Cities Index.
Agenda packet

Orange City Council
April 8, 2025

Document
Agenda packet
Meeting
April 8, 2025
Body
Orange City Council
Pages
13
Original file
92.5 MB
Text extracted from the city's file for reading and search. Open the original on cityoforange.legistar.com. That file is the official record.

DESIGN REVIEW COMMITTEE
Qualifications: The Committee shall consist of seven (7) members whose primary residence or primary place of employment is in the City of Orange. Committee members shall be qualified to analyze and interpret architectural and site planning information, including, but not limited to, licensed landscape architects, architects, urban planners, engineers, and licensed general contractors. At least two members shall have professional experience in urban planning, architectural history or historic preservation and possess a general knowledge of architecture in the Old Towne Historic District. (Duties are set forth in Section 17.08.020 of the Orange Municipal Code) Form 700 and AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required
Terms of Office: The term of office shall be for four (4) years.

Meetings: Meetings are held on the first and third Wednesday of each month at 5:30 p.m.

Name Appointed/Reappointed Term Expiration Date
Anne McDermott 3-10-2015/2-9-2021/2-14-2023 6-30-2027
Maryanne Skorpanich 8-8-2017/2-9-2021 6-30-2025
Jerico Farfan 7-13-2021 6-30-2025
Robert Grosse 3-14-2023 6-30-2027
Greg Ledesma 3-14-2023 6-30-2027
Michael Lopez 6-25-2024 6-30-2028
Adrienne Gladson 11-12-2024 6-30-2028

INVESTMENT ADVISORY COMMITTEE
Qualifications: The Committee shall consist of seven (7) members whose primary residence or primary place of employment is in the City of Orange. The City Treasurer and Finance Director, or their designee, shall serve as advisory non-voting members. Committee members shall demonstrate managerial experience of no less than five years in one or more of the following areas: investment banking, investment brokerage and sales, investment management, financial management and planning, or commercial banking. (Duties are set forth in Section 2.51.020 of the Orange Municipal Code)
Form 700 required and AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required
Terms of Office: The term of office shall be for two (2) years.

Meetings: Meetings are held quarterly on the fourth Wednesday of January, April, July, and October at 5:30 pm.

Name Appointed/Reappointed Term Expiration Date
Brian Beelner 3-25-2025 6-30-2027
Mark Mittmann 3-25-2025 6-30-2027
Paul Mittmann 3-25-2025 6-30-2027
Jordan Prell 3-25-2025 6-30-2027
Richard Madrigal 3-25-2025 6-30-2027
VACANT
VACANT
590
City of Orange 2024 Local Appointments List

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ORANGE PUBLIC LIBRARY BOARD OF TRUSTEES
Qualifications: The Board shall consist of five (5) members whose primary residence is in the City of Orange. Trustees shall have an understanding and appreciation of the role of the public library in the community and in a democracy. Trustees should be library users and should value books and information delivery. (Education Code 18910)
Form 700 required and AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required
Terms of Office: The term of office shall be for three (3) years (Education Code 18911).

Meetings: Meetings are typically held on the third Monday of each month at 3:30 p.m. (Determined at its June annual meeting per Board of Trustees By-Laws.) Name Appointed/Reappointed Term Expiration Date
Rebecca Martinez 1-12-2016/2-9-2021/5-10-2022* 6-30-2025 Susie Huber 7-14-2020/2-14-2023 6-30-2026
Katie Montgomery 4-12-2022 6-30-2025
Kathleen Stevens 6-13-2023**/4-23-2024 6-30-2027
VACANT 6-30-2027 (to fill unexpired term)
*Reappointed in 2021 for term serving 2019-2022
**Appointed in 2023 to fill unexpired term

PARK PLANNING AND COMMUNITY EVENTS COMMISSION
Qualifications: The Commission shall consist of seven (7) members who shall have their primary residence in the City of Orange. Commissioners shall have knowledge of sports complexes and/or park development, and knowledge of City-sponsored events. (Duties are set forth in Chapter 2.60 of the Orange Municipal Code)
Form 700 required and AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required
Terms of Office: The term of office shall be for four (4) years (OMC 2.60.030).

Meetings: Meetings are held on the third Tuesday of January, March, May, July, September, and October at 5:30 p.m.

Name Appointed/Reappointed Term Expiration Date
Eva Perez 6-8-2021 6-30-2025
Adam Litwin 6-8-2021 6-30-2025
Eugene Fields 6-8-2021 6-30-2025
Steve Freeman 7-13-2021 6-30-2025
Christopher Ahlswede 6-14-2022 6-30-2026
James Kushon 3-14-2023 6-30-2025 (to fill unexpired term) Erika de Vries 3-14-2023 6-30-2025 (to fill unexpired term) 591
City of Orange 2024 Local Appointments List

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PLANNING COMMISSION
Qualifications: The Commission shall consist of seven (7) members who shall have their primary residence in the City of Orange. Commission members shall have general knowledge of land use and development. (Duties are set forth in Section 17.08.020 of the Orange Municipal Code) Form 700 required (pursuant to California Government Code Section 87200) AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required Terms of Office: The term of office shall be for four (4) years (OMC 2.64.020).

Meetings: Meetings are held on the first and third Mondays of each month at 5:30 p.m.

Name Appointed/Reappointed Term Expiration Date
David Vazquez 2-12-2019/4-12-2022 6-30-2026
Rick Martinez 1-8-2019/4-12-2022 6-30-2026
Alison Vejar 3-14-2023 6-30-2025 (to fill unexpired term) Ruby Maldonado 3-14-2023 6-30-2027
Shannon Tucker 3-14-2023 6-30-2027
Tim McCormack 7-1-2023 6-30-2027
Isaiah Leslie 6-25-2024 6-30-2027(to fill unexpired term)

SANTIAGO CREEK COMMISSION
Qualifications: The Commission shall consist of seven (7) members who shall have their primary residence in the City of Orange. Members shall have general knowledge of the Santiago Creek Area. (Duties are set forth in Section 2.62.020 of the Orange Municipal Code) Form 700 and AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required
Terms of Office: The term of office shall be for four (4) years (OMC 2.62.030).

Meetings: Meetings are held on the fourth Wednesday of January, April, July, and October at 5:30 p.m.

Name Appointed/Reappointed Term Expiration Date
Addison Adams 2-13-2024 6-30-2028
Robert Baca 2-13-2024 6-30-2028
Pamela Galera 2-13-2024 6-30-2027
David Hillman 2-13-2024 6-30-2027
Michael Knight 2-13-2024 6-30-2028
Brendon Moeller 2-13-2024 6-30-2028
Susan Tillou 2-13-2024 6-30-2027
592
City of Orange 2024 Local Appointments List

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TRAFFIC COMMISSION
Qualifications: The Commission shall consist of seven (7) members who shall have their primary residence in the City of Orange. Members review matters of traffic and transportation planning, requests for speed limit increase or decreases, complaints concerning traffic safety conditions, and other general duties as set forth in Chapter 10.06 of the Orange Municipal Code. City Traffic Commission duties are considered as advisory to the City Council.

Form 700 and AB1234 Ethics Education & AB1661 Sexual Harassment Avoidance Training certificates required
Terms of Office: The term of office shall be for four (4) years (OMC 10.06.020).

Meetings: Meetings are held on the second Wednesday of February, April, June, August, October, and December at 5:30 p.m.

Name Appointed/Reappointed Term Expiration Date
Adam Feliz 3-10-2015/2-9-2021/2-14-2023 6-30-2027
A.J. Ricci 6-8-2021 6-30-2025
Joseph Barbeito 3-14-2023 6-30-2027
Matt Hamilton 3-14-2023 6-30-2027
Seimone Jurjis 7-1-2023 6-30-2027
Sean Chavarria 6-25-2024 6-30-2028
Doug Redding 2-25-2025 6-30-2027 (to fill unexpired term) Qualifications for membership, purpose, compensation, and meeting information for specified City Boards, Commissions, and Committees approved by Resolution No. 11536.

Pursuant to OMC Chapter 2.55.010, members of boards, commissions and committees may serve no more than 12 consecutive years on the board, commission or committee to which they are appointed.

No member of a board, commission, or committee who has served 12 consecutive years shall be eligible for reappointment to the same board, commission or committee prior to the passage of a two- year interval.

Revised 3/26/25
593
Community Development Block Grant Program Committee
Member Feb 08, 2024 Feb 15, 2024 Mar 14, 2024 TOTALS
Jonathan M St. Clair C P P 100.0%
Melissa M Mikail C E E 0.0%
Elaine J Muselli C P P 100.0%
Brendon Moeller** C P N/A 100.0%
Connie Benson C P P 100.0%
Kim Le C P A 50.0%
Chrissy Vaughn C P P 100.0%

Present: 6 4 76.92%

Absent: 0 1 7.69%
Excused: 1 1 15.38%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
**Brendon Moeller resigned 02/16/2024
City of Orange - Member Attendance Report - 2024
594
Design Review Committee
Member 1/3 1/17 2/7 2/21 3/6 3/20 4/3 4/17 5/1 5/15 6/5 6/19 7/3 7/17 8/7 8/21 9/4 9/18 10/2 10/16 11/6 11/20 12/4 12/18 TOTALS Robert Grosse C P P P P P P C C P C P C C P C P P P A P C C C 92.86% Greg Ledesma C E P P P P P C C E C P C C P C P P P P E C C C 78.57% Anne McDermott C P P P P P P C C P C P C C P C P P E P P C C C 92.86% Maryanne Skorpanich C P E P P P E C C E C P C C P C P P P P P C C C 78.57% Robert Imboden** C P P P P P P C C P C P C N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 100.0% Carol Fox*** C P P P P N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 100.0% Jerico Farfan C P P P P P P C C P C P C C P C P P E P P C C C 92.86% Michael V Lopez**** N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A C P C P A P P P C C C 83.33%

Present: 0 6 6 7 7 6 5 0 0 4 0 6 0 0 6 0 6 5 4 5 5 0 0 0 88.64%

Absent: 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 1 0 0 0 0 2.27% Excused: 0 1 1 0 0 0 1 0 0 2 0 0 0 0 0 0 0 0 2 0 1 0 0 0 9.09% * P = Present
* A = Absent
* E = Excused
* C = Canceled
** Robert Imboden term expired 06/30/2024
***Carol Fox term expired 06/30/2024
****Michael V Lopez appointed 07/01/2024
City of Orange - Member Attendance Report - 2024
595
Investment and Audit Committee (eliminated on February 27, 2024) Member Jan 24, 2024 TOTALS
Aaron Christensen P 100.0%
Richard Rohm P 100.0%
Mark Mittmann P 100.0%
Chris Horton A 0.0%
Mike Ludin P 100.0%
Jeff Grampp P 100.0%
Jordan Prell P 100.0%

Present: 6 85.71%

Absent: 1 14.29%
Excused: 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2024
596
Orange Public Library Board of Trustees
Member 1/22 2/26 3/5 3/18 4/2 4/15 5/20 6/17 7/15 8/19 9/16 10/21 11/18 12/16 TOTALS Rebecca Martinez P E P C P C P P P E C P P C 80.0%
Peggy Calvert P P A C P C P A P P C P P C 66.67%
Katie Montgomery P P P C P C P P P P C P P C 100.0%
Kathleen D Stevens P E E C P C P P P E C P P C 66.67%
Susie Huber P P P C P C P E P P C P P C 90.0%

Present: 5 3 3 0 5 0 5 3 5 3 0 5 5 0 95.45%

Absent: 0 0 1 0 0 0 0 1 0 0 0 0 0 0 4.55%
Excused: 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2024
597
Park Planning and Community Events Commission
Member Jan 16, 2024 Mar 19, 2024 May 21, 2024 Jul 16, 2024 Sep 17, 2024 Oct 15, 2024 TOTALS Steve Freeman P P C P P P 100.0%
Eva Perez E E C P P P 60.0%
Adam Litwin P P C A P P 80.0%
Eugene Fields P P C P P P 100.0%
James E Kushon P P C P P P 100.0%
Erika De Vries P P C P P P 100.0%
Christopher H Ahlswede P P C P A P 80.0%

Present: 6 6 0 6 6 7 88.57%

Absent: 0 0 0 1 1 0 5.71%
Excused: 1 1 0 0 0 0 5.71%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2024
598
Planning Commission
Member 4-Jan 15-Jan 5-Feb 22-Feb 4-Mar 18-Mar 1-Apr 15-Apr 6-May 20-May 3-Jun 17-Jun 1-Jul 15-Jul 5-Aug 19-Aug 5-Sep 16-Sep 7-Oct 21-Oct 4-Nov 18-Nov 2-Dec 16-Dec TOTALS Timothy Mccormack C P P C P P P E P P P C C C E P C P P A P C P C 81.25% Ruby Maldonado C P P C P P P P P P P C C C P P C P P E P C P C 93.75% Shannon J Tucker C P P C P E P P P E P C C C P P C P P P P C P C 87.5% Alison N Vejar C P P C P P P P P P P C C C P P C E P P P C P C 93.75% Rick Martinez C P P C P P P P P E P C C C P E C P P P P C E C 81.25% Dave Simpson** C P E C P P E P E P E C N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A 55.56% David Vazquez C P E C P P E P P P P C C C P P C P P P P C P C 87.5% Isaiah Leslie*** N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A C C P P C P P P P C P C 100.0%

Present: 0 7 5 0 7 6 5 6 6 5 6 0 0 0 6 5 0 6 7 5 7 0 5 0 87.04%

Absent: 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0.93% Excused: 0 0 0 0 0 1 2 1 1 2 1 0 0 0 1 1 0 1 0 1 0 0 1 0 12.04% * P = Present
* A = Absent
* E = Excused
* C = Canceled
**Dave Simpson resigned 06/26/2024
***Isaiah Leslie appointed 06/27/2024
City of Orange - Member Attendance Report - 2024
599
Santiago Creek Commission
Member Apr 24, 2024 Jul 24, 2024 Sep 26, 2024 Oct 23, 2024 TOTALS Brendon Moeller P P P P 100.0%
David K. Hillman P P P P 100.0%
Susan L Tillou P P P P 100.0%
Addison Adams P P P A 75.0%
Robert R Baca P P P A 75.0%
Michael J Knight P P P P 100.0%
Pamela M Galera P P P P 100.0%

Present: 7 7 7 5 92.86%

Absent: 0 0 0 2 7.14%
Excused: 0 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2024
600
Traffic Commission
Member Feb 14, 2024 Apr 10, 2024 Jun 12, 2024 Aug 14, 2024 Oct 09, 2024 Dec 11, 2024 TOTALS Seimone Jurjis P P A E P C 60.0%
Joseph Barbeito E P P E P C 60.0%
Matthew P Hamilton P P P P A C 80.0%
Derek T Tran**** P P A P E C 60.0%
AJ Ricci E P P P P C 80.0%
Larry Dick** E E P N/A N/A N/A 33.33%
Adam Feliz P P P P P C 100.0%
Sean P Chavarria*** N/A N/A N/A P P C 100.0%

Present: 4 6 5 5 4 0 85.71%

Absent: 0 0 2 0 1 0 10.71%
Excused: 0 1 0 0 0 0 3.57%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
**Larry Dick term expired 06/30/2024
***Sean P Chavarria appointed 07/01/2024
****Derek T Tran resigned 12/10/2024
City of Orange - Member Attendance Report - 2024
601
Agenda Item
City Council
Item #: 8.1. 4/8/2025 File #: 25-0207
TO: Honorable Mayor and Members of the City Council
FROM: Tom Kisela, City Manager

1. SUBJECT
Discussion on possibly utilizing the former Orange Fire Department Headquarters as a fire museum.

2. SUMMARY
With the Orange Fire Department Headquarters relocating to 1176 East Chapman Avenue, the old Orange Fire Department Headquarters off S. Grand Street and Almond Avenue has been vacant for nearly three years. The purpose of this item is to discuss using the former Orange Fire Department Headquarters as a fire museum.

3. RECOMMENDED ACTION
Discuss the possibility of utilizing the former Orange Fire Department Headquarters as a fire museum and provide direction to City staff.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.

6. DISCUSSION AND BACKGROUND
The old Orange Fire Department Headquarters (Old Fire HQ) off S. Grand Street and Almond Avenue has been vacant for nearly three years. The Old Fire HQ retains a centralized location that presents a significant opportunity for development that supports the City’s local economy while bolstering recreational opportunities for the community.

Overall, the intent of this item is to:

1. Discuss the possibility of using the Old Fire HQ as a fire museum; and

2. Provide direction to City staff.

7. ATTACHMENTS
· None
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Agenda Item
City Council
Item #: 8.1. 4/8/2025 File #: 25-0207
TO: Honorable Mayor and Members of the City Council
FROM: Tom Kisela, City Manager

1. SUBJECT
Discussion on possibly utilizing the former Orange Fire Department Headquarters as a fire museum.

2. SUMMARY
With the Orange Fire Department Headquarters relocating to 1176 East Chapman Avenue, the old Orange Fire Department Headquarters off S. Grand Street and Almond Avenue has been vacant for nearly three years. The purpose of this item is to discuss using the former Orange Fire Department Headquarters as a fire museum.

3. RECOMMENDED ACTION
Discuss the possibility of utilizing the former Orange Fire Department Headquarters as a fire museum and provide direction to City staff.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.

6. DISCUSSION AND BACKGROUND
The old Orange Fire Department Headquarters (Old Fire HQ) off S. Grand Street and Almond Avenue has been vacant for nearly three years. The Old Fire HQ retains a centralized location that presents a significant opportunity for development that supports the City’s local economy while bolstering recreational opportunities for the community.

Overall, the intent of this item is to:

1. Discuss the possibility of using the Old Fire HQ as a fire museum; and

2. Provide direction to City staff.

7. ATTACHMENTS
· None
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Agenda Item
City Council
Item #: 9.1. 4/8/2025 File #: 25-0141
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Public Hearing to consider an appeal of Planning Commission approval of Conditional Use Permit No. 3225, a request for alcohol sales in conjunction with a proposed restaurant located at 191 N.

Orange Street and finding of California Environmental Quality Act Exemption (Appeal No. 25-0009).

2. SUMMARY
On February 20, 2025, the Planning Commission approved Conditional Use Permit No. 3225, a request by CDO Orange, LLC, dba Culinary Dropout for alcohol sales under a Type 47 ABC License (On-Sale General) at a proposed restaurant. The approval was appealed to the City Council on March 3, 2025, by the applicant based on objections to the conditions of approval included in Planning Commission Resolution No. PC 33-24.

3. RECOMMENDED ACTION
The City Council shall consider the record and such additional evidence as may be offered and may affirm, reverse, or modify, in whole or in part the action that was appealed. Such action may include:

1. Conduct and close the Public Hearing; and

2. Deny Appeal No. 25-0009 and affirm Planning Commission approval of Conditional Use Permit No. 3225.

OR

1. Conduct and close the Public Hearing; and

2. Adopt Resolution No. 11603. A Resolution of the City Council of the City of Orange approving Conditional Use Permit No. 3225, a request by CDO Orange, LLC, dba Culinary Dropout for a Type 47 ABC License (On-Sale General) at a proposed restaurant located at 191 N. Orange Street; and

3. Find the request categorically exempt from the California Environmental Quality Act (CEQA) in accordance with Section 15301 of the State CEQA Guidelines.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
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Goal 2: Enhance Economic Development and Achieve Fiscal Sustainability.

2.4: Diversify tax revenue

6. DISCUSSION AND BACKGROUND
On February 20, 2025, the Planning Commission approved Planning Commission Resolution No. PC 33-24, a resolution approving Conditional Use Permit (CUP) No. 3225 for alcohol sales under a Type 47 ABC License (On-Sale General) at a proposed full-service restaurant, Culinary Dropout. The project was approved by a vote of 4-3. A detailed overview of the proposed use and hours of activity is provided in Attachment 4 (Planning Commission Staff Report).

The proposed 7,425 sq ft restaurant includes a total of 230 seats, with 164 seats indoors and 66 seats on the outdoor patio (Attachment 7). For purposes of discussion, the outdoor seating adjacent to Maple Street is referenced as the "North Patio," while the seating area facing Orange Street is referenced as the “West Patio.”
The operating hours, as approved by the Planning Commission are as follows:

Permitted Operating Hours for Indoor
Seating
Sunday - Thursday 7:00 a.m. - 10:00 p.m.

Friday - Saturday 7:00 a.m. - 11:00 p.m.

Permitted Operating Hours for Outdoor Patio Seating (North Patio Area)
Days Hours Last Customer Seated Time
Every Day 10:00 a.m. - 8:00 p.m. 7:00 p.m.

Permitted Operating Hours for Outdoor Patio Seating (West Patio Area)
Days Hours Last Customer Seated Time
Sunday - Thursday 7:00 a.m. - 10:00 p.m. 9:00 p.m.

Friday - Saturday 7:00 a.m. - 11:00 p.m. 10:00 p.m.

Outdoor Dining Area Use:

Of the 66 seats on the proposed outdoor dining area, 24 are proposed along the E. Maple Avenue frontage. As presented in the Planning Commission Minutes (Attachment 5), the Commission adopted operating hours for the restaurant and outdoor patio that were more restrictive than staff’s recommendation.

Noise
The Planning Commission Resolution (Condition No. 24) prohibits the use of any outdoor sound system or outdoor amplifying system. As part of this appeal, the applicant is requesting that outdoor amplification be allowed so long as the music is not audible at the edge of the property line. As shown in the outdoor speaker location exhibit (Attachment 9), the applicant proposes two speakers City of Orange Printed on 4/3/2025Page 2 of 4
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shown in the outdoor speaker location exhibit (Attachment 9), the applicant proposes two speakers for amplified sound along the North Patio and six speakers along the West Patio.

The immediate interface between the northern outdoor seating area of the restaurant and single- family residences on the north side of E. Maple Avenue warrants attention in order to support the required conditional use permit findings established by the Orange Municipal Code; specifically, those pertaining to potential negative effects the proposed use may have on surrounding land uses.

Outdoor amplification has the potential to create noise issues that could be disruptive to adjacent residents, particularly in the evening.

Appeal of Planning Commission Action
The Planning Commission approval was appealed to the City Council on March 3, 2025, by the applicant, CDO Orange, LLC (Leezie Kim). The grounds for that appeal are presented in Attachment

1. The Planning Commission upheld staff’s findings and recommendation for approval with modifications to the draft conditions of approval on February 20, 2025.

The grounds for the appeal are as follows:

We are appealing the 2/20/2025 Planning Commission decision because the Commission’s recommendation has an unreasonably negative effect on the restaurant by placing restrictions on its operations that are unheard of in the industry and unprecedented in the City of Orange. Specifically, we are appealing two decisions by the Planning Commission:

1. The Planning Commission rejected the City Staff’s recommended restaurant hours of operation, which generally matched or were shorter than the operating hours of other neighboring CUP holders and other restaurants that operate close to residential neighbors.

The Planning Commission recommended the restaurant be required to stop seating guests on parts of its patio at 7:00 p.m., seven nights a week. In addition, the Planning Commission recommended the interior of the restaurant close on Fridays and Saturdays by 11:00 p.m., at least an hour earlier than the neighboring CUP holders and earlier than staff had recommended. No other restaurant, even those located close to residential neighbors, has such restrictions placed on it. Even the immediate neighboring CUP holders (the Richland and Grand Gimeno) are permitted later hours of operation both on the interior of their patios.

2. We are also appealing a recommendation of the Planning Commission that the restaurant patios be prohibited from playing background music. Unlike hours of operation, this silent patio was a staff recommendation. Background music is important to the atmosphere of a restaurant. The requirement put on other restaurants (even those close to residential neighbors) is that background music is allowed on their patios so long as the music is not audible at the edge of the property line. That is the standard we are requesting be applied to this restaurant as well.

Staff Determination
At the time the project was presented to the Planning Commission, staff recognized the potential sensitivity of the outdoor dining area interface with single-family residences on E. Maple Avenue and considered the public comment on the Design Review Committee’s review of the building rehabilitation in March 2022. Therefore, for purposes of Planning Commission review of the subject CUP, staff included conditions of approval in the draft Planning Commission Resolution deemed necessary to make the Code-required findings that a CUP does not have detrimental effects on surrounding properties. The proposed conditions also reflect consistent treatment of the proposed City of Orange Printed on 4/3/2025Page 3 of 4
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surrounding properties. The proposed conditions also reflect consistent treatment of the proposed restaurant with CUPs for other restaurants in the Old Towne Mixed Use zoning district.

The conditions of approval were discussed extensively with the applicant prior to the Planning Commission hearing. The findings and conditions of approval as originally presented by staff to the Planning Commission are reflected in the City Council Resolution provided as Attachment 2.

Conditions of approval 8, 13, 25, 26, and 27 differ between Attachment 2 and Attachment 4.

Staff maintains that the conditions of approval originally presented to the Planning Commission would provide protection to the neighborhood adjacent to the restaurant and treat Culinary Dropout similar to other Old Towne restaurants. The content of the original draft Planning Commission Resolution has been repackaged for Council consideration as Option 2 for Recommended Action with the following modifications to the hours of operation:

Permitted Operating Hours for Indoor Seating
Sunday - Thursday 7:00 a.m. - 10:00 p.m.

Friday - Saturday 7:00 a.m. - 12:00 a.m.

Permitted Operating Hours for Outdoor Seating
Daily 7:00 a.m. - 10:00 p.m.

7. ATTACHMENTS
· Attachment 1 Appeal to Planning Commission Resolution No. PC 33-24 (APP 25-0009) · Attachment 2 Draft City Council Resolution No. 11603
· Attachment 3 Vicinity Map
· Attachment 4 Planning Commission Resolution No. PC 33-24 · Attachment 5 Planning Commission Staff Report, February 20, 2025 · Attachment 6 Planning Commission Minutes, February 20, 2025 · Attachment 7 Applicant Business Narrative Letter
· Attachment 8 Site Plan and Proposed Seating Chart
· Attachment 9 Outdoor Speaker Locations
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Agenda Item
City Council
Item #: 9.1. 4/8/2025 File #: 25-0141
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Public Hearing to consider an appeal of Planning Commission approval of Conditional Use Permit No. 3225, a request for alcohol sales in conjunction with a proposed restaurant located at 191 N.

Orange Street and finding of California Environmental Quality Act Exemption (Appeal No. 25-0009).

2. SUMMARY
On February 20, 2025, the Planning Commission approved Conditional Use Permit No. 3225, a request by CDO Orange, LLC, dba Culinary Dropout for alcohol sales under a Type 47 ABC License (On-Sale General) at a proposed restaurant. The approval was appealed to the City Council on March 3, 2025, by the applicant based on objections to the conditions of approval included in Planning Commission Resolution No. PC 33-24.

3. RECOMMENDED ACTION
The City Council shall consider the record and such additional evidence as may be offered and may affirm, reverse, or modify, in whole or in part the action that was appealed. Such action may include:

1. Conduct and close the Public Hearing; and

2. Deny Appeal No. 25-0009 and affirm Planning Commission approval of Conditional Use Permit No. 3225.

OR

1. Conduct and close the Public Hearing; and

2. Adopt Resolution No. 11603. A Resolution of the City Council of the City of Orange approving Conditional Use Permit No. 3225, a request by CDO Orange, LLC, dba Culinary Dropout for a Type 47 ABC License (On-Sale General) at a proposed restaurant located at 191 N. Orange Street; and

3. Find the request categorically exempt from the California Environmental Quality Act (CEQA) in accordance with Section 15301 of the State CEQA Guidelines.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
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Goal 2: Enhance Economic Development and Achieve Fiscal Sustainability.

2.4: Diversify tax revenue

6. DISCUSSION AND BACKGROUND
On February 20, 2025, the Planning Commission approved Planning Commission Resolution No. PC 33-24, a resolution approving Conditional Use Permit (CUP) No. 3225 for alcohol sales under a Type 47 ABC License (On-Sale General) at a proposed full-service restaurant, Culinary Dropout. The project was approved by a vote of 4-3. A detailed overview of the proposed use and hours of activity is provided in Attachment 4 (Planning Commission Staff Report).

The proposed 7,425 sq ft restaurant includes a total of 230 seats, with 164 seats indoors and 66 seats on the outdoor patio (Attachment 7). For purposes of discussion, the outdoor seating adjacent to Maple Street is referenced as the "North Patio," while the seating area facing Orange Street is referenced as the “West Patio.”
The operating hours, as approved by the Planning Commission are as follows:

Permitted Operating Hours for Indoor
Seating
Sunday - Thursday 7:00 a.m. - 10:00 p.m.

Friday - Saturday 7:00 a.m. - 11:00 p.m.

Permitted Operating Hours for Outdoor Patio Seating (North Patio Area)
Days Hours Last Customer Seated Time
Every Day 10:00 a.m. - 8:00 p.m. 7:00 p.m.

Permitted Operating Hours for Outdoor Patio Seating (West Patio Area)
Days Hours Last Customer Seated Time
Sunday - Thursday 7:00 a.m. - 10:00 p.m. 9:00 p.m.

Friday - Saturday 7:00 a.m. - 11:00 p.m. 10:00 p.m.

Outdoor Dining Area Use:

Of the 66 seats on the proposed outdoor dining area, 24 are proposed along the E. Maple Avenue frontage. As presented in the Planning Commission Minutes (Attachment 5), the Commission adopted operating hours for the restaurant and outdoor patio that were more restrictive than staff’s recommendation.

Noise
The Planning Commission Resolution (Condition No. 24) prohibits the use of any outdoor sound system or outdoor amplifying system. As part of this appeal, the applicant is requesting that outdoor amplification be allowed so long as the music is not audible at the edge of the property line. As shown in the outdoor speaker location exhibit (Attachment 9), the applicant proposes two speakers City of Orange Printed on 4/3/2025Page 2 of 4
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Item #: 9.1. 4/8/2025 File #: 25-0141
shown in the outdoor speaker location exhibit (Attachment 9), the applicant proposes two speakers for amplified sound along the North Patio and six speakers along the West Patio.

The immediate interface between the northern outdoor seating area of the restaurant and single- family residences on the north side of E. Maple Avenue warrants attention in order to support the required conditional use permit findings established by the Orange Municipal Code; specifically, those pertaining to potential negative effects the proposed use may have on surrounding land uses.

Outdoor amplification has the potential to create noise issues that could be disruptive to adjacent residents, particularly in the evening.

Appeal of Planning Commission Action
The Planning Commission approval was appealed to the City Council on March 3, 2025, by the applicant, CDO Orange, LLC (Leezie Kim). The grounds for that appeal are presented in Attachment

1. The Planning Commission upheld staff’s findings and recommendation for approval with modifications to the draft conditions of approval on February 20, 2025.

The grounds for the appeal are as follows:

We are appealing the 2/20/2025 Planning Commission decision because the Commission’s recommendation has an unreasonably negative effect on the restaurant by placing restrictions on its operations that are unheard of in the industry and unprecedented in the City of Orange. Specifically, we are appealing two decisions by the Planning Commission:

1. The Planning Commission rejected the City Staff’s recommended restaurant hours of operation, which generally matched or were shorter than the operating hours of other neighboring CUP holders and other restaurants that operate close to residential neighbors.

The Planning Commission recommended the restaurant be required to stop seating guests on parts of its patio at 7:00 p.m., seven nights a week. In addition, the Planning Commission recommended the interior of the restaurant close on Fridays and Saturdays by 11:00 p.m., at least an hour earlier than the neighboring CUP holders and earlier than staff had recommended. No other restaurant, even those located close to residential neighbors, has such restrictions placed on it. Even the immediate neighboring CUP holders (the Richland and Grand Gimeno) are permitted later hours of operation both on the interior of their patios.

2. We are also appealing a recommendation of the Planning Commission that the restaurant patios be prohibited from playing background music. Unlike hours of operation, this silent patio was a staff recommendation. Background music is important to the atmosphere of a restaurant. The requirement put on other restaurants (even those close to residential neighbors) is that background music is allowed on their patios so long as the music is not audible at the edge of the property line. That is the standard we are requesting be applied to this restaurant as well.

Staff Determination
At the time the project was presented to the Planning Commission, staff recognized the potential sensitivity of the outdoor dining area interface with single-family residences on E. Maple Avenue and considered the public comment on the Design Review Committee’s review of the building rehabilitation in March 2022. Therefore, for purposes of Planning Commission review of the subject CUP, staff included conditions of approval in the draft Planning Commission Resolution deemed necessary to make the Code-required findings that a CUP does not have detrimental effects on surrounding properties. The proposed conditions also reflect consistent treatment of the proposed City of Orange Printed on 4/3/2025Page 3 of 4
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surrounding properties. The proposed conditions also reflect consistent treatment of the proposed restaurant with CUPs for other restaurants in the Old Towne Mixed Use zoning district.

The conditions of approval were discussed extensively with the applicant prior to the Planning Commission hearing. The findings and conditions of approval as originally presented by staff to the Planning Commission are reflected in the City Council Resolution provided as Attachment 2.

Conditions of approval 8, 13, 25, 26, and 27 differ between Attachment 2 and Attachment 4.

Staff maintains that the conditions of approval originally presented to the Planning Commission would provide protection to the neighborhood adjacent to the restaurant and treat Culinary Dropout similar to other Old Towne restaurants. The content of the original draft Planning Commission Resolution has been repackaged for Council consideration as Option 2 for Recommended Action with the following modifications to the hours of operation:

Permitted Operating Hours for Indoor Seating
Sunday - Thursday 7:00 a.m. - 10:00 p.m.

Friday - Saturday 7:00 a.m. - 12:00 a.m.

Permitted Operating Hours for Outdoor Seating
Daily 7:00 a.m. - 10:00 p.m.

7. ATTACHMENTS
· Attachment 1 Appeal to Planning Commission Resolution No. PC 33-24 (APP 25-0009) · Attachment 2 Draft City Council Resolution No. 11603
· Attachment 3 Vicinity Map
· Attachment 4 Planning Commission Resolution No. PC 33-24 · Attachment 5 Planning Commission Staff Report, February 20, 2025 · Attachment 6 Planning Commission Minutes, February 20, 2025 · Attachment 7 Applicant Business Narrative Letter
· Attachment 8 Site Plan and Proposed Seating Chart
· Attachment 9 Outdoor Speaker Locations
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RESOLUTION NO. 11603

A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF ORANGE DENYING APPEAL NO.
25-0009 AND AFFIRMING THE APPROVAL
CONDITIONAL USE PERMIT NO. 3225, A

REQUEST BY CDO ORANGE, LLC, DBA
CULINARY DROPOUT FOR A TYPE 47 ABC

LICENSE (ON -SALE GENERAL) AT A
PROPOSED RESTAURANT LOCATED AT 191 N.

ORANGE STREET.

APPLICANT: CDO ORANGE, LLC (LEEZIE KIM)

WHEREAS, CDO Orange, LLC , submitted an application for Conditional Use Permit No. 3225, a request by CDO Orange, LLC, dba Culinary Dropout for a Type 47 ABC License (On-Sale General) at a proposed restaurant located at 191 N. Orange Street; and

WHEREAS, Conditional Use Permit No. 3225 was processed in the manner prescribed by state and local law; and

WHEREAS, on February 20, 2025, the Planning Commission review ed and approved Conditional Use Permit No. 3225 subject to conditions and findings; and

WHEREAS, on March 3, 2025, Appeal No. 25-0009 was filed by CDO Orange, LLC , appealing the Planning Commission’s approval;

NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Orange hereby approves Conditional Use Permit No. 3225 allowing the sale of alcoholic beverages for on-site consumption in conjunction with a State of California Department of Alcoholic Beverage Control (ABC) Type 47 License (On -Sale General - Eating Place) at a proposed restaurant, located at 191 N. Orange Street, based on the following findings:

SECTION 1 – FINDINGS

Conditional Use Permit Findings:

1. A Conditional Use Permit shall be granted upon sound principles of land use and in response to services required by the community.

Consideration has been given as to whether the proposed use will detrimentally affect adjacent land uses. The proposed use provides an opportunity to those customers desiring to purchase alcohol with food at a restaurant. It will occur on a site that has been zoned for a mix of uses, and the subject property is adjacent to similar uses in the Old Towne downtown core, a commercial destination that serves City residents as well as visitors. The sale of alcohol is an accessory to the proposed restaurant and w ill occur only when a complete Draft
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2 restaurant menu is available. This is a service typically expected by the public in association with a restaurant.

Strong consideration was given to the manner in which the business will operate under the provisions of this Conditional Use Permit. As conditioned, its operation should not create a nuisance to the community or a burden on police services. Consideration was given to the over-concentration of on -sale licenses and crime rate in the Reporting District, and conditions have been placed on the project to compensate for potential detrimental effects that could be caused by alcohol consumption. As conditioned, alcohol service should not contribute to the crime rate in the Reporting District.

Furthermore, the interface of the outdoor patio, with proposed amplified sound, and the single-family homes on the north side of E. Maple Avenue has been considered. Conditions of approval have been placed upon this Conditional Use Permit to mitigate any potential noise pollution in association with the proposed restaurant operations.

2. A Conditional Use Permit shall not be granted if it will cause deterioration of bordering land uses or create special problems for the area in which it is located.

The request to serve alcohol with food at the proposed restaurant is not anticipated to have adverse impacts on surrounding land uses or create a special problem, as conditioned. T he site is located in the Old Towne downtown core , which is intended to function as a commercial and mixed-use center. Conditions of approval include limiting the hours of the outdoor dining area, prohibiting amplified music on the outdoor patio, prohibiting live entertainment, and other s pecific project features compensate for potential detrimental effects on immediately adjacent single-family residences that could be caused by the project.

3. A Conditional Use Permit must be considered in relationship to its effect on the community or neighborhood plan for the area in which it is located.

The location is in an interface area between single -family neighborhoods and the Old Towne downtown core , where shopping and dining establishments are expected to be concentrated. The City’s General Plan for Old Towne encourage the development of mixed use, pedestrian -oriented projects. The proposed accessory alcohol service at a restaurant will support the success of the restaurant and the continuation of a vibrant mixed-use district. The use is n ot anticipated to have an adverse impact on sensitive land uses in the immediate area because granting an additional on -sale license with appropriate conditions of approval, would mitigate potential impacts related to alcohol service and consumption, and noise pollution.

4. A Conditional Use Permit, if granted, shall be made subject to those conditions necessary to preserve the general welfare, not the individual welfare of any particular applicant.

The conditions of approval for this Conditional Use Permit are included with the purpose of preserving the general welfare of the community. The conditions of approval include a review of the proposed restaurant operation one year after the beginning of the sale of alcoholic beverages. If the restaurant is not operating as required, or if there is a history of Draft
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3 criminal or nuisance behavior, this Conditional Use Permit may be revoked by the Planning Commission. Other conditions have been placed on the project to reduce crime -inducing activities by always requiring food service availability with alcohol service, addressing graffiti and litter removal, and requiring employee training.

SECTION 2 – ENVIRONMENTAL REVIEW
The proposed Project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15301 (Class 1 – Existing Facilities) because the project consists of licensing the sale of alcoholic beverages at a proposed restaurant in an existing building that results in negligible or no expansion of use beyond that existing at the time of the City’s determination.

SECTION 3 – APPROVAL AND CONDITIONS OF APPROVAL
The City Council hereby approves Conditional Use Permit No. 3225, with the following conditions:

General Conditions:

1. Any future change in the nature and operation of the use approved by Conditional Use Permit (CUP) No. 3225 shall require an application for a new or amended CUP.

2. The applicant agrees, as a condition of City’s approval of CUP No. 3225, to indemnify, defend, and hold harmless, at applicant’s expense, the City, its officers, agents, and employees (City) from and against any claim, action, or proceeding brought against the City, including, but not limited to, any claim, action or proceeding commenced within the time period provided in Government Code Section 66499.37 to attack, review, set aside, void or annul the City’s approval, to challenge the determination made by the City under the California Environmental Quality Act (CEQA) or to challenge the reasonableness, legality or validity of any condition attached hereto. City shall promptly notify applicant of any such claim, action or proceeding to which the City receives notice and to cooperate fully with the applicant in the defense thereof. Applicant shall reimburse the City for any and all costs and expenses, including, but not limited to, court costs and attorney’s fees that the City may be required to pay, including any expenses ordered by a court or expenses incurred through the Office of the City Attorney in connection with said claim, action or proceeding. City may, in its sole discretion, participate in the defense of any claim, action or proceeding but such participation shall not relieve applicant of the obligations of this condition. In the event the applicant is required to defend City in connection with such claim, action or proceeding, City shall have the right to approve counsel to so defend the City, approve all significant decisions concerning the manner in which the defense is conducted and approve any all settlements, which approval(s) shall not be unreasonably withheld. The obligations set forth herein remain in full force and effect throughout all stages of litigation including any and all appeals of any lower court judgment rendered in the proceeding. Further, applicant agrees to Draft
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4 indemnify, defend and hold harmless the City for all costs and expenses incurred in enforcing this provision.

3. The applicant shall comply with all federal, state, and local municipal laws, including local City ordinances and regulations. Any violations of these laws in conjunction with this use may be a cause for revocation of this permit.

4. Prior to the operation of the business, the applicant shall file for, or if applicable, amend a business license with the Business License Division. Failure to obtain the required business license may be cause for revocation of this approval.

Operational Conditions:

5. In conjunction with the ongoing operation of the business, the licensed premises shall comply with all requirements placed upon it by the State Alcoholic Beverage Control (ABC) Board.

6. This CUP shall be reviewed one year from the date of approval and may be reviewed each year thereafter. The review shall be conducted jointly by the Community Development Director and Police Chief or designees. The purpose of this review shall be to identify uniquely adverse issues such as curfew, loitering, vandalism, criminal activity, noise, or nuisance resulting from approval of the CUP. If such issues are identified, the CUP shall be presented to the Planning Commission for its consideration of conditions, modifications, or revocation.

7. The quarterly gross sales of alcoholic beverages shall not exceed the gross sales of merchant items that include food (including non -alcoholic beverages) within the restaurant during the same period. The licensee shall at all times maintain records which reflect separately the gross sales of food and the gross sales of alcoholic beverages of the licensed business. Said records shall be kept no less frequently than on a quarterly basis and shall be made available upon request.

8. The use of the business is considered a restaurant. Interior construction shall remain consistent with the plans submitted for review by the Planning Commission. No new interior construction resulting in a change to the floor plan will occur unless a revised floor plan is approved by the Community Development Department. None of the floor area will be designated for dancing or live entertainment unless a subsequent CUP is approved by the Planning Commission.

9. The subject ABC license shall not be exchanged for a public premise Type 48 (On - Sale General – Public Premises) license nor operated as a public premise.

10. The sale of beer and/or wine for consumption off the premises shall be prohibited.

11. All alcohol shall be consumed on the subject site, within the defined licensed premises. Signs shall be posted on all unmonitored public exits of the licensed Draft
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5 premises (e.g. the patio exits), which prohibit alcoholic beverages from leaving the confines of the premises.

12. The premises shall be maintained as a bona fide restaurant and shall provide a menu containing an assortment of foods normally offered in such restaurants.

13. The business shall operate Sunday through Thursday, from 7:00 a.m. to 10:00 p.m. and Fridays and Saturdays from 7:00 a.m. to 12:00 a.m. (midnight). These hours do not restrict employees from being on the premises before opening for preparations and deliveries or after close for clean-up. Clean-up may not be conducted by patrons.

14. At no time shall there be a fee for entrance/admittance into the premises.

15. Employees and/or contract security personnel shall not consume any alcoholic beverages prior to or during their work shift. Any and all security officers provided shall comply with all state and local ordinances regulating their services, including, without limitation, Chapter 11.5 of Division 3 of the California Business and Profession Code.

Alcohol and Food Service Conditions:

16. Food service, with an available menu, shall be made available until closing time on each day of operation.

17. Alcoholic beverages shall be served by restaurant employees permitted by law to serve alcohol.

18. Alcoholic beverages shall be sold and served in containers, which are distinguishable from other non-alcoholic beverages sold at the premise.

19. The business may offer alcoholic beverages in combination with non -alcoholic beverages and food items at a reduced price Monday to Friday from 3:00 p.m. to 6:00 p.m.

20. There shall be no promotions encouraging intoxication or drinking contests.

21. There shall be no requirement to purchase a minimum number of drinks.

22. No alcoholic beverages shall be sold from any self -service locations on the premises such as ice tubs, barrels, or any other such containers.

23. The petitioner shall not employ or permit any persons to solicit or encourage others, directly or indirectly, to buy them drinks in the licensed premises under any commission percentage salary or other profit.

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6 Outdoor Dining Area Conditions:

24. The use of any outdoor sound system, outdoor amplifying systems, paging system or any other such device is prohibited on the licensed premises.

25. The use of the outdoor dining area shall be limited to 7:00 a.m. to 10:00 p.m.

26. No pressure washing or mechanical cleaning methods shall occur in the outdoor dining area after 10:00 p.m. or before 6:00 a.m. on any day.

27. The outdoor dining area shall be enclosed by a fence and any gates located on the patio shall remain closed during business hours and used as an emergency exit only.

Sign(s) shall be posted on all patio gates indicating “Emergency Exit Only”.

28. Consistent with approved building shell entitlements (MNSP No. 1066 -22, DRC No. 5056-22 and APP No. 0557 -22; Resolution No. PC 05 -22), the door on the north elevation connecting the restaurant interior to the outdoor dining area shall be designed and used as “exit only”. This shall be verified by the Planning Division on the construction documents prior to the issuance of Building Permits for tenant improvements.

Special Events:

29. No portion of the premises shall be deemed to be “private” for the purposes of dispensing alcoholic beverages to selected patrons, where the permittee recognizes any form of membership cards, keys, or passes which would entitle the holder entry or preferential admittance or exclusive use of any portion of the mentioned premises, provided, however, the restaurant may hold social and corporate private dining events where a corporate or social host has reserved all or a portion of the restaurant (e.g. rehearsal dinners, corporate holiday parties, etc.).

30. The use of a promoter (such as a night -club operator) or sub -leasing the premises to be used in conjunction with dancing and/or live entertainment is prohibited.

31. There shall be no live entertainment (including karaoke), disc jockey, or dancing permitted on the premises at any time. Interior amplified music of any kind, including over a built-in system designated for background music, shall be permitted so long as the music is not audible outside when the doors are open or beyond the premises in such a manner as to unreasonably disturb the peace, quiet, and comfort of neighboring occupants, given the time of day and other conditions.

Coin Operated Machines:

32. There shall be no pool tables or coin -operated games or machines maintained on the premises at any time.

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7 Security and Exterior:

33. The parking lot of the premises shall be equipped with lighting of sufficient power to illuminate and make easily discernible the appearance and conduct of all persons on or about the parking lot.

34. Lighting in the parking area of the premises shall be directed, positioned, and shielded in such a manner so as not to unreasonably illuminate the window area of nearby residences.

35. The permittee shall install and maintain a closed -circuit television system capable of readily identifying facial features, and stature of all patrons entering the establishment during hours of operation and monitoring the rear of the premises. The camera system shall keep a minimum 30 -day library of events, which shall be available for downloading and inspection by Orange Police Department.

36. The permittee shall be responsible for maintaining free of litter the area adjacent to the premises over which they have control.

37. There shall be no exterior advertising signage of alcohol. This includes advertising signage placed directly to the exterior from within, promoting or indicating the availability of alcoholic beverages. Interior advertising signage of alcohol that are clearly visible to the exterior shall constitute a violation of this condition.

38. The restaurant shall be protected by a monitored alarm system, which shall detect an attempted entry or presence of people within the business during closing hours.

39. The premises shall be provided with an interior night light to illuminate the interior and an unobstructed view shall be maintained through storefront windows to provide police patrol officers the ability to observe unlawful activity within the business.

40. The licensee shall maintain on the premises a written security policy and procedures manual addressing at a minimum the following items: handling obviously intoxicated persons; establishing a reasonable ratio of employees to patrons, based upon activity level, in order to monitor alcoholic beverage sales and patron behavior; handing patrons involved in fighting or arguing; handling loitering about the licensed premises; verifying age/checking identification of patrons; warning patrons of reaching their drinking limit/potential intoxication and refusing to serve; calling the police regarding observed or reported criminal activity.

Training:

41. All employees of the permittee who sell or serve alcoholic beverage products shall be required to complete the Responsible Beverage Service (RBS) training program provided by the California State Department of Alcoholic Beverage Control (ABC).

For new employees, such training program must be completed within 30 days of the date of hire. The permittee shall maintain an active list of the employees who have Draft
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8 completed the training. The list shall be furnished, upon request, to any sworn police office or member of the Community Development Department. The employees must provide the Orange Police Department a copy of the completed RBS certificate, upon request.

Miscellaneous:

42. Graffiti shall be removed from the exterior walls, doors, windows, and any additional part of the property (including signage, etc.) within 72 hours of the time the City of Orange Notice of Violation is received by the business operator.

ADOPTED this day of 2025.

Daniel R. Slater, Mayor, City of Orange

ATTEST:

Pamela Coleman, City Clerk, City of Orange

APPROVED AS TO FORM:

Wayne W. Winthers, Interim City Attorney, City of Orange

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9 STATE OF CALIFORNIA )

COUNTY OF ORANGE )

CITY OF ORANGE )

I, PAMELA COLEMAN, City Clerk of the City of Orange, California, do hereby certify that the foregoing Resolution was duly and regularly adopted by the City Council of the City of Orange at a regular meeting thereof held on the day of , 202 5 by the following vote:

AYES: COUNCILMEMBERS:

NOES: COUNCILMEMBERS:

ABSENT: COUNCILMEMBERS:

ABSTAIN: COUNCILMEMBERS:

Pamela Coleman, City Clerk, City of Orange
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J:\GisProjects\Planning\ABC\GIS\APRX\ABC_Licenses\ABC_Licenses.aprx\191 N Orange Street 11/5/2024
Source: Alcohol Beverage Control (2024), City of Orange (08/2024), US Census (2020) 0 200100
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^_
&OHARAS PUB INC
150 GLASSELL
ST N 48
& RENATA'S CAFE
ITALIANO 227
CHAPMAN AVE E 41
&

GABBIS MEXICAN

KITCHEN
141 S GLASSELL ST
TYPE: 47 & 58
&

THE FILLING STATION

CAFE INC
201 GLASSELL ST N
TYPE: 41
& SMOQUED BBQ
128 GLASSELL
ST N 41
&

PROVISIONS DELI & BOTTLE SHOP
143 N GLASSELL ST
TYPE: 41
& RAMISONS INC
155 GLASSELL
ST N 42
&

ELKS LODGE
ORANGE 1475
211 CHAPMAN
AVE E 51
&
O SEA
109 GLASSELL ST S
TYPE: 41
&

CHIPOTLE MEXICAN
GRILL STORE 3983
112 MAPLE AVE E 41
&

HANANA RAMEN
161 GLASSELL
ST N 41
&

CITRUS CITY
GRILLE
122 GLASSELL ST N
TYPE: 47 & 58
&

JAXONS CHIX
TENDERS 149

GLASSELL
ST N 41
&

THE RICHLAND
137 MAPLE AVE E
TYPE: 47 & 68
&

JALAPENOS

ORANGE CIRCLE
154 GLASSELL
ST N 41
& RAMISONS INC
153 GLASSELL
ST N 41
&

THE RICHLAND
230 ORANGE ST N
Type: 47, 48, 68, 69
&

CULINARY DROPOUT
191 N. Orange Street
Type 47
& Portico Church
146 N Grand St,
Orange, CA 92866
&
First Presbyterian Church
191 N Orange St
&
Son Light
Christian Center
172 N Glassell St
Census Tract
759.01
Census Tract
759.02

N GLASSELL

N GRAND

S (ALLEY)

W CHAPMAN AV

P L A Z A S Q

E CHAPMAN AV

S GLASSELL

S CENTER

S GRAND

S ORANGE

W PALM AV
(DRIVEWAY)

E PALM AV

E (ALLEY)

E MAPLE AV
N
C
E
N
T
E
R

N ORANGE
Legend
^_ Proposed
600-ft Radius of Proposed
Active
")
Surrendered
Sensitive Receptors
Census Tract Boundary

ABC LICENSES
& SENSITIVE RECEPTORS

CITY OF ORANGE
ABC License
622
CONDITIONAL USE PERMIT NO.3225
RESOLUTION NO. PC 33-24

A RESOLUTION OF THE PLANNING COMMISSION OF

THE CITY OF ORANGE APPROVING CONDITIONAL USE
PERMIT NO. 3225, ALLOWING THE SALE OF

ALCOHOLIC BEVERAGES FOR ONSITE CONSUMPTION

IN CONJUNCTION WITH A STATE OF CALIFORNIA

DEPARTMENT OF ALCOHOLIC BEVERAGE CONTROL
TYPE 47 LICENSE (ON-SALE GENERAL EATING

PLACE) AT A PROPOSED RESTAURANT LOCATED AT
191 N. ORANGE STREET
APPLICANT: CDO Orange LLC dba Culinary Dropout
WHEREAS, the Planning Commission has authority pursuant to Orange Municipal Code (OMC) Table 17.08.020 and Sections 17.10.030.C and 17.30.030 to take action on Conditional Use Permit No. 3225, allowing the sale of alcoholic beverages for on-site consumption in conjunction with a State of California Department of Alcoholic Beverage Control (ABC) Type 47 License (On-Sale General - Eating Place) at a proposed restaurant, located at l9l N. Orange Street, (Project); and
WHEREAS, the application for Conditional Use Permit No. 3225 was filed by the applicant in accordance with the provisions of the OMC; and WHEREAS, Conditional Use Permit No. 3225 is Categorically Exempt from the provisions of the Califomia Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15301 (Class 1 - Existing Facilities), as the project consists of licensing the sale of alcoholic beverages at a proposed restaurant in an existing building that results in negligible or no expansion of use beyond that existing at the time of the City's determination; and WHEREAS, the Planning Commission conducted one duly advertised public hearing on February 20,2025, at which time interested persons had an opportunity to testiS either in support of, or opposition to, the proposed Conditional Use Permit No. 3225.

NOW, THEREFORE, BE IT RESOLVED that the Planning Commission of the City of Orange hereby approves Conditional Use Permit No. 3225 allowing the sale of alcoholic beverages for on-site consumption in conjunction with a State of California Department of Alcoholic Beverage Control (ABC) Type 47 License (On-Sale General - Eating Place) at a proposed restaurant, located at l9l N. Orange Street, based on the following findings:

SECTION 1 _ FINDINGS
Conditional Use Permit Findings
623
Resolution No. PC 33-24

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1. A Conditional Use Permit shall be granted upon sound principles of land use and in response to services required by the community.

Consideration has been given as to whether the proposed use will detrimentally affect adjacent land uses. The proposed use provides an opportunity to those customers desiring to purchase alcohol with food at a restaurant. It will occur on a site that has been zoned for a mix of uses, and the subject property is adjacent to similar uses in the Old Towne downtown core, a commercial destination that serves City residents as well as visitors. The sale of alcohol is accessory to the proposed restaurant and will occur only when a complete restaurant menu is available. This is a service typically expected by the public in association with a restaurant.

Strong consideration was given to the manner in which the business will operate under the provisions of this Conditional Use Permit. As conditioned, its operation should not create a nuisance to the community or a burden on police services. Consideration was given to the over- concentration of on-sale licenses and crime rate in the Reporting District, and conditions have been placed on the project to compensate tbr potential detrimental effects that could be caused by alcohol consumption. As conditioned, alcohol service should not contribute to the crime rate in the Reporting District.

2. A Conditional Use Permit shall not be granted if it will cause deterioration of bordering land uses or create special problems for the area in which it is located.

The request to serve alcohol with food at the proposed restaurant is not anticipated to have adverse impacts on surounding land uses or create a special problem, as conditioned. The site is located in the Old Towne downtown core, which is intended to function as a commercial and mixed-use center. Conditions of approval include limiting the hours of the outdoor dining area, prohibiting amplified music on the outdoor patio, prohibiting live entertainment, and other specific project features compensate for potential detrimental effects on immediately adjacent single-family residences that could be caused by the project.

3. A Conditional Use Permit must be considered in relationship to its ffict on the community or neighborhood planfor the area in which it is located.

The location is in an interface area between single-family neighborhoods and the Old Towne downtown core, where shopping and dining establishments are expected to be concentrated. The City's General Plan for Old Towne encourage the development of mixed use, pedestrian-oriented projects. The proposed accessory alcohol service at a restaurant will support the success of the restaurant and the continuation of a vibrant mixed-use district. The use is not anticipated to have an adverse impact on sensitive land uses in the immediate area because granting an additional on-sale license with appropriate conditions of approval, would mitigate potential impacts related to alcohol service and consumption, and noise pollution.

Furthermore, the interface of the outdoor patio, with proposed amplified sound, and the single- family homes on the north side of E. Maple Avenue has been considered. Conditions of approval have been placed upon this Conditional Use Permit to mitigate any potential noise pollution in association with the proposed restaurant operations. 624
Resolution No. PC 33-24

Page 3 ends

4. A Conditional Use Permit, if granted, shall be made subject to those conditions necessary to preserve the general welfare, not the individual welfare of any particular applicant.

