Becerra, Alexis
From: Dale Helvig <
Sent: Monday, August 3, 2026 2:56 PM
To: eComment; Amezcua, Valerie; Phan, Thai; Vazquez, Benjamin; Lopez, Jessie; Bacerra, Phil; Hernandez, Johnathan; Penaloza, David
Cc: Nunez, Alvaro; Carvalho, Sonia R.; Thai, Minh; Vazquez, Sylvia; Hall, Jennifer Subject: 2026- 08- 04 Letter to City Council - Item 30 Attachments: 2026- 08- 04 Letter to City Council - Item 30.pdf Attention: This email originated from outside of City of SantaAna. Use caution when opening attachmentsor links.
See attached file.
Dale Helvig
Resident, Santa Ana
1 Dale Helvig
Resident, Santa Ana CA 92706
August 3, 2026
Mayor Amezcua and Santa Ana City Councilmembers
City of Santa Ana
20 Civic Center Plaza, 81" Floor
Santa Ana CA 92702
Subject: Item 30: Density Bonus Agreement No. 2026- 03— Watermarke Sandpointe Mixed- Use Development.
The City of Santa Ana continues to approve mixed- use developments that have requested a density bonus agreement. This is a trend that is unsustainable. Some questions the city needs to consider:
1) As we continue to exceed RHNA goals, is someone at the city looking at the long- term effect this will have on future RHNA Cycles?
2) Why do we continue to placate every developer' s desire to build the maximum size project for any given piece of land? We continue to hear the American dream is to own you own residence. This project does nothing to make that a reality. It also removes much needed parking for adjacent offices.
3) This project should be placed on hold until the next RHNA cycle. Projects such as this only pad the pockets of developers while contributing to the long- term decline of the quality of the residents.
DO NOT approve this item, approving this Density Bonus will short- change the City in future RHNA cycles.
Respectfully,
Dale A Helvig
Resident, Santa Ana
cc: Alvaro Nunez, Minh Thai,
City Manager, Santa Ana Deputy City Manager, Santa Ana
Sonia Carvalho, Sylvia Vazquez,
City Attorney, Santa Ana Deputy City Manager, Santa Ana
2026- 08- 04 Letter to City Council- Item 30
Becerra, Alexis
From: JamesLloyd <[email protected]>
Sent: Tuesday, August 4, 2026 9:18 AM
To: eComment
Cc: Carvalho, Sonia R.; ! City Clerk; Planning; Nunez, Alvaro Subject: public comment re item 30 for tonight' s Council meeting Attachments: Santa Ana - 200 East Sandpointe Avenue - HAA Letter - CC.pdf Attention: This emailoriginatedfrom outsideof City of SantaAna. Usecautionwhenopeningattachmentsor links.
Dear Santa Ana City Council,
The California Housing Defense Fund ( CaIHDF) submits this attached public comment re item 30 for tonight' s Council meeting, the proposed 400- unit housing development project at 200 East Sandpointe Avenue, which includes 20 extremely low- income units.
Sincerely,
James M. Lloyd
Director of Planning and Investigations
California Housing Defense Fund
james@calhdf. org
CaIHDF is grant& donation funded
Donate today- https:// calhdf. org/ donate/
i
CAL
HDF
Aug 4, 2026
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92701
Re: Proposed Housing Development Project at 200 East Sandpointe Avenue By email: eCommentrasanta- ana. org
CC: scarvalho( casanta- ana. orq; cityclerk( casanta- ana. orq; Planning( casanta- ana. orq; ANunez( asanta- ana. org
Dear Santa Ana City Council,
The California Housing Defense Fund( Ca1HDF)submits this letter to remind the City of its obligation to abide by all relevant state housing laws when evaluating the proposed 400- unit housing development project at 200 East Sandpointe Avenue, which includes 20 extremely low- income units. These laws include the Housing Accountability Act( HAA), the Density Bonus Law( DBL),AB 130,and California Environmental Quality Act( CEQA)guidelines.
The HAA provides the project legal protections. It requires approval of zoning and general plan compliant housing development projects unless findings can be made regarding specific, objective, written health and safety hazards. ( Gov. Code, § 65589. 5, subd. ( j).) The HAA also bars cities from imposing conditions on the approval of such projects that would reduce the project' s density unless, again, such written findings are made. (Ibid.) As a development with at least two- thirds of its area devoted to residential uses, the project falls within the HAA's ambit, and it complies with applicable provisions of the local zoning code and the City' s general plan. Increased density, concessions, and waivers that a project is entitled to under the DBL( Gov. Code, § 65915)do not render the project noncompliant with the zoning code or general plan, for purposes of the HAA. ( Gov. Code, § 65589.5, subd. (j)(3).) The HAA' s protections therefore apply, and the City may not reject the project except based on health and safety standards, as outlined above. Furthermore, if the City rejects the project or impairs its feasibility, it must conduct" a thorough analysis of the economic, social, and environmental effects of the action"( Id. at subd. M.
The DBL offers the project certain benefits.( See Gov. Code, § 65915.) The City must respect these benefits. In addition to increased density, the City must grant any requested 2201 Broadway, PH1, Oakland, CA 94612
www. calhdf. org
concessions and waivers. If the City were to deny the requested waivers, Government Code section 65915, subdivision( e)( 1) requires findings that the waivers would have a specific, adverse impact upon health or safety, and for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact. If the City were to deny the requested requested concessions, Government Code section 65915, subdivision( d)( 1) requires findings that the concessions would not result in identifiable and actual cost reductions, that the concessions would have a specific, adverse impact on public health or safety, or that the concessions are contrary to state or federal law. The City,if it makes any such findings, bears the burden of proof. ( Gov. Code, § 65915, subd.( d)( 4).) Of note, the DBL specifically allows for a reduction in required accessory parking in addition to the allowable waivers and concessions. ( Id. at subd. ( p).) Additionally, the California Court of Appeal has ruled that when an applicant has requested one or more waivers and/ or concessions pursuant to the DBL, the City" may not apply any development standard that would physically preclude construction of that project as designed, even if the building includes amenities' beyond the bare minimum of building components"( Bankers Hill 150a City of San Diego( 2022) 74 Cal.App. Sth 755, 775.)
Finally, the project is exempt from state environmental review pursuant to CEQAGuidelines section 15168(Program EIR).The project is also eligible for an exemption from CEQA pursuant to AB 130 ( Pub. Res. Code, § 21080. 66). Caselaw from the California Court of Appeal affirms that local governments err, and may be sued,when they improperly refuse to grant a project a CEQAexemption or streamlined CEQAreview to which it is entitled. ( Hilltop Group, Inc. a County of SanDiego( 2024) 99 Cal.App.Sth 890, 911.) As you are well aware, California remains in the throes of a statewide crisis- level housing shortage. New housing such as this is a public benefit: it will provide badly needed affordable housing; it will bring new customers to local businesses; it will expand the city' s tax base; and it will reduce displacement of existing residents by reducing competition for existing housing. Ca1HDFtherefore strongly urges the City to approve the project, consistent with its obligations under state law.
Ca1HDFis a 501(c)(3) non- profit corporation whose mission includes advocating for increased accessto housing for Californians at all income levels, including low- income households. You may learn more about Ca1HDFat .,, ,:
Sincerely,
Dylan Casey
Ca1HDF Executive Director
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James M. Lloyd
Ca1HDFDirector of Planning and Investigations
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