Site
Condition: mid‐rise office
building surrounded by
surface parking lot.

Cameo Apartments
262 Apartments
(Moderate‐income restricted)

Project included construction of
parking structure to replace
surface parking lot displaced by
infill apartment project.

Status: Construction complete;
units occupied
 Sewer line easement
 Vehicular access rights easement
 Drainage easement
 Public utility easement
12 months
1110 W. Town and
Country Road

Pre‐application Site
Condition: undeveloped
office tower pad adjacent
to high‐rise office building
with parking structure.

Undeveloped pad was
originally intended to be
developed as second
phase of the constructed
office tower but sat
undeveloped for decades.

Eleven10 West Apartments
260 Apartments

Status: Construction complete;
units occupied

 Sewer easement
 Easement for water line and incidental
purposes
 Easement for underground electrical
supply systems, communication systems
and incidental purposes
 Easement for street, public utility and
incidental purposes
 Agreement related to the property’s
location in the Southwest Redevelopment
Project Area
 Deed of Trust to secure an original
indebtedness of $127,000,000
 Document entitled “Assignment of Leases
and Rents”
 Amended and Restated Deed of Trust,
Assignment of Leases and Rents, Security
Agreement and Fixture Filing
 Second Amended and Restated Deed of
Trust, Assignment of Leases and Rents,
Security Agreement ad Fixture Filing
 Second Amended and Restated
Assignment of Leases and rents as
4 months

Appendix B: Candidate Sites Analysis B‐19
2021‐2029 Housing Element Update
Table B‐3b: In‐Fill Residential Projects
Property Address Project Description Identified Agreements/Easements At Time of Entitlement
Timeline
for
Approvals
additional security for the payment of the
indebtedness secured by the deed of trust.
 Financing statement
 Amendments to the financing statement
Terms and provisions of a document
entitled “Agreement, between the City of
Santa Ana and Town and Country
Residential Towers, Inc.” recorded March
06, 1978 as Book 12586, Page 81 of
Official Records
702‐1078 W. Town and
Country Road

Pre‐application Site
Condition: low‐rise multi‐
building office complex
and related surface
parking.

Fairfield Apartments and
Townhomes
653 apartments
74 townhomes

Status: Construction complete;
units occupied
 Title at time of application submittal held
under multiple fractional ownerships
 Electrical easements
 Sewer easements
 Water service easement
 Public utilities easements
 Irrigation pipeline easement
 Deed of Trust to secure an original
indebtedness of $9,800,000
 A document entitled “absolute
Assignment of Leases and Rents”, 2009
 Terms and provisions contained in a
document entitled “Agreement and
Acknowledgement of Security Interest”,
2008
 Terms and provisions contained in a
document entitled “Memorandum of
Tenants in Common Agreement”, 2009
14 months
3800 W. Chapman
500‐600 City Boulevard
West

Pre‐application Site
Condition: surface
parking lots for mid‐ and
high‐rise office buildings
and The Outlets at
Orange regional shopping
mall.

Orange Collection

3800 W. Chapman: 278
apartments
500‐600 City Boulevard West:
213 apartments

Status: Projects entitled but not
constructed; project
implementation disrupted by
pandemic.

 Pipeline easements
 Public utilities easements
 Fire lane, access, and protection
easements
 Telephone and communication facility
easements
 Domestic water supply easements
 Access easements
 Natural gas pipeline easements
 Traffic control device easements
 Signage easements
 Terms and provisions of a lease between
The City, a California general partnership
as lessor and TGI Friday’s
 CC&Rs recorded 1997 and modified in
1998
3800 W.

Chapman:
41 months

500‐600
City
Boulevard
West: 41
months

Appendix B: Candidate Sites Analysis B‐20
2021‐2029 Housing Element Update
Table B‐3b: In‐Fill Residential Projects
Property Address Project Description Identified Agreements/Easements At Time of Entitlement
Timeline
for
Approvals
 Terms, provisions and easements
contained in “City Parking Lot Easement
Agreement”, 1997
 Terms, provisions and easements
contained in “Mills Parking Lot Easement
Agreement”, 1997
 Terms, provisions and easements
contained in “Roadway Easement
Agreement”, 1997
 Terms, provisions and easements
contained in “No Build Covenant”, 1997
 Terms, provisions and easements
contained in “Restrictive Covenant and
Declaration of Covenants, Conditions,
Restrictions and Easements”, 1997
 Terms and provisions of an unrecorded
lease between Orange City Mills Limited
Partnership and Saks & Company
 Terms and provisions of an unrecorded
lease between Orange City Mills Limited
Partnership and GCFF‐Orange LLC
 Terms and provisions of a document
entitled “Partial Assignment and
Assumption of Development Agreement”,
2011
 Terms, provisions, and easements
contained in a document entitled
“Agreement RE Roadway Easement
Agreement and Covenants, Conditions and
Restrictions, 2008
 Terms and provisions of an unrecorded
lease between Orange City Mills Limited
Partnership and TSA Stores, Inc.
 Deed of Trust to secure an original
indebtedness of $40,000,000
 Disclosure that the land is located within
the boundaries of the Southwest
Redevelopment Project Area
201 City Parkway West

Pre‐application Site
Condition: surface
parking lot and landscape
area for existing low‐rise
apartment complex.

Terrace Apartments
167 Apartments

Status: Projects entitled but not
constructed; project
implementation disrupted by
pandemic.

 Public utilities easements
 All subsurface water and subsurface water
rights in and under said land
 Easement and maintenance agreement
 Roadway easement
 Storm drain easement
 Sewer easement
14 months

Appendix B: Candidate Sites Analysis B‐21
2021‐2029 Housing Element Update
Table B‐3b: In‐Fill Residential Projects
Property Address Project Description Identified Agreements/Easements At Time of Entitlement
Timeline
for
Approvals
 Irrigation conduits and the perpetual
rights to ingress and egress
 Agreement for exclusive license and
easement
 Deed of Trust to secure an indebtedness
of $20,000,000
 An assignment of all the moneys due, or to
become due as rental, as additional
security for the obligations secured by
deed of thrust

Housing Market Analysis
In addition to an on‐the‐ground existing use analysis, the City of Orange has evaluated market conditions to facilitate the redevelopment of non‐vacant sites for residential. 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 3‐22
2021‐2029 Housing Element Update
Figure B-1: Map of Identified Sites (Candidate Housing Sites)

Appendix B: Candidate Sites Analysis B‐23
2021‐2029 Housing Element Update

Figure B-1: Map of Identified Sites (Candidate Housing Sites)

Appendix B: Candidate Sites Analysis 3‐24
2021‐2029 Housing Element Update
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 3‐25 2021‐2029 Housing Element Update
Table B‐4: 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
Dev
Scenario
37530116 9.95 UMU UMIX 55
1547 W
KATELLA AVE

STADIUM
PROMENADE LLC

BRECKENRIDGE
GROUP INC 547 136 411 98 38
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% B 23113140 9.95 UMU UMIX 60
1 CITY BLVD
WEST

WALTON/GREENLAW
CITY PLAZA HOLDINGS
VI LLC    597 149 448 107 41    449
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. The expected density
is set to 60 as the building could
handle greater density through an
adaptive re‐use given its 19
stories. The City has had
conversations with the broker for
the building about their efforts to
market the building for adaptive
re‐use to housing as they have not
had success finding office tenants. 19,710 1,300,266 2% B 37531125 9.56 UMU UMIX 55
1701 W
KATELLA AVE

STADIUM
PROMENADE LLC

BRECKENRIDGE
GROUP INC 525 130 395 94 36
See explanation for Parcel
37530116. 136,005 1,249,875 11% B

Appendix B: Candidate Sites Analysis 3‐26 2021‐2029 Housing Element Update
Table B‐4: 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
Dev
Scenario

09314149 9.17 R‐1‐7 PFI 6
515 N Rancho
Santiago Blvd
SCHOOL ORANGE
UNIFIED DIST 55 0 55 0 0 55
Largely vacant lot with some
agricultural uses and one small
structure. #N/A 1,198,336 #N/A VAC
37537105 8.32 UMU UMIX 60
1600 W STRUCK
AVE

ORANGELAND
RECREATION VEHICLE
PARK 499 123 375 89 34
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.

