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Local 11 Comments RE.Village Santa Ana Specific Plan
<br /> September 8,2025
<br /> Page 13 of 17
<br /> Second,the Transit Zoning Code (i.e.,SD-84) (SAMC 41-2000 et seq.) was adopted in 2010
<br /> and subsequently amended twice (i.e.,most recently in June 2025).35 SD-84 covers portions of the
<br /> City's central urban core (i.e., 100+blocks and 450 acres),36 which is broken into eight districts,
<br /> which hotel's by right in only four of the districts (e.g.,TV,DT,UC, CDR). (See SAMC §§41-2006(b)
<br /> [Fig. 2.1], 41-2007(a) [Tbl. 2A].) However, SD-84 explicitly excludes extended-stay hotels. (Id.,Tbl.
<br /> 2A.) Hence,SD-84 explicitly disallows extended-stay hotels(i.e.,unlike the Village Specific Plan that
<br /> allows by-right extended-stay hotel use).
<br /> Third,based on the other nearly 100 SDs reviewed,the Village Specific Plan is unlike the
<br /> rare instances where hotel uses are mentioned in the SD, as discussed below:
<br /> • SD-8 (i.e., Brookhollow Office Park, 1977) allows hotel uses in Zone II. (SD-8,37 pp. 3, 8.),
<br /> which is arguably an outdated zoning approval (i.e.,48 years old).Additionally,based on
<br /> the proposed plans (id., at PDF p. 10) and aerial imagery,38 the approximately 5.5-acre
<br /> property does not seem to have ever been developed as a hotel,which suggests allowing
<br /> hotel uses was merely an oversight. Hence,SD-8 is an outdated development approval that
<br /> permits hotel as a by-right use as an apparent oversight(i.e.,unlike the Village Specific Plan
<br /> that can remove ambiguity and cure potential ambiguity).
<br /> • SD-12 (1978 / 1982) was initially adopted in 1978,which did not allow hotel uses. (SD-12,39
<br /> PDF pp. 2, 8.) In 1982, SD-12 was amended to allow a variety of other uses, including hotels
<br /> and motels (id., at PDF p. 3),which the approximately 20.5-acre site was ultimately
<br /> developed with multiple hotels (based on aerial imagery) shortly after the approval.40
<br /> Hence,SD-12 permits hotel uses by-right because it seems that it specifically anticipated
<br /> specific hotel uses on that site (i.e.,unlike the Village Specific Plan that does not contemplate
<br /> hotel uses on the site)].
<br /> will be incorporated in the proposed project."),https://ceganet.Ici.ca.gov/1987042909;CEQAnet(SCH No.
<br /> 2004061140) MacArthur Place South(Document description stating(emphasis added): 'The proposed
<br /> project involves the development of three 25-story residential towers,a three-building 5&6 story
<br /> condominium development,a 5&6 story office and residential loft development and associated retail and
<br /> restaurant uses.The project would include the demolition of 47,000 sq.ft.of existing land uses and associated
<br /> parking facilities and the relinquishing of approved entitlements for a 162-room hotel.")
<br /> 35 SD-84(6/21/2010),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_84.NS-
<br /> 2803.TransitZoningCodel.pdf,see also TZC,Table of Contents,PDF p. 1,
<br /> https://storage.googleapis.com/proudcity/santaanaca/2025/07/Cover-and-ToC.pdf.
<br /> 36 City(6/3/25) Item 24 Staff Report,p.3,https://santa-ana.primegov.com/api/compile
<br /> meetingattachmenthistory/historyattachment/?historyld=72aab686-cde9-44cb-9461-43d42525d52f.
<br /> 37 SD-8(11/14/77),https://storage.googleapis.com/proudcity/
<br /> santaanaca/uploads/2022/04/SD_8_1360.pdf.
<br /> 38 Compare Google Earth aerial images (6/1/94)with(5/8/25).
<br /> 39 SD-12 (8/16/82),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_12.NS-
<br /> 1645.pdf.
<br /> 41 Compare Google Earth arial images (6/1/94)with(5/8/25);City Property Records, 1325 E.Dyer(land use
<br /> certificates issued for Embassy Suites Hotel in 1985);OC Register(7/13/13)The sweet history of Irvine's
<br /> Holly Sugar Plant(noting former Holly Sugar Plant razed in 1983); Business Traveler News,Embassy Suites
<br /> Santa Ana(noting hotel constructed in 1985).
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