These factors contribute to changes in population, influencing migration patterns, birth rates, and mortality rates, thereby altering the demographic landscape.
Other Threats
History has shown that pandemics can lead to supply chain issues - availability for PPE and sanitary product needs (toilet paper, sanitizer, baby wipes, etc.) and proper disposal of biohazard materials.
Tree Mortality
Physical Threat
Dead or dying trees create a cascade of risks that threaten infrastructure in both urban and rural settings. Dead trees lose structural integrity, making them prone to falling, especially during high winds or storms. Falling trees and branches can damage buildings, vehicles, and power lines, creating significant repair costs and safety hazards. One of the most critical threats posed by tree mortality is to electrical and communication infrastructure. Dead trees can easily topple onto power lines, causing outages, sparking fires, or disrupting essential services. Tree roots, even after a tree has died, can pose a threat to foundations. As roots degrade, they may leave voids in the soil, causing structural shifts and compromising the stability of nearby buildings. 755
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Social Threat
Healthy trees provide essential services such as carbon sequestration, temperature regulation, and stormwater absorption. Their loss exacerbates urban heat islands, increases air pollution, and diminishes soil stability. These impacts will affect lower income individuals and those with pre-existing health conditions.
Other Threats
Deadwood is highly flammable, increasing the risk of wildfires, particularly in regions already prone to fire outbreaks. Wildfire threatens homes, utilities, and large-scale infrastructure, often leading to massive economic losses. Repairing infrastructure damaged by tree mortality can be expensive, from clearing roadways to restoring power grids.
Changes in Population Patterns and Land Use and Development Tree mortality is not expected to have a significant effect on population patterns or land use. Integrating tree mortality concerns into development projects can reduce risks. For example, planting resilient tree species and maintaining safe distances from power lines and buildings can enhance infrastructure protection.
Human-Caused Hazards
Physical Threat
Cyber Attack
A significant cyber event could have considerable impact on the population, built environment, lifeline infrastructure, and the economy. Most jurisdictions have several levels of security in place, dependent upon security levels of individuals and the geographical locations (onsite or remote). Many also have redundant dispatch centers with separate systems that can function if the primary center is not functioning.
Cyber-attacks can infiltrate many institutions including banking, medical, education, government, military, and communication and infrastructure systems. Most of the effective malicious cyber-activity has become web based. Recent trends indicate that hackers are targeting users to steal personal information and targeting computers to cause system failures. The duration of a cyber-attack is dependent on the complexity of the attack, how widespread it is, how quickly the attack is detected, and the resources available to aid in restoring the system. A cyber-attack could be geared toward one organization, one type of infrastructure and/or a specific geographical area. The affected area could range from small to large scale.
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Hazardous Materials Release
Hazardous materials can cause damage to infrastructure and the population in Orange if they are released into the environment. Corrosive hazardous materials can damage the exteriors of buildings or structures. Flammable hazardous materials can be ignited and cause damage to nearby structures. Generally, sites closer to the origin of the release of hazardous materials are more at risk than those further away.
Power Outages
Power Outages are considered a form of lifeline system failure and could have a significant impact on the population, built environment, infrastructure, and the economy. Disruptions can be the consequence of another hazard, or can be the primary hazard, absent of an outside trigger. Orange gets its electricity from Southern California Edison, because of this, if the power grid increases in other parts of the state, it could curtail the energy available to Orange. This vulnerability is compounded by the reality that the community has become more reliant on power for gadgets and appliances to perform basic daily activities. This loss of power will not only be an inconvenience but could become a life-threatening experience. Many citizens rely on power and water infrastructure to operate medical machinery to survive (i.e., oxygen tanks, dialysis machines). There are various medical facilities that rely on these resources to maintain basic standards of care for patients.
Climate change considerations indicate that as the weather conditions change, there could be an increase in energy needs. This could be from both potential increase in heat and cold.
These predicted increases will put ever greater strain on Orange’s energy supply.
Terrorism
There is no way to predict which of Orange’s facilities or assets may be impacted by an act of terrorism since the motivation behind the incident is often complex and not easily understood. Generally, these incidents occur at places of political, economic, or cultural importance. If the perpetrator's motives are to shut down City or regional government activity for a period, they may instead target pieces of infrastructure, like water systems, utility delivery systems, or transportation networks. The financial losses that may result from this type of incident would depend on the degree of destruction associated with the activity. If the incident involves the destruction of physical assets, the cost to the City or property owners in Orange could be significant. The City of Orange Police Department works closely with the Orange County Intelligence Assessment Center to identify and investigate any potential terrorist threat.
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Social Threat
Cyber Attack
Cities like Orange are an attractive target for criminals and cyber threat actors to exploit vulnerable systems to steal critical infrastructure data and proprietary information, conduct ransomware operations, or launch destructive cyberattacks. Successful cyberattacks against cities could lead to disruption of infrastructure services, significant financial losses, exposure of citizens’ private data, erosion of citizens’ trust in the smart systems themselves, and physical impacts to infrastructure that could cause physical harm or loss of life. Additionally, a cyber attack that affects public safety systems may cause the public to feel unsafe and panic.
Hazardous Materials Release
The threat of a hazardous materials release event affects those closest to a source of hazardous materials, including industrial sites, gas stations, gas transmission lines, sewer mains, and transportation incidents that produce hazardous material spills. Orange residents living next to major transportation infrastructure such as highways or major roadways also face a greater risk of being affected by a hazardous materials release if vehicles transporting these materials accidentally release their contents into the environment. Groups such as the elderly, low-income, and renters face a greater risk of exposure since they may not have the financial resources necessary to retrofit their homes against infiltration by hazardous materials or relocate to a home farther from the potential sources of hazardous materials. Aerosolized hazardous material releases can cause severe health consequences for populations in and downstream from the epicenter of the release.
Power Outage/Infrastructure Failure
Power outages and infrastructure failures most immediately threaten seniors, people with disabilities, and those with home medical equipment. These groups often face the greatest threat during a power outage, during extreme heat or Public Safety Power Shutoffs.
Infrastructure failures are usually short term, which most of the population can withstand.
Any long term impacts may cause public concern and increase panic.
Terrorism
Since mass casualty incidents/acts of terrorism could occur anywhere in Orange, all groups are potentially threatened by the impacts of these incidents; however, the extent of the threat would depend upon the type and magnitude of the event. For example, an active shooter situation may be isolated to a single location, whereas a larger-scale incident may affect multiple locations. Some locations are more likely to be targeted than others, including but not limited to medical facilities, government buildings, financial institutions and the people frequently visiting these areas may face a greater threat than the average person. Seniors, pregnant women, and persons with disabilities, for instance, are more likely to frequently visit the local hospitals than other subpopulations in the city. If an 758
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incident occurs at a hospital or within the community (overwhelming hospital resources), these groups are expected to face an increased impact from the incident.
Changes in Population Patterns and Land Use and Development The hazards identified under human-caused hazards will not affect population patterns or land use and development, as no connection can be drawn between these hazards and changes in population patterns or land use and development.
It is not anticipated that population patterns will change over the next 20 years. A change in population pattern would only occur if a hazardous materials release was severe enough to require people to move for a prolonged period of time due to soil contamination.
Infrastructure Failure (Building Collapse/Water System
Failure)
Physical Threat
The impacts of a building collapse can be substantial, including monetary losses for property owners, the private sector, and the public. Insurance deductibles and uninsured losses could result in millions of dollars in damages, with the burden potentially falling on taxpayers if property owners are unable to cover debris removal and disposal costs. Older structures are generally at higher risk of structural failure, highlighting the vulnerability of aging infrastructure within the city.
The direct and indirect effects of water systems failure are difficult to quantify. The loss of water utility, for example, does negatively affect businesses, homes, and critical facilities – with serious consequences from long-term outages. Hotels and restaurants, for example, may have to provide bottled water for guests and diners in the event of a water utility failure, and this can be extremely costly.
The vulnerability of this hazard creates challenges for residents and businesses in the form of water advisories in the event of water pressure losses.
Social Threat
Infrastructure failure can have far-reaching impacts on the community. When essential services like water supply are disrupted, residents may face significant challenges in maintaining daily routines, accessing clean water, and ensuring personal hygiene.
Vulnerable populations, such as the elderly and those with medical conditions, are particularly at risk during prolonged outages. Additionally, the stress and uncertainty caused by service interruptions can erode public trust and increase anxiety among residents, affecting overall community well-being.
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Businesses, schools, and healthcare facilities also suffer, as they rely on consistent infrastructure to operate safely and efficiently. Water advisories and restrictions can disrupt local economies and force temporary closures, leading to loss of income and employment. In severe cases, extended infrastructure failure may result in population displacement if living conditions become untenable, further straining social networks and increasing demand on emergency services.
Changes in Population Patterns and Land Use and Development Infrastructure failure is not expected to have any impact on population patterns and land use and development. Most are short term system disruptions. If a building collapse were to occur, other development will take its place.
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SECTION 6: CAPABILITY ASSESSMENT
A capability assessment was conducted of the City’s authorities, policies, programs, and resources that can help to implement mitigation activities. From the assessment, goals, and mitigation actions were developed to lessen the effects of the identified hazards. The planning team also developed a plan to prioritize, implement, and administer the mitigation actions to reduce risk to existing buildings and new development.
6.1 Existing Authorities, Policies, Programs, and
Resources
An assessment of authorities, policies and programs, and resources was conducted to identify capabilities that reduce vulnerability to hazards. The capabilities include authorities and policies, such as legal and regulatory resources, fiscal resources, and staff (e.g., technical personnel such as planners/engineers with knowledge of land development and land management practices, engineers trained in construction practices related to building and infrastructure, planners and engineers with an understanding of natural or human-caused hazards, floodplain managers, surveyors, personnel with GIS skills, and staff with expertise of the hazards in the planning area). The planning team also considered ways to expand on and improve these existing policies and programs to integrate hazard mitigation into the day-to-day activities and programs of the City. Tables 6-1, 6-2, 6-3, and 6-4 summarize the existing authorities, policies, programs, and resources to implement mitigation activities.
6.1.1 Planning and Regulatory Capabilities
Planning and regulatory capabilities include local ordinances, policies, and laws to manage growth and development. Examples include land use plans, capital improvement plans, transportation plans, emergency preparedness and response plans, building codes, and zoning ordinances. These capabilities may be used to inform and support mitigation planning or may be modified as mitigation action. Table 6-1 lists City planning and regulatory capabilities. Under the Description column is an explanation of the City’s ability to use the LHMP to expand on and improve these existing policies and programs. 761
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Table 6-1: Local Planning and Regulatory Capabilities
Name/Version Date Hazards
Addressed Description (Effect on Hazard Mitigation)
Zoning Code Earthquake The Zoning Code is the main tool to implement the City’s General Plan. It sets land use regulations and the zoning map for the city.
Expansion and Improvement: Mitigation actions
outlined in this Plan can be adopted in the form of land use/development regulations.
Building Code/Fire
Code
Earthquake/
Fire
International Building Code, International Fire Code.
Expansion and Improvement: Mitigation actions
outlined in this Plan can be adopted in the form of new building codes and regulations
Floodplain
Management
Flooding In City of Orange, the Special Flood Hazard Areas are in the vicinity of Santa Ana River, Santiago Creek, and Handy Creek. City of Orange Municipal Code Chapter
15.60 establishes the code and regulations regarding
floodplain management within the City.
Expansion and Improvement: Mitigation actions
outlined in this Plan can be adopted in the form of new codes and regulations related to building in floodplain locations.
Planning Commission The Planning Commission meets twice per month to review and decide on planning and development
matters in Orange.
Expansion and Improvement: The Planning Commission
can ensure a periodic review of the city’s Hazard
Mitigation Plan.
Orange Adopted
Budget (2024-2025)
All The Orange City Council approved the City's Fiscal
Year 2024-2025 budget on June 25, 2024. The
General Fund budget consists of $145.2 million in
revenues excluding transfers, and $156.2 million in
expenditures.
Expansion and Improvement: Future budget will
include hazard mitigation projects as part of the general fund budget.
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Table 6-1: Local Planning and Regulatory Capabilities
Name/Version Date Hazards
Addressed Description (Effect on Hazard Mitigation)
Orange County
Essential Facilities
Risk Assessment
Project Report April,
2009
All Provides risk assessment on six natural hazards and Hazus estimated impacts on Orange County for two
Earthquake Scenarios.
Expansion and Improvement: Ensure all City plans align
with the report.
Capital Improvement
Program (2025-2028)
All A compilation of infrastructure and major maintenance projects designed to expand, enhance and/or preserve
the foundation of this great City.
Expansion and Improvement: Future iterations of the
CIP will incorporate hazard mitigation activities.
Capital Improvement
Program Water
System
Earthquake,
Drought,
A compilation of infrastructure and major maintenance
projects designed to expand, enhance, and preserve
the water system.
Expansion and Improvement: Future iterations of the
plan will ensure projects align with the hazard
mitigation activities.
2025-2030 Citywide
Strategic Plan
Flooding,
earthquake,
Fire
To provide Orange a five-year economic development
strategic plan that guides priorities, policies, programs, and services.
Expansion and Improvement: Future iterations of the
Strategic Plan will incorporate hazard mitigation
activities.
Orange 2010 General
Plan
All Established a long-term vision for growth and change through the year 2030. This “blueprint” for our City
specifies goals, policies, and measures to help influence physical growth and change in ways that protect our
citizen’s quality of life.
Expansion and Improvement: Future iterations of the
General Plan will incorporate hazard mitigation
activities.
Orange General Plan
Safety Element
Natural
Hazards
Addresses these safety issues, with emphasis on the
naturally occurring conditions that pose a hazard to
Orange, and provides goals, policies, and programs
aimed at reducing the City’s risk from these hazards.
Expansion and Improvement: Align the LHMP with the
future iteration of the Safety Element.
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Table 6-1: Local Planning and Regulatory Capabilities
Name/Version Date Hazards
Addressed Description (Effect on Hazard Mitigation)
Orange Code of
Ordinances
Multiple Local laws enacted by Orange, created to address matters of local concern that are not covered by state
or federal laws.
Expansion and Improvement: Ensure ordinances align
with industry standards and look at the implications of adding additional restrictions that improve mitigation
City wide.
City Urban Water
Management Plan
(2020)
Drought,
Climate
Change
The UWMP provides urban water suppliers (including
the City) with a planning document for long-term
resource planning to ensure adequate water supplies
are available to meet existing and future water supply
needs. In addition, the UMWP incorporates water
supply reliability determinations resulting from
potentially prolonged drought, regulatory revisions,
and/or changing climatic conditions.
Expansion and Improvement: The UWMP and LHMP
will be aligned in describing and developing mitigation actions to address climate change and drought. Water
demand reduction strategies contained in the UWMP
should be considered for inclusion as mitigation
activities in the LHMP.
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6.1.2 Administrative and Technical Capabilities
Administrative and technical capabilities include community (including public and private) staff and their skills and tools that can be used for mitigation planning and implementation.
This capability includes engineers, planners, emergency managers, GIS analysts, building inspectors, grant writers, and floodplain managers. Some communities may rely on other government entities such as counties or special City’s for resources. These capabilities may be used when planning mitigation activities to support project feasibility studies, designs, estimates, and construction.
Table 6-2: Administrative and Technical Capabilities
Resource Name Lead
Department Description (Effect on Hazard Mitigation)
Communications City Manager's
Office
The City’s Public Information Office provides outreach
and information to the public, creative services to all internal departments, and videography for the City; also handles all website administration.
Expansion and Improvement: Strengthen ties with
community organizations and businesses to ensure key
content and information is timely and relevant. Create
additional communications platforms to ensure
information and content reaches community members.
City Clerk's
Office
City Manager's
Office
The City Clerk supervises and coordinates City
elections; serves as Filing Officer for City appeals as designated by various sections of the Orange Municipal
Code; prepares and updates the City's Conflict of
Interest Code, and serves as Filing Officer for the Fair Political Practices Commission; receives and opens all
sealed bids and formally releases bid bonds; receives,
processes and maintains claims, public record requests, special event applications, summonses and complaints;
assists the public and City staff by providing information and research assistance; and directs the retention and
destruction of official records in accordance with
applicable laws and regulations.
Expansion and Improvement: Prioritize new initiatives
that support mitigation activities within the City.
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Table 6-2: Administrative and Technical Capabilities
Resource Name Lead
Department Description (Effect on Hazard Mitigation)
Engineering Public Works The department is charged with overseeing, planning, designing, and implementation of infrastructure
projects. Some of the department's functions include:
Act as the lead agency for construction and public
works contracts within the Right-of- Way.
Program, plan, design and administer the construction of the annual Capital Improvement Program.
Issue encroachment and traffic control permits for any
work within the Right-of-Way.
Inspect construction within the Right-of-Way to verify
conformance with the permit conditions and compliance
with the latest City codes.
Review all proposed residential, commercial and
industrial development projects and provide engineering input as well as conditions of approval for proposed
projects.
Plan check all development plans including those that
impact other department functions.
Manage the NPDES program activities, such as business
inspection, construction site inspection, public
education, and outreach, etc.
Manage traffic engineering and transportation planning
activities.
Provide support for other departments working within
the Right-of-Way.
Expansion and Improvement: Work with Engineering to
identify soft structures within the City boundary and
develop mitigation strategies to make improvements.
Public Works Public Works The City of Orange Public Works Department is responsible for maintaining and improving the City's
vital infrastructure, including streets, sidewalks, parks, landscaping, sewers, storm drains, and public facilities.
Expansion and Improvement: Improve the
understanding of the role that daily activities play in hazard mitigation. Develop hazard mitigation projects
that aid in mitigation.
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Table 6-2: Administrative and Technical Capabilities
Resource Name Lead
Department Description (Effect on Hazard Mitigation)
Water Division Public Works The City of Orange Public Works Department is responsible for maintaining and improving the City's
potable water distribution system.
Expansion and Improvement: Ensure the integration of
water infrastructure into the LHMP. Develop hazard
mitigation projects that aid in mitigation of water
infrastructure.
Information
Technology
Information
Technology
The role of the IT Department is to support the
operational departments with reliable systems and
information on a daily basis. The most critical support required of IT being network, communications and
applications support. The IT department provides shortand long-term direction in planning, researching, selecting and deploying future technologies. IT strives to accommodate improved business process automation,
self-service and quality customer service through a
variety of hardware and software solutions.
Expansion and Improvement: Increase system
redundancy and resiliency through improvements to
technologies and connectivity.
Public Safety Police
Department
Orange Police Department is tasked with protecting life and property while preserving peace. This department is responsible for conducting public safety activities,
investigating criminal activity, and directing traffic.
Expansion and Improvement: Provide training to
Officers to better enable them to see potential hazards and take action to report them.
Emergency
Management
Fire Develops, coordinates, and manages programs that
prevent, prepare for, respond to, recover from, and
mitigate natural and human-caused disasters and
emergencies.
Expansion and Improvement: Increase coordination and
collaboration with other City departments, especially
during annual budgeting.
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Table 6-2: Administrative and Technical Capabilities
Resource Name Lead
Department Description (Effect on Hazard Mitigation)
Fire Department Fire
The Orange Fire Department provides fire protection
and emergency medical services for the city.
Expansion and Improvement: Proactively identify
opportunities to coordinate and collaborate with
neighboring jurisdictions to increase City and regionwide capabilities.
Housing Community
Development
The Community Development administers funds the
City receives from the United States Department of
Housing and Urban Development (HUD). These funds
are authorized under HUD's Community Development
Block Grant (CDBG) program and used to benefit lowand moderate-income families and aid in the rehabilitation and development of blighted areas within the City.
Expansion and Improvement: Integrate mitigation
actions and strategies into low- and moderate-income
areas to reduce blight and potentially spur further
investment.
Planning Community
Development
The Community Development Department plays a
critical role in achieving the City Council's goals and objectives related to land use, urban design, and the
quality and sustainability of the built environment.
Expansion and Improvement: Provide opportunities for
continued education to Community Development staff
to maintain state-of-the-art knowledge of new code and
regulatory requirements.
Building Community
Development
The Community Development Department provides
professional plan review and inspection services to
ensure buildings and projects are built and developed in compliance with all applicable municipal and state code requirements.
Expansion and Improvement: Provide opportunities for
continued education to Community Development staff
to maintain state-of-the-art knowledge of new code and
regulatory requirements.
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Table 6-2: Administrative and Technical Capabilities
Resource Name Lead
Department Description (Effect on Hazard Mitigation)
Financial
Services
Finance The Finance Department is tasked with maintaining reliable accounting records, payment of approved
demands against the City treasury, financial statement
reporting, preparation of the annual budget, prudent
fiscal planning, payroll processing and debt
administration.
Expansion and Improvement: Assist with key mitigation
activities associated with cost tracking hazard events
and disasters, identifying grant funding opportunities, grant reporting and administration, and establishing
financial risk calculations that can help assist with
budgeting of operations, maintenance, and capital
improvements.
Human
Resources
Human
Resources
The Human Resources Department plans, coordinates
and administers a comprehensive human resources
management program for the City of Orange and its
employees. This includes the recruitment and retention
of highly qualified employees, maintenance of a
competitive employee compensation program,
implementation and use of current technology for the
City's human resources, organizational and employee
development, and employee/labor relations. Identifies,
evaluates and manages the City's risk and liability
programs. This includes claims administration, the
maintenance of liability/insurance coverage as well as
the compliance with governmental regulation. In
addition, the department administers the City's workers' compensation and employee safety programs.
Expansion and Improvement: Increase knowledge and
information through better data collection and tracking.
City Attorney City Manager's
Office
Reviews and approves resolutions and ordinances.
Expansion and Improvement: Provide opportunities for
the City Attorney to review updates to regulatory
information to provide expert review of City resolutions and ordinances that may address hazard mitigation
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Table 6-2: Administrative and Technical Capabilities
Resource Name Lead
Department Description (Effect on Hazard Mitigation)
GIS Public Works Provides complex mapping and data management of City facilities, land use, and potential hazards. Supports visualization of complex data sets using geo-location
and data correlation.
Expansion and Improvement: Acquire and conduct
training for GIS technicians on the latest versions of
ArcGIS.
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Financial Capabilities
Financial capabilities include grants, general funds, property sales, income taxes, development impact fees, or stormwater utility fees. Based on procedures for each resource, these financial resources may be used to support mitigation activities.
Table 6-3: Financial Capabilities
Resource Name Administrator Description (Effect on Hazard Mitigation) General Fund Department
Specific
Program operations and specific projects. Consists of
property tax, sales tax, transient occupancy tax, and
franchise tax that can be used for general purposes.
Expansion and Improvement: Hazard mitigation
projects may be considered during the annual
budgeting process for funding from the general fund.
Utility Fees Public Works Revenue from potable water sales is regularly used to fund mitigation activities to water infrastructure.
Expansion and Improvement: Continue to use revenue
generated from potable water sales on mitigation
activities.
Hazard
Mitigation Grant
Program (HMPG)
Emergency
Management
Provides support for pre-and post-disaster mitigation
plans and projects.
Expansion and Improvement: Train staff on notice of
intent (NOI) procedures and track opportunities on the
Cal OES mitigation website to initiate applications for grant funding.
Flood Mitigation
Assistance grant
program (FMA)
Grant Funding Mitigates structures and infrastructure that have been repetitively flooded.
Expansion and Improvement: Train staff on notice of
intent (NOI) procedures and track opportunities on the
Cal OES mitigation website to initiate applications for grant funding.
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Education and Outreach Capabilities
These capabilities include fire safety programs, hazard awareness campaigns, and public information or communications offices. Education and outreach capabilities can be used to inform the public on current and potential mitigation activities.
Table 6-4: Education and Outreach Capabilities
Resource Name City Leads Description (Effect on Hazard Mitigation) Public Information Officer City
Manager’s
Office,
Various
Departments
Develops and delivers outreach and
engagement programs that promote hazard
awareness.
Expansion and Improvement: Provide
additional information to the community
about hazard mitigation activities.
City Web Sites
https://www.cityoforange.org
/home
Various
Departments
Provides easily accessed information about
the City. Used for LHMP public outreach
and engagement.
Expansion and Improvement: Use the City
website to provide additional information to
the community about hazard mitigation
activities.
City Social Media Accounts
https://www.facebook.com/ci
tyoforange
https://www.instagram.com/c
ityoforange_ca/
https://www.linkedin.com/co
mpany/city-of-orange/
https://www.x.com/cityofora
ngeCA
https://www.facebook.com/o
rangecityfiredept
https://www.instagram.com/c
ityoforangepd/
Various
Department
Provides easily accessed information about
the City. Used for LHMP public outreach
and engagement.
Expansion and Improvement: Use the City
social media platforms to provide additional
information to the community about hazard
mitigation activities.
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6.2 National Flood Insurance Program
Participation
The City of Orange adopted the Model Floodplain Management Ordinance within the City in order to maintain eligibility within the National Flood Insurance Program (NFIP). Table 6-5 contains information from the FEMA Community Status Book Report for communities participating in the NFIP.
Table 6-5: NFIP Participation Information for the City of Orange CID Community
Name County Initial FHBMIdentified
Initial
FIRM
Identified
Current
Eff
Map
Date RegEmer Date
060228 City of Orange Orange
County
03/28/1978 09/30/82 12/03/09 05/01/1987
Since 1968 the NFIP has provided federally funded flood insurance to homeowners, renters, and businesses in communities that adopt and enforce floodplain management ordinances to reduce future flood damage. The adoption of Orange Municipal Code Chapter 15.60 allows residents of the City to remain eligible to purchase flood insurance through the National Flood Insurance Program. The Ordinance meets the minimum standards set forth in Title 44, Section 60.3 of the Code of Federal Regulations. The City of Orange participates in the Community Rating System. The City does not have any repetitive flood loss structures or severe repetitive loss structures The Floodplain Management Ordinance's effect is limited to requiring that any new construction or substantial improvement to existing structures will have to comply with the standards of construction identified in the Ordinance. The City’s continued involvement in NFIP supports this plan. Currently, the City of Orange implements a floodplain management program designed to protect the people and property of the City and implements activities such as public information and outreach activities, mapping and regulatory activities, and flood damage reduction activities. The floodplain administrator, City Manager, or designee shall obtain, review, and reasonably utilize any base flood data available from federal or state agencies or other source to identify flood-prone areas within the boundaries of the city.
Post incident, the Floodplain Administrator oversees local floodplain ordinances and will implement any substantial improvements/substantial damage provisions of their floodplain management regulations according to the Orange Municipal Code Chapter
15.60.050.
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SECTION 7: MITIGATION STRATEGY
Federal regulations require local mitigation plans to identify goals for reducing longterm vulnerabilities to the identified hazards in the planning area (Section 201.6(c)(3)(i)).
A hazard mitigation plan’s primary focus is the mitigation strategy. It represents the efforts selected by the City to reduce or prevent losses resulting from the hazards identified in the risk assessment. The strategy includes mitigation actions and projects to address the risk and vulnerabilities discovered in the risk assessment. The mitigation strategy consists of the following steps:
• Identify and profile hazards and risk within the City • Identify projects and activities that can prevent or mitigate damage and injury to the population and buildings
• Develop a mitigation strategy to implement the mitigation actions • Develop an action plan to prioritize, implement, and administerthe mitigation actions • Implement the LHMP mitigation action plan
7.1 Hazard Mitigation Statement
The 2025 LHMP represents the City’s commitment to create a safer, more resilient community by taking actions to reduce risk and by committing resources to lessen the effects of hazards on the people and property of the city.
7.2 Hazard Mitigation Goals and Objectives
Mitigation goals are guidelines that represent what the community wants to accomplish through the mitigation plan. Goals are broad statements that represent a long-term, community-wide vision. The planning team reviewed the goals and objectives from the previous LHMP and determined which goals best met the City’s objectives for future mitigation. In addition to the overarching hazard mitigation goals, the City worked to develop the strategies aligned with the CIP and other planning mechanisms that relate to hazard mitigation. The 2025 LHMP was revised to focus on the communities’ future priorities as they relate to Climate Change, Wild/Urban Fire, and their commitment to involving vulnerable populations to the planning process. Table 7-1 lists the goals for the 2025 LHMP.
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Table 7-1: Hazard Mitigation Goals
2025 Goals
Goal 1: Protect life and property, and reduce potential injuries from natural, technological, and human-caused hazards
Goal 2: Improve public understanding, support of, and need for hazard mitigation measures Goal 3: Promote disaster resilience for the City’s natural, existing, and future built environment
Goal 4: Strengthen partnerships and collaboration to implement hazard mitigation activities Goal 5: Enhance the City’s ability to effectively and immediately respond to disasters
7.3 Mitigation Actions/Projects and
Implementation Strategy
Mitigation actions are specific activities or projects that serve to meet the goals that the community has identified. Mitigation actions and projects are more specific than goals or objectives and often include a mechanism, such as an assigned timeframe, to measure the success and ensure the actions are accomplished. The planning team conducted a review of the mitigation actions and strategies from the State Hazard Mitigation Plan and from other planning efforts to develop new mitigation actions and projects to reduce the effects of hazards, with emphasis on new and existing buildings and infrastructure.
The City developed and prioritized new mitigation projects, and included them in the action plan discussed below in Table 7-4. The mitigation action plan developed by the planning team includes the action items that the City intends to implement during the next five years, assuming funding availability. The action plan includes the implementing department, an estimate of the timeline for implementation, and potential funding sources.
7.4 Previous Mitigation Actions/Projects
Assessment
The 2016 LHMP contained 43 mitigations actions. Many of the mitigation actions were completed or carried out to some degree or are considered ongoing. Some of the mitigation actions were duplicative, others were better categorized as emergency preparedness or recovery activities, and others were either not addressed during the time period or were not feasible to accomplish. Table 7-2 provides the status of mitigation actions from the 2016 LHMP.
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Table 7-2: 2016 Hazard Mitigation Plan Mitigation Action Status # Mitigation Action
Status (Complete,
Ongoing, Planned,
Remove)
1 Develop a strategy to effectively alert, warn, and make notifications to all community members in the event of an imminent threat or a need to evacuate. This strategy should include distribution of notices and “canned messages” through multiple methods
(television, phone, radio, mobile device, door-to-door notifications, etc.) and in all languages widely spoken in the community and for people with disabilities and access and functional needs.
Remove
2 Distribute information about ways to reduce the threat of hazards to all community members through mailings, printed notifications, television and digital devices, and in-person events and workshops.
All information should be in multiple languages, culturally appropriate, and for people with disabilities and access and functional needs
Remove
(Combined with
#14 and added to
2025 Mitigation
Actions)
3 Incorporate all hazards identified in the Local Hazard Mitigation Plan into all City emergency response planning efforts and programs.
Ongoing
(Added to 2025
Mitigation Actions)
4 Identify and implement needed infrastructure and program-level actions to maintain City services to community members during emergency situations.
Remove
5 Work with regional utility companies and service agencies, including electricity and natural gas providers, telecommunication providers, and transit agencies, to determine approximate time frames for service interruptions, develop appropriate stopgap measures, and establish emergency activities to provide public safety through the restoration process
On-going
(Added to 2025
Mitigation Actions)
6 In coordination with state and regional agencies and other key stakeholders, conduct disaster training and exercises of increasing complexity.
