HomeMy WebLinkAboutTHE KENNEDY COMMISSION - ITEM 5 ,L-u Ke n n e d Y
• M M I S S 1 •
March 16, 2021
www.kennedycommission.org
17701 Cowan Ave.,Suite 200
Irvine,CA 92614
Mayor Letitia Clark and City Council Members 9492500909
City of Tustin
300 Centennial Way
Tustin, CA 92780
RE: 2020 General Plan Annual Report and Annual Mitigation Monitoring Status Report for
FEIS/EIR for Tustin Legacy (formerly MCAS-Tustin) Specific Plan
Dear Mayor Letitia Clark and City Council Members:
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 $27,000 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 has led to the new construction of homes affordable to lower
income working families.
As the City Council reviews the City's 2020 Annual Housing Element Progress Report for the
2014-2021 planning period, the Commission urges the City to take into account the severe
imbalance between housing production at the lower income levels and above moderate income
levels. The City must evaluate its current policies and programs to ensure they facilitate the
development of homes affordable to lower income households in the City which they have
failed to do thus far. For the 2014-2021 Housing Element planning period, the City has a
Regional Housing Needs Assessment(RHNA) 283 very low- and 195 low-income households.
To-date,the City has built 94, or 33%, of the 283 very low-income units and 74, or 38%, of the
195 low-income units.' However, for the above moderate-income units, the City outperformed
and exceeded the RHNA by constructing 1,240, or 236%, of the 525 above moderate-income
RHNA? While 56 above moderate units were added in 2020, no units were added at the very
low and low income levels. With a remaining RHNA need of 310 lower income homes,it is
important the City prioritize policies and programs that will produce homes at the lower
income levels,for example,by creating a mixed-income housing ordinance.
The City has an urgent need to address housing production at the lower income levels given that
the City received higher RHNA allocations for the upcoming 2021-2029 Housing Element
planning period. SCAG anticipates the City's total RHNA allocation for the very low and low
income level for the upcoming cycle to be 1,724 and 1,046,respectively.3 That is a total of 2,770
lower income homes. In light of the City's inability to meet its lower income housing needs for
the current planning period, the City must focus on developing policies and programs that will
effectively produce affordable homes in the 2021-2029 Housing Element Planning Period. We
also understand the importance of Housing Elements in addressing racial equity in housing,
1 City of Tustin's 2020 Annual Housing Element Progress Report,March,16,2021.
2 City of Tustin's 2020 Annual Housing Element Progress Report,March,16,2021.
'"SCAG 6th Cycle Final RHNA Allocation Plan,"March 4,2021.https:Hscag.ca.gov/sites/main/files/file-attachments/6th-cycle-rhna-proposed-
final-allocation-plan.pdD1614911196
orking for systemicg' resulting in the productionof homesI o OrangeCounty's households
Mayor Letitia Clark and City Council Members
March 16, 2021
particularly with the new statutory requirements mandating the inclusion of programs that
affirmatively further fair housing in the new Housing Element planning period.4
Affordable homes are urgently needed for lower income residents given the increasing cost of
housing in Orange County. The County is consistently ranked among the top ten least affordable
metropolitan areas in the country.5 A resident must earn at least$42.62 per hour to afford a two-
bedroom apartment at a fair market rent.6 Based on this figure, the approximate annual income a
resident must have to afford housing in Orange County is $81,830.40. This income is completely
unrealistic for lower income families. According to the California Housing and Community
Development Department(HCD), the County's annual median income (AMI) for a family of
four at the extremely low income level is $38,450 and $64,050 at the very low income level.?
The City needs to prioritize the production of housing for lower income families for whom
market-rate, or above moderate income, rental prices are not affordable. The Commission
would like to work with the City to make this a reality.
The Commission looks forward to partnering with the City to increase affordable home
opportunities for lower income households in the City. Please keep us informed of any updates
and meetings regarding strategies to increase affordable homes for lower income households in
the City. If you have any questions,please free to contact me at(949) 250-0909 or
cesarc@kennedycommission.org.
Sincerely,
Cesar Covarrubias
Executive Director
4 California Government Code§8899.50(Assembly Bill 686).
5 Out of Reach 2020-The High Cost of Housing,National Low Income Housing Coalition,p.17,2021.
6 Out of Reach 2020-The High Cost of Housing,National Low Income Housing Coalition,p.17,2021.
'California Department of Housing and Community Development"State Income Limits for 2020,"p.8,April 30,2020.
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