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drCAJA Environmental Services, LLC
<br /> 9410 Topanga Canyon Blvd.,Suite 101
<br /> Chatsworth,CA 91311
<br /> Phone 310-469-6700 Fax 310-806-9801
<br /> The City already has a plan in place to accommodate new hotel development. In 2016, the City adopted a
<br /> hotel incentive program aimed at attracting new hotel development,13 spurred by an increase in tourism in
<br /> Orange County, and Santa Ana's proximity to hubs of tourism including Anaheim's resort district, the John
<br /> Wayne Airport, and local amenities including the Discovery Cube Orange County and the Bowers
<br /> Museum.14 The City's General Plan has identified certain locations appropriate for the development of
<br /> hotels including in the land use designations District Center— Medium and Industrial/Flex (at Brookhollow
<br /> Specific Development (SD) Plan No. 8), specifically at 55 Freeway and Dyer Road." The City's Harbor
<br /> Mix Use Transit Corridor Plan notes it could lead to the addition of new hotels.16 In addition, the City's
<br /> Midtown Specific Plan and Metro East Mixed-Use Overlay District Expansion and Elan Development
<br /> Projects each specifically contemplates new hotels." Further, hotel and motels are also permitted to be
<br /> constructed and operated in C-1, C1-MD, C2, C4, C5, CR, and CSM Zoning Districts. As the City has
<br /> identified specific areas where hotels could be developed, the City is capable of conducting meaningful
<br /> and informational environmental review of the hotels' construction now.
<br /> In 2016, the City noted that the average occupancy of Orange County hotels was at 78 percent, spurring
<br /> the need for new hotel development in the area.18 As discussed in the Ramboll report, hotel occupancy
<br /> rates in Orange County as of September 2024 are 77 percent. (Ramboll Economics Analysis, p. 2.)
<br /> Evidence from Ramboll shows that removal of all existing STRs which are a "significant portion of the
<br /> lodging market" would leave a "considerable gap in available accommodations, which the existing hotel
<br /> infrastructure is unlikely to be able to fully absorb." (Ramboll Economics Analysis, pp. 3-4.) The City must
<br /> evaluate this evidence to understand the current demand for hotels and STRs, and project the demand
<br /> that would result from a ban on all STRs in the City.
<br /> In the absence of all STRs, it is reasonably foreseeable that market forces will drive new hotel development
<br /> to replace the loss of nights from the STR market. It is also reasonably foreseeable that the construction
<br /> of new hotels in the City will result in a wide range of potential environmental effects to air quality, biological
<br /> resources, cultural and tribal cultural resources, energy, GHG emissions, hazards and hazardous
<br /> materials, land use and planning, noise and vibration, public services, transportation, and utilities.
<br /> The City Must Consider Cumulative Regional Impacts of STIR Bans
<br /> An STIR ban in the City has potential to cause a ripple effect across the region if other localities follow suit,
<br /> resulting in cumulative environmental impacts from rapid elimination of STIR uses, compounding issues
<br /> described above including shifting traffic patterns and increased VMT, increased use of resource-intensive
<br /> 13 City of Santa Ana, Hotel Incentive Program, available here: https://www.santa-ana.org/hotel-incentive-program
<br /> (last visited Oct. 7, 2024).
<br /> 14 City Council Staff Report, June 7, 2016, Hotel Development Incentive Program, available here:
<br /> https://publicdocs.santa-ana.org/WebLink/DocView.aspx?dbid=1&id=88417&page=1&cr=1.
<br /> 15 Santa Ana General Plan, Land Use Element, LU 56-58.
<br /> 16 City of Santa Ana, Harbor Mixed Use Transit Corridor Specific Plan, pp. 1-2 (Oct. 2014).
<br /> 17 City of Santa Ana, Midtown Specific Plan, pp. 29, 38 (Dec. 1996); Metro East Mixed-Use Overlay District
<br /> Expansion and Elan Development Projects Subsequent EIR, p. 3-39 (June 2018).
<br /> 11 City Council Staff Report, June 7, 2016, Hotel Development Incentive Program, available here:
<br /> https://publicdocs.santa-ana.org/WebLink/DocView.aspx?dbid=1&id=88417&page=1&cr=1.
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