07 & 11Public Comment
From: Cynthia Guerra <cynthiag@ken nedycommission.org>
Sent: Tuesday, February 16, 2021 5:16 PM
To: City Clerk
Cc: Public Comment; Cesar C; paul.mcdougall@hcd.ca.gov; Megan.Kirkeby@hcd.ca.gov
Subject: Letter re: City Council Agenda Items 7 and 11 (2.16.2021)
Attachments: Ltr_Anaheim_ City Council Items 7 and 11_2.16.2021.pdf
Hi,
Please find the attached letter on behalf of the Kennedy Commission addressing both of the following items in
today's Anaheim City Council meeting agenda (2.16.2021):
• Item 7: CONSIDERATION OF A RESOLUTION APPROVING, AUTHORIZING AND DIRECTING
EXECUTION OF A JOINT EXERCISE OF POWERS AGREEMENT RELATING TO THE CMFA
SPECIAL FINANCE AGENCY I AND THE FORM OF A PUBLIC BENEFIT AGREEMENT; AND
APPROVING THE ISSUANCE OF REVENUE BONDS BY SAID AGENCY FOR THE PURPOSE
OF FINANCING THE ACQUISITION, CONSTRUCT
• Item 11: RESOLUTION IN SUPPORT OF STATE LEGISLATION THAT PROVIDES LOCAL
CREDIT TOWARD REGIONAL HOUSING NEEDS ASSESSMENT FOR HOUSING UNITS
CREATED THROUGH THE MODERATE INCOME HOUSING PROGRAM
Please confirm receipt of this email and let me know if you have any questions.
Thank you,
Cynthia Guerra
Cynthia Guerra
The Kennedy Commission
Community Organizer
February 16, 2021
Mayor Harry Sidhu and City Council Members
City of Anaheim
200 S. Anaheim Boulevard
Anaheim, CA 92805
RE: Item 7 and Item 11 Concerning the City's Moderate Income Housing Program
Dear Mayor Harry Sidhu and Council Members:
www.kennedycoininission.org
17701 Cowan Ave., Suite 200
Irvine, CA 92614
949 250 0909
The Kennedy Commission (the Commission), a broad-based coalition of residents and community
organizations, advocates for the production of homes affordable for families earning less than
$20,000 annually in Orange County. Formed in 2001, the Commission has successfully partnered
and worked with Orange County jurisdictions to create effective housing and land -use policies that
have led to the new construction of homes affordable to lower-income working families.
As you review the agenda items concerning the City's Moderate Income Housing Program (the
Program), the Commission strongly encourages the Council to equally prioritize the creation of
housing at the lower income levels. The City's lack of progress in meeting its current very low and
low income RHNA allocations demonstrates the need for the City to take urgent action to increase
housing production at these levels. For the 2014-2021 Housing Element planning period, the City
has a Regional Housing Needs Assessment (RHNA) of 1,256 very low- and 907 low-income
households. To -date, the City has built 124 or 10% of the 1,256 very low-income units and 121 or
13% of the 907 low-income units.' However, for the above moderate -income units, the City
outperformed and exceeded the RHNA by constructing 7,182 or 287% of the 2,501 above
moderate -income RHNA.2 While 948 above moderate units were added in 2019, only 53 units total
were added at the very low and low income levels. With this Program, the City is addressing its
dearth in moderate income housing. However, the City has not taken equal decisive action to
address the shortage of lower income housing. With a remaining RHNA need of 1,950 lower
income homes, it is important the City equally prioritize the development of homes at the
lower income levels and adopt a mixed -income housing ordinance to encourage the
development of affordable homes for lower income households in the City.
Arguably, the City has a more urgent need to address housing production at the lower income levels
than the moderate income levels given the RHNA allocations the City received for the 2021-2029
Housing Element planning period. SCAG anticipates the City's total RHNA allocation for the very
low and low income level for the upcoming cycle to be 3,757 and 2,391, respectively.3 That is a
total of 6,148 lower income homes. In contrast, the City has received a moderate income level
allocation of 2,939 units. Given the City's track -record of prioritizing above moderate housing on
Housing Opportunity Sites identified in the current Housing Element as sites that can be used to
meet the City's RHNA requirements at the very -low and low, the City will have a very difficult
time meeting its current and upcoming RHNA allocation. For example, in 2019 the City approved a
'City of Anaheim's 2019 Annual Housing Element Progress Report, p. 2, April 2020.
2 City of Anaheim's 2019 Annual Housing Element Progress Report, p. 3, April 2020.
s "SCAG 6h Cycle Draft RHNA Allocation Based on Final RHNA Methodology & Final Connect SOCAL," September 3, 2020.
https:Hscaa.ca.aov/sites/main/tiles/tile-attachments/staff-recommended-rhna-estimated-allocations-030520.12dt?l602189445
Moderate Income Housing Program
February 16, 2021
Page 2 of 2
20 -acre market -rate residential development in the Residential Opportunity Overlay Zone, depleting
the capacity of the City meet its remaining housing needs for lower income households. Given the
dire lack of lower income homes and the larger RHNA allocations the City received at these
income levels for the upcoming cycle, the City has a greater responsibility to quickly and
effectively create policies and programs that specifically target production at the very low and
low income levels.
Affordable homes are urgently needed for lower income residents given the increasing cost of
housing in Orange County. The County is consistently ranked among the top ten least affordable
metropolitan areas in the country.4 A resident must earn at least $42.62 per hour to afford a two-
bedroom apartment at a fair market rents Based on this figure, the approximate annual income a
resident must have to afford housing in Orange County is $81,830. 40. This income is completely
unrealistic for lower income families. According to the California Housing and Community
Development Department (HCD), the County's annual median income (AMI) for a family of four at
the extremely low income level is $38,450, $64,050 at the very low income level, and $102,450 at
the low income level_6 Meanwhile, at the moderate income level, the County's AMI is $123,600.
These figures demonstrate that the residents most unable to afford housing in Orange County,
including the City of Anaheim, are the residents at the extremely low and very low income levels.
While the affordability housing crisis affects moderate income families at a much lesser extent, the
City is going to great lengths to address this issue by creating a Middle Income Housing Program,
and trying to pass legislation. However, it has taken nowhere near as concrete steps to address to
pass policies, programs, and support legislation that would create housing for lower income
families. In light of the above figures, the City should first prioritize the production of housing
for lower income families before they prioritize moderate income housing, or at the very least
address these issues simultaneously. The Commission would like to work with the City to
make this a reality.
We look forward to working with the City of Anaheim to encourage effective housing policies that
will help create balanced housing development and create much-needed affordable housing in our
local communities. If you have any questions, please feel free to contact me at (949) 250-0909 or
cesarcLkennedycommission.org.
Sincerely,
Cesar Covarrubias
Executive Director
cc: Ms. Megan Kirkeby, Deputy Director, Housing Policy Development, CA HCD
Mr. Paul McDougall, Housing Manager, CA HCD
' Out of Reach 2020- The High Cost of Housing, National Low Income Housing Coalition, p.17, 2021.
Out of Reach 2020- The High Cost of Housing, National Low Income Housing Coalition, p.17, 2021.
'California Department of Housing and Community Development "State Income Limits for 2020," p. 8, April 30, 2020.