Staff Responses to CEQA Related - Agenda Item No. 28

Home Browse Search

The Village Santa Ana Specific Plan Project Thus, impacts related to air quality and transportation uses (including vehicle miles travelled and a transportation demand management (“TDM”) plan)—as studied in the SEIR— reflect potentially more impactful uses than a hotel. As a result, the commenter’s claim that the SEIR did not include the appropriate analysis is inapposite. By studying the maximum buildout, the SEIR inherently studies the potential environmental impacts of less intense uses such as hotel. The SEIR studied feasible mitigation to reduce potential environmental impacts relating to air quality, transportation, and other subjects. With respect to transportation impacts and the commenter’s suggestions for additional strategies and mitigation measures, the SEIR found that transportation impacts would be less than significant. Accordingly, a TDM plan is not a mitigation measure required by the environmental analysis. Thus, requiring additional performance metrics as suggested by the commenter is not a CEQA issue. However, the City will take into consideration these additional strategies that the commenter suggests. Given that the SEIR studied potential impacts of the potential maximum buildout, the proposed mitigation provided in the SEIR is appropriate. The City notes that the Specific Plan includes an Administration and Implementation Chapter which details the additional future review of any development with the Specific Plan area. Pursuant to this Chapter, any future development project must obtain approval of a Development Project Plan Review. (See Specific Plan, § 6.3.3.) Thus, to the extent a hotel is included in the buildout of the Project’s commercial uses, that use will be subject to further City review during the Development Project Plan Review process. IV. A Hotel Use is Consistent with the Property’s General Plan Land Use Designation As described above, the proposed Specific Plan defines permissible uses within the Specific Plan area. Under the Specific Plan, hotel uses are permitted by right or subject to conditional approval depending on the number of other uses with onsite alcohol sales already permitted. (See Specific Plan Table 4-1.) The Specific Plan’s use mix is consistent with the City’s General Plan. Under the General Plan Land Use Plan, the Property is designated as District Center – High (DC-5), which allows a mix of uses consistent with new urban-scale development. Uses include residential, retail, commercial, office, and entertainment uses. Taken together, the proposed Specific Plan would amend the City’s zoning code to allow hotel uses on the Property consistent with the mixed-use urban development contemplated by the General Plan. The City’s diverse and varied mix of urban and suburban environments allow for many land use types and use intensities. As shown in the General Plan Land Use Plan, the pattern and distribution of land uses differ depending on the character of the surrounding environment. As a result, the commenter’s review of land uses and hotel uses in other areas of the City is not relevant to the Project or the required findings that the City considers when making a determination on the Project. Even so, the commenter’s review provides support for an opposite conclusion – there is precedent for hotels permitted “by right” in many other areas of the City. Indeed, the commenter provides an analysis of the City’s zoning code, Special Districts (“SD”), and Specific Plans in an effort to show that a hotel use is unwarranted on the Property. However, as the commenter points out, hotel uses has been permitted in other SDs and Specific Plan areas dating back to 1977 and as recently as the 2019 Main Place Specific Plan and 2024 Related Bristol Specific Plan. (See Letter, pg. 15-16.) City of Santa Ana September 2025 4 55394.00067\\44182451.1