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31B - SIGN PROGRAM MAINPLACE
REQUEST FOR COUNCIL ACTION CITY COUNCIL MEETING DATE: JUNE 2, 2015 TITLE: REGIONAL PLANNED SIGN PROGRAM NO. 2014 -01 AT WESTFIELD MAINPLACE AT 2800 NORTH MAIN STREET — GREGG BERWIN, APPLICANT (STRATEGIC PLAN NO. 3,2) CITY MANAGER [ «Zt �,TF11 ffAq L01j1J CLERK OF COUNCIL USE ONLY: -t• r ❑ As Recommended ❑ As Amended ❑ Ordinance on 1st Reading ❑ Ordinance on 2nd Reading ❑ Implementing Resolution ❑ Set Public Hearing For CONTINUED TO FILE NUMBER Receive and file the staff report approving Regional Planned Sign Program No. 2014 -01 as conditioned. PLANNING COMMISSION ACTION At its regular meeting on May 11, 2015 by a vote of 6:0 (Alderete absent), the Planning Commission adopted a resolution approving Regional Planned Sign Program No. 2014 -01 with a nominal modification to Condition No. 04 (clarified the five - percent requirement for public messages on digital advertising displays) and the addition of Condition No. 13 (to require the words "Santa Ana" on all vehicle entry monument signs) as outlined in the attached staff report (Exhibit A). DISCUSSION Gregg Berwin, representing Westfield MainPlace, is requesting approval of a comprehensive regional planned sign program at 2800 North Main Street pursuant to Section 41 -885 of the Santa Ana Municipal Code (SAMC). Specifically, the applicant is requesting approval of a variety of wall, freestanding, pylon, digital, and mimetic signs at the existing regional shopping center. These signs are intended to display or advertise stores or products sold on site. Full -sized plans are available for public viewing in the Clerk of the Council Office. STRATEGIC PLAN ALIGNMENT Approval of this item supports the City's efforts to meet Goal No. 3 Economic Development, Objective No. 2 (create new opportunities for business /job growth and encourage private development through new General Plan and Zoning Ordinance policies). 31 B -1 Regional Planned Sign Program No. 2014 -01 June 2, 2015 Page 2 FISCAL IMPACT There is no fiscal impact associated with this action. Vince Fregoso; ALQP-- Interim Executive Director Planning & Building Agency AP:kg ap\M: Reports \Staff Reports for CC \RSPG14 -01 Westfield MalnPlace Signage.cc Exhibit: A. Planning Commission Staff Report 31 B -2 PlIan i (" rrirr'tl soo n Acflon PLANNING COMMISSION MEETING DATE MAY 11, 2015 fl "t'I_E: PUBLIC HEARING — FILED BY GREGG BERWIN TO ALLOW REGIONAL PLANNED SIGN PROGRAM NO. 2014 -01 AT WESTFIELD MAINPLACE AT 2800 NORTH MAIN STREET (STRATEGIC PLAN NO. 3,2) Prepared by Ali rector RECOMMENDED Aurm PI ANNING COMMISSION SECRETARY APPROVED A As Recornmei7ded I I As.+Amended El Scat Public Ho wing Far DENIED f::l Appliranf's, Request EI Staff Rer. ;orrunendration LSO f INUED I() Acting Ellranning Manager Adopt a resolution approving Regional Planned Sign Program No. 2014 -01 as conditioned. Request of the Applicant Gregg Berwin, representing Westfield MainPlace, is requesting approval of a comprehensive regional planned sign program at 2800 North Main Street pursuant to Section 41 -885 of the Santa Ana Municipal Code (SAMC). Specifically, the applicant is requesting approval of a variety of wall, freestanding, pylon, digital, and mimetic signs at the existing regional shopping center. Project Location and Site Description The project site is approximately 52 -acres in size and contains a multi - tenant regional mall known as Westfield MainPlace that is located at the northwest corner of North Main Street and MainPlace Drive. The site is anchored by JC Penney, Macy's, and Nordstrom department stores and contains numerous retail and eating establishments. The proposed regional planned sign program will contain a variety of signage types that will be installed throughout the site and on the mall buildings. Westfield MainPlace contains approximately 1,128,000 square feet of tenant space and was significantly remodeled and expanded in 1987. Mall tenants currently share 4,768 parking spaces provided in a combination of surface parking lots and parking structures. The site is surrounded by the Garden Grove (State Route 22) Freeway to the north, professional and administrative office uses to the south, commercial and residential uses within the City Place development to the east, and the Santa Ana (Interstate 5) Freeway to the west (Exhibits 1, 2 and 3). 