This site is not likely to include a
non‐commercial mixed‐use
component as it fronts Struck Ave. 48,902 1,087,854 4% A 37501119 7.61 UMU UMIX 55
1350 W
KATELLA AVE WILSON DAVID W TR    418 104 314 75 29 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% A 23106152 5.91 UMU UMIX 55 LEWIS ST
REGENTS OF THE
UNIVERSITY OF
CALIFORNIA Yes 323 80 243 58 22 244
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% A
39062104 5.78 UMU UMIX 55 763 S MAIN ST
TOWN & COUNTRY
SPE Yes 317 79 238 57 22    238
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.

Representatives of center do not
object to the inclusion of the
property in this Housing Element. 66,917 755,281 9% B 23113132 5.10 UMU UMIX 55 LEWIS ST
ORANGE CITY MILLS III
LIMITED PARTNERSHIP Yes 280 69 210 50 192 211
See explanation for Parcel
23107126. 0 666,158 0% B

Appendix B: Candidate Sites Analysis 3‐27 2021‐2029 Housing Element Update
Table B‐4: 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
Dev
Scenario
23126207 4.33 UMU UMIX 60
625 THE CITY
DR S
THE REALTY
ASSOCIATES FUND XI
PORTFOLIO L P Yes 260 65 195 46 18 196
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.

A developer has recently
purchased the property to bring
forward residential development,
and the OC Register reports the
developer’s intentions are to
construct 360 units. 37,089 566,362 7% B
13747134 3.99 UMU UMIX 55
LEWIS ST
(3741 W.

Chapman)
CITY TOWN CENTER L
P   219 54 165 39 15   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.

Representatives of center do not
object to the inclusion of the
property in this Housing Element. 45,438 521,520 9% B 23108156 3.98 UMU UMIX 55
3901 W

METROPOLITAN
DR
ORANGE CITY MILLS
LTD PTNSHP 219 54 165 39 15 165
See explanation for Parcel
23107126.    32,385 520,715 6% B
23126208 3.53 UMU UMIX 55
765 THE CITY
DR S AG CITY OWNER L P Yes 194 47 146 34 13 147 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% B
23107154 2.67 UMU UMIX 55
3400

METROPOLITAN
ORANGE CITY MILLS II
LIMITED PARTNERSHIP    146 36 110 26 10
See explanation for Parcel
23107126.    0 348,939 0% B
23107131 2.40 UMU UMIX 55 THE CITY DR S
ORANGE CITY MILLS
LTD PARTNERSHIP Yes 132 32 99 23 9
See explanation for Parcel
23107126.    11,775 314,243 4% B
23107153 2.08 UMU UMIX 55
W

METROPOLITAN
DR
ORANGE CITY MILLS
LTD PARTNERSHIP 114 27 86 20 7
See explanation for Parcel
23107126. 0 272,454 0% B

Appendix B: Candidate Sites Analysis                  3‐28 2021‐2029 Housing Element Update
Table B‐4: 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
Dev
Scenario
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% B
23107126 1.84 UMU UMIX 55 THE CITY DR S
ORANGE CITY MILLS
LTD PARTNERSHIP Yes 101 25 76 18 7
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% B
23107133 1.69 UMU UMIX 55 THE CITY DR S
ORANGE CITY MILLS
LTD PARTNERSHIP Yes 92 22 69 16 6
See explanation for Parcel
23107126. 10,152 220,770 5% B
23106146 1.66 UMU UMIX 55 4125 LEWIS ST
WALWORTH RICHARD
R TR Yes 91 22 69 16 6 69
Several single‐family residences
on a single lot with storage and
large surface parking areas.

Existing units have been
accounted for and property is
directly adjacent to newer multi‐
family residential uses.    12,765 216,830 6% A
23107143 1.44 UMU UMIX 55
450 THE CITY
DR S
SCHIFFMAN TODD I TR
CARL KARCHER
ENTERPRISES INC   79 19 60 14 5
See explanation for Parcel
23107126.    5,803 188,046 3% B
23107140 1.39 UMU UMIX 55 THE CITY DR S
ORANGE CITY MILLS
LTD PARTNERSHIP 76 19 57 13 5 58
See explanation for Parcel
23107126.    0 181,362 0% B
23106153 1.30 UMU UMIX 55
4050 W
CHAPMAN AVE BARD ASSOCIATES CO Yes 70 16 54 12 4   54 Older restaurant building (Lucille's
BBQ) with a large surface parking
lot.  Potential to redevelop for
mixed‐use and retain capacity for
the existing use and additional
commercial. 7,153 169,279 4% B

Appendix B: Candidate Sites Analysis                  3‐29 2021‐2029 Housing Element Update
Table B‐4: 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
Dev
Scenario
23107147 1.29 UMU UMIX 55 THE CITY DR S
ORANGE CITY MILLS
LTD PARTNERSHIP 69 16 53 12 4 54
See explanation for Parcel
23107126.    0 168,604 0% B
39062103 1.27 UMU UMIX 55 745 S MAIN ST
ORANGE TOWN &
COUNTRY #3 LLC Yes 68 16 52 12 4   53
Commercial shopping center with
multiple tenants and large surface
parking lot.  Directly adjacent to
new multi‐family residential
development and across from the
Main Place mall (Santa Ana)
analyzed in the Housing Element.   16,221 165,630 10% B 39062105 1.25 UMU UMIX 55 791 S MAIN ST
WANG CHARLES S C TR
WANG FAMILY TR Yes 67 16 51 12 4 52
See explanation for Parcel
39062104.   19,249 162,997 12% B
23107132 1.19 UMU UMIX 55
330 S THE CITY
DR
ORANGE CITY MILLS
LTD PARTNERSHIP Yes 64 15 49 11 4
See explanation for Parcel
23107126.    4,616 155,612 3% B
37537110 1.16 UMU UMIX 55
1748 W
KATELLA AVE ORANGE KATELLA LLC 63 15 48 11 4
Existing standalone surface
parking lot.  City has recently
rezoned the W Katella Ave
corridor as it has been identified
as a large opportunity area for
mixed‐use development, including
multi‐family residential.    0 152,032 0% A
23109201 1.15 UMU UMIX 55 THE CITY DR S
THE REALTY
ASSOCIATES FUND XI
PORTFOLIO L P Yes 63 15 48 11 4 48
Surface parking lot adjacent to
older multi‐tenant office building.

