Ordinance and Attachments — Santa Ana City Council, December 17, 2024 (part 2 of 2)

Andrews

SANTA ANA BLVD

FLOWER ST

TUSTIN AV

WASHINGTON AV
1ST ST

LINCOLN AV

STANDARD AV

MAIN ST

CIVIC CENTER DR

EUCLID ST

RED HILL AV

NEWHOPE ST

RAITT ST
1ST ST

LA VETA AV

WARNER AV
17TH ST

TUSTIN AV
4TH ST

MCFADDEN AV

FAIRVIEW ST

CIVIC CENTER DR

MAIN ST
RAITT

FAIRHAVEN AV

GRAND AV

EDINGER AV

ALTON AV

FLOWER ST

GLASSELL ST

BEAR ST

PARKER ST

CHESTNUT AV

SUNFLOWER AV

YORBA ST

HAZARD AV

DYER RD

CAMBRIDGE ST

STANDARD AV

MACARTHUR BLVD

WASHINGTON AV

GRAND AV

FLOWER ST

GARDEN GROVE BLVD

MCFADDEN AV
AV

HARBOR BLVD

SUNFLOWER AV

WARNER AV

SEGERSTROM AV

NEWHOPE ST

MACARTHUR BLVD

SEGERSTROM

BROADWAY

RAITT ST

DYER RD

GRAND AV

YORBA ST

WARNER AV

HARBOR BLVD

BROADWAY

FLOWER ST

EUCLID ST

GRAND AV

HARBOR BLVDSEGERSTROM AV
1ST ST

EDINGER AV
1ST ST

CHESTNUT AV

BROADWAY

EDINGER AV

BRISTOL ST

MAIN ST

BROADWAY
1ST ST

FAIRVIEW ST
1ST ST
4TH ST
1ST ST
4TH ST

ALTON AV
17TH ST

GRAND AV
17TH ST

WARNER AV

FAIRVIEW ST

BRISTOL ST
1ST ST

EDINGER AV

MAIN ST

EDINGER AV

MAIN ST

BRISTOL ST

DYER RD
17TH ST

FLOWER ST

MACARTHUR BLVD

FAIRHAVEN AV

WARNER AV
5TH ST

MCFADDEN AV

NEWHOPE ST

WESTMINSTER AV

SANTA CLARA AV
ST

HAZARD AV

MCFADDEN AV

WARNER AV

BRISTOL ST

HARBOR BLVD

MACARTHUR BLVD

BRISTOL
ST

WILSHIRE PL

MORNINGSIDE
AV
CAMILE
PL

MILLWOOD
ST

DAN GURNEY
DR

DOUGLAS ST

GLENWOOD
PL

DAHL LN

MAJESTIC
DR
JETTY
CIR
JESSEE
DR

NA PALI
DR

GLENARBOR
ST
AZTEC
CIR

GARRY AV

WARBLER ST
PARTON
AV
HARVEY
AV
GATES
ST
HALL
AV
CAMILE
PL
CL DL
SUR
CL DL
NORTE
BURNS
AV
TUSTIN
CENTER
KEDGE
AV

MACARTHUR PL
ROGER

PENSKE DR
KENNY
CIR
ADRIN
WY

SAINT ANNE PL

COLUMBINE AV
COMO
AV

HARVARD ST
EDISON
WY

SANTA ANA BLVD

KEMPER AV
SHARON
RD

DEEGAN DR

MOORE AV
CHERRY
ST

ROSEWOOD AV

JACKSON ST

LINDA WY

BAKER ST

PENDLETON AV

SHAWNEE DR

AUSTIN ST

OLD GRAND ST

OLIVE ST

KENT AV

GREENBRIER ST

SAINT GERTRUDE PL

PACIFIC AV

SHELLEY ST

SAINT GERTRUDE PL

PINE ST
9TH ST

AURORA AV

BOOTH ST

CUBBON ST

VIRLEE ST

DAISY AV

BIRCH ST
2ND ST

VAN NESS AV
SIE
R RA

WESTERN AV

MINNIE ST
5TH ST

SHAWNEE DR
11TH ST

KENT AV

HALL AV

ROSS ST

PARK LN
15TH ST

VANCE ST

KAREN AV

BAKER ST

CIVIC CENTER DR

MINNIE ST

VAN NESS AV

PACIFIC AV

WALNUT ST

BUSH ST

WILSHIRE AV

LOWELL ST

RAITT ST

LACY ST

BIRCH ST

MAXINE ST

LEWIS ST

PARTON ST

AVALON AV

SAINT ANDREW PL

DAISY AV

PATTI LN

ALCO AV

SHELTON ST VAN NESS AV

OLIVE ST
OXFORD
16TH ST

MONTA VISTA AV

SANTA CLARA AV

SANTA ANA BLVD

ALPINE AV

ANAHURST PL

GLENWOOD PL

CAMILE ST

ROBERTS DR

LOGAN ST

LOWELL ST

MOHAWK DR

OCCIDENTAL ST

MYRTLE ST

WESTWOOD AV

PARTON ST

RANCHERO WY

KENT AV
GARRY
AV

WILSHIRE AV

RAITT ST

VAN NESS AV

OCCIDENTAL ST
BREWER
AV
CALLE

SOLEDAD

PARTON AV

ROSITA ST

LORI LN

BELL AV

HURON DR

ROSS ST

LACY ST
BROOK
ST

MAPLE ST

BAKER ST

WISTERIA PL

TOWNER ST

LINWOOD AV

SAIL ST

DAISY AV

HARMON ST
SPR
U
CE
ST

OAK ST

BUFFALO AV

VIRGINIA AV VIRGINIA AV

PARK LN

OCCIDENTAL ST

GARRY AV

KRISTI LN

DEMING ST

LILAC AV

KELLER AV

SANTA CLARA AV

SANTA ANA BLVD

CENTRAL AVCENTRAL AV

PACIFIC AV

WOOD ST

CEDAR ST

CARRIAGE DR

WILLIS ST

OAKFIELD AV

GARNSEY ST

MCLEAN DR

MT TRICIA ST

WASHINGTON AV

ANITA PL

DOREEN WY

FIGUEROA ST

RITCHEY ST

MAXINE ST

LA VETA AV

SYCAMORE ST

DAVIT AVDAVIT AV

DAVIT AV

PATRICIA LN

WESTERN AV

CLEGHORN WY

LA BONITA AV

WILLITS ST

BEWLEY ST

OCCIDENTAL ST

BLAIR AV

JACKSON ST

TOWNSEND ST

LENITA LN

GOETZ AV

CADDY CIR
RITA
RITA
RITA

SAINT ANDREW PL

LAURA LINDA LN

PACIFIC

HOLLYLINE AV

RAITT ST

ELLIOTT PL

CHARLAINE AV

OXFORD ST

OTIS ST

DEODAR ST
DIAM
O
ND

PINE ST

PINE STPINE STPINE ST

PINE ST PINE ST

LIME ST

JOANA DR

CENTRAL AV

ALENE CIR

LINGAN LN

ELAINE DR

BELL AV

SAINT GERTRUDE PL

WELLINGTON AV

FLIGHT AV

FLIGHT AVFLIGHT AV

MORNINGSIDE AV

ROSEWOOD AV

DAISY AV

STANFORD ST

ACAPULCO AV

GARNSEY ST

OAKFIELD AV

FREEMAN ST

ALPINE AVALPINE AV

ALPINE AV

FRUIT STFRUIT STFRUIT ST

FRUIT ST

LEHNHARDT AV

CATALINA AV

CATALINA AVCATALINA AV

CATALINA AV

CATALINA AV
11TH ST11TH ST
11TH ST
21ST ST
21ST ST
21ST ST
21ST ST21ST ST21ST ST
21ST ST
21ST ST21ST ST

TIMBER ST

CEDAR ST

MINNIE ST

LAIRD ST

OLIVE ST

OLIVE LN
OLIVE
LN

OAK ST

HALL AV

POMONA ST

SALTA ST

BROWN ST

ROSITA PL

LA BONITA

TAFT ST

RIVIERA DR

PETAL AV

HEMLOCK WY

JUDITH LN

SANTA CLARA AV
HUTTON

CENTRE DR

THE CITY DR

BOLIVAR CIR

GOLDEN WEST AV

OLD TUSTIN AV

HILTON LN

SENNIT AV

FRENCH ST

WALNUT ST

WISTERIA PL

STAFFORD ST

SAINT GERTRUDE PLSAINT ANNE PL

KING ST

KING ST
14TH ST14TH ST
14TH ST
14TH ST
14TH ST
14TH ST
15TH ST15TH ST
15TH ST
15TH ST
20TH ST
20TH ST
20TH ST
20TH ST
20TH ST
20TH ST 20TH ST
20TH ST
20TH ST
19TH ST
19TH ST
19TH ST
19TH ST
19TH ST19TH ST 19TH ST
19TH ST
19TH ST 19TH ST
18TH ST
18TH ST
18TH ST
18TH ST
18TH ST18TH ST
18TH ST
18TH ST
16TH ST
16TH ST16TH ST 16TH ST16TH ST
16TH ST
16TH ST
10TH ST
10TH ST
10TH ST10TH ST
10TH ST
12TH ST12TH ST12TH ST12TH ST

KEEL AV

WASHINGTON AV

ROSITA ST

ALBION AV

SIERRA AV

VALENCIA AV

POINSETTIA ST

POINSETTIA ST
CIR
CIR
CIR
CIR
CIR
CIR
CIR

MT MITCHELL CIR

MT HICKS ST
4TH ST
7TH ST7TH ST
7TH ST
7TH ST
7TH ST
8TH ST
5TH ST
5TH ST
5TH ST5TH ST5TH ST5TH ST
5TH ST
5TH ST
5TH ST
5TH ST
5TH ST
6TH ST
6TH ST6TH ST6TH ST6TH ST6TH ST6TH ST6TH ST
6TH ST
6TH ST
6TH ST
9TH ST9TH ST 9TH ST
9TH ST

JETTY ST

SANTA FE ST

STANDARD AV

WILSHIRE AV

CURIE AV

SULLIVAN ST

SULLIVAN ST
ZOO LN

WILLIAMS ST

JUNIPER AVJUNIPER AV

ARTESIA ST

GRIFFITH GRIFFITH

EL DON PL

BERNI ST

RIVER LN

RIVER LN RIVER LN

RITA WY

YALE ST

CALIFORNIA ST

HIGHLAND AV

JENKINS ST

SILVER DRSILVER DR

SILVER DR

GRISET PL

VICTORIA DR

ORANGE AV

TOLLIVER ST

VALENCIA ST

JAN WY JAN WYLA VERNE AV LA VERNE AVLA VERNE AV

LINNELL

LOUISE ST

ALBION LN

LINCOLN AV

GARNSEY ST

DEMING ST

BIRCH ST

DARIN ST

JUNIPER ST

LEWIS ST

LEWIS ST
LORI

CAMILLE ST

CAMILLE ST
BINE

MARCELLA LN

SANTA CLARA CIR

EASTSIDE AV

OAKFIELD AV

CANDIS AV

SCENIC AV

SISSON AV

SEBA AV

BALLAST

CAMILE ST

ELAINE DR

LINGAN LN

LINGAN LNLINGAN LN

MYRTLE STMYRTLE ST

FAIR WY

FAIR WY
22ND ST
22ND ST
22ND ST

VAN NESS AV

SHEFFIELD ST

GOLDEN WEST AV

SANTA CLARA AV

FUCHSIA ST
SAINT

SAINT GERTR UDE

PARTON ST

PARTON ST
LAIRD
LINDA
LINDA

POPLAR ST
OLIVE

FLINTRIDGE DR

STARBOARD ST

LIVINGSTONE ST

KENT AV

JODY AV

TRINIDAD

RIVERINE

ALTON AV

BISHOP STBISHOP STBISHOP ST

BISHOP ST

KELLER AV

KELLER AV KELLER AV

RIGHTER
CIR

FRANKLIN ST

POMONA ST

EASTSIDE
ST
FLIGHT

EDGEWOOD RD

TIMBER ST

DENNIS ST

DIANNE ST

FLOYD CIR

CLINTON ST

RITCHEY ST

RIVERSIDE DR

RIVERSIDE DR
2ND ST2ND ST
2ND ST2ND ST 2ND ST
2ND ST 3RD ST3RD ST3RD ST
3RD ST
3RD ST
3RD ST
3RD ST
3RD ST

ROY CIR

NUBIAN LN

COLUMBINE AV

SAINT ANNE

LACY ST

LACY ST
ALPINE

TOWNER ST

ENGLISH ST

STANELY
KORAL
CIR

JETTY DR

ORION AV

GROVEMONT ST

SULLIVAN

SALINAZ
W

ELLINGTON AV

WAYFIELD ST

GARFIELD ST

FAIRLAWN AV

TAMPION AV

TAMPION AV TAMPION AV

WELLINGTON AV

MAURIE AV

BORCHARD AV

WAKEHAM AV

LINDA WY

TERMINAL ST

DAHL ST

DAHL LN

DAHL LNDAHL LN

MAINPLACE DR

MINTER ST

MAXINE STMAXINE ST

SALVATION

FULLER ST

KILSON DR

KILSON DR
AVALON
AV

AVALON AVAVALON AV

AVALON AV

RICHLAND AV

RICHLAND AV RICHLAND AV

PARSONS PL

CABRILLO PARK DR

WALNUT ST

DAIMLER ST

HELIOTROPE

RUSSELL AV

RUSSELL AVRUSSELL AV

RUSSELL AV

LYON ST

ELK LN

LYON ST

PALM ST

PARK LN

LAUREL ST

LAUREL STLAUREL ST

JONQUIL RD

MIRASOL ST

MERIDAY LNMERIDAY LN

TRASK AV TRASK AV

JAMES AV

ELDER AV ELDER AV

ELDER AV

BEVERLY PL

STONE PINE GLEN

GREENVILLE ST

FAIRMONT AV

PONDEROSA ST

FIRST AMERICAN WY

LORETTA LN

CRYSTAL LN

CRYSTAL

BUFFALO AV

SHELLEY ST

WISTERIAWISTERIA

WISTERIA

YUMA CIR

WILSHIREWILSHIRE

FLORA ST

ASTER PL

CLARA ST

PLAZA DR

MANLY AV

NOBEL AV

HATHAWAY ST

MARINE ST

ANAHURST PL
FAY

NORMANDY PL

VILLAGE WY

SAINT GERTRUDE PL

YAWL ST

TAMY LN

RICHLAND ST

NAUTILUS DR

HASTINGS ST

SAINT ANDREW PL

OLD MC FADDEN AV

OCCIDENTAL STOCCIDENTAL ST

OCCIDENTAL ST

FAIRWAY DR

HICKORY ST

HALLADAY ST

HALLADAY ST
COMO
AV

GATES ST

DAYNA ST

CAMINO AV

FAIRMONT ST

CARNEGIE AV

MAGNOLIA AV

PEPPER TREE LN
FAY
MINNIE
JETTY

SIEMON ST

MELRIC DR

JUNIPER

FIGUEROA ST

SANTIAGO ST

HIGHLAND ST

WOODLAND PL

MONICA LN

HESPERIAN ST

SPINNAKER ST

SPINNAKER ST
OAK ST
OAK ST
OAK ST
OAK ST
OAK ST
OAK ST
OAK ST

BEAR ST

ALDER ST

JASON LN

CELESTE ST

CENTRAL AV

CENTRAL AVCENTRAL AVCENTRAL AV

CENTRAL AV CENTRAL AV
LOUISE
KILSON

ALONA ST

CAROL AV

LA VERNE
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PL
PLPL
PL
PL
PL
PL
PL
PL
PL
PL

FOREST AV

PENNY AV

BARBETTE AVBARBETTE AV

MADISON AV

STEVENS AV

HYLAND AV

GOETZ AV

FAIRBROOK LN

DEERE AV

KNOX AVKNOX AV

KNOX AV

PORTOLA AV

DEMING ST

HARVEY AV

MORNINGSIDE AV

SAN LORENZO AV

PASADENA AV

GOLDEN CIRCLE DR

ASPEN ST

ASPEN STASPEN ST

MAPLE ST

BAKER ST

REEVE ST

BUENA ST

CABRILLO

SHELTON ST

CARLTON PL

COLUMBINE AVCOLUMBINE AV

COLUMBINE AV

ANNE ST

BUSH ST

LAKE CENTER DR

BERN LN

LOWELL ST

LOWELL LN

DURYEA AV

BERKELEY ST

WILLOWICK DR
GRISET
GRISET

FRANZEN AVFRANZEN AV FRANZEN AV

JEFFERSON PL
SIERRA
SIERRA
CAMILE
ACACIA

STEARNS AV

COLLEGE AV

KEELSON AVKEELSON AV
LADELL

WELLINGTON AV

WRIGHT ST

FOREST ST

MYRTLE ST

TOLAND ST

SUNSET ST

HURLEY ST

FORBES AV

MOUNTAIN VIEW

VAN NESS

BRUCE AV

BURNS AV

POSEY ST

BOYER AV

KEDGE AV

BOBBY LN

DOWNIE PL

PARTON ST

MANTLE LN

MANTLE LN
MANTLE
LN

POPLAR ST

ENTERPRISE DR

WAVERLY ST

PARK DR

STAFFORD ST

CORRIGAN AV

MANITOBA DR

STEPHENS AV

ADRIN WY

ADRIN WYADRIN WY

MAINPLACE

OLD GRAND ST

JOANA DR

SUSAN ST

SUSAN STSUSAN ST

SUSAN ST

ROOSEVELT AV

GARRY AV GARRY AV

GARRY AV

PULLMAN

OTTAWA ST

MCCLAY ST

BAMDAL ST

LINWOOD AV

SHERWIN LN

CYPRESS AV

MARCELLA LN

CYNTHIA

ROSS ST

BOYD ST

TODDY ST

MARTY LN

HUNTER AV HUNTER AV

SYDNEY ST

DIAMOND ST

BRIAN EXWY

JACKSON ST

PULLMAN ST

CHESTNUT AV

STANDARD AV

GREENBRIER ST

HELIOTROPE
DR

HELIOTROPE DR

FAWN ST

COTTER ST

COTTER ST
JAN WY

MILLWOOD ST

CENTER ST

CUSTER ST
WEBER
CIR

GRANT ST

SYCAMORE ST

SEABOARD CIR

CALVO DR

JACARANDA ST

NANCY LN

ANDRES PL

ROUSSELLE ST

ROUSSELLE ST
AV
AV AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AV
AVAV
AV
AV
AV
AVAV
AV
AV
AV
AV
AV
AV AV
AV
AV
AV
AV
AV

NOTTINGHAM AV

LEHNHARDT AVLEHNHARDT AV

PENDLETON AV

CARRIAGE DR

CARRIAGE DRCARRIAGE DR

GEORGINE ST

PARSONS PL

HOBART ST

SHERRY LN

CEDAR ST

ARDEN ST

GRACE PL

OBARR PL

WEST ST

GOLDEN WEST AV

CATHERINE WY

WATKINS WY

LINWOOD ST

WESTMINSTER AV

DURANT ST

PORTER ST

CASTOR ST

CASTOR STCASTOR ST

MARTHA LN

MARTHA LNMARTHA LN

BEACON AV

BEWLEY ST

CORTA DR

GREENLEAF ST

CENTURY BLVD
BLVD

MORTIMER ST

STANFORD ST

HATHAWAY ST

HATHAWAY STANAHURST PL

ANAHURST PLANAHURST PL ANAHURST PL

CHANDLER AV

ACAPULCO AV

MARK ST

EDNA DR

MICHAEL

HARVARD STHARVARD ST

HARVARD ST

FRENCH ST

WALNUT STWALNUT ST

SPRUCE ST

HARPER ST

EVONDA ST

HAWLEY ST

ANNAPOLIS

CREST RD

PROGRESSO ST

GOLDEN WEST ST

CHERRY ST
MINTER
MINTER
ST
ST
ST
STST
ST
ST
ST
ST
ST
ST
STST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
STST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
STST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST
ST ST
ST
ST
ST
ST
ST
STST
ST
ST
ST
ST
ST
ST
FE
VIEW

