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HomeMy WebLinkAboutCorrespondence - Item 28 Becerra, Alexis From: jordan@jrsissonlaw.com Sent: Monday, September 8, 2025 10:28 AM To: eComment; !City Clerk; Pezeshkpour, Ali; Guevara, Jerry Cc: Vazquez, Benjamin; Lopez, Jorge (SAPD); Hernandez, Johnathan; Phan, Thai; Penaloza, David; Bacerra, Phil; Amezcua, Valerie;jmunoz@uniteherel 1.org Subject: Local 11 Comments: Village Santa Ana Specific Plan & DA (1561 West Sunflower Avenue) Attachments: CC Comments_final.pdf Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Dear Mayor Amezcua and Honorable City Councilmembers: On behalf of UNITE HERE Local 11 ("Local 11"), please see that attached comments on the above referenced Project and Supplemental Environmental Impact Report("SEIR") In short,we thank the City for the opportunity to provide these comments. As discussed in the attached comments, Local 11 has some concerns with the Project, such as the lack of required onsite affordable housing and the permitting by right of hotel uses. 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 specific hotel even considered under the SEIR, which may run afoul of the California Environmental Quality Act("CEQA"). 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; (ii)the Project is distinguishable from the few specific developments that involve hotel use ("SD(s)"), including the MacArthur Place SD and Transit Zoning Code; 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.). For the reasons discussed in the attached comment letter, Local 11 respectfully urges the City to consider: 1. Removing hotel uses from the Village Specific Plan,which can be accomplished with minor edits to four pages of the current planning document(i.e., pp. 73, 74, 83, 88),which are provided in the attached comment letter (attached thereto as Exhibit A). 2. Requiring some portion of the housing to be affordable and/or workforce housing. 3. Implementing additional design features and mitigation measures to help minimize potential impacts from vehicle miles traveled ("VMT") and mobile emissions, such as those measures suggested by public agencies and provided in the attached comment letter(attached thereto as Exhibit e). Thank you for the opportunity to provide these comments. Very truly yours, JORDAN R.SISSON,ESQ. Law Office of Jordan R. Sisson 3993 Orange St.,Ste. 201 Riverside,CA 92501 Office:951-405-8127 Direct: 951-542-2735 jordan@irsissonlaw.com 1 PRIVILEGED AND CONFIDENTIAL:This electronic message contains information from the Law Office of Jordan R. Sisson and is attorney work product confidential or privileged.The information is intended solely for the use of the individual(s)or entity(ies) named above. If you have received this transmission in error, please destroy the original transmission and its attachments without reading or saving in any manner. 2 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. Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 2 of 17 For the reasons discussed herein,Local 11 respectfully urges the City to consider: 1. Removing hotel uses from the Village Specific Plan,which can be accomplished with minor edits to four pages of the current planning document(i.e.,pp. 73, 74, 83, 88).They are attached hereto as Exhibit A. 2. Requiring some portion of the housing to be affordable and/or workforce housing. 3. Implementing additional design features and mitigation measures to potentially significantly minimize potential impacts from vehicle miles traveled("VMT") and mobile emissions,which affect air quality and greenhouse gas ("GHG") emissions. Measures suggested by public agencies, such as the measures attached hereto as Exhibit B, can help achieve this goal. The remainder of this comment letter is in response to the SEIR and documents presented during the City's Planning Commission hearing held on August 11, 2025,including the Planning Commission staff report("PC Staff Report"),4 hearing video (`PC Video"),5 and other public documents. A. THE CITY MAY WANT TO RECONSIDER A PLAN THAT PROVIDES SOME AFFORDABLE UNITS In 2022,the City revised its now-known Affordable Housing Opportunity and Creation Ordinance ("AHOCO"). (See Santa Ana Municipal Code ("SAMC") §41-1900 et seq.) Generally,the AHOCO encourages new residential developments to include affordable housing units onsite or offsite (e.g., 5-15% depending on affordability) or in-lieu fees ($6- $15 per square foot depending on the number of units proposed),which may be reduced to $5.00 in some cases. (See SAMC§41- 1904.) Here, under section five of the proposed development agreement("DA"),6 the Project is paying the lowest$5.00 per square foot of each market-rate residential unit. Hence,the Project may provide zero affordable housing units (i.e., onsite) and pay an in-lieu fee into an Inclusionary Housing Fund that is intended to be utilized for the construction of an unknown number of affordable units at some unknown project site (i.e.,offsite) at some unknown date in the future. This level of uncertainty is among other potential drawbacks of in-lieu fee programs as compared to inclusionary housing requirements.? Hence, the Village Specific Plan could allow not a single affordable unit within the proposed plan (i.e., onsite)with unknown certainty of when, where, or how many potential affordable units will be built. 4 Inclusive of all Exhibits ("Exh.")attached thereto on the City's online agenda. (See Planning Commission (8/11/25) Item 1,https://santa-ana.primegov.com/Portal/Meeting?meetingTemplateId=23803.) 5 PC Video (8/11/25) appx.03:21:40-3:27:00,https://www.youtube.com/watch?v=7cY4_O7GAs8. 6 PC Staff Report,Exh.8 (DA),PDF p.17 (section 5.1.1),https://santa-ana.primegov.com/api/ compilemeetingattachmenthistory/historyattachment/?historyld=fadfe Oc8-cf6f-4ff5-b9d0-9d92 cdfb93b4. See e.g.,Urban Land Institute (May 2020) Determining In-Lieu Fees in Inclusionary Zoning Policies Considerations for Local Governments,p.5 (noting potential disadvantages like:fees being set too low, undermining inclusionary zoning policy,creation of lower quality offsite affordable units,concentration of low-income housing that defeats mixed-income development), https://www.urban.org/sites/default/files/publication/102230/determining-in-lieu-fees-in-inclusionary- zoning-policies_1.pdf. Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 3 of 17 However, as discussed below,there seems to be: (i) substantial evidence from state data showing the City has a compelling need for affordable housing to meet its RHNA obligation (infra section A.1); (ii) the SEIR may not adequately consider potential inconsistencies with various policies under its General Plan(infra section A.2); and (iii)the SEIR did not consider potential inconsistencies with adopted regional housing policies (infra section A.3).Under the circumstances, the City may want to reconsider a Village Specific Plan that ensures some affordable housing units onsite. So too,failure to adequately consider potential conflicts/inconsistencies with applicable land use plans, policy,or regulation may run afoul of CEQA.8 1. HCD DATA SHOWS COMPELLING NEED FOR AFFORDABLE UNITS The California Department of Housing and Community Development("HCD") oversees local municipalities' compliance with various state housing laws, including those relevant to Housing Element updates to accommodate local RHNA numbers.9 Cities and counties provide self-reported Annual Progress Reports ("APR(s)") to HCD regarding their progress on these efforts,and HCD provides summaries of these"self-reported"APRs on its Housing Element&APR Data Dashboard ("Dashboard").10 The Dashboard displays various data across 18 sheets, allowing the user to focus on multiple jurisdictions,years,housing cycles, and other filters. Based on the APR Dashboard for the City of Santa Ana, one can make the following observation,which references the figures below: • Santa Ana is in its Sixth Housing Element Cycle (2021 - 2029),has a total RHNA obligation of 3,137 units,of which roughly 48.2%are to be affordable at moderate levels or lower. (See Fig. 1 below.) • Through 2024,the City was 37.5%through the cycle;while it has made significant strides,it has developed an excess of above-moderate income units (i.e., approximately 180%above its 1,624 RHNA obligation) as compared to its affordable units (i.e., approximately 52%of its 1,513 RHNA obligation). (See figure 2 below.) 8 The CEQA Initial Study Checklist,used to determine whether a project may have significant environmental impacts,includes the question of whether a project may"[c]onflict with any applicable land use plan,policy, or regulation ...adopted for the purpose of avoiding or mitigating an environmental effect." (CEQA Guidelines,Appendix G;Pocket Protectors v.City of Sacramento (2004) 124 Cal.AppAth 903,929 [EIR required to analyze project's inconsistency with City land use ordinance for planned developments].) A project is inconsistent if it conflicts with a fundamental,mandatory and specific land use policy. (Families Unafraid to Uphold Rural etc. County v.Board of Supervisors(1998)62 Cal.AppAth 1332, 1342.)Furthermore, a project that causes a loss of housing stock,land available for housing,or violates zoning laws designed to encourage housing,can pose a potentially significant impact that must be considered under CEQA. (Concerned Citizens v.Los Angeles Unified School District(1994) 24 Cal.App.4th 826,838 [SEIR acknowledged significant adverse impact on affordable housing stock];Sacramento Old City Assn. v.City Council(1991)229 Cal.App.3d 1011, 1038-39 [loss of housing can constitute a potentially significant impact necessitating adequate mitigation measures].) 9 See e.g.,HCD Housing Element,https://www.hcd.ca.gov/planning-and-community-development/housing- elements;HCD RHNA,https://www.hcd.ca.gov/planning-and-community-development/regional-housing- needs-allocation;HCD Annual Progress Reports,https://www.hcd.ca.gov/planning-and-community- development/annual-progress-reports. 10 HCD,Housing Element&APR Dashboard,https://www.hcd.ca.gov/planning-and-community- development/housing-element-implementation-and-apr-dashboard. Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 4 of 17 FIGURE 1: HCD APR DATA DASHBOARD (SHEET 10 OF 18) Housing Element Implementation and APR Data Dashboard Navigation Key Figures Construction Housing Needs Implemelltatlon User Guide Suhmil Feedhack Needs Regional Housing Needs Allocation (RHNA): Overview n 2nd Lytle 3rd Lytle 4tlt CyGe 5th Lytle 61h Cycle 71h CyrJe Y� r' aes ,a�a� orme w,al al��rrm�rr����r y 11 A Total Permits emcde r..d YayL— WTLm% L— L—% nmd.— M.1—% Ah—Wd— Ab­Md.-% Tway 3 01152a21-10n52'OLB 906 R3% 392 11.5% s 17.4% to 91BK 3,13T TiTod Y01Y5l�0�T-1W15f2rF19 06 Y9.394 362 11.5% 545 17.49L 1,LR4 51.8!li 3,Y31 Progress FIGURE 2: HCD APR DATA DASHBOARD (SHEET 13 OF 18) Housing Element Implementation and APR Data Dashboard A^ Navigation Key Figures Construction Housing Needs Implementation User Guide Suhmd Peadi Needs Regional Housing Needs Allocation: Permits by Affordability o a 5th Cycle 6th Cycle Total Permits Permits by Affordability Very Low Income Very Lw Ino me.ow lnwma n4oda a e rn�a a Abava Mode a e l came 303 606 50.00/c 611,Cycle Permils 6th Cycle RHNA %Attained 2l Progress LOW Income 296 362 81.8% OK 2r22 2023 2924 Min Cycle Fermi6th Cycle RHNA %Attained Y­ Moderate Income Permits by Jurisdiction 190 545 34.9% County Voy Low Inoonle•Low Inoome OlVaderate Income Ahave Moderate 61h Cycle Permils 6th Cycle RHNA %Attained All Above Moderate Income Jurisdiction 2,918 1,624 179.7% Sanla Ana v 611,Cycle Pemdl 6th Cycle RHNA %Attained Sama Ana .� CQGIRe9ion 37 50% All v %through Cycle 10115/2021 10/1512029 Clear Filters GK 1 K 2K 3K 1K Starl Dale End Bake As shown above,while the City has already achieved its non-affordable RHNA goals (i.e., above moderate-income),it still appears to have significant unmet affordable RHNA goals (i.e., moderate-income and lower). In light of being roughly halfway through the current 61h cycle (i.e., ending October 2029), the City is arguably missing an opportunity to encourage affordable housing units at the Proiect Site (relevant to housing element policies discussed below). Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 5 of 17 2. THE SEIR MAY NOT ADEQUATELY CONSIDER POTENTIAL INCONSISTENCIES WITH APPLICABLE GENERAL PLAN POLICIES The SEIR suggests the Village Specific Plan and Project is consistent or would have no conflict with various land use plans,goals, and policies under the General Plan. (See e.g., SEIR, PDF pp. 212, 371,425 [City Land Use Element Policies LU-1.5, 2.5], PDF pp. 425-426 [City Housing Element Goals 1,4, 5 and Policies HE-4.1, 4.2,and 5.6].) However, as discussed above,the Village Specific Plan may result in solely market-rate residential units without a single affordable unit despite the compelling need for affordable units.This could be inconsistent with a variety of General Plan measures, such as those listed below: General Land Use Element(emphasis added 1z • POLICY LU-1.2 HOMEOWNERSHIP OPPORTUNITIES: Support innovative development policies to expand homeownership opportunities at all income levels. • POLICY LU-1.5 DIVERSE HOUSING TYPES: Incentivize quality infill residential development that provides a diversity of housing types and accommodates all income levels and age groups • POLICY LU-2.5 BENEFITS OF MIXED-USE: Encourage infill mixed-use development at all ranges of affordabilitX to reduce vehicle miles traveled, improve jobs/housing balance, and promote social interaction. • POLICY LU-4.6 HEALTHY LIVING CONDITIONS: Support diverse and innovative housing types that improve living conditions and promote a healthy environment. • POLICY LU-4.7 DIVERSE COMMUNITIES: Promote mixed-income developments with mixed housing es to create inclusive communities and economically diverse neighborhoods. Housing Element (emphasis added 13 • GOAL HE-1 HOUSING AND NEIGHBORHOODS: Livable and affordable neighborhoods with healthy and safehousing conditions,community services,well-maintained infrastructure, and public facilities that inspire neighborhood pride and ownership. • GOAL HE-2: HOUSING SUPPLY AND DIVERSITY.• Foster an inclusive community with a diversity of quality housing, affordability levels, and living experiences that accommodate Santa Ana's residents and workforce of all household types, income levels, and age groups. • POLICY HE-2.1 CITYWIDE: Designate adequate land in the General Plan Land Use Element and Zoning for the development of a range of housing types to meet the identified needs of all economic segments of the community while providing a high quality of life for all residents. • POLICY HE-2.4 RENTAL HOUSING: Facilitate the construction of rental housing for Santa Ana's residents and workforce,with a commitment to provide rental housing for extremely low-, very low-, and low-income residents as well as moderate-income Santa Ana workers. • POLICY HE-2.5 DIVERSE HOUSING TYPES: Facilitate diverse types, prices,and sizes of housing,including single-family homes,apartments,townhomes, duplexes,mixed/multiuse housing,transit-oriented housing,multigenerational housing,accessory dwelling units, and live-work opportunities. 11 See gen.,Santa Ana General Plan,Elements,https://general-plan-santa-ana- ca.proudcity.com/agencies/elements/. 12 See City Land Use Element,PDF pp. 10-11,https://storage.googleapis.com/proudcity/ generalplansantaanaca/uploads/2023/02/Vol03_LandUse_April2022_compressed-2.pdf. 13 See City Housing Element,PDF pp. 10-18,https://storage.googleapis.com/proudcity/ generalplansantaanaca/uploads/2023/02/Housing_Element_Excerpt.pdf. �­1 Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 6 of 17 • POLICY HE-2.7 AFFORDABLE COMPONENT: Pursuant to the Affordable Housing Opportunity and Creation Ordinance (AHOCO), require eligible rental and ownership housing projects to include at least 15 percent of the rental housing units as affordable for low-income households,- or 10 percent of the rental units affordable to very low-income households; or 5 percent of rental units affordable to lower income households(5 percent to low-income, 3 percent to very low-income, and 2 percent to extremely low-income households); or at least 5 percent of the units ineligible ownership projects affordable to moderate-income households. Implement various strategies using the in-lieu fees generated by AHOCO to provide a wide array of affordable housing options. • GOAL HE-4 SPECIAL NEEDS: Provide sufficient rental and ownership housing opportunities and supportive services for seniors, people with disabilities, families with children, and people experiencing homelessness. • POLICY HE-4.1 SENIOR HOUSING: Support development of affordable senior rental and ownership housing,readily accessible to support services; provide assistance for seniors to maintain and repair their homes to facilitate the maximum independent living. • POLICY HE-4.2 FAMILY HOUSING: Facilitate and encourage the development of larger rental and ownership units for large families,including extremely low-, very low-, and low-income families as well as the provision of childcare, after-school care, and other services on-site when feasible. • POLICY HE-5.6 PRESERVE HOUSING Seek to preserve housing opportunities for all residents through actions aimed at limiting displacement, preserving affordable housing, and expanding Economic Prosperity Element(emphasis added :14 • POLICY EP-3.4 COMPLETE COMMUNITIES: Encourage the development of"complete communities"that provide a range of housing,services, amenities, and transportation options to support the retention and attraction of a skilled workforce and employment base. 3. THE SEIR MAY NOT ADEQUATELY CONSIDER POTENTIAL INCONSISTENCIES WITH APPLICABLE SCAG RTP/SCS COMMUNITY POLICIES The SEIR suggests the Village Specific Plan and Project is consistent with the SEIR,which cites goals/policies from the Southern California Association of Governments ("SCAG") 2020-2045 Regional Transportation Plan/Sustainable Community Strategy("RTP/SCS"or"Connect SoCal"). (See e.g., SEIR, PDF pp. 266, 327-328, 347-349, 351 [SCAG RTP/SCS Goal 9 and Strategy-Promote Diverse Housing Choices].) However, as noted in the SEIR, SCAG has adopted its 2024-2050 RTP/SCS. (Id., at PDF pp. 129, 245, 584.) The 2024 RTP/SCS15 has four primary goals (i.e.,mobility, communities,environment, economy) (pp. 9-12),each with respective subgoals (p. 85) and categories of policies (pp. 88-112),which totals nearly 90 regional planning policies (pp. 114-121), and other implementation strategies where local governments play a partner/supporting role (pp. 124-135). Providing affordable and sustainable housing is a major cross-cutting theme in the 2024 RTP/SCS (pp. 8,9, 10, 27, 28, 54, 56, 66, 100, 106, 112, 117, 135, 193, 197).As discussed above,the Village Specific Plan may result in solely market-rate residential units without a single affordable unit built onsite within the plan area, despite the compelling need for affordable units. This could be inconsistent with a variety of 2024 RTP/SCS Community provisions,such as those listed below: 14 See City Economic Prosperity Element,PDF pp.8-15,https://general-plan-santa-ana- ca.proudcity.com/documents/e conomic-prosperity/. 15 See 2024 RTP/SCS,https://scag.ca.gov/sites/default/files/2024-05/23-2987-connect-socal-2024-final- complete-040424.pdf. Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 7 of 17 Goal: • Develop, connect and sustain communities . • • thriving • Sub-goal: Create human-centered communities in urban,suburban and rural settings to increase mobility options and reduce travel distances • Sub-goal: •• • preserve diverse housing types in an effortto iml2rove affordabiliV accessibility • opportunities f•r all household Category: Housing the Region: Providing sufficient housing opportunities throughout the region will require a range of strategies and methods to increase both the production of and access to a wide range of housing es. Regional Planning Policies: 35. Encourage housing development in areas with access to important resources and amenities (economic,educational,health,social and similar)to further fair housing access and equity across the region 36. Encourage housing development in transit-supportive and walkable areas to create more interconnected and resilient communities 37. Support local,regional, state and federal efforts to produce and preserve affordable housing while meeting additional housing needs across the region 38. Prioritize communities that are vulnerable to displacement pressures by supporting community stabilization and increasing access to housing that meets the needs of the region 39. Promote innovative strategies and partnerships to increase homeownership opportunities across the region with an emphasis on communities that have been historically impacted by redlining and other systemic barriers to homeownership for people of color and other marginalized groups 40.Advocate for and support programs that emphasize reducing housing cost burden (for renters and homeowners),with a focus on the communities with the greatest needs and vulnerabilities 41. Support efforts to increase housing and services for people experiencing homelessness across the region Communities Implementation Strategies: • Support Provide technical assistance for jurisdictions to complete and implement their housing elements and support local governments and Tribal Entities to advance housing production • Identify and pursue partnerships at the local,regional, state and federal levels to align utility, transit and infrastructure investments with housing development and equitable outcomes across the region • Research and explore innovative homeownership models that can reduce costs and increase housing production in the region. Explore strategies to engage households of color and communities that are underrepresented as homeowners • Research community stabilization (anti-displacement) resources that can be utilized to address displacement pressures, such as preservation and tenant protections for communities across the region and Affirmatively Further Fair Housing B. No HOTEL USE HAS BEEN CONTEMPLATED FOR THE PROJECT SITE The Village Specific Plan (i.e., SP-6) allows by-right hotels. (See SP-6, p. 74 [Tbl. 4-1].) However, as discussed below,there seems to be: (i) no indication that a specific hotel is anticipated by the Project applicant(infra section 13.1); (ii)there is no existing hotel or vested right to a hotel use on the Project Site (infra section 13.1); (iii) the SEIR did not analyze a specific hotel use (infra section 13.2); and (iv)the SEIR and SP-6 did not consider robust TDM measures that have the co- Local 11 Comments RE:Village Santa Ana Specific Plan September 8,2025 Page 8 of 17 benefit of reducing impacts caused by mobile emissions (infra section 13.3).Under the circumstances,to allow hotel uses may amount to an improper project description under CEQA.16 1. IT SEEMS THAT THE CURRENT PROJECT DOES NOTINCLUDE A HOTEL AND THE PROJECT SITE HAS NO VESTED RIGHTS TO HOTEL USES During the Planning Commission hearing, it was indicated that the Project currently does not include or anticipate a hotel component.17 According to the Planning Commission staff report, the Project Site is currently zoned Specific Development No.48 ("SD-48"),18 which was established in 1989 for the purposes of facilitating the development of the South Coast Plaza Village. (See PC Staff Report,pp. 2, 13.) SD-48 allows for a variety of commercial uses by-right(e.g., retail, office, restaurant,specialty market, salon,bank,fitness,schools, etc.) and others via a conditional use permit("CUP") (e.g.,live dance entertainment,alcoholic beverage sales). (See SD-48, Exh. B,p. 1 [Section 3].) Notably missing is any ability to operate a hotel by-right or conditionally.Additionally, the SEIR confirms that the Project Site is zoned SD-48 (see Draft SEIR,19 p. 3-4 [Tbl. 3-2]),but also that there are no existing hotel uses (see Figure 3 below). Hence,the Project Site has no vested right to a hotel use. FIGURE 3: CALEEMOD WORKSHEET OF EXISTING USES(DRAFT SEIR,APP-13,20 PDF PP.7-8) 1.2.Land Use Types Strip Mall 46.8 1000sgft 1.08 46,843 4,684 Assume 10% landscape area 6)40 Village Santa Ana Existing Detailed Report,1 11 912 024 Hard—elPaint Store 47.3 1000sgft 1.09 47,301 4,730 Furniture Store. Assume 10% landscape area High Turnover(Sit 456 11 0.10 4,560 456 — — Assume 1G% Dnwn Restaurant) landscape area General Office 24.0 1000sgft 0.55 24,000 2,400 — — Assume 10% Building landscape area Quality Restaurant 36.3 10cosgft 0.88 38,290 3,829 Assume 10% landscape area Movie Theater(No 18.4 10cosgft 0.42 18,362 1,836 Assume 10% Matinee) landscape area Parking Let 350 Acre 3.50 000 15,246 — — Assume 10% landscape area City Park 0.50 Acre 0.50 0.00 2,178 2,178 — Assume 10% landscape area 16 An accurate and complete project description is foundational to fulfilling CEQA's purpose,by providing the public and decision-makers with adequate information to provide a transparent impact assessment. (See e.g., San Joaquin Raptor Rescue Ctr.v.Cnty.of Merced(2007) 149 Cal.AppAth 645,654-55 [accurate stable project description is sine qua non of an informative and legally sufficient CEQA review]; Western Placer Citizens for an Agr, and Rural Env't v. Cnty,of Placer(2006) 144 Cal.AppAth 890,898.) 17 PC Video,supra fn.5,appx.3:23:18-3:23:40,3:29:36-3:30:00, 18 See SD-48 (Ord.No.NS-1997),https://storage.googleapis.com/proudcity/santaanaca/ uploads/2 022/04/SD_48.NS-1997.pdf. 19 See Draft SEIR(Apr.2025),https://storage.googleapis.com/proudcity/santaanaca/ 2025/04/VillageSantaAnaSpecificPlan_DSEIR_Apr2025_Compressed.pdf. 20 Draft SEIR,Appendix B(AQ/GHG Modeling Output),https://storage.googleapis.com/proudcity/ santaanaca/2 02 5/04/AppB_AQ_GHG_E_HRA_Modeling_Outputs.pdf. Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 9 of 17 2. THE SEIR DID NOTEVALUATE A SPECIFIC HOTEL USE During the Planning Commission hearing, Planning staff suggested that hotels were evaluated under the SEIR.21 However,the Draft SEIR project description looked at 1,583 residential units (encompassing approximately 1,850,000 square feet of building space),80,000 square feet of retail space, and 300,000 square feet of office space. (Draft SEIR,p. 1-3.).Nowhere was the hotel speci icall listed sted or mentioned.Nor does the SEIR's air quality/GHG emission modeling consider hotel uses.This can be verified by the CalEEMod worksheets,which do not identify any hotel uses during any of the phased construction or ultimate operations of the entire Village Specific Plan.22 (See Figure 4 below.) Similarly,neither the SEIR's VMT Study23 nor its Water Supply Assessment considers hotel uses.24 FIGURE 4: CALEEMOD WORKSHEET OF OPERATIONAL USES (DRAFT SEIR.APP-13.25 PDF PP. 7-81 1.2.Land Use Types Apartments Mid Rise 1.583 Dwelling Unit 13.6 1,85D100D 185,000 — 4,717 — 6135 Village Santa Ana Operation Detailed Report,1/3112024 Strip Mall so 1D60sgft 0.00 80,c00 8,000 General Office 30c 1000sgft 0.00 300,000 30,000 — Building Llnenclosed Parking 3,278 Space 000 794,317 0_00 with El—.1 City Park 3.6c Acre 3.60 0.0c 15,680 15;680 — — 21 PC Video,supra fn.5,appx.3:24:58-3:25:10 ("This specific plan has been evaluated for its impact,Right?So the specific plan would not say for example,that residential is allowed without residential being evaluated by the environmental impact report.So similar concept here.") 22 See Draft SEIR,Appendix B,PDF pp.7-8(existing),47-48 (Phase 1 construction),p. 106 (Phase 2 construction),p.153 (Phase 3 construction),pp.200-201 (Phase 4 construction),pp.254-255 (Phase 5 construction),pp.308-309(Operational),https://storage.googleapis.com/proudcity/santaanaca/ 2 02 5/04/AppB_AQ_GHG_E_HRA_Modeling_Outputs.pdf. 23 See Draft SEIR,Appendix H,VMT Screening Assessment,pp.2,9 (tbl. 1),p.10 (Tbl.2), https://storage.googleapis.com/proudcity/santaanaca/2025/04/AppH_VMT_Screening_Assessment.pdf. 24 See Draft SEIR,Appendix J(Water Supply Assessment),pp.2,9-10(Tbls.1 &2), https://storage.googleapis.com/proudcity/santaanaca/2025/04/AppJ_Water_Supply_Assessment.pdf. 25 Draft SEIR,Appendix B (AQ/GHG Modeling Output),https://storage.googleapis.com/proudcity/ santaanaca/2 02 5/04/AppB_AQGHG_E_HRA_Modeling_Outputs.pdf. Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 10 of 17 3. THE SEIR AND VILLAGE SPECIFIC PLAN DID NOTCONSIDER ROBUST TDM MEASURES THAT HAVE THE Co-BENEFIT OF REDUCING VMTs,GHGs,AND OTHER AIR EMISSIONS Furthermore,while the Village Specific Plan may require a TDM plan to be reviewed and approved in the future (SP-6, p.83 [Tbl. 4-3, note 1]),it is not tethered to any environmental analysis and does not require any performance metrics to guide future decision making. Furthermore,it does not mandate consideration of a full range of TDM strategies and other sustainability measures which may be warranted,such as those measures attached hereto as Exhibit B that are recommended by public agencies like the California Air Pollution Control Officers Association ("CAPCOA"),the SCAG, and the California Air Resources Board ("CARB"). (See Exhibit B, Figs. 1 through 3 [respectively].) C. UNDER THE CIRCUMSTANCES,ALLOWING BY-RIGHT HOTELS(INCLUDING EXTENDED-STAYS) WOULD SEEM TO BE UNPRECEDENTED UNDER THE CITY'S ZONING CODE,SDS,SPS,AND OVERLAY Under the proposed Village Specific Plan(i.e.,SP-6),hotel use is generically listed under "Commercial/Retail/Office"uses as by-right use,including extended stay hotels. (See Figure 5 below.) During the Planning Commission hearing,Planning staff suggested that allowing hotels by right would not be an outlier or unprecedented,citing MacArthur Place (i.e.,SD-43),Transit Zoning Code (i.e.,SD-84),and a unspecified reference to elsewhere in the City.26 However, as discussed above,the Project may allow zero affordable units (supra subsection A); nor is a specific hotel project currently anticipated,existing,vested, or analyzed in the SEIR(supra subsection B). Additionally, as discussed below,it seems: (i)the City's Zoning Code does not allow by-right hotel uses, including extended-stay hotels (infra section C.1); (ii) the Village Specific Plan is distinguishable from MacArthur Place and the Transit Zone,which explicitly contemplated hotel uses or excluded by-right extended-stays (infra section C.2); (iii) the Project is also distinguishable from the rare handful of specific developments that even mention hotel use (e.g.,outdated, existing/vested right to hotel, contemplated specific hotel project,required CUPS,etc.) (infra section C.2); (iv)the Specific Plan is distinguishable from the City's five (5) other Specific Plans ("SP(s)") and one overlay zone,which either does not allow by-right hotels and/or extended stay hotels (i.e., SP-1,SP-2, SP-3) or allows hotels uses because there was either an existing hotel use,a vested right,and/or specifically contemplated a hotel project that was considered in the CEQA document(i.e.,SP-5, MEMU Overly) (infra section C.3). Under the circumstance, allowing by-right hotels without any specific hotel project contemplated and/or analyzed,seems to be unprecedented for the City. 26 See PC Video,supra fn.5,appx.3:22:24-3:22:48 ("MacArthur Place specific development that's SD number 43,Maine and MacArthur allows hotels by right and I believe,as you were alluding to,the transit zoning code actually does allow hotels by right in um all of the subzones where they're allowed.So there is precedence for allowing them administratively."); Id.,appx. 3:25:36-3:25:49 ("Given the precedence that I mentioned earlier with the transit zoning code,SD43 and any other areas.where hotels are already allowed administratively, this would not be breaking new ground policy-wise either.") Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 11 of 17 FIGURE 5:VILLAGE SPECIFIC PLAN EXCERPT(SP-6,P.741 PermitType • .ht Notes/ReferenceLUC=Land Use Certificate • alklse permit Includes extended stay,executive suites,and guest suites.Commercial, Hotel Ps day spa,and foodfalcohol service are Permitted incidental to the hotel u se_ Rooftop amenities,including dining are also permitted. 1. THE CITY'S GENERAL ZONING DISTRICTS DO NOT ALLOW BY-RIGHT HOTELS,AND REQUIRE CUPS FOR EXTENDED-STAY HOTELS FOR NEARLY 25 YEARS The City lists various zones under its Zoning Code.27 Generally,the Zoning Code defines a hotel/motel as more than five (5) guest rooms,28 with hotels containing kitchens considered long- term stay business hotels (referred to herein as"extended-stay"),29 and hotels used as a primary residence considered as transient/residential hotels.30 As shown in the table below,hotels are either not permitted("N") or require a conditional use permit("CUP").Additionally, CUPS are 27 See City,Zoning documents,https://www.santa-ana.org/zoning-documents/. 28 See SAMC§41-77 (emphasis added): "A hotel/motel is any building,or portion of a building,other than a care home,which is designed,occupied,used or intended to be used,rented or hired out as temporary or overnight accommodations for tourists or transients.Such hotel/motel shall contain more than�ve a)guest rooms.A hotel/motel that contains a kitchen(as defined in section 310.7(3)of the California Building Code) in guest rooms shall be deemed to be a long-term stay business hotel.A hotel/motel that meets the criteria of section 41-139 of this Code shall be deemed to be a transient/residential hotel.") 29 See SAMC§41-54(emphasis added): "A long-term stay business hotel is a hotel/motel which is designed and operated to primarily accommodate business travelers whose guest stays vary in general from one 1 week to a month or more.Any hotel/motel that contains a kitchen in guest rooms shall be considered a long- term stay business hotel.No long-term stay business hotel may be established in the city after lulu 1,2001 except as permitted by a SP C�pecific Plan)or SD (Specific Development)district and then only as a conditional use. Long-term stay business hotels shall not include transient/residential hotels.")see also SAMC§41-103.5 (same). 31 See SAMC§41-139 (emphasis added): "A transient/residential hotel differs from a hotel/motel in that, while guests at a hotel/motel have another,primary residence,the guests at a transient/residential hotel utilize it as their primary residence(for purposes of this section the term"primary residence"shall have the same definition as under California Health&Safety Code section 50519(b)(1)).Any hotel/motel that rents, lets or otherwise provides for compensation,twenty-five (25)per cent or more of the total number of rooms therein to any person,firm,partnership,corporation,association,or other business entity for occupancy which exceeds twenty-eight(28)consecutive days or twenty-eight(28)days in any 60-day consecutive period shall be deemed to be a transient/residential hotel.No transient/residential hotel may be established in the city after June 7 1999 unless: [¶] (1) It was existing on June 7,1999;and [¶(2)It is permitted by a SP (Specific Plan)or SD(S is Development)district and then only as a conditional use.");see also SAMC§41- 161.5 (same). Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 12 of 17 required for all extended-stay hotels(since 2001) and transient/residential hotels (since 1999).31 Hence, by-right hotels are an outlier under the Citv'sgeneral zoning rules. ZONE USE SAMC Al Zone (Agriculture) sec 41-200 et se N §41-200 et seg. C1 Zone (Community Commercial CUP §41-365.5 c C1-MD (Community Commercial Museum District CUP §41-375.2 c C2 Zone General Commercial CUP §41-377.5 a C4 Zone Planned Shopping Center CUP §41-412.5 C5 Zone Arterial Commercial CUP §41-424.5 a CR Zone Commercial Residential CUP §41-442.5 a CSM Zone Commercial South Main CUP §41-522 c GC Government Center N §41-343 et seg. M1 Zone (Light Industrial N §41-471 et seg. M2 Zone (Heavy Industrial N §41-489 et seg. 0 Zone (Open Space) N §41-582 et seg. P Zone Professional N §41-312 et seg. R1 Zone (Single Family Residential N §41-231 et seg. R2 Zone (Two-Family Residential N §41-246 et seg. R3 Zone (Multiple-Famil Residential N §41-258 et seg. R4 Zone Suburban Apartment) N §41-290 et seg. RE Zone Residential Estate N §41-216 et seg. 2. THE PROJECT IS DISTINGUISHABLE FROM MACARTHUR PLACE,TRANSIT ZONING CODE,AND THE OTHER SPECIFIC DEVELOPMENTS LISTED BY THE CITY The City lists nearly 100 other Specific Developments ("SD"), including the aforementioned SD-43 (i.e., MacArthur Place) and SD 84 (i.e.,Transit Zoning Code).32 However, as discussed above, the Village Specific Plan (i.e., SP-6) allows by-right hotels (including extended-stays),where it has no vested rights and where no specific hotel project was considered under CEQA.This makes the Village Specific Plan unprecedented and/or an outlier compared to the other SDs, considering the following: First, MacArthur Place District Center (i.e., SD-43) was adopted in 2012, explicitly contemplated a hotel,33 and was seemingly subject to multiple EIRs that also explicitly anticipated a hotel use.34 Hence,SD-43 and its underlying CEQA reviews explicitly contemplated hotel uses(i.e., unlike the Village Specific Plan that does not consider a specific hotel in the plan or CEQA review). 31 Supra fn.28,29. 32 City,Specific Development List,https://www.santa-ana.org/specific-development-list/;see also City of Santa Ana Zoning Map (11/14/24),https://storage.googleapis.com/proudcity/santaanaca/2023/12/2.- Zoning-FULL-CITY-2024-11-14-24.pdf. 33 SD-43/(4/16/12) PDF p. 1 (council action showing date),p.8, (explicitly included office/hotel conversion rates for square footage),p. 11 (purpose/intent of the SD was to provide"hotel service"),https://storage. googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_43-Without-a//ttachments-2012.pdf. 34 Ibid.,at PDF pp.5,8, 15 (referencing EIR);see also CEQAnet(SCH No. 1987042909) Main Street/MacArthur Boulevard Intersection Improvement Project(Document description stating(emphasis added): "At ultimate buildout,the proposed project would include 4,051,000 sq ft of office-commercial uses,including one or two hotels.the total floor are office/retail/hotel component is 1.5:1.0.additionally,400 multi-family dwelling units Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 13 of 17 Second,the Transit Zoning Code (i.e.,SD-84) (SAMC 41-2000 et seq.) was adopted in 2010 and subsequently amended twice (i.e.,most recently in June 2025).35 SD-84 covers portions of the City's central urban core (i.e., 100+blocks and 450 acres),36 which is broken into eight districts, which hotel's by right in only four of the districts (e.g.,TV,DT,UC, CDR). (See SAMC §§41-2006(b) [Fig. 2.1], 41-2007(a) [Tbl. 2A].) However, SD-84 explicitly excludes extended-stay hotels. (Id.,Tbl. 2A.) Hence,SD-84 explicitly disallows extended-stay hotels(i.e.,unlike the Village Specific Plan that allows by-right extended-stay hotel use). Third,based on the other nearly 100 SDs reviewed,the Village Specific Plan is unlike the rare instances where hotel uses are mentioned in the SD, as discussed below: • SD-8 (i.e., Brookhollow Office Park, 1977) allows hotel uses in Zone II. (SD-8,37 pp. 3, 8.), which is arguably an outdated zoning approval (i.e.,48 years old).Additionally,based on the proposed plans (id., at PDF p. 10) and aerial imagery,38 the approximately 5.5-acre property does not seem to have ever been developed as a hotel,which suggests allowing hotel uses was merely an oversight. Hence,SD-8 is an outdated development approval that permits hotel as a by-right use as an apparent oversight(i.e.,unlike the Village Specific Plan that can remove ambiguity and cure potential ambiguity). • SD-12 (1978 / 1982) was initially adopted in 1978,which did not allow hotel uses. (SD-12,39 PDF pp. 2, 8.) In 1982, SD-12 was amended to allow a variety of other uses, including hotels and motels (id., at PDF p. 3),which the approximately 20.5-acre site was ultimately developed with multiple hotels (based on aerial imagery) shortly after the approval.40 Hence,SD-12 permits hotel uses by-right because it seems that it specifically anticipated specific hotel uses on that site (i.e.,unlike the Village Specific Plan that does not contemplate hotel uses on the site)]. will be incorporated in the proposed project."),https://ceganet.Ici.ca.gov/1987042909;CEQAnet(SCH No. 2004061140) MacArthur Place South(Document description stating(emphasis added): 'The proposed project involves the development of three 25-story residential towers,a three-building 5&6 story condominium development,a 5&6 story office and residential loft development and associated retail and restaurant uses.The project would include the demolition of 47,000 sq.ft.of existing land uses and associated parking facilities and the relinquishing of approved entitlements for a 162-room hotel.") 35 SD-84(6/21/2010),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_84.NS- 2803.TransitZoningCodel.pdf,see also TZC,Table of Contents,PDF p. 1, https://storage.googleapis.com/proudcity/santaanaca/2025/07/Cover-and-ToC.pdf. 36 City(6/3/25) Item 24 Staff Report,p.3,https://santa-ana.primegov.com/api/compile meetingattachmenthistory/historyattachment/?historyld=72aab686-cde9-44cb-9461-43d42525d52f. 37 SD-8(11/14/77),https://storage.googleapis.com/proudcity/ santaanaca/uploads/2022/04/SD_8_1360.pdf. 38 Compare Google Earth aerial images (6/1/94)with(5/8/25). 39 SD-12 (8/16/82),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_12.NS- 1645.pdf. 41 Compare Google Earth arial images (6/1/94)with(5/8/25);City Property Records, 1325 E.Dyer(land use certificates issued for Embassy Suites Hotel in 1985);OC Register(7/13/13)The sweet history of Irvine's Holly Sugar Plant(noting former Holly Sugar Plant razed in 1983); Business Traveler News,Embassy Suites Santa Ana(noting hotel constructed in 1985). Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 14 of 17 • SD-64 (i.e., Candlewood Hotel Company, 1998) explicitly anticipated a 123-room extended- stay hotel (SD-64,41 PDF p. 7),which was ultimately built by 2002 (based on aerial imagery).42 Hence,SD-64 logically permits hotel uses by-right because it contemplated a specific hotel project(i.e.,unlike the Village Specific Plan that does not consider a particular hotel project). • SD-69 (PacifiCenter, 1999) allows by-right hotel uses within Project Area 1. (SD-69,43 PDF pp. 7, 16.) However,that site was partially subject to previously approved SD-56 (id., at PDF p. 2, 3,4),which was a 1990 approval that contemplated a potential Santa Ana sports arena subject to a specific development agreement(TA") and EIR. (See SD-56,44 PDF pp. 2-3, 6-7, 14, 22.) Nevertheless,SD-69 contemplated additional environmental documentation and potential discretionary review depending on the level of floor-area-ratio ("FAR") of the development proposed.45 Furthermore (based on aerial imagery),the approximately 15.5- acre site was undeveloped until after the SD-69 was approved,which was ultimately developed by 2003 as the site current exists today with no hotel, a large Home Depot, and several restaurants (i.e.,Jack in the Box, IHOP, El Pollo Loco).46 Hence,SD-691SD-56 is an outdated development approval(i.e.,26135,years old) that permits hotel uses by-right as an apparent oversight or legacy of an older EIRIDA approval, but nevertheless contemplated future CEQA review (i.e.,unlike the Village Specific Plan that has no vested rights to hotel use and provides no future CEQA review for a potential hotel). • SD-76 (i.e., Hutton Centre, 2005) allows hotels within Zone 1 via a CUP. (SD-76,47 PDF pp. 3, 10.)Additionally,the Plans show that the hotel within Zone 1 already existed in 2005 (id.,at PDF p. 16) and the structure was built by at least 1994 (based on aerial imagery).48 Hence, SD-76 does not permit by-right hotel use even when there are existing hotel uses on site (i.e., unlike the Village Specific Plan that has no existing hotel uses). 41 SD-84(5/4/98),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_64.NS- 2347.pdf. 42 Compare Google Earth arial images(6/1/94)with(6/5/02)and(5/8/25). 43 SD-69 (8/16/99),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_69.NS- 2399.PacifiCenter.pdf. 44 SD-56(4/16/90),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_56.NS- 2060.pdf. 45 Compare SD-69,PDF p. 5 section I.D ("Any construction on a parcel that results in a development intensity less than 0.45 floor area ratio may require technical studies and infrastructure improvements that will be determined through the City's site plan review process."Emphasis added)with section I.E ("Any construction on a parcel that results in a development intensity above a 0.45 floor area ratio will require a General Plan Amendment an amendment to the Specific Development Plan,the appropriate environmental analysis, CEQA documentation and infrastructure improvements as determined through the City's site plan review process."Emphasis added). 