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ATTACHMENT 3 <br />Identification of Alternative Sites <br />State law permits local governments to adopt a local AB 2011 implementing ordinance to exempt parcels <br />of land from the streamlining provisions provided certain findings are made. A local government must <br />identify one or more alternative sites for residential development and make findings that the alternative <br />development would result in no net loss of the total potential residential density permitted in the <br />jurisdiction, no net loss of the potential residential density of housing affordable to lower income <br />households in the jurisdiction, and will affirmatively further fair housing. Further, Government Code <br />sections 65912.114(i)(2)(A) and 65912.124(i)(2)(A) require that a local implementing ordinance that <br />identifies an alternative site to accommodate the lost potential units from exempt sites that is not <br />otherwise eligible for development pursuant to AB 2011, be "suitable for residential development" as <br />defined in Government Code Sec. 65583.2 of State Housing Element law. The analysis below will <br />demonstrate how all parcels identified as alternative sites by the City of Santa Ana's implementing <br />ordinance which are not otherwise eligible for development pursuant to AB 2011 meet the Housing <br />Element law definition for land suitable for residential development as defined in Gov. Code Sec. 65583.2. <br />AB 2011 Potential Housing Units Lost from Exempted Sites <br />Santa Ana's local implementing ordinance exempts 569 parcels from AB 2011—Affordable and 281 parcels <br />from AB 2011— Mixed -Income permit streamlining, respectively. Table 1 below provides the total number <br />of lost potential units for AB 2011 — Affordable and AB 2011— Mixed -Income streamlining provisions. <br />The City of Santa Ana's local implementing ordinance utilizes a multifaceted approach in achieving no net <br />loss of total potential density in the jurisdiction by upzoning (i.e., increasing the permitted General Plan <br />permitted density/intensity) certain parcels that are otherwise eligible for AB 2011 streamlining (Upzoned <br />Sites) and identifying alternative parcels that are not eligible for AB 2011 and designating them as eligible <br />for AB 2011 streamlining and also upzoning them (Alternative Sites). A combination of the upzoned <br />capacity on Upzoned Sites and the capacity permitted on the Alternative Sites demonstrate that no net <br />loss of the total potential residential density is achieved. Table 1 (Affordable) and Table 1.5 (Mixed - <br />Income) provide the total unit capacity of Upzoned and Alternative sites, respectively, and also provide <br />the total surplus capacity created between the two categories. In both cases, Affordable and Mixed - <br />Income, the total Surplus Capacity is greater than the Lost Potential capacity from the exempt parcels — <br />demonstrating that no net loss will be achieved. While detailed no net loss calculations and methodology <br />are provided separately on tables provided to HCD staff, this analysis will focus on demonstrating that the <br />Alternative Sites are suitable for residential development and complywith Gov. Code Sec. 65583.2 of State <br />Housing Element law. <br />Table 1(Affordable) <br />Fvcmnt AltarnntivP_ and Un7nnPd Site Unit Canacities <br />Total <br />Total <br />Total Lost <br />Number <br />Total <br />Surplus <br />Surplus <br />Potential/Exempted <br />Total <br />of <br />Acreage <br />Alternative <br />Upzoned <br />Capacity <br />Surplus <br />Parcels <br />Capacity <br />Capacity <br />p y <br />(Less Existing Capacity to <br />Capacity <br />Remain) <br />Exempt <br />569 <br />380.75 <br />10,932 <br />Parcels <br />1 <br />Ordinance No. NS-3075 <br />