The conditions of approval for this Conditional Use Permit are included with the purpose of preserving the general welfare of the community. The conditions of approval include a review of the proposed restaurant operation one year after the beginning of the sale of alcoholic beverages. If the restaurant is not operating as required, or if there is a history of criminal or nuisance behavior, this Conditional Use Permit may be revoked by the Planning Commission.

Other conditions have been placed on the project to reduce crime-inducing activities by always requiring food service availability with alcohol service, addressing graffiti and litter removal, and requiring employee training.

SECTION 2 _ ENVIRONMENTAL REVIEW
The proposed Project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15301 (Class I - Existing Facilities) because the project consists of licensing the sale of alcoholic beverages at a proposed restaurant in an existing building that results in negligible or no expansion of use beyond that existing at the time of the City's determination.

SECTION 3 _ APPROVAL AND CONDITIONS OF APPROVAL
The Planning Commission hereby approves Conditional Use Permit No. 3225, with the following conditions:

General Conditions
Any future change in the nature and operation of the use approved by Conditional Use Permit (CUP) No. 3225 shall require an application for a new or amended CUP.

The applicant agrees, as a condition of City's approval of CUP No. 3225, to indemnifu, defend, and hold harmless, at applicant's expense, the City, its officers, agents, and employees (City) from and against any claim, action, or proceeding brought against the City, including, but not limited to, any claim, action or proceeding commenced within the time period provided in Government Code Section 66499.37 to attack, review, set aside, void or annul the City's approval, to challenge the determination made by the City under the California Environmental Quality Act (CEQA) or to challenge the reasonableness, legality or validity of any condition attached hereto. City shall promptly notit/ applicant of any such claim, action or proceeding to which the City receives notice and to cooperate fully with the applicant in the defense thereof. Applicant shall reimburse the City for any and all costs and expenses, including, but not limited to, court costs and attorney's fees that the City may be required to pay, including any expenses ordered by a court or expenses incurred through the Office of the City Attorney in connection with said claim, action or proceeding. City may, in its sole discretion, participate in the defense of any claim, action or proceeding but such participation shall not relieve applicant of the obligations of this condition. In the event the applicant is required to defend City in connection with such claim, action or proceeding, City shall have the right to approve counsel to so defend the 1 2
625
J
4 5
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Resolution No. PC 33-24

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City, approve all significant decisions concerning the manner in which the defense is conducted and approve any all settlements, which approval(s) shall not be unreasonably withheld. The obligations set forth herein remain in full force and effect throughout all stages of litigation including any and all appeals of any lower court judgment rendered in the proceeding. Further, applicant agrees to indemniff, defend and hold harmless the City for all costs and expenses incurred in enforcing this provision.

The applicant shall comply with all federal, state, and local municipal laws, including local City ordinances and regulations. Any violations of these laws in conjunction with this use may be a cause for revocation of this permit.

Prior to the operation of the business, the applicant shall file for, or if applicable, amend a business license with the Business License Division. Failure to obtain the required business license may be cause for revocation of this approval.

Operat i onal C onditi ons
In conjunction with the ongoing operation of the business, the licensed premises shall comply with all requirements placed upon it by the State Alcoholic Beverage Control (ABC) Board.

This CUP shall be reviewed one year from the date of approval and may be reviewed each year thereafter. The review shall be conducted jointly by the Community Development Director and Police Chief or designees. The purpose of this review shall be to identifu uniquely adverse issues such as curfew, loitering, vandalism, criminal activity, noise, or nuisance resulting from approval of the CUP. If such issues are identified, the CUP shall be presented to the Planning Commission for its consideration of conditions, modifications, or revocation.

The quarterly gross sales of alcoholic beverages shall not exceed the gross sales of merchant items that include food (including non-alcoholic beverages) within the restaurant during the same period. The licensee shall at all times maintain records which reflect separately the gross sales offood and the gross sales ofalcoholic beverages ofthe licensed business. Said records shall be kept no less frequently than on a quarterly basis and shall be made available upon request.

The use of the business is considered a restaurant. Interior construction shall remain consistent with approved building shell entitlements (MNSP No. 1066-22, DRC No. 5056- 22 and APP No. 0557-22; Resolution No. PC 05-22). No new interior construction resulting in a change to the floor plan will occur unless a revised floor plan is approved by the Community Development Department. None of the floor area will be designated for dancing or live entertainment unless a subsequent CUP is approved by the Planning Commission.

The subject ABC license shall not be exchanged for a public premise Type 48 (On-Sale General - Public Premises) license nor operated as a public premise. 7 8
9 626
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Resolution No. PC 33-24

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10. The sale of beer andlor wine for consumption off the premises shall be prohibited All alcohol shall be consumed on the subject site, within the defined licensed premises.

Signs shall be posted on all unmonitored public exits of the licensed premises (e.g. the patio exits), which prohibit alcoholic beverages from leaving the confines of the premises.

12. The premises shall be maintained as a bona fide restaurant and shall provide a menu containing an assortment of foods normally offered in such restaurants. 13 The business shall operate Sunday through Thursday, from 7:00 a.m. to 10:00 p.m. and Fridays and Saturdays from 7:00 a.m. to1 1:00 p.m. These hours do not restrict employees from being on the premises before opening for preparations and deliveries or after close for clean-up. Clean-up may not be conducted by patrons.

14. At no time shall there be a fee for entrance/admittance into the premises.

15. Employees andlor contract security personnel shall not consume any alcoholic beverages prior to or during their work shift. Any and all security officers provided shall comply with all state and local ordinances regulating their services, including, without limitation, Chapter I 1.5 of Division 3 of the California Business and Profession Code.

Alcohol and Food Service Conditions
16 Food service, with an available menu, shall be made available until closing time on each day of operation.
t7 Alcoholic beverages shall be served by restaurant employees permitted by law to serve alcohol.
18 Alcoholic beverages shall be sold and served in containers, which are distinguishable from other non-alcoholic beverages sold at the premise.
l9 The business may offer alcoholic beverages in combination with non-alcoholic beverages and food items at a reduced price Monday to Friday from 3:00 p.m. to 6:00 p.m.

20. There shall be no promotions encouraging intoxication or drinking contests

21. There shall be no requirement to purchase a minimum number of drinks.

No alcoholic beverages shall be sold from any self-service locations on the premises such as ice tubs, barrels, or any other such containers.
23 The petitioner shall not employ or permit any persons to solicit or encourage others, directly or indirectly, to buy them drinks in the licensed premises under any commission percentage salary or other profit.

22. Outdoor Dining Area Conditions
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Resolution No. PC 33-24

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25. 24
26 27

28. 29

30. 32
Special Events
3 1 . No portion of the premises shall be deemed to be "private" for the purposes of dispensing alcoholic beverages to selected patrons, where the permittee recognizes any form of membership cards, keys, or passes which would entitle the holder entry or preferential admittance or exclusive use of any portion of the mentioned premises, provided, however, the restaurant may hold social and corporate private dining events where a corporate or social host has reserved all or a portion ofthe restaurant (e.g. rehearsal dinners, corporate holiday parties, etc.).

The use of a promoter (such as a night-club operator) or sub-leasing the premises to be used in conjunction with dancing and/or live entertainment is prohibited.

The use of any outdoor sound system, outdoor ampliffing systems, and paging system or any other such device is prohibited on the licensed premises.

The outdoor patio area that has street frontage along N Orange Street shall be known as the "west patio area". Sunday through Thursday use of the west outdoor patio area shall conclude by l0:00 p.m. No new customers shall be seated in the outdoor dining area after 9:00 p.m. as a means of concluding patron use and restaurant service outside by 10:00 p.m.

The outdoor patio area that has street frontage along N Orange Street shall be known as the "west patio area". Fridays and Saturdays use of the west outdoor patio area shall conclude by 11:00 p.m. No new customers shall be seated inthe outdoor dining areaafter 10:00 p.m. as a means of concluding patron use and restaurant service outside by 1 1:00 p.m.

The outdoor patio area that has street frontage along E Maple Avenue shall be known as the "north patio area". The use of outdoor dining on the north patio area shall not begin until 10:00 a.m. and shall conclude by 8:00 p.m. every day. No new customers shall be seated in the north patio area after 7:00 p.m.

No pressure washing or mechanical cleaning methods shall occur in the outdoor dining area after l0:00 p.m. or before 6:00 a.m. on any day.

The outdoor dining area shall be enclosed by a fence and any gates located on the patio shall remain closed during business hours and used as an emergency exit only. Sign(s) shall be posted on all patio gates indicating "Emergency Exit Only".

Consistent with approved building shell entitlements (MNSP No. 1066-22, DRC No. 5056- 22 and APP No. 0557-22; Resolution No. PC 05-22), the door on the north elevation connecting the restaurant interior to the outdoor dining area shall be designed and used as "exit only". This shall be verified by the Planning Division on the construction documents prior to the issuance of Building Permits for tenant improvements.

There shall be no live entertainment (including karaoke), disc jockey, or dancing permitted on the premises at any time. Interior amplified music of any kind, including over a built-in aaJJ
628

34. Resolution No. PC 33-24

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system designated for background music, shall be permitted so long as the music is not audible outside when the doors are open or beyond the premises in such a manner as to unreasonably disturb the peace, quiet, and comfort of neighboring occupants, given the time of day and other conditions.

Coin Operated Machines
There shall be no pool tables or coin-operated games or machines maintained on the premises at any time.

Security and Exterior
The parking lot of the premises shall be equipped with lighting of sufficient power to illuminate and make easily discernible the appearance and conduct of all persons on or about the parking lot.

36. Lighting in the parking area of the premises shall be directed, positioned, and shielded in such a manner so as not to unreasonably illuminate the window area of nearby residences.

The permittee shall install and maintain a closed-circuit television system capable of readily identiffing facial features, and stature of all patrons entering the establishment during hours of operation and monitoring the rear of the premises. The camera system shall keep a minimum 30-day library of events, which shall be available for downloading and inspection by Orange Police Department.
37 38 The permittee shall be responsible for maintaining free of litter the area adjacent to the premises over which they have control.

There shall be no exterior advertising signage of alcohol. This includes advertising signage placed directly to the exterior from within, promoting or indicating the availability of alcoholic beverages. Interior advertising signage of alcohol that are clearly visible to the exterior shall constitute a violation of this condition.

The restaurant shall be protected by a monitored alarm system, which shall detect an attempted entry or presence of people within the business during closing hours.

35. 40.
4t.
39 42.

The premises shall be provided with an interior night light to illuminate the interior and an unobstructed view shall be maintained through storefront windows to provide police patrol officers the ability to observe unlawful activity within the business.

The licensee shall maintain on the premises a written security policy and procedures manual addressing at a minimum the following items: handling obviously intoxicated persons; establishing a reasonable ratio of employees to patrons, based upon activity level, in order to monitor alcoholic beverage sales and patron behavior; handing patrons involved in fighting or arguing; handling loitering about the licensed premises; verifring agelchecking identification of patrons; warning patrons of reaching their drinking 629
Resolution No. PC 33-24

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limit/potential intoxication and refusing to serve; calling the police regarding observed or reported criminal activity.

Training.

43. All employees of the permittee who sell or serve alcoholic beverage products shall be required to complete the Responsible Beverage Service (RBS) training program provided by the Califomia State Department of Alcoholic Beverage Control (ABC). For new employees, such training program must be completed within 30 days of the date of hire.

The permittee shall maintain an active list of the employees who have completed the training. The list shall be fumished, upon request, to any sworn police office or member of the Community Development Department. The employees must provide the Orange Police Department a copy of the completed RBS certificate, upon request.

Miscellaneous
Graffiti shall be removed from the exterior walls, doors, windows, and any additional part of the property (including signage, etc.) within 72 hours of the time the City of Orange Notice of Violation is received by the business operator.

ADOPTED this 20th day of February 2025.

V
Planning Commission Chair
I hereby certiff that the foregoing Resolution was adopted by the Planning Commission of the City of Orange at a regular meeting thereof held on the 20th day of February 2025, by the following vote:

44. AYES:

NOES:

ABSENT:

Yazquez, Vejar, Maldonado, Leslie
Martinez, Tucker, McCormack
None
Anna Pehoushek, FAICP
Assistant Community Development Director
630
Agenda Item
Planning Commission
Item #: 5.1. 2/20/2025 File #: 25-0088
TO: Chair and Members of the Planning Commission
THRU: Anna Pehoushek, Assistant Community Development Director FROM: Arlen Beck, Associate Planner

1. SUBJECT
Public Hearing to consider a request by CDO Orange, LLC, dba Culinary Dropout for a Type 47 ABC License (On-Sale General) at a proposed restaurant located at 191 N. Orange Street and finding of CEQA Exemption (Conditional Use Permit No. 3225).

2. SUMMARY
The applicant, CDO Orange, LLC (Culinary Dropout), is requesting to serve a full range of alcoholic beverages with food at a proposed restaurant with a State of California Department of Alcoholic Beverage Control Type 47 license (On-Sale General - Eating Place).

3. RECOMMENDED ACTION

1. Adopt Planning Commission Resolution No. PC 33-24. A Resolution of the Planning Commission of the City of Orange approving Conditional Use Permit No. 3225, allowing the sale of alcoholic beverages for onsite consumption in conjunction with a State of California Department of Alcoholic Beverage Control Type 47 license (On-Sale General - Eating Place) at a proposed restaurant located at 191 N. Orange Street.

2. Find the request categorically exempt from the California Environmental Quality Act (CEQA) in accordance with Section 15301 of the State CEQA Guidelines.

4. AUTHORIZING GUIDELINES
Orange Municipal Code (OMC) Table 17.08.020 and Sections 17.10.030.C and 17.30.030 authorize the Planning Commission to review and take action on a request for a Conditional Use Permit to allow the sale of alcoholic beverages for on-site consumption in conjunction with a restaurant.

5. PROJECT BACKGROUND
In 2020, First Presbyterian Church of Orange filed an application for a Tentative Parcel Map to create two new parcels totaling 9,358 sq ft and 40,451 sq ft at the existing church campus. The project site is the smaller parcel and contains the building currently under construction.

Applicant: CDO Orange, LLC dba Culinary Dropout
Property Owner 191 Orange, LLC
Property Location 191 N. Orange Street
Existing General Plan Land Use
Element Designation
Old Towne Mixed Use 15, 0.5 - 1.0 FAR (OTMIX15)
Existing Zoning Classification Old Towne Mixed Use-15 (OTMU-15) Old Towne Yes
Specific Plan/PC N/A
Site Size Parcel: 9,358 sq ft Tenant space: 7,425 sq ft, including outdoor patio Circulation Primary access to the property is from N. Orange Street and E. Maple Avenue
Existing Conditions The site is located on the south side Maple Avenue, between N.

Orange Street to the west and N. Grand Street to the east. The proposed tenant space for the restaurant is currently under construction.

Surrounding Land Uses and
Zoning
North: Single family residences (R-1-6) South: Existing church (First Presbyterian Church of Orange) (OTMU-15) East: Single family residences (R-1-6), church sanctuary, and a surface parking lot (OTMU- 15) West: Office building (Architects Orange) and a surface parking lot (OTMU-15)
Previous
Applications/Entitlements
MNSP No. 1066-22, DRC No. 5056-22, and APP No. 0557-22 for a remodel and addition to the existing administration building, parking lot upgrades, new landscaping, new patios/outdoor dining areas, and paving the interior courtyard. TPM 0015 for the creation of two new parcels totaling 0.51 acres and 0.93 acres at an existing church campus City of Orange Printed on 2/13/2025Page 1 of 6
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Item #: 5.1. 2/20/2025 File #: 25-0088
Applicant: CDO Orange, LLC dba Culinary Dropout
Property Owner 191 Orange, LLC
Property Location 191 N. Orange Street
Existing General Plan Land Use
Element Designation
Old Towne Mixed Use 15, 0.5 - 1.0 FAR (OTMIX15)
Existing Zoning Classification Old Towne Mixed Use-15 (OTMU-15) Old Towne Yes
Specific Plan/PC N/A
Site Size Parcel: 9,358 sq ft Tenant space: 7,425 sq ft, including outdoor patio Circulation Primary access to the property is from N. Orange Street and E. Maple Avenue
Existing Conditions The site is located on the south side Maple Avenue, between N.

Orange Street to the west and N. Grand Street to the east. The proposed tenant space for the restaurant is currently under construction.

Surrounding Land Uses and
Zoning
North: Single family residences (R-1-6) South: Existing church (First Presbyterian Church of Orange) (OTMU-15) East: Single family residences (R-1-6), church sanctuary, and a surface parking lot (OTMU- 15) West: Office building (Architects Orange) and a surface parking lot (OTMU-15)
Previous
Applications/Entitlements
MNSP No. 1066-22, DRC No. 5056-22, and APP No. 0557-22 for a remodel and addition to the existing administration building, parking lot upgrades, new landscaping, new patios/outdoor dining areas, and paving the interior courtyard. TPM 0015 for the creation of two new parcels totaling 0.51 acres and 0.93 acres at an existing church campus

6. PROJECT DESCRIPTION
The applicant proposes a 7,425 sq ft restaurant, Culinary Dropout, with a State of California Department of Alcoholic Beverage Control (ABC) Type 47 License (On-Sale General - Eating Place).

The restaurant includes a total of 255 seats, with 201 seats indoors and 54 seats on the outdoor patio (Attachment 2). Attachment 1 includes conditions of approval that permit the following operating hours:

Proposed Permitted Operating Hours for
Indoor Seating
Sunday - Thursday 7:00 a.m. - 10:00 p.m.

Friday - Saturday 7:00 a.m. - 12:00 a.m. (midnight)
Proposed Permitted Operating Hours for Outdoor Patio
Seating
Days Hours Last Customer Seated Time
Sunday - Thursday 7:00 a.m. - 10:00 p.m. 9:00 p.m.

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Item #: 5.1. 2/20/2025 File #: 25-0088
Proposed Permitted Operating Hours for Outdoor Patio
Seating
Days Hours Last Customer Seated Time
Sunday - Thursday 7:00 a.m. - 10:00 p.m. 9:00 p.m.

Saturday - Sunday 7:00 a.m. - 11:00 p.m. 10:00 p.m.

7. PROJECT ANALYSIS
Adaptive Re-use of the Structure
The adaptive re-use of an existing building from administrative office to restaurant is allowed in the Old Towne downtown core and a logical use of the site given its close proximity to an event center, offices, restaurants, residences, and public parking lot.

Outdoor Dining Area Use:

Of the 54 seats on the proposed outdoor dining area, 24 are proposed along the E. Maple Avenue frontage. As shown in the sound location exhibit (Attachment 4), the applicant proposed two speakers for amplified sound along the portion of the dining area fronting E. Maple Avenue and six speakers along the N. Orange Street frontage.

The immediate interface between the northern outdoor seating area of the restaurant and single- family residences on the north side of E. Maple Avenue warrants attention in order to support the required conditional use permit findings established by the Orange Municipal Code; specifically, those pertaining to potential negative effects the proposed use may have on surrounding land uses.

Outdoor dining activity has the potential to create noise issues that could be disruptive to adjacent residents, particularly in the evening. Therefore, staff has included conditions of approval to mitigate potential noise impacts to sensitive receptors:
· Prohibition of an outdoor sound system or amplifying system. (Condition No. 24) · All outdoor patio seating to conclude by 10:00 p.m. Sunday through Thursday and by 11:00 p.m. Friday and Saturday, with no seating of new customers on the outdoor patio one hour before patio seating closes. (Condition No. 25 and 26)
· Limit hours of operation to no later than midnight on Fridays and Saturdays, and 10:00 p.m.

Sunday through Thursday to be generally consistent with hours of operation of other uses in the immediate vicinity operating with a Type 47 ABC License. (Condition No. 13) · Prohibit live entertainment (including karaoke), disc jockey, or dancing, and limit amplified music so that it is not audible outside (Condition No. 32).

Sensitive Receptors and Alcohol Sales:

For the findings, the Planning Commission shall consider whether the proposed use will:

1. Adversely affect the welfare of the surrounding community

2. Result in an undue concentration of premises for the sale of alcoholic beverages

3. Detrimentally affect nearby residentially zoned districts after giving consideration to the proposed hours of operation
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4. Detrimentally affect the proximity to the following:

A. Residential buildings.

B. Churches, schools, hospitals, public playgrounds, and other similar uses.

C. Other establishments dispensing, for sale or other consideration, alcoholic beverages, including beer and wine.

There are 20 other establishments selling alcoholic beverages within the vicinity (600-foot radius) of the subject property. Other sensitive receptors within the vicinity include single-family and multi-family residences, and two churches (see Attachment 5). Below is a list of sensitive receptors identified within the vicinity (600-foot radius) of the subject property as outlined by Orange Municipal Code Section 17.30.040:

Sensitive Receptors
Establishment Name Address Distance to Project Site
Single-Family Dwellings E. Maple Ave. & N. Grand St. 50 - 600 feet Multi-Family Dwellings
(2nd story apartments)
Plaza Square 300 feet
First Presbyterian
Church of Orange
180 N. Grand St. 0 feet
Son Light Church 172 N. Glassell St. 600 feet
While there are sensitive land uses in the vicinity of the site, approval of the CUP for alcohol sales, with the proposed conditions of approval, is unlikely to impact the sensitive receptors identified above given that the sale of alcohol is associated with a full-service restaurant with a majority of indoor seating, and limitations will be placed on outdoor dining activity.

Census Tract Concentration:

The business is located within Census Tract 759.01. This Census Tract is considered overconcentrated with On-Sale and Off-Sale Licenses.

Alcohol Licenses in Census Tract 760.01
License Type Allowed Existing
On-Sale Licenses 5 19
Off-Sale Licenses 2 4
Crime Statistics for Reporting District 23w:

Orange Police Department (OPD) crime statistics show the subject site is located within a high crime area, because reported crimes are more than 20% above the average of reported crimes citywide.

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The table below shows the OPD crime statistics for RD-23W compared to the citywide average.

Crime Statistics
Reporting
District
Reported Crimes
and Arrests
Citywide Average
Crimes and Arrests
Percent
Difference
61 115 85 35%
Staff does not anticipate that the use will create a negative impact on neighboring land uses because the restaurant, as conditioned, is compatible with the mix of uses within the surrounding area, has defined hours, will be adequately staffed, and the primary use will be food service. Should the Planning Commission approve the CUP, the standard conditions of approval for the safe operation of the restaurant with alcohol service are included in the Planning Commission Resolution (Attachment 1).

Project Conditions
The applicant’srequest for a Type 47 ABC License provides the City with an opportunity to impose standards and conditions of approval for restaurants serving alcoholic beverages in conjunction with food to protect the health, safety, and general welfare of the nearby neighborhood and overall community which include, but are not limited to:
· Gross sales of alcohol shall not exceed non-alcohol sales (Condition No. 7). · Alcohol shall only be consumed within the defined dining areas (Condition No. 11). · Food service must be made available until closing time on each day of operation (Condition No. 16).
· Live entertainment on the premises is prohibited (Condition No. 32).

8. PUBLIC NOTICE
On February 6, 2025, a public notice was posted at the project site, and the City sent a Public Hearing Notice to a total of 208 property owners/occupants within a 400-foot radius of the project site and persons specifically requesting notice.

9. ENVIRONMENTAL REVIEW
Categorical Exemption: The proposed project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines 15301 (Class 1 - Existing Facilities) because the project consists of licensing the sale of alcoholic beverages at a proposed restaurant in an existing building that results in negligible or no expansion of use beyond that existing at the time of the City’s determination.

10. ADVISORY BOARD ACTION
None required.

11. ATTACHMENTS
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Item #: 5.1. 2/20/2025 File #: 25-0088
· Attachment 1 - Planning Commission Resolution No. PC 33-24 · Attachment 2 - Site Plan and Floor Plan
· Attachment 3 - Applicant Business Narrative Letter
· Attachment 4 - Planning Commission Evaluation Map
· Attachment 5 - Orange Police Department Memorandum
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APPROVED BY THE PLANNING COMMISS]ON ON MARCH |f, 2025

MINUTES
City of Orange
Planning Commission
February 20,2025
The Planning Commission of the City of Orange, California convened on February 20, 2025, at 5:30 p.m. in a Regular Meeting in the Council Chamber, 300 E. Chapman Avenue, Orange, California.

1. OPENING/CALL TO ORDER
Chair Vazquez called the meeting to order at 5:30 p.m.

1.1 PLEDGE OF ALLEGIANCE
Commissioner Leslie led the flag salute.

1.2 ROLL CALL

Present: Leslie, Martinez, Yazquez, Maldonado, Tucker, McCormack, and Veiar

Absent: None

2. PUBLIC COMMENTS
None.

3. CONSENT CALENDAR
All matters listed under the Consent Calendar are considered to be routine by the Planning Commission and will be enacted by one motion. There will be no separate discussion of said items unless members of the Planning Commission, staff or the public request specific items removed from the Consent Calendar for separate action.

3.1. Approval of meeting minutes of the City of Orange Planning Commission Regular Meeting held on January 20,2025.

ACTION: Approved minutes as presented.

Approval of the Consent Calendar
A motion was made by Commissioner Tucker, seconded by Commissioner Maldonado to approve the Consent Calendar. The motion carried by the following vote:

Aves: Leslie, Simpson, Martinez, Yazquez, Maldonado, Tucker, McCormack, and Veiar Noes: None

Absent: None

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637
Planning Commission Minutes February 20,2025

4. COMMISSION BUSINESS

4.1. Selection of Planning Commission Officers
A motion was made by Chair Vazquez, seconded by Commissioner Martinez to nominate Commissioner Vejar to serve as Chair for a one-year term effective February 21, 2025. The motion carried by the following vote:

Aves: Martinez, Veiar, Maldonado, Tucker, Mccormack, Leslie, and Yazquez Noes: None

Absent: None
A motion was made by Commissioner Martinez, seconded by Commissioner nominate Chair Vazquez to serve as Vice Chair for a one-year term effective 21,2025.

Leslie to
February
Chair Vazquez declined the nomination for Vice Chair
A substitute motion was made by Chair Vazquez, seconded by Commissioner ltilartinez to nominate Commissioner Leslie to serye as Vice Chair for a one-year term effective February 21 , 2025. fhe motion carried by the following vote:

Aves: Leslie, Simpson, Martinez, YazQuez, Maldonado, Tucker, McCormack, and Veiar Noes: None

Absent: None

5. PUBLIC HEARINGS

5.1. Public Hearing to consider a request by CDO Orange, LLC, dba Gulinary Dropout for a Type 47 ABC License (On-Sale General) at a proposed restaurant located at 191 N. Orange Street and finding of CEQA Exemption (Resolution No. PC 33-24).

Chair Vazquez opened the public hearing 5:50 p.m.

Public Soeakers:

The following spoke in opposition of the project:

Diana Zdenk, Craig Enberg, Guy Hinrichs, Brian Lochrie' Kathy Bruner and Robert Boice
The following spoke in favor of the project: Leezie Kim Chair Vazquez closed the public hearing at 6:26 p.m
Chair Vazquez re-opened the public hearing at 6i42 p.m. to allow the applicant to speak.

Chair Vazquez closed the public hearing at 6:43 p.m.

A motion was made by Commissioner Maldonado, seconded by Commissioner Leslie, to:

Adopt Resolution No. PC 33-24 with the following modifications to proposed conditions:

Condition 8 shall read "The use of
construction shall remain consistent
the business is considered a restaurant
with approved building shell entitlements
lnterior
(MNSP

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638
Planning Commission Minutes Febtuary 20,2025
No. 1066-22, DRC No. 5056-22, APP No. 0557 -22, and Resolution No. PC 05-22). No new interior conslruction resulting in a change to the floor plan will occur unless a revised floor plan is approved by the Community Development Department. None of the floor area will be designated for dancing or live entertainment unless a subsequent CUP is approved by the Planning Commission-
Condition 13 shall read "The business shall operate Sunday through Thursday from 7:00 a.m. to 10:00 p.m. and Fridays and Saturdays from 7:00 a.m, to 11:00 p.m. These hours do not restrict employees from being on lhe premises before opening for preparations and deliveries or after close for clean-up. Clean-up may not be conducted by patrons
Condition 25 shall read "The outdoor patio area shall be divided into two sections: a North Patio dining section and a West Patio dining section- Everyday use of the North Patio shall be from 10:00 a.m. to 8100 p.m. with no new customers seated after 7:00 p.m. The West Patio shall be open Sunday through Thursday from 7:00 a.m. to 10:00 p.m. with no new customers seated after 9:00 pm. The West Patio shall be open Friday and Saturday from 7:00 a.m. to 11:00 p.m. with no new customers seated after 10:00 p.m.

Condition 26 is eliminated.

The motion carried by the following vote:

Aves: Veiar, lValdonado, Leslie, and Yazquez
Noes: lvlartinez, Tucker, and lt/cCormack

Absent: None

5.2. Public Hearing to consider a request to allow the sale of beer and wine for on-site consumption at a restaurant located at 765The City Drive South #130 and finding of CEQA Exemption (Resolution No. PC 01-25).

Chair Vazquez opened the public hearing at 7:16 p.m.

Public Speakers:

The following spoke on behalf of the project:

Hiro lgarashi from HiroNori Craft Ramen, Applicant
Chair Vazquez closed the public hearing at7:17 p.m.

A motion was made by Commissioner Tucker, seconded by Commissioner lvcCormack to:

1. Adopt Planning Commission Resolution No. PC 01-25. A Resolution of the Planning Commission of the City of Orange approving Conditional Use Permit No. 3232, allowing the sale of beer and wine for on-site consumption in conjunction with a State of California Department of Alcoholic Beverage Control Type 41 License (On-Sale Beer and Wine - Eating Place) at a restaurant located at 765 The City Drive South #130.

2. Find the proposed project exempt from the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15301 (Class 1 - Existing Facilities).

Page 3 of 4 ends

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Planning Commission Minutes February 20,2025
The motion carried by the following vote:

Aves: Martinez, Veiar, Maldonado, Tucker, Mccormack, Leslie, and Vazquez Noes: None

Absent: None

6. ADJOURNMENT
There being no further business, the meeting was adjourned at 7:19 p.m.

The next
2025 at
Califo
Regular Planning Commission Meeting will be
5:30 p.m., in the Council Chamber, 300 E.
92866.
held on Monday, March 17
Chapman Avenue, Orange,
Anna Pehoushek. FAICP
Assistant Community Development Director

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640
1 APPLICATION TO THE PLANNING DIVISION FOR CONDITIONAL USE PERMIT–

ALCOHOLIC BEVERAGE SERVICE
APPLICANT: CDO ORANGE LLC
PREMISES: 191 N ORANGE ST, ORANGE, CA 92866
REFERENCE: PER OCMC 17.10.030-D, A CONDITIONAL USE PERMIT TO

ALLOW THE SALE AND DISPENSING OF A FULL LINE OF

ALCOHOLIC BEVERAGES FOR ON-PREMISES AND OFF -

PREMISES CONSUMPTION IN CONJUNCTION WITH A FULL-
SERVICE RESTAURANT WITH 6,040 SQUARE FEET OF
INTERIOR SPACE AND 2,515 SQUARE FEET OF PATIO SPACE
LOCATED IN THE OTMU-15 ZONE.

Project Description
CDO Orange LLC, dba Culinary Dropout (the “Restaurant”), requests a Conditional Use Permit (“CUP”) for the sale of a full line of alcoholic beverages for on -premises and off -premises consumption under a Department of Alcoholic Beverage Control (“ABC”) Type -47 license in conjunction with a full-service restaurant with 6,040 square feet of interior space and 2,515 square feet of patio space located at 191 N. Orange St, Orange, CA 92866. Hours of operation will be Monday through Thursday from 11am to 10pm, Friday from 11am to 12am, Saturday from 10am to 12am, and Sunday from 10am to 9pm.

Culinary Dropout is an upscale neighborhood restaurant . The Restaurant’s menu consists of a unique take on classic items including house-made pretzels, soups, salads, burgers and sandwiches, ribs, fish and chips, roasted salmon, and a variety of appetizers. As an accompaniment to the food items, the Restaurant intends to offer a variety of alcoholic beverages including beer, wine, and craft cocktails.

The Restaurant site includes two buildings and a parking lot. The building located along the eastern boundary is an existing church, which will continue to operate. The Restaurant will be located in a portion of the adjacent building along the northern boundary. The other areas within this building that are not being occupied by the Restaurant will continue to be used for church operations. There are several parking spaces to the West of the building, and a larger shared parking lot located to the East across N Grand Street. While there will be interior and exterior improvements to the building, the project’s size, height, and operations will be consistent with the surrounding neighborhood, adding to the character and charm of the area.

The Restaurant will have 201 seats in the indoor dining area and 54 seats in the outdoor dining area, totaling 255 seats. The Restaurant intends to employ approximately 30 people per shift .

Managers and employees will regularly monitor both the indoor and outdoor dining area s to observe alcohol consumption. To ensure that alcoholic beverages are served and consumed in a responsible manner, all employees serving alcoholic beverages will undergo responsible beverage service training in accordance with ABC regulations. This training will focus on, among other things, responsible alcoholic beverage service and recognizing visible signs of intoxication . In 641
2 addition, e mployees will be trained through courses that have been developed and refined by Culinary Dropout and its parent corporation over the past 20 years.

The Restaurant is located on N orth Orange Street, one block from the historic Glassell Street in the OTMU-15 Zone. The proposed use as a neighborhood restaurant is appropriate for this mixed- use zone, adding to the diversification of commercial activities in the area. Culinary Dropout is compatible with the adjacent properties, which consist of commercial and residential uses. The commercial uses include antique stores, cafes, restaurants, bakeries , and other retail shops.

Although there are other licensed restaurants in the area, the Restaurant will offer a unique menu and atmosphere that will differ from other restaurants in the area. Allowing the sale of alcoholic beverages at the Restaurant will provide a benefit to patrons of the Restaurant because they will be able to enjoy alcoholic beverages as a complement to their meals.

The nearest residences to the Restaurant are located across Maple Avenue. Nearby residents are accustomed to restaurants of this nature in the surrounding area and they will benefit from the convenience of the Restaurant within walking distance of their residences. The nearest residential units are buffered by Maple Avenue and N Grand Street . The activity that occurs within the Restaurant will be self-contained, thus shielding nearby residential uses from noise impacts. The proposed hours of operation are reasonable, and the Rest aurant will operate in such a way that it does not attract crime or other undesirable activity. The Company responsibly operates other restaurants with liquor licenses throughout the State, and it will operate this location with the same level of professionalism and commitment to the welfare of the neighborhood.

The approval of the CU P will not adversely affect the economic welfare of the community . The Restaurant is anticipated to positively impact the value of nearby properties and improve the economic vitality of the area via increases in taxable revenue and local employment . Employees under 21 will be utilized for work in food production and service positions. Culinary Dropout will generate an increase in tax revenue with the inclusion of alcoholic beverage sales. Ample lighting, security, and supervision will also be provided to ensure that there will be no negative impact on the nearby residents and businesses . Therefore, the proposed alcohol sales will not be materially detrimental to the character of the neighborhood.
642
VAN
E. MAPLE AVE
N. ORANGE ST.

N. GRAND ST.
14 23
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60.00°
(E) FELLOWSHIP HALL(N.A.P.)
(E) PRE-SCHOOL(N.A.P.)
(E) SANCTUARY(N.A.P.)
(E) SHAREDPARKING LOT
(E) CHAPEL(N.A.P.)
(E) KID'S PLAY AREA(N.A.P.)
(E)PLAZA(N.A.P.)
(E) TRASHENCLOSURE
(E) 2-STORY BLDG.FIRST FLOOR: 9,637 S.F. + 1,294 S.F. = 10,931 S.F.SECOND FLOOR: 10,020 S.F.TOTAL:20,951 S.F. (GBA)CONSTRUCTION TYPE: V-B OCCUPANCY GROUP:A-2 / BFULLY SPRINKLERED BUILDING BLDG. EXPANSION1,294 S.F.

SEE SHEETA1.1 FOR PARTIALSITE PLAN
191 N. ORANGE ST.ORANGE, CA 92866
Project Number:
©2022 Architects Orange, LLP dba AO These plans are copyright protected. Under such protection unauthorized use is not permitted. These plans shall not be reproduced or used without written permission by AO.

Plan Check Number:

SEAL
v6.6

CONSULTANT
191 N. ORANGE ST.
fredtMay/15/2023 11:01 AMborder last saved:by:
2020-072- DD SET 06-03-2022PLAN CHECK SUBMITTAL 05-31-2023 .

PLANNORTH
1 OVERALL SITE PLAN1/16" = 1'-0"
fredtMay/15/2023 11:01 AMdwg last saved:by:

S H E E T
sheet plotted:drawing file name:May/31/2023 @ 10:18 PMp:\2020-072 c & c develop - first presbyterian church\cd\0072-a1.0 overall site plan.dwgA1.0OVERALL SITE PLAN GENERAL NOTES1.REFER TO CIVIL PLANS FOR SITE DIMENSIONS, GRADING, PAVING, CONCRETE CURBS, DRAINAGE ANDHORIZONTAL CONTROLS.2.REFER TO LANDSCAPE DRAWINGS FOR HARDSCAPE, PLANTING, IRRIGATION, FINE GRADING ANDSOILS PREPARATION.3.REFER TO GEOTECHNICAL REPORT FOR INFORMATION REGARDING GRADING, BEARING VALUES,COMPACTION, PAVING SECTIONS, CONCRETE MIX DESIGN AND SOIL AMMENDMENT INFORMATION.4.VERIFY THAT ALL GRADES ON SITE COMPLY WITH REQUIREMENTS FOR ACCESSIBILITY AS SHOWN ONALL ARCHITECTURAL AND CIVIL PLANS PRIOR TO CONSTRUCTION.5.VERIFY THAT ALL CLEARANCES ON SITE COMPLY WITH REQUIREMENTS FOR ACCESSIBILITY ASSHOWN ON ALL ARCHITECTURAL AND CIVIL PLANS PRIOR TO CONSTRUCTION.6.ALL PARKING LOT STRIPING ARE TO BE PAINTED PER CITY STANDARDS, INCLUDING PAINTED ACCESSIBLE PARKING SYMBOLS, ACCESS AISLES, ACCESSIBLE PATH CROSSWALK (WHERE OCCURS),STOP SIGN AND DIRECTIONAL ARROW MARKINGS SHALL HAVE A MINIMUM OF TWO COATS OF PAINT: BASE COAT - COLOR YELLOW TOP COAT - COLOR WHITE / BLUE PER LOCAL CODES7.ALL PROPERTY LINES, EASEMENTS AND BUILDINGS, BOTH EXISTING AND PROPOSED, ARE TO BEVERIFED WITH CIVIL PLANS.8.CONTRACTOR SHALL VERIFY ALL INFORMATION CONTAINED ON THIS DRAWING WITH CIVIL DRAWINGS.CONTACT ARCHITECT IF ANY DISPREPANCIES EXIST.9.REFER TO ELECTRICAL PLANS FOR SITE SIGNAGE POWER AND IN-GROUND LIGHTS AT LANDSCAPEPLANTING AREAS AND TREE LIGHTS.10.NO WORK SHALL BE PERFORMED IN THE PUBLIC RIGHT OF WAY WITHOUT FIRST OBTAINING A PERMITFROM THE CITY OF ORANGE ENGINEERING DIVISION. ALL WORK SHALL BE TO STANDARDSPECIFICATIONS. 02'8'16'24'4'32' 116"
SITE SUMMARYPARCEL SIZE: ±21,908 SFPROPOSED FAR:0.95 BUILDING AREABASEMENT: 0 SFFIRST FLOOR:±10,931 SFSECOND FLOOR: ±10,020 SFTOTAL:±20,951 SFPROPOSED PARKINGPARKING SPACES:4 STALLSACCESSIBLE SPACES:2 STALLSSHARED PARKING LOT:68 STALLS (EXISTING OFF-SITE)ACCESSIBLE SPACES:3 STALLS (EXISTING OFF-SITE)BICYCLE PARKING SPACE REQUIRED:SHORT TERM: 1 (5%) LONG-TERM:0 (NOT ADDING PRKG)BICYCLE PARKING SPACE PROVIDED:SHORT TERM: 3LONG-TERM:0 DD SET 06-03-2022PLAN CHECK SUBMITTAL 05-31-2023 1ST CITY SUBMITTAL: 05/31/2023
643
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1 2 3 4 5 61.2 3.1 3.8
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09 EMPLOYEE RESTROOM
10 MEN'S RESTROOM
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03 COOLER
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07 PRIVATE DINING ROOM
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All drawings and written material appearing herein constitute the original and unpublished work of the architect and the same may not be duplicated, used, or disclosed without the written consent of the architect © Field Paoli
SHEET NO.

JOB NO.

CHECKED BY

DRAWN BY
SCALE
10/28/2024 5:44:24 PM
3/16" = 1'-0"
A130

CONSTRUCTION DOCUMENT
2319.10
Designer
Checker

FIXTURE FLOOR PLAN

CULINARY DROPOUT -
ORANGE
191 N. ORANGE ST. SUITE 100
ORANGE, CA 92866

TENANT IMPROVEMENT
3/16" = 1' -0" A130
1 LEVEL 1 - FIXTURE PLAN
LEGEND

KEYNOTES

SHEET NOTES

1.3 STEEL COLUMN, SSD
NO. DESCRIPTION DATE
PERMIT SUBMITTAL 02/06/2024
1 PLAN CHECK RESPONSE 07/23/2024
2 PLAN CHECK RESPONSE 10/25/2024
644
645
Agenda Item
City Council
Item #: 10.1. 4/8/2025 File #: 25-0198
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Memorandum of Agreement between the City of Orange and the Mabury Ranch Homeowner’s Association for tree maintenance. (Continued from March 11, 2025)

2. SUMMARY
This item is continued from the March 11, 2025, City Council meeting. The City of Orange and the Mabury Ranch Homeowner’sAssociation recognize the importance of maintaining trees within the Mabury Ranch community public right of way for the safety, aesthetic, and environmental benefits it provides. Staff is recommending the approval of a memorandum of agreement with MRHOA for tree maintenance at an initial cost of $99,000, and an ongoing tree maintenance cost of $5,000 annually.

3. RECOMMENDED ACTION
Approve the Memorandum of Agreement with Mabury Ranch Homeowner’s Association for tree maintenance at an initial cost of $99,000, and an ongoing tree maintenance cost of $5,000 annually.

4. FISCAL IMPACT
Upon approval of the appropriation, the initial expense for this Memorandum of Agreement for $99,000 will utilize one-time salary savings, with an additional ongoing annual cost of $5,000 to be funded through General Fund.

5. STRATEGIC PLAN GOALS
Goal 5: Improve Infrastructure, Mobility, and Technology Objective 5.9: Identify costs and funding associated with maintaining new amenities

6. DISCUSSION AND BACKGROUND
This item is continued from the March 11, 2025, meeting. This agreement has been approved by the Mabury Ranch Homeowner’sAssociation (MRHOA) on March 25, 2025. Under the agreement, the City would assume maintenance responsibilities for the trees within the public right-of-way and liability after an initial two-year indemnification period provided by MRHOA. As a follow-up requested by the City Council, a detailed City arborist report for all Canary Island Pine trees along Serrano Ave. and Cannon Ave. was prepared.

In summary, 52 Pine trees out of 61 Pine trees on Serrano Ave. are planted within a 4 feet wide planter without adequate soil volume and are planted too close to private walls. These trees are recommended for removal. Five trees have defects relating to inadequate spacing and/or they are damaging adjacent infrastructure. These trees are also recommended for removal. Finally, 4 of the City of Orange Printed on 4/3/2025Page 1 of 3
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Item #: 10.1. 4/8/2025 File #: 25-0198
damaging adjacent infrastructure. These trees are also recommended for removal. Finally, 4 of the 61 Pine trees could be retained, however, it would require the removal of up to 3 Crape Myrtle trees that are adjacent and conflicting with the growth of the Pine trees.

The 22 pine trees along Cannon Avenue have no substantial defects. They have comparatively far more soil volume and are further away from private walls and trees.

In conclusion, staff is recommending all 61 Canary Island Pine trees along Serrano to be removed as part of this agreement. The 22 pine trees along Cannon will be retained with an initial prune.

Below is the summary of all 226 trees as part of this agreement:

Location Canary
Island
Pines
Eucalyptus Elms Crape
Myrtle
Liquid
Amber
Braford
Pears
Total RemovalTotal Initial Pruning
Cannon St. 22 6 28
Serrano Ave. 61 10 13 72 13
Mt.

Mckindley
Blvd.
22 5 22 5
Yellowstone
Blvd.
21 21 2 21 23
Orange Park
Blvd.
5 22 9 5 31
Taft
Extension
7 7
Total 126 100
The removal cost is estimated at $80,000 for 126 trees, including Canary Island Pines and Eucalyptus trees. The remaining 100 trees will require a special trim per the City Arborist’sdirection for an estimated cost of $19,000. Due to the existing landscape and surrounding infrastructure, replanting options are limited, however, staff will endeavor to replace trees where suitable within our existing tree planning program.

By approving this agreement, MRHOA agrees to indemnify the City from all liability arising out of and associated with those trees that used to be maintained by MRHOA as identified in the agreement for a period of two years. In addition, MRHOA will reimburse the City an amount not to exceed $16,000 or the cost of the initial pruning of the 100 trees.

MRHOA has an interest in the replanting of trees in and adjacent to the Mabury Ranch community.

MRHOA will reimburse the City up to $5,000 in 2025 and another additional $5,000 in 2026 for replanting. Any trees planted will remain the maintenance obligation of the City.

7. ATTACHMENTS
· Memorandum of Agreement
· City Arborist Report
City of Orange Printed on 4/3/2025Page 2 of 3
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Item #: 10.1. 4/8/2025 File #: 25-0198
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648
Agenda Item
City Council
Item #: 10.1. 4/8/2025 File #: 25-0198
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Christopher Cash, Public Works Director

1. SUBJECT
Memorandum of Agreement between the City of Orange and the Mabury Ranch Homeowner’s Association for tree maintenance. (Continued from March 11, 2025)

2. SUMMARY
This item is continued from the March 11, 2025, City Council meeting. The City of Orange and the Mabury Ranch Homeowner’sAssociation recognize the importance of maintaining trees within the Mabury Ranch community public right of way for the safety, aesthetic, and environmental benefits it provides. Staff is recommending the approval of a memorandum of agreement with MRHOA for tree maintenance at an initial cost of $99,000, and an ongoing tree maintenance cost of $5,000 annually.

3. RECOMMENDED ACTION
Approve the Memorandum of Agreement with Mabury Ranch Homeowner’s Association for tree maintenance at an initial cost of $99,000, and an ongoing tree maintenance cost of $5,000 annually.

4. FISCAL IMPACT
Upon approval of the appropriation, the initial expense for this Memorandum of Agreement for $99,000 will utilize one-time salary savings, with an additional ongoing annual cost of $5,000 to be funded through General Fund.

5. STRATEGIC PLAN GOALS
Goal 5: Improve Infrastructure, Mobility, and Technology Objective 5.9: Identify costs and funding associated with maintaining new amenities

6. DISCUSSION AND BACKGROUND
This item is continued from the March 11, 2025, meeting. This agreement has been approved by the Mabury Ranch Homeowner’sAssociation (MRHOA) on March 25, 2025. Under the agreement, the City would assume maintenance responsibilities for the trees within the public right-of-way and liability after an initial two-year indemnification period provided by MRHOA. As a follow-up requested by the City Council, a detailed City arborist report for all Canary Island Pine trees along Serrano Ave. and Cannon Ave. was prepared.

In summary, 52 Pine trees out of 61 Pine trees on Serrano Ave. are planted within a 4 feet wide planter without adequate soil volume and are planted too close to private walls. These trees are recommended for removal. Five trees have defects relating to inadequate spacing and/or they are damaging adjacent infrastructure. These trees are also recommended for removal. Finally, 4 of the City of Orange Printed on 4/3/2025Page 1 of 3
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Item #: 10.1. 4/8/2025 File #: 25-0198
damaging adjacent infrastructure. These trees are also recommended for removal. Finally, 4 of the 61 Pine trees could be retained, however, it would require the removal of up to 3 Crape Myrtle trees that are adjacent and conflicting with the growth of the Pine trees.

The 22 pine trees along Cannon Avenue have no substantial defects. They have comparatively far more soil volume and are further away from private walls and trees.

In conclusion, staff is recommending all 61 Canary Island Pine trees along Serrano to be removed as part of this agreement. The 22 pine trees along Cannon will be retained with an initial prune.

Below is the summary of all 226 trees as part of this agreement:

Location Canary
Island
Pines
Eucalyptus Elms Crape
Myrtle
Liquid
Amber
Braford
Pears
Total RemovalTotal Initial Pruning
Cannon St. 22 6 28
Serrano Ave. 61 10 13 72 13
Mt.

Mckindley
Blvd.
22 5 22 5
Yellowstone
Blvd.
21 21 2 21 23
Orange Park
Blvd.
5 22 9 5 31
Taft
Extension
7 7
Total 126 100
The removal cost is estimated at $80,000 for 126 trees, including Canary Island Pines and Eucalyptus trees. The remaining 100 trees will require a special trim per the City Arborist’sdirection for an estimated cost of $19,000. Due to the existing landscape and surrounding infrastructure, replanting options are limited, however, staff will endeavor to replace trees where suitable within our existing tree planning program.

By approving this agreement, MRHOA agrees to indemnify the City from all liability arising out of and associated with those trees that used to be maintained by MRHOA as identified in the agreement for a period of two years. In addition, MRHOA will reimburse the City an amount not to exceed $16,000 or the cost of the initial pruning of the 100 trees.

MRHOA has an interest in the replanting of trees in and adjacent to the Mabury Ranch community.

MRHOA will reimburse the City up to $5,000 in 2025 and another additional $5,000 in 2026 for replanting. Any trees planted will remain the maintenance obligation of the City.

7. ATTACHMENTS
· Memorandum of Agreement
· City Arborist Report
City of Orange Printed on 4/3/2025Page 2 of 3
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Item #: 10.1. 4/8/2025 File #: 25-0198
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657
March 25, 2025
Suitability of AdopƟng and Retaining 61 Canary Island Pine Trees along Serrano Blvd, and 22 Canary Island Pine Trees along Cannon St.

Prepared by:

Micah Jean – City of Orange Tree Services Coordinator
ISA Board CerƟfied Master Arborist WE-9971BM
ISA Tree Risk Assessment Qualified | ISA CerƟfied Urban Forest Professional Prepared for:

Chris Cash – City of Orange Director of Public Works
Background:

In August 2023, I provided a summary report of condiƟons regarding the suitability of adopƟng trees within the Right of Way adjacent to Mabury Ranch HOA. The report primarily served as a broad overview to establish esƟmated iniƟal and future maintenance costs. Future liability concerns due to observable condiƟons was a determining factor in anƟcipated costs.

A thorough inspecƟon of condiƟons was performed in March, 2025. This document serves to provide addiƟonal informaƟon on the 61 Canary Island Pine trees along Serrano Blvd, the 22 Canary Island Pines on Cannon St, and my recommendaƟon to remove the 61 trees on Serrano Ave, if adopted as City responsibility. This document is not intended to provide every observaƟon or potenƟal factor of concern, relaƟng to current condiƟons, defects, and likely future liability of these trees.

Method:

To determine the likelihood of future liability issues, and compaƟbility as City trees: trees were assessed for species characterisƟcs, immediate hazard, tree structural integrity defects, site condiƟons, and observed current infrastructure damage.

Tree Species CharacterisƟcs:

Canary Island Pine is the largest pine species naƟve to the Old World, with recorded height and width of 196’ tall and 105” DBH.

Mature trees are commonly 80-120’tall, with trunk widths 35-50” DBH. Canopy widths are commonly 20-35’.

Specimens in the naƟve range are reported to live over 800 years. In California, anƟcipated longevity is 100-200 years.

On a Low / Moderate / High scale for root damage potenƟal, Canary Island Pine is rated as Moderate.

Canary Island Pine has a generally deep root system. PrevenƟng root related infrastructuredamage relies upon correct site suitability and placement.
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PlanƟng Site CondiƟons:
 On Serrano Ave:
52 trees are located within 11 planters, behind the sidewalk and abuƫng the private HOA wall.

Planters are 4’ wide, with some minor variance in width. Trees within planters are spaced an average of 17’ apart, with some outliers. Trees in planters were measured to be between 7” and 29” to the wall, and from 9” to 28” to the sidewalk.
9 trees are located east of the planters, with distances of up to 7’-9’ to HOA wall, and 26” to 68” to sidewalk.
 On Cannon St:
22 trees are located behind the sidewalk, adjacent to an open trail. Trees are generally spaced between 17’ to 20’ apart. Trees measured between7’to 8’to HOA wall, and 30” to 45” to sidewalk (with 1 excepƟon).

CompeƟƟon with Private Trees:

Many trees were observed to be in current conflict with private property tree canopies, and other trees are anƟcipated to have future conflicts with private trees, as the trees mature.  On Serrano Ave:
22 trees were observed to have canopies within 10’ of private trees. 11 trees were observed to be in contact with private trees. 23 tree trunks were observed to have less than 30’ proximity to private tree trunks.
 On Cannon St:
8 trees were observed to have canopies within 10’ of private trees. 4 trees were observed to be in contact with private trees. 11 tree trunks were observed to have less than 30’ proximity to private tree trunks.

Tree CondiƟons:
 On Serrano Ave:

Current tree size is generally small for the species, with DBH measurements between 5” and 20”. The majority of trees are approximately 8”-12” DBH. The 61 trees have the capacity to grow far larger than their current size. Defects in the main stem or branch structure were observed in many (15) trees. Of 15 trees with observed structural defects, 5 consƟtuted severe defects that currently warrant tree removal.

Of the 9 trees to the east and outside of the 4’ planters:
3 trees are sƟll staked, and staked improperly with a splint, which weakens trunk development. 2 addiƟonal trees were observed with poor structure.
4 trees have observable adjacent infrastructure damage. 1 tree trunk measured 9’ to light pole.
3 trees have insufficient distance to 1 or more adjacent Crape Myrtle trees.  On Cannon St:

DBH measurements range from 10”-27”. The majority of trees are approximately 17”-20”. The 22 trees are anƟcipated to grow larger than their current size. 5 trees were improperly pruned to remove the majority of branches on the East facing side. 1 tree was impacted by an embedded 3”metal pole. No other substanƟal defects were observed.
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Current Infrastructure Damage:
 On Serrano Ave:
41/61 tree locaƟons observed to have current adjacent infrastructure damage. 27 locaƟons observed to have damage to public infrastructure. 28 locaƟons observed to have damage to adjacent private wall.
 On Cannon St:
13/22 tree locaƟons observed to have current adjacent infrastructure damage. 8 locaƟons observed to have damage to public infrastructure. 7 locaƟons observed to have damage to adjacent private wall.

PotenƟal for Future Damage and Liability:

Proper planning for tree planƟng is essenƟal to have healthy, long lived trees that provide many benefits, while limiƟng liability over the lifeƟme of trees.

When determining suitable tree placement for a site, an important factor is the space available for canopy, trunk, and root growth. Considering soil volume is a necessary component of site suitability.

Trees require adequate oxygen-rich soil space for their roots, to anchor and provide the tree water and nutrients. When trees are surrounded by hardscape, their available root space isgreatly diminished and made more inhospitable due to soil compacƟon, and other factors. When trees are placed close together, this also reduces soil volume available per tree, and the trees compete for this space. These condiƟons can create adverse effects, such as: stunted growth, poor health, poor anchorage, abnormal or raised root crown (mounding of the soil around trees), suscepƟbility to spread of pests and disease, increased likelihood of root conflicts with infrastructure, and increased likelihood of tree failure.

Generally, a “good”soil volume for a large tree is 1000 cu. Ō. For reference, the County of San Diego requires 600 cu. Ō. for small trees, 1000 cu. Ō. for medium size trees, and 1500 cu. Ō. for large trees (County of San Diego BMP Design Manual, SecƟon K, pg 32). The City of Orange Master Street Tree Plan (1999) establishes 8’ x 8’ as a minimum planƟng area for the species. If the root zone is limited to an 8’ x 8’ square, the soil volume is esƟmated as 192 cu. Ō.  On Serrano Ave:
52 trees within the 4’ planters do not meet the minimum requirement of an 8’ x 8’ square, and also do not have adequate soil volume. Trees within the 4’ planter are very likely to cause both public and private infrastructure damage. It is very likely that the future replacement of surrounding infrastructure would require the removal of trees.
 On Cannon St:
22 trees have comparaƟvely far more soil volume, and root space. Trees are located further from the private wall, as well as sidewalk. Trees are inadequately spaced, and in too close proximity to private trees. Due to the current proximity of the privatewall and sidewalk, there is opportunity to follow the City standard operaƟng procedure for root miƟgaƟons. There is potenƟal for selecƟve root removal to allow for retenƟon of trees, at the Ɵme of potenƟal future sidewalk replacement.

