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LAW OFFICE OF JORDAN R. SISSON LAND USE, ENVIPONMENTAL & MUNICIPAL LAW 3993 Orange Street,Suite 201 Office:(951)405-8127 jordan@jrsissonlaw.com Riverside,CA 92501 Direct:(951)542-2735 www.irsissonlaw.com September 8, 2025 VIA EMAIL: City Council, City of Santa Ana (eComment@santa-ana.org) c/o Jennifer L. Hall, City Clerk(cityclerk@santa-ana.org) Ali Pezeshkpour,AICP, Planning Manager(apezeshkpour@santa-ana.org) Jerry C. Guevara,AICP, Senior Planner (JGuevara@santa-ana.org) RE: ITEM NO(TBD),CITY COUNCIL HEARING SCHEDULED SEPTEMBER 16,2025; VILLAGE SANTA ANA SPECIFIC PLAN&DA(1561 WEST SUNFLOWER AVENUE) Dear Mayor Amezcua and Honorable City Councilmembers: On behalf of UNITE HERE Local 11 ("Local 11"),this office respectfully provides the following comments'to the City of Santa Ana("City") regarding the proposed Village Santa Ana Specific Plan ("Village Specific Plan"or"SP-6")that would allow the redevelopment of a 17.2-acre site located at the above-referenced address ("Site") into a mixed-use urban village containing up to 1,583 residential units, 80,000 square feet of commercial/retail space, 300,000 square feet of office space, and 13.8 acres of public and private outdoor and recreation space ("Project"). We thank the City for the opportunity to provide these comments on the Project and Supplemental Environmental Impact Report("SEIR").z Local 11 has a significant interest in the Project,given the union represents more than 25,000 workers employed in hotels,restaurants, airports,sports arenas,and convention centers throughout Southern California and Phoenix, Arizona—including hundreds who live and/or work in the City. In short(and discussed below), Local 11 is concerned with the Project's lack of affordable housing to meet the City's Regional Housing Needs Assessment("RHNA") obligations. State data suggests the City has already fulfilled its market-rate obligation but is still roughly halfway behind its affordable obligations (infra section A).Additionally, while the specific plan permits by-right hotel use, there is no hotel anticipated, no hotel currently existing, no vested right to a hotel use, nor a s_becific hotel even considered under the SEIR, which may run afoul of the California Environmental Quality Act("CEQA")3 (infra section B). Furthermore, under these circumstances, allowing by-right hotel uses (including extended-stays) seems to be unprecedented when considering: (i)the City's Zoning Code does not allow by-right hotel uses (infra section C.1); (ii) the Project is distinguishable from other specific developments ("SD(s)"),including MacArthur Place and Transit Zoning Code (e.g., explicitly contemplated hotel uses, excludes extended-stay hotels) (infra section C.2); and (iii) the Village Specific Plan is unlike the City's other five specific plans ("SP(s)") or overlay(e.g., does not allow by-right hotels and/or extended-stays, anticipated specifically hotel project/uses, involved existing and/or vested rights to hotel uses, etc.). 'Herein,page citations are either the stated pagination(i.e.,"p.#")or PDF-page location(i.e.,"PDF p.#"). Z Inclusive of Final EIR and all associated Appendices ("APP")retrieved from City website. (See https:// www.santa-ana.org/the-village-santa-ana-specific-plan/.) 3 Including"CEQA Guidelines"codified at 14 Cal.Code. Regs.§15000 et seq.