20Public Comment
From: City Clerk
Sent: Tuesday, July 20, 2021 1:52 PM
To: Public Comment
Subject: FW: Kennedy Commission Comments on Item 20
Attachments: Anaheim SLA 7.20.21.pdf
From: Cesar C <cesarc@ken nedycommission.org>
Sent: Tuesday, July 20, 20211:35 PM
To: City Clerk <cityclerk@anaheim.net>
Subject: Kennedy Commission Comments on Item 20
Anaheim City Clerk,
Please see attached comments on Item 420.
Item 20: DISCUSSION REGARDING CALIFORNIA DEPARTMENT OF HOUSING AND
COMMUNITY DEVELOPMENT LETTER TO THE CITY OF ANAHEIM REGARDING THE
SURPLUS LAND ACT
Cesar Covarrubias
Executive Director
July 20, 2021
Mayor Harry Sidhu
Councilmembers
City of Anaheim
200 S. Anaheim Blvd.
Anaheim, CA 92805
www.kennedycoininission.org
17701 Cowan Ave., Suite 200
Irvine, CA 92614
(949)250-0909
Re: CA Housing and Community Development Department Inquiry on Surplus Land Act
Violation for the Sale of 153 -acres of property generally located at 2000 E. Gene Autry
Way and 2200 E. Katella Ave. in Anaheim
Dear Mayor Harry Sidhu and Councilmembers:
The Kennedy Commission (the Commission) is broad 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 jurisdictions in Orange County to create effective policies that have
led to the production of new homes affordable to low income working families.
We submitted public comments on December 20, 2019, opposing the City's sale of the city
owned 153 -acres of property generally located at 2000 E. Gene Autry Way and 2200 E. Katella
Avenue. Our objection was based on the City's violation of the Surplus Land Act (the "Act").
Accordingly, we continue to urge the City to dispose of the Land in a manner that complied with
the Act by, at a minimum, offering a priority to sell or lease the land for affordable housing or
open space uses.
L 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, "housing is of vital statewide
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
highest order," and thus "surplus government land, prior to disposition, should be made
available for that purpose." Cal. Gov. Code, § 54220(a).
Specifically, the Act requires that a local agency disposing of surplus land must send a
"written offer to sell or lease for the purpose of developing low- and moderate -income
housing" to local public agencies and, upon request, to individuals or organizations
certified by the state to "own, construct, acquire, or rehabilitate a housing development"
Cal. Gov't Code § 54222(a). The Act further requires that a written offer to "sell or lease for
park and recreational purposes or open -space purposes" be sent to local and regional parks
agencies. Cal. Gov't Code § 54222(b).
IL The City's Proposed Sale of the Parcels, Violate the Act
Here, the city elected not to follow the process and priorities of the Surplus Land Act. Instead,
the city proposed to sell approximately 153 acres of City owned property generally
located at 2000 E. Gene Autry Way and 2200 E. Katella Ave. in Anaheim, upon which exist
certain improvements, including Angel Stadium of Anaheim (Stadium), City National Grove of
Anaheim (Grove), and their surrounding parking areas, in the City of Anaheim.
The City's proposal set forth in a Request for Council Action dated December 20, 2019,
"This is a public hearing to take public testimony and consider the Summary Report prepared pursuant to
California Government Code section 52201, and a resolution approving a Purchase and Sale Agreement
with SRB Management Company, LLC, in the purchase price of $325,000,000, for real property
generally located at 2000 E. Gene Autry Way and 2200 E. Katella Ave, upon which exists certain
improvements, including Angel Stadium of Anaheim, City National Grove of Anaheim and their
surrounding parking areas and environs (approximately 153 acres generally bounded by Orangewood
Avenue, State Route 57, Katella Avenue, and State College Boulevard) that will assist in the creation of
economic opportunity pursuant to California Government Code section 52201 (APNs 232-011-02, -06, -
35, -36,-37, -38, -39, -40, -41, -42, -43, -44, -47, -48, -49 -50)."
(the "Staff Report").
Here the City ignored the requirements and the formal process of the Surplus Land Act and
entered into direct discussion and negotiation with SRB Management Company and pursued a
sale of city owned surplus land without allowing for a disposition of surplus land in accordance
with the act or by offering priority to affordable housing developers.
III. Conclusion
We continue to ask that the City of Anaheim rescind this sale today and move forward with a
formal disposition of the land in a manner that complies with the Surplus Land Act by, at a
minimum, offering a priority to sell or lease the land for affordable housing or open space uses.
The city needs to prioritize its city owned land to create much needed affordable housing. As
highlighted in the City of Anaheim's April 2020 Housing Element Progress Report that was
submitted to the California Housing and Community Development, the city has a deficit of
affordable housing. The city has permitted over 7,644 housing units during the current Housing
Element period and only 308 have been in the affordability level of low and very low. The vast
majority of the housing units, 7,206 have been approve at moderate and above moderate -income
levels. With only a few months left in the planning period and with the City lacking site capacity
for affordable housing sites it is imperative that the City of Anaheim prioritize affordable
housing on this land.
Thank you for your consideration of these concerns. We look forward to further conversation
regarding this important matter.
Very truly yours,
Cesar Covarrubias
Executive Director