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(d) Approval of the project would not result in any significant effects relating to traffic, <br />noise, air quality, or water quality. <br />(e) The site can be adequately served by all required utilities and public services. <br />(14 Cal. Code Regs. § 15332). <br />In support of its determination, the Planning Commission found that the Russell Fischer Car <br />Wash Project is consistent with the General Plan and zoning designation (condition (a)), and that it will <br />not result in any significant impacts related to traffic, noise, air quality or water quality according to the <br />traffic impact analysis and with implementation of water quality requirements (condition (d)). (See <br />August 30, 2019 Notice of Public Hearing Before the Planning Commission). <br />Contrary to these findings, there is ample evidence showing that the Russell Fischer Car Wash <br />Project contradicts the General Plan Land Use Goals and Policies, and that the Car Wash Project will <br />have significant impacts on traffic and noise. Accordingly, there is not substantial evidence to support <br />the Commission's determination that the Car Wash Project is categorically exempt from CEQA review <br />under Section 15332. Consequently, CEQA environmental review must be completed before the Car <br />Wash Project may be approved. <br />1. The Car Wash Project Contradicts the Land Use Goals and Policies Stated in <br />the General Plan. <br />As discussed at length above, at minimum the Russell Fischer Car Wash Project does not meet <br />the General Plan Goals and Polices, Land Use Element Goal 1, to promote a balance of land uses, <br />because there are already 35 car wash facilities operating and available in Santa Ana. Rather than <br />creating a balance of land uses, the Russell Fischer car wash will oversaturate this specific type of <br />business within the City, causing significant economic loss to other car wash businesses, including <br />Speedie Wash. <br />Also discussed above, the Project is also contrary to Land Use Element Goal 2, to promote land <br />uses that enhance the City's economic and fiscal viability. As discussed above, the Russell Fischer Car <br />Wash Project contradicts this Land Use Goal because car washes provide little economic benefit since <br />they generate minimal sales tax revenues. Allowing the continued establishment of car washes, <br />including the Russell Fischer Car Wash Project, will result in the immediate loss of potential revenues to <br />the City and the immediate loss of desirable commercial sites throughout the City. The Russell Fischer <br />Car Wash Project will also directly reduce the viability of existing car washes in its vicinity, including <br />but not limited to Speedie Wash. <br />Specific to this Goal is Policy 2.2 — "Support commercial land uses in adequate amounts to <br />accommodate the City's needs for goods and services." With 22 existing car wash facilities in Santa <br />Ana, there is absolutely no need for the Russell Fischer Car Wash Project. The Project is also contrary <br />to Policy 2.5 — "Balance the economic and fiscal benefits of commercial development with its impact on. <br />12 <br />75A-22 <br />