Large site with potential for joined
redevelopment with adjacent
parcels and accessibility to
walking/biking trails.   0 150,094 0% A
39028537 1.13
NMU‐
24 NMIX24 16.3 480 S MAIN ST MP‐LAVETA LLC Yes 18 0 18 3 1 18 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   17,089 148,098 12% B
37537402 0.98 UMU UMIX 55
1095 N MAIN
ST
HARVARD 826
PROPERTY LLC   52 12 40 9 3
Older 2‐story commercial office
building currently signed available
for sale.   15,307 128,241 12% B
23113133 0.91 UMU UMIX 55 LEWIS ST
ORANGE CITY MILLS III
LIMITED PARTNERSHIP 50 12 38 9 3 38
See explanation for Parcel
23107126.    0 119,533 0% B
39028534 0.83
NMU‐
24 NMIX24 16.3 424 S MAIN ST MP‐LAVETA LLC Yes 15 2 13 2 0 13 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   19,731 109,044 18% B
37537403 0.82 UMU UMIX 55
1085 N MAIN
ST
HARVARD 826
PROPERTY LLC 47 11 36 8 3 36
Older 2‐story commercial office
building.  Common ownership and
could be redeveloped in
conjunction with Parcel 37537402
or independently.   13,014 106,990 12% B

Appendix B: Candidate Sites Analysis                  3‐30 2021‐2029 Housing Element Update
Table B‐4: 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
Dev
Scenario
13747132 0.76 UMU UMIX 55
3743 W
CHAPMAN AVE
CITY TOWN CENTER L
P Yes 41 10 31 7 3   31
Existing commercial shopping
center and surface parking lot
containing a bank, Starbucks, and
Quiznos Subs.  Opportunity to
develop in a mixed‐use fashion
similar to adjacent parcel which
contains hotel and restaurant
uses.    9,974 98,958 10% B
39028532 0.68
NMU‐
24 NMIX24 16.3 402 S MAIN ST MP‐LAVETA LLC Yes 12 1 11 1 0 11 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   3,909 89,513 4% B
39028536 0.60
NMU‐
24 NMIX24 16.3 MAIN ST MP‐LAVETA LLC Yes 10 1 9 1 0 9 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   17,089 77,922 22% B
39028535 0.57
NMU‐
24 NMIX24 16.3 468 S MAIN ST MP‐LAVETA LLC Yes 10 1 9 1 0 9 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   2,472 74,913 3% B
39027411 0.57
NMU‐
24 NMIX24 16.3 356 S MAIN ST WONG WAI PING INC Yes 10 1 9 1 0 9 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   8,589 74,761 11% B
13747133 0.57 UMU UMIX 55
3739 W
CHAPMAN AVE
CITY TOWN CENTER L
P WENDYS
INTERNATIONAL INC Yes 31 7 24 5 2 24
Existing Wendy's restaurant and
surface parking lot. Opportunity
to develop in a mixed‐use fashion
similar to adjacent parcel which
contains hotel and restaurant
uses.  May also be developed with
13747132 due to common
ownership. 3,964 74,730 5% B
39027410 0.57
NMU‐
24 NMIX24 16.3 370 S MAIN ST HOU MARVIN L S Yes 9 0 9 1 0 9 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   6,444 74,572 9% B
23107129 0.51 UMU UMIX 55 THE CITY DR S
ORANGE CITY MILLS
LTD PARTNERSHIP Yes 27 6 21 5 1
See explanation for Parcel
23107126.    0 66,759 0% B
37505101 0.50 UMU UMIX 55
1212 STRUCK
AVE B & B GARDNER LP   26 5 21 4 1
Older single‐story office
structures and maintenance sheds
surrounded by large surface
parking lot.    3,757 65,011 6% B
39028533 0.41
NMU‐
24 NMIX24 16.3 MAIN ST MP‐LAVETA LLC Yes 6 0 6 1 0 6 Small older commercial shopping
center with potential to redevelop
for mixed‐use.   19,731 54,039 37% B
1,054 488 732 1,777

Appendix C: Summary of Community
Engagement

Appendix C: Summary of Community Engagement C-2
2021-2029 Housing Element Update
Summary of Community Engagement
Section 65583 of the Government Code states that, "The local government shall make diligent effort to achieve public participation of all economic segments of the community in the development of the housing element, and the program shall describe this effort." Meaningful community participation is also required in connection with the City's Assessment of Fair Housing (AFH). A summary of citizen participation is provided below.

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

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

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

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

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

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

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

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

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

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

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

As part of the North Tustin Specific Plan focused outreach to underrepresented portions of the community, the City completed the following:
• In December 2021, staff conducted the first community workshop to introduce the initiation of the project and solicit input from the community. An online survey was conducted for this workshop. This first survey was made public on December 22nd and by February 12th had collected 762 responses.
• On March 4, 2021, staff conducted a second community workshop to solicit support for preferred environments and development within the plan area. A total of 91 persons attended this meeting and completed a survey.
• On July 20, 2021, staff conducted a third workshop to further involve the community in refining the vision of the project. Over 65 community members attended this in-person workshop and 58 survey responses were received by August 23, 2021.
• On June 16, 2022, staff conducted a scoping meeting kicking off the project EIR. The scoping session turned into a question and answer session to a full Council chambers. • For each of the workshops, mailers and notices went out to over 4,000 property owners and businesses within the plan area and extending 300 feet beyond. The workshops were also advertised on the City’s website and on social media.
• City Staff also conducted 11 one-on-one meetings with major land developers, property owners, and major business interests.

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

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

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

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

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

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

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

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

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

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

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

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

Appendix C: Summary of Community Engagement C-6
2021-2029 Housing Element Update
HCD Correspondence
Since submission of the first Draft Housing Element to HCD on July 12, 2021, the City has worked with HCD through to certification to ensure all State laws were adequately addressed. Correspondence included recommended additions to the Housing Element and revisions to candidate sites.

This updated October 2023 version of the Housing Element addresses all of HCD’s comments and includes revisions following public comments. On September 29, 2023, HCD published a letter reporting that the Orange 6th Cycle Housing Element has met minimum statutory requirements considered in its April 14, 2023 review. As noted in the letter – “this finding was based on, among other reasons, the additional owner outreach, updated analysis, and added and amended programs, as well as other information submitted to HCD that the City will enter into its housing element prior to adoption.” The information to be added to the Housing Element includes: 1) examples of recent projects developed on land with existing leases and other encumbrances; 2) inclusion of the updated status on owner conversations showing that all relevant property owners had been contacted and confirmed to have no objection to inclusion in the housing element, and that all were open to the concept of introducing housing to their site; and 3) clarification that Objective Design Standards will be available on sites, not just carryover sites (HCD recommends clarifying the Objective Design Standards by moving this commitment to Policy Action 2E).

These additions and revisions were made and the updated Housing Element posted for a minimum required 7 -day public review on October 6th, 2023, ahead of re -adoption and re -submission of the Adopted Housing Element to HCD.

Appendix C: Summary of Community Engagement C-7
2021-2029 Housing Element Update
Virtual Workshop Presentation
This section contains all Virtual Workshop Presentation materials and handouts. The recorded presentation is available on the City’s Housing Element Update webpage at:
https://www.cityoforange.org/290/Current-Projects
The City of Orange is in the process of updating the 2021-2029 Housing Element.

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

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

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

Very Low Income 0 – 50% MFI -- $51,500 1,064 units
Low Income 51 – 80% MFI $51,501 $82,400 603 units
Moderate Income 81 – 120% MFI $82,401 $123,600 676 units Above Moderate Income > 120% MFI $123,601 >$123,601 1,585 units Total: 3,927 units
Notes: 1 Income range is based on the 2020 HUD Median Family Income (MFI) for Orange County of $103,000.

Why is the City Updating the Housing Element?
The City of Orange is required by State law to update its Housing Element every eight years. The current adopted Housing Element covers the 2013-2021 planning period. The City is now planning for the 2021-2029 planning period.

