HomeMy WebLinkAboutPacket 3.6.25Planning Commission
Special Meeting Agenda
March 6, 2025
6:30 P.M.
Council Chamber
22 Civic Center Plaza
Santa Ana, CA
Members of the public may attend this meeting inperson or join via Zoom.
Join from your computer: https://zoom.us/j/82229414519
Join from your mobile phone via Zoom App. Meeting ID: 82229414519
Dial in from a mobile phone or landline.(669) 900 6833; Meeting ID: 82229414519
*For viewing only: www.youtube.com/cityofsantaanavideos. Please note: There is up to a 30
second delay when viewing the meeting via YouTube. If you plan to provide a public comment
during the meeting, please join the meeting via Zoom.
For detailed participation and commenting options, please review the instructions
provided at the end of this agenda.
To download or view each item, select either Download PDF or View Item Details to
the right of the agenda title.
Jennifer Oliva
Chair, Ward 6 Representative
Isuri S. Ramos
ViceChair
Ward 3 Representative
Christopher Leo
Citywide Representative
Manuel J. Escamilla
Ward 2 Representative
Carl Benninger
Ward 4 Representative
Bao Pham
Ward 1 Representative
Alan Woo
Ward 5 Representative
Ali Pezeshkpour, AICP
Acting Executive Director
Melissa M. Crosthwaite
Legal Counsel
Ricardo Soto, AICP
Acting Planning Manager
Nuvia Ocampo
Recording Secretary
In compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this Meeting,
contact Michael Ortiz, City ADA Program Coordinator, at (714) 6475624. Notification 48 hours prior to the Meeting will enable
the City to make reasonable arrangements to assure accessibility to this meeting. The City Council agenda and supporting
documentation can be found on the City’s website – www.santaana.org/citymeetings.
CALL TO ORDER
Commissioners: Jennifer Oliva, Chair
Isuri S. Ramos, ViceChair
Manuel J. Escamilla
Carl Benninger
Bao Pham
Christopher Leo
Alan Woo
Acitng Executive Director Ali Pezeshkpour,AICP
Senior Asst. City Attorney Melissa M. Crosthwaite
Acting Planning Manager Ricardo Soto, AICP
Recording Secretary Nuvia Ocampo
ROLL CALL
PLEDGE OF ALLEGIANCE
PUBLIC COMMENTS
CONSENT CALENDAR ITEM
b. Excused Absences
Recommended Action: Excuse absent commissioners.
BUSINESS CALENDAR
Public Hearing:The Planning Commission decision on Conditional Use Permits,
Variances, Tentative Tract and Parcel Maps, Minor Exceptions, Site Plan Review, and
Public Convenience or Necessity Determinations are final unless appealed within 10
days of the decision by any interested party or group (refer to the Basic Meeting
Information page for more information). The Planning Commission recommendation
on Zoning and General Plan amendments, Development Agreements, Specific
Developments, and Specific Plans will be forwarded to the City Council for final
determination. Legal notice was published in the OC Register on January 31, 2025,
and notices were mailed on said date.
1.ZONING ORDINANCE AMENDMENT (ZOA) NO. 202402 AND AMENDMENT
APPLICATION (AA) NO. 202403 AMENDING CERTAIN SECTIONS OF ARTICLE
XIX (THE TRANSIT ZONING CODE, SPECIFIC DEVELOPMENT NO. 84) OF
CHAPTER 41 (ZONING) OF THE SANTA ANA MUNICIPAL CODE (SAMC)
ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, AND
OPERATING STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONING
MAP TO REMOVE THE LIGHT INDUSTRIAL (M1) AND HEAVY INDUSTRIAL (M2)
SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE SD84 DISTRICT
BOUNDARY.
Project Applicant: City of Santa Ana
Proposed Project: Planning Commission recommendation that the City Council
adopt Zoning Ordinance Amendment (ZOA) No. 202402 and Amendment Application
(AA) No. 202403 to amend the Transit Zoning Code (Specific Development (SD) No.
84) zoning district of Chapter 41 (Zoning) of the Santa Ana Municipal Code and to
amend the City’s Zoning Map. The proposed amendments include removal of industrial
uses from the permitted uses table, updates to the nonconforming regulations, a new
amortization process, and new operational standards applicable to businesses within
the zoning district. The proposal also includes removing the Light Industrial (M1) and
Heavy Industrial (M2) suffixes from certain properties within the SD84 zoning district,
as shown on the City’s Zoning Map.
Environmental Impact: In accordance with CEQA and the CEQA Guidelines, an
addendum has been prepared to the City of Santa Ana’s Transit Zoning Code (SD84)
Environmental Impact Report (EIR) to demonstrate that, pursuant to the standards
contained in CEQA Guidelines Section 15162, this project is within the scope of the
Transit Zoning Code (SD84) EIR No. 200602, State Clearinghouse (SCH) No.
2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit Zoning
Code (SD84) EIR fully analyzed the potential impacts associated with the proposed
code amendments. This is consistent with Section 8.06 of the City’s Local Guidelines
for Implementing CEQA.
Recommended Action:
Recommend that the Planning Commission recommend that the City Council:
1. Adopt a resolution to make findings pursuant to Public Resources Code
Section 21166 and to adopt the Addendum to the Transit Zoning Code
Environmental Impact Report (State Clearinghouse Number No.
2006071100). Pursuant to the California Environment Quality Act (CEQA),
and based on independent review and analysis, and the administrative
record as a whole, that, in exercising its independent judgement, amend
TZC SD84 Final EIR with an addendum that the City Council find that
pursuant to CEQA Guidelines Section 15162, no subsequent
Environmental Impact Report (EIR) is required for the adoption of the
proposed Ordinances; and pursuant to CEQA Guidelines Section 15164,
an addendum to the Transit Zoning Code EIR was accordingly prepared;
2. Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No.
202402 amending certain sections of Article XIX (The Transit Zoning Code,
Specific Development No. 84 (SD84)) of Chapter 41 (Zoning) of the Santa
Ana Municipal Code including amendments to the regulations, overlay
districts and maps in the zoning district; modifying the authorized land uses
and permit types; establishing revised nonconforming use regulations,
including the addition of an amortization/termination of use process and
adding operational standards for certain permitted and nonconforming
uses; and
3. Adopt an ordinance to approve Amendment Application (AA) No. 202403
amending the zoning by removing the M1 (light industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
*End of Business Calendar*
STAFF COMMENTS
COMMISSIONER COMMENTS
ADJOURNMENT
The next meeting of the Planning Commission will be on Monday, March 10, 2025 at 5:30
p.m. in the Council Chambers located at 22 Civic Center Plaza, Santa Ana, CA 92701.
APPEAL INFORMATION
The formal action by the Planning Commission shall become effective after the tenday
appeal period, unless the City Council in compliance with section 41643, 41644 or 41645
holds a public hearing on the matter, then the formal action will become effective on the day
following the hearing and decision by the City Council. An appeal from the decision or
requirement of the Planning Commission may be made by any interested party, individual, or
group. The appeal must be filed with the Clerk of the Council, accompanied by the required
filing fee, and a copy sent to the Planning Department, within ten days of the date of the
Commission's action, by 5:00 p.m. If the final day to appeal falls on a City Hall observed
holiday or a day when City hall is closed, the final day to appeal shall be extended to the next
day City Hall is open for public business. Please note: Under California Government Code
Sec. 65009, if you challenge in court any of the matters on this agenda for which a public
hearing is to be conducted, you may be limited to raising only those issues which you (or
someone else) raised orally at the public hearing or in written correspondence received by
the Planning Commission or City Council at or before the hearing.
MEETING INFORMATION
If you would like to learn how to use Zoom before the meeting, visit Zoom Video Tutorials.
1. Connecting directly from your computer:
Click on the link on top of this agenda OR
Go to Zoom.us and click "Join a Meeting" at the top. Enter the Meeting ID. The Meeting
ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
2. Connecting via the Zoom App:
Download the free Zoom Cloud Meetings app from your favorite app store.
Launch the app and click on the blue Join a Meeting button. Enter the Meeting ID, your
name, and the blue Join button. The Meeting ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
3. Dialing in from a mobile phone or landline:
Dial (669) 9009128. When prompted, enter the meeting ID. The Meeting ID is listed at
the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, press *9 on your phone to virtually raise your hand. You will have 3 minutes.
Submit a written comment
You are invited to submit a written comment in one of the following ways:
Email PBAecomments@santaana.org and reference the topic in the subject line.
Mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza
– M20, Santa Ana, CA 92701.
Deadline to submit written comments, including any supplemental materials for
consideration by the Planning Commission, is 3:30 p.m. on the day of the
meeting. Comments received after the deadline may not be distributed to the
Planning Commission but will be made part of the record. All attendees wishing to
submit written comments or supplemental materials for distribution to Planning
Commission members during the inperson meeting must provide 15 printed copies.
Planning CommissionSpecial Meeting AgendaMarch 6, 20256:30 P.M.Council Chamber22 Civic Center PlazaSanta Ana, CA Members of the public may attend this meeting inperson or join via Zoom.Join from your computer: https://zoom.us/j/82229414519Join from your mobile phone via Zoom App. Meeting ID: 82229414519Dial in from a mobile phone or landline.(669) 900 6833; Meeting ID: 82229414519*For viewing only: www.youtube.com/cityofsantaanavideos. Please note: There is up to a 30second delay when viewing the meeting via YouTube. If you plan to provide a public commentduring the meeting, please join the meeting via Zoom.For detailed participation and commenting options, please review the instructionsprovided at the end of this agenda.
To download or view each item, select either Download PDF or View Item Details to
the right of the agenda title.
Jennifer Oliva
Chair, Ward 6 Representative
Isuri S. Ramos
ViceChair
Ward 3 Representative
Christopher Leo
Citywide Representative
Manuel J. Escamilla
Ward 2 Representative
Carl Benninger
Ward 4 Representative
Bao Pham
Ward 1 Representative
Alan Woo
Ward 5 Representative
Ali Pezeshkpour, AICP
Acting Executive Director
Melissa M. Crosthwaite
Legal Counsel
Ricardo Soto, AICP
Acting Planning Manager
Nuvia Ocampo
Recording Secretary
In compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this Meeting,
contact Michael Ortiz, City ADA Program Coordinator, at (714) 6475624. Notification 48 hours prior to the Meeting will enable
the City to make reasonable arrangements to assure accessibility to this meeting. The City Council agenda and supporting
documentation can be found on the City’s website – www.santaana.org/citymeetings.
CALL TO ORDER
Commissioners: Jennifer Oliva, Chair
Isuri S. Ramos, ViceChair
Manuel J. Escamilla
Carl Benninger
Bao Pham
Christopher Leo
Alan Woo
Acitng Executive Director Ali Pezeshkpour,AICP
Senior Asst. City Attorney Melissa M. Crosthwaite
Acting Planning Manager Ricardo Soto, AICP
Recording Secretary Nuvia Ocampo
ROLL CALL
PLEDGE OF ALLEGIANCE
PUBLIC COMMENTS
CONSENT CALENDAR ITEM
b. Excused Absences
Recommended Action: Excuse absent commissioners.
BUSINESS CALENDAR
Public Hearing:The Planning Commission decision on Conditional Use Permits,
Variances, Tentative Tract and Parcel Maps, Minor Exceptions, Site Plan Review, and
Public Convenience or Necessity Determinations are final unless appealed within 10
days of the decision by any interested party or group (refer to the Basic Meeting
Information page for more information). The Planning Commission recommendation
on Zoning and General Plan amendments, Development Agreements, Specific
Developments, and Specific Plans will be forwarded to the City Council for final
determination. Legal notice was published in the OC Register on January 31, 2025,
and notices were mailed on said date.
1.ZONING ORDINANCE AMENDMENT (ZOA) NO. 202402 AND AMENDMENT
APPLICATION (AA) NO. 202403 AMENDING CERTAIN SECTIONS OF ARTICLE
XIX (THE TRANSIT ZONING CODE, SPECIFIC DEVELOPMENT NO. 84) OF
CHAPTER 41 (ZONING) OF THE SANTA ANA MUNICIPAL CODE (SAMC)
ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, AND
OPERATING STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONING
MAP TO REMOVE THE LIGHT INDUSTRIAL (M1) AND HEAVY INDUSTRIAL (M2)
SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE SD84 DISTRICT
BOUNDARY.
Project Applicant: City of Santa Ana
Proposed Project: Planning Commission recommendation that the City Council
adopt Zoning Ordinance Amendment (ZOA) No. 202402 and Amendment Application
(AA) No. 202403 to amend the Transit Zoning Code (Specific Development (SD) No.
84) zoning district of Chapter 41 (Zoning) of the Santa Ana Municipal Code and to
amend the City’s Zoning Map. The proposed amendments include removal of industrial
uses from the permitted uses table, updates to the nonconforming regulations, a new
amortization process, and new operational standards applicable to businesses within
the zoning district. The proposal also includes removing the Light Industrial (M1) and
Heavy Industrial (M2) suffixes from certain properties within the SD84 zoning district,
as shown on the City’s Zoning Map.
Environmental Impact: In accordance with CEQA and the CEQA Guidelines, an
addendum has been prepared to the City of Santa Ana’s Transit Zoning Code (SD84)
Environmental Impact Report (EIR) to demonstrate that, pursuant to the standards
contained in CEQA Guidelines Section 15162, this project is within the scope of the
Transit Zoning Code (SD84) EIR No. 200602, State Clearinghouse (SCH) No.
2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit Zoning
Code (SD84) EIR fully analyzed the potential impacts associated with the proposed
code amendments. This is consistent with Section 8.06 of the City’s Local Guidelines
for Implementing CEQA.
Recommended Action:
Recommend that the Planning Commission recommend that the City Council:
1. Adopt a resolution to make findings pursuant to Public Resources Code
Section 21166 and to adopt the Addendum to the Transit Zoning Code
Environmental Impact Report (State Clearinghouse Number No.
2006071100). Pursuant to the California Environment Quality Act (CEQA),
and based on independent review and analysis, and the administrative
record as a whole, that, in exercising its independent judgement, amend
TZC SD84 Final EIR with an addendum that the City Council find that
pursuant to CEQA Guidelines Section 15162, no subsequent
Environmental Impact Report (EIR) is required for the adoption of the
proposed Ordinances; and pursuant to CEQA Guidelines Section 15164,
an addendum to the Transit Zoning Code EIR was accordingly prepared;
2. Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No.
202402 amending certain sections of Article XIX (The Transit Zoning Code,
Specific Development No. 84 (SD84)) of Chapter 41 (Zoning) of the Santa
Ana Municipal Code including amendments to the regulations, overlay
districts and maps in the zoning district; modifying the authorized land uses
and permit types; establishing revised nonconforming use regulations,
including the addition of an amortization/termination of use process and
adding operational standards for certain permitted and nonconforming
uses; and
3. Adopt an ordinance to approve Amendment Application (AA) No. 202403
amending the zoning by removing the M1 (light industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
*End of Business Calendar*
STAFF COMMENTS
COMMISSIONER COMMENTS
ADJOURNMENT
The next meeting of the Planning Commission will be on Monday, March 10, 2025 at 5:30
p.m. in the Council Chambers located at 22 Civic Center Plaza, Santa Ana, CA 92701.
APPEAL INFORMATION
The formal action by the Planning Commission shall become effective after the tenday
appeal period, unless the City Council in compliance with section 41643, 41644 or 41645
holds a public hearing on the matter, then the formal action will become effective on the day
following the hearing and decision by the City Council. An appeal from the decision or
requirement of the Planning Commission may be made by any interested party, individual, or
group. The appeal must be filed with the Clerk of the Council, accompanied by the required
filing fee, and a copy sent to the Planning Department, within ten days of the date of the
Commission's action, by 5:00 p.m. If the final day to appeal falls on a City Hall observed
holiday or a day when City hall is closed, the final day to appeal shall be extended to the next
day City Hall is open for public business. Please note: Under California Government Code
Sec. 65009, if you challenge in court any of the matters on this agenda for which a public
hearing is to be conducted, you may be limited to raising only those issues which you (or
someone else) raised orally at the public hearing or in written correspondence received by
the Planning Commission or City Council at or before the hearing.
MEETING INFORMATION
If you would like to learn how to use Zoom before the meeting, visit Zoom Video Tutorials.
1. Connecting directly from your computer:
Click on the link on top of this agenda OR
Go to Zoom.us and click "Join a Meeting" at the top. Enter the Meeting ID. The Meeting
ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
2. Connecting via the Zoom App:
Download the free Zoom Cloud Meetings app from your favorite app store.
Launch the app and click on the blue Join a Meeting button. Enter the Meeting ID, your
name, and the blue Join button. The Meeting ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
3. Dialing in from a mobile phone or landline:
Dial (669) 9009128. When prompted, enter the meeting ID. The Meeting ID is listed at
the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, press *9 on your phone to virtually raise your hand. You will have 3 minutes.
Submit a written comment
You are invited to submit a written comment in one of the following ways:
Email PBAecomments@santaana.org and reference the topic in the subject line.
Mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza
– M20, Santa Ana, CA 92701.
Deadline to submit written comments, including any supplemental materials for
consideration by the Planning Commission, is 3:30 p.m. on the day of the
meeting. Comments received after the deadline may not be distributed to the
Planning Commission but will be made part of the record. All attendees wishing to
submit written comments or supplemental materials for distribution to Planning
Commission members during the inperson meeting must provide 15 printed copies.
Planning CommissionSpecial Meeting AgendaMarch 6, 20256:30 P.M.Council Chamber22 Civic Center PlazaSanta Ana, CA Members of the public may attend this meeting inperson or join via Zoom.Join from your computer: https://zoom.us/j/82229414519Join from your mobile phone via Zoom App. Meeting ID: 82229414519Dial in from a mobile phone or landline.(669) 900 6833; Meeting ID: 82229414519*For viewing only: www.youtube.com/cityofsantaanavideos. Please note: There is up to a 30second delay when viewing the meeting via YouTube. If you plan to provide a public commentduring the meeting, please join the meeting via Zoom.For detailed participation and commenting options, please review the instructionsprovided at the end of this agenda.To download or view each item, select either Download PDF or View Item Details tothe right of the agenda title. Jennifer OlivaChair, Ward 6 RepresentativeIsuri S. Ramos ViceChairWard 3 Representative Christopher LeoCitywide RepresentativeManuel J. EscamillaWard 2 Representative Carl Benninger Ward 4 RepresentativeBao PhamWard 1 Representative Alan WooWard 5 RepresentativeAli Pezeshkpour, AICPActing Executive DirectorMelissa M. CrosthwaiteLegal Counsel Ricardo Soto, AICPActing Planning Manager Nuvia OcampoRecording Secretary
In compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this Meeting,
contact Michael Ortiz, City ADA Program Coordinator, at (714) 6475624. Notification 48 hours prior to the Meeting will enable
the City to make reasonable arrangements to assure accessibility to this meeting. The City Council agenda and supporting
documentation can be found on the City’s website – www.santaana.org/citymeetings.
CALL TO ORDER
Commissioners: Jennifer Oliva, Chair
Isuri S. Ramos, ViceChair
Manuel J. Escamilla
Carl Benninger
Bao Pham
Christopher Leo
Alan Woo
Acitng Executive Director Ali Pezeshkpour,AICP
Senior Asst. City Attorney Melissa M. Crosthwaite
Acting Planning Manager Ricardo Soto, AICP
Recording Secretary Nuvia Ocampo
ROLL CALL
PLEDGE OF ALLEGIANCE
PUBLIC COMMENTS
CONSENT CALENDAR ITEM
b. Excused Absences
Recommended Action: Excuse absent commissioners.
BUSINESS CALENDAR
Public Hearing:The Planning Commission decision on Conditional Use Permits,
Variances, Tentative Tract and Parcel Maps, Minor Exceptions, Site Plan Review, and
Public Convenience or Necessity Determinations are final unless appealed within 10
days of the decision by any interested party or group (refer to the Basic Meeting
Information page for more information). The Planning Commission recommendation
on Zoning and General Plan amendments, Development Agreements, Specific
Developments, and Specific Plans will be forwarded to the City Council for final
determination. Legal notice was published in the OC Register on January 31, 2025,
and notices were mailed on said date.
1.ZONING ORDINANCE AMENDMENT (ZOA) NO. 202402 AND AMENDMENT
APPLICATION (AA) NO. 202403 AMENDING CERTAIN SECTIONS OF ARTICLE
XIX (THE TRANSIT ZONING CODE, SPECIFIC DEVELOPMENT NO. 84) OF
CHAPTER 41 (ZONING) OF THE SANTA ANA MUNICIPAL CODE (SAMC)
ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, AND
OPERATING STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONING
MAP TO REMOVE THE LIGHT INDUSTRIAL (M1) AND HEAVY INDUSTRIAL (M2)
SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE SD84 DISTRICT
BOUNDARY.
Project Applicant: City of Santa Ana
Proposed Project: Planning Commission recommendation that the City Council
adopt Zoning Ordinance Amendment (ZOA) No. 202402 and Amendment Application
(AA) No. 202403 to amend the Transit Zoning Code (Specific Development (SD) No.
84) zoning district of Chapter 41 (Zoning) of the Santa Ana Municipal Code and to
amend the City’s Zoning Map. The proposed amendments include removal of industrial
uses from the permitted uses table, updates to the nonconforming regulations, a new
amortization process, and new operational standards applicable to businesses within
the zoning district. The proposal also includes removing the Light Industrial (M1) and
Heavy Industrial (M2) suffixes from certain properties within the SD84 zoning district,
as shown on the City’s Zoning Map.
Environmental Impact: In accordance with CEQA and the CEQA Guidelines, an
addendum has been prepared to the City of Santa Ana’s Transit Zoning Code (SD84)
Environmental Impact Report (EIR) to demonstrate that, pursuant to the standards
contained in CEQA Guidelines Section 15162, this project is within the scope of the
Transit Zoning Code (SD84) EIR No. 200602, State Clearinghouse (SCH) No.
2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit Zoning
Code (SD84) EIR fully analyzed the potential impacts associated with the proposed
code amendments. This is consistent with Section 8.06 of the City’s Local Guidelines
for Implementing CEQA.
Recommended Action:
Recommend that the Planning Commission recommend that the City Council:
1. Adopt a resolution to make findings pursuant to Public Resources Code
Section 21166 and to adopt the Addendum to the Transit Zoning Code
Environmental Impact Report (State Clearinghouse Number No.
2006071100). Pursuant to the California Environment Quality Act (CEQA),
and based on independent review and analysis, and the administrative
record as a whole, that, in exercising its independent judgement, amend
TZC SD84 Final EIR with an addendum that the City Council find that
pursuant to CEQA Guidelines Section 15162, no subsequent
Environmental Impact Report (EIR) is required for the adoption of the
proposed Ordinances; and pursuant to CEQA Guidelines Section 15164,
an addendum to the Transit Zoning Code EIR was accordingly prepared;
2. Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No.
202402 amending certain sections of Article XIX (The Transit Zoning Code,
Specific Development No. 84 (SD84)) of Chapter 41 (Zoning) of the Santa
Ana Municipal Code including amendments to the regulations, overlay
districts and maps in the zoning district; modifying the authorized land uses
and permit types; establishing revised nonconforming use regulations,
including the addition of an amortization/termination of use process and
adding operational standards for certain permitted and nonconforming
uses; and
3. Adopt an ordinance to approve Amendment Application (AA) No. 202403
amending the zoning by removing the M1 (light industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
*End of Business Calendar*
STAFF COMMENTS
COMMISSIONER COMMENTS
ADJOURNMENT
The next meeting of the Planning Commission will be on Monday, March 10, 2025 at 5:30
p.m. in the Council Chambers located at 22 Civic Center Plaza, Santa Ana, CA 92701.
APPEAL INFORMATION
The formal action by the Planning Commission shall become effective after the tenday
appeal period, unless the City Council in compliance with section 41643, 41644 or 41645
holds a public hearing on the matter, then the formal action will become effective on the day
following the hearing and decision by the City Council. An appeal from the decision or
requirement of the Planning Commission may be made by any interested party, individual, or
group. The appeal must be filed with the Clerk of the Council, accompanied by the required
filing fee, and a copy sent to the Planning Department, within ten days of the date of the
Commission's action, by 5:00 p.m. If the final day to appeal falls on a City Hall observed
holiday or a day when City hall is closed, the final day to appeal shall be extended to the next
day City Hall is open for public business. Please note: Under California Government Code
Sec. 65009, if you challenge in court any of the matters on this agenda for which a public
hearing is to be conducted, you may be limited to raising only those issues which you (or
someone else) raised orally at the public hearing or in written correspondence received by
the Planning Commission or City Council at or before the hearing.