31 B -3 Regional Planed Sign Program No. 2014 -01 May 11, 2015 Page 2 Project Description The applicant is proposing to construct a variety of signs in several distinct categories: wall, freestanding, pylon, digital, and mimetic sign types at Westfield MainPlace. These signs are intended to display or advertise stores or products sold on site. A combination of wall signs are proposed to advertise the anchor tenants at the site, including JC Penney, Macy's, and Nordstrom, as well as the Picture Show cinemas and other prominent interior tenants. Other wall signs colloquially referred to as "lifestyle signs" will display stores or products sold at the mall. The proposed freestanding signs will be located along Main Street and Main Place Drive and will contain sign panels for major tenants and department stores, restaurants, and directional purposes. In addition to the wall and freestanding signs, the applicant proposes to construct four pylon signs: three along the Santa Ana (1 -5) Freeway and one along the Garden Grove (SR -22) Freeway. Among the three Santa Ana Freeway signs, two are proposed to be two -sided static displays and one is proposed to be two -sided digital. The digital pylon will contain panels advertising major tenants, a time and temperature display, and a Westfield MainPlace Santa Ana sign. The proposed two -sided digital pylon sign along the Garden Grove Freeway will be similarly designed, with the exception of an additional, smaller digital panel to advertise current film and show times at the Picture Show cinemas. All pylons, static and digital, are proposed to be 80 feet tall. The proposed digital signs will utilize LED lighting, with both automatic and manual dimming capabilities part of the sign function. The sign will also incorporate a minimum of five percent of the display time (minirnum of three minutes per hour) to the City for public service announcements, warning messages or other similar messages as requested by the City. Finally, the applicant is proposing a mimetic sign for Round 1 Entertainment, a bowling and family entertainment venue located on the ground floor of the former Men's Macy's building. This mimetic sign will take the form of a 17 -foot tall bowling pin, which complements the logo and advertises the services offered by Round 1 Entertainment. The mimetic sign is proposed to be located adjacent to the eastern (primary) entrance to Round 1 Entertainment (Exhibit 4). Project Background Since 2012, Westfield has carried out numerous tenant and fagade improvements for multiple new restaurants at MainPlace mall. These improvements have reshaped the traditional mall experience, establishing stores that are accessible from both within the existing mall's interior corridor and from outside entrances that are intended to resemble individual storefronts. Some of these recent improvements include restaurants located near Macy's and JC Penney (Saigon de Pho, Genki Sushi, Boudin, and Johnny Rocket's), on the west side of the mall (Blaze Pizza and Dog Haus), and restaurants and stores in the former Men's Macy's building (Round 1 Entertainment, Panini Cafe, Ashley Furniture, 24 Hour Fitness, Lucille's, and Wokcano). The subject application for a regional planned sign program will create opportunities for additional marketing of these establishments and stores and products sold on the entire mall site. 31 B -4 Regional Planed Sign Program No. 2014 -01 May 11, 2015 Page 3 In March 2014, the City Council adopted Ordinance No. NS -2861. This ordinance amended standards for on- premise signage, creating provisions that allow certain commercial centers and attractions to apply for regional planned sign programs containing unique signage, including digital displays, on the subject premises. The ordinance also requires that the regional planned sign programs be reviewed by the Planning Commission. General Plan and Zoning Analysis The General Plan land use designation for the subject site is District Center (DC). District Center land use districts provide highly visible and accessible commercial development along the City's arterial transportation corridors and provide important neighborhood facilities and services, such as this regional commercial center. The project site is consistent with this General Plan land use designation. The subject site is located within the General Commercial (C -2) zoning district. The C -2 zoning district allows for retail and service uses such as regional malls with on- premise signage, making the proposed use consistent with the zoning designation. Project Analysis Regional planned sign program requests are governed by Section 41 -885 of the SAMC. Regional planned sign program requests may be granted when it can be shown that the following can be established: ® The scale and intensity of the proposed signage is consistent and harmonious with surrounding land uses and does not create conditions that could contribute to visual or physical blight intrusion or similar incompatibilities. a The location of the proposed signage will not contribute towards a hazardous environment for pedestrians, cyclists or motorists on City streets or freeways. e The proposed signage is compatible with the scale, intensity, and site development characteristics on which it is proposed, which may be determined by height of existing or proposed buildings on -site, the quantity of freestanding buildings, facades, and street frontages, the scale of buildings as they relate to pedestrian and vehicular access surrounding land uses and transportation corridors; visibility from streets, highways, pedestrian areas, rail corridors bikeways other transportation routes, parks, and other public, spaces; architecture color(s), material( s), illumination, and other site characteristics; the nature of business activities conducted on -site; and visibility from any property used or zoned for residential purposes. 