11 (2)Public Comment
From: Theresa Bass
Sent: Tuesday, August 10, 2021 12:45 PM
To: Public Comment
Subject: FW: Letter of Support - Anaheim Hills Assisted Living
Attachments: Anaheim HoldenAssistedLiving- LetterofSupport081021.pdf
From: Heaton, Brian@HCD <Brian.Heaton@hcd.ca.gov>
Sent: Tuesday, August 10, 202112:43 PM
To: Harry Sidhu (Mayor) <HSidhu@anaheim.net>; Stephen Faessel <SFaessel@anaheim.net>; Jose Diaz
<JoDiaz@anaheim.net>; Jose Moreno <JMoreno@anaheim.net>; Avelino Valencia <AValencia@anaheim.net>; Trevor
O'Neil <TONeil@anaheim.net>
Cc: Ted White <TedWhite@anaheim.net>; Niki J. Wetzel <NWetzel@anaheim.net>; West, Shannan@HCD
<Shannan.West@hcd.ca.gov>; MPHiggins@shjlobby.com; Curt@curtpringle.com; Zeshaan Younus
<Zeshaan@curtpringle.com>; Theresa Bass <TBass@anaheim.net>
Subject: Letter of Support - Anaheim Hills Assisted Living
Dear Mayor Sidhu and City Council Members,
Attached please find a letter of support for the Anaheim Hills Assisted Living Facility to be considered at tonight's City
Council Meeting.
Brian Heaton, AICP
Senior Housing Policy Specialist, Housing Policy Division
Housing and Community Development
2020 W. EI Camino Avenue, Suite 500 1 Sacramento, CA 95833
Phone: 916.776.7504
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August 10, 2021
Harry S. Sidhu, Mayor
Anaheim City Councilmembers
City of Anaheim
200 S. Anaheim Boulevard
Anaheim, CA 92805
RE: City of Anaheim, Holden Anaheim Hills — Letter of Support
Dear Mayor Harry Sidhu and City Councilmembers:
The California Department of Housing and Community Development (HCD) is aware
that the City Council for the City of Anaheim (City) will be further considering an appeal
of the Holden Anaheim Hills Project (Project) at its August 10, 2021 public hearing. The
purpose of this letter is to provide HCD's support for the Project and urge the City to
deny the appeal.
HCD understands the Planning Commission approved a conditional use permit (CUP
2019-05144) for the Project at its May 24, 2021 public hearing. An appeal of the
Planning Commission's approval was filed. The City Council held an appeal hearing on
July 20, 2021 during which the City Council expressed intention to grant the appeal and
deny the Project. To give staff time to prepare findings of denial, the item was continued
to the August 10, 2021 City Council meeting.
The Project would provide 118 units of housing for seniors who require the care of an
assisted living or memory care facility. The Project is proposed on a site in the "RH-3"
zone where a now -vacant church building and associated parking lot are already
constructed. The "Senior Living Facility — Large" is a permitted use — with a CUP in the
"RH-3" zone. The outright denial of a CUP application should be considered an act of
last resort, generally applicable when all attempts to condition the project have failed.
The proposed Project would provide necessary housing to a substantial number of
seniors and to persons with disabilities.
The State of California is in a housing crisis, and the provision of housing is a priority of
the highest order. HCD encourages the City Council to uphold the Planning
Commission's approval by denying the appeal and approving the Project.
Harry S. Sidhu, Mayor
Page 2
Housing Supply for Special Needs
Currently there is an inadequate supply and production of homes for persons in
protected classes, including housing for seniors. State Housing Element Law contains
multiple requirements related to the development of housing for seniors including:
• An analysis of special needs populations, including those of the elderly population (Gov.
Code, § 65583, subd. (a)(7));
• An analysis and provision of zoning that accommodates a variety of housing types (Gov.
Code, § 65583.2, subd. (c));
• An analysis of any potential governmental constraints to the development of housing (Gov.
Code § 65583, subd. (a)(5)); and
• Inclusion of program actions that:
o Encourage a variety of housing types (Gov. Code, § 65583, subd. (c)(1));
o Assist in the development of housing (Gov. Code, § 65583, subd. (c)(2))-
• Remove governmental constraints (Gov. Code, § 65583, subd. (c)(3)); and
o Affirmatively further fair housing (AFFH) (Gov. Code, § 65583, subd. (a)(10)).
Affirmatively Furthering Fair Housing
Assembly Bill (AB) 686 (Chapter 958, Statutes of 2018) amended Government Code
section 8899.50 to strengthen California's commitment to fair housing and access to
opportunity by mandating that all public agencies must AFFH through their housing and
community development programs. Government Code section 8899.50, subdivision
(a)(1), defines "AFFH" as taking meaningful actions, in addition to combating
discrimination, that overcome patterns of segregation and foster inclusive communities
free from barriers that restrict access to opportunity based on protected characteristics.
The duty to AFFH extends to all of a public agency's activities and programs relating to
housing and community development. Public agencies are required to take meaningful
actions to AFFH. The development of senior housing is an important strategy for
creating an inclusive community and AFFH.
City of Anaheim 5t" Cycle (2014-2021) Housing Element
The City's housing element states that 18.3% of Anaheim residents are seniors
(persons older than 65) and that 34.8% of these seniors have a disability. The housing
element includes the following Policy Considerations and Guiding Principle that support
the development of housing for seniors and persons with disabilities, particularly when
such projects represent an opportunity for infill and redevelopment: (emphasis added)
o Policy Consideration 7.0: Housing Availability and Affordability: The
demand for housing in Anaheim remains high due to employment opportunities,
its strategic location and local amenities. Housing costs in Anaheim and the
surrounding region continue to remain higher than what is affordable for many
households, especially the lower-income segments of the population.
Harry S. Sidhu, Mayor
Page 3
Additionally, the need for housing suitable for special needs groups is not
always fulfilled by the housing options currently available. Providing
policies and programs to increase available housing for all segments of the
population will help ensure that current residents and those who work in
Anaheim have the opportunity to remain in the City.
o Policy Consideration 8.0: Infill and Redevelopment: There are very few
areas of undeveloped land remaining in the City and it must rely on infill
and redevelopment sites, some of which are environmentally challenged, to
accommodate growth. Policies should allow and encourage creative solutions
such as land assemblage and environmental cleanup of "brownfield" sites to
maximize the potential in redeveloping areas of Anaheim.
o Guiding Principle C: Persons with special housing needs should have access to
a variety of housing choices that are integrated within the community.
In summary, the Project proposes housing for seniors and persons with disabilities —
both of which are protected classes — and the approval of this Project would increase
housing supply for these special needs. Approval of the Project would also be
consistent with the City's obligation to AFFH, and approval would be consistent with
stated policy considerations and a guiding principle in the City's housing element. HCD
urges the City to deny the appeal and uphold the Planning Commission's decision to
approve the Project. If you have any questions or need technical assistance, contact
Brian Heaton, of our staff, at brian.heatonp_hcd.ca.gov.
Sincerely,
147 llclk
Shannan West
Land Use and Planning Unit Chief
Enclosure
CC' Stephen Faessel, Mayor Pro Tempore District 5
Jose Diaz, Councilmember District 1
Jordan Brandman, Councilmember District 2
Jose F. Moreno, Councilmember District 3
Avelino Valencia, Councilmember District 4
Trevor O'Neil, Councilmember District 6