Remove
7 Ensure General Plan updates and incorporates hazards information provided in this Local Hazard Mitigation Plan and a policy framework consistent with the actions in this Local Hazard Mitigation Plan. Consider adopting the LHMP into the Safety Element of the General Plan.
On-going
(Added to 2025
Mitigation Actions)
8 Coordinate and participate with local, regional, and state agencies to monitor potential changes in the severity, duration, and affected areas of all hazards, and evaluate the possibility for additional hazards to become a threat. In particular, monitor the effects that climate change may have on future hazards.
On-going
(Added to 2025
Mitigation Actions)
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Table 7-2: 2016 Hazard Mitigation Plan Mitigation Action Status # Mitigation Action
Status (Complete,
Ongoing, Planned,
Remove)
9 Invest in energy efficiency upgrades, energy conservation programs, renewable energy facilities, and innovative energy technologies such as microgrids to ensure government facilities are operational during extreme events. Critical facilities and facilities identified as cooling centers should be prioritized.
On-going
(Added to 2025
Mitigation Actions)
10 Identify seismically vulnerable municipally owned facilities and identify potential funding sources to conduct seismic retrofits in public buildings.
On-going
(Added to 2025
Mitigation Actions)
11 Inventory the unreinforced masonry, soft story, and other seismically vulnerable private buildings in the city. Advise the owners of potential means of pursuing solutions to assist with seismic retrofits.
Removed
12 New development will be required to abide by the most recently adopted City and state seismic and geotechnical requirements. All older buildings, particularly unreinforced masonry buildings, and buildings located near the Peralta Hills and El Modena Faults should be reinforced and strengthened to prevent damage to structures and loss of life in the event of an earthquake.
Remove
13 Contact utility companies and districts to obtain information regarding seismic evaluations of utility infrastructure, including power lines, water pipelines, sewer lines, freeways and key surface streets, and natural gas pipelines, in coordination with utility companies and appropriate agencies. Advise utility companies and districts of potential means of pursuing solutions to assist with seismic retrofits.
Remove
14 Continue to provide public education programs regarding geologic and seismic hazards and continue to cooperate with surrounding cities, regional, state, and federal government in programs designed to implement the most strategic and efficient actions to mitigate such hazards.
On-going
(Added to 2025
Mitigation Actions)
15 Require liquefaction assessment studies and implementation of mitigation measures for qualifying projects. Potential mitigation measures include soil densification or compaction, displacement or compaction grouting, post-tensioned slab foundations, piles, or caissons.
Ongoing
(Added to 2025
Mitigation Actions)
16 Identify critical facilities and key pieces of infrastructure that are at an elevated risk of liquefaction and conduct retrofits to reduce vulnerability.
Remove
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Table 7-2: 2016 Hazard Mitigation Plan Mitigation Action Status # Mitigation Action
Status (Complete,
Ongoing, Planned,
Remove)
17 Continue to educate the public and provide up-to-date maps delineating areas that could face fire hazards.
Remove
(Combined with
#14 and added to
2025 Mitigation
Actions)
18 Regulate structural development within or adjacent to wildland to ensure best building practices to create fire resistive communities Ongoing
(Added to 2025
Mitigation Actions)
19 Designate selected City and community facilities as cooling centers, ensuring that all residents have easy access to a cooling center, including those with limited mobility. Set a temperature trigger to open the cooling centers and distribute information about cooling center availability through multiple media forms.
Completed
20 Provide training to outdoor City workers, including landscaping, recreation, and construction staff, about the risks posed by extreme heat and ways to reduce vulnerability. Work with local businesses and community groups to encourage similar training in the private sector.
Remove
21 Identify and pursue alternative water sources to supplement imported Colorado River and State Water Project deliveries.
On-Going
(Added to 2025
Mitigation Actions)
22 Explore constructing additional water storage facilities and additional emergency connections to supplement water supplies during drought conditions or short-term shortages.
On-Going
(Added to 2025
Mitigation Actions)
23 Develop and implement long-term strategies to reduce community water use, including mandatory use of drought-tolerant plants in new or replacement landscapes, and requirements to install water fixtures in new buildings that exceed minimum code requirements.
On-Going
(Added to 2025
Mitigation Actions)
24 Educate community residents and businesses about available rebates for water-efficient and water-conserving equipment.
On-Going
(Added to 2025
Mitigation Actions)
25 Consider implementing additional mandatory restrictions on water use during drought conditions.
Remove
26 Install drought-tolerant or artificial turf at City parks as feasible. On-going (Added to 2025
Mitigation Actions)
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Table 7-2: 2016 Hazard Mitigation Plan Mitigation Action Status # Mitigation Action
Status (Complete,
Ongoing, Planned,
Remove)
27 When conducting water supply analyses for future Urban Water Management Plans, use more severe/long-lasting drought scenarios.
On-Going
(Added to 2025
Mitigation Actions)
28 Design future critical infrastructure to withstand wind events beyond minimum code standards.
Remove
29 Monitor trees and other vegetation near power lines, and promptly inform Utilities and/or Public Works of the need for any tree trimming.
Remove
30 Develop and maintain protocols to ensure that City staff and emergency responders are notified as soon as possible following a hazardous materials release, or if an emergency situation (e.g., a flood) may result in a hazardous materials release.
Complete
31 Require all new development to abide by the most recently adopted City and state seismic and geotechnical requirements.
Ongoing
(Added to 2025
Mitigation Actions)
32 Provide public education programs regarding geologic threats and hazards.
Removed
(Combined with
#14 and added to
2025 Mitigation
Actions)
33 Continue to cooperate with surrounding cities, regional, state, and federal government in programs designed to implement the most strategic and efficient actions to mitigate landslide, expansive soil, and erosion hazards.
Ongoing
(Added to 2025
Mitigation Actions)
34 Evaluate the effectiveness of City-owned stormwater drainage and pipeline systems, and conduct improvements as needed.
On-Going
(Added to 2025
Mitigation Actions)
35 In coordination with utility companies and state and regional agencies, conduct a flood resiliency analysis of critical facilities and key utility and transportation infrastructure. Identify actions to reduce vulnerability and pursue funding to carry out improvements.
Remove
36 Supplement existing drainage systems with low-impact development features as feasible such as promoting developments that incorporate permeable surfaces within site design
Remove
37 Support the use of low-impact development features in new projects, including as a condition of approval for major developments.
Ongoing
(Added to 2025
Mitigation Actions)
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Table 7-2: 2016 Hazard Mitigation Plan Mitigation Action Status # Mitigation Action
Status (Complete,
Ongoing, Planned,
Remove)
38 Investigate the City’s ability to continue to participate in the National Flood Insurance Program’s Community Rating System to reduce local insurance premiums and further mitigate flood impacts.
Remove
39 Develop critical public and private facilities such as medical, educational, and civic facilities to be located outside of flood zones.
Ongoing
(Added to 2025
Mitigation Actions)
40 Develop and offer educational programs for the public and City staff regarding flood hazards.
Remove
41 Develop an outreach campaign for residents regarding the upgrades to Prado Dam, and potential flooding impacts in the city associated with Santiago and/or Villa Park dam failures.
Remove
42 Coordinate with the Orange County Public Health Services, Orange County Vector Control District, and local medical care providers to distribute information about ways to reduce the risks associated with diseases of concern, including influenza and West Nile virus.
Remove
43 Identify areas of poor drainage or other areas with consistently stagnant water and address through new or retrofitted drainage infrastructure.
Remove
7.4.1 New Mitigation Actions
Mitigation actions are specific activities or projects that serve to meet the goals that the community has identified. Mitigation actions and projects are more specific than goals or objectives and often include a mechanism, such as an assigned time period, to measure the success and ensure the actions are accomplished. The planning team conducted a review of the mitigation actions and strategies from the 2016 LHMP. With information from the risk assessment, capability assessment, and status of the actions implemented since the 2016 LHMP, the planning team developed 32 new ongoing mitigation actions and projects to reduce the effects of hazards, with emphasis on new and existing buildings and infrastructure. Those actions that were carried over from the 2016 LHMP, were incorporated into similar actions.
Table 7-3 lists potential mitigation actions developed by the planning team. Mitigation Actions that were chosen were excluded from Table 7-3 and incorporated into Table 7-4. 780
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Table 7-3: Potential Mitigation Actions 2025
Goal Action
Item # Action Description MitigationType
Related
Hazards
Implementing
Organizations
Goal 1: Protect
life, property,
and reduce
potential
injuries from
natural caused
hazards
1.1 Assess and
implement flexible
piping joints at
above-ground
storage reservoirs as
appropriate
Prevention Seismic Operations
1.2 Continue to identify
and ensure that pipe
specifications are
compatible with
engineering and
earthquake
specifications
Prevention Seismic Operations
1.3 Identify funding and
acquire a mobile
command and
communications
vehicle
Response All Operations
1.4 Continue to include
back-up power
Preparedness Loss of
Power/
PSPS
Operations
7.4.2 Mitigation Action Plan
The action plan developed by the planning team includes the action items that the City intends to implement during the next five years, assuming funding availability. The action plan, shown in Table 7-4, includes the implementing department, an estimate of the timeline for implementation, and potential funding sources.
The new mitigation actions include a broad range of approaches to hazard mitigation such as retrofitting, code enforcement, development of new regulations, public education, development of redundant facilities, and others. Measures are included to mitigate risks to existing buildings and infrastructure, as well as new buildings and infrastructure. The mitigation action plan assigns primary responsibility for each of the action items to an implementing department. The implementing department is the controlling department that will assign funding and oversee activity implementation, monitoring, and evaluation.
The planning team does not presume the expertise to prescribe which projects will be implemented. Prioritization of projects in the LHMP is a means to provide a basis for implementing the mitigation strategies, but all new mitigation actions and projects will be 781
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formally prioritized and selected by the implementing department. This will accommodate the project funding, schedule of the department, staff requirements, and ability to integrate the new project into existing and ongoing projects. D
Prioritization
To assist with implementing the mitigation action plan, the planning team used the following ranking process to provide a method to prioritize the projects for the Action Plan.
Designations of High, Medium, and Low priorities have been assigned to each action item using the following criteria.
Does the action Solve the problem?
Address vulnerability assessment?
Reduce the exposure or vulnerability to the highest priority hazard? Address multiple hazards?
Offer benefits that equal or exceed costs?
Implement a goal, policy, or project identified in the General Plan or Capital
Improvement Plan?
Can the action Be implemented with existing funds?
Be implemented by existing state or federal grant programs? Be completed within the five-year life cycle of the LHMP? Will the action Be implemented with currently available technologies? Be accepted by the community?
Be supported by community leaders?
Adversely affect segments of the population or neighborhoods? Require a change in local ordinances or zoning laws?
Result in a positive or neutral impact on the environment? Comply with all local, state, and federal environmental laws and regulations?
Is there Sufficient staffing to undertake the project?
Existing authority to undertake the project?
Each positive response is equal to one point. Answers to the criteria above determined the priority according to the following scale:
1–6 = Low priority 7–12 = Medium priority 13–18 = High priority 782
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Benefit-Cost Analysis
Conducting benefit/cost analysis for a mitigation activity can assist the City in determining whether a project is worth undertaking now to avoid disaster-related damages later. Costeffectiveness analysis evaluates how to best spend a given amount of money to achieve a specific goal. Determining the economic feasibility of mitigating hazards can provide decision-makers with an understanding of the potential benefits and costs of an activity, as well as a basis for comparing alternative projects.
Funding
The funds required to implement the mitigation action plan will come from a variety of sources, including Federal Hazard Mitigation Grants, City budget, bonds, fees and assessments, and others. Some projects are (or will be) included in capital improvement budgets, while some, especially ongoing projects, are included in department operating budgets.
Prior to beginning a project or when federal funding is involved, the implementing department will use a FEMA approved benefit/cost analysis approach to identify the actual costs and benefits of implementing these mitigation actions. For non-structural projects, implementing departments will use other appropriate methods to weigh the costs and benefits of each action item and then develop a prioritized list.
Implementation
Mitigation projects were assigned one of three categories as a tentative schedule for implementation: short-range, mid-range, and long-range. Projects that are currently being implemented by various departments are assigned to the ongoing category.
Implementation of short-range projects will typically begin within the next three (3) years.
Mid-range projects will require some planning and likely require funding beyond what is currently allocated to the various departments in the City’s Operations and Maintenance budget. Projects in the mid-range category will generally begin implementation in the next three (3) to five (5) years. Long-range projects will require great planning and funding and will generally begin implementation within five years and beyond.
7.5 Previous Plan Incorporated into Other
Planning Mechanisms
The 2016 LHMP was integrated into the following planning mechanisms:
• The City EOP contains a list of hazards. The LHMP provided a similar, more detailed description of these hazards. The update to the LHMP informed revisions to the EOP.
• The American Water Infrastructure Act required Risk and Resiliency Assessment 783
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(RRA) informed the update to the hazard analysis that are contained in both. Hazard analysis and risk/vulnerability updates to one document should be reviewed for inclusion in both.
• The City reviewed the 2016 mitigation action plan in the LHMP to update the CIP.
Several mitigation actions addressed facility improvement and resiliency. 784
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Table 7-4: Mitigation Action Implementation Plan
# Mitigation Action Funding
Sources
Responsible
Department
Relative
Cost*
Time
Frame Priority
1 Install energy efficient equipment and harden emergency backup power at critical facilities deemed necessary.
Prioritize installations for facilities that serve as key cooling/warming centers and evacuation centers/shelters. (Hazards addressed: All, Power Outage, Infrastructure
Failure)
General Fund,
HMGP
Public Works $$ 2-5
years
Medium
2 Develop a list of key facilities. Conduct a feasibility assessment of installing solar and battery backup systems at critical facilities within the City.
(Hazards addressed: All, Power Outage, Infrastructure
Failure)
General Fund,
HMGP
Public Works $ 2 years Medium
3 Upgrade power and water facilities, to include reservoirs, to improve resiliency due to power loss, flooding, and
seismic activity.
(Hazards addressed: All)
General Fund,
HMGP
Public Works $$$ Ongoing
- Yearly
High
4 Develop a policy to ensure the City's LHMP is reviewed during the development of capital improvement
plans/projects.
(Hazards addressed: All)
General Fund,
HMGP
Fire $ 1 year Medium
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Table 7-4: Mitigation Action Implementation Plan
# Mitigation Action Funding
Sources
Responsible
Department
Relative
Cost*
Time
Frame Priority
5 Develop a Public Outreach Plan geared towards providing hazard education, emergency management, and mitigation
action activities. Create and Integrate hazard mitigation material into public safety information and training
programs (e.g. Community Emergency Response Team
Program)
(Hazards addressed: All)
General Fund,
HMGP
Fire $ Ongoing
- yearly
Low
6 Integrate the LHMP into the City’s General Plan by
complying with AB 2140.
(Hazards addressed: All)
General Fund,
HMGP
Planning $ Ongoing
- yearly
Low
7 Develop a policy to ensure the City’s Building Codes are reviewed annually to reflect changes and best practices in hazard science
(Hazards Addressed: Flood, Earthquake).
General Fund,
HMGP
Planning $ 3 years Medium
8 Closely monitor changes in the boundaries of mapped
hazard areas resulting from land use changes or climate change and adopt new mitigation actions or revise
existing ones to ensure continued resiliency.
(Hazards addressed: All)
General Fund,
HMGP
Fire/
Planning
$ 2 years Medium
9 Integrate climate change mitigation and adaptation
information and analysis into future LHMP updates and
others.
(Hazards addressed: Climate Change)
General Fund,
HMGP
Fire $ Ongoing
- Yearly
High
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Table 7-4: Mitigation Action Implementation Plan
# Mitigation Action Funding
Sources
Responsible
Department
Relative
Cost*
Time
Frame Priority
10 Implement measures to bolster local water supply to meet demand, create a sustainable water supply, while meeting environmental mandates.
(Hazards addressed: Drought)
General Fund,
HMGP
Public Works $$$ 3 years High
11 Develop public messaging about water conservation to address climate change-induced drought for posting on
websites, social media, and other platforms.
(Hazards addressed: Drought)
General Fund,
HMGP
Public Works $ Ongoing
- Yearly
Low
12 Implement and enforce the soft story retrofit ordinance. (Hazards addressed: Seismic)
General Fund,
HMGP
Planning $ 2 years Medium
13 Conduct an educational campaign, incentivize and
promote medium-scale seismic retrofits, such as window
films to minimize shattering, anchors for rooftop-mounted equipment, bracing for masonry chimneys, and other
preventative measures to reduce damage to private
buildings.
(Hazards addressed: Seismic)
General Fund,
HMGP
Planning $ 2 years Medium
14 Develop a Landslide Management Plan that identifies
areas at risk and mitigation strategies and develop a policy to ensure the annual review of potential landslide areas in the City of Orange.
(Hazards addressed: Landslide)
General Fund,
HMGP
Fire/
Planning/
Public Works
$ 5 years Low
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Table 7-4: Mitigation Action Implementation Plan
# Mitigation Action Funding
Sources
Responsible
Department
Relative
Cost*
Time
Frame Priority
15 Conduct a seismic analysis of all City-owned key facilities and retrofit vulnerable facilities.
(Hazards addressed: Seismic)
General Fund,
HMGP
Public Works $ 2-3
Years
High
16 Initiate a program to schedule installation of resilient (seismically appropriate) piping for new or replacement water distribution pipelines.
(Hazards addressed: Seismic)
General Fund,
HMGP
Public Works $$$$ Ongoing
- Yearly
High
17 Identify and retrofit key critical facilities with seismically rated window film treatments that ensure glass windows
do not shatter during a strong seismic event.
(Hazards addressed: Seismic)
General Fund,
HMGP
Planning/
Public Works
$$ 5 years High
18 Investigate the use of permeable paved and landscaped swales for new construction and replacement of Cityowned hardscaped areas. [Identify which locations] (Hazards addressed: Flooding)
General Fund,
FMA
Public Works $$
3 years
Medium
19 Retrofit roadway medians to capture stormwater during rain events. Prioritize improvements along major arterials/ roadways throughout the City.
(Hazards addressed: Flooding)
General Fund,
FMA
Public Works $$$ 4 years Medium
20 Remove or trim trees determined to be susceptible to blowing over during a severe wind event and
underground power lines, where feasible.
(Hazards addressed: High Winds, Severe Rainstorm)
General Fund,
HMGP
Parks/
Public Works
$ Ongoing
- yearly
Medium
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Table 7-4: Mitigation Action Implementation Plan
# Mitigation Action Funding
Sources
Responsible
Department
Relative
Cost*
Time
Frame Priority
21 Educate and promote the proper maintenance and
separation of power lines from trees and other hazards. (Hazards addressed: All)
General Fund,
HMGP
Fire/ Public
Works
$ Ongoing
- Yearly
High
22 Conduct regular fuel modification projects to reduce fire hazard risks, such as clearing out dead vegetation in parks, open spaces, right-of-way embankments, and other areas
that could become fuel for fires.
(Hazards addressed: Wildfire)
General Fund,
HMGP
Fire/Public
Works
$ Ongoing
- Yearly
High
23 Adopt a wildfire mitigation ordinance to limit the use and development of wildfire hazard areas to mitigate risk to life and property.
(Hazards addressed: Wildfire)
General Fund,
HMGP
Fire $ 2 years High
24 Identify Dam inundation threats to the City and
implement an early warning system/protocol that notifies downstream communities in the event of a potential dam
failure incident.
(Hazards addressed: Dam Failure)
General Fund,
HMGP
Public Works $ 2 years Low
25 Continuously inspect businesses and other properties storing hazardous materials and create an inventory of
storage locations that require updates, maintenance, or renovation.
(Hazards addressed: Hazardous Materials)
General Fund,
HMGP
Fire $ Ongoing
- Yearly
Medium
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Table 7-4: Mitigation Action Implementation Plan
# Mitigation Action Funding
Sources
Responsible
Department
Relative
Cost*
Time
Frame Priority
26 Establish and provide annual cyber-security risk briefings to City officials. Leverage the Department of Homeland
Security’s State, Local, Tribal, and Territorial Cyber
security engagement programs.
(Hazards addressed: Cyber Attack)
General Fund,
HMGP
IT $ 2 years High
27 Conduct an annual survey of high-risk trees in the City and develop a strategy to remove high risk trees prior to major wind or rain event.
(Hazards addressed: Tree Mortality)
General Fund,
HMGP
Public Works $ 2 years Low
28 Evaluate all critical facilities, facilities of concern for potential human-caused hazard vulnerabilities and
integrate counterterrorism design elements and building materials, where feasible.
(Hazards addressed: Terrorism)
General Fund,
HMGP
Police $ Ongoing
- Yearly
Medium
29 Develop and coordinate planning with partners for
dispensing of medications or vaccines. Coordinate
infection control planning with partners.
(Hazard Addressed: Pandemic)
General Fund,
HMGP
Public Health $$ Ongoing
- Yearly
Medium
30 Storm drain enhancements throughout the city
(Hazard Addressed: Flooding)
General Fund,
HMGP
Public Works $$ Ongoing
- Yearly
Medium
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SECTION 8: PLAN IMPLEMENTATION
AND MAINTENANCE
Implementation and maintenance of the plan is critical to the overall success of hazard mitigation planning. This section details the process that the City will use to monitor, update, and evaluate the plan within the five-year cycle of the plan’s revision to ensure the LHMP remains an active and relevant document. The format of the plan aligns with the regulation checklist and is divided into sections of information. When it is time to maintain or revise the LHMP, data can be easily located and incorporated, resulting in an easy method to keep the plan current and relevant.
8.1 Monitoring and Evaluation
The planning team represents City staff from each department and other stakeholders that contributed to the development of the 2025 plan. The planning team oversaw the development of the plan and made recommendations on key elements of the plan, including the maintenance strategy.
It was important to the City that each department be represented in the planning team and given the opportunity to provide input during the plan development. This philosophy will continue for future plan revisions through evaluations, maintenance, and updates of data, processes, and programs. The City Emergency Manager will convene the planning team annually to perform annual reviews of the LHMP Mitigation Actions and its implementation to review the plans progress and effectiveness. To evaluate the plan’s effectiveness, the planning team will review project timelines and whether the project continues to meet the needs and goals of the City. The planning team will include representatives from the City, non-profit, chamber of commerce, County department, and interest groups within the planning area.
If internal planning team members can no longer serve on the planning team, the Department Director will assign another staff person to be on the planning team so that every City department is represented.
8.2 Plan Update
Section 201.6.d.3 of 44CFR requires that local hazard mitigation plans be reviewed, revised as appropriate, and resubmitted for approval in order to remain eligible for benefits awarded under the Disaster Mitigation Act. The City intends to update its hazard mitigation plan on a five-year cycle. The next update will begin starting April of 2029 Based on needs identified by the planning team, the update will, at a minimum, include the following elements:
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• The hazard risk assessment will be reviewed and updated using the most recent information and technologies
• The action plan will be reviewed and revised to account for any initiatives completed, dropped, or changed and to account for changes in the risk assessment • Any new City policies identified under other planning mechanisms, as appropriate • The draft LHMP update will be sent to appropriate agencies and organizations for comment
• The public will be given an opportunity to comment on the updated version prior to adoption
• The City Council will adopt the updated plan
At a minimum of 12 months before the expiration date of the 2026 LHMP, The City Emergency Manager will convene the planning team to commence the plan revision schedule to formally update the 2026 plan. The plan will be revised using the latest FEMA hazard mitigation guidance documents, such as the Mitigation Planning Tool and Regulation Checklist, to ensure compliance with current hazard mitigation planning regulations.
8.3 Continued Public Involvement
The overall success of the LHMP is through implementation of the plan’s hazard mitigation strategy and activities to reduce the effects of hazards, protect people and property, and improve the City’s efforts to respond to and recover from disasters. Members of the public and the City will ultimately benefit from the implementation of the LHMP and must be given the opportunity to provide input to the continuous cycle of LHMP planning.
The City will strive to keep the public aware of hazard mitigation projects that take place as a result of the LHMP. Public information will be released through press releases, City website announcements, public hearings as required, council meetings, social media, and press releases.
Projects that mitigate hazards are included in the City’s annual budget planning process.
The public is made aware of the planning through City Council meetings and press releases during this time. The budget planning process will serve as an annual opportunity to conduct outreach to the public on updates to the hazard mitigation planning process.
A survey can be conducted to gather input on how the community feels about the progress being made on LHMP activities. The Public Information Officer will be tasked with public outreach and responsible for ensuring the public is included and involved in the annual public plan update and outreach.
When the time comes to begin revising the 2025 LHMP, the plan update process will be implemented, which will include continued public involvement and input through 792
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attendance at designated public meetings, web postings, through press releases to local media, community fairs, and events, and surveys. As part of this effort, a series of public meetings will be held, and public comments will be solicited on the revisions to the LHMP according to the five-year cycle. Table 8-1 summarizes successful public involvement efforts previously conducted by the City, as well as proposed activities for public involvement and dissemination of information that shall be pursued whenever possible and appropriate.
Table 8-1: Past and Proposed Continued Public Involvement Activities or Opportunities Identified by the City
Department
Public Involvement Activity or Opportunity
Past Proposed
Fire LHMP Survey was conducted
online and given out at City
events in person.
Conduct annual surveys to be
completed online.
All Place more emphasis on the risks
associated with natural and manmade
hazards at public awareness
campaigns conducted by various City
departments. Consider developing and
distributing public education materials
for natural hazards.
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APPENDIX A – LOCAL MITIGATION
PLAN REVIEW TOOL
[To be inserted prior to State submission]
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APPENDIX B – PLANNING TEAM
MEETING/STAKEHOLDER
DOCUMENTATION
Appendix B contains documentation of the planning process for the LHMP Planning Team, including meetings, presentations, emails, etc.
Date Activity Documentation
February 10, 2025 Project Kick-off Meeting • Documentation 1: Meeting Notes March 4, 2025 Planning Team Meeting #1 • Documentation 2: Meeting Notes May 7, 2025 Planning Team Meeting #2 • Documentation 3: Meeting Notes October 7, 2025 Draft sent to stakeholders
for review
• Documentation 4: Stakeholder
Email
Documentation 1: Kick-off Meeting Notes
795
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
173
796
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
174
797
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
175
798
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
176
799
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
177
Documentation 2: Planning Meeting Notes
800
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
178
801
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
179
802
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
180
803
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
181
804
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
182
805
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
183
Documentation 3: Planning Meeting Notes
806
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
184
807
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
185
808
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
186
809
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
187
Documentation 4: Email to Stakeholders
810
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
188
APPENDIX C – PUBLIC ENGAGEMENT
DOCUMENTATION
Appendix C contains documentation of the planning process including meetings, presentations held for the stakeholders and public, and other stakeholder/public outreach efforts.
Date Activity Documentation
November 19,
2024 - Present
Survey posted on City Website
with links provided in social
media accounts. General Hazard
Mitigation documents. Pictures of
events and posting of
information.
Documentation 2: Orange Fire Website
Survey Distribution
Documentation 3: Orange Fire Website
Hazard Mitigation Material
Documentation 4: Flyers at City Public
Facing Facilities
Documentation 5: Social Media Hazard
Mitigation Material Screenshots
Documentation 7: Hazard Mitigation
Flyer
November 19,
2024 – July
2025
LHMP Outreach Event Documentation 1: City of Orange Car Show
Documentation 8: Hazard Mitigation
Public Outreach Presentation
3 months Public hazard mitigation survey
conducted.
Documentation 6: Hazard Mitigation
Public Survey
Documentation 9: Hazard Mitigation
Public Survey Results
TBD Draft LHMP provided for public
review.
TBD
TBD Draft LHMP provided to
neighboring jurisdiction for
review and comment.
TBD
811
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
189
Documentation 1: City of Orange Car Show
Documentation 2: Orange Fire Website Survey Distribution 812
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
190
Documentation 3: Orange Fire Website Hazard Mitigation
Material
Documentation 4: Flyers at City Public Facing Facilities 813
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
191
814
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
192
Documentation 5: Social Media Hazard Mitigation Material Screenshots
815
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
193
Documentation 6: Hazard Mitigation Public Survey
816
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
194
817
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
195
818
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
196
Documentation 7: Hazard Mitigation Flyer
819
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
197
Documentation 8: Hazard Mitigation Public Outreach
Presentation (Cover Slide Only)
820
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
198
Documentation 9: Hazard Mitigation Public Survey Results 821
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
199
822
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
200
823
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
201
824
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
202
825
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
203
826
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
204
827
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
205
828
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
206
APPENDIX D – ACRONYMS AND
ABBREVIATIONS
Acronym Definition
AB Assembly Bill
Cal OES California Governor’s Office of Emergency Services CARB California Air Resource Board
CDAA California Disaster Assistance Act
CFR Code of Federal Regulations
CIP Capital Improvement Plan
CPRI Calculated Priority Risk Index
DMA 2000 Disaster Mitigation Act of 2000
EAP Emergency Action Plan
EOP Emergency Operations Plan
ERP Emergency Response Plan
FEMA Federal Emergency Management Agency
FMA Flood Mitigation Assistance
GHG Greenhouse Gas
HMA Hazard Mitigation Assistance
HMGP Hazard Mitigation Grant Program
HMPC Hazard Mitigation Planning Committee
LHMP Local Hazard Mitigation Plan
MWD Metropolitan Water District of Southern California
NFIP National Flood Insurance Program
PDES National Pollutant Discharge Elimination System
NWS National Weather Service
OCTA Orange County Transportation Authority
PDM Pre-Disaster Mitigation
RFC Repetitive Flood Claims
RL Repetitive Loss
SB Senate Bill
SCADA Supervisory Control and Data Acquisition
829
CITY OF ORANGE LOCAL HAZARD MITIGATION PLAN
207
Acronym Definition
SHMO State Hazard Mitigation Officer
SHMP State Hazard Mitigation Plan
STAPLEE Social, Technical, Administrative, Political, Legal, Economic, Environmental U.S. EPA U.S. Environmental Protection Agency
UCERF3 (the third) Uniform California Earthquake Rupture Forecast USDM U.S. Drought Monitor
USSDO U.S. Seasonal Drought Outlook
UWMP Urban Water Management Plan
NIDIS National Integrated Drought Information System
WUI Wildland Urban Interface
830
Agenda Item
Orange City Council
Item #: 3.28. 4/28/2026 File #: 26-0013
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director
1. SUBJECT
Updates to the eligibility and preference criteria for the Tenant Based Rental Assistance Program Policies and Procedures
2. SUMMARY
Consideration of proposed updates the eligibility and preference criteria for the Tenant Based Rental Assistance Program Policies and Procedures adopted as part of the HOME Americal Rescue Plan Allocation Plan.
3. RECOMMENDED ACTION
1. Approve the following recommended changes to the eligibility and preference criteria for the Tenant Based Rental Assistance Program Policies and Procedures:
a. Remove the requirement to have applied for and been denied for CalAIM; b. Specify definition of elderly persons to 62+;
c. Update income eligibility to 60% of Area Median Income; d. Remove the tenant incentive for returned deposits.
2. Approve adding special consideration to applicants who are:
a. Experiencing homelessness;
b. At risk of homelessness;
c. Fleeing domestic violence, dating violence, sexual assault, or stalking.
