* Contrary to the claims made by Santa Ana Councilman Robert L. Richardson in response to a Times editorial (Letters, "Crowded Dwellings Are Dangerous, Damaging," April 10), state occupancy standards have been established on the basis of "habitable rooms" in the Uniform Housing Code since 1958 and in state housing law since 1911. In fact, California's standards are the same as those adopted in virtually every state in the nation and are based on health and safety consideration, not court interpretation.
These minimum standards have been found across the country to protect the health and safety of residents. They require that at least one room be not less than 120 square feet and that all other habitable rooms, excluding the kitchen, be at least 70 feet square in size. In addition, any room to be occupied by more than two persons must have at least an additional 50 square feet for each additional person.
In addition, it must be pointed out that Mr. Richardson's claims that the standards allow 10 people to live in a 600-square-foot apartment are misleading at best. This scenario would take place only in a very unusually designed unit that would feature a larger than normal bedroom and a combined living room-dining room that again would be larger than normal.
Still, despite the fact that the state's standards have been accepted nationwide, the California Department of Housing and Community Development has repeatedly advised Councilman Richardson and the city of Santa Ana that it stands ready to reconsider these requirements should they have evidence that establishes that these minimums are inadequate. Mr. Richardson and the city have failed to submit this evidence.
Santa Ana's proposed occupancy ordinance would have the direct effect of displacing hundreds of families, compounding not just Santa Ana's, but all of Orange County's affordable housing problems. Moreover, Mr. Richardson's plan would criminalize a safe level of resident density and would produce a costly new bureaucratic regime to police occupancy that is at best counter-intuitive to the goals of most fiscally prudent local elected officials.
California's communities do face extraordinary pressures due to overcrowded housing, but the answer is to create more, not less, affordable housing. If Councilman Richardson truly believes current permissible residency density standards are life-threatening, he should make his case to the state, not in letters to the editor.
TIMOTHY L. COYLE
Timothy Coyle is director of the state Department of Housing and Community Development.