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Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 12 of 17 required for all extended-stay hotels(since 2001) and transient/residential hotels (since 1999).31 Hence, by-right hotels are an outlier under the Citv'sgeneral zoning rules. ZONE USE SAMC Al Zone (Agriculture) sec 41-200 et se N §41-200 et seg. C1 Zone (Community Commercial CUP §41-365.5 c C1-MD (Community Commercial Museum District CUP §41-375.2 c C2 Zone General Commercial CUP §41-377.5 a C4 Zone Planned Shopping Center CUP §41-412.5 C5 Zone Arterial Commercial CUP §41-424.5 a CR Zone Commercial Residential CUP §41-442.5 a CSM Zone Commercial South Main CUP §41-522 c GC Government Center N §41-343 et seg. M1 Zone (Light Industrial N §41-471 et seg. M2 Zone (Heavy Industrial N §41-489 et seg. 0 Zone (Open Space) N §41-582 et seg. P Zone Professional N §41-312 et seg. R1 Zone (Single Family Residential N §41-231 et seg. R2 Zone (Two-Family Residential N §41-246 et seg. R3 Zone (Multiple-Famil Residential N §41-258 et seg. R4 Zone Suburban Apartment) N §41-290 et seg. RE Zone Residential Estate N §41-216 et seg. 2. THE PROJECT IS DISTINGUISHABLE FROM MACARTHUR PLACE,TRANSIT ZONING CODE,AND THE OTHER SPECIFIC DEVELOPMENTS LISTED BY THE CITY The City lists nearly 100 other Specific Developments ("SD"), including the aforementioned SD-43 (i.e., MacArthur Place) and SD 84 (i.e.,Transit Zoning Code).32 However, as discussed above, the Village Specific Plan (i.e., SP-6) allows by-right hotels (including extended-stays),where it has no vested rights and where no specific hotel project was considered under CEQA.This makes the Village Specific Plan unprecedented and/or an outlier compared to the other SDs, considering the following: First, MacArthur Place District Center (i.e., SD-43) was adopted in 2012, explicitly contemplated a hotel,33 and was seemingly subject to multiple EIRs that also explicitly anticipated a hotel use.34 Hence,SD-43 and its underlying CEQA reviews explicitly contemplated hotel uses(i.e., unlike the Village Specific Plan that does not consider a specific hotel in the plan or CEQA review). 31 Supra fn.28,29. 32 City,Specific Development List,https://www.santa-ana.org/specific-development-list/;see also City of Santa Ana Zoning Map (11/14/24),https://storage.googleapis.com/proudcity/santaanaca/2023/12/2.- Zoning-FULL-CITY-2024-11-14-24.pdf. 33 SD-43/(4/16/12) PDF p. 1 (council action showing date),p.8, (explicitly included office/hotel conversion rates for square footage),p. 11 (purpose/intent of the SD was to provide"hotel service"),https://storage. googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_43-Without-a//ttachments-2012.pdf. 34 Ibid.,at PDF pp.5,8, 15 (referencing EIR);see also CEQAnet(SCH No. 1987042909) Main Street/MacArthur Boulevard Intersection Improvement Project(Document description stating(emphasis added): "At ultimate buildout,the proposed project would include 4,051,000 sq ft of office-commercial uses,including one or two hotels.the total floor are office/retail/hotel component is 1.5:1.0.additionally,400 multi-family dwelling units