3. Direct staff to update the Tenant Based Rental Assistance Program Policies and Procedures with the recommended changes and submit to the Department of Housing and Urban Development for approval and implementation.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life
6. DISCUSSION AND BACKGROUND
On May 9, 2023, the City approved $150,000 for a Tenant Based Rental Assistance (TBRA) Program for security and utility deposit assistance as part of its 2023-2024 Annual Action Plan (Attachment A) using HOME Investment Partnerships Program (HOME) entitlement funds. A TBRA Program provides rental subsidy to assist individual households to address housing instability and insecurity by helping City of Orange Page 1 of 5 Printed on 4/23/2026
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Item #: 3.28. 4/28/2026 File #: 26-0013
rental subsidy to assist individual households to address housing instability and insecurity by helping families afford housing costs such as rent or security deposits. The Annual Action Plan is required by HUD and outlines the City’s intent for the use of funds in a given entitlement year. Detailed information about the program background is provided in Attachment B.
As part of the approval, the following requirements were established to determine eligibility for an applicant:
1. Current City of Orange resident staying in the City of Orange;
2. Referred by a supportive services agency/organization;
3. Have applied for and be ineligible or denied for CalAIM assistance;
4. Have income below 80% of the area median income.
In addition, the following preferences were established:
1. Families with children under 12;
2. Veterans with a valid DD-214 (honorable discharge); and
3. Elderly persons as defined by the Social Security Administration eligibility of full retirement qualification.
Since the launch of the TBRA Program in January 2025, the City has not received any applications from households that qualify under the adopted eligibility criteria, resulting in no utilization of the allocated HOME funds. After approximately one year of inactivity, staff conducted a programmatic review to determine whether the lack of utilization was attributable to a lack of community need or to structural barriers within the program design.
CalAIM Requirement
Following a review of the adopted program guidelines and consultation with the Orange County Continuum of Care and supportive service providers, staff determined that the requirement to first apply for and be denied CalAIM assistance created an unintended barrier to access that limited the program’s ability to respond to housing opportunities.
Staff reviewed applicable HOME regulations and identified the following considerations:
1. HOME regulations at 24 CFR Part 92 do not require or authorize conditioning TBRA eligibility on denial from another program.
2. HUD evaluates HOME programs based on timely commitment and expenditure of funds.
Prolonged inactivity increases the risk of timeliness concerns.
3. Additional eligibility criteria not tied to HOME statutory or regulatory requirements may be viewed during monitoring as creating unnecessary barriers to assistance.
4. Conditioning HOME TBRA eligibility on application to an unrelated health care benefit may undermine the independent purpose and structure of the HOME program.
5. TBRA eligibility should be based on HOME income and housing need requirements, not on denial of assistance from external programs.
CalAIM provides limited housing-related assistance, including one-time security deposit and utility assistance, to eligible Medi-Cal members with documented health and social risk factors. It is a City of Orange Page 2 of 5 Printed on 4/23/2026
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Item #: 3.28. 4/28/2026 File #: 26-0013
assistance, to eligible Medi-Cal members with documented health and social risk factors. It is a health care benefit administered through managed care plans and requires that an individual:
1. Be a Medi-Cal member;
2. Be enrolled in a participating managed care plan;
3. Be screened and determined eligible under Community Supports criteria; and
4. Provide documentation of qualifying medical and/or social risk factors.
Additionally, CalAIM assistance:
1. Is targeted to specific high-risk populations;
2. Is not available to all income-eligible renters; and
3. May be subject to plan funding limitations or provider capacity constraints.
While CalAIM provides valuable housing-related assistance, it is a health care benefit administered through managed care plans and requires enrollment, eligibility screening, and plan authorization.
These requirements may not align with the timeframe in which rental housing opportunities arise.
Tenant Incentive for Returned Deposits
In addition, staff determined that the well-intended provision allowing tenants who receive at least 80% of their security deposit back to retain 50% of the refunded amount as an incentive for proper unit maintenance may place the City at risk of a HUD monitoring finding and potential repayment obligation. Under HOME regulations, any TBRA funds returned to the City, including refunded security deposits, must be treated as program income and used for eligible HOME activities, such as additional TBRA assistance or other qualifying housing costs (e.g., gap financing for affordable housing developments). Once a tenant vacates the unit and the deposit is returned, those funds are no longer supporting an eligible housing cost. Disbursing a portion of the funds returned directly to the former tenant would constitute a cash incentive rather than an eligible HOME assisted housing expense, which is not permitted under HOME regulations.
Preference for Elderly Applicants
Social Security retirement eligibility varies by birth year, resulting in differing age thresholds for full retirement benefits. To ensure consistency and administrative clarity, staff recommends revising the elderly preference to apply to individuals 62 years of age or older, consistent with HUD’s general definition of an elderly person.
Income Eligibility
A review of TBRA programs administered by other HOME participating jurisdictions found that many programs limit eligibility to households earning 60% of Area Median Income (AMI) or below. Though federal regulations allow for up to 80% AMI for eligibility, a more restrictive income threshold ensures that the City’s limited HOME resources are directed to households most likely to experience barriers to securing housing, including those at risk of homelessness, families with children, seniors, and veterans. Households within this income range are more likely to face difficulty covering upfront move -in costs such as security deposits and utility deposits, particularly in the current rental market.
This adjustment also aligns the program with common HOME program practices nationwide, where TBRA and housing stability programs frequently target households earning 60% of AMI or below in order to prioritize lower-income households and maximize the housing stability impact of available City of Orange Page 3 of 5 Printed on 4/23/2026
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Item #: 3.28. 4/28/2026 File #: 26-0013
federal funds.
Special Consideration Criteria
Staff recommends adding language to the program guidelines that provides special consideration for households experiencing homelessness, at risk of homelessness, or fleeing domestic violence, dating violence, sexual assault, or stalking. The special criteria clarifies the City’s intent to align the program with federal housing policy priorities and best practices for housing stability programs.
The revision also strengthens the City’s compliance with federal protections, including the Violence Against Women Act (VAWA), which ensures that survivors of domestic violence, dating violence, sexual assault, and stalking are not denied housing assistance due to their circumstances.
Providing special consideration for these households helps ensure that limited HOME funds are used strategically to assist individuals and families facing the highest risk of housing instability. The change also supports coordination with local service providers and regional homelessness response systems, improving access to housing opportunities for vulnerable residents.
HOME-ARP Compliance Requirements
On September 20, 2021, the City was allocated $1,655,186 in HOME Investment Partnerships HOME American Rescue Plan (HOME-ARP) funds in response to the COVID-19 pandemic through HUD. To access the funds, the City developed a HOME-ARP Allocation Plan (Plan) that described the consultation and public participation process used to develop the Plan and outlined how the City would use the funds. The Plan was approved on May 8, 2023 and committed the funds to the operation of the HUB Resource Center (HRC) for supportive services to individuals experiencing homelessness.
To support the housing objectives identified in the Plan, the Plan proposed establishing a TBRA Program with its HOME funds. The City has implemented and completed the activities identified in its HOME-ARP Allocation Plan (Plan), except for the TBRA Program.
To ensure compliance with HOME-ARP requirements and the approved Plan, the City must demonstrate that it undertook reasonable and documented efforts to fulfill its obligations. HUD evaluates HOME-ARP performance based on adherence to the approved Allocation Plan, compliance with applicable regulations and Notice CPD-21-10 requirements, and timely commitment and expenditure of funds. As part of its program review, staff evaluated whether locally established eligibility criteria, though well-intentioned, may have created unintentional barriers to access beyond those required under HUD regulations.
This proactive review is intended to ensure that the TBRA Program is administered consistent with HOME-ARP statutory and regulatory requirements, supports timely expenditure of funds, and does not impose additional eligibility conditions unrelated to federal program requirements.
CDBG Program Committee Recommendations
On March 12, 2026, the Community Development Block Grant Program Committee (Committee) convened to review the TBRA guidelines and recommendations. After careful consideration, the Committee moved to recommend the removal of the CalAIM requirement, defining “elderly” as those 62+ of age, and removing the tenant “reward” incentive to reduce the City’s exposure to potential risks, including:
1. A HUD monitoring finding;
2. A determination of poor program performance or failure to meet HOME program objectives City of Orange Page 4 of 5 Printed on 4/23/2026
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Item #: 3.28. 4/28/2026 File #: 26-0013
and regulatory requirements; and
3. The risk of future funding loss or repayment obligations for not fulfilling the approved Plan’s commitments.
Additional Staff Recommendations
Following the Committee meeting, staff conducted additional research on TBRA program administration best practices and identified the two additional updates that would further strengthen program compliance and effectiveness. These include adjusting the income eligibility threshold to 60% of AMI and adding special consideration criteria for vulnerable households. Staff is bringing these items forward for Council consideration at this time in order to move forward with the program in a timely manner.
HUD evaluates HOME programs based on whether funds are used in a timely, effective, and compliant manner. Program restrictions that result in little or no activity increase the City’s exposure to potential compliance findings and funding risks. Because the City is not obligated to continue the TBRA program beyond the FY 2023-2024 allocation, removing these well-intentioned but restrictive criteria will allow the City to meet its remaining obligations related to HOME-ARP funding in accordance with federal requirements. These updates will also enable the City to administer the TBRA program in a manner consistent with HOME regulations while ensuring that limited housing resources are directed to households with the greatest need.
7. ATTACHMENTS
· Attachment A - Staff Report for FY2024 Annual Action Plan · Attachment B - Staff Report for TBRA Program Guidelines · Attachment C - Updated Draft Tenant Based Rental Assistance Program Policies and Procedures
City of Orange Page 5 of 5 Printed on 4/23/2026
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Agenda Item
Orange City Council
Item #: 3.28. 4/28/2026 File #: 26-0013
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director
1. SUBJECT
Updates to the eligibility and preference criteria for the Tenant Based Rental Assistance Program Policies and Procedures
2. SUMMARY
Consideration of proposed updates the eligibility and preference criteria for the Tenant Based Rental Assistance Program Policies and Procedures adopted as part of the HOME Americal Rescue Plan Allocation Plan.
3. RECOMMENDED ACTION
1. Approve the following recommended changes to the eligibility and preference criteria for the Tenant Based Rental Assistance Program Policies and Procedures:
a. Remove the requirement to have applied for and denied for CalAIM as a requirement; b. Specify definition of elderly persons to 62+;
c. Update income eligibility to 60% of Area Median Income; d. Remove the tenant incentive for returned deposits.
2. Approve adding special consideration to applicants who are:
a. Experiencing homelessness;
b. At risk of homelessness;
c. Fleeing domestic violence, dating violence, sexual assault, or stalking.
3. Direct staff to update the Tenant Based Rental Assistance Program Policies and Procedures with the recommended changes and submit to the Department of Housing and Urban Development for approval and implementation.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life
6. DISCUSSION AND BACKGROUND
On May 9, 2023, the City approved $150,000 for a Tenant Based Rental Assistance (TBRA) Program for security and utility deposit assistance as part of its 2023-2024 Annual Action Plan (Attachment A) using HOME Investment Partnerships Program (HOME) entitlement funds. A TBRA Program provides rental subsidy to assist individual households to address housing instability and insecurity by helping City of Orange Page 1 of 5 Printed on 4/23/2026
powered by Legistar™836
Item #: 3.28. 4/28/2026 File #: 26-0013
rental subsidy to assist individual households to address housing instability and insecurity by helping families afford housing costs such as rent or security deposits. The Annual Action Plan is required by HUD and outlines the City’s intent for the use of funds in a given entitlement year. Detailed information about the program background is provided in Attachment B.
As part of the approval, the following requirements were established to determine eligibility for an applicant:
1. Current City of Orange resident staying in the City of Orange;
2. Referred by a supportive services agency/organization;
3. Have applied for and be ineligible or denied for CalAIM assistance;
4. Have income below 80% of the area median income.
In addition, the following preferences were established:
1. Families with children under 12;
2. Veterans with a valid DD-214 (honorable discharge); and
3. Elderly persons as defined by the Social Security Administration eligibility of full retirement qualification.
Since the launch of the TBRA Program in January 2025, the City has not received any applications from households that qualify under the adopted eligibility criteria, resulting in no utilization of the allocated HOME funds. After approximately one year of inactivity, staff conducted a programmatic review to determine whether the lack of utilization was attributable to a lack of community need or to structural barriers within the program design.
CalAIM Requirement
Following a review of the adopted program guidelines and consultation with the Orange County Continuum of Care and supportive service providers, staff determined that the requirement to first apply for and be denied CalAIM assistance created an unintended barrier to access that limited the program’s ability to respond to housing opportunities.
Staff reviewed applicable HOME regulations and identified the following considerations:
1. HOME regulations at 24 CFR Part 92 do not require or authorize conditioning TBRA eligibility on denial from another program.
2. HUD evaluates HOME programs based on timely commitment and expenditure of funds.
Prolonged inactivity increases the risk of timeliness concerns.
3. Additional eligibility criteria not tied to HOME statutory or regulatory requirements may be viewed during monitoring as creating unnecessary barriers to assistance.
4. Conditioning HOME TBRA eligibility on application to an unrelated health care benefit may undermine the independent purpose and structure of the HOME program.
5. TBRA eligibility should be based on HOME income and housing need requirements, not on denial of assistance from external programs.
CalAIM provides limited housing-related assistance, including one-time security deposit and utility assistance, to eligible Medi-Cal members with documented health and social risk factors. It is a City of Orange Page 2 of 5 Printed on 4/23/2026
powered by Legistar™837
Item #: 3.28. 4/28/2026 File #: 26-0013
assistance, to eligible Medi-Cal members with documented health and social risk factors. It is a health care benefit administered through managed care plans and requires that an individual:
1. Be a Medi-Cal member;
2. Be enrolled in a participating managed care plan;
3. Be screened and determined eligible under Community Supports criteria; and
4. Provide documentation of qualifying medical and/or social risk factors.
Additionally, CalAIM assistance:
1. Is targeted to specific high-risk populations;
2. Is not available to all income-eligible renters; and
3. May be subject to plan funding limitations or provider capacity constraints.
While CalAIM provides valuable housing-related assistance, it is a health care benefit administered through managed care plans and requires enrollment, eligibility screening, and plan authorization.
These requirements may not align with the timeframe in which rental housing opportunities arise.
Tenant Incentive for Returned Deposits
In addition, staff determined that the well-intended provision allowing tenants who receive at least 80% of their security deposit back to retain 50% of the refunded amount as an incentive for proper unit maintenance may place the City at risk of a HUD monitoring finding and potential repayment obligation. Under HOME regulations, any TBRA funds returned to the City, including refunded security deposits, must be treated as program income and used for eligible HOME activities, such as additional TBRA assistance or other qualifying housing costs (e.g., gap financing for affordable housing developments). Once a tenant vacates the unit and the deposit is returned, those funds are no longer supporting an eligible housing cost. Disbursing a portion of the funds returned directly to the former tenant would constitute a cash incentive rather than an eligible HOME assisted housing expense, which is not permitted under HOME regulations.
Preference for Elderly Applicants
Social Security retirement eligibility varies by birth year, resulting in differing age thresholds for full retirement benefits. To ensure consistency and administrative clarity, staff recommends revising the elderly preference to apply to individuals 62 years of age or older, consistent with HUD’s general definition of an elderly person.
Income Eligibility
A review of TBRA programs administered by other HOME participating jurisdictions found that many programs limit eligibility to households earning 60% of Area Median Income (AMI) or below. Though federal regulations allow for up to 80% AMI for eligibility, a more restrictive income threshold ensures that the City’s limited HOME resources are directed to households most likely to experience barriers to securing housing, including those at risk of homelessness, families with children, seniors, and veterans. Households within this income range are more likely to face difficulty covering upfront move -in costs such as security deposits and utility deposits, particularly in the current rental market.
This adjustment also aligns the program with common HOME program practices nationwide, where TBRA and housing stability programs frequently target households earning 60% of AMI or below in order to prioritize lower-income households and maximize the housing stability impact of available City of Orange Page 3 of 5 Printed on 4/23/2026
powered by Legistar™838
Item #: 3.28. 4/28/2026 File #: 26-0013
federal funds.
Special Consideration Criteria
Staff recommends adding language to the program guidelines that provides special consideration for households experiencing homelessness, at risk of homelessness, or fleeing domestic violence, dating violence, sexual assault, or stalking. The special criteria clarifies the City’s intent to align the program with federal housing policy priorities and best practices for housing stability programs.
The revision also strengthens the City’s compliance with federal protections, including the Violence Against Women Act (VAWA), which ensures that survivors of domestic violence, dating violence, sexual assault, and stalking are not denied housing assistance due to their circumstances.
Providing special consideration for these households helps ensure that limited HOME funds are used strategically to assist individuals and families facing the highest risk of housing instability. The change also supports coordination with local service providers and regional homelessness response systems, improving access to housing opportunities for vulnerable residents.
HOME-ARP Compliance Requirements
On September 20, 2021, the City was allocated $1,655,186 in HOME Investment Partnerships HOME American Rescue Plan (HOME-ARP) funds in response to the COVID-19 pandemic through HUD. To access the funds, the City developed a HOME-ARP Allocation Plan (Plan) that described the consultation and public participation process used to develop the Plan and outlined how the City would use the funds. The Plan was approved on May 8, 2023 and committed the funds to the operation of the HUB Resource Center (HRC) for supportive services to individuals experiencing homelessness.
To support the housing objectives identified in the Plan, the Plan proposed establishing a TBRA Program with its HOME funds. The City has implemented and completed the activities identified in its HOME-ARP Allocation Plan (Plan), except for the TBRA Program.
To ensure compliance with HOME-ARP requirements and the approved Plan, the City must demonstrate that it undertook reasonable and documented efforts to fulfill its obligations. HUD evaluates HOME-ARP performance based on adherence to the approved Allocation Plan, compliance with applicable regulations and Notice CPD-21-10 requirements, and timely commitment and expenditure of funds. As part of its program review, staff evaluated whether locally established eligibility criteria, though well-intentioned, may have created unintentional barriers to access beyond those required under HUD regulations.
This proactive review is intended to ensure that the TBRA Program is administered consistent with HOME-ARP statutory and regulatory requirements, supports timely expenditure of funds, and does not impose additional eligibility conditions unrelated to federal program requirements.
CDBG Program Committee Recommendations
On March 12, 2026, the Community Development Block Grant Program Committee (Committee) convened to review the TBRA guidelines and recommendations. After careful consideration, the Committee moved to recommend the removal of the CalAIM requirement, defining “elderly” as those 62+ of age, and removing the tenant “reward” incentive to reduce the City’s exposure to potential risks, including:
1. A HUD monitoring finding;
2. A determination of poor program performance or failure to meet HOME program objectives City of Orange Page 4 of 5 Printed on 4/23/2026
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Item #: 3.28. 4/28/2026 File #: 26-0013
and regulatory requirements; and
3. The risk of future funding loss or repayment obligations for not fulfilling the approved Plan’s commitments.
Additional Staff Recommendations
Following the Committee meeting, staff conducted additional research on TBRA program administration best practices and identified the two additional updates that would further strengthen program compliance and effectiveness. These include adjusting the income eligibility threshold to 60% of AMI and adding special consideration criteria for vulnerable households. Staff is bringing these items forward for Council consideration at this time in order to move forward with the program in a timely manner.
HUD evaluates HOME programs based on whether funds are used in a timely, effective, and compliant manner. Program restrictions that result in little or no activity increase the City’s exposure to potential compliance findings and funding risks. Because the City is not obligated to continue the TBRA program beyond the FY 2023-2024 allocation, removing these well-intentioned but restrictive criteria will allow the City to meet its remaining obligations related to HOME-ARP funding in accordance with federal requirements. These updates will also enable the City to administer the TBRA program in a manner consistent with HOME regulations while ensuring that limited housing resources are directed to households with the greatest need.
7. ATTACHMENTS
· Attachment A - Staff Report for FY2024 Annual Action Plan · Attachment B - Staff Report for TBRA Program Guidelines · Attachment C - Updated Draft Tenant Based Rental Assistance Program Policies and Procedures
City of Orange Page 5 of 5 Printed on 4/23/2026
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Agenda Item
City Council
Item #: 9.1. 5/9/2023 File #: 23-0262
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 the FY2023-2024 Annual Action Plan for use of Community Development Block Grant and HOME Investment Partnerships Funding.
2. SUMMARY
Request to approve the funding for proposed public projects, non-profit agency programs and administration under the Community Development Block Grant and HOME Investment Partnerships Program.
3. RECOMMENDED ACTION
1. Approve the draft Fiscal Year 2023-2024 Annual Action Plan and authorize the City Manager or his designee to execute the Fiscal Year 2023-2024 Memorandum of Understanding with City departments, subrecipient agreements with non-profit agencies, and all related U.S. Department of Housing and Urban Development documents.
2. Authorize staff to incorporate comments received at the Public Hearing or make changes if needed into the Annual Action Plan before submitting to the Department of Housing and Urban Development.
4. FISCAL IMPACT
All public projects, programs, and administration will be fully funded by the Community Development Block Grant Fund (310) and HOME Investment Partnerships Program (317).
5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community e: Develop and strengthen collaborative partnerships to enhance and promote quality of life programs, projects, and services.
6. DISCUSSION AND BACKGROUND
The City receives annual federal funds from the U.S. Department of Housing and Urban Development (HUD) under the Community Development Block Grant (CDBG) and the HOME Investment Partnerships (HOME) programs for the benefit of primarily low- and moderate-income residents. The funds are allocated to projects and programs that include street improvements, handicap accessibility improvements, after-school programs, supportive services, and to increase the supply of affordable housing.
City of Orange Page 1 of 3 Printed on 5/4/2023
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Item #: 9.1. 5/9/2023 File #: 23-0262
Citizen Participation Plan Process
The City advertised the availability of CDBG funds on March 30, 2023, in the Anaheim Bulletin. Two Public Hearings and one Public Meeting were held to solicit input from nonprofit organizations and encourage residents to participate in the Fiscal Year (FY) 2023-2024 Annual Action Plan process.
The Action Plan is required annually by HUD and outlines the City’s plan for the use of funds in order to receive the funds.
The first Public Hearing was held on February 21, 2023, with the CDBG Committee (Committee) to hear eligible applicant presentations. The subject City Council Public Hearing is the second Public Hearing required for Council consideration and adoption of the funding recommendations made by the Committee. A Public Meeting was held on March 16, 2023, with the Committee during which it deliberated and reached consensus on the proposed funding recommendations presented to City Council with this report.
CDBG
The allocation for CDBG will be $1,034,444. The category limits are based on not-to-exceed caps set by HUD as follows:
· 20% or $206,888.80 for administration
· 15% or $155,166.60 for public service activities
· 65% or $672,390.60 for public facilities projects
This year, the City received a total of 11 applications for a total request of:
· $330,000 for public service activities
· $1,371,981 for public facilities projects
Factors used to determine funding recommendations included:
· Project eligibility
· Program description
· Organizational capacity and experience
· Goals and outcomes
· Budget
· Past performance goals
· Audit review
· Funding local priorities
In order to increase available resources for public services, the Fair Housing Foundation is recommended to be paid out of the administrative category as it is a qualifying expense.
Additionally, a proposal for a public restroom at the El Modena Basin, outside of the application process, was proposed to the Committee for consideration under the Public Facilities category. The Committee voted to recommend the project to Council, along with the funding recommendations for the projects and programs in Attachment 2 of this report.
HOME
The allocation for HOME will be $432,231. The category limits are based on caps set by HUD as follows:
· 10% or $43,223.10 for administration
· 15% or $64,834.65 for CHDO - Community Housing Development Organization nonprofit organizations that are rooted in neighborhoods and support the idea of community-led City of Orange Page 2 of 3 Printed on 5/4/2023
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Item #: 9.1. 5/9/2023 File #: 23-0262
revitalization, which the HOME Program and other HUD programs promote. · 75% or $324,173.25 for developer projects
In FY24, the City will be looking to establish a Tenant Based Rental Assistance (TBRA) Program that will work with local service providers such as the Homeless Resource Center to assist individuals and families in need. The guidelines for the program are being developed and will be brought to Council at a later date for consideration. The recommendation is to identify $150,000 to begin the program in FY24.
Staff recommends the approval of the CDBG funding recommendations and authorization to include the recommendations in the FY2023-24 Annual Action Plan.
7. ATTACHMENTS
· Fiscal Year 2023-2024 Draft Annual Action Plan
· Fiscal Year 2023-2024 CDBG Funding Recommendation Summary City of Orange Page 3 of 3 Printed on 5/4/2023
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Agenda Item
City Council
Item #: 8.2. 11/14/2023 File #: 23-0739
TO: Honorable Mayor and Members of the City Council
THRU: Tom Kisela, City Manager
FROM: Russell Bunim, Community Development Director
1. SUBJECT
Consideration of a Tenant Based Rental Assistance Program for security and utilities deposit rental assistance to be funded out of the HOME Investment Partnerships Program.
2. SUMMARY
The U.S. Department of Housing and Urban Development (HUD) requires the City to prepare a fiveyear strategic plan, the Consolidated Plan, for Community Development Block Grant (CDBG) and HOME Investment Partnerships (HOME) funds that includes an Action Plan for use of the funds. The proposed Tenant Based Rental Assistance Program is identified in the City’s 2023-2024 Action Plan.
The CDBG Committee has recommended allocation of a portion of the City’s HOME funding to establish a program that assists qualifying households with security and utility deposit rental assistance.
3. RECOMMENDED ACTION
Direct staff to establish a program that includes:
1. Security deposit assistance to qualifying households.
2. Utility deposit assistance to qualifying households.
3. Participant referral from a supportive services organization serving residents of the City of Orange as part of the qualification criteria for applying for the Tenant Based Rental Assistance Program.
4. A preference criterion (in order of preference):
a. Current City of Orange resident with intention to continue to reside in the City of Orange;
b. Families with children under 12;
c. Veterans with honorable discharge; and
d. Elderly as defined by the Social Security Administration for full retirement qualification
5. Security and utility deposits be paid directly to the landlord or property manager and any remaining funds at the end of residency be returned to the City as Program Income.
6. The security and utility deposit assistance be defined as a grant, with any remaining funds at the end of tenancy returned by the landlord directly to the City as program income.
4. FISCAL IMPACT
The total expenditure for this program is $150,000 and will be funded through HOME (317) and is included as part of the approved 2023-2024 City budget and Community Development Block Grant City of Orange Page 1 of 3 Printed on 11/9/2023
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Item #: 8.2. 11/14/2023 File #: 23-0739
included as part of the approved 2023-2024 City budget and Community Development Block Grant 2023-2024 Annual Action Plan.
5. STRATEGIC PLAN GOALS
Goal 3: Enhance and promote quality of life in the community c: Support and enhance attractive, diverse living environments.
6. DISCUSSION AND BACKGROUND
On March 11, 2021, the American Rescue Plan (ARP) was passed in response to the COVID-19 pandemic. Congress appropriated $5 billion in ARP funds to be administered through the HOME Investment Partnerships Program (HOME) and authorized the Department of Housing and Urban Development (HUD) to distribute the funds to participating jurisdictions (PJ) that qualified for an allocation of HOME funds in Fiscal Year (FY) 2021, of which Orange was a recipient.
On September 20, 2021, the City was notified that it was allocated $1,655,186 in HOME-ARP funds.
In order to access the funds, the City developed a HOME-ARP Allocation Plan (Plan) that described the consultation and public participation process that the City engaged in developing the Plan and outlines how the City will use HOME-ARP funds. The Plan was approved by HUD on May 8, 2023.
To meet the housing requirement of the HOME-ARP grant and address some of the housing assistance needed within the City, the Plan proposed to establish a Tenant Based Rental Assistance (TBRA) Program with its annual HOME entitlement funds. A TBRA Program is a rental subsidy to assist individual households afford housing costs such as rent or security deposits.
On May 9, 2023, the City approved $150,000 for a TBRA Program as part of its 2023-2024 Annual Action Plan using HOME entitlement funds. The Annual Action Plan is required by HUD and outlines the City’s intent for the use of funds in a given entitlement year.
On September 21, 2023, the CDBG Committee convened to review different options for a TBRA Program based on the below budget breakdown:
· $15,000 for consultant support. As a new program, consultant support will be required to set up the program, develop agreements with applicants, and assist with compliance in the first year;
· $7,500 for City staff time. Staff time for administering the program and code enforcement time for inspecting rental units;
· $127,500 for rental assistance.
· The approximate cost breakdown for assistance is as follows:
o Security Deposit: $5,100 per household
o Utility Deposit: $255 per household
o Month to Month rental assistance: $25,000 - $30,000 (depending on income) The following comparisons were also taken into consideration:
Month to Month Rental Assistance Security Deposit Assistance Funding for approximately 5 households Funding for approximately 25 households Requires significantly more staff time to
monitor
More sustainable with current staffing as it
is a one-time allowance
Continuous until household no longer
qualifies - City required to continue
assistance
Identified by Fair Housing Foundation as a
priority need
City of Orange Page 2 of 3 Printed on 11/9/2023
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Item #: 8.2. 11/14/2023 File #: 23-0739 Month to Month Rental Assistance Security Deposit Assistance Funding for approximately 5 households Funding for approximately 25 households Requires significantly more staff time to
monitor
More sustainable with current staffing as it
is a one-time allowance
Continuous until household no longer
qualifies - City required to continue
assistance
Identified by Fair Housing Foundation as a
priority need
Not a loan - no return Can be returned to City as Program Income at end of residency
The CDBG Committee recommends that the City Council establish a TBRA Program for security and utility deposit assistance because it would assist a greater number of households and would not obligate the City to provide the assistance in perpetuity. Additionally, the Committee voted to recommend that a referral from the Hub Resource Center (HRC) be required to apply for funds and assistance be paid directly to the landlord or management company. Furthermore, the Committee moved to set preference for the following applicants:
1. Current City of Orange resident with intention of remaining in the City of Orange;
2. Families with children;
3. Veterans with honorable discharge; and
4. Elderly as defined by retirement or social security requirements.
To further define the criteria set forth in the preferences, staff recommends including “children under the age of 12” in the criteria for “families with children” and to define elderly as defined by the “Social Security Administration for full retirement age”
to avoid any confusion. Furthermore, staff recommends amending the requirement of a referral from the HRC to a referral from a supportive services organization serving the residents of the City of Orange (i.e. HRC, Housing Authority, Fair Housing, etc.) Additionally, staff is recommending that any funds to be reimbursed at the end of the tenant’s residency be returned directly to the City as Program Income to be used for future TBRA assistance or affordable housing development projects.
Upon approval, staff will return to the City Council at a later date to amend the 2020-2024 Consolidated Plan to add a TBRA program. The Consolidated Plan is required every five years by HUD and is designed to assist PJs assess their affordable housing and community development needs and market conditions. Moreover, the Consolidated Plan sets the priority goals for the yearly HUD entitlement funds received by the City.
7. ATTACHMENTS
· None.
