Item No. 3 - DEV2021-00180 Public Comments (2)
December 5, 2022
Dave Vadodaria, Chairperson
Planning Commissioners
City of Anaheim Planning Commission
200 S. Anaheim Blvd.
Anaheim, CA 92805
RE: Item 3 - DEVELOPMENT APPLICATION NO. 2021-00180 CONDITIONAL USE
PERMIT TENTATIVE TRACT MAP NO. 19237
Chair Vadodaria and Planning Commissioners:
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 Planning Commission considers the request of a Conditional Use Permit and Tentative
Tract Map for the proposed development at the southwest corner of Lincoln Avenue and Sunkist
Street, The Kennedy Commission urges the Council to not approve an agreement until the City
of Anaheim and KB Home commit to creating affordable housing units on this Housing Element
identified housing opportunity site for lower income housing. The city identified sites and
created the Residential Opportunities Overlay Zone (ROO) as a by right program to address and
incentivize affordable housing and meet its housing sites capacity for lower income housing.
The ROO is intended to facilitate affordable housing and increase the likelihood that the ROO
sites will include affordable housing for lower incomes.
By approving market rate housing and not affordable housing the city continues to fall behind on
affordable housing production for lower income housing. In addition, the city currently does not
have a certified Housing Element nor does it currently have sufficiently identified lower income
sites capacity. The city needs to prioritize developments that are 100% affordable for lower-
income families, especially on land and sites in the Residential Opportunity Overlay Zones. At a
minimum, 15%-20% of the units should be affordable to low, very low, and extremely low-
income families.
As highlighted in the City of Anaheim’s latest Housing Element Annual Progress Report that
was submitted to the California Housing and Community Development department 1, the city has
a deficit of affordable housing production. The report points out that the city has approved and
1 City of Anaheim, Housing Element Annual Progress Report, June 2022
www.kennedycommission.org 17701 Cowan Ave., Suite 200 Irvine, CA 92614 949 250 0909
Planning Commission
December 5, 2022
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permitted over 8,719 housing units during the current Housing Element period and only 369
have been in the affordability level of low and very low income. The remaining
RHNA for lower-income households is 1,794. Most of the housing units, 8,350, have been
approved at moderate and above moderate-income levels (RHNA in above moderate has been
exceeded by over 300%). Given the City’s track-record of prioritizing moderate and above
moderate market-rate housing on Housing Opportunity Sites, the City will continue to have a
very difficult time meeting its current and upcoming RHNA allocation for lower-income
residents. It is imperative that opportunity sites identified in the Residental Opportunity
Overlay Zone are prioritized to develop lower-income housing that is not being addressed
by market-rate development.
The Commission looks forward to further conversations regarding the use of Residential
Opportunity Overlay zoned land to increase affordable housing opportunities for lower-income
families in Anaheim and enforcing the cities housing policies and commitments. 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 us 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