31 B -5 Regional Planed Sign Program No. 2014 -01 May 11, 2015 Page 4 If these findings can be made, then it is appropriate to grant the regional planned sign program permit. Conversely, the inability to make these findings would result in a denial. Using this information staff has prepared the following analysis, which, in turn forms the basis for the recommendation contained in this report. The new ordinance approved in 2014 requires applications for regional planned sign program be reviewed in a manner consistent with conditional use permits, as detailed in Sections 41 -633 through 41 -651 of the SAMC. The ordinance also contains findings of fact for planned sign programs, which are intended to ensure that the scale and intensity of the proposed signage is consistent with surrounding land uses, that the location of the proposed signage will not create a hazardous environment for those on City streets or nearby freeways, and that the proposed signage is compatible with the scale, intensity, and site development characteristics. Further, the ordinance contains provisions for electronic message displays ( "digital signs ") in planned sign programs for regional commercial centers and regional attractions. The review of these digital signs is intended to establish baseline conditions for all electronic message displays that would protect the health, safety, and welfare of those within viewing distance of such signage while also allowing flexibility in digital technology as it advances over time. Staff review of the proposed regional planned sign program indicates that the proposed signage and the digital reader board technology are consistent with the provisions of the ordinance. First, the Westfield MainPlace site is eligible to apply for an electronic sign as it meets the definition of a regional commercial center. Second, the proposed signage will comply with the conditions imposed on electronic message display signs, including provisions that the sign: be oriented to minimize visual and light emitting intrusion onto residentially zoned or used properties, produce a maximum light level of 0.3 foot - candles over ambient light levels, incorporate a means to ensure flexibility in reducing light levels upon request by the City, and provide a means of limiting excessive light or glare and have automatic diming capabilities. Third, the digital sign copy will also be restricted to change only through an immediate transition of the message that does not have the appearance of moving text or images, shall not use flashing, intermittent or moving lights or produce the optical illusion of movement, and shall be on display for a minimum of eight seconds. Fourth, the two proposed digital signs will not be located within 50 feet of a traffic signal or sign, or at a location that would not maintain safe conditions for motorists, pedestrians or cyclists as determined by the Public Works Agency. Finally, a minimum of five percent of the display time (three minutes per hour) will be allocated for public service announcements or warning signs as requested and provided by the City. In analyzing the regional planned sign program request, staff believes that the following findings of fact warrant approval of the regional planned sign program. MEW Regional Planed Sign Program No. 2014 -01 May 11, 2015 Page 5 The proposed signage contained within the regional planned sign program is designed to be consistent and harmonious with the surrounding commercial land uses and will not contribute to visual or physical blight. The location and height of the signs are needed due to the orientation of the site toward the Santa Ana and Garden Grove freeways. Both freeways' development, with a combination of at -grade and below -grade configurations, limits visibility of the MainPlace mall. Additional signage opportunities will maximize view of the site for pedestrians and cyclists on City streets and for motorists on adjacent freeways. Further, signage will be oriented toward traffic on the freeways, streets, and on -site travel lanes, which will minimize light impacts on residential uses located across the freeways and at City Place across Main Street. The digital signs will incorporate the latest technologies that will minimize light intrusion into neighborhoods, including automatic and manual dimmers that will regulate the lighting levels that may spill into adjacent uses. m The proposed signs will be located on private property that is