46 Compare Google Earth arial images(6/1/94)with(4/17/03)and(5/8/25). 47 SD(7/5/05),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_76-Updated- 05-01.pdf. 41 Compare Google Earth arial images(6/1/94)with(10/23/07)and(5/8/25). Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 15 of 17 • SD-92 (i.e.,Tiny Tim Plaza, 2018) allows hotels via a CUP. (SD-92,49 PDF p. 7 [incorporating C2 Zone conditional uses,which in turn incorporates C1 Zone conditional uses]; see also SAMC§§ 377.5(a), 41-365.5(c).) The Project was intended for a 51-unit affordable rental project(id., at PDF p. 2),which seems to have been ultimately developed by 2021 (based on aerial imagery).50 Hence,SD-92 does not permit by-right hotel uses even when the development includes affordable housing units(i.e.,unlike the Village Specific Plan that does not require a single affordable housing unit). 3. THE PROJECT IS DISTINGUISHABLE FROM THE CITY'S OTHER SPECIFIC PLANS AND OVERLAY ZONE The City lists five Specific Plans ("SP(s)") and one overlay zone.51 Under the circumstances, the Village Specific Plan (i.e.,SP-6) is unlike any of these five SPs or one overlay zone: • The Bristol Street Corridor Specific Plan(i.e.,SP-1) has four land use districts,including Commercial,that correspond to the C-5 Zone. (SP-1,52 p. 19.)As discussed above,the C-5 Zone allows hotels via a CUP. Hence,SP-1 does not allow by-right hotels(i.e.,unlike the Village Specific Plan). • The Harbor Mixed Use Transit Corridor Specific Plan(i.e.,SP-2) includes four land use districts,which allow hotels by right(but excluding transient and extended stays) in the Transit Node and Corridor,but do not permit them in other districts. (SP-2,53 pp. 3-2 - 3-3 [Fig. 3-1,Tbl. 3-2].) Hence,SP-2 does not allow by-right extended stays nor lumps them in with commercial, retail, and office into a single category of permitted uses(i.e.,unlike the Village Specific Plan). • The Midtown Specific Plan (i.e., SP-3) includes five land use districts (SP-3,54 pp. 22 [Exh. 7]),where hotels are not listed as a use either permitted by-right or via a CUP (id.,at pp. 29 [Civic/Professional District], 42-43 [Financial District], 57 [community and Specialty Retail District], 71 [Broadway Corridor District], 79 [Bush Street Professional District].) For Specific Plans,"[n]o use of property is permitted in the SP district except those uses stated in the applicable specific plan to be permitted uses or uses subject to the issuance of a conditional use permit." (SAMC §41-592.2.) Hence,SP-3 does not allow by-right hotels 55 (i.e.,unlike the Village Specific Plan). 49 SD(1/16/18),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/SD_92.NS- 2935.TinyTimPlaza.pdf. 50 Compare Google Earth arial images(10/3/95)and(3/30/18)with(2/21/21)and(5/8/25). 51 See City,Zoning documents,https://www.santa-ana.org/zoning-documents/. 52 See SP-1 (Mar.2018)Bristol Street Corridor Specific Plan,https://storage.googleapis.com/ proudcity/santaanaca/uploads/2022/03/BristolSpecificPlanAmendmentMarch2018cn.1.pdf. 53 See SP-2 (Oct.2014) Harbor Mixed Use Transit Corridor Specific Plan,https://storage.googleapis.com/ proudcity/santaanaca/uploads/2022/03/Full-Do cument-Harbor-Mixed-Use.pdf. 54 See SP-3 (Dec. 1996),https://storage.googleapis.com/proudcity/ santaanaca/uploads/2022/03/Midtown_Specific_Plan.pdf. 55 While SP-3 mentions a hotel option,it was subject to site plan review("SPR") (id.,at pp.29-30,38),which suggest it may be permitted via a discretionary approval.(See e.g.,SAMC§§41-2005(a).) Local 11 Comments RE.Village Santa Ana Specific Plan September 8,2025 Page 16 of 17 • The Main Place Specific Plan (i.e., SP-4) includes ten parcels,where hotel uses were anticipated (i.e., eight of the ten parcels) and allowed hotels by-right(including long-term stay). (SP-4,56 pp. 2-9 [Tbl. 2-2],p. 2-11 [Fig. 2-6],p. 3-4 [Tbl. 3-1].) However, SP-4 had a specific number of hotel rooms that were actually contemplated and analyzed in a prior EIR, with vested entitlements. (Id.,at p. ES-2 [Tbl. ES-1],pp. 1-7- 1-8 [§ 1.1.4],pp. 1-13 - 1-14 [Tbl. 1-1].) Hence,SP-4 permits by-right hotels because it had vested rights and specificallX contemplated a hotel use (i.e.,unlike the Village Specific Plan). • The Related California Bristol Specific Plan (i.e.,SP-5) includes 21 blocks split into two land use districts,where hotels (including long-term stay)are permitted by right. (SP-5,57 pp. 3- 7 - 3-9 [Tbl. 3-2, Figs. 3-1 - 3-2],p. 4-6 [Tbl. 4.1].) Hence,SP-5 contemplated a specific 250- room hotel(id.), which was analyzed in a prior EIR for various resources and impacts(e.g., traffic, air quality, GHG,water demand,solid waste, etc.)58 (i.e.,unlike the Village Specific Plan). • Under the Metro East Mixed-Use Overlay District Expansion("MEMU"),hotel use is either prohibited(in the Neighborhood Transitional District),allowed via a CUP (in Office District), or permitted by-right(in the Village Center and Active Urban). (See MEMU overly,59 PDF pp. 8, 9, 13.) However,the MEMU was initially adopted in 2007 (i.e., nearly 20 years ago),60 which covered 200+acres (i.e.,comprised of 73 parcels) that already included two motels (i.e.,approximately 180 rooms),61 and where the CEQA review explicitly anticipated future motel uses.62 Hence,MEMU partially allowed by-right hotel uses where it had existing motel uses and specifically analyzed the use under the CEQA review (i.e.,unlike the Village Specific Plan). 56 See SP-4(May 2019),https://storage.googleapis.com/proudcity/ santaanaca/uploads/2022/06/MainPlace-Specific-Plan-SP-4.pdf. 57 See SP-5 (Oct.2024)https://storage.googleapis.com/proudcity/santaanaca/2024/08/Final-Related- Bristol-Specific-Plan-October-2024-Compressed.pdf. 58 See Draft EIR(Jul 2023)SCH No.2020029087,PDF pp. 19,70,97-98,441,473,490,531,544, https://storage.googleapis.com/proudcity/santaanaca/uploads/2023/07/DEIR-Combined.pdf, Id.,Appendix 0(VMT Assessment),PDF p. 10 (Tbl. 1),https://storage.googleapis.com/proudcity/santaanaca/ uploads/2023/07/Appendix-O.-VMT-Assessment.pdf,Appendix P(Water Supply Assessment),PDF p.8(Tbl. 1),https://storage.googleapis.com/proudcity/santaanaca/uploads/2023/07/Appendix-P.-Water-Supply- Assessment.pdf,Id.,Appendix B(Air Quality Study),PDF pp.6,30,78,https://storage.googleapis.com/ proudcity/santaanaca/uploads/2023/07/Appendix-B.-Air-Quality-Analysis.pdf;Id.,Appendix I(GHG Study), PDF pp.5,29,63,https://storage.googleapis.com/proudcity/santaanaca/uploads/2023/07/Appendix-I.- GHG-Analysis.pdf. 59 MEMU(Aug.2018),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/05/Metro-East- Mixed-Use-Overlay-Zone.pdf. 60 City(7/23/18)Staff Report,PDF p.6 (executive summary),https://santa- ana.primegov.co m/meeting/attachment/8774.pdPname=STAFF%20 REPORT; 61 MEMO(Mar.2007)SCH No.2006031041,Draft EIR,Chapter 4,PDF p.70(section 4.3.1 Environmental Setting),https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/04/Chapter-4- Environmental-Setting-Impacts-and-Mitigation-Measures.pdf. 62 See e.g.,Ibid.,Appendix H(Traffic Study),PDF pp.54-56 (section 6.1.2,tbls. 11 &12),https://storage. googleapis.com/proudcity/santaanaca/uploads/2022/04/AppH_TrafficStudy.pdf,Appendix H(Water Supply Assessment),PDF pp.36-37,https://storage.googleapis.com/proudcity/santaanaca/uploads/2022/ 04/App I_WaterSupplyAssessment.p dE Local 11 Comments RE: Village Santa Ana Specific Plan September 8,2025 Page 17 of 17 CONCLUSION In closing, Local 11 thanks the City for the opportunity to provide these comments. For the reasons discussed above (and elsewhere in the administrative record),Local 11 respectfully requests that the City consider. 1. Removing hotel uses from the Village Specific Plan (via amendments attached hereto as Exhibit A); 2. Requiring some portion of the housing to be affordable and/or workforce housing; and 3. Implementing additional design features and mitigation measures (such as those measures attached hereto as Exhibit B). Local 11 reserves the right to supplement these comments at future hearings and proceedings for this Project. (See Galante Vineyards v.Monterey Peninsula Water Management Dist. (1997) 60 Cal.AppAth 1109, 1120 [CEQA litigation not limited only to claims made during EIR comment period].) To the extent not already on the notice list, please place this office on the notification list for all notices of CEQA actions and any approvals, Project CEQA determinations, or public hearings to be held on the Project under state or local law requiring local agencies to mail such notices to any person who has filed a written request for them. (See e.g., Pub. Res. Code §§ 21092.2, 21167(f) and Gov. Code § 65092.) Please send notice by electronic and regular mail to Jordan R. Sisson, Esq. Sincerely; ATTACHMENTS Exhibit A Proposed Amendment To Eliminate Hotel Uses63 Exhibit B: CAPCOA, SCAG, CARB Measures64 CC: bvazquez@santa-ana.org jlopez@santa-ana.org jryanhernandez@santa-ana.org tphan@santa-ana.org dpenaloza@santa-ana.org pbacerra@santa-ana.org vamezcua@santa-ana.org jmunoz@uniteherell.org 63 See also https://www.dropbox.com/scl/fi/7t3r699574nyrpjlrmu5r/Exh.-A_-Proposed- Amendment.docx?rlkey=e 1 e3 2 ggh2 rrtbydwot9wlb 6j 2&dl=0. 64 See also https://www.dropbox.com/scl/fi/lhmt4mhOgSbbc4g3vjhxf/Exh.-B_MM- Measures.pdPrlkey=c6n36vo8tll2krbczdr565uj 7&dl=0. EXHIBIT A Proposed Amendment to Specific Plan (additions shown in blue underline,deletions shown in ned ��, R): 4.1 Introduction This chapter establishes the land use and design regulations for development within the Plan area_These regulations include permitted uses,land-use density and intensity,building heights, e setbacks,parking requirements,open space,and building form standards.These regulations are consistent with and implement the applicable goals,policies,and requirements for the South Bristol Street Focus Area of the General Plan Land Use Element, I These development regulations should be used in conjunction y with Chapter S,Oesi_gn Gur deftncs,in the review and processing of subsequent development applications. f.r 4.2 Permitted lases This section establishes the permitted uses in the Plan area.Allowable uses a re listed in Table 4-1,Permitted Uses.Definitions of allowed land uses are provided in Appendix A of this Plan.Any use not listed in Table 4-1 shall be prohibited unless deemed to be similar to an l allowable use,as interpreted bythe Executive Director of the Planning and Building Agency or his/herdesig nee,except hotel use shall not be permitted within this Plan without an amendment r Chapter Four:Development Regulafons Page n all Table 4-1 Permitted Uses Permit F #:b. Right LUC=Land Use Certrfkate 17771"1 1 `- • 1 i Permit i' Live-work units P Either stand-alone residential building or in conjunction with commercial IMultifamilyapartmentsor P development.Allows for lea sing office or condominiums pro perty ma nage me nt office.recreation facilities,and other indoorloutdoor common areas_ Home occupations P Pursuant toSAMC Age restricted,independent living_ Seniorhousing P Subject to Section 4.2.4,Senior Housing and Care Facilities: • - Adult day care facilities P See SAMC for additional regulations_ Alcohol sales ton-site or off-site P*I CLIP Includes wine tasting,cocktail lounges. consumption) bars,and similar uses.Sege Appendix F Animal grooming and day-boarding P Art galleries„art studio,and P photography studios Brewery f Distillery P+.-,C JP On-site production and sales.See Appendix F. Childcarefacilities - Clublcommunityassemblyfacilit„es CUP See SAMC for additional regulations_ Congregate care = Subject to Section 4.2.4_ Continuum of care = Subject to Section 4.2.4. Convalescent facility P Subject to Section 4.2.4. Experiential museum and science , centers Gymnasiums,fitness,and health _ clubs ,u.it4_an,icp,est-suites Commercial w� are iHte 1. Page 74 1 The Village Santa Ana Speclfic Plan-August 2025 all Table 4-3 Parking Requirements Ratio(Minimum) Hn oR 6 key service,meeli ng spa— Office 3 spaces11,000 square feet Includes medical and dental. Residential 1.4 spaceslunit Includes guest parking. Retail„Restaurant,and Includes food and beverage Service Commercial 4 spacesll,CFCM( square feet service uses. Senior Care/Assisted Living 0-6 spaceslu nit Ind ud es e mployee pa rki ng. Residential Min im um of 10 bi cyc le I ocke r spa c es per May be located within garages. mu Itifa mi ly bu ild ing Retail and Service 59'aof required vehicle parking CalGreen 2022 (Long Term) Commercial Additional parking provisions: �} A parking management plan,approved Electric vehicle(EV)charging stations by the Planning Manager is required shall be provided in acco rd a nce wit h Title for shared,joint,orreciprocaI park]ng 24requirements- between uses or buildings,see Chapter Application of new technologies sha11 6,Section 6.2.&for modification be approved by the Executive Director authority and Appendix E,Par-king of the Planning and Building Agency ore Man agernent Pram. his#her designee per Chapter 6,Sec bon �} For rnixed-use buildings where ancillary 6_2.4_ commercial is provided#i_e_,services Parking stalls shall be as provided or small-scale food service of less than as required by the SnAMC,except as 2,500 square feet),the commercial provided below: component does not require parking. - Standard stalls:8.5'x 19' �} Paid parking is allowed_ = Compact stalls:7.5'x 16(single Parking lifts or automated parking is striped)85'x16'{double stripedI(up permitted subject to review as part of to 2D percent of total stallsI the Development Project Plan Approval process_See Chapter 6,Section 6.2.7. � Electric vehicle charging stations shall be provided on-site,consistent with City requirements. Chapter Four. [development Regulations I Page83 all Walls and fencing are allowed along the 4.6.3BuildingPIacerrientand northern edge of the property within the Form parkway of the North Connector- See Chapter 5, Design Guidelines,for the Four-sided arc hitecture shall be approved Village street tree,shrub,and implemented where feasible.All faces plant palette- of a building or parking structure(where visible}shall receive design treatment- 4.6. Ground-Floor Treatment With the exception of building sides and Activating Streets and Open facing Service Road, the sides of the Spaces buildings that do not face a public street or the Village.Square may All residential buildings shall have receivetargeted designtreatment, see ground-level entrance lobbies that open Chapter 5,Section 5.8,Parking Design, directly onto internal streets or publicly for additional parking structure design accessible open space- Building lobbies criteria- shall incorporate building amenities to )> Exposed parking structures shall be help activate the ground floor sc reened using architectural design and primary access paints to buildings or elements consistent to that of the rest of pedestrian spaces shall be clearly defined the building- using accent paving: signage, or other )> Screen trash enclosures and utility areas design details- with materials that are compatible in Residential lobbies shall be clearly vis ible color and finish with the Village buildings from surrounding street and drop- and landscape- off areas and s upport c o n nec ti n g the Rooftop mechanical equipment shall be building to the surrounding streets and screened from view from ground level. pedestrian areas- The aesthetics of all screening elements For commercial uses,ground-level shall be consistent with the architectural facades must have a minimum of 50 style, see also Chapter 5,Design percent of commercial windows to Guidelines. provide transparency,visual interest, and eyes on the Village Square- 4.6.4 Site Design Park'ing facades will have a50percent Commercial or hotel leading are as open facade for natural ventiIation or back-cif-house facilities shall be achieved via vertical fins,perforated screened from residential uses- metal, or similar to provide openness Pedestrian access into the Village shall while visually shielding the cars. be accommodated from the surrounding public roads either as sidewalks or paseos- X, Universal accessibility shall be implemented and prioritized for all public portions of the project. Page 88 1 The Village.Santa Ana Specific Plan -August 2025 EXHIBIT B Figure 1: CAPCOA Measures 1 Figure 3-1. Navigation Trees for Quantitotive GHG Reduction Measures Transportation LAND USE NEIGHBORHOOD DESIGN 0 T 1.Iricteose Residential Density O T-18 Provide Pedestrion Network Improvement 0 T-2.Inneaw Job Density 0 T-14-A.Construct or Improve Bike Fadlity Q T-3.Provide Transit,Oriented Development Q T-19,B.Construct or Improve Bike Boulevard 0 74.Integrate AffordabW and Below garket Rate Housing 0 T-20 Expand Bikeway Network 0 T•17.Improve Street Connectivity 0 T-21-A.Implement Conventional Carshore Program G 7•55.Infill Development Q T-21 B.implement Electric(arshore Program 0 T-22 A.implement Pedal Hon-Electnc)Bikeshare Program TRIP REDUCTION PROGRAMS O T-22-8.Implement Electric Bikeshate Program • T-S.Implement Commute Trip Reduction Program(Voluntary) 0 T-22-C Implement Srooterihore Program • T-6-Implement Commute Ttip Reduction Program{Mandatory 0 T-22-D Transition Conventional to BectrK Bikeshcre Implementation and Monitoring) a T-1.Implement Commute Trip Reduction Marketing TRANSIT • T-8 Provide Rideshoring Program 0 T-25 Extend.Transit Network Coverage of Hours O T-9 Implement Subsidized or Discounted Transit Program d T-26 Inuease Transit Service Frequency • T-lfl.Provide End-of-Trip Bkyde facilities Q T-27 Implement Transit-Supportive Roadway Treatments • T-11.Provide Employer-Sponsored Van* Q T-28 Provide Bus.Ropid Transit • T-12.Pr ce Workplace Parking 0 T-29 Reduce Transit Fares • T-13.Implement Employee Parking Cash-Out 0 T-M Provide Transit Shelters O 1-23.Provide Community-Based Travel Pionning CLEAN VEHICLES AND FUELS PARKING OR ROAD 0 T-30 Use CleanerfuelVehkles PRICING/MANAGEMENT • T-14.Provide Electric Vehicle Charging Infrastructure SCHOOL PROGRAMS • T-15.limit Residential Parking Supply Q T40 Establish a School Bins Program o T-16 Unbundle Residential Potking Costs from Property Cast 0 T-56 Aoive Modes of Transportation for Youth Q 1-24.Implement Market Price Public Parking(On-Street) CAPCOA(Dec.2021) Handbook for Analyzing GHG Reductions,Assessing Climate Vulnerabilities,and Advancing Health and Equity, pp. 31-32,47-51(listing measures https://www.caleemod.com/documents/handbook/fuII_handbook.pdf; id., pp. 52-60,84-417 (further describing each measure). Figure 1(Cont.) Lawn and Landscaping ENERGY EFFICIENCY IMPROVEMENTS 0 W-1 Use Reclaimed hbn-Phrahk Waver Q ll•l Regime Gas Powered Landscape Equrpmem 0 5-1 Insieute or Extend ReMling Q E•1-Buildings Exceed 2D19 Title 24 Building Envelope Energy Q W-2.Use Grey Wdor *nth iero•EmnsRan Landscape Equipment Services FfficienryStandards 0 W-3 Use Locality 5fevell Wow Suppty O S-2ImplemerniOrganirs d E•2-Require Energy EFkdem Appliances Diversion Program Q W-4.Requre Low.Flow Mfeter fixture Q E-3-A.Require Energy Efficient Residential$oilers 0 W-5,Design Warier•Efficieni Landscapes 0 S-3 Require Edible FDod © E-3-B-Require Energy Efficient(ommotod Pocko red Boiler Recovery Progrom Partnerships Q, W.S Reduce furl in Landscapes and Lawns with Food Generators * E4.Install Coal Rods andlor Cod Walls in Residential Development O W•7 Adopt o Waver(anservcnrOft 5traregy 0 E.5-Install Green Rosh in Place of Dark Roofs 0 E4 Encourage Residential Patuaperrae in Existing Demand Response Program(s) 0 E-7 Require Nigher Elfitacy Public Srreer and Area Lighting Natural and Working • o o Construction 0 E-ff Replace Incondesttnt Traff c Lights with LED traffic L ghn 0 E•9-Utilize a Combined Heat and Porter System Q N-1.(rears flew Vegetated Open Space 0 C.1-k.Use Ek it or Hybrid Powered Egwpment Q E•21,Instal]Caul Perement 0 N-2 Expand Ur bun Tree Planting 0 C-1-8 UseCeener-Fuel Equlpnnem RENEWABLE ENERGY GENERATION © N-3-implement Menagemenl Practices to Improve 1heHechfl 0 C-2.Llmh Heavy-bury EAese1 Whide Idling • E.104.Establish Onsste Renewable Energy Systems Genetic and Furx>ron of Natural and Working Lands 0 C-3.Use Local foastinrcrioe Conhaaars • E-I".Eualrirsh Onum Renexelile Energy Power O N-4,Require W Monogemenr Practices for Alma re Management 0 E-ID-C.Establish Ons se RenewableEoergy Systems—Wind Power O N-7 Wildfire Resilierxe and Alonogemenfi a E•11 Prmure EWrrcrty from Lower Carbon Inte"Power Supply a N-g.Agricultural Equ+pmem fHiciency 0 E•26.Biomass Energy BUILDING DECARBONIZATION Refrigerants Miscellaneous 0 E.12 Install Alternative"of Water Hearer in Plane of Gas IF Star op Tank Healer in Residences Cj E•13 ImraR Eleatic Ranges m Pfau of Gas Ranges 0 R-I.Use Afeernarire Refrigeranri Instead of High-GWP Refrigerants O M-1 Esrohlis6 a Carbon Sequestration Progert 0 E•14.Limit Wood B Roanim in Piece of as R of Go tie 0 R'2.Install Secondory Loop andlor Cauade Supermatker Srstems in 0 M-2 Establish Off m Mitigation 9 Po Platt of D+red Expansion Systems C] M-3.Im temenl an Innovatare Strategy far GNG Alrt os,on Fireplaces m Res iden ial Development P gl r9 C1 R 3.