Conclusion:

The Canary Island Pine trees of concern are generally not observed to be diseased, though there are a range of minor to major defects on some trees. Many trees have adjacent infrastructure damage present. Many trees have canopy conflicts with private trees.  On Serrano Ave:

The mature size of the species is highly non-compaƟble with the proximity to the HOA wall, as well as the undersized planter where they reside. The current size of the pines is considered small/ immature for the species, and it is anƟcipated that they would grow much larger . A mature Canary Island Pine 3 660
has the potenƟal trunk size over 4’ in diameter,as wide as the enƟre planter . As trees mature, their trunk flare and root crown (the widening at the base of the tree, where the trunk connects to the roots) oŌen become more pronounced, which has a very high likelihood of damage to adjacent infrastructure when planted in inadequate space.

Due to the inadequate space, the likelihood of any root miƟgaƟons performed being successful without undermining the stability of the trees is unlikely. When making determinaƟons to the suitability of selecƟve root removal for root miƟgaƟons, proximity of cuts to the trunk is a major consideraƟon. It would be very likely that sidewalk replacement would result in observaƟons of root caused damage, and required root miƟgaƟons would result in the removal of trees.

It is very likely that 52 trees planted within the 4’ planter will present with future liability issues. The likelihood of future issues greatly exceeds the potenƟal liability of typical new City tree locaƟons, due to the combinaƟon of small planter size, proximity to private infrastructure, and species.

The 9 trees not located in 4’ planters are assessed to havecomparaƟvely lower likelihood of damage related to soil volume, and distance to the private wall. The 9 trees were observed to have defects, substanƟally inadequate spacing, and current adjacent infrastructure damage. 61/61 Canary Island Pine Trees located on Serrano Ave are recommended for removal, if adopted as City responsibility.
 On Cannon St:

There is a comparaƟvely far greater space between infrastructure and trees, on Cannon St. Due to more available space, there is potenƟal to follow normal root assessment and miƟgaƟon procedures during infrastructure repair .
22/22 Canary Island Pine Trees located on Cannon St are recommended for retenƟon, if adopted as City responsibility.
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Examples of Current Infrastructure Damage
28 tree locations observed to have current damage to adjacent private wall. 5 662
Examples of Current Infrastructure Damage
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Agenda Item
City Council
Item #: 10.2. 4/8/2025 File #: 25-0133
TO: Honorable Mayor and Members of the City Council
FROM: Tom Kisela, City Manager

1. SUBJECT
Agreement with the Orange International Street Fair, Inc. to produce the Treats in the Streets Autumn Festival.

2. SUMMARY
For several decades, the City of Orange produced the annual Treats in the Streets Autumn Festival on the Thursday before Halloween in the Old Towne Orange Plaza. On June 25, 2024, the City Council voted to cancel all City-sponsored events unless a non-profit organization sponsored and produced the event in its entirety. On February 20, 2025, the Orange International Street Fair, Inc. sent the City of Orange a letter of intent to assume responsibility for the Treats in the Streets Autumn Festival. The proposed agreement will authorize the Orange International Street Fair, Inc. to produce the Treats in the Streets Autumn Festival for three years.

3. RECOMMENDED ACTION
Approve the agreement with the Orange International Street Fair, Inc. to produce the Treats in the Streets Autumn Festival; and authorize the Mayor and City Clerk to execute on behalf of the City.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.

6. DISCUSSION AND BACKGROUND
For several decades, the City of Orange (City) organized and funded the annual Treats in the Streets Autumn Festival (Treats) in the Old Towne Orange Plaza (Plaza). As one of the City’s highly anticipated events, Treats consistently attracts thousands of Orange residents and visitors alike to the Plaza for a family-friendly Halloween event.

In considering the City’sstructural budget deficit, the Orange City Council voted to cancel all City- sponsored events (including Treats) on June 25, 2024. However, the City Council qualified the cancellation that events may continue should a non-profit organization assume responsibility to fund and produce the event.

On February 20, 2025, the Orange International Street Fair, Inc. (OISF) submitted a letter of intent (LOI) to assume responsibility for Treats and requested a three-year agreement to produce the event.

The City and OISF have developed a three-year production agreement similar to what the City utilizes with OISF for the annual Street Fair and Orange Plaza Rotary Club for the annual Car Show.

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Item #: 10.2. 4/8/2025 File #: 25-0133
The more significant provisions in the proposed agreement include:
· The City will secure cost recovery for actual costs to help produce the event. · OISF will submit a proposed staging layout map no fewer than 60 days prior to the event. · The Community and Library Services Director will annually review and approve Plaza Park’s usage during the event.
· In keeping with Treat’sfamily-friendly tradition, attendees may not wear grotesque masks or costumes depicting violence nor may attendees use simulated guns, knives, swords, hammers, chainsaws, clubs, etc. to the extent the item can be mistaken for a real weapon. · City will begin the Plaza closure at 12:00 p.m. the day of the event and will re-open the Plaza no later than 12:00 a.m.

Should the City Council approve the production agreement with OISF, representatives from the City and OISF will work together to prepare for this year’sTreats scheduled for October 30, 2025. Lastly, per the LOI, OISF does not intend to allow alcohol sales during the event.

7. ATTACHMENTS
· Agreement with the Orange International Street Fair, Inc. · Orange International Street Fair, Inc. Letter of Intent.

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Agenda Item
City Council
Item #: 10.2. 4/8/2025 File #: 25-0133
TO: Honorable Mayor and Members of the City Council
FROM: Tom Kisela, City Manager

1. SUBJECT
Agreement with the Orange International Street Fair, Inc. to produce the Treats in the Streets Autumn Festival.

2. SUMMARY
For several decades, the City of Orange produced the annual Treats in the Streets Autumn Festival on the Thursday before Halloween in the Old Towne Orange Plaza. On June 25, 2024, the City Council voted to cancel all City-sponsored events unless a non-profit organization sponsored and produced the event in its entirety. On February 20, 2025, the Orange International Street Fair, Inc. sent the City of Orange a letter of intent to assume responsibility for the Treats in the Streets Autumn Festival. The proposed agreement will authorize the Orange International Street Fair, Inc. to produce the Treats in the Streets Autumn Festival for three years.

3. RECOMMENDED ACTION
Approve the agreement with the Orange International Street Fair, Inc. to produce the Treats in the Streets Autumn Festival; and authorize the Mayor and City Clerk to execute on behalf of the City.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.

6. DISCUSSION AND BACKGROUND
For several decades, the City of Orange (City) organized and funded the annual Treats in the Streets Autumn Festival (Treats) in the Old Towne Orange Plaza (Plaza). As one of the City’s highly anticipated events, Treats consistently attracts thousands of Orange residents and visitors alike to the Plaza for a family-friendly Halloween event.

In considering the City’sstructural budget deficit, the Orange City Council voted to cancel all City- sponsored events (including Treats) on June 25, 2024. However, the City Council qualified the cancellation that events may continue should a non-profit organization assume responsibility to fund and produce the event.

On February 20, 2025, the Orange International Street Fair, Inc. (OISF) submitted a letter of intent (LOI) to assume responsibility for Treats and requested a three-year agreement to produce the event.

The City and OISF have developed a three-year production agreement similar to what the City utilizes with OISF for the annual Street Fair and Orange Plaza Rotary Club for the annual Car Show.

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Item #: 10.2. 4/8/2025 File #: 25-0133
The more significant provisions in the proposed agreement include:
· The City will secure cost recovery for actual costs to help produce the event. · OISF will submit a proposed staging layout map no fewer than 60 days prior to the event. · The Community and Library Services Director will annually review and approve Plaza Park’s usage during the event.
· In keeping with Treat’sfamily-friendly tradition, attendees may not wear grotesque masks or costumes depicting violence nor may attendees use simulated guns, knives, swords, hammers, chainsaws, clubs, etc. to the extent the item can be mistaken for a real weapon. · City will begin the Plaza closure at 12:00 p.m. the day of the event and will re-open the Plaza no later than 12:00 a.m.

Should the City Council approve the production agreement with OISF, representatives from the City and OISF will work together to prepare for this year’sTreats scheduled for October 30, 2025. Lastly, per the LOI, OISF does not intend to allow alcohol sales during the event.

7. ATTACHMENTS
· Agreement with the Orange International Street Fair, Inc. · Orange International Street Fair, Inc. Letter of Intent.

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1 AGREEMENT FOR PRODUCTION OF TREATS IN THE STREETS

This AGREEMENT FOR PRODUCTION OF TREATS IN THE STREETS
(“Agreement”) is made at Orange, California, on this _____ day of _____ _________, 202 5 (“Effective Date”) by and between the CITY OF ORANGE, a municipal corporation (“City”), and ORANGE INTERNATIONAL STREET FAIR, INC. , a California non -profit public benefit corporation, also known as OISF (“OISF”).

1. Term and Termination of Agreement.

A. This Agreement shall commence upon execution and shall terminate December 31, 2028, unless amended or sooner terminated as provided herein.

B. City, acting through its City Manager or designee, reserves the right to terminate this Agreement for any reason by providing a written notice of intent to terminate to OISF no fewer than 120 days prior to the commencement of the next Treats in the Streets. City shall not be liable for any claim of damages or lost profits relating to any such termination.

2. Location.

Treats in the Streets shall take place on those public streets and rights -of-way in the City generally described as the area of Chapman Avenue from the center line of Grand Street to the center line of Lemon Street; and Glassell Street from the center line of Almond Avenue to the center line of Maple Avenue, as more particularly identified in the map attached hereto and incorporated herein as Exhibit “A.”

3. Date and Times.

A. The Treats in the Streets shall take place on the following dates and times:

1) October 30, 2025 beginning at 4:00 p.m. – 7:00 p.m.

2) October 29, 2026 beginning at 4:00 p.m. – 7:00 p.m.

3) October 28, 2027 beginning at 4:00 p.m. - 7:00 p.m.

4) October 26, 2028 beginning at 4:00 p.m. - 7:00 p.m.

4. OISF Obligations.

A. Production of Treats in the Streets

1) OISF shall produce the Treats in the Streets during the day and times stated in Section 3.

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2 2) The “production of Treats in the Streets” means all aspects of the planning, coordination, and execution of said Treats in the Streets including, but not limited to: reviewing and approving applications for participants; preparing and distributing advertising; obtaining all licenses, permits (e.g., Orange County Health Care Agency) and other applicable governmental approvals; obtaining all insurance set forth in Section 7; and developing a budget and fee schedule.

3) OISF shall work with designated City representatives for business involving the Treats in the Streets to ensure compliance with this Agreement.

B. Staging Layout.

1) The proposed staging layout map is contained in Exhibit “B.” Each year, no fewer than sixty (60) days prior to Treats in the Streets , OISF shall submit a detailed staging layout map showing the physical layout of the entertainment , food, and commercial booths, for approval by the Police Department, Fire Department, and Public Works Department.

2) All fire lanes, fire breaks, crosswalks, streets and alleyways shown on the approved plan shall remain free and clear of all objects, materials, vehicles, and other obstructions during set up, during the course of the event, and at break down of Treats in the Streets.

3) OISF shall not block or obstruct public sidewalks with tables, chairs, canopies or any other equipment preventing pedestrian circulation.

4) To the extent it is feasible, OISF shall not block pedestrian or delivery access to a merchant that is within or immediately adjacent to the event area.

5) The use of Plaza Park during this event will be reviewed on an annual basis.

At the discretion of the Community and Library Services Director, the historic fountain shall be enclosed and protected by fencing for the duration of the Treats in the Streets . The cost of such fence rental or other means to secure the historic fountain shall be the sole responsibility of OISF.

C. Site Inspection . No fewer than fifteen (15) days prior to the event, authorized representatives from City and OISF shall walk the footprint of Treats in the Streets to ensure safety standards.

D. Parking Lots. Excluding portions of the public parking lot on the west side of South Orange Street and u nless otherwise approved by the City Council, OISF agrees to leave public parking lots open for use by participants and the public during Treats in the Streets.

E. Sanitation.

1) Unless otherwise stated herein, OISF shall comply with all provisions of the Orange Municipal Code and all applicable state and federal mandates as they relate to all storm water issues, and as directed by City.

F. Entertainment. OISF shall furnish a complete entertainment schedule to the Police Department liaison a minimum of two (2) weeks prior to the Treats in the Streets. 676
3 G. Code of Conduct . OISF shall comply with and enforce the following guidelines related to its employees and volunteers, the general public, and all vendors within the Treats in the Streets footprint:

1) With the exception of ADA -recognized service animals, animals are not permitted.

2) Skateboards, roller skates, scooters, bikes, or any motorized or self - propelled device, other than wheelchairs, mobile scooters, and participant vehicles, for the purpose of personal motion are not permitted, unless pre-approved by City.

3) In keeping with the family -friendly nature of the event, attendees may not wear grotesque masks or costumes depicting violence or injury, including the use of simulated guns, knives, swords, hammers, chainsaws, clubs, etc. to the extent the item could be mistaken for a real weapon or instrument of violence.

4) Footwear and a shirt, or similar form of covering as otherwise approved by the City, must be worn at all times by participants and attendees.

5) Signs must be posted with the information in subsections 1), 2) and 3) above.

6) The Police Department has the right to approve or deny performers and both Police and Fire Departments have the right to stop live entertainment at their discretion based on conditions that may cause or create a hazardous situation to the public.

H. Equipment, Supplies, Costs.

1) OISF shall furnish all equipment and supplies reasonably necessary to carry out the purpose of this Agreement, except as otherwise provided herein and shall pay for all costs and expenses incurred for production of Treats in the Streets.

2) OISF shall reimburse City for all costs and expenses incurred by City in providing materials and services for Treats in the Streets , including public safety and other personnel.

a. The number of public safety personnel assigned is at the discretion of the Police Department and Fire Department. The City will notify OISF in writing when public safety personnel levels will exceed those utilized during the previous Treats in the Streets.

b. Materials and services may include costs incurred by City related to damage and cleanup of public and private property directly related to Treats in the Streets activities within the Treats in the Streets footprint as depicted in Exhibit “A.”

c. Reimbursement for said materials and services shall be due and payable within thirty (30) days of receipt of an itemized statement from City. 677
4 d. OISF will only be responsible for the actual costs incurred by City related to Treats in the Streets.

I. Maintenance and Inspection of Records . OISF shall maintain all records relating to this Agreement and the production of the Treats in the Streets for a minimum of three (3) years following the expiration or termination of the Agreement. All such records shall be available for inspection or review by an authorized representative of City within ten (10) days of written notice to OISF.

J. Communications and Contacts.

1) OISF shall designate an individual to serve as a public contact for any and all inquiries, including but not limited to complaints related to the production of the Treats in the Streets, and shall provide a list of contacts and phone numbers to City no fewer than thirty (30 ) days prior to commencement of the Treats in the Streets.

2) OISF will make reasonable efforts to engage with and educate downtown businesses regarding Treats in the Streets , footprint, hours, and any other Treats in the Streets logistics that may interfere with local business operations.

5. City Obligations.

A. City agrees that OISF shall have the sole and exclusive right to produce the Treats in the Streets.

B. City agrees to prepare the Treats in the Streets footprint to a mutually acceptable condition at the City’s expense, prior to commencement of Treats in the Streets which includes closing the Treats in the Streets footprint to vehicular traffic and temporarily suspending permit parking within the vicinity of the event area.

C. The City Manager’s Office shall designate a direct liaison with OISF as it pertains to the production, planning, and follow-up of the Treats in the Streets. The City Manager’s liaison shall serve as a public contact for any and all inquiries, including but not limited to complaints related to the production of Treats in the Streets. No fewer than thirty (30) days prior to Treats in the Streets , the City Manager’s liaison shall provide OISF with a list of contacts and phone numbers for each of the following departments: Public Works, Police, Fire, and City Manager’s Office.

D. City shall require any vendors or merchants within the Treats in the Streets footprint not otherwise participating in Treats in the Streets through the OISF approval process, to apply for and obtain a Special Event Permit from City. All such Special Event Permits must be submitted for review no later than thirty (30) days prior to Treats in the Streets.

E. City will encourage local businesses an d neighbors to report all clean up locations to City within forty-eight (48) hours of the closure of the Treats in the Streets. City will provide an itemized bill, including photos of the areas not cleaned, to OISF accordingly. 678
5 F. City shall provide OISF with a detailed break-down of the actual costs incurred by City for labor, material, and equipment related to the Treats in the Streets by January 15th.

G. City shall reopen all intersections in the Treats in the Street area to through traffic no later than 12:00 a.m.

6. Reserved.

7. Insurance.

A. If applicable, OISF shall carry workers’ compensation insurance as required by law for the protection of its employees during the progress of the work . OISF acknowledges that it is an independent contractor and not entitled to any worker's compensation benefits under any City program.

B. Throughout the duration of the event, OISF shall maintain the following minimum amount of comprehensive general liability insurance or commercial general liability insurance: the greater of (1) Two Million Dollars ($ 2,000,000) per occurrence with a Three Million Dollar ($3,000,000) aggregate; or (2) all the insurance coverage and/or limits carried by or available to OISF. Said insurance shall cover bodily injury, death and property damage and be written on an occurrence basis.

C. Any insurance proceeds in excess of or broader than the minimum required coverage and/or minimum required limits which are applicable to a given loss shall be available to City. No representation is made that the minimum insurance requirements of this Agreement are sufficient to cover the obligations of OISF under this Agreement.

D. Each policy of general liability shall provide that City, its officers, officials, agents, and employees are declared to be additional insureds under the terms of the policy, but only with respect to the event held by OISF under this Agreement. A policy endorsement to that effect shall be provided to City along with the certificate of insurance . In lieu of an endorsement, City will accept a copy of the policy(ies) which evidences that City is an additional insured as a contracting party. The minimum cove rage required by Subsection B, above, shall apply to City as an additional insured.

E. The insurance policies maintained by OISF shall be primary insurance and no insurance held or owned by City shall be called upon to cover any loss under the policy . OISF will determine its own needs in procurement of insurance to cover liabilities other than as stated above.

F. Before OISF performs any work or prepares or delivers any materials, it shall furnish certificates of insurance and endorsements, as required by City, evidencing the aforementioned minimum insurance coverages on forms acceptable to City, which shall provide that the insurance in force will not be canceled or allowed to lapse without at least ten (10) days’ prior written notice to City.

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6 G. All insurance maintained by OISF shall be issued by companies admitted to conduct the pertinent line of insurance business in California.

H. OISF shall immediately notify City if any required insurance lapses or is otherwise modified and cease performance of this Agreement unless otherwise directed by City . In such a case, City may procure insurance or self -insure the risk and charge OISF for such costs and any and all damages resulting therefrom, by way of set-off from any sums owed OISF.

I. OISF agrees that in the event of loss due to any of the perils for which it has agreed to provide insurance, it shall look solely to its insurance for recovery. OISF hereby grants to City, on behalf of any insurer providing insurance to either OISF or City with respect to the services of OISF herein, a waiver of any right to subrogation which any such insurer may acquire against City by virtue of the payment of any loss under such insurance.

J. OISF shall include all OISF subcontractors, if any, and Treats in the Streets vendors as additional insureds under its policies or shall require that said subcontractors and OISF vendors maintain their own insurance consistent with the requirements stated herein.

8. Indemnity.

A. To the fullest extent permitted by law, OISF agrees to indemnify, defend and hold City, its City Council and each member thereof, and the officers, officials, agents and employees of City (collectively the “Indemnitees”) entirely harmless from all liability arising out of:

1) Any and all claims under worker’s compensation acts and other employee benefit acts with respect to OISF’s employees or subcontractor’s employees arising out of OISF’s work under this Agreement; and

2) Any claim, loss, injury to or death of persons or damage to property caused by any act, neglect, default, or omission other than a professional act or omission of OISF, or person, firm or corporation employed by OISF, either directly or by independent contract, including all damages due to loss or theft sustained by any person, firm or corporation including the Indemnitees, or any of them, arising out of, or in any way connected with the work or services which are the subject of this Agreement, includi ng injury or damage either on or off City’s property; but not for any loss, injury, death or damage caused by the active negligence or willful misconduct of City . OISF, at OISF’s own expense, cost and risk, shall indemnify any and all claims, actions, suits or other proceedings that may be brought or instituted against the Indemnitees on any such claim or liability covered by this Subsection, and shall pay or satisfy any judgment that may be rendered against the Indemnitees, or any of them, in any action, suit or other proceedings as a result of coverage under this Subsection.

B. Except for the Indemnitees, the indemnifications provided in this Agreement shall not be construed to extend any third party indemnification rights of any kind to any person or entity which is not a signatory to this Agreement.

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7 C. The indemnities set forth in this section shall survive any closing, rescission, or termination of this Agreement, and shall continue to be binding and in full force and effect in perpetuity with respect to OISF and its successors.

9. Standard Provisions.

A. Licenses. OISF represents that it and any subcontractors it may engage possess any and all licenses which are required under state or federal law to perform the work contemplated by this Agreement and that OISF and subcontractors, if any, shall maintain all appr opriate licenses, including a City of Orange business license, at its cost, during the performance of this Agreement.

B. Independent Contractor. At all times during the term of this Agreement, OISF shall be an independent contractor and not an employee of City . City shall have the right to control OISF only insofar as the result of OISF’s services rendered pursuant to this Agreement. City shall not have the right to control the means by which OISF accomplishes services rendered pursuant to this Agreement . OISF shall, at its sole cost and expense, furnish all facilities, materials and equipment which may be required for furnishing services pursuant to this Agreement. OISF shall be solely responsible for, and shall indemnify, defend and save City harmless from all matters relating to the payment of its subcontractors, agents and employees, including compliance with social security, withholding and all other wages, salaries, benefits, taxes, exactions, and regulations of any nature whatsoever . OISF acknowledges that OISF and any subcontractors, agents or employees employed by OISF shall not, under any circumstances, be considered employ ees of City, and that they shall not be entitled to any of the benefits or rights afforded employees of City, including, but not limited to, sick leave, vacation leave, holiday pay, Public Employees Retirement System benefits, or health, life, dental, long -term disability or workers' compensation insurance benefits.

C. OISF Not Agent . Except as City may specify in writing, OISF shall have no authority, express or implied, to act on behalf of City in any capacity whatsoever as an agent .

OISF shall have no authority, express or implied, to bind City to any obligation whatsoever.

D. Amendment. No amendment of this Agreement or its Exhibits shall be effective unless in writing, signed by OISF and City. City Manager is specifically authorized to execute amendments to this Agreement on behalf of City.

E. Assignment or Subcontracting. No assignment or subcontracting by OISF of any part of this Agreement shall be of any force or effect unless the assignment has had the prior written approval of City. City may terminate this Agreement rather than accept any proposed assignment or subcontracting. Such assignment or subcontracting may be approved by the City Manager or designee.

F. Equal Opportunity and Non -Discrimination. During the performance of this Agreement, OISF agrees as follows:

1) OISF shall not discriminate against any employee , applicant for employment, vendor or participant because of race, color, religion, sex, national origin, mental or physical disability, or any other basis prohibited by applicable law . OISF shall ensure that such 681
8 persons are treated without regard to their race, color, religion, sex, national origin, mental or physical disability, or any other basis prohibited by applicable law . OISF agrees to post in conspicuous places, available to such persons , a notice setting forth provisions of this non - discrimination clause.

2) OISF shall, in all solicitations and advertisements for employees placed by, or on behalf of OISF, state that all qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, mental or physical disability, or any other basis prohibited by applicable law.

3) OISF shall cause the foregoing paragraphs 1) and 2) to be inserted in all subcontracts for any work covered by this Agreement, provided that the foregoing provisions shall not apply to subcontracts for standard commercial supplies or raw materials.

G. Conflicts of Interest. OISF agrees that it shall not make, participate in the making, or in any way attempt to use its position as a contractor to influence any decision of City in which OISF knows or has reason to know that OISF, its officers, partners, or employees have a financial interest as defined in Section 87103 of the Government Code.

H. Compliance with all Laws/Immigration Laws.

1) OISF shall be knowledgeable of and comply with all local, state and federal laws which may apply to the performance of this Agreement.

2) OISF shall comply with all applicable Fire Department guidelines in effect January 1 st of any given year during which the Treats in the Streets is produced . Additional requirements may be added by the Fire Department as necessary, and at the Fire Department’s discretion no later than 30 days prior to the event. If there are any existing violations present by 4 p.m. the day of Treats in the Streets, the City may remove the non-compliant vendor(s) from Treats in the Streets, and/or prevent the violating party from participating in Treats in the Streets until all violations have been corrected.

3) OISF represents and warrants that OISF:

a. Has complied and shall at all times during the term of this Agreement comply, in all respects, with all immigration laws, regulations, statutes, rules, codes, and orders, including, without limitation, the Immigration Reform and Control Act of 1986 (IRCA); and

b. Has not and will not knowingly employ any individual to perform services under this Agreement who is ineligible to work in the United States or under the terms of this Agreement; and

c. Has properly maintained, and shall at all times during the term of this Agreement properly maintain, all related employment documentation records including, without limitation, the completion and maintenance of the Form I-9 for each of OISF’s employees; and
682
9 d. Has responded, and shall at all times during the term of this Agreement respond, in a timely fashion to any government inspection requests relating to immigration law compliance and/or Form I -9 compliance and/or worksite enforcement by the Department of Homeland Security, the Department of Labor, or the Social Security Administration.

4) OISF shall require all subcontractors to make the same representations and warranties as set forth in Subsection 3 above.

5) OISF shall, upon request of City, provide a list of all employees working under this Agreement and shall provide, to the reasonable satisfaction of City, verification that all such employees are eligible to work in the United States . All costs associated with such verification shall be borne by OISF. Once such request has been made, OISF may not change employees working under this Agreement without written notice to City, accompanied by the verification required herein for such employees.

6) OISF shall require all subcontractors to make the same verification as set forth in Subsection 5 above.

7) If OISF or subcontractor knowingly employs an employee providing work under this Agreement who is not authorized to work in the United States, and/or fails to follow federal laws to determine the status of such employee , that shall constitute a material breach of this Agreement and may be cause for immediate termination of this Agreement by City.

8) OISF agrees to indemnify and hold City, its officials, and employees harmless for, of and from any loss, including but not limited to fines, penalties and corrective measures, City may sustain by reason of the Contrator's failure to comply with said laws, rules and regulations in connection with the performance of this Agreement.

I. Governing Law and Venue. This Agreement shall be construed in accordance with and governed by the laws of the State of California and OISF agrees to submit to the jurisdiction of California courts . Venue for any dispute arising under this Agreement shall be in Orange County, California.

J. Integration and Amendment. This Agreement constitutes the entire agreement of the parties. No other agreement, oral or written, pertaining to the work to be performed under this Agreement shall be of any force or effect unless it is in writing and signed by both parties . The City Manager or designee is granted authority to execute any amendments to this agreement.

10. Notice.

Except as otherwise provided herein, all notices required under this Agreement shall be in writing and delivered personally, by e-mail, or by first class mail, postage prepaid, to each party at the address listed below. Either party may change the notice address by notifying the other party in writing. Notices shall be deemed received upon receipt of same or within 3 days of deposit in 683
10 the U.S. Mail, whichever is earlier. Notices sent by e-mail shall be deemed received on the date of the e-mail transmission.

“OISF” “CITY”

Orange International Street Fair City of Orange
112 East Chapman Avenue, Ste. G 300 E. Chapman Avenue Orange, CA 92866 Orange, CA 92866
Attn: Adam Feliz Attn: Lisa Tamburelli

Email: [email protected] Email: [email protected]

11. Counterparts.

This Agreement may be executed in one or more counterparts, each of which shall be deemed an original, but all of which together shall constitute one and the same instrument.

Signatures transmitted via facsimile and electronic mail shall have the same effect as original signatures.

[Remainder of page intentionally left blank; signatures on next page]

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11 IN WITNESS of this Agreement, the parties enter into this Agreement on the year and day first above written.

“OISF” “CITY”

ORANGE INTERNATIONAL STREET CITY OF ORANGE, a municipal corporation FAIR, INC., a California non-profit public
benefit corporation
By:

Daniel R. Slater, Mayor
By:

Printed Name:

Title:

ATTEST:

Pamela Coleman, City Clerk

APPROVED AS TO FORM:

Nathalie Adourian
Senior Assistant City Attorney

√

Adam Feliz
President
685

EXHIBIT “A”

STREET AND RIGHT-OF-WAY LAYOUT

[Behind this sheet.]
686
J:\GisProjects\StreetFair2021\GIS\APRX\StreetFair\StreetFair.aprx\Treats in the Street - 2025 2/21/2025
Source: City of Orange (2024)
0 200100
Feet
.

E CHAPMAN AV

E ALMOND AVE

N OLIVE ST

N ORANGE ST

PLAZASQ

S GRAND ST

W CHAPMAN AV

S ORANGE STS OLIVE ST

S GLASSELL ST

W ALMOND AVE

E MAPLE AVEW MAPLE AVE

N LEMON ST N GLASSELL ST

N GRAND ST

S LEMON ST
Legend
Treats in the Street Area Street Centerline

CITY OF ORANGE

TREATS IN THE STREET
687

EXHIBIT “B”

STAGING LAYOUT

[Behind this sheet.]

This item is determined and provided annually by Orange International Street Fair, Inc.

688

EXHIBIT “C”

TREATS IN THE STREETS

PLANNING SCHEDULE AND RESPONSIBILITIES

(Behind this sheet)
689
1 The following is a guideline for the preparation, assignments, duties and responsibilities of OISF and other City departments in support of Treats in the Streets . Changes to these guidelines may be incorporated administratively as determined necessary by the City and OISF.

Ongoing
OISF fields calls from merchants and residents prior to Treats in the Streets.

Pre Event (60 days)
• OISF submits to City the layout for the staging of Treats in the Streets described in Section

4.B to Police, Fire, and Public Works for written approval. • OISF submits to City the layout and details of tents, audio equipment, portable restrooms, and any other equipment or materials related to Treats of the Streets not provided by City. Include power needs, if any.

Pre Event (45 days)
• OISF submits draft merchant letter to City for review.

Pre Event (30 days)
• OISF distributes information letter to Plaza merchants and residents. • OISF provides a list of contacts and phone numbers to City. • OISF orders trash liners and delivers to Corp Yard.OISF presents and conducts a meeting with Treats in the Streets participants to provide city staff an opportunity to explain standards and requirements.
• OPW orders disposable trash boxes
• OPW rents necessary equipment and materials for street closures. • OPW notifies OCTA of the event footprint to re-route buses.

Pre Event (15 days)
• Authorized representatives from City and OISF shall walk the footprint of Treats in the Streets to ensure the footprint meets safety standards.

Pre Event (5 days)
• OPW loads all equipment and material needed for setup and closure procedures. • OPW posts “no parking signs” on streets and parking lots.

Pre-Staging of Event (36 hours)
• OPW brings stored materials to site.
• OPW provides and places advanced detour signs.

690
2 Day of the Event Duties

• 5:00 a.m. Southeast Quadrant closed and block off parking row behind the Assistance League to reserve space for VIP’s (OPW)
• 12:00 p.m. Closure begins. (OPW)
Traffic signals on E. Chapman & Grand and W. Chapman & Lemon to flash during the closure. (OPW)
• 2:00 p.m. Vendors & Subcontractors are permitted into the Plaza for unloading/set-up (OISF)
Vehicles will enter S. Orange Street and exit S. Olive Street (OISF). • 4:00 p.m. Event festivities begin (OISF)
• 7:00 p.m. Festivities end (OISF)
• 7:30 p.m. Vendor vehicles are allowed into the Plaza for loading; entering on S.

Orange St., exiting S. Olive St. once given the “all clear” from OPD and OPW (OISF, OPD, and OPW).
• 10:00 -11:30 p.m. Flashing lights are returned to standard and streets are reopened. (OPW)

Upon mutual agreement, OISF and the City will add other services or amend the timeline as needed to ensure a safe closure, the public right -of-way is kept clean, and the safe operation of Treats in the Streets.
691
ORANGE INTERNATIONAL STREET FAIR, INC.
112 E. Chapman Avenue Suite G | Orange, CA 92866 | P:714.633.4816 | www.orangestreetfair.org

February 20, 2025
Mr. Tom Kisela, City Manager
City of Orange
300 E Chapman Avenue
Orange, CA 92866

RE: Letter of Intent (LOI)
Treats in the Street Event

Dear Mr. Kisela,

On behalf of the Orange International Street Fair, Inc. I am writing to officially express our intent to act as the Managing Organization for Treats in the Street. As a longstanding, community-oriented organization dedicated to fostering community enrichment, OISF possesses extensive experience in overseeing and managing this cherished special event.

This event aligns with our mission of community involvement and public service. We are enthusiastic about supporting this valued community event, which we believe plays a crucial role in promoting local engagement and celebrating our community.

As the Managing Organization, OISF will assume responsibility for Treats in the Street and oversee the various aspects of the event’s planning and execution, ensuring that it aligns with our goals and the high standards of the City of Orange. OISF will contract with the City of Orange to provide the necessary support services for the event, including public works and public safety management.

Following the acceptance of this LOI, OISF requests a formal three-year production agreement with the City of Orange, similar to the agreement OISF has for the production of the Orange International Street Fair. OISF wants to clarify that there is no intent to serve alcohol during this event.

Please let us know if there are any additional details or requirements needed from our organization to facilitate the process. We are dedicated to collaborating closely with your office to ensure a successful and memorable event for everyone involved. Thank you for considering our participation. We look forward to partnering with the City of Orange and making the Treats in the Street event a tremendous success in the years to come.

Sincerely,

Adam Feliz, President
Board of Directors
Orange International Street Fair, Inc.

692
Agenda Item
City Council
Item #: 10.3. 4/8/2025 File #: 25-0191
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Update on the progress of the development of the 2025-2029 Consolidated Plan including the 2025- 2026 Annual Action Plan and 2025-2029 Regional Analysis of Impediments to Fair Housing Choice.

2. SUMMARY
Update on the progress of the development of the 2025-2029 Consolidated Plan including the 2025- 2026 Annual Action Plan and the 2025-2029 Regional Analysis to Fair Housing Choice.

3. RECOMMENDED ACTION

1. Approve the identified priorities to be incorporated into the 2025-2029 Consolidated Plan.

2. Approve the funding recommendations for the 2025-2026 Annual Action Plan.

3. Authorize staff to incorporate approved priorities and funding recommendations into the 2025- 2029 Consolidated Plan that includes the 2025-2026 Annual Action Plan.

4. Receive and file the 2025-2029 Regional Analysis to Fair Housing Choice.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life

6. DISCUSSION AND BACKGROUND
The U.S. Department of Housing and Urban Development (HUD) mandates that jurisdictions receiving annual entitlement funding through the Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME) programs develop a Consolidated Plan (Con Plan) every five years. This plan is designed to establish the City’s housing and community development priorities, ensuring alignment with the objectives of the CDBG and HOME programs. Serving as a comprehensive strategic framework, the Con Plan enables the City to assess affordable housing and community development needs, evaluate market conditions, and make informed decisions based on data analysis.

Analysis of Impediments to Fair Housing Choice
As part of the development of the Con Plan, HUD requires participating jurisdictions to conduct an Analysis of Impediments to Fair Housing Choice (AI). The AI is a comprehensive study aimed at identifying and evaluating potential barriers-both in the public and private sectors-that may hinder an individual’s ability to select housing free from discrimination. Additionally, it provides City of Orange Printed on 4/3/2025Page 1 of 4
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individual’s ability to select housing free from discrimination. Additionally, it provides recommendations for addressing these barriers through a five-year Fair Housing Action Plan.

The AI study delivers the following key components:

1. An overview of relevant laws, regulations, and administrative policies and procedures;

2. An evaluation of the impact of these laws on the location, availability, and accessibility of housing; and

3. An analysis of public and private conditions influencing fair housing choice.

For the 2025-2029 Analysis of Impediments to Fair Housing Choice (AI), the City partnered with 35 other Orange County municipalities and the County of Orange to create a Regional AI. This comprehensive study addresses barriers to fair housing choice at both the countywide level and within individual jurisdictions.

The AI will be available for public review and comment from April 10, 2025 to May 12, 2025. 2025-2029 Identified Priorities
The City is currently in the process of developing the 2025-2029 Con Plan. Five priority goals were identified to guide the allocation of CDBG and HOME funding over the next five fiscal years:
· Economic Development
· Affordable Housing
· Homelessness
· Public Programs
· Public Capital and Infrastructure Projects
The following sources were used to determine need:
· City Council identified priorities
· 2025-2029 Regional AI
· City-wide needs assessment survey conducted from August 2023-December 2023 utilizing the City’s website, City sponsored city-wide events, Housing Summit, and City public counters · Other data sources identified in the Con Plan, including but not limited to the City’sGeneral Plan, United States Census Bureau, and Orange County Housing Authority · Public input from the CDBG Program Committee public hearings and meeting Consolidated Plan CDBG Eligibility Map
As part of the Consolidated Plan (Con Plan), the City's consultant developed updated eligibility areas in the city utilizing the 2022 5-Year American Community Survey (ACS) data from the U.S. Census Bureau, the most current data available. To meet eligibility, a census tract must have at least 51% of all households earning at or below 80% of the Area Median Income (AMI). The updated eligibility map, reflecting the current criteria, is provided in Attachment 2. 2025-2026 Annual Action Plan
The Consolidated Plan (Con Plan) is implemented through Annual Action Plans (AAP), which provide a comprehensive summary of the strategies, activities, and federal and non-federal resources allocated each year to address the specific needs and objectives outlined in the Con Plan. The 2025- 2029 Con Plan includes the first year of the plan, the 2025-2026 AAP.

The City published a Notice of Funding Availability in the City Orange News on November 14, 2024, and solicited applications from November 14, 2024, to February 1, 2025, for consideration of City of Orange Printed on 4/3/2025Page 2 of 4
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Item #: 10.3. 4/8/2025 File #: 25-0191
and solicited applications from November 14, 2024, to February 1, 2025, for consideration of estimated funding for the Fiscal Year 2025-2026 CDBG and HOME funds. The City received eight applications for public programs and two applications for public infrastructure projects (summarized in Attachment A) for the 2025-2026 AAP.

On February 13, 2025, the CDBG Program Committee convened to review presentations from applicants. Alongside the submitted applications, the Community Development Department proposed allocating funding under the Public Capital Improvements and Infrastructure category to develop a new program aimed at supporting local qualifying businesses. Prior to implementation, the program's structure and parameters would be presented to the City Council for consideration. The designated funding set-aside would enable staff to explore and evaluate potential program options.

On March 13, 2025, the Community Development Block Grant (CDBG) Program Committee conducted a Public Hearing to provide funding recommendations for the proposed programs and projects. These recommendations were based on the estimated CDBG funding allocation of $1,034,444.
· 20% or $206,888.80 for administration
· 15% or $155,166.60 for public service activities
· 65% or $672,388.60 for public capital improvement and infrastructure projects This year, the City received a total of eleven applications for a total request of:
· $246,640 for public service activities
· $967,936.50 for public facilities projects
Factors used to determine funding recommendations include:
· Project eligibility
· Program description
· Organizational capacity and experience
· Goals and outcomes
· Budget
· Past performance goals
· Audit review
· Funding/Local priorities
For detailed information on the funding recommendations, refer to Attachment 3.

To date, the City has not received the final notification regarding the actual funding amounts. The proposed funding recommendations will be incorporated into the draft Consolidated Plan (Con Plan) and will be presented to the City Council for approval at a Public Hearing once the final allocations are confirmed, along with the final version of the 2025-2029 Con Plan.

7. ATTACHMENTS
· Attachment 1 Draft 2025-2029 Consolidated Plan
· Attachment 2 Consolidated Plan CDBG Eligibility Map
· Attachment 3 2025-2026 CDBG Funding Recommendations
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Agenda Item
City Council
Item #: 10.3. 4/8/2025 File #: 25-0191
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director

1. SUBJECT
Update on the progress of the development of the 2025-2029 Consolidated Plan including the 2025- 2026 Annual Action Plan and 2025-2029 Regional Analysis of Impediments to Fair Housing Choice.

2. SUMMARY
Update on the progress of the development of the 2025-2029 Consolidated Plan including the 2025- 2026 Annual Action Plan and the 2025-2029 Regional Analysis to Fair Housing Choice.

3. RECOMMENDED ACTION

1. Approve the identified priorities to be incorporated into the 2025-2029 Consolidated Plan.

2. Approve the funding recommendations for the 2025-2026 Annual Action Plan.

3. Authorize staff to incorporate approved priorities and funding recommendations into the 2025- 2029 Consolidated Plan that includes the 2025-2026 Annual Action Plan.

4. Receive and file the 2025-2029 Regional Analysis to Fair Housing Choice.

4. FISCAL IMPACT
None.

5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life

6. DISCUSSION AND BACKGROUND
The U.S. Department of Housing and Urban Development (HUD) mandates that jurisdictions receiving annual entitlement funding through the Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME) programs develop a Consolidated Plan (Con Plan) every five years. This plan is designed to establish the City’s housing and community development priorities, ensuring alignment with the objectives of the CDBG and HOME programs. Serving as a comprehensive strategic framework, the Con Plan enables the City to assess affordable housing and community development needs, evaluate market conditions, and make informed decisions based on data analysis.

Analysis of Impediments to Fair Housing Choice
As part of the development of the Con Plan, HUD requires participating jurisdictions to conduct an Analysis of Impediments to Fair Housing Choice (AI). The AI is a comprehensive study aimed at identifying and evaluating potential barriers-both in the public and private sectors-that may hinder an individual’s ability to select housing free from discrimination. Additionally, it provides City of Orange Printed on 4/3/2025Page 1 of 4
powered by Legistar™
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Item #: 10.3. 4/8/2025 File #: 25-0191
individual’s ability to select housing free from discrimination. Additionally, it provides recommendations for addressing these barriers through a five-year Fair Housing Action Plan.

The AI study delivers the following key components:

1. An overview of relevant laws, regulations, and administrative policies and procedures;

2. An evaluation of the impact of these laws on the location, availability, and accessibility of housing; and

3. An analysis of public and private conditions influencing fair housing choice.

For the 2025-2029 Analysis of Impediments to Fair Housing Choice (AI), the City partnered with 35 other Orange County municipalities and the County of Orange to create a Regional AI. This comprehensive study addresses barriers to fair housing choice at both the countywide level and within individual jurisdictions.

The AI will be available for public review and comment from April 10, 2025 to May 12, 2025. 2025-2029 Identified Priorities
The City is currently in the process of developing the 2025-2029 Con Plan. Five priority goals were identified to guide the allocation of CDBG and HOME funding over the next five fiscal years:
· Economic Development
· Affordable Housing
· Homelessness
· Public Programs
· Public Capital and Infrastructure Projects
The following sources were used to determine need:
· City Council identified priorities
· 2025-2029 Regional AI
· City-wide needs assessment survey conducted from August 2023-December 2023 utilizing the City’s website, City sponsored city-wide events, Housing Summit, and City public counters · Other data sources identified in the Con Plan, including but not limited to the City’sGeneral Plan, United States Census Bureau, and Orange County Housing Authority · Public input from the CDBG Program Committee public hearings and meeting Consolidated Plan CDBG Eligibility Map
As part of the Consolidated Plan (Con Plan), the City's consultant developed updated eligibility areas in the city utilizing the 2022 5-Year American Community Survey (ACS) data from the U.S. Census Bureau, the most current data available. To meet eligibility, a census tract must have at least 51% of all households earning at or below 80% of the Area Median Income (AMI). The updated eligibility map, reflecting the current criteria, is provided in Attachment 2. 2025-2026 Annual Action Plan
The Consolidated Plan (Con Plan) is implemented through Annual Action Plans (AAP), which provide a comprehensive summary of the strategies, activities, and federal and non-federal resources allocated each year to address the specific needs and objectives outlined in the Con Plan. The 2025- 2029 Con Plan includes the first year of the plan, the 2025-2026 AAP.

The City published a Notice of Funding Availability in the City Orange News on November 14, 2024, and solicited applications from November 14, 2024, to February 1, 2025, for consideration of City of Orange Printed on 4/3/2025Page 2 of 4
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Item #: 10.3. 4/8/2025 File #: 25-0191
and solicited applications from November 14, 2024, to February 1, 2025, for consideration of estimated funding for the Fiscal Year 2025-2026 CDBG and HOME funds. The City received eight applications for public programs and two applications for public infrastructure projects (summarized in Attachment A) for the 2025-2026 AAP.

On February 13, 2025, the CDBG Program Committee convened to review presentations from applicants. Alongside the submitted applications, the Community Development Department proposed allocating funding under the Public Capital Improvements and Infrastructure category to develop a new program aimed at supporting local qualifying businesses. Prior to implementation, the program's structure and parameters would be presented to the City Council for consideration. The designated funding set-aside would enable staff to explore and evaluate potential program options.

On March 13, 2025, the Community Development Block Grant (CDBG) Program Committee conducted a Public Hearing to provide funding recommendations for the proposed programs and projects. These recommendations were based on the estimated CDBG funding allocation of $1,034,444.
· 20% or $206,888.80 for administration
· 15% or $155,166.60 for public service activities
· 65% or $672,388.60 for public capital improvement and infrastructure projects This year, the City received a total of eleven applications for a total request of:
· $246,640 for public service activities
· $967,936.50 for public facilities projects
Factors used to determine funding recommendations include:
· Project eligibility
· Program description
· Organizational capacity and experience
· Goals and outcomes
· Budget
· Past performance goals
· Audit review
· Funding/Local priorities
For detailed information on the funding recommendations, refer to Attachment 3.

To date, the City has not received the final notification regarding the actual funding amounts. The proposed funding recommendations will be incorporated into the draft Consolidated Plan (Con Plan) and will be presented to the City Council for approval at a Public Hearing once the final allocations are confirmed, along with the final version of the 2025-2029 Con Plan.

7. ATTACHMENTS
· Attachment 1 Draft 2025-2029 Consolidated Plan
· Attachment 2 Consolidated Plan CDBG Eligibility Map
· Attachment 3 2025-2026 CDBG Funding Recommendations
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Consolidated Plan ORANGE 2
OMB Control No: 2506-0117 (exp. 09/30/2021)
Executive Summary
ES-05 Executive Summary - 24 CFR 91.200(c), 91.220(b)

1. Introduction
The City of Orange Community Development Department annually receives federal funds through the US Department of Housing and Urban Development (HUD). Every five years, HUD requires all jurisdictions receiving federal funds to submit a Consolidated Plan (Con Plan). The plan helps define the City’s priorities, strategies, and goals for the five-year period.

The Consolidated Plan supports the objectives outlined in Title I of the Housing and Community Development Act of 1974, as amended, and the National Affordable Housing Act of 1990, as amended. It also aligns with HUD’s primary goals of creating sustainable urban communities by offering decent housing, providing a suitable living environment, and enhancing economic opportunities for individuals with low and moderate incomes.

The Consolidated Plan is for the period of July 1, 2025, through June 30, 2030. During this period, the City anticipates receiving Community Development Block Grant (CDBG) and HOME Investment Partnership Program (HOME).

The CDBG program provides funding to support community development activities such as public infrastructure improvement, economic development, and public services. HOME funds can be used for affordable housing development activities such as rehabilitation and new construction and tenant-based rental assistance for low-income individuals and families.

The City of Orange 2025-2030 Con Plan is organized around 5 sections: Needs Assessment (NA), Market Analysis (MA), Strategic Plan (SP), and 2025 Annual Action Plan (AP).

2. Summary of the objectives and outcomes identified in the Plan Needs Assessment Overview
All HUD-funded projects must meet one of three National Objectives: primarily benefit low- and moderate-income persons, prevent or eliminate slum or blight; or meet other community development needs that address an urgent need to existing conditions posing a serious and immediate threat to the health or welfare of the community. The City’s five-year Con Plan strategic goals address housing and community needs including affordable housing, economic development, public facilities improvement, public services for low mod income persons, and fair housing.
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Consolidated Plan ORANGE 3
OMB Control No: 2506-0117 (exp. 09/30/2021)

3. Evaluation of past performance
The City of Orange’s evaluation of past performance has been completed through its Annual Consolidated Annual Performance and Evaluation Report (CAPER) prepared at the end of each fiscal year. The documents compare the measurable goals and objectives to the actual performance. The review of the fifth and final year of the 2020-2025 Con Plan period will be conducted in the 2025 CAPER, which will be submitted to HUD in September 2025.

4. Summary of citizen participation process and consultation process Residents and stakeholders were included in the planning process and development of the Consolidated Plan in the following ways:

Community Needs Survey
The City of Orange conducted a community survey from August 2023 to December 2023, to gather input for its 2025-2029 Consolidated Plan. Over 180 residents participated. The survey featured 26 questions focused on identifying priority goals for the upcoming planning period.

Topics included housing needs, infrastructure/facilities needs, service needs, fair housing issues, economic development needs and transportation needs. The survey was conducted at city-wide events including National Night Out, Treats in the Streets, Tree Lighting, El Modena Neighborhood Outreach day, and offered at the City’s public counters and website. The survey results offer valuable insights into the community’s needs and priorities.

Housing Summit
A Housing Summit was held in November 2023 to collect data to inform the Analysis of Impediments to Fair Housing Rights (AI) and the 5-Year Consolidated Plan. A Workbook was developed for Housing Summit participants to complete. The workbook responses were summarized to inform the AI and Con Plan. Approximately 42 individuals participated in the Housing Summit representing the following Organizations:
o OC Goodwill
o Jamboree Housing
o C&C Development
o The HUB OC
o Rescue Mission
o Love Orange
o Temporary Shelter
o Home Aid
o Building Partners
o Orange Housing Development Organization
Public Hearing
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Public hearings on the Consolidated Plan (Con Plan) are held before the CDBG Committee and City Council to allow community members to provide input on local housing and development needs. These hearings help ensure that the City Council receives feedback on how federal funds should be allocated to address issues like affordable housing, homelessness, and public services, ensuring the plan aligns with the community's priorities and needs.  Public Hearing #1 and Presentation on the Draft Consolidated was held before the CDBG Committee on March 13, 2025
 Public Meeting #1 and Presentation on the Draft Consolidated Plan was held before the City Council on April 8, 2025
 Public Hearing #2 for the adoption of the Consolidated Plan was held before the City Council on May 13, 2025

5. Summary of public comments

PENDING

6. Summary of comments or views not accepted and the reasons for not accepting them

PENDING

7. Summary
The priority needs identified from findings from community needs survey, housing summit and community meetings are as follows:

Affordable Rental Housing
 Increased supportive housing to assist homeless persons in the transition from homelessness, and to promote the provision of supportive housing to homeless persons to enable them to live as independently as possible.
 Increased senior housing units to accommodate the aging population.  Low-barrier housing is housing where a minimum number of expectations are placed on people who wish to live there. The aim is to have as few barriers as possible to allow more people access to services.
 Homeowner housing rehabilitation.
 Housing code enforcement.
 Down payment assistance.
 Rehabilitation of aging apartment buildings.
 Accessibility to housing affordability.

Public Services
 Senior services are a top priority in the city for the aging population. 703
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 Crime awareness, prevention and safety measures.
 Youth services and childcare services.
 Afterschool programs for youth engagement and development.

Homeless Populations Needs
 Homeless services including mental health and addiction services, permanent housing and transitional housing.

Public Facilities and Improvements
 Increased Code Enforcement to address infrastructure needs.  Street improvements including undergrounding of utilities.  Parking facilities including parking permit programs.  Tree planting and urban greenery to enhance aesthetic and environmental quality.  Create a more bike friendly environment.
 Mindfulness of segments of society that are most vulnerable to natural disasters.  Identify broadband internet problems throughout the city and provide equal access throughout the city.

Economic Development
 Job creation and job-generating businesses to support local economic growth.  Small business loans.
 Employment training.
 Rehabilitation of commercial buildings.

Fair Housing Services
 Support for family/children, race, and anti-discrimination efforts.  Education and enforcement of anti-discrimination laws to ensure equal housing opportunities for all.
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The Process
PR-05 Lead & Responsible Agencies 24 CFR 91.200(b)

1. Describe agency/entity responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source The following are the agencies/entities responsible for preparing the Consolidated Plan and those responsible for administration of each grant program and funding source.

Agency Role Name Department/Agency
CDBG Administrator ORANGE Community Development
Department
HOME Administrator ORANGE Community Development
Department
Table 1 – Responsible Agencies
Narrative
The Community Development Department is the lead agency for the development of the Consolidated Plan and administers CDBG and HOME programs. The City is not a recipient of the Emergency Solutions Grant (ESG) to directly fund homeless related projects. The City of Anaheim is the lead agency for the Housing Opportunities for People with AIDS (HOPWA) Program and administers the Program for all jurisdictions in Orange County.

Consolidated Plan Public Contact Information
Jessica Herrera, Housing Manager
Community Development Department
300 East Chapman Avenue,
Orange, California 92866
Telephone: (714) 744-7270
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PR-10 Consultation – 91.100, 91.110, 91.200(b), 91.300(b), 91.215(I) and 91.315(I)

1. Introduction
Provide a concise summary of the jurisdiction’s activities to enhance coordination between public and assisted housing providers and private and governmental health, mental health and service agencies (91.215(I)).

The City advertised the availability of CDBG and HOME funds, solicited input from nonprofit organizations, and encouraged residents to participate in the development of the 2025-2029 Consolidated Plan and the 2025-2026 Annual Action Plan. A housing summit was held on October 12, 2023 in which stakeholders from local organizations and agencies were invited by the City to engage in open dialogue regarding the following topics: CDBG funding, affordable housing development, fair housing law, homelessness needs, and vital social services. Furthermore, a needs assessment a survey was administered to learn about community needs and gaps.

Describe coordination with the Continuum of Care and efforts to address the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans, and unaccompanied youth) and persons at risk of homelessness.

The City is not a recipient of homeless-related grants and therefore not a participant of Continuum of Care. However, the City takes part in a regional effort lead by the County of Orange to address homelessness in Orange and surrounding jurisdictions. The City is home to a regional healthcare cluster including UC Irvine Medical Center, Children's Hospital of Orange County (CHOC), and St. Joseph Hospital of Orange. Nonprofits such as Illumination Foundation and Family Solution Collaborative provide housing services to homeless families released from CHOC hospital and other Orange County hospitals.

If and when the City receives homeless grants that are eligible for housing services and case management services, they would consider allocating homeless funds to these groups. The City was the recipient of HOME American Rescue Program funds in 2022 and used the funding to support the Hub Resource Center (HRC) that provides resources, coordinates and facilitates continuum of care services, and assists with housing services to the City’s most vulnerable population.

Describe consultation with the Continuum(s) of Care that serves the jurisdiction's area in determining how to allocate ESG funds, develop performance standards and evaluate outcomes, and develop funding, policies and procedures for the administration of HMIS The County of Orange is the lead agency for Continuum of Care and covers the Orange County jurisdiction, including 34 cities and Unincorporated Areas. Participation from County 706
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departments and agencies, local governments, homeless, housing and supportive service providers, community groups (including non-profits, faith-based organizations, interested business leaders, schools, individuals with lived experience, and many other stakeholders) is welcomed and encouraged.

The City of Orange supports the County’s efforts to develop effective programs to address the needs of homeless individuals. To help address the issue and find ways to address the underlying problems that lead to homelessness, Orange has joined with the cities of Anaheim, Brea, Buena Park, Cypress, Fullerton, La Habra, La Palma, Placentia, Villa Park, Stanton, and Yorba Linda in an unprecedented partnership called the North Service Planning Area (SPA). The North SPA Partnership is a joint collaboration that includes two full-service Navigation Centers to provide help to the region’s homeless. The Buena Park Center and the Placentia Center will provide homeless individuals a total of 250 beds, health resources, job skill training, and the ability to reconnect with lost family. These facilities join the two shelters already built by the City of Anaheim, which house another 326 beds.

The County has put together a Consolidated Plan, which identifies the Urban County of Orange’s overall housing and community development needs and outlines a strategy to address those needs. The City supports the Orange County Housing Authority (OCHA's) applications for HUD/VASH funding for homeless veterans. In addition, the City has provided funding to key homeless resources/services which include HomeAid’s Family Care Center operated by Mercy House and The HUB which feeds, clothes and provides services that support and enhance the quality of life for homeless individuals.

The City is not a recipient of ESG funds.

2. Describe Agencies, groups, organizations and others who participated in the process and describe the jurisdictions consultations with housing, social service agencies and other entities
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Agency/Group/Orga
nization
Agency/Group/Orga
nization Type
What section
of the Plan was
addressed by
Consultation?
How was the
Agency/Group/Organization consulted
and what are the anticipated outcomes
of the consultation or areas for
improved coordination?
Friendly Center, Inc. Services-Children
Services-Elderly
Persons
Anti-poverty
Strategy
Friendly Center participated in the public
workshops and public hearing during the
needs assessment process and
completed needs assessment survey.