City of Orange Page 3 of 3 Printed on 11/9/2023
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Approved City Council:
Approved HUD:
Tenant Based Rental Assistance
(TBRA) Program
Policies and Procedures
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1 Index by Section
1. Background
2. Definitions
3. Eligibility and Preferences
4. Income Limits
5. Eligible Units
6. Ineligible Units
7. Prohibition Against Duplicative Rental Assistance
8. Ineligible Uses of TBRA Assistance
9. Support Services
10.Determining Income and Allowances
11.Household Identification
12.Residency Requirement
13.Security Deposits - Special Provisions
14.Pet Deposits
15.Service Animals
16.Utility Deposits
17.Utilities
18.Non-Refundable Fees
19.Inventory Checklists and Major Tenant Responsibilities Regarding Security Deposits
20.Re-certification
21.Occupancy Standards
22.Tenant Selection
23.Local Preferences
24.Conflict of Interest
25.Key Processing Steps for Initial Program Start Up
26.Eligibility and Income Calculations
27.Approving Rental Unit and Lease
28.Rent Reasonableness
29.Execution of Lease, and Lease Addendum
30.Annual Lease and Reexamination Activities
31.On-Going Program Responsibilities
32.Lease Enforcement and Termination of Tenancy
33.Due Process
34.Portability and Moving
35.Program Monitoring and Evaluation
36.Live-In Aide Requirements
37.Lead-Based Paint
848
2 These guidelines establish the policies and procedures governing the City of Orange HOME Tenant Based Rental Assistance (TBRA) Security Deposit Assistance Program.
The program is designed to help income-eligible households secure safe, decent, and sanitary housing in the private rental market by providing one-time assistance with security deposits and utility deposits.
1. Background
The City of Orange receives its funding for the Tenant Based Rental Assistance (TBRA) Program from the United States Department of Housing and Urban Development (HUD) under the HOME Investment Partnerships program (HOME). The City is authorized by federal regulations to develop and operate HOME eligible housing programs for lowincome households and families. The City must ensure compliance with federal laws, regulations, and notices, and must establish policies and procedures to ensure consistency in program operation and compliance with established regulations. a. Purpose and Use
The attached program guidelines have been developed to facilitate the efficient and effective operation of the HOME TBRA Security deposit program for the City of Orange.
The TBRA program will be administered by a contract entity, currently Neighborly Software. Funding for this program is provided under Title II of the National Affordable Housing Act (1990) through the HOME Investment Partnerships Program (HOME). The City sets-aside a portion of its HOME allocation to provide assistance to persons at-risk of, or currently experiencing homelessness, with the following preferences:
● Current resident of the City of Orange with the intention to remain in the City of Orange.
● Families with children under 12.
● Veterans with a valid DD-214 (honorable discharge); and ● Elderly persons 62+ years of age
b. Primary Objective
The primary objective of the TBRA program is to assist eligible applicants to secure safe, decent, and sanitary housing in the private rental market in the City of Orange. This program assists residents in need with the ability to access housing using security deposit assistance for rental housing. This will give households the ability to remain in the City of Orange while, at the same time, accessing more affordable move-in costs. c. Equal Opportunity
The City of Orange’s HOME TBRA Security Deposit program is a federally funded program through federal HOME Investment Partnership Funds. This is an equal opportunity program. The City does not discriminate based on race, color, ethnicity, or national origin, sex, religion, age, marital or familial status, sexual orientation, or disability in the provision of its services.
The program will comply with all applicable federal civil rights and fair housing laws, including the protections provided under the Violence Against Women Act (VAWA). 849
3 2. Definitions
a. AMI: Annual Median Income is a group of charts that are prepared annually for all the Counties and metropolitan areas in the US. The charts document income levels for various federal programs. The charts are broken down into extremely low, very low income, low income, 80% of median, and median income. b. Case Manager: A case manager coordinates various services on behalf of an individual or family that needs assistance.
c. CFR: The Code of Federal Regulations (CFR) is the codification of the general and permanent rules and regulations (sometimes called administrative law) published in the Federal Register by the executive departments and agencies of the federal government of the United States.
d. Elderly Participant: Those persons 62+ years of age. e. Disabled Participant: Those persons as defined by 24 CFR 5.403, including individuals with a physical or mental impairment expected to be long term or that substantially limits one or more major life activities. f. Family Obligations: Formal document executed between the City and all adults living in the household. This contract spells out all the obligations that the City and the participant’s household will be responsible to maintain the HOME TBRA security deposit.
g. FMR: Fair Market Rent is a payment standard that is set for each county/metropolitan area in the nation that establishes a fair market rent for all rental units by bedroom size and unit type. The rent standard is calculated for the base rent and the average cost of utilities for modest rental housing units. h. HAP: Housing Assistance Payment is a contract between a tenant that is on a rental assistance program and the landlord that is providing a rental unit. The HAP contract spells out the terms of the agreement for the landlord to receive a monthly subsidy.
i. HCV: The Housing Choice Voucher Program is a federally funded rental assistance program that provides "tenant-based" rental assistance so a tenant can move from one unit of qualified housing to another. The tenant pays at least 30% of their adjusted gross household income toward the rent and the voucher pays the balance of the rent up to HUD’s Fair Market Rent established for the area.
j. HOME: The HOME Investment Partnerships Program (HOME) is a type of United States Federal assistance provided by the U.S. Department of Housing and Urban Development (HUD) to Participating Jurisdictions in order to provide decent and affordable housing, particularly housing for extremely-low and very low-income Americans. It is the largest federal block grant to states and local 850
4 governments designed exclusively to create affordable housing for low-income families.
k. HQS/NSPIRE: Housing Quality Standards inspection was developed by HUD to set a national minimum housing standard for many of the housing programs funded by the agency. Beginning October 1, 2024, Housing Quality Standards will be replaced by NSPIRE standards.
l. Rent Limits: The official listing of maximum unit rents by bedroom size and type of building. The Payment Standard is broken down by city or geographic area. m. SNAPS: The Supplemental Nutrition Assistance Program (SNAP), formerly known as the Food Stamp program, provides financial assistance for purchasing food to low-income and no income people living in the U.S. It is a federal aid program, administered by the U.S. Department of Agriculture, though benefits are distributed by individual U.S. states.
n. SRO: Single Room Occupancy. A single room occupancy (more commonly SRO, sometimes called single resident occupancy) is a multiple tenant building that houses one or two people in individual rooms (sometimes two rooms, or two rooms with a bathroom or half bathroom), or to the single room dwelling itself. SRO tenants typically share bathrooms and/or kitchens, while some SRO rooms may include kitchenettes, bathrooms, or half-baths. Although many are former hotels, SROs are primarily rented as permanent residences. o. TANF: Temporary Assistance for Needy Families (TANF) is one of the United States of America's federal assistance programs. It began on July 1, 1997, and succeeded the Aid to Families with Dependent Children (AFDC) program, providing cash assistance to indigent American families with dependent children through the United States Department of Health and Human Services. This cash benefit is often referred to simply as "welfare."
p. TBRA Security Deposit Grant: The security deposit assistance will be made in the form of a grant. The terms and conditions of the grant will be set out in the TBRA Security Deposit Grant Agreement.
3. Eligibility and Preferences
HOME-eligible households referred by Continuum of Care providers for TBRA Security Deposit assistance are preferred but not required. Eligibility will be determined according to program requirements and local preference criteria outlined in Section 12.
In addition, the City has the current four (4) preferences. Preferences may be single or additive:
● Current residents of the City of Orange with the intention to continue residing in the City of Orange.
● Families with children under 12.
● Veterans with a valid DD-214 (honorable discharge); and ● Elderly persons 62+ of age
851
5 4. Income Limits
HOME TBRA is limited to households who are income eligible, which is here defined as being below 60% of median income by household size. Each year, 100% of the City’s HOME TBRA funds will be used to assist households whose incomes do not exceed 60 percent of Area Median Income (AMI), as established annually by HUD. The area median income is adjusted for household size as defined by the federal HOME Income Limits, established every year by HUD.
Eligibility will be verified prior to entering an agreement to receive TBRA funds. If a tenant or tenant family with verified income is on a TBRA waitlist for more than three months, income eligibility will be re-verified by program staff prior to receiving assistance in order to ensure that they still meet income eligibility for the program.
5. Eligible Units
Tenants who receive assistance from the City of Orange’s HOME TBRA can choose from any housing unit if that rental unit:
1. Meets HUD Housing Quality Standards (HQS), or a subsequent standard such as NSPIRE.
2. Has a rent that is reasonable when compared to similar unassisted units in the area (“rent reasonableness”).
3. Complies with all applicable lead-based paint requirements for units built before 1978, including visual assessments, paint stabilization, and remediation when required.
4. Households may select units developed or rehabilitated with HOME assistance.
However, the City may not, and will not, require TBRA assisted households to select a HOME unit as a condition of receiving TBRA.
6. Ineligible Units
1. TBRA may not be used to assist a resident owner of a cooperative or mutual housing unit when that resident is recognized by state law as a homeowner. a. However, under the provisions of some cooperative or mutual housing agreements, the units are considered rental housing under state law.
The residents of this rental housing may receive TBRA.
b. Under any circumstance, a tenant who rents from an owner of a cooperative or mutual housing unit may receive HOME TBRA.
2. HOME TBRA may not be used to prevent the displacement of tenants from projects assisted with Rental Rehabilitation Program funds.
3. PJs may not provide HOME TBRA to homeless persons for overnight or temporary shelter.
4. HOME TBRA may not duplicate existing rental assistance programs that 852
6 already reduce the tenant’s rent payment to 30 percent of income. For example, if the household is already receiving assistance under the Section 8 Program, the household may not also receive assistance under a HOME TBRA program. a. However, the household may still receive HOME TBRA Security Deposit assistance only if there is no other (Section 8/Housing Voucher) assistance program available.
5. The intent of TBRA funds is meant to temporarily assist families and individuals to obtain self-sufficiency and not to make mortgage payments. Therefore, rentto-own leases, in which monthly rental assistance payments are used as mortgage payment, are not permissible. Landlords cannot be related to the participant or any other member of the household. This includes parents, grandparents, aunts, uncles, or blood relatives. Exceptions to this rule may be granted on a case-by-case basis where the tenant has very special housing needs and the only way to accommodate these needs is through a family member or relative providing the rental unit. This process must be fully disclosed to the City and its Contractor, Neighborly, for review and approval.
The applicant and their Case Manager must present the request, in writing, explaining the situation.
7. Prohibition Against Duplicate Assistance
Participating households cannot receive TBRA, including security deposit assistance, if they are receiving assistance under another federal, state, or local program IF the HOME subsidy would result in duplicate subsidies.
8. Ineligible Uses of TBRA Assistance
TBRA assistance cannot be used in the following instances:
1. TBRA assistance cannot make commitments to specific owners for specific units/projects. Tenants must be free to use assistance in any eligible unit.
2. TBRA assistance cannot assist resident owners of cooperative housing that qualifies as home ownership housing. TBRA may, however, be used by a tenant who is renting from a cooperative unit owner.
3. TBRA assistance cannot pay cost overruns, such as late fees.
4. TBRA assistance cannot prevent displacement of or provide relocation assistance to tenants as a result of activities other than the HOME Program.
5. TBRA assistance cannot provide TBRA to homeless persons for overnight or temporary shelter. The HOME TBRA security deposit assistance must enable the homeless person to rent a transitional or permanent housing unit that meets Housing Quality Standards (HQS) or subsequent standard, such as NSPIRE.
9. Support Services
The City of Orange does not require participation in supportive services as a condition of receiving TBRA security deposit assistance. However, the City encourages households to connect with local service providers that may assist with housing stability, employment, health services, or other supportive resources.
853
7 Applicants may apply for TBRA assistance directly through the City or its Contractor, or they may be referred by an approved social service provider, including City or County service agencies, nonprofit service providers, or healthcare-based programs such as CalAIM.
Referrals from service providers are encouraged but not required for program eligibility.
10. Determining Income and Allowances
The City of Orange, and Neighborly, will use the HUD Technical Guide for Determining Income and Allowances for the HOME Program and HUD 24 CFR Part 5, Subpart F for determining annual household income for all program participants.
11. Household Identifications
Every household member is required to provide two pieces of identification (both adults and children). Acceptable forms of identification include birth certificates, social security cards, state issued IDs, and driver’s licenses. Copies of these identifications will be kept in the tenant’s file. Photo IDs are required for all adult members of the household. For those experiencing homelessness, alternative documentation may be accepted where standard identification is unavailable.
12. Residency Requirement
Preference may be given to applicants who are current residents of the City of Orange and intend to remain within the City.
The City recognizes that individuals and families experiencing housing instability may need to relocate in order to secure safe and stable housing. Therefore, applicants who are not currently residing in the City of Orange may still be eligible for assistance if they are seeking to secure housing within the City. The City will administer this preference in a manner consistent with all applicable federal and state fair housing laws, including protections for survivors under the Violence Against Women Act (VAWA).
Special consideration may be provided to applicants who are:
Experiencing homelessness
At risk of homelessness
Fleeing domestic violence, dating violence, sexual assault, or stalking Referred through a Continuum of Care or other service provider assisting vulnerable households
All applicants receiving assistance must ultimately secure an eligible rental unit located within the City of Orange.
854
8 13. Security Deposits - Special Provisions
HOME TBRA funds may be used to provide security deposit assistance for eligible participants to enable access to safe, decent, and sanitary housing in the private rental market. The maximum security deposit assistance provided under this program shall not exceed one month’s contract rent or the maximum security deposit allowed under California law, whichever is lower.
Security deposits will be paid directly by the City, or its Contractor, to the landlord or property manager on behalf of the participant.
Security deposit assistance is provided with the understanding that the funds remain HOME program funds. Any portion of the security deposit refunded by the landlord at the termination of the tenancy must be returned to the City of Orange. Returned funds will be recorded as HOME program income and must be used for other eligible HOME activities in accordance with 24 CFR 92.503.
Participants must agree, as a condition of assistance, that any security deposit refund issued by the landlord will be made payable to the City or its Contractor.
14. Pet Deposits
HOME TBRA funds, including security deposit assistance, cannot be used to pay pet deposits. The tenant will have to use their own funds to pay a pet deposit.
15. Service Animals
A service animal is not considered a pet. Any applicant that has a service animal or expects to acquire one during the time they will be assisted by the HOME TBRA security deposit assistance program will have to provide certification from a medical doctor or a psychologist that the animal is acting in the capacity of a service animal. In most cases, a landlord cannot charge a pet deposit for a service animal. The tenant is responsible for any damage done to the rental unit by the service animal.
16. Utility Deposits
HOME TBRA funds may also be used to provide assistance for required utility deposits necessary to establish utility service for an approved rental unit. Utility deposit assistance may be provided in conjunction with security deposit assistance Eligible utility services may include:
Electricity
Natural gas
Water
Sewer
Trash collection
855
9 Utility deposit assistance is limited to a maximum grant of $500 per household and is available only one time per participating household.
Utility deposits will be paid directly to the utility provider on behalf of the participant upon submission of documentation verifying the required deposit amount and confirmation that the utility account will be established for the rental unit.
Because these funds are HOME program funds, any refund of the utility deposit issued after service termination must be returned to the City of Orange. These returned funds will be treated as HOME program income and used for eligible HOME activities in accordance with 24 CFR 92.503. Participants receiving assistance must acknowledge this requirement and agree to cooperate with the City and its Contractor to ensure that any refunded utility deposits are returned to the City.
17. Utilities
If the participant is leasing a rental unit where they will be responsible for paying for the utility service, they must bring the City, or its Contractor, written verification that the participant can connect the service in their name prior to moving into the rental unit. It is important that the head of household, co-head of household, or another adult living in the household will have utility service connected in their name. The City, or its Contractor, will not permit utility service to be connected in a minor child’s name or any other person that is not a member of the household. If these provisions cannot be met, then the City, or its Contractor, will require that the participant secure a rental unit that has all utilities paid by the landlord.
18. Non-Refundable Fees
Nonrefundable fees cannot be paid from TBRA program funds. There may be charges in addition to the security deposit at the time tenancy begins. These charges may be reasonable and nonrefundable. A cleaning fee, for example, does not negate the obligation of the tenant to maintain the unit in a normal sanitary manner. These nonrefundable fees or charges are separate items from the security deposit and, as such, are not covered by the security and utility deposit provisions above.
19. Inventory Checklists and Major Tenant Responsibilities Regarding Security Deposits
In order to protect the deposit and assure its return upon moving out (whether or not program funds are used), the City, or its Contractor, will assist the household to understand their responsibilities as summarized below:
1. Complete an Inventory Checklist at the start of occupancy (within seven days of move in).
2. Give the owner a forwarding address within four days after moving out. If the tenant does not do this, the right to an itemized list of damages from the owner is forfeited.
However, this requirement only applies if the owner has informed the tenant of this requirement in writing within 14 days after the tenant has moved in.
3. Respond in writing if the participant disputes the charges against the security deposit within 7 days of receipt of notice. It is a good practice to retain some type 856
10 of proof of mailing.
20. Re-certification
Recertification does not apply to HOME TBRA security deposit assistance programs only.
21. Occupancy Standards
The City, or its Contractor, occupancy standards are based on the following table:
Rental Assisted Unit
Bedroom Size
Number of Persons
Minimum Maximum
1 1 2
2 2 4
3 3 6
4 5 8
In addition, household composition is considered, and unit size is also based on the following:
Unit
Size
Family Composition
1 1 adult or 2 adults (couple)
2 2 adults of the same or opposite sex living together in a non-conjugal relationship
2 1 adult and 1 child
2 2 adults (couple) and 1 child of any age
2 1 adult and 2 same-sex children
2 1 adult or a couple and 2 opposite sex children, both under 6 years of age 15 3 1 adult or a couple and 2 opposite sex children when one child is at least 6 years of age
3 1 adult and 3 same sex children or opposite sex children all under 6 years of age
3 2 adults (couple) and 3 children
857
11 3 1 adult or a couple and 4 children (either all the same sex or any combination) where 2 children of the opposite sex will not share a bedroom unless both are under the age of 6
4 1 adult or a couple and 4 children, 3 of the same sex and 1 of the opposite sex, when all children are at least 6 years of age 4 1 adult or a couple and 5 to 7 children, providing children do not have to share a bedroom with the parent(s) or with a child of the opposite sex when either is over the age of 6 years
22. Tenant Selection
The City of Orange will maintain a waitlist for the HOME TBRA program. The City will partner with its continuum of care partners to ensure that eligible households experiencing homelessness or at risk of homelessness are identified, screened for eligibility, and assisted in being placed on the waitlist. All tenant selection activities will comply with applicable HOME regulations and fair housing requirements. Questions related to the Tenant Selection and Outreach Strategy should be directed to the Housing Manager.
To qualify for assistance an applicant must meet the following general requirements:
1. Household income must fall at or below 60% of AMI. Applicants must secure an eligible rental unit located within the City of Orange.
2. The applicant and all adult members of the applicant’s household must sign and agree to the program’s terms and conditions.
3. All household members must provide two (2) forms of valid identification.
4. No member of the household shall be or is subject to a lifetime registration requirement under a State sex offender registration program.
5. No member of the household has been evicted from federally assisted housing for drug-related criminal activity within the last three years (unless they have completed a supervised drug rehabilitation program).
6. Anyone the PHA has reasonable cause to believe is currently engaging in illegal drug use.
7. No member of the household has been convicted of the manufacturing or the sales of methamphetamine on federal property.
8. Applicants on a waitlist are required to update their contact information while their name is on the waitlist.
When the number of eligible applicants exceeds available funding, the City or its Contractor will maintain a waiting list. Applications will be placed on the waiting list in the order they are received and determined eligible.
Applicants selected from the waiting list will be prioritized according to the local 858
12 preferences described below. If multiple applicants share the same preference category, selection will be made based on the date and time the completed application was received.
23. Local Preferences
The Housing Manager may give an applicant preference once their name is on the waitlist due to severe emergency situations where the applicant or member of the applicant’s household has a medical or emergency situation that warrants them being moved to the top of the waitlist.
Applicants on the waitlist will be prioritized based on the following local preferences:
1. Current residents of the City of Orange who intend to remain in the City.
2. Applicants experiencing homelessness or at risk of homelessness.
3. Applicants fleeing domestic violence, dating violence, sexual assault, or stalking.
4. Applicants referred through a Continuum of Care or other approved service provider.
Within each category, applicants will be placed on the waitlist based on the date and time their completed application was received.
24. Conflict of Interest
The City of Orange will comply with the conflict of interest provisions of the HOME Investment Partnerships Program regulations at 24 CFR 92.356. No employee, officer, elected official, or agent of the City or its Contractor who exercises or has exercised any functions or responsibilities with respect to HOME activities, or who is in a position to participate in a decision-making process or gain inside information regarding these activities, may obtain a financial interest or benefit from the program. Any potential conflict must be disclosed and may require a written exception from HUD.
25. Key Processing Steps for Initial Program Start Up
Step 1: Marketing and Outreach Activities
a. Public Announcement of Program.
b. Outreach to Referring Agencies and to Eligible Households. c. Outreach to Prospective Owners.
Step 2: Accept Applications
a. All applications must be in writing on a form prescribed by the City or its Contractor. The application includes information that enables the City or its Contractor to determine household income and eligibility. b. Each application received must be reviewed for completeness and to determine if the applicant is eligible. Neighborly, the City’s contractor, may elect to fully determine eligibility at the time the household makes application, or make the determination when the household is drawn from the waitlist.
c. If an applicant is determined to be ineligible, they will be notified in writing.
The written notice will identify the reason(s) the household is ineligible and state that the applicant has 10 days from the date of the notice to request an informal review of the decision.
859
13 d. A tenant file will be created for each application. This file will ultimately contain the application, documentation of the household’s eligibility, copies of program forms, unit information, correspondence, etc.
Step 3: Determine Eligibility
Applicants are selected from the waiting list in the order established by the City’s contractor, based on its adopted preferences. To determine a household’s eligibility, the Grantee must verify:
a. The household’s eligibility status. Eligibility is not always verified at the time of application, but it must be verified before the household receives assistance.
b. The household’s size and composition. This enables the Contractor to determine the unit size for which the household qualifies. c. Household income and adjustments to income. This enables the Contractor to determine if the household is income eligible. Verification of the information provided by the household can be accomplished through a variety of sources and documents.
Step 4: Issue Approval for Deposit Assistance
The issuance of approval authorizes the amount and timing of deposit assistance.
The issuance involves working directly with the applicant on finalizing the required documents, getting signatures, and having a counseling session to brief the household on the rights, amounts, and responsibilities and obligations of assistance. The briefing will cover:
a. Roles and responsibilities of the applicant, household members, owner, and the City’s Contractor.
b. Security deposit policy, including how much may be charged, who pays, and who receives any refund.
c. Issuance Period and Extension Policies, and what happens in the event the lease is not executed and/or the family fails to take possession of the unit, including events such as failure to provide required appliances and to have utilities turned on in the tenant (participant’s) name. d. Role of HQS/NSPIRE standards in unit approval and procedures for submitting the rental unit information form.
e. Households should be counseled against signing any lease or moving into a unit until the unit has been approved by the City’s contractor. f. Lead-Based Paint information.
g. Prohibited Lease Provisions/Lease Addendum
h. Fair housing information, including any search assistance that may be available, and the process for filing a complaint in the case of discrimination.
Step 5: Unit/Lease Approval
Once the household has located a unit and the owner has agreed to participate, the household and the owner jointly submit the Request for Unit Approval/Rental Unit Information form. The submission of this document triggers the inspection, deposit negotiations and review of the owner’s lease.
a. Housing Quality Standards: Each unit must be inspected to confirm that it 860
14 meets HQS or NSPIRE if after October 1, 2024. If the unit initially fails HQS, the owner may be given a reasonable amount of time to correct deficiencies, or the participant may elect to look for another unit.
b. Rent Determination: The rent for each must be determined to be reasonable when compared to comparable, unassisted units. See above for key components of Rent Reasonable determination.
c. Lease Review: The City, or its Contractor, must review the owner’s lease to assure that it does not include any of the prohibited lease provisions. The Lease Addendum provided by the City is required for all HOME TBRAassisted units, including security deposit assistance. d. Final Subsidy Calculation: Once the unit has been approved, a final subsidy calculation is required to determine the amount and type of deposit assistance.
Step 6: Contract/Lease Execution
The Lease Agreement and Lease Addendum are executed by and between the tenant and owner only. At this time, The City’s Contractor can provide the security deposit on behalf of the participant and any necessary final corrections can be made to the security documents (“loan”) executed by the participant and the City/Contractor.
26. Eligibility and Income Calculations
As previously stated, the City’s Contractor, Neighborly, will determine annual household income in accordance with HOME regulations at 24 CFR 92.203, which require the use of income definitions set forth in 24 CFR Part 5 (Section 8 definition of annual income).
Neighborly will also follow guidance provided in HUD’s Technical Guide for Determining Income and Allowances under the HOME Program. Income will be verified in the following ways:
1. Third Party Verifications: Request for written income verification from the tenant's employer or other income source; must be pre-approved by the applicant.
2. Review of Documents: Documents include but are not limited to benefit award letters, pay stubs, bank statements, and income tax returns.
3. Self-Certification: This is the least preferred method but may be used if no other sources are available.
27. Approving Rental Unit and Lease
Once the participant has located a unit and the owner has agreed to participate, the household and the landlord jointly submit the Request for Unit Approval. The processing staff are available to discuss the program with prospective landlords to answer questions and review the rental documents and procedures for the provision of security deposit assistance. Units identified by the program participant must be acceptable under the TBRA HOME guidelines. The following guidelines apply:
1. Rent Reasonableness
The subsidized rent and unsubsidized rents charged for comparable units are similar. Neighborly will use the Rent Reasonable checklist provided by HUD. Rental 861
15 units that are found to be out of compliance with the HUD Rent Reasonableness standards will be rejected, and the applicant will be asked to identify another suitable rental unit. The City or its Contractor will maintain documentation supporting rent reasonableness determinations in the participant file, including information on at least three comparable unassisted rental units and the factors used in determining comparability, such as location, unit size, condition, amenities, and utilities.
2. Housing Conditions
HQS/NSPIRE will be applied to all units assisted with HOME TBRA funds.
Enforcement of local codes may be applied in addition to HQS standards.
Contractor staff will schedule initial inspections, including a lead visual assessment, with landlords upon receiving and approving a completed and signed Request for Unit Approval from the participant and landlord. The Contractor will schedule the inspection with the landlord. Landlords will be notified in writing of the inspection violations. If the landlord is not willing to correct the violations cited and to make the unit ready for move-in in a reasonable amount of time, the participant will be given a new Landlord packet and be asked to look for another rental unit. The HOME Program regulation requires that all units assisted with HOME funds meet HQS/NSPIRE standards.
For HOME TBRA Security Deposit assistance only, annual HQS/NSPIRE inspection standards do not apply.
3. Size Requirement
The City’s program will use the Occupancy Standards in determining unit size for each household. Occupancy Standards are found in Section 20.
4. Lease Approval
The lease must comply with all the requirements in 24 CFR 92.253 (Tenant and Participants Protection).
Prohibited lease terms. The lease may not contain any of the following provisions:
(1) Agreement to be sued. Agreement by the tenant to be sued, to admit guilt, or to a judgment in favor of the owner in a lawsuit brought in connection with the lease; (2) Treatment of property. Agreement by the tenant that the owner may take, hold, or sell personal property of household members without notice to the tenant and a court decision on the rights of the parties. This prohibition, however, does not apply to an agreement by the tenant concerning disposition of personal property remaining in the housing unit after the tenant has moved out of the unit. The owner may dispose of this personal property in accordance with State law; (3) Excusing owner from responsibility. Agreement by the tenant not to hold the owner or the owner's agents legally responsible for any action or failure to act, whether intentional or negligent;
(4) Waiver of notice. Agreement of the tenant that the owner may institute a lawsuit without notice to the tenant;
862
16 (5) Waiver of legal proceedings. Agreement by the tenant that the owner may evict the tenant or household members without instituting a civil court proceeding in which the tenant has the opportunity to present a defense, or before a court decision on the rights of the parties;
(6) Waiver of a jury trial. Agreement by the tenant to waive any right to a trial by jury;
(7) Waiver of right to appeal court decision. Agreement by the tenant to waive the tenant's right to appeal, or to otherwise challenge in court, a court decision in connection with the lease;
(8) Tenant chargeable with cost of legal actions regardless of outcome. Agreement by the tenant to pay attorney's fees or other legal costs even if the tenant wins in a court proceeding by the owner against the tenant. The tenant, however, may be obligated to pay costs if the tenant loses; and
(9) Mandatory supportive services. Agreement by the tenant (other than a tenant in transitional housing) to accept supportive services that are offered.
Once a unit meets City code and HQS/NSPIRE, the landlord must provide a copy of the proposed lease to the City’s Contractor, who will review the lease to assure that it does not include any of the prohibited lease provisions as outlined in 24 CFR Part 92 and 92.253(b).
28. Rent Reasonableness
TBRA assisted units must rent for a reasonable amount, compared to rents charged for comparable, unassisted units. The City, through its Contractor, must document the basis for their rent reasonableness determinations. The prescribed form provides a rent analysis for three (3) comparable unassisted units. Key components of a comparability analysis include:
1. Location in Community: In many markets’ location is the key determinant of housing price (i.e., good/safe neighborhood, close to schools/bus routes, etc.).
2. Size: Only units of comparable size (both in terms of number of bedrooms and square footage) should be used.
3. Rent for Unit: Amount of rent being charged by owner.
4. Utilities Included: Consider the type and fuel source of utilities.
5. Condition: Only units in similar condition should be compared.
6. Amenities: Consider such amenities as garage, appliances, and lot size.
29. Execution of Lease, and Lease Addendum Once the unit has been verified to have passed and the lease has been reviewed and approved, the tenant and landlord can execute the lease and lease addendum, providing an original copy to the City’s Contractor (Neighborly). The HOME deposit assistance will not go into effect until the unit passes HQS and all above referenced documents are signed and returned, providing, of course, that deposit assistance can be processed concurrently with lease and lease addendum execution where that is possible.
863
17 30. Annual Lease and Reexamination Activities These do not apply to the HOME TBRA Security Deposit only program. However, all Violence Against Women Act (VAWA) protections, including the VAWA lease addendum, continue to apply to all assisted households.
31. On-Going Program Responsibilities On-going Contractor program responsibilities include:
1. Perform program duties, such as processing applications, maintaining files, processing deposit returns.
2. Take referrals from authorized referral agencies, such as City or County social services, or through CalAIM when that program is available.
3. Maintaining a wait list when the number of applicants exceeds available funding. If the wait list time to be served exceeds two (2) years, the wait list may be closed through a public process.
4. Monitor the state of the wait list. When the list is less than two (2) years long, use the appropriate public process to reopen list if it has been closed.
5. Maintain records in accordance with federal and state records retention requirements, answer correspondence, assist the City, auditors, and program monitors as required.
32. Lease Enforcement and Termination of Tenancy
Neither the City, nor its contractors are a party to the tenant/landlord lease and will not be obligated to enforce or intervene in a tenant/landlord dispute and is not a party to any eviction process.
33. Due Process
The City or its Contractor will work with program participants who are experiencing problems that may threaten their housing stability. Participants are expected to observe and abide by all the rules of the TBRA program; when a participant or a member of the participant’s household violates one or more of these rules, there are two levels of review that can apply, depending on the situation.