ADAMS STADAMS ST

ADAMS ST

ADAMS ST
MAXINE
BONNIE
LACY

CROSSING DR

DRESSER ST

EVERGLADE ST

PARKCOURT PL

FALLBROOK DR
ST
LN
LN
LN LN
LN
LN
LN
LN
LN
LN
ST
LNLN

LN LN LN

WASHINGTON AV

AMETHYST CT

KIRKWOOD AV

CORWIN CT

EMMETT ST

RAYMAR ST

MT MATTERHORN ST

FLOWER AV

RHONDA AV

HOOD AV

ROSWELL STRICHMOND ST

RICHMOND ST

GREENWICH AV

STARBOARD ST

AURORA ST

HESPERIAN ST

CLEMENSEN AV

GARNSEY ST

RENE DR

HALLADAY

MABURY ST

MABURY ST
ZOO LN

MURPHY AV

FREEMAN ST

GUNTHER PL

FREEMAN LN

DOUGLAS ST

HARWOOD PLCRYSTAL

FAIRMONT

BROOK ST

HIGHLAND

HIGHLANDHIGHLAND
ST

ANCHOR AV

ORANGE AV

TOWNLEY ST

CAPE COD WY

MONTE CARLO DR

OXFORD ST

FLOWER ST

DEODAR ST

CUBBON ST

CUBB ON ST

CUBBON ST

WESTERN AVWESTERN AV

WESTERN AV

CLEMENSEN ST
GRISET

CAMDEN PL

HICKORY

SUNSWEPT AV

SUNSWEPT AV SUNSWEPT AV
LARCHM
ONT
AV

LARCHMONT AV

GUNTHER ST

FONDREN ST

LUCKY WY

LUCKY WY
SY
CAMORE
ST

BUFFALO

CELESTE

RUSSELL

AVALON AVALON
AVALON

SAN LORENZO

LARAMORE LN
SANTA
KATHY
STACY

OAKMONT AV

REGENT DR

MCEVOY LN

PARKCENTER DR

JOANE WY

GREENVIEW DR

YOUNG ST

MARK AND

EVERGREEN ST

GLENARBOR ST

GLENARBOR ST
MALL
MALL

PASADENA
ST

FORDHAM AV

ROBERTS DR

ARAPAHO DR

MARION WY

MCLEAN DR

COOPER ST

THORNTON ST

BORCHARD AV

BORCHARD AV BORCHARD AVBORCHARD AV

BORCHARD AV

BROADWAY PL
ORION
ORION
KRAFT

SHANNON ST

FARMERS DR

MACARTHUR PL

HUCKLEBERRY RD HUCKLEBERRY RD

STRAWBERRY LN

MOUNTAIN VIEW

MOUNTAIN

WEST ORANGE RD

MOORE AV

MOORE AVMOORE AVMOORE AVMOORE AV

PONDEROSA ST

HENDERSON PL

HENDERSON PL
ANABEL

SECREST WY

ROWLAND AVROWLAND AV

DEVON RD

MARINERS

GENOA DR

GRAHAM LN

DEEGAN DR

ANDREW PL

POMONA ST

POMONA ST POMONA ST

POMONA ST

TOWN AND COUNTRY

HALESWORTH ST

BEDFORD RDBRONSON ST

WAKEHAM AVWAKEHAM AV

SPURGEON ST

SYCAMORE ST

RIDGEWOOD ST

RIDGEWOOD ST
PARK
SPAR
SPAR

WARREN ST

WARREN ST
GATES
GATES

WAKEHAM PL

PASTEUR

STAFFORDSTAFFORD

TOWNER ST

EASTWOOD AV

NORMANDY PLNORMANDY PL

NORMANDY PL

CORPORATE DR
CT
CT

BROWNING

DORMAN ST
DEMING
CIR
MARION

MADDOCK ST

PENN WY

SHARON RD

NAKOMA DR

GORDON PL
JOANA

STEVENS
CLARA
ELDER

GLENDALE

SANDPOINTE

MEMORY LN

HARBOR GATEWAY

CARLTON

TOWNSEND ST

WOODLAND AV

ROOSEVELT

GREENGROVE

BLUEBERRY

EASTWOOD ST

TEAKWOOD ST

GOLDEN WEST

WOODLAND PL

CONCORD ST

CONCORD ST CONCORD ST

RAMONA DR

KEEGAN WY

HURON DR

MCGAW AV

EDENDALE

SHAWNEE DR
VANCE
DAYNA

GROVEMONT ST

DIAMOND

BOYD WY
FOREST
FOREST
FOREST
HURLEY
LOWELL

GLENWOOD PL

GLENWOOD PL GLENWOOD PL

GLENWOOD PL

PENDLETON

COMMERCIAL
BAKER
ST
BAKER

NANTUCKET

PEARWOOD LN

CHESTNUT

HATHAWAY
YOST
CORTA

MAYWOOD PL

MAYWOOD PL MAYWOOD PL

HARWOOD PL

WOOD ST

LINWOOD

HEMLOCK WYHEMLOCK WY

DRIFTWOODDRIFTWOOD

DRIFTWOOD DR

DOREEN WY

DOREEN WY
CENTER
CENTER

BEECHWOOD ST

BRYNWOOD ST

PEACHWOOD LN

SHERWOOD LN

ROSEWOOD AV

ROSEWOOD AV
B
ENTON
W
Y
ELMELM
BAMDAL
BERRY

PLUMWOOD LN

LAWSON WY
PENNY

CRODDY WY

CRODDY WY
AUTO
AUTO

WESTWOOD AV

MORNINGSIDE

CASCADE
RUTH
CIR
BRAE
RENE

RENE DR

EDNA ST
HANS
SPRUCE
SPRUCE
SPRUCE
SPRUCE
SURREY
KEEGAN

DANBURY

FERNWOOD DR

MOONRIDGE
HAWLEY

GLENARBOR ST

FREEMAN

WOODBURY DR

MOHAWK DR

MOHAWK DR
ADDEN
CHERRY

BRADFORD

LARAMORE
EVONDA

OAKMONT

HEMLOCK

NORTHPARK
GARRY

MACARTHUR
ROSS
EVON
GRACE
DOREEN

AURORA AURORAAURORA

SHANNON

BORCHARD

BROADWAY
MARY
RD
DR
DR DR
DR
DR
DR
DR
DR
DR
DR
DR
DR
DR
DR
DR
DR

CHANDLER
CIR

OAKMONT
CAMDEN
CAMDEN
CAMDEN

CAMDEN PL
MURPHY
COLUM
MEASOR
BROOK
BROOK
BROOK
GENOA

TOWNSEND

NEWPORT

GROVEMONT
ST

EASTWOOD

ROWLAND
POPLAR
GRAHAM
POPLAR
TOWNER

MARENGO

HARMON ST

BEECHWOOD
AV

COTTONWOOD

GLENWOOD
MEMORY

WOODBURY

GREENWOOD
MOORE
COWAN

MAYWOOD

MAYWOOD
MOHAWK
MOHAWK

WESTWOOD
AV
BOMO
BROWN
G

OLDEN CIRCLE
DR
WY
WY
WY
WY
WY
WY
WY
WY
WY
WY
WY
WY
WY

COACH DICK

HILL WY

CUBBON ST BEVERLY PL

MACARTHUR PL

CEDAR ST
4TH ST

GARNSEY ST
ST

MEDFORD
AV

BUFFALO AV
LN
AV
ELK LN
17 18
19 20
21 22
23 24
29 30
31 32
33 34
35 36
37 63
64 65
66 68
69 70
71 72
74 75
76 77
78 79
80 81 82 83 84
86 87 88 89 90 91 92
93 94 95 96 97
98 99
100
101
102
103
104
105
107
108
110
111
112
113
114
115
116
117
118
121
122
123
124
125
126
127
128
129
130
131
132
133
137
138
139
140
141
142
143
162
163
164
171
174
175
176
177
180
181
182
279
281
282
283
284
285
286
287
289
291
454
455
457
469
473
475
476
477 478
480
481
500
501
502
504
518
519
520 521
522
523
524
525
526
527
528
529
530
531 532
533
534
535
541
542
543
545
552
553
554
555 556
557
558559 560
561
562
563
564
565
566
567
568
569570
576
577
578 579
584
587 586 585
588
590
591
592
593
595
596
597
598
599
600
601
602
603
604
605
606
607
609
610
611
612
613
614
616 617
642
643
644
646
649
653
658 665
666
667
668
669 670
671
672
673 674
675
676677
678
679
680
681
682683
684685
686
687 688
689
690
693
695
696
697
698
699
700
701
703
704 705
706
707
708
709
710
712
713
727
728
729
730
731
732
733
734
735
736
737
738
739
740
741
742
743
744
750
751
752
753
754
755
756
767
768
769 770
775
776
777
778
779
780
781
793
794
795
799
800
801
802803
804
805 807
808
809
810
811
812
813
814
815
816 817
818
819
820
821
822
823
824
825
826
827
828829830
831
832
833
834
835
836
837
841
848
849
850851
852
853
854 855
860
861
862
863
864
865
866868 867
869
870
871
872
873
874
875
876879
880
881
882
883
884
884 885
894
895
896
898
899
900
901
903
904
905 906
907
908
909
910
911
912
913
915
916
917918919920
926
927
928 929
930
931
932
933
934
935
936
938
939940
941
942 943
949
950
951
954955
956
957
958
959
964
965
1050
1051
1052
1053
1054
1055
1056
10571058
1059
1060
1061
1062
1063
1080
1083
1090
1094 1095
1105
1111
1113
1115
1116
1117
1118
1119
1124
1126
1127
1128
1129
1130
1131
1135
1136
1138
1139
1160
1166
1167
1168
1169
1170
1171
1172
1173
1174
1175
1176
1177
1178
1179
1180
11811182
1183
1185
1198
1200
12011202
1203
1204
1205
1231
1232
1233
1234
1236 1237
1238
1239
1242
85 106
109
172
173
178
179
536
544
571
572
573
574
575
580
581
582
583589
594
615
694 702
711
806
877
878
1 132
1 133
1 134
1137
1184
1199
67 I
0 ½ 1¼
Miles
California Wetlands
Eligible Properties
Alternative Site
Upzoned Site
Affected by Wetlands/
Deepwater Habitat - (none)
Map Date: 12/5/2024
Source: U.S.Fish & Wildlife Service's National Wetlands Inventory https://www.fws.gov/program/national-wetlands-inventory Eligible Zones:

C1, C1-MD, C2, C4, C5, CR, C-SM,
P,
SD-31, SD-48, SD-52, SD-54, SD-60
SD-64, SD-72, SD-78
SD-84 (except Government Center)
SP 2 (except park)
SP 3 (only the Bush Str. Professional District and
Broadway Corridor District)
SP 4
Exemptions (does not qualify if..):
* If used for mobile home parks
* Completely Within 500 feet of freeway
* Owned by the City of Santa Ana
* Abutting Industrial General Plan Areas (old verison)
* Abutting Existing Industrial Landuse
* Not abuting a commercial corridor (70 ft -150 ft wide) Note: Abutting is assumed to be properties adjacent,
across the street, and diagonal for intersections
City of
Santa Ana
AB 2011
Mixed Income Housing
Act of 2022
Eligible Properties and
Wetlands & Deepwater Habitats
1 Identification of Alternative Sites
State law permits local governments to adopt a local AB 2011 implementing ordinance to exempt parcels of land from the streamlining provisions provided certain f indings are made. A local government must identify one or more alternative sites for residential development and make findings that the alternative development would result in no net loss of the total potential residential density permitted in the jurisdiction, no net loss o f the potential residential density of housing affordable to lower income households in the jurisdiction, and will affirmatively further fair housing. Further, Government Code sections 65912.114(i)(2)(A) and 65912.124(i)(2)(A) require that a local implemen ting ordinance that identifies an alternative site to accommodate the lost potential units from exempt sites that is not otherwise eligible for development pursuant to AB 2011, be “suitable for residential development” as defined in Gov ernment Code Sec. 65 583.2 of State Housing Element law. The analysis below will demonstrate how all parcels identified as alternative sites by the City of Santa Ana’s implementing ordinance which are not otherwise eligible for development pursuant to AB 2011 meet the Housing Element law definition for land suitable for residential development as defined in Gov. Code Sec. 65583.2.

AB 2011 Potential Housing Units Lost from Exempted Sites Santa Ana’s local implementing ordinance exempts 569 parcels from AB 2011 – Affordable and 281 parcels from AB 2011 – Mixed-Income permit streamlining, respectively. Table 1 below provides the total number of lost potential units for AB 2011 – Affordable and AB 2011 – Mixed-Income streamlining provisions.

The City of Santa Ana’s local implementing ordinance utilizes a multifaceted approach in achieving no net loss of total potential density in the jurisdiction by upzoning (i.e., increasing the permitted General Plan permitted density/intensity) certain parcels that are otherwise eligible for AB 2011 streamlining (Upzoned Sites) and identifying alternative parcels that are not eligible for AB 2011 and designating them as eligible for AB 2011 streamlining and also upzoning them (Alternative Sites) . A combination of the upzoned capacity on Upzoned Sites and the capacity permitted on the Alternative S ites demonstrate that no net loss of the total potential residential density is achieved. Table 1 (Affordable) and Table 1.5 (Mixed- Income) provide the total unit capacity of Upzoned and Alternative sit es, respectively, and also provide the total surplus capacity created between the two categories. In b oth cases, Affordable and Mixed - Income, the total Surplus Capacity is greater than the Lost Potential capacity from the exempt parcels — demonstrating that no net loss will be achieved. While detailed no net loss calculations and methodo logy are provided separately on tables provided to HCD staff, this analysis will focus on demonstrating that the Alternative Sites are suitable for residential development and comply with Gov. Code Sec. 65583.2 of State Housing Element law.

Table 1 (Affordable)
Exempt, Alternative, and Upzoned Site Unit Capacities

Number
of
Parcels
Total
Acreage
Total
Surplus
Alternative
Capacity
Total
Surplus
Upzoned
Capacity
Total Lost
Potential/Exempted
Capacity
(Less Existing Capacity to
Remain)
Total
Surplus
Capacity
Exempt
Parcels 569 380.75 -- -- 10,932 --
2 Number
of
Parcels
Total
Acreage
Total
Surplus
Alternative
Capacity
Total
Surplus
Upzoned
Capacity
Total Lost
Potential/Exempted
Capacity
(Less Existing Capacity to
Remain)
Total
Surplus
Capacity
Alternative
Sites 161 71.74 4,222 -- -- --
Upzoned
Sites 286 271.27 -- 17,068 -- --
TOTAL 4,222 17,068 10,932 10,358

Table 1.5 (Mixed-Income)
Exempt, Alternative, and Upzoned Site Unit Capacities

Number
of
Parcels
Total
Acreage
Total
Surplus
Alternative
Capacity
Total
Surplus
Upzoned
Capacity
Total Lost
Potential/Exempted
Capacity
(Less Existing
Capacity to Remain)
Total
Surplus
Capacity
Exempt
Parcels 281 244.99 -- -- 15,481 --
Alternative
Sites 320 139.96 9,648 -- -- --
Upzoned
Sites 194 215.15 -- 7,064 -- --
TOTAL 9,648 7,064 15,481 1,231

Sites Inventory Consideration
It is important to note that the capacity analysis is a planning exercise and does not mandate the elimination of existing use(s) or building(s) on a property. Instead, this analysis demonstrates that the City’s zoning and land use designations as applied to specific sites is adequate to accommodate possible units on specific sites. This capacity analysis looks at the Alternative Sites and applies the greater of the existing development capacities as permitted by the City’s land use plan which would be perm itted to be developed pursuant to AB 2011 streamlining or the densities permitted by AB 2011 , and calculates the resultant number of housing units that could be provided.

General Plan Density/Intensity
The City adopted the General Plan Update in 2022 and zoning ordinance amendments to increase residential densities for mixed -use designations and zones . Table 2 below illustrates the current maximum permitted densities by General Plan land use designation and groups the corresponding land uses of the Alternative Sites by AB 2011 category (i.e., Affordable or Mixed -Income). Please note that while maximums are provided in the Table 2, minimum development densities must comply with AB 2011.

Pursuant to AB 2011, a development project utilizing AB 2011 permit stre amlining must develop to at least the maximum permitted by the local jurisdiction’s land use plan or by default densities established by the law. This analysis will utilize the minimum default densities established for Affordable (30 dwelling 3 unit per acre ) or Mixed -Income (30-80 dwelling units per acre) where the General Plan does not permit equal to or greater densities for the alternative sites. In cases where the General Plan permits higher densities than those specified in AB 2011, the General Plan per mitted densities will be utilized as minimums.

Table 2
General Plan and AB 2011 Category (Affordable/Mixed-Income) Required
Density

General Plan Designations
Maximum
Density

AB 2011 -
Affordable

30 du/ac
Corridor Residential 30 du/ac
Urban Neighborhood-Medium Low 30 du/ac
Industrial Flex- Low 30 du/ac
Urban Neighborhood-Medium 40 du/ac
Urban Neighborhood-High 50 du/ac
District Center-Low 90 du/ac
District Center-Medium Low
90 du/ac
District Center-Medium
90 du/ac
District Center-Medium-High
90 du/ac
District Center-High
125 du/ac

AB 2011 –
Mixed-
Income
30 – 80 du/ac
Corridor Residential 30 du/ac
Urban Neighborhood-Medium Low
30 du/ac
Industrial Flex- Low
30 du/ac
Urban Neighborhood-Medium
40 du/ac
Urban Neighborhood-High
50 du/ac
District Center-Low
90 du/ac
District Center-Medium Low
90 du/ac
District Center-Medium
90 du/ac
District Center-Medium-High
90 du/ac
District Center-High
125 du/ac

Realistic Capacity Assumption
4 Pursuant to AB 2011, a development project utilizing AB 2011 permit streamlining must develop to at least the maximum permitted by the local jurisdiction’s land use plan or by default densities established by the law, whichever is greater. T he capacities included i n this analysis will utilize the minimum default densities established for Affordable (30 dwelling unit per acre) or Mixed-Income (30-80 dwelling units per acre) where the General Plan does not permit equal to or greater densities for the alternative sites . In cases where the General Plan permits higher densities than those specified in AB 2011, the General Plan permitted densities will be utilized. Since AB 2011 establishes minimum densities for permit streamlining qualification, this analysis will not inc lude a “realistic capacity” analysis as is typically found in housing elements. Rather, will rely on the AB 2011 minimum densities or the General Plan densities where they are greater in compliance with applicability requirements established in AB 2011 .

Site Infrastructure and Services
Water and Sewer Infrastructure
The City operates and maintains Santa Ana’s sewer system, which serves the entire city and portions of Garden Grove and Orange. The City’s sewer collection system consists of approximately 450 miles of sewer mains, including approximately 60 miles of Orange County Sanitation District (OCSD) regional trunk facilities within the city. The system operates largely by gravity and discharges at several locations into OCSD gravity trunk sewers for conv eyance to OCSD Treatment Plant 1.

The City’s most recent Sewer Master Plan update was performed in December 2016. The 2016 Sewer Master Plan Update Final Report (SMP) was an update to a sewer capacity analysis performed in 2003.

The 2016 SMP analyzed the age of the sewer infrastructure, and the capacity of the City’s sewer collection system for existing and future peak -flow conditions under both dry and wet weather conditions. In addition, the 2016 SMP summarized the rankings of the condition of the sewer pipes/manholes and the recommended rehabilitation and replacement of these sewers. The results of the capacity analysis and condition assessment are summarized below.

City Sewer Capacity
The capacity of the City’s sewer system was assessed for all major trunk lines with diameters ranging from 10 to 39 inches in size. In total, approximately 97 miles of City pipelines, 20 miles of OCSD trunk lines, and a total of 1,799 manholes were modelled. The capacity of the system was assessed for existing and future (2040) base flow scenarios in addition to peak wet -weather flows (PWWF) derived for a 10 -year storm event.

The SMP identified four areas of the City where sewer capacity deficiencies were identified. The most significant areas of potential wet weather capacity deficiencies are between Fairhaven Avenue and 17th Street running through Old Grand Street, to Santa Clara Avenue, and then onto Wright Street in the northeastern area of the city.

In addition to the sewer capacity assessment, the City assessed t he condition of its sewer system. The review identified several defects in the condition in the sewer system, primarily in the central part of the city, including the downtown area. This area is known to have older pipes compared to the outer neighborhoods and consequently has more defect issues.

Capital improvement projects are prioritized to allocate available funds to critical projects based on risk of failure and level of impact to economic, social, and environment issues. Similar to many public agencies, 5 the City has an annual budget for replacing or rehabilitating aging infrastructure and therefore requires a systematic and defensible method for prioritizing both capacity and condition -based improvement projects. The SMP has aided in prioritizing projects on each year’s CIP. The SMP references 20 projects for Fiscal Year (FY) 2016/2017 to FY 2020/2021. The current 2018/2019 CIP sewer projects are listed below:
 Bristol Street Sewer Main Improvements
 Santa Ana Memorial Neighborhoods Sewer Main Improvemen ts  Warner Garnsey Sewer Main Diversion Improvements (project listed in SMP as CIP -CAP-006A)  Willard Neighborhood Sewer Main Improvements

Furthermore, the current CIP projects currently under design or construction are listed below:
 Citywide Sewer Main Improvements Phase II
 Columbine Sewer Main Improvements
 Washington Square Neighborhood Sewer Main Improvements  Flower Street Sewer Main Improvements (Washington Street – 17th)  Segerstrom/San Lorenzo Sewer List Station

In addition to the SMP and CIP sewer sys tem management procedures, the City currently requires sewer monitoring studies for all projects that go through the entitlement process. After submittal and review of these studies by City staff, if the sewer system is found to be deficient, the developer will be required to upsize the portion of the sewer pipe within the frontage of their property. There may be options depending on the condition of the sewer infrastructure for the developers to enter into a joint cost - sharing agreement with the City to co ver a portion of the cost for required upsizing that may be done by the City at a later date. If improvements are needed to infrastructure downstream of the project site, the developer may be required to participate and pay into the fair -share agreement cu rrently employed by the City. The fair -share agreement will allow the developer to fund a percentage of the downstream improvement that will be carried out by the City in the future. Therefore, the City has a robust process in place on a project-by-project basis to ensure the sewer system is functioning efficiently and will not impact development of any of the Alternative Sites.

Water Supply and Distribution
The City’s Water Utility provides water service within a 27 -square-mile service area. The service area includes the City of Santa Ana, and a small neighborhood in the City of Orange, near Tustin Avenue and Fairhaven by the northeast corner of Santa Ana. There are also Irvine Ranch Water District (IRWD) water lines that serve portions of the city. In ad dition, Orange County Water District (OCWD) provides recycled water service to portions of the city. Metropolitan Water District of Southern California (Metropolitan) also has delivery/conveyance lines that run through the city. The City’s water system has a total of nine reservoirs with a storage capacity of 49.3 million gallons, 21 groundwater wells, and seven imported water connections.

The 2017 Santa Ana Water Master Plan (WMP) is a multi -year capital improvement program to maintain the City’s water utility infrastructure systems in sound operable condition and to meet the level of service expectations of the City over the proposed planning period from 2017/2018 to 2039/2040. The WMP analyzed several components of the City’s water system, including groundwater well rehabilitation needs, reservoir and pump station status, distribution system upgrade needs, and other miscellaneous improvements. Maintaining groundwater wells has been given the highest priority as groundwater supply is more affordable as com pared with water supplies purchased from Metropolitan. The results of the water supply analysis indicated that the City’s water system has adequate capacity and distribution 6 capabilities to supply the entire water system demands using only groundwater well s. However, as discussed in the WMP, as of 2017, based on age of the existing pipe, 20 percent (about 560,000 feet of pipe) of the City’s distribution system has already past the pipe material’s typical useful life. By the end of the proposed planning peri od (fiscal year 2039/2040), 70 percent (about 1,870,000 feet of pipe) of the City’s distribution system will be past the material’s lifetime. In summary, while the City’s distribution system is robust and hydraulically sound, the system is old and needs to be systematically replaced. The recommended proposed pipeline replacement program is documented in the WMP, in addition to updates from the City’s most recent CIP Update and discussions with the City on the status of improvement projects.

The City obtain s water from two primary sources: local groundwater from the Orange County Groundwater Basin (OC Basin), which is managed by OCWD, and imported water from Metropolitan. The City is a member agency of Metropolitan. Groundwater production accounts for 70 to 77 percent of the water supply and Metropolitan-imported water supplies provide the remaining 23 to 30 percent. The City also receives recycled water from OCWD.

Overall, the City has documented that it is 100 percent reliable for a normal year, a single -dry year, and multiple dry year events from 2020 through 2040. Furthermore, the 2015 Metropolitan Urban Water Management Plan (UWMP) stated that Metropolitan would be able to meet the demands of its member agencies, including the City of Santa Ana, through 2 040. Therefore, imported water demands for the City are projected to be met through the 20 -year requirements of SB 610 and beyond. The City of Santa Ana 2015 UWMP also confirmed the ability of the local supplies and the OC Basin to meet the growing demands of the City, posing no water access or distribution issues to any of the Alternative Sites.

Dry Utilities
All of the Alternative Sites lie within developed areas and have access to full dry utilities , posing no challenges for development . Southern Califor nia Edison (SCE) is responsible for providing electric power supply to Santa Ana. SCE is one of the nation’s largest electric utilities providing service to more than 15 million people in a 50,000 -square-mile area of central, coastal, and Southern Californ ia. Natural gas is provided by the Southern California Gas Company (SoCalGas). SoCalGas service area span much of the southern half of California, from Imperial County on the southeast to San Luis Obispo County on the northwest, to part of Fresno County on the north, to Riverside County and most of San Bernardino County on the east. Natural gas is available throughout Santa Ana, and supplies are forecasted to remain constant through 2035. Additional dry utilities include various telecommunications providers and cable providers and solid waste collection. Republic Services provides solid waste collection service to the City, and solid waste is disposed at the Olinda Alpha Landfill in the City of Brea, which is under the operation by the Orange County Waste & Recycling Department.

Local and Regional Trends
Based on a survey of recent housing development over the past 10 years in Santa Ana and ongoing development applications for housing and mixed-use projects, nearly all consist of redevelopment of sites with existing improvements. Santa Ana is an entirely built out city with very limited vacant land available to accommodate new development of any sort. The City has established a variety of mixed -use zones to accommodate additional residential development in districts and along major corridors. Current development trends in mixed -use areas show that high residential density is feasible and realistic, and 7 appropriate to accommodate housing for all income level s. Sites t hat have been redeveloped include social lodge s, religious facilities , office buildings, industrial buildings, older/smaller mu lti-family residential, and single-family units. The buildings tend to be older than 30 years of age and have been at various levels of physical repair/maintenance. It is of note that many of the office and industrial buildings that underwent or are currently undergoing redevelopment were not in physical distress or economic decline. Rather, the underlying land values presente d opportunities to redevelop despite the existing improvements’ value. See Table 3 for listing of projects in Santa Ana , which include s previously existing use, age of building, and its location in relation to high quality transit areas.

Table 3
Mixed-Use and Housing Trends
Projects Completed/Under Construction
Project Address Units
Affordability
Project Description
Previously Existing Use/Building
Meets Site
Suitability
Criteria
Status
Lower Mod. Above Use Building
Age
Located on
High Quality
Transit Area
*2112 E.

First St.
552 547 -- 5
Demolition of two (2)
office/commercial
buildings (approximately
64,713 square feet) and
construction of a mixed-
use development with
552 multi-family
residential units and
10,000 square feet of
commercial space.

Office/com
mercial
buildings
1970 No
Meets
Criteria 2,
Criteria 4,
and Criteria
5 Complete
1660 E. First St. 603 -- -- 603
Demolition of a social
lodge building
(approximately 38,379
square feet) and
construction of a mixed-
use development with
603 multi-family
residential units and
8,900 square feet of
commercial space.

Social lodge
building 1963 No
Meets
Criteria 2,
Criteria 4,
and Criteria
5 Complete
2300 S. Redhill
Ave.
1,100 -- -- 1,100
Demolition of three
industrial buildings
(approximately 154,096
square feet) and
construction of a mixed-
use development with
1,100 multi-family
residential units and
approximately 80,000
square feet of
commercial space.

Vacant/Ind
ustrial
buildings
1979 No
Meets
Criteria 2,
Criteria 4,
Criteria 5,
and Criteria
6 Complete
8 Project Address Units
Affordability
Project Description
Previously Existing Use/Building
Meets Site
Suitability
Criteria
Status
Lower Mod. Above Use Building
Age
Located on
High Quality
Transit Area
2800 N. Main St. 309 -- -- 309
Construction of 309
multi-family residential
units. Parking lot

Yes
Meets
Criteria 2,
Criteria 3,
Criteria 4,
and Criteria
6 Complete
*301 E. Santa
Ana Blvd. 93 92 -- 1
Demolition of religious
facility and the
construction of a mixed-
use development with 93
multi-family residential
units and 2,722 square
feet of commercial
space.

Religious
facility
1969 Yes
Meets
Criteria 2,
Criteria 3,
Criteria 4,
and Criteria
5 Complete
*801 E. Santa
Ana Blvd. 17 16 -- 1
Construction of a
two-story
building with 17
flats/apartment
units and
covered parking.

Vacant/
Two single-
family
residences
1913 Yes
Meets
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6 Complete
1513 W. Civic
Center Dr. 8 -- -- 8
Demolish duplex
and subdivide
site into four
lots, each
proposed with
two units.

Single-
family
residence
and Duplex
1966 Yes
Meets
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6 Complete
301 N. Mountain
View St. 8 -- -- 8
Demolition of
two detached
single-family
residences and
construct eight
units.

Two single-
family
residences
1959 Yes
Meets
Criteria 3,
Criteria 4,
Criteria 5,
and
Criteria 6
Under
Construction
*Indicates an affordable housing project.

A survey of housing and mixed-use projects built, under construction , or approved in the neighboring cities of Anaheim, Garden Grove, and Westminster shows a similar trend of development happening on sites with exi sting improvements. See Table 4 for a listing of recently built, under construction, or approved housing or mixed-use projects in neighboring jurisdictions. This table also identifies built affordable housing in neighboring jurisdictions. The prior property conditions of non -vacant sites that were recently developed into new residential and mixed-use projects within the region signify a trend that can be used for selecting other sites suitable for redevelopment in Santa Ana. These include a range of building conditions and exi sting land uses. The sites previous uses consisted primarily of commercial, industrial and/or residential uses. Many of the sites include commercial buildings such as used car dealerships, restaurants, car washes, industrial warehouse, offices, religious f acilities, single-family 9 residences, and parking lots. These uses are also consistent with uses that were redeveloped locally in Santa Ana.