MEETING INFORMATION
If you would like to learn how to use Zoom before the meeting, visit Zoom Video Tutorials.
1. Connecting directly from your computer:
Click on the link on top of this agenda OR
Go to Zoom.us and click "Join a Meeting" at the top. Enter the Meeting ID. The Meeting
ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
2. Connecting via the Zoom App:
Download the free Zoom Cloud Meetings app from your favorite app store.
Launch the app and click on the blue Join a Meeting button. Enter the Meeting ID, your
name, and the blue Join button. The Meeting ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
3. Dialing in from a mobile phone or landline:
Dial (669) 9009128. When prompted, enter the meeting ID. The Meeting ID is listed at
the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, press *9 on your phone to virtually raise your hand. You will have 3 minutes.
Submit a written comment
You are invited to submit a written comment in one of the following ways:
Email PBAecomments@santaana.org and reference the topic in the subject line.
Mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza
– M20, Santa Ana, CA 92701.
Deadline to submit written comments, including any supplemental materials for
consideration by the Planning Commission, is 3:30 p.m. on the day of the
meeting. Comments received after the deadline may not be distributed to the
Planning Commission but will be made part of the record. All attendees wishing to
submit written comments or supplemental materials for distribution to Planning
Commission members during the inperson meeting must provide 15 printed copies.
Planning CommissionSpecial Meeting AgendaMarch 6, 20256:30 P.M.Council Chamber22 Civic Center PlazaSanta Ana, CA Members of the public may attend this meeting inperson or join via Zoom.Join from your computer: https://zoom.us/j/82229414519Join from your mobile phone via Zoom App. Meeting ID: 82229414519Dial in from a mobile phone or landline.(669) 900 6833; Meeting ID: 82229414519*For viewing only: www.youtube.com/cityofsantaanavideos. Please note: There is up to a 30second delay when viewing the meeting via YouTube. If you plan to provide a public commentduring the meeting, please join the meeting via Zoom.For detailed participation and commenting options, please review the instructionsprovided at the end of this agenda.To download or view each item, select either Download PDF or View Item Details tothe right of the agenda title. Jennifer OlivaChair, Ward 6 RepresentativeIsuri S. Ramos ViceChairWard 3 Representative Christopher LeoCitywide RepresentativeManuel J. EscamillaWard 2 Representative Carl Benninger Ward 4 RepresentativeBao PhamWard 1 Representative Alan WooWard 5 RepresentativeAli Pezeshkpour, AICPActing Executive DirectorMelissa M. CrosthwaiteLegal Counsel Ricardo Soto, AICPActing Planning Manager Nuvia OcampoRecording SecretaryIn compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this Meeting,contact Michael Ortiz, City ADA Program Coordinator, at (714) 6475624. Notification 48 hours prior to the Meeting will enablethe City to make reasonable arrangements to assure accessibility to this meeting. The City Council agenda and supportingdocumentation can be found on the City’s website – www.santaana.org/citymeetings.CALL TO ORDER Commissioners: Jennifer Oliva, ChairIsuri S. Ramos, ViceChairManuel J. EscamillaCarl BenningerBao Pham Christopher LeoAlan Woo Acitng Executive Director Ali Pezeshkpour,AICPSenior Asst. City Attorney Melissa M. CrosthwaiteActing Planning Manager Ricardo Soto, AICPRecording Secretary Nuvia OcampoROLL CALLPLEDGE OF ALLEGIANCEPUBLIC COMMENTSCONSENT CALENDAR ITEMb. Excused AbsencesRecommended Action: Excuse absent commissioners.BUSINESS CALENDARPublic Hearing:The Planning Commission decision on Conditional Use Permits,Variances, Tentative Tract and Parcel Maps, Minor Exceptions, Site Plan Review, andPublic Convenience or Necessity Determinations are final unless appealed within 10days of the decision by any interested party or group (refer to the Basic MeetingInformation page for more information). The Planning Commission recommendationon Zoning and General Plan amendments, Development Agreements, SpecificDevelopments, and Specific Plans will be forwarded to the City Council for finaldetermination. Legal notice was published in the OC Register on January 31, 2025,and notices were mailed on said date. 1.ZONING ORDINANCE AMENDMENT (ZOA) NO. 202402 AND AMENDMENTAPPLICATION (AA) NO. 202403 AMENDING CERTAIN SECTIONS OF ARTICLE
XIX (THE TRANSIT ZONING CODE, SPECIFIC DEVELOPMENT NO. 84) OF
CHAPTER 41 (ZONING) OF THE SANTA ANA MUNICIPAL CODE (SAMC)
ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, AND
OPERATING STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONING
MAP TO REMOVE THE LIGHT INDUSTRIAL (M1) AND HEAVY INDUSTRIAL (M2)
SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE SD84 DISTRICT
BOUNDARY.
Project Applicant: City of Santa Ana
Proposed Project: Planning Commission recommendation that the City Council
adopt Zoning Ordinance Amendment (ZOA) No. 202402 and Amendment Application
(AA) No. 202403 to amend the Transit Zoning Code (Specific Development (SD) No.
84) zoning district of Chapter 41 (Zoning) of the Santa Ana Municipal Code and to
amend the City’s Zoning Map. The proposed amendments include removal of industrial
uses from the permitted uses table, updates to the nonconforming regulations, a new
amortization process, and new operational standards applicable to businesses within
the zoning district. The proposal also includes removing the Light Industrial (M1) and
Heavy Industrial (M2) suffixes from certain properties within the SD84 zoning district,
as shown on the City’s Zoning Map.
Environmental Impact: In accordance with CEQA and the CEQA Guidelines, an
addendum has been prepared to the City of Santa Ana’s Transit Zoning Code (SD84)
Environmental Impact Report (EIR) to demonstrate that, pursuant to the standards
contained in CEQA Guidelines Section 15162, this project is within the scope of the
Transit Zoning Code (SD84) EIR No. 200602, State Clearinghouse (SCH) No.
2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit Zoning
Code (SD84) EIR fully analyzed the potential impacts associated with the proposed
code amendments. This is consistent with Section 8.06 of the City’s Local Guidelines
for Implementing CEQA.
Recommended Action:
Recommend that the Planning Commission recommend that the City Council:
1. Adopt a resolution to make findings pursuant to Public Resources Code
Section 21166 and to adopt the Addendum to the Transit Zoning Code
Environmental Impact Report (State Clearinghouse Number No.
2006071100). Pursuant to the California Environment Quality Act (CEQA),
and based on independent review and analysis, and the administrative
record as a whole, that, in exercising its independent judgement, amend
TZC SD84 Final EIR with an addendum that the City Council find that
pursuant to CEQA Guidelines Section 15162, no subsequent
Environmental Impact Report (EIR) is required for the adoption of the
proposed Ordinances; and pursuant to CEQA Guidelines Section 15164,
an addendum to the Transit Zoning Code EIR was accordingly prepared;
2. Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No.
202402 amending certain sections of Article XIX (The Transit Zoning Code,
Specific Development No. 84 (SD84)) of Chapter 41 (Zoning) of the Santa
Ana Municipal Code including amendments to the regulations, overlay
districts and maps in the zoning district; modifying the authorized land uses
and permit types; establishing revised nonconforming use regulations,
including the addition of an amortization/termination of use process and
adding operational standards for certain permitted and nonconforming
uses; and
3. Adopt an ordinance to approve Amendment Application (AA) No. 202403
amending the zoning by removing the M1 (light industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
*End of Business Calendar*
STAFF COMMENTS
COMMISSIONER COMMENTS
ADJOURNMENT
The next meeting of the Planning Commission will be on Monday, March 10, 2025 at 5:30
p.m. in the Council Chambers located at 22 Civic Center Plaza, Santa Ana, CA 92701.
APPEAL INFORMATION
The formal action by the Planning Commission shall become effective after the tenday
appeal period, unless the City Council in compliance with section 41643, 41644 or 41645
holds a public hearing on the matter, then the formal action will become effective on the day
following the hearing and decision by the City Council. An appeal from the decision or
requirement of the Planning Commission may be made by any interested party, individual, or
group. The appeal must be filed with the Clerk of the Council, accompanied by the required
filing fee, and a copy sent to the Planning Department, within ten days of the date of the
Commission's action, by 5:00 p.m. If the final day to appeal falls on a City Hall observed
holiday or a day when City hall is closed, the final day to appeal shall be extended to the next
day City Hall is open for public business. Please note: Under California Government Code
Sec. 65009, if you challenge in court any of the matters on this agenda for which a public
hearing is to be conducted, you may be limited to raising only those issues which you (or
someone else) raised orally at the public hearing or in written correspondence received by
the Planning Commission or City Council at or before the hearing.
MEETING INFORMATION
If you would like to learn how to use Zoom before the meeting, visit Zoom Video Tutorials.
1. Connecting directly from your computer:
Click on the link on top of this agenda OR
Go to Zoom.us and click "Join a Meeting" at the top. Enter the Meeting ID. The Meeting
ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
2. Connecting via the Zoom App:
Download the free Zoom Cloud Meetings app from your favorite app store.
Launch the app and click on the blue Join a Meeting button. Enter the Meeting ID, your
name, and the blue Join button. The Meeting ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
3. Dialing in from a mobile phone or landline:
Dial (669) 9009128. When prompted, enter the meeting ID. The Meeting ID is listed at
the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, press *9 on your phone to virtually raise your hand. You will have 3 minutes.
Submit a written comment
You are invited to submit a written comment in one of the following ways:
Email PBAecomments@santaana.org and reference the topic in the subject line.
Mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza
– M20, Santa Ana, CA 92701.
Deadline to submit written comments, including any supplemental materials for
consideration by the Planning Commission, is 3:30 p.m. on the day of the
meeting. Comments received after the deadline may not be distributed to the
Planning Commission but will be made part of the record. All attendees wishing to
submit written comments or supplemental materials for distribution to Planning
Commission members during the inperson meeting must provide 15 printed copies.
Planning CommissionSpecial Meeting AgendaMarch 6, 20256:30 P.M.Council Chamber22 Civic Center PlazaSanta Ana, CA Members of the public may attend this meeting inperson or join via Zoom.Join from your computer: https://zoom.us/j/82229414519Join from your mobile phone via Zoom App. Meeting ID: 82229414519Dial in from a mobile phone or landline.(669) 900 6833; Meeting ID: 82229414519*For viewing only: www.youtube.com/cityofsantaanavideos. Please note: There is up to a 30second delay when viewing the meeting via YouTube. If you plan to provide a public commentduring the meeting, please join the meeting via Zoom.For detailed participation and commenting options, please review the instructionsprovided at the end of this agenda.To download or view each item, select either Download PDF or View Item Details tothe right of the agenda title. Jennifer OlivaChair, Ward 6 RepresentativeIsuri S. Ramos ViceChairWard 3 Representative Christopher LeoCitywide RepresentativeManuel J. EscamillaWard 2 Representative Carl Benninger Ward 4 RepresentativeBao PhamWard 1 Representative Alan WooWard 5 RepresentativeAli Pezeshkpour, AICPActing Executive DirectorMelissa M. CrosthwaiteLegal Counsel Ricardo Soto, AICPActing Planning Manager Nuvia OcampoRecording SecretaryIn compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this Meeting,contact Michael Ortiz, City ADA Program Coordinator, at (714) 6475624. Notification 48 hours prior to the Meeting will enablethe City to make reasonable arrangements to assure accessibility to this meeting. The City Council agenda and supportingdocumentation can be found on the City’s website – www.santaana.org/citymeetings.CALL TO ORDER Commissioners: Jennifer Oliva, ChairIsuri S. Ramos, ViceChairManuel J. EscamillaCarl BenningerBao Pham Christopher LeoAlan Woo Acitng Executive Director Ali Pezeshkpour,AICPSenior Asst. City Attorney Melissa M. CrosthwaiteActing Planning Manager Ricardo Soto, AICPRecording Secretary Nuvia OcampoROLL CALLPLEDGE OF ALLEGIANCEPUBLIC COMMENTSCONSENT CALENDAR ITEMb. Excused AbsencesRecommended Action: Excuse absent commissioners.BUSINESS CALENDARPublic Hearing:The Planning Commission decision on Conditional Use Permits,Variances, Tentative Tract and Parcel Maps, Minor Exceptions, Site Plan Review, andPublic Convenience or Necessity Determinations are final unless appealed within 10days of the decision by any interested party or group (refer to the Basic MeetingInformation page for more information). The Planning Commission recommendationon Zoning and General Plan amendments, Development Agreements, SpecificDevelopments, and Specific Plans will be forwarded to the City Council for finaldetermination. Legal notice was published in the OC Register on January 31, 2025,and notices were mailed on said date. 1.ZONING ORDINANCE AMENDMENT (ZOA) NO. 202402 AND AMENDMENTAPPLICATION (AA) NO. 202403 AMENDING CERTAIN SECTIONS OF ARTICLEXIX (THE TRANSIT ZONING CODE, SPECIFIC DEVELOPMENT NO. 84) OFCHAPTER 41 (ZONING) OF THE SANTA ANA MUNICIPAL CODE (SAMC)ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, ANDOPERATING STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONINGMAP TO REMOVE THE LIGHT INDUSTRIAL (M1) AND HEAVY INDUSTRIAL (M2)SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE SD84 DISTRICTBOUNDARY.Project Applicant: City of Santa AnaProposed Project: Planning Commission recommendation that the City Counciladopt Zoning Ordinance Amendment (ZOA) No. 202402 and Amendment Application(AA) No. 202403 to amend the Transit Zoning Code (Specific Development (SD) No.84) zoning district of Chapter 41 (Zoning) of the Santa Ana Municipal Code and toamend the City’s Zoning Map. The proposed amendments include removal of industrialuses from the permitted uses table, updates to the nonconforming regulations, a newamortization process, and new operational standards applicable to businesses withinthe zoning district. The proposal also includes removing the Light Industrial (M1) andHeavy Industrial (M2) suffixes from certain properties within the SD84 zoning district,as shown on the City’s Zoning Map.Environmental Impact: In accordance with CEQA and the CEQA Guidelines, anaddendum has been prepared to the City of Santa Ana’s Transit Zoning Code (SD84)Environmental Impact Report (EIR) to demonstrate that, pursuant to the standardscontained in CEQA Guidelines Section 15162, this project is within the scope of theTransit Zoning Code (SD84) EIR No. 200602, State Clearinghouse (SCH) No.2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit ZoningCode (SD84) EIR fully analyzed the potential impacts associated with the proposedcode amendments. This is consistent with Section 8.06 of the City’s Local Guidelinesfor Implementing CEQA.Recommended Action: Recommend that the Planning Commission recommend that the City Council:1. Adopt a resolution to make findings pursuant to Public Resources CodeSection 21166 and to adopt the Addendum to the Transit Zoning CodeEnvironmental Impact Report (State Clearinghouse Number No.2006071100). Pursuant to the California Environment Quality Act (CEQA),and based on independent review and analysis, and the administrativerecord as a whole, that, in exercising its independent judgement, amendTZC SD84 Final EIR with an addendum that the City Council find thatpursuant to CEQA Guidelines Section 15162, no subsequentEnvironmental Impact Report (EIR) is required for the adoption of theproposed Ordinances; and pursuant to CEQA Guidelines Section 15164,an addendum to the Transit Zoning Code EIR was accordingly prepared;2. Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No.202402 amending certain sections of Article XIX (The Transit Zoning Code,Specific Development No. 84 (SD84)) of Chapter 41 (Zoning) of the SantaAna Municipal Code including amendments to the regulations, overlaydistricts and maps in the zoning district; modifying the authorized land usesand permit types; establishing revised nonconforming use regulations,
including the addition of an amortization/termination of use process and
adding operational standards for certain permitted and nonconforming
uses; and
3. Adopt an ordinance to approve Amendment Application (AA) No. 202403
amending the zoning by removing the M1 (light industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
*End of Business Calendar*
STAFF COMMENTS
COMMISSIONER COMMENTS
ADJOURNMENT
The next meeting of the Planning Commission will be on Monday, March 10, 2025 at 5:30
p.m. in the Council Chambers located at 22 Civic Center Plaza, Santa Ana, CA 92701.
APPEAL INFORMATION
The formal action by the Planning Commission shall become effective after the tenday
appeal period, unless the City Council in compliance with section 41643, 41644 or 41645
holds a public hearing on the matter, then the formal action will become effective on the day
following the hearing and decision by the City Council. An appeal from the decision or
requirement of the Planning Commission may be made by any interested party, individual, or
group. The appeal must be filed with the Clerk of the Council, accompanied by the required
filing fee, and a copy sent to the Planning Department, within ten days of the date of the
Commission's action, by 5:00 p.m. If the final day to appeal falls on a City Hall observed
holiday or a day when City hall is closed, the final day to appeal shall be extended to the next
day City Hall is open for public business. Please note: Under California Government Code
Sec. 65009, if you challenge in court any of the matters on this agenda for which a public
hearing is to be conducted, you may be limited to raising only those issues which you (or
someone else) raised orally at the public hearing or in written correspondence received by
the Planning Commission or City Council at or before the hearing.
MEETING INFORMATION
If you would like to learn how to use Zoom before the meeting, visit Zoom Video Tutorials.
1. Connecting directly from your computer:
Click on the link on top of this agenda OR
Go to Zoom.us and click "Join a Meeting" at the top. Enter the Meeting ID. The Meeting
ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
2. Connecting via the Zoom App:
Download the free Zoom Cloud Meetings app from your favorite app store.
Launch the app and click on the blue Join a Meeting button. Enter the Meeting ID, your
name, and the blue Join button. The Meeting ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
3. Dialing in from a mobile phone or landline:
Dial (669) 9009128. When prompted, enter the meeting ID. The Meeting ID is listed at
the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, press *9 on your phone to virtually raise your hand. You will have 3 minutes.
Submit a written comment
You are invited to submit a written comment in one of the following ways:
Email PBAecomments@santaana.org and reference the topic in the subject line.
Mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza
– M20, Santa Ana, CA 92701.
Deadline to submit written comments, including any supplemental materials for
consideration by the Planning Commission, is 3:30 p.m. on the day of the
meeting. Comments received after the deadline may not be distributed to the
Planning Commission but will be made part of the record. All attendees wishing to
submit written comments or supplemental materials for distribution to Planning
Commission members during the inperson meeting must provide 15 printed copies.
Planning CommissionSpecial Meeting AgendaMarch 6, 20256:30 P.M.Council Chamber22 Civic Center PlazaSanta Ana, CA Members of the public may attend this meeting inperson or join via Zoom.Join from your computer: https://zoom.us/j/82229414519Join from your mobile phone via Zoom App. Meeting ID: 82229414519Dial in from a mobile phone or landline.(669) 900 6833; Meeting ID: 82229414519*For viewing only: www.youtube.com/cityofsantaanavideos. Please note: There is up to a 30second delay when viewing the meeting via YouTube. If you plan to provide a public commentduring the meeting, please join the meeting via Zoom.For detailed participation and commenting options, please review the instructionsprovided at the end of this agenda.To download or view each item, select either Download PDF or View Item Details tothe right of the agenda title. Jennifer OlivaChair, Ward 6 RepresentativeIsuri S. Ramos ViceChairWard 3 Representative Christopher LeoCitywide RepresentativeManuel J. EscamillaWard 2 Representative Carl Benninger Ward 4 RepresentativeBao PhamWard 1 Representative Alan WooWard 5 RepresentativeAli Pezeshkpour, AICPActing Executive DirectorMelissa M. CrosthwaiteLegal Counsel Ricardo Soto, AICPActing Planning Manager Nuvia OcampoRecording SecretaryIn compliance with the Americans with Disabilities Act (ADA), if you need special assistance to participate in this Meeting,contact Michael Ortiz, City ADA Program Coordinator, at (714) 6475624. Notification 48 hours prior to the Meeting will enablethe City to make reasonable arrangements to assure accessibility to this meeting. The City Council agenda and supportingdocumentation can be found on the City’s website – www.santaana.org/citymeetings.CALL TO ORDER Commissioners: Jennifer Oliva, ChairIsuri S. Ramos, ViceChairManuel J. EscamillaCarl BenningerBao Pham Christopher LeoAlan Woo Acitng Executive Director Ali Pezeshkpour,AICPSenior Asst. City Attorney Melissa M. CrosthwaiteActing Planning Manager Ricardo Soto, AICPRecording Secretary Nuvia OcampoROLL CALLPLEDGE OF ALLEGIANCEPUBLIC COMMENTSCONSENT CALENDAR ITEMb. Excused AbsencesRecommended Action: Excuse absent commissioners.BUSINESS CALENDARPublic Hearing:The Planning Commission decision on Conditional Use Permits,Variances, Tentative Tract and Parcel Maps, Minor Exceptions, Site Plan Review, andPublic Convenience or Necessity Determinations are final unless appealed within 10days of the decision by any interested party or group (refer to the Basic MeetingInformation page for more information). The Planning Commission recommendationon Zoning and General Plan amendments, Development Agreements, SpecificDevelopments, and Specific Plans will be forwarded to the City Council for finaldetermination. Legal notice was published in the OC Register on January 31, 2025,and notices were mailed on said date. 1.ZONING ORDINANCE AMENDMENT (ZOA) NO. 202402 AND AMENDMENTAPPLICATION (AA) NO. 202403 AMENDING CERTAIN SECTIONS OF ARTICLEXIX (THE TRANSIT ZONING CODE, SPECIFIC DEVELOPMENT NO. 84) OFCHAPTER 41 (ZONING) OF THE SANTA ANA MUNICIPAL CODE (SAMC)ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, ANDOPERATING STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONINGMAP TO REMOVE THE LIGHT INDUSTRIAL (M1) AND HEAVY INDUSTRIAL (M2)SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE SD84 DISTRICTBOUNDARY.Project Applicant: City of Santa AnaProposed Project: Planning Commission recommendation that the City Counciladopt Zoning Ordinance Amendment (ZOA) No. 202402 and Amendment Application(AA) No. 202403 to amend the Transit Zoning Code (Specific Development (SD) No.84) zoning district of Chapter 41 (Zoning) of the Santa Ana Municipal Code and toamend the City’s Zoning Map. The proposed amendments include removal of industrialuses from the permitted uses table, updates to the nonconforming regulations, a newamortization process, and new operational standards applicable to businesses withinthe zoning district. The proposal also includes removing the Light Industrial (M1) andHeavy Industrial (M2) suffixes from certain properties within the SD84 zoning district,as shown on the City’s Zoning Map.Environmental Impact: In accordance with CEQA and the CEQA Guidelines, anaddendum has been prepared to the City of Santa Ana’s Transit Zoning Code (SD84)Environmental Impact Report (EIR) to demonstrate that, pursuant to the standardscontained in CEQA Guidelines Section 15162, this project is within the scope of theTransit Zoning Code (SD84) EIR No. 200602, State Clearinghouse (SCH) No.2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit ZoningCode (SD84) EIR fully analyzed the potential impacts associated with the proposedcode amendments. This is consistent with Section 8.06 of the City’s Local Guidelinesfor Implementing CEQA.Recommended Action: Recommend that the Planning Commission recommend that the City Council:1. Adopt a resolution to make findings pursuant to Public Resources CodeSection 21166 and to adopt the Addendum to the Transit Zoning CodeEnvironmental Impact Report (State Clearinghouse Number No.2006071100). Pursuant to the California Environment Quality Act (CEQA),and based on independent review and analysis, and the administrativerecord as a whole, that, in exercising its independent judgement, amendTZC SD84 Final EIR with an addendum that the City Council find thatpursuant to CEQA Guidelines Section 15162, no subsequentEnvironmental Impact Report (EIR) is required for the adoption of theproposed Ordinances; and pursuant to CEQA Guidelines Section 15164,an addendum to the Transit Zoning Code EIR was accordingly prepared;2. Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No.202402 amending certain sections of Article XIX (The Transit Zoning Code,Specific Development No. 84 (SD84)) of Chapter 41 (Zoning) of the SantaAna Municipal Code including amendments to the regulations, overlaydistricts and maps in the zoning district; modifying the authorized land usesand permit types; establishing revised nonconforming use regulations,including the addition of an amortization/termination of use process andadding operational standards for certain permitted and nonconforminguses; and3. Adopt an ordinance to approve Amendment Application (AA) No. 202403amending the zoning by removing the M1 (light industrial) and M2 (HeavyIndustrial) suffixes from certain properties within the SD84 zoning districtboundary as designated on the City of Santa Ana Zoning Map. *End of Business Calendar*STAFF COMMENTSCOMMISSIONER COMMENTSADJOURNMENTThe next meeting of the Planning Commission will be on Monday, March 10, 2025 at 5:30p.m. in the Council Chambers located at 22 Civic Center Plaza, Santa Ana, CA 92701.APPEAL INFORMATIONThe formal action by the Planning Commission shall become effective after the tendayappeal period, unless the City Council in compliance with section 41643, 41644 or 41645holds a public hearing on the matter, then the formal action will become effective on the dayfollowing the hearing and decision by the City Council. An appeal from the decision orrequirement of the Planning Commission may be made by any interested party, individual, orgroup. The appeal must be filed with the Clerk of the Council, accompanied by the requiredfiling fee, and a copy sent to the Planning Department, within ten days of the date of theCommission's action, by 5:00 p.m. If the final day to appeal falls on a City Hall observedholiday or a day when City hall is closed, the final day to appeal shall be extended to the nextday City Hall is open for public business. Please note: Under California Government CodeSec. 65009, if you challenge in court any of the matters on this agenda for which a publichearing is to be conducted, you may be limited to raising only those issues which you (orsomeone else) raised orally at the public hearing or in written correspondence received bythe Planning Commission or City Council at or before the hearing.MEETING INFORMATIONIf you would like to learn how to use Zoom before the meeting, visit Zoom Video Tutorials.1. Connecting directly from your computer:Click on the link on top of this agenda ORGo to Zoom.us and click "Join a Meeting" at the top. Enter the Meeting ID. The MeetingID is listed at the top of this agenda.To speak during the meeting: When you wish to comment on an item that is being isdiscussed, click on the button next to your name to virtually raise your hand and let us knowyou wish to speak. You will have 3 minutes.