1. HUD Requirement for Due Process
HUD regulations at 24 CFR 92.209 and 24 CFR 92.253 requires “due process” be given to any participant whose rental assistance has been terminated because of program rule violations. Due process must consist of, at a minimum, the following steps as stated in the regulation:
a. Written notice to the participant containing a clear statement of the reason for termination.
b. A review of the decision, in which the participant is given the opportunity to present written or oral objection before a person other than the person (or a subordinate of the person) who made or approved the termination decision; and
c. Prompt written notice of the final decision to the participant. 864
18 2. Informal Hearings
Based on the above, The City’s Contractor, Neighborly, has a procedure whereby a participant who has been denied assistance or had the assistance terminated can appeal the termination. The following steps are required to initiate and conduct the informal hearing.
a. The participant must submit a written request requesting an appeal of the household’s termination from assistance. Normally the participant responds by filling out a form that is attached to or is a part of the letter sent informing the participant of the termination.
b. On receiving a written request for an appeal and the informal hearing is scheduled. staff person responsible for initiating the termination is mandatory. All other relevant persons, who may include the participant’s case manager, the landlord and any other persons who have first-hand knowledge or documentation of the issues involved – witnesses, in other words - are invited. The participant may be represented by legal counsel at his or her own expense and may bring up to two additional persons to act as witnesses.
c. Paragraph (2) of the HUD regulation establishing the due process requirement requires that an impartial person preside over the informal hearing. An impartial person is unfamiliar with the participant personally, has no prior knowledge of the issues that lead to the termination, and has no personal interest in seeing it resolved one way or another. This person is known as the Hearing Officer.
d. The Hearing Officer will preside by examining all written and electronic documentation, hearing the testimony of all witnesses, and making the final decision on the appeal. The role of the staff person processing the file/assistance is to facilitate the presentation of evidence and to show how it was determined that termination was the appropriate step. The staff person will provide an agenda for the informal hearing and provide access to relevant records to everyone present at the meeting. Witnesses present will be called upon by the person presiding to present evidence. e. The presiding person should attempt to render a decision while the participant is still in attendance. If this is not feasible, the decision must be issued within five working days, and a letter will be sent to the participant documenting the final decision. The hearing decision is final and there are no further appeals process available.
3. Termination from Assistance Without Hearing or Due Process Some actions by program participants can result in automatic termination from assistance without the need for a hearing or due process. Generally, these situations involve the participant’s absence from the assisted unit, either because of long-term incarceration or because the participant has abandoned the unit voluntarily without giving notice.
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19 34. Portability and Moving
There is no portability of HOME TBRA security deposit assistance outside the City of Orange..
35. Program Monitoring and Evaluation
The City or a subcontractor will conduct periodic and annual examination of the HOME TBRA program to ensure program compliance to these program policies and procedures and to ensure compliance with HOME regulations. Staff will conduct compliance monitoring and will issue reports and findings to the Director. Compliance monitoring reviews will be focused on the
following areas:
1. Compliance with policies set forth in this document, including but not limited to:
i. Accuracy of rent calculations
ii. Organization of participants file and timing of annual recertification iii. Documentation and accuracy of calculating household income and income derived from assets.
iv. Accuracy of Contractor billings to HOME
v. Accuracy of security and utility deposits
vi. Soundness of Rent Reasonableness surveys
2. Compliance with local, state, and federal, fair housing laws and ordinances, including landlord discrimination complaints and Fair Housing violations.
Record Retention: The City of Orange and its Contractor will maintain program records in accordance with the HOME Investment Partnerships Program recordkeeping requirements under 24 CFR 92.508. Records related to program administration and participant eligibility will be retained for the period required by federal regulations and will be made available for review by the City, auditors, and the U.S. Department of Housing and Urban Development upon request.
36. Live-In Aid Requirements
The City and its Contractor has adopted the following guidelines related to live-in aides:
1. Definition of Live-in Aide: HUD 24 CFR 5.403
A person who resides with one or more elderly persons or nearly elderly persons or persons with disabilities and who:
a. Is determined to be essential to the care and well-being of the persons.
b. Is not obligated for the support of the persons; and c. Would not be living in the unit except to provide the necessary supportive services.
d.
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20 2. Essential Care
A medical doctor, psychiatrist, or a non-medical agency that provides services to people with disabilities, such as a Center for Independent Living, will have to provide written documentation that the TBRA participant needs the services of a live-in aide. The recommendations should be from a professional that is familiar with the participant and have direct medical or professional experience in the areas related to the participant’s disability.
The written documentation needs to define:
a. the duration of the services (short-term or long-term care), and b. level of daily care that the person with a disability needs to be able to live in an independent apartment or home setting (i.e. hours of care needed in a 24- hour period), and
c. skill level of live-in aide (i.e. any specialized medical certification or training needed by the live-in aide to meet the needs of the participant)
d. The written documentation needs to be on official letterhead from the medical professional or agency making the recommendation.
The documentation needs to be dated within 60 days from the date that the services of the live-in aide will be required. The documentation should also give full contact information if there are questions concerning the recommendations.
3. Determining the Residence of the Live-in Aide
The City requires that the services of the live-in aid must be at an “arm'slength transaction” between the participant and the live-in aide. The aide must not have been a member of the participant’s household prior to becoming the personal care aide.
4. Relatives as Live-In Aides
A person that was or is a member of the participant’s household does not qualify as a live-in aide. If the participant wants to engage the services of a relative, the City requires that the participant certify that:
a. The live-in aide is qualified to provide the needed care. b. The live-in aide was not part of the household prior to the participant enrolling in the TBRA program.
c. There is no other reason for the aide to reside in the unit other than to care for the participant (i.e. the individual can demonstrate they have a previous residence they left in good standing).
d. The aide and the participant will maintain separate finances.
If a participant has a family member or member of the participant’s current household that wishes to provide services for the TBRA participant and the family member does not meet the live-in aide requirements outlined above, this family member can be part of the household, but their income will be counted as part of the household income.
38. Lead-Based Paint
The program will ensure compliance by conducting both an HQS and a Lead-Based Paint visual assessment of units identified by applicants in their Request for Tenancy Approval. 867
21 The Lead-Based Paint inspection will consist of a visual assessment for deteriorated paint (cracking, scaling, peeling, or chipping paint as well as visible dust, debris and paint chips) and will include verification that the owner has stabilized each deteriorated paint surface in accordance with §35.1330(a) and §35.1330(b) before occupancy of a vacant dwelling unit.
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Agenda Item
Orange City Council
Item #: 3.29. 4/28/2026 File #: 26-0202
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Trang Nguyen, Finance Director
1. SUBJECT
Single Audit Report of Federally Assisted Grant Programs for the Fiscal Year ended June 30, 2025
2. SUMMARY
Financial and Compliance Reports provided by LSL, LLP, independent auditors, as a result of their audit of federally funded grant programs for the fiscal year ended June 30, 2025.
3. RECOMMENDED ACTION
Receive and file.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Goal 2: Enhance Economic Development and Achieve Fiscal Sustainability Objective 2.9: Create a fiscal sustainability plan
6. DISCUSSION AND BACKGROUND
LSL, LLP (LSL), an independent certified public accounting firm, provided audit services to the City for the fiscal year ended June 30, 2025. Following the receive and file of the Annual Comprehensive Financial Report (ACFR) and related audit reports on February 24th, the Single Audit Report has been completed by the auditor and filed with Federal Audit Clearinghouse and California State Controller’s Office ahead of the March 31st deadline.
The Single Audit is a federally mandated compliance audit required when an entity expends $750,000 or more in federal grant funds during a fiscal year, in accordance with the U.S. Office of Management and Budget (OMB) 2 CFR Part 200, Uniform Guidance.
The audit evaluates compliance with federal program requirements and the effectiveness of internal controls over grant administration. Key procedures include reviewing internal controls, testing a sample of grant transactions for compliance, monitoring subrecipients, and reporting any findings or recommendations for corrective action. For the Fiscal Year 2025, the Single Audit was completed with no findings identified specifically to the federally funded grant programs. However, because the Single Audit relies extensively on the financial data and internal control framework established in the ACFR, auditing standards require the inclusion of applicable findings reported in the ACFR.
Accordingly, while there were no standalone Single Audit findings, any relevant matters noted in the City of Orange Page 1 of 2 Printed on 4/23/2026
powered by Legistar™869
Item #: 3.29. 4/28/2026 File #: 26-0202
Accordingly, while there were no standalone Single Audit findings, any relevant matters noted in the ACFR are incorporated by reference to ensure consistency and completeness in reporting.
The completion of the Single Audit provides assurance that the City has properly managed federal funds and remains in compliance with applicable requirements.
7. ATTACHMENTS
· Single Audit of Federally Assisted Grant Programs
City of Orange Page 2 of 2 Printed on 4/23/2026
powered by Legistar™870
Agenda Item
Orange City Council
Item #: 3.29. 4/28/2026 File #: 26-0202
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Trang Nguyen, Finance Director
1. SUBJECT
Single Audit Report of Federally Assisted Grant Programs for the Fiscal Year ended June 30, 2025
2. SUMMARY
Financial and Compliance Reports provided by LSL, LLP, independent auditors, as a result of their audit of federally funded grant programs for the fiscal year ended June 30, 2025.
3. RECOMMENDED ACTION
Receive and file.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Goal 2: Enhance Economic Development and Achieve Fiscal Sustainability Objective 2.9: Create a fiscal sustainability plan
6. DISCUSSION AND BACKGROUND
LSL, LLP (LSL), an independent certified public accounting firm, provided audit services to the City for the fiscal year ended June 30, 2025. Following the receive and file of the Annual Comprehensive Financial Report (ACFR) and related audit reports on February 24th, the Single Audit Report has been completed by the auditor and filed with Federal Audit Clearinghouse and California State Controller’s Office ahead of the March 31st deadline.
The Single Audit is a federally mandated compliance audit required when an entity expends $750,000 or more in federal grant funds during a fiscal year, in accordance with the U.S. Office of Management and Budget (OMB) 2 CFR Part 200, Uniform Guidance.
The audit evaluates compliance with federal program requirements and the effectiveness of internal controls over grant administration. Key procedures include reviewing internal controls, testing a sample of grant transactions for compliance, monitoring subrecipients, and reporting any findings or recommendations for corrective action. For the Fiscal Year 2025, the Single Audit was completed with no findings identified specifically to the federally funded grant programs. However, because the Single Audit relies extensively on the financial data and internal control framework established in the ACFR, auditing standards require the inclusion of applicable findings reported in the ACFR.
Accordingly, while there were no standalone Single Audit findings, any relevant matters noted in the City of Orange Page 1 of 2 Printed on 4/23/2026
powered by Legistar™871
Item #: 3.29. 4/28/2026 File #: 26-0202
Accordingly, while there were no standalone Single Audit findings, any relevant matters noted in the ACFR are incorporated by reference to ensure consistency and completeness in reporting.
The completion of the Single Audit provides assurance that the City has properly managed federal funds and remains in compliance with applicable requirements.
7. ATTACHMENTS
· Single Audit of Federally Assisted Grant Programs
City of Orange Page 2 of 2 Printed on 4/23/2026
powered by Legistar™872
CITY OF ORANGE, CALFORNIA
FOR THE YEAR ENDED JUNE 30, 2025 SINGLE AUDIT REPORT
873
CITY OF ORANGE, CALIFORNIA
Single Audit Report
For the Year Ended June 30, 2025
874
CITY OF ORANGE, CALIFORNIA
Single Audit Report
For the Year Ended June 30, 2025
Table of Contents
Page
Number
Independent Auditors’ Report on Internal Control Over Financial Reporting and on Compliance and Other Matters Based on an Audit of Financial Statements Performed in Accordance with Government Auditing Standards ....................................................................................... 1 Independent Auditors’ Report on Compliance for Each Major Program and on Internal Control Over Compliance; and Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance ..................................................................................................... 3 Schedule of Expenditures of Federal Awards for the
For the Year Ended June 30, 2025 .................................................................................................................. 6 Notes to the Schedule of Expenditures of Federal Awards ................................................................................. 7 Schedule of Findings and Questioned Costs for the
For the Year Ended June 30, 2025 .................................................................................................................. 8 Summary Schedule of Prior Year Findings and Questioned Costs for the For the Year Ended June 30, 2024 ................................................................................................................ 10 875
LSLCPAS.COM
INDEPENDENT AUDITORS’ REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON
COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN
ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS
To the Honorable Members of the City Council
City of Orange, California
We have audited, in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States, the financial statements of the governmental activities, the business-type activities, each major fund, and the aggregate remaining fund information of the City of Orange, California (hereafter, the City), as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the City’s basic financial statements, and have issued our report thereon dated January 26, 2026.
Report on Internal Control over Financial Reporting
In planning and performing our audit of the financial statements, we considered the City’s internal control over financial reporting (internal control) as a basis for designing audit procedures that are appropriate in the circumstances for the purpose of expressing our opinions on the financial statements, but not for the purpose of expressing an opinion on the effectiveness of the City’s internal control. Accordingly, we do not express an opinion on the effectiveness of the City’s internal control.
A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.
Our consideration of internal control was for the limited purpose described in the first paragraph of this section and was not designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies and therefore, material weaknesses or significant deficiencies may exist that were not identified. We identified a certain deficiency in internal control, described in the accompanying schedule of findings and questioned costs as item 2025-001 that we consider to be a material weakness.
Report on Compliance and Other Matters
As part of obtaining reasonable assurance about whether the City’s financial statements are free from material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements, noncompliance with which could have a direct and material effect on the financial statements.
However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards. 876
To the Honorable Members of the City Council
City of Orange, California
City of Orange, California’s Response to Finding
Government Auditing Standards requires the auditor to perform limited procedures on the City’s response to the finding identified in our audit and described in the accompanying schedule of findings and questioned costs. The City’s response was not subjected to the other auditing procedures applied in the audit of the financial statements and, accordingly, we express no opinion on the response.
Purpose of This Report
The purpose of this report is solely to describe the scope of our testing of internal control and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the City’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the City’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose.
Irvine, California
January 26, 2026
2 877
LSLCPAS.COM
INDEPENDENT AUDITORS’ REPORT ON COMPLIANCE FOR EACH MAJOR PROGRAM
AND ON INTERNAL CONTROL OVER COMPLIANCE AND REPORT ON SCHEDULE OF EXPENDITURES OF
FEDERAL AWARDS REQUIRED BY THE UNIFORM GUIDANCE
To the Honorable Mayor and Members of the City Council
City of Orange, California
Report on Compliance for Each Major Federal Program
Opinion on Each Major Federal Program
We have audited the City of Orange, California (hereafter, the City)’s compliance with the types of compliance requirements identified as subject to audit in the OMB Compliance Supplement that could have a direct and material effect on each of the City’s major federal programs for the year ended June 30, 2025. The City’s major federal programs are identified in the summary of auditors’ results section of the accompanying schedule of findings and questioned costs.
In our opinion, the City complied, in all material respects, with the types of compliance requirements referred to above that could have a direct and material effect on each of its major federal programs for the year ended June 30, 2025.
Basis for Opinion on Each Major Federal Program
We conducted our audit of compliance in accordance with auditing standards generally accepted in the United States of America; the standards applicable to financial audits contained in Government Auditing Standards issued by the Comptroller General of the United States; and the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Our responsibilities under those standards and the Uniform Guidance are further described in the Auditors’ Responsibilities for the Audit of Compliance section of our report.
We are required to be independent of the City and to meet our other ethical responsibilities, in accordance with relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion on compliance for each major federal program. Our audit does not provide a legal determination of the City’s compliance with the compliance requirements referred to above.
Responsibilities of Management for Compliance
Management is responsible for compliance with the requirements referred to above and for the design, implementation, and maintenance of effective internal control over compliance with the requirements of laws, statutes, regulations, rules, and provisions of contracts or grant agreements applicable to the City’s federal programs.
878
To the Honorable Mayor and Members of the City Council
City of Orange, California
Auditors’ Responsibilities for the Audit of Compliance
Our objectives are to obtain reasonable assurance about whether material noncompliance with the compliance requirements referred to above occurred, whether due to fraud or error, and express an opinion on the City’s compliance based on our audit. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with generally accepted auditing standards, Government Auditing Standards, and the Uniform Guidance will always detect material noncompliance when it exists. The risk of not detecting material noncompliance resulting from fraud is higher than for that resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Noncompliance with the compliance requirements referred to above is considered material if there is a substantial likelihood that, individually or in the aggregate, it would influence the judgment made by a reasonable user of the report on compliance about the City’s compliance with the requirements of each major federal program as a whole.
In performing an audit in accordance with generally accepted auditing standards, Government Auditing Standards, and the Uniform Guidance, we:
• Exercise professional judgment and maintain professional skepticism throughout the audit. • Identify and assess the risks of material noncompliance, whether due to fraud or error, and design and perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the City’s compliance with the compliance requirements referred to above and performing such other procedures as we considered necessary in the circumstances. • Obtain an understanding of the City’s internal control over compliance relevant to the audit in order to design audit procedures that are appropriate in the circumstances and to test and report on internal control over compliance in accordance with the Uniform Guidance, but not for the purpose of expressing an opinion on the effectiveness of the City’s internal control over compliance. Accordingly, no such opinion is expressed.
We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit and any significant deficiencies and material weaknesses in internal control over compliance that we identified during the audit.
Report on Internal Control over Compliance
A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
A material weakness in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance, such that there is a reasonable possibility that material noncompliance with a type of compliance requirement of a federal program will not be prevented, or detected and corrected, on a timely basis. A significant deficiency in internal control over compliance is a deficiency, or a combination of deficiencies, in internal control over compliance with a type of compliance requirement of a federal program that is less severe than a material weakness in internal control over compliance, yet important enough to merit attention by those charged with governance.
Our consideration of internal control over compliance was for the limited purpose described in the Auditor’s Responsibilities for the Audit of Compliance section above and was not designed to identify all deficiencies in internal control over compliance that might be material weaknesses or significant deficiencies in internal control over compliance. Given these limitations, during our audit we did not identify any deficiencies in internal control over compliance that we consider to be material weaknesses, as defined above. However, material weaknesses or significant deficiencies in internal control over compliance may exist that were not identified. 4 879
To the Honorable Mayor and Members of the City Council
City of Orange, California
Our audit was not designed for the purpose of expressing an opinion on the effectiveness of internal control over compliance. Accordingly, no such opinion is expressed.
The purpose of this report on internal control over compliance is solely to describe the scope of our testing of internal control over compliance and the results of that testing based on the requirements of the Uniform Guidance.
Accordingly, this report is not suitable for any other purpose.
Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance We have audited the financial statements of the governmental activities, the business-type activities, each major fund, and the aggregate remaining fund information of the City, as of and for the year ended June 30, 2025, and the related notes to the financial statements, which collectively comprise the City’s basic financial statements. We issued our report thereon dated January 26, 2026, which contained unmodified opinions on those financial statements. Our audit was performed for the purpose of forming opinions on the financial statements that collectively comprise the basic financial statements. The accompanying schedule of expenditures of federal awards is presented for purposes of additional analysis as required by the Uniform Guidance and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from and relates directly to the underlying accounting and other records used to prepare the basic financial statements. The information has been subjected to the auditing procedures applied in the audit of the financial statements and certain additional procedures, including comparing and reconciling such information directly to the underlying accounting and other records used to prepare the basic financial statements or to the basic financial statements themselves, and other additional procedures in accordance with auditing standards generally accepted in the United States of America. In our opinion, the schedule of expenditures of federal awards is fairly stated in all material respects in relation to the basic financial statements as a whole.
Irvine, California
March 12, 2026 (Except for the Report on Schedule of Expenditures of Federal Awards Required by the Uniform Guidance, which is dated January 26, 2026)
5 880
CITY OF ORANGE, CALIFORNIA
Schedule of Expenditures of Federal Awards
For the Year Ended June 30, 2025
Assistance
Listing Pass-Through Entity Passed-Through Total Federal Number Unique Entity ID to Subrecipients Expenditures
U.S Department of Housing and Urban Development
Direct Programs:
CDBG - Entitlement Grants Cluster
Community Development Block Grants/Entitlement Grants * 14.218 N/A $ 155,421 $ 982,832 Total CDBG - Entitlement Grants Cluster 155,421 982,832 Home Investment Partnerships Program * 14.239 N/A - 832,051 Economic Development Initiative 14.251 N/A - 5,918
Total U.S. Department of Housing and Urban Development 155,421 1,820,801 U.S. Department of Justice
Direct Programs:
Public Safety Partnership and Community Policing Grants 16.710 N/A - 47,144 Equitable Sharing Program 16.922 N/A - 541,783
Pass-through Programs:
County of Orange:
Edward Byrne Memorial Justice Assistance Grant Program 16.738 RFT6BJ98H2A5 - 12,884 Total U.S. Department of Justice 601,811 -
U.S. Department of Transportation
Direct Programs:
Highway Safety Cluster
State and Community Highway Safety 20.600 N/A - 142,693 Total Highway Safety Cluster - 142,693
Minimum Penalties for Repeat Offenders for Driving While Intoxicated 20.608 N/A - 183,019 Highway Planning and Construction 20.205 N/A - 22,892
Pass-through Programs:
State of California Department of Transportation (Caltrans):
Highway Planning and Construction 20.205 UK66CLD4DX71 - 102,319 Total Highway Planning and Construction - 125,211
Total U.S. Department of Transportation 450,923 -
U.S. Department of the Treasury
Direct Programs:
Equitable Sharing Program 21.016 N/A - 33,385
Total U.S. Department of the Treasury 33,385 -
U.S. Department of Energy
Direct Programs:
Energy Efficiency and Conservation Block Grant Program 81.128 N/A - 127,137 Total U.S. Department of Energy 127,137 -
U.S. Department of Homeland Security
Pass-through Programs:
California Office of Emergency Services:
Hazard Mitigation Grant 97.039 UTM3S7LKYQZ4 - 52,326
Emergency Management Performance Grants 97.042 UTM3S7LKYQZ4 - 44,489 County of Orange:
Emergency Management Performance Grants 97.042 RFT6BJ98H2A5 - 36,852 Total Emergency Management Performance Grants - 81,341
Total U.S. Department of Homeland Security 133,667 -
Total Expenditures of Federal Awards $ 3,167,724 155,421 $ * Major Program
There was no federal awards expended in the form of noncash assistance and insurance in effect during the year.
Federal Grantor/Pass-Through
Grantor/Program or Cluster Title
See accompanying notes to this schedule.
6 881
CITY OF ORANGE, CALIFORNIA
Notes to the Schedule of Expenditures of Federal Awards For the Year Ended June 30, 2025
NOTE 1: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES APPLICABLE TO THE SCHEDULE OF
EXPENDITURES OF FEDERAL AWARDS
A. Scope of Presentation
The accompanying schedule presents only the expenditures incurred by the City of Orange, California, that are reimbursable under federal programs of federal financial assistance. For the purposes of this schedule, federal awards include both federal financial assistance received directly from a federal agency, as well as federal funds received indirectly by the City from a non-federal agency or other organization. Only the portion of program expenditures reimbursable with such federal funds is reported in the accompanying schedule. Program expenditures in excess of the maximum federal reimbursement authorized or the portion of the program expenditures that were funded with state, local or other non-federal funds are excluded from the accompanying schedule.
B. Basis of Accounting
The expenditures included in the accompanying schedule were reported on the modified accrual basis of accounting.
Under the modified accrual basis of accounting, expenditures are incurred when the City becomes obligated for payment as a result of the receipt of the related goods and services. Expenditures reported included any property or equipment acquisitions incurred under the federal program. The City has elected not to use the de minimis indirect cost rate allowed under the Uniform Guidance.
7 882
CITY OF ORANGE, CALIFORNIA
Schedule of Findings and Questioned Costs
For the Year Ended June 30, 2025
SECTION I - SUMMARY OF AUDITORS' RESULTS
Financial Statements
Type of auditors' report issued: Unmodified Opinion
Internal control over financial reporting:
• Material weaknesses identified? X yes no
• Significant deficiencies identified? yes X none reported Noncompliance material to financial
statements noted? yes X no
Federal Awards
Internal control over major programs:
• Material weaknesses identified? yes X no
• Significant deficiencies identified? yes X none reported Type of auditors' report issued on compliance for major programs: Unmodified Opinion Any audit findings disclosed that are required to be
reported in accordance with Title 2 U.S. Code of
Federal Regulations (CFR) Part 200, Uniform
Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards (Uniform
Guidance)? yes X no
Identification of major programs:
Assistance Listing Number(s) Name of Federal Program or Cluster
14.218 Community Development Block Grants/Entitlement Grants
14.239 Home Investment Partnerships Program
Dollar threshold used to distinguish
between type A and type B program $750,000
Auditee qualified as low-risk auditee? yes X no
8 883
CITY OF ORANGE, CALIFORNIA
Schedule of Findings and Questioned Costs
For the Year Ended June 30, 2025
SECTION II - FINANCIAL STATEMENT FINDINGS
Reference Number: 2025-001
Financial Closing and Reporting
Material Weakness
Condition
During our audit, we noted that the City recorded a substantial number of post–trial balance journal entries to correct errors and adjust account balances after the initial trial balance was prepared. The adjustments prepared staff, after audit has begun, were necessary to ensure the financial statements were presented in accordance with generally accepted accounting principles (GAAP).
Criteria
Government Auditing Standards and GAAP require entities to maintain effective internal controls over financial reporting to ensure accurate and timely preparation of financial statements. An effective financial closing process should minimize the need for extensive post–closing adjustments and ensure that account balances are complete and accurate prior to audit.
Cause
The City lost several key finance personnel during the year, including the Finance Manager, and Senior Accountant, while simultaneously implementing a new ERP system. These factors strained the department’s capacity and contributed to weaknesses in the financial closing process, as staff turnover and system changes disrupted established procedures and reduced the availability of experienced personnel to perform timely reconciliations and reviews.
Effect or Potential Effect
The combination of staff turnover and ERP implementation caused delays in the financial closing process, increased the risk of errors, and required significant post-closing adjustments. These issues impacted audit readiness and the timeliness of financial reporting, creating inefficiencies and elevating the risk of material misstatements in the financial statements.
Recommendation
We recommend the City fill open positions to take over or allocate resources to the procedures that have led to impacts on the timeliness of the financial closing procedures. This will ensure all journal entries and reconciliations are prepared and will be included in the trial balance provided to the auditors at the beginning of the audit, and limit the number of post-trial balance journal entries.
Management’s Response
Management acknowledges and concurs with the finding and recommendation. While the implementation of a new ERP system during Fiscal Year 2024–2025 created significant operational challenges, the turnover in key Finance positions highlights the critical need of allocating adequate staffing to core financial functions.
Management is actively recruiting to fill critical vacancies and is simultaneously exploring opportunities to streamline processes, leverage system capabilities, and implement innovative approaches to improve efficiency. With the combination of filling critical vacancies, process improvements, and continued stabilization of the new ERP system, the Finance Department is committed to provide a more timely and accurate trial balance at the start of next year’s audit cycle.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Our audit did not disclose any matters required to be reported in accordance with 2 CFR 200.516(a). 9 884
CITY OF ORANGE
FINANCE DIRECTOR PHONE: (714) 744-2222 www.cityoforange.org FAX: (714) 744-5147 ORANGE CIVIC CENTER • 300 E. CHAPMAN AVENUE • ORANGE, CA 92866-1591 • P.O. BOX 449 Printed on recycled paper
Summary Schedule of Prior Year Findings and Questioned Costs For the Year Ended June 30, 2024
Reference Number: 2024-001 – This matter is considered resolved. 10 885
Agenda Item
Orange City Council
Item #: 4.1. 4/28/2026 File #: 26-0197
TO: Members of the City Council
FROM: Mayor Dan Slater
1. SUBJECT
Appointment of City Councilmembers to Regional Boards and Committees
2. SUMMARY
Consider the appointment of City Councilmembers to serve as representatives and alternates on various regional boards and committees. A list of current appointments is attached for reference.
Unless otherwise specified, all appointments are for a one-year term or serve at the discretion of the Mayor.
In accordance with FPPC Regulation 18702.5, Form 806 has been posted on the City’s website. If the City Council appoints a representative or alternate who is not currently listed on Form 806, both the appointed member and the alternate must recuse themselves from voting on the appointment until Form 806 is updated and posted.
3. RECOMMENDED ACTION
Confirm City Councilmember appointments to regional boards and committees.
4. ATTACHMENT
· Current Councilmember appointments to City Regional Boards and Committees · FPPC Form 806 (posted on the City website on April 21, 2026) City of Orange Page 1 of 1 Printed on 4/23/2026
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Agenda Item
Orange City Council
Item #: 4.1. 4/28/2026 File #: 26-0197
TO: Members of the City Council
FROM: Mayor Dan Slater
1. SUBJECT
Appointment of City Councilmembers to Regional Boards and Committees
2. SUMMARY
Consider the appointment of City Councilmembers to serve as representatives and alternates on various regional boards and committees. A list of current appointments is attached for reference.
Unless otherwise specified, all appointments are for a one-year term or serve at the discretion of the Mayor.
In accordance with FPPC Regulation 18702.5, Form 806 has been posted on the City’s website. If the City Council appoints a representative or alternate who is not currently listed on Form 806, both the appointed member and the alternate must recuse themselves from voting on the appointment until Form 806 is updated and posted.
3. RECOMMENDED ACTION
Confirm City Councilmember appointments to regional boards and committees.
4. ATTACHMENT
· Current Councilmember appointments to City Regional Boards and Committees · FPPC Form 806 (posted on the City website on April 21, 2026) City of Orange Page 1 of 1 Printed on 4/23/2026
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CURRENT
Council Appointments to City Committees and Regional Boards (Terms are for 1 year unless otherwise noted.)
BOARD/COMMITTEE/COMMISSION Term Member Alternate
Orange City/Schools Coordinating
Committee
1 year Gutierrez Tavoularis
Foothill Eastern TCA (Tollroad)* 1 year Bilodeau Tavoularis North Net Fire Training (Joint Powers
Authority)
1 year Dumitru Tavoularis
Orange County Transportation Authority
(OCTA)
2 years
Term expires
12/31/2026
Tavoularis (appointed by
City Selection Committee)
N/A
Orange County Sanitation District* 2 years
Term expires
2027
Dumitru Gyllenhammer
Orange County Mosquito and Vector
Control
2 years
Term expires
1/3/2028**
Sean Chavarria
(Orange resident)
N/A
Orange Elderly Services (Senior Center) 1 year Tavoularis Gutierrez Santa Ana Flood Protection Agency 1 year Bilodeau Gutierrez *Members receive stipend and are listed on the City’s Form 806 **Mr. Chavarria was re-appointed on 12/9/2025 to a term ending 1/3/2028 OCTA term is 1/1/2025-12/31/2026
888
FPPC Form 806 (1/18)
FPPC Toll-Free Helpline: 866/ASK-FPPC (866/275-3772)
Comment:
A Public Document
Appt Date and
Length of Term
Agency Report of:
Public Official Appointments
2. Appointments
3. Verification
I have read and understand FPPC Regulation 18702.5. I have verified that the appointment and information identified above is true to the best of my information and belief.
