15Jennifer L. Hall
From: Cesar C <cesarc@kennedycommission.org>
Sent: Tuesday, December 7, 2021 5:50 PM
To: City Clerk
Subject: [EXTERNAL] Item 15 - Second Amended Negotiation Agreement Anaheim Blvd and
Ball
Attachments: Ltr_Item 15 12.7.2021.pdf
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Please see attached the Kennedy Commission's comments for Item 15 - Second Amended Negotiation
Agreement - Anaheim Blvd and Ball
Cesar Covarrubias
Executive Director
December 7, 2021
Mayor Harry Sidhu
City Council Members
City of Anaheim
200 S. Anaheim Boulevard
Anaheim, CA 92805
www.kennedycoininission.org
17701 Cowan Ave., Suite 200
Irvine, CA 92614
949 250 0909
RE: Item 15 - APPROVAL OF SECOND AMENDED AND RESTATED EXCLUSIVE
NEGOTIATION AGREEMENT BETWEEN THE CITY OF ANAHEIM AND GREENLAW
DEVELOPMENT, LLC FOR DEVELOPMENT AT THE SOUTHEAST CORNER OF
ANAHEIM BOULEVARD AND BALL ROAD
Dear Mayor Harry Sidhu and City Council Members:
The Kennedy Commission (the Commission) is a broad-based 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 Orange County jurisdictions to create effective
housing and land -use policies that has led to the new construction of homes affordable to lower
income working families.
As the City Council considers the amendment to the Exclusive Negotiation agreement for the
proposed development at the southeast corner of Anaheim Boulevard and Ball Road, The
Kennedy Commission continues to urge the Council to not approve an agreement until this
development there are direct commitments to maximize affordable housing production on this
city owned land.
The City needs to prioritize developments that are 100% affordable for lower income
families on this city owned site to maximize and leverage additional federal and state
housing funds. At a minimum a 15%-20% of the units should be affordable to low, very
low and extremely low-income families. We stated our position in the letter submitted for
the first reading of the project on October 27, 2020, and November 10, 2020 (second
reading). The developer last proposed only a voluntary contribution of $269,000,1 which is
not enough to meet the need of Anaheim residents. If the City is unwilling to require the
inclusion of affordable units in the proposed development, then it should require a more
appropriate in lieu fee to build affordable housing off site based on comparable costs
specifically at the low, very low and extremely low-income families.
In addition, the city should follow the requirements of the California Surplus Land Act
when disposing of city owned land.
'City of Anaheim's City Council Agenda Staff Report, Item 19, p. 1, November 2020.
Mayor Harry Sidhu and City Council Members
December 7, 2021
The City's 2020 Annual Housing Element Progress Report for the 2014-2021 planning period
illustrates the urgent need for affordable housing for Anaheim residents and the disproportionate
production of above moderate -income units. 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.2 However, for the above moderate -income
units, the city outperformed and exceeded the RHNA by constructing 7,644 or 30% of the 2,501
above moderate -income RHNA.3 With a remaining RHNA need of 1,695 lower income
homes, it is important the city prioritize the development of new affordable homes and
adopt a mixed -income housing ordinance to encourage the development of affordable
homes for lower income households in the City.
The city has a new RHNA allocation for the very low and low income level for the upcoming
cycle of 3,757 and 2,391, respectively.4 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 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. It is imperative that city owned land is prioritized to develop
lower income housing that is not being address by market rate development.
The Commission looks forward to partnering with the city to increase affordable home
opportunities for lower income households in the city, especially as the city works to address the
impact of COVID-19 on the housing security of residents. Please keep us informed of any
updates and meetings regarding strategies to increase affordable homes for lower income
households in the city. If you have any questions, please free to contact me at (949) 250-0909 or
cesarc@kennedycommission.org.
Sincerely,
Cesar Covarrubias
Executive Director
cc: Ms. Megan Kirkeby, Acting Deputy Director, Housing Policy Development, CA HCD
Mr. Paul McDougall, Housing Manager, CA
HCD PublicLands@hcd.ca.gov
2 City of Anaheim's 2019 Annual Housing Element Progress Report, p. 2, April 2020.
s City of Anaheim's 2019 Annual Housing Element Progress Report, p. 3, April 2020.
' "SCAG 6' Cycle Draft RHNA Allocation Based on Final RHNA Methodology & Final Connect SOCAL," September 3, 2020.
ham://www.scan.ca.nov/pro2 ams/Documents/RHNA/RFINA-Draft-Allocations-090320-1Jpdated.pdf
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