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would result in significant environmental impacts that have not been evaluated under <br />CEQA. <br />As discussed on Page 7 of the EIR Addendum, Section 41-190(a) of the Santa Ana Municipal <br />Code is a permissive ordinance, meaning that those uses expressly listed in the Section are <br />permissible and those not listed are prohibited. The Santa Ana Municipal Code does not <br />now, and has never listed STRs as permissible uses in any zone district, including those <br />zoned for residential. According to the California Department of Housing and Community <br />1 <br />, STRs decrease housing supply; thereby altering the existing <br />Development (HCD) <br />conditions established in the Geneal Plan EIR. The Modified Projectwould amend the Santa <br />Ana Municipal Code to expressly prohibit short-term rentals within the City. The Modified <br />Projectwould reaffirm existing law and solidify the existing conditions analyzed in the <br />certified General Plan Update Final PEIR and would set administrative fines for violations <br />of local building codes and short-term rental laws, pursuant to Government Code Section <br />36900 and Santa Ana Municipal Code Sections 1-21 through 1-21.9.The Modified Project <br />would not result in a significant expansion of existing or former uses.No development, <br />redevelopment, or change to existing development type in the City is proposed or required <br />to implement the Modified Project. Therefore, the Modified Projectwould not significantly <br />change the scope of the approved project analyzed in the certified General Plan Update <br />Final PEIR. Ergo, the EIR Addendum prepared for the Modified Projectis the appropriate <br />CEQA documentation as the Modified Projectis within the scope of the approved project. <br />The commenter suggests that the Modified Project (permitted uses) would result in more <br />severe impacts as compared to the existing illegal uses (STRs). This comment states that <br />the following environmental topics will be adversely affected by the Modified Project <br />based on conclusions identified in Attachment A (CAJA EnvironmentalServices, Significant <br />Environmental Effects of BanningShort-Term Rentals in the City of Santa andRequirement <br />Require Additional EnvironmentalAnalysis Under CEQA) of the comment letter: <br />Air quality (mobile emissions) <br />Energy (energy demand) <br />GHG emissions(mobile emissions) <br />Noise (traffic noise) <br />Transportation (VMT) <br />It should be noted that “Environmental Justice” is not an environmental topic included in <br />Appendix G of the CEQA Guidelines. However, impacts on disadvantaged communities are <br />discussed in the topics listed above. No response is required to address environmental <br />justice. <br />The commenter’s conclusions regarding the above listed topics are rooted in speculative <br />data and assumptionsused in Attachment A. For example, Attachment A of the comment <br />letter states that the Modified Project would force visitors and residents to find transient <br />accommodations outside the Citywhich necessarily assumes that the visitors would ignore <br />the many existing hotels and motels that already exist within the City.This comment is <br />speculative as it is based on unsubstantiated assumptionrather than substantial evidence. <br />CEQA Guidelines Section 21082.2 states that “argument, speculation, unsubstantiated <br />opinion or narrative, evidence which is clearly inaccurate or erroneous,or evidence of <br /> <br />1 <br />California Department of Housing and Community Development, California’s Housing Future 2040: The Next RHNA, <br />https://www.hcd.ca.gov/sites/default/files/docs/planning-and-community/rhna/cahf-2040-rhna-report-2024.pdf <br />November 19,2024|Page 4 <br /> <br />