Signature of Agency Head or Designee Print Name Title (Month, Day, Year) Agency Boards and
Commissions Name of Appointed Person Per Meeting/Annual Salary/Stipend (Last, First)
(Last, First)
(Last, First)
(Last, First)
Alternate, if any
Alternate, if any
Alternate, if any
Alternate, if any
(Last, First)
(Last, First)
(Last, First)
(Last, First)
Name
Name
Name
Name
$0-$1,000
$0-$1,000
$0-$1,000
$0-$1,000
$1,001-$2,000
$1,001-$2,000
$1,001-$2,000
$1,001-$2,000
$2,001-$3,000
$2,001-$3,000
$2,001-$3,000
$2,001-$3,000
Other
Other
Other
Other
California
Form
1. Agency Name
Designated Agency Contact (Name,Title)
E-mail
Division, Department, or Region (If Applicable)
806
For Official Use Only
Area Code/Phone Number
(Month, Day, Year)
_____________
Appt Date
_____________
Appt Date
_____________
Appt Date
_____________
Appt Date
Length of Term
Length of Term
Length of Term
Length of Term
Estimated Annual:
Estimated Annual:
Estimated Annual:
Estimated Annual:
Per Meeting: $
Per Meeting: $
Per Meeting: $
Per Meeting: $
Page _____ of _____
Date Posted:
1168 889
Agenda Item
Orange City Council
Item #: 5.1. 4/28/2026 File #: 26-0249
TO: Honorable Mayor and Members of the City Council
FROM: Councilmember Arianna Barrios, District 1
1. SUBJECT
Consideration of a Proclamation celebrating May 1, 2026, as International Workers’ Day (Barrios)
2. RECOMMENDED ACTION
Consider adding the Proclamation to the May 12, 2026, Regular City Council meeting agenda.
3. ATTACHMENTS
· Draft Proclamation
City of Orange Page 1 of 1 Printed on 4/23/2026
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Agenda Item
Orange City Council
Item #: 5.1. 4/28/2026 File #: 26-0249
TO: Honorable Mayor and Members of the City Council
FROM: Councilmember Arianna Barrios, District 1
1. SUBJECT
Consideration of a Proclamation celebrating May 1, 2026, as International Workers’ Day (Barrios)
2. RECOMMENDED ACTION
Consider adding the Proclamation to the May 12, 2026, City Council Regular meeting agenda.
3. ATTACHMENTS
· Draft Proclamation
City of Orange Page 1 of 1 Printed on 4/23/2026
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Proclamation
Recognizing
May 1, 2026, as International Workers’ Day
WHEREAS, May 1 is recognized and celebrated around the world as International Workers’ Day, also known as May Day, honoring the contributions and achievements of workers across all industries; and WHEREAS, the origins of May Day trace back to the United States labor movement, including the 1886 movement for the eight-hour workday, which advanced fundamental labor protections that continue to benefit workers today; and
WHEREAS, workers in the City of Orange and throughout Orange County play a vital role in supporting the local economy, providing essential services, and contributing to the social and cultural fabric of the community; and
WHEREAS, immigrant workers have historically and continue to contribute significantly to the economic vitality, diversity, and resilience of communities throughout California, including the City of Orange; and
WHEREAS, the labor movement has contributed to important advancements in workplace safety, fair wages, healthcare access, and civil rights, improving quality of life for workers and families; and WHEREAS, many workers continue to face challenges including economic inequality, workplace safety concerns, and barriers to fair labor practices; and
WHEREAS, recognizing International Workers’ Day provides an opportunity to acknowledge the dignity of work and the importance of supporting policies that promote equitable and safe working conditions for all workers;
NOW, THEREFORE, I, Dan Slater, Mayor of the City of Orange, on behalf of the City and entire City Council, do hereby recognize May 1, 2026, as International Workers’ Day in the City of Orange and encourage residents, businesses, and community organizations to acknowledge the contributions of workers and to support efforts that promote fair and safe working conditions.
DATED this day of _______ 2026.
_____________________________________
Daniel R. Slater, Mayor
Draft
892
Agenda Item
Orange City Council
Item #: 7.1. 4/28/2026 File #: 25-0714
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Pamela Coleman, City Clerk/City Clerk Services Director
1. SUBJECT
Annual presentation of Local Appointments List of all City Boards, Commissions, and Committees
2. SUMMARY
On or before December 31 of each year, the legislative body shall approve the Local Appointments List in compliance with Government Code §54972 and direct staff to post a copy of the list on the City’s Website in compliance with Government Code §54973.
This information is provided for City Council consideration. Council may wish to make any changes and/or deactivate any board, commission, or committee which the Council believes has completed its original purpose.
3. RECOMMENDED ACTION
1. Confirm Mayor Slater’s recommendation to reappoint the following eligible existing positions:
o Audit Advisory Committee Members Chris Horton, Andrew Li, and Brian Wilterink for two-year terms respectively expiring June 30, 2028;
o CDBG Program Committee Member Jonathan St. Clair for a two-year term expiring June 30, 2028;
o Orange Public Library Board of Trustees Member Susie Huber for a three-year term expiring June 30, 2029;
o Park Planning and Community Events Commissioner Christopher Ahlswede for a four-year term expiring June 30, 2030; and
o Planning Commissioner David Vazquez for a four-year term expiring June 30, 2030.
2. Confirm Mayor Slater’s recommendation to appoint Perla Lozano to the Park Planning and Community Events Commission to fill an unexpired term ending June 30, 2029.
3. Approve the Local Appointments List and direct the City Clerk to post a copy in compliance with the Maddy Act.
4. Direct the City Clerk to post a Notice of Scheduled Vacancy for the following positions:
City of Orange Page 1 of 3 Printed on 4/23/2026
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Item #: 7.1. 4/28/2026 File #: 25-0714
o Audit Advisory Committee due to expiration of Jack Schroeder’s term on June 30, 2026 o Planning Commission due to expiration of Rick Martinez’s term on June 30, 2026
4. FISCAL IMPACT
There is no fiscal impact in the appointment of committee members.
5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.
6. DISCUSSION AND BACKGROUND
The California Legislature established Government Code Sections 54970 to 54974, also known as the “Maddy Act,” to inform and promote opportunities for the public to serve on local government boards, commissions, and committees.
The Maddy Act requires that on or before December 31 of each year, the legislative body prepare and post a Local Appointments List of all regular and ongoing boards, commissions, and committees whose members are appointed by the City Council. The list must contain the following information:
1) all appointive terms which will expire during the next calendar year 2) the name of the incumbent appointee
3) the date of appointment and the date the term expires 4) the necessary qualifications for the position
Pursuant to Government Code §40605, the elected Mayor, with the approval of the City Council, makes all appointments to City boards, commissions, and committees unless otherwise specifically provided by statute.
Below is a list of vacancies scheduled to occur on June 30, 2026. Some of these vacancies will be filled by confirming Mayor Slater’s recommendation for reappointment. There is also one unscheduled vacancy on the Audit Advisory Committee due to the resignation of Jeff Grampp that occurred on February 16, 2026. In accordance with Government Code §54974, the City Clerk posted the unscheduled vacancy notice on February 17, 2026.
Audit Advisory Committee (two-year term of office):
Current vacancies: 2 (two) (one scheduled vacancy and one unscheduled vacancy) · Four scheduled vacancies due to expired terms eligible for reappointment · Three positions being recommended for reappointment (Horton, Li, Wilterink), leaving one scheduled vacancy (Schroeder)
· One unscheduled vacancy with a term ending June 30, 2028, due to the resignation of Jeff Grampp
CDBG Program Committee (two-year term of office):
Current vacancies: none
· One scheduled vacancy due to an expired term, eligible for reappointment · One position being recommended for reappointment (St. Clair), leaving no scheduled City of Orange Page 2 of 3 Printed on 4/23/2026
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Item #: 7.1. 4/28/2026 File #: 25-0714
vacancies
Orange Public Library Board of Trustees (three-year term of office):
Current vacancies: none
· One scheduled vacancy due to an expired term, eligible for reappointment · One position being recommended for reappointment (Huber), leaving no scheduled vacancies Park Planning & Community Events Commission (four-year term of office):
Current vacancies: none
· One scheduled vacancy due to an expired term, eligible for reappointment; and one unscheduled vacancy with a term ending June 30, 2029, due to the resignation of Steve Freeman
· One position being recommended for reappointment (Ahlswede) · Unscheduled vacancy being recommended to be filled by Perla Lozano (which will leave an unscheduled vacancy on CDBG)
Planning Commission (four-year term of office):
Current vacancies: 1 (one) (scheduled vacancy)
· Two scheduled vacancies due to expired terms, eligible for reappointment · One position being recommended for reappointment (Vazquez), leaving one scheduled vacancy (Martinez)
In addition, there are still two vacancies on the Investment Advisory Committee. A Notice of Vacancy was posted on April 10, 2024.
Any other vacancies that occur during 2026 would be unscheduled and a notice would be posted in accordance with Government Code §54974.
Once approved by the City Council, the Local Appointments List will be posted on the City’s website in compliance with State Law. In addition, staff will also post a copy at the Main Library and in the City Clerk’s office. The City Clerk’s Office will update the list as appointments are confirmed.
7. ATTACHMENTS
· Proposed Local Appointments List
· 2025 Attendance Reports
City of Orange Page 3 of 3 Printed on 4/23/2026
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Agenda Item
Orange City Council
Item #: 7.1. 4/28/2026 File #: 25-0714
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Pamela Coleman, City Clerk/City Clerk Services Director
1. SUBJECT
Annual presentation of Local Appointments List of all City Boards, Commissions, and Committees
2. SUMMARY
On or before December 31 of each year, the legislative body shall approve the Local Appointments List in compliance with Government Code §54972 and direct staff to post a copy of the list on the City’s Website in compliance with Government Code §54973.
This information is provided for City Council consideration. Council may wish to make any changes and/or deactivate any board, commission, or committee which the Council believes has completed its original purpose.
3. RECOMMENDED ACTION
1. Confirm Mayor Slater’s recommendation to reappoint the following eligible existing positions:
o Audit Advisory Committee Members Chris Horton, Andrew Li, and Brian Wilterink for two-year terms respectively expiring June 30, 2028;
o CDBG Program Committee Member Jonathan St. Clair for a two-year term expiring June 30, 2028;
o Orange Public Library Board of Trustees Member Susie Huber for a three-year term expiring June 30, 2029;
o Park Planning and Community Events Commissioner Christopher Ahlswede for a four-year term expiring June 30, 2030; and
o Planning Commissioner David Vazquez for a four-year term expiring June 30, 2030.
2. Confirm Mayor Slater’s recommendation to appoint Perla Lozano to the Park Planning and Community Events Commission to fill an unexpired term ending June 30, 2029.
3. Approve the Local Appointments List and direct the City Clerk to post a copy in compliance with the Maddy Act.
4. Direct the City Clerk to post a Notice of Scheduled Vacancy for the following positions:
City of Orange Page 1 of 3 Printed on 4/23/2026
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Item #: 7.1. 4/28/2026 File #: 25-0714
o Audit Advisory Committee due to expiration of Jack Schroeder’s term on June 30, 2026 o Planning Commission due to expiration of Rick Martinez’s term on June 30, 2026
4. FISCAL IMPACT
There is no fiscal impact in the appointment of committee members.
5. STRATEGIC PLAN GOALS
Goal 3: Enhance Public Communication Strategy and Quality of Life.
6. DISCUSSION AND BACKGROUND
The California Legislature established Government Code Sections 54970 to 54974, also known as the “Maddy Act,” to inform and promote opportunities for the public to serve on local government boards, commissions, and committees.
The Maddy Act requires that on or before December 31 of each year, the legislative body prepare and post a Local Appointments List of all regular and ongoing boards, commissions, and committees whose members are appointed by the City Council. The list must contain the following information:
1) all appointive terms which will expire during the next calendar year 2) the name of the incumbent appointee
3) the date of appointment and the date the term expires 4) the necessary qualifications for the position
Pursuant to Government Code §40605, the elected Mayor, with the approval of the City Council, makes all appointments to City boards, commissions, and committees unless otherwise specifically provided by statute.
Below is a list of vacancies scheduled to occur on June 30, 2026. Some of these vacancies will be filled by confirming Mayor Slater’s recommendation for reappointment. There is also one unscheduled vacancy on the Audit Advisory Committee due to the resignation of Jeff Grampp that occurred on February 16, 2026. In accordance with Government Code §54974, the City Clerk posted the unscheduled vacancy notice on February 17, 2026.
Audit Advisory Committee (two-year term of office):
Current vacancies: 2 (two) (one scheduled vacancy and one unscheduled vacancy) · Four scheduled vacancies due to expired terms eligible for reappointment · Three positions being recommended for reappointment (Horton, Li, Wilterink), leaving one scheduled vacancy (Schroeder)
· One unscheduled vacancy with a term ending June 30, 2028, due to the resignation of Jeff Grampp
CDBG Program Committee (two-year term of office):
Current vacancies: none
· One scheduled vacancy due to an expired term, eligible for reappointment · One position being recommended for reappointment (St. Clair), leaving no scheduled City of Orange Page 2 of 3 Printed on 4/23/2026
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Item #: 7.1. 4/28/2026 File #: 25-0714
vacancies
Orange Public Library Board of Trustees (three-year term of office):
Current vacancies: none
· One scheduled vacancy due to an expired term, eligible for reappointment · One position being recommended for reappointment (Huber), leaving no scheduled vacancies Park Planning & Community Events Commission (four-year term of office):
Current vacancies: none
· One scheduled vacancy due to an expired term, eligible for reappointment; and one unscheduled vacancy with a term ending June 30, 2029, due to the resignation of Steve Freeman
· One position being recommended for reappointment (Ahlswede) · Unscheduled vacancy being recommended to be filled by Perla Lozano (which will leave an unscheduled vacancy on CDBG)
Planning Commission (four-year term of office):
Current vacancies: 1 (one) (scheduled vacancy)
· Two scheduled vacancies due to expired terms, eligible for reappointment · One position being recommended for reappointment (Vazquez), leaving one scheduled vacancy (Martinez)
In addition, there are still two vacancies on the Investment Advisory Committee. A Notice of Vacancy was posted on April 10, 2024.
Any other vacancies that occur during 2026 would be unscheduled and a notice would be posted in accordance with Government Code §54974.
Once approved by the City Council, the Local Appointments List will be posted on the City’s website in compliance with State Law. In addition, staff will also post a copy at the Main Library and in the City Clerk’s office. The City Clerk’s Office will update the list as appointments are confirmed.
7. ATTACHMENTS
· Proposed Local Appointments List
· 2025 Attendance Reports
City of Orange Page 3 of 3 Printed on 4/23/2026
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CITY OF ORANGE
2026 LOCAL APPOINTMENTS LIST
Pursuant to Government Code Section § 54972, the following Local Appointments List is posted on an annual basis by December 31. The list contains names and terms of office for appointments to all regular Boards, Commissions, and Committees which are appointed by the City Council.
Note: The names on this list are subject to change based on term expirations and resignations that occur during the year. Further information regarding these vacancies may be obtained by calling the City Clerk’s Office at (714) 744-5500 or visiting the City’s website: www.cityoforange.org.
AUDIT 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 have business-related experience, and the designation of Certified Public Accountant (CPA) is desirable.
Duties are set forth in Section 2.50.020 of the Orange Municipal Code.
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be two (2) years.
Meetings: Meetings are held the first Thursday of February and October at 5:30 p.m.
Name Appointed/Reappointed Term Expiration Date
Chris Horton 11-26-2024/4-28-2026 6-30-2028
Andrew Li 11-26-2024/4-28-2026 6-30-2028
Brian Wilterink 11-26-2024/4-28-2026 6-30-2028
Caleb Brown 1-28-2025 6-30-2027
Carolyn Cavecche 1-28-2025 6-30-2027
VACANT 6-30-2028 (to fill unexpired term)
VACANT 6-30-2028 (to fill expired term)
COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) PROGRAM COMMITTEE Qualifications: The CDBG Program Committee shall consist of seven (7) members whose primary residence is in the City of Orange. Members should show an interest in and have knowledge of housing and community development issues, especially as they relate to affordable housing and public service for residents of low and moderate income.
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be two (2) years.
Meetings: Meetings are held on the second Thursday of February and March at 6:00 p.m.
Name Appointed/Reappointed Term Expiration Date
Jonathan St. Clair 6-8-21/4-13-22/4-23-24/4-28-26 6-30-2028 Kim Le 6-8-2021/2-14-2023/4-8-2025 6-30-2027
Connie Benson 6-8-2021/2-14-2023/4-8-2025 6-30-2027
Elaine Muselli 2-14-2023/4-8-2025 6-30-2027
Chrissy Vaughn 3-14-2023/4-8-2025 6-30-2027
Pat Buttress 5-14-2024*/4-8-2025 6-30-2027
VACANT 6-30-2027 (to fill unexpired term)
*Appointed in 2024 to fill unexpired term
Draft
899
City of Orange 2026 Local Appointments List
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.
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be 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 8-8-2017/2-9-2021/4-8-2025 6-30-2029 Jerico Farfan 7-13-2021/4-8-2025 6-30-2029
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.
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be 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
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
Al Zelinka 12-9-2025 6-30-2027
VACANT 6-30-2027 (to fill unexpired term)
VACANT
Draft
900
City of Orange 2026 Local Appointments List
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)
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also 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
Susie Huber 7-14-2020/2-14-2023/4-28-2026 6-30-2029
Kathleen Stevens 6-13-2023**/4-23-2024 6-30-2027
Rebecca Martinez 1-12-2016/2-9-2021/5-10-2022*/
5-13-2025
6-30-2027
Ariana Cazares 5-13-2025*** 6-30-2027 (to fill unexpired term) Sharon Zimmerman 8-12-2025 6-30-2028
*Reappointed in 2021 for term serving 2019-2022
**Appointed in 2023 to fill unexpired term
***Appointed in 2025 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.
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also 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 6-8-2021/4-8-2025 6-30-2029
Adam Litwin 6-8-2021/4-8-2025 6-30-2029
Eugene Fields 6-8-2021/4-8-2025 6-30-2029
Christopher Ahlswede 6-14-2022/4-28-2026 6-30-2030
James Kushon 3-14-2023*/4-8-2025 6-30-2029
Brandy Romero 7-1-2025 6-30-2029
Perla Lozano 4-28-2028 6-30-2029 (to fill unexpired term) *Appointed in 2023 to fill unexpired term
Draft
901
City of Orange 2026 Local Appointments List
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) If appointed, Commissioners are required to file Form 700 pursuant to California Government Code Section 87200. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be 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 2-12-2019/4-12-2022/4-28-2026 6-30-2030
Alison Vejar 3-14-2023*/4-8-2025 6-30-2029
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) VACANT 6-30-2030 (to fill expired term)
*Appointed in 2023 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) If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be 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*
*Terms were randomly chosen to be staggered upon Commission establishment Draft
902
City of Orange 2026 Local Appointments List
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.
If appointed, members are required to file Form 700. AB1234 Ethics Education and AB1661 Sexual Harassment Avoidance Training certificates are also required.
Terms of Office: The term of office shall be 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 6-8-2021/4-8-2025 6-30-2029
Joseph Barbeito 3-14-2023 6-30-2027
Sean Chavarria 6-25-2024 6-30-2028
Doug Redding 2-25-2025 6-30-2027 (to fill unexpired term) Steve Freeman 3-10-2026 6-30-2027 (to fill unexpired term) Alexia Deligianni-Brydges 4-14-2026 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 twoyear interval.
Revised 4/21/2026
Draft
903
Audit Advisory Committee
Member Feb 06, 2025 Apr 03, 2025 May 08, 2025 Jun 03, 2025 Oct 02, 2025 TOTALS Chris Horton P P P P C 100.0%
Brian P Wilterink P P P P C 100.0%
Jack Schroeder A P A P C 50.0%
Andrew P Li P P P P C 100.0%
Jeff Grampp P P P P C 100.0%
Garrett Smith (Treasurer) P P P P C 100.0%
Carolyn Cavecche P P P P C 100.0%
Caleb E Brown P P P P C 100.0%
Present: 7 8 7 8 0 93.75%
Absent: 1 0 1 0 0 6.25%
Excused: 0 0 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2025
904
Community Development Block Grant Program Committee
Member Feb 13, 2025 Mar 13, 2025 Oct 16, 2025 TOTALS
Jonathan M St. Clair P P P 100.0%
Pat I Buttress P P P 100.0%
Elaine J Muselli P P P 100.0%
Kim Le P P P 100.0%
Connie Benson P P P 100.0%
Chrissy Vaughn P P P 100.0%
Melissa M Mikail A A P 33%
Present: 6 6 6 90.0%
Absent: 1 1 0 10.0%
Excused: 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2025
905
Design Review Committee
Member 1/1 1/15 2/5 2/19 3/5 3/19 4/2 4/16 5/7 5/21 6/4 6/18 7/2 7/16 8/6 8/20 9/3 9/17 10/1 10/15 11/5 11/19 12/3 12/17 TOTALS Robert Grosse C C C C P C C P P C P P C C P P E C C P C A C P 81.82% Greg Ledesma C C C C E C C E P C P P C C E P E C C E C A C E 36.36% Maryanne Skorpanich C C C C P C C P E C P P C C P P P C C P C A C P 80.0% Michael V Lopez C C C C E C C P P C P E C C E P P C C A C P C P 63.64% Adrienne J Gladson C C C C P C C P P C P P C C P P P C C P C P C P 100.0% Anne McDermott C C C C P C C P P C P P C C P P P C C P C P C P 100.0% Jerico Farfan C C C C P C C P P C P A C C E P P C C P C P C P 80.0%
Present: 0 0 0 0 5 0 0 6 6 0 7 5 0 0 4 7 5 0 0 5 0 4 0 6 81.08%
Absent: 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 1 0 3 0 0 6.76% Excused: 0 0 0 0 0 0 0 0 1 0 0 1 0 0 3 0 2 0 0 1 0 0 0 1 12.16% * P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2025
906
Investment Advisory Committee
Member Apr 23, 2025 Jul 23, 2025 Oct 22, 2025 TOTALS
Garrett Smith (Treasurer) C P P 100.0%
Jordan Prell C P P 100.0%
Mark Mittmann C P A 50.0%
Paul M Mittmann C E P 50.0%
Richard Madrigal C P P 100.0%
Adam D Carr C P P 100.0%
Present: 0 5 5 83.33%
Absent: 0 0 1 8.33%
Excused: 0 1 0 8.33%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2025
907
Orange Public Library Board of Trustees
Member 1/27 2/24 3/17 4/21 5/19 6/16 *7/21 7/21 8/18 9/15 10/20 11/27 12/15 TOTALS Peggy Calvert ** A N/A N/A N/A N/A N/A N/A C N/A N/A N/A N/A N/A 0.0% Kathleen D Stevens P P P P C C E C P P P P C 88.89%
Katie Montgomery*** P P E P C C N/A C N/A N/A N/A N/A N/A 75.0% Rebecca Martinez P P P P C C P C E P P P C 83.33%
Susie Huber P P P P C C P C P P E P C 88.89%
Ariana Cazares**** N/A N/A N/A N/A C C P C P P P P C 100.0% Sharon H Zimmerman***** N/A N/A N/A N/A N/A N/A N/A C P P P P C 100.0%
Present: 4 4 3 4 0 0 3 0 4 5 4 5 0 100.0%
Absent: 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0%
Excused: 0 0 0 0 0 0 0 0 0 0 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
* 7/21 = Adjourned Regular Meeting
** Peggy Calvert resigned 02/03/2025
*** Katie Montgomery term expired 06/30/2025
**** Ariana Cazares appointed 05/13/2025
***** Sharon Zimmerman appointed 08/13/2025
City of Orange - Member Attendance Report - 2025
908
Park Planning and Community Events Commission
Member Jan 21, 2025 Mar 18, 2025 May 20, 2025 Jul 15, 2025 Sep 16, 2025 Oct 21, 2025 TOTALS James E Kushon C C P C E P 66.67%
Erika De Vries** C C P N/A N/A N/A 100.0%
Christopher H Ahlswede C C P C A P 66.67%
Steve Freeman C C P C P P 100.0%
Eva Perez C C P C P E 33.33%
Adam Litwin C C P C E E 33.33%
Eugene Fields C C A C P E 33.33%
Brandy Romero*** N/A N/A N/A C P P 100.0%
Present: 0 0 6 0 4 4 87.5%
Absent: 0 0 1 0 1 0 12.5%
Excused: 0 0 0 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
** Erika De Vries term completed June 30, 2025
*** Brandy Romero appointed July 1, 2025
City of Orange - Member Attendance Report - 2025
909
Planning Commission
Member 1/6 1/20 2/3 2/20 3/3 3/17 4/7 4/21 5/5 5/19 6/2 6/16 7/7 7/21 8/4 8/18 9/4 9/15 10/6 10/20 11/3 11/17 12/1 12/15 TOTALS Timothy McCormack C P C P C P A P P C P P P P C P C P P C P C P C 93.33% Ruby Maldonado C P C P C P P P P C P P P P C P C E P C E C P C 86.67% Shannon J Tucker C P C P C P P E P C P E P P C P C P P C P C P C 86.67% Isaiah Leslie C P C P C P P P P C P A P P C P C P P C P C E C 86.67% Alison N Vejar C P C P C P P P P C P P P P C E C P P C P C P C 100.0% Rick Martinez C P C P C P P P P C P P P P C E C P P C P C E C 86.67% David Vazquez C P C P C P P E P C P E P E C E C P P C P C E C 66.67%
Present: 0 7 0 7 0 7 6 5 7 0 7 4 7 6 0 4 0 6 7 0 6 0 4 0 89.11%
Absent: 0 0 0 0 0 0 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 0 1.98% Excused: 0 0 0 0 0 0 0 2 0 0 0 2 0 1 0 0 0 0 0 0 1 0 3 0 8.91% * P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2025
910
Santiago Creek Commission
Member Jan 22, 2025 Apr 23, 2025 Jul 23, 2025 Oct 22, 2025 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 P 100.0%
Robert R Baca P P P P 100.0%
Michael J Knight P P P P 100.0%
Pamela M Galera P P P P 100.0%
Present: 7 7 7 7 100.0%
Absent: 0 0 0 0 0.0%
Excused: 0 0 0 0 0.0%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
City of Orange - Member Attendance Report - 2025
911
Traffic Commission
Member Feb 12, 2025 Apr 09, 2025 Jun 11, 2025 Aug 13, 2025 Oct 08, 2025 Dec 10, 2025 TOTALS Joseph Barbeito P P P P P P 100.0%
Sean P Chavarria P P A P P P 83.33%
Seimone Jurjis A P E P E P 50.0%
Adam Feliz P P P P P P 100.0%
AJ Ricci P P P P P P 100.0%
Matthew P Hamilton P P P P P P 100.0%
Douglas R Redding** N/A P P P P P 100.0%
Present: 5 7 5 7 6 7 92.5%
Absent: 1 0 1 0 0 0 5.0%
Excused: 0 0 0 0 1 0 2.5%
* P = Present
* A = Absent
* E = Excused
* C = Canceled
** Douglas Redding appointed 02/26/2025
City of Orange - Member Attendance Report - 2025
912
Agenda Item
Orange City Council
Item #: 9.1. 4/28/2026 File #: 26-0147
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director
1. SUBJECT
Public Hearing to consider a request to subdivide an existing vacant site and construct 15 detached three-story residential dwellings at 715 W. Fletcher Avenue and finding of California Environmental Quality Act (CEQA) exemption (ENT25-0015)
2. SUMMARY
The applicant proposes to subdivide an existing vacant site and construct 15 detached three-story residential dwellings, each with private two-car garages, and nine additional off-street surface parking spaces. One of the proposed residential units will be restricted to a very low-income household, which under State Density Bonus Law, allows an increase to the project baseline density of four units.
3. RECOMMENDED ACTION
1. Conduct and close the Public Hearing.
2. Adopt Resolution No. 11662. A Resolution of the City Council of the City of Orange approving ENT25-0015 (Tentative Tract Map, Major Site Plan Review, and Administrative Design Review), a request to subdivide an existing 0.72-acre vacant site to construct 15 detached three-story residential dwellings at 715 W. Fletcher Avenue.
3. Find the request categorically exempt from the California Environmental Quality Act (CEQA) in accordance with section 15332 (Class 32-In-Fill Development Projects) of the State CEQA Guidelines.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Not applicable.
6. DISCUSSION AND BACKGROUND
The project site is currently vacant and is located on a segment of Fletcher Avenue characterized by residential uses and an elementary school on the north side of the street, and industrial uses to the south. The site is flanked on three sides by multi-family residential development.
The proposed project utilizes the Small Lot Subdivision provisions of the Orange Municipal Code to develop a detached single-family development in a Multi-family Residential (R3) zone in lieu of a City of Orange Page 1 of 3 Printed on 4/23/2026
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Item #: 9.1. 4/28/2026 File #: 26-0147
develop a detached single-family development in a Multi-family Residential (R3) zone in lieu of a traditional multi-family project. The subdivision requires approval of a tentative tract map. While the General Plan designation allows up to 11 units on the site, under State Density Bonus law the inclusion of an affordable unit allows a 30 percent density bonus, resulting in a total of 15 units.
The units are arranged along the perimeter of the site, oriented around a private T-shaped driveway that provides fire access and circulation, with primary access from W. Fletcher Avenue. The project includes development standard reductions pursuant to State Density Bonus Law, including reduced front and rear yard setbacks, reduced open space dimensions, and modified parking and driveway standards. Detailed project information is provided in Attachment 4 to this report.
The proposed units are designed in a Spanish Colonial Revival architectural style, with enhanced treatment for the two street-facing units. Staff finds the project to be compatible with the surrounding two-story multi-family development to the north, east, and west that reflect a variety of contemporary architectural styles with high roof pitches.
The project contributes to the City’s Regional Housing Needs Assessment (RHNA) goals by adding both market-rate and one affordable unit to the City’s housing stock.
7. ADVISORY BOARD ACTION
Staff Review Committee:
The Staff Review Committee (SRC) reviewed the project and on December 17, 2025, the SRC recommended approval of the project to the Planning Commission.
Planning Commission:
On February 19, 2026, the Planning Commission reviewed and recommended City Council approval of ENT25-0015 by a vote of 7-0, for the Tentative Tract Map, Major Site Plan Review, and Administrative Design Review.
8. ENVIRONMENTAL REVIEW
The proposed project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines 15332 (Class 32 - In-Fill Development Projects) because the project is consistent with the applicable General Plan designation and zoning designation; the proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; the project site has no value was a habitat for endangered, rare, or threatened species; approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and the site can be adequately served by all required utilities and public services. No public review is required.