-GWI'Tifor rititol[CIr Supermarket Systems in PUare of M-6.Off-Road Equipment Effaian C] E-15 Require All-ElerMirDr�relopmera High•GWPSystec� 0 ' ry Q E-16 Require Zero Nor Energy Bull drngS 0 R-4.Install lticrachannel Had Exdwrsgon in W Equipment in Flare 0 E-17 Require Renewable-Surplus Buildings ol(onvennonal Heat Exchanger D R-5.Reduce Service leak Emissions METHANE RECOVERY 0 R-6.Reduce Opaotional Leak Emissions 0 E•1B Establish Mdtiane Recovery in Lon dfil6 Q R 7-Reduce Disposal Emissions 0 E•19.Establish Meifsone Recovery in Wastewater Treatment Plants Figure 1(Cont.) Table 3-1.Summary of Supporting or Non-Quantified GHG Reduction Aheasures and Descriptors Co-Benefits Em ❑ c _ ' o ❑ F n a w m ❑ C ❑ z, a- -0 OL a J- w w v U V7 m r7 �0 ❑ ❑ UC � w U � � � C c of O F Q) ❑ � � O ❑ ❑ o a irs ❑ � ❑ a a � # Measure Title an } W F _ w n Transportation (Land Use) T-31-A Locate Project in Area with High Destination Accessibility P/5 U,5 0 • 0 O # 0 O O O e T-31-13 Improve Destination Accessibility in Underserved Areas P/C U,5 0 • 0 C • f O O O 0 T-32 Orient Project Toward Transit,Bicycle,or Pedestrian Pf5 U,5,R=, 0 • 0 C f O O O C Facility R e,R T-33 Locate Project near Bike Patl-V ike Lane P/5 U,S • • • C i f O O O Design)Transportation fNeighborhood T-34 Provide Bike Parking All Al 0 • 0 C • s O O O C T-35 Provide Traffic CaIming Mmasures P/C Al • 49 0 C • f O O O C T-36 Create Urtwn plan-Motonzed hones P/C U ■ 49 ■ C • O O C C T-37 Dedicate'Land for Bike Trails P/C Al • ! • C • • O O O S Transportation Rfip Reduction Programs) T-3a Provide First and Last Mile TNC Incentives P/C U,5, R= • # • C # f O O O C T-39 Implement Preferential Parking Permit Program P/5 U,S ■ i ■ O f O O O 0 Figure 1(Cont.) Co-Benefits `o 5 U in m yy V } 7 Q L m ❑ a p w m w w w w - � m a -0 m ❑ ro ro m m o (} U En m m p ❑ m u C w a a as 0 m o ❑ ❑ ❑ ❑ p � a- m p s d a ❑ L L u # Measure Title to � E w j � w � E E 2 w w fn T-A1 Implement❑School Pool Program PIS All • • • O • • O O 0 e T-A2 Implement Telecommute and/or Atemative Work PIS Al e e e 0 e e O O 0 e Schedule Program T-A3 Provide Real-Time Transit Information PIC All • i • O • i O O O e T-AA Provide Shuttles(Gas or Electric) P/S U,S • • • O • • O O O e T-A5 Provide On-Demand Microtransit All U,S • • • O • • O O O e T-A7 Provide Bike Parking Near Transit PIC U,S Is • • O • • O O O e Transportation(Parking or Road Pricing/Monag-ement) T-AS Implement Area or Cordon Pricing PIC U • • • O • • O O O O T-49 Replace Traffic Controls with Roundabout PIC Al • i i O • • O O O O T-54 Required Project Contributions'to Transportation PIC Al • • • O • • O O O O Infrastructure Improvement T-51 Install Park-and-Ride Lots PIC S,R • • • O • • O O O e T-52 Designate Zero Emissions Delivery Zones PIC U • ! • O • • O O O e MEASURES TO REDUCE GHG EMISSIONS 49 Figure 1(Cont.) Co-Benefits C p U j 0 o en° 0 = m m in 0! —a SJ ii a m m m p r a- Q -0 U C� w 0Y w w w w Q O p -U -0 _U -0 a O _U U ti In 0 0 m m a s m of a a -o o 0 0 o U E p s a E m # Wleasure Title to ° �; > „ F E = w w tn Transporki-tion(Clean Vehicles and FLFPAS) T-53 Eleclri{y Loading Docks PIS Ail • • • O O O O • O _. T-5d Install Hydrogen Fueling Infrastructure All — • • O O O • O • O O Energy(Energy Efficiency lrnprcvements� E-20 Install Whole-House'Fans PIS — O • O 0 0 O O • O e E-22 Obtain Third-party HVAC Commissioning and PIS — O • O O O O O • O C Verification of Energy Savings Energy(Renewable Energy Generation) E-23 Use Microgrids and Energy Storage All — (D • O O O • O • O C E-24 Prcwide Battery Storage All — 0 • O O O • O • O C Energy(Building fa E-25 Install Electric Heat Pumps All — • • O O O • O E O O Lawn and Landscaping LL-2 Implement Yard Equipment Exchange Program PIS — • • ❑ O O • i • 0 G LL 3 Electric Yard Equipment Compatibility PIS — O O O O O • D 0 0 O MEASURES TO REDUCE GHG ENJSSIONS 49 Figure 1(Cont.) Ca-Benefiis r o u o m m _ m rn 0 0 m 3 V C O u m w m a- u V] m m m m w a a� Ca a as m O m O O a u o E c o r o E E m Jr r_ o # Measure Title to E w } � %w F E Ew w to S-Q Recycle Demolished Construction Material P/S — o • G O O 0 0 O 0 5-5 Source Wood Materials from Urban Wood Re-Use All — 0 a r a Q G • C © ❑ Progra m Natural cand Working Lands N-5 Establish a Local Farmers Market P/C — f 0 0 f 0 4 G * v N-6 Establish Community Gardens P/C — D G D 4 # • a • C C-d Use Local and Sustainable Building Materials All — 0 • # 0 0 O E O O G M-4 Require Environmentally Responsible Purchasing P/S — f7 G 'O C O O 0 G O O M-5 Fund Incentives for Green Technologies P/C — 0 C G C' C C' E G D O Sector abbreviations:T=transportation;E=energy;W=water;ILL= lawn and landscaping;5=solid waste;N=natural and working lands;C= construction;M= miscellaneous. Scale of application column abbreviations:P/S=Project/Site,P/C=Plan/Community;All. MEASURES TO REDUCE GHG EMISSIONS 50 Figure 1(Cont.) Figure 1(Cont.) Figure 1(Cont.) Figure 2: 2024 RTP/SCS Project Level Mitigation Measures 2 TABLE A-1 Mitigation Monitoring and Reporting Program Matrix ow Air Quality SMM AQ-1: SLAG shall continue to support and provide information on regional air quality planning and related issue Ongoing overthe SLAG areas in the region.SLAG staff shall also continue to work with the U.S.Environmental Protection Agency, life of the plan California Air Resources Board,and the air districts within the SLAG region and provide updates to relevant stakeholders on regional air quality planning and related issue areas through regional collaboration forums such as SCAG'sTransportation Conformity Working Group. PMM AQ-1: In accordance with provisions of sections 15091(a)(2)and 15126,4(a)(1)(5)of the State CEQA Guidelines,a lead Ongoing overthe Lead Agency agency for a project can and should consider mitigation measures to reduce significant adverse effects related life of the plan to violating air quality standards..Such measures may include the following or other comparable measures identified by the lead agency: a) Minimize land disturbance. b) Suspend grading and earth moving when wind gusts exceed 25 miles per hour unless the soil is wet enough to prevent dust plumes. Q Cover trucks when hauling dirt d) Stabilize the surface of dirt piles if not removed immediately. e) Limit vehicular paths on unpaved surfaces and stabilize any temporary roads. f) Minimizeunnecessary vehicular and machineryactivities. g) Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway. h) Revegetate disturbed land,including vehicular paths created during construction to avoid future off-road vehicular activities. J On Ca trans projects,Caltrans Standard Specifications 10-Dust Control,17-Watering,and 18-Dust Palliative shall be incorporated into project specifications. j) Assemble a comprehensive inventory fist(i.e,make,model,engine year,horsepower,emission rates)of all heavy-duty off-road(portable and mobile)equipment(50 horsepower[hp]and greater)that could be used an aggregate of 40 or more hours for the construction project.Prepare a plan for approval by the applicable air district demonstrating achievement of the applicable percent reduction for a CARE-approved fleet k) Ensure that all construction equipment is properly tuned and maintained. q Minimize idling time to 5 minutes—saves fuel and reduces emissions. m) Provide an operational water truck on-site at all times.Use watering trucks to minimize dust:watering should be sufficient to confine dust plumes to the project work areas.Sweep paved streets at least once per day where there is evidence of dirt that has been carried on to the roadway. n) Utilize existing power sources(e.g.r power poles)or clean fuel generators rather than temporary power generators. o) Develop a traffic plan to minimize traffic flow interference from construction activities.The plan may include advance public notice of routing,use of public transportation,and satellite parking areas with a shuttle service.Schedule operations affecting traffic for off-peak hours.Minimize obstruction of through- traffic lanes.Provide a flag person to guide traffic property and ensure safety at construction sites. p) Obtain CARB Portable Equipment Registration with the state or a local district permit for portable engines and portable engine-driven equipment units used at the project work site,with the exception of on-road and off-road motor vehicles.Arrange appropriate consultations with GARB or the local air district to determine registration and permitting requirements priorto equipment operation at the site. q) Use Titer 4 Final equipment or better for all engines above 50 hp.In the event that construction equipment cannot meet to Tier4 Final or better engine certification,the Project representative or contractor must demonstrate through future study with written findings supported by substantial evidence that is approved by the project's lead agency before using other tech nolog ies/strategies..Alternative applicable strategies may include,but would not be limited to,construction equipment with Tier 4 Interim or reduction in the number and/or horsepower rating of construction equipment and/or limiting the number of construction equipment operating at the same time.All equipment must be tuned and maintained in compliance with the manufacturer's recommended maintenance schedule and specifications.All maintenance records for each equipment and their contractor(s)should make available for inspection and remain on-site for a period of at least two years from completion of construction,unless the individual project can demonstrate thatTier4 Final or better engines would not be required to mitigate emissions below significance thresholds.Project sponsors should also consider including,ERNE technologies where appropriate and feasible or higher tier standard diesel equipment as A becomes developed and feasible. r) Projects located within the South Coast Air Basin and the Coachella Valley should consider applying for South Coast AQMD"SOON"funds which provides funds to applicable Fleets for the purchase of commercially available low-emission heavy-duty engines to achieve near-teen reduction of NOx emissions from in-use off-road diesel vehicles. s) Projects located within AB 617 communities should review the applicable Community Emissions Reduction Plan(CERP)for identification of additional feasible mitigation that can be applied to individual projects. 2 SCAG(Apr. 2024) MMRP for the 2024 RTP/SCS Program EIR, pp.A-3,A-7—A-13 (air quality),A-26—A-30(GHG),A-42—A-43 (Transportation),A-44—A-46 (utilities service systems), https:Hscag.ca.gov/sites/default/files/2024- 05/exh i b it_a_m m rp_508_fi n a I.pdf. Figure 2(continued) t) Where applicable,projects should provide information about air quality related programs to schools, including the Environmental Justice Community Partnerships(EJCP),Clean Air Ranger Education(CARE), and Why Air Duality Matters programs. u) Projects should work with local cities and counties to install adequate signage that prohibits truck idling in certain locations(e.g.,near schools and sensitive receptors). v) As applicable for airport projects,the following measures should be considered; - Considering operational improvements to reduce taxi time and auxiliary power unit usage,where feasible.Additionally,consider single engine taxing,if feasible as allowed per Federal Aviation Administration guidelines. - Set goals to achieve a reduction in emissions from aircraft operations over the lifetime of the proposed project - Use ground service equipment(GSE)that can operate on battery-power.If using electric equipment is not feasible,require the use of alternative fuel,the cleanest gasoline equipment,or Tier 4 Final,at a minimum. w) As applicable for port projects,the following measures should be considered: - Develop specifictfinefires fortransihoning to zero-emissions cargo handling equipment(CHE). - Develop Interim performance standards with a minimum amount of CHE replacement each yearto ersure adequate(progress. - Use short side electric power for ships,which may include tugboats and other ocean-going vessels or develop incentives to gradually ramp up the usage of shore power. - Install the appropriate infrastructure to provide shore powerto operate the ships..Electrical hookups should be appropriately sized. - Maximize participation in the Port of Los Angeles'Vessel Speed Reduction Program orthe Port of Long Beach's Green Flag Initiation Program in order to reduce the speed of vessel transiting within 40 nautical miles of Point Fermin. - Encourage the participation in the Green Ship Incentives. - Offer incentives to encourage the use of on-dock rail. x) As applicable for rail projects,the following measures should be considered: - Provide the h'ghest incentives for electric locomotives and then locomotives that meet Tier 5 emission standards with a floor on the incentives for locomotives that meet Tier 4 emission standards. y) Projects that will introduce sensitive receptors within 500 feet of freeways and other sources should consider installing high-efficiency or enhanced filtration units,such as Minimum Efficiency Reporting Value (MERV)13 or better.Installation of enhanced filtration units can be verified during occupancy inspection prior to the issuance of an occupancy permit. z) Develop an ongoing monitoring,inspection,and maintenance program for the MERV filters, aaa - Disclose potential health impacts to prospective sensitive receptors from living in dose proximity to freeways or other sources of air pollution and the reduced effectiveness of airfiRtration systems when windows are open or residents are outside. - Identifythe responsible implementing and enforcement agencyto ensure that enhanced filtration units are installed on-site before a permit of occupancy is issued. - Disclose the potential increase in energy costs for running the HVAC system to prospective residents. - Provide information to residents on where MERV filters can be purchased. - Provide recommended schedule(e.g.,every year or every six months)far replacing the enhanced filtration units. - Identify the responsible entity such as future residents themselves,Homeowners Association,or property managers for ensuring enhanced filtration units are replaced on time. - Identify,provide,and disclose ongoing cost-sharing strategies,if any,forreplacing the enhanced filtration units. - Set criteria for assessing progress in installing and replacing the enhanced filtration units;and - Develop a process for evaluatingthe effectiveness ofthe enhanced filtration units. aa)Consult the SCAG Equity Resources for Action(ERA)Toolbox available on the SCAG's Environmental Justice webpage for potential measures to address impacts to low-income andfor communities of color. bb)The following criteria related to diesel emissions shall be implemented on by Individual project sponsors as appropriate and feasible: - Diesel nonroad vehicles on site for more than 10 total days shall have either Cl)engines that meet EPA on road emissions standards or(2)emission control technology verified by EPA or CARE to reduce PM emissions by a minimum of 85%. - Diesel generators on site for more than 10 total days shall be equipped with emission control technology verified by EPA or CARB to reduce PM emissions by a minimum of 65%. - Nonroad diesel engines on site shall be Tier 2 or higher. - Diesel nonroad construction equipment on site for more than 10 total days shall have either(1)engines meeting EPA Tierd nonroad emissions standards or(2)emission control technology verified by EPA or CARS for use with nonroad engines to reduce PM emissions by a minimum of&5%for engines for 50 hp and greater and by a minimum of 20%for engines less than 50 hp. - The construction contractor shall maintain a fist of all diesel vehicles,construction equipment,and generators to be used on site.The list shall include the following:. I. Contractor and subcontractor name and addresar plus contact person responsible forthe vehicles. or equipment. i. Equipment type,equipment manufacturer,equipment serial number,engine manufacturer,engine model year,engine certification(Tier rating),horsepower,engine sefial number,and expected fuel usage and hours of operation. Figure 2(continued) iii, For the emission control technology installed:technology type,serial number,make,model, manufacturer,EPAICARB verification nu..mberllevel,and installation date and hour-meter reading on Installation date. — Establish generator sites and truck-staging zones for vehicles waiting to load or unload material on site. Such zones shall be located where diesel ern issions have the least impact on abutters,the general public,and especially sensitive receptors such as hospitals,schools,daycare facilities,elderly housing, and convalescent facilities. — Maintain a monthly report that,for each on goad diesel vehicle,nonroad construction equipment,or generator o nsite,includes: i. Hour-meter readings on arrival on-site,the first and last day of every month,and on off-site date. 1. Any problems with the equipment or emission controls. iii. Certified copies of fuel deliveries for the time period that identify: t. Source of supply 2. Quantity of fuel 3. Quantity of fuel,including sulfur content(percent by weight) cc)Promote energy efficiency and exceed Title-24 Building Envelope Energy Efficiency Standards(California Building Standards Code): — Install programmable thermostat timers — Obtain Third-party HVAC commissioning and verification of energy savings(to be grouped with exceedance of Title 24). — Install energy efficient appliances(Typical reductions for energy-efficient appliances can be found in the Energy Star and Other Climate Protection Partnerships Annual Reports) — Install higher efficacy public street and area lighting — Limit outdoor lighting requirements — Replace traffic lights with LED traffic lights — Establish onsite renewable or carbon neutral energy systems—generic,solar pourer and wind power — Utilize a combined heat and power system dd)Promote transportation efficiency.The following measures can be used to increase transportation efficiency. — Locate project near bike path/bike lane — Provide pedestrian network improvements,such as interconnected street network'narrower roadways and shorter block lengths,sidewalks,accessibility to transit and transit shelters,traffic calming measures,parks and public spaces,minimize pedestrian barriers. — Provide traffic calming measures,such as: i. Marked crosswalks i. Count-down signal timers iii. Curb extensions iv. Speed tables v. Raised crosswalks vi. Raised intersections vii.Median islands viii.Tight corner radii x. Roundabouts or mini-circles x. On-street parking xi. Chicanes/chokers — Create urban non-motorized zones — Provide bike parking in non-residential and multi-unit residential projects — Dedicate land for bike trails — Limit parking supply through: i. Elimination(or reduction)of minimum parking requirements . Creation of maximum parking requirements iii. Provision of shared parking — Require residential area parking permit. — Provide ride-sharing programs. i. Designate a certain percentage of parking spacing for ride sharing vehicles i. Designating adequate passenger loading and unloading and waiting areas for ride-sharing vehicles iii. Providing a web site or messaging board for coordinating rides iv. Permanent transportation management association membership and finding requirement. ee)Lengthen the construction period during smog season(May through October)by extending the construction hours per workday or number of days worked per week,to minimize the number ofvehicles and equipment operating at the same time. ff) Install signage containing the complaint number of the local air district where construction activities are located at the construction sites. Figure 2(continued) PIn1M GHG-1:. In accordance with provisions of Sections 15091(a)(2)and 15125A(a)(1)(B)of the State CECjA Guidelines,a lead Ongoing over the Lead Agency agency for a project can and should consider mitigation measures to reduce substantial adverse effects related life of the plan to greenhouse gas emissions.Such measures may include the following or other comparable measures identified by the lead agency: a) Integrate green building measures consistent with CALGreen(California Building Code Title 24),local building codes and other applicable laws,into project design including: i) Use energy efficient materials in building design,construction,rehabilitation,and retrofit, ii) Install energy-efficient lighting,heating,and cooling systems(cogeneration);water heaters;appliances; equipment;and control systems. ii,) Reduce lighting,heating,and cooling needs bytaking advantage of light-colored roofs,trees forshade, and sunlight Iv) Incorporate passive environmental control systems thataccount forthe characteristics ofthe natural environment. v) Use high-efficiency lighting and making devices. v) Incorporate passive solar design. vl)Use h ig h-reftectivity build ing materials anal multiple glazi ng. vii)Use no gas-powered landscape maintenance equipment ix) Install altemative fuel(.e.,electric,hydrogen-fueled,etc.)vehicle charging and fueling stations. x) Reduce woad burning staves or fireplaces. xi) Provide bike lanes accessibility and packing at residential developments. xis Encourages projects to reduce natural gas infrastructure in buildings and/or reduce the use of natural gas appliances,with exceptions for limited uses. b) Reduce emissions resulting from projects through implementation of project features,project design,or othermeasures,such as those described in Appendix Fofthe State CEQA Guidelines. c) Include off-site measures to mitigate a project's emissions. d) Measures that consider incorporation of Best Available Control Technology(BACT)during design, construction,and operation of projects to minimize(;HG emissions,including but not limited to: i) Use energy and fuel-efficient vehicles and equipment; i) Deployment of zero-and/or rear zero emission technologies; ii) Use lighting systems that are energy efficient,such as LED technology; iv) Use the minimum feasible amount of GHG-emitting construction materials; v) Use cement blended with the maximum feasible amount of flash or other materials that reduce GHG emissions from cement production; v) Incorporate design measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse; vi)Incorporate design measures to reduce energy consumption and increase use of renewable energy; vui)Incorporate design measures to reduce water consumption; Ix) Use fighter-colored pavement where feasible; x) Recycle construction debris to maximum extent feasible; xi) Plant shade trees in or near construction projects where feasible;and xi7 Solicit bids that include concepts listed above. e) Measures that encourage transit use,carpooling,bike-share and car-share programs,active transportation, and parking strategies.,including,but not limited to the following:. i) Promote transit-active transportation coordinated strategies in Increase bicycle carrying capacity on transit and rail vehicles; ii) Improve or increase access to transit; iv) Increase access to common goods and services,such as groceries,schools,day care,and medical care; v) Incorporates housing,including affordable housing,into the project; v) Incorporate a neighborhood electric vehicle network; v[i)Orient the project toward transit,bicycle,and pedestrian facilities, viir]Improve pedestrian or bicycle networks,or transit service ix) Provide traffic calming measures x) Provide bicycle parking; xi) Unnt or eliminate park supply, xis Unbundle parking casts; xii)Provide parking cash-out programs; xiv)Implement or provide access to commute reduction program; Q Incorporate bicycle and pedestrian facilities into project designs,maintain these facilities,and provide amenities incentivaing their use,'and plan for and construct local bicycle projects that connect with the regional network; g) Improve transit access to rail and bus routes by incentives for construction of transit facilities within developments,and/or providing dedicated shuttle service to transit stations; h) Adopt employer trip reduction measures to reduce employee trips such as vanpool and carpool programs, provide end-of-trip facilities,and telecommuting programs including but not limited to measures that: i) Provide car-sharing,bike sharing,and ride-sharing programs; i) Provide transit passes; Figure 2(continued) ii) Shift single occupancy vehicle trips to carpooling or vanpoo ling,for example by providing rde- matching services; Irv) Provide incentives orsubsidies that increase use of modes otherthan single-occupancy vehicle; v) Provide on-site amenities at places of wort{such as priority parting for carpools and vanpools,secure bike parking,and showers and locker rooms; vi} Provide employee transportation coordinators at employment sites; vii) Provide a guaranteed ride home service to users of non-auto modes. ) Designate a percentage of parking spaces for ride-sharing vehicles or high-occupancy vehicles,and provide adequate passenger loading and unloading for those vehic leg , jJ Land use siting and design measures that reduce GHG emissions,including: i) Developing an inf11 and brownfrelds sites; Q Building compact and mixed-use developmentsneartransit; ii) Retaining on-site mature trees and vegetation,and planting newcanopytrees; iv) Measures that increase vehicle efficiency,encourage use of zero and low emissions vehicles,or reduce the carbon content of fuels,including constructing or encouraging construction of alternative fuel(e.g., electric,hydrogen-fueled,etc.)vehicle charging and fueling stations or neighborhood alterative fuel vehicle networks,or charging for electric bicycles; v) Measures to reduce GHG emissions from solid waste management through encouraging solid waste recycling and reuse;and vi} Establish methane recovery in Landfills and Wastewater Treatment Plants,where applicable. k) Consult the SCAG Equity Resources for Action(ERA)Toolbox available on SCAG's Environmental Justice webpage for potential measures to address impacts to low-income and/or communities of color. 