2. Connecting via the Zoom App:
Download the free Zoom Cloud Meetings app from your favorite app store.
Launch the app and click on the blue Join a Meeting button. Enter the Meeting ID, your
name, and the blue Join button. The Meeting ID is listed at the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, click on the button next to your name to virtually raise your hand and let us know
you wish to speak. You will have 3 minutes.
3. Dialing in from a mobile phone or landline:
Dial (669) 9009128. When prompted, enter the meeting ID. The Meeting ID is listed at
the top of this agenda.
To speak during the meeting: When you wish to comment on an item that is being is
discussed, press *9 on your phone to virtually raise your hand. You will have 3 minutes.
Submit a written comment
You are invited to submit a written comment in one of the following ways:
Email PBAecomments@santaana.org and reference the topic in the subject line.
Mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza
– M20, Santa Ana, CA 92701.
Deadline to submit written comments, including any supplemental materials for
consideration by the Planning Commission, is 3:30 p.m. on the day of the
meeting. Comments received after the deadline may not be distributed to the
Planning Commission but will be made part of the record. All attendees wishing to
submit written comments or supplemental materials for distribution to Planning
Commission members during the inperson meeting must provide 15 printed copies.
Planning and Building Agency
www.santa-ana.org/pb
Item # 1
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Planning Commission Staff Report
March 6, 2025
Topic: Supplemental Staff Report to February 24, 2025 Planning Commission Staff
Report: Resolution to make findings and adopt Addendum to the Transit Zoning Code
Environmental Impact Report (State Clearinghouse Number No. 2006071100), Zoning
Ordinance Amendment (ZOA) No. 2024-02 and Amendment Application (AA) No. 2024-
03 amending certain sections of Article XIX (The Transit Zoning Code, Specific
Development No. 84) of Chapter 41 (Zoning) of the Santa Ana Municipal Code (SAMC)
addressing industrial land uses, nonconformities, and operating standards, and amending
the City of Santa Ana Zoning Map to remove the Light Industrial (M1) and Heavy Industrial
(M2) suffixes from certain properties within the SD-84 district boundary.
RECOMMENDED ACTIONS
Recommend that the Planning Commission recommend that the City Council:
1) Adopt a resolution to make findings pursuant to Public Resources Code Section
21166 and to adopt the Addendum to the Transit Zoning Code Environmental
Impact Report (State Clearinghouse Number No. 2006071100). Pursuant to the
California Environmental Quality Act (CEQA), and based on independent review
and analysis, and the administrative record as a while, that, in exercising its
independent judgement, amend TZC SD-84 Final EIR with an addendum that the
City Council find that pursuant to CEQA Guidelines Section 15162, no subsequent
Environmental Impact Report (EIR) is required for the adoption of the proposed
Ordinances; and pursuant to CEQA Guidelines Section 15164, and addendum to
the Transit Zoning Code EIR was accordingly prepared.
2) Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) NO. 2024-
02 amending certain sections of Article XIX (The Transit Zoning Code, Specific
Development No. 84 (SD-84)) of chapter 41 (Zoning) of the Santa Ana Municipal
Code including amendments to the regulations, overlay districts and maps in the
zoning district; modifying the authorized land uses and permit types; establishing
revised non-conforming use regulations, including the addition of an
amortization/termination of use process and adding operational standards for
certain permitted and non-conforming uses.
3) Adopt an ordinance to approve Amendment Application (AA) No. 2024-03
amending the zoning by removing the M1 (Light Industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD-84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
Planning Commission 1 – 1 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments Supplemental
Staff Report to February 24, 2025 Planning Commission Staff Report)
March 6, 2025
Page 2
3
3
6
7
BACKGROUND
On February 24, 2025, the Santa Ana Planning Commission held a duly noticed public
hearing on amendments proposed for the Transit Zoning Code (TZC), ZOA No. 2024-02,
the companion Zoning Map amendment, No. 2024-03, and the Addendum to TZC SD-84
Final EIR. Upon hearing all testimony, the Commission closed the public hearing, held
discussion, provided direction to staff, and continued the item to a special meeting
scheduled for March 6, 2025. The Commission requested that staff conduct and provide
certain deliverables for their further consideration of the proposed amendments, in order
to render a recommendation to the City Council on the proposed TZC amendments. The
three requested actions for staff were as follows:
1) Conduct an additional community meeting collectively, with interested parties in
attendance at the hearing, including residents, businesses, and property owners,
to facilitate further input on the proposed amendments;
2) Prepare a financial analysis to address potential impacts to the City as a result of
adopting the proposed amendments; and
3) Provide a legal briefing related to potential challenges that may result from
adoption of the proposed amendments.
DISCUSSION
The actionable items requested by the Commission have been addressed by staff and
are summarized below.
Community Meeting – March 3, 2025
Staff held the requested additional community meeting with interested parties, including
business owners, property owners, residents and others, on Monday, March 3, 2025, from
5:30 p.m. to 7:30 p.m. at the Santa Ana Regional Transportation Center (SARTC) First
Floor Conference Room (1000 E. Santa Ana Blvd.) to garner additional feedback about
the proposed changes. For a summary of the meeting, meeting format, and conclusions
from the meeting, please refer to Exhibit 1.
As a result of the input received at that meeting, combined with the prior analysis of the
proposed amendments as outlined in the February 24, 2025, Planning Commission staff
report, staff proposes making clarifying edits as well as text edits to the Ordinance
presented to the Planning Commission on February 24, 2025, as provided in Exhibit 2
(Clarifications to ZOA No. 2024-02). Specifically, the clarifications address typographical
errors as well as the emergent themes from the March 3rd community meeting related to
hours of operation and clarifying that nonconforming and “legal” nonconforming are one
and the same term for the purposes of implementing the TZC.
Planning Commission 1 – 2 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments Supplemental
Staff Report to February 24, 2025 Planning Commission Staff Report)
March 6, 2025
Page 3
3
3
6
7
Financial Information related to adoption of proposed TZC amendments
The Planning Commission requested City staff to provide financial information specifically
on the amendments’ effects on City revenues that would result from the proposed
ordinance. Staff from the City’s Finance and Management Services Agency evaluated
aggregate financial information using data sources for the City’s tax base that include
sales tax, property tax, businesses license tax, and utility users’ tax within the TZC. This
information will be provided as part of City staff’s presentation during the scheduled
meeting. Lastly, due to confidentiality requirements, revenue details provided are in
general and aggregate form, preventing the disclosure of individual business revenue.
The fiscal information is intended for general informational purposes only. The actual
fiscal impact cannot be determined and may vary significantly due to numerous
unpredictable factors, including the fact the proposed ordinance does not propose the
closure of any business; rendering businesses uses legal nonconforming does not
preclude the establishment of a new, similar business in the same location that may result
in no change to the City’s revenues; fluctuations in economic conditions; and potential
changes in business operations.
Legal Analysis
The Commission requested that the City Attorney provide a briefing related to legal
challenges to the proposed TZC amendments, specifically the creation of nonconforming
status to business and structures, and the general argument of a “taking,” as that term is
used legally. The City Attorney’s Office has provided a confidential memorandum
separately to the Planning Commission summarizing these legal questions. Due to the
potential for litigation, the information contained in the memorandum is considered client
privileged and confidential.
ENVIRONMENTAL IMPACT
The California Environmental Quality Act (CEQA) requires public agencies and local
governments to measure the environmental impacts of development projects or other
major land use decisions, and to limit or avoid those impacts if possible. CEQA Guidelines
Section 15164 states the following with respect to an Addendum to an EIR:
a) The lead agency or responsible agency shall prepare an addendum to a previously
certified EIR if some changes or additions are necessary but none of the conditions
described in Section 15162 calling for preparation of a subsequent EIR have occurred.
b) An addendum to an adopted negative declaration may be prepared if only minor
technical changes or additions are necessary or none of the conditions described in
Section 15162 calling for the preparation of a subsequent EIR or negative declaration
have occurred.
c) An addendum need not be circulated for public review but can be included in or
attached to the final EIR or adopted negative declaration.
Planning Commission 1 – 3 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments Supplemental
Staff Report to February 24, 2025 Planning Commission Staff Report)
March 6, 2025
Page 4
3
3
6
7
d) The decision-making body shall consider the addendum with the final EIR or adopted
negative declaration prior to making a decision on the project.
e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to
Section 15162 should be included in an addendum to an EIR, the lead agency’s
findings on the project, or elsewhere in the record. The explanation must be supported
by substantial evidence.
Additionally, CEQA Guidelines Section 15162, Subsequent EIRs and Negative
Declarations, states the following with respect to a Subsequent EIRs:
(a) When an EIR has been certified or a negative declaration adopted for a project, no
subsequent EIR shall be prepared for that project unless the lead agency determines,
on the basis of substantial evidence in the light of the whole record, one or more of
the following:
(1) Substantial changes are proposed in the project which will require major
revisions of the previous EIR or negative declaration due to the involvement of
new significant environmental effects or a substantial increase in the severity
of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the
project is undertaken which will require major revisions of the previous EIR or
Negative Declaration due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified
significant effects; or
(3) New information of substantial importance, which was not known and could not
have been known with the exercise of reasonable diligence at the time the
previous EIR was certified as complete or the Negative Declaration was
adopted, shows any of the following:
(A)The project will have one or more significant effects not discussed in the
previous EIR or negative declaration;
(B)Significant effects previously examined will be substantially more severe
than shown in the previous EIR;
(C)Mitigation measures or alternatives previously found not to be feasible
would in fact be feasible, and would substantially reduce one or more
significant effects of the project, but the project proponents decline to
adopt the mitigation measure or alternative; or
(D)Mitigation measures or alternatives which are considerably different
from those analyzed in the previous EIR would substantially reduce one
or more significant effects on the environment, but the project
proponents decline to adopt the mitigation measure or alternative.
(b) If changes to a project or its circumstances occur or new information becomes
available after adoption of a negative declaration, the lead agency shall prepare a
subsequent EIR if required under subdivision (a). Otherwise, the lead agency shall
determine whether to prepare a subsequent negative declaration, an addendum, or
no further documentation.
Planning Commission 1 – 4 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments Supplemental
Staff Report to February 24, 2025 Planning Commission Staff Report)
March 6, 2025
Page 5
3
3
6
7
ZOA No. 2024-02 and AA No. 2024-03 are considered a project as defined by the CEQA.
The City, as the Lead Agency, has determined that it is subject to CEQA guidelines and
regulations (Public Resources Code (PRC) Sections 21000-21177). An Addendum,
attached as Exhibit 5, to the Transit Zoning Code Environmental Impact Report (EIR)
(State Clearing House (SCH) No. 2006071100) has been prepared by the City. Based on
its independent review and analysis, and the administrative record as a whole, and, in the
exercising its independent judgement, hereby finds that pursuant to CEQA Guidelines
Section 15162, no subsequent EIR would be required for the proposed project; and
pursuant to CEQA Guidelines Section 15164, an addendum to the Transit Zoning Code
EIR is required for the adoption of the Ordinances.
Specifically, pursuant to CEQA Guidelines Section 15162, the City finds on the basis of
substantial evidence in light of the whole record, that: (1) no substantial changes are
proposed in the project which will require major revisions of the EIR due to the
involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects; (2) no substantial changes have
occurred with respect to the circumstances under which the project is undertaken which
will require major revisions of the EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects; and (3) there is no new information of substantial importance, which
was not known and could not have been known with the exercise of reasonable diligence
at the time the EIR was certified as complete, that shows any of the following: (A) the
project will have one or more significant effects not discussed in the EIR; (B) significant
effect previously examined will be substantially more severe than shown in the EIR; (C)
mitigation measures or alternatives previously found not to be feasible would in fact be
feasible and would substantially reduce one or more significant effects of the project, but
the project proponents decline to adopt the mitigation measure or alternative; or (D)
mitigation measures or alternative which are considerably different from those analyzed
in the EIR would substantially reduce one or more significant effects on the environment,
but the project proponents decline to adopt the mitigation measure or alternative.
Additionally, as detailed in the General Plan Consistency subsection of the Planning
Commission’s February 24, 2025 staff report, attached as Exhibit 6 (February 24, 2025
Planning Commission Staff Report, without attachments), the proposed Ordinances are
consistent with numerous General Plan goals and policies that were evaluated as part of
the General Plan Update Program EIR. The proposed Ordinances also satisfy and further
implementation actions of the General Plan Update.
FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBITS
1. March 3, 2025 Transit Zoning Code (SD-84) Community Meeting Summary
Planning Commission 1 – 5 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments Supplemental
Staff Report to February 24, 2025 Planning Commission Staff Report)
March 6, 2025
Page 6
3
3
6
7
2. Clarifications to ZOA No. 2024-02
3. Ordinance for Zoning Ordinance Amendment (ZOA) No. 2024-02
4. Ordinance for Amendment Application (AA) No. 2024-03
5. Resolution of the City Council and Addendum to TZC EIR
6. February 24, 2025 Planning Commission Staff Report (Without Attachments)
7. Copy of Public Notice
Submitted By: Margarita Macedonio, Principal Planner
Approved By: Ali Pezeshkpour, AICP, Acting Executive Director, Planning and Building
Agency
Planning Commission 1 – 6 3/6/2025
Exhibit 1: Transit Zoning Code (SD-84) March 3, 2025 Community Meeting
Summary
Page 1
Overview
At the Planning Commission public hearing on Monday, February 24, 2025, the Planning
Commission continued the proposed amendment to the Transit Zoning Code (SD-84) and
zoning map item to a special meeting scheduled for Thursday, March 6, 2025 at 6:30 p.m.
at Santa Ana City Hall Council Chamber (22 Civic Center Plaza). In addition, the Planning
Commission directed staff to conduct an additional community meeting, before the March
6th special meeting, with interested parties in attendance at the hearing, including
residents, businesses, and property owners, to garner additional feedback on the
proposed amendments.
This report summarizes the meeting outcomes, detailing outreach efforts, participation
format, and key themes derived from community input. Additionally, it emphasizes and
implements the Planning Commission's intent to facilitate continued collaboration
between residents and businesses in identifying areas of common ground and potential
compromise regarding the proposed amendments.
Outreach
To ensure broad participation, staff conducted extensive outreach for the March 3, 2025,
community meeting. Staff contacted community members that provided public testimony
at the regularly scheduled February 24, 2025 Planning Commission meeting that provided
contact information and members of the public on the project interested parties list,
directly emailing invitations to approximately 184 individuals, and personally calling those
without email, securing updated contact details. Staff also programmed and sent a pre-
recorded voice message reminder to approximately 130 contacts. Finally, staff sent a
same-day email reminder. To ensure inclusivity, staff also arranged for Spanish
interpretation services for the community meeting.
Location
The meeting was held on
Monday, March 3, 2025, from
5:30 p.m. to 7:30 p.m., at the
Santa Ana Regional
Transportation Center (SARTC)
First Floor Conference Room.
The meeting location is located
within the boundaries of the
Transit Zoning Code and in close
proximity to both established
residential communities within the
district and properties with an
industrial overlay subzone.
Participation Format
The meeting included a presentation that covered the major points of the proposed
ordinance and the purpose of the meeting as directed by the Planning Commission, with
a majority of the meeting time allocated to small group discussion. The small group
Planning Commission 1 – 7 3/6/2025
Exhibit 1: Transit Zoning Code (SD-84) March 3, 2025 Community Meeting
Summary
Page 2
discussion format kept the meeting focused on facilitating a productive dialogue,
achieving consensus and thoughtful solutions, with discussion centered on two questions:
1) What industrial and quasi-industrial business types operating today within the
district can be considered compatible with residential uses?
2) What new proposed operational standards—for example, limits on hours of
operation, prohibition on truck idling—create the greatest concerns for businesses,
and how might they be adjusted/refined without adversely impacting residential
uses?
Attendance and Randomly-Assigned Small Groups
Approximately, 120 people attended the March 3, 2025, meeting comprised of residents,
businesses, property owners, real estate brokers, community-based organizations, and
staff from the offices of elected representatives. Of those in attendance, approximately,
58 percent represented businesses and 36 percent of the community members in
attendance were residents of the area. Although staff recognizes that not all attendees
sign in, the meeting sign in sheets indicate 94 contacts.
To fulfill the Planning Commission's
directive for open community dialogue,
staff designed a check-in system that
randomly assigned attendees to small
groups using color stickers to help
balance representation from resident
and businesses. At the check-in tables,
attendees indicated whether they were a
resident, business or property owner,
and their nametag included color
stickers to assign them randomly to a
small group. Each group included a
facilitator led by City staff or one of the
City’s planning consultants to help guide the discussion and comments to identify areas
of commonality, or compromise from residents and businesses regarding the proposed
amendments. Lastly, Spanish interpreters were present at one of the small groups to
facilitate mono-lingual Spanish speakers’ participation in the meeting.
Conclusion
The meeting was held in accordance with and satisfied the Planning Commission’s
direction provided to staff on February 24, 2025 to conduct a community meeting with
both business owners and residents. Areas of consensus included ensuring that the
ordinance addresses the most impactful industrial businesses, while areas of
disagreement remain in the extent to which the proposed amendments will result in land
use changes. Lastly, specific feedback from business owners addressing the definition
of craft and specialized automotive restoration service, hours of operation, and the
Planning Commission 1 – 8 3/6/2025
Exhibit 1: Transit Zoning Code (SD-84) March 3, 2025 Community Meeting
Summary
Page 3
terms “nonconforming use” and “legal nonconforming use” having the same meaning,
have been added to Exhibit 2 (Clarifications to ZOA No. 2024-02).
Planning Commission 1 – 9 3/6/2025
Exhibit 2: Clarifications to ZOA No. 2024-02
1
The following represents clarifications proposed to the draft Ordinance text published for
the February 24, 2025, Planning Commission hearing agenda. The clarifications include
non-substantive, typographical errors as well as proposed amendments that respond to
community feedback received at the March 3, 2025, community meeting referenced in
the staff report and in Exhibit 1.
The following non-substantive, typographical clarifications shall be included in the draft
Ordinance recommended by the Planning Commission for City Council consideration:
1. Revise all typographical errors related to numeric/alphanumeric labeling of sections
and subsections.
2. Ordinance Page 24, Subsection (I) of Section 41-2008 (Operational Standards) in
Section 10 of the Ordinance shall read as follows, reflecting proposed text in underline
and deleted text in strikethrough:
(l) Operational standards for aAutomobile servicing uses including nonconforming
establishments, shall comply with the following operational standards:
3. Ordinance Page 33, Subsection 35. b. of Section 41-2080 (Definitions) in Section 12
of the Ordinance shall read as follows, reflecting proposed text in underline and
deleted text in strikethrough:
b. art supplies, including framing services bicycles
4. Ordinance Page 4, Subsection (5) b. of Section 41-2002 (Nonconforming Buildings,
Structures and Uses) in Section 5 of the Ordinance shall read as follows, reflecting
proposed text in underline and deleted text in strikethrough:
b. Rehabilitation may include expansion of floor area without intensification of the
nonconforming use when the total floor area of all expansions occurring in any
five year period does not exceed ten (10) percent of the floor area as it legally
existed as permitted and constructed as of April 15, 2025 at the beginning of the
five year period, provided that the following standards conditions are met:
5. Ordinance Page 10, Subsection (6) c. of Section 41-2002 (Nonconforming Buildings,
Structures and Uses) in Section 6 of the ordinance shall read as follows reflecting
proposed text in underline and deleted text in strikethrough related to the Hearing
Officer Determination and Compliance:
c. Hearing Officer Determination and Compliance. The determination of the
Hearing Officer shall be made in writing and shall be final.
Planning Commission 1 – 10 3/6/2025
Exhibit 2: Clarifications to ZOA No. 2024-02
2
1. Notice of Amortization and Termination of Use. The Executive Director
of the Planning and Building Agency, or designee, shall give notice by
certified mail of the date upon which an amortization period will end to
each owner of record whose property, or use of property, is not in
conformance with the regulations of this Article, in those instances
where an amortization period has been determined pursuant to this
Article. Such notice shall be sent within ten (10) days of the termination
of any appeal period the determination of the Hearing Officer. If the
amortization period ends before or less than six (6) months after
providing such notice, the notice shall be given that the amortization
period in each instance shall be not less than six (6) months from the
date the notice is sent. The notice shall set forth all pertinent provisions
of this Article, including the declared purposes thereof and the approved
amortization term. Failure to send notice by mail to any such owner
where the address of such owner is not a matter of public record shall
not invalidate any proceedings under this Article. The Executive
Director of the Planning and Building Agency, or designee, shall be
authorized record a Notice of Amortization Term & Termination of Use
with the County Recorder, as provided for in California Government
Code Section 27201(a).
The following changes based upon community feedback received at the Transit Zoning
Code community meeting held on March 3, 2025, shall be included in the draft Ordinance
recommended by the Planning Commission for City Council consideration:
6. Ordinance Page 24, Subsection (l) of Section 41-2008 (Operational Standards), which
proposed prohibiting automobile servicing on Sundays shall remain unchanged and
reflect the existing standard as shown below:
(l) Automobile servicing uses including nonconforming establishments, shall comply
with the following operational standards:
(1)No automobile servicing shall be conducted before 7:00 a.m. or after 8:00 p.m.
Monday through Friday and before 10:00 a.m. or after 8:00 p.m. Saturday and
Sunday.
(2)All work shall be conducted inside an enclosed structure.
(3)Outdoor or overnight vehicle storage is not permitted.
7. Ordinance Page 27, Subsection (k) of Section 41-2009 (Operational Standards for
Nonconforming Industrial Uses), which proposed imposing new operational hours
shall be removed in its entirety, as the operating hours imposed on all uses under
Planning Commission 1 – 11 3/6/2025
Exhibit 2: Clarifications to ZOA No. 2024-02
3
Section 41-2008 would apply. The ordinance shall read as follows reflecting proposed
text deletion in strikethrough related to hours of operation:
(k) Hours of Operation
(1)For non-conforming industrial uses which are directly across a street from or
abutting residential uses or structures, hours of operation shall be limited to
7:00 a.m. to 6:00 p.m., Monday through Friday, and 10:00 a.m. to 6:00 p.m.
