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Local 11 Comments RE.Village Santa Ana Specific Plan
<br /> September 8,2025
<br /> Page 10 of 17
<br /> 3. THE SEIR AND VILLAGE SPECIFIC PLAN DID NOTCONSIDER ROBUST TDM MEASURES THAT
<br /> HAVE THE Co-BENEFIT OF REDUCING VMTs,GHGs,AND OTHER AIR EMISSIONS
<br /> Furthermore,while the Village Specific Plan may require a TDM plan to be reviewed and
<br /> approved in the future (SP-6, p.83 [Tbl. 4-3, note 1]),it is not tethered to any environmental
<br /> analysis and does not require any performance metrics to guide future decision making.
<br /> Furthermore,it does not mandate consideration of a full range of TDM strategies and other
<br /> sustainability measures which may be warranted,such as those measures attached hereto as
<br /> Exhibit B that are recommended by public agencies like the California Air Pollution Control Officers
<br /> Association ("CAPCOA"),the SCAG, and the California Air Resources Board ("CARB"). (See Exhibit B,
<br /> Figs. 1 through 3 [respectively].)
<br /> C. UNDER THE CIRCUMSTANCES,ALLOWING BY-RIGHT HOTELS(INCLUDING EXTENDED-STAYS)
<br /> WOULD SEEM TO BE UNPRECEDENTED UNDER THE CITY'S ZONING CODE,SDS,SPS,AND OVERLAY
<br /> Under the proposed Village Specific Plan(i.e.,SP-6),hotel use is generically listed under
<br /> "Commercial/Retail/Office"uses as by-right use,including extended stay hotels. (See Figure 5
<br /> below.) During the Planning Commission hearing,Planning staff suggested that allowing hotels by
<br /> right would not be an outlier or unprecedented,citing MacArthur Place (i.e.,SD-43),Transit Zoning
<br /> Code (i.e.,SD-84),and a unspecified reference to elsewhere in the City.26 However, as discussed
<br /> above,the Project may allow zero affordable units (supra subsection A); nor is a specific hotel
<br /> project currently anticipated,existing,vested, or analyzed in the SEIR(supra subsection B).
<br /> Additionally, as discussed below,it seems: (i)the City's Zoning Code does not allow by-right
<br /> hotel uses, including extended-stay hotels (infra section C.1); (ii) the Village Specific Plan is
<br /> distinguishable from MacArthur Place and the Transit Zone,which explicitly contemplated hotel
<br /> uses or excluded by-right extended-stays (infra section C.2); (iii) the Project is also distinguishable
<br /> from the rare handful of specific developments that even mention hotel use (e.g.,outdated,
<br /> existing/vested right to hotel, contemplated specific hotel project,required CUPS,etc.) (infra
<br /> section C.2); (iv)the Specific Plan is distinguishable from the City's five (5) other Specific Plans
<br /> ("SP(s)") and one overlay zone,which either does not allow by-right hotels and/or extended stay
<br /> hotels (i.e., SP-1,SP-2, SP-3) or allows hotels uses because there was either an existing hotel use,a
<br /> vested right,and/or specifically contemplated a hotel project that was considered in the CEQA
<br /> document(i.e.,SP-5, MEMU Overly) (infra section C.3). Under the circumstance, allowing by-right
<br /> hotels without any specific hotel project contemplated and/or analyzed,seems to be
<br /> unprecedented for the City.
<br /> 26 See PC Video,supra fn.5,appx.3:22:24-3:22:48 ("MacArthur Place specific development that's SD number
<br /> 43,Maine and MacArthur allows hotels by right and I believe,as you were alluding to,the transit zoning code
<br /> actually does allow hotels by right in um all of the subzones where they're allowed.So there is precedence for
<br /> allowing them administratively."); Id.,appx. 3:25:36-3:25:49 ("Given the precedence that I mentioned earlier
<br /> with the transit zoning code,SD43 and any other areas.where hotels are already allowed administratively,
<br /> this would not be breaking new ground policy-wise either.")
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