1) Require at least five percent of all new vehicle parking spaces Include alternative fuel(e.g.,electric, hydrogen-fueled,etc)vehicle charg'ng and fueling stations,or at a minimum,install the appropriate infrastructure to facilitate sufficient a ectric charging for passenger vehicles and trucks to plug-in. Encourage electric vehicle capable(branch circuit and raceway)or ready(charging Gullet)spaces to accommodate future growth in electric vehicles, rn) Encourage telecommuting and alterative work schedules,such as, it Staggered startingtimes if) Flexible schedules ii) Cam pressed workweeks n) Implement commute trip reduction marketing,such as: i) New employee orientation of trip reduction and alternative mode options i) Event promotions i) Publications o) Im plem ent preferential parking permit program p) Implement school pool and bus programs q) Price workplace parking,such as: i) Explicitly charging for parking for its employees i) Implementing above market rate pricing i"s) Validating parking only for invited guests Irv) Not providing employee parking and transportation allowances v) Educating employees about available alternatives. Figure 2(continued) iif. Promoting water-efficient land use and development iv. Encouraging muRiple uses,such as the joint use of schools v, lncludfng trail systems and trail segments in General Plan recreation standards. Transportation SMM TRA-1: SCAG shall facilitate the reduction of vehicle miles traveled(VMT)and impacts to circulation and access Ongoing over the SLAG through mobility,improvements and by encouraging transit/rail and active transportation use via stakeholder life of the plan forums(e g.,quarterly Safe and Active Streets Working Group meetings,bimonthly Regional Transit Technical Advisory Committee meetings,monthly Active Transportation Program check-fnswith County Trarsportation Commissions),These objectIrves will also be facilitated through the hosting of regional forums for policy makers,County Transportation Commissions,planning agencies,local jurisdictions,and state partners to promote information sharing. SMM TRA-2: SCAG shall€ontinue to support development of local and regional SB 743 implementation programs. Ongoing over the SLAG life of the plan SMM TRA-3: SCAG shall continue to develop and support its program for reducing average daily number of SLAG Ongoing over the SLAG employees`commute vehicle trips. life of the plan PIVIM TRAl-1: In accordance with provisions of sections 15091(a)(2)and 15126.4(a)(1)(B)ofthe CEQA Guidelines,a lead Ongoing over the Lead Agency agency for a project can and should consider mitigation measures to reduce substantial adverse effects related life of the plan to transportation impacts.Stich measures may include the following or other comparable measures identified bythe lead agency: For future land use development projects,lead agencies to encourage the incorporation of transit,bicycle, pedestrian,and micro-mobility facilities,features,and services in project designs,as well as encourage developers to prov de information regarding the availabflity ofthese facilities and services to residents, tenants,and owners in order to facilitate increased access to and utilization oftransit and active transportation services and facilities. PMtwt TRA-2: In accordance with provisions of sections 15091(a)(2)and 15126.4(a)(1)(B)ofthe CEQA Guidelines,a lead Ongoing over the Lead Agency agency for a project can and should consider mitigation measures to reduce substantial adverse effects related life of the plan to transportation impacts.Such measures may include the following or other comparable measures Identified by the lead agency: • Transportation demand management CTDM)strategies should be incorporated into individual land use and transportation projects and plans,as part of the planning process.Local jurisdictions should incorporate strategies identified in the Federal Highway Administratior's publication:Integrating Demand Management into the Transportation Planning Process:A Desk Reference(August 2012)into the planning process(FHWJA 2012).For example,the following strategies may be included to encourage use oftransit and non-motorized modes of transportation and reduce vehicle miles traveled on the region's roadways: - Include TDMmitigationrequfrements for new developments; - Incorporate supporting infrastructure for non-motorized modes,such as,bike lanes,secure bike parking,sidewalks,and crosswalks; - Provide incentives to use alternative modes and reduce driving,such asb universal transit passes,road and parking pricing; - Implement parking management programs,such as parking cash-outs priority parking for carpools and va npools; - Develop TDM-specif€performance measures to evaluate project-specffi€and system-wide performance; - Incorporate TDM performance measures in the decision-making process for identifying transportation investments; - Implement data collection programs for TDM to determine the effectiveness of certain strategies and to measure success overtime;and - Set aside funding for TDM initiatives PIVIM TRAk-3: In accordance with provisions of sections 15091(a)(2)and 15126.4(a)(1)(B)ofthe CEQA Guidelines,a lead Ongoing over the Lead Agency agency for a project can and should consider mitigation measures to reduce substantial adverse effects related life of the plan to transportation impacts.Such measures may include the following or other comparable measures Identified by the lead agency., Prepare a sight distance analysis as needed for locations where sfgiht lines could be Impeded.The sight distance aralysis to be prepared according to the jurisdiction's applicable Municipal Code requirements and the Caltrans Highway Design Manual(HCM)standards and guidelines,and should recommend safety improvements as appropriate such as limited use areas(e.g,low-height landscaping),on-street parking restrictions(e.g.,red curb),and any turning restrictions(eq.,right-In/right-out), Figure 2(continued) c) Provide permanent conservation easements or other interests in real property,with culturally appropriate management criteria for the purposes of preserving or utilizing the resources or places;and protecting the resource. d) If tribal cultural resources are found,then the lead agency should consider tribal construction monitoring. Utilities and Serv@ce Systems 5MM USSW-1: SCAG shall continue to provide support for coordinating with waste management agencies,and appropriate Ongoing over the SLAG local and regional jurisdictions,and sharing information to facilitate and encourage diversion of solid waste life of the plan where applicable,appropriate,and feasible. PMM UTILA: In accordance with provisions of sections 15091(a)(2)and 15126.4(a)(1)(B)ofthe CEOA Guidelines,a Lead Ongoing over the Lead Agency Agency for a project can and should consider mitigation measures to reduce substantial adverse effects on life of the plan utilities and service systems,particularty for construction of wastewater facrl-dies,as applicable and feasible. Such measures may incude the following or other comparable measures identified by the Lead Agency. • During the design and CEQA review of individual future projects.,implementing agencies and projects sponsors shall determine whether sufficient wastewater capacity exists for the proposed projects.The proposed development can and should be served by its existing or planned treatment capacity.If adequate capacity does not exist,project sponsors shall coordinate with the relevant service providerto ensure that adequate public services and utilities could accommodate the increased demand,and if not,infrastructure improvements for the appropriate public service or utility shall be identified in each project's CEQA documentation.The relevant public service provider or utility shall be responsible for undertaking project- level review as necessary to provide CEQA clearance for new facilities. PMM UTIL-2: In accordance with provisions of sections 15091(a)(2)and 15126.4(a)(1)(B)ofthe CEQA Guidelines,a lead Ongoing overthe Lead Agency agency for a project can and should consider mitigation measures to ensure sufficient water supplies,as Irfe of the plan applicable and feasible.Such measures may include the following or other comparable measures identified by the lead agency: a) Reduce exterior consumptive uses of water in public areas,and promote reductions in private homes and businesses,by shifting to drought-tolerant native landscape plantings,using weather-based irrigation systems,educating other public agencies about water use,and installing related water pricing incentives. b) Promote the availability of drought-resistant landscaping options and provide information on how these can be obtained.Use of reclaimed water especially in median landscaping and hillside landscaping can and should be implemented where feasible. c) Implement water conservation best practices such as tow-flow toilets,water-efficient clothes washers, water system audits,and leak detection and repair. d) For projects located in an area with existing reclaimed waterconveyance infrastructure and excess reclaimed water capacity,use reclaimed water foe non-potable uses,especially landscape irrigation.For projects fn a location planned for future reclaimed water service,projects should install dual plumbing systems in anticipation of future use.Large developments could treat wastewater onsrte to tertiary standards and use R for non-potable uses onsde. PMM UTIL-3: n accordance with provisions of sections 15091(a)(2)and 15126A(a)(1)(B)ofthe CEQA Guidelines,a lead Ongoing overthe Lead Agency agency fora project can and should consider mitigation measures to reduce the generation of solid waste,as life of the plan applicable and feasible.Such measures may include the following or other comparable measures identified by the lead agency: Integrate green building measures consistent with CALGreen(California Building Code Title 24)into project design including,but not limited to the following: a) Reuse and minimize construction and demolition CMD)debris anddiversion of C&D waste from landfills to recycling faciltie& b) Include a waste management plan that promotes maximum C&D diversion. c) Source reduction through(1)use of materials that are more durable and easierto repair and maintain,(2) design to generate less scrap material through dimensional planning,(3)increased recycled content,(4) use of reclaimed materials,and(5)use of structural materials in a dual role as finish material(e.g..stained concrete flooring,unfinished ceilings,etc.). d) Reuse existing structure and shell in renovation projects. e) Develop indoor recycling program and space,. f) Discourage the siting of new landfills unless all other waste reduction and prevention actions have been fully explored,If landfill siding or expansion is necessary,site landfills with an adequate landfill-owned, undeveloped land buffer to minimize the potential adverse impacts ofthe landfill in neighboring communities, g) ❑iscourage exporting of locally generated waste outside of the SCAG region during the construction a.nd implementation of a project Encourage disposal within the county where the waste originates as much as possible.Promote green technologies for Bong-distance transport ofwaste(e.g.,clean engines and clean locomotives or electric rail for waste-by-rail disposal systems)and where appropriate and feasible. h) Encourage waste reduction goals and practices and look for opportunities for voluntary actions to exceed the Sit percent state waste diversion target. 0 Encourage the development of local markets for waste prevention,reduction,and recycling practices by supporting recycled content and green procurement policies,as well as other waste prevention,reduction, and recycling practices. j) Develop ordinances that promote waste prevention and recycling activities such as:requiring waste prevention and recycling efforts at all large events and venues.;implementing recycled content procurement programs;and developing additional opportunities to divert food waste away from landfills and toward food franks and composting facilities. k) Develop and site composting,recycling,and conversion technology facilities that have minimum environmental and health impacts. I] Integrate reuse and recycling into residential industrial,institutional,and commercial projects. m) Provide education and publicity about reducing waste and available recycling services. Figure 2(continued) n) Implement or expand city or county-wide recycling and compastrng programs for residents and businesses.This could rncude extending the types of recycling senrrces offered(e.g.,to rnclude food and green waste recycling)and providing public education and publicity about recycling services. Figure 3: CARB's 2022 Scoping Plan, Local Action Appendix(Priority Strategies) 3 ReductionPriority Areas Priority GHG Convert local government fleets to ZEVs and provide EV charging at public sites Transportation p Create a jurisd fiction-specific ZEV ecosystem to support deployment of ZEVs statewide(such as budding standards that Electrification exceed state building codes,permit streamlining,infrastructure siting, consumer education,preferential parking policies, and ZEV readiness plans) Reduce or eliminate minimum parking standards?' Implement Complete Streets policies and investments,consistent with general plan circulation element requirements24,25 Increase access to public transit by increasing density of development near transit,improving transit service by increasing service frequency,creating bus priority lanes,reducing or eliminating fares,microtransit,etc. VMT Reduction increase public access to clean mobility options by planning for and investing in electric shuttles,bike share,car share, and walking Implement parking pricing or transportation demand management pricing strategies Strategiesaaa Priority Areas Priority GHG Reduction Amend zoning or development codes to enable mixed-use,walkable,transit-oriented,and compact infll development (such as increasing the allowable density of a neighborhood)26 Preserve natural and working lands by implementing land use policies that guide development toward infill areas and do not convert°greenfield" land to urban uses (e.g.,green belts,strategic conservation easements) Adopt all-electric new construction reach codes for residential and commercial uses27 Adopt policies and incenfve programs to implement energy efficiency retrofits for existing buildings,such as weatherization,lighting upgrades,and replacing energy-intensive appliances and equipment with more efficient systems (such as Energy Star-rated equipment and equipment control lers) Adopt policies and incentive programs to electrify all appliances and equipment in existing buildings such as appliance Building rebates,existing building reach codes,or time of sale electrification ordinances Decarbonization Facilitate deployment of renewable energy production and distribution and energy storage on privately owned land uses (e.g-,permit streamlining,information sharing) Deploy renewable energy production and energy storage directly in new public projects and on existing public facilities (e.g-,solar photovoltaic systems on rooftops of municipal buildings and on canopies in public parking lots, battery storage systems in municipal buildings) s CARB 2022 Scoping Plan,Appendix D(Local Action), pp. 11-12,22-23, https:Hww2.arb.ca.gov/sites/default/files/2022-11/2022-sp- appendix-d-local-actions.pdf. Figure 3 (continued) Table 3 — Fief+ Residential and Mixed-Use Project Attributes that Reduce GHGs Priority Areas Key Project Attribute Provides EV charging infrastructure that, at minimum, meets the Transportation Electrification most ambitious voluntary standard in the California Green Building Standards Code at the time of project approval4$ Is located on infill sites that are surrounded by existing urban uses and reuses or redevelops previously undeveloped or underutilized land that is presently served by existing utilities and essential public services (e.g., transit, streets, water, sewer)as Does not result in the loss or conversion of natural and working lands Consists of transit-supportive densities (minimum of 20 residential VMT Reduction dwelling units per acre),54 or Is in proximity to existing transit stops (within a half mile),51 or Satisfies more detailed and stringent criteria specified in the region's SCS52 Reduces parking requirements53 by: Eliminating parking requirements or including maximum allowable parking ratios (i.e., the ratio of parking spaces to residential units or square feet); or Providing residential parking supply at a ratio of less than one parking space per dwelling unit, or ProjectPriority Areas Key For multifamily residential development, requiring parking costs to be unbundled from costs to rent or own a residential unit.54 At least 20 percent of units included are affordable to lower-income residents55 ss Results in no net loss of existing affordable units Uses all-electric appliances without any natural gas connections and Building Decarbonization does not use propane or other fossil fuels for space heating, water heating, or indoor coo king5' 58 Figure 3:CARB's 2017 Scoping Plan, Local Action Appendix(Local Policies)4 Energy - Streamline permitting .and environmental review and reduce fees for small-scale renewable energy systems - Adopt a community solar program to Delp realize economies of scale and help residents without appropriate rooftop space to participate in clean energy generation - Promcte property-assessed clean energy financing districts or ether -inancing mechanisms to fund permanent energ�Y-e-ficiency, water-e-ficiency. and renewable energy improvements in the residential and commercial sectors - I ncentivize energy-efficiency Li pg rades for e isti ng build ings at the time Cf a in ajor remodel or change of owne rs h ip - Reduce permit fees and strearn line permitting requirements for energy-efficiency- and renewable energy-related building renovations - I rnplement building energy aLid it and retrcfit prcgrams and residential solar preg rams - adept residential and commercial energy conservation, renewable energy, and/or zero net energy ordinances (consider requirements for audits or upgrades at rn ajor renovation or time of sale) - Incorporate renewable energy and energy e—iciency into public facilities' capital improvements - Replace pLi bliC Iig Ming with e nergy-efficient I ighting - Permit renev%,able energy generation facilities as of right in zones with compatible Li ses - Create incentive programs to prcrncte the building energy-eff cierlcy projects - Implement large-scale energy storage in Commercial and industrial buildings to control peak loads - Require nevo residential and commercial Construction to install solar or be solar ready (see California Energy Ccde) - Encourage the development -of brightfields — brownfields that are used tc develop solar energy — through tax incentives. streamlining, and use of loca IIy-ovmed land - Pti rs ue rene,.hrable energy development cn municipal buildings or purchase renewable energy to power municipal operations - Require on-site renewable energy generation by large-scale residential and commercial I projects - I ncentivize energy-efficiency u pg rades to existing bLl ildings, where apprc priate: Li pon iss a ing a permit for substantial modification 4 CARB 2017 Scoping Plan,Appendix B(Local Action), pp. 1-10, https://ww3.arb.ca.gov/cc/scopingplan/2030sp_appb_localaction_final.pdf. Figure 3 (continued) Natural and Working Lands (NWL) Policy in this sector should balance carbon sequestration with -other co-benefits- The overall objective is to maintain Nle'VL as a carbon sink and minimize the net GHG emissions associated ,Arith management_ biomass disposal, and wildfire events. Examples that could be considered include: - Incorporate NWL