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Ciry of Sww Ma -The 6o"q <br />May 11, 2020 <br />page 2e of zs <br />integrated within the fabric of existing Santa Ana urban life —,not an the outskirLs of <br />the City within an office park zone that is disconnected from major activity centers. <br />The fact that the proposed Project will be located adjacent to the City of'17ustin's <br />Legacy Specific Plan area does not save the proposed change in land use designation <br />either. This area is current massively underdeveloped, and as llie Applicant points out, <br />will only meet the current character of the site's existing land use designation for <br />commercial use. (DEIR at 5.9-13) And in any event, any result of the building up of <br />the Legacy Area in the future will not connect the project to any of the Ul 7s major <br />acdvity auras. the Applicant cannot depend on contingent plans in other cities to <br />support its proposed change. <br />TTae proposed change to a DC is not consistent with the language or intent of the <br />City's General Plan and should be revised. <br />B. The DEIWs proposed Zoning Change to a Specific Development <br />District Conflicts with the City's General Plan. <br />The Applicant also seeks to amend the site's zoning designation from M1-Light <br />Industrial to a Specific Development. District (SD). This zoning change would conflict <br />with the City�s General Plan because the Project site is not appropriate for a General <br />Plan amendment to a DC and thus the underlying zoning change would also be <br />inappropriate. SDs am designed to facilitate certain types of development within <br />suitable DCO <br />C. Tlrc Proposed Land Use Amendments Conflict witli Change Countv's <br />Land Use Plan far John Wayne Airport. <br />California requires every county with an airport that includes use by a scheduled airline, <br />or where the airport is operaled for die benefit of the general public, to establish an <br />airport land use commission (ALI It)_'Ihe purpose of the ALLICis to provide for <br />orderly development and expansion of airports and adoption of "land use measures <br />that minimi>.e the public's exposure to excessive noise and safety hazards within areas <br />around public airports to the extent that these areas are not already devoted to <br />incompatible uses." (Cal. P.U.C. 921670(a)) ALUCs cannot exempt a city or countv's <br />specific plan (i.e., the portion of the locality's general plan affecting land in the vicinil r <br />of an airport) from compliance with the AI.LC's more stringent compatibility <br />5 Cay of Santa Ana, General Plan - HousingElement, p. 57. Availahte at https;'- <br />ana.erc/ sire s / de Eau kt /files /Hai s i n �'/a 20 Lletn s n t �df. <br />25 <br />26 <br />75C-146 <br />