Table 4
Regional Mixed-Use and Housing Trends
Recently
Approved/Under
Construction Mixed
Use Project Address

Residential
Units
Affordability
Previous Existing Use Before Development
and Building Age Lower Mod. Above
Mod.
1600 W. Lincoln Ave.,
Anaheim

315 -- -- 315
Used vehicle dealership (building over 40
years old)
2970 W. Lincoln Ave.,
Anaheim

134 -- -- 134
Restaurant and car wash (buildings over 50
years old)
1910 S. Union St.,
Anaheim

332 -- -- 332
Industrial/warehouse (building over 30
years old)

1011-1091 N. Tustin
Ave., Anaheim

406
-- -- 406
Office building, small retail shopping center,
and large format retail store (buildings
between 20 and 30 years old)
1623 W. Cerritos Ave.,
Anaheim 57 -- -- 57
Single-family residence
2301-2331 W. Lincoln
Ave., Anaheim

152 -- -- 152
Office complex (building over 30 years
old)
12901 Lewis St.,
Garden Grove 70 -- -- 70
Church/religious facility and school
*10861 Acacia
Pkwy., Garden
Grove
47 47 -- --
Garden Grove United Methodist Church
and church operated pre-school and the
Head Start pre-school program
11222 Garden
Grove Blvd.,
Garden Grove
16 -- -- 16
Freestanding restaurant
*12811 Garden
Grove Blvd.,
Garden Grove
93 93 -- --
Restaurant and Automotive
buildings/uses
*14800 Beach
Blvd.,
Westminster
50 49 -- 1
Commercial businesses and parking lot
(buildings over 50 years old)
10 Recently
Approved/Under
Construction Mixed
Use Project Address

Residential
Units
Affordability
Previous Existing Use Before Development
and Building Age Lower Mod. Above
Mod.
*7122
Westminster
Blvd.,
Westminster
65 64 -- 1
Furniture store (buildings over 50 years
old)
*Indicates an affordable housing project.

Lot Consolidation Development Record
Lot consolidation, the process of combining multiple adjacent lots into a single larger parcel to facilitate development, is a common practice in built -out cities like Santa Ana. As discussed above, Santa Ana is an entirely built out city with very limited vacant land available to accommodate new development of any sort. Nearly all multi-family housing development projects consist of the consolidation of contiguous lots and the redevelopment of sites with existing improvements. Table 5 provides examples of recent development projects in Santa Ana that required lot consolidation, demonstrating its feasibility and effectiveness as a tool for promoting development in the city . Moreover, as these examples illustrate, lot consolidation is not a constraint to housing production in Santa Ana, rather, is a feature intrinsic to development in highly urbaniz ed areas.

Table 5
Example Projects that Required Lot Consolidation

Project Name Project Address
Number of
Parcels
Consolidated
Total
Number
of Units
Affordability
Project Status Very
Low
Low Moderate
Andalucia
815 N. Harbor
Blvd./816 N.

Figueroa St.
7 70 Constructed
(2017)
Crossroads at
Washington
1126 E.

Washington
Ave.
2 86 85 Constructed
(2024)
Legacy Square 609 N. Spurgeon
St. 2 93 75 17 Constructed
(2023)
Rafferty
401 N. Main
St./500 N. Bush
St.
10 220 11 Constructed
(2024)
The Arches
2530 W.

Westminster
Ave.
2 85 84 Constructed
(2024)
FX Residences 801 E. Santa Ana
Blvd. 4 17 16 Under
Construction
WISEPlace 1411 N.

Broadway 2 48 47 Under
Construction
Soni 1202 E. Third St. 2 2 Under
Construction
11 Project Name Project Address
Number of
Parcels
Consolidated
Total
Number
of Units
Affordability
Project Status Very
Low
Low Moderate
First and
Harbor Mixed-
Use
Development
101 N. Harbor
Blvd. 12 183 28 Entitled
Cabrillo
Crossing
Townhomes
1814 E. First St. 2 35 4 Under
Construction
Broadway
Live-Work
Development
1412 N.

Broadway 2 3 Constructed
(2024)
Duplex and
Two ADU
2246 S. Cypress
Ave. 4 4 Pre
Entitlement

General Plan Focus Areas
Santa Ana's Focus Areas, as defined in the General Plan, are strategically located throughout the city along major arterials with access to high quality public transportation and link the City’s existing form -based code areas . The Focus Areas provide opportunities to develop a breadth of housing types at densities ranging from 20 to 125 dwelling units per acre by right, and stand to address the diverse housing needs of the community. These areas, characterized by existing, under construction, and planned infrastructure and growth potential, are envisioned as mixed -use hubs combining residential, commercial, and recreational elements. A detailed description of each Focus Area can be found on the interactive Gene ral Plan website (https://general-plan-santa-ana-ca.proudcity.com/ ).

The Focus Areas have already begun to experience rapid chang e and increased opportunity for residents.

The West Santa Ana Boulevard Focus Area parallels the OC Streetcar route, Orange County’s first modern streetcar that will run 4.15 miles and connect to the regional train network by way of the Santa Ana Regional Transportation Center , offering multi -modal mob ility options and residential development opportunities along the streetcar stations. The OC Streetcar is slated to be completed and operational in 2025. The Related Bristol Specific Plan was approved October 2024 in the South Bristol Focus Area , effectuating the vision for the Focus Area outlined in the General Plan . At buildout, Bristol Related will accommodate up to 3,750 residential units, a 250 -room hotel, a 200 -unit tower for senior living , and up to 350,000 square feet of restaurants and shops, as we ll as a grocery store and 13 acres of park space .

Additionally, the City has contracted the services of Torti Gallas + Associates to draft five pu blic realm plans, one for each Focus Area, to ensure infrastructure, pedestrian, bicyclist, and recreational needs are being met in the Focus Areas . This approach will fosters walkable environments with easy access to essential services and amenities , providing a high quality of life for all residents, including lower -income individuals residing in existing residences or future residents that will occupy units in future developments within these areas. As such, the Focus Areas are the ideal location for new residential development, opportunity, and housing mobility.

Specific Plan, Specific Development, and Overlay Zone Areas 12 The City’s specific plan , specific development, and overlay zone areas are connected to the General Plan Focus Areas, and are generally located along major arterials with public transportation options, such as the OC Streetcar, the Santa Ana Regional Transportation Center, and some of the only rapid bus routes in Orange County offered by the Orange County Transportation Authority. All of these areas have been planned for high density housing and will foster walkable environments with easy access to essential services and amenities, providing a high quality of life for all residents, including lower-income individuals residing in existing residences or future residents that will occupy units in future developments within these areas. These areas have also seen the most investment in terms of development within the City over the five years. As such, the specific plan, specific development, and overlay areas are the ideal location for new residential development, opportunity, and housing mobility.

Figure 1: General Plan Focus Areas, Specific Development, and Overlay Zone Areas

13 Criteria for Selecting Alternative Sites for AB 2011 - Affordable The following suitability criteria was used to identify parcels listed in Table 6 under the Meets Suitability Criteria column:

1. AB 2011 Site Criteria: AB 2011 requires that alternative sites comply with Government Code Sec. 65912.111(b) through (f).

2. Opportunity Areas: Opportunity areas are sites located within a Specific Plan area or a General Plan Focus Area. The City has a made a concerted effort over the past 10 years to foster development activity, the creation of community amenities, and public s ervice improvements into these areas.

These areas stand to provide improved access to opportunities into the future.

3. Access to Public Transit: Site is located within a high quality transit area.

4. Existing Use: Uses that are similar to those that have been previously recycled in surrounding communities (e.g., industrial uses, shopping centers and retail stores, office complexes, standalone restaurants and retail uses, and single -family buildings).

5. Year: Structure was built prior to 1985 (over 40 years of age ), making redevelopment of the site more probable.

6. Building/Land Value: Property improvement value is less than half of the land value (ratio is less than 1.00).

AB 2011 (Affordable) requires that all alternative sites comply with Government Code Sec. 65912.111(b) through (f). All sites identified in Table 6 below have been reviewed by HCD staff and determined to comply with the aforementioned Government Code section. The detailed site and environmental criteria analysis of the alternative sites is provided separately.

The alternative sites are within or near a specific plan area or General Plan Focus Area. These areas have been identified by the City for higher intensity development. These areas are also undergoing significant levels of reinvestment from both the City and the private sector. As such, they are opportune sites for redevelopment. Moreover, these areas provide housing opportunities for lower income residents in close proximity to amenities, jobs, resources, and mobility options.

Alternative sites were also selected based on proximity to public transportation options. Housing near transit can be beneficial for low -income residents by allowing them to live in areas with opportunities without the costs of car ownership.

Key sites with existing uses that are ripe for redevelopment typically contain older structures and are underutilized given the development potential afforded by the mixed -use development standards.

Examples of existing u ses on alternative sites include commercial uses, office, auto sales lots, structures with large surface parking lots, and single family residences. These align with uses identified in Table 3 and Table 4 which list housing/mixed -use projects in the City a nd region, including affordable housing, which have recently been entitled, are under construction, or completed.

The average building age for the sites is over 65 years old. The lifespan of a commercial building on average ranges from 50 to 60 years , depending on the preservation techniques employed by the owner and the 14 way the building is utilized. Most commercial buildings need an overhaul after 20 or more years to keep the building in suitable condition. Determining whether reinvestment to the properti es has occurred recently involves reviewing both the building -to-land value ratio and building age. The ratio is calculated by comparing the building improvement value (the value of improvements to the structure of the building) to the land value. These nu mbers are derived from the Orange County Assessor Department and are the assessed values for determining property taxes. To calculate assessed property values, all building improvement information from jurisdictions are sent to the Orange County Assessor D epartment during the building permitting process. If the building -to-land value ratio is less than one, it means that the building improvements are worth less than the property value. If building improvements are relatively new or the building is newer, ty pically a building-to- land value ratio can easily go above 2.0 to as high as

10.0. If the ratio is below one, or even below 0.5, it is a clear sign that there has not been recent building improvements to improve the condition. If the property has a low bu ilding-to-land value ratio with building over 50 years old, it is likely that building has not improved and deterioration may be occurring to structure, including to the façade, decline of the roof, and equipment and services (e.g., space and heating, ductwork, electrical work, etc.).

Table 6 summarizes the sites identified as alternative parcels, which can facilitate a total surplus capacity of 5,853 units. It also identifies if the site meets the suitability criteria for non -vacant sites. These sites comply with AB 2011 site criteria, are located with opportunity areas, have access to public transportation, contain existing commercial and/or residential uses that are of marginal economic viability, are at or near the end of their useful life, and/or the existing intensity of development is substantially lower than allowed by existing zoning. The criteria thresholds selected are based on regional trends for redevelopment of residential and mixed-use development.

Additionally, sites that are smaller than 0.5 acres have multiple parcels that are adjacent to each other and are appropriate for consolidation into larger development projects, achieving a lot size of at least 0.5 acres. These sites have common ownership, function as a part of a larger site currentl y, such as a commercial building with an adjacent parking lot, and/or are significantly underutilized and have been identified for potential projects.

For the purpose of calculating the net surplus capacity as shown in Table 6, individual parcels that mak e up a larger development site were aggregated and assigned a site identifier expressed by a number. The site identifier is shown in the column on the far left of Table 6 titled Lot Consolidation. These are sites that would require lot consolidation to occur to develop at the rates expressed in the table. Those parcels that do not have a Lot Consolidation number, could be developed without lot consolidation and do not include a Lot Consolidation num ber. The City’s General Plan Land Use Element indicates that when calculating the number of units permitted on a site based on permitted residential densities, the total number of units permitted shall be rounded down in any case where a fraction of a unit is permissible. For sites with a Lot Consolidation number, the total area of each parcel comprising the development site was aggregated before being multiplied by the permitted density. The product of the density calculation was then rounded down, as is required by the City’s General Plan, and included in the Net Surplus Capacity (consolidated and round down) column.

MainPlace Mall Site
The net surplus capacities for the MainPlace Mall site, Affordable Alternative/Upzoned Map ID Nos. 19 - 25 and Mixed -Income Alternative/Upzoned Map ID Nos. 18 -24 in Table 6 and Table 7 below , utilize a 15 similar approach outlined above. The total area of each parcel comprising the development site was aggregated before being multiplied by the permitted density. The product of the density calculation was then rounded down, as is required by the City’s General Plan, and included in the Net Surplus Capacity .

However, three of the seven parcels that make up the site (Affordable Alternative/Upzoned Map ID Nos. 20, 22, and 25; and M ixed-Income Alternative/Upzoned Map ID Nos. 19, 21, and 24) are entirely within the 500-foot freeway buffer. While AB 2011 does not permit housing to be developed within this area, the unit capacities derived by calculating the lot size multiplied by the b ase density allowances can be accommodated elsewhere on the development site, which includes approximately 27 acres of land that is outside of the freeway buffer area , that if developed alone at the base density of 90 dwelling units per acre could yield approximately 2,430 units at minimum . Through site planning and design, the site can be developed in accordance with AB 2011. Moreover, a majority of the site is owned by one entity and it largely functions as part of integrated center currently. As such, the parcels within the freeway buffer that are part of the MainPlace Mall site will be included in Table 6 and Table 7 below, as part of the calculations for the integrated development site and identified with a Lot Consolidation number . 16 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
10 70 005-184-01
Parking Lot
SP3 DC-1 90 47

0.002
Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
between 47
and 74 years
old

0.17 113
71 005-184-02 SP3 DC-1 90 47 0.17
72 005-184-03 SP3 DC-1 90 74 0.14
73 005-184-04 SP3 DC-1 90 56 0.15
77 005-184-14 SP3 DC-1 90 56 0.15
78 005-184-15 SP3 DC-1 90 60 0.15
82 005-184-29 SP3 DC-1 90 0.16
83 005-184-30 SP3 DC-1 90 56 0.17
20 76 005-184-10
Office
SP3 DC-1 90 94

0.76 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 94
years old

0.32 86
79 005-184-25 SP3 DC-1 90 101 0.64
21 940 398-455-02
Religious
Facility/Multiple
Detached
Residential Units
R2 UN-40 40 114

0.11 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings

0.15 34
941 398-455-03 R2 UN-40 40 42 0.15
942 398-455-04 R2 UN-40 40 112 0.14
943 398-455-05 R2 UN-40 40 61 0.13
944 398-455-06 R2 UN-40 40 123 0.07
945 398-455-07 R2 UN-40 40 62 0.07
946 398-455-08 R2 UN-40 40 58 0.13
17 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
947 398-455-09 R2 UN-40 40 104 over 42
years old

0.13 948 398-455-10 R2 UN-40 40 116 0.14
949 398-455-11 R2 UN-40 40 116 0.28
30 74 005-184-07
Office
SP3 DC-1 90 69

0.51 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 64
years old

0.17 59
75 005-184-08 SP3 DC-1 90 64 0.49
31 953 398-456-04
Religious
Facility/Detached
Residential Unit
R2 UN-40 40

0.04 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 108
years old

0.14 32
954 398-456-05 R2 UN-40 40 120 0.14
955 398-456-06 R2 UN-40 40 120 0.14
956 398-456-07 R2 UN-40 40 108 0.14
957 398-456-08 R2 UN-40 40 109 0.13
958
398-456-09 R2 UN-40 40 114 0.13
40 84 005-185-27
Office/School
SP3 DC-1 90 102

1.93 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings

0.28 188
86 005-185-34 SP3 DC-1 90 100 0.65
87 005-185-37 SP3 DC-1 90 46 1.16
18 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
over 46
years old
41 1025 398-562-01
Office
SP3 DC-1 90 53

7.13 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,
and Criteria
5; buildings
over 53
years old

1.55 144
1026 398-562-02 SP3 DC-1 90 54 0.06
50 88 007-161-02
Multiple
Detached
Residential Units
R2 CR-30 30 57

0.29 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 52
years old

0.13 21
89 007-161-03 R2 CR-30 30 107 0.13
90 007-161-04 R2 CR-30 30 99 0.13
91 007-161-05 R2 CR-30 30 79 0.14
92 007-161-06 R2 CR-30 30 58 0.14
93 007-161-07 R2 CR-30 30 101 0.05
94 007-161-08 R2 CR-30 30 62 0.08
95 007-161-09 R2 CR-30 30 74 0.13
96 007-161-10 R2 CR-30 30 52 0.13
97 007-161-11 R2 CR-30 30 102 0.14
98 007-161-12 R2 CR-30 30 98 0.13
99 007-161-13 R2 CR-30 30 74 0.13
51 1027 398-562-06
School/Parking
Lots
SP3 DC-1 90 64

3.15 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,

0.67 229 1028 398-562-09 SP3 DC-1 90 62 0.38
1029 398-562-10 SP3 DC-1 90 54 1.5
19 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
and Criteria
5; buildings
over 54
years old
60 105 007-163-02
Multiple
Detached
Residential Units
R2 CR-30 30 106

0.25 Meets
Criteria
1,Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 46
years old

0.14 36
106 007-163-03 R2 CR-30 30 56 0.14
107 007-163-04 R2 CR-30 30 76 0.13
108 007-163-05 R2 CR-30 30 61 0.13
109 007-163-07 R2 CR-30 30 57 0.15
110 007-163-08 R2 CR-30 30 46 0.14
111 007-163-10 R2 CR-30 30 114 0.13
112 007-163-11 R2 CR-30 30 63 0.13
113 007-163-12 R2 CR-30 30 112 0.13
114 007-163-13 R2 CR-30 30 101 0.13
115 007-163-14 R2 CR-30 30 99 0.15
116 007-163-15 R2 CR-30 30 78 0.13
117 007-163-16 R2 CR-30 30 99 0.13
118 007-163-17 R2 CR-30 30 97 0.14
119 007-163-18 R2 CR-30 30 107 0.15
120 007-163-19 R2 CR-30 30 95 0.13
121 007-163-21 R2 CR-30 30 112 0.15
122 007-163-22 R2 CR-30 30 67 0.13
70 100 007-162-01
Religious
Facility/Multiple
R2 CR-30 30 101

0.61 Meets
Criteria
1,Criteria 2,

0.28 12 101 007-162-03 R2 CR-30 30 102 0.14
102 007-162-04 R2 CR-30 30 84 0.11
20 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
103 007-162-05 Detached
Residential Units
R2 CR-30 30 34 Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
near or over
40 years old

0.17 104
007-162-06 R2 CR-30 30 52 0.14
80 123 007-164-01
Multiple
Detached
Residential Units
R2 CR-30 30 37

0.56 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
and Criteria
6; buildings
near or over
30 years old
or

0.29 8
124 007-164-02 R2 CR-30 30 24 0.14
125
007-164-03 R2 CR-30 30 101 0.14
90 128 007-183-01
Multiple
Detached
Residential Units
R1 UN-30 30 23

0.34 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
near 100
years old

0.15 17
129 007-183-02 R1 UN-30 30 23 0.15
130 007-183-03 R1 UN-30 30 104 0.15
131 007-183-04 R1 UN-30 30 23 0.15
132
007-183-05 R1 UN-30 30 102 0.15
91 1279 405-176-01
Multiple
Detached
Residential Units
R3 CR-30 30 32

0.52 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,

0.52 35 1280 405-176-02 R2 CR-30 30 101 0.14
1281 405-176-03 R2 CR-30 30 76 0.14
1282 405-176-04 R2 CR-30 30 84 0.14
21 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
1283 405-176-05 R2 CR-30 30 59 Criteria 5,
and Criteria
6; most
buildings
near 100
years old

0.14 1284 405-176-06 R2 CR-30 30 101 0.14
1285 405-176-07 R2 CR-30 30 101 0.14
1286 405-176-08 R2 CR-30 30 103 0.14
1287 405-176-09 R2 CR-30 30 78 0.14
1288 405-176-10 R2 CR-30 30 101 0.14
1289 405-176-11 R2 CR-30 30 102 0.14
1290 405-176-12 R2 CR-30 30 102 0.14
1291 405-176-13 R2 CR-30 30 101 0.14
1292 405-176-14 R2 CR-30 30 10 0.14
100
133 007-183-10
Multiple
Detached
Residential Units
R2 UN-30 30 106

0.31 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 50
years old

0.15 15
134 007-183-12 R2 UN-30 30 55 0.15
135 007-183-13 R2 UN-30 30 95 0.15
136 007-183-14 R2 UN-30 30 126 0.15
137 007-183-15 R2 UN-30 30 47 0.15
138 007-183-19 R2 UN-30 30 69 0.15
139 007-183-20 R2 UN-30 30 61 0.15
110
147 007-201-04
Multiple
Detached
Residential Units
R2 CR-30 30 112

0.14 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings

0.14 9
148 007-201-06 R2 CR-30 30 77 0.11
149 007-201-07 R2 CR-30 30 99 0.11
151 007-201-17 R2 CR-30 30 100 0.14
152 007-201-18 R2 CR-30 30 100 0.14
22 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
over 75
years old
120
174 008-082-16
Multiple
Detached
Residential Units
R2 UN-30 30 104

0.06 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5;
buildings
over 100
years old

0.14 6
175 008-082-17 R2 UN-30 30 111 0.14
176 008-082-18 R2 UN-30 30 111 0.14
124 1339 412-031-03 Multiple-family
Residential R4 UN-30 30 54 0.57
Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 5,
and Criteria
6; building
over 50
years old

5.64 84
130
183 008-091-01
Vacant/Multiple
Detached
Residential Units
SP1 UN-30 30

0.40 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
near 100
years old

0.27 57
184 008-091-02 SP1 UN-30 30 0.15
185 008-091-03 R2 UN-30 30 100 0.15
186 008-091-04 R2 UN-30 30 112 0.15
187 008-091-05 R2 UN-30 30 10 0.15
188 008-091-06 R2 UN-30 30 111 0.15
189 008-091-14 SP1 UN-30 30 0.15
190 008-091-15 SP1 UN-30 30 108 0.15
191 008-091-16 SP1 UN-30 30 110 0.15
23 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
192 008-091-17 SP1 UN-30 30 63 0.15
193 008-091-18 SP1 UN-30 30 87 0.15
194 008-091-19 R2 UN-30 30 114 0.15
140
342 011-154-20
Multiple-family
Residential
R3 UN-40 40 65

0.31 Meets
Criteria 1,
Criteria 2,
Criteria 5,
and Criteria
6; buildings
over 40
years old

0.28 113
343 011-154-21 R3 UN-40 40 41 0.26
344 011-154-22 R3 UN-40 40 44 0.37
345 011-154-23 R3 UN-40 40 67 0.32
346 011-154-24 R3 UN-40 40 65 0.72
347 011-154-25 R3 UN-40 40 67 0.65
348 011-154-33 R3 UN-40 40 52 0.24
174
20 002-210-48
Commercial
SP4 DC-2.1 90

0.09 Meets
Criteria 1,
Criteria 2,
Criteria 3,
and Criteria
6; building
34 years old

4.48 983 22 002-221-30 SP4 DC-2.1 90 34 3.28
25 002-222-01 SP4 DC-2.1 90 3.17
190
555 398-015-01
Office
SP3 DC-1 90 111

3.09 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5;
buildings
near or over
60 years old

0.13 123
556 398-015-02 SP3 DC-1 90 73 0.13
557 398-015-03 SP3 DC-1 90 59 0.13
558 398-015-04 SP3 DC-1 90 58 0.98
200
564 398-022-10
Office
SP3 DC-1 90 102

0.33 Meets
Criteria 1,
Criteria 2,

0.91 153
1359 398-022-12 SP3 DC-1 90 63 0.8
24 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 60
years old
220
652 398-231-01
Office and
Commercial
SP3 DC-1 90 94

0.42 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,
and Criteria
6; buildings
over 65
years old

0.13 113
653 398-231-02 SP3 DC-1 90 89 0.13
654 398-231-03 SP3 DC-1 90 66 0.13
655 398-231-06 SP3 DC-1 90 118 0.22
656 398-231-07 SP3 DC-1 90 0.22
657 398-231-08 SP3 DC-1 90 39 0.43
230
85 005-185-29
Commercial
SP3 DC-1 90 68

1.97 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5;
buildings
over 65
years old

1.25 157
686 398-244-01 SP3 DC-1 90 0.2
687 398-244-02 SP3 DC-1 90 107 0.3
240
889 398-384-09
Vacant
R2 UN-40 40 62

0.01 Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5,

0.26 20
890 398-384-11 R2 UN-40 40 51 0.14
891 398-384-12 R2 UN-40 40 111 0.14
892 398-384-15 R2 UN-40 40 0.28
25 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
and Criteria
6; buildings
over 50
years old
80 005-184-26 Parking Lot SP3 DC-1 90 22 2.36
Meets
Criteria 1,
Criteria 2,
Criteria 3

0.87 78
81 005-184-27 Office SP3 DC-1 90 76 1.06
Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5;
building over
75 years old

0.81 72
153 007-201-28 Residential R2 CR-30 30 10 0.68
Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
and Criteria
6 0.12 1
340 011-154-01 Commercial C2 UN-40 40 64 1.01
Meets
Criteria 1,
Criteria 2,
Criteria 4;
building over
60 years old

0.49 19
352 011-154-43 Multiple-family
Residential SD89 UN-40 40 5 2.83 Meets
Criteria 1 2.16 86
26 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)
and Criteria
2 547 396-361-02 Multiple-family
Residential R4 UN-30 30 54 4.84
Meets
Criteria 1,
Criteria 2,
Criteria 4,
Criteria 5;
building over
50 years old

6.35 146
551 398-011-01 Office SP3 DC-1 90 75 4.41
Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 4,
Criteria 5;
building over
75 years old

1.96 176
563 398-021-01 Mortuary SP3 DC-1 90 99 0.74
Meets
Criteria 1,
Criteria 2,
Criteria 3,
Criteria 5
and Criteria
6; building
near 100
years old

0.76 68
1125 402-222-04 Office R3 DC-3 90 1 0.00
Meets
Criteria 1,
Criteria 2,
Criteria 4,
and Criteria
6 3.96 356
27 TABLE 6
AB 2011 - Affordable Alternative Sites
Lot
Consolidation
MAP
ID APN Existing Use Zone GP
Designation
GP Max.

