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GK LA LAND USE, EwiRoNMENTAL & MvNiciPAL LAwYERs January 16, 2024 VIA EMAIL: Mayor Valerie Amezcua City Council City of Santa Ana eComment@santa-ana.org Jordan R. Sisson Los Angeles, California 90017 Office: ( E-mail: www.gideonlaw.net RE: ITEM 27, CITY COUNCIL MEETING JANUARY 16, 2024; ORDINANCE AMENDMENT No. 2023-04 (HOTEL -RELATED ZONING AMENDMENTS) Dear Honorable Mayor Amezcua and City Councilmembers: On behalf of UNITE HERE Local 11 ("Local 11"), this office respectfully provides the following comments' to the City of Santa Ana ("City") regarding the above -referenced item involving Zoning Ordinance Amendment No. 2023-04 ("ZOA") that would amend the Santa Ana Municipal Code ("SAMC" or "Code"), which would (among other things) change the zoning rules to allow certain hotels by right - without any discretionary approval from the City and without any environmental review - in various parts of the City. For purposes of the California Environmental Quality Act ("CEQA"), the staff report dated January 16, 2024 ("Staff Report")z claims that adoption of the ZOA will not foreseeably result in a physical change to the environment and is not considered a "project" pursuantto CEQA Guidelines § 15378. Local 11 has a significant interest in this matter, with over 30,000 workers employed in hotels, restaurants, airports, sports arenas, and convention centers throughout Southern California and Phoenix —including hundreds of members who live and/or work in the City. In short, Local 11 is concerned about the ZOA's hotel -related provisions. As explained below, the ZOA is a project subject to CEQA that requires some level of environmental review. Additionally, Local 11 questions why - during a housing crisis - the City is making it easier to build hotels than it would be to build multi -family housing in many parts of the City. This runs counter to numerous goals and policies under the City's Housing Element, which is not considered in the Staff Report. So too, the proposed standards on hotels are weak and do not address many potential impacts that hotel projects can cause (e.g., displacing housing, low-income residents, increasing auto travel and associated environmental impacts, etc.). These and other issues can be addressed through carefully crafted measures as part of a discretionary approval process, which the ZOA would eliminate in many circumstances. Furthermore, while the Staff Report urges less hotel development oversight by the elected City Council, other cities see the need for more oversight to mitigate potential negative impacts, such as the City of Los Angeles, which recently passed a new CUP requirement (appealable to its City Council) for all hotels proposed in Hollywood and Downtown Los Angeles. 1 Herein, page citations are either the stated pagination (i.e., "p. #") or PDF-page location (i.e., "PDF p. #") 2 Inclusive of all associated Exhibits ("Exh-##") retrieved from City website. (See https://santa- ana.primegov.com/portal/item?id=52126.)