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HomeMy WebLinkAboutPUBLIC INPUT - KENNEDY COMMISSION am rr September 14, 2021 www.kennedycoininission.org 17701 Cowan Ave.,Suite 200 Irvine,CA 92614 949 250 0909 Chair Amy Mason and Commissioners City of Tustin Planning Commission 300 Centennial Way Tustin, CA 92780 RE: Item 42 City of Tustin—General Plan Amendment GPA 2021-002 (Housing Element Update)—Negative Declaration Chair Mason and Commissioners, The Kennedy Commission (the Commission), a broad-based coalition of residents and community organizations, advocates for the production of homes affordable for families earning less than $27,000 annually in Orange County. Formed in 2001, the Commission has successfully partnered and worked 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 and increasing investment in our communities. The Kennedy Commission has provided formal comments to the proposed Tustin's General Plan Housing Element Update ("the Update") and its accompanying Environmental Negative Declaration ("the ND") and they are part of the record. A more detailed letter will be will be submitted with more detailed analysis to include recent changes to second amended draft. These are preliminary comments. The Update will guide development of Tustin for many years, and the Housing Element and California Environmental Quality Act("CEQA"), Public Resources Code § 21000 et seq., requires that the city thoroughly assess the Update and its environmental impacts. In developing its Housing Element Sites Inventory the city must demonstrate in its Housing Element the ability to meet the assigned housing needs, through the provision of sites suitable for residential development. To meet the assigned housing needs, the Housing Element identifies sites (Table 2)that may be suitable for residential development in the following areas: - Ten (10) Downtown Commercial Core Specific Plan (DCCSP) mixed-use sites; - Four (4)Red Hill Avenue Specific Plan (RHASP) mixed-use sites; - Four (4) Tustin Legacy Specific Plan (TLSP) mixed-use urban residential sites; -The Market Place; and -The Ederle Center In order to accommodate the additional units to meet RHNA, the City proposes zoning amendments and the creation of overlay zones for The Market Place and Ederle Center will need to be accomplished within the first three (3) years following adoption of the Housing Element, as required by State law. 1 However, the Update continues to be deficient in the analysis of the sites allocated to lower income, especially in regard to the non-vacant sites at Market Place and Elder Center sites. The proposal continues to be ambiguous, and it does not fully explain how these thriving community retail anchors will be incentivized to transition to housing and ensure that affordable housing opportunities will be created to meet lower income targets. In addition, the city does not explain sites viability or how the inconsistencies caused by proposed overlays or zoning changes will be analyzed or mitigated. The proposed update is creating inconsistencies and uncertainties with contrary requirements in Land Use, Zoning Code, Housing Element and affordable housing policies. The General Plan serves as a"constitution" for the regulation of future development in the City. The City's land use regulations must be consistent with the General Plan. We request that the City provide specific site by site identification, analysis, studies and data to support that these sites are feasible to meet the housing needs of lower income families. The identified lower income sites need to incorporate affordable housing policies that will help create affordable housing and not just incentivize only market rate housing. We urge the City to (1)provide for more feasibility analysis and information on sites identified for meeting the lower income affordable housing RHNA. (2)Ensure that identified lower income also include an affordable housing policy that results in the creation of affordable housing on these sites. (3)Analyze the potential planning and environmental impacts and environmental justice on new areas proposed for housing development, especially those identified for lower income RHNA. We respectfully request that the City revise the Update to address these issues. eo""a" Cesar Covarrubias Executive Director cesarc@kennedycommission.org 2