Density
(units/acre)
Building
Age
Building/Land
Value
Meets
Suitability
Criteria
Parcel
Size
(acres)
Net Surplus
Capacity
(consolidated
and rounded
down)

1347
430-221-14 Commercial M1 DC-2 90 39 1.06
Meets
Criteria 1,
Criteria 2,
Criteria 4,
Criteria 5;
building near
40 years old

2.79 251

1394
005-185-30 Live/Work and
Parking Lot SP3 DC-1 90 59 3.00
Meets
Criteria 1,
Criteria 2,
Criteria 3;
building over
55 years old

1.36 122
TOTAL 71.74 4,222
28 Criteria for Selecting Alternative Sites for AB 2011 – Mixed-Income Alternative sites for AB 2011 – Mixed-Income can support market rate multi-family development at ranges between 30 and 125 dwelling u nits per acre . Alternative sites for AB 2011 - Mixed-Income are located within or near a specific plan area or General Plan Focus Area. These areas have been identified by the City for higher intensity development. These areas are also undergoing significant levels of reinvestment from both the City and the private sector. As such, they are opportune sites for redevelopment. Moreover, these areas provide housing opportunities for lower income residents in close proximity to amenities, jobs, resources, and mobility options.

AB 2011 (Mixed -Income) requires that all alternative sites comply with Government Code Sec. 65912.121(b) through (f). All sites identified in Table 7 below have been reviewed by HCD staff and determined to comply with the aforementioned Government Code section. A detailed site and environmental criteria analysis of the alternative sites is provided separat ely. 29 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
6 534 398-235-03
Parking Lot
SD84 DC-3 90 0.14 80

19.2 19 535 398-235-04 SD84 DC-3 90 0.13 80
536 398-235-05 SD84 DC-3 90 0.21 80
7 703 398-334-01
Detached
Residential Units
SD84 UN-30 30 0.14 80

84.4 84
704 398-334-02 SD84 UN-30 30 0.14 80
705 398-334-05 SD84 UN-30 30 0.43 80
706 398-334-07 SD84 UN-30 30 0.72 80
8 867 398-591-08
Parking
Lot/Commercial
SD84 DC-3 90 0.09 80

19.2 19 868 398-591-09 SD84 DC-3 90 0.17 80
869 398-591-10 SD84 DC-3 90 0.22 80
10 63 005-184-01
Parking Lot
SP3 DC-1 90 0.17 80
113.4 113
64 005-184-02 SP3 DC-1 90 0.17 80
65 005-184-03 SP3 DC-1 90 0.14 80
66 005-184-04 SP3 DC-1 90 0.15 80
70 005-184-14 SP3 DC-1 90 0.15 80
71 005-184-15 SP3 DC-1 90 0.15 80
75 005-184-29 SP3 DC-1 90 0.16 80
76 005-184-30 SP3 DC-1 90 0.17 80
17 707 398-337-01 SD84 UN-30 30 0.14 80 35 35
30 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
708 398-337-02
Parking
Lots/Detached
Residential Units
SD84 UN-30 30 0.14 80
709 398-337-03 SD84 UN-30 30 0.14 80
710 398-337-04 SD84 UN-30 30 0.14 80
711 398-337-05 SD84 UN-30 30 0.14 80
18 879 398-593-07
Office
SD84 DC-3 90 0.43 80
26 26
880 398-593-08 SD84 DC-3 90 0.22 80
20 69 005-184-10
Lodge/Office
SP3 DC-1 90 0.32 80

86.4 86 72 005-184-25 SP3 DC-1 90 0.64 80
21 818 398-455-01
Religious
Facility/Detached
Residential Units
C2 UN-40 40 0.49 80
167.15 167
819 398-455-02 R2 UN-40 40 0.15 80
820 398-455-03 R2 UN-40 40 0.15 80
821 398-455-04 R2 UN-40 40 0.14 80
822 398-455-05 R2 UN-40 40 0.13 80
823 398-455-06 R2 UN-40 40 0.07 80
824 398-455-07 R2 UN-40 40 0.07 80
825 398-455-08 R2 UN-40 40 0.13 80
826 398-455-09 R2 UN-40 40 0.13 80
827 398-455-10 R2 UN-40 40 0.14 80
828 398-455-11 R2 UN-40 40 0.28 80
829 398-455-16 C2 UN-40 40 0.47 80
26 541 398-237-01 SD84 UN-30 30 0.44 80 67.5 67
31 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
542 398-237-02
Hall/Detached
Residential
SD84 UN-30 30 0.13 80
543 398-237-03 SD84 UN-30 30 0.06 80
544 398-237-04 SD84 UN-30 30 0.20 80
545 398-237-05 SD84 UN-30 30 0.52 80
27 712 398-338-01 Detached
Residential Unit
SD84 UN-30 30 0.09 80

7.5 7
713 398-338-09 SD84 UN-30 30 0.06 80
28 895 400-041-04 Office/Parking
Lots
P DC-3 90 2.01 60
267.3 267 896 400-041-05 P DC-3 90 0.96 30
30 67 005-184-07 Office SP3 DC-1 90 0.17 80 59.4 59
68 005-184-08 SP3 DC-1 90 0.49 80
31 830 398-456-02
Religious
Facility/Detached
Residential Units
C2 UN-40 40 0.13 80

91.2 91
831 398-456-03 C2 UN-40 40 0.14 80
832 398-456-04 R2 UN-40 40 0.14 80
833 398-456-05 R2 UN-40 40 0.14 80
834 398-456-06 R2 UN-40 40 0.14 80
835 398-456-07 R2 UN-40 40 0.14 80
836 398-456-08 R2 UN-40 40 0.13 80
837 398-456-09 R2 UN-40 40 0.13 80
841 398-456-19 C2 UN-40 40 0.05 80
37 727 398-371-15 SD84 UN-30 30 0.19 80 127.5 127
32 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
728 398-371-16
Multiple
Detached
Residential Units
SD84 UN-30 30 0.14 80
729 398-371-17 SD84 UN-30 30 0.14 80
730 398-371-18 SD84 UN-30 30 0.14 80
731 398-371-19 SD84 UN-30 30 0.14 80
732 398-371-20 SD84 UN-30 30 0.14 80
733 398-371-21 SD84 UN-30 30 0.14 80
734 398-371-22 SD84 UN-30 30 0.14 80
735 398-371-23 SD84 UN-30 30 0.14 80
736 398-371-24 SD84 UN-30 30 0.14 80
737 398-371-25 SD84 UN-30 30 0.15 80
738 398-371-26 SD84 UN-30 30 0.13 80
739 398-371-27 SD84 UN-30 30 0.14 80
740 398-371-28 SD84 UN-30 30 0.14 80
741 398-371-29 SD84 UN-30 30 0.14 80
742 398-371-30 SD84 UN-30 30 0.14 80
743 398-371-31 SD84 UN-30 30 0.14 80
744 398-371-32 SD84 UN-30 30 0.12 80
38 898 400-042-04 Office/Parking
Lot P DC-3 90 1.53 60 137.7 137
40 77 005-185-27 Office/School SP3 DC-1 90 0.28 80 188.1 188 79 005-185-34 SP3 DC-1 90 0.65 80
33 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
80 005-185-37 SP3 DC-1 90 1.16 80
41 860 398-562-01
Office
SP3 DC-1 90 1.55 80
144.9 144
861 398-562-02 SP3 DC-1 90 0.06 80
43 518 398-221-24
Office
P UN-30 30 1.67 80
176.8 176
519 398-221-26 P UN-30 30 0.23 80
520 398-221-27 P UN-30 30 0.21 80
521 398-221-28 P UN-30 30 0.10 80
47 750 398-372-04
Multiple
Detached
Residential Units
SD84 UN-30 30 0.14 80

49.5 49
751 398-372-05 SD84 UN-30 30 0.14 80
752 398-372-06 SD84 UN-30 30 0.14 80
753 398-372-07 SD84 UN-30 30 0.14 80
754 398-383-01 SD84 UN-30 30 0.14 80
755 398-383-02 SD84 UN-30 30 0.14 80
756 398-383-03 SD84 UN-30 30 0.15 80
48 900 400-043-04 Office/Parking
Lots
P DC-3 90 0.36 30 151.2 151
901 400-043-06 P DC-3 90 1.32 60
50 81 007-161-02
Multiple
Detached
Residential Units
R2 CR-30 30 0.13 80

94.9 94
82 007-161-03 R2 CR-30 30 0.13 80
83 007-161-04 R2 CR-30 30 0.13 80
84 007-161-05 R2 CR-30 30 0.14 80
85 007-161-06 R2 CR-30 30 0.14 80
34 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
86 007-161-07 R2 CR-30 30 0.05 80
87 007-161-08 R2 CR-30 30 0.08 80
88 007-161-09 R2 CR-30 30 0.13 80
89 007-161-10 R2 CR-30 30 0.13 80
90 007-161-11 R2 CR-30 30 0.14 80
91 007-161-12 R2 CR-30 30 0.13 80
92 007-161-13 R2 CR-30 30 0.13 80
51 862 398-562-06
School/Parking
Lots
SP3 DC-1 90 0.67 80
229.5 229 863 398-562-09 SP3 DC-1 90 0.38 80
864 398-562-10 SP3 DC-1 90 1.50 80
56 559 398-252-07 Office SD84 DC-3 90 1.70 80 68 68
57 775 398-385-06 Vacant/Multiple
Detached
Residential Units
SD84 UN-40 40 0.15 80

17.6 17 776 398-385-07 SD84 UN-40 40 0.15 80
777 398-385-08 SD84 UN-40 40 0.14 80
60 98 007-163-02
Multiple
Detached
Residential Units
R2 CR-30 30 0.14 80
159.9 159
99 007-163-03 R2 CR-30 30 0.14 80
100 007-163-04 R2 CR-30 30 0.13 80
101 007-163-05 R2 CR-30 30 0.13 80
102 007-163-07 R2 CR-30 30 0.15 80
103 007-163-08 R2 CR-30 30 0.14 80
104 007-163-10 R2 CR-30 30 0.13 80
35 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
105 007-163-11 R2 CR-30 30 0.13 80
106 007-163-12 R2 CR-30 30 0.13 80
107 007-163-13 R2 CR-30 30 0.13 80
108 007-163-14 R2 CR-30 30 0.15 80
109 007-163-15 R2 CR-30 30 0.13 80
110 007-163-16 R2 CR-30 30 0.13 80
111 007-163-17 R2 CR-30 30 0.14 80
112 007-163-18 R2 CR-30 30 0.15 80
113 007-163-19 R2 CR-30 30 0.13 80
114 007-163-21 R2 CR-30 30 0.15 80
115 007-163-22 R2 CR-30 30 0.13 80
61 918 400-062-03 Office/Parking
Lots P UN-40 40 0.48 30 19.2 19
64 1080 410-401-05 Plant Nursery C2 UN-30 30 0.34 30 10.2 10 66 561 398-254-01 Office/Parking
Lot
SD84 DC-3 90 0.43 80

26.8 26
562 398-254-02 SD84 DC-3 90 0.24 80
67 778 398-386-07 Detached
Residential Units
SD84 UN-30 30 0.11 80

12.5 12 779 398-386-08 SD84 UN-30 30 0.14 80
68 905 400-051-05
Office/Parking
Lot
P DC-3 90 0.90 30
207.9 207 949 400-051-12 P DC-3 90 0.95 30
908 400-051-13 P DC-3 90 0.46 30
36 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
70 93 007-162-01
Religious
Facility/Multiple
Detached
Residential Units
R2 CR-30 30 0.28 80

54.6 54
94 007-162-03 R2 CR-30 30 0.14 80
95 007-162-04 R2 CR-30 30 0.11 80
96 007-162-05 R2 CR-30 30 0.17 80
97 007-162-06 R2 CR-30 30 0.14 80
74 1090 410-411-21 Office/Parking
Lot C2 UN-30 30 2.10 30 63.0 62
78 906 400-051-06 Office/Parking
Lot P DC-3 90 1.65 60 148.5 148
80 116 007-164-01 Multiple
Detached
Residential Units
R2 CR-30 30 0.29 80

37.05 37 117 007-164-02 R2 CR-30 30 0.14 80
118 007-164-03 R2 CR-30 30 0.14 80
86 578 398-257-11 Parking Lot SD84 DC-3 90 0.28 80 11.2 11 87 803 398-441-31 Commercial C2 UN-40 40 0.08 30 3.2 3
90 121 007-183-01
Multiple
Detached
Residential Units
R1 UN-30 30 0.15 80

54.75 54
122 007-183-02 R1 UN-30 30 0.15 80
123 007-183-03 R1 UN-30 30 0.15 80
124 007-183-04 R1 UN-30 30 0.15 80
125 007-183-05 R1 UN-30 30 0.15 80
91 1050 405-176-01 Multiple
Detached
Residential Units
R3 CR-30 30 0.52 80
141.7 141 1051 405-176-02 R2 CR-30 30 0.14 80
1052 405-176-03 R2 CR-30 30 0.14 80
37 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
1053 405-176-04 R2 CR-30 30 0.14 80
1054 405-176-05 R2 CR-30 30 0.14 80
1055 405-176-06 R2 CR-30 30 0.14 80
1056 405-176-07 R2 CR-30 30 0.14 80
1057 405-176-08 R2 CR-30 30 0.14 80
1058 405-176-09 R2 CR-30 30 0.14 80
1059 405-176-10 R2 CR-30 30 0.14 80
1060 405-176-11 R2 CR-30 30 0.14 80
1061 405-176-12 R2 CR-30 30 0.14 80
1062 405-176-13 R2 CR-30 30 0.14 80
1063 405-176-14 R2 CR-30 30 0.14 80
94 1094 410-421-04 Office/Parking
Lot
C2 UN-30 30 1.52 60 205.2 205
1095 410-421-05 C2 UN-30 30 1.90 60
96 579 398-258-01
Office/Commerci
al
SD84 DC-3 90 0.27 80
28 28 580 398-258-02 SD84 DC-3 90 0.14 80
586 398-258-10 SD84 DC-3 90 0.09 80
587 398-258-11 SD84 DC-3 90 0.20 80
97 805 398-451-04 Multiple
Detached
Residential Units
SD84 UN-30 30 0.14 80

12.5 12 806 398-451-06 SD84 UN-30 30 0.11 80
100 126 007-183-10 R2 UN-30 30 0.15 80 68.25 68
38 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
127 007-183-12
Multiple
Detached
Residential Units
R2 UN-30 30 0.15 80
128 007-183-13 R2 UN-30 30 0.15 80
129 007-183-14 R2 UN-30 30 0.15 80
130 007-183-15 R2 UN-30 30 0.15 80
131 007-183-19 R2 UN-30 30 0.15 80
132 007-183-20 R2 UN-30 30 0.15 80
107
807 398-453-02
Vacant/Multiple
Detached
Residential Units
SD84 UN-30 30 0.06 80

66.8 66
808 398-453-03 SD84 UN-30 30 0.14 80
809 398-453-04 SD84 UN-30 30 0.14 80
810 398-453-05 SD84 UN-40 40 0.14 80
811 398-453-06 SD84 UN-40 40 0.54 80
812 398-453-07 SD84 UN-40 40 0.14 80
813 398-453-08 SD84 UN-30 30 0.14 80
814 398-453-09 SD84 UN-30 30 0.14 80
815 398-453-10 SD84 UN-30 30 0.06 80
110
137 007-201-04
Multiple
Detached
Residential Units
R2 CR-30 30 0.14 80

41.6 41
138 007-201-06 R2 CR-30 30 0.11 80
139 007-201-07 R2 CR-30 30 0.11 80
141 007-201-17 R2 CR-30 30 0.14 80
142 007-201-18 R2 CR-30 30 0.14 80
117 816 398-454-03 SD84 UN-30 30 0.14 80 24.2 24
39 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
817 398-454-14 Vacant/Detached
Residential Unit SD84 UN-40 40 0.43 80
120
162 008-082-16 Multiple
Detached
Residential Units
R2 UN-30 30 0.14 80

27.3 27 163 008-082-17 R2 UN-30 30 0.14 80
164 008-082-18 R2 UN-30 30 0.14 80
124 1105 412-031-03 Multiple-family
Residential R4 UN-30 30 5.64 80 366.6 366
130
171 008-091-01
Vacant/Multiple
Detached
Residential Units
SP1 UN-30 30 0.27 80
142.35 142
172 008-091-02 SP1 UN-30 30 0.15 80
173 008-091-03 R2 UN-30 30 0.15 80
174 008-091-04 R2 UN-30 30 0.15 80
175 008-091-05 R2 UN-30 30 0.15 80
176 008-091-06 R2 UN-30 30 0.15 80
177 008-091-14 SP1 UN-30 30 0.15 80
178 008-091-15 SP1 UN-30 30 0.15 80
179 008-091-16 SP1 UN-30 30 0.15 80
180 008-091-17 SP1 UN-30 30 0.15 80
181 008-091-18 SP1 UN-30 30 0.15 80
182 008-091-19 R2 UN-30 30 0.15 80
136
609 398-267-05 Parking
Lot/Commercial
SD84 DC-3 90 0.08 80

19.6 19
610 398-267-06 SD84 DC-3 90 0.13 80
40 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
611 398-267-09 SD84 DC-3 90 0.28 80
140
281 011-154-20
Multiple-family
Residential
R3 UN-40 40 0.28 30

85.2 85
282 011-154-21 R3 UN-40 40 0.26 30
283 011-154-22 R3 UN-40 40 0.37 30
284 011-154-23 R3 UN-40 40 0.32 30
285 011-154-24 R3 UN-40 40 0.72 30
286 011-154-25 R3 UN-40 40 0.65 30
287 011-154-33 R3 UN-40 40 0.24 30
145 504 398-101-13 Multiple-family
Residential SD84 DC-5 125 0.17 80 5.95 5
154 1231 412-141-10 Multiple-family
Residential C4 DC-2 90 0.83 80 74.7 74
156
615 398-274-01
Parking Lot
SD84 DC-3 90 0.14 80

11.6 11
616 398-274-02 SD84 DC-3 90 0.15 80
166
642 398-301-12
Multiple-family
Residential
SD84 UN-30 30 0.09 80
41 41
643 398-301-13 SD84 UN-30 30 0.18 80
644 398-301-16 SD84 UN-30 30 0.18 80
646 398-301-20 SD84 UN-30 30 0.37 80
174
19 002-210-48
Commercial
SP4 DC-2.1 90 4.48 60
1519.2 1519 20 002-221-28 SP4 DC-2.1 90 2.94 60
21 002-221-30 SP4 DC-2.1 90 3.28 60
41 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
22 002-221-51 SP4 DC-2.1 90 3.01 60
24 002-222-01 SP4 DC-2.1 90 3.17 60
176 649 398-302-02 Multiple-family
Residential
SD84 UN-30 30 0.08 80 21.5 21
653 398-302-14 SD84 UN-30 30 0.35 80
190
475 398-015-01
Office
SP3 DC-1 90 0.13 80
123.3 123 476 398-015-02 SP3 DC-1 90 0.13 80
477 398-015-03 SP3 DC-1 90 0.13 80
478 398-015-04 SP3 DC-1 90 0.98 80
196 658 398-311-05 Detached
Residential Units SD84 UN-30 30 0.11 80 5.5 5
200
481 398-022-10
Office
SP3 DC-1 90 0.91 80
153.9 153 1124 398-022-12 SP3 DC-1 90 0.80 80
206
670 398-321-05
Parking Lot
SD84 DC-3 90 0.29 80

27.6 27 671 398-321-07 SD84 DC-3 90 0.14 80
672 398-321-08 SD84 DC-3 90 0.26 80
216
675 398-324-02
Vacant/Multiple
Detached
Residential Units
SD84 DC-3 90 0.29 80

56.8 56
676 398-324-03 SD84 DC-3 90 0.14 80
677 398-324-08 SD84 DC-3 90 0.14 80
678 398-324-09 SD84 DC-3 90 0.14 80
679 398-324-10 SD84 DC-3 90 0.14 80
680 398-324-12 SD84 DC-3 90 0.57 80
42 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
220
522 398-231-01
Commercial
SP3 DC-1 90 0.13 80
113.4 113
523 398-231-02 SP3 DC-1 90 0.13 80
524 398-231-03 SP3 DC-1 90 0.13 80
525 398-231-06 SP3 DC-1 90 0.22 80
526 398-231-07 SP3 DC-1 90 0.22 80
527 398-231-08 SP3 DC-1 90 0.43 80
222
454 396-161-02
Commercial
C4 UN-30 30 0.76 30

44.1 44 455 396-161-03 C4 UN-30 30 0.55 30
457 396-161-08 C4 UN-30 30 0.16 30
226
685 398-327-01
Parking Lot
SD84 DC-3 90 0.22 80

23.2 23 687 398-327-07 SD84 DC-3 90 0.20 80
688 398-327-08 SD84 DC-3 90 0.16 80
230
78 005-185-29
Commercial
SP3 DC-1 90 1.25 80
157.5 157 555 398-244-01 SP3 DC-1 90 0.20 80
556 398-244-02 SP3 DC-1 90 0.30 80
237
1130 398-501-10
Parking
Lots/Commercial
SD84 DC-3 90 0.11 80

15.6 15 1129 398-501-11 SD84 DC-3 90 0.14 80
1128 398-501-12 SD84 DC-3 90 0.14 80
240
767 398-384-09
Vacant
R2 UN-40 40 0.26 80

53.3 53 768 398-384-11 R2 UN-40 40 0.14 80
43 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
769 398-384-12 R2 UN-40 40 0.14 80
770 398-384-15 R2 UN-40 40 0.28 80
246
693 398-332-04
Multiple
Detached
Residential Units
SD84 UN-30 30 0.14 80
71 71
694 398-332-05 SD84 UN-30 30 0.14 80
695 398-332-06 SD84 UN-30 30 0.14 80
696 398-332-10 SD84 UN-30 30 0.57 80
697 398-332-11 SD84 UN-30 30 0.43 80
254 529 398-234-04 Vacant SD84 DC-3 90 0.28 80 11.2 11
255
698 398-333-02
Multiple-family
Residential
SD84 UN-30 30 0.14 80

71.5 71
699 398-333-07 SD84 UN-30 30 0.14 80
700 398-333-10 SD84 UN-30 30 0.43 80
701 398-333-11 SD84 UN-30 30 0.43 80
702 398-333-12 SD84 UN-30 30 0.29 80
74 005-184-27 Office SP3 DC-1 90 0.81 80 72.9 72
1160 005-185-30 Live/Work and
Parking Lot SP3 DC-1 90 1.36 80 122.4 122
133 007-183-25 Commercial/Parki
ng Lot
C2,
SP1 UN-30 30 0.64 80 51.2 51
140 007-201-14 Residential C2, R2 CR-30 30 0.14 80 11.2 11 143 007-201-28 Residential R2 CR-30 30 0.12 80 7.8 7
279 011-154-10 Parking Lot R1 UN-40 40 0.49 30 14.7 14
44 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
291 011-154-43 Multiple-family
Residential SD89 UN-40 40 2.16 40 86.4 86
469 396-361-02 Multiple-family
Residential R4 UN-30 30 6.35 60 336.5 336
473 398-011-01 Office SP3 DC-1 90 1.96 80 176.4 176
480 398-021-01 Mortuary SP3 DC-1 90 0.76 80 68.4 68
665 398-315-01 Open Space SD84 UN-30 30 0.10 80 5.0 5
673 398-322-01 Office SD84 DC-3 90 1.44 80 57.6 57
674 398-323-08 Multiple-family
Residential SD84 DC-3 90 1.43 80 57.2 57
684 398-326-11 Parking Lot SD84 DC-3 90 0.69 80 27.6 27 852 398-503-11 Parking Lot SD84 DC-3 90 0.81 80 72.9 72 872 398-592-09 Office SD84 DC-3 90 0.31 80 12.4 12
883 398-601-04 Live/Work and
Parking Lot SD84 DC-3 90 0.51 80 20.4 20
885 398-603-02 Parking Lot SD84 DC-3 90 0.29 80 11.6 11 912 400-052-01 Office P DC-3 90 1.62 60 145.8 145
930 400-081-05 Office C5 DC-3 90 1.10 60 99 99
933 400-082-04 Office C5 DC-3 90 0.90 30 81 81
957 402-191-04 Office/Parking
Lot C2 DC-3 90 2.92 60 262.8 262
45 TABLE 7
AB 2011 – Mixed-Income Alternative Sites
Lot
Consolidation
Map
ID APN Existing Use Zone GP
Designation
GP
Max.

Density
(units/
acre)
Parcel
Size
(acres)
AB
2011
Base
Density
Net Surplus
Capacity
(Consolidated
Site)
Consolidated
Site Net
Surplus
Capacity
(Rounded
Down)
965 402-222-04 Office R3 DC-3 90 3.96 60 356.4 356
1083 410-401-09 Office C2 UN-30 30 1.38 30 41.4 41
1111 412-191-06 Multiple-family
Residential C4 UN-30 30 2.85 60 171.0 170
1113 430-221-14 Commercial M1 DC-2 90 2.79 60 251.1 251 TOTAL 139.96 9,690.45 9,648

46 Alternative Sites Capacity
The alternative sites inventory identifies a surplus capacity 4,222 units for Affordable and 9,648 units for Mixed-Income. Overall, the City has the ability to adequately accommodate the total residential capacity of potential units on exempt sites as required by AB 2011. These sites and the densities allowed meet no net loss requirements for both Affordable and Mixed -Income. The sites are located in areas that are considered highly likely to experience redevelopment for two key reasons: 1) the high demand for housing throughout the Southern California region, and 2) the availability of underutilized land in areas designated for high -density mixed -use and residen tial use. In addition, recent developments and market interest, new flexible and housing -supportive zoning standards (i.e., making the alternative sites eligible for AB 2011 streamlining), and density allowances will serve as a catalyst for more intense de velopment.

