May 27, 2025
City Council Meeting
Written Public Comments
General Public
Comment
Jennifer Connally
From: Janice Brownfield
Sent: Monday, May 26, 2025 6:22 PM
To: City Council Public Comment
Subject: Public Comment Non-Agenda Item
Researchers' recent discovery of the composition of our air pollution allows specific strategies to be developed for reducing a main source, fossil fuel emissions. The levels of ammonium nitrate have now been quantified, revealing there is much more of it than previously calculated, especially on the most polluted days. Ammonium nitrate forms through chemical reactions between ammonia in the air and nitrogen oxides, including NOz (nitrogen dioxide), from the burning of fossil fuels. So powering vehicles and appliances such as lawn mowers with electricity instead of gasoline (a fossil fuel) will reduce air pollution and improve our health.
Comparing our air quality here in Orange with that of Bellevue, Washington, location of the teleconference, we can see the difference in levels of NOr. On a recent afternoon there it was 17, rated "Excellent," and here it was 23, "Fair." Their ozone was "Fair" and ours was "Poor." Breathing in high levels of NOz increases the risk of respiratory problems, and ozone can aggravate existing respiratory diseases.
Known as the Evergreen State for its abundance of trees, which clean the air, Washington was recently ranked one of the top three states for best air quality. Bellevue has a "City in a Park" vision to create a healthy and sustainable environment for its residents and visitors by connecting them with nature. Bellevue's new reduction target for greenhouse gas emissions (fossil fuel combustion) is 95% by 2050. Its city council adopted the Sustainable Bellevue Environmental Stewardship Plan in 2020 and is set to be regularly updated every five years.
Bellevue tracks GHG emissions for both government operations and the entire community on an annual basis. With 40% of climate emissions coming from household activities, more ways to shrink their carbon footprints are being shared with residents. A townhall was held as was a festival with garden tours, environmental education and activity booths, heat pump information session and electric lawncare equipment demonstration.
Here we can do the same, with vendors, community partners and the Orange Sustainability Group to share ways to improve our environment and health. Educational programs and completion of GHG inventory to include mobile transportation are among the measures Orange residents consider important, according to the Citywide Sustainability Plan received May 14 of last year by our city council.
1 Item 8.1
Re-zone Cypress
Barrio;
Ordinance No. 06-25
*Kennedy
COMMISSION
www.kennedycommission.org
May 21, 2025 17701 Cowan Ave., Suite 20C
Irvine. CA 92614
949 250 0905
Mayor Dan Slater
Members of the City Council
City of Orange
300 E. Chapman Ave.
Orange, CA 92866
RE: Agenda Item 8.1 - Zone Change No. 1267-12(B) (Cypress Street Barrio) To The Honorable Mayor Slater and Members of the City Council, The Kennedy Commission (the Commission) is a broad-based coalition of residents and community organizations advocating for the production of homes affordable for families earning less than $30,000 annually in Orange County. Since 2001, we have successfully partnered with jurisdictions across the county to create housing and land-use policies that increase affordable housing opportunities for lower-income working families.
The Cypress Street Barrio is one of the oldest immigrant communities in Orange County.
Established over a century ago by Mexican laborers drawn to the booming citrus industry, the Barrio has served as a cultural and social anchor for generations of Latino families. It was a place where people worked, celebrated, raised families, and built livesoften in the face of racial segregation and economic marginalization. From the Azteca Tortilleria to the Simon Luna Grocery Store, from the neighborhood fiestas to the tight-knit social bonds, the Barrio is a living, breathing testament to the resilience and contributions of immigrant communities in shaping the City of Orange.
While change and evolution are inevitable, we must be cautious not to erase the unique cultural and historical legacy of neighborhoods like the Cypress Street Barrio under the guise of administrative consistency. The proposed zoning action risks doing exactly that—by reducing residential capacity and encouraging displacement in an already gentrifying area.
This is not only bad planning policy-it is unlawful under state law. Senate Bill 330, the Housing Crisis Act of 2019, and its subsequent amendment, SB 8, explicitly prohibit local governments from enacting policies that would downzone land where housing is an allowable use. Government Code Section 66300(b)(1) states that affected cities, including Orange, "shall not enact a development policy, standard, or condition" that reduces residential capacity, including reductions in density, height, floor area ratio, or similar metrics. Such changes are deemed void under state law unless offset concurrently to result in no net loss of housing.
The City of Orange's justification for this proposed downzoning is to align zoning with the Low Density Residential General Plan Land Use Designation. However, consistency requirements do not override state housing law. In fact, to achieve consistency while complying with SB 330, the correct path forward would be to amend the General Plan land use designation to match the existing zoning-not the other way around. Any attempt to lower zoning intensity in the Cypress Street Barrio violates not only the spirit but the letter of California housing law.
Moreover, the city cannot afford to lose more housing capacity. According to the City's latest RHNA progress, Orange has only permitted 50 of 1,067 Very Low-Income units, 252 of 604 Low-Income units, and 285 of 677 Moderate-Income units. Meanwhile, existing multifamily housing in the Cypress Barrio offers critical options for low-income households in an increasingly expensive housing market. Downzoning these properties will further limit affordable housing opportunities and threaten the multigenerational stability of a historically marginalized community.
For these reasons, The Kennedy Commission strongly urges the City Council to reject the proposed zoning change under Agenda Item 8.1. Instead, we recommend the Council initiate a motion to update the General Plan land use designation to reflect the existing zoning, consistent with SB 330, to avoid unlawful downzoning. This path preserves not only the housing stock and historic character of the Cypress Barrio but also the city's legal standing and commitment to equitable housing policy.
Thank you for your time and consideration. If you have any questions, please feel free to contact me at (949) 250-0909 or cesarc @kennedycommission.org.
Sincerely,
Cesar
Cesar Covarrubias
Executive Director
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