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Public Comment
From:Cesar C <cesarc@kennedycommission.org>
Sent:Tuesday, September 29, 2020 5:24 PM
To:Public Comment
Subject:Item 7 - Opposition Letter to the Sale of Stadium Land
Attachments:Ltr_Item 7 Anaheim Stadium Project_9.29.2020.pdf
Please see attached the Kennedy Commission's letter in Opposition to the Sale of Stadium Lands, Item #7
--
Cesar Covarrubias
Executive Director
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www.kennedycommission.org
September 28, 2020
17701 Cowan Ave., Suite 200
Irvine, CA 92614
949 250 0909
Mayor Harry Sidhu and City Council Members
City of Anaheim
200 S. Anaheim Boulevard
Anaheim, CA 92805
RE: #7- Zoning Code Amendment No. 2020-00171, Development Agreement No. 2020-0002
Dear Mayor Harry Sidhu and City Council Members:
The Kennedy Commission (the Commission) is a broad based coalition of residents and community
organizations that advocates for the production of homes affordable for families earning less than
$20,000 annually in Orange County. Formed in 2001, the Commission has been successful in
partnering and working with Orange County jurisdictions to create effective housing and land-use
policies that has led to the new construction of homes affordable to lower income working families.
The Commission is opposed to the 1-acres of property generally
located at 2000 E. Gene Autry Way and 2000 E. Katella Ave. of City-owned land (the
California Surplus Land Act
The item before the Council today is a sale that is subject to the
As surplus land, the Land should be disposed of in accordance to the requirements of the SLA.
1.The Surplus Land Act Requires that Surplus Land Be Offered for Affordable Housing
or Open Space
The Act, Cal. Gov. Code, § 54220, et seq., requires that when a local agency wishes to
dispose of land it no longer requires, the agency must send a written offer to sell or lease the
property to certain entities for affordable housing or park purposes.
In adopting the Act, the California Legislature declared
importance to the health, safety, and welfare of the residents of this state and . . . provision
of a decent home and a suitable living environment for every Californian is a priority of the
should be made
The City has not followed the Surplus Land process and has not given priority to affordable housing
developers nor given priority for parks and open space.
2.The Cit Would Violate the SLA
Here the City has ignored the requirements and the formal process of the SLA and is today
considering the sale of City-owned surplus land as a result of these direct negotiation with SRB
Management Company. The proposed sale of the Land is before the Council on September 29,
2020. The current proposal sale that is proposed to be approved with new terms and consideration.
Mayor Harry Sidhu and City Council Members
September 29, 2020
The requirements of the California Surplus Land Act apply to this disposal of the proposed City
surplus land. The City has an obligation to follow the Surplus Land Act requirement and make the
land available first for the community priorities of affordable housing and open space as identified
in the Surplus Land Act, before offering the property for sale on the market.
We ask that the City not approve this sale and follow the state law and requirements to dispose
surplus property.
Affordable Housing Need in Anaheim
Should the City Council move forward with the proposed project, the Kennedy Commission
requests that the number of affordable housing units required of the project be at minimum
25% at the very low and low income levels and should be developed within the next five years
to meet dire community housing needs for lower income working families; anything less is
insufficient.
The proposed project prioritizes economic development providing only the minimum
amount of 466 of affordable housing units and open space while the vast majority of the 151 acres
would be left for private development such as the Angel Stadium of Anaheim, hotels, and market-
1
rate housing.
Anaheim is in dire need of deeply affordable housing for lower income families and other public
benefits such as open space; a rare opportunity of 151 acres should not be misused when there is so
much need.
As is evident by looking at the Ci2019 Housing Element Annual Progress Report
for the 2014-2021 planning period, there is a dire need for affordable housing accessible to low-
income families. The City has an acute deficit of affordable housing and a surplus in above market
production of housing. The City has permitted over 7,477 housing units during the current Housing
Element period and only 145 total have been in the affordability level of low and very low. The vast
majority of the housing units, 7,332 have been approved at moderate and above moderate income
levels. To-date, the City has outperformed and exceeded their above moderate-income RHNA
2
requirement, constructing 7,182 or 287% of the 2,501 required. Meanwhile, only 124 or 10% of the
1,256 very low-income units and 121 or 13% of the 907 low-income units have been approved in
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the City. With a remaining total RHNA need of 1,950 lower income homes, it is important the City
effectively encourage and prioritize the development of affordable homes for lower income
households over above moderate housing.
The project proposal being considered would only provide 466 units of affordable housing at the
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moment. These affordable housing units would be required to be built in the next 25 years.
This amount does not come close to -low
and low income level. Even if the 466 units were included
current 2014-2021 planning period that would still leave a deficit of 1,484 units at the very low and
low income levels. Meanwhile, the project would add 4,709 market-rate residential units at the
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above moderate level. This would cause Anaheim to further exceed there RHNA requirement for
1 City of City Council Staff Report, Item 7, p. 5, September 29, 2020.
2 9 Annual Housing Element Progress Report, p. 3, April 2020.