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

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

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

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

Ms. Ashley Brodkin, Associate Planner, City of Orange
Email [email protected] or at call directly at (714) 744-7238

La Ciudad de Orange está en proceso de actualizar en Elemento Vivienda 2021-2029. Esta hoja informativa pro- porciona información sobre el Elemento Vivienda y el proceso de actualización de la ciudad. ¿Qué es un Elemento Vivienda?
El Elemento Vivienda es un capítulo del Plan General de la Ciudad. Es un documento de procedimientos iniciado por la ciudad que identifica los métodos y los programas para lograr cumplir con las necesidades de vivienda existentes y proyectadas para el futuro para todos los segmentos económicos de los residentes de Orange. El Elemento Vivienda 2021-2029 identifica acciones específicas para afrontar las necesidades de vivienda locales.

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

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

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

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

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

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

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

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

Sra. Ashley Brodkin, Planificadora Asociada, Ciudad de Orange Correo electrónico [email protected] o llamando directamente al (714) 744-7238

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

Appendix C: Summary of Community Engagement C-8
2021-2029 Housing Element Update
Community Workshop
This section contains all workshop materials and handouts, flyers, and all available public comments provided verbally and in the chat during the workshop. A video recording of the workshop is available on the City’s Housing Element Update webpage at:
https://www.cityoforange.org/2226/2021-2029-Housing-Element-Update

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

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

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

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

WHERE: Online Meeting Via Zoom, The link is located on the City’s Website under Current Projects:
www.cityoforange.org/housingelement
City of Orange
2021-2029 Housing Element Update
Community W orkshop #2

Si tiene alguna pregunta, por favor comuníquese con Anna Pehoushek, Subdirectora de Desarrollo Comunitario, por correo electrónico a [email protected] La ciudad de Orange se está preparando para publicar el Borrador de Revisión Pública del Elemento de Vivienda 2021-2029. Únase a nosotros en un taller virtual para aprender sobre las diferentes partes del borrador del documento y cómo puede proporcionar comentarios durante el período de revisión pública.

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

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

LUGAR: Reunión en línea a través de Zoom, el enlace se encuentra en el sitio web de la ciudad en Proyectos Actuales:
www.cityoforange.org/housingelement
Ciudad de Orange
Actualización del Elemento de Vivienda 2021-2029
Taller Comunitario #2

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

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

Community Response Survey
Additionally, the City launched an online community survey on May 26, 2021. The survey was the second survey created and distributed to gather feedback on the Housing Element and focused on obtaining feedback on the Draft Housing Element document. Direct responses to the survey are provided in Appendix C under “Public Comments”.

City of Orange
Community Workshop #2 Summary
May 26, 2021
The survey was available on the City’s Housing Element Update webpage. The City promoted the survey at the workshop and through social media, email and community announcements. The survey was live through the end of the public review period.
file:///kimley-horn.com/...20of%20Orange%20-%206th%20Cycle%20HE/Community%20Outreach/Workshop%20%232/Recordings/chat.txt[10/4/2021 9:20:49 AM] 18:41:24 From Maria Zacarias Torres : when is the last day to provide feedback? 18:43:47 From Molly Mendoza : Link to Public Review Draft:
https://www.cityoforange.org/DocumentCenter/View/12889/Housing-Element-Public-Review-Draft_May-2021 18:55:04 From Byron de Arakal : Does the lack of an Inclusionary Housing Ordinance prelude an applicant from invoking state density bonus on a particular project?
18:56:15 From Maria Zacarias Torres : will there be another meeting before sending the draft to HCD? 18:56:23 From Byron de Arakal : *preclude*
18:58:44 From Molly Mendoza : Hi Maria, the City will not host an additional meeting, however you can comment on the draft document and share your ideas by sending your comments to the City. Thanks for participating! 19:17:20 From Molly Mendoza : Link to Public Review Draft:
https://www.cityoforange.org/DocumentCenter/View/12889/Housing-Element-Public-Review-Draft_May-2021 19:18:34 From soraya to Ines Galmiche(Direct Message) : Thank you Ines. Great job. 19:22:01 From Maria Zacarias Torres : yes, that would be very helpful! 19:22:09 From Bonnie Robinson : Thank you for presenting this workshop and responding to questions!

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

Appendix C: Summary of Community Engagement C-9
2021-2029 Housing Element Update
Online Community Survey
This section contains an outline of the community survey and a summary of the survey results. The online community survey received 148 responses from the public.

City of Orange
2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 1

Community Survey
October 12, 2020 to November 30, 2020 the City of Orange launched an online community survey in order to gather feedback regarding potential policies and programs to include in the Housing Element, as well as potential housing types and opportunities for housing in the City. The survey also solicited feedback regarding potential barriers to housing access and constraints to the development of housing. Below is a summary of the survey’s results.

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

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

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

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

Figure C-1: Affordable Housing Program Opportunities

Community Assistance Programs – Figure C-2 displays survey results for participant interest in different community assistance programs. Overall, participants showed a high interest in all the potential community assistance programs. The figure shows that participants were most interested in the City providing housing information, participants also identified assistance funding for first-time homebuyers 0 10
20 30
40 50
60 70
Accessory Dwelling
Unit s
Housing
Partnerships
Inclusionary
Housing
Keep Affordable
Housing
MixedUse
Opport unities
1 2
3 4
5 City of Orange
2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 2

as a priority. The data shows a split in interest between one a nd five stars for property maintenance assistance, as well as a split interest for rental assistance.

Figure C-2: Community Assistance

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

Figure C-3: Fair Housing
0 10
20 30
40 50
60 Homebuyer Assistance Housing Rental
Assistance
Property Maint enance Provide Housing Info
1 2
3 4
5 City of Orange
2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 3

Streamlining Processes – Figure C-4 displays survey results for participants interest in programs and policies to streamline the development process. Overall, participants showed little interest in streamlining the development process, including little interest in decreasing developments fees, expediting review process and streamlining the permit timeline.

Figure C-4: Streamlining Processes

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

The potential areas included the following:
0 10
20 30
40 50
60 70
Persons with Disabilities Promote Fair Housing Senior Housing Support ive Housing 1 2
3 4
5 0
10 20
30 40
50 60
70 80
Development Fees Development Process Project Processing 1 2
3 4
5 City of Orange
2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 4

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

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

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

Figure C-5: Housing Areas

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

2.43 2.61

2.93 3.02 3.21

3.7 1

1.5 2

2.5 3

3.5 4

4.5 5
Highest Priority
Lowest Priority
City of Orange
2021-2029 Housing Element Outreach
Draft Community Survey Summary
Page | 5

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

Figure C-6: Constraints to Housing

356 352
170
127
157
274
0 50
100
150
200
250
300
350
400
L ack of
Informational
Resources
Housing
Availab ility
Permit
Strea mlining
Flexible
Development
Standards
Housing Fees Access to Funding
Stars Allocated

Appendix C: Summary of Community Engagement C-10
2021-2029 Housing Element Update
Stakeholder Meetings
This section contains all available meeting materials, including combined notes from both of the stakeholder meetings.

