YIMBY Law joins the comments sent under separate cover by Mr. Allan Abshez regarding the City's housing element. We do not believe the housing element adequately plans to meet the City's need allocation, and would request the City delay adoption until it releases the public records that Mr. Abshez has requested.
A letter has been separately emailed to Anna Pehoushek.
The Sisters of St. Joseph of Orange Healthcare Foundation provides funding to support organizations seeking to increase housing security, food security and reduce family violence. In 2024 we will be focusing our funding on reducing and preventing family homelessness.
We encourage the City to actively implement these policies quickly to address the affordable housing crisis in Orange.
1) Housing Policy Action 2E:
The City will encourage infill development within feasible development sites for homeownership and rental units.
2) Housing Policy Action 2L:
The city must adopt objective development standards pursuant to State Housing law, candidate sites identified in this Housing Element to accommodate a portion of the City's low- and very low- income RHNA that were identified in previously adopted Housing Elements. They must be rezoned to allow residential use by right at specified densities for housing developments in which at least 20 percent of the units are affordable to lower income households.
3) Housing Policy Action 2N:
The City will establish a ministerial process to allow for the subdivision of existing large parcels, such as shopping centers or older apartment communities that have the potential to accommodate more intensive development, recognizing that these projects may need to be phased over 5-10 year periods and that the resultant land parcels may be irregular in shape (i.e., allowing for multifamily development on a former big box store site while the rest of the center remains in use)
4) Housing Policy Action 20:
Should affordably housing unit production not meet the pace of development projected through the Housing Element by 2026 the City will study the development of an inclusionary housing ordinance and consider adoption during the planning period. This will be particularly important in the UMU zones and Retail and Mall Reuse opportunities, where higher density is being proposed, but no affordable housing policy is facilitating or requiring lower income units.
5) Housing Policy Action 3D:
The City will extend outreach efforts throughout the planning period.
6) Housing Policy Action 3F:
Existing shopping center and office complex properties represent much of the future residential redevelopment potential in Orange. If fthese properties are not entitled and able to receive building permits for residential uses by mid-2027, the City will identify additional alternative sites within Orange that can accommodate a potential shortfall in housing sites to accommodate the remaining RHNA within 180 days of determination of a shortfall of adequate sites as required by SB 166
New State Laws to Incentivize Affordable Housing (2023)
In 2023 the CA Legislature passed, and the Governor signed over 60 new laws that aim to streamline housing development, facilitate affordable housing and promote housing stability. These new laws present an opportunity for the City of Orange to work with advocates such as us to create more affordable housing. We particular encourage the city to actively work with faith-based groups to leverage SB4.
City Owned Land
In addition, we recommend that the city facilitate discussions around utilizing city and special district-owned surplus land to create affordable housing. Having public land available for affordable housing is imperative to creating affordable housing for working families that are struggling to find housing options in the City of Orange.
The Kennedy Commission is submitting comments to Item 3.1. A detailed letter has been sent to Anna Pehoushek and the City Clerk's office.
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 $30,000 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 have led to the new construction of homes affordable to lower-income working families.
Thank you for the opportunity to review and comment on Agenda Item 3.1 regarding the adoption of City of Orange’s Housing Element. The Commission has submitted prior comments and recommendations to the city to incorporate in the development of the draft Housing Element.
These comments were considered as part of the California Housing and Community Development Department’s (HCD) review of the city’s draft Housing Element (July 2023). HCD has found that the revised draft Housing Element meets the minimum statutory requirements. HCD’s September 29th letter identifies the following key findings and commitments to achieve compliance and to incentivize affordable housing development.
YIMBY Law joins the comments sent under separate cover by Mr. Allan Abshez regarding the City's housing element. We do not believe the housing element adequately plans to meet the City's need allocation, and would request the City delay adoption until it releases the public records that Mr. Abshez has requested.
A letter has been separately emailed to Anna Pehoushek.
Keith Diggs
YIMBY Law
keith@yimbylaw.org
The Sisters of St. Joseph of Orange Healthcare Foundation provides funding to support organizations seeking to increase housing security, food security and reduce family violence. In 2024 we will be focusing our funding on reducing and preventing family homelessness.
We encourage the City to actively implement these policies quickly to address the affordable housing crisis in Orange.
1) Housing Policy Action 2E:
The City will encourage infill development within feasible development sites for homeownership and rental units.
2) Housing Policy Action 2L:
The city must adopt objective development standards pursuant to State Housing law, candidate sites identified in this Housing Element to accommodate a portion of the City's low- and very low- income RHNA that were identified in previously adopted Housing Elements. They must be rezoned to allow residential use by right at specified densities for housing developments in which at least 20 percent of the units are affordable to lower income households.
3) Housing Policy Action 2N:
The City will establish a ministerial process to allow for the subdivision of existing large parcels, such as shopping centers or older apartment communities that have the potential to accommodate more intensive development, recognizing that these projects may need to be phased over 5-10 year periods and that the resultant land parcels may be irregular in shape (i.e., allowing for multifamily development on a former big box store site while the rest of the center remains in use)
4) Housing Policy Action 20:
Should affordably housing unit production not meet the pace of development projected through the Housing Element by 2026 the City will study the development of an inclusionary housing ordinance and consider adoption during the planning period. This will be particularly important in the UMU zones and Retail and Mall Reuse opportunities, where higher density is being proposed, but no affordable housing policy is facilitating or requiring lower income units.
5) Housing Policy Action 3D:
The City will extend outreach efforts throughout the planning period.
6) Housing Policy Action 3F:
Existing shopping center and office complex properties represent much of the future residential redevelopment potential in Orange. If fthese properties are not entitled and able to receive building permits for residential uses by mid-2027, the City will identify additional alternative sites within Orange that can accommodate a potential shortfall in housing sites to accommodate the remaining RHNA within 180 days of determination of a shortfall of adequate sites as required by SB 166
New State Laws to Incentivize Affordable Housing (2023)
In 2023 the CA Legislature passed, and the Governor signed over 60 new laws that aim to streamline housing development, facilitate affordable housing and promote housing stability. These new laws present an opportunity for the City of Orange to work with advocates such as us to create more affordable housing. We particular encourage the city to actively work with faith-based groups to leverage SB4.
City Owned Land
In addition, we recommend that the city facilitate discussions around utilizing city and special district-owned surplus land to create affordable housing. Having public land available for affordable housing is imperative to creating affordable housing for working families that are struggling to find housing options in the City of Orange.
The Kennedy Commission is submitting comments to Item 3.1. A detailed letter has been sent to Anna Pehoushek and the City Clerk's office.
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 $30,000 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 have led to the new construction of homes affordable to lower-income working families.
Thank you for the opportunity to review and comment on Agenda Item 3.1 regarding the adoption of City of Orange’s Housing Element. The Commission has submitted prior comments and recommendations to the city to incorporate in the development of the draft Housing Element.
These comments were considered as part of the California Housing and Community Development Department’s (HCD) review of the city’s draft Housing Element (July 2023). HCD has found that the revised draft Housing Element meets the minimum statutory requirements. HCD’s September 29th letter identifies the following key findings and commitments to achieve compliance and to incentivize affordable housing development.