adjacent to two freeways (Interstate 5 and State Route 22), as well as major local arterials (Broadway and Main Street). The signs are designed to be in scale with the surrounding streetscape, which will minimize the potential for creating a hazardous environment for pedestrians, cyclists or motorist travelling in the immediate vicinity where the signs are visible. The proposed signage will be compatible with the scale and site development characteristics on which they are proposed as the signs will be placed in strategic locations intended to maximize visibility of the mall, which is the intended audience for the signs. The 80 -foot height of the pylon and digital signs will allow the signs to be visible from local freeways whose viewships are limited by overcrossings, significantly wide rights -of -way, and below -grade configurations. Further, the proposed signage, including the digital reader board signs, are an appropriate means of advertising the multitude of stores and products sold at the regional commercial center. Finally, the proposed signs will be architecturally compatible with one another and with the buildings found at Westfield MainPlace. Public Notification The project site is not located within the boundaries of an established Neighborhood Association. However, staff contacted the presidents of the nearby Fisher Park, Morrison /Eldridge Park, and Park Santiago neighborhood associations to inform them of the project and answer any questions related to the proposed project. The contact person for the Fisher Park Neighborhood Association inquired about the location and quantity of the proposed signs. Staff emailed the contact person two site plans and a view rendering of the pylon signs to provide further clarification. Moreover, the project site was posted with a notice advertising this public hearing, a notice was published in the Orange County Reporter, and mailed notices were sent to all property owners and tenants within 500 feet of the project site. At the time of this printing, no correspondence, by phone, written, or electronic, had been received from any members of the public. 31 B -7 Regional Planed Sign Program No. 2014 -01 May 11, 2015 Page 6 CEQA Analvsis In accordance with the California Environmental Quality Act, the proposed project is exempt from further review pursuant to Sections 15303 and 15311. Section 15303 applies to construction of small structures, and Section 15311 applies to structures accessory to a commercial use, with the proposed on- premise signs serving as minor structures that are accessory to the primary regional commercial center use. Categorical Exemption Environmental Review No. 2015 -36 will be filed for this project. Strategic Plan Alignment Approval of this item supports the City's efforts to meet Goal No. 3 Economic Development, Objective No. 2 (create new opportunities for business /job growth and encourage private development through new General Plan and Zoning Ordinance policies). Conclusion Based on the analysis provided within this report, staff recommends that the Planning Commission approve Regional Planned Sign Program No. 2014 -01 as conditioned. Ali Pezeshkpour Assistant Planner I AP:jm Ap1M. \Reports \Staff Reports for PC\RSPG 2014 -0 1 MainPlace Signs 2800 N Main.pc. Attachments: Exhibit 1 — General Vicinity Map Exhibit 2 — Land Use Map Exhibit 3 — Site Photograph Exhibit 4 — Regional Planned Sign Program MWOO Al GEtl8 LAGP WEOJRALr (N CGAAMEPJALRSOWOAL m SNG FAM LYI H001nk 8 RwNGMCOIFlualm Cr.', CCAA PAOITp3JiE R2 PAO FAMILY FS30 CE CS%i CUMM&UALS)UNMAIN Mi Ui MN01JSRAL P1 MULIIREDENSWKIULnRE ,t C NIU ONWMM6 AL M2 HFAWIND lsmL FAMILYF EDUV, CbMD C M. 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O LW z 2 19 31 B-73 NW QQ Fa (D 0 Z Z LU U a- 91 N y > LL- LO N (D 4- V) c c E O p 31 B -74 a Z D 0 v Z E 2 31 B-75 gz tL O 9 NW uz R Z Z rd LLJ U CL CQ 19 0 z n 0 R 31 B-76 21 " 1 9 L-U O 0, wz Nw u Z R 0 Z 0 O Z Z U IL z CQ C) z D 0 0 z E 0 LU w 31 B-77 / \ \\ 0 z 0 ■ O�, uz Fg7 0 z u LL CL z I D z w uj 31 B-78 \ � z =1 0 R T 0 ■ LLJ 7 Q DC) Z R 0 z z r) w u CL z I LS 5.12.15 RESOLUTION NO. 2015 -16 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF SANTA ANA APPROVING REGIONAL PLANNED SIGN PROGRAM NO. 2014 -01 AS CONDITIONED TO APPROVE THE COMPREHENSIVE REGIONAL PLANNED SIGN PROGRAM FOR WESTFIELD MAINPLACE LOCATED AT 2800 NORTH MAIN STREET BE IT RESOLVED BY THE PLANNING COMMISSION OF THE CITY OF SANTA ANA AS FOLLOWS: Section 1. The Planning Commission of the City of Santa Ana hereby finds, determines and declares as follows: A. The applicant is requesting approval of Regional Planned Sign Program No. 2014 -01 as conditioned to allow the construction of a variety of wall, freestanding, pylon, digital, and mimetic signs at the existing Westfield MainPlace which is a "regional commercial center" per Santa Ana Municipal Code Section 41.885 (a)(1). The proposed regional planned sign