City of Orange
Housing Element Update 2021-2029
Stakeholder Meeting Notes – December 1, 2020
Housing Constraints
Entitlement Process
Amount of upfront work on tentative maps has gone up - most of the work is required up front now. Lengthens entitlement period
Not requiring affordable or on-site affordable
Tough line to walk on entitlement process - requirements vs. community character
Tentative maps determine feasibility of the work, so certain details could be pushed off to post-entitlement period to lower upfront costs Lowering fees (park fees, development fees) - upfront cost Not necessarily easing up on process - maybe it's addressing the timing of review/entitlement process
Needed application and project components should be known up front City staff as partners to the community - partnerships is the goal Offer fees in the form of a loan that could be paid over time Review the level of detail needed up front. Determining feasibility is important
Cost issue of requiring details that may change as the building permit process gets closer
Standard ministerial Design guidelines
Lack of specific policies or programs to prioritize affordable housing - Density bonuses and incentives do not match existing zoning & ordinances Are local zoning & ordinances blocking the dev. of affordable housing? Specific Policy - Streamline development process to proceed by-right in some cases

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

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

City of Orange
Housing Element Update 2021-2029
Promoting Affordable Housing
Incentives &
Subsidies
Financial incentives
-loans
Work with tweezers and not a blunt spoon - not necessarily need to create citywide policies/impacts
City grants to help first time homebuyers with down payments to help fill the gap for affordable units
Land use as a way to incentivize - up zoning increases value If up zone, asking for help to meet the City's requirements is reasonable -Discount factor to address market rate units taking on additional cost from affordable units
Micro Units/Tiny
Homes
Room in Orange's Code for smaller studio units (250 SF) for seniors and special needs populations tied with affordability, amenities/services City to provide CDBG/HOME funds for ADUs and add deed restriction to ensure affordability for a number of years
Pre-approved ADU plans / Permit ready ADU programs
Other
Specific policies to streamline and incorporate affordable housing addressing affordable housing through City resources & land storage requirements outside the units - non-code required closets in units count towards storage requirements
No net loss - build in a potential buffer of available sites

What can the City do to Provide Access to Affordable Housing? Communication and
Education
Communicating the long-term value of affordable housing in a community Educational materials year round rather than affordable housing being tied to a particular project
Communicating that people benefiting from affordable housing are those who already work in the community
Show example of other work that has been done in another community Workforce housing - wording is important for perception Council and City Staff sharing that housing opportunities may benefit the children of people already living in the City
Changing the narrative away from affordable housing being negative to a community
Understanding the importance of stable housing for families/households and what it looks like
Other
Spending 30% of income on housing v 60-70% impacts how people live their lives and contribute
Local community is moving out due to high cost of living Courage to approve affordable housing - subsidies/zoning are there Approval of projects is encouraging for future development Ordinance to rent out empty rooms in your house
Increase supply of (affordable) housing - only 25% of those eligible for assistance receive it
Inclusionary Housing Policy
City of Orange
Housing Element Update 2021-2029
New and Innovative Trends
Redevelopment
Areas
Existing retail areas that may benefit from conversion to housing due to economic changes
Church properties - housing on the property
Keep Church use
Aging church properties that could serve as good partnership locations Looking at underutilized institutional properties
Continuing platinum triangle down Katella and continuing that pattern (redeveloping parking lot areas)
ADUs Financing programs to help homeowners afford ADUS
Buying incentives
Mixed Use
Little shops, medical clinics on first floor and residential above Less trips and helps the environment. Near mass transit/public transportation
TODs - Transit Oriented Developments
Horizontal mixed-use - housing with medical
Modular/Pre-Fab ADU pre-fab units
How is this handled in the City code?
Other
Co-living - 2 bedroom senior housing where occupants can split the rent Work with developers on this
Housing Advocacy program - training of residents on how to give effective public comment
Capacity buffer to catch "lost" units
Look at unintended consequences of planning just to meet the City's RHNA Ensuring people are not displaced and priced out of current homes for newer upzone
Equitable upzoning / growth

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

1 2021-2029 Housing Element Update
2021-2029Housing Element UpdateStakeholder MeetingDecember 1, 2020 City of Orangewww.cityoforange.org/HousingElement 2021-2029 Housing Element UpdateAgendaI. Housing Element Update ProcessII. Stakeholder DiscussionIII. Next Steps2 2021-2029 Housing Element Update
Housing Element Update Process3
2021-2029 Housing Element UpdateHousing Element Features4Population and housing profile Evaluation of existing programs and policies
Evaluation of housing constraints and resources
Analysis of sites to accommodate the City’s RHNA Allocation Policies, programs and quantified objectives to achieve the City’s housing goals 2021-2029 Housing Element UpdateRHNA Draft Allocation: 2021 – 2029 Planning Period5Income Category% of Area Median Income (AMI)Income Range*RHNA Allocation(Housing Units)**Min. Max.Very Low Income 0 - 50% MFI -- $51,500 1,064 unitsLow Income 51 – 80% MFI $51,501 $82,400 603 unitsModerate Income 81 – 120% MFI$82,401 $123,600 676 unitsAbove Moderate Income >120% MFI $123,601 >$123,601 1,585 unitsTotal: 3,927 units*Income range is based on the 2020 HUD Median Family Income (MFI) for Orange County of $103,000.**RHNA Allocation is in draft form and subject to change pending final approval by SCAG. 2021-2029 Housing Element UpdateHousing Element Update Schedule6Community Survey –Fall 2020Stakeholder Study Session – Fall 2020City Council Briefing Sessions -Winter 2021Public Review Draft – Spring 2021Community Workshop -Late Spring 2021Planning Commission Public Hearing –Summer 2021City Council Public Hearing –Late Summer 2021 1 23 45 6
2 2021-2029 Housing Element Update
Stakeholder Discussion7
2021-2029 Housing Element UpdateWhat are the Top 3 constraints to Housing?8 2021-2029 Housing Element UpdateWhat can the City do to promote affordable Housing?9 2021-2029 Housing Element UpdateAre there any new or innovative practices when it comes to building affordable housing?10 2021-2029 Housing Element Update
Next Steps11
2021-2029 Housing Element UpdateThank you!Questions?Contact Ashley Brodkin, Associate PlannerPhone: 714-744-7238Email: [email protected] Housing Element webpage: www.cityoforange.org/1956/Housing-Element-Update12 7 89 1011 12

Appendix C: Summary of Community Engagement C-11
2021-2029 Housing Element Update
Public Comments
This section contains all available public comments received by the City relating to the Housing Element update process. Personal information such as emails and addresses have been redacted for privacy reasons.

The City of Orange continues to receive comments on its Housing Element through the multiple iterations and has considered all comments received to date. The City values community input on housing issues within Orange and will continue to outreach to property owners, developers, stakeholders, and others who are passionate about the development of housing at all levels. Comments are not responded to directly within this document, however elements of those letters received have resulted in changes within the document. Most recently, that includes letters received by the Kennedy Commission and other parities requesting that the City consider an inclusionary housing ordinance and ways to promote development on infill sites. Housing Policy Action 2O was added to address the City’s approach to inclusionary housing and Policy Action 2E was modified to broaden commitments relating to a Transfer of Development Rights Ordinance, objective design standards, and monitoring programs to assess the City’s progress in meeting its RHNA.

City of Orange
2021-2029 Housing Element Update
Public Rev iew D raft Comments 10/4/2021
Public Review Draft - Community Comments
Public Comment Response to Comments
Section 1 (Introduction)
Ya no puedo seguir pagando donde vivo Comment has been noted.

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

Comment has been noted.

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

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

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

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

Special Needs Groups 7. Homeless Page 2-6:

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

Comment has been noted.

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

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

Explains constraints better in this section on reality that Orange is nearly built out and that available land (vacant or developed) is scarce, costly, and privately owned. Government constraints are not the true barrier of development rather its the cost of the Comment has been noted.

City of Orange
2021-2029 Housing Element Update
Public Rev iew D raft Comments 10/4/2021
land. Infrastructure capacity is a major need for new
development. New development must provide for their share of the increased load to the system.

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

The distinction has been added
to the section.

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

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

Comment has been noted.

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

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

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

Comment has been noted.

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

Comment has been noted.

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

Comment has been noted.

City of Orange
2021-2029 Housing Element Update
Public Rev iew D raft Comments 10/4/2021
Restructure and refine a better toolkit for senior market rate and affordable senior housing development in our commercial zones when the subject site is adjacent to single-family neighborhoods.