Assistance League of
Orange
Services-Children
Services-Education
Anti-poverty
Strategy
Assistance League of Orange
participated in the public workshops and
public hearing during the needs
assessment process and completed
needs assessment survey.

Building Partners Housing Developer Housing Need
Assessment
Homeless
Strategy
Strategic Plan
Building Partners participated in the
Housing Summit and needs assessment
survey.

C&C Development Housing Developer Housing Need
Assessment
Homeless
Strategy
Strategic Plan
C&C Development participated in the
Housing Summit and needs assessment
survey.
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County of Orange Housing Services -
Housing Services-
Children Services-
Elderly Persons
Services-Persons with
Disabilities Services-
homeless Services-
Health Health Agency
Other government -
County
Housing Need
Assessment
Public Housing
Needs
Homelessness
Strategy
Homeless
Needs -
Chronically
homeless
Homeless
Needs -
Families with
children
Homelessness
Needs -
Veterans
Homelessness
Needs -
Unaccompanie
d youth Anti-
poverty
Strategy
Various County agencies (i.e, Housing
Authorities, Office of Care Coordination,
Social Services Agency, Health Care
Agency, Community Resources, and
Housing and Community Development)
participated in the Needs Assessment
Survey and Housing Summit.

HomeAid Nonprofit housing
developer –
Emergency shelter
provider
Housing Need
Assessment
Homeless
Strategy
Strategic Plan
HomeAid participated in the Housing
Summit and needs assessment survey.

The HUB OC Services-Children
Services-Elderly
Persons-Services-
Persons with
disabilities-Services-
vulnerable
communities
Anti-poverty
strategy
Housing Need
Assessment
Homeless
Strategy
Strategic Plan
The Hub OC participated in the public
meeting, public hearing during the needs
assessment process, Housing Summit
and completed needs assessment
survey.

Jamboree Housing Nonprofit housing
developer
Housing Need
Assessment
Homeless
Strategy
Strategic Plan
Jamboree Housing participated in the
Housing Summit and needs assessment
survey.

Love Orange Services-Children
Services-Elderly
Persons-Services-
Persons with
disabilities-Services-
vulnerable
communities
Anti-poverty
strategy
Housing Need
Assessment
Homeless
Strategy
Love Orange participated in the Housing
Summit and needs assessment survey.
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OC Goodwill Services – workforce
development
Housing Need
Assessment
Non-Homeless
Special Needs
Strategic Plan
OC Goodwill participated in the Housing
Summit and needs assessment survey.

OC Rescue Mission Services-Children
Services-Elderly
Persons-Services-
Persons with
disabilities-Services-
vulnerable
communities
Housing Need
Assessment
Non-Homeless
Special Needs
Strategic Plan
OC Rescue Mission participated in the
Housing Summit and needs assessment
survey.

Orange Housing
Development
Corporation (OHDC)
Non-profit housing
developer
Housing Need
Assessment
Homeless
Strategy
Strategic Plan
OHDC participated in the Housing
Summit and needs assessment survey.

Temporary Shelter Emergency Shelter
Provider
Housing Need
Assessment
Homeless
Strategy
Strategic Plan
Temporary Shelter participated in the
Housing Summit and needs assessment
survey.

Table 2 – Agencies, groups, organizations who participated Identify any Agency Types not consulted and provide rationale for not consulting The City consulted all known local agencies and organizations involved in activities that are relevant to the preparation of this Consolidated Plan.

Other local/regional/state/federal planning efforts considered when preparing the Plan Name of Plan Lead Organization How do the goals of your Strategic Plan overlap with the
goals of each plan?
Continuum of Care County of Orange Homelessness strategy Housing Element City of Orange Housing Affordability Policies and Programs
Table 3 – Other local / regional / federal planning efforts Describe cooperation and coordination with other public entities, including the State and any adjacent units of general local government, in the implementation of the Consolidated Plan (91.215(l))
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The City worked with the Orange County Housing Authority (OCHA), the Orange County Office of Care Coordination, and the Orange County Social Services Agency during the preparation of the Consolidated Plan.

Narrative (optional):
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PR-15 Citizen Participation – 91.105, 91.115, 91.200(c) and 91.300(c)

1. Summary of citizen participation process/Efforts made to broaden citizen participation. Summarize citizen participation process and how it impacted goal-setting.

A Community and Stakeholder Survey was conducted to gather data for the preparation of the Analysis of Impediments to Fair Housing and the 2025-2029 Consolidated Plan process from August 10, 2023 through December 30, 2023. The survey was hosted on the City’s website housing page, social media, city kiosk, and made available in paper form on the City Clerks and Community Development counter. To maximize outreach opportunities, the City also conducted the survey at the 2023 National Night Out, Treats in the Streets, and Annual Tree Lighting events and the 2023 El Modena Neighborhood Outreach. The City also held a Housing Summit in October 2023. A workbook was distributed to stakeholders at a Housing Summit to solicit input and assess housing needs, infrastructure/facilities needs including broadband, service needs, fair housing needs, economic development needs and transportation needs.

The City advertised the availability of CDBG and HOME funds, held one public hearing (March 13, 2025) and one public meeting (February 13, 2025) before the CDBG program advisory body and a public meeting (April 8, 2025) and a public hearing before the City Council (May 13, 2025). The City collected input from local nonprofit agencies, and encouraged residents to participate in the development of the 2025- 2029 Consolidated Plan and the 2025-26 Annual Action Plan. The City provided the needs assessment survey in English and Spanish at various public and nonprofit service counters and on the City's website. The City considered the survey responses when setting program goals and priorities.
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Citizen
Participation
Outreach
Mode of
Outreach
Target of
Outreach
Summary of
response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
1 Newspaper Ad Non-
targeted/broad
community

N/A N/A N/A N/A
2 Letters to Public
Service Agencies
Invitation to 78
different fair
housing service
organizations
across Orange
County to
participate in focus
groups and
interviews.

Four one-on-one
interviews and two
focus groups were
conducted during
the preparation of
the Analysis of
Impediments.

Comments
comprised of the
fair housing issues
frequently
encountered by the
organizations, the
underlying causes
for those issues,
and ongoing efforts
currently to
address them.

All comments received
were considered in the
preparation of this
report.

N/A
3 Community
Meetings
(In person and
virtual)
City residents,
interested
organizations
The City and
County,
respectively,
provided
opportunities to
engage via in-
person and online
to accommodate
various residents’
needs.

Citizen input and
comments will be
included in the
ConPlan.

All comments were
accepted.

N/A
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Citizen
Participation
Outreach
Mode of
Outreach
Target of
Outreach
Summary of
response/attendance
Summary of
comments received
Summary of comments
not accepted
and reasons
URL (If
applicable)
4 Internet
Outreach
Non-
targeted/broad
community
185 survey
respondents
participated.

Comments
comprised of
needs for
affordable rental
housing units,
improvements to
public facilities,
and homeless
shelters.

All comments received
were considered in the
preparation of this
report.

N/A
Table 4 – Citizen Participation Outreach
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Needs Assessment
NA-05 Overview
Needs Assessment Overview
The City of Orange held a housing summit in October of 2023 and promoted a community outreach survey to collect input from the public on housing and community needs. Based on the needs that were identified during the community outreach process, as well as data from the 2020 American Community Survey (5-year estimate) and 2016 – 2020 Comprehensive Housing Affordability Strategy (CHAS), priority needs, goals, and objectives for the Consolidated Plan were identified.

1. Economic Development

2. Affordable Rental Housing

3. Public Services

4. Homeless Population Needs

5. Public Capital and Infrastructure Improvements

6. Fair Housing Services
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NA-10 Housing Needs Assessment - 24 CFR 91.205
Summary of Housing Needs
The Housing Needs Assessment section of this Consolidated Plan utilizes data from the 2016- 2020 American Community Survey (ACS) 5-year estimates as well as 2016-2020 Comprehensive Housing Affordability Strategy (CHAS) data from HUD. The City’s total population is currently 139,320, a less than 1% decrease since 2009. Incidentally, the number of households actually increased slightly by 2%. Small family households make up the largest household group at 47%.

Moreover, the two senior household categories (62 years to 74 years and 75 years and older) combined in the extremely low-income category is larger than the non-senior households. From this data, we can infer that affordable senior rental housing is a need in the community. The statistical data from the 2016-2020 ACS 5-year estimates on demographics, income, and housing reveals the following key information:
 Median household income is $96,605.
 Median house price is $680,300.
 Median monthly rent is $1,751.
 More than half of the City’s housing units are owner-occupied (59.2%).  Almost 39% of the City’s population makes less than $75,000.  Approximately 10.3% of the City’s population lives below the poverty rate.

Demographics Base Year: 2009 Most Recent Year: 2020 % Change Population 139,760 139,320 -0%
Households 42,680 43,325 2%
Median Income $78,513.00 $96,605.00 23%
Table 5 - Housing Needs Assessment Demographics
Data Source: 2000 Census (Base Year), 2016-2020 ACS (Most Recent Year) Number of Households Table
0-30%
HAMFI
>30-50%
HAMFI
>50-80%
HAMFI
>80-100%
HAMFI
>100%
HAMFI
Total Households 6,070 5,195 8,800 4,805 18,450
Small Family Households 1,705 2,325 3,550 1,845 10,790
Large Family Households 615 510 1,185 715 1,975
Household contains at least one
person 62-74 years of age 1,250 1,290 2,115 1,570 4,230 Household contains at least one
person age 75 or older 1,245 770 995 475 1,410
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0-30%
HAMFI
>30-50%
HAMFI
>50-80%
HAMFI
>80-100%
HAMFI
>100%
HAMFI
Households with one or more
children 6 years old or younger 1,110 854 1,330 700 1,415 Table 6 - Total Households Table
Data
Source:
2016-2020 CHAS
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Housing Needs Summary Tables

1. Housing Problems (Households with one of the listed needs) Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total

NUMBER OF HOUSEHOLDS
Substandard
Housing -
Lacking
complete
plumbing or
kitchen
facilities 140 100 35 40 315 15 10 0 0 25
Severely
Overcrowded -
With >1.51
people per
room (and
complete
kitchen and
plumbing) 280 100 235 45 660 0 15 35 115 165
Overcrowded -
With 1.01-1.5
people per
room (and
none of the
above
problems) 405 340 430 180 1,355 45 55 110 30 240
Housing cost
burden greater
than 50% of
income (and
none of the
above
problems) 2,090 925 440 0 3,455 1,295 885 1,020 70 3,270 718
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Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
Housing cost
burden greater
than 30% of
income (and
none of the
above
problems) 360 980 1,800 455 3,595 150 650 1,050 725 2,575 Zero/negative
Income (and
none of the
above
problems) 295 0 0 0 295 50 0 0 0 50
Table 7 – Housing Problems Table
Data
Source:
2016-2020 CHAS

2. Housing Problems 2 (Households with one or more Severe Housing Problems: Lacks kitchen or complete plumbing, severe overcrowding, severe cost burden) Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total

NUMBER OF HOUSEHOLDS
Having 1 or more
of four housing
problems 2,915 1,465 1,140 265 5,785 1,350 965 1,165 215 3,695 Having none of
four housing
problems 1,155 1,260 3,445 2,100 7,960 650 1,505 3,055 2,225 7,435 Household has
negative income,
but none of the
other housing
problems 0 0 0 0 0 0 0 0 0 0
Table 8 – Housing Problems 2
Data
Source:
2016-2020 CHAS
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3. Cost Burden > 30%
Renter Owner
0-30%
AMI
>30-50%
AMI
>50-80%
AMI
Total 0-30%
AMI
>30-50%
AMI
>50-80%
AMI
Total

NUMBER OF HOUSEHOLDS
Small Related 1,130 1,285 985 3,400 400 640 665 1,705
Large Related 505 305 185 995 60 130 265 455
Elderly 665 325 385 1,375 855 625 900 2,380
Other 935 445 795 2,175 160 200 285 645
Total need by
income
3,235 2,360 2,350 7,945 1,475 1,595 2,115 5,185
Table 9 – Cost Burden > 30%
Data
Source:
2016-2020 CHAS

4. Cost Burden > 50%
Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total

NUMBER OF HOUSEHOLDS
Small Related 0 0 410 410 345 325 0 670
Large Related 0 0 115 115 60 60 50 170
Elderly 485 135 25 645 775 360 600 1,735
Other 0 855 365 1,220 145 0 0 145
Total need by
income
485 990 915 2,390 1,325 745 650 2,720
Table 10 – Cost Burden > 50%
Data
Source:
2016-2020 CHAS

5. Crowding (More than one person per room)
Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total

NUMBER OF HOUSEHOLDS
Single family
households 680 390 550 200 1,820 45 60 90 95 290
Multiple,
unrelated family
households 14 65 120 34 233 0 10 55 49 114
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Renter Owner
0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total 0-
30%
AMI
>30-
50%
AMI
>50-
80%
AMI
>80-
100%
AMI
Total
Other, non-family
households 30 44 0 10 84 0 0 0 0 0
Total need by
income
724 499 670 244 2,137 45 70 145 144 404
Table 11 – Crowding Information – 1/2
Data
Source:
2016-2020 CHAS
Renter Owner
0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total 0-30%
AMI
>30-
50%
AMI
>50-
80%
AMI
Total
Households
with Children
Present

N/A N/A N/A N/A N/A N/A N/A N/A
Table 12 – Crowding Information – 2/2
Describe the number and type of single person households in need of housing assistance.

It is important to note that the “other” classification in Tables 9, 10, and 11 is attributed to “single-person households.” 2016 – 2020 CHAS data for “low-income or below” (i.e. – making less than 80% AMI) and “single - person households” under the categories for “cost burden greater than 30%, “cost burden greater than 50%”, and “crowding” indicates the following observations. Based on this information, there is a need for more affordable studios or 1- bedroom apartments for low income, single-person households.

1. Single-person households that are considered “low income or below” and “renters” make up roughly one third of the low-income household renters that report facing cost burden.

2. Cost burden greater than 30% - 2,175 single-person households with incomes less than 80% of AMI pay more than 30% of their income on rental housing expenses.

Cost burden greater than 50% - 1,220 single-person households with incomes less than 80% of AMI pay more than 50% of their income on rental housing expenses.

Estimate the number and type of families in need of housing assistance who are disabled or victims of domestic violence, dating violence, sexual assault and stalking.

The City does not allocate funding to the Section 8 program operated by the Orange County Housing Authority. Therefore, the City does not have access to the data collected from the 721
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applicants through the Section 8 program to provide specific information on the number and types of families in need of Section 8 vouchers. Furthermore, the Orange County Housing Authority does not collect this type of information for families participating in the Section 8 program.

What are the most common housing problems?
Among renters, the most prevalent issue is housing cost burden greater than 30% of income, with 3,595 households affected, predominantly in the 50 - 80% AMI range. Additionally, 3,455 renter households face a housing cost burden greater than 50% of their income, 60% of which are in the 0 – 30% AMI income bracket. Similarly, overcrowding and severe overcrowding are more prevalent amongst lower income renting households. The most prevalent housing issue for owners is housing cost burden greater than 50%. Once again, the majority of owner households (40%) that reported a cost burden greater than 50% are in the extremely low-income (0 – 30% AMI) bracket.

Overall, the data reflects a shortage of affordable rental housing for households that make less than 30% of the Area Median Income.

Are any populations/household types more affected than others by these problems? Special needs populations such as the elderly are more susceptible to housing problems. For example, there are 485 renter households in the City of Orange that make less than 30% of the Area Median Income and report a housing cost burden greater than 50%, 100% of which are elderly households.

Describe the characteristics and needs of Low-income individuals and families with children (especially extremely low-income) who are currently housed but are at imminent risk of either residing in shelters or becoming unsheltered 91.205(c)/91.305(c)). Also discuss the needs of formerly homeless families and individuals who are receiving rapid re-housing assistance and are nearing the termination of that assistance
The City of Orange does not receive funds to specifically address the needs of the homeless but rather works in collaboration with the County and surrounding jurisdictions to do such. Several nonprofits operate within Orange to provide support and resources to individuals or families who are at risk of becoming homeless, such as Mercy House and the Hub Resource Center.

If a jurisdiction provides estimates of the at-risk population(s), it should also include a description of the operational definition of the at-risk group and the methodology used to generate the estimates:

Not applicable.
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Consolidated Plan ORANGE 24
OMB Control No: 2506-0117 (exp. 09/30/2021)
Specify particular housing characteristics that have been linked with instability and an increased risk of homelessness
The high cost of housing is a significant factor in the instability and increased risk of homelessness in the City of Orange. As previously mentioned, the median home value in Orange is $680,300, which is 196% increase from the national median of $229,800. Similarly, the median monthly rent in the City of Orange is $1,751 compared to the national median of $929.

Discussion
Refer to the sections above.
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Consolidated Plan ORANGE 25
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-15 Disproportionately Greater Need: Housing Problems – 91.205 (b)(2) Assess the need of any racial or ethnic group that has a disproportionately greater need in comparison to the needs of that category of need as a whole.

Introduction
The City’s primary racial or ethnic group is White including White Hispanics. A disproportionately greater housing need exists when members of a racial or ethnic group at an income level experience housing problems at a greater rate (10% or more) than the income level as a whole.

The following tables identify the presence of one or more housing problems among households of differing race/ethnicities and income levels, with the analysis that follows identifying any racial/ethnic group having evidence of a disproportionate housing need. 0%-30% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 4,770 1,300 0
White 1,975 675 0
Black / African American 135 10 0
Asian 710 250 0
American Indian, Alaska Native 0 20 0
Pacific Islander 0 0 0
Hispanic 1,800 335 0
Table 13 - Disproportionally Greater Need 0 - 30% AMI
Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4.Cost Burden greater than 30%
30%-50% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 4,055 1,140 0
White 1,875 635 0
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Consolidated Plan ORANGE 26
OMB Control No: 2506-0117 (exp. 09/30/2021)
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Black / African American 30 10 0
Asian 380 175 0
American Indian, Alaska Native 0 0 0
Pacific Islander 45 0 0
Hispanic 1,670 305 0
Table 14 - Disproportionally Greater Need 30 - 50% AMI
Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4.Cost Burden greater than 30%
50%-80% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 5,150 3,650 0
White 2,245 1,885 0
Black / African American 175 55 0
Asian 795 270 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 0 0
Hispanic 1,890 1,235 0
Table 15 - Disproportionally Greater Need 50 - 80% AMI
Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4. Cost Burden greater than 30%
725
Consolidated Plan ORANGE 27
OMB Control No: 2506-0117 (exp. 09/30/2021)
80%-100% of Area Median Income
Housing Problems Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 1,665 3,140 0
White 815 1,805 0
Black / African American 40 10 0
Asian 180 255 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 10 0
Hispanic 535 955 0
Table 16 - Disproportionally Greater Need 80 - 100% AMI Data
Source:
2016-2020 CHAS
*The four housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than one person per room, 4.Cost Burden greater than 30%
Discussion
The tables above identify the presence of one or more housing problems (lacks complete kitchen, lacks complete plumbing, overcrowding at > 1 person per room, or overpayment at > 30%) for different racial/ethnic groups within a given income category. The following summarizes the results of these CHAS tables and identifies groups experiencing disproportionate housing need in the City of Orange.
0 – 30% of Area Median Income
 79% of extremely low-income households in the City of Orange have one or more housing problems, 38% of these households identified as Hispanic.  The highest incidence of housing problems amongst extremely low-income households is experienced by Black/African American households at 93% although they only make up roughly 2% of the total 6,070 extremely low-income households. 30 – 50% of Area Median Income
 The highest incidence of housing problems amongst low-income households is experienced by Pacific Islanders (100%), Black/African Americans (75%), and White 726
Consolidated Plan ORANGE 28
OMB Control No: 2506-0117 (exp. 09/30/2021)
households (75%). Despite these numbers, Pacific Islanders and Black/African American households each only make up less than 1 percent of this income group.  Similar to the last income group, zero households reported no or negative income without the presence of at least one other housing problem.
 Of the 1,975 Hispanic households in this income group, 85% experienced one or more housing problems.
50 – 80% of Area Median Income
 76% of Black/African American households in this income group experienced one or more of the four housing problems despite only making up 3% of this income group. 75% of Asian households in this income group experienced one or more housing problems while making up 12% of the total group.
 59% of median income households in the City of Orange have housing problems, with high incidences among all racial groups, ranging from 54% (White) to 76% (Black/African American).
 60% of Hispanic households in the median income bracket have housing problems.

Hispanic households make up 36% of the total households in this income group. 80 – 100% of Area Median Income
 35% of median income households in the City of Orange have housing problems with incidences amongst racial groups ranging from 0% to 80%.  The highest incidence of housing problems (80%) in this income group is experienced by Black/African American households although they only make up 1% of median income households in the City. Asian households make up 9% of this income group yet 41% experience housing problems.
 There are only 10 Pacific Islander households in the median income bracket, none of them experience housing problems.
727
Consolidated Plan ORANGE 29
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-20 Disproportionately Greater Need: Severe Housing Problems – 91.205 (b)(2)
Assess the need of any racial or ethnic group that has a disproportionately greater need in comparison to the needs of that category of need as a whole.

Introduction
While the City is predominately White (69%) and race plays a role in determining if a household is more susceptible to housing problems, severe housing problems are tightly linked to income levels as well as race and ethnicity.

A disproportionately greater housing need exists when the members of a racial or ethnic group at an income level experience housing problems at a greater rate (10% or more) than the entire income bracket. The following tables identify the presence of severe housing problems among households of differing race/ethnicities and income levels, with the analysis that follows identifying any racial/ethnic group evidencing a disproportionate housing need. 0%-30% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 4,265 1,805 0
White 1,720 935 0
Black / African American 110 40 0
Asian 630 335 0
American Indian, Alaska Native 0 20 0
Pacific Islander 0 0 0
Hispanic 1,690 450 0
Table 17 – Severe Housing Problems 0 - 30% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4.Cost Burden over 50%
728
Consolidated Plan ORANGE 30
OMB Control No: 2506-0117 (exp. 09/30/2021)
30%-50% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,430 2,765 0
White 1,085 1,425 0
Black / African American 30 10 0
Asian 280 270 0
American Indian, Alaska Native 0 0 0
Pacific Islander 45 0 0
Hispanic 960 1,015 0
Table 18 – Severe Housing Problems 30 - 50% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4.Cost Burden over 50%
50%-80% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 2,305 6,500 0
White 765 3,365 0
Black / African American 80 150 0
Asian 375 690 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 0 0
Hispanic 1,070 2,065 0
Table 19 – Severe Housing Problems 50 - 80% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4.Cost Burden over 50%
729
Consolidated Plan ORANGE 31
OMB Control No: 2506-0117 (exp. 09/30/2021)
80%-100% of Area Median Income
Severe Housing Problems* Has one or more
of four housing
problems
Has none of the
four housing
problems
Household has
no/negative
income, but none
of the other
housing problems
Jurisdiction as a whole 480 4,325 0
White 150 2,475 0
Black / African American 0 50 0
Asian 50 380 0
American Indian, Alaska Native 0 0 0
Pacific Islander 0 10 0
Hispanic 280 1,210 0
Table 20 – Severe Housing Problems 80 - 100% AMI
Data
Source:
2016-2020 CHAS
*The four severe housing problems are:

1. Lacks complete kitchen facilities, 2. Lacks complete plumbing facilities, 3. More than 1.5 persons per room, 4.Cost Burden over 50%
Discussion
The tables above identify the presence of one or more severe housing problems (lacks complete kitchen facilities, lacks complete plumbing facilities, overcrowding at more than 1.5 persons per room, or cost burden over 50%) for different racial/ethnic groups within a given income category.

The following summarizes the results of these CHAS data tables and identifies groups experiencing disproportionate housing need in the City of Orange. 0 – 30% AMI
 70% of extremely low-income households in the City of Orange as a whole have one or more severe housing problems.
 73% of Black/African American households in this income group experience severe housing problems, although they only make up 2% of the total 6,070 extremely low- income households. Similarly, 65% of Asian households in this income group have severe housing problems, accounting for 16% of the total.
 There are 20 American Indian or Alaska Native households in this income bracket, none of which reported severe housing problems.
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Consolidated Plan ORANGE 32
OMB Control No: 2506-0117 (exp. 09/30/2021)
 Hispanic households face severe housing problems at a rate of 79%, representing 35% of the total households in this group.
30 – 50% AMI
 47% of low-income households in the City of Orange have one or more housing problems.  There are only 45 Pacific Islander households and 40 Black/African American households in the low-income group, respectively making up roughly 1% of the total 5,195 low- income households. However, these groups have the highest incidence of severe housing problems. 100% of Pacific Islander households and 75% of Black/African American low- income households reported severe housing problems.
 51% of Asian households in this income group have severe housing problems, accounting for 11% of the total.
50 – 80% AMI
 26% of households in the 50-80% AMI range report having one or more severe housing problems.
 The highest incidence of severe housing problems in the moderate-income bracket is found among Black/African American (35%) and Asian households (35%) although Black/African American households only make up 3% of moderate income households and Asian households only make up 12%
80 – 100% AMI
 10% of households in the median income level report severe housing problems.  6% of White households in this income group experience severe housing problems, making up the largest portion of the total households at 2,625, which represents 55% of the total.
 12% of Asian households in this income group have severe housing problems, accounting for 430 households and 9% of the total.
 Black/African American households made up roughly 1% of this income group and Pacific Islander households made up less than .5%. Both of these racial/ethnic groups did not experience any severe housing problems, although being more at risk in lower income groups. This reflects the intersectionality between income level and race/ethnicity in determining if a household is more at risk of experiencing severe housing problems. 731
Consolidated Plan ORANGE 33
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-25 Disproportionately Greater Need: Housing Cost Burdens – 91.205 (b)(2) Assess the need of any racial or ethnic group that has a disproportionately greater need in comparison to the needs of that category of need as a whole.

Introduction:

The data indicates that White (including non-Hispanic) households earning less than 30% of Area Median Income (AMI) experience housing cost burden at a disproportionate rate, making up 56% of housing burdened households in this income category. Roughly one out of four of the households earning less than 30% of AMI identify as Hispanic. For income levels between 30% to 50% AMI and more than 50% of AMI, the impact of housing cost burdens affects higher percentages of White households followed by Hispanic and then Asian households.

Housing Cost Burden
Housing Cost Burden <=30% 30-50% >50% No / negative
income (not
computed)
Jurisdiction as a whole 26,950 8,420 7,600 365
White 15,145 4,180 3,460 240
Black / African
American 165 225 195 0
Asian 3,595 1,035 1,195 20
American Indian,
Alaska Native 100 0 0 0
Pacific Islander 85 0 45 0
Hispanic 6,940 2,635 2,535 105
Table 21 – Greater Need: Housing Cost Burdens AMI
Data
Source:
2016-2020 CHAS
Discussion:

Please refer to the narrative above.
732
Consolidated Plan ORANGE 34
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-30 Disproportionately Greater Need: Discussion – 91.205(b)(2) Are there any Income categories in which a racial or ethnic group has disproportionately greater need than the needs of that income category as a whole? The data reflects that Black/African American and Pacific Islander households across different income levels have a disproportionately greater need than the needs of that income category as a whole. Hispanic (including White Hispanic) households exhibited a disproportionate need as well. Households at lower income levels (below 80%) have an increased need for decent and affordable housing.

If they have needs not identified above, what are those needs? No other housing needs identified.

Are any of those racial or ethnic groups located in specific areas or neighborhoods in your community?
The City of Orange has few predominately Hispanic neighborhoods. These geographic areas include Central Orange (near Glassell Street and Katella Avenue), El Modena, and Olive (near Lincoln Avenue and Batavia Street).
733
Consolidated Plan ORANGE 35
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-35 Public Housing – 91.205(b)
Introduction
The City of Orange does not own any public housing projects, but works collaboratively with and is assisted by the Orange County Housing Authority (OCHA) which operates a Section 8 Rental Assistance and Housing Choice Voucher Program. Therefore, the City does not have access to the data collected for the Section 8 or Housing Choice Voucher Program. The information shown in the following tables is collected from The Public and Indian Housing Information Center (PIC) dataset, an annual extract from HUD's administrative system that manages financial controls over Indian Housing, Housing Choice Voucher, and Public Housing programs.

Totals in Use
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units vouchers in use 0 0 0 10,825 0 10,418 187 207 10 Table 22 - Public Housing by Program Type
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Data Source: PIC (PIH Information Center)
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Consolidated Plan ORANGE 36
OMB Control No: 2506-0117 (exp. 09/30/2021)
Characteristics of Residents
Program Type
Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Average Annual Income 0 0 0 16,476 0 16,470 17,239 15,594 Average length of stay 0 0 0 8 0 8 0 4
Average Household size 0 0 0 2 0 2 1 3
# Homeless at admission 0 0 0 87 0 5 72 10
# of Elderly Program Participants
(>62) 0 0 0 4,926 0 4,884 38 3
# of Disabled Families 0 0 0 2,163 0 2,075 64 14
# of Families requesting
accessibility features 0 0 0 10,825 0 10,418 187 207
# of HIV/AIDS program
participants 0 0 0 0 0 0 0 0
# of DV victims 0 0 0 0 0 0 0 0
Table 23 – Characteristics of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center)
735
Consolidated Plan ORANGE 37
OMB Control No: 2506-0117 (exp. 09/30/2021)
Race of Residents
Program Type
Race Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
White 0 0 0 5,857 0 5,528 139 182 6
Black/African American 0 0 0 745 0 693 39 10 2
Asian 0 0 0 4,128 0 4,107 4 15 2
American Indian/Alaska
Native 0 0 0 64 0 60 4 0 0
Pacific Islander 0 0 0 31 0 30 1 0 0
Other 0 0 0 0 0 0 0 0 0
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 24 – Race of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center)
Ethnicity of Residents
Program Type
Ethnicity Certificate Mod-
Rehab
Public
Housing
Vouchers
Total Project -
based
Tenant -
based
Special Purpose Voucher
Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
Hispanic 0 0 0 1,941 0 1,814 34 87 4
Not Hispanic 0 0 0 8,884 0 8,604 153 120 6
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 25 – Ethnicity of Public Housing Residents by Program Type Data Source: PIC (PIH Information Center)
736
Consolidated Plan ORANGE 38
OMB Control No: 2506-0117 (exp. 09/30/2021)
Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants on the waiting list for accessible units:

The City does not allocate funding to the Section 8 or Housing Choice Voucher program operated by the Orange County Housing Authority.

Most immediate needs of residents of Public Housing and Housing Choice voucher holders The City does not allocate funding to the Section 8 or Housing Choice Voucher program operated by the Orange County Housing Authority.

How do these needs compare to the housing needs of the population at large The City does not allocate funding to the Section 8 or Housing Choice Voucher program operated by the Orange County Housing Authority.

Discussion
Please refer to the sections above.
737
Consolidated Plan ORANGE 39
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-40 Homeless Needs Assessment – 91.205(c)
Introduction:

The County of Orange released the 2024 biennial “Point-in-Time Count” that provides information on homeless individuals and households throughout the County. This report shows that on a given night in the last ten days of January 2024, the City of Orange had a total of 369 homeless, including individuals and families, 42% of which were sheltered and 58% of which were unsheltered.

Information on special populations such as seniors and veterans was not published in this report, however local nonprofits such as The Hub Resource Center (HRC), Mercy House, Illumination Foundation, and HomeAid offer housing navigation and case management services to this population. While Orange does not receive homeless related grants from HUD, the City supports the efforts of these organizations and the County of Orange’s Continuum of Care strategies to address homelessness.

If data is not available for the categories "number of persons becoming and exiting homelessness each year," and "number of days that persons experience homelessness," describe these categories for each homeless population type (including chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth):

The City is not a recipient of homeless related grants. 738
Consolidated Plan ORANGE 40
OMB Control No: 2506-0117 (exp. 09/30/2021)
Nature and Extent of Homelessness: (Optional)
Race: Sheltered: Unsheltered (optional)
Ethnicity: Sheltered: Unsheltered (optional)
Estimate the number and type of families in need of housing assistance for families with children and the families of veterans.

This information is not included in the last PIT County Report.

Describe the Nature and Extent of Homelessness by Racial and Ethnic Group.

This information is not included in the last PIT County Report.

Describe the Nature and Extent of Unsheltered and Sheltered Homelessness.

The 2024 PIT count revealed that out of the 369 homeless in the City of Orange, 214 were unsheltered and 155 were sheltered. Although there was a slight decrease in the number of unsheltered (31% decrease) and sheltered (22% decrease) homeless between 2019 and 2022, the numbers in the latest 2024 report are higher than those of both 2019 and 2022, reflecting an increased need for homeless assistance in the City. The after-effects of the Covid-19 pandemic may also have impacted these numbers.

Discussion:

Please refer to the sections above.
739
Consolidated Plan ORANGE 41
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-45 Non-Homeless Special Needs Assessment - 91.205
Introduction:

Although special needs populations do not make up significant portions of the population, the City of Orange supports and encourages affordable housing development projects targeted to these groups, specifically low-income special needs persons, due to the fact that they are more susceptible to fair housing barriers.

There are a number of senior housing developments throughout the City, many of which are affordable such as Triangle Terrace, a 75 unit affordable senior community comprised of studios and one-bedroom apartments, Palmyra, Richlyn & Fern Gardens Senior Apartment Homes offering one and two-bedroom units for low-income seniors, and Villa St. Joseph, a community of 18 one-bedroom units for seniors experiencing homelessness.

Describe the characteristics of special needs populations in your community:

The American Community Survey’s 2020 5 – year estimate reveals that approximately 8.5% of the City’s population is disabled, 49% of which report an ambulatory difficulty.

What are the housing and supportive service needs of these populations and how are these needs determined?
As previously mentioned, the most common disability amongst residents in the City of Orange is ambulatory difficulties. This points to a need for more accessible housing and reasonable accommodations for those with ambulatory disabilities such as more ramps in public buildings.

The City allocated $90,000 of CDBG funds for the fiscal year of 2024 – 2025 to support the Public Works initiative of adding more ADA Wheelchair Access Ramps throughout Orange.

According to ACS 2016 – 2020 data, approximately 14% of the City’s population is elderly (over the age of 65). The Orange County Housing Authority (OCHA) operates a Section 8 Rental Assistance/Housing Choice program for the City and provides housing to seniors seeking Section 8 housing units. The Orange County Health Care Agency administers the Senior Health Outreach & Prevention Program (SHOPP) which provides crisis intervention and community outreach services to low-income seniors over the age of 60. The City itself has a Senior Center where a variety of free and minimal cost workshops, services, and classes are offered. The Orange Senior Center also offers food assistance and transportation services. Sunrise of Orange is a 62-bed assisted living facility for seniors.

Overall, there is a need for more affordable housing for all special needs populations (disabled, elderly, and persons with HIV/AIDS).
740
Consolidated Plan ORANGE 42
OMB Control No: 2506-0117 (exp. 09/30/2021)
Discuss the size and characteristics of the population with HIV/AIDS and their families within the Eligible Metropolitan Statistical Area:

According to information from the 2022 Orange County HIV Continuum of Care, at the end of 2022, there were 6,916 individuals residing in Orange County diagnosed with HIV. The Centers for Disease Control and Prevention (CDC) estimates that approximately 16% of persons living with HIV/AIDS are unaware of their status, therefore, the total estimated number of persons living with HIV in Orange County for the year of 2022 was 8,204.

If the PJ will establish a preference for a HOME TBRA activity for persons with a specific category of disabilities (e.g., persons with HIV/AIDS or chronic mental illness), describe their unmet need for housing and services needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2) (ii)) The County of Orange administers a Housing Opportunities for Persons with AIDS program which can be used for either project-based or tenant-based rental assistance, short-term rent, mortgage, or utility payments.
741
Consolidated Plan ORANGE 43
OMB Control No: 2506-0117 (exp. 09/30/2021)
NA-50 Non-Housing Community Development Needs – 91.215 (f) Describe the jurisdiction’s need for Public Facilities:

The City of Orange proudly offers 22 parks to the public, each boasting their own distinctive amenities including volleyball courts, tennis courts, BBQ stations, community buildings and more, however, the City continuously needs funding to improve its park system, recreational facilities and public streets. A recent community outreach survey conducted in preparation for the 2025- 2029 Consolidated Plan reflected that the majority of respondents (approximately 27%) indicated that parks and recreational facilities should be the City’s top priority in terms of community facilities. The City’s Public Works department receives a substantial amount of CDBG funds for street improvements and ADA improvements in areas that are predominately low and moderate income.

How were these needs determined?
These needs were determined based on a needs assessment survey that was conducted in preparation for the 2025 – 2029 Consolidated Plan cycle.

Describe the jurisdiction’s need for Public Improvements:

The City has deteriorating public streets, sewer, and storm drain infrastructure within low- income neighborhoods that need to be repaired or replaced. Public response to a needs assessment survey revealed that public opinion regarding top priorities for infrastructure improvements include increased code enforcement as well as street improvements. As per the City’s FY 2024 Five-Year Capital Improvement Plan, Orange currently has eight roadway bridges throughout the City that require maintenance. Caltrans has inspected them and made recommendations for maintenance and repair. A maintenance and retrofit plan is ready for implementation, but the City is awaiting funding to implement these plans.

How were these needs determined?
These needs were determined based on a needs assessment survey that was conducted in preparation for the 2025 – 2029 Consolidated Plan cycle as well as the Public Works section of the City’s FY 2024 Five-Year Capital Improvement Plan.

Describe the jurisdiction’s need for Public Services:

The City has a need for youth services and homeless services focused on providing supportive and transitional housing for residents experiencing homelessness. The City currently allocates CDBG funds to the HUB OC Youth Centers of Orange’s after school program; Families Forward, a housing services and homeless prevention organization; the Friendly Center, which provides food 742
Consolidated Plan ORANGE 44
OMB Control No: 2506-0117 (exp. 09/30/2021)
to those in need; and the Assistance League of Orange, an organization that provides uniforms and supplies to low-income children.

How were these needs determined?
These needs were determined based on a needs assessment survey that was conducted in preparation for the 2025 – 2029 Consolidated Plan cycle as well as the City’s General Plan. 743
Consolidated Plan ORANGE 45
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Housing Market Analysis
MA-05 Overview
Housing Market Analysis Overview:

Overall, there is a very high demand for affordable housing within the City of Orange. Data from the 2016 – 2020 American Community Survey reflects that the median home value in the City is $680,300, the median contract rent is $1,751 and the median income is $96,605. The high cost of living and housing, coupled with low wages, a dwindling of local, state, and federal funding, and increased cost of land and construction materials has only exacerbated the existing affordable housing crisis. Homeownership has become increasingly difficult for households in lower income brackets.

The City of Orange currently boasts 1,426 affordable housing units and continues to seek opportunities to partner with affordable housing developers to build affordable developments and units for low-income households. Most recently, the City has added the following affordable housing developments to its list: Villa St. Joseph, a community of 18 one-bedroom units for seniors experiencing homelessness; Valencia Gardens, a 62 unit affordable housing community; Katella Terrace, a 75 unit affordable housing development for seniors; and Orion, a 166 unit affordable senior housing development.
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MA-10 Number of Housing Units – 91.210(a)&(b)(2)
Introduction
According to data from the 2016 – 2020 ACS 5 – year estimates, the total number of housing units in the City of Orange is 45,160. As shown below in table 31, the majority of housing units (56%) are single family houses. 66% of housing units in Orange are one unit structures. Out of the occupied housing units in the City, 59.2% are owner-occupied and 40.8% are renter-occupied.

The average household size is three. Due to the high cost of housing throughout the State, there is a high demand for affordable rental housing units.

All residential properties by number of units
Property Type Number %
1-unit detached structure 25,240 56%
1-unit, attached structure 4,445 10%
2-4 units 5,325 12%
5-19 units 3,580 8%
20 or more units 5,295 12%
Mobile Home, boat, RV, van, etc 1,275 3%
Total 45,160 100%
Table 26 – Residential Properties by Unit Number
Data Source: 2016-2020 ACS
Unit Size by Tenure
Owners Renters
Number % Number %
No bedroom 130 1% 1,030 6%
1 bedroom 550 2% 4,135 23%
2 bedrooms 3,365 13% 7,510 42%
3 or more bedrooms 21,610 84% 5,005 28%
Total 25,655 100% 17,680 99%
Table 27 – Unit Size by Tenure
Data Source: 2016-2020 ACS
Describe the number and targeting (income level/type of family served) of units assisted with federal, state, and local programs.

The City leverages CDBG and HOME funds to assist low- to moderate-income families and individuals throughout the City who are in need of housing assistance. Furthermore, the Housing Choice Voucher program administered by the Orange County Housing Authority serves households with federally funded rental assistance. The Housing Authority gives priority on the 745
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waiting list to veterans, the elderly, and persons with disabilities. There are currently 9,925 units throughout the entire County of Orange that receive assistance in the form of a Housing Choice Voucher, approximately 9% are veteran households and approximately 17% are part of the Authority’s Family Unification Program which seeks to support families and youth who are at risk of losing their children to foster care, or who are aging out of foster care and at risk of homelessness.

The following is a list of affordable housing projects in the City of Orange that rely on funding from federal programs:

Project 30% 50% 60% 70% Manager Total
Valencia Gardens 20 9 25 7 1 62
Katella Terrace 8 44 21 0 1 74
Villa St. Joseph 24 25 0 0 1 50
Orion Project 17 32 32 83 2 166
Total 69 110 78 90 5 352
Provide an assessment of units expected to be lost from the affordable housing inventory for any reason, such as expiration of Section 8 contracts.

Typically, the City enforces a long-term affordability period of 55 years for most of its affordable housing projects. Some of these projects have an indefinite affordability term linked to the conditional land use permit. In the near future, only two project, Adams Triplex I and Casas Del Rio, will conclude their affordability periods in 2027 and 2028 respectively. Adams Triplex I includes three assisted affordable housing units while Cases Del Rio has 40 for elderly residents and although their current affordability is tied to their loan which terminates in 2028, their mission is to preserve the affordability of the units in perpetuity.

Does the availability of housing units meet the needs of the population? Overall, the City of Orange, and the state of California as a whole, is experiencing a housing shortage across all income levels. The City’s Housing Plan, included in the 2021 – 2029 Housing Element, describes the specific policy action and goals the City intends to take to achieve long- term housing objectives. The City’s 2021 – 2029 Regional Housing Needs Assessment identified the need for 3,936 new housing units, 27% of which are to be for very low-income (0 – 50% County Median Family Income [MFI]) residents, 15% low-income (51 – 80% County MFI), 17% 746
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moderate income (81 – 120% County MFI), and 40%, the majority, for above moderate income households (120% or more of County MFI).

Describe the need for specific types of housing:

It is clear that this is a need for affordable multifamily housing units in the City, especially for extremely low, very low, and low income households. The rising number of homeless individuals and families also points to a need for more transitional and supportive housing, as well as single- room occupancy (SRO) units which would also benefit senior residents struggling to access affordable housing that meets their needs.

Discussion
Overall, in the City of Orange, like many areas across California, the demand for affordable housing units often exceeds the available supply. Some key factors contributing to this include high land and construction costs, limited funding for affordable housing projects, zoning restrictions, and more. The City has taken steps to address this issue by identifying opportunities for housing sites near employment and transit hubs, offering incentives for developers such as the density bonus program, and utilizing funding from HOME and CDBG to support affordable housing projects and low- to moderate-income individuals and families. 747
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MA-15 Housing Market Analysis: Cost of Housing - 91.210(a) Introduction
The City of Orange’s housing market has grown substantially in the past decade, with the median home value increasing by 27% based on the ACS data shown below in table 33. Population growth as well as a statewide housing shortage have contributed to the very strong demand for housing.

As previously mentioned, the national median home value of $229,800 is a 196% decrease from the median home value in Orange. This makes homeownership unattainable for many households in City, where the median rent is also 47% more than that of the U.S. as a whole. Due to the high cost of housing, many households in lower income brackets are at risk of homelessness and experience housing problems such as overcrowding or cost burden (paying more than 30% of their income towards housing costs).

Cost of Housing
Base Year: 2009 Most Recent Year: 2020 % Change
Median Home Value 534,300 680,300 27%
Median Contract Rent 1,469 1,751 19%
Table 28 – Cost of Housing
Data Source: 2000 Census (Base Year), 2016-2020 ACS (Most Recent Year) Rent Paid Number %
Less than $500 1,220 6.9%
$500-999 1,185 6.7%
$1,000-1,499 3,855 21.8%
$1,500-1,999 5,625 31.8%
$2,000 or more 5,780 32.7%
Total 17,665 99.9%
Table 29 - Rent Paid
Data Source: 2016-2020 ACS
Housing Affordability
Number of Units affordable to
Households earning
Renter Owner
30% HAMFI 965 No Data
50% HAMFI 2,410 595
80% HAMFI 9,365 1,465
100% HAMFI No Data 2,490
Total 12,740 4,550
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Table 30 – Housing Affordability
Data Source: 2016-2020 CHAS
Monthly Rent
Monthly Rent ($) Efficiency (no
bedroom)
1 Bedroom 2 Bedroom 3 Bedroom 4 Bedroom
Fair Market Rent $2,200 $2,344 $2,783 $3,769 $4,467
High HOME Rent $1,826 $1,958 $2,352 $2,708 $3,001
Low HOME Rent $1,381 $1,479 $1,776 $2,051 $2,288
Table 31 – Monthly Rent
Data Source: 2024 HOME Program Rents for Santa Ana-Anaheim-Irvine, CA HUD Metro Is there sufficient housing for households at all income levels? As previously noted, the City’s Housing Element outlines plans to accommodate over 3,900 new housing units across different income levels. According to an affordable housing list published by the Orange County Housing & Community Development Commission and revised as recently as December of 2024, there are a little over 1,400 affordable housing units in the City of Orange, approximately 68% of which are affordable to low and very low-income households.

How is affordability of housing likely to change considering changes to home values and/or rents?
As previously discussed, the City of Orange and California as a whole boasts a competitive housing market with high costs. High home values, however, means less affordability, which is why the City maintains a number of affordable housing units that are greatly subsidized and have a long- term affordability period (i.e. - 55 years or in perpetuity).

How do HOME rents / Fair Market Rent compare to Area Median Rent? How might this impact your strategy to produce or preserve affordable housing? According to the 2016 – 2020 ACS estimate, the median contract rent in Orange is $1,751. Fair market rent based on the 2024 HOME Program Rent Limits published by HUD are more than this, even for one-bedroom units. Low HOME Rent Limits are less. HOME-assisted units throughout the City of Orange are subject to HOME rent limits which is good for the community in that it creates and preserves affordable housing.

Discussion
Please refer to the sections above.
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MA-20 Housing Market Analysis: Condition of Housing – 91.210(a) Introduction
This section provides an overview of housing conditions in the City of Orange including housing stock, risk of containing lead-based paint, and the need of rental and owner-occupied rehabilitation.

There are four main housing conditions:

1. Lack of complete kitchen facility

2. Lack of complete plumbing facility

3. More than one person per room

4. Housing cost of more than 30%
More renter households experienced at least one of the aforementioned housing conditions than did owner-occupied housing units.

Describe the jurisdiction's definition of "standard condition" and "substandard condition but suitable for rehabilitation":

Condition of Units
Condition of Units Owner-Occupied Renter-Occupied
Number % Number %
With one selected Condition 7,855 31% 8,410 48%
With two selected Conditions 135 1% 1,250 7%
With three selected Conditions 10 0% 120 1%
With four selected Conditions 0 0% 0 0%
No selected Conditions 17,650 69% 7,895 45%
Total 25,650 101% 17,675 101%
Table 32 - Condition of Units
Data Source: 2016-2020 ACS
Year Unit Built
Year Unit Built Owner-Occupied Renter-Occupied
Number % Number %
2000 or later 2,205 9% 1,920 11%
1980-1999 6,170 24% 3,670 21%
1950-1979 16,110 63% 10,185 58%
Before 1950 1,170 5% 1,905 11%
Total 25,655 101% 17,680 101%
Table 33 – Year Unit Built
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Risk of Lead-Based Paint Hazard
Risk of Lead-Based Paint Hazard Owner-Occupied Renter-Occupied Number % Number %
Total Number of Units Built Before 1980 17,280 67% 12,090 68% Housing Units build before 1980 with children present 2,235 9% 1,150 7% Table 34 – Risk of Lead-Based Paint
Data Source: 2016-2020 ACS (Total Units) 2016-2020 CHAS (Units with Children present) Vacant Units
Suitable for
Rehabilitation
Not Suitable for
Rehabilitation
Total
Vacant Units 0 0 1,830
Abandoned Vacant Units 0 0 0
REO Properties 0 0 0
Abandoned REO Properties 0 0 0
Table 35 - Vacant Units
Data Source: 2016 – 2020 ACS 5-year Estimates
Need for Owner and Rental Rehabilitation
The majority (63% of owner-occupied and 58% of renter-occupied) of housing units in the City of Orange were built between the years 1950 – 1979. This is typical, in fact the largest share of America’s housing stock was built between 1975 and 1979 as the baby boomer generation reached peak home buying age. The City also has a number of historic homes in its Old Towne district. Older housing units require ongoing maintenance and rehabilitation for owners and renters alike. The City has a Mills Act Program that offers property tax reductions to owners who restore historic properties, however the City also recognizes the need for housing rehabilitation for lower income households and as per the Housing Element, would consider funding rehabilitation programs contingent on funding availability.

Estimated Number of Housing Units Occupied by Low or Moderate Income Families with LBP Hazards
According to 2016 – 2020 CHAS data shown above in Table 39, only 9% of owner-occupied and 7% of renter-occupied housing units built before 1980 are occupied by families with children present. While exact data is not available, it is safe to assume that these units are likely occupied by low to moderate income families as they are inexpensive to own and rent. The Orange County Health Care Agency operates the “Childhood Lead Poisoning Prevention” program for the entire county. This agency receives reports of lead-based paint poisoning from the State and provides 751
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case management services as well as educational programs to families affected by lead poisoning. In addition, Orange County has a new program to help families affected by lead poisoning. The California Department of Public Health, Lead Poisoning Prevention at no cost to the homeowner. Households that are eligible must live in a housing unit within Orange County constructed before 1978, be low-income, and have a child under the age of six.

Discussion
According to 2016 – 2020 ACS 5 – year estimate data, the City of Orange has a total of 45,157 housing units, 4.1%, or 1,830 of which are vacant.
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MA-25 Public and Assisted Housing – 91.210(b)
Introduction
The City of Orange does not own, operate, or develop public housing units. Instead, the Orange County Housing Authority (OCHA) administers the Section 8 Housing Choice Voucher program for the city. Since the City of Orange does not allocate funding to this program, it does not have access to the data collected through Section 8 administration.

The data presented in the following table is sourced from the federal Public and Indian Housing (PIH) Information Center and reflects information on the Orange County Housing Authority as a whole. Because the City of Orange does not have direct access to this dataset, it cannot verify or provide detailed insights beyond what is reported at the federal level.

Totals Number of Units
Program Type
Certificate Mod-Rehab Public
Housing
Vouchers
Total Project -based Tenant -based Special Purpose Voucher Veterans
Affairs
Supportive
Housing
Family
Unification
Program
Disabled
*
# of units vouchers
available 9,925 879 1,669 0
# of accessible units
*includes Non-Elderly Disabled, Mainstream One-Year, Mainstream Five-year, and Nursing Home Transition Table 36 – Total Number of Units by Program Type
Data Source: PIC (PIH Information Center)
Describe the supply of public housing developments:

The City of Orange does not develop or manage public housing. Public housing developments are typically owned and operated by local public housing authorities (PHAs), but the City of Orange does not have its own PHA. Instead, the Orange County Housing 753
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Authority (OCHA) oversees federally funded housing assistance programs, such as the Section 8 Housing Choice Voucher program, for eligible low-income households within the city.

Since OCHA primarily administers rental assistance rather than constructing or managing public housing developments, there is no dedicated public housing stock within the City of Orange. Affordable housing in the city is instead provided through private developments that receive federal, state, or local funding support, such as Low-Income Housing Tax Credit (LIHTC) projects, HUD- assisted housing, and other subsidized rental opportunities.

Given that the city does not directly operate public housing, it does not maintain detailed records on public housing units within its jurisdiction. Data on public and assisted housing in the area must be obtained through regional or federal sources such as OCHA or HUD databases.

Describe the number and physical condition of public housing units in the jurisdiction, including those that are participating in an approved Public Housing Agency Plan:

There is no public housing in the City of Orange. Given that the city does not directly operate public housing, it does not maintain detailed records on public housing units within its jurisdiction. Data on public and assisted housing in the area must be obtained through regional or federal sources such as OCHA or HUD databases. 754
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Public Housing Condition
Public Housing Development Average Inspection Score

N/A N/A
Table 37 - Public Housing Condition
Describe the restoration and revitalization needs of public housing units in the jurisdiction:

There is no public housing in the City of Orange. Given that the city does not directly operate public housing, it does not maintain detailed records on public housing units within its jurisdiction. Data on public and assisted housing in the area must be obtained through regional or federal sources such as OCHA or HUD databases.

Describe the public housing agency's strategy for improving the living environment of low- and moderate-income families residing in public housing:

There is no public housing in the City of Orange. Given that the city does not directly operate public housing, it does not maintain detailed records on public housing units within its jurisdiction. Data on public and assisted housing in the area must be obtained through regional or federal sources such as OCHA or HUD databases.

Discussion:

The city does not operate or own public housing units.
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MA-30 Homeless Facilities and Services – 91.210(c)
Introduction
Facilities and Housing Targeted to Homeless Households
Emergency Shelter Beds Transitional
Housing Beds
Permanent Supportive Housing
Beds
Year Round Beds
(Current & New)
Voucher /
Seasonal /
Overflow Beds
Current & New Current & New Under
Development
Households with Adult(s) and
Child(ren)
730 1,553 1,364 0 1,673
Households with Only Adults 0 0 0 0 0
Chronically Homeless Households 0 0 0 0 0
Veterans 0 0 217 0 0
Unaccompanied Youth 0 0 0 0 0
Table 38 - Facilities and Housing Targeted to Homeless Households 756
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Describe mainstream services, such as health, mental health, and employment services to the extent those services are used to complement services targeted to homeless persons In addition to targeted services for individuals experiencing homelessness, the City of Orange collaborates with various mainstream service providers to address health, mental health, and employment needs. These services are integral to a comprehensive approach, helping individuals achieve stability and self-sufficiency.

Health and Mental Health Services
Orange County Health Care Agency (HCA): HCA offers a range of health services, including mental health programs for adults with serious mental illnesses. The Supported Employment (SE) program serves residents aged 18 and older, assisting them in obtaining competitive or volunteer employment.

Be Well Orange County: A collaborative initiative aimed at establishing a coordinated system of mental health care, Be Well OC provides crisis stabilization units, outpatient services, and community-based support to individuals, including those experiencing homelessness.

Federally Qualified Health Centers (FQHCs): Facilities such as Serve the People and SOS Health Care offer accessible medical, dental, and mental health services to low-income and homeless individuals in Orange County.

Employment Services
Orange County Workforce Development Board (OCWDB): Through the America’s Job Centers of California (AJCCs), OCWDB provides job training, placement assistance, and career counseling to help individuals, including those experiencing homelessness, re-enter the workforce.

Goodwill of Orange County: Offers vocational training and employment services tailored to individuals facing barriers to employment, such as homelessness or disabilities.

Working Wardrobes: Provides job readiness programs, including resume building, interview preparation, and professional attire, to empower individuals transitioning into the workforce.

By integrating these mainstream services with targeted homeless assistance programs, the City of Orange and its partners strive to address the multifaceted challenges faced by individuals experiencing homelessness, promoting long-term stability and well-being.

List and describe services and facilities that meet the needs of homeless persons, particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth. If the services and facilities are listed on screen SP-40 757
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Institutional Delivery Structure or screen MA-35 Special Needs Facilities and Services, describe how these facilities and services specifically address the needs of these populations.

Emergency Shelter and Crisis Response
Emergency Shelter Beds: There are 730 emergency shelter beds available for both households with adults and children and households with only adults in Orange County. These facilities provide temporary shelter, case management, and access to supportive services aimed at transitioning individuals into permanent housing.

Cold Weather Shelters: Operated seasonally to provide additional emergency shelter during colder months.

Permanent Supportive Housing (PSH)
Permanent Supportive Housing for Adults and Families: There are currently 1,364 PSH beds designated for households with adults and children, with 1,673 additional beds under development. These units provide long-term housing with on-site case management and supportive services, targeting individuals who have experienced chronic homelessness.

Veteran Permanent Supportive Housing: There are 217 PSH beds specifically for veterans, providing stable housing and wraparound services for those who have served in the military and are experiencing homelessness.