9 Annual Housing Element Progress Report, p. 2, April 2020.
3
4 City of City Council Staff Report, Item 7, p. 8, September 29, 2020.
5 City of City Council Staff Report, Item 7, p. 8, September 29, 2020.
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Mayor Harry Sidhu and City Council Members
September 29, 2020
housing at the above moderate income level by 9,540 units. A new and larger RHNA allocation will
be issued for the City when the new Housing Element planning period begins in 2021. To-date,
SCAG predicts the total RHNA allocation for the very low and low income level for the upcoming
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cycle to be 3,757 and 2,391, respectively. While the total proposed affordable housing units is 15%
of all units developed, or approximately 776 units, it is unclear when the rest of the affordable
housing units will be developed. There is no assurance that they will even be available for the next
planning period.
k-record of prioritizing above moderate housing on Housing Opportunity Sites
identified in the current Housing Element as sites that can be
requirements at the very-low and low, the City will have a very difficult time meeting its current
and upcoming RHNA allocation. For example, a 20- acre market-rate development by TRI Pointe
Homes, Inc. was approved in two of these opportunity sites located in the Residential Overlay Zone.
Upon its completion, the development will provide 546 residential units at the above moderate
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income level. The City must cease to prioritize above moderate housing production on city-owned
land, like the land in question in this project proposal, and on the identified Housing Opportunity
Sites and instead actively and effectively encourage affordable housing production. The sale of this
It is the Commissions strong belief that the City should not provide the developer with a
credit at escrow of $123,677,843 for setting aside 466 of the total units for affordable housing
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and $46,233,094 for 7 acres of Community Benefit Park.
The land the City is attempting to
dispose of is city-owned, land, specifically surplus land as defined by the CA Surplus Land Act. As
such, the City should require the developer to provide these community benefits at no cost to the
City. The community benefits are not sufficient to meet the needs of residents and they are rendered
even more inadequate when more City resources are used to pay the developer to provide them. The
City should require an increase in the amount of affordable housing and park space proposed on the
site at zero cost to the City.
While the RHNA requirement is one indicator of the affordable housing needs of residents,
there are various other indicators. For one, the homelessness crisis is worsening. According to the
2019 Orange County Point in Time count, 6,860 people experienced homelessness in Orange
County on a single night in January 2019, which is a drastic increase from the 2017 Orange County
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Point in Time count which documented 4,792 homeless people. During the 2017 to 2018 school
year, a total of 6,056 Anaheim Elementary and Anaheim Union High School District students in
th
grades Pre-K through 12 grade were identified as homeless living in unstable environments in the
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Orange County school districts, and increase of 1,117 students from the previous year. In addition,
according to the recent release of the Cost Study of Homelessness, close to $300 million was spent
to address homelessness in Orange County during 2014 to 2015. Studies have shown that housing
coupled with supportive services is a cost-efficient intervention that will safely house individuals
experiencing chronic homelessness.
6 SCAG 6 th Cycle Draft RHNA Allocation Based on Final RHNA Methodology & Final Connect SOCAL
http://www.scag.ca.gov/programs/Documents/RHNA/RHNA-Draft-Allocations-090320-Updated.pdf
City Council Agenda Report for Item 20, p.1, June, 2019.
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8
City of City Council Staff Report, Item 7, p. 2, September 29, 2020.
9 Orange County Homeless Population Jumps to Nearly 7,000, Survey Shows, Los Angeles Times, April 25, 2019.
10 Orange County Homeless Children and Youth District Enrollment Ratios 2017 2018, Orange County Department of Education, 2019.
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Mayor Harry Sidhu and City Council Members
September 29, 2020
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y comprised of occupations that cater to the service sector.
Of the top 15 principal employers in the City, ten provide entertainment, leisure, hospitality and
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health services. These jobs related to entertainment (Disneyland Resort, Angels Baseball, Honda
Center), hospitality services (hotels), leisure (restaurants and retail) and health services (Kaiser,
service sector market typically offers lower wages. The average salary for occupations in the
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tourism market is approximately less than $30,000 a year, which is not enough to rent an
apartment home in the City without overpaying and being rent burdened. In Orange County a
resident must earn at least $39.17 per hour to afford a two-bedroom apartment at a fair market rent
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of $1,876 a month. Orange County renters paid an average of $355 more a month in the seven
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years prior to 2018 and rents are projected to continually rise. During 2000 to 2015, Orange
inflation-adjusted median rent increased by 28 percent while the median renter income
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decreased by 9 percent. Anaheim residents cannot afford to live in the City or in other parts of
Orange County. Given the housing insecurity residents face, the City must prioritize the production
of affordable housing over above moderate housing, especially in City-owned land. It should not
waste the opportunity that 152-acres of city-owned land can provide .
Thank you for your consideration of these concerns. We look forward to further conversation
regarding this important matter. Please keep us informed of any updates and meetings regarding
strategies to increase affordable homes for lower income households in the City. If you have any
questions, please free to contact me at (949) 250-0909 or cesarc@kennedycommission.org.
Sincerely,
Cesar Covarrubias
Executive Director
Multi-Family Anaheim Orange County Market, CoStar, p. 2, March 2019.
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12 Financial Annual Report, p. 121, June 30, 2019.
13 OC Community Indicators 2018, p. 40, 2018.
Out of Reach 2019- The High Cost of Housing, National Low Income Housing Coalition, p.15, 2019.
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15 Southern Californians Scrimp to Get By As Average Rents Hit $1,900, Orange County Register, February 15, 2018.
16 ary 15, 2018.
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