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Local 11 Comments RE.Village Santa Ana Specific Plan
<br /> September 8,2025
<br /> Page 14 of 17
<br /> • SD-64 (i.e., Candlewood Hotel Company, 1998) explicitly anticipated a 123-room extended-
<br /> stay hotel (SD-64,41 PDF p. 7),which was ultimately built by 2002 (based on aerial
<br /> imagery).42 Hence,SD-64 logically permits hotel uses by-right because it contemplated a
<br /> specific hotel project(i.e.,unlike the Village Specific Plan that does not consider a particular
<br /> hotel project).
<br /> • SD-69 (PacifiCenter, 1999) allows by-right hotel uses within Project Area 1. (SD-69,43 PDF
<br /> pp. 7, 16.) However,that site was partially subject to previously approved SD-56 (id., at PDF
<br /> p. 2, 3,4),which was a 1990 approval that contemplated a potential Santa Ana sports arena
<br /> subject to a specific development agreement(TA") and EIR. (See SD-56,44 PDF pp. 2-3, 6-7,
<br /> 14, 22.) Nevertheless,SD-69 contemplated additional environmental documentation and
<br /> potential discretionary review depending on the level of floor-area-ratio ("FAR") of the
<br /> development proposed.45 Furthermore (based on aerial imagery),the approximately 15.5-
<br /> acre site was undeveloped until after the SD-69 was approved,which was ultimately
<br /> developed by 2003 as the site current exists today with no hotel, a large Home Depot, and
<br /> several restaurants (i.e.,Jack in the Box, IHOP, El Pollo Loco).46 Hence,SD-691SD-56 is an
<br /> outdated development approval(i.e.,26135,years old) that permits hotel uses by-right as an
<br /> apparent oversight or legacy of an older EIRIDA approval, but nevertheless contemplated
<br /> future CEQA review (i.e.,unlike the Village Specific Plan that has no vested rights to hotel use
<br /> and provides no future CEQA review for a potential hotel).
<br /> • SD-76 (i.e., Hutton Centre, 2005) allows hotels within Zone 1 via a CUP. (SD-76,47 PDF pp. 3,
<br /> 10.)Additionally,the Plans show that the hotel within Zone 1 already existed in 2005 (id.,at
<br /> PDF p. 16) and the structure was built by at least 1994 (based on aerial imagery).48 Hence,
<br /> SD-76 does not permit by-right hotel use even when there are existing hotel uses on site (i.e.,
<br /> unlike the Village Specific Plan that has no existing hotel uses).
<br /> 41 SD-84(5/4/98),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_64.NS-
<br /> 2347.pdf.
<br /> 42 Compare Google Earth arial images(6/1/94)with(6/5/02)and(5/8/25).
<br /> 43 SD-69 (8/16/99),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_69.NS-
<br /> 2399.PacifiCenter.pdf.
<br /> 44 SD-56(4/16/90),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_56.NS-
<br /> 2060.pdf.
<br /> 45 Compare SD-69,PDF p. 5 section I.D ("Any construction on a parcel that results in a development
<br /> intensity less than 0.45 floor area ratio may require technical studies and infrastructure improvements that
<br /> will be determined through the City's site plan review process."Emphasis added)with section I.E ("Any
<br /> construction on a parcel that results in a development intensity above a 0.45 floor area ratio will require a
<br /> General Plan Amendment an amendment to the Specific Development Plan,the appropriate environmental
<br /> analysis, CEQA documentation and infrastructure improvements as determined through the City's site plan
<br /> review process."Emphasis added).
<br /> 46 Compare Google Earth arial images(6/1/94)with(4/17/03)and(5/8/25).
<br /> 47 SD(7/5/05),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_76-Updated-
<br /> 05-01.pdf.
<br /> 41 Compare Google Earth arial images(6/1/94)with(10/23/07)and(5/8/25).
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