20 (22)
Susana Barrios
From:Alli Valdivia <sales@rocknroca.com>
Sent:Monday, June 22, 2026 4:12 PM
To:Public Comment
Subject:\[EXTERNAL\] Prohousing Designation
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I understand the city is considering submi?ng for Prohousing designa?on.
Please take the necessary ?me to review the parameters of this designa?on carefully.
California’s Prohousing Designa?on Program
(h?ps://www.hcd.ca.gov/planning-and-research/prohousing) incen?vizes local governments to streamline development.
However, cri?cs and policy experts highlight notable drawbacks: it can bypass vital local input and safety reviews, fails to
directly force physical construc?on, and awards points for loosely related criteria that don't always accelerate housing
supply.
Here is a breakdown of the main cri?cisms:
1. Weak Direct Impact on Actual Housing
The designa?on provides state funding preferences and priority processing, but it does not actually build units or force
private developers to break ground. A policy analysis from the Terner Center notes that some jurisdic?ons struggle with
market-rate labor and material costs, making the designa?on ineffec?ve at truly boos?ng housing supply without deep
subsidies.
2. Bypass of Community Input & Safety Reviews For many residents, par?cularly in hazard-prone areas like Anaheim
Hills,the biggest nega?ve is that "prohousing" policies o?en force ci?es to fast-track dense development in zones facing
severe wildfire risks or traffic bo?lenecks. Cri?cs argue these top-down state pushes disregard vital resident feedback
and community-specific safety constraints.
3. Flawed Point and Scoring Systems
The California Department of Housing and Community Development scores jurisdic?ons across various policy categories
to grant the status.
However, the Terner Center's evalua?on concluded that several qualifying criteria (such as adop?ng universal design
ordinances, reducing alterna?ve transporta?on barriers, or coun?ng ADU policies
twice) do not explicitly or directly increase a city's housing produc?on.
4. Financial Strain on Municipal Budgets Some local municipali?es and advocacy groups have pushed back because
adding large volumes of rental housing or affordable units doesn't inherently expand a city's local property tax base.
Because new residen?al units bring increased infrastructural demands (schools, roads, u?li?es) but generate less
revenue, exis?ng homeowners o?en worry they will shoulder the burden of rising municipal expenses down the road.
I respec?ully ask the City to explain why it would pursue California’s Prohousing Designa?on when significant concerns
about traffic, parking, infrastructure, and evacua?on safety remain unresolved.
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This is not a ques?on of whether Anaheim should build housing. It is a ques?on of why the City would encourage even
greater density before demonstra?ng that our roads, infrastructure, and emergency evacua?on systems can safely
support the growth already approved.
The City has already prepared studies, but independent CEQA counsel iden?fied serious deficiencies in the City’s own
analyses, including inconsistencies with Anaheim’s adopted evacua?on plans and failures to adequately account for
cumula?ve impacts.
Even more concerning, the City Council, City staff, and the Fire Chief previously concluded that addi?onal density on
these same roadways would increase evacua?on risks and threaten public safety.
East Anaheim and Anaheim Hills are located in a Very High Fire Hazard Severity Zone, where evacua?on is a ma?er of life
and death. Residents have already experienced the reali?es of wildfire and gridlock. Seeking Prohousing Designa?on and
state funding to encourage even greater density while these unresolved safety risks remain is irresponsible.
Public safety must come before development incen?ves.
Anaheim should not be seeking state incen?ves to encourage addi?onal density when it has yet to demonstrate that the
growth already approved can be safely accommodated.
Please do not submit for this designa?on, retain your power and support your cons?tuents.
Respec?ully,
Anaheim Resident
Allison Valdivia
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