Saturday.
(2)No operating hours are permitted on Sundays, or Federal Holidays.
8. Ordinance Page 35, Subsection 50. of Section 41-2080 (Definitions), in Section 12 of
the ordinance related to the definition of nonconforming industrial use shall read as
follows reflecting proposed text in underline:
50.Nonconforming Industrial Use: A nonconforming use as defined in Section 41-126
of the SAMC that was established on any parcel or within any building located
within the boundaries of SD-84 established by this Article that is listed in the uses
permitted or uses permitted subject to a conditional use permit of Division 18. M-1
(Light Industrial) or Division 19. M-2 (Heavy Industrial) of this Chapter but that are
no longer permissible through amendment to this Article. The terms
“nonconforming use” and “legal nonconforming use” have the same meaning in
the implementation of this Article.
9. Ordinance Page 31, Subsection 23. of Section 41-2080 (Definitions), in Section 12 of
the ordinance related to the definition of craft and specialized automotive restoration
service shall read as follows reflecting proposed text in underline and deleted text in
strikethrough:
23. Craft and specialized automotive restoration service: A specialized business or
commercial enterprise occurring inside of a fully-enclosed structure that focuses
on repairing and restoring older cars, often considered "collector cars" as defined
by the State; which includes (1) a vehicle model 35+ years old, (2) a vehicle model
25+ years old with historic plates, or (3) a vehicle model classified as a special
interest vehicle. Such restoration services return these types of vehicles to their
original condition, including mechanical components, bodywork, and interior,
aiming to preserve their historical authenticity and aesthetic appeal. The vehicle
must not be altered from the manufacturer's original specifications or considered
a "kit" car.
Planning Commission 1 – 12 3/6/2025
Ordinance No. NS-XXX
Page 1 of 49
ORDINANCE NO. NS-XXXX
AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA APPROVING ZONING ORDINANCE
AMENDMENT NO. 2024-02, AMENDING CERTAIN
SECTIONS OF CHAPTER 41 (ZONING) OF ARTICLE XIX
OF THE SANTA ANA MUNICIPAL CODE RELATED TO THE
REGULATIONS, OVERLAY DISTRICTS AND MAPS IN THE
TRANSIT ZONING CODE/SPECIFIC DEVELOPMENT (SD)
NO. 84 ZONING DISTRICT; MODIFYING THE
AUTHORIZED LAND USES AND PERMIT TYPES;
ESTABLISHING REVISED NONCONFORMING USE
REGULATIONS, INCLUDING THE ADDITION OF AN
AMORTIZATION/TERMINATION OF USE PROCESS AND
ADDING OPERATIONAL STANDARDS FOR CERTAIN
PERMITTED AND NONCONFORMING USES
THE CITY COUNCIL OF THE CITY OF SANTA ANA HEREBY ORDAINS AS FOLLOWS:
Section 1. The City Council has, by separate action taken on March 18, 2025,
adopted an Addendum to the Transit Zoning Code Environmental Impact Report (“EIR”)
(State Clearinghouse No. 2006071100), which was certified on June 7, 2010, by the City
Council (“Addendum”). The Addendum analyzed the environmental impacts of the
actions taken in this Ordinance. Adopting the Addendum satisfied the City Council’s
obligations under the California Environmental Quality Act (“CEQA”) regarding
amendments to the Transit Zoning Code and none of the conditions in Public Resources
Code section 21166 or State CEQA Guidelines 15162 apply. Thus, no further
environmental review is required as adoption of this Ordinance falls within the scope of
the adopted Addendum and previously certified EIR.
Section 2. The City Council of the City of Santa Ana hereby adopts the findings
contained in the attached Exhibit “A” to this Ordinance as if fully set forth herein.
Section 3. Section 41-2001 (Application of Article) of Chapter 41 of the Santa
Ana Municipal Code is hereby amended to read as follows:
“Sec. 41-2001. Application of Article
(a)The Transit Zoning Code, as authorized by Chapter 41, Article III, Division 26,
Section 41-593 et seq., of the Santa Ana Municipal Code (SAMC), is subject to the
standards and regulations contained in this Article for the express purpose of
establishing land use regulations and standards. All other applicable chapters,
articles, and sections of the SAMC and any other regulations adopted by the City
Council shall apply unless expressly stated or superseded by this Article. All terms
contained herein shall be defined by the SAMC, unless specifically defined in this
Article.
Exhibit 3: Ordinance for Zoning Ordinance Amendment (ZOA) No. 2024-02
___________________________________________________________________________
Planning Commission 1 – 13 3/6/2025
Ordinance No. NS-XXX
Page 2 of 49
(b) Proposed development, including the construction, reconstruction or structural
alteration of a structure, subdivisions, and new and existing land uses, whether
conforming or nonconforming, as defined in Section 41-126 of the SAMC, within
the specific development area shall comply with all the applicable regulations
established by this Article article.
(c) The regulations contained in this Article shall also apply to:
1. A change in land use within an existing building; and
2. A change in tenancy within an existing building requiring issuance of
a new Certificate of Occupancy.”
Section 4. Section 41-2001.5 (Organization) of Chapter 41 of the Santa Ana
Municipal Code is hereby amended to read as follows:
“Sec. 41-2001.5 Organization
(a) Regulating Plan and Zones Established: Sections 41-2006 through 2008 2009 of
this Article defines the zones within the Specific Development (SD) boundaries of
SD-84, the parcels included within each zone, and describes, zone by zone, the
standards for building placement, design, and use consistent with the permitted
uses identified in Table 2A.
(b) Use Standards: Table 2A identifies the land use types allowed by the City in each
of the zones established by the Regulating Plan. A parcel within the Specific
Development (SD-84) boundaries shall be occupied only by land uses identified
as allowed within the applicable zone and the type of City approval required by
Table 2A.
(c) Urban Standards by Zone: Sections 41-2010 through 2015 of this Article regulates
the features of buildings that affect the public realm. The urban standards regulate
building and parking placement, height, and profile, and vary according to the
parcel's zone applied by the Regulating Plan. Standards for items not explicitly
described in this section, including but not limited to, walls and fences, mechanical
equipment, trash bin enclosures, heliport and helipad, underground utility,
installation of dish antennas, loading areas, parking lot design standards, refer to
other Sections of Chapter 41 of the Santa Ana Municipal Code SAMC and the
Citywide Design Guidelines.
(d) Architectural Standards: Sections 41-2020 through 2039 regulates the manner in
which individual parcels and blocks are developed to create diverse and
pedestrian-oriented development, through the use of three main components:
(1) Sections 41-2020 through 2032 building types (e.g., duplex, rowhouse,
courtyard housing)
Planning Commission 1 – 14 3/6/2025
Ordinance No. NS-XXX
Page 3 of 49
(2) Sections 41-2033 through 2039 frontage types (e.g., front yard/porch, stoop,
arcade, shopfront)
(3) Section 41-2040 (Table 4.3A) architectural styles (e.g., Main Street
Commercial, Mission Revival, Art Deco, Folk Victorian, Craftsman, California
Contemporary).
(e) Sign Standards: Section 41-2050 regulates all signage within the SD boundaries
to be consistent with the character described for each zone.
(f) Subdivision Guidelines: Establishes guidelines for the creation and maintenance
of a finely grained and walkable network of blocks punctuated by integral and
varied open spaces.
(g) Street Network Concepts: identifies conceptual location and guidelines for the
street network. This section provides guidelines for the rights-of-way alignment,
and width in plan and section with the corresponding details.
(h) Definitions: Sections 41-2080 identifies and defines the terms used in this Code.”
Section 5. Section 41-2002 (Nonconforming Buildings, Structures and Uses) of
Chapter 41 of the Santa Ana Municipal Code is hereby amended to read as follows:
“Sec. 41-2002. Nonconforming Buildings, Structures and Uses
(a) A nonconforming building, structure or use shall comply with Article VI of this
Chapter, except as provided below modified as follows:
(1) A building or structure that does not conform to the architectural style or story
height requirements at the time of the adoption of this Article shall not cause
the structure to be non-conforming.
(2) A nonconforming building, structure or use shall not be required to conform to
current zoning regulations based solely upon a change in ownership of the
property, except as otherwise provided in this Article.
(3) A sale, lease or other transfer of a property containing a nonconforming
building, structure or use does not trigger the loss of nonconforming status,
except as otherwise provided in this Article.
(24)Sections 41-681.1 through 41-681.4 and 41-683.6 of Article VI of this Chapter
shall not apply to this buildings, structures and uses addressed within this
Article or building, structures, and uses within SD-84, nor to existing accessory
dwelling units (ADUs) permitted by the City of Santa Ana before the
amendment to this Article.
Planning Commission 1 – 15 3/6/2025
Ordinance No. NS-XXX
Page 4 of 49
(35)Rehabilitation, enlargement or exterior structural alterations of any
nonconforming structure or structure occupied by a nonconforming use, except
for structures occupied by single family and two-family dwellings, may be
rehabilitated made as follows:
a. Rehabilitation, limited to structural or non -structural alterations without any
building expansion and without any intensification of a nonconforming use,
is permitted if:
1. The operational standards contained in sections 41-2008 and 41-2009,
as applicable, of this Article are met.
1. 2. All signage on the structure and the site on which it is located is brought
into conformity with the signage requirements of this Chapter , as
approved by the Executive Director of the Planning and Building Agency,
or designee.
2. 3. All outdoor storage is screened by a solid screen wall not to exceed eight
(8) feet in height. Outdoor storage shall not exceed the height of the
screen wall.
3. 4. There shall be no increase in the number of dwelling units unless the site
on which the structure is located complies with the off-street parking and
open space requirements of this Chapter.
4. 5. Architectural massing, features and detailing shall be modified to bring
the structure into closer compliance with the architectural standards of
this Article code, as approved deemed appropriate by the Executive
Director of the Planning and Building Agency, or their designee.
b. Rehabilitation may include expansion of floor area without intensification of
the nonconforming use when the total floor area of all expansions occurring
in any five-year period does not exceed ten (10) percent of the floor area as
it legally existed as permitted and constructed as of April 15, 2025 at the
beginning of the five year period, provided that the following standards
conditions are met:
1. The existing use is not a nonconforming industrial use. Nonconforming
industrial uses may not be expanded.
2. The operational standards contained in Section 41-2008 are met.
1. 3. All signage on the structure and the site on which it is located shall be
brought into conformity with the requirements of this chapter Chapter as
approved by the Executive Director of the Planning and Building Agency,
or designee.
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2. 4. There shall be no loading or unloading of vehicles between the hours of
10 pm and 7 am.
3. 5. All outdoor storage is screened by a solid screen wall not to exceed eight
(8) feet in height. Outdoor storage shall not exceed the height of the
screen wall.
4. 6. There shall be no enlargement which would intrude into any required
setback area required by this Article.
5. 7. There shall be no enlargement which would result in a new
nonconforming condition in violation of the requirements of this
Chapter.
6. 8. Off-street parking shall be provided in conformance with the
requirements of this Chapter.
7. 9. Landscaping shall be improved to bring the site on which the structure
is located into closer compliance with the landscaping requirements of
this Chapter, as approved deemed appropriate by the Executive Director
of the Planning and Building Agency, or their designee.
8. 10. Architectural massing, features and detailing, shall be modified to bring
the structure into closer compliance with the architectural standards of
this Chapter, as approved deemed appropriate by the Executive
Director of the Planning and Building Agency, or their designee.
(46)Rehabilitation, enlargement or exterior structural alterations of buildings
occupied by a single family and two-family dwellings is permitted subject to
the following:
a. Structural alterations and additions may be made where the total floor area
of all such expansions occurring in a five-year period does not exceed forty
(40) percent of the floor space of the building as it existed at the beginning
of that five-year period, provided the number of dwelling units is not
increased; and no new non-conformances with the requirements of this
code Chapter are created.
b. Structural alterations and additions which exceed forty (40) percent of the
total floor area as it existed at the beginning of a five -year period; or
remodeling which involves the demolition of more than fifty (50) percent of
the building shall be permitted; provided that the following conditions are
met:
1. Off-street parking shall be provided in conformance with the
requirements of this Chapter.
2. No new nonconformities with the requirements of this Chapter are
created.
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3. A minimum of eight hundred (800) square feet of usable, continuous,
non-front yard open-space, excluding driveways and parking areas is
provided. Any open space with a minimum dimension of fifteen (15) feet
by fifteen (15) feet shall be deemed continuous open space.
c. Where rehabilitation of a building involves more than fifty (50) percent of a
building wall which encroaches into a front or side yard setback and is
demolished or is structurally altered, the remainder of the building wall shall
be demolished. Any subsequent building wall shall conform to all provisions
of this Chapter.
d. An existing two-car garage with a minimum dimension of eighteen (18) feet
by eighteen (18) feet exterior dimension shall be considered con - forming.
e. Remodeling shall mean to reconstruct, or to make over in structure or style,
but shall exclude re-roof, window replacement, exterior finish replacement
and repair or similar modifications, as determined by the Executive Director
of the Planning and Building Agency, or designee.
f. No provision contained in this Article shall be interpreted or implemented in
a manner inconsistent with State law addressing accessory dwelling units,
as contained in Government Code Section 66310, et. seq., as amended
from time to time.
(5) Discontinuance of Nonconforming Uses, Generally. Nonconforming uses shall
be discontinued pursuant to Sec. 41-683 (Discontinuance of nonconforming
building or use) of this Chapter, regardless of intent, except as provided below:
a. Discontinuance of Noxious Use.
1. If a nonconforming industrial use that meets the definition of a Noxious
Uses as defined in this Article requires a new certificate of occupancy
for any reason other than a change in business name with no change in
owner of the business, legal nonconforming status shall be lost and any
subsequent use must conform in every respect to the provisions of this
Article.
2. If a nonconforming industrial use that meets the definition of a Noxious
Use as defined in this Article is in violation of any applicable Federal,
State, or local regulation, as provided below, legal nonconforming status
shall be lost and any subsequent use of the building shall conform in
every respect to the provisions of this Chapter:
A. The violation lasts a period of thirty (30) consecutive days; or
B. The violation(s) are observed and documented for a total period of
sixty (60) days in a one-year period; or
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C. Three noncompliant notices from a Federal, State, or local regulatory
agency relating to or arising from the nonconforming use are sent in
a one-year period.
3. For the purpose of this subsection 5(a)(2):
A. The thirty (30) consecutive day time period shall be measured
from the date of the first observed and documented violation.
B. A one-year period shall be the twelve (12) consecutive months of
time preceding the sixtieth (60th) day of total violations; or the
twelve (12) consecutive months of time preceding the issuance
of the third (3rd) noncompliant notice.
C. Local regulations mean the SAMC, including, but not limited to,
the operational standards contained in Section 41-2009 of this
Article.
D. A local regulatory agency includes the City, County of Orange,
special districts, or any other local government agency charged
with regulating noxious uses.
E. Noncompliant notices may include, but are not limited to, Notice
to Comply and Notice of Violation as issued by the South Coast
Air Quality Management District (SCAQMD), Department of Toxic
Substances Control (DTSC), California Environmental Protection
Agency (CalEPA), Certified Unified Program Agency (CUPA),
and Santa Ana Regional Water Quality Control Board
(SARWQB).
(6) Elimination of Nonconforming Uses and Structures.
a. Elimination of Nonconforming Uses and Structures, Generally.
1. The City Council has determined that elimination of nonconforming uses
and structures by amortization may be considered based upon one or
more of the following factors:
A. The threat to the public health, safety, and welfare posed by the
continuance of the nonconforming use or structure;
B. Adaptability of the land and improvements to a currently permitted
use;
C. Compatibility with the existing land use patterns and densities of
the surrounding neighborhood;
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D. Excessive calls for service to applicable response agencies related
to the operation of the nonconforming use; and
E. Failures to remedy notices of violation, administrative warnings, or
other notices of noncompliance issued by a Federal, State, or local
agency, including the City.
2. The Executive Director of the Planning and Building Agency, or
designee, in conjunction with other City Departments and Agencies,
may establish, and periodically update, a list or data resource that
identifies categories of nonconforming uses or structures with specific
metrics and operational characteristics, to develop a ranking system for
use in the consideration of eliminating nonconforming uses or structures
through amortization.
3. The determination of an appropriate amortization period for termination
of a nonconforming use pursuant to this Article shall be made by a
Hearing Officer retained by the City and who has professional legal and
land use experience to address amortization. The Hearing Officer shall
order nonconforming uses and structures to be discontinued and
removed from their sites within a period determined pursuant to the
process set forth in Subsection b (Establishment of Amortization
Periods), and consider the following:
A. If the nonconforming user has not made a substantial investment in
furtherance of the use or structure, or if the investment can be
substantially utilized or recovered through a currently permitted use,
the order may require a nonconforming use or structure to be
discontinued and removed from their site within a minimum of one
year after the date of the order.
B. If the nonconforming user has made a substantial investment in
furtherance of the use or structure, or if the investment cannot be
substantially utilized or recovered through a currently permitted use,
the order may require the discontinuation and removal of the
nonconforming use or structure within a longer reasonable amount
of time.
C. Nonconforming uses or structures that are determined to be an
imminent threat to the public health or safety may be subject to
immediate cessation and removal, pursuant to Chapter 1 (General
Provisions) of the SAMC.
4. Nonconforming uses and structures may also, upon order from the City
or a court order, be subject to immediate cessation and removal of the
nonconforming use or structure.
b. Establishment of Amortization Periods. Where a period during which a
nonconforming use or structure is to be discontinued and removed from a
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site or sites is required pursuant to this Article, such period shall be
established as follows:
1. The Executive Director of the Planning and Building Ag ency, or
designee, shall submit the nonconforming use or structure and a
recommended amortization period, based on subsection 4. herein, to a
Hearing Officer pursuant to Chapter 3 of the SAMC for review;
2. The Hearing Officer shall hold a noticed hearing to consider the
recommended amortization period. Notice of the hearing shall be
provided to the owner or operator of the nonconforming use or structure
and the property owner at least ten (10) days prior to the hearing.
Additional notice may also be provided to surrounding property owners
and/or tenants, at the discretion of the Executive Director of the Planning
and Building Agency, or designee.
3. The Hearing Officer shall consider the recommendations submitted by
the Executive Director of the Planning and Building Agency, the General
Plan of the City, and any testimony or evidence provided during the
hearing, in order to determine the amortization schedule for elimination
of the nonconforming use or structure.
4. The Hearing Officer shall establish a maximum amortization period
during which the nonconforming use or structure shall be permitted to
continue after considering the following in relation to the use or structure:
A. The amount of investment or original cost of the use or structure;
B. The present actual or depreciated value of the use or structure;
C. The remaining useful life of the use or structure;
D. The remaining term of the lease (if applicable);
E. The date or dates of construction;
F. Amortization of the business or structure for tax purposes;
G. The salvage value;
H. Adaptability of the land and improvements to a currently
permitted use;
I. Cost of moving and reestablishing the use elsewhere;
J. Compatibility with the existing land use patterns and densities of
the surrounding neighborhood;
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K. The threat to the public health, safety, and welfare posed by the
continuance of the nonconforming use or structure;
L. Calls for service to applicable response agencies;
M. Notices of violation, administrative warnings, or other notices of
noncompliance arising from or related to the nonconforming use
issued by a Federal, State, or local agency, including the City;
and
N. Other factors as appropriate.
c. Hearing Officer Determination and Compliance. The determination of the
Hearing Officer shall be made in writing and shall be final.
1. Notice of Amortization and Termination of Use. The Executive Director
of the Planning and Building Agency, or designee, shall give notice by
certified mail of the date upon which an amortization period will end to
each owner of record whose property, or use of property, is not in
conformance with the regulations of this Article, in those instances
where an amortization period has been determined pursuant to this
Article. Such notice shall be sent within ten (10) days of the termination
of any appeal period. If the amortization period ends before or less than
six (6) months after providing such notice, the notice shall be given that
the amortization period in each instance shall be not less than six (6)
months from the date the notice is sent. The notice shall set forth all
pertinent provisions of this Article, including the declared purposes
thereof and the approved amortization term. Failure to send notice by
mail to any such owner where the address of such owner is not a matter
of public record shall not invalidate any proceedings under this Article.
The Executive Director of the Planning and Building Agency, or
designee, shall be authorized record a Notice of Amortization Term &
Termination of Use with the County Recorder, as provided for in
California Government Code Section 27201(a).
2. Notice of Termination and Order to Comply and Conclusion of
Amortization Period. Notice of Termination of a nonconforming use and
order to comply shall be served by the Executive Director of the Planning
and Building Agency, or designee, at the end of the amortization period
upon the owner of record whose property contains such nonconforming
use. In those instances, where the Executive Director of the Planning
and Building Agency, or designee, is unable with reasonable effort to
serve such notice to the property owner, such notice and order shall be
served within thirty (30) days of the end of the amortization period by
delivering same to an occupant of the structure containing the
nonconforming use.
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3. Request for a Continuance of Nonconformities Beyond Period of
Amortization Period. A request for a continuance of nonconformities
beyond the period of amortization may be granted as follows:
a. Grounds for Continuance. A nonconforming use or structure
may be maintained for a reasonable time beyond its period of
amortization as specified in this Article if the Executive
Director of the Planning and Building Agency, or designee,
makes the following determinations:
i. Special Circumstances. That special circumstances
apply to any such use or structure that do not apply
generally to others affected hereby; and
ii. Compatibility with Public Welfare. That such a
continuance for a prescribed period of additional time
is in the public interest and will be reasonably
compatible with, and not detrimental to, the use of
adjacent properties.
b. Application Process for Continuance. Any application for a
continuance of a nonconforming use or structure must be filed
with the Planning Division no later than thirty (30) days
following the service of a Notice of Termination and Order to
comply, or within thirty (30) days following the continued
termination date. An application for a continuance may be
filed by the owner of the property, a person with a power of
attorney from the owner of the property, or a lessee, if the
terms of the lease permit the existing use. Fees shall be
required in accordance with this Code.
c. Determination by Executive Director of the Planning and
Building Agency, or designee. Upon filing of a complete
application, the Executive Director of the Planning and
Building Agency, or designee, shall investigate the matter,
give proper notice to the applicant, hold an administrative
hearing and make a decision thereon based on the criteria set
out in this Section and supported by written findings of fact
within seventy-five (75) days from the date the application is
filed, or within such extended period of time as may be
mutually agreed upon by the applicant and the Executive
Director of the Planning and Building Agency, or designee.
The Executive Director of the Planning and Building Agency,
or designee, may impose such conditions, including additional
time extensions not to exceed two (2) additional years, as may
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be deemed necessary for the compatibility of such
nonconformity with adjacent properties.
d. Appeals. Appeals shall be filed in accordance with Chapter 3
of the Santa Ana Municipal Code.
4. Failure to Comply with Hearing Officer’s Determination. Failure to
comply with the Hearing Officer’s determination to discontinue a
nonconforming use or structure shall constitute a violation of this
Chapter and is subject to fines and enforcement provisions of Sec. 1-8
of the SAMC.
5. Failure to Terminate Use at Conclusion of Amortization Period. The
failure to terminate a nonconforming use at the conclusion of an
approved amortization period shall be deemed a public nuisance in
accordance with California Government Code, Section 38771. The City
is hereby authorized to abate the nuisance in accordance with Chapter
17 of this Code or may pursue any alternative remedy to abate the use
authorized by this Code or State law.
d. Additional Administrative Policies and Procedures. The Executive Director
of the Planning and Building Agency, or designee, may enact and shall
publish any additional administrative policies and procedures to effectuate
the purposes of this Chapter, including, but not limited to, administrat ive
policies and procedures to govern the selection of a neutral hearing officer
and the conduct of hearings for the Establishment of Amortization Periods
in order to implement the provisions of this Article.
(7) Abatement. The provisions of this Section are in addition to authority existing
under State law to declare and abate a public nuisance pursuant to California
law and other applicable provisions of the SAMC. In the event that a legal
nonconforming structure or use is found to constitute a public nuisan ce,
appropriate and alternative action may be taken by the City pursuant to Chapter
1 (General Provisions) of the SAMC and Article VIII (Enforcement) of this
Chapter).
