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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 26 of 28 <br />integrated within the fabric of existing Santa Ana urban life—not on the outskirts 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 Tustin’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 the 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 City’s major <br />activity areas. The Applicant cannot depend on contingent plans in other cities to <br />support its proposed change. <br />The 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 DEIR’s 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 are designed to facilitate certain types of development within <br />suitable DCs.5 <br />C. The Proposed Land Use Amendments Conflict with Orange County’s <br />Land Use Plan for John Wayne Airport <br />California requires every county with an airport that includes use by a scheduled airline, <br />or where the airport is operated for the benefit of the general public, to establish an <br />airport land use commission (ALUC). The purpose of the ALUC is to provide for <br />orderly development and expansion of airports and adoption of "land use measures <br />that minimize 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. §21670(a).) ALUCs cannot exempt a city or county's <br />specific plan (i.e., the portion of the locality's general plan affecting land in the vicinity <br />of an airport) from compliance with the ALUC's more stringent compatibility <br /> <br />5 City of Santa Ana, General Plan – Housing Element, p. 57. Available at https://www.santa- <br />ana.org/sites/default/files/Housing%20Element.pdf.