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The Housing Elements for the cities and County of Orange do not reflect that the number of affordable senior housing units in Orange County will not accommodate the projected population. Response: The City disagrees partially with the finding. The City cannot speak for the countywide supply of affordable senior housing units. However, for the City of Tustin, the City's Housing Element provided analysis of senior housing needs in Tustin as follows: Table HTM-2 of the Housing Element Technical Memorandum identifies 7.1 percent of the population in 2000 were persons aged 65 years or older. Table H-7 of the Housing Element shows the tenure of households with the head of household aged 65 years or older in the City of Tustin in 2000. The City had 747 renter households and 2,086 owner households with a head of household aged 65 years or older. Households with a senior householder represented 11.9 percent of all households in the City. TABLE H-7 Tenure of Households with Head of Household Aged 65 Years or Older 2000 Head of Household 65 Years or Older # Households Tenure % Households 747 Renters 6.2% 17.6%2 2,086 Owners Total Households 2,833 11.9%3 As a percentage of 12,002 renter households. As a percentage of 11,829 owner households. As a percentage of 23,831 total households. Source: 2000 U.S. Census; Comprehensive Affordable Housing Strategy 2008 - 2018. All the second Table H-7A shows the estimated household income distribution for householders aged 65 years or older in 2000. Approximately 27 percent of elderly households earned less than $20,000 annually or about 36 percent of AMI for a household of two persons in 2000.1 1 HUD median household income for a family of four in Orange County in 2000 was $69,600. OC Grand Jury No County for Old Boomers TABLE H-7A Estimated Household Income Distribution Households with Head of Household Aged 65 Years or Older 2000 Income Range Number1 Percent Cumulative % Less Than $10,000 300 10.4% 10.4% $10,000-$19,999 467 16.2% 26.6% $20,000-$34,999 618 21.4% 48.0% $35,000-$49,999 439 15.2% 63.2% $50,000-$74,999 520 18.0% 81.2% $75,000-$99,999 7.3% 211 88.5% 332 $100,000 or More 11.5% 100.0% Total Households 2,887 100.0% Derived by applying the percentage of households with head of household aged 65 years or older by income category from Summary File 3 Table P55 (based on sample data; total number of households shown as 23,853) to a total of 23,831 households from Summary File 1, Table H-1 for consistency with other Census data on the number of households used in this report. Source: 2000 U.S. Census; Comprehensive Affordable Housing Strategy, 2008-2018. In addition to identifying the current needs of the City's senior population, the City also adopted policies to ensure adequate housing are available to the senior population. The following are examples of policies adopted: Policy 1.14: Encourage the availability of affordable housing for special needs households, including large, low-income families. Special needs households include the elderly, large families, female-headed households, households with a disabled person, and the homeless (see discussion under Summary of Housing Needs for Special Needs Groups). Policy 1.17: Encourage the design and occupancy of housing for senior citizens and the disabled. Promote the construction or rehabilitation and adoption of dwelling units accessible to seniors and/or the disabled. The City also included in Table H-17 of the New Construction objective table in the Housing Element identifying construction goals during the Housing Element planning period. Included in the table are several projects involving seniors. For example: within the MCAS Tustin Housing Units, 240 senior housing units are being constructed, 153 units will be set-aside for affordable ownership senior housing. A total of 201 units of assisted living/congregate care facility for persons of 62 years and older are also anticipated to be completed during the planning period. Potential 10 new granny units are also expected. Lastly, a developer (TLCP) has expressed their interest in developing a senior congregate OC Grand Jury No County for Old Boomers care facility at Tustin Legacy. The City will actively confer and negotiate with the developer to support the proposed project. However, actual timing on this proposal is contingent on developer's timing and market conditions. (For information on Tustin's senior housing stock, please see response under F-4) TABLE H-17 NEW CONSTRUCTION QUANTIFIED OBJECTIVES SUMMARY CITY OF TUSTIN 2006-2014 Very Upper Low 5 (120\% + Total # Low Moderate Program of Units (<50%) <80%) (80-120%) NEW CONSTRUCTION MCAS Tustin Housing Units1 3,645 199⁴ 220⁴ 3424 2,884 MCAS Tustin Emergency Housing 2 192 192 MCAS Tustin Transitional Family 48 48 Housing MCAS Tustin Social Services 2 90 90 Granny Flats 10 10 New Owner Housing 3 155 155 New Senior Housing 201 126 75 Recycling of SFD to MFD 25 25 Total Quantified Objectives 4,366 529 410 468 2,959 RHNA 2381 410 512 468 991 Difference 1,985 17 0 0 1.968 MCAS Tustin Specific Plan authorized a total 4,049 potential units at Tustin Legacy. Based upon State Redevelopment Law and the proposed Specific Plan requirement, at least 15 percent of the total units (607) units) would be affordable to Very-Low, Low, and Moderate income households, of which at least 6 percent or 243 units would be affordable to Very Low income households. See footnote 4 for additional inclusionary units information. These housing units shown as separate line items will serve as transitional/emergency housing facilities. The City counts these units as new construction as they are new additions to the housing inventory. Projects at the end of planning period. Includes MCAS Tustin additional inclusionary units (296 units) Pursuant to Government Code Section 65583(a)(1), City's share of extremely-low income units is 211 (8.85 percent of the total RHNA new construction objective). Total number of units for extremely-low income and low income units equals to City's share of vey-low income units of 512 units Source: 2007 RHNA; City of Tustin; MCAS Tustin Specific Plan. The City also has identified in the Housing Element of the following programs to accommodate the needs of the seniors: Program 1.16 - Senior Citizen Housing: Continue to identify sites that are suitable for senior citizens housing projects. These sites will be promoted for private development and applications will be made for any available subsidy funds. Program 4.5 - Affordable Senior Housing Project and Senior Board and Care Facility: To maintain 74 units of affordable housing for seniors OC Grand Jury No County for Old Boomers located at 17432-17442 Mitchell Avenue (20 units) and 54 units affordable senior apartments at 1311 Sycamore Avenue (Heritage Place). Together, all of the above analysis, policies, goals, and objectives identified in the Housing Element prepare the City in meeting the housing needs of current and projected senior population. The Housing Elements for the County of Orange and the cities do not focus