(8) Exception. The provisions of this section shall not apply to multifamily dwellings
damaged or destroyed by fire in accordance with Government Code Section
65852.2.
(9) Voluntary Compliance Agreement. The Executive Director of the Planning and
Building Agency, or designee, is hereby authorized to enter into a Voluntary
Compliance Agreement with a business owner or property owner in order to
establish terms for compliance with the provisions of this Article.”
Section 6. Section 41-2004 (The Industrial Overlay I-OZ) Zone) of Chapter 41
of the SAMC is hereby amended to read as follows:
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“Sec. 41-2004 Reserved. The Industrial Overlay (I-OZ) Zone
(a) The Industrial Overlay Zone (I-OZ) is applied to areas zoned M1 or M2 and
occupied with an industrial use at the time of the adoption of this Article. The zoning
for the individual parcels shall be determined by Sectional District Map number 7-
5-9 as it appeared on May 1, 2010.
(b) The I-OZ allows the M1 and M2 regulations to apply to said parcel until such time
as the property owner applies to modify the zoning district. The Regulating Plan
identifies the boundaries of the applicable zoning district (i.e. Transit Village, Urban
Center, Corridor, Urban Neighborhood 1 or Urban Neighborhood 2) within the
Transit Zoning Code.
(c) A property owner may apply to develop the parcel consistent with the applicable
zoning district within the Transit Zoning Code. The applicant shall receive all the
necessary site approvals including, the approval of the overlay zone site plan
pursuant to Article III, Division 28 prior to development.
(d) The uses in the I-OZ shall be subject to the regulations of the M1 and M2 zones
(SAMC 41, Article III, Divisions 18 and 19), as applicable.”
Section 7. Section 41-2005 (Application for Discretionary Approvals) of Chapter
41 of the Santa Ana Municipal Code is hereby amended to read as follows:
“Sec. 41-2005. Application for Discretionary Approvals
(a) Site Plan Review shall mean specific development plan and shall comply with
Sections 41-593.4 through 41-593.6. Sections 41-593.4 through 41-593.6 shall
only apply to structures over four (4) stories in height.
(b) Conditional use permits, variances and minor exceptions. Conditional use permits,
variances and minor exceptions shall be subject to Article V of this Chapter, except
for the permit thresholds for minor exceptions shall be as identified in Table 1B of
this Article.
(c) Effect of amendments to this Article on applications in progress shall apply as
follows:
(1) Discretionary Applications Submitted and Determined Complete. All
discretionary permit applications that are active and that have been determined
to be complete before the effective date of the Article or any amendment, shall
be processed in compliance with the requirements in effect when the
application was deemed complete, and pursuant to all requirements of Sections
41-2008 and 41-2009.
(2) Approved Projects Not Yet Under Construction. Any structure authorized by a
discretionary permit or approval of a land use as allowed by this Article for
which a Building Permit application has been submitted or a Building Permit
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has been issued may be constructed in compliance with the permit or approval,
as long as construction is completed and the approved land use is established
before the expiration of the permit or, where applicable, before the expiration
of any approved time extension.
(3) Project Under Construction. A project for which a Building Permit has been
issued may be continued and completed in compliance with the plans and
specifications upon which the permit was issued.”
Section 8. Section 41-2006 (Zones Established) of Chapter 41 of the Santa Ana
Municipal Code is hereby amended, including the replacement of Figure 2.1, to read as
follows:
“Sec. 41-2006. Zones Established
(a) Purpose. This section establishes the zones app lied to property within the plan
area by the Regulating Plan. The Regulating Plan divides the plan area into
separate zones that are based on a transect of intensity within the plan area that
ranges from the most urban types of development and land use to the least urban
types, with most zones providing for a significant mixture of land uses within them.
This approach differs from conventional zoning maps that typically divide cities into
zones that rigidly segregate residential, commercial, industrial, an d institutional
uses into separate areas, and thereby require residents to drive for nearly all daily
activities. The use of zones based on development intensity (instead of land use
zones) as the spatial basis for regulating development, directly reflects the
functions of, and interrelationships between, each part of the plan area. The zones
also effectively implement the City’s urban design objectives for each part of the
plan area, to establish and maintain attractive distinctions between each zone. This
is why some parcels are zoned with more than one zone. In such cases, the zoning
is divided along a clear boundary such as the middle of a block.
The zones of this Regulating Plan allocate architectural types, frontage types, and
land uses within the plan area, as well as providing detailed standards for building
placement, height and profile. The diagram to the right Figure 2.1 identifies the
eight (8) 9 zones applied within the plan area as they relate to existing rights -of-
way and parcels.
(b) Zones established. The following zones are applicable to this specific plan, and
applied to property within the boundary as shown on the Regulating Plan.
(1) Transit Village (TV) Zone.
The Transit Village zone is intended to provide standards for compact transit -
supportive mixed-use/residential development. This zone is characterized by a
wide range of building intensity, including mixed-use tower-on-podium
buildings, flex blocks, liners, stacked flats, and courtyard housing. The zone
accommodates retail, restaurant, entertainment, and other pedestrian-oriented
uses at street level, with offices and flats above in the mixed -use building types,
at high intensities and densities. The landscape palette is urban, with shading
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and accent street trees in parkway strips along Santa Ana Boulevard, and in
sidewalk tree wells where on-street parking is provided. Parking is
accommodated on-street, in structures with liner buildings, and underground.
(2) Government Center (GC) Zone.
This area accommodates a wide variety of civic uses, including Federal, State,
and local government offices and services, libraries, museums, community
centers, and other civic assembly facilities and is identified, but not regulated,
by this Article. Refer to City requirements as identified in SAMC Chapter 41.
Building types vary according to their public purpose, are programmed by the
various government agencies for their specific sites, and therefore are not
coded by this Article the Transit Zoning Code (SD84A and SD84B). The
landscape style is urban, emphasizing shading street trees in sidewalk tree
wells, and in landscaped public plazas.
(3) Downtown (DT) Zone.
This zone is applied to the historical shopping district of Santa Ana, a vital,
pedestrian-oriented area that is defined by multi-story urban building types (flex
blocks, live-work, stacked dwellings, and courtyard housing in the Downtown
edges) accommodating a mixture of retail, office, light service, and residential
uses. The standards of this zone are intended to reinforce the form and
character represented by pre-World War II buildings and recognized as a
National Historic District, through restoration, rehabilitation, and context-
sensitive infill. The standards also facilitate the replacement or improvement of
post-war development that eliminated the pedestrian orientation of various
downtown blocks (for example, parking structures with no features of
pedestrian interest along their entire lengths). The landscape st yle is urban,
emphasizing shading and accent street trees in sidewalk tree wells. Parking is
accommodated on-street and may also be in structures with liner buildings,
underground, and within block centers in surface lots not visible from streets.
(4) Urban Center (UC) Zone.
This zone is applied to the area surrounding the Downtown, which serves as a
transitional area to the surrounding lower intensity neighborhoods and to other
areas where mixed-use and multi-unit residential buildings create a pedestrian-
oriented urban fabric. The zone provides for a variety of non -residential uses
and a mix of housing types at medium intensities and densities. Besides
accommodating community serving businesses, this zone may also serve the
daily convenience shopping and service needs of nearby residents. Building
types include mixed-use Flex Blocks, stacked flats, live-work, row- houses, and
courtyard housing. The landscape is urban, emphasizing shading street trees
in sidewalk tree wells. Parking is accommodated on -street and may also be in
structures with liner buildings and underground in areas adjacent to the DT
zone, and in surface lots away from street frontages.
(5) Corridor (CDR) Zone.
This zone is applied to properties fronting existing commercial corridors and
provides standards to improve pedestrian-orientation in a transit-supportive,
mixed-use area. Mixed-use flex block and live-work building types are at or
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near the sidewalk, and accommodate street level retail, service, and office
uses, with office and residential above. The landscape style is urban,
emphasizing shading street trees in sidewalk tree wells. Parking is
accommodated on-street, and in screened surface lots between buildings, or
away from streets, with no more than half the site frontage occupied by parking.
(6) Urban Neighborhood 2 (UN-2) Zone.
This zone is applied to primarily residential areas intended to accommodate a
variety of housing types, with some opportunities for live -work, neighborhood-
serving retail, and cafes. Appropriate building types include single dwellings,
duplexes, triplexes and quadplexes, courtyard housing, rowhouses, and live -
work. In some areas, the more intense, hybrid court building type is allowed
where additional intensity is warranted while maintaining compatibility with
neighboring properties (see Regulating Plan). The landscape is appropriate to
a neighborhood, with shading street trees in parkway strips, and shallow- depth
landscaped front yards separating buildings from sidewalks. Parking is on -
street, and in garages located away from street frontages.
(7) Urban Neighborhood 1 (UN-1) Zone.
This zone is applied to existing primarily residential areas and is intended to
strengthen and stabilize the low intensity nature of these neighborhoods.
Appropriate building types include single dwellings, duplexes, triplexes, and
quadplexes, and live-work. The landscape is appropriate to a neighborhood,
with shading street trees in parkway strips and landscaped front yards
separating buildings from sidewalks. Parking is on-street, and in garages
located away from street frontages.
(8) Industrial Overlay (I-OZ) Zone.
The I-OZ is applied to areas currently zoned M1 or M2, and occupied with an
industrial use, to allow the types of land use activity and development permitted
by existing M1 and M2 zoning to continue until such time that the owner
chooses to apply the new zones identified in Figure 2.1. In order to determine
if the M1 or M2 land use activity and development apply to a particular parcel,
the I-OZ is further identified as I-OZ-M1 or I-OZ-M2. Until the property owner
applies to modify the zoning district, property in the I-OZ shall be regulated by
the provisions of the M1 and M2 zones (SAMC 41, Article III, Divisions 18 and
19), as applicable.
(8) (9) Open Space (O) Zone.
This zone identifies areas reserved for community parks and other open spaces
and is identified, but not regulated, by this Article. Refer to City requirements
as identified in SAMC Chapter 41. Allowable structures in this zone are limited
to those necessary to support the specific purposes of the particular open
space area (e.g., sport-court enclosures and multi-purpose buildings in active
parks, and trails within passive parks).”
Figure 2.1 Regulating Plan with Existing R.O.W.
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Figure 2.1 Regulating Plan with Existing R.O.W.
Section 9. Section 41-2007 (Uses Permitted) of Chapter 41 of the Santa Ana
Municipal Code is hereby amended to read as follows:
“Sec. 41-2007. Uses Permitted.
(a) Allowable Land Use Types. A parcel or building within the Specific Development
SD-84 area shall be occupied by only the land uses allowed by the table entitled
Use Standards (hereinafter Use Standards Table) within the zone applied to the
site by the Regulating Plan.
(b) No building shall be erected, constructed, reconstructed or structurally altered
except in conformance with the provisions contained herein; nor shall any building
or land be used for any purpose other than that which is permitted in the district or
modified district in which such building or land is located. All u ses, as defined in
this Article, not expressly permitted in any district enumerated in Table 2A, are
prohibited.
(b) (c) Garage sales are allowed in compliance with Section 41-193.
(c) (d) Temporary outdoor activities are allowed in compliance with Section 41-195.5.
(d) (e) Youth amusement rides are permitted in compliance with Section 41 -366 for C1
districts.
Planning Commission 1 – 30 3/6/2025
Ordinance No. NS-XXX
Page 19 of 49
(e) (f) Drive-through facilities shall not be permitted.
(g) The conversion of existing structures containing residential land uses to non -
residential land uses is prohibited in the UN-1 and UN-2 zones.
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
RESIDENTIAL
Live-Work Use / Joint living-working quarters P (2) P (2) P (2) P (2) CUP CUP
Care Homes CUP CUP CUP CUP CUP CUP
Single Dwelling --- --- --- --- P P
Multi-Family Dwellings P (1) P (1) P (1) P (1) P P
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
RECREATION, EDUCATION AND ASSEMBLY
Community assembly P (1) P (1) P (1) P CUP CUP
Health/fitness facility P P P P CUP ---
Library, museum P P P P P CUP
Schools P (1) P (1) P (1) P CUP CUP
Studio P P P P CUP CUP
Trade School P (1) P (1) P (1) P (1) CUP ---
Theater, cinema or performing arts P P P P CUP ---
Commercial Recreation (Indoor) up to 5,000
square feet maximum floor area per tenant
CUP
P
CUP
P
CUP
P
--- ---
P
---
Commercial Recreation (Indoor) > 5,000
square feet floor area per tenant
CUP CUP CUP --- CUP ---
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
RETAIL
General retail, except with any of the following
features
P P P P P (2) ---
• Floor area over 20,000 per tenant CUP CUP P --- CUP ---
Planning Commission 1 – 31 3/6/2025
Ordinance No. NS-XXX
Page 20 of 49
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
Artisan/craft product – limited on-site
production
CUP CUP CUP --- CUP ---
Eating establishments P P P P P (2) ---
Auto or motor vehicle service --- --- P P --- ---
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
SERVICE GENERAL
Banquet facility/catering-sub. to 41.199.1(a)
through (d)
CUP CUP CUP CUP
(1)
CUP ---
Child day Day care center P (3) P (3) P P CUP CUP
Adult day care center-subject to 41.199.2 of the
SAMC
P (3) P (3) P P P ---
Hotel, excludes transient residential hotel and
long-term stay
P P P P --- ---
Mortuaries, funeral homes --- --- CUP P --- ---
Personal services P P P P P (2) P (2)
Personal services - restricted --- --- CUP CUP CUP ---
Pet day care facility CUP CUP CUP CUP CUP ---
Tattoo/Body Art Establishments - subject to
41.199.3 of the SAMC
P P P P --- ---
Craft and specialized automotive restoration
service
--- P P P CUP ---
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
SERVICES-BUSINESS-FINANCIAL-PROFESSIONAL-TECHNOLOGY
Bank, financial services P P P P --- ---
Business support service P P P P P (2) P (2)
Planning Commission 1 – 32 3/6/2025
Ordinance No. NS-XXX
Page 21 of 49
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
Clinic, urgent care --- --- CUP P --- ---
Doctor, dentist, chiropractor, etc., office P (1) P (1) P (1) P --- ---
Extended Care P P P P CUP ---
Laboratory – medical – analytical --- P (1) P (1) P ---
CUP
---
Media production – office or storefront type (no
soundstage)
P P P (1) --- P ---
Professional / administrative/service office P (1) P (1) P (1) P P (2) P (2)
Research and development P (3) --- P (3) --- CUP ---
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
SMALL SCALE INDUSTRY
Artisan/craft product manufacturing CUP CUP CUP --- CUP ---
Furniture and fixture manufacturing, cabinet
shop
P (3) --- P (3) --- --- ---
Laboratory - medical - analytical --- P (1) P (1) P --- ---
Manufacturing - light P (3) --- P (3) --- CUP ---
Media production - office or storefront type (no
sound stage)
P P P (1) --- --- ---
Printing and publishing --- P (1) P --- --- ---
Research and development P (3) --- P (3) --- CUP ---
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
TRANSPORTATION, COMMUNICATION, INFRASTRUCTURE
Helistops CUP CUP --- --- --- ---
Planning Commission 1 – 33 3/6/2025
Ordinance No. NS-XXX
Page 22 of 49
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
Parking facility - public or commercial, inclusive
of ancillary recharging spaces for electric
vehicles
P P P P --- ---
Transit station or terminal CUP --- --- CUP --- ---
Public utility structure, excluding wireless
communication facilities
--- --- --- --- CUP ---
Table 2A – Use Standards
Land Use Type Permit Required by Zone
TV DT UC CDR UN-2 UN-1
MISCELLANEOUS
Any structure over four (4) stories in height SPR SPR SPR SPR SPR ---
Businesses operating between 12 and 7 am CUP CUP CUP CUP CUP CUP
Alcoholic beverage sales or consumption CUP CUP CUP CUP CUP ---
Expansion of existing, legally established self -
storage facility
--- --- --- --- CUP ---
Drive-thru facility --- --- --- --- --- ---
Section 10. Section 41-2008 (Operational Standards) of Chapter 41 of the Santa
Ana Municipal Code is hereby amended to read as follows:
Planning Commission 1 – 34 3/6/2025
Ordinance No. NS-XXX
Page 23 of 49
“Sec. 41-2008. Operational Standards
(a) All property shall be maintained in a safe, sanitary and attractive condition
including, but not limited to, structures, landscaping, parking areas, walkways, and
trash enclosures.
(b) All business activities shall be conducted and located within an enclosed building,
except as allowed by Section 41-195 of the SAMC and except that the following
business activities may be conducted outside of an enclosed building:
(1) Newsstands
(2) Flower Stands
(c) There shall be no manufacturing, processing, compounding, assembling or
treatment of any material or product., other than that which is clearly incidental to
a particular retail and ser- vice general enterprise, and where such goods are sold
on the premises.
(d) There shall be no work inside of a structure that generates noise that exceeds 60
dB CNEL measured at the exterior wall of the individual tenant unit of a structure.
(e) Storage of goods and supplies shall be limited to those sold at retail on the
premises or utilized in the course of business.
(f) Public utility structures, including electric distribution and transmission substations
shall be screened by a solid wall at least eight (8) feet high, except as restricted by
Sections 36-45, 36-46, and 36-47.
(g) Any activity permitted shall be conducted in such a manner as not to have a
detrimental effect on permitted adjacent uses by reason of refuse matter, noise,
light, or vibration.
(h) Small scale industry Artisan/craft product - limited on site production and research
and development land uses shall require a solid wall or fence not less than eight
(8) feet in height along any rear or side lot line.
(i) All business activities, including, but not limited to, compounding, processing,
packaging or assembly of articles of merchandise and treatment of products shall
be conducted within a completely enclosed building. No ancillary vehicle
maintenance or repair shall be allowed on site.
(j) Loading areas shall not be visible from streets. Loading areas not facing a street
shall be setback at least thirty-five (35) feet from the property line.
(k) No business activity that generates noise or vibration shall be conducted
between 8:00 p.m. and 7:00 a.m. Monday through Friday and 8:00 p.m. and
10:00 a.m. Saturday and Sunday.
Planning Commission 1 – 35 3/6/2025
Ordinance No. NS-XXX
Page 24 of 49
(l) Automobile servicing uses including nonconforming establishments, shall comply
with the following operational standards:
(1) No automobile servicing shall be conducted before 7:00 a.m. or after 8:00 p.m.
Monday through Friday and before 10:00 a.m. or after 8:00 p.m. Saturday and
Sunday. No servicing shall be conducted on Sundays.
(2) All work shall be conducted inside an enclosed structure.
(3) Outdoor or overnight vehicle storage is not permitted.”
Section 11. Section 41-2009 (Operational Standards for Nonconforming
Industrial Uses) of Chapter 41 of the Santa Ana Municipal Code is hereby added in its
entirety to read as follows:
“Sec. 41-2009. Operational Standards for Nonconforming Industrial Uses.
(a) In addition to the operational standards listed in Sec. 41 -2008, the following shall
apply to nonconforming industrial uses:
(1) The purpose of these operational standards is to protect and improve the living
and working environment, the appearance of the community, reduce or
eliminate nuisance conditions, and minimize the impacts of industrial uses on
adjacent properties.
(2) These standards are in addition to the operational standards established in
Sec. 41-2008 and shall apply to all nonco nforming industrial uses, including
those existing industrial uses that become nonconforming at the effective date
of any implementing ordinance.
(3) Land or buildings shall not be used or occupied in a manner creating any
dangerous, injurious, or noxious fire, explosive or other hazard that would
adversely affect the surrounding area.
(4) If any nonconforming use that operates in an unlawful manner, including but
not limited to: frequent code violations, police calls, or loitering complaints
relating to the nonconforming use; or is not in good standing with the City,
including, but not limited to violations of Chapter 16 of the Santa Ana Municipal
Code or public nuisances as defined and addressed by Chapter 17 of the Santa
Ana Municipal Code, or lapses in Business License renewal, will lose its
nonconforming status, enabling the City to take corrective action as it deems
appropriate, including initiating a hearing to consider business license
revocation and/or terminating utility services or connections. For the purposes
of this section, “frequent” is defined as more than one (1) violation, call, or
complaint per month during any twelve (12) month period, and “constant
service calls” is defined as more than one (1) service call per month relating to
or arising from the nonconforming use during any twelve (12) month period
Planning Commission 1 – 36 3/6/2025
Ordinance No. NS-XXX
Page 25 of 49
(b) Enclosed Operations.
(1) All business activities, including, but not limited to, compounding, processing,
packaging, or assembly of articles of merchandise and treatment of products
shall be conducted within a completely enclosed building.
(2) No automobile service or repair of any kind shall be allowed outdoors on site.
(c) Air Emissions and Dust
(1) No land use shall generate or cause any visible dust, gases, or smoke to be
emitted into the atmosphere.
(2) Uses, activities, and processes shall not operate in a manner that emit dust,
fumes, odors, smoke, or particulate matter, unless authorized under Federal,
State, or local law. Sources of air emissions shall comply with all rules
established by the Environmental Protection Agency (Code of Federal
Regulations, Title 40), the California Air Resources Board, and the South Coast
Air Quality Management District.
(d) Light, Glare, and Heat
(1) No direct or indirect glare or heat, whether from floodlight s or from high-
temperature processes (including combustion or welding or otherwise) shall be
visible or felt at the property line.
(2) To ensure that industrial development does not create light and glare
nuisances, the following performance standards shall be observed:
a. Lighting must be shielded, boxed, or directed at a downward angle so as to
minimize the generation of light and glare and to ensure that there is no
spillover of light and glare that will impact drivers or pedestrians on the
public streets, on-site activities, and adjoining or nearby properties.
b. No activity shall be permitted which causes excessive light and glare to be
transmitted or reflected to surrounding properties at a level resulting in
detrimental impacts to adjacent properties as dete rmined by the Executive
Director of the Planning and Building Agency, or designee.
(3) Light sources shall generally not be permitted in landscaped, buffer, or setback
areas except for those illuminating pedestrian walkways. Lighting used to
illuminate parking areas shall be designed, located, and installed to be shielded
and down-lit and to reflect away from any nearby residential areas. Lighting for
advertising signs shall not create glare or light which extends to surrounding
properties.
(4) No use shall be operated such that significant, direct glare, incidental to the
operation of the use, is visible beyond the boundaries of the lot where the use
is located.
Planning Commission 1 – 37 3/6/2025
Ordinance No. NS-XXX
Page 26 of 49
(e) Ground Vibration
(1) No use shall generate ground vibration perceptible without instruments at any
point along the property line of the site except for motor vehicle operations.
(2) No vibration shall be produced that is transmitted through the ground and is
discernible without the aid of instruments by a reasonable person at the
property lines of the site. Vibrations from temporary construction, demolition,
and vehicles that enter and leave the subject parcel are exempt from this
standard.
(f) Storage and Screening
(1) No material or waste shall be deposited upon a subject parcel in such form or
manner that it may be transferred off the parcel by natural causes or forces.
(2) All materials or wastes which might cause fumes or dust, or which constitute a
fire hazard, or which may be edible by or otherwise be attractive to rodents or
insects shall be stored outdoors only in closed containers.
(g) Hazardous Materials
(1) Land or buildings shall not be used or occupied in any manner so as to create
any fire, explosive or other hazard. All activities involving the use or storage of
combustible, explosive, caustic, or otherwise hazardous materials shall comply
with all applicable local, State, and Federal safety standards and shall be
provided with adequate safety devices against the hazard of fire and explosion,
and adequate firefighting and fire suppression equipme nt in compliance with
City of Santa Ana regulations. The burning of waste materials in open fires
without written approval of the Fire Department is prohibited.
(2) No activities shall be permitted which emit dangerous radioactivity at any point
nor shall electrical disturbances which adversely affect the operation of any
equipment, other than that of the creator of such disturbances, be allowed.
(3) No use, activity or process shall cause electromagnetic interference with
normal radio and television reception, or with the function of other electronic
equipment beyond the property line of the site in which it is situated. All uses,
activities and processes shall comply with applicable Federal Communications
Commission regulations.
(h) Liquid and Solid Waste
(1) Liquid or solid wastes discharged from the premises shall be properly treated
prior to discharge so as not to contaminate or pollute any watercourse or
groundwater supply or interfere with bacterial processes in sewage treatment.
