Community Development Agency
www.santa-ana.org/cd
Item # 21
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
November 4, 2025
TOPIC: Adopt an Amendment to the Affordable Housing Funds Policies and Procedures
AGENDA TITLE
Adopt an Amendment to the Affordable Housing Funds Policies and Procedures
RECOMMENDED ACTION
Approve recommended changes to the Affordable Housing Funds Policies and Procedures.
GOVERNMENT CODE §84308 APPLIES: No
DISCUSSION
Staff recommends that the City Council approve revisions to the City’s adopted Affordable Housing Funds Policies and Procedures (“Policies”) to prevent situations in which the Council is asked to approve a “pre-loan commitment” or “pre-loan commitment letter” if the project is not consistent with the City’s General Plan Land Use Element and Zoning Classification. The proposed revisions aim to ensure that funding decisions occur only if the project is consistent with these foundational regulatory frameworks, thereby avoiding the appearance that project outcomes are predetermined and strengthening the transparency and integrity of the City’s review and decision- making process.
This recommendation is responsive to a conflict situation highlighted by a recent proposal submitted to the Community Development Agency (“CDA”) by Habitat for Humanity of Orange County (“Habitat”). The Habitat proposal requests a pre-loan commitment by the City to a housing project with more units proposed on a property than permissible under the existing General Plan Land Use Element and Zoning Classification, thereby requiring Planning Commission and City Council approval of a zone change and general plan amendment. Even though the pre-loan commitment is consistent with past practices and the approval would have a condition that the project developer must obtain all necessary land use approvals and entitlements from the City, in this situation, the pre-loan commitment puts the City Council in a position of having to approve funding even though the project is not consistent with the General Plan Land Use Element and the Zoning Classification and has not undergone the public decision- making process.
Adopt an Amendment to the Affordable Housing Funds Policies and Procedures November 4, 2025
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Revising the Policy as shown in the text below (underlined & strikethrough) would require a determination from the Executive Director of the Planning and Building Agency to certify that the project is consistent with the City’s General Plan Land Use Element and Zoning Classification. This determination would need to be issued prior to a pre- loan commitment letter’s approval in order to strengthen the transparency and integrity of the City’s decision-making process, and ensure consistency with the General Plan Land Use Element and Zoning Classification.
Projects that are consistent with the City’s General Plan Land Use Element and Zoning Classification, but require approvals including, but not limited to, a Tentative Tract Map, Design Review, Conditional Use Permit, Density Bonus Agreement, and entitlements of a similar nature, can proceed with a pre-commitment letter following the determination by the Executive Director of the Planning and Building Agency.
Recommended Revisions to Section IV. Pre-Loan Commitment of the Policies:
“Following the RFP Process, Proposal Review, Determination of Reasonable Costs and Financial Feasibility, and the proposed project has received a determination from the Executive Director of the Planning and Building Agency that the proposed project is consistent with the City’s General Plan Land Use Element and Zoning Classification conditional on meeting the other requirements and conditions outlined above, a pre-loan commitment letter may be drafted by the Housing Division, reviewed and approved by the Housing Division Manager, the City Attorney’s Office, and the Executive Director of Community Development, before being recommended for approval. For the purposes of this Policy, the Executive Director of the Planning and Building Agency shall evaluate consistency with the City’s General Plan Land Use Element and Zoning Classification based on the proposed project’s land use, maximum proposed floor area ratio (FAR), and maximum proposed dwelling units per acre (du/ac).
FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBIT(S)
1. Affordable Housing Funds Policies and Procedures (Underline and Strikethrough Version)
Submitted By: Michael L. Garcia, Executive Director, Community Development Agency Approved By: Alvaro Nuñez, City Manager