Memo - #27 - Response to Comments

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Attachment 1 Response to Public Comment The City received public comment on Item 27 on January 16, 2024 City Council Agenda on the date of the scheduled meeting. Below is a list of the comments and the City's response to those comments. Comment 1: There has been no environmental review for the ZOA despite it being a project as defined by CEQA Response Environmental review for the ZOA was completed and was found be exempt pursuant to sections 15060(c)(2) of the CEQA Guidelines. CEQA Guidelines section 15060(c)(2) states that an activity is not subject to CEQA if it will not result in a direct or reasonably foreseeable indirect PHYSICAL (emphasis added) change in the environment. Permitting full service hotels by right will not have a direct or foreseeable physical change since it is only the use being permitted and development standards that shape physical changes in the environment that apply to all uses will continue to apply —resulting in no physical change in what otherwise is already permitted in the zone. Other design requirements would, similarly, have no change in the environment as they are applicable by code or City Council adopted design guidelines to all development in the zoning districts. Comment 2: During a housing crisis, the ZOA would make it easier to build hotels than it would be to build multi -family housing in many parts of the City. Response: Multi -family housing is permitted by right in all of the zoning districts where residential uses are permitted outside of R1 (single-family residence), R2 (two family residence) and RE (residential estate). That would not change as a result of adoption of this ordinance. Comment 3: The Staff Report does not consider inconsistencies with numerous goals/policies under the City's Housing Element that calls for more than 3,000 new housing units by 2029. Response: There are no inconsistencies with the Housing Element goals of providing housing at all income levels. The City can have a thriving commercial/tourist economy and permit the development of hotels while simultaneously providing opportunities for housing, as demonstrated by the City being on trackto meetits RHNA goals (over 50% complete as of 2022 APR), exempt from SB 50 (formerly SIB 35) streamlining, and already permitting hotels by right in certain zoning districts (Specific Plan No. 2 and Transit Zoning Code). Comment4: The proposed hotel standards 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.), which can be addressed through carefully crafted measures as part of a discretionary approval process. Response: Impacts associated with displacing housing and low-income residents have been addressed by the City's Rent Stabilization and Just Cause Eviction ordinances. Moreover, housing at all income levels continue to be developed far in excess of RHNA goals. Lastly, impacts related to auto travel for hotels are less than other uses already permitted in the zones where full -service hotels will be permitted by right, such as hospitals and churches.