program will contain a variety of signage types that will be installed throughout the site and on the mall buildings. B. Santa Ana Municipal Code Section 41 -885 requires a regional planned sign program to be approved by the Planning Commission. C. On May 11, 2015, the Planning Commission held a duly noticed public hearing regarding Regional Planned Sign Program No. 2014 -01. D. The Planning Commission determines that the following findings, which must be established in order to grant this Regional Planned Sign Program pursuant to Santa Ana Municipal Code Section 41 -885, have been established for Regional Planned Sign Program No. 2014 -01 to allow for the variety of wall, freestanding, pylon, digital, and mimetic signs at the existing regional shopping center: 1. The scale and intensity of the proposed signage is consistent and harmonious with surrounding land uses and does not create conditions that could contribute to visual or physical blight intrusion or similar incompatibilities. The proposed signage contained within the regional planned sign program is designed to be consistent and harmonious with the surrounding commercial land uses and will not contribute to visual or physical blight. The location and height of the signs are needed due to the orientation of the Resolution No. 2015 -16 31 B -79 Page 1 of 6 site toward the Santa Ana and Garden Grove freeways. Both freeways' development, with a combination of at -grade and below -grade configurations, limits visibility of the Westfield MainPlace mall. Additional signage opportunities will maximize view of the site for pedestrians and cyclists on City streets and for motorists on adjacent freeways. Further, signage will be oriented toward traffic on the freeways, streets, and on -site travel lanes, which will minimize light impacts on residential uses located across the freeways and at City Place across Main Street. The digital signs will incorporate the latest technologies that will minimize light intrusion into neighborhoods, including automatic and manual dimmers that will regulate the lighting levels that may spill into adjacent uses. 2. The location of the proposed signage will not contribute towards a hazardous environment for pedestrians, cyclists or motorists on City streets or freeways. The proposed signs will be located on private property that is adjacent to two freeways (Interstate 5 and State Route 22), as well as major local arterials (Broadway and Main Street). The signs are designed to be in scale with the surrounding streetscape, which will minimize the potential for creating a hazardous environment for pedestrians, cyclists or motorist travelling in the immediate vicinity where the signs are visible. 3. The proposed signage is compatible with the scale, intensity, and site development characteristics on which it is proposed, which may be determined by height of existing or proposed buildings on -site; the quantity of freestanding buildings, facades, and street frontages; scale of buildings as they relate to pedestrian and vehicular access surrounding land uses and transportation corridors; visibility from streets, highways, pedestrian areas, rail corridors bikeways other transportation routes, parks, and other public spaces; architecture color(s), material(s), illumination, and other site characteristics; the nature of business activities conducted on -site; and, visibility from any property used or zoned for residential purposes. The proposed signage will be compatible with the scale and site development characteristics on which they are proposed as the signs will be placed in strategic locations intended to maximize visibility of the mall, which is the intended audience for the signs. The 80 -foot height of the pylon and digital signs will allow the signs to be visible from local freeways whose viewships are limited by overcrossings, significantly wide rights -of -way, and below -grade Resolution No. 2015 -16 Page 2 of 6 RIVER configurations. Further, the proposed signage, including the digital reader board signs, are an appropriate means of advertising the multitude of stores and products sold at the regional commercial center. Finally, the proposed signs will be architecturally compatible with one another and with the buildings found at Westfield MainPlace. E. In accordance with the California Environmental Quality Act, the proposed project is exempt from further review pursuant to Sections 15303 and 15311. Section 15303 applies to construction of small structures, and Section 15311 applies to structures accessory to a commercial use, with the proposed on- premise signs serving as minor structures that are accessory to the primary regional commercial center use. Categorical Exemption Environmental Review No. 2015 -36 will be filed for this project. Section 2. The Planning Commission of the City of Santa Ana after conducting the public hearing hereby approves Regional Planned