Table 8
Alternative Sites Inventory Summary
Sites Number of
Parcels

Total Area
(acres)
Total Surplus
Alternative
Capacity
(units)

Affordable 161 71.74 4,222
Mixed-Income 320 139.96 9,648

Assessment of Fair Housing
Affirmatively Furthering Fair Housing Analysis

Table of Contents
Assessment of Fair Housing ................................................................................................... 3

1.1 Introduction .................................................................................................................. 3

1.2 Sources of Information ................................................................................................. 3

1.3 General Plan ................................................................................................................ 4

1.4 Assessment of Fair Housing Issues ............................................................................. 8

1.5 Affordable Housing ...................................................................................................... 9

1.6 Patterns of Integration and Segregation ......................................................................11

1.7 Access to Opportunities ..............................................................................................56

1.8 Disproportionate Housing Needs ................................................................................92

1.9 Contributing Factors .................................................................................................. 123

Assessment of Fair Housing

1.1 Introduction
Assessment of Fair Housing (AFH) consistent with the core elements of the analysis required by the federal Affirmatively Furthering Fair Housing (AFFH) Final Rule of 2015. The goal of this assessment is to ensure that people have fair housing choice. The AFFH Act has two main purposes—prevent discrimination and reverse housing segregation.

To affirmatively further fair housing means “taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws” (Government Code § 8899.50(a)).

AB 2011 permits a local government to exempt a parcel from streamlined approval before a developer submits a development application on the parcel if: (1) the local government identifies one or more alternative sites for residential development; (2) the local government has permitted the alternative parcels not otherwise eligible for development pursuant to AB 2011 to be developed pursuant to AB 2011 streamlining; (3) the local government has permitted the alternative parcels that are subject to AB 2011 streamlining to be developed at densities above the residential density required in subdivision (b) of Section 65912.113 (100 percent affordable) or subdivision (b) of 65912.123 (Mixed- Income) of the Government Code; (4) the alternative development would result in no net loss of the total potential residential density in the jurisdiction; (5) the alternative development would result in no net loss of the potential residential density of housing affordable to lower income households in the jurisdiction; and (6) the alternative development would affirmatively further fair housing.

This assessment includes the following components: a summary of fair housing issues and an assessment of the City’s fair housing enforcement and outreach capacity; an analysis of segregation patterns and disparities in access to opportunities; an assessment of contributing factors, and an identification of fair housing goals and actions and related to housing and community development in a way that affirmatively furthers fair housing; and an analysis demonstrating that the alternative sites identified by the City of Santa Ana in its local implementing ordinance exempting certain sites from AB 2011 streamlining affirmatively furthers fair housing in a manner consistent with the AFFH Act.

1.2 Sources of Information
The City used a variety of data sources for the AFFH analysis at the regional and local level.

These include:
• U.S. Census Bureau’s Decennial Census and American
Community Survey (ACS)
• Orange County Analysis of Impediments to Fair Housing Choice, May 2020 (2020 AI). • Local Knowledge, including information gathered from planning outreach events for major projects such as the Housing Element Update, General Plan Update, and the Zoning Code Update.

Some of these sources provide data on the same topic through different methodologies, which results in various data outcomes. For example, the decennial census is based on a count of the entire population every 10 years while the ACS is based on a small but more detailed survey of the population conducted every year. For this reason, the Census data and ACS data often show some differences. This AFFH analysis includes the most relevant data source for identifying fair housing issues and trends.

1.3 General Plan
The Santa Ana General Plan, adopted April 19, 2022, provides long-term policy direction to guide the physical development, quality of life, economic health, and sustainability of the city through 2045. Informed by a comprehensive public engagement process, the General Plan establishes a shared vision of the community’s aspirations as the world- class capital of Orange County that celebrates diversity, neighborhoods, and cultural heritage.

Focus Areas
Santa Ana's Focus Areas, as defined in the General Plan, are strategically located throughout the city along major arterials with access to high quality public transportation and link the City’s existing form-based code areas. The Focus Areas provide opportunities to develop a breadth of housing types at densities ranging from 20 to 125 dwelling units per acre by right, and stand to address the diverse housing needs of the community. These areas, characterized by existing, under construction, and planned infrastructure and growth potential, are envisioned as mixed-use hubs combining residential, commercial, and recreational elements. A detailed description of each Focus Area can be found on the interactive General Plan website (https://general-plan-santa-ana- ca.proudcity.com/).

The Focus Areas have already begun to experience rapid change and increased opportunity for residents. The West Santa Ana Boulevard Focus Area parallels the OC Streetcar route, Orange County’s first modern streetcar that will run 4.15 miles and connect to the regional train network by way of the Santa Ana Regional Transportation Center, offering multi -modal mobility options and residential development opportunities along the streetcar stations. The OC Streetcar is slated to be completed and operational in 2025. The Related Bristol Specific Plan was approved October 2024 in the South Bristol Focus Area, effectuating the vision for the Focus Area outlined in the General Plan. At buildout, Bristol Related will accommodate up to 3,750 residential units, a 250- room hotel, a 200- unit tower for senior living, and up to 350,000 square feet of restaurants and shops, as well as a grocery store and 13 acres of park space. Additionally, the City has contracted the services of Torti Gallas + Associates to draft five public realm plans, one for each Focus Area, to ensure infrastructure, pedestrian, bicyclist, and recreational needs are being met in the Focus Areas. This approach will foster walkable environments with easy access to essential services and amenities, providing a high quality of life for all residents, including lower-income individuals residing in existing residences or future residents that will occupy units in future developments within these areas. As such, the Focus Areas are the ideal location for new residential development, opportunity, and housing mobility. The locations of the Focus Areas can be seen in Figure 1 and Figure 2. These plans are currently being developed and are expected to be completed in 2025 as a part of a larger General Plan implementation effort.

Special Development Areas
Midtown Plan
Santa Ana’s Midtown Plan is a strategic initiative aimed at revitalizing and transforming the Midtown area into a vibrant, mixed-use community that supports residential, commercial, and cultural growth. The plan focuses on enhancing connectivity, creating walkable neighborhoods, and encouraging transit -oriented development around key transportation hubs. By integrating affordable housing, public spaces, and improved infrastructure, the Midtown Plan seeks to balance economic growth with inclusivity and sustainability. It prioritizes the preservation of community character while attracting new investments that align with the City’s broader vision for equitable urban development. This initiative is part of Santa Ana’s efforts to create dynamic and livable neighborhoods that serve diverse residents and businesses. This area encompasses the northern part of Downtown and acts as a bridge between the South Main Focus Area, Transit Zoning Code, and the West Santa Ana Boulevard Focus Area.

Transit Zoning Code
Santa Ana’s Transit Zoning Code (TZC) is a comprehensive planning framework designed to promote transit -oriented development and sustainable urban growth. Focused on areas near major transportation corridors and hubs, the TZC encourages mixed- use, high- density developments that integrate housing, retail, and employment opportunities. The code prioritizes walkability, bicycle infrastru cture, and access to public transit, reducing reliance on cars and supporting environmentally friendly mobility options. It also incorporates affordable housing incentives, such as density bonuses, to ensure equitable development and mitigate displacement risks. By streamlining the development process and fostering a pedestrian-friendly urban environment, the TZC aligns with Santa Ana’s vision for a connected, livable, and sustainable city. The TZC is located east of the Downtown and Civic Center and borders the 5 freeway.

Metro East Mixed-Us
e Overlay Zone
Santa Ana’s Metro East Mixed-Use Overlay Zone (MEMU) is a targeted zoning strategy designed to transform the Metro East area into a dynamic, mixed-use urban environment. This overlay zone encourages the development of high- density residential, commercial, and office spaces within proximity to major transportation routes and employment centers. By fostering a blend of uses, the MEMU zone promotes walkability, reduces traffic congestion, and enhances access t o amenities for residents and workers alike. The zone includes incentives for incorporating affordable housing and green building practices, ensuring that growth is both inclusive and sustainable. Through the MEMU, Santa Ana aims to reimagine the Metro East area as a vibrant, interconnected community that supports economic development while addressing housing needs and environmental goals. The MEMU overlay zone border the TZC and the south end of the Grand and 17
th Street Focus Area. It then runs east across the 5 freeway.

Figure 1 – Santa Ana Focus Areas and Affordable Sites

Figure 2 – Santa Ana Focus Areas and Mixed Income Sites

1.4 Assessment of Fair Housing Issues
Federal fair housing laws prohibit discrimination based on race, color, religion, national origin, sex/gender, handicap/disability, and familial status. Specific federal legislation and court rulings include:
• The Civil Rights Act of 1866 covers only race and was the first legislation of its kind. • The Federal Fair Housing Act 1968 covers refusal to rent, sell, or finance. • The Fair Housing Amendment Act of 1988 added the protected classes of handicap and familial status.
• The Americans with Disabilities Act (ADA) covers public accommodations in both businesses and in multifamily housing developments.
• Shelly v. Kramer 1948 made it unconstitutional to use deed restrictions to exclude individuals from housing.
• Jones v. Mayer 1968 made restrictive covenants illegal and unenforceable.

California state fair housing laws protect the same classes as the federal laws, with the addition of marital status, ancestry, source of income, sexual orientation, and arbitrary discrimination.

Specific State legislation and regulations include:
• Unruh Civil Rights Act extends to businesses and covers age and arbitrary discrimination. • California Fair Employment and Housing Act (Rumford Act) covers the area of employment and housing, with the exception of single- family houses with no more than one roomer/boarder.
• California Civil Code Section 53 takes measures against restrictive covenants. • Department of Real Estate Commissioner’s Regulations 2780 to 2782 define disciplinary actions for discrimination, prohibit panic selling, and affirm the broker’s duty to supervise. • Business and Professions Code covers people who hold licenses, including real estate agents, brokers, and loan officers.

Santa Ana residents have access to information about fair housing enforcement, outreach capacity, and resources available to them. First, the California Department of Fair Employment and Housing (DFEH) accepts, investigates, conciliates, mediates, and prosecutes complaints under state and federal law. DFEH investigates complaints of employment and housing discrimination based on protected class. The program provides California’s tenants, landlords, and property owners and managers with a means of resolving housing discrimination cases in a fair, confidential, and cost-effective manner.

Community Legal Aid SoCal serves low -income people in Orange County with direct representation and engages in policy advocacy and impact litigation. Legal Aid provides legal assistance across a broad range of fair housing issues, including eviction, federally or otherwise publicly subsidized housing, substandard housing, landlord/tenant issues, homeownership issues, homeowners association issues, housing discrimination, and predatory lending practices.

The main office is in Santa Ana, with additional offices in Southern California. Community Legal Aid SoCal is funded by the Legal Services Corporation, which carries restrictions against representing undocumented clients.

Locally, the Fair Housing Council of Orange County provides a variety of services, including community outreach and education, homebuyer education, mortgage default counseling, landlord-tenant mediation, and limited low-cost advocacy. Their services are provided in English, Spanish, and Vietnamese. The Fair Housing Council also investigates claims of housing discrimination and assists with referrals to DFEH. The Council may also occasionally assist with or be part of litigation challenging housing practices.

1.5 Affordable Housing
Santa Ana has been a leader in affordable housing development in the region and currently has 14 family housing projects, 7 senior housing projects, 4 homeless housing projects, and 3 special needs housing projects that serve the community. Currently there are 3 additional housing projects under construction. A full list of the housing projects can be found here:
https://www.santa-ana.org/affordable-housing-resources/ The location of subsidized housing in the City can be seen in Figure 3. The City currently has 14 housing projects for families, 7 for seniors, 4 for people experiencing homelessness, and 3 special needs housing projects.

With the addition of AB 2011 alternative sites, there is an opportunity for increased development of housing for all affordability levels and to increase the access to affordable housing in the areas of the City that have the higher populations of vulnerable communities.

Figure 3 – Locations of Subsidized Housing

1.6 Patterns of Integration and Segregation
This section includes an analysis of integration and segregation, including patterns and trends, related to people with protected characteristics.

Race and Ethnicity
Ethnic and racial composition of a region is useful in analyzing housing demand and any related fair housing concerns, as it tends to demonstrate a relationship with other characteristics such as household size, locational preferences, and mobility.

The U.S. Department of Housing and Urban Development (HUD) provides racial or ethnic dissimilarity trends as an indicator of segregation. Dissimilarity indices can be used to measure how consistent two groups (frequently used to analyze race or ethnicity characteristics) are distributed across a geographic unit, such as a census tract or block group. The dissimilarity index ranges from 0 to 100, with 0 meaning no segregation and 100 meaning high segregation among the two groups. The following ranges show how HUD characterizes levels of dissimilarity:
• <40: Low Segregation
• 40–54: Moderate Segregation
• >55: High Segregation
Regional Trend
As shown in Table 1, racial/ethnic minority groups make up 59 percent of the Orange County population. 34 percent of the Orange County population is Hispanic/Latino, 39 percent of the population is White, 21.1 percent is Asian, and 1.6 percent is Black/African American. Santa Ana and the neighboring cities of Anaheim, Tustin, and Garden Grove have larger populations of racial/ethnic minority (non-White) populations compared to the County.

Table 1
Racial/Ethnic Composition: Orange County, Santa Ana, and Neighboring Cities Race/Ethnicity
Santa
Ana Anaheim Tustin
Costa
Mesa
Garden
Grove Irvine Orange County
Hispanic or Latino (of
any race) 76.7% 54.0% 40.0% 35.9% 36.9% 12.0% 34.0%
Not Hispanic or Latino 23.3% 46.1% 60.0% 64.1% 63.1% 88.1% 66.0% White alone 9.5% 23.2% 29.6% 40.1% 18.1% 37.4% 39.0%
Black or African
American alone 0.9% 2.5% 2.3% 1.3% 0.9% 1.7% 1.6%
American Indian and
Alaska Native alone 0.1% 0.1% 0.2% 0.1% 0.1% 0.1% 0.1%
Asian alone 11.8% 17.1% 24.1% 9.0% 41.7% 42.6% 21.1%
Native Hawaiian, Other
Pacific Islander alone 0.2% 0.4% 0.2% 0.6% 0.2% 0.3% 25.0% Some other race alone 1.0% 0.3% 0.2% 0.4% 13.0% 0.3% 0.3% Two or more races 0.8% 2.5% 3.3% 3.7% 5.4% 5.6% 6.0%
Source: 2021 American Community Survey (ACS), 5-Year Estimates.

As discussed previously, HUD’s dissimilarity indices can be used to estimate segregation levels over time. Dissimilarity indices for Orange County and Santa Ana are shown in Table 2.

Dissimilarity indices between non-White and White groups indicate that segregation in the county increased with regard to segregation since 1990. Segregation between Hispanic and White communities has increased to moderate levels after having had decreased to Low levels in 2010.

Segregation between Black and Asian/Pacific Islander communities with White communities has also increased but at lower levels than Hispanic communities. As a whole, Orange County has seen an increase in diversity since 1990. Non-White populations have been and continue to grow in concentration in central and northern portions of the County, primarily in cities such as Santa Ana, Westminster, Anaheim, Buena Park, and Norwalk.

Areas in central Orange County have the highest Dissimilarity Index values for their populations.

Orange, Santa Ana and Tustin are particularly affected. The Black/White index value for the city of Orange is 42.35, as opposed to a 22.63 Non-White/White index value. Neighboring Tustin has a 48.19 as their Black/White index value.

Table 2
Racial/Ethnic Dissimilarity Trends: Orange County and Santa Ana 1990 2000 2010 Current
Orange County
Non-White/White 30.48 36.54 35.55 40.20
Black/White 32.90 35.33 34.07 40.77
Hispanic/White 36.26 42.43 39.52 43.26
Asian or Pacific Islander/White 36.26 36.76 37.16 40.77 Santa Ana
Non-White/White 47.77 49.28 46.49 47.97
Black/White 36.53 27.91 25.15 33.97
Hispanic/White 53.09 53.61 50.00 51.40
Asian or Pacific Islander/White 43.10 46.77 46.87 48.78 Source: U.S. Department of Housing and Urban Development (HUD) Affirmatively Furthering Fair Housing (AFFH) Database, 2020.

Figure 4 shows that most central areas in Orange County have high concentrations of racial/ethnic minorities. Coastal cities, including Huntington Beach and Costa Mesa, and the areas east and southeast of Interstate 5 generally have smaller non-White populations. Most block groups inland, including Westminster, Garden Grove, Anaheim, and some parts of Irvine have majority racial/ethnic minority populations. Santa Ana’s racial/ethnic minority populations are comparable to the immediately surrounding jurisdictions. Coastal communities west and south of Santa Ana tend to have smaller racial/ethnic minority populations, and communities directly surrounding Santa Ana, such as Garden Grove and Westminster, have larger concentrations of racial/ethnic minorities.

The post-World War II period saw urbanization in Orange County, with white, middle class families moving to newly developed suburban communities, particularly along the coast. In contrast, working-class and immigrant populations were often relegated to older, urbanized areas like Santa Ana, where housing was more affordable, and employment opportunities (often in agriculture or industrial sectors) were closer. As a result, these inland areas became home to larger Latino and Asian immigrant communities, particularly after the Immigration and Nationality Act of 1965, which expanded immigration opportunities for non- European groups. This can still be seen today with the dissimilarity patterns throughout the region.

Figure 4 – Racial Demographics Percent of Non-White Population

Local Trend
According to the 2021 ACS, about 77 percent of the Santa Ana population identifies as being Hispanic or Latino of any race. In comparison, only 34 percent of Orange County residents identify the same. The City has a smaller population of White- alone residents compared to neighboring jurisdictions.

The Asian- alone population in Santa Ana (11.8 percent) is smaller than in surrounding cities (Anaheim, 17.1 percent; Tustin, 24.1 percent; and Garden Grove, 41.7 percent). However, the census tracts in the western part of Santa Ana, in the Riverview West neighborhood, have large concentrations of Asian residents. T he Asian population increased by 11 percent between the 2010 and 2020 census, the majority of which was Vietnamese. The concentration of Vietnamese residents in Santa Ana can be tied to the growing Vietnamese community of Little Saigon that was historically located in Westminster and now encompasses sizable communities in G arden Grove and west Santa Ana.

Santa Ana also has smaller population of Black- or African-American-alone residents (>1 percent) compared to many neighboring jurisdictions (Anaheim, 2.5 percent; Tustin, 2.3 percent; and Irvine, 1.7 percent). However, that was not always the case. The Central City neighborhood, roughly bounded by Bristol Street, McFadden Avenue, Raitt Street, and Santa Ana Boulevard, was once home to a thriving African-American population. Many community members served on military bases in Orange County and eventually settled in Santa Ana. However, many African- American families began to move out of Santa Ana during the late 1970s and 80s, with many relocating to the Inland Empire. Some religious institutions and businesses that served this community are still present in the neighborhood today.

Dissimilarity indices between non-White and White groups indicate that the city has also stayed almost the same with regard to segregation since 1990. Segregation between Black and White Hispanic communities has decreased, and segregation between Asian/Pacific Islander communities and White communities has increased.

Figure 5 and Figure 6 show predominant race in Santa Ana. The majority of the city is predominantly Hispanic or Latino. The Majority Hispanic and Latino population continues in the north into parts of Garden Grove, but this is in contrast to the predominantly Asian population to the West and Southeast.

AB2011 Sites Inventory
To assess the City’s AB2011 sites inventory, the distribution of sites by income category and predominant population are shown in Figure 5 and Figure 6. Most sites for affordable and mixed income are in areas where the predominant population is Hispanic or Latino. This is consistent with the demographics in the City. As shown in the figures, a majority of these sites are located in the central and northern parts of the City where existing general plan land use designations and zoning districts permit multi-family development are located. These areas are also served by high quality transit, such as rapid transit bus lines, the OC Streetcar, and the Santa Ana Regional Transportation center (SARTC), which connect to the broader Metrolink system. The locations of the sites have the potential to improve existing conditions through increased investment and provision of new services that will not only benefit new res idents but also improve the quality of life for all segments of the community, especially existing residents. The sites are also located in areas that have been designated for redevelopment through the City’s General Plan and Focus Areas. Current development trends show that high residential density is feasible and realistic, and appropriate to accommodate housing for all income levels and can be accommodated on the alternative parcel sites. Sites that have been redeveloped include social lodges, religious facilities, office buildings, industrial buildings, older/smaller multi-family residential, and single family units.

Exempt Sites
The sites exempted by the City are mostly concentrated along the west side of 17 th Street, the east side of 17 th Street, and Tustin Avenue on the east. These sites are generally not in Focus Areas or in areas that have been designated for redevelopment through the City’s General Plan.

Like the Alternative sites, the majority of the sites are in areas where the predominant population is Hispanic or Latino, matching the demographics of the City. The City’s local AB 2011 implementing ordinance exempted these parcels of land from the streamlining provisions with the identification of one or more alternative sites for each that result in a no net loss of the permitted residential density in the City.

Conclusion
In the case of predominant race, both the Alternative and Exempt sites are located in areas with the majority of the population identifies as Hispanic or Latino. Ultimately the Alternative sites are predominantly located in the central and northern areas of the City, where zoning and land use plans support multi-family development. With access to high-quality public transit, including rapid bus lines, the OC Streetcar, and connections to the Metrolink system via the Santa Ana Regional Transportation Center (SARTC), these locations are well positioned to attract new investment.

This new development has the potential to improve conditions for both new and existing residents by providing additional services and enhancing the overall quality of life for the entire community.

Figure 5 – Predominant Race and Affordable Sites

Figure 6 – Predominant Race and Mixed Income Sites

Figure 7 – Predominant Race and Affordable Exempt Sites

Figure 8 – Predominant Race and Mixed Income Exempt Sites

Disability
Persons with disabilities often have special housing needs because of the lack of accessible and affordable housing, and the higher health costs associated with their disability. In addition, many may be on fixed incomes that further limits their housing options. Persons with disabilities also tend to be more sus ceptible to housing discrimination due to their disability status and required accommodations associated with their disability.

Regional Trend
According to the 2021 ACS, 8.8 percent of Orange County residents experience a disability, while

8.2 percent of the Santa Ana population experiences a disability. Santa Ana has a smaller percentage of persons with disabilities compared to Garden Grove (10.9 percent) and Anaheim (8.8 percent) but larger than Irvine (5.6 percent) and Tustin (6.8 percent).

As shown in Figure 9, less than 20 percent of the population in most tracts in Orange County experiences a disability. Tracts with disabled populations exceeding 20 percent are not concentrated in one specific area of the county. Santa Ana and areas to the east have the smallest concentration of persons with disabilities and this is due to resources and housing in the census tracts with higher populations. The tracts with the highest population are locations of senior communities, most notably Leisure World to the west. The concentration of persons with disabilities in Santa Ana is comparable to neighboring cities.

Local Trend
Most tracts in Santa Ana have populations of persons with disabilities below 10 percent. A handful of census tracts in the northern, central, and western part of the city have a higher percentage of persons with disabilities. These tracts are home to a higher proportion of senior -headed households and residential-care facilities than the other tracts in the City. Independent living and cognitive difficulties are the most common disability type in Santa Ana; 4.4 percent of the population experiences an independent living difficulty, 3.7 percent experiences a cogni tive difficulty, 4.4 percent experiences an ambulatory difficulty, 2.3 percent experiences a hearing difficulty, 1.8 percent experiences a vision difficulty, and 2.4 percent experiences a self -care difficulty according to the 2021 ACS . According to the 2012 ACS Santa Ana had 7.1 percent of the population with a disability. The population with a disability is slowly growing, but does not show a drastic change since 2012.

AB2011 Sites Inventory
All AB2011 sites are in tracts where less than 20 percent of residents experience one or more disabilities as seen in Figure 10, Figure 11, and Table 3. A majority of these sites are located in the central and northern parts of the City where there is 10 percent or less of the population with a disability and where existing general plan land use designations and zoning districts permit multi-family development are located. These areas are also served by high quality transit, such as rapid transit bus lines, the OC Streetcar, and the Santa Ana Regional Transportation center (SARTC), which connect to the broader Metrolink system. The locations of the sites have the potential to improve existing conditions through increased investment and provision of new services that will not only benefit new residents but also improve the quality of life for all segments of the community, especially existing residents. The sites are also located in areas that have been designated for redevelopment through the City’s General Plan and Focus Areas. The Focus Areas will incorporate new recommendations to sidewalks, public gathering places, and local amenities, in order to reach and accommodate all residents. Current development trends show that high residential density is feasible and realistic, and appropriate to accommodate housing for all income levels and can be accommodated on the alternative parcel sites. Sites that have been redeveloped include social lodges, religious facilities, office buildings, and industrial buildings, older/smaller multi-family residential and single-family units.

Table 3
Distribution of Units by Disability
Affordable
Mixed
Income Total
< 10% 94% 92% 93%
10%–20% 6% 8% 7%
20%–30% 0% 0% 0%
30%–40% 0% 0% 0%
> 40% 0% 0% 0%
Total 4,222 9,648 13,870

Conclusion
For populations with disabilities, both the Alternative and Exempt sites are in areas where less than 10 percent of the population is affected. However, the Alternative sites are primarily situated in the central and northern parts of the City, where zoning and land use plans encourage multi - family development. These areas also benefit from excellent public transit options, including rapid bus lines, the OC Streetcar, and connections to the broader Metrolink system through the Santa Ana Regional Transportation Center (SARTC). As a result, these locations are well-positioned to attract new investment. The development of these sites has the potential to improve conditions for both new and existing residents, offering additional services and enhancing the quality of life for the entire community.