conservation into local land use plans including adoption of a natural and -.vorking lands climate plan, land climate plan, and the recognition of the climate resiliency benefits of NWL - Adopt policies that encourage management practices known to enhance carbon sequestration on NVVL - .Adopt policies to expand and improve management of urban forests for net long- term carbon storage - Adopt urban forestry and green infrastructure programs - Adopt zoning to allow empty lots and other underutilized space to be converted into community gardens and greenspace - Adopt ordinances preserving and enhancing carbon sequestration of wetlands: forests, croplands, and grasslands - Adopt plans to conserve lands, water; and other natural features and resources for habitat function, v atershed protection; air and water quality protection, and other ecosystem services - Adopt ordinances preserving trees in urban areas through the review of proposed land use developments where trees are present on either public or private property - Adopt plans and support projects for forest management activities to restore California. forest lands that have high tree mortality and unnaturally dense fuel leads to a fire resilient condition that will mitigate wildfire size and severity - Promote and encourage the development of value-added alternatives, such as composting, energy, biochar, and good products to avoid open burning of forest biomass wastes - Develop strategies to value the benefits of forest fuels reductions on upper- watershed water quality: quantity, and timing aaa Agriculture - Incorporate farmland conservation in local land use plans - Provide incentives for carbon sequestration and carbon-based conservation farm ing techniques; including the use of b'iochar and compost from biomass ,-�;astes that ..vould have otherodse been landfilled or-open burned - Promote value-added alternatives,_ such as composting, energy, biochar, and ,good products, and prohibit open burning of agricultural biomass wastes - Develop incentives to red rice applications of pesticides and fertilizers and increase use of compost - Support development of farmers markets and provide guidance and support for local farmers. especially in disadvantaged communities - Develop programs to encourage use -of composting to enhance soil for carbon sequestration and soil healthy farms plans - Promote grazing management and animal dietary strategies to red rice methane emissions from enteric fermentation - Require best management practices for livestock waste for confined animal facilities Figure 3 (continued) Transportation and Land Use Update Lead Agency's transportation impact analysis guidelines and congestion management plans to comply with SB 743 Adopt general plan policies and diagram designations and zone map and standards that are consistent with the Sustainable Communities Strategy In appropriate locations, adopt: 1)as-of-right zoning, and 2)design standards and guidelines, to enable mixed use, walkable, compact, infill development that includes a range of housing types and affordability levels Build infrastructure necessary for residential development in existing communities, and ensure any urban growth boundaries are paired with significant infill promotion strategies and removal of infill development barriers Streamline permitting and environmental review and reduce fees for construction of secondary units to promote infill in targeted areas Streamiine local permitting and siting for hydrogen fueling and electric vehicle (EV)charging infrastructure Adopt ajurisdiction-wide transportation demand management plan which sets numeric targets or caps for the proportion of non-single occupancy vehicle(SOV) trips associated with new development, and/or an overall vehicle mules traveled (VMT)target Require employer-based trip reduction programs and provide funding to support them if feasible Update code of ordinances to reduce parking requirements and eliminate parking minimums. impose parking maximums Institute paid parking for local on-street parking, structures and lots Adopt and implement EV and hydrogen readiness plans Adopt voluntary'green building standards that exceed minimum State building standards for EV Capable parking spaces(e.g_, by requiring installation of EV chargers and/or a larger number of EV-capable parking spaces)or match local climate action plan goals Replace public fleet vehicles and trips with electric or alternative fueled vehicles as much as feasible and provide EV chargers in public spaces Adopt and implement a bicycle and pedestrian master plan which includes targets for trips taken by bicycle and on foot Adopt complete streets policies and active design guidelines Develop a transportation impact fee program to fund low-carbon transportation Support biogas use in the transportation sector Provide incentives for certifying development plans and projects using LEER for Neighborhood Development or similar third-party certification system. Partner with locailregional transit agencies to enhance transit ridership Adopt a Transportation Management Ordinance to require carpool, electric vehicle,andfar vanpool preferential parking spaces close to the major employment areas Adopt a Safe Routes to School Program that encourages youth to walk or ride bicycles to schools o At schools where students drive, reduce the number of student parking spaces to encourage walking,biking and carpooling Develop Safe Routes to transit programs for pedestrians and bicyclists Develop intelligent traffic management systems to im prove traffic flow Incentivize use of alternative fuel or high-fuel efficient vehicles by public agencies and private businesses Require local public agencies to contract with fleets that set targets and policies for lowering the average G HG emissions of their fleet vehicles Require clean vehicles be purchased as part of municipal vehicle fleet procurement aaa Adopt regional joint-purchase agreements to facilitate local fleets to purchase Ells, hybrids, telematics, and other technology that can reduce GHG emissions Require Local specific plans for rideshare-designated parking spaces, new bus stops, employment centers, and commercial areas Expand transit and rail services and clean-fueled transit vehicles Promote ridesharing and last-mile connections Create incentives for electric landscaping power tools and off-road equipment Promote smart driving strategies through public education and outreach Restrict idling for all vehicles, especially in sensitive areas such as near schools Figure 3 (continued) Waste Management - Prohibit disposal of organic materials at landfills and/or prohibit the jurisdictions' hauler(s) and self-haulers from taking organic material to landfills - Require edible food recovery programs; require collected organicwaste materials be used as -eedstock for composting and anaerobic digestion, include assessment of 15 years organics recycling capacity needs in the General Plan, and provide appropriate zoning in compatible areas for large and community- scale composting and digestion operations - Implement residential and commercial waste prevention, recycling, organics collection, and edible food recovery programs to meet requirements of AD 341 , AB 1826, and SB 1388 - Require generators of edible food to have contractslagreements with food recovery organizations and prohibit edible food from being disposed or destroyed aaa - Adopt ordinances to meet zero waste goals by 2020 - Ado pt c rd ina noes req a firing h auling routes and fuels that m inimize vehicle emissions compared to current practices (e.g., through use of renewable fuels, route optimization plan: etc.) - Adopt a construction & demolition ,A aste recycling ordinance (see CALGreen Divisions 4.4 and 5.4) - Adopt an ordinance for zero v aste -rom construction and demolition waste - Adopt green building standards that include targets to exceed minimum State building standards for new construction, including requiring new construction to include bin space for organics recycling (see CAL Green Divisions 4.4 and 5.4 as well as Append ices A4.4 and A5.4) - Require that landfills incorporate the financial impact of organics disposal redretions pursuant to SB 1883 into their Financial Assurance plans - Create an effective solid %A aste management plan to reduce scarce generation and to divert waste from landfills to achieve emission reductions and address in General Plan - Ensure compost materials meet standards to be used in rural lands application for carbon sequestration - Expand anaerc bic digestic n capacit,y, at existing gaste,.� ater treatment plants to allover them to accept food . aste - Require zefo waste at public events. including food recovery and recycling - Require food waste Fed LIction at commercial facilities such as restaurants, hotels, hospitals, etc.: including food donations - Require large commercial landscapers and public projects to use compost-based nutrients and soil amendments on landscaping and plants instead of artificial fertilizers and soil amendments - Implement recycled content procurement practices in all operations - Implement a plan nor food recovery for municipal food operations - Establish ",-aste diversion programs like „pay as Vofi thro,tihi:' .A.-here people pay per pick up an7crrnt Figure 3 (continued) Water - Adopt water-efficient landscaping ordinances (see CALGreen Divisions 4_3 and 5.3), including the rise of compost and mulch, to reduce water use and encourage use of greywater for landscaping: when available - Develop a plan requiring water recycling, and greywater and rain water reuse and provide funding for incentives and other program delivery mechanisms if feasible - Develop a plan to quantify and reduce GHG emissions at publicly operated treatment works (ROTS, s) - Develop a residential water efficiency auditing program - Create an incentive program to promote efficient water use projects - Eliminate Homeowner Association requirements for lawns and landscaping - 'A'ork %�Jth local water agencies to evaluate the impact of proposed new developments and land use plans cn ground,,-eater and long-term water supply aaa Short-Lived Climate Pollutants — Require bicgas generation at wastewater treatment plants and methane capture at landfill facilities — Require that air conditioning and refrigeration units in new construction (and at major renovation) rely on refrigerants with lever global warming potential (e.g., they use 02 or ammonia instead of hydrofluorocarbons) — Promote alternatives to open pile burning as disposal options forwoody biomass wastes - Support hazardous fuel reduction: defensible space clearing and forest friel reduction in rural forested areas with high tree mortality and unnaturally high fuel loads to reduce the size and severity of catastrophic wildfires .A hich reduces the release non-anthropogenic black carbon and methane — Adept use of lour global v.-arming potential ( VdP) alternative refrigerants aaa — Work with local utility and waste management agencies to adopt a curbside program for old refrigerators, air-conditioning units, and automobiles to ensure proper disposal of refrigerants — Adopt programs, ordinances; or regulations to reduce wood smoke from residents, commercial, and recreational activities — Require alternatives to wood heating such as heat pumps or gas heating devices in new developments, in appropriate climate zones, where infrastructure is available — Provide incentives to reduce wood smoke by changing out uncertified wood heating devices to gas. electric, or pellet devices - Implement organics v aste prevention, recycling. and -cod recovery programs Figure 3 (continued) Green Buildings - When determined to be feasible and achlevable within the local jurisdiction. adapt Tier 2:7 residential and commercial green building standards c- the California {Green Building Standards (CALGreen Code2), or a third Party green building rating systems such as the LEED or Green Point Rated for new construction and existing building retrofits. CALGreen allcv s a local jurisdiction to adapt ':Tier 2,_ as a more restrictive option. The California Health and Safety Code also allows local jurisdictions to adopt more restrictive building standards based on local conditions. Local jurisdictions also may adopt green rating systems, but in addition to the mandatory CALG Peen requirements. - Incentivize implementation of CALGreen Code building code voluntan provisions to divert and recycle construction and demolition .paste, and use locally-sourced building materials and recycled content building materials, including mulchrcompcst, to the extent possible - Adopt Guidelines for incentivizing new buildings to maximize energy conservation designs to promote passive solar energy generation.. natural .ventilation, effective use of daylight. and on-site electricity generation - Encourage the use of on-site rene,-.vable energy combined with storage - Link green building Frith transportation planning to encourage lowest possible transportation impacts - Develop strategies and goals to reduce urban heat islands through cool roofs, urban forestr (shade trees) and coral non-roof surfaces: including covered parking areas .�,,Ith PV systems to provide shading - Require cool roofs andior green roofs on new construction. for all buildings or a subset (commercial, multi-family. etc.) of building types - Require cool paving andfor light reflective permeable suraces in sidewalks.- patios, driveways, parking lots: or other paved areas3 Figure 3:CARB's 2017 Scoping Plan, Local Action Appendix(Mitigation Measures) 5 Construction - Enforce idling time restrictions for construction vehicles - Require construction vehicles to operate with the highest tier engines commercially available - Divert and recycle construction and demolition waste, and use locally-sourced building materials with a high recycled material content to the greatest extent feasible - Minimize tree removal, and mitigate indirect GHG emissions increases that occur due to vegetation removal, loss of sequestration, and soil disturbance - Utilize existing grid power for electric energy rather than operating temporary gasolineldiesel powered generators - Increase use of electric and renewable fuel powered construction equipment and require renewable diesel fuel where commercially available - Require diesel equipment fleets to be lower emitting than any current emission standard Operation Comply with lead agency's standards for mitigating transportation impacts under SB 743 Require on-site EV charging capabilities for parking spaces serving the project to meet jurisdicticn-wide EV proliferation goals Allow for new construction to install fewer on-site parking spaces than required by Iocal municipal building code, if appropriate4 Dedicate on-site parking for shared vehicles Provide adequate,safe,convenient, and secure on-site bicycle parking and storage in multi-family residential projects and in non-residential projects Provide on-and off-site safety improvements for bike,pedestrian, and transit connections, andler implement relevant improvements identified in an applicable bicycle and/or pedestrian master plan Require on-site renewable energy generation Prohibit wood-burning fireplaces in new development: and require replacement of wood-burning fireplaces for renovations over a certain size developments Require cool roofs and "cool parking"that promotes cool surface treatment for new parking facilities as well as existing surface lots undergoing resurfacing aaa Require the use of energy-efficient lighting for all street., parking. and area lighting Require the landscaping design for parking lots to utilize tree cover and compostlmulch Incorporate water retention in the design of parking lots anti landscaping, including using compostlmulch Require the development project to propose an off-site mitigation project which should generate carbon credits equivalent to the anticipated GHG emission reductions. This would be implemented via an approved protocol for carbon credits from California Air Pollution Control Officers Associatlon (CAPCOA), the California Air Resources Board, or other similar entities determined acceptable by the local air district - Require the project to purchase carbon credits from the CAPCOA GHG Reduction Exchange Program,American Carbon Registry(ACR), Climate Action Reserve (CAR)or other similar cartoon credit registry determined to be acceptable by the local air district Encourage the applicant to consider generating or purchasing local and California-only carbon credits as the preferred mechanism to implement its off- site mitigation measure for GHG emissions and that will facilitate the State's efforts in achieving the GHG emission reduction goal 5 Ibid. Figure 3 (continued) Operation (continued) - Require solar-ready roofs - Require organic collecticn in ne,%�; developments - Require landscaping in ne,-.l� developments (see CALGreen Divisions 4.3 and F-.3 and the Model %:'eater Efficient Landscape Ordinance [ICI%N ELO], which is re-erenced in CALF Teen). Regrl ire ..eater efficient landscape maintenance tc cc nserve water and reduce landscape °..vaste. - Achieve Zero Net Energy performance building standards prior to dates required by the Energy Cede - Encourage new construction, including municipal building construction, to achieve th ird-party green build in g certifications, such as the G reenPoint Rated prog ram, LEER rating s,Y ste m, or Living Bu ilding Oh allenge - Require the design of bike lanes to connect to the regional bicycle net,. c rk - Expand urban forestry and green infrastructLIre in new land developlrlent - Require preferential parking spaces for park and ride to i nce ntivize ca rpoc ling: v anpcoling. com rn niter bus, electric ve h isles. and rail sereice use - Require a transpc rkaticn management plan for specific plans -.vhich establishes a numeric target for non-SOS! travel and cve ra ll V10T - Develop a rideshare program targeting com meters to major earl plov rnent cente rs - Require the design of bus stops1shelters/express lanes in ne,..v deve Ic plrlents to promote the usage of mass-transit - Require gas outlets in residential backyards for use with outdoor cooking appliances such as gas barbeques if natural gas service is available - Require the installation of electrical outlets c n the exterior .�.alls cf both the front and back of residences to promote the use of electric landscape maintenance equ ipment5 - Require the desig n of the electric outlets and;or miring in ne,,Ar residentia 111 n it garages to promote electric vehicle usage - Require electric vehicle charging static !Cc ndUctive. inductive" and signage -or non-residential developments - Provide electric outlets to pronicte the rise of electric landscape maintenance egrl ipment to the extent -easible on parks and publictqu asi-public lands - Require each residential unit tc be "solar ready,:: including installing the appropriate hafd', ;are and prcper structural engineering - Require the installaticn of energy conserving appliances such as cn-deniand tank-less ,%�;ater heater and whole-house fans - Require each residential and commercial building equip buildings with energy efficient AC units and heating systems with programmable thermostatsitimers - Require large-scale residential developments and commercial buildings to report energy use, and set specific targets for per-capita energy use - Requi re each residential and commercial building to utilize lour flow water fixtures such as lo,.