07Public Comment
From: Cynthia Guerra <cynthiag@kennedycommission.org>
Sent: Tuesday, March 23, 2021 10:15 AM
To: City Clerk
Cc: Public Comment; Cesar C; paul.mcdougall@hcd.ca.gov; Megan.Kirkeby@hcd.ca.go
Subject: Letter re: City Council Agenda Items 7 (3.22.2021)
Attachments: Ltr_Anaheim_ City Council Item 7_3.22.2021.pdf
Hi,
Please find the attached letter on behalf of the Kennedy Commission addressing the following item on
today's Anaheim City Council meeting agenda (3.22.2021):
Item 7: Annual Housing Element Progress Report for the 2020 Reporting Period
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
March 22, 2021
Mayor Harry Sidhu and City Council Members
City of Anaheim
200 S. Anaheim Boulevard
Anaheim, CA 92805
RE: Item 7 - Annual Housing Element Progress Report for the 2020 Reporting Period
Dear Mayor Harry Sidhu and Council Members:
www.kennedycommission.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 the City Council reviews the City of Anaheim's 2020 Annual Housing Element Progress Report
for the 2014-2021 planning period, the Commission urges the City to take into account the severe
imbalance between housing production at the lower income levels and above moderate income
level. The City must evaluate its current policies and programs to ensure they facilitate the
development of homes affordable to lower income households in the City which they have
failed to do thus far. 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 308 or 25% of the 1,256 very low-income units and 160 or 18% of the 907 low-
income units! However, for the above moderate -income units, the City outperformed and exceeded
the RHNA by constructing 7,644 or 306% of the 2,501 above moderate -income RHNA.2 The City
has a remaining RHNA need of 1,695 lower income homes for the current planning period.
Thus far, the City has followed a market -rate approach towards affordable housing and opted not to
implement concrete policies that would facilitate its production. It is clear from the City's inability
to meet its current lower income housing need and the drastic housing over -production at the above
moderate income level that a market -rate approach does not produce affordable housing. In order
to ensure there are enough homes available the City must:
1. Develop and implement policies and programs that truly produce affordable housing.
Examples of effective policies are mixed -income ordinances and inclusionary policies which
guarantee that any development in the City will provide affordable housing.
2. Incentivize the development of affordable housing on the housing opportunity sites the
City identified in its current and upcoming Housing Elements. The City has a track -
record of prioritizing above moderate housing on housing opportunity. For example, in
2019, the City approved a 20 -acre residential development at the above moderate income
level in the Residential Opportunity Overlay Zone. The City will have a difficult time
City of Anaheim's 2020 Annual Housing Element Progress Report, March 22, 2020.
z City of Anaheim's 2020 Annual Housing Element Progress Report, March 22, 2020.
2020 Annual Housing Element Progress Report
March 22, 2021
Page 2 of 2
meeting its current and upcoming lower income RHNA allocations if it continues to
prioritize the development of above moderate homes on its housing opportunity sites.
3. Prioritize the development of affordable housing on City -owned land.
The need for strategies that effectively produce affordable housing is even more urgent in light of
the City's new RHNA allocations for the 2021-2029 Housing Element planning period. The City's
total RHNA allocation for the very low and low income level for the upcoming planning period are
3,767 and 2,397, respectively.3 That is a total of 6,164 lower income homes, which is almost three
times larger than the previous lower income RHNA allocation. If a market -rate approach was not
effective during the current planning period, it will not work with a much larger RHNA allocation
in the upcoming period. Moreover, the City has new statutory requirements for the upcoming
Housing Element planning period that mandate the inclusion of programs that affirmatively further
fair housing (AFFH). AFFH includes ensuring a sufficient number of affordable homes are
available for lower income residents throughout the entire City.
Time is overdue for the City to develop policies and programs that will increase production at the
lower income levels. The City has no problem facilitating the production of above moderate
housing and it has gone to great lengths to address moderate income housing by creating a Middle
Income Housing Program. However, the City has not taken similar concrete steps to address the
lack of housing at the lower income levels. 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 cesarc(kkennedycommission.org.
Sincerely,
Cesar Covarrubias
Executive Director
cc: Ms. Megan Kirkeby, Deputy Director, Housing Policy Development, CA HCD
Mr. Paul McDougall, Housing Manager, CA HCD
s "SCAG 6th Cycle Final RHNA Allocation Plan," March 4, 2021. https:Hsca .c�a.gov/sites/main/files/file-attachments/6th-cycle-rhna-proposed-final-
allocation-plan.pdf? 1614911196