9. ATTACHMENTS
· Attachment 1 Resolution No. 11662
· Attachment 2 Vicinity Map
· Attachment 3 Applicant Project Narrative Letter
· Attachment 4 Project Plans
· Attachment 5 Conceptual Landscape Plan
City of Orange Page 2 of 3 Printed on 4/23/2026
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Item #: 9.1. 4/28/2026 File #: 26-0147
· Attachment 6 Tentative Tract Map 19429
· Attachment 7 Site Photos
· Attachment 8 Legal Memo for State Density Bonus Law
· Attachment 9 CEQA Class 32 Categorical Exemption Memo · Attachment 10 Planning Commission Staff Report of February 19, 2026 · Attachment 11 Planning Commission Minutes of February 19, 2026 City of Orange Page 3 of 3 Printed on 4/23/2026
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Agenda Item
Orange City Council
Item #: 9.1. 4/28/2026 File #: 26-0147
TO: Honorable Mayor and Members of the City Council
THRU: Jarad Hildenbrand, City Manager
FROM: Russell Bunim, Community Development Director
1. SUBJECT
Public Hearing to consider a request to subdivide an existing vacant site and construct 15 detached three-story residential dwellings at 715 W. Fletcher Avenue and finding of CEQA Exemption (ENT25- 0015)
2. SUMMARY
The applicant proposes to subdivide an existing vacant site and construct 15 detached three-story residential dwellings, each with private two-car garages, and nine additional off-street surface parking spaces. One of the proposed residential units will be restricted to a very low-income household, which under State Density Bonus Law, allows an increase to the project baseline density of four units.
3. RECOMMENDED ACTION
1. Conduct and close the Public Hearing.
2. Adopt Resolution No. 11662. A Resolution of the City Council of the City of Orange approving ENT25-0015 (Tentative Tract Map, Major Site Plan Review, and Administrative Design Review), a request to subdivide an existing 0.72-acre vacant site to construct 15 detached three-story residential dwellings at 715 W. Fletcher Avenue.
3. Find the request categorically exempt from the California Environmental Quality Act (CEQA) in accordance with section 15332 (Class 32-In-Fill Development Projects) of the State CEQA Guidelines.
4. FISCAL IMPACT
None.
5. STRATEGIC PLAN GOALS
Not applicable.
6. DISCUSSION AND BACKGROUND
The project site is currently vacant and is located on a segment of Fletcher Avenue characterized by residential uses and an elementary school on the north side of the street, and industrial uses to the south. The site is flanked on three sides by multi-family residential development.
The proposed project utilizes the Small Lot Subdivision provisions of the Orange Municipal Code to develop a detached single-family development in a Multi-family Residential (R3) zone in lieu of a City of Orange Page 1 of 3 Printed on 4/23/2026
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develop a detached single-family development in a Multi-family Residential (R3) zone in lieu of a traditional multi-family project. The subdivision requires approval of a tentative tract map. While the General Plan designation allows up to 11 units on the site, under State Density Bonus law the inclusion of an affordable unit allows a 30 percent density bonus, resulting in a total of 15 units.
The units are arranged along the perimeter of the site, oriented around a private T-shaped driveway that provides fire access and circulation, with primary access from W. Fletcher Avenue. The project includes development standard reductions pursuant to State Density Bonus Law, including reduced front and rear yard setbacks, reduced open space dimensions, and modified parking and driveway standards. Detailed project information is provided in Attachment 4 to this report.
The proposed units are designed in a Spanish Colonial Revival architectural style, with enhanced treatment for the two street-facing units. Staff finds the project to be compatible with the surrounding two-story multi-family development to the north, east, and west that reflect a variety of contemporary architectural styles with high roof pitches.
The project contributes to the City’s Regional Housing Needs Assessment (RHNA) goals by adding both market-rate and one affordable unit to the City’s housing stock.
7. ADVISORY BOARD ACTION
Staff Review Committee:
The Staff Review Committee (SRC) reviewed the project and on December 17, 2025, the SRC recommended approval of the project to the Planning Commission.
Planning Commission:
On February 19, 2026, the Planning Commission reviewed and recommended City Council approval of ENT25-0015 by a vote of 7-0, for the Tentative Tract Map, Major Site Plan Review, and Administrative Design Review.
8. ENVIRONMENTAL REVIEW
The proposed project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines 15332 (Class 32 - In-Fill Development Projects) because the project is consistent with the applicable General Plan designation and zoning designation; the proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; the project site has no value was a habitat for endangered, rare, or threatened species; approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and the site can be adequately served by all required utilities and public services. No public review is required.
9. ATTACHMENTS
· Attachment 1 Resolution No. 11662
· Attachment 2 Vicinity Map
· Attachment 3 Applicant Project Narrative Letter
· Attachment 4 Project Plans
· Attachment 5 Conceptual Landscape Plan
City of Orange Page 2 of 3 Printed on 4/23/2026
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· Attachment 6 Tentative Tract Map 19429
· Attachment 7 Site Photos
· Attachment 8 Legal Memo for State Density Bonus Law
· Attachment 9 CEQA Class 32 Categorical Exemption Memo · Attachment 10 Planning Commission Staff Report of February 19, 2026 · Attachment 11 Planning Commission Minutes of February 19, 2026 City of Orange Page 3 of 3 Printed on 4/23/2026
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RESOLUTION NO. 11662
A RESOLUTION OF THE CITY COUNCIL OF THE
CITY OF ORANGE APPROVING ENT25-0015
(TENTATIVE TRACT MAP, MAJOR SITE PLAN
REVIEW, AND ADMINISTRATIVE DESIGN
REVIEW), A REQUEST TO SUBDIVIDE AN
EXISTING 0.72-ACRE VACANT SITE TO
CONSTRUCT 15 DETACHED THREE-STORY
RESIDENTIAL DWELLINGS AT 715 W.
FLETCHER AVENUE
APPLICANT: HAMILTON LAND DEVELOPMENT, INC. (MATT HAMILTON) WHEREAS, the City Council of Orange has authority per Orange Municipal Code (OMC) Section 17.08.020 to take action on ENT25-0015 (Tentative Tract Map, Major Site Plan Review, Administrative Design Review); and
WHEREAS, the application for ENT25-0015 (Tentative Tract Map, Major Site Plan Review, Administrative Design Review) was filed by Hamilton Land Development, Inc. (Matt Hamilton) in accordance with the provisions of the OMC; and WHEREAS, the application for ENT25-0015 (Tentative Tract Map, Major Site Plan Review, Administrative Design Review) was processed in the time and manner prescribed by state and local law; and
WHEREAS, the application for ENT25-0015 (Tentative Tract Map, Major Site Plan Review, Administrative Design Review) is Categorically Exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines Section 15332 (Class 32 – In-Fill Development Projects) because the project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations; the proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; the project site has no value as habitat for endangered, rare, or threatened species; approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and the site can be adequately served by all required utilities and public services. There is no environmental public review required for a CEQA categorically exempt project; and WHEREAS, the City Council conducted a duly advertised public hearing on April 28, 2026, at which time all interested persons had an opportunity to testify either in support of or in opposition to the project.
NOW, THEREFORE, BE IT RESOLVED that the City Council approves ENT25-0015 (Tentative Tract Map, Major Site Plan Review, Administrative Design Review), a request to Attachment 1
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2 subdivide an existing 0.72-acre vacant site to construct 15 detached three-story residential dwellings at 715 W. Fletcher Avenue, based on the following findings:
SECTION 1 – FINDINGS
Tentative Tract Map
1. The proposed division of land complies with all requirements of the Subdivision Map Act and Title 16, Subdivisions, of the Orange Municipal Code, and all other resolutions and ordinances of this City, including, but not limited to, requirements concerning area, improvements and design, floodwater drainage control, appropriate improved public roads, sanitary disposal facilities, water supply availability, public safety facilities and environmental protection.
The proposed Tentative Tract Map complies with the requirements of the Subdivision Map Act, Title 16, Subdivisions of the Orange Municipal Code, and all other resolutions and ordinances of this City. The Tentative Tract Map proposes to subdivide an approximately
0.72-acre site into 15 single-family residential lots. Lot sizes will range from 1,370 to 1,760 square feet. The project will utilize the small lot subdivision development standards as outlined in OMC Section 17.14.270, which is allowed in the Multiple-Family Residential (R3) zoning district. The R3 zoning is the same as the existing multi-family residential developments to the north, east, and west. Vehicle access to the site will be provided from a private driveway along the southern property line fronting onto W. Fletcher Avenue. Two dwelling units (Units 1 and 15) will have frontage on W. Fletcher Avenue; however, all private garages will be accessed from the common private driveway.
Major Site Plan Review
1. The project design is compatible with surrounding development and neighborhoods.
The project transforms a vacant and underutilized R3 zoned property into a new small lot subdivision consisting of 15 detached residential dwelling units that incorporates a Spanish Colonial Revival-inspired architectural style to create a uniform identity for the development. New landscaping along the street frontage and trees planted throughout the project site will soften the predominant paved areas of the site. The zoning designation of the project site as well as the adjacent residential development to the north, east, and west is R3.
2. The project conforms to City development standards and any applicable special design guidelines or specific plan requirements.
The project utilizes the City’s Small Lot Subdivision Development Standards as outlined in OMC Section 17.14.270 to allow an alternate “detached” housing typology, as opposed to the traditional multi-family development. Proposed lot sizes will range from 1,370 to 1,760 square feet. The project is also subject to the City of Orange Small Lot Subdivision Guidelines which ensure that new small lot subdivisions fit into the existing neighborhood 920
3 context, promote walkable urbanism through infill development, and achieve high-quality new urban design. The Spanish Colonial Revival-inspired architecture with the variety of landscaping types makes this a high-quality and visually appealing development along that residential corridor (along the northside of W. Fletcher Avenue).
3. The project provides for safe and adequate vehicular and pedestrian circulation, both onand off-site.
Vehicle access to the site will be provided from a private two-way driveway along the southern property line fronting onto W. Fletcher Avenue. Two dwelling units (Units 1 and 15) will have frontage on W. Fletcher Avenue; however, all private garages will be accessed from the common private driveway. The sidewalk along the street frontage will be maintained consistent with the adjacent properties to the east and west, thus maintaining connectivity.
4. City services are available and adequate to serve the project.
The project incorporates design features and conditions of approval that address Code requirements for building and infrastructure systems that maximize safety and ensure adequate utility services to the site. The applicant will be subject to payment of impact fees associated with schools, parks, libraries, sewer, and Sanitation District fees.
5. The project has been designed to fully mitigate or substantially minimize adverse environmental impacts.
The proposed project includes project design features that minimize potential adverse impacts to Transportation/Traffic, Air Quality, Cultural Resources, Tribal Cultural Resources, Geology/Soils, and Noise. The applicant prepared a CEQA (Class 32-In-Fill Development Projects Categorical Exemption) Memo, which is included as Attachment 10 to the staff report. Per the memo, the project meets the criteria for a categorically exempt project and would not have a significant effect on the environment.
Administrative Design Review
1. The project design upholds community aesthetics through the use of an internally consistent, integrated design theme and is consistent with all adopted specific plans, applicable design standards, and their required findings.
The project transforms a vacant and underutilized R3 zoned property into a new small lot subdivision consisting of 15 detached residential dwelling units that incorporates a Spanish Colonial Revival-inspired architectural style to create a uniform identity for the development. New landscaping along the street frontage and trees planted throughout the project site will soften the impervious areas of the site.
2. For infill residential development, as specified in the City of Orange infill residential design guidelines, the new structure(s) or addition are compatible with the scale, massing, 921
4 orientation, and articulation of the surrounding development and will preserve or enhance existing neighborhood character.
The project is developed to the City of Orange Small Lot Subdivision Guidelines which ensure that new small lot subdivisions fit into the existing neighborhood context, promote walkable urbanism through infill development, and achieve high-quality new urban design.
The Spanish Colonial Revival-inspired architecture with the variety of landscaping types makes this a high-quality and visually appealing development along that residential corridor (along the northside of W. Fletcher Avenue).
SECTION 2 - ENVIRONMENTAL REVIEW
The proposed project is categorically exempt from the provisions of the California Environmental Quality Act (CEQA) per State CEQA Guidelines 15332 (Class 32 – In-Fill Development Projects) because the project is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations; the proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; the project site has no value as habitat for endangered, rare, or threatened species; approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and the site can be adequately served by all required utilities and public services. There is no environmental public review required for a CEQA categorically exempt project.
SECTION 3 – CONDITIONS OF APPROVAL
BE IT FURTHER RESOLVED that the following conditions are imposed with the approval:
General:
1. The final conditions of approval shall be reprinted on a dedicated sheet of the construction documents when submitted to the Building Division for the plan check process.
2. The term “applicant” shall refer to the entity that requests approval of this action or any successor in interest to this approval.
3. Except as otherwise provided herein, this Project is approved as a precise plan. After any application has been approved, if subsequent changes or modifications are proposed regarding the location or alteration of any use or structure, architecture, color scheme, etc., a changed plan may be submitted to the Community Development Director for review and approval. If the Community Development Director or designee determines that the proposed change complies with the provisions and the spirit and intent of the approval action, and that the action would have been the same for the changed plan as for the approved plot plan, the Community Development Director may approve the changed plan administratively. Should the modifications be considered substantial, the modifications shall be reviewed by the Planning Commission at a subsequent public meeting. 922
5 4. The applicant agrees, as a condition of City`s approval of ENT25-0015, 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 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 indemnify, defend and hold harmless the City for all costs and expenses incurred in enforcing this provision.
5. The applicant shall comply with all federal, state, and local laws, including all City regulations. Violation of any of those laws in connection with the use may be cause for revocation of this permit.
6. If no use or construction has occurred, the project approval expires 24 months from the approval date. Extensions of time may be granted, if requested in writing in accordance with OMC Section 17.080.060.
Planning Division:
7. The applicant/operator at all times shall provide the required number of parking spaces based on the uses on site. Parking facilities shall be made permanently available and permanently marked for parking purposes only. The storage of materials or other objects on required off-street parking shall be prohibited, in accordance with OMC Section
17.34.030.
8. Prior to building permit issuance, all required parking spaces shall be shown on construction documents as double striped to City standards at the time of approval.
9. Building permits shall be obtained for all construction work, as required by the City of Orange, Community Development Department\`s Building and Safety Services. Failure to obtain the required building permits may be cause for revocation of this entitlement. 923
6 10. In conjunction with construction, all activity will be limited to the hours between 7:00 a.m. and 8:00 p.m. Monday through Saturday. No construction activity will be permitted on Sundays and Federal holidays.
11. In conjunction with the operation of the residences, the property owner shall be responsible to maintain the property to a level deemed adequate by the Community Development Director, or designee. This includes, but is not limited to, the buildings, landscape on-site, recreational facilities, trash areas, signage, utilities, property walls, and gates.
12. Prior to building permit issuance, the applicant shall demonstrate to the satisfaction of the Community Development Director that all mechanical and air conditioning equipment shall be shielded and screened from view from adjacent streets and properties. The screening shall be integrated architecturally with the building.
13. A lighting plan shall be submitted for review and approval for any exterior lighting of common areas or parking areas. Lighting plan shall be designed to confine all direct lighting to the property in a manner meeting the approval of the Community Development Director, or designee. Lighting shall be included for any trail not adjoining a public street that will be utilized in evening hours.
14. A final common area landscaping and irrigation plan shall be submitted for review and approval by the Planning Division and Public Works. Plants and shrubbery chosen for landscaping around common area fencing or public trails shall be such that when installed is of a graduated height, from lower to higher away from the access area so as to prevent blind corners and maintain maximum visibility of surrounding area for those using the access.
15. Prior to building permit issuance, final landscaping plans for the Project shall be designed to comply with the City’s Water Efficient Landscape Guidelines as described in Section IX et al of the City of Orange Landscape Standards and Specifications.
16. Prior to issuance of certificate of occupancy, all parking lot and landscaping improvements shall be completed according to the approved plans and to the satisfaction of the Community Development Director, or designee.
17. Prior to building permit issuance, the applicant shall prepare a final landscaping and irrigation plan consistent with the grading plans, site plans, and the conceptual landscaping plan as proposed for the project for the review and approval of the Community Development Director, or designee.
18. Landscape maintenance shall be performed in such a manner as to allow all trees to retain their full canopy height for screening and full canopy breadth for shade at point of maturity, except as required for public safety purposes.
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7 19. Any new lighting on the premise shall be installed in such a way to direct, control, and screen the lighting to prevent off-site light spillage onto adjoining properties and shall not be a nuisance to any point beyond the exterior boundaries of the property.
20. Any graffiti shall be removed within 72 hours from the time the City of Orange Notice of Violation is received by the applicant/property owner.
21. Prior to building permit issuance, the applicant shall pay all of the applicable Development Impact Fees in accordance with the most current fee schedule at the time of payment (e.g., TSIP fees).
22. Prior to Building Permit issuance, the applicant shall pay any outstanding monies due to the City of Orange for Planning Division entitlement activities related to the Project.
Tentative Tract Map:
23. A Tentative Tract Map shall expire unless recorded within 24 months after tentative map approval (April 28, 2026) and prior to the sale or lease of any parcel, unless the tentative map is extended pursuant to Government Code Section 66452.6.
24. This approval constitutes approval of the proposed subdivision only to the extent that the project complies with the City of Orange’s Subdivision Ordinance and any other applicable zoning regulations. Approval does not include any action or findings as to compliance or approval of the project regarding any other applicable ordinance, regulation, or requirement.
Covenants, Conditions, and Restrictions (CC&R’s):
25. CC&R’s shall be designed and approved by the City for the entire site and address specific responsibilities of the Homeowners Association (HOA). A few specific areas include, but are not limited to:
a. Any aspect that is zoning in nature shall be structured so they cannot be rescinded or modified without City concurrence.
b. Maintenance responsibilities for any private drainage or water quality features. c. Maintenance responsibilities for fuel modification areas. d. Maintenance responsibilities for landscape areas, including parkway median roadway areas, arterial roadway landscaping, common slopes or native open space. e. Identification of HOA community trail or bikeway systems that will be open to the general public through public pedestrian easements, and maintenance of these community trails and bikeways.
f. Detailing enforcement options available to the City to ensure that maintenance is continuously undertaken for common slopes, drainage and water quality, fuel modification zones, trails that are open to the public or other zoning aspects. g. Maintenance of any applicable private streets.
h. Maintenance of any applicable private recreation facilities. 925
8 i. Identification of common open space lots that will be owned or under the control of the HOA and maintenance for open space lots.
j. Ensure, in perpetuity, that private trails and bikeways open to the general public shall not be blocked through the construction of any fencing, gates or other devices that would limit or restrict access to the general public. k. A method to distribute the cost of required maintenance in an equitable manner among the owners of eh dwelling units within the subdivision. l. Ownership and maintenance of common slope areas, including down drain and terrace drains.
m. The CC&R’s shall contain a provision that the Fire Chief can, at his discretion, require further street markings for fire lanes (including red curbing) if signage fails to keep fire lanes clear of vehicles or other obstructions.
26. The CC&R’s shall be recorded prior to or at the same time as the first final map.
27. The CC&R’s shall be subject to a joint review by the Community Development Director, Public Works Director, and City Attorney. The applicant shall be required to pay for the review of the CC&R’s by the City Attorney, Public Works Director and the Community Development Director at City’s hourly billing rate.
28. All lettered parcels not specifically assigned to and accepted by a governmental entity shall remain under the common ownership, maintenance, and liability of the HOA. No lettered lot may be sold separately. Private park facilities within a development area shall be maintained as designed and approved by the City and shall not be altered or removed without specific approval from the City of Orange. These provisions shall be reflected in the CC&R’s.
Density Bonus Agreement:
29. Prior to the building permit issuance, the applicant shall record a Density Bonus Housing Agreement on the parcel(s) designated for the construction of the affordable units. The Density Bonus Housing Agreement shall be drafted by the applicant and reviewed by the Community Development Director and the City Attorney with a recommendation made to the Planning Commission and City Council. The Density Bonus Housing Agreement shall provide for the following conditions governing the initial sale and use of affordable units during the applicable use period:
a. Affordable units shall, upon initial sale, be sold to eligible very low or lower income households at an affordable sales price and housing cost. b. Affordable units shall be initially owner-occupied by eligible very low or lower income households.
c. The initial purchaser of each affordable housing unit shall execute an instrument or agreement approved by the City restricting the sale of the affordable housing unit in accordance with this chapter during the applicable use restriction period. Such instrument or agreement shall be recorded against the parcel containing the 926
9 affordable housing unit and shall contain such provisions as the City may require to ensure continued compliance with this chapter and the state Density Bonus Law. d. Sale Clause. The Density Bonus Housing Agreement shall stipulate that, when the terms of affordability have expired on an affordable unit, the City, its redevelopment agency and/or a non-profit housing organization shall have a first right of purchase option sixty (60) days prior to the affordable unit being advertised on the market.
e. Rental of For-Sale Units. Rental of affordable units shall not be allowed unless the proposed renter(s) qualifies as a very low or lower income household. f. Monitoring of Compliance to Agreement. A monitoring program shall be required, specifying the party responsible for certifying tenant incomes and rent levels or sales price, maintaining the required number of affordable units and each affordable unit’s property, and marketing and filling unit vacancies.
30. Prior to the issuance of a building permit, the applicant shall record a Density Bonus Housing Agreement on the parcel(s) designated for the construction of the affordable units.
The Density Bonus Housing Agreement shall be drafted by the applicant and reviewed by the Community Development Director and the City Attorney with a recommendation made to the Planning Commission and City Council. The Density Bonus Housing Agreement shall provide for the following conditions governing the use of the affordable housing units during the use restriction period:
a. The rules and procedures for qualifying tenants, establishing affordable rent, filling vacancies and maintaining the affordable units for qualified tenants. b. Provisions requiring owners to verify tenant incomes and maintain books and records to demonstrate compliance with this chapter.
c. Provisions requiring owners to submit an annual report to the city, which includes the name, address and income of each person occupying each affordable unit, and which identifies the bedroom size and monthly rent or cost of each affordable unit. d. Determination of Rent. A maximum rent schedule shall be submitted to the Department of Community Development prior to the issuance of an occupancy permit for the affordable units and updated annually on the anniversary date of occupancy.
e. Deposit amount. Total move-in costs for eligible tenants occupying affordable units shall be limited to first month`s rent plus a security/cleaning deposit not to exceed one month`s rent.
f. Upward Mobility Allowance. When a tenant occupying an affordable unit no longer qualifies under the income requirements, verified through the monitoring program required as part of the Density Bonus Housing Agreement, that tenant may then be charged market rate rent. If this occurs, any currently vacant unit of similar type to the affordable unit in question shall then be designated as an affordable unit, and the owner shall immediately attempt to secure tenants in accordance with this chapter. The owner is required to maintain at all times during the use restriction the minimum number of affordable units identifies in the Density Bonus Housing Agreement.
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10 g. Subletting of Affordable Units. No subletting of designated affordable units shall be allowed unless the following conditions are met:
i. Written permission is obtained from the Community Development Director. ii. The sublessee qualifies as a very low or lower income household. iii. The rent collected shall not exceed the maximum affordable rent.
Fire Department:
31. Automatic Fire Sprinklers required. Deferred submittal for plan and permit by licensed C16 contractor. Permit is required prior to water service approval.
32. Plans submitted for Building Plan Review shall comply with the California Fire Code as amended by the City and as frequently amended and in effect at the time of application for Building Permit.
33. Onsite fire department access will require reciprocal easement recording prior to issuance of Rough Grading Permit and shall be reviewed by Fire prior to approval. The easement shall include reciprocal access amongst all properties. Recording shall include a Declaration of Restrictions in perpetuity, to include impact and liability being created by the shared obligation of all property owners and future individuals with interest to each property. All maintenance of, including but not limited to roadways, utility mains, fire lane signage, markings, fire lines, fire hydrants testing and service, and all equipment thereto within the reciprocal easement.
Police Department – Crime Prevention Bureau:
34. Security and design measures that employ defensible space concepts shall be utilized in development and construction plans. These measures incorporate the concepts of Crime Prevention through Environmental Design (CPTED), which involves considerations such as placement and orientation of structures, access and visibility of common areas, placement of doors, windows, addressing, and landscaping. CPTED promotes public safety, physical security and allows citizens the ability to monitor activity. It is based on five concepts to provide non-invasive and permanent measures to prevent and reduce crime: territoriality, natural surveillance, access control, activity support, and maintenance.
The project shall also comply with the requirements contained in the City of Orange Municipal Code Chapter 15.52, Building Security Construction Standards reference Ordinance #6-22.
Building and Safety Division:
35. Prior to building permit issuance, the construction documents shall provide the “Green Code Checklist”. And the green measures associated with the project shall be clearly specified as to what sheet of plans are shown.
36. Prior to building permit issuance, a Soils Report is required. 928
11 37. Prior to building permit issuance, the plans shall show that the climate zone is Zone 8.
38. Beginning on January 1, 2026, each California City is required by State law to enforce the 2025 Edition of California Building Standards Codes (a.k.a., Title 24 of the California Codes of Regulations). All projects submitted before or on December 22, 2025, are permitted to comply with the 2022 Edition of the California Building Standards Code.
39. Prior to building permit issuance, the plans shall provide the design data on the first sheet of the construction documents:
a. Occupancy groups
b. Type of construction
c. Sprinkler building
d. Floor area
e. Height
f. Number of stories
g. Allowable floor area
h. APNs (assessor parcel numbers)
40. Prior to building permit issuance, the applicant shall provide Energy Conservation – Title 24 energy forms and calculations:
a. Certificate of Compliance Documents
41. Projections of dwelling units and accessory buildings:
a. With an automatic residential fire sprinkler protection are not permitted less than 2 feet to the property line and are required to be 1 hour fire rated on the underside with a fire separation distance between 2 feet and 3 feet. [CRC Table R302.1 (2)].
42. Walls of dwelling units and accessory buildings:
a. With an automatic residential fire sprinkler protection with a fire separation distance less than 3 feet are required to have a full one hour rating. [CRC Table R302.1 (2)]
43. Openings are not permitted less than 3 feet to the property line. In without an automatic residential fire sprinkler protection openings are limited to 25 percent the wall area when fire.
44. See the link below, it may provide you the general info for residential permit applications. https://www.cityoforange.org/home/showpublisheddocument/1670/63770755484347000 0 45. Prior to building permit issuance, the construction documents shall include a Utility Plan with dimensions demonstrating the locations for proposed utilities such as sewer. 929
12 46. Periodic special inspection is required for wood shear walls, shear panels, and diaphragms, including nailing, bolting, anchoring, and other fastening to components of the seismic/ wind force resisting system. Special inspection by a deputy inspector is required where the fastener spacing of the sheathing is 4” o.c. or less. [CBC 1705.12.1 & CBC 1705.13.2]
47. Provide the following Electric-Ready requirements on plan: [150] a. Heat Pump Space Heater Ready
b. Electric Cooktop Ready
c. Electric Clothes Dryer Ready
d. Energy Storage System (ESS) Ready
48. R327.1.4 Doorbell buttons. Doorbell buttons or controls, when installed, shall not exceed 48 inches (1219.2 mm) above exterior floor or landing, measured from the top of the doorbell button assembly. Where doorbell buttons integrated with other features are required to be installed above 48 inches (1219.2 mm) measured from the exterior floor or landing, a standard doorbell button or control shall also be provided at a height not exceeding 48 inches (1219.2 mm) above exterior floor or landing, measured from the top of the doorbell button or control.
Public Works – Development Services:
49. Pavement restorations on streets under Moratorium or with a Pavement Condition Index of 75 or greater, shall be done per Std Plan 125, Note 17 of the Encroachment Permit. W.
Fletcher Ave. does currently have a PCI greater than 75.
50. Any soil imported or exported shall require a Transportation Permit from Public Works Traffic Division.
51. An approval by the City Council is required prior to import or export of soil exceeding 30,000 cubic yards. A dirt haul route shall be approved by the City Council and the travel path is subjected to pavement deterioration evaluation. (O.M.C. 10.67.030(B)).
52. Upon submittal of grading plan for plan check, the applicant shall make a deposit to cover plan check and inspection services related to the grading activities.
53. The grading plan shall detail all of the locations where retaining walls will be constructed.
Geometric detail of retaining walls shall be shown on the grading plan, including material type, dimensions, backfill, and subdrains. A building permit is also required for retaining walls over 4 feet in height measured from the bottom of the footing to the top of the wall prior to construction. Structural details and design calculations shall be submitted as a separate document and will be reviewed and permitted by City Building Division.
54. Show all sewer and storm drain lines on the Grading Plan. Other utility lines, such as water lines, may also be shown on Grading Plan for reference. 930
13 55. The applicant shall submit a grading plan in compliance with City standards for review and approval by the Public Works Director. All grading and improvements on the subject property shall be made in accordance with the Manual of Grading and Standard Plans and Specifications to the satisfaction of the Public Works Director. The applicant may be required to include Phased Erosion and Sediment Control Plans, Site Demolition Plan, and Utility Plan as parts of the grading plan.
56. Site grading shall conform to the latest California Building Code Section 1804. The ground immediately adjacent to the foundation shall be sloped away from the building at a slope of 5% for pervious surfaces, and 2% for impervious surfaces, at a minimum distance of 10 feet.
57. The contractor shall obtain a Grading Permit from Public Works Department prior to start of any site demolition, clearing and grubbing, and grading.
58. A sewer capacity analysis shall be required to ensure sufficient sewer service can be provided.
59. Submit a hydrology report for 10- and 100-year rainstorms. Show that 100-year flood elevation level to confirm there is a one-foot freeboard to the building finished floor level.
60. The final map and CC&R’s shall be recorded (model homes excluded) prior to issuance of building permits or sale or lease of any parcels.
61. The CC&R’s shall be subject to a joint review by the Community Development Director, Public Works Director, and City Attorney. The applicant shall be required to pay for the review of the CC&R’s by the City Attorney, Public Works Director and the Community Development Director at City’s hourly billing rate.
62. All works within public right-of-way and public utility easements will require Encroachment Permits, including sidewalk and driveway constructions and utility main and lateral constructions.
63. All public infrastructures, including street sections, sidewalk, driveway apron, and utilities shall comply with City of Orange Standard Plans and Specifications.
64. Utilities serving the development, such as electric, cable television, street lighting and communication shall be installed underground, completed and approved by the appropriate utility provider.
65. Driveway aprons shall conform to Public Works Standard Plan 115 for commercial driveway with ADA accessibility.
66. Repair any cracked, uneven, or damaged public sidewalk, curb and gutter along property frontage.
931
14 67. The applicant shall extend the sewer main with a manhole at the upstream end, with an additional 4 feet stub out prepared for any future extension. The extended sewer main shall be dedicated to City of Orange.
68. Sanitary sewer system connecting from the buildings to public mainline shall be private and maintained by the property owner.
69. Show all structural BMPs for water quality purpose on Grading Plan. Water quality features shown on the Grading Plan must match WQMP.
70. Prior to building foundation construction, a Certificate Letter of Line and Grade shall be submitted to Public Works Construction Inspector demonstrating that the site grading and pad elevation are completed according to the grading plan.
71. Arborist report and tree removal permit will be required prior to any tree removal.
72. Prior to issuance of building permits, the applicant shall submit an address number request, including an addressing plan, to Public Works Department for review and approval.
73. A sewer capacity analysis report, stamped and signed by a registered Civil Engineer, shall be required to ensure sufficient sewer service downstream of the project site.
74. Prior to building permit issuance, the applicant shall submit to the Public Works Department an address number request, including an addressing plan for the buildings within the property for review and approval by the Addressing Committee.