�; flc,,A, toilets and faucets (see CAL Green Divisions 4.3 and 5.3 as well as Appendices A4.3 and A5.3) Becerra, Alexis From: Juan Perez <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:57 PM To: eComment Subject: We need a nice hotel (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, We need nice hotels in Santa Ana so that we can have friends and family stay in Santa Ana and not send them to Costa Mesa. We already have enough housing. Thank you. Juan Perez i Becerra, Alexis From: Gabrielle Ridley <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:50 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Gabrielle Ridley i Becerra, Alexis From: damaris solis <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:58 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. damaris solis i Becerra, Alexis From: Vanessa Chavez <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:11 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Vanessa Chavez i Becerra, Alexis From: Yuri Lara <lara119@mail.chapman.edu> Sent: Thursday, September 11, 2025 8:16 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Yuri Lara i Becerra, Alexis From: Randee Tejeda <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:16 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Randee Tejeda i Becerra, Alexis From: Sarah Meza <smeza@orangeusd.org> Sent: Friday, September 12, 2025 11:26 AM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Sarah Meza i Becerra, Alexis From: Nicole Ortega <nortega@att.net> Sent: Friday, September 12, 2025 11:59 AM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Nicole Ortega i Becerra, Alexis From: Cenorino Gomez <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 5:49 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Cenorino Gomez i Becerra, Alexis From: Julio Castillo <noreply@adv.actionnetwork.org> Sent: Saturday, September 13, 2025 11:44 AM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Julio Castillo i Becerra, Alexis From: Francis Franklin <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:51 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Francis Franklin i Becerra, Alexis From: Megan Eierman <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:52 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Megan Eierman i Becerra, Alexis From: Micah you <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:56 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Micah you i Becerra, Alexis From: Greg C <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:57 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Greg C i Becerra, Alexis From: Angel Maldonado <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:10 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Angel Maldonado i Becerra, Alexis From: ALMA Moreno <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:19 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. ALMA Moreno i Becerra, Alexis From: Lisette Cabrera <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:27 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Lisette Cabrera i Becerra, Alexis From: Dulce Pineda <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 9:31 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Dulce Pineda i Becerra, Alexis From: Pedro Nava <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 12:41 AM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Pedro Nava i Becerra, Alexis From: richard ramirez <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 7:09 AM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. richard ramirez i Becerra, Alexis From: Mire Molnar <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 8:55 AM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Mire Molnar i Becerra, Alexis From: Johnyoel Yap <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 9:37 AM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Johnyoel Yap i Becerra, Alexis From: Rosalinda Arellsno <noreply@adv.actionnetwork.org> Sent: Saturday, September 13, 2025 9:58 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Rosalinda Arellsno i Becerra, Alexis From: seleny Arroyo <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:50 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. seleny Arroyo i Becerra, Alexis From: Cindy Spitzer <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:52 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Cindy Spitzer i Becerra, Alexis From: Susan Guadarrama <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:53 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Susan Guadarrama i Becerra, Alexis From: Ellen Heard <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:53 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Ellen Heard i Becerra, Alexis From: Lizette Negrete <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 7:54 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Lizette Negrete i Becerra, Alexis From: Suzanne Jaglowski <sjaglowski@sbcglobal.net> Sent: Thursday, September 11, 2025 8:01 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Councilmembers Mayor and, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Suzanne Jaglowski sjaglowski@sbcglobal.net i Becerra, Alexis From: Lauren Niggl <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:14 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Lauren Niggl i Becerra, Alexis From: Ellen Diamond <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:16 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Ellen Diamond i Becerra, Alexis From: Jocelyn Calderon <jocelyn.calderon@sbcglobal.net> Sent: Thursday, September 11, 2025 8:24 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Jocelyn Calderon jocelyn.calderon@sbcglobal.net i Becerra, Alexis From: Khanh Morales <noreply@adv.actionnetwork.org> Sent: Thursday, September 11, 2025 8:28 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Khanh Morales i Becerra, Alexis From: Marco Ayala <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 10:03 AM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove or limit hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Marco Ayala i Becerra, Alexis From: Holly Carpenter <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 10:29 AM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require a minimum on-site affordable units that are based on median income of residents . Thank you. Holly Carpenter i Becerra, Alexis From: Mey Nicolas <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 10:43 AM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Mey Nicolas i Becerra, Alexis From: Barbara Berrocal <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 11:48 AM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Barbara Berrocal i Becerra, Alexis From: Victor Perez <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 1:50 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Victor Perez i Becerra, Alexis From: Jacqueline Guadarrama <noreply@adv.actionnetwork.org> Sent: Friday, September 12, 2025 4:08 PM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Jacqueline Guadarrama i Becerra, Alexis From: Crystal Medina <noreply@adv.actionnetwork.org> Sent: Sunday, September 14, 2025 10:26 AM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Crystal Medina i Becerra, Alexis From: Ricardo Cardenas <noreply@adv.actionnetwork.org> Sent: Monday, September 15, 2025 12:00 PM To: eComment Subject: Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Ricardo Ci6'hrdenas i GAM ELENO BAND OL MISSION INDIANS-KIZH NATION 7 Historically 6own as The San Gabriel gancl of Mi,,,5ion Indians recognized 6,9 tke State of California as tke a aboriginal tribe of the Los Angeles basin Friday, September 5,2025 Jerry C. Guevara,AICP Senior Planner City of Santa Ana 20 Civic Center Plaza Santa Ana,CA 92702 RE: Objection to City of Santa Ana Final EIR—CEQA &AB 52 Violations Dear Mr. Guevera, The Gabrielefio Band of Mission Indians—Kizh Nation ("Kizh Nation") submits this formal response objecting to the City's decision,to (1)reject revisions requested through our government-to-government consultation and(2)revise Tribal Cultural Resource (TCR)mitigation measures in the Final Environmental Impact Report(Final EIR)based solely on a public comment letter submitted by the Juaneno Band of Mission Indians,who did not participate in AB 52 consultation and failed to provide substantial evidence of direct lineal connection to the Santa Ana project area. The City's actions constitute multiple violations of CEQA,AB 52, and California law, as detailed below. I. Failure to Conduct Good-Faith Consultation—PRC §21080.3.1 and Gov. Code §65352.4 • Under PRC §21080.3.l(b),once a California Native American tribe traditionally and culturally affiliated with the project area requests consultation,the lead agency must initiate consultation within 30 days and engage in meaningful,good-faith,government-to-government dialogue. The City substituted the views of a non-consulting entity Quanefio Band of Mission Indians)in place of consultation with the Kizh Nation,violating this statute. • Gov. Code §65352.4 defines "consultation"as a mutual process of seeking, discussing, and considering information,with the goal of reaching agreement. By failing to respect this process and by relying on a third-party letter instead,the City failed to meet its legal duty. Andrew Salas,Chairman Nadine Salas,Vice-Chairman Dr.Christina Swindall Martinez,Secretary Mike Jesus Lemos,Treasurer I Samantha Lemos,Treasurer II Richard Gradias,Chairman of the council of Elders PO box 595 Covina,CA 91725 www.,gabrielenoindians.org admin@gakrielenoindians.org Improper Reliance on Public Comments Instead of AB 52 Consultation—PRC §21082.3 • PRC §21082.3(d)requires that when an EIR identifies a Tribal Cultural Resource,the lead agency must document and consider the results of consultation,including whether agreed-upon mitigation measures can avoid or reduce impacts. The statute clearly distinguishes AB 52 consultation from general public comment. • Public comments are not a substitute for consultation and cannot override tribe-specific mitigation measures. By incorporating Juaneno Band comments,the City ignored its duty to reflect Kizh Nation consultation outcomes in the Final EIR. Lack of Substantial Evidence to Support Mitigation (PRC§21074 and§21082.2) • CEQA requires decisions to be supported by substantial evidence (PRC §21082.2). AB 52 defines "Tribal Cultural Resources"under PRC §21074,emphasizing that significance must be based on the cultural and historical knowledge of traditionally affiliated tribes. o The Juaneno Band did not provide substantial evidence demonstrating historical or genealogical connection to Santa Ana. o The City's reliance on this unsupported public comment violates CEQA's substantial evidence standard. Pattern of Late Responses and Neglect by Joyce Perry It has become evident through repeated projects that Joyce Perry consistently provides late responses or neglects to engage in timely consultation as required by AB 52. This pattern of delay and neglect appears to occur because: • This individual cannot provide substantial evidence demonstrating cultural affiliation or direct lineal connection to the geographic area or project site. • She uses late-stage public comments to attempt to insert herself into projects after consultation deadlines have passed,thereby avoiding the rigorous requirements of AB 52. This behavior not only violates PRC §21080.3.1(b) (timely initiation of consultation)but also undermines the integrity of CEQA by circumventing the very process intended to protect Tribal Cultural Resources. Misrepresentation and Mishandling of Tribal Mitigation Measures (PRC §21080.3.2 and CEQA Guidelines §15126.4) • Under PRC §21080.3.2(b),lead agencies must consult with each tribe separately, and mitigation measures developed during consultation are tribe-specific and cannot be shared or combined with other groups. Andrew Salas,Chairman Nadine Salas,Vice-Chairman Dr.Christina Swindall Martinez,Secretary Mike Jesus Lemos,Treasurer I Samantha Lemos,Treasurer II Richard Gradias,Chairman of the council of Elders PO box 393 Covina,CA 91723 www.,gakrie)enoindians.or� admin ftabrielenoindians.org o By incorporating non-affiliated parties such as Joyce Perry into the Kizh Nation's mitigation framework,the City breached confidentiality and violated our sovereign rights. o CEQA Guidelines §15126.4 requires mitigation to be feasible,enforceable,and specifically tailored to avoid or reduce significant impacts. o Generic mitigation suggestions by non-affiliated commenters fail this standard. Confidentiality Breach (PRC §21082.3(c)(1)) • PRC §21082.3(c)(1)requires that any information shared by tribes during consultation regarding sacred sites,locations,or cultural practices must remain confidential. o By sharing or merging our confidential mitigation measures with outside parties like Joyce Perry and the Juaneno Band,the City unlawfully disclosed protected information. Failure to Avoid or Minimize Impacts—PRC §21084.3(a) • CEQA and AB 52 place a preference on avoidance of impacts to Tribal Cultural Resources whenever feasible (PRC §21084.3(a)). o By relying on third-party comments and failing to implement Kizh Nation's avoidance- first measures,the City neglected this statutory requirement. Incorporating Miscellaneous Entities Without Substantial Evidence The inclusion of mitigation language provided by miscellaneous entities such as Joyce Perry,who has no direct lineal connection or did not provide substantial evidence or direct connection to the Santa Ana area, creates immediate and substantial harm to our cultural resources. This action: • Dilutes and disrupts tribe-specific mitigation required under AB 52 (PRC §21080.3.2(b)). • Causes direct damage to ancestral sites and sacred areas by allowing unqualified entities to dictate treatment standards. • Exposes the City to legal liability for failing to protect sensitive resources under CEQA. IL Specific CEQA and AB 52 Violations Summary Violation Statute/Guideline Failure to initiate meaningful consultation PRC §21080.3.1(b);Gov. Code §65352.4 Substituting public comment for consultation PRC §21082.3(d) Lack of substantial evidence to support PRC §21074; PRC §21082.2 mitigation Combining mitigation across tribes PRC §21080.3.2(b) Confidentiality breach of tribal information PRC §21082.3(c)(1) Andrew Salas,Chairman Nadine Salas,Vice-Chairman Dr.Christina Swindall Martinez,Secretary Mike Jesus Lemos,Treasurer I Samantha Lemos,Treasurer II Richard Gradias,Chairman of the council of Elders ro gox 393 Covina,CA 91723 www.,gakrie)enoindians.or� admin ftabrielenoindians.org Failure to prioritize avoidance of impacts PRC §21084.3(a) Generic,non-enforceable mitigation CEQA Guidelines §15126.4 Late responses and neglect of consultation PRC §21080.3.1(b) deadlines III. Requested Corrective Actions To bring the City back into compliance with CEQA and AB 52, we demand the following immediate actions: 1. Reinstate all Kizh Nation mitigation measures as presented during consultation. 2. Remove all language originating from non-consulting entities,including Joyce Perry and the Juaneho Band. 3. Resume government-to-government consultation with the Kizh Nation within 10 days,as required by PRC §21080.3.1. 4. Adopt enforceable,tribe-specific mitigation measures that prioritize avoidance, as required by PRC §21084.3(a)and CEQA Guidelines §15126.4. 5. Issue a corrective notice reaffirming the City's legal obligations under CEQA and AB 52. Failure to take these corrective actions will leave the City vulnerable to legal challenge and judicial invalidation of the project approvals. Conclusion The City's improper reliance on unverified public comments over direct consultation with the ancestral tribe is a fundamental violation of CEQA and AB 52. Furthermore, Joyce Perry's consistent pattern of late responses and neglect of consultation deadlines demonstrates her inability to provide substantial evidence or cultural affiliation to these projects and their geographic areas. This behavior undermines the purpose of AB 52 and results in mismanagement of sacred sites. The Kizh Nation, as the lineal descendants and sovereign government traditionally and culturally affiliated with Santa Ana,stands ready to continue consultation in good faith.However,we cannot allow non-affiliated individuals or groups to dictate the protection of our sacred lands and cultural heritage. Respectfully, Hereditary Chief Andrew Salas Gabrieleno Band of Mission Indians—Kizh Nation Andrew Salas,Chairman Nadine Salas,Vice-Chairman Dr.Christina Swindall Martinez,Secretary Mike Jesus Lemos,Treasurer I Samantha Lemos,Treasurer II Richard Gradias,Chairman of the council of Elders PO box 393 Covina,CA 91723 www.,gakrie)enoindians.or� admin ftabrielenoindians.org Becerra, Alexis From: Zapien, Gema Sent: Monday, September 15, 2025 2:17 PM To: !City Clerk Subject: FW: Support for the Segerstrom Family-Their Generosity Saved Our Children's Arts Education Good Afternoon, Please find below a public comment for item #28 (The Village Specific Plan). Thank you, Gema Zapien Acting Planning Commission Secretary 0 City of Santa Ana I Planning and Building Agency g 20 Civic Center Plaza I Santa Ana, CA 92702 (714) 667-2732 1 gzapien@santa-ana.org ;, .', www.santa-ana.org/pb City Hall hours are 8 a.m. to 5 p.m. Monday through Thursday, and 8:00 a.m. to 5:00 p.m. every other Friday. Click here for a list of observed holidays and Friday closure dates. From: Erica Pedraza <Erica@mclaw.org> Sent: Monday, September 15, 2025 12:43 PM To: eComments, PBA<pbaecomments@santa-ana.org> Subject: Support for the Segerstrom Family-Their Generosity Saved Our Children's Arts Education Attention:"This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Dear Santa Ana Planning Commissioners, We are writing as former parents of our student who attended Santiago Elementary School, for 6t"-8t" grades, to express my heartfelt gratitude to the Segerstrom Family. Several years ago, our beloved performing arts program — the only elementary school program of its kind in all of Orange County—was on the brink of disappearing. Without immediate funding, it would have ceased to exist. Thanks to the generous donation from the Segerstrom Family, the program not only survived but flourished. Their support gave us the critical two years we needed to secure grants and additional funding to keep it going. Today, my child and hundreds of others are learning confidence, teamwork, and creativity through the arts because of their gift. As we are both longtime residents of Santa Ana, we see firsthand how these programs impact these kids. More programs like this are needed in order to keep kids out of unhealthy environments. This is not just a program, it's a lifeline for students who might otherwise never have this opportunity. Please know the Segerstrom Family's contributions have had a profound and lasting impact on our school and community. Sincerely, Erica Pedraza i Jose Pedraza Erica Pedraza Paralegal/Bankruptcy Department Supervisor A4q Rfi IF CORPORATION 2112 Business Center Drive Irvine, CA 92612 949-252-9400, Ext. 399 949-252-1032 (fax) www.malcolmcisneros.com Follow our firm at:[It Certified Minority Owned Corporation Malcolm Cisneros,A Law Corporation, is an AV rated, regional commercial and civil litigation firm with offices across the Western United States in Phoenix,AZ; Irvine and Riverside, CA; Las Vegas, NV; Lake Oswego,OR; Dallas,TX; Seattle,WA. **CONFIDENTIALITY NOTICE** This email message is covered by the Electronic Communications Privacy Act, 18 U.S.C. §§ 2510-2521 and is legally privileged. It is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. 2 Becerra, Alexis From: David Benavides <david.benavides@kidworksoc.org> Sent: Monday, September 15, 2025 3:03 PM To: eComment Subject: Agenda Item 28 (The Village Santa Ana Project) - SA City Council, 9/16/25 Attachments: Agenda Item 28 - Village Santa Ana - Letter of Support (E Mandrup).pdf, Agenda Item 28 - Village Santa Ana - Letter of Support (D Benavides).pdf; Agenda Item 28 - Village Santa Ana - Letter of Support (G Magana).pdf Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Santa Ana City Clerk— Please find attached three letters of support for the 9/16/25 City Council Agenda Item#28(The Village Santa Ana Project). Thank you for distributing to the Mayor and City Council and entering into the record. David Benavides I Kid Works I Executive Director/CEO david.benavides@kidworksoc.org I kidworksoc.org 1902 W. Chestnut Ave., Santa Ana, CA 92703 Phone: (714) 834-9400 x 107 1 Mobile: (714) 651-4380 0000 1 2321 E. 4th Street,#C454 ECM Santa Ana, CA 92705 www.ecm.11c MANAGEMENT September 15, 2025 Re: Agenda Item 28 - The Village Santa Ana Specific Plan Dear Mayor and Honorable Council Members: As a proud board member of KidWorks, I'd like to express my strong support for the Segerstrom family and their many investments in the Santa Ana community, including the Village Santa Ana Project. As a Santa Ana resident, local business owner, and Board Chair for KidWorks, I can attest to the Segerstrom family's commitment to our community and its youth. Through their generosity, the Segerstrom family has invested in programs that give children the tools, skills, and confidence they need to succeed. Like KidWorks, they are committed to building a stronger community where every child can thrive. Our partnership is rooted in shared values of integrity, compassion, and an unwavering belief in investing in the next generation. Their dedication goes beyond financial contributions; over the years they have also given of their time; it reflects genuine care for the young people we serve and a desire to help them reach their full potential. It is a privilege to work alongside the Segerstrom family in our shared mission to create a better future for our community. Sincerely, Emily Mandrup Founder, ECM Management 1902 W. Chestnut Avenue lu Santa Ana, CA 92703 1A Office: 714.834.9400 Fax: 714-834.9494 KidWorks- www•kidworksoc.org September 15,2025 Re: Agenda Item 28 - The Village Santa Ana Specific Plan Project Santa Ana Mayor and Members of the City Council, I am writing this letter with reference to The Village Santa Ana Specific Plan Project before you for consideration. The project on its merits will bring many positive impacts to our city,including needed housing,jobs,real estate development revitalization, and economic growth.However,I would particularly like to share some points regarding the applicant. The success of any project relies heavily on the applicant,in this case the Segerstrom Company. As Executive Director of a Santa Ana youth development organization,I can confirm that C.J. Segerstrom and Sons is more than a company seeking to execute a real estate development project. The Segerstrom family has long-standing roots in our city and has been invested in the success of our community for a very long time. The Segerstrom family has a long-standing partnership with KidWorks and has made profound and lasting impacts on our mission.For nearly 30 years,the Segerstrom Family has stood beside us in our work to serve children,youth, and families in our community. They are more than generous donors;they are true neighbors who care deeply about the well-being and success of our students and their families. Their commitment is evident not only through their financial contributions but also through the time, energy, and encouragement they invest. The Segerstrom Family shows up. They attend our events,meet with our students, and offer encouragement to our staff,making them an active part of the KidWorks family. When KidWorks was in its infancy 28 years ago,members of the Segerstrom family opened their home to host,mentor, and encourage our college volunteer staff. Over the years they have been intentional about supporting many youth serving non-profits through the annual Festival of Children at Southcoast Plaza. They have also provided ongoing training,resourcing, and support to many non-profits in our community.Their leadership in the community sets a powerful example of how businesses, philanthropists,and residents can come together to create meaningful and lasting change. We are grateful for their partnership,their trust,and their dedication to building a brighter future for the youth and families of Santa Ana. Grateful to have the Segerstrom Company and Family committed to supporting the Santa Ana community. Respectfully submitted, David Benavides Executive Director/CEO,KidWorks KiclWorks...We Unleash Youth Potential 1902 W. Chestnut Avenue Santa Ana, CA 92703 lu Office:714.834.9400 IA Fax:714.834.9494 www.kidworksoc.org KidWorks- September 15, 2025 Re: Agenda Item 28 - The Village Santa Ana Project Dear Mayor and Members of the City Council, As the Sr. Director of Programs at KidWorks, I write this letter to express my support for the Segerstrom Family, whose steadfast generosity has been essential in sustaining and expanding KidWorks' educational, leadership, and mentorship programs. Their financial and in-kind contributions have helped us maintain and expand the quality and reach of initiatives such as