Planning Commission 1 – 38 3/6/2025
Ordinance No. NS-XXX
Page 27 of 49
(2) The disposal or dumping of solid wastes, such as slag, paper and fiber wastes,
or other industrial wastes, is prohibited.
(3) Wastes shall be handled and stored so as to prevent nuisances, health, safety,
and fire hazards, and to facilitate recycling subject to the review and oversight
of the Fire Department. Closed containers shall be provided and used for the
storage of any materials which by their nature are combustible, volatile, dust,
or odor producing or edible or attractive to rodents, vermin, or insects.
(i) Site Maintenance. All industrial land uses shall be maintained in compliance with
Chapter 16 of the Santa Ana Municipal Code and not constitute public nuisances
as defined and addressed by Chapter 17 of the Santa Ana Municipal Code at all
times and consistent with project conditions of approval (if applicable).
(j) Truck Parking and Loading
(1) All truck parking areas must be on paved surfaces. The parking, loading or
unloading of trucks associated with a business on public streets is prohibited.
(2) Trucks idling is prohibited.
(3) All truck parking and loading areas shall be maintained in good condition as
determined by the City. Annual inspections may be conducted by the City to
ensure compliance. Any violation or failure to comply with any of the
requirements of this Chapter shall be deemed a nuisance.
(k) Hours of Operation
(1) For non-conforming industrial uses which are directly across a street from or
abutting residential uses or structures, hours of operation shall be limited to
7:00 a.m. to 6:00 p.m., Monday through Friday, and 10:00 a.m. to 6:00 p.m.
Saturday.
(2) No operating hours are permitted on Sundays, or Federal Holidays.”
Section 12. Section 41-2080 (Definitions) of Chapter 41 of the Santa Ana
Municipal Code is hereby amended to read as follows:
“Sec. 41-2080 - Definitions
The words and phrases, shall be construed as defined in this Article, unless from the
context a different meaning is intended or unless a different meaning is specifically
defined and more particularly directed to the use of such words or phrases. The words
used in the present tense include the future tense, and words in the singular number
include the plural number. If any of the definitions in this section conflict with definitio ns
in Chapter 41 of the Santa Ana Municipal Code (SAMC), these definitions shall control
for the purposes of this Article. If any term herein is not defined by this subsection, the
definitions contained within Division 2 (Definitions) of Article I of Chapter 41 of the SAMC
shall apply.
Planning Commission 1 – 39 3/6/2025
Ordinance No. NS-XXX
Page 28 of 49
1. Access (Direct): The physical pedestrian entrance to a unit that is provided directly
from the street or courtyard. Also described as walk-up access.
2. Access (Point): The physical pedestrian entrance to a unit that is provided through
a common space, such as a lobby or corridor that connects directly to the street or
courtyard. Also described as non-walk-up access.
3. Accessory Structure: An accessory structure or building is a detached building or
structure, or part of a building or structure, which is incidental or subordinate to the
main building, structure or use on the same lot or parcel of land, without cooking
facilities (e.g., storage shed, garage, gazebo), and is used exclusively by the
occupant of the main building.
4. Alley: An alley is any public or private thoroughfare for the use of pedestrians or
vehicles, not less than ten (10) feet nor more than thirty (30) feet in width, and is
intended for service and only a secondary means of access to abu tting properties.
5. Arcade: see ‘Frontage Types’
6. Artisan/craft product manufacturing - limited on-site production: The manufacturing
of products primarily by hand by persons trained in an artistic skill, including
ceramics, pottery, glass blowing, or sculptures. A specialized commercial facility
with a retail-facing operation open to the public. Products are typically made by
hand or with a restricted level of automation demonstrating an artistic skill. On -site
production of artisan/craft product activities include design, production,
processing, printing, assembly, treatment, testing, repair, and packaging, as well
as any incidental storage. Typical artisan/craft products include, but are not limited
to, electronics, food products, furniture-making, beverages, leather products,
clocks and watches, jewelry, clothing/apparel, metal work, furniture and fine
woodworking, glass, ceramics, paper and paper products, soaps, perfumes, and
lotions, together with ancillary training and/or educational program activities.
7. Attic: The area found directly below the roof of a building and the ceiling of the top
floor. The attic shall be an uninhabitable area.
8. Automobile repair: Automobile repair is the repair of motor vehicles, including the
repair or replacement of engines and transmissions, body and fender repair, and
the installation of non-factory installed products except those permissible through
automobile servicing as defined herein.
9. Automobile service or Automobile servicing: Automobile service or automobile
servicing is the servicing and minor repair of motor vehicles, including the
replacement of belts, hoses, batteries, tires, shock absorbers, oil and air filters,
chassis lubrication, air conditioning servicing, wheel alignments, replacement of
brake pads, and engine tune-ups.
10. Bank, financial institution: An establishment for the custody, loan, exchange or
issue of money, for the extension of credit, and for facilitating the transmission of
Planning Commission 1 – 40 3/6/2025
Ordinance No. NS-XXX
Page 29 of 49
funds. Excludes check cashers as defined by California Civil Code secti on
1789.31.
11. Basement: That portion of a building between floor and ceiling which is either
totally or partly below grade and in compliance with the definition of basement
established in the California Building Code (CBC).
12. Block: An area of land within a subdivision which area is entirely bounded by
streets, highways or ways, excepts alley and the exterior boundary of the
subdivision.
13. Building Height: The vertical extent of a building measured in stories to the eave
of the highest story, not including a basement or an attic. Height limits do not apply
to masts, belfries, clock towers, steeples, equipment screening, chimney flues, and
similar structures. Building height shall be measured from the average grade of the
fronting thoroughfare curb level.
14. Building Placement: The maximum horizontal envelope available for placing a
building on a lot.
15. Building Type: A structure defined by the combination of configuration and
placement. The building types used in this Article are listed below:
a. Bungalow Court: A configuration of freestanding single units arranged
around a common, shared courtyard that is wholly open to the street. The
individual buildings are arranged next to each other to form the bungalow
court building type.
b. Courtyard Housing: A building type consisting of residences that can be
arranged in four possible configurations: townhouses, townhouses over
flats, flats, and flats over flats. The structures are arranged next to each
other, on one or more courts that are partly or wholly open to the street.
c. Duplex, Triplex, and Quadplex: Multiple dwelling forms that are
architecturally presented as large single-family houses in their typical
neighborhood setting.
d. Flex Block: A building generally of a single massing e lement, designed for
occupancy by retail, service, or office uses on the ground floor, with upper
floors also configured for those uses or for residences.
e. House: A structure occupied by a single household that also accommodates
commercial and office uses as allowed.
f. Hybrid Court: A building that combines the point-access portion of the
stacked dwelling building type (double-loaded corridor element) with the
walk-up portion of the courtyard housing building type.
Planning Commission 1 – 41 3/6/2025
Ordinance No. NS-XXX
Page 30 of 49
g. Lined Block: A building that conceals a public garage or other faceless
building that is designed for occupancy by retail, service, or office uses on
the ground floor, with upper floors also configured for those uses or for
residences.
h. Live/Work: An integrated residence and working space, occupie d and
utilized by a single household in an arrangement of at least 3 such
structures or 1 multiple structure with a least 3 units arranged side by side
along the primary frontage, that has been designed or structurally modified
to accommodate joint residential occupancy and work activity.
i. Rowhouse: An individual structure on a parcel with a private rear yard and
individual garage accessed from an alley. Such structure shall be developed
in an arrangement of at least 3 such structures along the primary fron tage.
Or, a structure of at least 3 attached townhouse unit types arranged side by
side with a private rear yard and individual garage accessed from an alley
along the primary frontage.
j. Stacked Dwellings: A building of single-floor or multi-floor residences of
similar configuration either above or below that are stacked.
k. Tower-on-Podium: A multi-level building organized around a central core
with the first two to five floors expressed as a podium building.
l. Tuck-Under Housing: An individual structure on a parcel with no rear yard,
where its garage is tucked under the rear of the house and accessed from
an alley. Such structure shall be developed with at least four such individual
structures, or a structure of at least four attached townhouse units types
arranged side by side along the primary frontage.
16. Bungalow Court: See 'Building Types'
17. Business support service. Commercial establishment that provides services to
other businesses including maintenance, repair and service, testing, rental, etc.
including the following examples:
a. Computer-related services (rental/repair)
b. Copying and quick printing services
c. Film processing and photofinishing (retail)
d. Graphic design services
e. Mailing and mail box services
f. Security systems services
18. Clinic, Urgent Care: A facility other than a hospital where medical, mental health,
surgical or other personal health services are provided on an outpatient basis,
including incidental medical laboratories. Examples of these uses include:
a. mMedical offices with five or more licensed practitioners or medical
specialties
Planning Commission 1 – 42 3/6/2025
Ordinance No. NS-XXX
Page 31 of 49
b. oOut-patient care facilities, urgent care facilities.
c. Counseling services by other than medical doctors or psychiatrists are
included under "Offices - Professional/Administrative."
19. Community Assembly: Group gatherings conducted indoors such as synagogues,
mosques, temples, churches, community centers, bingo halls, private clubs,
fraternal, philanthropic and charitable organizations and lodges.
20. Commercial Recreation Facility - Indoor: Establishments providing indoor
amusement and entertainment services for a fee or admission charge, including:
a. Bowling alleys, Tossing or Throwing Games, Indoor Sports
b. Coin-operated amusement arcades
c. Electronic game arcades (video games, etc.) Pool, billiards
d. Skating sports (ice, roller, board), Escape Room, Mystery Games
This use does not include adult businesses. Four or more electronic games or coin -
operated amusements in any establishment, or a premises where 50 percent or
more of the floor area is occupied by amusement devices, are considered an
electronic game arcade as described above; three or fewer machines are not
considered a land use separate from the primary use of the site.
Ancillary uses include meeting rooms, snack bars, and equipment rental or sales
are permitted within an indoor recreation facility, provided that their gross floor area
of the ancillary use does not exceed twenty percent (20%). Ancillary uses shall
operate in conjunction with the primary recreation use, and shall maintain the same
or fewer hours of operation.
21. Commercial Frontage: The non-residential frontage of a building. Non-residential
activities subject to city approval are allowed within this space, which must be at
least 25 feet in depth. These spaces are limited to the first floor and as such, have
different building requirements than upper floors (e.g., large storefront windows,
signage, etc.).
22. Courtyard Housing: See 'Building Types'
23. Craft and specialized automotive restoration service: A specialized bus iness or
commercial enterprise occurring inside of a fully-enclosed structure that focuses
on repairing and restoring older cars, often considered "collector cars" as defined
by the State; which includes (1) a vehicle model 35+ years old, (2) a vehicle model
25+ years old with historic plates, or (3) a vehicle model classified as a special
interest vehicle. Such restoration services return these types of vehicles to their
original condition, including mechanical components, bodywork, and interior,
aiming to preserve their historical authenticity and aesthetic appeal. The vehicle
must not be altered from the manufacturer's original specifications or considered
a "kit" car.
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Ordinance No. NS-XXX
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24. Doctor, dentist, chiropractor, etc. office: A facility other than a hospital where
medical, dental, mental health, surgical, and/or other personal health care ser -
vices are provided on an outpatient basis, and that accommodates no more than
four licensed primary practitioners (for example, chiropractors, medical doctors,
psychiatrists, etc., other than nursing staff) within an individual office suite.
25. Duplex, Triplex and Quadplex: See 'Building Types'
26. Dwelling Unit Types:
a. Apartment: A rental version of a Flat, Loft, or Townhouse.
b. Condominium: An ownership version of a Flat, Loft or Townhouse
c. Flat: A single-story unit.
d. Loft: A double-story height unit with a mezzanine.
e. Townhouse: A two to three-story unit.
27. Elevation (Building): The exterior walls of a building. Also referred to as 'Facade'
when the elevation is along a frontage line.
28. Entrance (Main or Primary): The principal point of access of pedestrians to a
building. In the support of pedestrian activity, the main or primary entrance should
be oriented to the frontage rather than to the parking.
Extended Care: Residential facilities providing nursing and health-related care as
a primary use with in-patient beds. Examples of these uses include: board and
care homes; convalescent and rest homes; extended care facilities; and skilled
nursing facilities. Long-term personal care facilities that do not emphasize medical
treatment are included under "Care Homes."
29. Facade: The exterior wall of a building that is set along a frontage line. Facades
support the public realm and are subject to frontage requirements additional to
those required of elevations.
30. Flex Block: See 'Building Types' Forecourt: See ‘Frontage Types’
31. Frontage Line: Those lot lines that coincide with a public street line. One shall be
designated as the Principal Frontage Line. Facades along Frontage Lines define
the public realm and are therefore more highly regulated than the elevations that
coincide with other lot lines. Frontage lines are subject to the urban standards,
architectural standards, signage standards, and subdivision standards.
32. Frontage Type: The architectural element of a building between the public right-
of-way and the private property associated with the building. Frontage Types
combined with the public realm create the perceptible streetscape. The following
frontage types used in this Article are listed below:
a. Arcade: A facade with an attached colonnade, that is covered by upper
stories. This frontage type is ideal for retail use, but only when the sidewalk
is fully absorbed within the arcade so that a pedestrian cannot bypass it.
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For Building Code considerations, this frontage type cannot cover the public
right- of-way.
b. Forecourt: A semi-public exterior space partially within the shopfront, gallery
or arcade frontage that is partially surrounded by a building and also
opening to a thoroughfare forming a court. The court is suitable for gardens,
outdoor dining, vehicular drop-off and utility off-loading.
c. Front yard / Porch: A common frontage type associated with single family
houses, where the facade is set back from the right of way with a front yard.
A porch may also be appended to the facade. A fence or wall at the property
line may be used to define the private space of the yard. The front yard may
also be raised from the sidewalk, creating a small retaining wall at the
property line with entry steps to the yard.
d. Gallery: A colonnade that is attached to storefronts and projects over the
sidewalk.
e. Shopfront: A facade placed at or close to the right-of-way line, with the
entrance at sidewalk grade. This frontage type is conventional for retail
front- age and is commonly equipped with cantilevered shed roof(s) or
awning(s). Recessed storefronts are also acceptable. The absence of a
raised ground floor precludes residential use on the ground floor facing the
street, although such use is appropriate above.
f. Stoop: An elevated entry porch that corresponds directly to the building
entry, with stairs placed close to the frontage line on a building with the
ground story elevated from the sidewalk, securing privacy for the win dows
and front rooms. This type is suitable for ground -floor residential uses with
short set- backs. This type may be interspersed with the shopfront frontage
type. A porch or shed roof may also cover the stoop.
33. Front yard/Porch: See 'Frontage Types'
Furniture and Fixture Manufacturing, cabinet shop: The manufacture or assembly
of high-grade articles of furniture and fixtures calling for fine finish, such as
decorative cabinets, desks and chairs, store fixtures and office equipment. In the
production of such goods, noise above 60 dB CNEL beyond the walls of the
building is prohibited.
34. Gallery: see ‘Frontage Types’
35. General Retail: Stores and shops selling many lines of merchandise. Examples of
these stores and lines of merchandise include:
a. art galleries, retail
b. art supplies, including framing services bicycles
c. books, magazines, and newspapers cameras and photographic supplies
clothing, shoes, and accessories department stores
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d. drug stores and pharmacies dry goods
e. fabrics and sewing supplies
f. florists and houseplant stores with indoor sales only hobby materials
g. furniture and home decor stores
h. hardware and building supply stores
i. jewelry
j. luggage and leather goods
k. musical instruments (small), parts and accessories,
l. Large instruments are under "Furniture, Furnishings, and Appliance Store"
m. orthopedic supplies small wares specialty shops
n. sporting goods and equipment stationery
o. toys and games variety stores
p. videos, DVDs, records, CDs, including rental stores
General retail does not include the following:
a. Adult business as defined in section 41-1701.6 of the SAMC, antique or
collectible stores, furniture, furnishings and appliance stores, medical
marijuana dispensaries or second-hand stores.
b. Sheet metal shops, body-fender works, automobile paint shops, repair
garages, and any activity which includes the processing, treatment,
manufacturing, assembling or compounding of any product, other than that
which is clearly and traditionally incidental and essential to a particular retail
activity.
c. Any use which is more specifically identified as a permitted use or as a use
which may be permitted subject to the issuance of a conditional use permit
or land use certificate in one or more use districts pursuant to this code.
36. Ground Floor/ Footprint: The area resulting from the application of building
placement and open space requirements and as further articulated by particular
building design. In calculating the area, only the conditioned floor space shall be
counted for purposes of calculating allowable upper floor area, the area occupied
by zaguans shall be counted as "ground floor/footprint."
37. Ground Floor Residential: Dwellings with their primary entrance and habitable
space at grade.
38. Health and Fitness: A commercial establishment providing facilities for aerobic
exercises, running and jogging, exercise equipment, game courts, swimming
facilities, and saunas, showers and lockers. Health and fitness facilities may also
provide for instruction programs and classes, such as martial arts, yoga where
lockers and showers are provided.
39. Hotel (land use): A facility offering short-term lodging accommodations, as defined
and regulated by the SAMC, to the general public and which may include additional
facilities and services, such as restaurants, meeting rooms, entertainment,
personal services and recreational facilities. Access to the guest rooms shall be
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through the main lobby of the building. A hotel shall contain more than 5 guest
rooms. A hotel that contains a kitchen as defined by the California Building Code
(CBC) in guest rooms shall be deemed to be a long term stay business hotel as
defined by the SAMC. A hotel that meets the criteria of a transient/residential hotel
as defined by the SAMC, shall be deemed to be a transient/residential hotel .
40. House: See 'Building Types'
41. House Scale: Multi-family building form that is derivative of and compatible with
surrounding single-family houses and that can be applied in 1 to 4 direct-access
assemblies of units to form larger buildings from duplex up to and including
Courtyard Housing.
42. Hybrid Court: See 'Building Types'
43. Laboratory- medical-analytical: A place equipped for experimentation or
observation in a field of study, or devoted to the application of scientific principles
in testing and analysis. Quantities of biological or hazardous materials used in situ,
shall be limited to those quantities established by the fire department
Light Manufacturing: The manufacture or assembly of products from previously
treated material where no impact is created to the adjacent uses and no hazardous
materials are used in the production of such products. The maximum number of
employees shall be 10. Examples of light manufacturing include:
athletic equipment
bakeries
camera, photo equipment
clothing
electronics
musical instruments
optical goods
woodworking (limited)
44. Lined Block: See 'Building Types' Live/Work: See 'Building Types'
45. Lot Width: The frontage of a parcel which is used to identify the parcel for street
address purposes.
46. Media production: An establishment dedicated to the production of visual and
audio mass media, including television, films, videos, video games, mobile
devices, internet and digital interactive media, but excludes magazines,
newspapers, and periodicals.
47. Mixed-Use Building: A structure lawfully containing residential and non -residential
uses.
48. Multi-Family Building: A residential structure lawfully containing two or more
dwelling units.
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49. Net Developable Area: The private area defined by blocks which is not to remain
for public uses such as Plazas, Greens, Squares, Thoroughfares or Streetscapes.
50. Nonconforming Industrial Use: A nonconforming use as defined in Section 41-126
of the SAMC that was established on any parcel or within any building located
within the boundaries of SD-84 established by this Article that is listed in the uses
permitted or uses permitted subject to a conditional use permit of Division 18. M-1
(Light Industrial) or Division 19. M-2 (Heavy Industrial) of this Chapter but that are
no longer permissible through amendment to this Article.
51. Noxious Use: A nonconforming industrial use that is located within one thousand
(1,000) linear feet of a public park, school (K-12) as defined by Section 11362.768
of the Health and Safety Code, or property used or zoned for residential purposes
whose primary business operations involve any two (2) or more of the following:
a. Emitting, generating, or discharging of particulate materials; exhausting
emissions; or handling, storing emitting or discharging regulated
compounds, hazardous materials, chemicals, or substances;
b. Operations that are regulated by and require a permit from a federal, state,
or regional agency;
c. Storing, processing, or disposing of listed or hazardous waste; or
d. Operations that are not contained within a fully enclosed building.
52. A primary use is the principal and dominant activity that the business is devoted
to, distinguishing it from a secondary or ancillary use as defined in Section 41-13.5
of the SAMC.
53. Office: These do not include medical offices (see Clinic, Urgent Care," and "Doctor,
dentist, chiropractor, etc. office.")
a. Service. Establishments providing direct services to consumers. Examples
of these uses include employment agencies, insurance agent offices, real
estate offices, travel agencies, utility company offices, elected official
satellite offices, etc. This use does not include "Bank, Financial S ervices,"
which is separately defined.
b. Administrative. Office-type facilities characterized by high employee
densities, and occupied by businesses engaged in information processing,
and other computer-dependent or telecommunications-based activities.
Examples of these uses include:
c. airline, lodging chain, and rental car company reservation centers, not
including retail travel agencies
d. computer software and hardware design and development consumer credit
reporting
e. data processing services
f. health management organization (HMO) offices where no medical services
are provided
g. insurance claim processing
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h. mail order and electronic commerce transaction processing
telecommunications facility design and management telemarketing
i. Professional. Office-type facilities occupied by businesses that provide
professional services, or are engaged in the production of intellectual
property. Examples of these uses include:
j. accounting, auditing and bookkeeping services advertising agencies
k. attorneys
l. business associations, chambers of commerce commercial art and design
services construction contractors (office facilities only) counseling services
m. court reporting services
n. detective agencies and similar services
o. design services including architecture, engineering, landscape architecture,
urban planning
p. educational, scientific and research organizations financial management
and investment counseling literary and talent agencies
q. management and public relations services media postproduction services
r. news services
s. photographers and photography studios political campaign headquarters
psychologists
t. secretarial, stenographic, word processing, and temporary clerical
employee services
u. security and commodity brokers
v. writers and artists offices
54. Paseo: a public place or path designed for walking; promenade.
55. Pedestrian First: The practice of addressing the needs of people, once out of their
automobiles, through a series of interdependent urban design and streetscape
principles (e.g., wide sidewalks, street trees and shade, on-street parking, outdoor
dining, inviting storefronts, the feeling of being in an ‘outdoor room’, short cross -
walk distances, interconnected and short blocks).
56. Pedestrian Shed: An area defined by the average distance that may be traversed
at an easy pace from its edge to its center in approximately 5 minutes. This
distance is used to determine the size of a neighborhood. This dimension averages
one quarter of a mile or approximately 1,400 feet for generally flat terrain.
57. Personal Services: Establishments providing non-medical services to individuals
as a primary use. Examples of these uses include:
a. barber, nail salons and beauty shops clothing rental
b. dry cleaning pick-up stores with limited equipment home electronics and
small appliance repair locksmiths
c. pet grooming with no boarding shoe repair shops
d. tailors
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e. These uses may also include accessory retail sales of products related to
the services provided.
58. Personal Services - Restricted: Personal services that may tend to have a blighting
and/or deteriorating effect upon surrounding areas and which may need to be
dispersed to minimize their adverse impacts. Examples of these uses include:
a. laundromats (self-service laundries). Laundromats shall comply with the
development and performance standards set forth in Section 41-199.
b. massage establishments (licensed, therapeutic) as defined on Section 41 -
1751 of the SAMC. Massage establishments shall comply with Article XVII.I
of Chapter 41 of the SAMC. Pawnshops.
59. Pet day care facility: Establishment offering daily, without overnight, care to a
customer’s personal canine or feline pets. Grooming and educational training may
be allowed as an ancillary use within the establishment. Does not include
veterinary care or treatment, hospitalizations, or long-term boarding of pets.
60. Planter: The layer of the streetscape which accommodates street trees. Planters
may be continuous or individual according to the Thoroughfare and location within
the neighborhood.
61. Podium: A continuous raised platform supporting a building, or a large block of two
or three stories beneath a multi-layer block of a smaller area.
62. Porch: see ‘Frontage Types’
63. Private Frontage: The privately held layer between the frontage line and the
principal building facade. The structures and landscaping within are held to specific
standards. The variables of Private Frontage are the depth of the setback and the
combination of architectural elements such as fences, stoops, porches and
galleries. These elements inf luence social behavior in the public realm. The
Frontage layer may overlap the public streetscape in the case of awnings,
Galleries and Arcades.