75. Additional comments will be provided during the plan check process.
Water Division:
76. Plans submitted during plan check must show that the minimum separation requirements are met and that each of the various designer’s plan sets match. The applicant’s consultant preparing the improvement and utility plans must coordinate their plans with the consultants preparing the landscape, architectural, surface water quality management, fire master and/or fire suppression plans so that all designs are consistent.
77. Prior to issuance of encroachment permit, the applicant must prepare and provide product material submittals consistent with the water improvement plans for all proposed public water system facilities to the Water Division per the City of Orange Standard Specifications and Plans For the Construction of Water System for review and approval.
78. Prior to issuance of any grading permit or building permit, the applicant must submit improvement plans to the Water Division for review and approval for any new fire hydrants, domestic water services, fire services, landscape services, backflow prevention devices, and any other proposed improvements or relocations affecting the public water system facilities.
932
15 79. Prior to issuance of any grading permit, the applicant must construct all public and/or private improvements to the satisfaction of the Water Division. The applicant may be required to enter into an agreement with the City of Orange, and post security in a form and amount acceptable to the City Engineer and/or Water Division to ensure construction of said improvements.
80. Prior to issuance of any grading permit or building permit, the applicant will be responsible for the installation and/or relocation of the proposed or existing public water system facilities to a location and of a design per the improvement plans approved by the Water Division.
81. Prior to issuance of building permit, the Water Division will approve the type and location of landscaping services, fire services, and backflow prevention devices for proposed City services.
82. Prior to issuance of building permit, the applicant must submit construction documents must show that the installation of sewer mains in the vicinity of water mains is done per the Department of Public Works Water Division Standard No. 113 and will be approved by the Water Division.
83. Prior to issuance of building permit, the applicant must submit construction documents must show that a six foot minimum horizontal clearance and a one foot minimum vertical clearance would be maintained between City water mains, laterals, services, meters, fire hydrants and all other utilities except sewer. The Water Division will review and approve the construction documents.
84. Prior to issuance of building permit, the applicant must submit construction documents that show that an eight-foot minimum clearance is provided between City water mains, laterals, services, meters, fire hydrants, signs, or trees or other substantial shrubs and plants as required by the Water Division. The Water Division will review and approve the construction documents.
85. Prior to issuance of building permit, construction documents must show that permanent signs, awning, surface water quality management features or other structures are not built over water mains, laterals, services, meters, or fire hydrants as required by the Water Division.
86. Prior to approval of a water improvement plan, the applicant must satisfy all water main connection, plan check, and inspections charges as determined by the Water Division.
Surface Water Quality:
87. Prior to recordation of the final map, a copy of the project’s CC&Rs shall be provided to the Public Works Department for review and approval that includes requirements for maintenance and funding of the project’s structural and treatment water quality best management practices as approved by the City in the project’s Water Quality Management Plan (WQMP).
933
16 88. The project applicant shall maintain all structural, treatment and low impact development best management practices (BMPs) at the frequency specified in the approved WQMP.
Upon transfer of ownership or management responsibilities for the project site, the applicant shall notify the City of Orange Public Works Department of the new person(s) or entity responsible for maintenance of the BMPs.
89. Prior to issuance of building permits, the applicant shall review the approved WQMP and grading plan to ensure the structure’s downspouts or drainage outlet locations are consistent with those documents. Copies of the building or architectural plans specifically showing the downspouts and drainage outlets shall be submitted to the Public Works Department for review.
90. Prior to issuance of certificates for use of occupancy or final signoff by the Public Works Department, the applicant shall demonstrate to the satisfaction of Public Works, that the preparer of the WQMP has reviewed the BMP maintenance requirements in Section V of the WQMP with the responsible person and that a copy of the WQMP has been provided to that person. A certification letter from the WQMP preparer may be used to satisfy this condition.
91. Prior to issuance of certificates for use and occupancy, the applicant shall demonstrate the following to the Public Works Department:
a. That all structural and treatment control BMPs described in the Project WQMP have been constructed and installed in conformance with the approved plans and specifications.
b. That the applicant is prepared to implement all non-structural BMPs described in the Project WQMP.
c. That an adequate number of copies of the project’s approved final Project WQMP are available for the future occupiers.
92. Prior to issuance of grading permits the applicant shall submit a Priority Project WQMP for review and approval to the Public Works Department that:
a. Prioritizes the use of Low Impact Development principles as follows: preserves natural features; minimizes runoff and reduces impervious surfaces; and utilizes infiltration of runoff as the method of pollutant treatment. Infiltration BMPs to be considered include the use of permeable materials such as concrete and concrete pavers, infiltration trenches, infiltration planters, and other infiltration BMPs as applicable.
b. Incorporates the applicable Site Design, Routine Source, Structural Control and Low Impact BMPs as defined in the Model Water Quality Management Plan and Technical Guidance Document.
c. Maintains the hydrologic characteristics of the site by matching time of concentration, runoff, velocity, volume and hydrograph for a 2-year storm event. 934
17 d. Minimizes the potential increase in downstream erosion and avoids downstream impacts to physical structures, aquatic and riparian habitat. e. Generally describes the long-term operation and maintenance requirements for structural and Treatment Control BMPs.
f. Identifies the entity or employees that will be responsible for long-term operation, maintenance, repair and or replacement of the structural and Treatment Control BMPs and the training that qualifies them to operate and maintain the BMPs. g. Describes the mechanism for funding the long-term operation and maintenance of all structural and Treatment Control BMPs.
h. Includes a copy of the forms to be used in conducting maintenance and inspection activities.
i. Meets recordkeeping requirements (forms to be kept for 5 years). j. Includes a copy of the form to be submitted annually by the project owner to the Public Works Department that certifies that the project’s structural and treatment BMPs are being inspected and maintained in accordance with the project’s WQMP.
Traffic Division:
93. Prior to issuance of certificate of occupancy, the applicant will be responsible for paying Transportation Systems Improvement Program (TSIP) fees based on the proposed net change in land use. Final TSIP fees will be calculated using the final approved building plans and current rates at the time of building permit issuance. TSIP fees can be found on the City’s website.
ADOPTED this ____ day of ____________________, 2026
Daniel R. Slater, Mayor, City of Orange
ATTEST:
Pamela Coleman, City Clerk, City of Orange
APPROVED AS TO FORM:
Nathalie Adourian, City Attorney, City of Orange
935
18 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 , 2026 by the following vote:
AYES: COUNCILMEMBERS:
NOES: COUNCILMEMBERS:
ABSENT: COUNCILMEMBERS:
Pamela Coleman, City Clerk, City of Orange
936
J:\GisProjects\DRC_PC_Staff_reports\Fletcher 15 Residential 2/9/2026
Source: City of Orange (2026)
0 100 200
Feet
.
N
B
A
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Fletcher Elementary
W FLETCHER AV
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Subject
Parcels
R3
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R2-6
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COUNTY
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Subject
Parcels
Legend
Parcels
Subject Parcels
CITY OF ORANGE
FLETCHER 15 RESIDENTIAL PROJECT
VICINITY MAP
Project Name:ENT25-0015
(Tentative Tract Map,
Major Site Plan Review and
Administrative Review)
Address: 715 W. Fletcher Ave. Zoning: R3
Attachment 2
937
hamiltonldi.com 1635 Ohms Way, Suite A, Costa Mesa, CA 92627 949-791-8401 July 21, 2025
Mr. Ryan Agbayani
Senior Planner
City of Orange
300 E. Chapman Ave.
Orange, CA 92866
Re: Fletcher 15 - Proposed Mixed-Income Residential Project 705-715 West Fletcher Avenue
Dear Ryan,
On behalf of ADC Fletcher 15, LLC, I am pleased to submit the complete entitlement submittal for the proposed small lot subdivision project at the above referenced property. In accordance with our previous correspondence, the project’s SB330 application was deemed complete last month securing the vesting rights. We recently closed escrow on the property and look forward to perfecting all approvals and permits necessary to start construction.
The property is a .72 acre vacant parcel previously occupied by a street sweeping company. All structures were recently demolished and the site is essentially a flat pad with no trees or vegetation. The property is surrounded to the east, west and north by residential townhomes with a similar density as the proposed project. The south side of the property is bounded by Fletcher Avenue with the Fletcher Basin beyond.
The proposed project will feature 15 new single-family homes on individual small lots, one of which will be set aside for a very low income household (50% AMI). The proposed entry level three story homes are anticipated to be approximately 1,750 square feet with four bedrooms and a two car garage and will be geared towards growing families. The project will be a common interest development with a homeowners association owning and managing the private streets and walkways, common open space, common landscape areas and guest parking spaces.
The baseline density for the project under the City’s land use designation of Low Medium Density Residential (LMDR) is 11 homes (.72 net acres * 15 du/acre). The proposed set aside is for 9% of the homes (9% * 11 homes = 1). The affordable home will be set-aside for a very low income household (50% AMI) which qualifies the project for a density bonus of 30%, or 4 homes, in accordance with state density bonus law and City of Orange municipal code section
17.15. The proposed project qualifies for an unlimited number of reductions and waivers to zoning standards in accordance with state density bonus law and City code. These reductions and waivers are listed on the cover sheet of the entitlement plan set and are further outlined in the accompanying legal opinion letter from our land use attorney.
The project also qualifies for one incentive/concession under state density bonus law: The requested project incentive is expedited processing of the entitlement application.
It is anticipated that the project will be constructed in one phase, with all homes being sold and occupied within a three to four month period. Building the project in one phase should minimize any impacts associated with construction noise and traffic.
We look forward to continuing to work with the City of Orange on this proposed mixed-income housing project.
Please contact me if you have any questions or need additional information.
Sincerely,
Matt Hamilton, PE
ADC Fletcher 15, LLC
Attachment 3
938
5.0 5.0
13.0 8.5
13.0 8.0
7.0 8.0
22.6 8.5
13.0 8.0
7.0 8.0 20.0 10.0
24.0 20.0
9.0 P.Y.
7.6 P.Y. P.Y. 120'
260' FLETCHER AVENUE 26.0 30.0 EXISTING SIDEWALK TO REMAIN 151413 101112 6 7 8 9 51234 EXISTING F.H. A A 3.8 7.0 6.9 6.9 6.9 6.9 6.9 9.4 18.0 24.0 24.0 8.0 8.0 18.0
9.0 7.9
7.8 7.7 7.0 7.5 7.0 22.4
10.3 10.3
10.2 10.2 9.5 9.9 9.5 9.4 9.4
7.0 7.0
7.0 7.0 7.0 7.0 6.9 9.4 12 5 9
4.5 8.0 3 2 STORY MULTI-FAMILY 2 STORY MULTI-FAMILY 7 2 8 9 66 5 1 STORY GARAGE
2 STORY MULTI-FAMILY 6 6 11 4 PL 1B PL 1B PL 1C 3.8 3.8 9.5 3.8 PL 1A PL 1C3.8 PL 1A PL 1C PL 1A PL 1C PL 1A PL 1C PL 1C PL 1A PL 1C PL 1A 13 13 2.2 2.2 2.2 2.2 2.2 2.2
6.8 20.0 1 2 8 10 12 4.0 EXISTING C.M.U. WALL TO REMAIN +/- 12' HIGH LOCATED ON ADJACENT PROPERTY PROPOSED 6' HIGH C.M.U. EXISTING C.M.U. WALL TO REMAIN +/- 12' HIGH LOCATED ON ADJACENT PROPERTY 2 2 22 2 2 2
10.5 10.4 SITE ADDRESS: 705-715 W FLETCHER AVENUE APN: 374-261-10 AND 11 GENERAL PLAN: LOW MEDIUM DENSITY RESIDENTIAL (LMDR) ZONING.: R3 - SMALL LOT SUBDIVISION SITE ACREAGE: 0.72 ACRES BASELINE DENSITY: 11 UNITS (15 DU/ACRE * .72 ACRES) SET ASIDE (VERY LOW): 1 UNIT (9%) DENSITY BONUS: 4 UNITS (30% * 11 UNITS) TOTAL RESIDENTIAL UNITS/LOTS: 15 HOME SIZE: 1,750 SF +/-, 4 BDRM, 3.5 BATH PARKING REQUIRED: 38 (2.5 SPACES PER 4 BR UNIT UNDER STATE DENSITY BONUS LAW) PARKING PROVIDED: 39 (30 ENCLOSED GARAGE SPACES AND 9 OPEN SPACES) BLDG.STORIES: 3 STORY BLDG HEIGHT: 35' (35' ALLOWED) PRODUCT SUMMARY 2 PL 1A 1,757 SF 4 BD 13 PL 1B 1,769 SF 4 BD BUILDING CODE SUMMARY OCCUP. TYPE: R3/U (CRC) CONST. TYPE: TYPE VB FIRE SPRINKLER: NFPA 13D (CRC R313.1) 2022 CALIFORNIA RESIDENTIAL CODE (CRC) 2022 CALIFORNIA ELECTRICAL CODE (CEC) 2022 CALIFORNIA MECHANICAL CODE (CMC) 2022 CALIFORNIA PLUMBING CODE (CPC) 2022 CALIFORNIA FIRE CODE (CFC) 2022 CALIFORNIA GREEN BLD'G STDS CODE (CGBSC) 2022 CALIFORNIA ENERGY EFFICIENCY STDS (CEES) USUABLE OPEN SPACE SUMMARY (SEE SHT. OS FOR LOCATIONS) PRIVATE YARDS (P.Y.) 4,505 S.F. (300 S.F./UNIT) PRIVATE BALCONIES 1,500 S.F. (100 S.F./UNIT) COMMON OPEN SPACE 480 S.F. (32 S.F./UNIT) TOTAL OPEN SPACE 5,305 S.F. (332 S.F/UNIT). 12 PROPERTY LINE 345678 PROPOSED 6' HIGH C.M.U. WALL 9 AMENITY AREA (SEE LANDSCAPE PLAN) STANDARD PARKING STALL - 9' X 18' 3-STORY DWELLING, TYP. FIRE LANE SITE PLAN KEYNOTES ENHANCED PAVING (SEE LANDSCAPE PLAN) 4' CONCRETE WALKWAY 6' FIRE ACCESS PATH, TYP. 10 LEGEND PRIVACY FENCE FIRE LADDER AREA AT EGRESS WINDOWS 2' X 2' AT GROUND, 6' FROM BLDG FOR 24' HIGH WINDOW PER OCFD ATTACHMENT 22 REQUIREMENTS AIR CONDITIONING CONDENSER LOCATED WITHIN PRIVATE YARD AREA LOT NUMBER 11 EXISTING FIRE HYDRANT COMPACT PARKING STALL - 8' X 18' EXISTING CMU WALL TO REMAIN +/- 12' HIGH ON ADJ. PROPERTY 1213 PRIVATE YARD FENCING, TYP. 1 NORTH SITE PLAN DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE FLETCHER 15 - SMALL LOT SUBDIVISION ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 0 20 40 60 SP Attachment 4
939
120'
260' FLETCHER AVENUE 151413 101112 6 7 8 9 51234 EXISTING F.H. A A PL 1B PL 1B PL 1A PL 1C PL 1C PL 1A PL 1C PL 1A PL 1C PL 1A PL 1C PL 1C PL 1A PL 1C PL 1A LEGEND COMMON RECREATION OPEN AREA HOMEOWNER PRIVATE YARD AREA HOMEOWNER BALCONY AREA (2ND FLR) COMMON LANDSCAPE AREA 2022 CALIFORNIA ENERGY EFFICIENCY STDS (CEES) USUABLE OPEN SPACE SUMMARY (SEE SHT. OS FOR LOCATIONS) PRIVATE YARDS (P.Y.) 4,505 S.F. (300 S.F./UNIT) PRIVATE BALCONIES 1,500 S.F. (100 S.F./UNIT) COMMON OPEN SPACE 480 S.F. (32 S.F./UNIT) TOTAL OPEN SPACE 5,305 S.F. (332 S.F/UNIT). NORTH OPEN SPACE EXHIBIT DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE FLETCHER 15 - SMALL LOT SUBDIVISION ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 0 20 40 60 OS 940
120'
260' FLETCHER AVENUE EXISTING SIDEWALK TO REMAIN 151413 101112 6 7 8 9 51234 EXISTING F.H. A A 2 STORY MULTI-FAMILY 2 STORY MULTI-FAMILY 1 STORY GARAGE
2 STORY MULTI-FAMILY PL 1B PL 1B PL 1A PL 1C PL 1C PL 1A PL 1C PL 1A PL 1C PL 1A PL 1C PL 1C PL 1A PL 1C PL 1A NORTH TRASH EXHIBIT DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE FLETCHER 15 - SMALL LOT SUBDIVISION ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 0 20 40 60 TS SOLID WASTE HANDLING PLAN SERVICE TYPE: INDIVIDUAL PICKUP (TRASH/RECYCLE/ORGANIC) REFER TO UNIT PLAN SHT. A-1 AND A-2 FOR LOCATIONS OF BIN STORAGE AREAS AT PRIVATE GARAGES TRASH/RECYCLE BIN STAGING LOCATION TRASH VEHICLE DIRECTION OF TRAVEL T R O 941
DINING PWD KITCHEN BDRM 2 BDRM 3 BDRM 1 CL BA 2 BA 1 LAUN BALCONYLIVING LIN PAN STOR 21'-0" 8'-2"
5'-7" 13'-412" 33'-2" 5'-0"
11'-012" 3RD FLOOR PLAN 2ND FLOOR PLAN 100 S.F. FIRE EGRESS FIRE
EGRESS
FIRE
EGRESS LIN
12'-812"
1'-10" 13'-7" 7'-5" 1'-3"
1'-10" 10'-812" 10'-312"
4:12 ROOF PLAN
4:12 RIDGE
RIDGE
RIDGE
RIDGE 4:12
4:12
4:12
4:12
4:12
4:12 4:12 GARAGE 21'-0"
40'-0"
2'-0" 20'-7" 11'-112" 20'-5"
20'-112" BDRM 4 BA 3 R TR 13'-7" 7'-1012"
6'-4" 1ST FLOOR PLAN SOLAR ZONE 18" TYP. EAVE 12" TYP. RAKE LADDER PAD, TYP. WH O 3'-812" 11'-11" 5'-412"
2'-7" 6'-1112" 8'-4" 8'-4" 2'-9"
4'-10" 5'-5" 120 CU FT. STORAGE RACK AT CEILING 6' W X 10' D X 2' H 6" 7'-0" ENTRY ENTRY OFFSET ENTRY DOORS, TYP. DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 FLETCHER 15 - SMALL LOT SUBDIVISION PLAN 1A - 1,757 S.F.A-1 942
ROOF PLAN 3RD FLOOR PLAN 2ND FLOOR PLAN GARAGE 21'-0"
40'-0" WH
2'-0" 20'-7" 11'-112" 20'-5"
20'-112" BDRM 4 BA 3 O RTR 13'-7" 7'-1012"
6'-4" 1ST FLOOR PLAN AT LOTS 1 AND 15 AT LOTS 1 AND 15 AT LOTS 1 AND 15 AT LOTS 1 AND 15 LADDER PAD, TYP. 120 CU FT. STORAGE RACK AT CEILING 6' W X 10' D X 2' H DINING PWD KITCHEN LAUN LIVING PAN STOR 21'-0" LIN 2'-9" 7'-5" 6"
4'-10" 5'-5" 1'-0"
8'-912" 13'-1" 15'-412" BALCONY
8'-2"100 S.F. 13'-7" BDRM 2 BDRM 3 BDRM 1 CL BA 2 BA 1 LIN 5'-7" 13'-412" 33'-2" 5'-0"
11'-012" FIRE EGRESS
FIRE
EGRESS
FIRE
EGRESS
12'-812" 1'-10" 10'-812" 10'-312" 3'-912" 11'-10" 5'-412" 2'-7" 6'-1112" 8'-4" 8'-4" 2'-9"
4:12
4:12 RIDGE
RIDGE
RIDGE
RIDGE 4:12
4:12
4:12
4:12
4:12
4:12 4:12 SOLAR ZONE 18" TYP. EAVE 12" TYP. RAKE4:12 4:12 RIDGE DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 FLETCHER 15 - SMALL LOT SUBDIVISION PLAN 1B - 1,769 S.F.A-2 943
DINING PWD KITCHEN BDRM 2 BDRM 3 BDRM 1 CL BA 2 BA 1 LAUN BALCONYLIVING LIN PAN STOR 21'-0" 8'-2"
5'-7" 13'-412" 33'-2" 5'-0"
11'-012" 3RD FLOOR PLAN 2ND FLOOR PLAN 100 S.F. FIRE EGRESS FIRE
EGRESS
FIRE
EGRESS LIN
12'-812"
1'-10" 13'-7" 7'-5" 1'-3"
1'-10" 10'-812" 10'-312" ROOF PLAN GARAGE 21'-0"
40'-0"
2'-0" 20'-7" 11'-112" 20'-5"
20'-112" BDRM 4 BA 3 R TR 13'-7" 7'-1012"
6'-4" 1ST FLOOR PLAN
LADDER PAD, TYP. WH O 3'-812" 11'-11" 5'-412"
2'-7" 6'-1112" 8'-4" 8'-4" 2'-9"
4'-10" 5'-5" 120 CU FT. STORAGE RACK AT CEILING 6' W X 10' D X 2' H 6" 7'-0" ENTRY ENTRY OFFSET ENTRY DOORS, TYP.
4:12
4:12 RIDGE
RIDGE
RIDGE
RIDGE 4:12
4:12
4:12
4:12
4:12
4:12 4:12 SOLAR ZONE 18" TYP. EAVE 12" TYP. RAKE DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 FLETCHER 15 - SMALL LOT SUBDIVISION PLAN 1C - 1,757 S.F.A-3 944
35'-0" BLD'G. HT.
9'-0" 9'-0" 8'-6" 2 6 1 3 2 4 14 9 3 14 1 7 9 1 11 8 10 2 MATERIAL SCHEDULE 1. ROOF - CONCRETE S TILE 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. DECORATIVE METAL RAILING 5. VINYL WINDOW W/ STUCCO TRIM 6. STUCCO CONTROL JOINT 7. EXTERIOR LIGHT FIXTURE 8. DECORATIVE SHUTTERS 9. DECORATIVE GABLE ACCENT 10. DECORATIVE METAL POTSHELF 11. SECTIONAL GARAGE DOOR 12. ARCHED RECESS 13. DECORATIVE METAL GRILLE 14. FIXED 3RD FLR. ACCENT WINDOW (FACING ADJACENT PROPERTIES) 5 7 2 6 8 9 12 3 3 1 DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 FLETCHER 15 - SMALL LOT SUBDIVISION ELEVATIONS 1A & 1B SIDE ELEVATION 1A & 1B PRIVATE YARD ELEVATION 1A & 1B FRONT ELEVATION 1A & 1B DRIVE ELEVATION 1A & 1B ENHANCED SIDE ELEVATION AT FLETCHER - 1B A-4 SEE PLAN SHEET A-1 FOR OFFSET ENTRY DOOR ALIGNMENTS, TYP. AT UNIT TO UNIT LOCATIONS 945
35'-0" BLD'G. HT.
9'-0" 9'-0" 8'-6" 2 6 3 1 2 4 14 9 3 14 1 7 9 1 13 11 8 10 2 MATERIAL SCHEDULE 1. ROOF - CONCRETE S TILE 2. FASCIA - 2X RESAWN WOOD 3. 16/20 SAND FINISH STUCCO 4. DECORATIVE METAL RAILING 5. VINYL WINDOW W/ STUCCO TRIM 6. STUCCO CONTROL JOINT 7. EXTERIOR LIGHT FIXTURE 8. DECORATIVE SHUTTERS 9. DECORATIVE GABLE ACCENT 10. DECORATIVE METAL POTSHELF 11. SECTIONAL GARAGE DOOR 12. ARCHED RECESS 13. DECORATIVE METAL GRILLE 14. FIXED 3RD FLR. ACCENT WINDOW (FACING ADJACENT PROPERTIES) DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 FLETCHER 15 - SMALL LOT SUBDIVISION ELEVATIONS 1C SIDE ELEVATION 1C PRIVATE YARD ELEVATION 1C FRONT ELEVATION 1C DRIVE ELEVATION 1C A-5 SEE PLAN SHEET A-3 FOR OFFSET ENTRY DOOR ALIGNMENTS, TYP. AT UNIT TO UNIT LOCATIONS 946
DEC 23, 2025
5256 S. Mission Road, Ste. 404
Bonsall, CA 92003
www.summarch.com p.760.724.1198
ARCHITECTURE
ORANGE
ADC FLETCHER 15, LLC
1635 OHMS WAY, SUITE A
COSTA MESA, CA 92627
949.791.8401
FLETCHER 15 - SMALL LOT SUBDIVISION SHADE - SHADOW EXHIBITS 3 PM - DEC 21
A-6
NOON - DEC 21
9 AM - DEC 21
9 AM - JUN 21
NOON - JUN 21
5 PM - JUN 21
EXISTING SITE - VACANT (NO SHADOWS)
947
35'-0" EAVE HT. SECTION A-A
9'-0" 9'-0" 8'-6" P.L. GARAGE
9'-0" 9'-0" 8'-6" P.L.
3'-0"
24'-10" 2 STORY MULTI-FAMILY 1 STORY GARAGE 1 STORY GARAGE 3 STORY DETACHED HOME 3 STORY DETACHED HOME 2 STORY MULTI-FAMILY 30'-0" BUILDING HT. 6'X10'X2' STOR. RACK
7'-6"
2'-0"6'X10'X2' STOR. RACK
7'-6"
2'-0" DEC 23, 2025 5256 S. Mission Road, Ste. 404 Bonsall, CA 92003 www.summarch.com p.760.724.1198 ARCHITECTURE ORANGE ADC FLETCHER 15, LLC 1635 OHMS WAY, SUITE A COSTA MESA, CA 92627 949.791.8401 FLETCHER 15 - SMALL LOT SUBDIVISION LINE OF SITE SECTION/ LADDER EXHIBIT A-7 948
Attachment 5
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AcDbArcAlignedText (ATEXT)
AcDbArcAlignedText (ATEXT) AcDbArcAlignedText (ATEXT)
AcDbArcAlignedText (ATEXT)
PREPARED BY:
ALI MONSHIZADEH, R.C.E No. C67674 DATE
REVISIONS
NO. DATE DESCRIPTION APPROVED
DRAWN BY:
CHECKED BY:
PROJECT
NUMBER
SHEET No.___________OF__________ SCALE: HORIZ.:________________ VERT.:_________________
1"= 20'
STAFF
AM
N/A
TENTATIVE TRACT MAP 119429
ORANGE, CALIFORNIA
705 & 715 W FLETCHER AVE
’ ”
’
’
0 1" = 20'
10 20 40
Attachment 6
951
RECORD DRAWING
PREPARED BY:
ALI MONSHIZADEH, R.C.E No. C67674 DATE
ENGINEER (SIGNATURE) DATE
REVISIONS
NO. DATE DESCRIPTION APPROVED
CITY OF ORANGE
OFFICE OF THE CITY ENGINEER
DRAWN BY:
CHECKED BY:
PROJECT
NUMBER ________
RECOMMENDED:
DATE PRINCIPAL CIVIL ENGINEER
DIAL TOLL FREE
811 or
AT LEAST TWO DAYS
BEFORE YOU DIG
1-800-422-4133
SHEET No.___________OF__________ SCALE: HORIZ.:________________ VERT.:_________________
SEE PLAN
PRELIMINARY ENGINEERING PLAN
STAFF
AM
SEE PLAN
DETAILS AND SECTIONS
952
RECORD DRAWING
PREPARED BY:
ALI MONSHIZADEH, R.C.E No. C67674 DATE
ENGINEER (SIGNATURE) DATE
REVISIONS
NO. DATE DESCRIPTION APPROVED
CITY OF ORANGE
OFFICE OF THE CITY ENGINEER
DRAWN BY:
CHECKED BY:
PROJECT
NUMBER ________
RECOMMENDED:
DATE PRINCIPAL CIVIL ENGINEER
DIAL TOLL FREE
811 or
AT LEAST TWO DAYS
BEFORE YOU DIG
1-800-422-4133
SHEET No.___________OF__________ SCALE: HORIZ.:________________ VERT.:_________________
SEE PLAN
PRELIMINARY ENGINEERING PLAN
STAFF
AM
SEE PLAN
GRADING AND DRAINAGE PLAN
0 1" = 20'
10 20 40
953
RECORD DRAWING
PREPARED BY:
ALI MONSHIZADEH, R.C.E No. C67674 DATE
ENGINEER (SIGNATURE) DATE
REVISIONS
NO. DATE DESCRIPTION APPROVED
CITY OF ORANGE
OFFICE OF THE CITY ENGINEER
DRAWN BY:
CHECKED BY:
PROJECT
NUMBER ________
RECOMMENDED:
DATE PRINCIPAL CIVIL ENGINEER
DIAL TOLL FREE
811 or
AT LEAST TWO DAYS
BEFORE YOU DIG
1-800-422-4133
SHEET No.___________OF__________ SCALE: HORIZ.:________________ VERT.:_________________
SEE PLAN
PRELIMINARY ENGINEERING PLAN
STAFF
AM
SEE PLAN
UTILITY PLAN
0 1" = 20'
10 20 40
954
5 6
1 3 2
4 Photo Key - 705-715 W Fletcher
Attachment 7
955
956
957
958
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Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
One America Plaza
600 West Broadway, 27th Floor | San Diego, CA 92101-0903 Telephone: 619.233.1155 | Facsimile: 619.233.1158
www.allenmatkins.com
Timothy M. Hutter
E-mail: [email protected]
Direct Dial: 619.235.1510 File Number: 394349.00001/4916-1209-0967.2 Los Angeles | Orange County | San Diego | Century City | San Francisco | New York Allen Matkins
Via Submission by Applicant
July 21, 2025
Russell Bunim
Community Development Director
City of Orange
300 E. Chapman Ave.
Orange, CA 92866
[email protected]
Ryan Agbayani
Senior Planner
City of Orange
300 E. Chapman Ave.
Orange, CA 92866
[email protected]
Re: ADC Fletcher 15, LLC’s Proposed 15-unit Residential Project 715 W Fletcher Ave, Orange, CA 92865, APN: 374-261-10
Dear Mr. Bunim and Mr. Agbayani,
This law firm represents the applicant, ADC Fletcher 15, LLC (the “Applicant”), with regard to the above-referenced project (the “Project”). We understand that City of Orange (the “City”) sent the Applicant a letter on June 13, 2025 that highlighted several design features that the City found conflicted with the applicable design standards. After reviewing the letter, Mr. Hamilton requested that we provide a summary of California Density Bonus Law (the “DBL”) and the Housing Accountability Act (the “HAA”). To that end, this letter summarizes the DBL and HAA and analyzes their application to the Project in order to provide the City with assistance and guidance in its review of the Project application.
BACKGROUND ON DENSITY BONUS LAW
A. State Density Bonus Law, Government Code Section 65915 The DBL incentivizes the development of affordable housing and other under-produced housing types by providing additional density as well as incentives and waivers to qualifying projects. Cities and counties are required to adopt ordinances to specify how their jurisdictions will comply with the DBL, but failure to adopt such ordinances does not relieve a jurisdiction from compliance.
1 1 Gov. Code § 65915(a).
Attachment 8
962
Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
Russell Bunim, Community Development Director
Ryan Agbayani, Senior Planner
July 21, 2025