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,--Kennedy • M M I S S 1 • r.kennedycwm ssion,org November 4, 2025 17701 Oman Ave„Sadie 200 Lyine,CA 92614 Mayor Valerie Amezcua 949 250 0909 Santa Ana City Council Santa Ana City Hall 20 Civic Center Plaza Santa Ana, CA 92701 RE: Consent Calendar Item 21 —Adopt an Amendment to the Affordable Housing Funds Policies and Procedures Department(s): Community Development Agency Honorable Mayor Amezcua and Members of the City Council, The Kennedy Commission (the Commission)is a broad-based coalition of residents and community organizations advocating for the production of homes affordable for families earning less than $30,000 annually in Orange County. Since 2001, we have successfully partnered with jurisdictions across the county to create housing and land-use policies that increase affordable housing opportunities for lower-income working families. We are writing to oppose the changes to the Affordable Housing Funds Policies and Procedures. The considered changes to the policy language will further limit the scope of potential available sites and add uncertainty to acquiring property for the production of affordable housing within the City of Santa Ana. While it is ideal for affordable housing developers to acquire sites that are already appropriately zoned, many times that may not be the case for a variety of reasons. For one, affordable housing developers traditionally face greater challenges when competing with market rate developers in acquiring sites for development. Market rate developers are profit driven and are therefore best positioned to afford to pay more for zoned sites that are higher land-value residential sites. As a result, affordable housing developers must frequently pursue properties that may not yet have the appropriate zoning, but are otherwise well-suited for affordable housing—often at lower land values that make projects financially feasible. These purchase agreements between affordable housing developers on opportunity sites are also conditioned on closing the purchase only if the zoning is approved. Additionally, it is acknowledged that the city has put forth tremendous efforts to update its General Plan, Zoning Code and Specific Plans, despite these efforts that reality is that Santa Ana is a built out city and does not have vacant sites purely zoned for multifamily residential development. Most housing opportunity sites under identified under its updated general plan and specific plans create residential development opportunities over sites that currently have a different use, for example commercial or industrial uses. Since Santa Ana is a built out city, it is very likely that other potential sites that could be appropriate for affordable housing may be currently not zoned for residential. The proposed language changes to the Affordable Housing Guidelines will exclude creative land reuse strategies and innovative partnerships that will help address affordable housing needs not addressed by the traditional market rate developments. 1