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CAJA Environmental Services, LLC
<br />9410 Topanga Canyon Blvd., Suite 101
<br />Chatsworth, CA 91311
<br />Phone 310-469-6700 Fax 310-806-9801
<br />The City already has a plan in place to accommodate new hotel development. In 2016, the City adopted a
<br />hotel incentive program aimed at attracting new hotel development,13 spurred by an increase in tourism in
<br />Orange County, and Santa Ana's proximity to hubs of tourism including Anaheim's resort district, the John
<br />Wayne Airport, and local amenities including the Discovery Cube Orange County and the Bowers
<br />Museum.14 The City's General Plan has identified certain locations appropriate for the development of
<br />hotels including in the land use designations District Center — Medium and Industrial/Flex (at Brookhollow
<br />Specific Development (SD) Plan No. 8), specifically at 55 Freeway and Dyer Road.15 The City's Harbor
<br />Mix Use Transit Corridor Plan notes it could lead to the addition of new hotels.16 In addition, the City's
<br />Midtown Specific Plan and Metro East Mixed -Use Overlay District Expansion and Elan Development
<br />Projects each specifically contemplates new hotels.17 Further, hotel and motels are also permitted to be
<br />constructed and operated in C-1, C1-MD, C2, C4, C5, CR, and CSM Zoning Districts. As the City has
<br />identified specific areas where hotels could be developed, the City is capable of conducting meaningful
<br />and informational environmental review of the hotels' construction now.
<br />In 2016, the City noted that the average occupancy of Orange County hotels was at 78 percent, spurring
<br />the need for new hotel development in the area.18 As discussed in the Ramboll report, hotel occupancy
<br />rates in Orange County as of September 2024 are 77 percent. (Ramboll Economics Analysis, p. 2.)
<br />Evidence from Ramboll shows that removal of all existing STRs which are a "significant portion of the
<br />lodging market" would leave a "considerable gap in available accommodations, which the existing hotel
<br />infrastructure is unlikely to be able to fully absorb." (Ramboll Economics Analysis, pp. 3-4.) The City must
<br />evaluate this evidence to understand the current demand for hotels and STRs, and project the demand
<br />that would result from a ban on all STRs in the City.
<br />In the absence of all STRs, it is reasonably foreseeable that market forces will drive new hotel development
<br />to replace the loss of nights from the STR market. It is also reasonably foreseeable that the construction
<br />of new hotels in the City will result in a wide range of potential environmental effects to air quality, biological
<br />resources, cultural and tribal cultural resources, energy, GHG emissions, hazards and hazardous
<br />materials, land use and planning, noise and vibration, public services, transportation, and utilities.
<br />The City Must Consider Cumulative Regional Impacts of STR Bans
<br />An STR ban in the City has potential to cause a ripple effect across the region if other localities follow suit,
<br />resulting in cumulative environmental impacts from rapid elimination of STR uses, compounding issues
<br />described above including shifting traffic patterns and increased VMT, increased use of resource -intensive
<br />13 City of Santa Ana, Hotel Incentive Program, available here: https://www.santa-ana.org/hotel-incentive-program
<br />(last visited Oct. 7, 2024).
<br />14 City Council Staff Report, June 7, 2016, Hotel Development Incentive Program, available here:
<br />https://publicdocs.santa-ana.org/WebLink/DocView.aspx?dbid=1 &id=88417&page=1 &cr=1.
<br />15 Santa Ana General Plan, Land Use Element, LU 56-58.
<br />16 City of Santa Ana, Harbor Mixed Use Transit Corridor Specific Plan, pp. 1-2 (Oct. 2014).
<br />17 City of Santa Ana, Midtown Specific Plan, pp. 29, 38 (Dec. 1996); Metro East Mixed -Use Overlay District
<br />Expansion and Elan Development Projects Subsequent EIR, p. 3-39 (June 2018).
<br />18 City Council Staff Report, June 7, 2016, Hotel Development Incentive Program, available here:
<br />https://publicdocs.santa-ana.org/WebLink/DocView.aspx?dbid=1 &id=88417&page=1 &cr=1.
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