64. Research and Development: A quasi-industrial facility where creative work is
undertaken on a systematic basis in order to increase the stock of knowledge
generally in the fields of medicine, scientific instruments, safety- critical mechanism
or high technology. These facilities may include pilot plant operations as an
ancillary use, which shall not exceed 25 percent of the floor area. A facility
providing full scale production shall be deemed a manufacturing use and shall be
prohibited.
65. Rowhouse: See 'Building Types'
66. Setback: The area of a lot measured from a lot line to a building facade or elevation
that must be maintained clear of permanent structures excepting galleries, fences,
garden walls, arcades, porches, stoops, balconies, bay windows, and terraces
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which are permitted to encroach into the setback subject to the standards
established in Division 3 of this Article.
67. Shared Parking (Park-Once Policy): An accounting for parking spaces that are
avail- able to more than one function. The requirement is based on a range of
parking- demand found in mature, mixed-use centers. The Shared Parking ratio
varies according to multiple functions in close proximity unlikely to require the
spaces at the same time. This approach to parking uses the following types of
parking in combination to achieve a balanced and distributed supply of parking:
off-street (surface lots and garages), on-street (parallel and diagonal).
68. Shopfront: see ‘Frontage Types’
69. Stacked Dwellings: See 'Building Types'
70. Stoop: see ‘Frontage Types’
71. Story: A habitable level within a building from finished floor to finished ceiling: Attics
and basements, as defined by the California Building Code (CBC) are not
considered a story for the purposes of determining building height and are subject
to the applicable requirements of this code and the CBC, except for when the
finished floor level directly above a basement or cellar is more than six feet above
grade, such basement or cellar shall be considered a story
72. Streetscape: The urban element that provides the major part of the public realm
as well as paved lanes for vehicles. A streetscape is endowed with two attributes:
capacity and context. Capacity is the number of vehicles that can move safely
through a segment within a given time period. It is physically manifested by the
number of lanes and their width, and by the curb radius.
73. Studio: A workplace of one or more individuals who are engaged in the production
of art, such as fine and fiber arts, lithography, calligraphy, photography, music,
dance and the performing arts. Galleries, not to exceed 50 percent of the floor
area, are permitted as an ancillary use. Any regulated use, as defined on Sec 41 -
191 of the SAMC is not allowed. Uses meeting the definition of artisan/craft product
manufacturing shall be deemed an artisan/craft product manufacturing use.
74. Tandem Parking Stall: Two or more parking spaces arranged one behind the other.
75. Thoroughfare: A vehicular way incorporating moving lanes and parking lanes
(except alleys/lanes which have no parking lanes) within a right-of-way.
76. Tower-on-Podium: See 'Building Types'
77. Trade school: A school consisting of vocational educational programs for students
to be trained in the fields related to healthcare, technology, legal services, and
professional trades.
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78. Traffic-Calming: A set of techniques which serves to reduce the speed of traffic.
Such strategies include lane-narrowing, on-street parking, chicanes, yield points,
sidewalk bulge-outs, speed bumps, surface variations, mid-block deflections, and
visual clues. Traffic calming is a retrofit technique unnecessary when
thoroughfares are correctly designed for the appropriate speed at initial
construction.
79. Transect: A system of classification deploying the conceptual range of ‘rural-to-
urban’ to arrange in useful order, the typical context groupings of natural and urban
areas. This gradient, when rationalized and subdivided into zones becomes the
basis of the Regulating Plan and the 9 zones supporting this Plan.
80. Transit-Oriented Development: A remedial pattern within a loose urbanized area.
Its structure creates nodes at an efficient spacing for commuter or light rail. These
nodes are mixed-use areas limited in extent by walking distance to the transit stop.
These nodes are usually surrounded by a residential hinterland, structured as
neighborhood T.O.D.’s connected by a feeder bus system.
81. Transition Line: A horizontal line, the full width of a facade expressed by a material
change or by a continuous horizontal articulation such as a cornice or a balcony.
82. Tuck-under Housing: See 'Building Types'
83. Zaguan: A covered pedestrian passage between courts of one to two rooms in
depth and one story in height.”
Section 13. Any section or subsection of this Article, Article XIX (The Transit
Zoning Code, Specific Development No. 84) that is not reprinted or modified by this
ordinance is hereby unamended.
Section 14. Any provision of the Santa Ana Municipal Code (SAMC) or
appendices thereto found inconsistent with the provisions of the Ordinance, only to the
extent of such inconsistencies and no further, are hereby repealed or modified to that
extent necessary to affect the provisions of this Ordinance, inclusive of correc tions for
typographical error, and shall be considered the same as if adopted at the time of this
Ordinance.
Section 15. If any section, subsection, sentence, clause, phrase or portion of this
ordinance is for any reason held to be invalid or unconstitu tional by the decision of any
court of competent jurisdiction, such decision shall not affect the validity of the remaining
portions of this ordinance. The City Council of the City of Santa Ana hereby declares that
it would have adopted this ordinance and each section, subsection, sentence, clause,
phrase or portion thereof irrespective of the fact that any one or more sections,
subsections, sentences, clauses, phrases, or portions be declared invalid or
unconstitutional.
Section 16. This Ordinance shall become effective thirty (30) days after its
adoption. Upon the effective date of this Ordinance, Ordinance Nos. NS-3063 and NS-
3064 shall be automatically repealed and rescinded as of that date.
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Section 17. The Clerk of the Council shall certify the adoption of this ordinance
and shall cause the same to be published as required by law.
ADOPTED this _______ day of ___________, 2025.
________________________________
Valerie Amezcua
Mayor
APPROVED AS TO FORM
Sonia R. Carvalho, City Attorney
By: _________________________
Melissa M. Crosthwaite
Senior Assistant City Attorney
AYES: Councilmembers: __________________________________
NOES: Councilmembers: __________________________________
ABSTAIN: Councilmembers: _________________________________
NOT PRESENT: Councilmembers: _________________________________
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, ____________________, City Clerk, do hereby attest to and certify that the
attached Ordinance No. NS-_______ to be the original ordinance adopted by the
City Council of the City of Santa Ana on ___________________, 2025 and that
said ordinance was published in accordance with the Charter of the City of Santa
Ana.
Date: ______________________ ________________________________
Jennifer L. Hall
City Clerk
City of Santa Ana
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EXHIBIT “A”
A. On April 19, 2022, The City adopted an Amended General Plan. The
Amended General Plan became effective on May 26, 2022 and adopted a
new Land Use Plan for the City and established new land use designations
and policies for development of the City.
B. On April 16, 2024, the City Council passed an Urgency Ordinance to adopt
a 45-day moratorium on the approval, commencement, establishment,
relocation, or expansion of industrial uses within the Transit Zoning
Code/Specific Development (SD) No. 84 Zoning District (Moratorium
Ordinance”). No. NS-3063. The purpose of the moratorium was to
immediately protect the public health, safety, and welfare of residents and
businesses from incompatible industrial uses that cause a significant
pollution burden to adjacent residential neighborhoods within the SD84
Zoning District.
C. On May 7, 2024, the City Council issued and file a Council report to the
public, pursuant to Section 65858(d) of the California Government Code,
describing the City’s measures to alleviate conditions that led to the
adoption of Urgency Interim Ordinance No. NS-3063, on April 16, 2024,
regarding a 45-day moratorium on the approval, commencement,
establishment, relocation, or expansion of industrial uses within Specific
Development No. 84 (the Transit Zoning Code).
D. On May 21, 2024, the City Council adopted an extension of the Moratorium
Ordinance for an additional ten (10) months and fifteen (15) days pursuant
to the California Government Code, Section 65858. The extension was
necessary to allow sufficient time for staff to continue with conduct research
of appropriate regulations, and coordinate with outside regulatory agencies
and City departments to develop appropriate zoning regulation to address
the impacts of industrial development in the SD84 Zoning District.
E. The Planning and Building Agency routinely reviews its ordinances to
incorporate best practices, reflect changes to State law, and address
community needs.
F. In adopting the Moratorium on April 16, 2024, the City Council of the City of
Santa Ana established the following findings, all of which below remain true,
applicable and necessary to support the adoption of Zoning Ordinance
Amendment (ZOA) No. 2024-02 amending certain portions of Chapter 41
(Zoning) of the Santa Ana Municipal Code, Article XIX. The Transit Zoning
Code/Specific Development (SD) No. 84 Zoning District:
1. The Transit Zoning Code (TZC), located in the central core of Santa Ana,
comprises approximately 450 acres, encompasses the Logan, Lacy,
and Downtown neighborhoods, and was adopted by the City Council on
June 7, 2010, and amended on July 16, 2019; and
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2. Upon the initial adoption of the TZC in 2010, the General Plan of the City
of Santa Ana was updated with new land use designations for the areas
covered by the TZC to allow for new, mixed-use residential and
commercial communities; and
3. The goals of the TZC are to provide a transit-supportive, pedestrian-
oriented development framework to support the addition of new, and
enhancement of existing communities through, transit infrastructure; to
preserve and reinforce the existing character and pedestrian nature of
the City by strengthening urban form through improved development
and design standards; to encourage alternative modes of transportation;
to provide zoning for the integration of new infill development into
existing neighborhoods; to provide for a range of housing options; and
to allow for the reuse of existing structures; and
4. Industrial uses were established within the Logan and Lacy
neighborhoods in close proximity to sensitive land uses such as
residences and schools prior to the adoption of the TZC, as far back as
the late 19th century, predating modern zoning practices that take into
account irreconcilable land use conflicts among variegated land uses;
and
5. The TZC provides new mixed-use zoning for properties contained within
its boundary while creating industrial overlay zones allowing properties
being used as industrial uses at the time of its adoption to continue to
be governed by industrial zoning districts until su ch time that properties
were developed or improved to the mixed-use zones allowed by the
TZC; and
6. Senate Bill (SB) 1000 went into effect in 2018, requiring local
governments to identify environmental justice communities, called
“disadvantaged communities”, in their jurisdictions and address
environmental justice in their general plans through facilitating
transparency and public engagement in the planning and decision -
making processes, reducing harmful pollutants and the associated
health risks in disadvantaged communities, and promoting equitable
access to health-inducing benefits such as healthy housing options; and
7. The City of Santa Ana completed a comprehensive update of its General
Plan in April 2022; and
8. The Office of the Attorney General of the State of California was actively
involved in ensuring Santa Ana’s General Plan update complied wit h all
aspects of SB 1000 prior to its adoption; and
9. As required by SB 1000, update of the General Plan and its associated
land use plan identified and addressed long standing environmental
justice issues throughout all its elements, which include 77
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implementation actions aimed at reducing harmful pollutants and
associated health risks in disadvantaged communities; and
10. Numerous policies of the General Plan are inconsistent with the present,
irreconcilable land use pattern of the TZC. Specifically, these policies
include Policy LU-1.1 (Compatible Uses), Policy LU-2.4 (Cost and
Benefit of Development), Policy LU-3.8 (Sensitive Receptors), Policy
LU-3.9 (Noxious, Hazardous, Dangerous, and Polluting Uses), Policy
LU-3.11 (Air Pollution Buffers), Policy LU-4.3 (Sustainable Land Use
Strategies), Policy LU-4.6 (Healthy Living Conditions), Policy CM-3.2
(Healthy Neighborhoods), Policy EP-1.9 (Avoid Conflict of Uses), Policy
EP-3.3 (Mitigate Impacts), Policy CN-1.5 (Sensitive Receptor
Decisions), Policy CM-.2 (Healthy Neighborhoods), and Policy HE -5.5
(Community Development), which are targeted at correcting past land
use planning practices that have placed an unequitable environmental
and health burden on certain neighborhoods now termed disadvantaged
communities; and
11. The industrial overlay zones in the TZC perpetuate past planning
practices of locating industrial uses, or other noxious and unwanted
uses, in close proximity to communities of color; and
12. The Logan neighborhood is the oldest Mexican and Mexican -American
neighborhood in Santa Ana and one of the oldest in Orange County, and
one of the few places where Mexicans and those of Mexican descent
were allowed to buy land due to restrictions and covenants based on
race during the first half of the 20th century; and
13. The construction of Santa Ana (I-5) Freeway through Santa Ana in the
1950s resulted in many families being displaced through the demolition
of single-family homes in the northeastern portion of the Logan
neighborhood; and
14. In the 1970s, a proposed expansion of an arterial highway along Civic
Center Avenue would have demolished a significant portion, if not all, of
the Logan neighborhood; and
15. The Logan and Lacy neighborhoods are within the second and third
highest scored census tracts in Santa Ana, each with a composite score
of 90 percent or greater, ranking in the 90th percentile or greater of
census tracts in the State, and identified as “disadvantaged
communities” by the Office of Environmental Health Hazard Assessment
(OEHHA) in its CalEnviroScreen model; and
16. Assembly Bill (AB) 686 requires local jurisdictions to take deliberate
actions to explicitly address, combat, and relieve disparities to
disadvantaged communities, such as Logan and Lacy neighborhoods,
resulting from past patterns of segregation, disinvestment, and planning
practices; and
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17. The updated land use plan in the Land Use Element of the General Plan
does not designate any properties within the TZC, including the Logan
or Lacy neighborhoods, as industrial; rather, they are designated as
varying intensities of District Center or Urban Neighborhood land use
designations—both of which are inconsistent with industrial uses; and
18. There are pressing and growing code enforcement complaints
stemming from the irreconcilable land use conf licts in the TZC.
Specifically, in the Logan and Lacy neighborhoods, the City’s Code
Enforcement Division has investigated over 35 commercial and
industrial properties in the past twelve months and currently has 16
active open cases that have been issued Notice of Violations and
administrative citations for the following types of violations: illegal
storage, land use, zoning, property and landscape maintenance,
unpermitted work, business license, and certificate of occupancy. The
close proximity of active open industrial cases during a short period of
time is creating a public nuisance that is draining City resources and that
is harming public health, safety, and general welfare of the TZC’s
existing and new residential neighborhoods from the concentration of
open code enforcement cases nearby; and
19. In the Logan neighborhood, 52 industrial facilities (automotive,
warehouse/storage, crematory, towing yards, construction) are
presently near sensitive uses monitored by external regulatory agencies
such as South Coast AQMD, Orange County Health Care Agency –
Certified Unified Program Agencies (OC CUPA), Santa Ana Regional
Water Quality Board (SARWQB), Orange County Fire Authority.
Industrial facilities have caused significant pollution exposure to
disadvantaged communities, including lead risk in soil and housing,
diesel particulate matter from idling trucks, toxic release from facilities,
traffic impacts, noise pollution, and airborne particulate matter or fine
inhalable particles of 2.5 (PM2.5) microns or less in diameter.
CalEnviroScreen reports higher environmental effects from active facility
cleanup sites, hazardous waste facilities, and solid waste locations.
Cumulative health impacts in the area include asthma, cardiovascular
disease, and low birth weight, in this overburdened disadvantaged
community factored by socioeconomic indicators of poverty, linguistic
isolation, housing burden, and education; and
20. In the Lacy neighborhood, 76 industrial facilities (automotive,
warehouse/storage, towing yards, construction) are presently near
sensitive uses monitored by external regulatory agencies such as South
Coast AQMD, Orange County Health Care Agency – Certified Unified
Program Agencies (OC CUPA), Santa Ana Regional Water Quality
Board (SARWQB), Orange County Fire Authority. Industrial facilities
have caused significant pollution onto disadvantaged communities,
including lead risk exposure, diesel particulate matter from idling trucks,
toxic release from facilities, traffic impacts, noise pollution, vibration
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impacts, and airborne particulate matter or fine inhalable particles of 2.5
(PM2.5) microns or less in diameter. CalEnviroScreen reports higher
environmental effects from active facility cleanup sites, hazardous waste
facilities, and solid waste locations. Cumulative health impacts in the
area include asthma, cardiovascular disease, and low birth weight, in
this overburdened disadvantaged community factored b y
socioeconomic indicators of poverty, linguistic isolation, housing burden,
and education; and
21. There is a recent surge in residential development activity in the TZC
that is exacerbating the irreconcilable land use conflicts between
residential and industrial land uses. Examples include the Lacy Crossing
residential development with over 100 ownership units directly adjacent
to existing industrial land uses, for which the City receives regular
complaints from residential occupants of disturbances from noise,
vibrations, odors, and truck traffic; and the Rafferty mixed-use
development with 218 residential units, including 11 onsite units for very-
low income households, which is located less than one-fifth of a mile
from industrial land uses; and
22. There is a marked increase in the pending and active development
applications for industrial land uses in the TZC, including for contractor’s
yards, construction debris storage yards, manufacturing operations,
expansion of existing industrial businesses, and st orage and
warehousing operations, stemming from shifting economic demands for
goods and services emerging from the Covid-19 pandemic; and
23. The City Council approved a contract with Moore, Iacofano, Goltsman,
Inc. (MIG) on October 17, 2023 to ensure the City’s Zoning Code and
General Plan are consistent, and to maintain compliance with state law,
comprehensive amendments to the Zoning Code are required; and
24. MIG and City staff have conducted extensive community outreach,
stakeholder interviews, and reviews of existing zoning-related codes
and policies in Santa Ana. These early efforts have indicated that the
irreconcilable land use conflicts and land use inconsistencies in the TZC
area are among the most pressing topics that must be addressed as part
of the comprehensive Zoning Code Update process to protect the
health, safety, and welfare of the most vulnerable communities that face
the impacts of the land use conflicts within the TZC area. Since adoption
of the moratorium and its extension, MIG and City staff have focused the
comprehensive update through an initial phase concentrating on
amending the TZC; and
25. The policies and implementation actions in the General Plan also require
review, study, and possible revision to respond to recent concerns
relating to the impacts of these industrial business uses in the TZC; and
Planning Commission 1 – 58 3/6/2025
Ordinance No. NS-XXX
Page 47 of 49
26. Given these concerns, the City Council directed that a study be
undertaken of the current provisions of the TZC to address industrial
business uses and determine whether such uses should be permitted in
the zoning district, and if not, proceed with an ordinance amendment to
preclude such uses from the district.
G. Following said analysis of the City Council points of discussion as iterated
above, City staff has prepared ZOA No. 2024-02 to amend and add certain
sections to Chapter 41 (Zoning) of the Santa Ana Municipal Code (SAMC),
Article XIX. The Transit Zoning Code/Specific Development (SD) No. 84
Zoning District, including the deletion of industrial land uses; amend non -
conforming regulations including the addition of an amortization process;
amend and add operational standards for allowed uses and non -conforming
uses; and delete the Industrial Overlay (I-OZ) zone from text and maps from
certain properties within the SD84 Zoning District.
H. Amendments to Chapter 41 (Zoning) are necessary to ensure uniform and
legally consistent regulations as well as additions to enable the City to
implement a regulatory framework that protects the health, safety, and
welfare of the City.
I. The proposed amendments to the Santa Ana Municipal Code (SAMC) that
are the subject of this Ordinance support the objectives and policies of the
City’s General Plan and are required to ensure consistency in accordance
with Government Code Section 65860.
J. Specifically, these amendments to the SAMC timely address current
inconsistencies within an area of the City prioritized for addressing EJ. In
effect, the amendments are necessary to address numerous policies of the
General Plan that the current TZC is found to be incon sistent with, that
without such amendments, will continue the path of irreconcilable land use
patterns within the TZC. Specifically, these policies include Policy LU -1.1
(Compatible Uses), Policy LU-2.4 (Cost and Benefit of Development), Policy
LU-3.8 (Sensitive Receptors), Policy LU-3.9 (Noxious, Hazardous,
Dangerous, and Polluting Uses), Policy LU-3.11 (Air Pollution Buffers),
Policy LU-4.3 (Sustainable Land Use Strategies), Policy LU-4.6 (Healthy
Living Conditions), Policy CM-3.2 (Healthy Neighborhoods), Policy EP-1.9
(Avoid Conflict of Uses), Policy EP-3.3 (Mitigate Impacts), Policy CN-1.5
(Sensitive Receptor Decisions), Policy CM-3.2 (Healthy Neighborhoods),
and Policy HE-5.5 (Community Development), which are targeted at
correcting past land use planning practices that have placed an unequitable
environmental and health burden on certain neighborhoods now termed
disadvantaged communities. The proposed amendments support these
goals and policies by:
1. Fostering the compatibility between residential and nonresidential land
uses within the TZC to enhance livability and promote healthier
lifestyles, and improve public health and quality of life;
Planning Commission 1 – 59 3/6/2025
Ordinance No. NS-XXX
Page 48 of 49
2. Resolving the development of industrial land uses and sensitive
receptors being in close proximity to each other that pose health hazards
by eliminating an overlay zone that promulgated continuation of
industrial uses without recourse;
3. Improving the health of the existing and future residents of the TZC by
regulating the operations of noxious, hazardous, dangerous, and
polluting uses by giving priority to the discontinuance or elimination of
those uses;
4. Responding to overarching EJ policies to develop and implement land
use and zoning strategies to separate existing sensitive uses from heavy
industrial facilities and emission sources;
5. Continuing to support the creation of healthy neighborhoods by
addressing land use conflicts and incompatible uses through the
elimination of the I-OZ zone and associated industrial land use types
from the list of allowable land uses within the TZC;
6. Developing and adopting new regulations to address facilities that emit
pollution near sensitive receptors within EJ area boundaries, which
includes areas of the TZC;
7. Avoiding potential land use conflicts in the future by prohibiting the
location of noxious land uses in proximity to sensitive receptors; and
8. Creating a sustainable land use plan for the area that phases out land
uses that are causing a substantial drain on City and other public agency
resources in addressing the impacts from irreconcilable land use
conflicts in the TZC area.
K. Additionally, the proposed amendments implement and/or contribute to
achieving the following specific action programs of the General Plan, most
particularly directly addressing LU3.3 through the creation of a
discontinuance of nonconforming industrial uses through amortization:
1. LU1.1 - Development Code Update. Prepare a comprehensive update
to the zoning code to ensure that the City’s zoning regulations align with
the General Plan’s goals and policies.
2. LU3.3 - Healthy lifestyles. Collaborate with residents and industry
stakeholders to create a program to incentivize and amortize the
removal of existing heavy industrial uses adjacent to sensitive uses.
3. CN1.4 - Health risk criteria. Establish criteria for requiring health risk
assessments for existing and new industries, including the type of
business, thresholds, and scope of assessment. Review existing and
establish new regulation to reduce and avoid increased pollution near
sensitive receptors within environmental justice area boundaries.
Planning Commission 1 – 60 3/6/2025
Ordinance No. NS-XXX
Page 49 of 49
4. CN1.7 - Truck idling. Evaluate strategies to reduce truck idling found or
reported in areas with sensitive receptors, with a priority placed on
environmental justice areas.
5. CN1.11 - Public education. Augment existing outreach programs to
improve public awareness of State, regional and local agencies’ roles
and resources to identify, monitor, and address air quality and other
environmental hazards in the community.
6. HE5.C – Healthy Neighborhoods Initiatives. Update the City’s zoning
code development and operational standards for industrial zones to
address incompatibility with adjacent uses, including minimum distance
requirements to buffer heavy industrial uses from sensitive receptors.
Conduct a study to evaluate and establish appropriate minimum
distances and landscape buffers between polluting industrial uses from
sensitive receptors such as residences.
7. HE44.A – Fair Housing. Ensure all City programs and activities related
to housing and community development are administered in a manner
that affirmatively furthers fair housing.
L. ZOA No. 2024-02 amends and adds certain sections to Chapter 41 (Zoning)
of the Santa Ana Municipal Code (SAMC), Article XIX. The Transit Zoning
Code/Specific Development (SD) No. 84 Zoning District, including Section
41-2001 (Application of Article), Section 41-2001.5 (Organization), Section
41-2002 (Nonconforming Buildings, Structures and Uses), Section 41-2004
(The Industrial Overlay (I-OZ) Zone), Section 41-2005 (Application for
Discretionary Approvals), Section 41-2006 (Zones Established), Section
41-2007 (Uses Permitted) Section 41-2008 (Operational Standards),
Section 41-2009 (Operational Standards for Nonconforming Industrial
Uses), and Section 41-2080 (Definitions).