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

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

Comment has been noted.

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

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

Comment has been noted.

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

Comment has been noted.

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

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

Mobile home parks are assessed
in Section 2 and 3.

Appendix A (Review of Past Performance)
Appendix A: Although Orange had exceeded 5th Cycle targets for low, moderate, and above moderate housing units, there was an unbalanced production of moderate and above moderate units, as opposed to extremely low, very low and low. This imbalance indicates that Orange's affordable housing policies have not been effective in incentivizing and producing housing for lower income Comment has been noted.

City of Orange
2021-2029 Housing Element Update
Public Rev iew D raft Comments 10/4/2021
households. Although several areas were zoned Urban Mixed Use to encourage density, that density did not result in a significant amount of affordable housing. A great example of a missed opportunity are the large developments in the Town and Country area that don't include housing for low and very low income levels.

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

Comment has been noted.

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

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

Comment has been noted.

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

Comment has been noted.

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

Comment has been noted.

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

Comment has been noted.

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

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

Nicholas Che n, AICP
Kimley-Horn |

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

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

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

Thanks,

Ashley Brodkin

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

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

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

Thank you once again,
Cecilia

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

St. Joseph Hospital of Orange

www.sjo.org

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

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

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

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

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

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

Regards,

Ashley Brodkin
Associate Planner
Community Development Department

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

From: Chen, Nick
Sent: Wednesday, May 19, 2021 4:52 PM
To: Galmiche, Ines
Subject: FW: Additional Comments Regarding Housing Element Survey

Nicholas Che n, AICP
Kimley-Horn |

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

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

Public comment on Housing Element.

As
hley Brodkin

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

De
ar Associate Planner Brodkin,

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

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

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

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

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

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

Sincerely,
Bonnie Robinson

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

From: Chen, Nick
Sent: Wednesday, May 19, 2021 4:52 PM
To: Galmiche, Ines
Subject: FW: City of Orange Housing Element Update - Virtual Workshop

Nicholas Che n, AICP
Kimley-Horn |

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

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

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

As
hley Brodkin

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

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

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

The answer is to build more housing at higher densities, not just for low income people but for moderate income people, like young professionals who want to buy their first home. NIMBYism is the single greatest barrier to getting more housing built. Existing residents are resistant to new housing, density, and poor people. Housing elements (and their aligned zoning codes) need to identify places and where townhomes, apartments, and condos can be built with

minimal discretionary review. A good housing element can facilitate development in a way that minimizes opportunities for NIMBYism. It's in the city's own interest to make it's housing element, land use policies, and zoning code align to depoliticize the approval of housing development.

That's my general feedback.

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

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

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

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

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

Regards,

Ashley Brodkin

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

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

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

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

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

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

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

There is also an informational presentation on the 2021-2029 Housing Element Update, as well as a Fact Sheet to provide you information about the Housing Element and the City’s update process.

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

Regards,

Ashley Brodkin
Associate Planner
Community Development Department

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

August 17, 2020

Dear City of Orange:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

We would appreciate the City giving us notice of any public meetings regarding the Housing Element. We look forward to working with the City to encourage effective housing policies that will help create balanced housing development and create much-needed affordable housing in our local communities. If you have any questions, please feel free to contact me at
Sincerely,

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

¹California Government Code § 8899.50 (Assembly Bill 686).

September1,2023
Ms.MelindaCoy, ProactiveAccountabilityChiefCaliforniaDepartmentofHousingandCommunityDevelopment2020W. El CaminoAvenue, Suite500Sacramento,CA95833 RE:CommentstoRevisedHousingElementUpdatedatedJuly2023
ToMs.Coy
TheKennedyCommission(theCommission)isabroad-basedcoalitionofresidentsandcommunityorganizationsthatadvocatesfortheproductionofhomesaffordableforfamiliesearninglessthan$30,000annuallyinOrangeCounty. Formedin2001,theCommissionhasbeensuccessfulinpartneringandworkingwithOrangeCountyjurisdictionstocreateeffectivehousingandland-usepoliciesthathaveledtothenewconstructionofhomesaffordabletolower-incomeworkingfamilies.

ThankyoufortheopportunitytoreviewandcommentontheCityofOrange’s2021-2029draftHousingElement(July2023).Wehavereviewedthedraftandaresubmittingthisinitiallettertoprovidepubliccomments.

TheCommissionhasreviewedtheproposedopportunitysitesandprogramstoaddresstheneedsofaffordablehousingforextremelylow, verylow, andlowincomefamiliesintheCityofOrange.WerecommendthatthecityincorporateanewhousingpolicytostrengthenitsaffordablehousingprogramstoensurethataffordablehousingunitsaredevelopedalongwithmarketratehousingthatisbeingincentivizedintheUMUMixedusezoningsites.SincethevastmajorityoflowerincomeopportunitiesareidentifiedonsitesintheUMUzoningitisimperativethataneffectivepolicybeimplemented.

City’sPoliciesNotProducingAffordableHousingAsthe5thCycleHousingElementAnnualProgressReportsindicates,theCity’scurrenthousingpolicieshavedevelopedhousinginanunbalancedwayandprioritizedmarket-ratehousing.Duringthecurrent5thcycleplanningperiodtheCityhadatotalRegionalHousingNeedsAssessment(RHNA)of363(83atverylow-income,59atlow-income,66atmoderateand155atabovemoderate).Asof2021,theCityapproved1,449unitsatmoderateand552unitsatabovemoderate.Atvery-lowincome,thecityhasapproved9unitsand72atlow-income. ThecityhasmadeprogressinmeetingtheRHNAneedsforhigherincomecategories,butlittleprogressintheverylowincomecategory. Mostofthemoderateandabovemoderatehousing 1 unitshavebeenachievedintheUMUzoningsites.Thisstrategyisnotenoughtoaddressthehousingcrisisinthecitythatisimpactinglowerincomehouseholdsandhousingdevelopmentwillsimplycontinuetobebuiltinaninequitableandunsustainablefashion. 6thCycleUMUSites- AffordableHousingThesitesidentifiedforlower-incomecategoriesinthe6thcycledraftHousingElementarepredominantlyagainidentifiedbasedondefaultdensitiesforlowerincomeunitsandinthesameUrbanMixedUse(UMU)zones.Thisisthesamestrategyandzoningthatthecityreliedoninthe5thcycletoaddresslowerincomeaffordablehousingwithoutsuccess.NoaffordablehousingwasplannedorapprovedintheUMUzones.

TheUMUzoneoffersstreamlineddevelopmentstandards,generousdevelopmentstandardsanddensitiesintherangeof48to60unitstotheacrethathaveincentivizedexclusivelymarketratehousingNootherhousingpolicyhasbeenincorporatedtoincentivizeaffordablehousingonthesesites.

HousingPoliciestoIncreaseAffordableHousingAstheCityreviewsitshousingpoliciesandopportunitysites,werecommendthatitimplementhousingpoliciesthatcanbeeffectiveinincentivizingandproducingaffordableunitsonproposedUMUsiteswhileconsideringalldevelopmentstandards,zoningandpastdevelopmenthistoryandpatterns.

Currently, therehavebeenneitherunitspermittednorprojectsinthepipelinethatfulfillthecity’sExtremelyLow/VeryLow2021-2029RHNAof1,067intheUMUsites.ThecitycontinuestohopethatthemarketwilldeliveraffordablehousingbyidentifyinghigherdensitysitesforlowerincomeRHNAneeds.Asdemonstratedinthe5thcycle,thisstrategyhasprovenineffectiveandhasonlyproducedluxury, marketratehousingthatisunaffordabletomostofthecity’sresidents.

