02
Jennifer L. Hall
From:Cynthia Guerra <cynthiag@kennedycommission.org>
Sent:Tuesday, May 18, 2021 5:23 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 2 (5.18.2021)
Attachments:Ltr_Anaheim_ City Council-Housing Authority_Item 2_5.18.2021.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 (5.18.2021):
Item 2: This is a Joint Public Hearing of the Anaheim Housing Authority (“Authority”) and the
Anaheim City Council regarding the proposed sale and the proposed ground lease of certain
real property owned by the Authority located at 100, 130, and 212 South Beach Boulevard and
2970 West Lincoln Avenue, Anaheim (“Properties”). Certain parcels of the Properties are
proposed to be sold by the Authority under the terms of a certain Disposition and Development
Agreement between the Authority, as seller, to Greenlaw 39 Commons Beach, LLC or an
affiliate thereof. Certain other parcels of the Properties are proposed to be ground leased by
the Authority to Greenlaw 39 Commons Beach, LLC (or to a limited partnership of which
Affordable Housing Access, Inc. is the general partner and Greenlaw 39 Commons Beach LLC
or its affiliate is the administrative partner) for long-term affordable housing and the
development and operation of a new 100-unit affordable rental housing project \[noticed
consideration of the Disposition and Development Agreement has been removed and will be re-
noticed and considered separately by the Anaheim Housing Authority at a future public
hearing\].
Please confirm receipt of this email and let me know if you have any questions.
Thank you,
Cynthia Guerra
Cynthia Guerra
The Kennedy Commission
Research and Policy Analyst
Pronouns: She/Her/Ella
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May18, 2021
www.kennedycommission.org
17701 Cowan Ave., Suite 200
Irvine, CA 92614
Mayor Harry Sidhu and City Council Members
949 250 0909
City of Anaheim
200 S. Anaheim Boulevard
Anaheim, CA 92805
RE: Item 2 Regarding the 39 Commons II affordable housing project between the Anaheim
Housing Authority and Greenlaw 39 Commons Beach, LLC
Dear Mayor Harry Sidhu and Council Members:
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
$27,000 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.
The Commission urges the Council to require that Greenlaw 39 Commons Beach, LLC
increase the number of units in the proposed development dedicated to affordable housing
before approving the proposed development. At minimum the City should ask for 200 units
that are deed-restricted at the extremely low and a very low income levels and at least 3 acres
of the City-owned land be dedicated to affordable housing.
Under the current proposal, Greenlaw would provide 1.796 acres of affordable housing in exchange
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for 5.474 acres of city-owned land that will be developed into market-rate housing and retail. This
is not a fair trade. The City should NOT be giving away its priced land resources to projects that
will not meet the needs of the community. Given inability to meet its Regional Housing
Needs Assessment allocation (RHNA) at the lower income levels during the current Housing
Element Planning Period (2014-2021) and over production at the above moderate income level, the
City needs to prioritize the use of all City-owned sites for affordable housing. For the 2014-2021
Housing Element planning period, the City has a 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
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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
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moderate-income RHNA. The City has a remaining RHNA need of 1,695 lower income homes for
the current planning period. The 100 units of affordable housing the Greenlaw development
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proposes are not sufficient to meet the affordable housing deficiency the City is experiencing.
The need to prioritize the production of affordab
new RHNA allocations for the 2021-2029 Housing Element planning period. T
RHNA allocation for the very low and low income level for the upcoming planning period are 3,767
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and 2,397, respectively. That is a total of 6,164 lower income homes, which is almost three times
Anaheim City Council Staff report for Item 2a, page 2, May 18, 2021.
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2 Annual Housing Element Progress Report, March 22, 2021.
3 City of Anahe20 Annual Housing Element Progress Report, March 22, 2021.
Anaheim City Council Staff report for Item 2a, page 2, May 18, 2021.
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5 https://scag.ca.gov/sites/main/files/file-attachments/6th-cycle-rhna-proposed-final-
allocation-plan.pdf?1614911196
Working for systemic change resulting in the production of homes affordable to -income households
May 18, 2021July 30, 202030, 2020y 30, 2020
Page 2 of 2
larger than the previous lower income RHNA allocation. The City history over-producing above
moderate housing and poor performance producing lower income housing is an indication that the
One strategy the City can use to meet its
City needs to focus on prioritizing affordable housing.
lower income housing need is to implement stronger affordable housing requirements on City-
owned land, such as the 5.6 acres that are being considered for the Greenlaw project.
Affordable homes are urgently needed for lower income residents given the increasing cost of
housing in Orange County. A resident must earn at least$42.62 per hour to afford a two-bedroom
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apartment at a fair market rent. 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 unrealistic for lower
income families in Anaheim. According to the California Housing and Community Development
Department for a family of four at the extremely low income
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level is $40,350 and $67,250 at the very low income level. The median income for Anaheim
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residents in 2018 was $65,313. Based on these figures, it is clear that many Anaheim residents are
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extremely low and very low income and cannot afford market-rate housing in Orange County.
City must not give away limited City-owned land for the production of market-rate housing
and should, instead, prioritize this valuable resource for affordable housing.
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@kennedycommission.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.
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7 9, April 26, 2021.
8 City of Anaheim