Targeted Services by Population

1. Chronically Homeless Individuals and Families
 Be Well OC: Provides mental health and substance use treatment services, including crisis stabilization.
 Illumination Foundation: Offers temporary housing, medical respite care, and case management for those with serious health conditions.
 Mercy House: Provides permanent supportive housing and emergency shelter to individuals experiencing long-term homelessness.

2. Families with Children
 Family Assistance Ministries (FAM): Provides shelter, rental assistance, and case management for families.
 Pathways of Hope: Offers family shelter programs and rapid rehousing assistance. 758
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 Orange County United Ways United to End Homelessness Program: Focuses on housing placement and financial assistance for families in crisis.  Family Care Center: Provides emergency shelter, food, and services to families in need.

3. Veterans and Their Families
 Veterans Affairs (VA) Supportive Housing (VASH) Program: Offers housing vouchers and case management for homeless veterans.
 Tierney Center for Veteran Services: Provides employment support, housing assistance, and mental health services to veterans and their families.  U.S. Vets Inland Empire: Offers transitional and permanent supportive housing for homeless veterans.

4. Unaccompanied Youth
 Casa Youth Shelter: Provides temporary housing and crisis intervention for youth aged 12-17.
 Covenant House California Orange County: Offers housing and job training programs for homeless youth.
 Orangewood Foundation: Supports young adults aging out of foster care with transitional housing, education, and job support.

These services and facilities work in coordination to address the diverse needs of the homeless population, providing shelter, housing assistance, mental health support, employment services, and long-term stability. The City of Orange remains committed to leveraging these resources as part of the regional effort to reduce homelessness and provide sustainable solutions for vulnerable individuals and families.
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MA-35 Special Needs Facilities and Services – 91.210(d) Introduction
As of 2024, the City of Orange, California, has an estimated population of approximately 137,965 residents. According to data from the U.S. Census Bureau, 5% of the population under the age of 65, and 30.4% of those aged 65 and over, are living with disabilities. This equates to approximately 13,800 individuals with disabilities in the city.

To support these residents, the City of Orange offers a range of services and facilities aimed at enhancing the quality of life for individuals with special needs.

Services in the City of Orange
Regional Center of Orange County (RCOC): A private, nonprofit organization contracted by the State of California to coordinate lifelong services and support for individuals with developmental disabilities and their families. RCOC serves over 26,000 Orange County residents with conditions such as autism, epilepsy, cerebral palsy, and intellectual disabilities.

Comfort Connection Family Resource Center: Operated by RCOC, this center connects families who have children with special needs to community resources and support, free of charge. Most of the staff are parents of children with developmental disabilities, providing peer support and guidance.

Family Support Network: Offers a wide range of programs to provide resources for families of children with special needs or those at risk. Services include assistance with navigating special education, disability services, and access to assistive.

Countywide Services technology
In-Home Supportive Services (IHSS): Helps eligible aged, blind, and disabled individuals, allowing them to remain safely in their own homes. Services include personal care, household chores, and accompaniment to medical appointments.

Dayle McIntosh Center: Offers services and advocacy for persons with disabilities, promoting independent living and community integration.

Council on Aging Southern California: Provides programs such as the Long-Term Care Ombudsman, Health Insurance Counseling and Advocacy Program (HICAP), and the Financial Abuse Specialist Team (FAST) to support older adults and individuals with disabilities. 760
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These services, among others, are designed to enhance the quality of life for individuals living with disabilities in the City of Orange and throughout Orange County, ensuring access to necessary support and resources.

Including the elderly, frail elderly, persons with disabilities (mental, physical, developmental), persons with alcohol or other drug addictions, persons with HIV/AIDS and their families, public housing residents and any other categories the jurisdiction may specify, and describe their supportive housing needs
The City of Orange recognizes the critical need for affordable housing and quality care for its vulnerable populations, including:
 Frail elderly individuals
 Persons with disabilities
 Individuals living with addiction issues
 Persons with HIV/AIDS and their families
 Public housing residents
 Chronically homeless individuals and families
 Families with children
 Veterans and their families
 Unaccompanied youth
 Victims fleeing from domestic violence
Through strategic partnerships, affordable housing projects, and supportive services, the City of Orange continues to work toward sustainable housing solutions for these populations.

Supportive Housing and Services by Population
Frail Elderly Persons
In-Home Supportive Services (IHSS): Provides personal care, housekeeping, and medical accompaniment to help seniors remain in their homes.

Council on Aging Southern California: Offers programs such as the Long-Term Care Ombudsman and Health Insurance Counseling to support seniors.

Meals on Wheels: Ensures homebound seniors receive nutritious meals and wellness checks. 761
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Persons living with Disabilities
Dayle McIntosh Center: Assists individuals with disabilities in navigating housing options and maintaining sustainable living arrangements.

Regional Center of Orange County (RCOC): Coordinates lifelong services for individuals with developmental disabilities, including housing assistance.

Individuals living with Addiction
Orange County Health Care Agency (HCA): Provides behavioral health services, including substance use treatment and housing options for those in need.

Mercy House: Offers housing and comprehensive supportive services to various populations, including those overcoming substance addictions.

Persons living with HIV/AIDS and Their Families
Housing Opportunities for Persons with AIDS (HOPWA): Provides housing assistance and supportive services to individuals living with HIV/AIDS.

Radiant Health Centers: Offers housing resources and support services tailored for people affected by HIV/AIDS.

Public Housing Residents
Orange County Housing Authority (OCHA): Administers housing assistance programs, including the Section 8 Housing Choice Voucher Program.

Orange County Community Housing Corporation (OCCHC): Assists extremely low-income families in achieving self-sufficiency through housing and education.

Housing and Services for Homeless Individuals and Families The City of Orange participates in Orange County’s regional Continuum of Care (CoC) strategy to address homelessness. The 2024 Point-in-Time (PIT) Count identified 7,322 individuals experiencing homelessness countywide, with 369 sheltered and unsheltered individuals residing in the City of Orange.

Emergency Shelter and Crisis Response
730 emergency shelter beds are available for both households with adults and children and households with only adults in Orange County.
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Cold Weather Shelters operate seasonally to provide additional emergency shelter during colder months.

Permanent Supportive Housing (PSH)
1,364 permanent supportive housing (PSH) beds for adults and children, with 1,673 additional beds under development.
217 permanent supportive housing beds for veterans, offering stable housing and wraparound services.

Targeted Services for Homeless Populations
Chronically Homeless Individuals and Families: Be Well OC, Illumination Foundation, and Mercy House provide mental health care, temporary housing, and case management.

Families with Children: Family Assistance Ministries (FAM), Pathways of Hope, and Orange County United Way provide shelter, rental assistance, and family support programs.

Veterans and Their Families: Veterans Affairs (VA) Supportive Housing (VASH), Tierney Center for Veteran Services, and U.S. Vets offer housing, job training, and healthcare services.

Unaccompanied Youth: Casa Youth Shelter, Covenant House California, and Orangewood Foundation provide housing, job training, and life skills programs.

Affordable Housing for Seniors and Vulnerable Populations The City of Orange continues to support affordable housing developments aimed at serving vulnerable populations.

Recent and Upcoming Affordable Housing Projects
The Orion (Under Construction)
 166-unit affordable housing development for seniors (55+).  Includes eight permanent supportive housing units for seniors experiencing homelessness.
 Features a clubroom, fitness center, community garden, and secure parking.

Villa St. Joseph Apartments (Completed)
 18-unit permanent supportive housing complex for seniors experiencing homelessness.  Residents receive housing vouchers and supportive services from the Orange County Housing Authority (OCHA).
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Valencia Gardens
 62-unit affordable housing development
 Features a community room, computer room, and BBQ Pavilion and outdoor seating area
Katella Terrace
 74-unit affordable housing development for seniors (55+)  Features community garden, outdoor patio, and dog park Through these initiatives and ongoing collaborations with nonprofit organizations and service providers, the City of Orange remains dedicated to enhancing housing stability, expanding affordable housing options, and providing supportive services to its most vulnerable residents.

Describe programs for ensuring that persons returning from mental and physical health institutions receive appropriate supportive housing
The City of Orange, in collaboration with Orange County agencies and nonprofit organizations, offers several programs to ensure that individuals transitioning from mental and physical health institutions receive appropriate supportive housing. These initiatives aim to provide stable housing environments coupled with essential services to facilitate successful community reintegration.

1. Non-Elderly Disabled (NED) Program
The Orange County Housing Authority (OCHA) administers the NED program, which provides Section 8 Housing Choice Vouchers to non-elderly individuals with disabilities transitioning from nursing facilities to independent living. Eligible individuals are referred by partner agencies, such as the Dayle McIntosh Center.

2. Mainstream Voucher Program
This program offers rental assistance to non-elderly homeless individuals with disabilities who are exited, or have exited, from recuperative care or are frequent users of hospital emergency services. Referrals are made through the Orange County Health Care Agency (HCA) and the Coordinated Entry System (CES).

3. Illumination Foundations Recuperative Care Program
The Illumination Foundation provides recuperative care, offering safe bridge housing where individuals experiencing homelessness can recover after hospital discharge. The program includes medical oversight, intensive case management, behavioral health therapy, and 764
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substance use counseling, facilitating stabilization and connection to long-term housing solutions.

4. Housing and Residential Care Facilities
Orange County offers various housing options for individuals requiring behavioral health care who are homeless or at risk of homelessness. These include emergency housing, permanent supportive housing, and residential rehabilitation facilities. The Orange County Health Care Agency provides resources and shelter referrals for individuals experiencing homelessness with mental health needs.

5. Project-Based Voucher (PBV) Program
Under the PBV program, OCHA partners with property owners to provide rental assistance for specific units designated for individuals transitioning from institutions. Eligible individuals are referred through the Coordinated Entry System (CES). To access this program, individuals can contact 2-1-1 to be connected to a CES access point.

These programs collectively aim to support individuals returning from health institutions by providing stable housing and comprehensive services, thereby promoting successful reintegration into the community.

Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals.

91.315(e)
The City of Orange is committed to addressing the housing and supportive service needs of residents who are not homeless but have other special needs, including elderly persons, persons with disabilities, veterans, and families with young children. Over the next year, the city will implement various programs and policies to support these vulnerable populations, with a particular focus on Tenant-Based Rental Assistance (TBRA) and supportive housing initiatives.

Tenant-Based Rental Assistance (TBRA) Program Launch (2025) In 2025, the City of Orange launched a HOME-funded Tenant-Based Rental Assistance (TBRA) program to provide rental and security deposit assistance for eligible low-income households.

This program will help families secure safe, stable, and affordable housing while promoting housing choice. This program will help families secure safe, stable, and affordable housing while promoting housing choice.

TBRA Eligibility and Preferences
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To ensure that assistance reaches those with the greatest need, the city has identified the following preferences for HOME TBRA assistance:
 Current residents of the City of Orange intend to continue residing in the city.  Families with children under the age of 12.
 Veterans with a valid DD-214 (honorable discharge).
 Elderly people, as defined by the Social Security Administration as qualified for full retirement benefits.

Through the launch of the TBRA program in 2025, and enhancement of supportive services, the City of Orange continues to address the housing and service needs of special needs populations.

By prioritizing families, veterans, elderly individuals, and persons with disabilities, the city is working toward increasing housing stability, reducing cost burdens, and improving access to essential support services for its most vulnerable residents.

For entitlement/consortia grantees: Specify the activities that the jurisdiction plans to undertake during the next year to address the housing and supportive services needs identified in accordance with 91.215(e) with respect to persons who are not homeless but have other special needs. Link to one-year goals. (91.220(2)) The City of Orange actively participates in Orange County’s Continuum of Care (CoC), collaborating with regional agencies, service providers, and housing organizations to address housing and supportive service needs for both homeless individuals and those at risk of homelessness. While the CoC primarily focuses on homelessness response, the City of Orange also prioritizes housing and supportive services for non-homeless special needs populations, including frail elderly individuals, persons with disabilities, veterans, and families with children.

Over the next year, the city plans to expand its efforts by launching the HOME Tenant-Based Rental Assistance (TBRA) program in 2025, which will provide rental and security deposit assistance to eligible households, ensuring greater access to stable, affordable housing.

Additionally, the city continues to support the development of affordable and supportive housing projects, such as The Orion senior housing community and Villa St. Joseph Apartments for elderly individuals experiencing homelessness. By maintaining its commitment to fair housing practices, rental assistance, and social service coordination, the City of Orange aims to provide long-term housing solutions and wraparound services that promote stability and self-sufficiency for its vulnerable residents.
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MA-40 Barriers to Affordable Housing – 91.210(e)
Negative Effects of Public Policies on Affordable Housing and Residential Investment The City of Orange, like many jurisdictions in California, faces significant challenges in developing and maintaining affordable housing options due to land constraints, zoning regulations, and high development costs. While the City recognizes the importance of providing affordable housing opportunities for low- and moderate-income residents, various public policies, both local and state impact the feasibility of affordable housing development. This chapter outlines the negative effects of public policies on affordable housing and residential investment, particularly regarding land availability, zoning restrictions, community opposition, and regulatory challenges.

Limited Land Availability for Residential Development
One of the most significant barriers to affordable housing development in the City of Orange is the scarcity of vacant land. With limited available land zoned for residential use, identifying suitable sites for affordable housing projects is increasingly difficult. The high cost of land further exacerbates this issue, making it challenging for developers to produce affordable housing units that are financially viable. The limited land supply also restricts the City’s ability to meet state- mandated housing goals, creating further pressure on policymakers and developers.

Zoning Regulations and Historic District Constraints
In addition to land scarcity, the City of Oranges historic district neighborhoods have unique zoning regulations and development requirements that further constrain affordable housing development. These regulations preserve the architectural and cultural character of historic neighborhoods but limit the ability to construct new housing units or modify existing structures to accommodate increased residential density. While these measures serve an important preservation purpose, they reduce opportunities for expanding the City’s housing stock, particularly for low- and very low-income households.

Public Opposition to Affordable Housing Development
Another barrier to fair housing in the City of Orange is community resistance to affordable housing projects. Even when the city approves high-density or income-restricted housing developments, they frequently face strong public opposition during the review process. Many residents express concerns related to neighborhood character, property values, traffic congestion, and infrastructure strain, which can delay or even derail projects that would otherwise help meet affordable housing needs. The presence of Not in My Backyard (NIMBY) attitudes remains a significant challenge, limiting the City’s ability to expand housing options for low- and moderate-income residents.

State-Mandated Housing Goals and Policy Adjustments
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In response to Californias ongoing housing crisis, the state has introduced new legislation and funding mechanisms to facilitate residential development and encourage local governments to streamline housing projects. The City of Orange is currently in the process of updating its Housing Element, which includes a Regional Housing Needs Allocation (RHNA) requirement of 3,900 new housing units over the next eight years. Despite efforts to revisit zoning policies and development programs, the high cost of land and construction remains a significant obstacle to fulfilling these mandates.

Furthermore, the City has incorporated new state laws on accessory dwelling units (ADUs), reducing regulatory burdens on homeowners and property managers to develop ADUs as a means of increasing the housing supply. While these changes represent progress, ADUs alone are not enough to meet the demand for affordable housing, particularly for very low-income households.

City Efforts to Promote Affordable Housing Development
Despite these barriers, the City of Orange has implemented several initiatives to encourage affordable housing development:
 Allocation of HOME and Local Funds: The City continues to allocate HOME Investment Partnerships (HOME) funds and other local funding sources to support the development of affordable housing projects.
 Density Bonus Program: Developers are offered density bonuses and waivers for certain development standards (provided they do not violate the building code) to encourage higher-density residential projects.
 Streamlined Approval Processes: The City has revised its land use policies to align with state-mandated housing development reforms, making it easier to expedite the approval process for certain residential projects.

The development of affordable housing in the City of Orange is a complex challenge impacted by land scarcity, zoning regulations, high development costs, community opposition, and state- mandated housing requirements. While the City is actively working to address these barriers through policy adjustments, financial incentives, and regulatory reforms, overcoming these challenges will require continued collaboration with state agencies, developers, and community stakeholders. The expansion of affordable housing options remains a critical priority to ensure fair housing opportunities for all residents, particularly low- and moderate-income households, seniors, and persons with disabilities.
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MA-45 Non-Housing Community Development Assets – 91.215 (f) Introduction
A strong local economy and workforce are essential components of a thriving community. To assess the economic landscape, workforce composition, and educational attainment of residents in the City of Orange, this section analyzes business activity, employment trends, labor force participation, and educational attainment using data from multiple sources, including:
 2016-2020 American Community Survey (ACS) 5-Year Estimates, which provide insights into business activity, workforce demographics, occupations by sector, travel time to work, and educational attainment by age and employment status.  2020 Longitudinal Employer-Household Dynamics (LEHD) business activity jobs data, which highlights employment distribution across industries and key employment centers in the city.  Median earnings data from the past 12 months, which offers a snapshot of income levels across different educational backgrounds and occupational sectors.

By analyzing these datasets, the City of Orange can better understand employment trends, workforce mobility, and economic challenges, which can help guide non-housing community development initiatives, workforce training programs, and local business support efforts.

Economic Development Market Analysis
Over the past five years, Orange County’s economy has demonstrated remarkable resilience, navigating challenges such as the global pandemic and supply chain disruptions. The region has maintained a strong economic foundation, characterized by low inflation and unemployment rates, which have consistently remained below national averages. In 2023, job growth in Orange County slightly surpassed the national average, underscoring the area’s robust economic health.

Despite this positive trajectory, a notable challenge has emerged: the number of jobs created in most business sectors exceeds the available workforce. This imbalance has led to a tight labor market, compelling employers to seek talent beyond county borders. As the economy continues to recover and expand, particularly in sectors such as construction, logistics, retail trade, and financial services, 769
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the demand for skilled workers remains high. Projections suggest that while economic activity is expected to accelerate, it may take up to five years to fully regain all jobs lost during the early stages of the pandemic.

Business Activity
Business by Sector Number of
Workers
Number of Jobs Share of Workers
%
Share of Jobs
%
Jobs less workers
%
Agriculture, Mining, Oil & Gas Extraction 407 110 1 0 -1 Arts, Entertainment, Accommodations 7,991 9,297 14 8 -5 Construction 4,021 11,774 7 11 4
Education and Health Care Services 8,836 19,833 15 18 3 Finance, Insurance, and Real Estate 4,583 8,447 8 8 0
Information 1,385 560 2 1 -2
Manufacturing 5,510 7,232 10 7 -3
Other Services 1,963 3,347 3 3 0
Professional, Scientific, Management Services 6,671 11,799 12 11 -1 Public Administration 0 0 0 0 0
Retail Trade 5,835 8,904 10 8 -2
Transportation and Warehousing 1,588 1,363 3 1 -2
Wholesale Trade 3,394 4,710 6 4 -2
Total 52,184 87,376 -- -- --
Table 39 - Business Activity
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Labor Force
Total Population in the Civilian Labor Force 75,025
Civilian Employed Population 16 years and
over 71,690
Unemployment Rate 4.47
Unemployment Rate for Ages 16-24 12.12
Unemployment Rate for Ages 25-65 2.88
Table 40 - Labor Force
Data Source: 2016-2020 ACS
Occupations by Sector Number of People
Management, business and financial 21,895
Farming, fisheries and forestry occupations 3,255
Service 6,080
Sales and office 16,475
Construction, extraction, maintenance and
repair 4,945
Production, transportation and material
moving 3,170
Table 41 – Occupations by Sector
Data Source: 2016-2020 ACS
Travel Time
Travel Time Number Percentage
< 30 Minutes 37,602 59%
30-59 Minutes 21,729 34%
60 or More Minutes 4,823 8%
Total 64,154 100%
Table 42 - Travel Time
Data Source: 2016-2020 ACS
Education:

Educational Attainment by Employment Status (Population 16 and Older) Educational Attainment In Labor Force
Civilian Employed Unemployed Not in Labor
Force
Less than high school graduate 5,865 305 3,435
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Educational Attainment In Labor Force
Civilian Employed Unemployed Not in Labor
Force
High school graduate (includes
equivalency) 10,070 305 3,560
Some college or Associate's degree 17,020 655 4,485
Bachelor's degree or higher 25,600 915 3,430
Table 43 - Educational Attainment by Employment Status
Data Source: 2016-2020 ACS
Educational Attainment by Age
Age
18–24 yrs 25–34 yrs 35–44 yrs 45–65 yrs 65+ yrs
Less than 9th grade 165 500 1,240 2,610 1,165
9th to 12th grade, no diploma 1,220 1,585 1,160 2,505 1,345 High school graduate, GED, or
alternative 4,835 4,260 3,210 6,460 3,555
Some college, no degree 7,270 4,700 3,795 8,200 4,595
Associate's degree 755 1,650 1,115 2,700 1,580
Bachelor's degree 1,430 7,695 5,185 8,420 3,540
Graduate or professional degree 70 2,240 2,245 4,170 3,415 Table 44 - Educational Attainment by Age
Data Source: 2016-2020 ACS
Educational Attainment – Median Earnings in the Past 12 Months Educational Attainment Median Earnings in the Past 12 Months Less than high school graduate 25,976
High school graduate (includes equivalency) 35,560
Some college or Associate's degree 46,919
Bachelor's degree 62,963
Graduate or professional degree 87,518
Table 45 – Median Earnings in the Past 12 Months
Data Source: 2016-2020 ACS
Based on the Business Activity table above, what are the major employment sectors within your jurisdiction?
The City of Orange has a diverse economy, with several key employment sectors driving local job growth. The education and healthcare services sector are the largest employer, with 8,836 772
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workers, reflecting the presence of major institutions such as Chapman University and UCI Health. Following closely, the arts, entertainment, and accommodations sector employs 7,991 workers, supported by the city’s hotels, restaurants, and entertainment venues, which benefit from Orange’s proximity to major tourist attractions like Disneyland and Anaheim’s resort district. The retail trade sector accounts for 5,835 workers, highlighting the city’s vibrant commercial centers, including The Outlets at Orange and Old Towne Orange’s shopping district.

Meanwhile, manufacturing remains a key industry, employing 5,510 workers, driven by aerospace, food production, and specialized manufacturing firms. Overall, the City of Orange has a total workforce of 52,184 employees, contributing to a balanced economy with opportunities across multiple industries.

Describe the workforce and infrastructure needs of the business community:

The business community in the City of Orange relies on a skilled workforce and modern infrastructure to sustain growth and remain competitive. As the local economy continues to expand, businesses face challenges in workforce availability and infrastructure capacity that must be addressed to maintain economic momentum.

Workforce Needs
The City of Orange has a strong labor market, but job creation is outpacing the number of available workers in many sectors, particularly in healthcare, education, retail, and hospitality.

Key workforce challenges include:

Skilled Labor Shortages: Industries such as healthcare, manufacturing, and technology require workers with specialized skills. Expanding vocational training programs and partnerships with local colleges and universities can help bridge skill gaps.

Cost of Living and Workforce Retention: High housing costs in Orange County make it difficult for many workers to live near their jobs, leading to longer commutes and labor shortages in certain industries.

Entry-Level and Service Sector Employees: The hospitality, retail, and service industries require a steady pipeline of entry-level workers, but competition with neighboring cities and wage pressures make recruitment challenging.

Infrastructure Needs
Businesses in the City of Orange rely on efficient transportation, digital connectivity, and commercial space availability to operate effectively. Key infrastructure needs include:
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Transportation and Mobility: With rising traffic congestion and long commute times, businesses need improvements in public transit options, road maintenance, and parking availability.

Expanding Metrolink services, bus routes, and last-mile transportation solutions can help workers access job centers more efficiently.

Technology and Broadband Expansion: Reliable high-speed internet and digital infrastructure are critical for businesses, particularly in professional services, education, and healthcare. Expanding fiber-optic networks and 5G connectivity will support business growth and remote work opportunities.

Commercial and Industrial Space: As demand for manufacturing, logistics, and office space increases, businesses require affordable and well-located commercial properties. Encouraging adaptive reuse of underutilized spaces and promoting mixed-use developments can provide more options for businesses to expand.

Addressing these workforce and infrastructure needs is essential for business retention, economic growth, and long-term sustainability in the City of Orange. Through strategic planning, workforce development programs, and infrastructure investments, the city can continue to support a dynamic and competitive business environment.

Describe any major changes that may have an economic impact, such as planned local or regional public or private sector investments or initiatives that have affected or may affect job and business growth opportunities during the planning period. Describe any needs for workforce development, business support or infrastructure these changes may create.

The City of Orange is poised for significant economic growth due to several planned public and private sector investments and initiatives. These developments are expected to enhance job creation and business expansion opportunities in the coming years.

Public Sector Investments:

OC Streetcar Project: The OC Streetcar, currently under construction, is a significant public transportation project that will connect the City of Orange with Santa Ana and Garden Grove.

Scheduled to begin operations in August 2025, this streetcar line is anticipated to improve regional connectivity, reduce traffic congestion, and stimulate economic activity along its route.

Enhancing accessibility is expected to attract new businesses and support existing ones, thereby contributing to job growth in the area.

Private Sector Investments:

Healthcare Corridor Development: The City of Orange is home to a robust healthcare sector, with several prominent hospitals and medical centers. Ongoing investments in healthcare facilities are 774
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expected to create additional employment opportunities and attract related businesses to the area.

These initiatives are likely to create a demand for a skilled workforce and necessitate infrastructure enhancements. To address these needs, the City of Orange may consider implementing workforce development programs focused on sectors experiencing growth, such as healthcare and transportation. Collaborations with local educational institutions could facilitate training programs aligned with industry requirements. Additionally, infrastructure improvements, particularly in transportation and digital connectivity, will be essential to support the anticipated economic expansion and ensure sustainable development.

How do the skills and education of the current workforce correspond to employment opportunities in the jurisdiction?
The City of Orange has a diverse and educated workforce that largely aligns with the city’s major employment sectors, including education, healthcare, arts, entertainment, accommodations, retail trade, and manufacturing. However, differences in educational attainment and income levels reveal potential workforce development needs.

Educational Attainment and Workforce Participation
According to the most recent data, the labor force in the City of Orange consists of individuals with varying levels of education and employment status:

High School Diploma or Equivalency
 10,070 civilian employed individuals
 305 unemployed individuals
 3,560 not in the labor force
Some College or associate's degree
 17,020 civilian employed individuals
 655 unemployed individuals
 4,485 not in the labor force
Bachelor’s Degree or Higher
 25,600 civilian employed individuals
 915 unemployed individuals
 3,430 not in the labor force
The high percentage of individuals with some college or higher education supports the demand for skilled labor in education, healthcare, and professional services. However, there is a significant number of high school graduates and individuals with some college education who are unemployed or not in the labor force, suggesting the need for job training programs and vocational education.
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Median Earnings by Educational Attainment
Educational attainment significantly impacts income levels, reflecting the demand for higher- skilled jobs in the region:
 Less than High School Diploma – $25,976
 High School Graduate – $35,560
 Some College or associate’s degree – $46,919
 Bachelor’s Degree – $62,963
 Graduate or Professional Degree – $87,518
These earnings indicate that higher education and specialized training lead to better job opportunities and higher wages in the city.

Workforce Development and Economic Implications
While the City of Orange has a well-educated workforce, there is a clear need for vocational training, workforce development programs, and industry-aligned skill-building initiatives to support individuals with a high school diploma or some college education. The Orange County Workforce Development Board (OCWDB) plays a vital role in bridging these gaps by collaborating with local businesses and educational institutions to ensure that workers are equipped with relevant skills for the evolving job market.

Additionally, as job creation continues to outpace workforce availability, initiatives focused on upskilling workers, expanding trade programs, and increasing job placement services will be crucial for maintaining a strong labor market and supporting business growth in the City of Orange.

Describe any current workforce training initiatives, including those supported by Workforce Investment Boards, community colleges and other organizations. Describe how these efforts will support the jurisdiction's Consolidated Plan.

The City of Orange, in collaboration with various organizations, offers several workforce training initiatives to enhance the skills of its residents and align them with local employment opportunities.
 Orange County Workforce Development Board (OCWDB): The OCWDB designs and implements programs for businesses, adult job seekers, dislocated workers, and young adults. By partnering with educational institutions, businesses, labor organizations, and economic development entities, the OCWDB prepares workers to meet the demands of Orange County’s growing economy.
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 OC Workforce Solutions: As an American Job Center of California, OC Workforce Solutions provides comprehensive, no-cost employment and training services for job seekers.

Services include career counseling, job search assistance, and access to training programs aimed at enhancing employability in various sectors.
 UpSkill OC by Orange County United Way: This initiative supports candidates by enrolling them in training programs that equip them with skills sought by employers in Orange County. By focusing on in-demand middle-skills jobs, UpSkill OC connects participants with sustainable employment opportunities.
 READY S.E.T. OC: Managed by the OCWDB, this program offers high-quality services for young adults, including career exploration, educational support, and skills training in in- demand industries and occupations. The goal is to guide participants toward good jobs along career pathways or enrollment in post-secondary education.

These initiatives align with the Citys Consolidated Plan by addressing the need for workforce development and business support. By enhancing the skills of the local workforce, these programs contribute to economic development, reduce unemployment, and support the growth of local businesses, thereby fostering a more prosperous and resilient community.

Does your jurisdiction participate in a Comprehensive Economic Development Strategy (CEDS)?
The City does not participate in a Comprehensive Economic Development Strategy. Orange primarily allocates CDBG funds to public services and improvements to public facilities.

If so, what economic development initiatives are you undertaking that may be coordinated with the Consolidated Plan? If not, describe other local/regional plans or initiatives that impact economic growth.

Economic development is a top priority for the City of Orange, and one of the main goals outlined in this Consolidated Plan. The City intends to address this through a variety of community-based solutions and activities. The City will be exploring and developing options for strategy and programs in 2025 and 2026.

In addition, Orange County Business Council is an active organization that partners with businesses, government, and academia to promote economic development in Orange County.

They research economic indicators and publish several reports including workforce indicators report and community indicators report. The City’s Economic Development Manager is tasked with interfacing with the local businesses in Orange to address any issues related to land use, waste collection systems, and signage.
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Discussion
The City of Orange has a diverse and well-educated workforce that largely aligns with its key employment sectors, including education, healthcare, arts, entertainment, accommodations, retail trade, and manufacturing. With a total workforce of 52,184 employees, the city benefits from a strong labor market. However, job creation is outpacing workforce availability, particularly in specialized fields such as healthcare and advanced manufacturing. Educational attainment plays a significant role in employment opportunities and earnings, with median salaries increasing as education levels rise—ranging from $25,976 for individuals with less than a high school diploma to $87,518 for those with graduate or professional degrees. Workforce training initiatives, such as those supported by the Orange County Workforce Development Board (OCWDB), local community colleges, and UpSkill OC, are actively working to bridge skill gaps and connect workers to high-demand industries. Additionally, the city faces workforce challenges related to housing affordability, long commutes, and skills mismatches, which impact recruitment and retention across industries. Moving forward, investments in vocational training, workforce development programs, and infrastructure improvements will be essential to sustaining economic growth and supporting the City’s Consolidated Plan goals. 778
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MA-50 Needs and Market Analysis Discussion
Are there areas where households with multiple housing problems are concentrated? (include a definition of "concentration")
The City does not have specific geographic areas with a concentration of households that have multiple housing problems, nor does it have a definition for “concentration”.

Are there any areas in the jurisdiction where racial or ethnic minorities or low-income families are concentrated? (include a definition of "concentration") The City of Orange has few predominately Hispanic neighborhoods. These geographic areas include Central Orange (near Glassell Street and Katella Avenue), El Modena, and Olive (near Lincoln Avenue and Batavia Street). These neighborhoods have older housing units that make these areas less expensive for low-income residents.

What are the characteristics of the market in these areas/neighborhoods? While these areas may have more affordable housing and a different mix of retail businesses, they do not differ significantly from the rest of the city.

Are there any community assets in these areas/neighborhoods? These areas are near parks, libraries, and schools. These community assets promote social equity for these neighborhoods.

Are there other strategic opportunities in any of these areas? Any strategic opportunities would include the redevelopment of existing properties and the repair and upgrade of existing infrastructure.
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MA-60 Broadband Needs of Housing occupied by Low- and Moderate-Income Households - 91.210(a)(4), 91.310(a)(2)
Describe the need for broadband wiring and connections for households, including low- and moderate-income households and neighborhoods.

Access to reliable high-speed internet is essential for all residents of the City of Orange, particularly for low- and moderate-income households. Broadband connectivity enables participation in educational programs, access to healthcare services, and economic opportunities, all of which are critical components of a sustainable and equitable community.

In the City of Orange, several broadband providers offer a range of services to meet the diverse needs of the community:
 AT&T Fiber: Offers fiber-optic internet with speeds up to 5 Gbps, providing extensive coverage in Orange.
 Spectrum: Provides cable internet services with download speeds up to 1 Gbps, covering approximately 94% of Orange residents.
 Google Fiber: Offers high-speed fiber-optic internet services with speeds up to 2 Gbps in select areas of Orange County.
 Frontier Communications: Provides fiber-optic internet services with plans offering symmetrical upload and download speeds up to 7 Gbps, available in various parts of California, including Orange.
 Cox Communications: Offers cable internet services with download speeds up to 1 Gbps in select areas of Orange.
 Verizon: Provides 5G mobile and home internet services, offering high-speed connectivity and reliable coverage.

Despite the availability of these services, challenges persist in ensuring that all households, especially those with low and moderate incomes, have access to affordable and reliable broadband. Addressing these challenges is crucial for promoting digital equity and supporting the city’s sustainability goals.

The City consulted with a broadband stakeholder, Verizon, in order to gain insight on the broadband needs of the City. Orange is well-known for its downtown historic district, also dubbed ‘Old Towne’ or ‘The Circle’, boasting original structures built after the City’s incorporation with distinct Victorian and Spanish Colonial Revival architectural styles. This one-square mile district is a cherished community hub that preserves Orange’s rich history. However, preserving the architectural integrity of this area has proven to be a challenge in delivering high-speed internet 780
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and mobile coverage. The largest Nationally Registered Historic District in California contains the remnants of railroad tracks and old cobblestone roads. This mitigates the installation of fiber broadband wiring in the ground, a necessary part of delivering internet and mobile service. In fact, any projects in that area must adhere to strict historic preservation standards. These standards ensure that any infrastructure changes, including broadband installation, do not compromise the architectural integrity or historical significance of the area. Projects often require evaluations by historic preservation professionals and compliance with design standards specific to the district. Verizon’s Community and Government Affairs department has met with City staff and representatives to discuss this issue and while there are no current projects underway, the City will continue to partner with providers and stakeholders to ensure that the needs of the community are being met.

By integrating broadband infrastructure development into its sustainability initiatives, the City of Orange can enhance digital inclusion, providing all residents with the tools necessary to thrive in a connected society.

Describe the need for increased competition by having more than one broadband Internet service provider serve the jurisdiction.

Access to reliable and affordable high-speed internet is essential for economic development, education, healthcare, and overall quality of life. While the City of Orange has several broadband providers, the market remains dominated by a few major companies, leading to limited competition in certain areas. This lack of competition can result in higher prices, slower speeds, and fewer service options, disproportionately impacting low- and moderate-income households who rely on affordable broadband for remote work, virtual learning, and telehealth services.

Challenges of Limited Broadband Competition

1. High Costs and Limited Pricing Options – In areas where only one or two broadband providers operate, residents and businesses face higher prices due to a lack of competitive pricing. Increased competition would encourage providers to offer better pricing and more flexible service plans to attract customers.

2. Inconsistent Service Quality – Some neighborhoods, particularly those with lower population densities, experience slower speeds and network congestion. More competition would incentivize providers to improve infrastructure and service quality to remain competitive.

3. Barriers to Digital Inclusion – Limited broadband options widen the digital divide, especially for low- and moderate-income households. Expanding competition could lead to more affordable service plans and digital equity programs, ensuring that all residents have access to reliable high-speed internet.
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4. Limited Investment in Fiber-Optic Expansion – Some areas of the City of Orange lack fiber-optic broadband, which provides faster speeds and greater reliability compared to traditional cable or DSL. Increased competition would encourage providers to invest in fiber-optic expansion and improve service availability across all neighborhoods.

Encouraging Broadband Expansion and Competition
To address these challenges, the City of Orange can explore public-private partnerships, policy incentives, and infrastructure grants to attract new broadband providers. The city can also advocate for state and federal funding to support broadband expansion projects in underserved areas. By fostering an environment where multiple providers compete for customers, residents and businesses will benefit from more affordable pricing, faster speeds, and enhanced digital access, strengthening the city’s economic development and sustainability goals.

Furthermore, in an increasingly digital world there is an ever-growing need for wireless internet and mobile connectivity, this need is especially exacerbated for individuals who are low- or moderate-income as they may struggle to secure access to reliable coverage due to a lack of affordability or access to necessary devices. Verizon addresses this need in the City of Orange, and elsewhere, through programs such as Total Wireless and SafeLink, offering discounted internet and phone services to eligible families and individuals. These initiatives ensure affordable connectivity, helping households stay connected to essential resources and opportunities.
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MA-65 Hazard Mitigation - 91.210(a)(5), 91.310(a)(3)
Describe the jurisdiction’s increased natural hazard risks associated with climate change.

The City of Orange is increasingly vulnerable to natural hazards exacerbated by climate change, necessitating proactive measures to enhance community resilience. Rising heatwaves, prolonged droughts, increased wildfire risks, and flooding hazards threaten public health, infrastructure, and economic stability. Projections indicate a significant rise in extreme heat days, with temperatures exceeding 93.9°F increasing from an average of 7 days annually in 1990 to an anticipated 25 days per year by 2050. Drought conditions continue to strain the Santa Ana watershed, which has experienced drought in 73% of weeks since 2000, impacting both water supply and quality. Approximately 35% of buildings in Orange face significant wildfire risks, with the frequency of extreme fire weather days projected to increase through 2050, while 39% of buildings are at risk of flooding, with a 29% chance of experiencing severe flood damage over 30 years due to intensified rainfall patterns and potential sea-level rise.

Recognizing these challenges, the City of Orange has developed a comprehensive Sustainability Plan in collaboration with Chapman University, aimed at identifying sources of greenhouse gas emissions and implementing strategies to mitigate climate-related hazards. Additionally, the city’s Safety Element, within its General Plan, outlines specific wildfire mitigation and prevention strategies, particularly in areas designated as Very High Fire Hazard Severity Zones (VHFSZ), ensuring a structured approach to wildfire resilience.

Mitigation and Prevention Strategies for Wildfire Risks To minimize wildfire risks and enhance safety, the City has implemented key mitigation measures:
 Vegetation Management: The city enforces defensible space regulations, requiring the clearance of flammable vegetation around properties to reduce fuel loads near structures.
 Building Codes and Standards: Fire-resistant building materials and construction methods are mandated for new developments and significant remodels within VHFSZs to strengthen structural resilience.
 Infrastructure Improvements: Collaboration with utility providers ensures power line maintenance and upgrades to minimize ignition sources and enhance system resilience.

In addition to mitigation, the City employs prevention strategies to enhance community preparedness and reduce fire risks:
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Consolidated Plan ORANGE 85
OMB Control No: 2506-0117 (exp. 09/30/2021)
 Public Education and Outreach: The city conducts educational programs to inform residents about wildfire risks, preparedness measures, and evacuation procedures, fostering community awareness and readiness.
 Emergency Evacuation Planning: The development of detailed evacuation routes and procedures ensures efficient and safe evacuations during wildfire emergencies, with regular drills and updates to response plans.
 Interagency Collaboration: The City actively participates in mutual aid agreements and collaborates with local, state, and federal agencies, including the Orange County Fire Authority (OCFA), to coordinate wildfire prevention and emergency response efforts.

By integrating climate resilience strategies, wildfire mitigation efforts, and sustainability initiatives, the City of Orange seeks to protect its residents, infrastructure, and natural resources from the escalating risks associated with climate change. These ongoing efforts reflect the City’s commitment to adapting to environmental challenges and building a safer, more resilient community for future generations.

Describe the vulnerability to these risks of housing occupied by low- and moderate-income households based on an analysis of data, findings, and methods.

The areas of the City that are vulnerable to wildfires are located on the eastern part of the city and do not include low- and moderate-income neighborhoods. 784
Consolidated Plan ORANGE 86
OMB Control No: 2506-0117 (exp. 09/30/2021)
Strategic Plan
SP-05 Overview
Strategic Plan Overview
The City developed its strategic plan based on high priority community needs identified during the community outreach process. The City conducted:
 Needs assessment survey at City sponsored events including National Night Out, Treats In the Streets, Tree Lighting, El Modena Neighborhood outreach day, and via the City’s website and public counters
 Housing Summit with stakeholders that included non-profits, affordable housing developers, housing advocacy groups, and continuum of care providers  Scheduled three public hearings before the CDBG Program Advisory Body and the City Council to gain public input on community needs.

The City also participated in a regional Analysis of Impediments to Fair Housing covering Orange County as a whole in which a total of six community meetings were held in March 2025 to gather public input on the fair housing issues impacting residents of Orange County. Moreover, four one-on-one interviews and two focus groups were conducted in January and February 2025.

Approximately 78 organizations that provide fair housing services throughout Orange County were invited to participate and offer insight on the needs of the community.

A total of 180 respondents participated in the City survey, 27% chose affordable rental housing as the top housing program the City should be considered. Demographic information was also collected to determine whether participant involvement such as city residents, work for or own a business in the city or represent a housing agency, social service agency or a non-profit.

For this reason, the strategic plan for CDBG and HOME funds is not only based on the survey data but also on grant applications for projects received in the past. Both the survey data and historic funding allocations guide the City to follow a strategic funding allocation plan that will result in a greater benefit to the community while meeting the regulatory and statutory requirements. 785
Consolidated Plan ORANGE 87
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-10 Geographic Priorities – 91.215 (a)(1)
Geographic Area
1 Area Name: City of
Orange
Area Type: City of
Orange
Other Target Area Description: City of
Orange
HUD Approval Date:
% of Low/ Mod:

Revital Type:

Other Revital Description:

Identify the neighborhood boundaries for this target area.

Include specific housing and commercial characteristics of this target area.

How did your consultation and citizen participation process help you to identify this neighborhood as a target area?
Identify the needs in this target area.

What are the opportunities for improvement in this target area? Are there barriers to improvement in this target area?
Table 46 - Geographic Priority Areas
General Allocation Priorities
Describe the basis for allocating investments geographically within the jurisdiction (or within the EMSA for HOPWA)
The City allocates CDBG and HOME funds to projects or programs located in CDBG-eligible areas.

These areas are determined based on the census tracts and block groups published by HUD that have more than 51% of low- and moderate-income households. Moreover, the City allocated CDBG funding to programs that provide direct benefit to low and moderate income households regardless of where they reside in the City. The City also provides subrecipients with an eligibility map that denotes all the areas within the city with a median income for eligibility. 786
Consolidated Plan ORANGE 88
OMB Control No: 2506-0117 (exp. 09/30/2021)
The map below outlines the low- and moderate-income areas in the City of Orange that are eligible for CDBG funding. To reflect an accurate representation of current eligible areas, the map was created with 2022 Census Data and reflects both eligible Census Tracts as well as eligible Block Groups.

Figure 1 Low- and Moderate-Income Areas
Source: 2022 Census Data
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Consolidated Plan ORANGE 89
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-25 Priority Needs - 91.215(a)(2)
Priority Needs
1 Priority Need Name Economic Development
Priority Level High
Population Extremely Low
Low
Moderate
Geographic Areas
Affected
City-wide
Associated Goals Economic Development
Description City Council identified as a high priority
Basis for relative
priority
City Council identified priority
2 Priority Need
Name
Affordable Housing
Priority Level High
Population Extremely Low
Low
Moderate
Families with Children
Individuals
Families with Children
Geographic Areas
Affected
City-wide
Associated Goals Affordable Housing
Description Data collected from the needs assessment survey indicated affordable housing as a high priority need.

Basis for
Relative Priority
Needs assessment survey.
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Consolidated Plan ORANGE 90
OMB Control No: 2506-0117 (exp. 09/30/2021)
3 Priority Need
Name
Homelessness
Priority Level High
Population Extremely Low
Families with
Children Elderly
Chronic
Homelessness
Individuals
Families with Children
Geographic
Areas Affected
City-wide
Associated Goals Homelessness
Description Homelessness is a high priority need based on the needs assessment survey.

Basis for
Relative Priority
Needs assessment survey
4 Priority Need
Name
Community Development
Priority Level High
Population Extremely Low
Low
Moderate
Families with Children Elderly
Geographic
Areas Affected
City-wide
Associated
Goals
Community Development
Description Public services and public facilities improvement is a high priority need based on the comments received during the community outreach process.

Basis for
Relative Priority
Needs Assessment
Table 47 – Priority Needs Summary
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Consolidated Plan ORANGE 91
OMB Control No: 2506-0117 (exp. 09/30/2021)
Narrative (Optional)
Priority needs are based on input collected from the community outreach process and the types of project proposals submitted for CDBG and HOME funds. The 2025-2029 Consolidated Plan and FY 2025- 2026 Action Plan identifying housing, homelessness and community development projects as high priority needs to be pursued in order to provide affordable housing as well as community services and public facility improvements for low and moderate income residents.
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Consolidated Plan ORANGE 92
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-30 Influence of Market Conditions – 91.215 (b)
Influence of Market Conditions
Affordable
Housing Type
Market Characteristics that will influence
the use of funds available for housing type
Tenant Based
Rental Assistance
(TBRA)
The City has launched its TBRA program using HOME funds to provide assistance to eligible households with one-time security deposit and utility deposit assistance when moving into a new housing unit. Many low- to moderate-income households live paycheck to paycheck and therefore find it difficult to come up with the funds for a deposit advance in order to move into a new unit. Therefore, this program aims to mitigate this barrier by providing assistance in the form of a grant that will be paid directly to the landlord.

TBRA for Non-
Homeless Special
Needs
The City’s security and utility deposit TBRA program is administered using HOME funds. For this program, the City has established the following preferences:

1. Current City of Orange resident with intention of
remaining in the City of Orange;

2. Families with children;

3. 3. Veterans with honorable discharge; and

4. 4. Elderly as defined by retirement or social security requirements.

The City recognizes that special needs populations such as veterans and the elderly are more susceptible to fair housing discrimination and barriers, and therefore always seeks to provide comprehensive services and assistance that properly address community needs.

New Unit
Production
According to the City’s 2021 – 2029 Housing Element, the City’s Regional Housing Needs Allocation for the current planning period is 2,265. This includes 677 moderate income units and 1,588 above moderate income units. The City expects to fulfill the housing unit requirements through a combination of existing residentially zoned areas and certain mixed-use zones within the community. Additionally, an estimated 103 accessory dwelling units (ADUs) are projected to be developed.

Rehabilitation The rehabilitations of housing units depends on contractor costs and material costs.

Acquisition,
including
preservation
The acquisition and preservation depends on land costs and demand for housing.

Table 48 – Influence of Market Conditions
791
Consolidated Plan ORANGE 93
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-35 Anticipated Resources - 91.215(a)(4), 91.220(c)(1,2) Introduction
The City annually receives CDBG and HOME funds that are earmarked for community-based projects. The City is working with a local affordable housing developer (Orange Housing Development Corporation) to allocate HOME funds for several affordable housing projects including the newly completed Villa St. Joseph, Katella Terrace, and the Orion project which is still under construction. With the new State housing legislatives and funds, the City is making every effort to promote the creation and preservation of affordable housing units. In the past, the City used its HOME funds as well as its former redevelopment funds to subsidize affordable housing projects. With new State funds, the City continues to encourage and support affordable housing projects and over the next five years, will receive State funding that will be used for transitional and permanent supportive housing projects.

Anticipated Resources
Program Source of Uses of Funds Expected Amount Available Year 1 Expected Narrative Description Funds Annual Program Prior Year Total: Amount
Allocation: Income: $ Resources: $ Available
$ $ Remainder
of ConPlan
$
CDBG public -
federal
Acquisition
Admin and Planning
Housing
Public Improvements
Public Services
$1,034,444 0 0 $5,172,220 $5,172,220 The City allocates CDBG funds to public services and public
facilities projects.

HOME public -
federal
Acquisition
Homebuyer
assistance
Homeowner rehab
Multifamily rental
new construction
$430,000 0 0 $2,150,000 $2,150,000 The City allocates HOME funds to affordable housing projects.
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Consolidated Plan ORANGE 94
OMB Control No: 2506-0117 (exp. 09/30/2021)
Multifamily rental
rehab
New construction for
ownership
TBRA
Table 49 - Anticipated Resources
Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied
The City uses former redevelopment funds with HOME funds to comply with the match requirement under the HOME program. The While there is no match requirement under the CDBG program, the City gives priority to projects or programs that leverage CDBG funds with other local and state funds.

If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan
The City does not own land or property that could be used to address the needs in this plan.

Discussion
Please refer to the sections above.
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Consolidated Plan ORANGE 95
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-40 Institutional Delivery Structure – 91.215(k)
Explain the institutional structure through which the jurisdiction will carry out its consolidated plan including private industry, non-profit organizations, and public institutions.

Responsible Entity Responsible Entity
Type
Role Geographic Area Served
City of Orange Government Non-homeless special
needs
neighborhood
improvements
public facilities
public services

ORANGE COUNTY

HOUSING AUTHORITY
Government Rental

ORANGE HOUSING

DEVELOPMENT

CORPORATION
CHDO Rental
Fair Housing Foundation Non-profit
organizations
public services
Table 50 - Institutional Delivery Structure
Assess of Strengths and Gaps in the Institutional Delivery System The City partners with Orange County Housing Authority for the Section 8 Housing Choice Voucher program to provide rental assistance. The City allocates CDBG funds to nonprofit groups to provide public services to the low-income communities. And finally, the City collaborates with the Orange Housing Development Corporation who is a Community Housing Development Organization (CHDO) to develop rental housing units for low and very low income households. The City is receptive to collaboration with nonprofit groups, other local agencies, and affordable housing developers to help achieve community and housing goals and objectives consistent with the 2025-2029 Consolidated Plan.

Availability of services targeted to homeless persons and persons with HIV and mainstream services
Homelessness Prevention
Services
Available in the
Community
Targeted to
Homeless
Targeted to People
with HIV
Homelessness Prevention Services
Counseling/Advocacy X X
Legal Assistance X
Mortgage Assistance
Rental Assistance X
Utilities Assistance X
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Consolidated Plan ORANGE 96
OMB Control No: 2506-0117 (exp. 09/30/2021)
Street Outreach Services
Law Enforcement X X
Mobile Clinics X X
Other Street Outreach Services X X
Supportive Services
Alcohol & Drug Abuse X X
Child Care X X
Education X X
Employment and Employment
Training
X X
Healthcare X X

HIV/AIDS X
Life Skills X X
Mental Health Counseling X X
Transportation X X
Other
Other
Table 51 - Homeless Prevention Services Summary
Describe how the service delivery system including, but not limited to, the services listed above meet the needs of homeless persons (particularly chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) The City does not receive homeless-related grants or HOPWA grants.

Describe the strengths and gaps of the service delivery system for special needs population and persons experiencing homelessness, including, but not limited to, the services listed above While the City does not receive homeless-related grants, they collaborate with the County of Orange and other local agencies to address issues on homelessness and special needs residents at a regional level.

Provide a summary of the strategy for overcoming gaps in the institutional structure and service delivery system for carrying out a strategy to address priority needs The City proactively participates in an effort and coordination to carry out priority needs (i.e. - housing, homelessness, and community development) and works closely with other local agencies to further the goals and objectives of the 2025-2029 Consolidated Plan. 795
Consolidated Plan ORANGE 97
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-45 Goals Summary – 91.215(a)(4)
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic
Area
Needs Addressed Funding Goal Outcome Indicator
1 Affordable
Housing
2025 2029 Affordable Housing Affordable
Housing
Rental units constructed:

XX Household Housing Unit
2 Homelessness 2025 2029 Homeless Homelessness Housing for Homeless added:

XX Household Housing Unit
3 Community
Development
2025 2029 Non-Housing
Community
Development
Community
Development
Public Facility or Infrastructure
Activities other than Low/Moderate
Income Housing Benefit:
15000 Persons Assisted
Public service activities other than
Low/Moderate Income Housing
Benefit:
50000 Persons Assisted
Table 52 – Goals Summary
Goal Descriptions
1 Goal Name Create Economic Development Opportunities
Goal Description Provide assistance to qualifying businesses serving or employing extremely low, low and moderate income employees
2 Goal Name Affordable Housing
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Consolidated Plan ORANGE 98
OMB Control No: 2506-0117 (exp. 09/30/2021)
Goal Description Provide affordable housing to extremely low, low, and moderate income households. 3 Goal Name Homelessness
Goal Description Addressing homelessness by providing housing units to homeless families. 4 Goal Name Community Development
Goal Description Provide public services to low-income population and improve public facilities within low income neighborhoods.

Estimate the number of extremely low-income, low-income, and moderate-income families to whom the jurisdiction will provide affordable housing as defined by HOME 91.315(b)(2)
The City intends to allocate HOME funds to affordable housing projects during the next five years. Below are the estimated number of households benefiting from these affordable housing projects.

1. Extremely low-income households - 0

2. Low-income households – 11

3. Moderate-income households - 0I
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Consolidated Plan ORANGE 99
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-50 Public Housing Accessibility and Involvement – 91.215(c) Need to Increase the Number of Accessible Units (if Required by a Section 504 Voluntary Compliance Agreement)
Not applicable because the City does not operate a public housing facility.

Activities to Increase Resident Involvements
Not applicable because the City does not operate a public housing facility.

Is the public housing agency designated as troubled under 24 CFR part 902? Not applicable because the City does not operate a public housing facility.

Plan to remove the ‘troubled’ designation
Not applicable because the City does not operate a public housing facility. 798
Consolidated Plan ORANGE 100
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-55 Barriers to affordable housing – 91.215(h)
Barriers to Affordable Housing
As common in many communities, a variety of constraints affect the provisions and opportunities for adequate housing in the City of Orange. Housing constraints consist of both governmental constraints, including but not limited to development standards and building codes, land use controls, and permitting processes; as well as, nongovernmental or market constraints, including but not limited to land costs, construction costs, and availability of finances. Combined, these factors create barriers to the availability and affordability of new housing, especially for lower and moderate-income households.

Due to a housing crisis in California, the State has passed new housing legislatives and provided funding to help cities prepare and plan for housing and land use policies to streamline housing development projects. The City has incorporated new legislations on accessory dwelling units that makes it less stringent for homeowners or property managers to build accessory dwelling units. In the meantime, the City is in the process of updating its Housing Element.

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

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

HCD established the planning period for the current RHNA from October 15, 2021 to October 15, 2029. For the 2021-2029 planning period the City is allocated a total of 3,936 units, including 1,067 units affordable to very low-income households, 604 units affordable to low-income, 677 units affordable to moderate income, and 1,588 units affordable to above-moderate income households.

Strategy to Remove or Ameliorate the Barriers to Affordable Housing 799
Consolidated Plan ORANGE 101
OMB Control No: 2506-0117 (exp. 09/30/2021)
The City continues to seek funding from the State or federal sources in order to provide financial assistance for affordable housing projects. Moreover, the City offers density bonus, waivers and concessions for development standards, and deferred impact fees to incentivize residential developers. Finally, the City is preparing a land use ordinance and specific plans to streamline the entitlement process and promote housing production.
800
Consolidated Plan ORANGE 102
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-60 Homelessness Strategy – 91.215(d)
Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
The City is not a recipient of homeless-related grants, but do collaborate with the County of Orange to address homelessness.

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

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again.