Figure 9 – Population with a Disability

Figure 10 – Population with a Disability and Affordable Sites

Figure 11 – Population with a Disability and Mixed Income Sites

Figure 12 – Population with a Disability and Affordable Exempt Sites

Figure 13 – Population with a Disability and Mixed Income Exempt Sites

Familial Status
Familial status refers to the presence of children under the age of 18, pregnant women, and any person in the process of securing legal custody of a minor child (including adoptive or foster parents). Housing discrimination can affect families with children, or families that recently had a child. This primarily happens through landlords refusing to rent to a family with children or evicting a family that just had a child. Under the Fair Housing Act, housing providers may not discriminate based on familial status.

Regional Trend
Approximately 55 percent of Santa Ana households are families with a married couple. Out of those couples, 48 percent have children (2021 ACS). The City’s share of households with a married couple is larger than the county’s share and the shares of the neighboring cities of Anaheim, Costa Mesa, Garden Grove, Irvine, and Tustin (Figure 14). Of the selected jurisdictions, Costa Mesa has the largest proportion of single-adult households, which represent 46.4 percent of all households in the City. In 2010, Orange County household makeup was relatively similar to today, with 54.2 percent of households being married couple households. However, the number of female headed households has increased with only 11.4 percent of households being headed by a female in 2010 to now being 24.3 percent.

Figure 14 – Households in Orange County, Santa Ana and Neighboring Cities

Local Trend
Santa Ana has seen a decrease in households with children since 2010. During the 2006- 2010 ACS, 47 percent of households had children. The 2017- 2021 ACS estimates that only 36.4

55.0% 50.5%

43.6%

53.5% 51.7% 52.9% 54.1%

6.8%

7.1%

10.0%

5.7% 5.7% 5.7% 6.0%

23.4% 26.5%

25.0%

24.5% 23.9% 26.8% 24.3%

14.9% 15.8% 21.4% 16.3% 18.7% 14.5% 15.5%

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

70.0%

80.0%

90.0%
100.0%
Santa Ana Anaheim Costa Mesa Garden Grove Irvine Tustin Orange County Married-couple household Cohabiting couple household
Female householder, no spouse or partner present Male householder, no spouse or partner present percent of households have children in Santa Ana, representing an approximate 10 percent decrease. According to the 2017-2021 ACS, approximately 27 percent of Santa Ana households are single parents with children, and 71 percent of those are female headed. Female- headed households with children require special consideration and assistance because of their greater need for affordable housing and accessible day care, health care, and other supportive services.

As shown in Figure 15 and Figure 16, there are tracts throughout the City that have a slightly higher number female headed households with children and a small cluster in the south that has over 40 percent of the households being female headed households with children and no spouse present.

AB 2011 Sites Inventory
In Santa Ana, a majority of the City’s AB 2011 sites are in tracts where 60 to 80 percent of households are married couple households with children (Table 4). The location of the sites and the units are consistent with the makeup of the city as a majority of the tracts in the City have 60 to 80 percent of the households being married couple households with children ( Figure 19 and Figure 20 ). The locations of the sites do not exacerbate existing conditions. Moreover, the locations of the sites have the potential to improve existing conditions through providing additional housing opportunities for families w ith children in areas where they already have established social networks and capital ensuring that families stay in the City.

Table 4
Distribution of Units by Children in Married Couple Households Affordable
Mixed
Income Total
< 20% 0% 0% 0%
20%–40% 0% 3% 2%
40%–60% 22% 27% 25%
60%–80% 51% 42% 45%
> 80% 27% 28% 28%
Total 4,222 9,648 13,870
Exempt Sites
The exempt sites designated by the City are primarily located along the west and east sides of 17th Street and Tustin Avenue to the east. These areas are generally outside of the City’s Focus Areas and not targeted for redevelopment under the General Plan. Similar to the Alternative sites, most of the exempt sites are in tracts where 60 to 80 percent of households are married couple households with children. The City’s AB 2011 implementing ordinance exempts these parcels from streamlining provisions, while identifying one or more Alternative sites to ensure no net loss of permitted residential density.

Conclusion
Both the Alternative and Exempt sites are located in areas where 60 to 80 percent of the population consists of married couple households with children. However, the Alternative sites are predominantly in the central and northern parts of the City, where zoning and land use plans promote multi-family development. The promotion of multi -family development in these areas allows for higher-density housing, making them ideal locations for apartments, townhomes, and condominiums. This provides more affordable housing options and increases the availability of housing units especially allowing for the potential for larger units to accommodate families. The Alternative sites being in and around downtown and the Focus Areas ready them for revitalization which includes have improved safety and walkability, with a growing focus on pedestrian-friendly streets and traffic calming measures making these sites a great place to keep our family populations.

Figure 15 – Children in Female Headed Household and Affordable Sites

Figure 16 – Children in Female Headed Household and Mixed Income Sites

Figure 17 – Children in Female Headed Households and Affordable Exempt Sites

Figure 18 – Children in Female Headed Households and Mixed Income Exempt Sites

Figure 19 – Children in Married Couple Households and Affordable Sites

Figure 20 – Children in Married Couple Households and Mixed Income Sites

Figure 21 - Children in Married Couple Households and Affordable Exempt Sites

Figure 22 – Children in Married Couple Households and Mixed Income Exempt Sites

Income
Identifying low- or moderate-income (LMI) geographies and individuals is important to overcome patterns of segregation. HUD defines an LMI area as a census tract or block group where over 51 percent of the population is LMI (based on HUD’s income definition of up to 80 percent of the AMI).

Regional Trend
As shown in Table 5, 44.8 percent of Orange County households are low/moderate income, earning 80 percent or less of the area median income (AMI). There are significantly more LMI Renter occupied households (61.8 percent of total households) compared to owner occupied households (32.1 percent of total households). Figure 23 shows LMI areas regionally. Coastal cities from Sea l Beach to Costa Mesa as well as the southern end of Irvine have low concentrations of LMI households. In these areas, less than 25 percent or 25 to 50 percent of the population is LMI in most tracts. LMI households are most concentrated in the central Orange County region around Santa Ana. There are smaller concentrations of LMI households in and around the cities of Garden Grove and Anaheim. Santa Ana has LMI household concentrations that are most similar with the cities immediately surrounding the city boundaries.

According to the ACS, in 2021 the median income for a household in Orange County was $100,485 up from $74,344 in 2010.

Table 5
Household Income Category by Tenure – Orange County
Income Category Owner Renter Total
0%-30% of AMI 8.3% 23.7% 14.9%
31%-50% of AMI 8.9% 17.4% 12.5%
51%-80% of AMI 14.9% 20.7% 17.4%
81%-100% of AMI 9.9% 10.5% 10.2%
Greater than 100% of AMI 57.9% 27.7% 45.0%
Total 588,550 436,425 1,024,975
Source: HUD CHAS based on 2013-2017 ACS.

Local Trend
More than half of Santa Ana households are in the low or moderate income categories. According to HUD’s definition, there are many LMI areas in Santa Ana, especially concentrated in downtown and the west side of the city. The west side of Santa Ana historically had a large number of industrial and manufacturing sites, which typically attracted lower-income workers.

According to the 2021 ACS, the median household income in Santa Ana is $77,283 significantly lower than $100,485 countywide. Santa Ana also has a lower median income than the nearby cities of Tustin ($93,901), Irvine ($114,027) and Anaheim ($81,806). Figure 24 and Figure 25 show median income in Santa Ana by tract. Downtown Santa Ana and the west side of the City has the lowest median incomes, with downtown being less than $55,000. In 2010, the median income was $54,877 and did not increase at the same rate as the median income in the County overall.

AB2011 Sites Inventory
Figure 24 and Figure 25 show the sites in relation to median income. Most of the sites are in areas where household income is between $55,000 to $90,100 (Table 6). The locations of the sites do not exacerbate existing conditions as they do not displace any local employers that provide living wages. The locations of the sites have the potential to improve existing conditions through increased investment and provision of new services that will not only benefit new residents but also improve the quality of life for all segments of the community, especially existing residents.

The sites are also located in areas that have been designated for redevelopment through the City’s General Plan and Focus Areas. The Focus Areas will fosters walkable environments with easy access to essential services and amenities, providing a high quality of life for all residents, including lower-income individuals residing in existing residences or future residents that will occupy units in future developments within these areas. Current development trends show that high residential density is feasible and realistic, and appropriate to accommodate housing for all income levels and can be accommodated on the alternative parcel sites. Sites that have been redeveloped include social lodges, religious facilities, office buildings, and industrial buildings, older/smaller multi-family residential and single-family units.

Table 6
Distribution of Units by Median Income
Affordable
Mixed
Income Total
< $55,000 27% 30% 29%
$55,000 - $90,100 68% 61% 63%
$90,100 - $120,000 5% 9% 8%
$120,000 - $175,000 0% 0% 0%
> $175,000 0% 0% 0%
Total 4,222 9,648 13,870

The City’s AB 2011 implementing ordinance exempts these parcels from streamlining provisions, while identifying one or more Alternative sites to ensure no net loss of permitted residential density.

Conclusion
Both the Alternative and Exempt sites are located in tracts where household income is between $55,000 to $90,100. However, the Alternative sites are predominantly in the central and northern parts of the City, where zoning and land use plans promote multi -family development. The promotion of multi-family development in these areas allows for higher -density housing, making them ideal locations for apartments, townhomes, and condominiums. This provides more affordable housing options and increases the availability of housing units especially a variety of housing types for a large range of incomes.

Figure 23 – Low to Moderate Income Population

Figure 24 – Median Income and Affordable Sites

Figure 25 – Median Income and Mixed Income Sites

Figure 26 – Median Income and Affordable Exempt Sites

Figure 27 – Median Income and Mixed Income Exempt Sites

Racially/Ethnically Concentrated Areas of Poverty
Racially and ethnically concentrated areas of poverty (R/ECAP) are geographies where a high percentage of the population are people of color who have lower incomes. HUD has identified census tracts with a non-white population of greater than 50 percent and with 40 percent or more of individuals living at or below the poverty line or are three or more times the average poverty rate for the metropolitan/micropolitan area, whichever threshold is lower.

Regional Trend
Black/African American, American Indian/Alaska Native, persons of a race not listed (“Some other race”), Native Hawaiian/Other Pacific Islanders, Asian Alone and Hispanic/Latino populations all experience poverty at a higher rate than the average countywide (Table 7). The proportion of non- Hispanic White residents under the poverty level is the lowest compared to other racial/ethnic groups in the county. Overall, in Orange County, 9.9 percent of all people are below the poverty level.

Table 7
Poverty Status by Race/Ethnicity
Percent Below Poverty Level
Santa Ana Orange County
White alone 11.6% 8.4%
Black or African American alone 10.4% 12.8%
American Indian and Alaska Native alone 10.0% 11.2%
Asian alone 12.9% 11.2%
Native Hawaiian and Other Pacific Islander alone 8.3% 10.0% Some other race alone 13.2% 14.9%
Two or more races 9.0% 8.3%
Hispanic or Latino origin (of any race) 12.5% 12.6%
White alone, not Hispanic or Latino 9.6% 6.9%
Overall 12.3% 9.9%
Source: 2021 American Community Survey (ACS), 5-Year Estimates.

Figure 28 shows R/ECAPs, TCAC-designated areas of high segregation and poverty, and poverty status in the Orange County region. R/ECAPs and areas of high segregation and poverty are seen in Santa Ana, Garden Grove, Anaheim and Costa Mesa. Tracts with larger populations of persons experiencing poverty are also concentrated in these areas (Error! Reference source not found. and Error! Reference source not found. ). There are no R/ECAPs near the boundaries of the City.

Local Trend

12.3 percent of the Santa Ana population is below the poverty level, higher than the rate countywide. Residents belonging to Asian alone experienced poverty at the highest rate. Over 13 percent of the population belonging to a race not listed (“some other race”), 12.9 percent of the Asian population and 12.5 % of the Hispanic or Latino of any race is below the poverty level.

There are R/ECAPs and TCAC-designated areas of high segregation and poverty in the city, and they are mainly concentrated in and around the downtown area (Figure 28, Figure 29, and Figure 30).

AB2011 Sites Inventory
The R/ECAP concentration in Downtown Santa Ana is also the location of 53 percent of the units that are being provided by the sites. These areas however are prime for redevelopment and have current projects under construction that will provide market rate and affordable housing that were first identified in the City’s Certified Housing Element. As shown in the figures, a majority of the AB2011 alternative sites are located in the central and northern parts of the City where existing general plan land use designations and zoning districts permit multi -family development are located. These areas are also served by high quality transit, such as rapid transit bus lines, the OC Streetcar, and the Santa Ana Regional Transportation center (SARTC), which connect to the broader Metrolink system. The locations of the sites have the potential to improve existing conditions through increased investment and provision of new services that will not only benefit new residents but also improve the quality of life for all segments of the community, especially existing residents. The sites are also located in areas that have been designated for redevelopment through the City’s General Plan and Focus Areas. With a greater concentration downtown, the West Santa Ana Boulevard Focus Area would bring great investment to this area greatly impacted by R/ECAP concentration. The West Santa Ana Boulevard Focus Area parallels the OC Streetcar route, Orange County’s first modern streetcar that will run 4.15 miles and connect to the regional train network by way of the Santa Ana Regional Transportation Center, offering multi -modal mobility options and residential development opportunities along the streetcar stations. The OC Streetcar is slated to be completed and operational in 2025. With development increasing citywide, the City has implemented measures to ensure that displacement of residents in vulnerable areas is reduced. The City has a Rent Stabilization and Just Cause Eviction Ordinance limiting annual rent increases for most rental units to 3% or 80% of the consumer price index (CPI), whichever is lower and includes protections for tenants, requiring landlords to provide a valid reason ("just cause") for evictions . Santa Ana has also focused on preserving its existing affordable housing stock by working with nonprofits and developers to acquire and rehabilitate propertie s, which includes numerous properties in the Downtown area. Current development trends show that high residential density is feasible and realistic, and appropriate to accommodate housing for all income levels and can be accommodated on the alternative parcel sites.

Table 7
Distribution of Units by R/ECAPs
Affordable
Mixed
Income Total
High POC Segregation 56% 51% 53%
Low-Medium Segregation 25% 34% 31%
Racially Integrated 19% 15% 16%
Total 4,222 9,648 13,870

Conclusion
Both the Alternative and Exempt sites are in areas where there is a R/ECAP. However, with the Alternative sites primarily situated in the central and northern parts of the City, zoning and land use plans encourage multi -family development that could lead to improved conditions for all residents. As a r esult, these locations are well positioned to attract new investment, especially following the City’s goals and policies set forth in the General Plan. The development of these sites has the potential to improve conditions for both new and existing residents, offering additional services and enhancing the quality of life for the entire community. This could lead to increased resources, more local jobs, and a variety of housing types, that could help eliminate the high POC segregation areas.

Figure 28 – County R/ECAPs

Figure 29 – R/ECAPs and Affordable Sites

Figure 30 – R/ECAPs and Mixed Income Sites

Figure 31 – R/ECAPs and Affordable Exempt Sites

Figure 32 – R/ECAPS and Mixed Income Exempt Sites

Racially/Ethnically Concentrated Areas of Affluence
While R/ECAPs have long been the focus of fair housing policies, racially concentrated areas of affluence (RCAA) must also be analyzed to ensure housing is integrated, a key to fair housing choice. A HUD Policy Paper defines racially concentrated areas of affluence as affluent, White communities. According to this report, Whites are the most racially segregated group in the United States and “in the same way neighborhood disadvantage is associated with concentrated poverty and high concentrations of people of color, conversely, distinct advantages are associated with residence in affluent, White communities.” Based on this research, HCD defines RCAAs as census tracts where 1) 80 percent or more of the population is white, and 2) the median household income is $125,000 or greater (slightly more than double the national median household income in 2016).

Regional Trend
Figure 33 shows that the City of Santa Ana has no racially concentrated areas of affluence itself, but there are areas surrounding the City within the County. There is a higher concentration of RCAAs in South County, particularly in Newport Beach and along the coast. There is also a high concentration to the east in Tustin and north towards Yorba Linda. These areas all have higher median income and a higher percentage of white only populations.

Local Trend
While Santa Ana is generally a diverse and lower income city, with a large Latino population, there are some areas of relative affluence. However, Santa Ana does not typically align with traditional definitions of RCAAs, which are more common in wealthy suburban or metropolitan areas where affluent, racially homogeneous communities form. West Flora l Park and Park Santiago are adjacent to Floral Park, one of the more affluent areas of Santa Ana. These two neighborhoods have higher incomes and are less racially diverse than other parts of Santa Ana, but these areas offer more development opportunity. These areas tend to have more single-family homes, larger lots, and greater access to amenities like parks, schools, and services. With the proximity of these neighborhoods to the West Santa Ana Boulevard Focus Area, these more affluent areas could influence growth in Downtown.

Figure 33 – Racially Concentrated Areas of Affluence

1.7 Access to Opportunities
To assess fair access to opportunities regionally and locally, this analysis uses HUD Opportunity Indicators and TCAC Opportunity Area Maps. This section also specifically addresses economic, education, environmental, and transportation opportunities.

HUD developed an index for assessing fair housing by informing communities about disparities in access to opportunity based on race/ethnicity and poverty status. Index scores are based on the following opportunity indicator indices (values range from 0 to 100):
• Low Poverty Index: The higher the score, the less exposure to poverty in a neighborhood. • School Proficiency Index: The higher the score, the higher the school system quality is in a neighborhood.
• Labor Market Engagement Index: The higher the score, the higher the labor force participation and human capital in a neighborhood.
• Transit Trips Index: The higher the trips transit index, the more likely residents in that neighborhood utilize public transit.
• Low Transportation Cost Index: The higher the index, the lower the cost of transportation in that neighborhood.
• Jobs Proximity Index: The higher the index value, the better access to employment opportunities for residents in a neighborhood.
• Environmental Health Index: The higher the value, the better environmental quality of a neighborhood.

To assist in this analysis, HCD and the California TCAC convened the California Fair Housing Task Force to “provide research, evidence- based policy recommendations, and other strategic recommendations to HCD and other related state agencies/departments to further the fair housing goals (as defined by HCD).” The task force created “opportunity maps” to identify resource levels across the state “to accompany new policies aimed at increasing access to high opportunity areas for families with children in housing financed with 9 percent Low Income Housing Tax Credits (LIHTCs).” These opportunity maps are made from composite scores of three different domains made up of a set of indicators related to economic, environmental, and educational opportunities and poverty and racial segregation. Based on these domain scores, tracts are categorized as Highest Resource, High Resource, Moderate Resource, Moderate Resource (Rapidly Changing), Low Resource, or areas of High Segregation and Poverty. Table 8 shows the full list of indicators.

Table 8
Domains and List of Indicators for Opportunity Maps
Domain Indicator
Economic
Poverty
Adult education
Employment
Job proximity
Median home value
Environmental CalEnviroScreen 4.0 pollution Indicators and values Education
Math proficiency
Reading proficiency
High School graduation rates
Student poverty rates
Poverty and Racial Segregation
Poverty: tracts with at least 30% of population under
federal poverty line
Racial Segregation: Tracts with location quotient
higher than 1.25 for Blacks, Hispanics, Asians, or all
people of color in comparison to the County
Source: California Fair Housing Task Force, Methodology for TCAC/HCD Opportunity Maps.

Regional Trend
HUD Opportunity Indicator scores for Orange County are shown in Table 9. For the county, the White population, including the population below the federal poverty line, received the highest scores in low poverty, labor market participation, jobs proximity, and environmental health.

Hispanic communities scored the lowest in low poverty, school proficiency, and labor market participation. Asian or Pacific Islander (non- Hispanic) communities scored the lowest in environmental health and jobs proximity, and was most likely to use public transit.

Table 9
HUD Opportunity Indicators by Race/Ethnicity: Santa Ana/Orange County Low
Poverty
School
Prof.

Labor
Market Transit
Low
Transp.

Cost Jobs Prox.

Env.

Health
Santa Ana - Total Population
White, non-Hispanic 43.58 40.95 48.31 92.62 80.95 74.89 10.29 Black, non-Hispanic 37.22 34.86 40.19 92.78 81.04 67.18 10.60 Hispanic 27.34 28.45 33.05 92.92 80.41 62.17 11.06
Asian or Pacific Islander, non-
Hispanic 37.32 41.90 37.03 92.43 79.82 52.24 10.44
Native American, non-Hispanic 30.92 33.84 37.35 92.65 79.81 61.51 Santa Ana - Population below federal poverty line
White, non-Hispanic 36.59 35.69 45.31 92.55 81.75 72.63 10.59 Black, non-Hispanic 30.40 34.66 39.64 91.94 82.25 76.57 10.44 Hispanic 22.21 27.00 30.56 93.36 82.18 60.87 10.98
Asian or Pacific Islander, non-
Hispanic 36.22 40.88 35.66 92.11 80.53 46.13 10.05
Native American, non-Hispanic 22.28 21.56 35.82 93.35 79.06 60.67 11.72 Orange County - Total Population
White, non-Hispanic 76.48 81.89 74.59 60.92 67.05 46.96 24.39 Black, non-Hispanic 69.50 75.53 68.16 74.64 71.50 44.07 15.23 Hispanic 58.20 67.52 59.65 75.35 73.08 45.50 15.65
Asian or Pacific Islander, non-
Hispanic 69.64 76.68 67.46 77.05 70.10 43.85 13.93
Native American, non-Hispanic 68.87 73.43 68.92 69.65 69.78 46.01 19.49 Orange County - Population below federal poverty line
White, non-Hispanic 68.31 77.99 69.03 62.05 71.85 49.98 24.26 Black, non-Hispanic 57.08 70.54 60.65 74.14 71.46 42.77 13.74 Hispanic 40.26 56.48 46.97 79.38 77.74 45.63 12.87
Asian or Pacific Islander, non-
Hispanic 59.82 72.84 58.95 82.14 75.35 40.98 10.57
Native American, Non-Hispanic 59.71 78.50 58.72 80.71 75.06 48.72 12.85 Source: HUD AFFH Database – Opportunity Indicators, 2020 Opportunity map scores for Orange County census tracts are presented in Figure 34. The central Orange County areas around Santa Ana comprise mostly low and moderate resource tracts and areas of high segregation and poverty. The central Orange County area, including Anaheim and Garden Grove, also has concentrations of low resource areas and some areas of high segregation and poverty. High and highest resource areas are most concentrated in coastal communities from Seal Beach and Huntington Beach to Newport Beach and in the unincorporated community of North Tustin and down towards South County.

Local Trend
The HUD Opportunity Indicator scores for Santa Ana are found in Table 9 Similar to the county data, the White population in Santa Ana, including the population below the federal poverty line, received the highest scores in low poverty and labor market participation. However, Asian or Pacific Islander (non-Hispanic) communities, including the population below the federal poverty line, received the highest scores for school proficiency. Hispanic communities above the federal poverty line scored the lowest in low poverty, school proficiency, and labor market participation.

Asian or Pacific Islander (non-Hispanic) communities scored the lowest in jobs proximity.

Opportunity map scores for Santa Ana census tracts are presented in Figure 35 and Figure 36 along with the City’s sites.

A majority of the tracts in the city are low to moderate resource tracts. There are pockets of High resource tracts located near the intersection of Bristol St. and 17th St., the tract that houses the entirety of Santa Ana College, and all other High resource tracts are in the cities periphery. There are no tracts in the highest resource category in Santa Ana. Two tracts in the city near the downtown area are classified as areas of high segregation and poverty.

AB2011 Sites Inventory
A majority of the sites are located in Moderate Resource areas with 60 percent of the affordable units being located in these areas. The location of the sites within resource areas reflect the pattern in the City with a majority of the tracts being moderate resource. The alternative sites are also within or near a specific plan area or General Plan Focus Area. These areas have been identified by the City for higher intensity development. These areas are also undergoing significant levels of reinvestment from both the City and the private sector and may change the level of resource available to residents. As such, they are opportune sites for redevelopment. Moreover, these areas provide housing opportunities for lower income residents in close proximity to amenities, jobs, resources, and mobility options.

Table 10
Distribution of Units by Opportunity
Affordable
Mixed
Income Total
High Segregation and
Poverty 23% 20% 21%
Low Resource 12% 21% 18%
Moderate Resource 60% 50% 54%
High Resource 5% 9% 8%
Total 4,222 9,648 13,870

Conclusion
Both the Alternative and Exempt sites are in areas where there are moderate access to resources.

However, with the Alternative sites primarily situated in the central and northern parts of the City, zoning and land use plans encourage multi -family development that could lead to improved conditions for all residents. As a r esult, these locations are well positioned to attract new investment, especially following the City’s goals and policies set forth in the General Plan. The development of these sites has the potential to improve conditions for both new and exis ting residents, offering additional services and enhancing the quality of life for the entire community .

In the City’s Opportunity Zone Prospectus from 2021 approximately 22% of Santa Ana is designated as an Opportunity Zone, covering over 3,800 acres acro ss 11 census tracts. These zones include key areas such as Downtown Santa Ana, the Civic Center, and the Santa Ana Regional Transportation Center where the Alternative sites have been identified. These opportunity Zones are said to encourage investment in projects that can help improve local infrastructure, housing, and businesses.

Figure 34 – County Opportunity Scores

Figure 35 - Opportunity Scores and Affordable Sites

Figure 36 – Opportunity Scores and Mixed Income Sites

Figure 37 – Opportunity Scores and Affordable Exempt Sites

Figure 38 – Opportunity Scores and Mixed Income Exempt Sites

Economic
As described previously, the Fair Housing Task Force calculates economic scores based on poverty, adult education, employment, job proximity, and median home values. See Table 8 for the complete list of TCAC Opportunity Map domains and indicators.