Additionally, sitesidentifiedonTableB-2detailonlyonesitethatisdedicatedtowardsofferingincome-restrictedfamilyapartmentsforthelow-incomecategory, therestoftheidentifiedopportunitiesforlowerincomeareAccessoryDwellingUnits,whoseincomecategoryisunknownandwillbemarketrate..TheCity’shopethatthesesitesaswellastheprojectsinthepipelinewouldfulfillthecity’sLow-incomeRHNAscoreisunfeasible.Additionally, accessorydwellingunits,despitetheirconstructionbeingunlikelytoalleviatethehousingneedsofverylowandlowincomeresidentsunlesstheydeedrestricted.

NewHousingPoliciesforAffordableHousingInHousingPolicyAction2H,thecityiscommittingtoannuallymonitoradequatesitesforaffordablehousingdevelopment,“TheCitywillcontinuetorequirenon ‐ residentialandmixeduseprojectsintheUrbanMixedUse(UMU)zoningdistrictsonlybeapprovedwhenafinding 2 canbemadethattheprojectwillnotreduceUMU ‐ zonedlandavailableforresidentialdevelopmentsuchthattheCitycannolongeraccommodateitsremainingRHNAneed.”ThecitymuststrengthenthispolicybybeingmoreproactiveandincludingactionsandprogramsthatwillincludeandincreaseaffordablehousingintheUMUsites.Takingactiontorezoneothersitesforaffordablehousingdevelopmentisthefirststep,butaffordablehousingneedstobefacilitatedonthesesites.

Finally, ourteamhastakenthetimetoreviewthehousinggoalsandpolicyactionsthatthecityistakinginordertofulfillthiscycle’sRHNAgoals.Ouranalysisofsuchgoalshasrevealedinadequaciesinensuringthatthecitydevelopshousingunitsforthepeopleintheextremelylow,verylow, andlowincomecategories.ThereviewoftheCity’smonitoringprogramhasshownthatitsanalysisistooweaktoensurethedevelopmentofaffordablehousinginOrange.

HousingPolicyAction2Aand2HTheobjectiveofHousingPolicyAction2HmonitoringcommitmentsarealreadymandatedbystatelawandislargelysimilartoPolicyAction2A.PolicyAction2A’smonitoringcommitmentsthereforehavetobestrengthenedbytheintroductionofstrongerprogramsthatwillincentivizethedevelopmentofaffordableunitsinsteadofmonitoringthem.Toensurethataffordablehousingisincentivizedonthesesites,thecityneedstoprioritizeanInclusionaryHousingOrdinanceasawaytoaddressthegapbetweentheextremelylow, verylow, andlowincomerentsandthehigherrentsinthehousingmarket.InOrangeCounty, thethirteencitiesthathaveadoptedanInclusionaryHousingOrdinanceandhaveseenprogresstowardsbalancedandequitablehousingdevelopmentintheirzoning.

HousingPolicyAction2EHousingpolicy2Eproposestoencourageconstructionbygeneralplanupdatesthatwillfacilitatemarketratehousing;thecitymusttakeintoaccountthatUrbanMixedUsehousingisgenerallydirectedtowardsmarketratehousing.Wearealreadytwoyearsintotheplanningperiod,andnoaffordablehousinghasbeenplannedordevelopedinUMUZoning.Wehavetoevaluatetheseprogramsandpoliciestoensurethataffordablehousingiscreatedonthosesites.Andrecommendthatthecityadoptamorerobusthousingprogramtoaddressaffordablehousingontheidentifiedopportunitysites.

TheKennedyCommissionRecommendationTheCommissionstronglyrecommendsthecityadoptanInclusionaryHousingOrdinanceoraHousingOpportunitiesOrdinancethatrequires15%ofunitsofallcitywideresidentialprojectsbesetattheextremelylow(5%),very-low(5%),andlow-incomelevels(5%).Thisordinancewillhelpthecitycreatebalancedhousingdevelopmentalongwithmarketratehousing.ThispolicywillhelpcreatetheaffordablehousingthatisnotcreatedintheOrange 3 housingmarket.TheInclusionaryHousingOrdinanceshouldbeimplementednolaterthansixmonthsfromtheadoptionofthe6thCycleHousingElement.

UMUSitesIdentifiedThecitymustalsoprovideadditionalanalysisontheUMUzonesitesidentifiedinthe6thcycleandwhetherthesesitesorareasarebeingrecycledfromthe5thcycle.Thecitymustalsoprovideabyrightapprovalprogramanda20%affordablehousingcommitmentonthesesitestoensurelowerincomeunitsarebuiltalongwithmarketratehousing.

WelookforwardtoworkingwiththeCityofOrangetoencourageeffectivehousingpoliciesthatwillhelpcreatebalancedhousingdevelopmentandcreatemuch-neededaffordablehousinginourlocalcommunities.Ifyouhaveanyquestions,pleasefeelfreetocontactmeat(949)[email protected].

Sincerely,
CesarCovarrubiasExecutiveDirector
4 Fighting
for
a
future
of
abundant
housing
in
Orange
County.
peopleforhousing.org
July
26,
2023
Via
Email
Ms.

Melinda
Coy
Senior
Housing
Accountability
Manager
California
Department
of
Community
&
Economic
Development
[email protected]
Mr.

Alex
Fisch
Mr.

David
Pai
Special
Assistant
Attorney
General
Deputy
Attorney
General
California
Department
of
Justice
California
Department
of
Justice
alex.ﬁ[email protected]
[email protected]
Cc:

Ms.

Anna
Pehoushek
Assistant
Community
Development
Director
City
of
Orange
[email protected]
RE:

MORE
DATA
to
support
our
objection
to
revised
version
of
City
of
Orange
Housing
Element
dated
July
2023
Dear
HCD,
I
am
writing
a
second
letter
to
share
additional
data
to
support
our
assertion
that
decision
makers
at
the
city
of
Orange
are
obstinate
in
their
refusal
to
ADD
sites
to
the
sites
inventory
for
which
there
is
an
active
interest
in
housing
development
and
at
the
same
time
evading
their
responsibility
to
include
parcels
with
a
high
probability
of
redevelopment
into
housing.

The
revised
housing
element
assigned
the
critical
mass
of
the
RHNA
to
multiple
fully-leased,
functional
shopping
centers,
1 including:

1. As
mentioned
in
our
prior
letter,
the
Outlets
at
Orange,
a
fully-leased
mall
for
which
there
are
no
current
plans
or
demonstrable
interest
in
redevelopment
into
housing.

The
city
has
designated
over
2400
housing
units
at
this
location.

2. The
Stadium
Promenade
Center,
an
entertainment
location
with
theaters
and
restaurants.

The
city
has
designated
over
1000
units
at
this
location.

3. The
Towne
and
Country
Center,
a
retail/
commercial
center
with
three
separate
property
owners.

The
city
has
designated
over
450
units.

4. And
the
City
Town
Center,
a
retail
center
with
three
separate
property
owners.

The
city
has
designated
over
290
units
on
these
three
occupied
and
operating
parcels.

These
four
(4)
retail/
commercial
center
sites
represent
over
5000
units
out
of
the
city’s
6142
included
on
the
revised
housing
element
submittal.

It
is
critical
to
recognize
that
none
of
these
retail
center
owners
have
taken
action
to
redevelop
their
properties
to
include
housing
at
the
level
the
city
is
assigning
in
their
revised
Housing
Element.

Perhaps
it
would
be
less
egregious
to
include
these
implausible
sites
if
the
city
would
concurrently
move
forward
with
projects
when
and
where
there
is
interest
in
developing
new
housing,
such
as
the
long
term
vacant
site
proposed
as
the
Chapman
Yorba
housing
development.