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

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

Help low-income individuals and families avoid becoming homeless, especially extremely low- income individuals and families who are likely to become homeless after being discharged from a publicly funded institution or system of care, or who are receiving assistance from public and 801
Consolidated Plan ORANGE 103
OMB Control No: 2506-0117 (exp. 09/30/2021)
private agencies that address housing, health, social services, employment, education or youth needs
Beginning in 2022, “The HUB OC” established the Hub Resource Center (HRC) to oversee continuum of care services on behalf of the City of Orange and manages rental facilities including laundry machines, portable showers, hand washing stations, and portable restrooms to help with personal hygiene – in an effort to reduce the transmission of COVID-19. The HUB OC manages the recruiting, training, and mobilizing the team of volunteers from local churches and the community to help meet the needs of homeless residents in partnership with the City of Orange, the HEART team, and LOVE Orange. A summary of services provided by the HUB OC is listed below:
 Provide initial contact with homeless individuals for intake information;  Coordinate with the HEART team for entry into Coordinated Entry System (CES) and Homeless
 Management Information System (HMIS);
 Coordinate efforts with local non-profits to recruit volunteers;  Provide training to volunteers as listed below:
 Manage and provide homeless individuals with referrals to shelters  Distribute hygiene supplies to homeless individuals
 Manage the on-site hygiene resources that include laundry, showers, wash stations, and restrooms
 Manage and provide homeless individuals with access to phone charging stations  Provide homeless individuals with referrals to mental, medical, vision, dental, and healthcare services;
 Provide homeless individuals with referrals to veterinary care services  Provide homeless individuals with referrals to COVID-19 vaccines  Provide homeless individuals with referrals to clothes providers including resources from Full Circle
 Provide homeless individuals with voucher assistance and referrals to bus or other modes of transportation
 Provide the children of homeless individuals with referrals to free after school care through the Youth Centers of Orange
The goal of the HRC in the long run is to continue to offer the same services it does now, but adjust meals to a more nutritional, medical, and supplemental based service. Current services such as showers and laundry will continue to be offered and will encourage the clients to attend a class, workshop, or other empowering services offered at the site through one of its partners or volunteers. Currently, the HUB OC has over 40 partners and is continuously seeking out 802
Consolidated Plan ORANGE 104
OMB Control No: 2506-0117 (exp. 09/30/2021)
additional partners to expand services and resources for the homeless community at no additional cost. The HUB OC develops it partnerships by reaching out to schools, non-profits, and local businesses and donors directly and sharing the mission and vision of the HRC with the goal of receiving continuous or one-time financial or in-kind donations. Partnerships are also developed through word of mouth from volunteers and current partner organizations already providing services at the site. If the outreach results in a long-term partnership, the HUB OC will create agreements for the service or donation to be provided at no-cost at the HRC, including those services already being offered.

The HRC has already started to secure partnerships for the classes, workshops, and other empowering services it will offer at the site in the long-term. Examples include:
 Work Program focused on creating healthy work ethics and facilitating project participation throughout the City to develop workforce skills;  Classes on health care for individuals living on the streets by nurses from local state university.
 Support classes for mothers including lactation and birthing that will also offer essential items that can be purchased using EBT and WIC onsite;  Resume building and application assistance by professionals and volunteers in our community;
 Drug and addiction programs through Celebrate Recovery/AA that offers vide and workbook curriculum, sponsors, and success chips;
 Men’s and Women's support groups for holistic well-being;  Associate Degree Program through a local college that clients will be able to complete at the HRC through the use of donated computers;  Nutritional courses by a food scientist;
 Outreach courses for volunteers and local businesses wanting to understand the difficulties of the homeless population and discover ways in which they can help. 803
Consolidated Plan ORANGE 105
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-65 Lead based paint Hazards – 91.215(i)
Actions to address LBP hazards and increase access to housing without LBP hazards The County of Orange Health Care Agency ensures that residents receive information about the risks of Lead Based Paint (LBP) hazards and the services available to those who have been exposed.

How are the actions listed above related to the extent of lead poisoning and hazards? An estimated 7% to 9% of homes in Orange were built before 1980 where families with children live. The Orange County Health Care Agency operates the “Childhood Lead Poisoning Prevention” program for the entire county. This agency receives reports from the State and provides case management services as well as educational programs to families affected by lead poisoning.

How are the actions listed above integrated into housing policies and procedures? The City of Orange, in collaboration with Orange County, addresses lead-based paint hazards through targeted programs and public education. The County’s Childhood Lead Poisoning Prevention Program (CLPPP) provides case management, environmental investigations, and education to eliminate lead exposure, especially in children. The Lead Hazard Removal Program offers free remediation services for homes built before 1978, focusing on households with young children or pregnant individuals. Additionally, public awareness campaigns emphasize the risks of lead exposure and promote lead-safe practices within the community. These efforts aim to protect families from the harmful effects of lead-based paint.

Currently, due to limited federal funding, the City does not operate housing related programs such as a minor home repair program or a down payment assistance program. 804
Consolidated Plan ORANGE 106
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-70 Anti-Poverty Strategy – 91.215(j)
Jurisdiction Goals, Programs and Policies for reducing the number of Poverty-Level Families During the community outreach process, homeless was identified as a priority need in the city.

While the City is not a recipient of homeless related grants, they do collaborate with other local agencies at a regional level to address this issue. Moreover, the City continues to support programs and projects that benefit families at poverty level by allocating its CDBG and HOME funds.

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

How are the Jurisdiction poverty reducing goals, programs, and policies coordinated with this affordable housing plan
The City encourages affordable housing projects by offering incentives such as density bonus and waivers in development standards. Additionally, the City collaborates with local affordable housing developers to provide housing to very low and low income households. 805
Consolidated Plan ORANGE 107
OMB Control No: 2506-0117 (exp. 09/30/2021)
SP-80 Monitoring – 91.230
Describe the standards and procedures that the jurisdiction will use to monitor activities carried out in furtherance of the plan and will use to ensure long-term compliance with requirements of the programs involved, including minority business outreach and the comprehensive planning requirements
The City monitors CDBG and HOME funded projects by first evaluating whether a subrecipient of CDBG fund is at risk of noncompliance using a risk assessment process and then performing onsite monitoring of the subrecipients to correct any noncompliance issues. The City’s monitoring procedures include the following steps.

1. Assessing the risk threshold of CDBG funded programs using risk factors such as high organizational turnover or slow expenditure rate.

2. Evaluating quarterly performance reports of CDBG funded projects to ensure projects are meeting beneficiary goals as well as timely expenditure of funds.

3. Collecting and evaluating certified annual report of HOME funded projects.

4. Reviewing tenant income certification of HOME funded projects. 806
Consolidated Plan ORANGE 108
OMB Control No: 2506-0117 (exp. 09/30/2021)
Expected Resources
AP-15 Expected Resources – 91.220(1,2)
Introduction
The City annually receives CDBG and HOME funds that are earmarked for community-based projects. While affordable housing is a high priority need, the City has not received viable applications for affordable housing projects to allocate CDBG and HOME funds.

With new State housing legislatives and funds, the City is making every effort to promote the creation and preservation of affordable housing units. In the past, the City used its HOME funds as well as its former redevelopment funds to subsidize affordable housing projects. Over the next five years, the City will receive State funding that will be used for transitional and permanent supportive housing projects.

Anticipated Resources
Program Source of Uses of Funds Expected Amount Available Year 1 Expected Narrative Description Funds Annual Program Prior Year Total: Amount
Allocation: Income: $ Resources: $ Available
$ $ Remainder
of ConPlan
$
CDBG public-
federal
Acquisition
Admin and Planning
Housing
Public Improvements
Public Services X 0 0 X X
The City allocates CDBG funds
to public services and public
facilities projects.

HOME public -
federal
Acquisition
Homebuyer
assistance
Homeowner rehab
Multifamily rental
The City allocates HOME funds
to affordable housing projects.
807
Consolidated Plan ORANGE 109
OMB Control No: 2506-0117 (exp. 09/30/2021)
new construction
Multifamily rental
rehab
New construction for
ownership
TBRA X 0 0 X X
Table 53 - Expected Resources – Priority Table
Explain how federal funds will leverage those additional resources (private, state and local funds), including a description of how matching requirements will be satisfied
The City uses former redevelopment funds with HOME funds to comply with the match requirement under the HOME program. The City plans to use Housing Trust Funds from the County of Orange and SB 2 funds from the State along with HOME funds for affordable housing projects. While there is no match requirement under the CDBG program, the City gives priority to projects and programs that leverage CDBG funds with other local and state funds.
808
Consolidated Plan ORANGE 110
OMB Control No: 2506-0117 (exp. 09/30/2021)
If appropriate, describe publicly owned land or property located within the jurisdiction that may be used to address the needs identified in the plan The City does not own land or property that could be used to address the needs in this plan.

Discussion
Please refer to the above sections.
809
Consolidated Plan ORANGE 111
OMB Control No: 2506-0117 (exp. 09/30/2021)
Annual Goals and Objectives
AP-20 Annual Goals and Objectives
Goals Summary Information
Sort
Order
Goal Name Start
Year
End
Year
Category Geographic Area Needs
Addressed
Funding Goal Outcome Indicator
1 Economic
Development
2025 2026 Economic
Development
City of Orange Economic
Development
CDBG: $XXX Program to be developed.
2 Affordable
Housing
2025 2026 Affordable
Housing
City of Orange Housing
Rehab and
Housing new
construction
HOME: $XXX Rental units constructed: 11 Household
Housing Unit
3 Community
Development -
Public Service
Programs
2025 2026 Non-Housing
Community
Development
City of Orange Public
services/hom
eless/non
homeless
special need
CDBG:
$XXX
Public service activities other than
Low/Moderate Income Housing Benefit:
40,796 Persons Assisted
4 Community
Development -
Public Facilities
and Infrastructure
Improvements
2025 2026 Non-Housing
Community
Development
City of Orange Public
facilities and
infrastructure
improvements
CDBG:
$XXX
Public Facility or Infrastructure Activities
other than Low/Moderate Income Housing
Benefit: 61,730 Persons Assisted
810
Consolidated Plan ORANGE 112
OMB Control No: 2506-0117 (exp. 09/30/2021)
5 Administration/
Planning
2025 2025 Administration City of Orange Administration
of CDBG and
HOME
program
CDBG $XXX
HOME: $XXX
Successful administration of the CDBG and
HOME programs.

Table 54 – Goals Summary
Goal Descriptions
1 Goal Name Economic Development
Goal Desciption Provide assistance to businesses serving or employing qualifying populations 2 Goal Name Affordable Housing
Goal Description Multi-family new housing development or acquisition/rehab of existing housing for low-to- moderate income residents.
3 Goal Name Homelessness
Goal Description Assistance and resources to individuals experiencing homelessness. 4 Goal Name Community Development - Public Service Programs Goal Description Services for low to moderate income individuals and families, fair housing, resources for homeless individuals.
5 Goal Name Community Development – Public facilities and capital improvement for low-income neighborhoods
Goal Description Providing public services and public facilities improvement for low-income neighborhoods. 6 Goal Name Rental Assistance
811
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Goal Description Rental Assistance to low-and-moderate income individuals. 7 Goal Name Administration/Planning
Goal Description Administration and planning for grant management. 812
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Projects
AP-35 Projects – 91.220(d)
Introduction
The FY 2025-2026 Action Plan identifies housing and community development projects as high priority needs. The City will allocate the CDBG funds to public facilities projects including street improvement and Americans with Disability Act improvements, as well as to public services programs serving qualifying populations. These projects funded under the CDBG program will address the needs of low- and moderate-income residents.

Projects
# Project Name
1 PS-Orange Fair Housing Program
2 PF-ADA Wheelchair Access Ramps
3 PF-25-26 Street Rehabilitation
4 PS-Affordable Housing Supportive Services
5 PS-After School Community Program
6 PS-Bike Patrol Program-Community Oriented Policing
7 PS-Operation School Bell
8 PS-Community Food Orange
9 PS-Case Management Support for expectant mothers experiencing homelessness 10 ED-Community Development Assistance Program
11 AD-Administration
Table 55 – Project Information
Describe the reasons for allocation priorities and any obstacles to addressing underserved needs
The City allocates CDBG funds to activities that address the priorities of the 2025-2029 Consolidated Plan and comply with CDG regulations. The City and the CDBG Program Committee consider funding requests from nonprofit organizations based on the proposed benefits to low- and moderate-income residents, the agency’s demonstrated capacity to carry out the proposed activities, and financially feasibility of the proposed activity, and the funding available. 813
Consolidated Plan ORANGE 115
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-38 Project Summary
Project Summary Information
1 Project Name Orange Fair Housing Program
Target Area CDBG eligible areas within the City of Orange Goals Supported Community Development – Public Services Needs Addressed Fair housing counseling
Funding CDBG: $25,000
Description Providing Fair Housing Services to low and moderate income Orange residents.

Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
150 low- and moderate-income persons
Location Description Low- and moderate-income areas.

Planned Activities The Fair Housing Foundation (FHF) will provide fair housing education, counseling, and enforcement; and
related housing activities to affirmatively further
housing laws on behalf of the City to comply with
federal regulations.
814
Consolidated Plan ORANGE 116
OMB Control No: 2506-0117 (exp. 09/30/2021)
2 Project Name CDBG Fiscal Year 25-26 ADA Wheelchair Ramp Replacement
Target Area CDBG Eligible Areas within the City of Orange Goals Supported Community Development – Public facilities and capital improvement for low-income neighborhoods
Needs Addressed Public Infrastructure improvements
Funding CDBG: $100,000
Description This project includes the construction of sidewalk access ramps at various locations throughout the
City. These access ramps will improve accessibility for the disabled to comply with the Americans with
Disabilities Act.

Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
1,000 low- and moderate-income disabled persons
Location Description Various city locations.

Planned Activities This project includes the construction of sidewalk access ramps at various locations throughout the
City. These access ramps will improve accessibility for the disabled to comply with the Americans with
Disabilities Act.
3 Project Name 25-26 Street Rehabilitation
Target Area CDBG Eligible Areas within the City of Orange 815
Consolidated Plan ORANGE 117
OMB Control No: 2506-0117 (exp. 09/30/2021)
Goals Supported Community Development – Public facilities and capital improvement for low-income neighborhoods
Needs Addressed Infrastructure Improvements in low to moderate income areas
Funding CDBG: $667,936.50
Description Roadway pavement rehabilitation and pedestrian facilities
Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
5,099 low and moderate income persons
Location Description Various eligible streets in the City Planned Activities Street improvement will include addressing issues with pavement distress and raveling of roadways;
replacement of segments of sidewalks, driveways,
curb ramps, curb and gutters.
4 Project Name Affordable Housing Supportive Services
Target Area 67 W. Struck Avenue
Goals Supported Community Development – Public Services Needs Addressed Supportive services to extreme low, low and moderate households
Funding CDBG: $20,000
Description Supportive services providing access to housing and resources aimed at preventing homelessness.
816
Consolidated Plan ORANGE 118
OMB Control No: 2506-0117 (exp. 09/30/2021)
Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
130 low- and moderate-income persons
Location Description 62-unit affordable housing complex Planned Activities Dedicated Care Team, comprised of multi-disciplinary specialists and subject matter experts, who work
together to identify suitable housing options and
create a plan for short and long-term goals.
5 Project Name The Hub OC Community Center
Target Area CDBG Eligible Areas within the City of Orange Goals Supported Community Development – Public Services Needs Addressed Public services for low- and moderate-income children
Funding $40,000
Description The programs will provide supervised after-school recreation with a homework assistance component
for children of ages five to 13.

Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
175 low-income and at-risk youth.
817
Consolidated Plan ORANGE 119
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Location Description Three community centers in the City of Orange Planned Activities The programs will provide supervised after-school recreation with a homework assistance component
for children of ages five to 13.
6 Project Name Bike Patrol Program – Community Oriented Policing Target Area Low- and Moderate-Income Areas within the City of Orange
Goals Supported Community Development – Public Services Needs Addressed Homeless outreach and resources
Funding CDBG: $55,000
Description This program will provide a community-oriented policing strategy designed to improve the quality of
life in high density housing located in Low Income
areas of the City.

Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
10,000 low income persons
Location Description City Parks in CDBG areas
Planned Activities This program will provide a community-oriented policing strategy designed to improve the quality of
life in high density housing located in Low Income
areas of the City.

Project Name Operation School Bell
818
Consolidated Plan ORANGE 120
OMB Control No: 2506-0117 (exp. 09/30/2021)
7 Target Area CDBG Eligible Areas within the City of Orange Goals Supported Community Development – Public Services Needs Addressed Public services for low to moderate income persons Funding CDBG: $15,000
Description This program will provide school clothing/uniforms, undergarments, shoe vouchers, and hygiene kits to
Low Income elementary school (Kindergarten to Sixth
Grade) students in the Orange Unified School District
(OUSD).

Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
260 low-income students
Location Description 124 South Orange Street
Planned Activities The program will provide school clothing and hygiene kits to Low Income OUSD elementary school
(Kindergarten to Sixth Grade) students.
8 Project Name Community Food Orange
Target Area CDBG Eligible Areas within the City of Orange Goals Supported Community Development Public Services
Needs Addressed Public services for low to moderate income persons Funding CDBG: $15,000
Description This program will provide free food to low-income residents.
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Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
1000 low- and moderate-income persons
Location Description 147 W. Rose Avenue, 1820 N. Meats Avenue Planned Activities Food will be distributed on a weekly basis at two Friendly Center sites.
9 Project Name Steps to Independence
Target Area CDBG Eligible Areas within the City of Orange Goals Supported Community Development – Public Services Needs Addressed Public services for expectant mothers experiencing homelessness
Funding CDBG: $10,166.60
Description Case management for expectant mothers
experiencing homelessness
Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
low- and moderate-income persons
Location Description 123 W Maple
Planned Activities Case management for expectant mothers experiencing homelessness aimed at self-sufficiency
10 Project Name Community Development Assistance Program Target Area City-wide eligible areas
820
Consolidated Plan ORANGE 122
OMB Control No: 2506-0117 (exp. 09/30/2021)
Goals Supported Economic Development
Needs Addressed Assistance to qualifying businesses serving or employing low- and moderate-income persons
Funding $72,388.60
Description Assistance to qualifying businesses serving or employing low- and moderate-income persons
Target Date 6/30/2026
Estimate the number and type of
families that will benefit from the
proposed activities
Program to be developed
Location Description 300 E Chapman Avenue
Planned Activities Business assistance that serves low- and moderate- income persons
11 Project Name Planning and Administration
Target Area City of Orange
Goals Supported Planning and Administration of grant
Needs Addressed Public facilities infrastructure and improvements; public services/homeless/non-homeless special need;
housing rehabilitation and development – new
construction.

Funding CDBG: 181,888.80
HOME: $35,405
Description Planning and administration of grant funding.

Target Date 6/30/2026
821
Consolidated Plan ORANGE 123
OMB Control No: 2506-0117 (exp. 09/30/2021)
Estimate the number and type of
families that will benefit from the
proposed activities
Low to moderate income individuals throughout the
City of Orange.

Location Description 300 E Chapman Avenue
Planned Activities Administration and planning of grant funding. 822
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AP-50 Geographic Distribution – 91.220(f)
Description of the geographic areas of the entitlement (including areas of low-income and minority concentration) where assistance will be directed Geographic Distribution
Target Area Percentage of Funds
City of Orange 100%
Table 56 - Geographic Distribution
Rationale for the priorities for allocating investments geographically Discussion
823
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OMB Control No: 2506-0117 (exp. 09/30/2021)
Affordable Housing
AP-55 Affordable Housing – 91.220(g)
Introduction
One Year Goals for the Number of Households to be Supported Homeless: 0
Non-Homeless: 0
Special-Needs: 0
Total
Table 57 - One Year Goals for Affordable Housing by Support Requirement One Year Goals for the Number of Households Supported Through Rental Assistance: 20
The Production of New Units: 0
Rehab of Existing Units: 0
Acquisition of Existing Units: 0
Total: 0
Table 58 - One Year Goals for Affordable Housing by Support Type Discussion
See the previous portions of this section for discussion. 824
Consolidated Plan ORANGE 126
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-60 Public Housing – 91.220(h)
Introduction
There is no public housing in the City of Orange.

Actions planned during the next year to address the needs to public housing Not applicable
Actions to encourage public housing residents to become more involved in management and participate in homeownership
Not applicable
If the PHA is designated as troubled, describe the manner in which financial assistance will be provided or other assistance
Not applicable
Discussion
Not applicable
825
Consolidated Plan ORANGE 127
OMB Control No: 2506-0117 (exp. 09/30/2021)
AP-65 Homeless and Other Special Needs Activities – 91.220(i) Introduction
The City identified unmet needs for homeless and special needs population during the needs assessment process. The City also received applications for homeless-related programs to allocate FY 2025-26 CDBG funds. Given the limited public service funds available, not all the funding requests can be addressed. However, the City plans to use other funding sources to provide financial assistance for the operation of the two homeless navigation centers in Buena Park and Placentia.

Additionally, the City used HOME-America Rescue Plan (HOME-ARP) funds for the HRC which services those experiencing homelessness and the most vulnerable populations. Services that meet special needs are provided including food, laundry, and shower services are provided, as well as one-stop location for the coordination with continuum of care agencies.

Describe the jurisdictions one-year goals and actions for reducing and ending homelessness including
Reaching out to homeless persons (especially unsheltered persons) and assessing their individual needs
While the City does not receive Emergency Solutions Grant (ESG) funds, the City supports the County of Orange Continuum of Care strategies to address homelessness. Additionally, the City is part of the North Orange County Service Planning Area and actively collaborates with the County of Orange and other local cities to address homeless related needs. Finally, the City gives priority and allocates CDBG funds to projects benefiting the homeless population whenever it receives applications for CDBG funds.

The City also supported the services at the HRC with HOME-ARP. Services at the HRC specifically focused on helping homeless individuals with accessing services and resources they need to improve their situation, including food, water and services for mental and physical well-being, job training resources, and housing needs. Due to the centralized and unique structure of the HRC, the staff is very familiar with the individual needs of clients, helping to maximize the effectiveness of the services offered and leverage other resources.

Addressing the emergency shelter and transitional housing needs of homeless persons The City continues to support projects related to homelessness by allocating CDBG funds to these projects.

Helping homeless persons (especially chronically homeless individuals and families, families with children, veterans and their families, and unaccompanied youth) make the transition to 826
Consolidated Plan ORANGE 128
OMB Control No: 2506-0117 (exp. 09/30/2021)
permanent housing and independent living, including shortening the period of time that individuals and families experience homelessness, facilitating access for homeless individuals and families to affordable housing units, and preventing individuals and families who were recently homeless from becoming homeless again
The City collaborates with the Orange County Housing Authority to provide Section 8 rental assistance to homeless families. The City is also working on implementing its Regional Housing Needs Assessment (RHNA) allocations mandated through the California Department of Housing and Community Development by supporting projects that create permanent housing for the homeless population or those at risk of becoming homeless (extremely low and very low income).

The City supports OCHA’s applications for Continuum of Care Program Permanent Supportive Housing Program projects. Currently, # households are residing in Orange with certificates for this program.

The City also supports OCHA's applications for the Housing and Urban Development-Veterans Affairs Supportive Housing (HUD-VASH) Program vouchers, which combines rental assistance with case management and clinical services for homeless veterans. The VA Medical Center in Long Beach screens and selects veterans for participation in the Program, and refers qualified veterans to OCHA, which administers the housing component of the Program. Currently, 28 Orange households are participating in the HUD-VASH Program as of September 16, 2024.

Additionally, the City used HOME-ARP funding for services at the Hub Resource Center (HRC) that provides basic needs services including food, clothing, showers, and laundry, and in addition, offers access to continuum of care partners on-site in a centralized setting to ensure that individuals are able to receive the support they need. On-site partner agencies offer support for connection to housing, mental and physical wellness, and childcare needs to allow parents more opportunities to improve their situation.

Finally, the City established a TBRA program to assist eligible households with security and utility deposit assistance when moving into a new housing unit.

Helping low-income individuals and families avoid becoming homeless, especially extremely low-income individuals and families and those who are: being discharged from publicly funded institutions and systems of care (such as health care facilities, mental health facilities, foster care and other youth facilities, and corrections programs and institutions); or, receiving assistance from public or private agencies that address housing, health, social services, employment, education, or youth needs
The City supports OCHA’s applications for the Rental Assistance for Non-Elderly Persons with 827
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OMB Control No: 2506-0117 (exp. 09/30/2021)
Disabilities (NED) Program, which provides incremental Section 8 vouchers. The goal of the Program is to enable Non-Elderly, Disabled households to transition from health care institutions or skilled nursing care to independent living with appropriate services.

The City also supports OCHA’s applications for the Family Unification Program (FUP), which provides Section 8 Rental Assistance to eligible families whose lack of adequate housing is a primary factor in the separation or threat of imminent separation of children from their families. The Program also provides vouchers for up to 18 months to emancipated youth (18- to 21-year-old children that left foster care at age 16 or older and lack adequate housing). The Orange County Social Services Agency refers potential FUP participants to OCHA, which administers the housing component of the Program.

Discussion
The City supports nonprofit applications for Continuum of Care funds to provide services and housing to the homeless. The City also seeks to provide CDBG funds to nonprofit agencies that serve the homeless. The Orange Police Department has a Homeless Engagement Assistance and Resource Team (HEART) to reach out to the homeless and connect them with the services. Officers work with the Orange County Mental Health Department and the Centralized Assessment Team to address homeless issues and find long-term solutions.

In addition, the City used HOME-ARP funds for services to the most vulnerable populations at the HRC which offers access with continuum of care partners on-site, including social services, mental and physical wellness services, and resources to help individual improve their situation. 828
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AP-75 Barriers to affordable housing – 91.220(j)
Introduction:

The City faces limited available land for residential development and given the high cost of land, it is difficult to create financially viable affordable housing projects. Additionally, the City's historic district neighborhoods have specific zoning regulations and requirements further complicating the development of affordable housing. While the City acknowledges the importance of providing affordable housing for low- and moderate-income residents, it allocates home and local funds to such projects whenever possible.

Actions it planned to remove or ameliorate the negative effects of public policies that serve as barriers to affordable housing such as land use controls, tax policies affecting land, zoning ordinances, building codes, fees and charges, growth limitations, and policies affecting the return on residential investment
The City grants regulatory incentives and concessions to housing developers through its discretionary process. Concessions such as increased density (Density Bonus Ordinance) may be granted for a project when it includes a certain number of long-term affordable housing units.

Discussion:

See the previous sections for discussion.
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AP-85 Other Actions – 91.220(k)
Introduction:

The City will undertake a variety of activities aimed at addressing the needs of households at low and moderate income levels. It allocated CDBG funds to the Fair Housing Foundation to carry out Fair Housing activities, resolve any issues regarding Fair Housing, and hold workshops for tenants and landlords. Additionally, the City is preparing land use planning documents and ordinances using State SB 2 funds to streamline the entitlement process and encourage affordable housing development projects. Finally, the City is updating the Housing Element and will identify parcels suitable for housing development opportunities as well as developing policies and programs to support the development of affordable housing units for extremely low- and low-income households.

Actions planned to address obstacles to meeting underserved needs The City supports services and projects aimed at addressing homelessness, social services, and housing affordability. It collaborates with Orange County Housing Authority to provide Section 8 rental assistance to low-income families. Furthermore, the City allocates CDBG funds to public services projects benefitting low- and moderate-income households. The allocation of CDBG and HOME funds is based on high priority unmet needs that were discovered during the needs assessment process of the 2025-2029 Consolidated Plan.

Actions planned to foster and maintain affordable housing.

The City addresses the need for affordable housing through a variety of programs and incentives such as the density bonus incentive for developers and the TBRA program to provide security and utility deposit assistance. The City also leverages federals funds through HOME and CDBG to assist low- to moderate-income families and individuals in securing affordable housing. There are several affordable housing developments throughout Orange such as Villa St. Joseph, Katella Terrace, and the Orion.

Actions planned to reduce lead-based paint hazards
Given limited CDBG funds, the City does not directly fund lead-based paint evaluation and reduction. It does support the County of Orange efforts to reduce lead-based paint hazards. If funding is available in the future, the City and the County plan to intensify their efforts to reduce the risk of lead poisoning for young, low income children.

Actions planned to reduce the number of poverty-level families The City uses CDBG dollars to fund a variety of community programs such as Families Forward which helps families experiencing homelessness or are on the verge of homelessness in regaining 830
Consolidated Plan ORANGE 132
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stability and self-sufficiency through counseling, career-coaching, and skills training.

Actions planned to develop institutional structure
The City’s Community Development Department includes the following Divisions: Building and Safety, Code Enforcement, Planning, and Housing. This enables the City to effectively coordinate its housing activities. The Planning Division performs functions that directly affect the development and rehabilitation of housing including preparation of the State-mandated Housing Element. The Planning Division also oversees the permit process, regulates development and conducts compliance with zoning and building codes, and administers the Density Bonus Program.

The Housing Division administers the CDBG and HOME programs and is responsible for updating the Consolidated Plan every five years, preparing Annual Action Plans, and the Consolidated Annual Performance and Evaluation Report (CAPER). This Division works with various City departments that carry out CDBG-funded projects.

The City also works with Orange Housing Development Corporation (OHDC) and other developers to develop or rehab affordable housing projects. OHDC has provided attractive, affordable housing for low- and moderate-income households. The City encourages nonprofit agencies to apply for CDBG funds for programs that primarily benefit low- and moderate-income residents.

Actions planned to enhance coordination between public and private housing and social service agencies
The City will continue to work with public and private agencies to coordinate the delivery of housing and related services. City staff sits on the Orange County Housing Authority Advisory Committee to provide input on housing issues that affect the community. The City also maintains close relationship with nonprofit organizations that provide social services to the community.

Discussion:

Please refer to the previous sections.
831
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Program Specific Requirements
AP-90 Program Specific Requirements – 91.220(l)(1,2,4)
Introduction:

Community Development Block Grant Program (CDBG)
Reference 24 CFR 91.220(l)(1)
Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

1. The total amount of program income that will have been received before the start of the next program year and that has not yet been reprogrammed

2. The amount of proceeds from section 108 loan guarantees that will be used during the year to address the priority needs and specific objectives identified in the grantee's strategic plan

3. The amount of surplus funds from urban renewal settlements

4. The amount of any grant funds returned to the line of credit for which the planned use has not been included in a prior statement or plan.

5. The amount of income from float-funded activities
Total Program Income
Other CDBG Requirements

1. The amount of urgent need activities
HOME Investment Partnership Program (HOME)
Reference 24 CFR 91.220(l)(2)

1. A description of other forms of investment being used beyond those identified in Section 92.205 is as follows: N/A

2. A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows: N/A 832
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3. A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows: N/A

4. Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows: N/A

5. If applicable to a planned HOME TBRA activity, a description of the preference for persons with special needs or disabilities. (See 24 CFR 92.209(c)(2)(i) and CFR 91.220(l)(2)(vii)). N/A

6. If applicable to a planned HOME TBRA activity, a description of how the preference for a specific category of individuals with disabilities (e.g. persons with HIV/AIDS or chronic mental illness) will narrow the gap in benefits and the preference is needed to narrow the gap in benefits and services received by such persons. (See 24 CFR 92.209(c)(2)(ii) and 91.220(l)(2)(vii)). N/A

7. If applicable, a description of any preference or limitation for rental housing projects. (See 24 CFR

92.253(d)(3) and CFR 91.220(l)(2)(vii)). Note: Preferences cannot be administered in a manner that limits the opportunities of persons on any basis prohibited by the laws listed under 24 CFR 5.105(a).

N/A
833
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Appendix - Alternate/Local Data Sources
1 Data Source Name
Community Needs Survey
List the name of the organization or individual who originated the data set.

The City of Orange
Provide a brief summary of the data set.

A Community and Stakeholder Survey was conducted to gather data for the preparation of the Analysis of Impediments to Fair Housing and the 2025-2029 Consolidated Plan process from August 10, 2023 through December 30, 2023. The survey was hosted on the City’s website housing page, social media, city kiosk, and made available in paper form on the City Clerks and Community Development counter. To maximize outreach opportunities, the City also conducted the survey at the 2023 National Night Out event and the 2023 El Modena Neighborhood Outreach. The City also held a Housing Summit in October 2023. A workbook was distributed to stakeholders at a Housing Summit to solicit input and assess housing needs, infrastructure/facilities needs including broadband, service needs, fair housing needs, economic development needs and transportation needs.

What was the purpose for developing this data set?
The purpose of the surveys was to gather community input to help the City inform its AI and 5- Year Consolidated Plan for 2025-2029 which will result in setting its future goals and establish programs to better serve the community.

Provide the year (and optionally month, or month and day) for when the data was collected.

August 10, 2023 through December 30, 2023
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Briefly describe the methodology for the data collection.

A Housing Summit was held in October 2023 to collect data to inform the Analysis of Impediments to Fair Housing Rights and the 5-Year Consolidated Plan. Approximately 42 individuals participated in the Housing Summit. A workbook was developed for Housing Summit participants to complete. The workbook responses were summarized to inform the AI and Con Plan.

An electronic survey was also prepared in English and Spanish and conducted via the City’s website. The survey was hosted on the City’s website housing page, social media, and city kiosk. For in-person engagements, surveys were made available in paper form at the City Clerk’s office, Community Development office public counter, Library and public counter. To maximize outreach opportunities, the City also conducted the survey at the 2023 National Night Out event and the 2023 El Modena Neighborhood Outreach. Over 180 respondents participated in the surveys and responded to 26 questions.

The surveys collected demographic data in addition to identifying and prioritizing community needs.

Describe the total population from which the sample was taken.

Over 180 respondents participated in the survey and included City residents, Business Owners, Housing agencies, social service agencies, or nonprofit organizations.

Describe the demographics of the respondents or characteristics of the unit of measure, and the number of respondents or units surveyed.

A total of 185 respondents participated in the survey, 27% chose affordable rental housing as the top housing program the City should be considered. Demographic information was also collected to determine whether participant involvement such as city residents, work for or own a business in the city or represent a housing agency, social service agency or a non-profit. 2 Data Source Name
Administrative Data Sets
List the name of the organization or individual who originated the data set.

City of Orange Community Development Department
835
Consolidated Plan ORANGE 137
OMB Control No: 2506-0117 (exp. 09/30/2021)
Provide a brief summary of the data set.

The data set comprises a comprehensive collection of demographics, housing, economic, and social data from various reputable sources. It includes census data, housing affordability metrics, homelessness counts, regional housing needs, fair market rents, and other relevant information.

This data is essential for recognizing housing and community development needs. The data set is used to inform policy decisions, allocate resources, and develop strategic plans to improve the quality of life for residents.
a. U.S. Census Bureau:
 2010 DEC U.S. Census
 2020 DEC U.S. Census
 2016-2020 American Community Survey (ACS) 5-Year Estimates  2018-2022 American Community Survey (ACS) 5-Year Estimates b. County of Orange
 2023 Orange County Homeless Point In Time (PIT) Count c. SCAG:
 Regional Housing Needs Allocation (RHNA)
d. U.S. Department of Housing and Urban Development (HUD):
 Fair Market Rents (FMRs) 2022
 Comprehensive Housing Affordability Strategy (CHAS)
2016-2020
 Orange County Treasurer and Tax Collector (TTC)
 Federal Financial Institutions Examination Council (FFIEC)  Home Mortgage Disclosure Act (HMDA) 2022
e. City of Orange:
 2021-2029 Housing Element
 Land Use Element
836
Consolidated Plan ORANGE 138
OMB Control No: 2506-0117 (exp. 09/30/2021)
 Stakeholder One-On-One Interviews
 Community and Stakeholder Surveys
 Community Meetings
 2023 Housing Summit
 Orange County Housing Authority (NHA)

1. Other Sources:
 Brown University: 2020 Diversity and Disparities Index  DataUSA: Median Earnings by Industry Source 2018-2022 5-Year Estimates  National Fair Housing Alliance: Guidelines for Responsible Advertising What was the purpose for developing this data set?
This data set was developed to comply with the Housing and Community Development Act of 1974, which mandates that communities receiving HUD funds actively promote fair housing. The report examines laws, regulations, and practices that impact housing location, availability, and accessibility and recommends strategies to overcome impediments. The purpose was to also gather data for the development of the 2025-2029 AI and Con Plan.

How comprehensive is the coverage of this administrative data? Is data collection concentrated in one geographic area or among a certain population?
The data collection is comprehensive, covering various aspects of the community, including demographics, housing profiles, lending practices, and public participation. The data is concentrated on the City of Orange but includes comparisons with Orange County and the State of California. It also addresses specific populations such as low-income households, homeless individuals, and special needs groups.

Data was collected throughout Orange, including those who lived and worked in the City. To ensure comprehensive data collection, the City promoted the survey on the City website; emailed survey links to public service agencies (who were also encouraged to share with their Orange clients); physical copies were handed out at City events; and shared at Orange public facilities, such as public libraries, police department and City Hall.

What time period (provide the year, and optionally month, or month and day) is covered by this data set? The data set will be used for the Consolidated Plan period from 2025 to 2030. Data includes historical data from previous years as previously described. Community and Stakeholder surveys were conducted from August 10, 2023 through December 30, 2023 What is the status of the data set (complete, in progress, or planned)? The data set is complete.
837
Consolidated Plan ORANGE 139
OMB Control No: 2506-0117 (exp. 09/30/2021)
838
COUNTY

ORANGEPARKACRES

CITYCITY
OF

NORTHEL MODENA
COUNTY
COUNTY

EL MODENA
OLIVE

COUNTYTUSTINTUSTIN

ANAHEIM

ORANGESPHERE OFINFLUENCE

ANAHEIM
COUNTY

GARDENGROVE

SANTA ANA

VILLA PARK

ORANGESPHERE OFINFLUENCE
219.03
219.12
219.13
219.14
219.15
219.16
219.17
219.18
219.20
219.23
219.24
524.19
524.37
753.01
754.04
756.04
756.05
757.01
758.05
758.06
758.07
758.08
758.09
758.10
758.11
758.12
758.13
758.14
758.15
758.16
759.01
759.02
760.01
760.02
761.02
761.03
761.04
761.05
762.01
762.02
762.04
762.05
762.06
762.08
863.03
864.07
891.07

E RIVERDALE AV

N FLOWER ST

TRASK AVE

W MEMORY LN

S FLOWER

W SANTA CLARA AVE

N GRAND

HEWES AV

N BROADWAY

S PROSPECT

E KATELLA AVE

HASTER ST
E 17TH

N MAIN ST

N HEWES

N CAMBRIDGE ST

N SANTIAGO BL

W COLLINS AV

S YORBA

E KATELLA AV

N RANCHO SANTIAGO BL

S ANAHEIM BLVD

E FAIRHAVEN AV

E COLLINS AV

E LA PALMA AV

N BRISTOL ST

W CHAPMAN AV

E VILLA PARK RD
W 17TH ST

E SANTA CLARA AV

S GLASSELL

N BATAVIA ST

E BOND AV

W LA VETA AV

N WANDA RD

N ECKHOFF

E CHAPMAN AV

S HEWES

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17TH

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S LEWIS

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S MAIN

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S STATE COLLEGE BL

N TUSTIN

S STATE COLLEGE BLVD

E LA VETA AV

N PROSPECT

S TUSTIN

S THE CITY DR

N ORANGE-OLIVE RD

E SANTIAGO CANYON RD

N GLASSELL

E MIRALOMA AV

NEWPORT BL

E VIA ESCOLA

E SERRANO AV

E SANTA ANA CANYON RD

S JAMBOREE RD

N CANNON

SANTIAGO CANYON RD
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Legend
CDBG Qualified Census Tract (2025)
J:\GisProjects\Planning\Housing\CDBG2024\GIS\APRX\CDBG_2025.aprx\Low-Moderate Income Areas (2025)

ORANGE COUNTY, CALIFORNIA

CITY OF ORANGE
5,500 0 5,5002,750 2,750
Feet
.

Low-Moderate Income Areas
839
$1,034,444.00
Public Services (15% of Grant) $155,166.60
Amount Requested
for 2026
Recommended
Award
Assistance League School clothing assistance to kids $20,000.00 $15,000.00 Bike Patrol Program Community Policing & Crime Prevention $60,000.00 $55,000.00 Fentanyl Solutions Outreach and engagement and distribution of supplies to address opioid crisis
$22,640.00 $0.00
Families Forward Comprehensive housing services and homeless prevention $24,000.00 $20,000.00 Hub OC (Youth Centers of Orange) Child care, homeworks assistance, nutrional activies, etc $50,000.00 $40,000.00 Casa Teresa Case management support for pregnant women experiencing homelessness
$30,000.00 $10,166.60
Friendly Center Food and Personal Hygiene Distribution $40,000.00 $15,000.00 $246,640.00 $155,166.60
Facilities and Construction $672,388.60
Amount Requested
for 2026
Recommended
Award
Street Rehab Various Streets $667,936.50 $500,000.00
ADA Ramps Various Streets $100,000.00 $100,000.00
Community Development Business Support Assistance to small businesses that qualify for CDBG funding $200,000.00 $72,388.60 $967,936.50 $672,388.60
Admin (20% of Grant) $206,888.80
Amount Requested
for 2026
Recommended
Award
Fair Housing Fair housing services $25,000.00 $25,000.00 CDBG Administration Administration $181,888.80 $181,888.80 $206,888.80 $206,888.80Total Administration
Summary of the Funding Recommendations for CDBG 2025-2026 Program Year Activity
Total Public Services
Activity
Total Facilities and Construction
Activity
840
Orange County Regional
Assessment of Fair Housing
2025-2029

EQUAL HOUSING

OPPORTUNITY
841
Orange County i 25-29 Regional AFH

Acknowledgements
Special thanks to all individuals and organizations that contributed to the planning process, including, but not limited to, the following:

The individuals and organizations (including Equus Workforce Solutions, Project Hope Alliance, Alianza Translatinx, Human Options, Illumination Foundation, The Eli Home, The Cambodian Family, and Orange County Families Forward) who attended the in-person and virtual community meetings.

The organizations that participated in the stakeholder interviews and focus groups, including Fair Housing Council of Orange County, Fair Housing Foundation, Orange County Families Forward, Orange County United Way, Family Assistance Ministry, The HUB OC, National Core, NeighborWorks Orange County, Thomas House Family S helter, Domus Development, Dayle McIntosh Center, CalOptima, and Assistance League of Orange County.

Staff from all jurisdictions that participated in the planning effort, with additional thanks to staff from:
• The Cities of Costa Mesa, La Habra, and Santa Ana, for hosting in-person community meetings.
• The Cities of Anaheim, Aliso Viejo, Buena Park, Fountain Valley, Fullerton, Irvine, San Clemente, Santa Ana, and Rancho Santa Margarita, for advertising the in-person and virtual community meetings through various channels.
• The City of Santa Ana, which served as lead agency responsible for coordinating the development of this report.

842
Orange County ii 25-29 Regional AFH

Cover Photo Credit
The cover photograph for this report was provided courtesy of C&C Development. The photograph features Terraces at Santiago in the City of Santa Ana’s Station District.

Terraces at Santiago is an award-winning 36-unit urban infill transit -oriented multifamily affordable rental housing development featuring a mix of two -, three-, and five-bedroom apartments. In keeping with surrounding neighborhoods, this property was designed with Spanish/Santa Barbara architectural influences. Exterior detailing accents include wrought iron, decorative gables , wall sconces, decorative arches, decorative wood rafter rails, decorative painted wood shutters, and recessed stucco elements with wrought iron lattice.

The building is LEED Gold Certified.

843
Orange County iii 25-29 Regional AFH

Table of Contents
I. Executive Summary ................................ ................................ ................................ ......... 1 II. Community Participation Process ................................ ................................ ................... 3 A. Stakeholder Consultation ................................ ................................ ............................. 3 B. Community Meetings ................................ ................................ ................................ ... 3 III. Fair Housing Analysis ................................ ................................ ................................ ....... 5 A. Demographic and Housing Summary ................................ ................................ ......... 5 B. Segregation/Concentration and Integration ................................ ............................... 37 C. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) .............................. 59 D. Disparities in Access to Opportunity................................ ................................ ...........65

1. Education ................................ ................................ ................................ .................65

2. Employment ................................ ................................ ................................ .............79

3. Transportation ................................ ................................ ................................ ..........91

4. Access to Low Poverty Neighborhoods ................................ ................................ .98

5. Access to Environmentally Healthy Neighborhoods ................................ ........... 111

6. Disability and Access ................................ ................................ ............................. 119

7. Patterns in Disparities in Access to Opportunity ................................ .................. 123 E. Disproportionate Housing Needs ................................ ................................ ............. 128 F. Local and State Policies and Practices Impacting Fair Housing .............................. 142 IV. Fair Housing Issues and Action Plan ................................ ................................ ............ 145 A. Orange County Urban County ................................ ................................ ................... 145

1. Unincorporated Orange County ................................ ................................ ............ 148

2. Brea ................................ ................................ ................................ ........................ 155

3. Cypress ................................ ................................ ................................ ................... 158

4. Dana Point ................................ ................................ ................................ .............. 160

5. La Palma ................................ ................................ ................................ ................. 164

6. Laguna Beach ................................ ................................ ................................ ......... 169

7. Laguna Hills ................................ ................................ ................................ ........... 173

8. Laguna Woods................................ ................................ ................................ ........ 178 844
Orange County iv 25-29 Regional AFH

9. Los Alamitos ................................ ................................ ................................ .......... 181

10. Placentia ................................ ................................ ................................ ................. 183

11. San Juan Capistrano ................................ ................................ .............................. 188

12. Seal Beach ................................ ................................ ................................ .............. 190

13. Stanton ................................ ................................ ................................ ................... 192

14. Villa Park ................................ ................................ ................................ ................. 193

15. Yorba Linda ................................ ................................ ................................ ............ 195 B. Aliso Viejo ................................ ................................ ................................ .................. 198 C. Anaheim ................................ ................................ ................................ ..................... 200 D. Buena Park ................................ ................................ ................................ ................. 205 E. Costa Mesa................................ ................................ ................................ ................. 208 F. Fountain Valley ................................ ................................ ................................ ........... 212 G. Fullerton ................................ ................................ ................................ ..................... 214 H. Garden Grove ................................ ................................ ................................ ............. 224 I. Huntington Beach ................................ ................................ ................................ ...... 227 J. Irvine ................................ ................................ ................................ .......................... 228 K. La Habra ................................ ................................ ................................ ..................... 239 L. Laguna Niguel ................................ ................................ ................................ ............ 243 M. Lake Forest ................................ ................................ ................................ ................. 248 N. Mission Viejo ................................ ................................ ................................ .............. 250 O. Newport Beach ................................ ................................ ................................ .......... 252 P. Orange ................................ ................................ ................................ ........................ 254 Q. Rancho Santa Margarita ................................ ................................ ............................ 257 R. San Clemente ................................ ................................ ................................ ............. 260 S. Santa Ana ................................ ................................ ................................ ................... 263 T. Tustin ................................ ................................ ................................ .......................... 267 U. Westminster ................................ ................................ ................................ ............... 271

845

Orange County 1 25-29 Regional AFH

I. Executive Summary
The Assessment of Fair Housing (AFH) provides communities an opportunity to assess their progress toward the goals of eliminating housing discrimination and promoting access to housing opportunity for both current and future residents . Jurisdictions that receive funding from the U.S. Department of Housing and Urban Development (HUD), including Community Development Block Grant (CDBG), HOME Investment Partnership s Program (HOME), and Emergency Solutions Grant (ESG) funds, complete an AFH at least once every five years, consistent with the Consolidated Plan cycle, as part of their obligations under the Housing and Community Development Act of 1974 and the Cranston- Gonzalez National Affordable Housing Act.

As a fair housing planning document, t he AFH facilitates HUD grantee compliance with statutory and regulatory requirement s to affirmatively further fair housing. Affirmatively furthering fair housing entails taking meaningful actions, in addition to combating discrimination, that overcome patterns of segregation and foster inclusive communities free from barriers that restrict access to opportunity based on protected characteristics. The duty to affirmatively further fair housing applies to all activities and programs within a jurisdiction related to housing and urban development.

This AFH is a collaborative effort among the following jurisdictions:
• Orange County and the Urban County Program participating cities of Brea, Cypress, Dana Point, La Palma, Laguna Beach, Laguna Hills, Laguna Woods, Los Alamitos, Placentia, San Juan Capistrano, Seal Beach, Stanton, Villa Park, and Yorba Linda. • The HUD Entitlement Cities of Aliso Viejo, Anaheim, Buena Park, Costa Mesa, Fountain Valley, Fullerton, Garden Grove, Huntington Beach, Irvine, La Habra, Laguna Niguel, Lake Forest, Mission Viejo, Newport Beach, City of Orange, Rancho Santa Margarita, San Clemente, Santa Ana, Tustin, Westminster.

To prepare the AFH, jurisdictions first must identify fair housing issues. A fair housing issue refers to a condition within a specific geographic area that restricts fair housing choice or limits access to opportunity. Fair housing issues may include ongoing local or regional segregation/concentration or lack of integration, racially or ethnically concentrated areas of poverty, disparities in access to opportunity, disproportionate housing needs, and evidence of discrimination or violations of civil rights law or regulations related to housing.

To iden tify fair housing issues, HUD recommends that jurisdictions gather and analyze data. For this AFH, the jurisdictions analyzed data on the following topics:
• Demographics
• Segregation or Concentration/Integration
• Racially and/or Ethnically Concentrated Areas of Poverty • Disparities in Access to Opportunity
846

Orange County 2 25-29 Regional AFH

• Housing Needs
• Discrimination Complaints
The data utilized in the analysis are from the U.S. Census Bureau American Community Survey (ACS), HUD’s AFFH Data and Mapping Tool, the California Department of Housing and Community Development (HCD) AFFH Data Viewer 2.0 , housing discrimination complaint data provided by HUD’s Office of Fair Housing and Equal Opportunity (FHEO) , and information gathered through the community participation process (described below).

The ACS data utilized in the assessment are from the 2018-2022 five-year estimates, which were the most current data across all participating jurisdictions at the time the analysis was conducted.

After analyzing the data and identifying fair housing issues, jurisdictions then must identify contributing factors. A contributing factor is a ny condition that creates, contributes to, perpetuates, or increases the severity of one or more fair housing issues. For each fair housing issue and its contributing factors, jurisdictions must then develop fair housing goals. A fair housing goal is a specific, meaningful action that can reasonably be expected to create meaningful positive change that affirmatively furthers fair housing by increasing fair housing choice or reducing disparities in access to opportunity.

For the contributing factors and fair housing goals in this AFH, the jurisdictions built upon the extensive work they have already done preparing their most recent Housing Elements, which cover an eight-year planning period. As part of the state-mandated Housing Element, California jurisdictions must conduct a fair housing assessment that includes an analysis of fair housing issues, identification of factors that create and/or contribute to those issues, and development of goals and meaningful actions to affirmatively further fair housing.

Progress toward reaching the goals identified in the Housing Element must then be periodically reported to the state.

A summary of the fair housing issues, significant contributing factors, and fair housing goals for each jurisdiction can be found in Section IV of this AFH.

847

Orange County 3 25-29 Regional AFH

II. Community Participation Process
To develop the AFH, information was also gathered from residents, housing professionals, and service providers. Incorporating information from these sources is important for ensuring that the AFH reflects community needs and knowledge that may not be discernible from other data sources. The community participation process for this AFH involved the following efforts:

A. Stakeholder Consultation
Four one-on-one interviews, and two focus groups were conducted during January and February 2025 with organizations that provide fair housing services and/or housing and services to protected class groups throughout the County. The interviews and focus group sessions discussed the fair housing issues frequently encountered by the organizations, the underlying causes for those issues, and ongoing efforts currently to address them.

Participants also discussed additional actions the ir organizations would recommend.

Invitations to participate in the stakeholder consultation activities were sent to approximately 78 organizations identified by the jurisdictions involved in the planning process. Fourteen organizations, as well as staff from two of the participating jurisdictions, participated in these consultations, including: Fair Housing Council of Orange County, Fair Housing Foundation, Orange County Families Forward, Orange County United Way, Family Assistance Ministry, The HUB OC, National Core, NeighborWorks Orange County, Thomas House Family Shelter, Domus Development, City of Garden Grove, City of Lake Forest, Dayle McIntosh Center, CalOptima, and Assistance League of Orange County. Information gathered through these consultations is incorporated throughout this report.

B. Community Meetings
A total of six community meetings were held in March 2025 to gather public input on the fair housing issues impacting residents of Orange County, and the factors that create, contribute to, perpetuate, or increase the severity of those issues. These meetings included two virtual meetings and four in -person meetings held at the dates, times, and locations listed below.

In-person community meetings:
• March 5, 2025, from 10:30 a.m. – 11:30 a.m. at Santa Ana City Council Chamber, 22 Civic Center Plaza, Santa Ana, CA 92701
• March 5, 2025, from 6:30 p.m. – 7:30 p.m. at Santa Ana City Council Chamber, 22 Civic Center Plaza, Santa Ana, CA 92701
• March 6, 2025, from 10:30 a.m. – 11:30 a.m. at La Habra City Hall, Festival Room, 110 E. La Habra Boulevard, La Habra, CA 90631
• March 6, 2025, from 6:30 p.m. – 7:30 p.m. at Costa Mesa City Hall, Community Room, 77 Fair Drive, Costa Mesa, CA 92626
848

Orange County 4 25-29 Regional AFH

Virtual community meetings:
• March 7, 2025, at 6:00 p.m., via Microsoft Teams
• March 13, 2025, at 1:00 p.m., via Microsoft Teams
Outreach to advertise the community meetings included the following efforts:
• City of Anaheim notified the 250 members of their Homeless Collaborative and community stakeholders.
• City of Aliso Viejo posted a copy of the notice to their City website and shared on social media and city newsletters.
• City of Buena Park posted the public notice on the City website and City Hall bulletin board.
• City of Fountain Valley posted the public notice on the City website • City of Fullerton published the public notice in the Fullerton Observer newspaper , placed the notice on the City of Fullerton website, and placed copies of the notice at various public facilities and libraries as well as over 25 affordable housing sites. • City of Irvine sent copies of the notice to subrecipient partners and other interested parties.
• City of San Clemente posted the public notice on the City website. • City of Santa Ana published the public notice for the public meetings in six languages (English, Spanish, Vietnamese, Korean, Chinese, and Arabic) including the following publications: Orange County Register, La Opinion, Nguoi Viet Daily News, Korea Times, World Journal, and Beirut Times.
• City of Rancho Santa Margarita posted the public notice on bulletin boards outside City Hall, OCFA Station 45, and Trabuco Canyon Water District.

A total of fifteen individuals participated in these meetings to share their knowledge on fair housing issues and contributing factors in Orange County. These included representatives from the following organizations: Equus Workforce Solutions, Project Hope Alliance, Alianza Translatinx, Human Options, Illumination Foundation, The Eli Home, The Cambodian Family, Orange County Families Forward, City of Fountain Valley, and City of Buena Park. Information gathered through these meetings is incorporated throughout this report.

849

Orange County 5 25-29 Regional AFH

III. Fair Housing Analysis
A. Demographic and Housing Summary
Table 1 – Demographics, shows demographic information for the population of Orange County overall, the Orange County Urban County jurisdictions1, the participating HUD Entitlement Cities, and the region2. These data are from the Census Bureau’s 201 8-2022 American Community Survey 5 -year Estimates. Table 2 – Demographic Trends , shows similar data over time, dating back to 1990. These tables indicate the following:

Population
Orange County has a population of 3,175,227. The largest cities in the County are Anaheim (population 347,111), Santa Ana (population 311,379), and Irvine (population 304,527). The Urban County population is 585,178.

Race/Ethnicity
Orange County’s population is majority-minority; however, the largest population group is White (38.46%). Hispanic residents comprise the second largest population group (33.93%), followed by Asian American and Pacific Islanders (AAPI), who make up 21.77% of the County population. African Americans account for 1.54% of the County population.

Compared to the region, Orange County has a higher proportion of White and AAPI residents, and a smaller proportion of Hispanic and Black residents.

Among the participating HUD Entitlement Cities, in comparison to the County overall:
• The Urban County, Aliso Viejo, Costa Mesa, Huntington Beach, Laguna Niguel, Lake Forest, Mission Viejo, Newport Beach, Rancho Santa Margarita, and San Clemente have a significantly higher3 proportion of White residents. • Anaheim, La Habra, and Santa Ana have a significantly higher proportion of Hispanic residents.
• Buena Park, Fountain Valley, Garden Grove, Irvine, and Westminster have a higher proportion of AAPI residents.

Since 1990, the County population has become more diverse, transitioning from a White majority in 1990 to a majority-minority population today. The number of White residents in

1 The Orange County Urban County comprises the County unincorporated area, twelve (12) cities with populations under 50,000 (participating cities) and two (2) cities, Placentia and Yorba Linda, with populations over 50,000 (metropolitan cities).
2 The region is defined by HUD as the Los Angeles -Long Beach-Anaheim Metropolitan Statistical Area (MSA), which comprises Los Angeles and Orange counties.
3 For this analysis, “significantly higher” means that the percentage of residents of a particular race/ethnicity in a city is at least 10% higher than the percentage of residents of the same race/ethnicity in the County overall. 850

Orange County 6 25-29 Regional AFH

the County declined each decade, while the number of Hispanic and AAPI residents grew.

The number of Black residents increased between 1990-2010 but declined over the past decade. These same trends are generally shared with the region and across the Urban County and HUD Entitlement Cities, with the following exceptions:
• In the region, the Black population has been declining since 2000. • In Aliso Viejo, the population of all racial/ethnic groups, including White , has increased in each decade.
• In Costa Mesa, Garden Grove, Huntington Beach, and Newport Beach , the AAPI population has declined over the last decade.
• In Fountain Valley and Garden Grove, the Black population has been declining since 2000.
• In Irvine, the White and Black population s have been increasing since 2000, in addition to growing Hispanic and AAPI populations.
• In La Habra, the Black population continued to grow after 2010. • In Laguna Niguel and Lake Forest, the White population increased during the 1990s before declining over the subsequent decades , and the Black population has continued to grow over the last decade.
• In Rancho Santa Margarita, the White population increased during the 1990s before declining over the last two decades.
• In San Clemente, the White population grew between 1990 -2010, before shrinking slightly over the last decade; and the AAPI population fell over the last decade. • In Santa Ana, the Black population has been falling since 1990, and the Hispanic population has been declining since 2000.
• In Tustin, the Black population has been declining since 1990.

