Staff Responses to CEQA Related - Agenda Item No. 28

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The Village Santa Ana Specific Plan Project As courts have described, no project can completely satisfy every policy stated in a City’s general plan, and state law does not impose such a requirement. (Naraghi Lakes Neighborhood Preservation Ass’n v. City of Modesto, (2016) 1 Cal. App. 5th 9, 18 citing Sequoyah Hills Homeowners Ass’n v. City of Oakland, (1993) 23 Cal. App. 4th 704, 719-720.) Instead, a Project should be compatible with, and not frustrate the General Plan’s goals and policies. (Id.) The Project’s Specific Plan includes an Appendix B which details the Project’s consistency and compatibility with the City’s General Plan. The commenter is referred to this appendix for a full understanding of the Project’s compatibility with the City’s General Plan. To the extent the commenter suggests the Project is not compatible with the General Plan because the Project elects to use in-lieu fees, such a suggestion is inconsistent with the purpose of the City’s AHOCO. As described above, the AHOCO applies to housing projects proposing five or more units and that are located in certain areas where additional residential development is contemplated. The AHOCO establishes standards and procedures to encourage the development of housing that is affordable to a range of households with varying income levels. As discussed above, one of the procedures is paying in-lieu fees, the proceeds of which will contribute towards affordable housing. Put simply, the payment of in-lieu fees helps the City progress towards its goal of increasing the availability of affordable housing. Thus, the Project, as proposed, is compatible with the affordable and diverse housing goals noted in the commenter’s Letter. Similarly, the Project’s proposed 1,583 units and provision of approximately $7.1 million in in-lieu fees are compatible with the housing development goals of the 2020-2045 Regional Transportation Plan/Sustainable Community Strategy, which are also described in the commenter’s Letter. III. The Project’s SEIR appropriately studied the Project as contemplated by the Proposed Specific Plan The Project consists of a 17.2 acre mixed-use urban village. The Project would permit up to 1,583 residential units, 80,000 square feet of commercial space, 300,000 square feet of office space, and 13.8 acres of public and private outdoor and recreation space (of which 7.5 acres will be publicly accessible open space) through implementation of a Specific Plan. Regardless of any prior zoning for the Property or adjacent lands, the Specific Plan defines permissible and conditionally permissible uses in the Specific Plan area. There is no requirement for a “vested right” to a specific use as the commenter alludes to. As noted in the Specific Plan, a variety of commercial uses, including a hotel use, are permitted. The Project’s environmental review studied the impacts of the Specific Plan’s commercial uses. The Project’s Supplemental Environmental Impact (“SEIR”) conservatively studied the potential full buildout of the Project with intensive uses. This analysis included the 80,000 sf of commercial space, which was studied using more intensive permitted commercial uses. The 80,000 sf of commercial space was assumed to include high traffic retail and dining akin to a regional shopping center. These uses have higher intensity levels than hotel uses and generate approximately twice as many trips per 1,000 sf compared with a hotel use. Given hotel uses are significantly less intense when compared with high-turnover retail and restaurant uses, impacts from a hotel are inherently captured in the environmental analysis as a less intensive use than what was studied. City of Santa Ana September 2025 3 55394.00067\\44182451.1