This
site
has
been
vacant
for
a
long
time,
and
the
owner,
Stoneﬁeld
Development,
is
eager
to
build.

They
submitted
plans
for
the
development
of
a
senior
apartment
complex
more
than
two
years
ago.

This
site
is
surrounded
by
a
hospital/
medical
facility
on
one
side,
a
single-family
neighbor
on
Fighting
for
a
future
of
abundant
housing
in
Orange
County.
peopleforhousing.org
2 another
and
a
city
park
on
another.

This
would
be
an
ideal
site
for
housing,
with
an
owner
anxious
to
build.

This
same
owner
currently
has
a
Builder's
Remedy
plan
for
the
site
that
calls
for
apartments
with
20%
aﬀordable
units,
which
has
not
moved
forward.

I
am
writing
at
this
11th
hour
to
share
these
additional
examples
with
you
in
the
hope
that
HCD
will
reject
the
revised
version
of
the
City
of
Orange
Housing
Element.

The
city’s
failure
to
identify
any
NEW
sites
to
replace
the
ones
removed,
the
further
consolidation
and
concentration
of
the
RHNA
on
fewer
parcels,
and
the
city’s
molasses-like
response
to
active
residential
project
submittals
demonstrates
the
city
is
not
taking
its
charge
to
plan
for
housing
seriously.

We
need
cities
to
do
so
much
more
than
plan.

We
need
cities
to
actively
facilitate
the
development
of
new
housing
–
at
higher
densities
and
lower
aﬀordability
levels
–
so
families
can
ﬁnd
aﬀordable
places
to
live;
so
seniors
can
downsize;
so
the
workforce
that
teaches
our
children,
ﬁxes
our
cars,
stocks
our
shelves,
makes
our
lattes,
and
keeps
us
and
our
communities
safe
can
aﬀord
to
live
here,
too.

We
are
counting
on
you
at
HCD
and
DOJ
to
make
it
happen.

Don’t
let
the
NIMBYs
win.

Sincerely,
Elizabeth
Hansburg
Coﬁunder
&
Director
Fighting
for
a
future
of
abundant
housing
in
Orange
County.
peopleforhousing.org
3 1
Galmiche, Ines
From: Galmiche, Ines
Sent: Wednesday, October 4, 2023 6:37 PM
To: Galmiche, Ines
Subject: FW: Objections to City of Orange July 19, 2023 proposed 6th Cycle Housing Element From: Allan Abshez
Sent: Monday, September 18, 2023 12:25:02 PM
To: Anna Pehoushek ; David Pai Coy, Melinda@HCD

Cc: Russell Bunim ; Ayobi, Mashal@HCD ; Mike Vigliotta

Subject: RE: Objections to City of Orange July 19, 2023 proposed 6th Cycle Housing Element

Ladies and Gentlemen,

On July 25th we submitted our objections to the City of Orange’s regarding the City of Orange’s July 19, 2023 proposed 6th Cycle Housing Element.

We invite your attention to the attached article regarding the Los Angeles Superior Court’s writ of mandate and invalidation of the City of Beverly Hills Housing Element for improperly relying on developed commercial sites to meet the City’s RHNA obligation.

https://therealdeal.com/la/2023/09/15/beverly-hills-court-decision-could-boost-builders-remedy/

The Court’s decision against Beverly Hills underlines the comments we submitted on July 25th regarding the City of Orange’s proposed Housing Element. The errors identified in our July 25th communication and supporting materials should lead to HCD’s prompt disapproval of the City’s July 19, 2023 proposed 6th Cycle Housing Element.

Thank you,

Allan Abshez
Partner

CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is STRICTLY PROHIBITED. If you have received this transmission in error, please immediately notify the sender. Please destroy the original transmission and its attachments without reading or saving in any manner.

Thank you, Loeb & Loeb LLP.

From: Allan Abshez
Sent: Tuesday, July 25, 2023 3:49 PM
To: Anna Pehoushek ; David Pai ; Coy, Melinda@HCD

Cc: ; Ayobi, Mashal@HCD Allan Abshez ;

2 Subject: Objections to City of Orange July 19, 2023 proposed 6th Cycle Housing Element

I'm using Mimecast to share large files with you. Please see the attached instructions.

Please confirm your receipt of the attached correspondence and exhibits regarding the City of Orange’s July 19, 2023 proposed 6th Cycle Housing Element

Thank you,
Allan Abshez

Allan Abshez
Partner

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

Appendix D: Glossary of Housing Terms

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Parcel. A lot or tract of land.

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

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

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

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

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

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

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

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

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

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

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

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

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

Section 8 Rental Assistance Program. A federal (HUD) rent-subsidy program that is one of the main sources of federal housing assistance for low -income households. The program operates by providing “housing assistance payments” to owners, developers, and public housing agenc ie s t o make up the difference between the “Fair Market Rent” of a unit (set by HUD) and the household’s contribution toward the rent, which is calculated at 30% of the household’s adjusted gross monthly income (GMI). “Section 8” includes programs for new construction, existing housing, and substantial or moderate housing rehabilitation.

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

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

Single-Family Dwelling, Attached. A dwelling unit occupied or intended for occupancy by only one household that is structurally connected with at least one oth er such dwelling unit. (Se e “Townhouse.”)

Appendix D: Glossary of Housing Terms D-8
2021-2029 Housing Element Update
Single-Family Dwelling, Detached. A dwelling unit occupied or intended for occupancy by only one household that is structurally independent from any other such dwelling unit or structure intended for residential or other use. (See “Family.”)
Single Room Occupancy (SRO). A single room, typically 80-250 square feet, with a sink and close t , but which requires the occupant to share a communal bathroom, shower, and kitchen.

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

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

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

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

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

Townhouse. A townhouse is a dw elling unit located in a group of three (3) or more attache d dwelling units with no dwelling unit located above or below another and with each dwelling unit having its own exterior entrance.

Appendix D: Glossary of Housing Terms D-9
2021-2029 Housing Element Update
Transitional Housing. Shelter provided to the homeless for an extended period, often as long as 18 months, and generally integrated with other social services and counseling programs to assist in the transition to self -sufficiency through the acquisition of a stable income and permanent housing. (See “Homeless” and “Eme rgency Shelter.”)
Undevelopable. Specific areas where topographic, geologic, and/or superficial soil conditions indicate a significant danger to future occupants and a liability to the City.

Appendix D: Glossary of Housing Terms D-10
2021-2029 Housing Element Update
Acronyms Used
ACS: American Community Survey
BMPs: Best Management Practices
CALTRANS: California Department of Transportation
CEQA: California Environmental Quality Act
CHAS: Comprehensive Housing Affordability Strategy
CIP: Capital Improvement Program
DDS: Department of Developmental Services
DIF: Development Impact Fee
DU/AC: Dwelling Units Per Acre
EDD: California Employment Development Department
FAR: Floor Area Ratio
FEMA: Federal Emergency Management Agency
HCD: Department of Housing and Community Development
HOA: Homeowners Association
HUD: Department of Housing and Urban Development
LAFCO: Local Agency Formation Commission
MFI: Median Family Income
NPDES: National Pollutant Discharge Elimination System
RTFH: Regional Task Force on the Homeless
RTP: Regional Transportation Plan
SCAG: Southern California As sociation of Governments
SPA: Sectional Planning Area
STF: Summary Tape File (U.S. Census)
TOD: Transit-Oriented Development
TDM: Transportation Demand Management
TSM: Transportation Systems Management
WCP: Water Conservation Plan

Orange City CouncilOctober 30, 2023

Orange City Council
October 30, 2023