26 (2)
Susana Barrios
From:Adam Wood <awood@biasc.org>
Sent:Tuesday, June 27, 2023 8:40 AM
To:City Clerk; Public Comment; Ashleigh Aitken; Natalie Rubalcava; Jose Diaz; Carlos A.
Leon; Norma C. Kurtz; Stephen Faessel; Natalie Meeks
Subject:\[EXTERNAL\] Item 26 - Housing Coalition Comment Letter
Attachments:Item 26 - Coalition Letter.pdf
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Thank you.
-Adam
Adam S. Wood
Senior Vice President – BIA/SC
Orange County Chapter
Building Industry Association of Southern California, Inc.
awood@biasc.org
ph: (949) 777-3860 w: biasc.org
Address: 17192 Murphy Ave., #14445, Irvine, CA 92623
1
June 27, 2023
Mayor Ashleigh Aitken
City of Anaheim
200 S. Anaheim Blvd.
Anaheim, CA 92805
Re: File Item 26: Update on the City’s Housing Affordability Ad Hoc – Oppose
Dear Mayor and Council,
Housing affordability is unquestionably a leading issue for California policy makers. Historically
high home prices have dominated news cycles and placed undue burdens on communities across
the State. Action is needed to address the growing housing crisis but before that can happen, we
must first understand the cause.
For over 40 years, the population of California has rapidly outpaced housing production. For as
complicated as housing policy can be, cost escalation is relatively straight forward. California has
not produced enough units to meet the demand. As California remains a highly desirable place to
live, the supply/demand imbalance has resulted in rapidly escalating home prices.
The specific reasons why California underproduced can be debated but ultimately it results from
laws and policies that have constrained production. With this in mind, we are deeply concerned
to see the Staff Report for the “Update from the Housing Affordability Ad Hoc Committee”
expressing a desire to investigate development fees and inclusionary housing programs.
Additional fees and barriers will do nothing to facilitate new housing production in Anaheim.
The staff report states that the Ad Hoc Committee specifically looked at development fee programs
and inclusionary housing. There is an implication that other programs might have been
considered but none are addressed in the staff report. The conclusion of said report states if
“staff is directed to conduct a study in furtherance of the Committee’s work…” it will cost $50,000.
We have considerable concern about the scope and procurement of such direction.
The ad hoc committee was not subject to the Brown Act and thus had no public participation.
Other than the information contained in the Staff Report, there is no indication as to what exactly
a “study in furtherance” would entail. The proposed $50,000 cost estimate indicates a specific
scope that staff contemplated. To date, this scope is not public information.
Further, proceeding under the City Manger’s budget authority raises multiple questions. Will this
$50,000 report be competitively bid to ensure the city receives a balanced report? As far as the
record reflects, the only outside voice considered at this point is that of Keyser Marston. Input
from one potential vendor does not make for a balanced or equitable approach to procurement. In
the interest of transparency and best practice, if this advances, we hope multiple firms are contacted
and given the ability to submit a reasonable scope of work (and cost estimate) aligning with “a
study in furtherance.”
This, however, brings the central question back into focus. Why is Anaheim even considering fee
programs and inclusionary housing? The Staff Report states that on March 9, 2023, staff provided
background on current practices which includes meeting with housing developers to review the
merits for voluntarily including below market rate units on site. It is implied this meeting did not
assuage concerns of the Ad Hoc Committee. This is where concerns about lack of public input
comes in to focus.
If the goal of this Council is to produce housing, the question is how to maximize production, not
squeeze concession. If the current “meet and confer” approach did not address concerns of the Ad
Hoc committee, then we need to study why the incentives the city offers are insufficient. The
Ad Hoc should consider spending $50,000 on an incentive system that leverages market realities,
as opposed to investigating programs to extract fees and impose barriers.
A perfect example of why incentives, not fees, should be pursued can be seen in Santa Ana. During
a hot housing market, Santa Ana spent years with zero new projects entering the production
pipeline. Then, in 2020 their Council reduced burdensome Inclusionary requirements and a flood
of new units were proposed. This provides a tangible neighboring-city example where city-
imposed burdens on development stopped housing. This is common across the state but remains
underreported as there is no database for projects that “didn’t happen.” Instead, you must look at
the continued rates of underproduction to see that no city with development fees and inclusionary
“solved” their affordability issues.
It does merit mentioning that many supporters of the Inclusionary approach like to cite the city of
Irvine as an example of success. If every city had a decommissioned military base with unified
development control, then citing Irvine would be valid. As no other jurisdiction sits in a land use
or economic situation reflective of Irvine conditions, comparisons are not valid.
In conclusion, Inclusionary is not a solution if the goal is housing production. We hope the
council will consider leveraging market realities to offer a non—punitive approach to
subsidized housing production. Anything short of that will further limit production in Anaheim
and will mark a clear departure from the City’s long held values of vitality through innovation.
We appreciate your thoughtful consideration of this matter.
Sincerely,
Adam Wood, Senior Vice President
Building Industry Association Southern California – OC Chapter (BIA/OC)
Victor Cao, Senior Vice President, Local Public Affairs
California Apartment Association (CAA)
Jennifer Bullard, Senior Vice President
Orange County Business Council (OCBC)
Phil Hawkins, Chief Executive Officer
Pacific West Association of REALTORS® (PWR)
Sara Catalán, President and CEO
Orange County Taxpayers Association (OCTax)
David Cordero, Executive Director
Apartment Association of Orange County (AAOC)
Vickie Talley, Executive Director
Manufactured Housing Educational Trust (MHET)