3 - The Bowery_PUBLIC COMMENT_RAMSEY

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City of Santa Ana – The Bowery May 11, 2020 Page 25 of 28 consistent with other general plan policies. (See Endangered Habitats League v. County of Orange (2005) 131 Cal. App. 4th 777, 782-83; Families Unafraid to Uphold Rural El Dorado County v. Bd. of Supervisors (1998) 62 Cal. App. 4th 1332, 1341-42 [“FUTURE”].) Moreover, even in the absence of such a direct conflict, an ordinance or development project may not be approved if it interferes with or frustrates the general plan’s policies and objectives. (See Napa Citizens, 91 Cal. App. 4th at 378-79; see also Lesher, 52 Cal. App. 3d at 544 [zoning ordinance restricting development conflicted with growth- oriented policies of general plan].) A. Changing the Project Site’s General Plan Designation to a District Center conflict with the City’s General Plan Here, the Project proposes a General Plan Land Use Amendment that would change the land use designation from PAO for professional or administrative offices to District Center (DC) to allow for a mixed-use residential development. The Project’s mixed-use, primarily residential, development plans for the construction of a multi-building project with approximately 80 residential units on each acre of the site. The maximum allowable units for a DC zone is 90 units per acre. A DC land use designation, according to the City of Santa Ana’s General Plan – Land Use Element, is: (1) reserved for “major activity areas in the City”; (2) designed to “serve as anchors to the City’s commercial corridors…”; and (3) “are to be developed with an urban character that includes a mixture of highrise office, commercial, and residential uses which provide shopping, business, cultural education, recreation, entertainment, and housing opportunities.”3 The proposed change is inconsistent with the General Plan’s guidance on designation of DCs because the Project site area (and the entire surrounding area within the City), off Red Hill Avenue and east of SR-55, is exclusively designated for light industrial and commercial use and is not connected to any of the City’s existing commercial corridors, and is not a major activity area in the City relating to urban life in any respect.4 (DEIR at 3-5, Figure 3-2.) The Project site area is surrounded by open spaces and office parks, and would not be consistent with the character of any existing DC in the City of Santa Ana. DCs are reserved for mixed-use developments that seek to be 3 City of Santa Ana, General Plan – Land Use Element, p. 60. Available at https://www.santa-ana.org/sites/default/files/pb/general-plan/LandUse.pdf. 4 Id. at A-25, Exhibit A-5. This exhibit of the City’s General Plan maps the existing District Centers of Santa Ana.