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drCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 City must evaluate and disclose whether new hotel construction would release contaminants and whether that can be mitigated to understand if construction of these hotel facilities is possible. Santa Ana has extensive groundwater contamination from volatile organic compounds (VOCs) related to historic manufacturing uses in the City.38 The City has identified certain locations for new hotels but has not evaluated potential impacts from hazardous or hazardous materials in those locations, such as potential for construction to release hazardous materials into the environment. The City must evaluate this potential given that new hotel development is reasonably foreseeable. Land Use / Planning Overview The STR ban is reasonably likely to have significant land use and planning impacts by eliminating all STRs in the City, and from the reasonably foreseeable construction of new hotels to accommodate patrons who would have previously utilized STRs. The STR ban also has potential to result in significant land use impacts due to urban decay. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in land use and planning impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 37.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of land use and planning impacts is insufficient, finding that the STR ban would only affect existing structures, and "is not anticipated to result in physical impacts to the environment." (Staff Report, Exhibit 3, p. 37.) The Addendum notes that the STR ban would "improve the connectivity of existing communities by improving the compatibility of existing uses and preserving the character and integrity of existing neighborhoods (Land Use Element Goal 3)through the prohibition of STRs within long- term residential neighborhoods." (Id., p. 38.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable land use impacts resulting from eliminating all STRs, construction of new hotels, and urban decay from the STR ban. Inconsistency with General Plan The City failed to adequately analyze the consistency of the STR ban with its General Plan, narrowly focusing only on the goal of preserving the character or residential neighborhoods. (Staff Report, Exhibit 3, pp. 37-38 [citing to Land Use Element Goal 3].) The STR ban's elimination of all existing STRs in the City is inconsistent with the City's General Plan Land Use Element when viewed holistically and in the context of the entire General , which contemplates efficient use of City land and maximizing efficient use of City resources, including a variety of goals and policies for responsible development in the City.39 For example, Land Use Element Goal LU-2 is aimed at providing a balance of land uses to meet the City's 31 City of Santa Ana, Delhi Groundwater, available here: https://www.santa-ana.orci/delhi- groundwater/#:—:text=This%20groundwater%20is%20contaminated%20near,of%20Santa%20Ana%27s%20drinkin q%20water(last visited Oct. 7, 2024). 31 See Santa Ana General Plan, Land Use Element. 25