Regional Trend
As presented in Table 9, in Orange County , White residents have the highest labor market participation, and Hispanic residents have the lowest labor market participation. Figure 39 shows TCAC Opportunity Map economic scores in the Orange County region by tract. Consistent with final TCAC categories, tracts with the highest economic scores are concentrated in coastal communities from the Seal Beach and Huntington Beach to Newport Beach, areas around Irvine, and the unincorporated community of North Tustin. Tracts with economic scores in the lowest quartile are concentrated in central and northern regions of Orange County areas in cities such as Santa Ana, Garden Grove, Wes tminster, Stanton, Anaheim and Fullerton. Many of the cities in central and northern Orange County, such as Anaheim and Fullerton, historically grew around industries like agriculture, manufacturing, and railroads. The types of jobs these industries provided attracted lower-income workers. Even after the decline of manufacturing and agriculture, many residents remained in these areas due to affordable housing and established community networks.

Local Trends
As presented in Figure 40, the northeastern corner of the city, along the I-5, holds the tracts with the highest economic scores, in the third and fourth highest quartiles. As discussed previously, the tracts along the southeastern and southwestern city boundaries consist of mostly industrial and scored in the second lowest quartile for economic opportunity. The block groups along the central and western parts of the city have high concentrations of racial/ethnic minor ities, exceeding and scored in the lowest quartile for economic opportunity. Santa Ana was historically affected by redlining and other discriminatory housing practices. These policies prevented racial and ethnic minorities, particularly Latinos, from purchasing homes in wealthier, predominantly white neighborhoods. This forced minority communities to settle in more affordable, less desirable areas, which today corresponds to central and western Santa Ana.

AB2011 Sites Inventory
A majority of the sites are located in 0.2 to 0.4 economic opportunity score areas with 53 percent of the affordable units being located in these areas. The location of the sites within this level of economic opportunity areas reflect the pattern in the City with a majority of the tracts being in this range. The alternative sites are also within or near a specific plan area or General Plan Focus Area. These areas have been identified by the City for higher intensity development. Specific areas in Downtown are centered around several key developments and initiatives aimed at revitalizing the city and boosting its economic base. Downtown is considered a cultural and economic hub, with efforts to enhance public spaces and foster a vibrant community to attract both residents and businesses . The city is focusing on fostering business clusters in emerging sectors, such as information technology and green businesses, which align with sustainability goals. Santa Ana's economic strategy also encourages local small business development and community-led initiatives to strengthen its diverse economy . These economic revitalization projects not only aim to provide jobs but also improve the overall quality of life, especially in the areas currently lower in economic opportunity scores.

Table 11
Distribution of Units by Economic Opportunity
Affordable
Mixed
Income Total
0 - 0.2 4% 4% 4%

0.2 - 0.4 53% 44% 47%

0.4 - 0.6 22% 28% 26%

0.6 - 0.8 22% 23% 23%
> 0.8 0% 0% 0%
Total 4,222 9,648 13,870

Conclusion
Both the Alternative and Exempt sites are in areas where there are lower in economic opportunity scores. However, with the Alternative sites primarily situated in the central and northern parts of the City, zoning and land use plans encourage multi -family development that could lead to improved conditions for all residents. Santa Ana has implemented a variety of economic and housing initiatives aimed at revitalizing its downtown area and supporting this kind community growth. The city aims to enhance downtown as a mixed- income, transit -oriented hub w ith affordable housing options for all income levels. In the City’s General Plan a key policy is to also encourage the creation of “complete communities” where residents have access to housing, services, and amenities within walkable mixed-use neighborhoods. These efforts, combined with historic preservation and proactive tenant protection policies, are designed to make downtown Santa Ana a vital hub for the community.

Figure 39 – County Economic Scores

Figure 40 – Economic Scores and Affordable Sites

Figure 41 – Economic Scores and Mixed Income Sites

Figure 42 – Economic Scores and Affordable Exempt Sites

Figure 43 – Economic Scores and Mixed Income Exempt Sites

Education
As described above, the Fair Housing Task Force determines education scores based on math and reading proficiency, high school graduation rates, and student poverty rates. See Table 8 for the complete list of TCAC Opportunity Map domains and indicators.

Regional Trend
As presented in Table 9, White Orange County communities are located closest to the highest quality school systems, and Hispanic communities are typically located near lower quality school systems. TCAC Opportunity Map education scores for the region are shown in Figure 43. The central county areas, namely the cities of Santa Ana, Garden Grove, Anaheim, and Stanton, have the highest concentration of tracts with education scores in the lowest percentile. There is also a concentration of tracts with low education scores in Costa Mesa and some scattered tracts in Westminster and Huntington Beach. Coastal communities and areas near Irvine and the unincorporated community of North Tustin have the highest education scores.

Local Trend
Figure 43 shows TCAC education scores for Santa Ana tracts. Tracts in Santa Ana generally received education scores consistent with economic scores discussed above. A majority of the residential tracts in the city scored in the lowest quartile (scores below 0.25), while the northwestern corner of the city, where tracts received higher economic opportunity scores, only scored slightly better, with education scores in the second lowest education score quartile.

However, tracts along the western city boundary were also slightly better, with scores in the second lowest education quartile and one tract scoring in the second highest quartile (scores of

0.50 to 0.75), which is the highest scoring tract in the city.

According to the City’s Neighborhood Initiatives and Environmental Services team, community members have continually expressed that two primary factors directly affect their children’s ability to learn and excel in school—overcrowding and lack of youth- targeted community spaces and programs. Overcrowding was cited as affecting youth education through there not being t he physical space needed within the home for a child to concentrate and do their work. Often unpermitted subdivisions of common living areas in units are constructed to accommodate additional family members, leaving little to no space for a child to sit and study. Community members expressed that the lack of community spaces and programs further put those children that reside in overcrowded households at a disadvantage by not providing spaces where youth can study and engage in enrichment programs. According to residents, neighborhoods such as Cedar Evergreen, Townsend-Raitt, and Willard, where there is a strong gang presence, would benefit from providing spaces for youth, after -school programs, and strategies to keep students from dropping out.

The correlation between overcrowding and less positive education outcomes that was voiced by the community can be observed when comparing Figure 43 and Figure 68. The areas with less positive education outcome scores in Santa Ana are generally the same areas that have higher percentages of overcrowded households. Similarly, the tracts in the northwestern corner of the city and tracts along the western boundary, where education outcome scores are higher, are the same tracts where there are less overcrowded households.

AB2011 Sites Inventory
As discussed above, tracts in Santa Ana mainly scored in the lowest quartile (scores below 0.25), but there are a few exceptions in the northwestern corner of the city, where tracts received higher economic opportunity scores, only scored slightly better. In the City’s General Plan there are policies in place to address educational inequities, including partnerships between the city and educational institutions to improve resources for marginalized groups. There are efforts to integrate technology into schools to close the digital divide and ensure that students have access to necessary learning tools that would increase the education scores over time.

Exempt Sites
The exempt sites designated by the City are primarily located along the west and east sides of 17th Street and Tustin Avenue to the east. These areas are generally outside of the City’s Focus Areas and not targeted for redevelopment under the General Plan. Again, the entire City having lower educations scores shows the investment needed in education for all residents in the City Conclusion
With the Alternative sites primarily situated in the central and northern parts of the City, zoning and land use plans encourage multi -family development that could lead to improved conditions for all residents. The City aims to increase its education opportunity scores through a range of strategies focused on equity, infrastructure improvements, and support for students at all levels and have goals and policies in the General Plan to help accomplish this. One important note is infrastructure improvements that are being targeted in the Downtown and the South Coast Metro Area. By improving access to technology, particularly for students in underserved areas with infrastructure improvements such as high -speed internet, the City can help ensure that all students can engage in learning, both in school and at home. As stated in the General Plan, the City is striving to create more equitable educational opportunities for all residents.

Figure 44 – Education Scores
Environmental
TCAC environmental health scores are determined by the Fair Housing Task Force based on 12 of the indicators that are used in the California Office of Environmental Health Hazard Assessment’s (OEHHA) CalEnviroScreen 4.0 tool under the “exposures” and “environmental effect” subcomponents of the “pollution burden” domain. The CalEnviroScreen 4.0 tool considers (1) environmental factors such as pollutant exposure, groundwater threats, toxic sites, and hazardous materials exposure and (2) sensitive receptors, including seniors, children, persons with asthma, and low birth weight infants. Socioeconomic factors include educational attainment, linguistic isolation, poverty, and unemployment. Based on the environmental pollution and population indicators, the CalEnviroScreen ranks census tracts on a statewide level. A community or area that ranks in the 75th percentile statewide (25 percent worst) or above is considered a “disadvantaged community.” Disadvantaged or “EJ” communities have been identified as communities that are disproportionately burdened by multiple sources of pollution.

Regional Trends
Asian or Pacific Islanders (non -Hispanic) residents countywide are most likely to experience adverse environmental health conditions, while White residents are the least likely. The central part of the county, in the areas generally around I-5 have the lowest environmental TCAC scores (see Figure 45). The central Orange County cities of Santa Ana, Orange, and Anaheim all have concentrations of tracts with environmental scores in the lowest quartile. Tracts with the highest environmental scores are in western parts of the county (i.e., Cypress and west Anaheim), coastal cities (i.e., Seal Beach, Huntington Beach, and Newport Beach), and around the inland community of El Toro. CalEnviroScreen scores for the county generally follow a similar pattern to the TCAC scores, with the central Orange County cities having census tracts with greater environmental burdens than coastal areas (Figure 34).

Local Trends
TCAC environmental scores by tract in Santa Ana are shown in Figure 46 and Figure 47 as well as the location of Affordable sites and Mixed Income Sites respectively. Tracts in the central and western parts of the City received environmental scores in the second and third highest quartiles, while the tracts located along or in close proximity to the freeways (I -5, I-405, and SR-55) that traverse the city, generally along the eastern and southern boundaries, received scores in the lowest quartile. No tracts in the city received an environmental score in the highest quartile.

According to CalEnviroScreen, 26 census tracts in Santa Ana are disadvantaged communities, these tracts represent the 25% highest scoring census tracts in CalEnviroScreen 4.0. These tracts or Disadvantaged communities are located in the southeastern part of the city along an industrial corridor that parallels the SR-55, around the downtown area south of the I-5, in the city’s central core going westward to its boundary, and in the southwestern part of the city, which also has a large industrial land use base.

The location of Disadvantaged census tracts closely follows the historic development pattern of the city, proximity to freeways, and adjacency to industrial uses. The oldest portions of the city, located in and around the downtown area, that were developed when planning and environmental laws were not what they are today, tend to suffer from a disproportionate burden of environmental pollution. For example, the Logan neighborhood, the City’s earliest Mexican and Mexican- American neighborhood located northeast of downtown, is currently bounded by railroad tracks, the I-5 freeway, and industrial uses. While the railroad lines facilitated the initial growth of the neighborhood in the late 1800s, they also physically split the community from the rest of Santa Ana and encouraged past City officials to designate Logan for industrial uses despite opposition from residents. The construction of the I -5 freeway in the 1950s removed a number of single - family homes in the northeastern portion of the neighborhood and created a barrier between the community and the formerly open orchards. A 1970s proposal to bulldoze the neighborhood in order to expand an arterial highway along Civic Center Drive would have bisected and destroyed the community. Neighborhood leaders were successful in opposing this proposal and saved what was left of the neighborhood. Today, due to the proximity of the I -5 freeway, the railroad tracks, and the lasting legacy of industrial uses, Logan is within a census tract with one of the highest CalEnviroScreen scores in Santa Ana. Community members voiced concerns stemming from air pollution from the freeway, industrial uses, cemetery, and soil lead contamination most likely stemming from historical leaded-gasoline use and lead-based paint.

The disproportionate burden of environmental pollution facing certain communities in Santa Ana is being addressed in the City’s General Plan. The Disadvantaged communities’ census tracts coincide with the Environmental Justice (EJ) communities identified by the City in the General Plan with an addition of two census tracts. The City undertook a multiyear effort to engage EJ communities and listen to their experiences and issues regarding environmental health and quality of life. Planning staff facilitated a multifaceted outreach campaign culminating with a series of workshops in the Spring of 2021 (January through May). The campaign consisted of numerous community meetings, a multilingual EJ Survey (electronic and hard copy), and 10 virtual and 1 in- person community forums, each focusing on a specific EJ area in the city. Feedback received during the outreach campaign can be generally grouped into the following categories: improving air and water quality; improving public city facilities; improving infrastructure; providing healthy food options; providing safe and sanitary housing; increasing physical activity; and fostering civic engagement. The City has documented these environmental impacts to ensure alignment of mitigating policies, require appropriate remediation with other State agencies (e.g., Department of Toxic Control Substances), and direct investments to burdened communities as part of the new policies in the comprehensive General Plan. In total, 78 actions spread throughout the 11 elements in the General Plan and will directly lead to working with the community, neighborhood associations, advocacy groups, and community leaders to address environmental justice issues facing the Santa Ana community.

As of July 1 , 2022, the name of the Neighborhood Initiatives Program changed to the Neighborhood Initiatives and Environmental Services (NIES) program. The program continues to provide capacity -building support, project consultation and acts as a connector between neighborhoods, communities, public and regulatory agencies, and the City. NIES functions are to promote community solutions, capacity building, and civic engagement in addressing environmental justice challenges within the City as identified in the General Pl an. NIES will champion the important work and collaboration ahead regarding the framework and next steps for the implementation phases that focus on improving the environmental health, sustainability, and quality of life for disadvantaged communities and the overall City of Santa Ana.

AB2011 Sites Inventory
A majority of the sites are located in tracts with environmental scores of 60 through 80, which accounts for a majority of the City. Even with this being the case the City has a very proactive NIES team as described above and the General Plan with 78 actions to address environmental justice. With the majority of the City affected by environmental burdens, having a committed team to address those is the most important factor in ensuring a safe and equitable place for all to live.

Table 12
Distribution of Units and CalEnviroScreen Scores
Affordable
Mixed
Income Total
0 - 20 0% 0% 0%
20 - 40 0% 1% 0%
40 - 60 5% 9% 7%
60 - 80 52% 48% 49%
80 - 100 44% 43% 43%
Total 4,222 9,648 13,870

Conclusion
Both the Alternative and Exempt sites are in areas where there are environmental burdens .

However, with the Alternative sites primarily situated in the central and northern parts of the City, zoning and land use plans encourage multi -family development that could lead to improved conditions for all residents . The City and the NIES team has been actively addres sing environmental justice through a range of policies and initiatives designed to mitigate pollution, improve public health, and promote sustainability, particularly in the underserved communities that bear the brunt of environmental hazards. With the use of CalEnviroScreen data, the NIES team can create targeted initiatives in areas like Downtown to create a healthier, more equitable living environment for all residents.

Figure 45 – County CalEnviroScreen

Figure 46 – CalEnviroScreen and Affordable Sites

Figure 47 – CalEnviroScreen and Mixed Income Sites

Figure 48 – CalEnviroScreen and Affordable Exempt Sites

Figure 49 – CalEnviroScreen and Mixed Income Exempt Sites

Transportation
HUD’s Job Proximity Index, shown in Table 9, can be used to show transportation needs geographically. Block groups with lower jobs proximity indices are located further from employment opportunities and have a higher need for transportation. Availability of efficient, affordable transportation can be used to measure fair housing and access to opportunities. SCAG developed a mapping tool for High Quality Transit Areas (HQTA) as part of the Connect SoCal 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). SCAG defines HQTAs as areas within one- half mile from a major transit stop and a high -quality transit corridor. This section also utilizes All Transit metrics to identify transportation opportunities in Orange County and Santa Ana.

Regional Trend
All Transit explores metrics that reveal the social and economic impact of transit, specifically looking at connectivity, access to jobs, and frequency of service. Orange County’s All Transit Performance score is 4.2, compared to the cities of Orange (5.1), Garden Grove (5.5), Anaheim (4.9) Tustin (4.8), and Costa Mesa (5.4). Orange County All Transit metrics are shown in Figure

50. The County’s All Transit score indicates a low combination of trips per week and number of jobs accessible, enabling few people to take transit to work. All Transit estimates 99.0 percent of jobs and 87.4 percent of workers in Orange County are located within ½ a mile from transit.

Figure 50 – Orange County Transit Score
As shown in Figure 52, block groups around southern and eastern Santa Ana, northern Costa Mesa, Irvine, Newport Beach, and Orange have the highest jobs proximity index scores, indicating employment opportunities are most accessible in these areas. Central county areas, from central to western Santa Ana, Garden Grove, Westminster, Stanton, and parts of Huntington Beach have the lowest jobs proximity index scores.

Local Trend
All Transit metrics for Santa Ana are shown in Figure 51. Santa Ana received an All Transit Performance Score of 6.6, indicating a moderate combination of trips per week and number of jobs accessible by transit. Santa Ana’s score is higher than the county as a whole and is or near the highest in the county. All Transit estimates that 100 percent of jobs and 99.9 percent of workers in Santa Ana are within ½ a mile from transit.

Figure 51 – Santa Ana Transit Score
As shown in Figure 53, census blocks in the southern, eastern, and northern parts of Santa Ana received the highest jobs proximity index scores, exceeding 80, indicating that employment opportunities are very accessible in large parts of the city, with the exceptions being the central and western parts of the city, which scored in the lowest and second lowest quartiles. Additionally, nearly all of Santa Ana, with a few exceptions, is considered an HQTA (Figure 51).

AB2011 Sites Inventory
All sites are in areas with access to high quality transit. The General Plan uses HQTA principles to guide policies that will lead to a more sustainable urban growth. The West Santa Ana Boulevard Focus Area parallels the OC Streetcar route, Orange County’s first modern streetcar that will run

4.15 miles and connect to the regional train network by way of the Santa Ana Regional Transportation Center, offering multi -modal mobility options and residential development opportunities along the streetcar stations. Many, if not all of the sites in the City center will be serviced by this new mode of transportation offered for residents.

are in areas where there are less jobs within a 45 minute transit ride, but not much less than other areas of the City.

Conclusion
Both the Alternative and Exempt sites are in areas where there is adequate access to public transit. However, with the Alternative sites primarily situated in the central and northern parts of the City, there are more opportunities to use public transit. This will also be evident when the OC Street Car is completed. Overall, transportation and access to jobs is relatively high. As of the most recent data from the U.S. Bureau of Labor Statistics (BLS) and local economic reports, Santa Ana is home to a diverse job market across various industries. While the exact number of jobs can fluctuate over time, Santa Ana typically has around 150,000 to 170,000 jobs. A larger number of these jobs are in Government and Public Administration.

Figure 52 – County Proximity to Jobs

Figure 53 – Proximity to Jobs and Affordable Sites

Figure 54 – Proximity to Jobs and Mixed Income Sites

Figure 55 – Proximity to Jobs and Affordable Exempt Sites

Figure 56 – Proximity to Jobs and Mixed Income Exempt Sites

1.8 Disproportionate Housing Needs
Housing problems in Santa Ana were calculated using HUD’s 2023 Comprehensive Housing Affordability Strategy (CHAS) data based on the 2016- 2020 ACS. Table 13 breaks down households by race, ethnicity, and presence of housing problems for Santa Ana and Orange County households. The following conditions are considered housing problems:
• Substandard Housing (measured by incomplete plumbing or kitchen facilities) • Overcrowding (more than 1 person per room)
• Cost burden (housing costs greater than 30 percent)
In Santa Ana, 42.9 percent of owner -occupied households and 72.46 percent of renter households have one or more housing problems. The City has a larger proportion of owner and renter households with a housing problem compared to the county, where 32.6 percent of owner households experience a housing problem, and 59.1 percent of renter households experience a housing problem. In Santa Ana, Asian renter households experience a housing problem at the highest rate at 81 percent. Hispanic renter households also experience housing problems at a higher rate at 77.2 percent than the city average of 72 percent. Hispanic owner households also experience housing problems at a higher rate at 49.5 percent than the city average of 42.9 percent.

Table 13
Housing Problems by Race/Ethnicity

Santa Ana Orange County
Owner Renter Owner Renter
White 2,330 2,965 98,795 90,356
Black 135 355 2,270 6,600
Asian 2,530 4,140 45,700 45,650
American
Indian 10 10 245 335
Pacific Islander 29 35 305 815
Hispanic 10,585 23,430 42,380 3,949
Other 86 -- 4,360 3,949
All 15,705 30,835 194,055 262,960
Source: HUD CHAS Data (based on 2016-2020 ACS)
Note: -- = 0 households in category.

Cost Burden
Households are considered cost burdened if housing costs exceed 30 percent of their gross income for housing and severely cost burdened if housing costs exceed 50 percent of their gross income. Cost burden in Santa Ana and Orange County is assessed using 2023 HUD CHAS data (based on 2016- 2020 ACS estimates) and the HCD Data Viewer (based on 2017- 2021 ACS estimates).

Regional Trend
Cost burden by tenure and race/ethnicity for Orange County is shown in Table 14. Approximately 39 percent of Orange County households are cost burdened, including 29.5 percent of owner - occupied households and 51.3 percent of renter -occupied households. Hispanic renter households have the highest rate of cost burden —55.7 percent. Non-Hispanic American Indian and non-Hispanic White owner households have the lowest rate of cost burden, 19.3 percent and

27.9 percent, respectively. Cost burden is more common among renter households than owner households regardless of race or ethnicity.

Table 14
Cost Burden by Race/Ethnicity and Tenure: Orange County

Cost Burdened
(30% -50%)
Severely Cost
Burdened
(>50%)
Total
Households
Owner-Occupied
White, non-Hispanic 53,125 42,775 344,165
Black, non-Hispanic 1,485 745 5,765
Asian, non-Hispanic 22,425 18,240 128,995
American Indian, non-Hispanic 70 150 1,140
Pacific Islander, non-Hispanic 220 75 1040
Hispanic 19,150 12,820 100,095
Other 2,345 1,670 13,580
Renter-Occupied
White, non-Hispanic 44,895 46,055 186,945
Black, non-Hispanic 2,700 3,440 11,800
Asian, non-Hispanic 17,600 21,575 78,585
American Indian, non-Hispanic 100 180 775
Pacific Islander, non-Hispanic 315 310 1,425
Hispanic 41,785 42,680 151,625
Other 3,120 3,185 13,625
Source: HUD CHAS Data (based on 2016-2020 ACS)
Figure 57 and Figure 58 show concentrations of cost burdened owners and renters by tract for the region. Tracts with high concentrations of cost burdened owners are generally dispersed throughout the county. However, there is a higher prevalence of tracts with higher percentages of cost burdened owners and renters in central Orange County compared to the coastal areas. In most tracts in coastal areas from Seal Beach to Newport Beach, 20 percent to 60 percent of owners are cost burdened. Tracts where more than 60 percent of renters are cost burdened are most concentrated in the central county areas around Huntington Beach, Fountain Valley, Santa Ana, Garden Grove and Anaheim.

Local Trend
Cost burden by tenure in Santa Ana based on HUD CHAS data is shown in Table 15 .

Approximately 42 percent of households in the city are cost burdened, including 30.1 percent of owner-occupied households and 52 percent of renter-occupied households. Further, 24.3 percent of renter households in Santa Ana are severely cost burdened. The renter-occupied rate of Santa Ana is over 10 percentage points’ higher than that of Orange County at 52.8 percent and 42.8 percent. Non-Hispanic American Indian and Black renter-occupied households have the highest rate of cost burden in the city at 100 percent and 58.3 percent, respectively. Like the county as a whole, cost burden is more common in renter households. Non-Hispanic American Indian and non-Hispanic White households have the lowest rate of owner -occupied cost burden at 15.4 percent and 28.1 percent, respectively. More households as a percentage are cost burdened in Santa Ana compared to the county.

Table 15
Cost Burden by Race/Ethnicity and Tenure, Santa Ana
Cost Burdened
(30%-50%)
Severely Cost
Burdened (>50%)
Total
Households
Owner-Occupied
White, non-Hispanic 1,350 910 8,050
Black, non-Hispanic 95 45 375
Asian, non-Hispanic 1,050 860 6,395
American Indian, non-Hispanic 0 10 65
Pacific Islander, non-Hispanic 25 0 40
Hispanic 3,975 2,625 21,385
Other 50 30 285
Renter-Occupied
White, non-Hispanic 1,240 1,120 6,000
Black, non-Hispanic 160 190 600
Asian, non-Hispanic 1,085 1,305 5,055
American Indian, non-Hispanic 10 0 10
Pacific Islander, non-Hispanic 20 10 90
Hispanic 9,175 7,630 30,330
Other 150 65 465
Source: HUD CHAS Data (based on 2016-2020 ACS)
Figure 59, Figure 60, Figure 61, and Figure 62 show concentrations of cost burden by tract in Santa Ana. High rates of cost burdened owner occupied tracts are located southeast of the downtown in the vicinity of the intersection of Grand and Edinger Avenues as well as north of downtown in the vicinity of Main and 17th St. While large portions of the area in the vicinity of Grand and Edinger Avenues are industrial, there are residential uses in the census tracts along the western edge of the concentration of cost burden. Concentrations of cost burdened renter - occupied tracts are located in the northeast area of the city bordering the cities of Garden Grove and Orange. Another area of cost burden concentration is along the southern boundary, north of the South Coast Plaza regional mall in Costa Mesa. Owner -occupied cost burdened tracts are more dispersed throughout the city, but almost all renter occupied tracts in Santa Ana are cost burdened.