National Origin
Orange County has a foreign-born population of 937,254 (29.52% of the total population4).

The primary countries of origin for the foreign -born population are Mexico (9.17% ) and Vietnam (4.69%).

In the region, 32.52% of the population is foreign born, which is slightly higher than in Orange County.

Among the participating HUD Entitlement Cities, in comparison to the County overall:
• Huntington Beach, Laguna Niguel, Newport Beach, Orange, and San Clemente have significantly lower percentages of foreign-born residents.

4 Source: U.S Census Bureau, 2018-2022 American Community Survey 5-Year Estimates, Table B05006 851

Orange County 7 25-29 Regional AFH

• Garden Grove, Irvine, Santa Ana, and Westminster have significantly higher percentages of foreign-born residents. In these cities, the main countries of origin for the foreign-born population are:
o Garden Grove: Vietnam and Mexico
o Irvine: China (excluding Taiwan), Korea, and India
o Santa Ana: Mexico and Vietnam
o Westminster: Vietnam and Mexico
Since 1990, the County’s foreign -born population has increased in each decade, with the most dramatic increase occurring during the 1990s. In comparison, • The foreign-born population in the region grew between 1990-2010 and has been declining since 2010.
• The foreign-born population has declined in the following jurisdictions:
o The Urban County, Anaheim, La Habra, Orange, and San Clemente, where the foreign-born population has been declining since 2010.
o Costa Mesa and Santa Ana, where the foreign -born population has been declining since 2000. However, in Santa Ana, foreign-born residents still make up approximately half of the total population.
• In Irvine, the foreign-born population has continued to grow rapidly, nearly doubling since 2010.

Limited English Proficiency
Individuals who have Limited English Proficiency (LEP) are those who primarily speak a language other than English and speak English “less than very well .” In Orange County, there are 539,484 LEP individuals5, which is equal to approximately 16.99% of the population. The primary languages spoken by the LEP population in the County are Spanish (11.72%) and Vietnamese (3.45%).

In the region, 21.95% of the population is LEP, which is slightly higher than in Orange County.

Among the participating HUD Entitlement Cities, in comparison to the County overall:
• Aliso Viejo, Newport Beach, and San Clemente, have significantly lower percentages of LEP residents.
• Anaheim, Buena Park, Garden Grove, Santa Ana, and Westminster have significantly higher percentages of LEP residents. In these cities, the primary languages spoken by the LEP population are:
o Anaheim: Spanish and Vietnamese

5 Source: U.S Census Bureau, 2018-2022 American Community Survey 5-Year Estimates, Table S1601 852

Orange County 8 25-29 Regional AFH

o Buena Park: Spanish and Korean
o Garden Grove: Vietnamese and Spanish
o Santa Ana: Spanish and Vietnamese
o Westminster: Vietnamese and Spanish
Between 1990-2010, the County’s LEP population increased. Since 2010, the County’s LEP population has declined, though it remains well above the 1990 LEP population. In comparison:
• The LEP population in the region grew during the 1990s but has been declining since 2000.
• The LEP population has grown each decade since 1990, including since 2010, in the Urban County jurisdictions, Aliso Viejo, Fountain Valley, Irvine, Laguna Niguel, Lake Forest, Mission Viejo, Rancho Santa Margarita, and Westminster. • The LEP population has been declining since 2000 in Anaheim, Costa Mesa, Huntington Beach, and Santa Ana.
• In Garden Grove, Newport Beach, and San Clemente, the LEP population declined between 2000-2010, but has increased since 2010.

Age
Approximately 63.2% of the Orange County population is between the ages of 18 and 64;

15.38% are aged 65 and older, and 21.42% are younger than 18. The age distribution of the population in the region is similar.

Among the participating HUD Entitlement Cities, in comparison to the County overall, the Urban County, Laguna Niguel, Mission Viejo, and Newport Beach all have slightly older populations, with over one-fifth of their population aged 65 and older.

Since 1990, the County’s population has been getting older. Currently, the County’s population has a smaller proportion of the population (when compared to 1990) in both the “Under 18” and “18-64” year-old age categories, and a higher proportion of the population in the “65+” age category. The same general trend is evident in the region and all other jurisdictions, except for Aliso Viejo, where the percentage of the population under age 18 has increased, and the percentage of the population aged 65 and older has decreased, since 1990.

Families with Children
In Orange County, approximately 41.56% of families have children. This is slightly higher than the region, where 40.02% of families have children. Among the participating HUD Entitlement Cities, in comparison to the County overall:
853

Orange County 9 25-29 Regional AFH

• Aliso Viejo and Tustin have significantly higher percentages of families with children (52.06% and 52.64%, respectively), and in Irvine, over half (50.45%) of families have children.
• Laguna Niguel, Huntington Beach, Newport Beach, and Westminster have the lowest percentages of families with children, although the percentages are not significantly lower than those for the County overall.

The percentage of families with children in the County is lower today than it was in 1990, when 48.04% of families had children. This is also true in the region and the other jurisdictions, with the following exceptions:
• Aliso Viejo, Newport Beach, and Tustin, where the current percentage of families with children is higher than it was in 1990.

Table 1 – Demographics

854

Orange County 10 25-29 Regional AFH

Table 1 – Demographics (continued)

855

Orange County 11 25-29 Regional AFH

Table 1 – Demographics (continued)

856

Orange County 12 25-29 Regional AFH

Table 1 – Demographics (continued)

857

Orange County 13 25-29 Regional AFH

Table 1 – Demographics (continued)

858

Orange County 14 25-29 Regional AFH

Table 1 – Demographics (continued)

859

Orange County 15 25-29 Regional AFH

Table 1 – Demographics (continued)

860

Orange County 16 25-29 Regional AFH

Table 1 – Demographics (continued)

861

Orange County 17 25-29 Regional AFH

Table 2 – Demographic Trends

862

Orange County 18 25-29 Regional AFH

Table 2 – Demographic Trends (continued)

863

Orange County 19 25-29 Regional AFH

Table 2 – Demographic Trends (continued)

864

Orange County 20 25-29 Regional AFH

The following paragraphs d escribe housing patterns, including tenure, cost burden, and the location of renters and owners.

Tenure
Table 3 - Housing Tenure, shows data on housing tenure for the region, Orange County, the Orange County Urban County jurisdictions, and each HUD Entitlement City. These data are from the 2018-2022 American Community Survey 5-Year Estimates. This table indicates the following:

In Orange County overall, the homeownership rate is 56.5%. This is higher than the homeownership for the region, which is 48.7%. Among the jurisdictions, • The following have a comparable homeownership rate (within five percentage points of the County’s rate)
o Aliso Viejo
o Buena Park
o Fullerton
o Garden Grove
o Huntington Beach
o La Habra
o Newport Beach
o Orange
o Westminster
• The following jurisdictions have a homeownership rate that is lower than the homeownership rate for the County overall by at least five percentage points , indicating a higher percentage of households are renters:
o Anaheim
o Costa Mesa
o Irvine
o Santa Ana
o Tustin
• The following jurisdictions have a homeownership rate that is higher than the County overall by at least five percentage points:
o The Urban County jurisdictions
o Fountain Valley
o Laguna Niguel
o Lake Forest
o Mission Viejo
o Rancho Santa Margarita
o San Clemente

865

Orange County 21 25-29 Regional AFH

Table 3 – Housing Tenure

866

Orange County 22 25-29 Regional AFH

Cost Burden
Table 4 – Cost Burden shows data on housing cost burden for the region, Orange County, the Orange County Urban County, and each HUD Entitlement City. These data are from the 2018-2022 American Community Survey 5 -Year Estimates. Cost burden is defined as spending more than 30% of monthly gross income on housing -related costs. This table presents the following:

In Orange County overall, over half (53.2%) of all renters are cost burdened. The rate is significantly lower for homeowners (30.3%). These rates are comparable to the experience of owners and renters across the region. Among the jurisdictions, • The following have a comparable rate of cost burdened renters (within five percentage points of the County’s rate)
o The Urban County jurisdictions
o Aliso Viejo
o Buena Park
o Costa Mesa
o Fullerton
o Garden Grove
o Huntington Beach
o Irvine
o Laguna Niguel
o La Habra
o Mission Viejo
o Orange
o Rancho Santa Margarita
o Santa Ana
o Westminster
• The following jurisdictions have a renter cost-burden rate that is lower than the rate for the County overall by at least five percentage points:
o Newport Beach
o San Clemente
• The following jurisdictions have a renter cost-burden rate that is higher than the rate for the County overall, by at least five percentage points , meaning a higher percentage of renters in these jurisdictions are cost burdened compared to the County overall:
o Anaheim
o Fountain Valley
o Lake Forest
o Tustin
867

Orange County 23 25-29 Regional AFH

Table 4 – Cost Burden

868

Orange County 24 25-29 Regional AFH

Location of Renters and Owners
Map 1 – Housing Tenure. is a series of maps showing the distribution of renter households in the region, and in northern, central, and southern Orange County. These maps were produced by California HCD to facilitate the fair housing planning process 6. On the maps, the darker shaded areas have a higher proportion of renter households. These maps reflect the following:
• In Orange County overall, renters are concentrated in the north, west, and central parts of the County. Moving east and south from the border with L os Angeles County, a higher percentage of housing units are owner-occupied.

Within the participating jurisdictions, there are concentrations of renter -occupied and owner-occupied housing in the following areas:
• In the Orange County Urban County jurisdictions there are relatively few areas with a high percentage of renter households, with the exceptions of Placentia, which has high concentrations of renter households in the southwest corner of the city and in parts of the city near CSU-Fullerton; and Los Alamitos, which has a high concentration of renters in the neighborhood north of Joint Forces Training Base Los Alamitos and west of Lexington Drive . Conversely, there are various parts of the Urban County jurisdictions with relatively high concentrations of owner households, including Yorba Linda and the unincorporated area to the east of Yorba Linda, North Tustin, Seal Beach (outside the Naval Weapons Station), Rossmoor , Villa Park, Orange Park Acres, and Northwest Brea.
• In Aliso Viejo there is a relatively high percentage of renter households south of SR- 73 between Aliso Viejo Parkway and Woodfield Park, and a relatively high percentage of owner households along the southern and western edges of city, south of SR-73 and west of Pacific Park Drive and Wood Canyon Drive.
• In Anaheim there are relatively high percentages of renter households in the Census Tracts north of SR-91 in Northeast Anaheim; between the Convention Center and I- 5, and around Angel Stadium, in the southeastern part of the city; and in the Census Tract south of I -5 bounded by Lincoln Ave nue and Brookhurst St reet, in the northwestern part of the city. There is a relatively high percentage of owner households in Anaheim Hills.
• In Buena Park there is a relatively high percentage of renters in the Census Tracts just north of I-5.

6 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 869

Orange County 25 25-29 Regional AFH

• In Costa Mesa there are relatively high concentrations of renter households north of SR-55 in the downtown area, and west of Orange Coast College ; and there is a relatively high percentage of owner households north of Adams Avenue. • In Fountain Valley there are relatively high percentages of owner households in the neighborhoods south of Talbert Avenue and west of Brookhurst St reet, and in the neighborhood just to the west of Mile Square Regional Park. • In Fullerton there are relatively high percentages of renter households in and around CSU Fullerton and along Highland Ave between SR -91 and Orangethorpe Avenue (adjacent to the Fullerton Metrocenter shopping mall); and there are relatively high percentages of owner households in Census Tracts between CSU Fullerton and Brea Boulevard, and between Harbor Boulevard and the Robert E. Ward Nature Preserve. • In Garden Grove, there is a relatively high percentage of owner households in West Garden Grove, compared to the rest of the city.
• In Huntington Beach there are high percentages of owner households in the eastern half of the city, as well as in the area surrounding the Huntington Club country club. • In Irvine there are relatively high percentages of renter households in the southwestern part of the city—specifically in the Census Tracts west of Harvard Ave, around San Remo Park, and north of UC Irvine in University Town Center; and near the I-5/I-405 interchange—specifically in the Census Tracts encompassing the Irvine Medical and Science Complex, the Irvine Spectrum Center, and East Irvine. • In La Habra there are a relatively high percentage of owner households in the neighborhoods south of SR-90 and west of Euclid St.
• In Laguna Niguel there are relatively high percentages of owner households in the southeast corner of the city (bordering San Juan Capistrano and Dana Point), adjacent to the El Niguel County Club, and in the neighborhoods between Crown Valley Pkwy and Alicia Pkwy.
• In Lake Forest there are relatively high percentages of owner households in the northeast of the city (to the north of SR -24) and in the southwest of the city (south of Trabuco Rd and west of Ridge Route Dr).
• In Mission Viejo there are relatively high percentages of owner households throughout the city, with some renters located in the southern part of the city. • In Newport Beach there is a relatively high percentage of owner households in the Newport Coast community, and a relatively high percentage of renters around the Newport Beach Country Club.
• In the City of Orange there are relatively high percentages of renter households in the southwestern corner of the city, west of SR -57 and I -5, and relatively high percentages of owner households in the eastern half of the city. • In Rancho Santa Margarita there is a relatively high percentage of owner households throughout the city, with some renters located in the neighborhoods just to the east of SR-241 between Antonio Pkwy and Santa Margarita Pkwy. 870

Orange County 26 25-29 Regional AFH

• In San Clemente there is a relatively high percentage of renter households in the neighborhoods south of Max Berg Plaza Park, and relatively high percentages of homeowners in a number of neighborhoods to the north and northwest. • In Santa Ana there are relatively high percentages of renter households in the downtown area and in the neighborhoods southeast of downtown. • In Tustin there are relatively high percentages of renter households in the neighborhoods adjacent to SR -55 south of I -5, and relatively high percentages of owner households in the northeast part of the city.
• In Westminster there are relatively high percentages of renters in the neighborhoods just north and south of Westminster Blvd between Hoover St. and Beach Blvd.

Map 1 – Housing Tenure – Region

Source: California HCD, AFFH Data Viewer
871

Orange County 27 25-29 Regional AFH

Map 1 – Housing Tenure – North Orange County

Source: California HCD, AFFH Data Viewer

872

Orange County 28 25-29 Regional AFH

Map 1 – Housing Tenure – Central Orange County

Source: California HCD, AFFH Data Viewer

873

Orange County 29 25-29 Regional AFH

Map 1 – Housing Tenure – South Orange County

Source: California HCD, AFFH Data Viewer

874

Orange County 30 25-29 Regional AFH

Demographics of residents of publicly supported housing.

Table 5 – Publicly Supported Households by Race/Ethnicity, provides the demographics of residents of different types of publicly support housing programs, including Public Housing, Project -Based Section 8, Other Multifamily, and the Housing Choice Voucher (HCV) Program. This table shows that, in Orange County:
• The majority of publicly supported housing is provided through the HCV Program (over 20,000 households with HCVs countywide). Additionally, there are approximately 4,000 units in Project-based Section 8 properties and approximately 100 units in Other Multifami ly properties. There are no Public Housing units in the County.
• A significant portion of households with HCVs are headed by an AAPI individual (41.16%), followed by households headed by a White individual (25.32%), then Hispanic-headed households (21.12%), and then Black households (7.06%). • Project-based Section 8 units have a similar racial composition to the HCV Program overall; however, the percentages of households headed by AAPI and White individuals are higher (47.11% and 33.06% respectively), and households headed by Hispanic and Black individuals are lower (15.19% and 1.77% respectively).

Within the participating jurisdictions, the racial/ethnic composition of publicly supported housing units varies:
• In the Orange County Urban County jurisdictions, the racial/ethnic composition of households in the HCV Program and in Project -based Section 8 units matches the County overall, with the one exception being that the number of AAPI and White households in Project -based Section 8 units are equal (each comprise 36.75% of those units).
• In Aliso Viejo, the only publicly supported housing available is through the HCV Program. Two-thirds of households using HCVs in the city are White. • In Anaheim, there are Project -based Section 8 developments in addition to households using HCVs. In the Project -based Section 8 units, the majority of households are AAPI. In the HCV Program, Hispanic households make up the largest single group of voucher recipients, followed by AAPI and White households. • In Buena Park, the overwhelming majority of households in Project-based Section 8 units are AAPI. In the HCV Program, approximately one-third of households are Hispanic, 25% AAPI, 25% White, and nearly one-fifth of households are Black. • In Costa Mesa, the majority of households in both Project-based Section 8 housing and the HCV Program are White, and there are no Black households in Project-based Section 8 units.
875

Orange County 31 25-29 Regional AFH

• In Fountain Valley, the majority of households in both Project -based Section 8 housing and the HCV Program are AAPI, and there are no Black households in Project-based Section 8 units.
• In Fullerton, nearly all of the households in Project -based Section 8 units are AAPI and the majority of households in Other Multifamily program units are White. In the HCV Program, White and Hispanic families each make up approximately one-third of households, and Black and AAPI families each make up approximately 14% of households.
• In Garden Grove, a large majority of households in both Project -based Section 8 housing and the HCV Program are AAPI (over 80% in each program). • In Huntington Beach, over 50% of households in Project -based Section 8 units are AAPI and around one-third are White. In the HCV Program, over 40% of households are White and around one-third are AAPI.
• In Irvine, White households are the majority in Project -based Section 8 and Other Multifamily program units and are the largest share of households in the HCV Program (46.76%). In the HCV Program, Black households are the second largest racial/ethnic group, comprising approximately one-fifth of households. • In La Habra, Hispanic households are the majority of HCV Program participants. The second largest racial/ethnic group is White households, who comprise 25% of households in the program. In Project -based Section 8 units, Hispanic, White, and AAPI each comprise approximately one-third of households. • In Laguna Niguel, the majority of households in both Project -based Section 8 housing and the HCV Program are White.
• In Lake Forest, the majority of households in the HCV Program are White. There are no other types of publicly supported housing in the city. • In Mission Viejo, the majority of households in the HCV Program are White. There are no other types of publicly supported housing included in the HUD-provided data. (However, per the City’s Housing Element and other local sources, there are various publicly supported housing developments in the city.)
• In Newport Beach, the majority of households in both Project -based Section 8 housing and the HCV Program are White.
• In Orange, White and Hispanic households each comprise a slightly more than 40% of households in Project -based Section 8 units, and approximate ly one -third of households in the HCV Program. AAPI households make up around 25% of households in the HCV Program.
• In Rancho Santa Margarita, the majority of households in the HCV Program are White. There are no other types of publicly supported housing in the city. • In San Clemente, the majority of households in both Project -based Section 8 housing and the HCV Program are White.
876

Orange County 32 25-29 Regional AFH

• In Santa Ana, the majority of households in Project-based Section 8 units and in the HCV Program are AAPI. The second largest racial/ethnic group in each of these programs is Hispanic households.
• In Tustin, the majority of households in Project-based Section 8 units are AAPI (over 70%) and approximately one -fifth are White. In the HCV Program, Hispanic households are the largest group (38%), followed by White households (33%). • In Westminster, AAPI households are the majority in both Project -based Section 8 units and in the HCV Program.

877

Orange County 33 25-29 Regional AFH

Table 5 – Publicly Supported Households by Race/Ethnicity

878

Orange County 34 25-29 Regional AFH

Table 5 – Publicly Supported Households by Race/Ethnicity (continued)

879

Orange County 35 25-29 Regional AFH

Table 5 – Publicly Supported Households by Race/Ethnicity (continued)

880

Orange County 36 25-29 Regional AFH

Table 5 – Publicly Supported Households by Race/Ethnicity (continued)

881

Orange County 37 25-29 Regional AFH

B. Segregation/Concentration and Integration
Describe segregation /concentration levels and identify the racial/ethnic groups that experience the highest levels of segregation /concentration. Explain how these segregation/concentration levels and patterns have changed over time.

Table 6 – Racial/Ethnic Dissimilarity Trends , displays how segregated /concentrated or integrated various racial/ethnic groups are in the region, the Orange County Urban County, and the HUD Entitlement Cities using a Dissimilarity Index, which is calculated using data from the 2010 Decennial Census. The Dissimilarity Index measures the degree to which two groups are evenly distributed across a geographic area and is commonly used for assessing residential segregation between two groups. Dissimilarity index values indicate the following:
• Values between 0 and 39 generally indicate high integration (low segregation/concentration)
• Values between 40 and 54 generally indicate moderate segregation/concentration • Values between 55 and 100 generally indicate a high level of segregation/concentration
Please note two key shortcomings of these data:

1. The data only measure segregation between Black and White, Hispanic, and White, and AAPI and White residents. As a result, no conclusions can be drawn regarding segregation among Black, Hispanic, and AAPI residents.

2. The data measure segregation only within each jurisdiction and do provide insights into racial/ethnic segregation across jurisdictional boundaries.

Table 6 shows that, in the region, there are high levels of segregation between Black and White residents and between Hispanic and White residents, and there is moderate segregation between AAPI and White residents. Since 1990, segregation between Black and White residents has declined, while segregation between Hispanic/White and AAPI/White has increased.

In Orange County the following jurisdictions are highly integrated, indicating low levels of segregation/concentration among the groups analyzed:
• The Urban County jurisdictions – While segregation levels are higher compared to 1990, they have trended downward since 2000 for Black/White and Hispanic/White residents.
• Aliso Viejo – Since 1990, concentrations of Hispanic and AAPI residents have been increasing but remain low.
882

Orange County 38 25-29 Regional AFH

• Anaheim – Segregation levels between Black/White and AAPI/White have been increasing since 1990. Segregation level between Hispanic/White were high in 2000 but have since declined.
• Buena Park – Segregation levels have increased since 1990 but remain low. • Fountain Valley – Since 1990, segregation levels between Hispanic/White and between AAPI/White have been increasing but remain low. • Fullerton – Segregation level between AAPI/White is increasing but remains low. • Garden Grove – Segregation levels have increased since 1990 but remain low. • Huntington Beach – Segregation level between Black/White increased between 2000-2010 but remains low.
• Irvine – Segregation levels between the groups analyzed decreased between 2000- 2010.
• La Habra – Since 1990, segregation between Black/White residents has increased, though remains low, and segregation between Hispanic/White and between AAPI/White has decreased.
• Laguna Niguel – Between 1990-2010, concentrations of Black and Hispanic residents increased, though remain low.
• Lake Forest – Between 1990-2010, segregation between Hispanic/White and between AAPI/White increased, though remains low.
• Mission Viejo – Between 1990-2010, concentration of Hispanic residents increased, though remains low.
• Newport Beach – Between 1990 -2010, segregation between Hispanic/White and between AAPI/White increased, though remains low.
• Orange – Between 1990-2010, segregation between AAPI/White increased, though remains low.
• Rancho Santa Margarita – Concentration by race/ethnic group has increased since 1990 but remains low.
• Westminster – Segregation levels have increased since 1990 but remain low.

In Orange County the following jurisdictions have moderate levels of segregation between at least two of the racial groups analyzed (no jurisdictions in the County have high levels of segregation):
• Costa Mesa – There is moderate segregation between Hispanic and White residents.

Segregation levels declined slightly between 2000-2010 but remain moderate. • Santa Ana – There is moderate segregation between Hispanic and White residents, and between AAPI and White. Segregation levels between Hispanic/White residents declined slightly between 2000-2010 but remain moderate. Since 1990, segregation between AAPI/White residents has increased.
• Tustin – There is moderate segregation between Hispanic and White residents.

Segregation levels declined between 2000-2010 but remain moderate. 883

Orange County 39 25-29 Regional AFH

Table 6 - Racial/Ethnic Dissimilarity Trends

884

Orange County 40 25-29 Regional AFH

Identify areas with relatively high segregation /concentration and integration and indicate the predominant groups living in each area.

Race/Ethnicity
Map 2 – Racial/Ethnic Concentration is a series of maps showing racial/ethnic concentrations in the region, and in northern, central, and southern Orange County. These maps are published by California HCD using methodology from the Othering & Belonging Institute, which combines various measures of segregation and integration (including a dissimilarity index), and uses data from 2020. On these maps, dark red indicates areas where people of color (POC) experience high levels of segregation /concentration; green indicates areas where White residents experience high levels of segregation/concentration; yellow indicates areas that are racially/ethnically integrated.

Map 3 – Predominant Population by Race/Ethnicity , is a series of maps showing the predominant racial/ethnic group by Census Tract in the region, and in northern, central, and southern Orange County. The colors indicate different racial/ethnic groups, and the relative strength of the shading indicates the extent to which one group is dominant over the next most populous group (with d arker shading indicating a higher concentration of that racial/ethnic group). These maps were created by California HCD using 2017-2021 ACS data, to facilitate fair housing planning.7
Collectively, the maps illustrate that in Orange County overall, there are areas of high POC segregation/concentration in the central and northern parts of the County (including the cities of Santa Ana, Westminster, Garden Grove, Anaheim, and Fullerton), and there are areas of high White segregation/concentration along the entire coast (including Seal Beach, Huntington Beach, Newport Beach, Laguna Beach, Dana Paint, Capistrano Beach, and San Clemente) and in the southern part of the County (including Mission Viejo, Aliso Viejo, Laguna Niguel, and Rancho Santa Margarita).

Within each participating jurisdiction, there are areas of high segregation/integration in the following locations:
• In the Orange County Urban County jurisdictions,
o There are areas of h igh White segregation in Dana Point, Laguna Beach, Laguna Hills, Laguna Woods, the unincorporated areas east of Rancho Santa Margarita, North Tustin, Seal Beach , Yorba Linda, north ern Placentia, Villa Park, and Orange Park Acres.
o There are areas of high POC segregation in Stanton (which are predominantly Hispanic or AAPI), Cypress (which are predominantly AAPI), northern Yorba

7 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 885

Orange County 41 25-29 Regional AFH

Linda (which are predominantly AAPI), La Palma (which are predominantly AAPI), and San Juan Capistrano (which is predominantly Hispanic). o There are areas of i ntegration including the Atwood neighborhood in Placentia, which is predominantly Hispanic ; Brea just northwest of the SR - 90/SR-57 interchange, which is a predominantly Hispanic area ; and in Los Alamitos, in the neighborhood north of Joint Forces Training Base Los Alamitos and west of Lexington Drive, which is predominantly Hispanic. • In Aliso Viejo, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration (which are predominantly White) in the northern and eastern parts of the city. • In Anaheim, the map shows integrated areas in Southeast Anaheim (where Hispanic residents are the predominant group), in western Anaheim west of Brookhurst Street (where Hispanic residents are the predominant group in many neighborhoods, and AAPI residents are the predominant group in a few others), and in the neighborhoods between Modjeska Park and Palm Lane Park in the Hermosa Village community (where Hispanic residents are the predominant group). The map shows another integrated area in Northeast Anaheim, to the north of SR-91. However, this is primarily an industrial/commercial area. The city also has neighborhoods of high POC segregation, including the neighborhoods north of downtown and along SR - 91, and neighborhoods south of downtown and adjacent to Disneyland. These areas are predominantly Hispanic. The Anaheim Hills area demonstrates a high White segregation.
• In Buena Park, most of the city is considered an area of low-medium segregation with the exception of the following areas: the northeast corner of the city is considered an area of high POC segregation and is predominantly AAPI; the neighborhood between I -5, Artesia Boulevard, Beach Boulevard, and the L os Angeles County border is also considered an area of high POC segregation, and is predominantly Hispanic; and the neighborhoods south of Boisseranc Park between Dale Street and the nurseries, is considered a racially integrated area. • In Costa Mesa, the neighborhoods between downtown and the Costa Mesa Country Club are areas of high POC segregation, with a predominantly Hispanic population.

The neighborhoods in East Side Costa Mesa (east of SR-55 and south of Mesa Drive) are all areas of high White segregation, as are the neighborhoods north of the Country Club and the neighborhoods between Estancia High School and Canyon Park.
• In Fountain Valley, the majority of Census Tracts are considered areas of high POC segregation, and many have a predominantly AAPI population (particularly north of Warner Ave nue). The neighborhoods surrounding the intersection of Magnolia Street and Ellis Avenue in the city’s southwest, and between Brookhurst Street and Ward Street south of I-405, are considered areas of high White segregation. 886

Orange County 42 25-29 Regional AFH

• In Fullerton, there are various neighborhoods that are considered racially integrated, including in the area around CSU Fullerton and extending west to Fullerton College, and in the southwest area of the city. There are also areas considered to have high POC segregation, including most of the neighborhoods west of Harbor Boulevard and north of Malvern Avenue, which are predominantly AAPI areas. • In Garden Grove , the majority of the city is considered an area of high POC segregation except for West Garden Grove. In West Garden Grove, the residential neighborhoods west of Knott Street are considered areas of high White segregation.

East of Knott Street is primarily industrial and commercial land uses. In the high POC segregation areas, AAPI residents are the predominant group west of 9th Street and Hispanic residents are the predominant group east of there. • In Huntington Beach, most of the city ’s neighborhoods are predominantly White, with the exception of one Census Tract in the center of the city that is predominantly Hispanic.
• In Irvine, there are a number of Census Tracts considered to be areas of high POC segregation, some of which are predominantly AAPI and others are predominantly White. These areas include the neighborhoods between I -405 and UC Irvine , the Westpark community north of I-405, the neighborhoods between Como Channel and I-5, and the Northwood community north of I -5. There are also areas of high White segregation in Irvine, including the neighborhood bounded by Turtle Rock Drive the area surrounding the Strawberry Farms Golf Club, the Woodbridge community north of I-405, and the neighborhood west of the Oak Creek Golf Club. Please note that data was unavailable for many parts of the city, as indicated by the grey shading. • In La Habra , there are various neighborhoods considered to have high POC segregation, including neighborhoods in the center of the city north of Guadalupe Park and between Idaho Street to the west and Sonora High School to the east. These neighborhoods are predominantly Hispanic. The city also has two racially integrated areas, one that extends across its border to the west (between SR-90 and the railroad tracks) and another that extends across its border to the south (south of SR -90 and east of Euclid St).
• In Laguna Niguel, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration (which are predominantly White) in the northeastern and eastern parts of the city. • In Lake Forest , most of the city’s neighborhoods have a predominantly White population. There are predominantly Hispanic neighborhoods in the southeast corner of the city, along El Toro R oad, and t he northwest corner of the city is predominantly AAPI.
• In Mission Viejo, most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low-medium concentration in the southern, northern, and western parts of the city.
887

Orange County 43 25-29 Regional AFH

• In Newport Beach, the entire city is classified as an area of high White segregation. • In Orange, most of the city to the north and east of Villa Park is considered an area of high White segregation, and most of the city to the south and west of Villa Park is considered an area of low-medium POC segregation. In the low-medium segregation areas, the neighborhoods are predominantly Hispanic west of Glassel Street with a high concentration of Hispanic residents in the neighborhoods north of Walnut Ave nue. The neighborhoods between Glassel St reet and SR -55 are predominantly White, and the neighborhoods east of SR-55 and south of Villa Park are predominantly Hispanic. There is one area in the city that is considered integrated. This area lies to the south of Villa Park and runs south along Santiago Creek and east along the northside of Chapman Avenue toward El Modena. • In Rancho Santa Margarita , most of the city is considered an area of high White concentration, with the exception of a few neighborhoods with low -medium concentration (which are predominantly White) in the neighborhoods east of SR-241 between Antonio Parkway and Santa Margarita Parkway.
• In San Clemente , the majority of the city is considered an area of high White concentration, with the exception of one Census Tract encompassing neighborhoods north and east of Max Berg Plaza Park, which is classified as low-medium concentration with a predominantly White population.
• In Santa Ana, the majority of the city is considered an area of high POC segregation and has a predominantly Hispanic population except for the Riverview West community which is predominantly AAPI. There are some areas of low-medium POC segregation in the city, including the neighborhoods north of I -5, Floral Park, West Floral Park, Fisher Park, Morrison/Eldridge Park, Riverglen, Casa de Santiago, and neighborhoods south of Warner Avenue. There is one integrated area in the southern part of the city between Segerstrom High School and the Bristol Place Shopping Mall, where White residents are the predominant group.
• In Tustin, there are racially integrated neighborhoods just to the north of I -5. These are surrounded by neighborhoods of low-medium segregation that are a mix of predominantly White, Hispanic, and AAPI.
• In Westminster, the majority of the city is considered an area of high POC segregation and has a predominantly AAPI population with a few exceptions. The northwestern corner of the city, between I -405 and Bolsa Chica R oad is an area of high White segregation. Across I -405 from those neighborhoods is an integrated area with a predominantly Hispanic population (west of Edwards Avenue). This area includes mobile home parks near the intersections of SR-22 and I-405.

888

Orange County 44 25-29 Regional AFH

Map 2 – Racial/Ethnic Concentration – Region

Source: California HCD, AFFH Data Viewer

889

Orange County 45 25-29 Regional AFH

Map 2 – Racial/Ethnic Concentration – North Orange County

Source: California HCD, AFFH Data Viewer

890

Orange County 46 25-29 Regional AFH

Map 2 – Racial/Ethnic Concentration – Central Orange County

Source: California HCD, AFFH Data Viewer

891

Orange County 47 25-29 Regional AFH

Map 2 – Racial/Ethnic Concentration – South Orange County

Source: California HCD, AFFH Data Viewer

892

Orange County 48 25-29 Regional AFH

Map 3 – Predominant Population by Race/Ethnicity – Region

Source: California HCD, AFFH Data Viewer

893

Orange County 49 25-29 Regional AFH

Map 3 – Predominant Population by Race/Ethnicity – North Orange County

Source: California HCD, AFFH Data Viewer

894

Orange County 50 25-29 Regional AFH

Map 3 – Predominant Population by Race/Ethnicity – Central Orange County

Source: California HCD, AFFH Data Viewer

895

Orange County 51 25-29 Regional AFH

Map 3 – Predominant Population by Race/Ethnicity – South Orange County

Source: California HCD, AFFH Data Viewer
The fo llowing analysis compares the locations of publicly supported housing with the areas of concentration.

Map 4 - Publicly Supported Housing, is a series of maps showing the location of federal- and state-subsidized housing in the region, and in northern, central, and southern Orange County. These maps were created by California HCD to facilitate fair housing planning, using data from California Housing Partnership 8. On the maps, t he size of each dot correlates to the number of publicly -supported housing units in an area —larger dots indicate higher numbers of units. The shading of the Census Tract s indicates the percentage of renter occupied housing units in that Tract that are supported by a HCV, including both tenant -based and project -based vouchers. The darker shading indicates higher percentages of vouchers.

The locations of publicly supported housing on these maps align with the areas of segregation and integration on Map 2 (Racial/Ethnic Segregation/Integration), in the following places:

8 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 896

Orange County 52 25-29 Regional AFH

• In the Orange County Urban County jurisdictions,
o There is overlap between the location of publicly supported housing, including a high rate of voucher use, and areas of high POC segregation in the following places:
 Cypress – in the neighborhood around King Elementary School, in the north of the city.
 Placentia – in the southwest corner of the city
 Stanton – throughout the city
 San Juan Capistrano – in the Census Tract that encompasses the interchange between I-5 and the Ortega Highway (SR-74)
o There is overlap between areas without any publicly supported housing and either low HCV use or no data on HCV use, and areas of high White segregation, the following places:
 Rossmoor, Seal Beach, North Tustin, Villa Park, Orange Park Acres, North Laguna Hills, Laguna Woods, and Dana Point
• In Aliso Viejo, there are publicly supported units and higher percentages of units with vouchers in the south of city, which is an area of high White concentration. • In Anaheim, there are multiple publicly supported housing developments downtown and north of downtown, which are high POC segregation areas. The map also shows a concentration of vouchers in the high POC segregation area between Santa Ana River and Orangethorpe Ave nue, east of Anaheim Canyon Metrolink station and west of Imperial Highway (SR-90). However, this is largely a commercial/industrial area with few housing units. In the western part of the city, around Western High School, there is also a cluster of publicly supported housing developments in a racially integrated area.
• In Buena Park, most publicly supported housing units are located in between I-5 and the Artesia Freeway (SR-91), which is a low-medium segregation area like most of the city.
• In Costa Mesa, the largest number of publicly supported housing units and the highest concentration of vouchers is in high POC segregation area located downtown and west of downtown.
• In Fountain Valley, the location of publicly supported housing units and highest concentrations of vouchers mirrors the high POC segregation areas. • In Fullerton, publicly supported housing units are mostly clustered in the center of the city, which is a low-medium segregation area.
• In Garden Grove, there are lots of publicly supported housing units in the center of city along Garden Grove Boulevard , which is a high POC segregation area.

There are no publicly supported housing units in West Garden Grove, which is an area of high White segregation.
897

Orange County 53 25-29 Regional AFH

• In Huntington Beach, the map shows publicly supported housing units located in the center of the city. Local data identify affordable housing projects distributed broadly across the city.
• In Irvine, the high POC segregation areas north of I-405 overlap with the location of publicly supported housing units. In other parts of the city where there is high voucher use and multiple publicly supported housing developments, there is no segregation data available.
• In La Habra, publicly supported housing units are located in the city’s center and north neighborhoods, which are all low-medium or high POC segregation areas. • In Laguna Niguel, the map shows one public supported housing development (near the intersection of Pacific Park Drive and La Paz Road ) and a small concentration of voucher use in northwest part of city , which is a low-medium concentration area. City staff report that another development, Alicia Park Apartments, also receives Project-Based Section 8 assistance. • In Lake Forest, there are publicly supported housing units in the northwest, near the intersection of SR-241 and Alton Parkway. There are a smaller number of units in the south of the city, along El Toro Road.
• In Mission Viejo, the map shows two publicly supported housing developments in the southern part of the city . One of these developments , in the southeast, aligns with a low-medium concentration area. City staff report that there are additional publicly supported housing developments that are not reflected in the HUD-provided data.
• In Newport Beach, there are two publicly supported housing developments (one east and one west of Newport Center) , both of which are in high White segregation areas.
• In Orange, all publicly supported housing units and households with vouchers are located to the west and south of Villa Park ( which are low-medium segregation areas). There are no units or vouchers in use to the east of Villa Park, where it is a high White segregation area. The largest publicly supported housing development (biggest blue dot) is in the integrated area to the south of Villa Park, running south along Santiago Creek and east along the northside of Chapman Avenue towards El Modena.
• In Rancho Santa Margarita, there are no publicly supported housing units. There are some vouchers in use in the northeast part of the city that is a low-medium concentration area
• In San Clemente, there is a c luster of publicly supported housing units in the low- medium concentration area north and east of Max Berg Plaza Park. • In Santa Ana, a significant number of publicly supported housing units are located downtown and southeast of downtown, both of which are high POC segregation areas. There is a h igher concentration of vouchers, as well as some publicly 898

Orange County 54 25-29 Regional AFH

supported housing units, west of the Santa Ana River, which is also a high POC segregation area.
• In Tustin, there is a large concentration of publicly supported housing units in the south. Segregation data for this area are unavailable; however, according to Map 3 (Predominant Population by Race/Ethnicity) the population is predominantly AAPI. • In Westminster, the location of publicly supported housing units and areas with highest concentration of vouchers aligns with the high POC segregation areas in the central part of the city. There are no publicly supported housing units, and fewer vouchers in use, in the western parts of the city that are high White segregation , racially integrated, and low-medium segregation areas.

Map 4 - Publicly Supported Housing – Region

Source: California HCD, AFFH Data Viewer

899

Orange County 55 25-29 Regional AFH

Map 4 - Publicly Supported Housing – Region (HCV Only)

Source: California HCD, AFFH Data Viewer

900

Orange County 56 25-29 Regional AFH

Map 4 - Publicly Supported Housing – North Orange County

Source: California HCD, AFFH Data Viewer

901

Orange County 57 25-29 Regional AFH

Map 4 - Publicly Supported Housing – Central Orange County

Source: California HCD, AFFH Data Viewer

902

Orange County 58 25-29 Regional AFH

Map 4 - Publicly Supported Housing – South Orange County

Source: California HCD, AFFH Data Viewer
The following analysis describes the public or private policies or practices, demographic shifts, economic trends, or other factors that may have caused or contributed to the patterns described above (including siting decisions of private or publicly supported housing or the location of residents using Housing Choice Vouchers).

Broadly speaking, the patterns of residential segregation /concentration by race – both between and within jurisdictions in Orange County and across the United States – are due, in part, to:
• Historic practices of redlining and legal racial segregation, which created many of the residential patterns that still exist today.
• Local land use and zoning laws that have perpetuated patterns of racial segregation, some of which remain in place, while others which have been removed but continue to have lasting effects.
• Market factors, including the high cost of land and existing housing throughout Orange County, constrain the development of new affordable housing and limit access for families to existing housing.
903

Orange County 59 25-29 Regional AFH

• Discrimination in the private housing market, including source -of-income discrimination, driven in part by a lack of knowledge of state and federal fair housing laws and regulations, which in turn limits housing mobility. • There are numerous ethnic enclaves of Hispanic, Vietnamese, Chinese, and other groups throughout Orange County. These enclaves provide a sense of community and a social network that may help newcomers preserve their cultural identities.

However, these active choices should not obscure the significant impact of structural barriers to fair housing choice and discrimination.

Through the stakeholder consultations and community meetings, it was also reported that segregation/concentration patterns in the County are due to:
• In addition to landlord resistance to renting to HCV Program participants, the gap between HCV subsidy amounts and housing costs further inhibits HCV Program participants from accessing housing in higher cost (and higher opportunity) areas. • Lack of housing mobility for some minority groups based on a lack of credit history coupled with high demand for affordable housing across the County, which permits landlords and property management companies to prioritize applicants based on credit history.

Detailed lists of the public or private policies or practices, demographic shifts, economic trends, and other factors that have caused or contributed to segregation /concentration in each of the jurisdictions are included in Section IV.

C. Racially or Ethnically Concentrated Areas of Poverty (R/ECAPs) Identify any R/ECAPs or groupings of R/ECAP tracts.

HUD defines racially or ethnically concentrated areas of poverty (R/ECAPs) as Census Tracts that meet both of the following criteria:
• a non-White population of 50 percent or more, and
• a poverty rate that exceeds 40% or a poverty rate that is three or more times the average Tract poverty rate for the metropolitan area, whichever threshold is lower.

The analysis in this report uses a measure of segregation and concentrated poverty created by the California Tax Credit Allocation Committee (TCAC) and California HCD. The TCAC/HCD Opportunity Map ’s poverty concentration and racial segregation filter aligns with HUD's R/ECAP methodology but is designed to more effectively reflect the level of racial and ethnic diversity in many parts of California. This measure uses the following criteria to define Census Tracts as “High Segregation and Poverty” areas:
• Tracts and rural block groups where at least 30 percent of the population is living below the poverty level (note that college and graduate students are removed from 904

Orange County 60 25-29 Regional AFH

the poverty calculation in the filter in Census Tracts where they comprise at least 25% of the population); and
• Tracts that have a Location Quotient (LQ) higher than 1.25 for Black, Hispanic, Asian, or all people of color. The LQ measures relative segregation by calculating how much more segregated a Census Tract is relative to a larger area (in this case, the County).

Compared to the measure used by HUD (which is an absolute threshold of non - White population in a Census Tract), this measure better captures inequality operating on individuals at the neighborhood level.

Map 5 – High Segregation and Poverty Areas, indicates racially or ethnically concentrated areas of poverty in Orange County (note that the only R/ECAP areas are located in the central part of the County). This map was created by California HCD to facilitate fair housing planning, using the TCAC/HCD Opportunity Map data. This map shows R/ECAPs in the following areas:
• Placentia – in the southwestern corner of the city, south of Orangethorpe Avenue • Anaheim – northeast of Disneyland, along Ball Road and I-5 • Garden Grove – in the northern part of the city to between Brookhurst St reet and Gilbert Street, north of Chapman Avenue
• Santa Ana – covering multiple Census Tracts in the downtown • Costa Mesa – on the west side of downtown and the area southwest of downtown (between Newport Avenue (SR-55) and Placentia Avenue, south of 19th Street).

905

Orange County 61 25-29 Regional AFH

Map 5 – High Segregation and Poverty Areas – Central Orange County

Source: California HCD, AFFH Data Viewer
The following analysis describes and identifies the predominant protected classes residing in R/ECAPs, and how these demographics compare with the overall demographics of the area.

To identify the predominant protected classes residing in R/ECAPs and compare them to the overall demographics of the surrounding areas, we look at the areas designated as “High Segregation and Poverty” on Map 5 (High Segregation and Poverty Areas) in relation to the demographic information on Map 3 (Predominant Population by Race/Ethnicity). The analysis finds that R/ECAPs in Orange County are predominantly Hispanic. Specifically, • In Placentia, the R/ECAP Tract is predominantly Hispanic, as are the neighborhoods to the west and south in Fullerton and Anaheim. The neighborhoods to the east are predominantly White.
• In Anaheim, the R/ECAP Tract is predominantly Hispanic, as are all the surrounding neighborhoods.
• In Costa Mesa, the R/ECAP area is predominantly Hispanic, as are the adjacent neighborhoods to the north and west. The Census Tracts to the east, across Newport Avenue, are all predominantly White.
• In Garden Grove, the R/ECAP Tract is predominantly Hispanic and is surrounded by Census Tracts that are predominantly AAPI.
906

Orange County 62 25-29 Regional AFH

• In Santa Ana, the R/ECAP Tracts are predominantly Hispanic, as are all the surrounding neighborhoods.

The foll owing analysis describes how R/ECAPs align with the location of publicly supported housing.

Map 6 - Publicly Supported Housing and R/ECAPs, shows the location of public-supported housing in Orange County in comparison to the location of the R/ECAP s (outlined in red).

This map shows no overarching patterns between the location of publicly supported housing and R/ECAPs.
• In Placentia, the R/ECAP area is home to one public housing development of 50-100 units, and between 5 -15% of renter -occupied units in the Tract utilize a voucher — which is similar to other Tracts in the city.
• In Anaheim, there are no publicly supported housing units in the R/ECAP Tract, and fewer than 5% of renter-occupied units in the R/ECAP Tract utilize a voucher. • In Costa Mesa, the largest publicly supported housing development in the city is located on the northern boundary of the R/ECAP area. There is no data on voucher usage in the Tract.
• In Garden Grove, 15 -30% of renter -occupied units in the R/ECAP tract utilize a voucher, which is similar to a number of other non -R/ECAP Tracts in the city. There are no publicly supported housing developments in the R/ECAP Tract. • In Santa Ana, fewer than 5% of renter -occupied housing units in the R/ECAP areas utilize a voucher ; however, there are various publicly supported housing developments within the boundaries of the R/ECAP area.

907

Orange County 63 25-29 Regional AFH

Map 6 - Publicly Supported Housing and R/ECAPs

Source: Created by authors using map from California HCD, AFFH Data Viewer 908

Orange County 64 25-29 Regional AFH

The following analysis describes the public or private policies or practices, demographic shifts, economic trends, or other factors that may have caused or contributed to the patterns described above.

In the most recent Housing Elements prepared and adopted by each jurisdiction, the following factors were identified that contribute to the existence of R/ECAPs in these jurisdictions.

In Placentia:
• Lack of affordable housing, which limits housing mobility. • Limited participation in the Housing Choice Voucher Program. • Land use and development practices that constrain affordable housing development.
• Private discrimination in housing, due in part to a lack of fair housing knowledge and enforcement.

In Anaheim:
• Historic practices of redlining and legal racial segregation have created many of the residential patterns that still exist today. Additionally, the high cost of land and existing housing in Anaheim (and throughout Orange County) are significant constraints to the development of new affordable housing and access for families to existing housing.

In Costa Mesa:
• Housing discrimination, which limits mobility for families. • Lack of affordable housing due to both governmental and market constraints.

In Garden Grove:
• Lack of affordable, accessible housing in a range of unit sizes, due to high land and development costs in the region, public opposition to new development, and land use and zoning laws.
• Housing discrimination, which limits mobility for families. • Limited access to financial services.
• Lack of meaningful language access for individuals with limited English proficiency. • Lack of private investment in specific neighborhoods.

In Santa Ana:
• Lack of fair housing education and outreach.
• Lack of affordable housing.

909

Orange County 65 25-29 Regional AFH

D. Disparities in Access to Opportunity
The following paragraphs analyze disparities in access to opportunity for education, employment, transportation, povert y, environmentally healthy neighborhoods, disability and access, and patterns in any disparities to access to opportunity.

1. Education
Table 6 – Opportunity Indicators by Race/Ethnicity (below), includes a School Proficiency Index, which measures the proximity various racial/ethnic groups have, based on where they live, to neighborhoods with high-performing schools. School proficiency is measured using school-level data on the performance of 4th grade students on state exams. The index is based on a range of 0 to 100 , with higher scores indicating better proximity to high - performing schools.

Table 6 shows the following disparities in access to neighborhoods with high -performing schools in each of the participating jurisdictions:
• In the region, there are significant disparities in access to neighborhoods with high performing schools. Access is lowest for Black and Hispanic residents, and highest for White and AAPI residents. Access is especially low for Black residents living below the Federal Poverty Level (FPL).
• In the Orange County Urban County jurisdictions, Hispanic residents have the least access to neighborhoods with high -performing schools, and this disparity is even more pronounced for Hispanic residents living below the FPL. Compared to the region, access is better across all groups and there are smaller disparities between groups.
• In Aliso Viejo, access to neighborhoods with high-performing schools is high for all groups and there is little disparity between race/ethnic groups. • In Anaheim, access to neighborhoods with high-performing schools is relatively low for all groups in the city and there are significant racial/ethnic disparities. Hispanic residents have the least access, followed by Native American and Black residents.

Access also t ends to be worse for residents living below the FPL, with Hispanic residents living below the FPL having the least access to neighborhoods with high- performing schools.
• In Buena Park, Hispanic and Black residents have less access to neighborhoods with high-performing schools than other groups, and this disparity is even greater for Hispanic residents living below the FPL. Residents in the city have better access to neighborhoods with high-performing schools than their counterparts regionwide, and there are fewer disparities in access by race/ethnicity when compared to the region.
• In Costa Mesa, Hispanic residents have less access to neighborhoods with high - performing schools than other groups, and this disparity is even greater for Hispanic 910

Orange County 66 25-29 Regional AFH

residents living below the FPL. Generally, residents in the city have better access to neighborhoods with high-performing schools than their counterparts regionwide, and there are fewer disparities in access by race/ethnicity when compared to the region.
• In Fountain Valley, access to neighborhoods with high -performing schools is high for all groups, with little disparity between race/ethnic groups, except for Native Americans living below the FPL, who have relatively poor access. • In Fullerton, access to neighborhoods with high performing schools is comparable to the region, with relatively low access and evidence of racial/ethnic disparities.

Hispanic residents have the least access, followed by Native American and Black residents.
• In Garden Grove, Hispanic residents have less access than other groups to neighborhoods with high -performing schools, though these disparities are less pronounced than in the region as a whole.
• In Huntington Beach, Hispanic and Black residents have less access than other groups to neighborhoods with high -performing schools, and these disparities are more pronounced for residents living below the FPL.
• In Irvine, access to neighborhoods with high -performing schools is high for all groups.
• In La Habra, access to neighborhoods with high-performing schools is relatively low for all groups and there is little disparity between race/ethnic groups. • In Laguna Niguel, access to neighborhoods with high-performing schools is high for all groups.
• In Lake Forest, access to neighborhoods with high-performing schools is moderately high for all groups, though residents living below the federal FPL have less access to these types of neighborhoods. Hispanic residents living below the federal FPL, in particular, have the least access compared to other groups. • In Mission Viejo, access to neighborhoods with high -performing schools is moderately high for all groups and there is little disparity between groups. • In Newport Beach, access to neighborhoods with high -performing schools is high for all groups.
• In Orange, there are some disparities in access to neighborhoods with high - performing schools, with Black and Hispanic residents having less access than other groups. These disparities are less pronounced than in the region overall —this is because, Hispanic, Black, and Native American residents of Orange have better access to these kinds of neighborhoods than their counterparts in the region overall, while White and AAPI residents of Orange have less access. • In Rancho Santa Margarita, access to neighborhoods with high-performing schools is high for all groups.
911

Orange County 67 25-29 Regional AFH

• In San Clemente, access to neighborhoods with high -performing schools is moderately high for all groups with few disparities between groups. • In Santa Ana, access to neighborhoods with high -performing schools is relatively low for all groups and there are significant disparities between race/ethnic groups.

Hispanic and Native American residents have the least access to neighborhoods with high-performing schools.
• In Tustin, Hispanic and Native American residents living below the FPL have significantly less access to neighborhoods with high-performing schools than other groups.
• In Westminster, access to neighborhoods with high -performing schools is moderately high for all groups and there is little disparity between groups. 912

Orange County 68 25-29 Regional AFH

Table 6 – Opportunity Indicators by Race/Ethnicity

913

Orange County 69 25-29 Regional AFH

Table 6 – Opportunity Indicators by Race/Ethnicity (continued)

914

Orange County 70 25-29 Regional AFH

Table 6 – Opportunity Indicators by Race/Ethnicity (continued)

915

Orange County 71 25-29 Regional AFH

Table 6 – Opportunity Indicators by Race/Ethnicity (continued)

916

Orange County 72 25-29 Regional AFH

Table 6 – Opportunity Indicators by Race/Ethnicity (continued)

917

Orange County 73 25-29 Regional AFH

Table 6 – Opportunity Indicators by Race/Ethnicity (continued)

By comparing the School Proficiency Index in Table 6 to the demographic data in Table 1 (Demographics), a pattern emerges showing that cities where all residents have access to neighborhoods with high -performing schools , have a lower percentage of Hispanic residents than the County overall. In other words, Hispanic residents are concentrated in cities with fewer high -performing schools. Specifically, in the following cities, the School Proficiency Index is 70 or higher for every racial/ethnic group, and the percentage of the population that is Hispanic is lower than the countywide percentage of 33.93%:
• Aliso Viejo, where the School Proficiency Index is over 83 for all groups, and 20.02% of the population is Hispanic.
• Fountain Valley, where the School Proficiency Index is over 73 for all groups, and

17.08% of the population is Hispanic.
• Irvine, where the School Proficiency Index is over 90 for all groups, and 11.24% of the population is Hispanic.
• Laguna Niguel, where the School Proficiency Index is over 77 for all groups, and

16.10% of the population is Hispanic.
• Mission Viejo, where the School Proficiency Index is over 72 for all groups, and

19.67% of the population is Hispanic.
918

Orange County 74 25-29 Regional AFH

• Newport Beach, where the School Proficiency Index is over 88 for all groups, and

10.47% of the population is Hispanic.
• Rancho Santa Margarita , where the School Proficiency Index is over 80 for all groups, and 20.41% of the population is Hispanic.

Map 7 – Education Score is a series of maps showing the TCAC/HCD Opportunity Map’s Education Composite Score for north, central, and south Orange County, and the region.

These maps were created by California HCD to facilitate fair housing planning, using the TCAC/HCD Opportunity Map data9. The Education Composite Score for a particular Census Tract is based on four indicators, all of which are based on enrollment-weighted averages of the three schools closest to the tract’s center point10:
• Math and Reading Proficiency, where “Proficiency” is the percentage of students performing at grade-level in the 4th grade.
• High School Graduation Rate , which is calculated using California Department of Education data on the percent of students who graduate in four years. • Student Poverty, which is measured as the percentage of students that do not receive free and reduced-price lunch.

A tract’s composite score is determined by whether it falls above or below the median (50th percentile) tract or block group value within each region. Each indicator that falls above the regional median adds one point to the final score. On the map s, the categories equal the following scores:
• Highest: >3-4
• High: >2-3
• Moderate: >1-2
• Low: 0-1
These maps, along with Map 3 showing the predominant race/ethnicity in each area, show the following relationship between residency patterns and proximity to proficient schools by race/ethnicity:
• In the County overall,
o Cities in the central County have the lowest education scores, indicating that residents in these areas are less likely to live near high quality schools. Areas in the southern County, along the coast, and in the unincorporated areas in the north and east parts of the County, have the highest education scores.