Sign Program No. 2014 -01 as conditioned in Exhibit A attached hereto and incorporated herein by this reference. This decision is based upon the evidence submitted at the abovesaid hearing, which includes but is not limited to: the Request for Planning Commission Action dated May 11, 2015 and exhibits attached thereto; and the public testimony, all of which are incorporated herein by this reference. ADOPTED this 11" day of May 2015 by the following vote: AYES: Commissioners: Bacerra, Bauer, Gartner, Mill, Nalle, Verino (6) NOES: Commissioners: None (0) ABSENT: Commissioners: Alderete(1) ABSTENTIONS: Commissioners: None (0) APPROVED AS TO FORM: Sonia R. Carvalho, City Attorney By: Lisa Storck Assistant City Attorney James Gartner Chairman Resolution No. 2015 -16 31 B -81 Page 3 of 6 CERTIFICATE OF ATTESTATION AND ORIGINALITY I, KAREN GERARDO, Secretary of the Planning Commission, do hereby attest to and certify the attached Resolution No. 2015 -16 to be the original resolution adopted by the Planning Commission of the City of Santa Ana on May 11, 2015 Date: Secretary of the Planning Commission City of Santa Ana 31 B -82 Resolution No. 2015 -16 Page 4 of 6 EXHIBIT A Conditions for Approval of Regional Planned Sign Program No. 2014 -01 Conditions for Approval Regional Planned Sign Program No. 2014 -01 is approved subject to compliance, to the reasonable satisfaction of the Planning Manager, with all applicable sections of the Santa Ana Municipal Code, the California Administrative Code, the California Building Standards Code and all other applicable regulations. The applicant must comply in full with each and every condition listed below rip or to exercising the rights conferred by this sign program. The applicant must remain in compliance with all conditions listed below throughout the life of the sign program. Failure to comply with each and every condition may result in the revocation of the sign program. A. Planning Division 1. There shall be a maximum of one (1) double -faced digital sign per freeway frontage. 2. The digital reader board signs shall contain an easily - legible and accessible phone number available at all times for response 24 hours per day, seven days per week in case of digital signage malfunction or failure. 3. The property owner shall comply with Santa Ana Municipal Code Section 41- 638.2 that pertains to graffiti abatement. 4. In addition to their on- premise advertising and identification purposes, the signs shall be used for public service announcements or warning signs as requested and provided by the City of Santa Ana. Five percent (5 %) of the display time shall be set aside for these public service messages. 5. At all times, the sign shall comply with all federal, state and local laws, regulations and permitting requirements. 6. The uppermost static sign panel on the column of the two digital signs shall at all times integrate a display of the text "Santa Ana" in fashion that is of consistent scale and legibility as the other static panels. 7. Any landscaping, including but not limited to trees, shrubs, groundcover, and hardscape materials, that is removed to accommodate installation of new signage shall be replaced or enhanced in a nearby area on the site. In the event Resolution No. 2015 -16 31 B -83 Page 5 of 6 MAY 11, 2015 PAGE 2 OF 2 that staff determines that a significant amount of landscaping is to be removed as part of the project, staff may request a landscape plan to be submitted by the applicant to ensure compliance with the City's design standards for commercial properties. 8. Prior to any building permit finals, the applicant shall restore any dead or missing landscaping on the entire regional mall site. 9. Prior to any building permit finals, the applicant shall remove all debris, debris or rubbish containers, and outside storage bins other than those which are enclosed or for regular trash pickup. 10. Prior to any building permit finals, the applicant shall repaint or restore any paint blemishes, discoloration, or marred paint from rust or water runoff on all site structures, including the mall buildings, parking structures, and signage that is intended to remain in place. 11. The applicant or operator of the digital signs shall measure lighting levels of both digital signs after seven (7) days and after one (1) month of full operation and submit lighting level reports to the Planning Division for review to ensure compliance with brightness standards contained within the Santa Ana Municipal Code. 12.Any amendment to this regional planned sign program must be submitted to the Planning Division for review. At that time, staff will determine if administrative relief is available or if the approved regional sign program must be amended. 13.The text "Santa Ana" shall be added to all site monument signs as proposed in the sign program at all entrances to Westfield MainPlace. Resolution No. 2015 -16 Page 6 of 6 R •