Laserfiche WebLink
LetterO1–Gaines&StaceyLLP(171pages) <br />O1.ResponsetoCommentstoAliciaB.BartleyfromGaines&StaceyLLP,datedNovember18,2024. <br />O1-1This commentsummarizes the role of Gaines & Stacey LLP and requests the City repeal <br />and reenact a prohibition on short-term rentals (STRs). No response is required. <br />O1-2This comment summarizes the conclusions made in the comment letter. Specifically,that <br />the Modified Projectwould adverselyimpactthe environment(vehicle miles traveled <br />\[VMT\], air quality, energy consumption, and greenhouse gas emissions \[GHG\]), violate <br />state and federal law, and infringe on the rights ofSTR hosts and their guests. <br />The Environmental Impact Report (EIR)Addendum identified that the previously certified <br />General PlanUpdate Final ProgramEIR(GPU PEIR)concluded significant and unavoidable <br />impacts related to air quality and greenhouse gas emissions. Significant changes related to <br />VMT and energy consumption would occur if the Modified Projectproposedwouldresult <br />in significant expansionsor changes toexisting or former uses; these changes would <br />deviate from the scope of the approved project, the impacts of which would not be <br />covered by the certified General PlanUpdate FinalPEIR. The Modified Projectwould not <br />result in a significant expansion of existing or former uses; the Modified Projectreaffirms <br />existing lawwhich is that STRs are not permitted in any zone district of the Cityand were <br />not permitted at the time the General Plan Update Final PEIR was certified. No <br />development, redevelopment, or change to existing development type in the City is <br />proposed or required to implement the Modified Project. The Modified Projectwould not <br />result in any new or more severe significant impacts than previously analyzed in the <br />certified General Plan Update FinalPEIR because STRs have never been an allowed use. <br />The Modified Project affirms this conditionand establishes a mechanism to enforce <br />removal of land uses inconsistent with this policy of the City.This comment does not <br />identify a specific deficiency in the EIR Addendumnor a new or exacerbated potential <br />significant environmental impact. No changes to the EIR Addendumand no additional <br />CEQA documentation are required. <br />O1-3This comment requests that the City repeal the existing Article XXI to Chapter 8 of the Santa <br />Ana Municipal Code and requests that City Staff work with stakeholders to develop a new <br />ordinance that underscores that STRs may continue operating. This comment does not <br />identify a specific deficiency in the EIR Addendum nor a new or exacerbatedpotential <br />significant environmental impact. No changes to the EIR Addendum and no additional <br />CEQA documentation are required. <br />O1-4This comment provides background information regarding the Santa Ana Short-Term <br />Rental Alliance and challenge to the April 2024 STR Ordinance.This comment does not <br />identify a specific deficiency in the EIR Addendum nor a new or exacerbated potential <br />significant environmental impact. No changes to the EIR Addendum and no additional <br />CEQA documentation are required. <br />O1-5This comment provides a summary of the history and importance of STRs in the City.No <br />further response is necessary. <br />O1-6This comment states that the Modified Projectis unrelated to the approved project <br />analyzed in the certified General Plan Update Final PEIR and that the Modified Project <br />November 19,2024|Page 3 <br /> <br />