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Comments RE Caribou Industries Mixed -Use Project November 17, 2020 Page 7 of 9 E. THE OPTION TO CONVERT THE HOTEL IS INCONSISTENT WITH PARKING AND DENSITY REQUIREMENTS So too, the land use findings concerning density and parking do not come to terms with the Staff Report 10/20/20 page 7SA-5 admission that the hotel (which requires less parking) can be converted to residential or condominiums. As a result, if the hotel is converted, more parking is required, and the density bonus calculations are completely skewed to allow 70+ dwelling units more than allowed, and to permit less affordable housing than otherwise would be required. The developer will also have the option to convert the hotel to residential after three years of operation if certain revenues per available room thresholds are reached. This would indicate the hotel is not financially sustainable after those first three years to continue operations. The developer will guarantee that the anticipated revenues from the parking will cover the City's estimated annual debt service of $750,000. There will be no out-of-pocket costs to the City. Staff Report 10/20/20 page 7SA-169 makes clear that only 83 spaces of hotel parking are to be provided because a hotel has less density. Section 41-1344 of the City of Santa Ana Municipal Code (SAMC) includes an off-street parking rate of one space for each guest room, plus one spaces for each ten rooms_ As such, the parking requirements for the hotel portion of the Project are calculated as follows: 75 rooms x 1 on -site parking space - 75 parking spaces required. 75 rooms x (1/30) on -site parking space - 7.5 parking spaces required. As identified, 83 parking spaces are required pursuant to the CiWs Municipal Code requirements Although application of the parking requirements set forth in the TZC SAMC Section 41-2011 Non - Residential Uses would require 156 spaces for the hotel, given the mixed -use nature, urban location (it is expected that many patrons would use ride -sharing or public transit), the fact that hotels are not typically 100% occupied, it is appropriate to utilize the SAMC Section 41-1344 Hotel parking in lieu of the TZC parking requirements. But of course, these projections on less density go out the window if the hotel is converted to housing after three years. In that circumstance, Transit Zoning Code EIR p. 3-23 makes clear that far more parking would be required, something that the Project land use findings and CEQA analysis entirely ignores: Zane Tableg Requirement per Zone Type Residential (per dwelling urm lire/Woik fperdwe&ngurnf) Nan-ResidenfiaP Transit Village (TV) Zane 2 spaces * 0,15 in -lieu for guests 2 spaces 1 space per 400 st Downlown )DI) 2 spaces * 0.15 in -lieu for guests 2 spaces 1 space per 400 st In fact, the Project's C EQA addendum does not appear to mention even onetime the 'bait and switch" option to convert the hotel into a residential use. The fact that the Project will then be under -parked by possibly 70+ spaces, greatly exceed dwelling unit density limits, and that no affordable units will be required if the conversion to residential occurs all go unanalyzed. The expert comments of land use planner Michael Tharp confirm this (see Exhibit A attached hereto).