Santa Ana has a large population of foreign-born residents - 42 percent of the city’s population is foreign born compared to 30 percent countywide (2017- 2021 ACS). Research shows that many immigrant households, particularly those with limited English skills, earn lower incomes than later generations. This increases the difficulty of finding adequate and affordable housing and exacerbates cost burden. Community members have expressed that difficulty in finding adequate and affordable housing is compounded for residents who are undocumented because many housing assistance programs require proof of legal residency.

AB2011 Sites Inventory
As discussed above, approximately 48.1 percent of households overpay for housing in all Santa Ana tracts. Figure 59 and Figure 60 show where cost burdened owners are in relation to s ites.

The distribution of units for the sites by cost burdened renters is shown in Table 16. A majority of the units are in tracts where 40 percent to 60 percent of renters overpay for housing. As shown in Figure 61 and Figure 62, between 40 percent and 80 percent of renters are cost burdened in a majority of the City. The locations of the sites do not exacerbate existing conditions as they do not demolish any existing units and are located in areas designated for redevelopment that avoid potential negative externalities that may cause rent increases. Moreover, the locations of the sites have the potential to improve existing conditions through providing additional housing options at all affordability levels and driving rents down as more options become available to renters and owners alike.

Table 16
Distribution of Units by Renter Overpayment
Affordable
Mixed
Income Total
20-40% 0% 4% 3%
40-60% 78% 80% 80%
60-80% 22% 15% 17%
80-100% 0% 0% 0%
Total 4,222 9,648 13,870

Conclusion
Both the Alternative and Exempt sites are in areas where residents are affected by cost burden.

Santa Ana has a large population of low and moderate income households, many of whom work in service industries, retail, or other essential but lower-wage jobs. For these households, the high cost of housing consumes a large portion of their income. Santa Ana is working to expand affordable housing options by encouraging the development of mixed income housing, especially in the Focus Areas. The Alternative sites for both affordable and mixed income are in areas where there are targeted initiatives in place in order to facilitate the development of all types of housing.

Figure 57 – County Overpayment by Homeowners

Figure 58 – County Overpayment by Renters

Figure 59 – Overpayment by Homeowners and Affordable Sites

Figure 60 – Overpayment by Homeowners and Mixed Income Sites

Figure 61 – Overpayment by Renters and Affordable Sites

Figure 62 – Overpayment by Renters and Mixed Income Sites

Figure 63 – Overpayment by Homeowners and Affordable Exempt Sites

Figure 64 – Overpayment by Homeowners and Mixed Income Exempt Sites

Figure 65 – Overpayment by Renters and Affordable Exempt Sites

Figure 66 – Overpayment by Renters and Mixed Income Exempt Sites

Overcrowding
A household is considered overcrowded if there is more than one person per room and severely overcrowded if there is more than 1.5 persons per room. HUD CHAS data based on the 2016- 2020 ACS and the HCD AFFH Data Viewer (2017-2021 ACS) are used to show overcrowding in Santa Ana and Orange County.

Regional Trend
As shown in Table 17, 2.7 percent of owner -occupied households and 9.5 percent of renter - occupied households in the county are overcrowded. Severe overcrowding is slightly less of an issue in the county. Approximately 1 percent of owner households and 6.1 percent of renter households are severely overcrowded.

Table 17
Overcrowding by Tenure

Overcrowded
(>1 person per room)
Severely Overcrowded
(>1.5 persons per
room) Total
Households
Households Percent Households Percent
Santa Ana
Owner-Occupied 3,860 10.60% 2,085 5.70% 36,590
Renter-Occupied 8,640 20.00% 7,555 17.80% 42,550
Orange County
Owner-Occupied 16,150 2.70% 6,520 1.10% 595,230
Renter-Occupied 42,145 9.50% 27,060 6.10% 444,775
Source: HUD CHAS Data (based on 2016-2020 ACS), 2023
Figure 67 shows concentrations of overcrowded households by tract regionally. Overcrowded households are most concentrated in the central county areas, including the cities of Santa Ana, Garden Grove, Westminster, Anaheim, and Stanton. Additionally, there are some dispersed tracts with high percentages of households experiencing overcrowding in Costa Mesa. Areas northeast, south, and west of Santa Ana have concentrations of overcrowded households below the State average.

Local Trend
As presented in Table 17, a larger share of households in Santa Ana are overcrowded compared to the countywide average. Nearly 17 percent of owner -occupied households and 38 percent of renter-occupied households in the city have more than one person per room, which is significantly higher than surrounding areas in the county. Moreover, 5.7 percent of owner households and 17.8 percent of renter households are severely overcrowded, with more than 1.5 persons per room.

Figure 68 and Figure 69 show overcrowding by tract in the city. A majority of tracts have 20 or more percent of households experiencing overcrowding. The northeast part of the city has census tracts with slightly less overcrowding. Overall, there are six census tracts in the city with percentages of overcrowded households at or below 5 percent, these are located in the northeast and to the south in the South Coast Metro area. The South Coast Metro area, in particular, features more recently developed housing, including larger single-family homes, townhomes, and upscale apartment complexes. These homes tend to be larger and designed to accommodate smaller household sizes, making overcrowding less likely.

Overcrowding is a common concern voiced in community meetings and to Neighborhood Initiatives and Environmental Services staff. Residents have expressed a form of overcrowding knows as “doubling up” —where a family co- resides with other family members or friends for economic reasons—as being prevalent and underreported due to fear stemming from legal status, language barriers, and retaliatory tactics from landlords. Community members have also expressed that due to the legal status of income earners, establishing credit worthiness is challenging and forces some residents to live with family members, creating or compounding overcrowded households.

AB2011 Sites Inventory
The majority of the City’s units are in tracts with 12 percent to 15 percent overcrowded households or more than 20 percent. The location of the units does not exacerbate conditions and provides for units of all income levels in different areas of overcrowded household concentrations. The locations of the sites do not exacerbate existing conditions, as the projects do not include demolition of any existing units. Rather, the locations of the sites have the potential to improve existing conditions through providing additional housing at all income levels and creating options for families that may be doubling up or need larger units.

Table 18
Distribution of Units by Overcrowded Households
Affordable
Mixed
Income Total
<= 8.2% (Statewide
Average) 39% 41% 41%

8.3-12% 9% 8% 8%
12-15% 20% 17% 18%
15-20% 1% 3% 2%
> 20% 31% 31% 31%
Total 4,222 9,648 13,870
Exempt Sites
The exempt sites designated by the City are primarily located along the west and east sides of 17th Street and Tustin Avenue to the east. These areas are generally outside of the City’s Focus Areas and not targeted for redevelopment under the General Plan. Similar to the Alternative sites, there is a high number of exempt sites located within areas that have a higher portion of households being overcrowded, but this is consistent with the makeup of the entire City.

Conclusion
Santa Ana has one of the highest rates of overcrowded households in Orange County and California. According to recent Census data, around 25 percent of all households in Santa Ana are considered overcrowded. To combat overcrowded households the City is working to expand its supply of affordable housing. With the Alternative sites the City hopes to promote a multitude of housing options in areas prime for redevelopment, especially near Focus Areas. This, along with other initiatives in the City such as tenant protection policies, the City hopes to start to providing more resources and housing options for all household sizes.

Figure 67 – County Overcrowding

Figure 68 – Overcrowding and Affordable Sites

Figure 69 – Overcrowding and Mixed Income Sites

Figure 70 – Overcrowding and Affordable Exempt Sites

Figure 71 – Overcrowding and Mixed Income Exempt Sites

Substandard Housing
Incomplete plumbing or kitchen facilities and housing stock age can be used to measure substandard housing conditions. Incomplete facilities and housing age are based on the HUD CHAS data (based on 2016-2020 ACS).

Regional Trend
Approximately 1.4 percent of households in the county lack complete plumbing or kitchen facilities. Incomplete facilities are more common among renter -occupied households. Only 0.4 percent of owner households lack complete plumbing or kitchen facilities compared to 2.7 percent of renters (Table 19).

Table 19
Incomplete Facilities

Lacking Complete Plumbing or Kitchen
Facilities Total
Households Households Percent
Santa Ana
Owner-Occupied 140 0.40% 36,590
Renter-Occupied 585 1.40% 42,550
Total 725 1.00% 79,140
Orange County
Owner-Occupied 2,150 0.40% 595,230
Renter-Occupied 11,890 2.70% 444,775
Total 14,040 1.40% 1,040,005
Source: HUD CHAS Data (based on 2016-2020 ACS).

Housing age can also be used as an indicator for substandard housing and rehabilitation needs.

In general, residential structures over 30 years of age require minor repairs and modernization improvements, while units over 50 years of age are likely to require major rehabilitation such as roofing, plumbing, and electrical system repairs. In the county, 85.6 percent of the housing stock was built prior to 2000, including 59.6 percent built prior to 1980.

Local Trend
Less than 1 percent of owner -occupied households in Santa Ana lacks complete plumbing or kitchen facilities (Table 19). A slightly larger proportion of renter-occupied units compared to the share of owner -occupied units lack complete facilities. Overall, the percentages of owner - occupied households that lack complete facilities in Santa Ana (0.4 percent) same as the county rate (0.4 percent), and Santa Ana’s rate for renter units of 1.4 percent is less than the countywide rate of 2.7 percent.

Nearly 80 percent of the city’s housing stock was built prior to 1980 and approximately 94 percent was built prior to 2000. The biggest construction boom happening between 1960 and 1979 as the city was being built out (Table 20). Units produced during that construction boom make up 43.7 percent of the housing stock in the city. Units built prior to 1960 make up 35.2 percent of the housing stock. In general, the housing stock in Santa Ana is older than that of the county as a whole, and the rate of construction in recent years has lagged that of the county. Housing that is 30 or more years old often requires some form of moderate or major rehabilitation.

The Code Enforcement Division enforces ordinances pertaining to property maintenance, building conditions, and other housing and neighborhood issues. Evidence stemming fr om the quantity and types of code enforcement cases suggests that housing requiring rehabilitation is disproportionately concentrated in the central parts of the city, generally bounded by Seventeenth Street and Warner Avenue (north and south) and Grand Avenue to Harbor Boulevard (east and west). The census tracts with the highest percentage of poverty are in this area. The area also has high levels of overcrowded households, which exacerbates wear and tear and maintenance needs.

Table 20
Santa Ana Housing Stock, Year Structure Built
Year Built
Santa Ana Orange County
Number of Units Number of Units
2020 or later 304 1,559
2010 to 2019 1,994 63,440
2000 to 2009 2,633 86,392
1980 to 1999 11,223 276,146
1960 to 1979 33,519 445,644
1940 to 1959 20,913 159,324
1939 or earlier 6,038 25,087
Total: 76,624 1,057,592
Source: 2021 American Community Survey (ACS), 5-Year Estimates.

AB2011 Sites Inventory
Substandard housing and the age of housing stock are significant concerns in Santa Ana, contributing to housing challenges such as overcrowding and health issues. With such a high number of homes built before 1980, especially in the center of the City, it is important to provide new housing types at all affordability levels in areas that are ready for redevelopment. The City has been working to increase the supply of affordable housing, including new developments that meet modern safety and energy efficiency standards. While adding new housing is crucial , preserving existing affordable housing and ensuring that older buildings are properly maintained are also priorities.

Conclusion
Both the Alternative and Exempt sites are in areas where the majority of buildings or homes were built before 1980. This of course brings financial challenges to households that are making their current housing options work for them in the best way possible. Addressing these issues will require a combination of housing rehabilitation programs, code enforcement, and the creation of new, affordable housing options which can be done using the Alternative sites list. Along with the General Plan policies and other initiatives the City has in place, the City hopes to ensure that all residents have access to safe and healthy homes.

Displacement Risk
Displacement is a term often used to describe any involuntary household move caused by landlord action, market changes, or other disruptions. Factors contributing to displacement might include: 1) increasing overpayment and overcrowding due to housing costs; 2) significant investment or disinvestment in housing, transportation, jobs, or physical infrastructure; or 3) other local market- or demographic-related change.

Many different definitions of household displacement have been offered. However, the Urban Displacement project has developed a hierarchy of communities at risk of displacement based on multiple criteria. The stages of vulnerability/gentrification/displacement are:
• Low-income susceptible to displacement
• Ongoing displacement of low income households
• At risk of gentrification
• Early/ongoing gentrification
• Advanced gentrification
• Stable/moderate/mixed income
• At risk of becoming exclusive
• Becoming exclusive
• Stable/advanced exclusive
Regional Trend
Regionally, as shown in Figure 72, Santa Ana borders eastern Orange County, a more rural area fronting the Cleveland National Forest that is generally considered stable and at a level of advanced exclusivity. In addition, coastal cities to the southeast, including the cities of Irvine, Newport Beach, Mission Viejo, and others, are similarly exclusive, as reflected by their median incomes and very high housing prices. Vulnerable communities, which are characterized by higher levels of immigration, are most concentrated in the central county areas around the cities of Santa Ana, Garden Grove, Westminster, Anaheim, and Stanton. There are also smaller concentrations of vulnerable communities in Costa Mesa, Tustin, and Huntington Beach. Figure E-38 shows the risk of displacement in Santa Ana.

Local Trend
The Urban Displacement Project developed a neighborhood- change database to help stakeholders better understand where neighborhood transformations are occurring and to identify areas that are vulnerable to gentrification and displacement in Southern California. The database includes Los Angeles, Orange, and San Diego Counties, with gentrification and sociodemographic indicators based on 2015 data from the American Community Survey. It shows whether a census tract gentrified between 1990 and 2000; gentrified between 2000 and 2015; gentrified during both of these periods; or exhibited characteristics of a “disadvantaged” tract that did not gentrify between 1990 and 2015.

Based on this neighborhood change database, the Urban Displacement Project team found that the number of gentrified census tracts Orange County the greatest share of neighborhoods that were considered “disadvantaged” and potentially susceptible to gentrification (~43 percent).

Figure 73 shows the displacement levels for Santa Ana and the County . A majority of cen sus tracts in the southern and northern parts of the city are categorized as low displacement risk meaning a Stable Moderate/Mixed Income or At Risk of Becoming Exclusive. Census tracts in and around the downtown, such as Willard, French Court, French Park, Lacy, and Pico- Lowell neighborhoods, are categorized as Low-Income/Susceptible to Displacement.

In addition, the city’s housing market is expected to experience change around the downtown, corridors, and specific plan areas. As the county seat, Santa Ana’s downtown and other activity areas are intensifying, and this is expected to continue into the future as the general plan is implemented and the Focus Areas Public Realm plans are established. These efforts are anticipated to add significant new housing, including affordable housing, either through the application for density bonuses or through the City’s Housing Opportunities Ordinance. So while land uses are being recycled for market rate housing, the City is also seeing the addition of new affordable housing.

To combat displacement risk, the City of Santa Ana has a variety of programs in place to address housing preservation and security.
• Housing Preservation. The City has approximately 40 deed-restricted affordable housing projects offering 3,200 units of afford able to lower income households with more in construction.
• Housing Security. The City has 340 mobile home parks that offer almost 4,000 market rate units that are affordable to lower income households and are also rent stabilized. • Renter Protections. The City adopted its Just Cause Eviction in December 2021. The ordinance is consistent with California Civil Code Section 1946.2 and provides additional tenant protections to those provided under State law, pursuant to AB 1482. • Rent Stabilization. In December 2021, the City adopted a Rent Stabilization Ordinance, which prohibits rent increases that exceed 3 percent annually or 80 percent of the change in consumer price index, whichever is less, within the City. • Other Local Policies. The City also adopted a Local Resident Preference Ordinance in July 2024 for residents working and living in Santa Ana who are seeking affordable housing.

AB2011 Sites Inventory
The housing market in Santa Ana is anticipated to undergo significant changes, particularly in the downtown area, key corridors, and specific plan zones. The different planning initiatives are projected to introduce substantial new housing, including affordable options, facilitated by density bonuses or the City’s Housing Opportunities Ordinance. The locations of the sites have the potential to improve existing conditions through increased investment and provision of new services that will not only benefit new residents but also improve the quality of life for all segments of the community, especially existing residents. The sites are also located in areas that have been designated for redevelopment through the City’s General Plan and Focus Areas. Current development trends show that high residential density is feasible and realistic, and appropriate to accommodate housing for all income levels and can be accommodated on the alternative parcel sites. By combining policy tools, direct support, and community -centered planning, Santa Ana aims to balance growth and investment with the need to protect long- term residents from being displaced.

Conclusion
Both the Alternative and Exempt sites are in areas where there is a potential for displacement risk. Santa Ana is actively addressing displacement risk through a combination of policies, protections, and community -focused initiatives. The City’s Housing Opportunity Ordinance ensures that new developments contribute to affordable housing, while density bonus programs incentivize developers to include affordable units in their projects. To protect renters, Santa Ana has enacted rent stabilization measures and just -cause eviction protections, limiting rapid rent increases and arbitrary evictions. The preservation of existing affordable housing is a priority, with efforts to rehabilitate older properties and prevent their conversion to market -rate housing.

Additionally, the City collaborates with community land trusts to secure land for long -term affordability and provides financial assistance programs to help stabilize families at risk of displacement. Through inclusive planning efforts, such as the General Plan and Focus Areas Public Realm plans, Santa Ana aims to promote equitable development that benefit s existing residents while ensuring that growth does not come at the expense of community stability.

Figure 72 – County Displacement Risk

Figure 73 – Santa Ana Displacement Risk and Affordable Sites

Figure 74 – Santa Ana Displacement Risk and Mixed Income Sites

Figure 75 – Santa Ana Displacement Risk and Affordable Exempt Sites

Figure 76 – Santa Ana Displacement Risk and Mixed Income Exempt Sites

1.9 Contributing Factors
In the City’s Housing Element, contributing factors were identified and prioritized based on disproportionate housing needs. These factors then influenced t he City’s Housing Plan and programs established in the Housing Element. Those programs are currently being implemented or have already been completed and are working to address the issues identified in the Housing Element AFFH and also in this analysis conducted for AB2011 and its alternative sites.

Issue 1: Displacement Risk
Santa Ana, much like the Southern California region as a whole, has experienced increasing land values and rental rates since the nadir of the Great Recession. This period in Santa Ana can be characterized by an influx of development in the city, particularly development that includes housing. While more housing opportunities are coming online, many residents have expressed that there is a lack of affordable housing options that threatens displacement or that may cause homelessness. As demonstrated by Figure 59, Figure 60, Figure 61, and Figure 62, considerable percentages of owners and renters in the city are overpaying for housing, and overpaying among renters is more acute. Moreover, as shown in Figure 73, some census tracts in Santa Ana are designated sensitive communities at risk of displacement.

The Housing Plan provides programs for:
• Housing Stabilization. Implement the rent stabilization and just cause eviction ordinances to preserve affordable housing through regulating rent increases and establishing just cause eviction regulations (e.g., Program 33). • Housing Opportunity Ordinance. Require eligible rental and ownership housing projects to include affordable units (e.g., Program 25).
• Housing Priority. Administer local preference for affordable housing created under the AHOCO or with City funding (e.g., Program 32) with a new Local Preference Ordinance adopted in July 2024.
• Community Land Trusts and Collective Ownership. Partner with community -based organizations to support a community land trust program and pursue collective ownership models to promote ownership options and opportunities (e.g., programs 32 and 34). • Shelters and Support Ser vices. Provide funding for creation and/or the provision of shelters, permanent supportive housing, and services for those experiencing homelessness or that are at risk of becoming homeless (e.g., programs 37, 38, and 39).

Issues 2: Safe and Sanitary Housing
Safe, sound, and healthy housing conditions are essential to fair housing opportunity for all Santa Ana residents. Due to the age of the housing stock in the city, much of it is in need of repair (Table 20). Many areas with lower median incomes are the same areas with older housing stock requiring rehabilitation. This means that renters may not have the housing mobility, due to lower income levels, to seek out housing units that are in better condition, and owners may lack the finances to regularly maintain and rehabilitate their homes. Additionally, those experiencing homelessness are most acutely affected by the lack of safe and sanitary housing.

The Housing Plan provides programs for:
• Tenant Protections. Provide resources to residential tenants regarding landlord- tenant laws and responsibilities to ensure units are being maintained and up to code, and if not, tenants are aware of their rights and options for recourse (e.g., Program 44). • Code Enforcement. Enforce building and property maintenance standards and remove blight and unhealthy or dangerous housing conditions, and work with County Health Department to identify violations and streamline resolutions (e.g., programs 9 and 10). • Home Rehabilitation Grant Program. Provide grants to assist in the repair and rehabilitation of single- and multifamily homes as well as mobile homes for lower-income households (e.g., programs 1 and 2).
• Emergency and Transitional Housing. Continue providing funding and services for providers of emergency shelters, permanent supportive housing, and support services for those at risk of becoming homeless (e.g., programs 37, 38, and 39).

Issue 3: Housing Overcrowding
Housing overcrowding refers to situations where a home has more than one person per habitable room. As shown in Table 17, nearly 19 percent of owner-occupied households and 42 percent of renter-occupied households in the city are considered overcrowded. In addition, during the workshops and community feedback opportunities, many residents described a form of residential overcrowding known as "doubling up"—where a family co-resides with family members or friends for economic reasons —as also being prevalent and undercounted in Santa Ana. As was discussed above and depicted in Figure 68 and Figure 69, a majority of census tracts in Santa Ana have greater than 20 percent of households experiencing overcrowding, and four tracts have overcrowding exceeding 60 percent. This issue is also correlated with Issue 2: Safe and Sanitary Housing, as overcrowding accelerates the wear and tear on housing.

The Housing Plan provides programs for:
• Overcrowding Conditions. Facilitate development of accessory dwelling units and additions to existing homes to alleviate overcrowded housing conditions (e.g., Program 43).
• Diverse Housing Types. Facilitate diverse types, prices, and sizes of housing for the different needs in the community (e.g., Program 27).
• Affordable Component. Continue applying AHOCO to include affordable units as part of new housing developments (e.g., Program 25).

Issue 4: Household Income
Since the housing market is not a closed system, assessing income groups in Santa Ana in relation to neighboring cities and the county as a whole is a critical component for evaluating housing access and affordability. Santa Ana’s median household income is significantly lower than that of the County overall. This issue is directly correlated with Issue 1: Displacement Risk, since lower-earning households in Santa Ana are vying for housing units in a highly competitive housing market and competing with higher- earning individuals looking to locate in a jobs -rich region.

The Housing Plan provides programs for:
• Affordable Housing Production. Provide financial assistance to support the production and/or rehabilitation of affordable housing for extremely low -, very low-, and low-income families (e.g., Program 21).
• Rent Stabilization and Just Cause Eviction . Adopted a rent stabilization ordinance to preserve affordable housing through regulating rent increases and establishing just cause eviction regulations (e.g., Program 33).
• Down Payment Assistance. A ssist low -income households with down payment assistance loans to facilitate ownership opportunities (e.g., Program 34). • Supportive Services. Allocate funding to agencies that provide services to people experiencing homelessness or that are at risk of becoming homeless (e.g., programs 37, 38, and 39).

Issue 5: Environmental Justice Areas
An environmental justice community is an area of the city where residents have the highest risk of exposure to pollution in the air, water, and soil. Residents in these areas also tend to be burdened by socioeconomic and health issues, such as higher rates of language barriers, poverty, and asthma. Such areas also tend to experience lower rates of investment and improvements from individuals, private companies, and public agencies. All of these factors can lead to unequal opportunities to lead a healthy and prosperous life. There are 24 census tracts in the city that are considered disadvantaged or environmental justice (EJ) areas (Figure 46 and Figure 47).

To address EJ issues, the City underwent an extensive multiyear engagement effort as part of its comprehensive General Plan update, with the last year focusing on engaging EJ communities and listening to their experiences and issues regarding environmental health and quality of life.

The campaign consisted of a multilingual EJ Survey (electronic and hard copy) and 10 virtual and 1 in-person community forums, each focusing on a specific EJ area in the city. Feedback can be generally grouped into the following categories: improving air and water quality; improving public city facilities; improving infrastructure; providing healthy food options; providing safe and sanitary housing; increasing physical activity; and fostering civic engagement.

The City has developed over 75 policies and over 70 programs that are informed by the feedback received fro m the community and that address pollution and population variables in the CalEnviroScreen model that are in the upper quartile rank in the identified EJ areas. With the completion of the General Plan, the City has begun the process of addressing the disproportionate environmental burden that residents in these communities have experienced. All of the efforts can be viewed on the City’s NIES webpage: https://www.santa-ana.or g/departments/neighborhood-
initiatives/
Issue 6: Education and Workforce Development
As stated in Issue 4: Household Income, median incomes in Santa Ana lag behind the county.

Moreover, as discussed above, more than half of Santa Ana households are in the low or moderate income categories ( Table 15 ). This is despite Santa Ana residents being in closer proximity to jobs compared to the county as a whole and having more access to those jobs through transit connections (Figure 53 and Figure 54). This suggests that access to jobs is not an issue; rather, the issue lies in access to higher paying jobs. Higher paying jobs often require higher levels of job skills and educational attainment. However, nearly all of Santa Ana tracts scored in the lowest TCAC education quartile score. Additionally, a majority of the tracts in the city, with a noticeable concentration in the central city area, scored in the lowest TCAC economic opportunity quartile score.

To address educational and economic opportunity barriers that lead to housing and affordability issues, the City is included an Economic Prosperity Element in the updated General Plan. The element includes programs for workforce development, small business creation and retention, and incentives to hire local. In addition, the updated General Plan includes an element called the Community Element. The Community Element includes numerous policies and programs to directly address the education and jobs training issue. For example, there are policies and programs to support parent participation programs to increase high school and college graduation rates, expanding access to libraries and learning centers, promoting skill -based education programs, and investing in lifelong learning programs.

Santa Ana City CouncilDecember 17, 2024

Santa Ana City Council
December 17, 2024