after-school programs, college and career readiness, and youth leadership training. Without their support, many of these programs would not be possible at the same level of excellence. Several years ago, KidWorks was running a wait list for our programs serving Santa Ana youth. We had a dream of expanding our main community center. When members of the Segerstrom family heard about our dream for expansion, they decided that they wanted to make the dream a reality for our community's youth and families. They provided the vital lead gift to make KidWorks' expansion possible. We are now able to serve more Santa Ana youth and families and in more comprehensive ways. The Segerstrom Family's investment directly helps students from under-resourced neighborhoods gain access to the tools, mentors, and experiences they need to succeed. Time and again, their generosity has opened doors for students who may not have otherwise had the opportunity to envision and pursue a brighter future. We are deeply grateful for their belief in our mission and for the tangible difference they have made in the lives of our students. Sincerely, Gerardo Magana Sr. Director of Programs KidWorks Community Development Corporation KidWorks: Unleashing Youth Potential Becerra, Alexis From: Zapien, Gema Sent: Tuesday, September 16, 2025 9:35 AM To: !City Clerk Cc: Guevara, Jerry Subject: FW: LETTER OF STRONG SUPPORT FOR THE VILLAGE SANTA ANA SPECIFC PLAN PROJECT Attachments: LTR OF STRONG SUPPORT FOR THE VILLAGE SANTA ANA SPECIFIC PLAN PROJECT 09 15 2025.pdf; LTR OF STRONG SUPPORT FOR THE VILLAGE SANTA ANA SPECIFIC PLAN PROJECT 09 15 2025.pdf; LTR OF STRONG SUPPORT FOR THE VILLAGE SANTA ANA SPECIFIC PLAN PROJECT 09 15 2025.pdf; LTR OF STRONG SUPPORT FOR THE VILLAGE SANTA ANA SPECIFIC PLAN PROJECT 09 15 2025.pdf Good Morning, Please find attached additional public comments for The Village Specific Plan (item#28). Thank you, Gema Zapien Acting Planning Commission Secretary oCity of Santa Ana I Planning and Building Agency tor 20 Civic Center Plaza I Santa Ana, CA 92702 (714) 667-2732 1 gzapien@santa-ana.org ,1.',. www.santa-ana.org/pb City Hall hours are 8 a.m. to 5 p.m. Monday through Thursday, and 8:00 a.m. to 5:00 p.m. every other Friday. Click here for a list of observed holidays and Friday closure dates. From:Jon Preciado<jon@scdcl.org> Sent: Monday, September 15, 2025 4:37 PM To: eComments, PBA<pbaecomments@santa-ana.org>;Amezcua,Valerie<VAmezcua@santa-ana.org>; bvasquez@santa-ana.org; Phan,Thai <TPhan@santa-ana.org>; Lopez,Jessie<JessieLopez@santa-ana.org>; Bacerra, Phil <pbacerra@santa-ana.org>; Hernandez,Johnathan <JRyanHernandez@santa-ana.org>; Penaloza, David <DPenaloza@santa-ana.org> Cc:Adrian Esparza <adrian@local652.org>; Robert Ruiz<robert@local652.org>; Nunez,Alvaro<ANunez@santa- ana.org>; Mills, Susan <smills@santa-ana.org>; Leticia Preciado<leticia@scdcl.org> Subject: LETTER OF STRONG SUPPORT FOR THE VILLAGE SANTA ANA SPECIFC PLAN PROJECT Attention:This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Dear Honorable Mayor and City Council: Please find attached our letter of strong support for the project referenced above. Thank you for your consideration in this matter. Jon P. Preciado i Business Manager SOUTHERN CALIFORNIA DISTRICT COUNCIL OF LABORERS 1123 Park View Dr., Suite 300 Covina, CA 91724 (626) 350-6900 (phone) (626) 350-7583 (facsimile) SOUTHERN ERN LIFORNIA DISTRICT COUNCIL L3'9LUNA01 OF LABORER YOUR WORKFORCE LUTI N EDMW #LIUNASCDCL 2 `NSERNgT�O , o . o = ' SOUTHERN CALIFORNIA DISTRICT COUNCIL LiUNA. OF LABORERS JON P.PRECIADO Feel the Power Business Manager PETER SANTI LLAN Secretary-Treasurer SERGIO RASCON President September 15, 2025 AFFILIATED LOCALS SOUTHERN CALIFORNIA BURBANK SENT VIA EMAIL LOCAL 345 CITY OF SANTA ANA CITY COUNCIL HOLLYWOOD (PBAeComments@santa-ana.org) LOCAL 724 Mayor Valerie Amezcua Mayor Pro Tern Benjamin Vasquez LONG BEACH Councilmember Thai Phan LOCAL 1309 Councilmember Jessie Lopez LOS ANGELES Councilmember Phil Bacerra LOCAL 300 Councilmember Johnathan Ryan Hernandez ORANGE COUNTY Councilmember David Penaloza LOCAL 652 20 Civic Center Plaza POMONA Santa Ana, CA 92701 LOCAL 1414 Re: Letter of Strong Support for The Village Santa Ana Specific Plan RIVERSIDE AND IMPERIAL Project COUNTIES LOCAL 1184 SAN BERNARDINO,INYO, Dear Honorable Mayor and City Council: AND MONO COUNTIES LOCAL 783 On behalf of our ten affiliated local unions, our Orange County affiliate, SAN DIEGO Laborers Local 652, and our over 36,650 members throughout Southern LOCAL 89 California, I write to relay our strong support for the Village Santa Ana Specific VENTURA Plan Project and ask you to approve the project as recommended by Staff as it LOCAL 585 will create thousands of local jobs for Santa Ana residents; many of whom KERN, are our members. SAN LUIS OBISPO,AND NTA BARBARACOUNTIES The Southern California District Council of Laborers and the Western States LOCAL 220 Council of Carpenters are partnering Hines who will use one of our signatory ARIZONA general contractors to build this project should the be approved. You may PHOENIX,AZ LOCAL 1184 rest assured that our members who will be employed on and build this project will earn good paying, family sustaining wages and first-rate benefits LBUQUERQUE.NM Y NEW that will cover not only our members, but also their families. Further, the city ARQUE. LOCAL 16 can trust that the craft persons employed on this project will be skilled and trained and will build a first class project. Many of our members live in the SOUTHERN CALIFORNIA city of Santa Ana and throughout Orange county and would enjoy nothing DISTRICT COUNCILIL OF more than being able to work local) and end local) as well as being able LABORERS g Y P Y� g 123 Parkview Dr.,Suite 300 to spend more time at home after work rather than spending that time Covina,CA 91724 commuting to points unknown for work outside of Orange county. Phone(626)350-6900 Fax(626)350-7583 www.scdcl.org Qf 400 For all the reasons stated above, we ask that the City Council approve this project without any changes to the development agreement deal points or the public benefits package. On behalf of our members and affiliated local unions, including Laborers Local 652, we thank you for your consideration in this matter. Sincerely, SOUTHERN CALIFRONIA DISTRICT Jon P. Preciado Business Manager cc: Adrian Esparza, Business Manager, UUNA Local 652 (adrian@local652.org ) Robert Ruiz, Secretary-Treasurer, LIUNA LOCAL 652 (robert@local652.org) Alvaro Nunez, City Manager (anunez@santa-ana.org Sue Mills, Administrative Assistant to the City Manager (smills@santa-ana.org ) Becerra, Alexis From: Christine Maralit <christinem@mitchtsailaw.com> Sent: Tuesday, September 16, 2025 9:41 AM To: Guevara, Jerry; eComment; !City Clerk Cc: Mitchell M. Tsai Attorney at Law, P.C.; Omar Corona Subject: WSRCC - City of Santa Ana, The Village Santa Ana Specific Plan Project (SCH No. # 2020029087) (Agenda Item No. 28) - Supportive Comment Letter Attachments: 20250916_WSRCC_CityofSantaAna_TheVillage_SCL.pdf Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hello, Our office is submitting the attached supportive comment letter on behalf of WSRCC for the Tuesday, September 16, 2025 City Council Meeting on agenda item 28,The Village Santa Ana Specific Plan Project(SCH No. #2020029087). We would appreciate confirmation of receipt of this email and its attachment. Thank you, Christine Christine Maralit,Assistant Office Manager Mitchell M.Tsai Law Firm-Environmental and Land Use Litigation 139 South Hudson Avenue Suite 200 Pasadena, CA 911o1 Phone: (626)314-3821 Fax: (626)389-5414 Email: christinem(&mitchtsailaw.com Website: https://www.mitchtsailaw.com CONFIDENTIALITY NOTICE: This e-mail transmission,and any documents,files or previous e-mail messages accompanying it,may contain confidential information that is legally privileged. If you are not the intended recipient,or a person responsible for delivering it to the intended recipient,you are hereby notified that any disclosure,copying,distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error,please immediately notify us by reply e-mail at christinem(a)mitchtsailaw.com or by telephone at(626)314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. 1 0 P: (626) 314-3821 Mitchell M. Tsai 139 S. Hudson Ave., Suite 200 E:info@mitchtsaHaw.com Law Firm Pasadena, California 91101 VIA E-MAIL September 16, 2025 City of Santa Ana, City Council 22 Civic Center Plaza Santa Ana, CA 92701 Em: eComment(iLanta-ana.org RE: City of Santa Ana, The Village Santa Ana Specific Plan Project (SCH No. #2020029087) (Agenda Item No. 28) Dear Santa Ana City Councilmembers: On behalf of the Western States Regional Council of Carpenters ("Western Carpenters" or "WSRCC"), our Office is submitting these comments for the City of Santa Ana City Council's meeting addressing the proposed development project known as The Village Santa Ana Specific Plan Project (SCH No. #2020029087) ("Project"). WSRCC would like to express its support for this Project. After further reviewing this Project, WSRCC believes that the Project will benefit the environment and the local economy by practicing protocols that will protect worker health and safety and will incorporate adequate environmental mitigation. Should the City have any questions or concerns, the City should feel free to contact our office. Sincerely, Omar Corona Attorneys for Western States Regional Council of Carpenters Becerra, Alexis From: Timothy Rush < Sent: Tuesday, September 16, 2025 12:19 PM To: eComment Subject: THE VILLAGE Redevelopment project, @ south coast Village Attention:This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. On behalf of the members of the G7 Neighborhood Leaders Alliance (Neighborhood Leader's from 18 different neighborhood associations)we wish to express our unanimous support for THE VILLAGE REDEVELOPMENT PROJECT which is on your agenda this evening and is being brought forward by a joint venture with CJ Segarstrom &Sons. Given the long history that our city has of not only quality development, but incredible engagement with the residence and stakeholders of our communities we believe that this well designed and planned project needs your approval.This will be a wonderful addition to the South Coast Metro area, as well as a wonderful book end for RELATED BRISTOL DEVELOPMENT. Thank you for your thoughtful consideration of this project and it's impact to the residence of not just the immediate neighborhoods but the entire city as we will all benefit from this important site. Sincerely, Tim Rush Chair& Founder G7 Neighborhood Leaders Alliance "Leaders leading the way to a better Santa Ana" Sent from my iPhone i Flores, Dora From:Jimmy Elrod <jelrod@wscarpenters.org> Sent:Tuesday, September 16, 2025 12:48 PM To:eComment Cc:John Tafoya; Jacob Lopez; John Hanna Subject:Letter of Support for Agenda Item 28 - Village Santa Ana Specific Plan Attachments:Letter of Support - Village Project.pdf Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Dear City Clerk, I have attached a letter of support from the Western States Regional Council of Carpenters regarding Agenda Item 28, the th Village Santa Ana Specific Plan, scheduled for consideration at the September 16 City Council meeting. We respectfully request that this letter be included in the public record for the meeting. Thank you so much for your help. Sincerely, Jimmy Elrod Deputy Political Director Western States Regional Council of Carpenters 909.665.3273 . Download our app: Google Play | iTunes App Store Disclaimer The information contained in this communication from the sender is confidential. It is intended solely for use by the recipient and others authorized to receive it. If you are not the recipient, you are hereby notified that any disclosure, copying, distribution or taking action in relation of the contents of this information is strictly prohibited and may be unlawful. 3 September 16, 2025 City of Santa Ana Councilmembers and City Manager 26 Civic Center Plaza Santa Ana, CA 92701 Dear Members of the Council, On behalf of the Western States Regional Council of Carpenters, I am writing to express our strong support for the Village Project, which will be considered at the September 16th City Council meeting. Our union has deep roots in Santa Ana and across Orange County. We are proud to represent approximately 1,200 hardworking members who live right here in the city. They are raising families, supporting local businesses, and contributing to the community every day. The Village Project is an opportunity to strengthen Santa Ana. It will create good- paying local jobs for our members, bring new economic investment, and deliver lasting benefits that families can rely on for years to come. Just as importantly, it is a project that our membersyour neighborswill be directly involved in building. This effort has gone through a thorough and transparent process, with input from neighbors, community leaders, city staff, and labor. We respectfully ask the Council to approve this project and help ensure that Santa Ana remains a place where working families can thrive. Thank you for your leadership and for considering our voice in this important decision. With respect and appreciation, Jacob Lopez Regional Manager Western States Regional Council of Carpenters CC: Jimmy Elrod Flores, Dora From:Irma Jauregui <irmapj@yahoo.com> Sent:Tuesday, To:eComment Subject:Support item 28, The Village at Sunflower Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Hello Mayor Amezcua and council members, I’m writing in support of item 28 which is the redevelopment of The South Coast Village and agree that in expediting the process, this redevelopment hopefully can be done in close time proximity as is the project of Related Bristol. Not only will in bring more employment, tax revenue and continue to enhance the value of our city overall, but if done in same time frame, it will also alleviate and shorten the construction time any inconveniences our surrounding neighborhoods. Thanks you again, Irma P Jauregui Wilshire Square resident 1 Flores, Dora From:David Benavides <david.benavides@kidworksoc.org> Sent:Tuesday, September 16, 2025 3:37 PM To:eComment Subject:Agenda Item 28 (The Village Santa Ana Project) - SA City Council, 9/16/25 (additional letter) Attachments:Agenda Item 28 - Village Santa Ana - Letter of Support (E Sanchez).pdf Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Santa Ana City Clerk – Please find attached an additional letter of support for the 9/16/25 City Council Agenda Item #28 (The Village Santa Ana Project). Thank you for distributing to the Mayor and City Council and entering into the record. David Benavides | KidWorks | Executive Director/CEO david.benavides@kidworksoc.org | kidworksoc.org 1902 W. Chestnut Ave., Santa Ana, CA 92703 Phone: (714) 834-9400 x 107 | Mobile: (714) 651-4380 1 1902 W. Chestnut Avenue Santa Ana, CA 92703 Office: 714.834.9400 Fax: 714-834.9494 www.kidworksoc.org September 16, 2025 Re: Agenda Item 28 - The Village Santa Ana Project Santa Ana Mayor and Members of the City Council, As a proud KidWorks alumna, I know firsthand the difference that community investment makes in the lives of young people. Growing up in Santa Ana and being part of KidWorks gave me the tools, skills, and confidence to pursue my goals; I am currently working on completing my Doctorate in Education and recently returned to KidWorks as Associate Director of Programs. I am grateful for those partners that have supported KidWorks youth in reaching our goals. The Segerstrom family has long been one of those champions. Their generosity has supported programs that not only shaped my own journey but continue to empower hundreds of students every year. Their commitment goes beyond financial giving; it reflects genuine care for the young people of our city and a desire to help us reach our full potential. Like KidWorks, the Segerstrom family believes in building a stronger community where every child can thrive. Their values of integrity, compassion, and dedication to the next generation are evident in both their actions and their investments. For these reasons, I gladly extend my voice of support, along with many other youth and families in Santa Ana for the Segerstrom family and their proposed improvements of The Village Santa Ana Project. Sincerely, Erika Sanchez KidWorks Alumna and Santa Ana Resident KidWorks…We Unleash Youth Potential Flores, Dora From:Kara Grant <kara@grant-law.net> Sent:Tuesday, September 16, 2025 5:46 PM To:eComment Cc:Guevara, Jerry; Andrew Salas; Sophia Pina; Gabrieleno Administration Subject:URGENT - AGENDA ITEM 28 - PUBLIC COMMENTS Attachments:2025.09.16 - Kizh Nation - Public Comments re Agenda Item 28.pdf Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Good Evening, Please include the public comments attached comments for the Village at Santa Ana Specific Plan agenda item tonight. Please confirm receipt. Thank you, Kara E. Grant | attorney at law KARA GRANT LAW 3 ! ! IVOUJOHUPO!CFBDI-!DB!:3759!!f}!lbsbAhsbou.mbx/ofu!u}!825/432/8583! ! ! WJB!F.NBJM!POMZ! ! ! ! Tfqufncfs!27-!3136! ! ! !! ! SF;!!!!!Bhfoeb!Jufn!39!Ä!Qvcmjd!Dpnnfout<!uif!Wjmmbhf!Tboub!Bob!Tqfdjgjd!Qmbo!! ! ! ! Efbs!Nbzps!boe!Nfncfst!pg!uif!Djuz!Dpvodjm;!! ! ! 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Obujpo!jotjtut!uibu!bmm!Usjcbm!Dvmuvsbm!Sftpvsdf!njujhbujpo!nfbtvsft!sfnbjo! jnqmfnfoufe!tpmfmz!boe!fydmvtjwfmz!cz!uif!Lj{i!Obujpo-!uif!ÆfyqfsuÇ!pg!jut!usjcbm!dvmuvsbm! sftpvsdft!qvstvbou!up!DFRB/!! ! Xf!sftqfdugvmmz!sfrvftu!uibu!uif!Djuz!xjuiesbx!uif!qspqptfe!npejgjdbujpo!boe! sfbggjsn!jut!dpnqmjbodf!xjui!DFRB!boe!BC!63!cz!beifsjoh!up!uif!njujhbujpo!gsbnfxpsl! bmsfbez!bhsffe!vqpo!xjui!uif!Lj{i!Obujpo/!Qmfbtf!dpogjsn!jo!xsjujoh!uibu!uif!Djuz!xjmm! ublf!uif!ofdfttbsz!tufqt!up!beesftt!uijt!nbuufs/!Tipvme!zpv!ibwf!boz!rvftujpot!sfhbsejoh! uijt!mfuufs-!qmfbtf!gffm!gsff!up!dpoubdu!nf!bu!)825*!432.8583-!ps!cz!fnbjm!bu!lbsbAhsbou. mbx/ofu/!! ! ! Tjodfsfmz-!! ! ! ! Lbsb!F/!Hsbou!!! ! hsbou.mbx/ofu! Flores, Dora From:vpfacilities@santaanapony.com Sent: 53 PM To:eComment Subject:Public Hearing Item #28 Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Good evening Mayor and Councilmembers, My name is Carlos Castellanos, and I serve as the Vice President of Facilities for Santa Ana Pony Baseball out of Riverview Park. We are the largest youth baseball league in the City. With me are a few of our players … I want to take a moment to recognize the Segerstrom Family for their longstanding support of our league and local youth programs across the city. Over the years, they have helped fund special event permits and provided resources for essential safety equipment, allowing us to offer hundreds of local children a safe and positive place to learn teamwork, leadership, and sportsmanship through baseball. While our organization does not take a position on development proposals, I want to acknowledge the Segerstrom Family as a valued community partner who has made a meaningful difference in the lives of our young athletes and their families. I also want to take to take this opportunity to thank the city’s Public Works and Parks staff for the hard work in maintaining some of the smoothest fields in all of Orange County. Thank you. Sent from my T-Mobile 5G Device Get Outlook for Android 4 Becerra, Alexis From: Irene Lara <noreply@adv.actionnetwork.org> Sent: Wednesday, September 17, 2025 9:27 AM To: eComment Subject: Housing 1st not Hotels Please Remove Hotel Uses from the Specific Plan (Item #28) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, I urge you to change the proposed Village Santa Ana Specific Plan to remove hotel uses. Currently, hotels are not allowed on the site, and the proposed project currently does not include any hotel uses, nor were any specific hotel uses evaluated as part of the environmental review for the project. However, the proposed plan would allow hotels to be built by right, without any opportunity for public participation in the future. Most places in the City do not allow hotels to be approved in this way. The City Council should continue to have the ability to decide whether hotel development works for the community. We are in a housing crisis, not a hotel crisis. To that end, I ask that you please remove the hotel uses under the plan. Thank you kindly Irene Lara irene.energy@gmail.com PO Box 11104 Santa Ana, California 92711 i Becerra, Alexis From: Chris Flores <noreply@adv.actionnetwork.org> Sent: Friday, September 19, 2025 11:26 AM To: eComment Subject: Santa Ana Needs Homes, Not Hotels (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana has a dire need for housing, especially affordable housing, amid the state's housing crisis. And while the city has made many strides with adding housing, it is very concerning that the proposed Village Santa Ana Specific Plan allows hotels by-right, which means no public input that would allow us to decide whether the proposal is good for the community and the City. We should be making it easier to build affordable housing on-site, not hotels. Please remove hotel uses from the proposed Specific Plan and require at least some on-site affordable units. Thank you. Chris Flores i Becerra, Alexis From: Angelica Gamez <noreply@adv.actionnetwork.org> Sent: Tuesday, September 23, 2025 12:26 PM To: eComment Subject: Please Consider Much-Needed Affordable Housing (Item #28, Village Santa Ana Specific Plan) Attention: This email originated from outside of City of Santa Ana.Use caution when opening attachments or links. Hon. Mayor and Councilmembers, Santa Ana is in desperate need for affordable housing. This project would create up to 1,583 needed residential units but not a single unit on-site is affordable. Too many working people can't afford to live closer to where they work, spending hours away from their families in traffic. However, because the Development Agreement allows the developer to pay the lowest in-lieu fee ($5/sq. ft.), rather than provide on-site affordable housing, the Village Specific Plan could move forward without a single affordable unit on-site—despite the community's urgent need. Accordingly, we urge you to require some portion of the housing to be affordable housing. Please do not move forward with the Village Santa Ana plan, until this and other concerns are addressed. Thank you. Angelica Gamez i