sufficiently on or analyze the population growth and housing needs of the aging baby boomer generation. Response: The City disagrees partially with the finding. Although the City's Housing Element does not discuss specifically the needs of the aging "baby boomer generation," the City focuses the analysis on seniors in general. Nevertheless, based upon current available data, the City of Tustin Housing Element adequately addresses the needs of the aging population.

Not all Housing Elements are available online for easy access by the public. Response: The City disagrees with the finding. The City of Tustin Housing Element is available online for the public to access. In addition, the Housing Element is also available at City Hall and Tustin Library to allow access for those residents who do not have computers. Municipalities are not proactive enough in encouraging the development of

affordable senior housing. The City disagrees with the finding. Currently Tustin has a Response: proportionately greater supply of senior housing as compared to other special need groups (i.e. the disabled, female-headed households, large families, extremely low income households), summarized as follows: Apartments/Mobile Homes/Ownership Units Total Units Project Name Senior Mobile Homes* 460 100 Tustin Gardens 54 Heritage Place at Sycamore OC Grand Jury No County for Old Boomers Although these mobile home parks are not designated for seniors only, there are a large number of seniors live in mobile home park communities. Assisted Living Project Name Total Units Residential Care for the Elderly 24 facilities with 146 beds capacity Tustin Royale at Bryan Ave.2 1 facility with 100 beds (85 units) Silverado Senior Living 1 facility with 42 beds 26 facilities with 288 beds Total Congregate Care/Assisted Living Project Name Total Units Monarch Village (American Senior Living)3 201 units (Age 62+) 1 Under construction Notes: 2 Under rehabilitation 3 Entitled – construction plans are being prepared As demonstrated above, Tustin is rich with senior housing and facilities. While the City agrees that it is important to accommodate the needs for senior housing, the City also has the responsibility to balance its housing stock to accommodate other special needs groups such as large-family, female headed households, extremely-low income households, disabled, homeless, etc. The City however will analyze the needs of senior populations from time to time to ensure adequate housing for various economic segments are available. To promote senior services, the City devoted $270,000 of Community Development Block Grant (CDBG) funds for senior center kitchen improvements and approximately $25,000 annually of CDBG public services funds to provide free meals for seniors. Recommendations Include the current and projected affordable senior housing inventory by