Memo - #27 - Response to Comments

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Item 27 Comments RE. Hotel -Related Zoning Amendment January 16, 2024 Page 5 of 5 S. THE CITY SHOULD CONSIDER A HOTEL -SPECIFIC CUP, JUST LIKE THE CITY OF Los ANGELES 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.15 This measure was passed by the Los Angeles City Council by a 14-0 vote and includes important provisions to help ensure hotels do not improperly displace housing and other conditions that help ensure sustainable and responsible hotel development (e.g., a sufficient market demand, reduce impacts to workers and housing needs, encourage hiring of local workers and reduced VMTs, supporting local business, etc,). However, the proposed ZOA does the very opposite by making full -service hotels (which are ubiquitous in today's market) permitted by right in many areas of the City in which such development currently would not be allowed without a zone change, CUP, or other types of discretionary approval from the City and subject to environmental review. Respectfully, this is simply the wrong direction for Santa Ana. In conclusion Local 11 r=ectfully requests the Qy Council strike and remove the hotel - related provisions of the ZOAs—specifically Sections 7 throuah 20 and ExhihitsA and B of the uugdated ZOA included in the Executive Director's Memorandum dated lanuary 11, 2024, Local 11 reserves the right to supplement these comments at future ZOA hearings and proceedings. (See Galante Vineyards v. Monterey Peninsula Water Management Dist (1997) 60 Cal.App.4th 1109, 1120 [CEQA litigation not limited only to claims made during El comment period].) This office requests, to the extent not already on the notice list, all notices of CEQA actions and any approvals, Project CEQA determinations, or public hearings to be held on the Project under state or local law requiring local agencies to mail such notices to any person who has filed a written request for them. (See Pub. Res. Code §§, 21092.2, 21167(f) and Gov. Code § 65092.) Please send notice by electronic and regular mail to Jordan R. Sisson, Esq., 801 S. Grand Avenue, 11th Floor, LA, CA 90017 (Jordan@gideonlaw. net). Thank you for your consideration of these comments. We ask that this letter be placed in the ProjecCs administrative record. Sincerely, LAW OFFICE OF GIDEON KRACOV Jo ' an R. n rney fo UNI ERE Local 11 15 See Council File No. 21-0934 (showing Hollywood hotel CUP amendments made and adopted by Council on 5/3/23), https://cityclerk.lacity.org/lacityclerkconnect/index.cfn?fa=ccfl.viewrecord&cthumber=21-0934, see also Amending Motion 53B (showing CUP language), https://clkrep.lacity.org/onlinedocs/2021/21- 0934_mist_amd%2053B_kre_sm_5-3-23.pdf; Council File No. 22-0617 (same for Downtown hotel CUP), https://cityclerk.lacity.org/lacityclerkconnect/index.cfm?fa=ccfr.viewrecord&cfnumber=22-0617; see also Amending Motion 54 D (same as above), https://cikrep.lacity.org/onlinedocs/2022/22- 0617_misc_amd%2 054D_kre_price_S-3-23.pdf/.