9 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 10 Detailed descriptions of the methodology used to measure each indicator can be found on the CTAC website, https://www.treasurer.ca.gov/ctcac/opportunity.asp
919

Orange County 75 25-29 Regional AFH

Low education score areas generally correspond to areas where the population is predominantly Hispanic.
• In the Orange County Urban County jurisdictions,
o Brea and Los Alamitos have high education score s and are predominantly White in most but not all areas.
o Cypress has high education scores and a predominantly AAPI and White population.
o La Palma has high education scores and a predominantly AAPI population o Yorba Linda, Villa Park, Orange Park Acres, North Tustin, unincorporated areas of the County, Laguna Woods, Laguna Beach, and Laguna Hills, all have the highest education scores and are predominantly White.
o Dana Point has a mix of education scores, all areas are predominantly White. o Placentia has low education scores in the southeast, which align with the predominantly Hispanic neighborhoods.
o San Juan Capistrano has low education score areas that are a mix of predominantly Hispanic and predominantly White neighborhoods. • In Aliso Viejo, all neighborhoods in the city have the highest education score and are predominantly White.
• In Anaheim, most of the city ’s neighborhoods have low education scores and are predominantly Hispanic. The exception is Anaheim Hills, which is both predominantly White, and has the highest education scores. • In Buena Park, there are neighborhoods with low education scores in the city’s center and southeast, which are also areas of predominant Hispanic population. • In Costa Mesa, the southwest quarter of the city has low education scores. This area is a mix of predominantly Hispanic neighborhoods in and around downtown, and predominantly White neighborhoods to the west.
• In Fountain Valley, almost all of the city’s neighborhoods have high education scores.

These neighborhoods are a mix of predominantly White and AAPI. • In Fullerton, neighborhoods in the south of the city have l ow education scores and are also the areas with the highest concentrations of Hispanic residents. • In Garden Grove, the neighborhoods with low education score areas in the east are predominantly Hispanic, and the neighborhoods with low education scores in the northwest are predominantly Hispanic and AAPI.
• In Huntington Beach, the neighborhoods with the highest education scores correlate to areas that are predominantly White, which is most of the city. One area of the city with low education scores has a predominantly Hispanic population. • In Irvine, neighborhoods across the city have the highest education score . These neighborhoods are a mix of predominantly White and AAPI. 920

Orange County 76 25-29 Regional AFH

• In La Habra, neighborhoods with low education scores are located in the center and eastern part of the city, which are also the areas with the highest concentrations of Hispanic residents.
• In Laguna Niguel, all neighborhoods have high education scores and are predominantly White.
• In Lake Forest, all neighborhoods have high education score s and most are predominantly White, except in the southeastern corner of the city, along El Toro Road, which is predominantly Hispanic.
• In Mission Viejo, all neighborhoods have high education scores , and most are predominantly White except in the southern part of the city. • In Newport Beach, all neighborhoods have high education score s and are predominantly White.
• In Orange, neighborhoods in the western half of the city have low education scores and are predominantly Hispanic. The neighborhoods with the highest education scores are in the eastern half of the city. The high education score areas north and west of Villa Park are predominantly White, and the high education score areas south and west of Villa Park are predominantly Hispanic.
• In Rancho Santa Margarita, all neighborhoods have high education scores and are predominantly White.
• In San Clemente, all neighborhoods have high education scores and are predominantly White.
• In Santa Ana, neighborhoods with low education score areas comprise most of the city, and are areas where population is predominantly Hispanic. • In Tustin, the neighborhoods with low education scores are predominantly Hispanic and White , and the neighborhoods with the h ighest education scores are predominantly AAPI.
• In Westminster, there is a mix of moderate, high, and highest education score areas.

There is one part of the city with low education scores, in the north. This area is predominantly Hispanic.

921

Orange County 77 25-29 Regional AFH

Map 7 – Education Score – Region

Source: California HCD, AFFH Data Viewer
Map 7 – Education Score – North Orange County

Source: California HCD, AFFH Data Viewer
922

Orange County 78 25-29 Regional AFH

Map 7 – Education Score – Central Orange County

Source: California HCD, AFFH Data Viewer
Map 7 – Education Score – South Orange County

Source: California HCD, AFFH Data Viewer
923

Orange County 79 25-29 Regional AFH

2. Employment
Table 6 includes a Jobs Proximity Index, which measures the physical distance between where residents of different races/ethnicities live and the location of jobs. A higher index value indicates better access to employment opportunities. Table 6 also includes a Labor Market Index, which measures the unemployment rate, labor-force participation rate, and percentage of the population age d 25 and above with at least a bachelor’s degree, by neighborhood. A higher index value indicates that residents live in a neighborhood with higher labor force participation and human capital.

Table 6 shows the following regarding disparities in access to neighborhoods close to jobs and with high labor force participation and human capital in each of the participating jurisdictions:
• In the region , there are significant disparities in both the Jobs Proximity and the Labor Market Index. The Jobs Proximity Index is the lowest for Black residents, especially those living below FPL. It is also low for Hispanic residents. White residents are most likely to live in neighborhoods close to jobs . The Labor Market Index is lowest for Black and Hispanic residents, especially those living below FPL, and h ighest for White residents. Generally, the Labor Market Index is lower for individuals living below FPL.
• In the Orange County Urban County jurisdictions, there is relatively low access to neighborhoods close to jobs for all races/ethnicities, with no large disparities between groups. Compared to the region, residents of all races/ethnicities have better access to neighborhoods with high labor force partici pation and human capital. However, there are disparities between racial/ethnic groups, with Hispanic residents having significantly less access than other groups, and White residents having more access.
• In Aliso Viejo, access to neighborhoods with high labor force participation and human capital is high for all races/ethnicities, with no large disparities between groups. This is also true for access to neighborhoods close to jobs. On both indices, the city performs significantly better than the region overall. • In Anaheim, there are significant disparities in access to neighborhoods close to jobs, and with high labor force participation and human capital. Hispanic residents have the least access to neighborhoods with high labor force participation and human capital. Black and AAPI residents have the least access to neighborhoods close to jobs. On both indices, the city is comparable to the region overall, with low- to-moderate scores and significant disparities between groups. • In Buena Park, there is relatively low access to neighborhoods close to jobs for all races/ethnicities, with no large disparities between groups. Compared to the region, residents of all races/ethnicities have less access to neighborhoods close to jobs.

There is moderate access to neighborhoods with high labor force participation and 924

Orange County 80 25-29 Regional AFH

human capital, with slight disparities between races/ethnicities—Hispanic residents have the least access to these neighborhoods. Compared to the region, access is higher for Hispanic and Black residents in the city.
• In Costa Mesa, access to neighborhoods close to jobs is high for all races/ethnicities, with only slight disparities —Hispanic residents have the least access. Access to neighborhoods with high labor force participation and human capital is also high for all races/ethnicities, but with significant disparities between races/ethnicities—again Hispanic residents have the least access. On both indices, the city performs better than the region overall for all racial/ethnic groups.
• In Fountain Valley, access to neighborhoods close to jobs, and with high labor force participation and human capital, is relatively high for all groups except for Native American residents living below the FPL, who have very low index values for each measure.
• In Fullerton, all race/ethnicities have moderate access to neighborhoods close to jobs, with slight disparities between groups—AAPI residents have the least access of any group. Regarding access to neighborhoods with high labor force participation and human capital, th ere are some disparities between groups (with Hispanic residents having the least access), and index values for Hispanic, Black, and AAPI residents are higher than their counterparts regionwide. • In Garden Grove, access to neighborhoods close to jobs is low for all groups, with some disparities between groups—AAPI residents have the least access. Compared to the region, all groups in Garden Grove have less access. Access to neighborhoods with high labor force part icipation and human capital is also relatively low for all groups in the city, with slight disparities between races/ethnicities. Access is lowest for Hispanic and AAPI residents. Compared to the region, the Labor Market Index in the city is higher for Black and Hispanic residents, and lower for all others. • In Huntington Beach, access to neighborhoods close to jobs is relatively low for all groups, with few disparities between races/ethnicities. Overall, groups in the city have better access to neighborhoods with high labor force participation and human capital; however, there are large disparities between groups. Hispanic residents, and especially those living below the FPL, have the least access to these neighborhoods. • In Irvine, access to neighborhoods close to jobs and with high labor force participation and human capital is high for all groups (and higher than the region) .

The only significant disparities are for Black residents living below FPL, who have less access to neighborhoods close to jobs, and Native American residents living below FPL, who have less access to neighborhoods with high labor force participation and human capital.
• In La Habra, access to neighborhoods close to jobs is very low for all groups, with no disparities between groups. There are disparities, however, in access to neighborhoods with high labor force participation and human capital. Hispanic 925

Orange County 81 25-29 Regional AFH

residents and Native American residents living below FPL have the least access of all groups. Compared to region, Hispanic, Black and AAPI residents in the city have more access, while White residents have less access.
• In Laguna Niguel, access to neighborhoods close to jobs is lower than the region for all groups, with little disparity between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups, with little disparity between groups.
• In Lake Forest, access to neighborhoods close to jobs is relatively high, and higher than region, for all groups . There is very little disparity between groups, except for Black residents below FPL, who have very low access to neighborhoods close to jobs. Access to neighborhoods with high labor force participation and human capital is higher than in the region for all groups, with little disparity except for Hispanic, AAPI, and Native American residents living below FPL, all of whom have significantly less access.
• In Mission Viejo, access to neighborhoods close to jobs is low for all groups, with no disparities between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups, with little disparity except for Hispanics living below FPL, for whom access is relatively low compared to other city residents but is still higher than in the region.
• In Newport Beach, access to neighborhoods close to jobs, and neighborhoods with high labor force participation and human capital, is high for all groups, with very little disparity between groups.
• In Orange, access to neighborhoods close to jobs is higher than the region, but there are some disparities—access is lowest for AAPI and White residents. There are also disparities in a ccess to neighborhoods with high labor force participation and human capital. Black and Hispanic residents overall, and Black and AAPI residents living below FPL have the least access. However, access is higher for all groups (except White residents), in comparison to the region.
• In Rancho Santa Margarita, access to neighborhoods close to jobs is very low for all groups, with no disparities between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups, with some disparities—Hispanic residents living below FPL have the least access. • In San Clemente, access to neighborhoods close to jobs is low for all groups, with very little disparity between groups. Access to neighborhoods with high labor force participation and human capital is high for all groups (and higher than in the region), with some disparity—namely, Hispanic residents living below FPL have less access. • In Santa Ana, access to neighborhoods close to jobs is higher for all groups than in region, with some disparities—access is lowest for AAPI residents, especially those living below FPL. Access to neighborhoods with high labor force participation and human capital is lower than in the region for all groups except Black residents, and 926

Orange County 82 25-29 Regional AFH

there are significant disparities in access—Hispanic residents have the least access, and access is also lower for individuals living below FPL in each racial/ethnic group. • In Tustin, access to neighborhoods close to jobs is higher for all groups than in region, with some disparities between races/ethnicities—White residents have the least access . Access to neighborhoods with high labor force participation and human capital is higher than in the region, with some disparities—Hispanic residents have the least access, and access is also lower for individuals living below FPL in each racial/ethnic group.
• In Westminster, there are disparities in access to neighborhoods close to jobs by race/ethnicity. Native American residents living below FPL, and AAPI residents, have the least access . There are some disparities in a ccess to neighborhoods with high labor force participation and human capital by race/ethnicity —Native American residents living below FPL and Hispanic and AAPI residents overall, have less access.

Compared to the region, access in the city is slightly better for Black and Hispanic residents, worse for all other groups.

The following analysis describes how a person’s place of residence affects their ability to obtain a job.

Map 8 – Economic Score is a series of maps showing the TCAC/HCD Opportunity Map’s Economic Composite Score for north, central, and south Orange County, and the region.

These maps were created by California HCD to facilitate fair housing planning, using the TCAC/HCD Opportunity Map data11. The Economic Composite Score for a particular Census Tract is based on four indicators12:
• Poverty Rate – Measured as the percentage of the Tract residents who live above 200 percent of the FPL (the 200 percent threshold is used to account for the higher cost of living in California compared to other regions of the United States). • Adult Education Rate – Measured as the percentage of adults aged 25 years and older in each Tract, who have earned at least a bachelor’s degree. • Employment Rate - Measured as the percentage of individuals in each Tract ages 20 to 64 who are employed in either the civilian labor force or the armed forces. • Home Value – Measured as the median home value (dollars) of owner -occupied housing units in each tract.

11 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 12 Detailed descriptions of the methodology used to measure each indicator can be found on the CTAC website, https://www.treasurer.ca.gov/ctcac/opportunity.asp
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Orange County 83 25-29 Regional AFH

The composite score for each Tract is determined by whether it falls above or below the median (50th percentile) tract or block group value within each region. On the map, a higher numerical score indicates more positive economic outcomes.

These maps show the following relationship between residency patterns and economic outcomes, including employment:
• Countywide, there is a s imilar pattern to the education scores, with cities in the central County tending to have lower economic scores than cities and unincorporated areas along the coast and in the southern, northern, and eastern parts of the County. Low score areas generally correspond to areas where the population is predominantly Hispanic of AAPI, whereas the high score areas correspond to predominantly White areas.
• In the Orange County Urban County jurisdictions,
o There are generally good economic outcomes in Cypress, Yorba Linda, North Tustin, La Palma , Los Alamitos , unincorporated areas east of Yorba Linda , Brea, North Tustin, Orange Park Acres, Villa Park, Seal Beach (except for the Tract where Leisure World, a retirement community, is located), Rossmoor , Laguna Beach, Dana Point, Ladera Ranch, and Capistrano Beach. o There is a mix of economic outcomes in the following places:
 Placentia, where there are lower economic scores in the southwest corner of the city, which is predominantly Hispanic.
 Laguna Woods and North Laguna Hills , which are predominantly White and have lower economic scores.
 San Juan Capistrano, where there are lower economic scores in the Census Tract that encompasses the interchange between I -5 and the Ortega Highway (SR-74), which is also a high POC segregation area and predominantly Hispanic.
• In Aliso Viejo, neighborhoods across the city have high economic scores, are predominantly White, and are mostly areas of high White concentration. • In Anaheim, neighborhoods with lower economic scores include neighborhoods considered to be areas of high POC segregation, including those north of downtown and along SR-91, and south of downtown and adjacent to Disneyland. These areas are predominantly Hispanic. Conversely, Anaheim Hills has high economic scores and is predominantly White.
• In Buena Park, the neighborhoods between I-5 and SR-91 have the lowest economic scores in the city. These areas are predominantly Hispanic. The northeastern corner of the city, which is predominantly AAPI, has the highest economic scores in the city. • In Costa Mesa, the neighborhoods in and surrounding downtown, on the west side of Newport Boulevard have the lowest economic scores. These are also areas that are predominantly Hispanic.
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Orange County 84 25-29 Regional AFH

• In Fountain Valley, neighborhoods across the city have high economic scores. • In Fullerton, there is a general north/south divide between areas with higher and lower economic scores. The southeastern neighborhoods, which are predominantly Hispanic, have the lowest economic scores , while the northern half of the city , predominantly White and AAPI neighborhoods, have the highest economic scores. • In Garden Grove, economic scores are moderate north of Garden Grove Freeway (SR-22) and are higher in West Garden Grove. Economic scores are generally lower south of SR-22.
• In Huntington Beach, neighborhoods across the city have high economic scores. • In Irvine, neighborhoods across the city have high economic scores except in the area surrounding UC Irvine, and in the neighborhoods east of the intersections of SR-133 and I-5—these are predominantly AAPI.
• In La Habra, the areas with the lowest economic scores are the same areas with high POC segregation, including the neighborhoods in the center of the city north of Guadalupe Park and between Idaho St reet to the west and Sonora High School to the east. These neighborhoods are predominantly Hispanic. • In Laguna Niguel, neighborhoods across the city have high economic scores, are predominantly White, and are mostly areas of high White concentration. • In Lake Forest, neighborhoods across the city have high economic scores except for in the southeastern corner, which is a predominantly Hispanic area. • In Mission Viejo, neighborhoods across the city have high economic scores, are predominantly White, and are primarily areas of high White concentration. • In Newport Beach, neighborhoods across the city have high economic scores, are predominantly White, and are all areas of high White segregation. • In Orange, neighborhoods across the city have good economic scores. The best economic scores are in the neighborhoods north and east of Villa Park, where the population is predominantly White and classified as an area of high White segregation. The neighborhoods with lower economic scores are located west of Glassel Street and north of Walnut Avenue, which is a predominantly Hispanic area. • In Rancho Santa Margarita, neighborhoods across the city have high economic scores, are predominantly White, and a re generally areas of high White concentration.
• In San Clemente, neighborhoods across the city have high economic scores, are predominantly White, and are primarily areas of high White concentration. • In Santa Ana, there are neighborhoods with low economic scores in much of the central and western parts of the city, which correspond to the areas of high POC segregation and are predominantly Hispanic , except for the Riverview West community, which is predominantly AAPI . Neighborhoods with higher economic scores are in the northern and southern parts of the city, which are areas of low - medium segregation.
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Orange County 85 25-29 Regional AFH

• In Tustin, all neighborhoods have good economic scores except for one neighborhood south of I-5 and west of SR-55, adjacent to Santa Ana. This is also a predominantly Hispanic area and is classified as an area of high POC segregation. • In Westminster, economic scores are lowest in the central part of the city, in the neighborhoods south of Westminster Boulevard, east of Hoover Street, and north of Bolsa Avenue. These are all areas of predominantly AAPI population.

Map 8 – Economic Score – Region

Source: California HCD, AFFH Data Viewer

930

Orange County 86 25-29 Regional AFH

Map 8 – Economic Score – North Orange County

Source: California HCD, AFFH Data Viewer

931

Orange County 87 25-29 Regional AFH

Map 8 – Economic Score – Central Orange County

Source: California HCD, AFFH Data Viewer

932

Orange County 88 25-29 Regional AFH

Map 8 – Economic Score – South Orange County

Source: California HCD, AFFH Data Viewer
The following analysis describes the groups that are least successful in accessing employment.

Table 7 - Labor Force Participation and Unemployment, shows 2018-2022 ACS data on labor force participation rates and unemployment rates in the region and Orange County, for the overall population and by race/ethnicity, disability status, and sex. The table shows that:
• Orange County has lower unemployment rates than the region for every group measured in the table, except for Pacific Islanders.
• Labor force participation rates are generally higher in Orange County than the region, except for White individuals (lower in the County than the region) and Asian individuals (same rate in County and region).
• Similar to the region overall, Black individuals have the highest unemployment rate in Orange County. In the County, Pacific Islanders have the second highest unemployment rate.

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Orange County 89 25-29 Regional AFH

Table 7 – Labor Force Participation and Unemployment

934

Orange County 90 25-29 Regional AFH

Table 7 – Labor Force Participation and Unemployment (continued)

935

Orange County 91 25-29 Regional AFH

3. Transportation
This analysis describes any disparities in access to transportation related to costs and access to public transit by protected class groups.

Table 6 includes a Transit Index, which measures the likelihood that residents will utilize public transportation. Higher index values indicate better access to public transit in a neighborhood. Table 6 also includes a Low Transportation Cost Index, which measures the cost of transportation in a neighborhood. Higher index values indicate lower transportation costs. Transportation costs may be low in a neighborhood due to better access to public transportation, or to the density of housing, services, and employment, or contributing factors.

Table 6 shows the following regarding disparities in access to transit and to neighborhoods with low transportation costs in each of the participating jurisdictions:
• In the region, access to transit and access to neighborhoods with low transportation costs are relatively high for all groups , though there are s ignificant disparities between racial/ethnic groups. Both indices are l owest for White residents and highest for Black residents and are higher across all groups for individuals living below the FPL.
• In the Orange County Urban County jurisdictions, access to transit is slightly lower for all groups compared to the region but is still relatively high. There are also significant disparities, with AAPI residents having the best access, and White residents having the least access. Access is slightly higher across groups for people living below the FPL. Access to neighborhoods with low transportation costs is lower for all groups compared to the region overall but is still relatively high. There are some disparities between groups, with Hispanic residents having the best access , and White residents having the least access. Access is slightly higher across groups for people living below the FPL, except for Hispanic residents living below the FPL who have similar access to the overall Hispanic population. • In Aliso Viejo, access to transit is low for all groups, and lowest for Black and Native American residents living below the FPL. Access to neighborhoods with low transportation costs is relatively high for all groups, with small disparities between groups—access is lowest for Black and Native American residents living below the FPL.
• In Anaheim, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Buena Park, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Costa Mesa, access to transit and access to neighborhoods with low transportation costs are high for all groups.
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Orange County 92 25-29 Regional AFH

• In Fountain Valley, access to transit and access to neighborhoods with low transportation costs are high for all groups. Black residents living below the FPL have the highest access to neighborhoods with low transportation costs. • In Fullerton, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Garden Grove, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Huntington Beach, access to transit and access to neighborhoods with low transportation costs are high for all groups. Native American residents living below the FPL have relatively low access to neighborhoods with low transportation costs, compared to other groups in city and the region.
• In Irvine, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In La Habra, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Laguna Niguel, access to transit is low for all groups. Access to neighborhoods with low transportation costs is slightly lower for residents of the city in comparison to the region.
• In Lake Forest , access to transit is low for all groups, and lowest for Black and Hispanic residents living below the FPL. Access to neighborhoods with low transportation costs is slightly lower for residents of the city in comparison to the region.
• In Mission Viejo, access to transit is low for all groups. Access to neighborhoods with low transportation costs is slightly lower for residents of the city in comparison to the region.
• In Newport Beach, access to transit is high for all groups. Access to neighborhoods with low transportation costs is comparable to the region for most groups, except for AAPI residents in the city, who have less access than other groups and compared to the region.
• In Orange, access to transit is high for all groups and slightly better than access in the region. Access to neighborhoods with low transportation costs is relatively high for all groups and is comparable to the region as a whole. • In Rancho Santa Margarita, access to transit is low for all groups. Access to neighborhoods with low transportation costs is also lower in the city compared to the region, and there are significant racial/ethnic disparities. AAPI residents living below the FPL have significantly lower access than other groups. • In San Clemente, access to transit is low for all groups, and access to neighborhoods with low transportation costs is also lower in the city compared to the region. There are some racial/ethnic disparities in access to neighborhoods with low 937

Orange County 93 25-29 Regional AFH

transportation costs—Native American residents living below the FPL line, and AAPI residents of all income levels, have less access compared to other groups. • In Santa Ana, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Tustin, access to transit and access to neighborhoods with low transportation costs are high for all groups.
• In Westminster, access to transit and access to neighborhoods with low transportation costs are high for all groups.

The following analysis describes how a person’s place of residence affects their access to transportation.

Map 9 – High Quality Transit Areas is a series of maps showing the areas of north, central, and south Orange County, and the region, that have access to “high quality” public transit, defined as having scheduled frequencies of 15 minutes or less. These maps were created by California HCD to facilitate fair housing planning, using data from the California Department of Transportation (Caltrans)13. On the maps, the outlined areas are those within half a mile of a transit stop that is served by public transit with scheduled frequencies of 15 minutes or less.

These maps show the following relationship between a person’s place of residence and access to transportation:
• Countywide, high quality transit areas (HQTAs) are concentrated in central County cities, and there are no HQTAs in the southern or northeast parts of the County. • In the Orange County Urban County jurisdictions, there are HQTAs in the following places
o In Brea, there is a HQTA in the center of city, overlapping with the racially integrated Census Tract that has a predominantly Hispanic population. o In Cypress, there is a HQTA on the southern edge of the city. o In Stanton, HQTAs cover the entire city.
o In Seal Beach, there are HQTAs along Seal Beach Boulevard north of US-1. o In Rossmoor, the southeastern corner of the city is a HQTA, along Seal Beach Boulevard.
o In Los Alamitos, the northern edge of the city is part of an HQTA. o In Laguna Woods, the eastern half of the city is a HQTA, along El Toro Rd. o In Laguna Hills, the part of the city a djacent to the HQTAs in Laguna Woods and Lake Forest is a HQTA.

13 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 938

Orange County 94 25-29 Regional AFH

o The following areas have no HQTAs: Placentia, Yorba Linda, unincorporated areas east of Yorba Linda, La Palma, Villa Park, Orange Park Acres, El Modena, North Tustin, L aguna Beach, Dana Point, Capistrano Beach, San Juan Capistrano, Ladera Ranch, and North Laguna Hills
• In Aliso Viejo, there are no HQTAs
• In Anaheim, there are HQTAs in the western part of city along Beach Boulevard; in the central and southern part of city along Harbor Boulevard and Katella Ave nue, including the Anaheim Regional Transportation Intermodal Center near Angel Stadium; and in the eastern part of the city near the Anaheim Canyon Metrolink station. These areas overlap with both high POC segregation areas and racially integrated areas.
• In Buena Park, there are HQTAs in the eastern half of city, along Beach Boulevard and La Palma Avenue.
• In Costa Mesa, HQTAs cover most of the city’s area except for the high White segregation areas in the northwest (the neighborhoods north and west of the Country Club) and in East Side Costa Mesa (east of SR-55 and south of Mesa Drive), which do not have HQTAs.
• In Fountain Valley, there are no HQTAs
• In Fullerton, there are HQTAs in downtown Fullerton and up to Fullerton College, including the area around the Metrolink station.
• In Garden Grove, there are HQTAs south of SR-22, in West Garden Grove, and in the eastern part of the city. There are no HQTAs in the city’s north-central area. • In Huntington Beach, most of the city is not a HQTA. There is one HQTA around the intersection of Main Street and Pacific Coast Highway (US-1). • In Irvine, there are HQTAs located near UC Irvine and John Wayne Airport, and the Irvine Medical and Science Complex. The majority of the city does not have HQTAs. • In La Habra, the western half of the city is a HQTA. In the eastern half of the city, which is a high POC segregation area and has a concentration of predominantly Hispanic neighborhoods, there are no HQTAs
• In Laguna Niguel, there are no HQTAs except in a small area in the northeast corner along Crown Valley Parkway, adjacent to Mission Viejo.
• In Lake Forest, most of the city is not a HQTA. There are two HQTAs in the city: one in Foothill Ranch, north of SR-241(around Towne Center); and the other in the city’s southeastern corner along El Toro Rd (which is a predominantly Hispanic area). • In Mission Viejo, most of the city does not have HQTAs. There are two HQTAs in the city: one in the southern part, along Crown Valley Parkway (which is a low-medium concentration area with a predominantly Hispanic population); and the other in the northern part of the city, around the intersections of Santa Margarita Parkway with Los Alisos Boulevard and Marguerite Parkway ( which are low-medium concentration areas with predominantly White populations) 939

Orange County 95 25-29 Regional AFH

• In Newport Beach, there are HQTAs just south of Costa Mesa and around the Civic Center. Much of the city does not have HQTAs.
• In Orange, there are HQTAs downtown, in the neighborhoods west and northwest of downtown, and along the westside of Costa Mesa Freeway (SR-55) north of Katella Avenue. There are no HQTAs east of the Costa Mesa Freeway. • In Rancho Santa Margarita, there are no HQTAs
• In San Clemente, there are no HQTAs
• In Santa Ana, most of the city is covered by HQTAs, except for northeast and southeast corners.
• In Tustin, most of the city does not have HQTAs. There are two HQTAs in the following areas: one HQTA is in the racially integrated neighborhoods just to the north of I-5, in and around downtown; the other HQTA is in South Tustin, around the Metrolink train station.
• In Westminster, most of the city is considered a HQTA, with the exception of the western and southeastern areas.

Map 9 – High Quality Transit Areas – Region

Source: California HCD, AFFH Data Viewer

940

Orange County 96 25-29 Regional AFH

Map 9 – High Quality Transit Areas – North Orange County

Source: California HCD, AFFH Data Viewer

941

Orange County 97 25-29 Regional AFH

Map 9 – High Quality Transit Areas – Central Orange County

Source: California HCD, AFFH Data Viewer

942

Orange County 98 25-29 Regional AFH

Map 9 – High Quality Transit Areas – South Orange County

Source: California HCD, AFFH Data Viewer

4. Access to Low Poverty Neighborhoods
The following analysis describes any disparities in exposure to poverty by protected class groups.

Table 6 includes a Low Poverty Index , which measures the level of poverty in a neighborhood. Higher index values indicate less exposure to poverty in a neighborhood.

Table 6 shows the following regarding disparities in access to low-poverty neighborhoods in each of the participating jurisdictions:
• In the region, there are significant disparities in access to low -poverty neighborhoods. Hispanic and Black residents have the least access, and White residents have the most access . Individuals living below the FPL also have less access to low-poverty neighborhoods, compared to the overall population. • In the Orange County Urban County jurisdictions, access to low -poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL. However, there are significant disparities in access.

Hispanic residents have the least access. White residents have the most access .

Individuals living below the FPL also have less access to low -poverty neighborhoods, compared to the overall population.
943

Orange County 99 25-29 Regional AFH

• In Aliso Viejo, access to low -poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In Anaheim, there are significant disparities in access to low-poverty neighborhoods.

Hispanic residents have the least access. White residents have the most access.

Individuals living below the FPL also have less access to low -poverty neighborhoods, compared to the overall population. Compared to the region, White, AAPI, and Native American residents of the city have less access to low -poverty neighborhoods; and Black residents of the city have better access. • In Buena Park, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale because Hispanic, Black, and Native American residents in the city have better access than their counterparts in the region. Access in the city is lowest for Hispanic and Black residents, and highest for White residents. Individuals living below the FPL have less access across all groups, except for Native American residents.
• In Costa Mesa, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale due to the fact that all groups, except for White residents, in the city have better access than their counterparts in the region as a whole. Access in the city is lowest for Hispanic residents and highest for AAPI residents. Individuals living below the FPL have less access across all groups, except for Black residents
• In Fountain Valley, all residents have relatively good access to low -poverty neighborhoods compared to the region. There are some disparities by race/ethnicity, with Hispanic residents, and Native American residents living below the FPL, having the least access.
• In Fullerton, all residents have relatively good access to low-poverty neighborhoods compared to the region. There are some disparities by race/ethnicity, with Hispanic residents, including those living below the FPL, and Black residents living below the FPL, having the least access.
• In Garden Grove, there are significant disparities in access to low -poverty neighborhoods. AAPI and Hispanic residents have the least access. White residents have the best access. The population living below the FPL has less access across all groups. Compared to the region, disparities in the city are less pronounced due to lower index values for White and AAPI residents in the city, and higher index values for all other groups in the city, as compared to values in the region. • In Huntington Beach, all residents have relatively good access to low -poverty neighborhoods compared to the region. There are some disparities by race/ethnicity, with Hispanic residents having the least access and White residents having the most access. Individuals living below the FPL have less access across all groups, except for Native American residents.
944

Orange County 100 25-29 Regional AFH

• In Irvine, access to low-poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In La Habra, access to low-poverty neighborhoods is higher for all groups compared to the region, except for White residents. There are significant disparities in access to low-poverty neighborhoods by race/ethnicity. Hispanic residents have the least access. AAPI residents overall have the most access, however, the AAPI population living below the FPL has significantly less access compared to the overall AAPI population in the city.
• In Laguna Niguel, access to low -poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In Lake Forest, access to low -poverty neighborhoods is higher for all groups compared to the region. However, some racial/ethnic disparities exist, with Hispanic residents having the least access. For the population living below the FPL, access is much lower for Native American residents compared to any other group, access is lower for AAPI residents compared to the overall AAPI population, and access is higher for Black residents compared to the overall Black population. • In Mission Viejo, access to low -poverty neighborhoods is higher for all groups compared to the region. However, some disparities exist for individuals living below the FPL, with Black residents living below the FPL having less access than other groups in the city (though still with better access compared to the region). • In Newport Beach, access to low -poverty neighborhoods is higher for all groups compared to the region, including for individuals living below the FPL, and there are no major disparities by race/ethnicity.
• In Orange, there are similar disparities in access to low -poverty neighborhoods as in the region, though at a smaller scale because all groups, except for White residents, in the city have better access than their counterparts in the region as a whole. Hispanic residents in the city have the least access to low -poverty neighborhoods. Additionally, Black residents living below the FPL have significantly lower access.
• In Rancho Santa Margarita, access to low-poverty neighborhoods is higher for all groups compared to the region, and there is little racial/ethnic disparity. For the population living below the FPL, racial/ethnic disparities are larger, mainly because the AAPI population below the FPL has the most access to low -poverty neighborhoods of any group in the city.
• In San Clemente, access to low -poverty neighborhoods is higher for all groups compared to the region. However, some racial/ethnic disparities exist, with Hispanic residents experiencing the least access. Disparities are larger for the population 945

Orange County 101 25-29 Regional AFH

living below the FPL, with Black residents living below the FPL having the least access in the city.
• In Santa Ana, there are significant disparities in access to low -poverty neighborhoods. Hispanic residents have the least access overall, and White residents have the most access overall. For the population living below the FPL, access is lower across all groups. Compared to the region, all groups in the city have less access to low -poverty neighborhoods, except for Black residents, who have access comparable to the region overall.
• In Tustin, there are similar disparities in access to low-poverty neighborhoods as in the region, though at a smaller scale due to the fact that Hispanic, Black, and Native American residents in the city have higher access relative to the region, and White and AAPI residents have lower access relative to region. In the city, Hispanic residents have the lowest access. For the population living below the FPL, there are also significant disparities. Access to low -poverty neighborhoods is lowest for Native American and Hispanic residents living below the FPL, and access for White residents living below the FPL is significantly lower than access for the overall White population.
• In Westminster, access to low poverty neighborhoods is lower than in the region for all groups, except for Black residents, and there are significant racial/ethnic disparities. Hispanic and AAPI residents have the least access, overall . For the population living below the FPL, access is lower across all groups and is lowest for AAPI residents.

Map 10 – Poverty Status is a series of maps showing the percent of households, by Census Tract, living below the FPL in north, central, and south Orange County, and in the region.

These maps were created by California HCD to facilitate fair housing planning, using data from the U.S. Census Bureau American Community Survey, 2017-2021 5-Year Estimates14.

These maps show the following relationship between a n individual’s place of residence and their exposure to poverty:
• Countywide, higher poverty areas are in the central County cities, whereas the areas along the coast, in the south, and in the northeast are low poverty areas. • In the Orange County Urban County jurisdictions, there are high poverty areas (i.e., with poverty rates above 20%) in the following places:
o In Placentia, in the southwest corner of the city, which is a high POC segregation area that is predominantly Hispanic.
o In Stanton, in the neighborhoods on the south side of Katella Avenue and on the eastside of Beach Boulevard north of Katella Avenue.

14 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 946

Orange County 102 25-29 Regional AFH

o In San Juan Capistrano, there is one tract between Camino Del Avion, Del Obispo Street, and Alipaz St reet, which has a poverty rate over 20% and is predominantly Hispanic.
• In Aliso Viejo, all Census Tracts have a poverty rate below 20%. • In Anaheim, the highest poverty area is located downtown north of Lincoln Avenue (in a predominantly Hispanic area). There are other areas of concentrated poverty south and west of downtown, which are also predominantly Hispanic. The areas of lowest poverty are downtown south of Lincoln Avenue, east of downtown (including the racially integrated areas), in Northeast Anaheim, and in Anaheim Hills. • In Buena Park, all Census Tracts have a poverty rate below 20%. • In Costa Mesa, all Census Tracts have a poverty rate below 20%. • In Fountain Valley, all Census Tracts have a poverty rate below 20%. • In Fullerton, there are high poverty areas in the southeast (predominantly Hispanic, low-medium segregation areas) and surrounding CSU Fullerton (likely due to the presence of college students).
• In Garden Grove, there are high poverty areas in the industrial area in West Garden Grove, in the Census Tract between Brookhurst St reet and Gilbert St reet north of Chapman Avenue (a low-medium segregation area that is predominantly Hispanic), and in the Census Tract in between SR -22 and Garden Grove Boulevard west of Gilbert Street (a high POC segregation area that is predominantly AAPI). • In Huntington Beach, all Census Tracts have a poverty rate below 20%. • In Irvine, the high est poverty area is surrounding UC Irvine (likely due to the presence of college students). There is also a high poverty area west of San Diego Creek north of I -405. This is primarily an industrial/commercial area encompassing the Irvine Business Complex.
• In La Habra, all Census Tracts have a poverty rate below 20%. • In Laguna Niguel, all Census Tracts have a poverty rate below 20%. • In Lake Forest, all Census Tracts have a poverty rate below 20%. • In Mission Viejo, all Census Tracts have a poverty rate below 20%. • In Newport Beach, all Census Tracts have a poverty rate below 20%. • In Orange, all Census Tracts have a poverty rate below 20%, and all neighborhoods east of Villa Park have poverty rates below 10%.
• In Rancho Santa Margarita, all Census Tracts have a poverty rate below 20%. • In San Clemente, all Census Tracts have a poverty rate below 20%. • In Santa Ana, high poverty areas are concentrated in downtown and southeast of downtown where land use is primarily industrial and commercial , and in western Santa Ana, specifically the Census Tract northwest of the intersection of McFadden Avenue and Harbor Boulevard, where Kona Kai Mobile Home Park is located. All of these areas are high POC segregation areas with predominantly Hispanic populations.
947

Orange County 103 25-29 Regional AFH

• In Tustin, all Census Tracts have a poverty rate below 20%. • In Westminster, there are high poverty areas between Edwards Street and Beach Boulevard along Westminster Boulevard , and s outh of Bolsa Ave nue west of Bushard St reet. These areas are high POC segregation areas with predominantly AAPI populations.

Map 10 – Poverty Status – Region

Source: California HCD, AFFH Data Viewer

948

Orange County 104 25-29 Regional AFH

Map 10 – Poverty Status – North Orange County

Source: California HCD, AFFH Data Viewer
949

Orange County 105 25-29 Regional AFH

Map 10 – Poverty Status – Central Orange County

Source: California HCD, AFFH Data Viewer

950

Orange County 106 25-29 Regional AFH

Map 10 – Poverty Status – South Orange County

Source: California HCD, AFFH Data Viewer
Table 8 - Poverty by Race/Ethnicity and National Origin, shows data from the 201 8-2022 ACS on poverty rates by race/ethnicity and national origin, for the region, Orange County, the Urban County jurisdictions, and the HUD Entitlement Cities . The table shows t he following:
• Countywide, the poverty rate is lower than region for all groups except AAPI residents (who have a poverty rate comparable to the region). There are significant racial/ethnic disparities. The Black poverty rate is highest and is nearly double the White poverty rate , and the f oreign-born population is more likely to live below poverty than the native-born population.
• In the Orange County Urban County jurisdictions, the poverty rate is lower than the County overall. Similar to the County overall, the Black poverty rate is highest and is nearly double the White poverty rate, and the foreign -born population is more likely to live below poverty than the native-born population. • In Aliso Viejo, the overall poverty rate is lower than the County. Similar to the County, the foreign-born population is more likely to live below poverty than the native-born population. (Note that the Black and Native American populations may be too small for the sample data to be accurate.)
• In Anaheim, the overall poverty rate is higher than the County and is comparable to the region poverty rate. Black and Hispanic residents have the highest poverty rates. 951

Orange County 107 25-29 Regional AFH

Similar to the County overall, the foreign-born population is more likely to live below poverty than the native-born population.
• In Buena Park, the overall poverty rate is lower than in the County. Similar to the County overall, Black residents have the highest poverty rate. • In Costa Mesa, the overall poverty rate is similar to the County and there are much larger racial/ethnic disparities. The Black poverty rate in the city is over 20%, which is nearly three times as high as the White poverty rate and double the AAPI poverty rate. Similar to the County overall, the foreign-born population is more likely to live below poverty than the native-born population.
• In Fountain Valley, the overall poverty rate is lower than the County. Similar to the County, the foreign -born population is more likely to liv e below poverty than the native-born population. (Note that the Black and Native American populations may be too small for the sample data to be accurate.)
• In Fullerton, the overall poverty rate is higher than the County and is comparable to the region poverty rate , and there are much larger racial/ethnic disparities than in the County overall. The Black poverty rate is over 22%, which is almost three times higher than the White and AAPI poverty rates . The Hispanic poverty rate is above 17%, which is more than double the White and AAPI rates. Similar to the County overall, the foreign -born population is more likely to live below poverty than the native-born population. (Note that the Native American population may be too small for the sample data to be accurate.)
• In Garden Grove, the overall poverty rate is higher than the County and is comparable to the region poverty rate. There are relatively small disparities by race/ethnicity, with Black residents experiencing the highest poverty rates, and foreign-born residents more likely to live below the FPL than native-born residents. • In Huntington Beach, the overall poverty rate is lower than the County and the foreign-born population is much more likely to live below poverty than the native - born population. (Note that the Native American population may be too small for the sample data to be accurate.)
• In Irvine, the overall poverty rate is higher than the County and is comparable to the region poverty rate. Black, Hispanic, and AAPI residents experience similar poverty rates, which are all higher than the poverty rate for White residents. Foreign -born residents are more likely to live below the FPL than native-born residents. • In La Habra, the overall poverty rate is similar to the County. Foreign-born residents more likely to live below the FPL than native-born residents, and Hispanic residents have a higher poverty rate than other groups. (Note that the Black and Native American populations may be too small for the sample data to be accurate.) • In Laguna Niguel, the overall poverty rate is lower than the County. However, there are disparities between groups. Hispanic residents have the highest poverty rate in 952

Orange County 108 25-29 Regional AFH

the city, and foreign-born residents are more likely to live below the FPL than native- born residents.
• In Lake Forest, the overall poverty rate is lower than in the County. However, there are disparities between groups. Hispanic residents have the highest poverty rate in the city, and foreign-born residents are more likely to live below the FPL than native- born residents.
• In Mission Viejo, the overall poverty rate is lower than the County. The data show the Black poverty rate to be much higher than other racial/ethnic groups, however the population size may be too small for the data to be accurate. • In Newport Beach, the overall poverty rate is lower than the County. Unlike the County overall, foreign-born residents in the city are less likely to live below the FPL than native -born residents. Poverty rates for Black, AAPI, and Native American residents are the highest. However, note that the Black and Native American populations may be too small for the sample data to be accurate. • In Orange, the overall poverty rate is similar to the County. In the city, Native American and Hispanic residents have the highest poverty rates, and foreign -born residents are more likely to live below the FPL than native-born residents. • In Rancho Santa Margarita, the overall poverty rate is lower than the County. The data show the Native American poverty rate to be much higher than other racial/ethnic groups, however the population size may be too small for the data to be accurate.
• In San Clemente, the overall poverty rate is lower than the County and foreign-born residents are more likely to live below the FPL than native-born residents. The data show the Black poverty rate to be much higher than other racial/ethnic groups, however the population size may be too small for the data to be accurate. • In Santa Ana, the overall poverty rate is higher than the County but lower than the region poverty rate. Black residents have the highest poverty rate (nearly 20%). • In Tustin, the overall poverty rate is higher than the County but lower than the region poverty rate. Hispanic residents have the highest poverty rate (nearly double the White poverty rate), and foreign-born residents are more likely to live below the FPL than native-born residents.
• In Westminster, the overall poverty rate is higher than the County and the region. The Black poverty rate is over 20% and more than double the White poverty rate. The AAPI poverty rate is over 18% and is also more than double the White poverty rate.

Foreign-born residents are more likely to live below the FPL than native -born residents. (Note that the Native American population may be too small for the sample data to be accurate.)

953

Orange County 109 25-29 Regional AFH

Table 8 – Poverty by Race/Ethnicity and National Origin

954

Orange County 110 25-29 Regional AFH

Table 8 – Poverty by Race/Ethnicity and National Origin (continued)

955

Orange County 111 25-29 Regional AFH

5. Access to Environmentally Healthy Neighborhoods
The following analysis describes any disparities in access to environmentally healthy neighborhoods by protected class groups.

Table 6 includes an Environmental Health Index, which captures the potential exposure to harmful toxins in a neighborhood. Higher index values indicate less exposure to harmful toxins, and therefore better environmental quality, in a neighborhood.

Table 6 shows the following regarding disparities in access to environmentally healthy neighborhoods in each of the participating jurisdictions:
• In the region, there is relatively low access to environmentally healthy neighborhoods for all groups, and racial/ethnic disparities exist. Access to environmentally healthy neighborhoods is highest access for White residents, and lowest for Black residents followed by Hispanic and AAPI residents. Access is lower for all groups living below the FPL, with the least access experienced by Hispanic residents living below the FPL.
• In the Orange County Urban County jurisdictions, there is relatively low access to environmentally healthy neighborhoods for all groups, and racial/ethnic disparities exist. Access to environmentally healthy neighborhoods is highest access for White residents, and lowest for AAPI residents followed by Black and Hispanic residents.

Access is lower for all groups living below the FPL, except for White residents who have comparable access to the overall population.
• In Aliso Viejo, there is relatively high access to environmentally health neighborhoods for all groups compared to the region, and no racial/ethnic disparities.
• In Anaheim, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Buena Park, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Costa Mesa, residents have better access to environmentally healthy neighborhoods than residents of the region, but access is still low. There are some racial/ethnic disparities in access. Overall, AAPI residents have the least access to environmentally healthy neighborhoods, and Hispanic residents have the best access. For the population living below the FPL, Black and Native American residents have the least access.
• In Fountain Valley, there is very poor access to environmentally friendly neighborhoods for all residents compared to the region. There are small disparities in access for the population living below the FPL. Specifically, Black residents living below the FPL have the least access.
956

Orange County 112 25-29 Regional AFH

• In Fullerton, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Garden Grove, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity. • In Huntington Beach, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still fairly low and there are some racial/ethnic disparities. Access to environmentally healthy neighborhoods is lowest for Hispanic residents, and even more so for Hispanic residents living below the FPL.
• In Irvine, residents have better access to environmentally healthy neighborhoods than those of the region, but access is still low for all groups regardless of race/ethnicity.
• In La Habra, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Laguna Niguel, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited for all groups regardless of race/ethnicity.
• In Lake Forest, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited and there are some disparities among the population living below the FPL—specifically, Native American residents living below the FPL have the least access. • In Mission Viejo, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited for all groups regardless of race/ethnicity
• In Newport Beach, residents have better access to environmentally healthy neighborhoods than residents of the region overall, but access is still limited for all groups regardless of race/ethnicity
• In Orange, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Rancho Santa Margarita, there is relatively high access to environmentally health neighborhoods for all groups compared to the region and other jurisdictions in Orange County, and no racial/ethnic disparities.
• In San Clemente, there is relatively high access to environmentally health neighborhoods for all groups compared to the region and other jurisdictions in Orange County, and no racial/ethnic disparities.
• In Santa Ana, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
• In Tustin, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.
957

Orange County 113 25-29 Regional AFH

• In Westminster, there is very poor access to environmentally friendly neighborhoods for all residents, regardless of race/ethnicity.

Map 11 – Environmental Health is a series of maps showing data from the California Office of Environmental Health Hazard Assessment (OEHHA) California Communities Environmental Health Screening Tool (CalEnviroScreen 4.0). These maps were created by California HCD to facilitate fair housing planning, using CalEnviroScreen data from OEHHA15.

The CalEnviroScreen tool is designed to identify communities most affected by pollution, and those where residents may be especially vulnerable to its effects. To do this, it uses a composite score based on 13 different indicators of pollution burden – such as exposure indicators (e.g., diesel particulate matter levels and lead risk from housing and environmental effect indicators (e.g., location of solid waste facilities) - as well as eight indicators of population characteristics including sensitive population indicators (e.g., asthma rates) and socioeconomic factor factors (e.g., poverty and linguistic isolation). More detailed information on the mapping methodology is available on the OEHHA website 16.

On these maps, green areas represent regions with more positive environmental factors, while red areas indicate regions with more negative environmental factors.

These maps show the following relationship between an individual’s place of residence and their access to environmentally healthy neighborhoods:
• Countywide, the areas with more positive environmental factors are along the coast, in the south, and northeast. The areas with more negative environmental factors are in the central parts of the County north of I-405 and west of the Costa Mesa Freeway (SR-55).
• In the Orange County Urban County jurisdictions, most neighborhoods have primarily positive environmental factors. The a reas with more negative environmental factors are located in the following places:
o Stanton.
o Southwest Placentia, next to Fullerton , which is an area of high POC segregation and is predominantly Hispanic.
o San Juan Capistrano, in the Census Tract that encompasses the interchange between I-5 and the Ortega Highway (SR-74), which is a high POC segregation area and is predominantly Hispanic.
• In Aliso Viejo, all neighborhoods in the city have positive environmental factors.

15 The maps were downloaded from the AFFH Data Viewer, which can be accessed at https://www.hcd.ca.gov/planning-and-community-development/affirmatively-furthering-fair-housing 16 https://oehha.ca.gov/calenviroscreen
958

Orange County 114 25-29 Regional AFH

• In Anaheim, Anaheim Hills ( a high White segregation area), has positive environmental factors. Much of the rest of the city is affected by negative environmental factors, with the severe environmental factors located in and around downtown, along I-5 cutting across the city, and along Riverside Freeway (SR-91) on the northern edge of the city.
• In Buena Park, there is one Census Tract with a score lower than 40 (indicating more positive environmental factors). This area is between La Palma Avenue and Crescent Avenue, on either side of Knott Avenue. Areas of the city with more negative environmental factors include the neighborhoods north of the Artesia Freeway (SR- 91) and adjacent to I -5, and the western part of the city, which includes numerous warehouses and distribution facilities.
• In Costa Mesa, areas with more positive environmental factors include neighborhoods east of Newport Boulevard (SR -55), which are high White segregation areas, as well as neighborhoods along the western edge of the city and north of I -405, which are also predominantly White. The areas with more negative environmental factors include neighborhoods downtown, which are predominantly Hispanic.
• In Fountain Valley, areas with more positive environmental factors include the neighborhoods in the southwest corner of city, which have a high concentration of White residents, and those surrounding Mile Square Regional Park , a high POC segregation area that is predominantly AAPI . The rest of the city experiences moderate environmental factors.
• In Fullerton, areas with more positive environmental factors include the neighborhoods near the Panorama Nature Preserve in the city’s northeast. A reas with more negative environmental factors include the neighborhoods in the southeast part of the city, which are predominantly Hispanic—this area includes the commercial/industrial area along the Riverside Freeway (SR-91); and neighborhoods in the southwest part of the city, around Fullerton Municipal Airport and to the south, which are also predominantly Hispanic.
• In Garden Grove, residential neighborhoods in West Garden Grove, west of Knott Street have more positive environmental factors and are areas of high White segregation. The rest of the city experiences less positive environmental factors, with the most negative factors located in West Garden Grove, east of Knott St reet an industrial and commercial area, and a long Garden Grove Freeway (SR -22), in the city’s southeast.
• In Huntington Beach, most of the city – particularly along the coast and in the southeastern region – has more positive environmental factors. However, an area with less positive environmental factors is in the industrial/commercial area between Beach Boulevard (SR -39) and Gothard Street, spanning from Talbert 959

Orange County 115 25-29 Regional AFH

Avenue to Edinger Avenue. This area overlaps with the one predominantly Hispanic Census Tract.
• In Irvine, most of the neighborhoods in the city have positive environmental factors.

The few places with more negative environmental factors include the area west of San Diego Creek north of I -405 ( which is primarily comprised of industrial and commercial land uses, including the Irvine Business Complex), the area between UC Irvine and I-405 (which is a high POC segregation area and is predominantly AAPI), and the e astern part of city along I -5 near Lake Forest , where Irvine Industrial Complex East and Irvine Technology Center are located.
• In La Habra, most of the city is affected by negative environmental factors, with the most negative factors concentrated in the central and southeast areas of the city / This is likely due to the proximity to warehouses, distribution centers, and Imperial Highway (SR-90). These areas overlap with the high POC segregation areas, which are predominantly Hispanic.
• In Laguna Niguel, all neighborhoods in the city have positive environmental factors. • In Lake Forest, most neighborhoods in the city have positive environmental factors, except for those south of Serrano Creek, which experience more negative environmental factors.
• In Mission Viejo, all neighborhoods in the city have positive environmental factors. • In Newport Beach, all neighborhoods in the city have positive environmental factors. • In Orange, the neighborhoods east of Villa Park, which haver high White segregation, experience more positive environmental factors . Neighborhoods west of Glassel Street, which are predominantly Hispanic , are affected by more negative environmental factors.
• In Rancho Santa Margarita, all neighborhoods in the city have positive environmental factors.
• In San Clemente, most neighborhoods in the city have positive environmental factors, except for one area with moderate environmental factors . This area encompasses the neighborhoods north and east of Max Berg Plaza Park, and is classified as a low-medium concentration area with a predominantly White population.
• In Santa Ana, most of the city has negative environmental factors, with the most negative factors located in the east and southeast side of the city along the Costa Mesa Freeway (SR -55), where many of the commercial/industrial land uses are located. Other highly impacted areas include downtown and neighborhoods west of downtown. These are all areas of high POC segregation, and most are predominantly Hispanic, except for one of the Tracts to the far west of downtown, which is predominantly AAPI. There is one Census Tract with positive environmental factors located in the southern part of the city, within a racially integrated area between 960

Orange County 116 25-29 Regional AFH

Segerstrom High School and the Bristol Place Shopping Mall, where White residents are the predominant group.
• In Tustin, neighborhoods north of I-5 have more positive environmental factors, and neighborhoods south of I-5 have more negative environmental factors. • In Westminster, most of the city has negative environmental factors, with the most negative factors located in the c entral neighborhoods, from I-405 north, between Beach Boulevard and Edwards Street.

Map 11 – Environmental Health – Region

Source: California HCD, AFFH Data Viewer

961

Orange County 117 25-29 Regional AFH

Map 11 – Environmental Health – North Orange County

Source: California HCD, AFFH Data Viewer

962

Orange County 118 25-29 Regional AFH

Map 11 – Environmental Health – Central Orange County

Source: California HCD, AFFH Data Viewer

963

Orange County 119 25-29 Regional AFH

Map 11 – Environmental Health – South Orange County

Source: California HCD, AFFH Data Viewer

6. Disability and Access
The following analysis describes the barriers that deny individuals with disabilities access to opportunity and community assets.

Table 7 – Disability by Type, presents the percentage of residents with various disabilities living in the region, Orange County, the Orange County Urban County jurisdictions, and in HUD Entitlement City. In the region and Orange County overall, the most prevalent form of disability is ambulatory difficulty , followed by independent living difficulty. Ambulatory difficulty is also the most prevalent form of disability in the Urban County jurisdictions and all HUD Entitlement Cities except for Aliso Viejo and Rancho Santa Margarita, where cognitive difficulty is most prevalent, and Irvine, where independent living difficulty is most prevalent.

964

Orange County 120 25-29 Regional AFH

Table 7 – Disability by Type

965

Orange County 121 25-29 Regional AFH

According to data from HUD, in Orange County, a total of 398 housing discrimination cases were opened between January 2019 and November 2024 (when this report was prepared).

As shown in Table 8, below, the majority (65.33%) of cases alleged discrimination based on disability. (Please note, the total number of cases in the table below equal more than 398, and the percentages equal more than 100% because one case can involve allegations of discrimination based on multiple protected classes). Table 9 shows the number of cases by jurisdiction, and the number and percentage of cases that included allegations of discrimination based on disability status. As the table shows, in nearly all jurisdictions, discrimination based (in whole or in part) on disability status comprises most cases.

Table 8 – Discrimination Complaints, Orange County, 2019-2024

966

Orange County 122 25-29 Regional AFH

Table 9 – Discrimination Complaints by Jurisdiction,
Orange County, 2019-2024

967

Orange County 123 25-29 Regional AFH

The fair housing challenges facing individuals with a disability were described during the stakeholder consultations and community meetings. Participants in these meetings reported the following barriers that deny individuals with disabilities access to opportunity and community assets:
• Individuals with disabilities often seek affordable housing in older buildings that may not meet accessibility standards, creating additional barriers. • Affordable housing options are concentrated in areas of Santa Ana and Anaheim, with fewer options in higher opportunity areas of the County.
• Individuals with disabilities often face barriers in accessing necessary modifications in housing. Tenants must provide a doctor's letter to request modifications, yet landlords are often resistant to approving accommodation requests . In many cases, tenants are responsible for covering modification costs, unless the property is government -owned.

Additionally, low-income individuals with disabilities struggle to afford the necessary modifications.

7. Patterns in Disparities in Access to Opportunity
Identify and discuss any overarching patterns of access to opportunity and exposure to adverse community factors. Include how these patterns compare to patterns of segregation, integration, and R/ECAPs. Also identify areas that experience: (a) high access; and (b) low access across multiple indicators.

In Orange County, there is a general pattern of disparities in access to opportunity between the cities in the central part of the County, and the cities and unincorporated areas along the coast and in the southern and northeastern parts of the County. Cities in central Orange County tend to have higher poverty areas, lower educational scores, lower economic scores, and worse environmental health factors. These cities are also comprised of many areas of high POC segregation, with predominantly Hispanic populations . Except for Garden Grove and Westminster , which have neighborhoods with predominantly AAPI populations. Conversely, the cities and unincorporated areas along the coast and in the south and northeast experience lower poverty rates, higher educational scores, higher economic scores, and better environmental health factors. These areas correspond to areas of high White segregation and predominantly White populations.

In the Orange County Urban County jurisdictions,
• The following racial/ethnic groups experience disparities in access across multiple indicators:
o Hispanic residents, and particularly those living below the Federal Poverty Level (FPL) , have the least access to low poverty neighborhoods, neighborhoods in close proximity to high performing schools, and neighborhoods with high labor force participation and human capital. 968

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