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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