M. On February 24, 2025, the Planning Commission held a duly noticed public
hearing to consider this Ordinance, where all interested persons were given
an opportunity to be heard, and recommended approval of the Ordinance
to the City Council.
N. On March 18, 2025, the City Council held a duly noticed public hearing to
consider this Ordinance, where all interested persons were given an
opportunity to be heard.
Planning Commission 1 – 61 3/6/2025
Ordinance No. NS-XXX
Page 1 of 7
ORDINANCE NO. NS-XXXX
AMENDMENT APPLICATION (AA) NO. 2024-03 – AN
ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA AMENDING THE OFFICIAL ZONING MAP OF
THE CITY OF SANTA ANA BY REMOVING THE M1
(LIGHT INDUSTRIAL) AND M2 (HEAVY INDUSTRIAL)
SUFFIXES FROM CERTAIN PROPERTIES WITHIN THE
SD-84 ZONING DISTRICT BOUNDARY
THE CITY COUNCIL OF THE CITY OF SANTA ANA HEREBY ORDAINS AS
FOLLOWS:
Section 1. The City Council has, by separate action taken on March 18, 2025,
adopted an Addendum to the Transit Zoning Code Environmental Impact report (“EIR”)
(State Clearinghouse No. 2006071100), which was certified on June 7, 2010, by the
City Council (“Addendum”). The Addendum analyzed the environmental impacts of the
actions taken in this Ordinance. Adopting the Adden dum satisfied the City Council’s
obligations under the California Environmental Quality Act (“CEQA”) regarding
amendments to the Transit Zoning Code and none of the conditions in Public
Resources Code section 21166 or State CEQA Guidelines 15162 apply. Thu s, no
further environmental review is required as adoption of this Ordinance falls within the
scope of the adopted Addendum and previously certified EIR.
Section 2.
The City Council of the City of Santa Ana hereby finds, determines, and declares
as follows:
A.Chapter 41, Article I, Division 1, Section 41-1 of the Santa Ana Municipal
Code provides that
“Because of the necessity of segregating the location of residences,
businesses, trades and industries; regulating the use of buildings,
structures, and land; and regulating the location, height, bulk and size of
buildings and structures, the size of yards and open spaces, the City is
divided into land-use districts of such number, shape and area as may be
considered best suited to carry out these regulatio ns and provide for their
enforcement. The regulations are considered necessary in order to:
(a)Encourage the most appropriate use of land;
(b)Conserve and stabilize property value,
(c)Provide adequate open spaces for light and air and to prevent and
fight fires,
(d)Prevent undue concentration of population, lessen congestion on
streets and highways, and
Exhibit 4: Ordinance for Amendment Application (AA) No. 2024-03
___________________________________________________________________________
Planning Commission 1 – 62 3/6/2025
Ordinance No. NS-XXX
Page 2 of 7
(e) Promote the health, safety and general welfare of the people, all as
part of the general plan of the City.”
Consistent with this purpose, the City of Santa Ana has adopted a
zoning map, which has since been amended from time to time.
B. On April 19, 2022, the City adopted an Amended General Plan The
Amended General Plan became effective on May 26, 2022 and adopted a
new Land Use Plan for the City and established new lan d use
designations and policies for development of the City.
C. On April 16, 2024, the City Council passed an Urgency Ordinance to
adopt a 45-day moratorium on the approval, commencement,
establishment, relocation, or expansion of industrial uses within the T ransit
Zoning Code/Specific Development (SD) No. 84 Zoning District (the
“Moratorium Ordinance”). The purpose of the Moratorium Ordinance was
to immediately protect the public health, safety, and welfare of residents
and businesses from incompatible industrial uses that cause a significant
pollution burden to adjacent residential neighborhoods within the SD -84
Zoning District.
D. On May 7, 2024, the City Council issued and file a Council report to the
public, pursuant to Section 65858(d) of the California Government Code,
describing the City’s measures to alleviate conditions that led to the
adoption of Urgency Interim Ordinance No. NS-3063, on April 16, 2024,
regarding a 45-day moratorium on the approval, commencement,
establishment, relocation, or expansion of industrial uses within the Transit
Zoning Code Specific Development No. 84.
E. On May 21, 2024, the City Council adopted an extension of the
Moratorium Ordinance for an additional ten (10) months and fifteen (15)
days pursuant to California Government Code , Section 65858. The
extension was necessary to allow sufficient time for staff to continue with
conduct research of appropriate regulations, and coordinate with outside
regulatory agencies and City departments to develop appropriate zoning
regulation to address the impacts of industrial development in the SD -84
Zoning District.
F. After continued research and study, two ordinances have been developed
that address the impacts from industrial land uses in the SD -84 Zoning
District. The ordinances address the following:
a. Zoning Ordinance Amendment (ZOA) No. 2024-02 to amend certain
provisions of the Santa Ana Municipal Code and amend portions of the
Transit Zoning Code/Specific Development (SD) No. 84 Zoning District,
including the deletion of industrial land uses; amendment of non-
conforming regulations; and,
b. Amendment Application (AA) No. 2024-03 to remove the M1 (Light
Industrial) and M2 (Heavy Industrial) suffixes from certain properties
Planning Commission 1 – 63 3/6/2025
Ordinance No. NS-XXX
Page 3 of 7
within the SD-84 Zoning District boundary as designated on the City of
Santa Ana Zoning Map.
G. AA No. 2024-03 is consistent with and implements the amendments
proposed by ZOA No. 2024-02 by ensuring uniform and legally consistent
mapping of the City’s Zoning Districts; and enables the City to implement
a regulatory framework that protects the health, safety, and welfare of the
City and its residents.
H. The proposed amendments to the Zoning Map contained in AA No. 2024 -
03 are required to ensure consistency with the City’s General Plan in
accordance with California Government Code, Section 65860.
I. Adoption of AA No. 20243 is consistent with and implements the Amended
General Plan. Specifically, it is consistent with the following:
The amendments timely address current inconsistencies within an area of
the City prioritized for addressing EJ.
(a) Policy LU-1.1 (Compatible Uses),
(b) Policy LU-2.4 (Cost and Benefit of Development)
(c) Policy LU-3.8 (Sensitive Receptors),
(d) Policy LU-3.9 (Noxious, Hazardous, Dangerous, and Polluting
Uses),
(e) Policy LU-3.11 (Air Pollution Buffers),
(f) Policy LU-4.3 (Sustainable Land Use Strategies),
(g) Policy LU-4.6 (Healthy Living Conditions),
(h) Policy CM-3.2 (Healthy Neighborhoods),
(i) Policy EP-1.9 (Avoid Conflict of Uses),
(j) Policy EP-3.3 (Mitigate Impacts);
(k) Policy CN-1.5 (Sensitive Receptor Decisions),
(l) Policy CM-3.2 (Healthy Neighborhoods), and
(m) Policy HE-5.5 (Community Development) which are targeted at
correcting past land use planning practices that have placed an
unequitable environmental and health burden on certain
neighborhoods now termed disadvantaged communities. The
proposed amendments support these goals and policies by:
1. Fostering the compatibility between residential and nonresidential land
uses within the TZC to enhance livability and promote healthier
lifestyles, and improve public health and quality of life;
2. Resolving the development of industrial land uses and sensitive
receptors being in close proximity to each other that pose health
hazards by eliminating an overlay zone that promulgated continuation
of industrial uses without recourse;
3. Improving the health of the existing and future residents of the TZC by
regulating the operations of noxious, hazardous, dangerous, and
polluting uses by giving priority to the discontinuance of those uses;
Planning Commission 1 – 64 3/6/2025
Ordinance No. NS-XXX
Page 4 of 7
4. Responding to overarching EJ policies to develop and implement land
use and zoning strategies to separate existing sensitive uses from
heavy industrial facilities and emission sources;
5. Continuing to support the creation of healthy neighborhoods by
addressing land use conflicts and incompatible uses through the
elimination of the I-OZ zone and associated industrial land use types
from the list of allowable land uses within the TZC;
6. Developing and adopting new regulations to address facilities that emit
increased pollution new sensitive receptors within EJ area boundaries,
which includes areas of the TZC;
7. Avoiding potential land use conflicts in the future by prohibiting the
location of noxious land uses in proximity to sensitive receptors; and
8. Creating a sustainable land use plan for the area that phases out land
uses that are causing a substantial drain on City and other public
agency resources in addressing the impacts from irreconcilable land
use conflicts in the TZC area.
J. Additionally, AA No. 2024-03 implements and/or contributes to achieving
the following specific action programs of the General Plan, most
particularly directly addressing LU3.3 through the creation of a
discontinuance of nonconforming industrial uses through amortization:
1. LU1.1 - Development Code Update. Prepare a comprehensive update
to the zoning code to ensure that the City’s zoning regulations align
with the General Plan’s goals and policies. Update the Metro East
Mixed-Use Overlay District to remove the portion within the 17th Street
and Grand Avenue Focus Area. Update the Midtown Specific Plan.
2. LU3.3 - Healthy lifestyles. Collaborate with residents and industry
stakeholders to create a program to incentivize and amortize the
removal of existing heavy industrial uses adjacent to sensitive uses.
3. CN1.4 - Health risk criteria. Establish criteria for requiring health risk
assessments for existing and new industries, including the type of
business, thresholds, and scope of assessment. Review existing and
establish new regulation to reduce and avoid increased pollution near
sensitive receptors within environmental justice area boundaries.
4. CN1.7 - Truck idling. Evaluate strategies to reduce truck idling found or
reported in areas with sensitive receptors, with a priority placed on
environmental justice areas.
5. CN1.11 - Public education. Augment existing outreach programs to
improve public awareness of State, regional and local agencies’ roles
and resources to identify, monitor, and address air quality and other
environmental hazards in the community.
Planning Commission 1 – 65 3/6/2025
Ordinance No. NS-XXX
Page 5 of 7
6. HE5.C - Healthy Neighborhoods Initiatives. Update the City’s zoning
code development and operational standards for industrial zones to
address incompatibility with adjacent uses, including minimum distance
requirements to buffer heavy industrial uses from sensitive receptors.
Conduct a study to evaluate and establish appropriate minimum
distances and landscape buffers between polluting industrial uses from
sensitive receptors such as residences.
7. HE44.A - Fair Housing. Ensure all City programs and activities relating
to housing and community development are administered in a manner
that affirmatively furthers fair housing.
Section 3. The City Council of the City of Santa Ana hereby adopts and
approves the Amendment to the Official Zoning Map of the City of Santa Ana, as shown
in Exhibit “A,” attached hereto and incorporated herein by reference. This decision is
based upon the evidence submitted at the above said hearing, which includes, but is not
limited to: the Request for City Council Action dated March 18, 2025, and exhibits
attached hereto; and the public testimony, written and oral, all of which are incorporated
herein by this reference.
Section 4. If any section, subsection, sentence, clause, phrase or portion of this
ordinance is for any reason held to be invalid or unconstituti onal by the decision of any
court of competent jurisdiction, such decision shall not affect the validity of the
remaining portions of this ordinance. The City Council of the City of Santa Ana hereby
declares that it would have adopted this ordinance and e ach section, subsection,
sentence, clause, phrase or portion thereof irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases, or portions be declared invalid or
unconstitutional.
Section 5. This Ordinance shall become effective thirty (30) days after its
adoption.
Section 6. The Clerk of the Council shall certify the adoption of this ordinance
and shall cause the same to be published as required by law.
ADOPTED this _______ day of ___________, 2025.
________________________________
Valerie Amezcua
Mayor
Planning Commission 1 – 66 3/6/2025
Ordinance No. NS-XXX
Page 6 of 7
APPROVED AS TO FORM
Sonia R. Carvalho, City Attorney
By: _________________________
Melissa Crosthwaite
Senior Assistant City Attorney
AYES: Councilmembers: __________________________________
NOES: Councilmembers: __________________________________
ABSTAIN: Councilmembers: _________________________________
NOT PRESENT: Councilmembers: _________________________________
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, ____________________, City Clerk, do hereby attest to and certify that the
attached Ordinance No. NS-_______ to be the original ordinance adopted by the
City Council of the City of Santa Ana on ___________________, 2024 and that
said ordinance was published in accordance with the Charter of the City of Santa
Ana.
Date: ______________________ ________________________________
Jennifer L. Hall
City Clerk
City of Santa Ana
Planning Commission 1 – 67 3/6/2025
Ordinance No. NS-XXX
Page 7 of 7
Exhibit A
Planning Commission 1 – 68 3/6/2025
RESOLUTION NO. 2025-___
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SANTA
ANA TO MAKE FINDINGS PURSUANT TO PUBLIC RESOURCES
CODE SECTION 21166 AND TO ADOPT THE ADDENDUM TO
THE TRANSIT ZONING CODE ENVIRONMENTAL IMPACT
REPORT (STATE CLEARINGHOUSE NUMBER NO. 2006071100)
WHEREAS , at a duly noticed public hearing held on June 7, 2010, the City
Council of the City of Santa Ana (“City Council”) adopted findings and a Statement of
Overriding Considerations and certified the Transit Zoning Code Environmental Impact
Report (State Clearinghouse No. 2006071100, “Transit Zoning Code EIR”), pursuant to
the California Environmental Quality Act (Public Resources Code, §§ 21000, et seq.,
“CEQA”), the regulations promulgated thereunder (14 Cal. Code of Regulations,
§§15000, et seq., “CEQA Guidelines”) and adopted the City of Santa Ana’s Transit
Zoning Code (“Transit Zoning Code”), which is designed to provide the zoning
necessary to support the long-term development of a successful transit program; and
WHEREAS, after continued research and study, two ordinances have been
developed that address the impacts from industrial land uses in the Specific
Development No. 84 (SD-84) Zoning District, also known as the Transit Zoning Code:
(1) Zoning Ordinance Amendment (ZOA) No. 2024-02 to amend certain provisions of
the Santa Ana Municipal Code and amend portions of the Transit Zoning Code, including
the deletion of industrial land uses; amendment of non -conforming regulations; and (2)
Amendment Application (AA) No. 2024-03 to remove the M1 (Light Industrial) and M2
(Heavy Industrial) suffixes from certain properties within the SD-84 Zoning District
boundary as designated on the City of Santa Ana Zoning Map; and
WHEREAS, pursuant to CEQA, when taking subsequent discretionary actions in
furtherance of a project for which an EIR has been certified, the lead agency is required
to review any changed circumstances to determine whether any of the circumstances
under Public Resources Code section 21166 and CEQA Guidelines section 15162
require additional environmental review; and
WHEREAS, the City has evaluated the proposed ordinances to the Transit
Zoning Code in light of the standards for subsequent environmental review outlined in
Public Resources Code section 21166 and CEQA Guidelines section 15162, and
concluded that the proposed changes would not result in new significant environmental
effects or a substantial increase in the severity of previously identified significant effects
that were previously disclosed in the Transit Zoning Code EIR, and therefore no
subsequent EIR or mitigated negative declaration is required; and
WHEREAS, the proposed changes would nonetheless necessitate minor
changes or additions to the Transit Zoning Code EIR and, thus, the City has prepared
an Addendum for the Transit Zoning Code EIR (“Addendum”), attached as Exhibit 1,
pursuant to State CEQA Guidelines section 15164 to address the proposed ordinances;
and
Exhibit 5: Resolution of the City Council and Addendum to TZC EIR
_____________________________________________________________________
Planning Commission 1 – 69 3/6/2025
WHEREAS, the Addendum was prepared in full compliance with CEQA, CEQA
Guidelines, and the City’s Local CEQA Guidelines; and
WHEREAS CEQA Guidelines Section 15164, subdivision (c) does not require
the Addendum to be circulated for public review but can be included in or attached to a
final EIR or adopted negative declaration; and
WHEREAS, under CEQA and the CEQA Guidelines and as referenced below,
the "project" shall mean the proposed ordinances under the Transit Zoning Code
including implementation of these ordinances; and
WHEREAS, on February 24, 2025, the Planning Commission held a duly noticed
public hearing to consider these proposed ordinances, where all interested persons
were given an opportunity to be heard, and recommended approval of the ordinances
to the City Council;
WHEREAS, on March 18, 2025, the City Council held a duly noticed publi c
hearing to consider these proposed ordinances, where all interested persons were given
an opportunity to be heard; and
WHEREAS the City Council considered the entire administrative record,
including the staff report (and all attachments thereto), the Transit Zoning Code EIR and
Addendum, and oral and written testimony from interested persons;
NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Santa
Ana as follows:
Section 1. The above recitals are true and incorporated herein by reference.
Section 2. CEQA Guidelines Section 15164 requires lead agencies to prepare
an addendum to a previously certified EIR if some changes or additions to the project
are necessary, but none of the conditions requiring preparation of a subsequent EIR are
present. The City Council has reviewed and considered the administrative record,
including but not limited to the Transit Zoning Code EIR and the Addendum, which are
all incorporated by reference as though set forth fully herein, and finds that those
documents taken together contain a complete and accurate reporting of all the
environmental impacts associated with the Transit Zoning Code. The City Council
further finds that the Addendum and the administrative record have been completed in
compliance with CEQA, the CEQA Guidelines, and the City’s Local CEQA Guidelines.
The City Council finds and determines that the Addendum reflects the City’s
independent judgment.
The City Council finds that the foregoing is supported by substantial evidence in
the record.
Furthermore, when taking subsequent discretionary actions in furtherance of a
project for which an EIR has been certified, the City is required to review any changed
Planning Commission 1 – 70 3/6/2025
circumstances under Public Resources Code Section 21166 and CEQA Guidelines
Section 15162 to determine whether additional environmental review is required. Based
on the substantial evidence set forth in the administrative record, including but not limited
to the Transit Zoning Code EIR and the Addendum, the City Council finds that none of
the conditions under CEQA Guidelines Section 15162 requiring subsequent
environmental review have occurred because the proposed ordinances:
a) do not constitute substantial changes that would require major revisions to
the Transit Zoning Code EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously
identified effects; and
b) do not constitute substantial changes with respect to the circumstances under
which the project was developed that would require major revisions of the
Transit Zoning Code EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of the
previously identified significant effects; and
c) do not present new information of substantial importan ce that was not known
and could not have been known with the exercise of reasonable diligence at
the time the Transit Zoning Code was certified, showing any of the following:
(i) that the project would have one or more significant effects not discussed in
the earlier environmental documentation; (ii) that significant effects previously
examined would be substantially more severe than shown in the earlier
environmental documentation; (iii) that mitigation measures or alternatives
previously found not to be feasible would in fact be feasible and would
substantially reduce one or more significant effects, but the applicant declined
to adopt such measures; or (iv) that mitigation measures or alternatives
considerably different from those previously analyzed woul d substantially
reduce one or more significant effects on the environment, but which the
applicant declined to adopt.
Pursuant to CEQA and CEQA Guidelines, the City Council hereby adopts the foregoing
findings and adopts the Addendum attached as Exhibit 1. City Council further directs
City staff to cause a Notice of Determination to be filed and posted with the County of
Orange Registrar-Recorder/County Clerk and the State Clearinghouse within five
working days of the City Council’s adoption of this Resolution.
Section 3. This Resolution shall become effective immediately upon its
adoption.
Section 4. The documents and materials associated with this Resolution
that constitute the record of proceedings on which these findings are based are
located at Sant a Ana City Hall, 20 Civic Center Plaza, Santa Ana, CA 92701. The
Planning and Building Agency is the custodian of records for the record of
Planning Commission 1 – 71 3/6/2025
proceedings. This information is provided pursuant to Public Resources Code
section 21081.6.
Section 5. This Resolu tion shall take effect immediately upon its adoption by
the City Council, and the Clerk of the Council shall attest to and certify the vote
adopting this Resolution.
ADOPTED this 18th day of March, 2025 by the following vote:
AYES: Councilmembers:
NOES: Councilmembers:
ABSENT: Councilmembers:
ABSTENTIONS: Councilmembers:
_______________________
Valerie Amezcua
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho, City Attorney
By:________________________
Melissa Crosthwaite
Senior Assistant City Attorney
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, Jennifer L. Hall, City Clerk, do hereby attest to and certify the attached Resolution No.
2025-XXX to be the original resolution adopted by the City Council of the City of Santa
Ana on March 18, 2025.
Date: ________________ ____________________________________
Jennifer L. Hall
City Clerk
City of Santa Ana
Planning Commission 1 – 72 3/6/2025
EXHIBIT 1
ADDENDUM
Planning Commission 1 – 73 3/6/2025
ADDENDUM TO THE
CITY OF SANTA ANA TRANSIT ZONING CODE
ENVIRONMENTAL IMPACT REPORT
SCH NO. 2006071100
City of Santa Ana
Amendment to Transit Zoning
Code/Specific Development No. 84
Prepared For:
City of Santa Ana
20 Civic Center Plaza
Santa Ana, California 92701
Prepared By:
MIG, Inc.
1650 Spruce Street, Suite 106
Riverside, California 92507
January 2025
Planning Commission 1 – 74 3/6/2025
TABLE OF CONTENTS
Page
SECTION 1.0 – INTRODUCTION AND PURPOSE .................................................................... 1
1.1 Introduction and Purpose ................................................................................................ 1
1.2 Statutory Authority and Requirements ............................................................................. 1
1.3 Incorporation by Reference ............................................................................................. 2
SECTION 2.0 – BACKGROUND ................................................................................................ 3
SECTION 3.0 – DESCRIPTION OF PROPOSED PROJECT ..................................................... 6
SECTION 4.0 – ENVIRONMENTAL SETTING..…..…………………………….............................9
SECTION 5.0 – ENVIRONMENTAL ANALYSIS ....................................................................... 12
5.1 Aesthetics/Visual Resources ......................................................................................... 13
5.2 Air Quality ...................................................................................................................... 16
5.3 Biological Resources ..................................................................................................... 22
5.4 Cultural Resources ........................................................................................................ 24
5.5 Hazards and Hazardous Materials ................................................................................. 27
5.6 Hydrology and Water Quality ......................................................................................... 31
5.7 Land Use………. ........................................................................................................... 34
5.8 Noise ............................................................................................................................. 36
5.9 Population, Housing and Employment ........................................................................... 39
5.10 Public Services .............................................................................................................. 40
5.11 Transportation ............................................................................................................... 42
5.12 Utilities and Service Systems ........................................................................................ 46
5.13 Global Climate Change ................................................................................................. 48
5.14 Mandatory Findings of Significance ............................................................................... 51
5.20 Conclusion .................................................................................................................... 52
FIGURES
Figure 1: Transit Zoning Code Area ............................................................................................ 4
Figure 2: Transit Zoning Code Zoning Designations ................................................................... 5
Figure 3: Regional Location ...................................................................................................... 10
Figure 4: Citywide Aerial ........................................................................................................... 11
TABLES
Table 1 - Current and Proposed Text Regulations ...................................................................... 6
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1.0 INTRODUCTION
1.1 Introduction and Purpose
On April 16, 2024, the City Council adopted a 45-day moratorium on the approval,
commencement, establishment, relocation, or expansion of industrial uses within the Transit
Zoning Code/Specific Development (SD) No. 84 Zoning District (or “SD 84A and 84B”) through
adoption of Urgency Interim Ordinance No. NS-3063. The purpose of the moratorium was to
immediately offer protection of public health, safety, and welfare from industrial uses
significantly causing pollution burden to adjacent residential neighborhoods within the SD84
Zoning District. On May 21, 2024, the City Council adopted Ordinance No. NS-3064 to extend
the moratorium for an additional ten (10) months and fifteen (15) days pursuant to the
Government Code to provide sufficient time for staff to continue with data tracking and
reporting, research appropriate regulations, and coordinate with outside regulatory agencies
and City departments to determine whether further, permanent action is necessary and to
generate recommendations to the Planning Commission and City Council.
Based upon the City Council’s actions and direction enacting the moratorium combined with the
research and analysis of the issues herein, staff has prepared Zoning Ordinance Amendment
(ZOA) No. 2024-02 and Amendment Application (AA) No. 2024-03. The proposed amendments
(“proposed amendments” or “project”) will modify the list of land uses and permit types including
the deletion of industrial land uses; amend nonconforming regulations including the addition of
an amortization process for industrial uses; amend and add operational standards for allowed
uses and nonconforming uses; delete the Industrial Overlay (I-OZ) zone from text and maps;
and delete the M1 (Light Industrial) and M2 (Heavy Industrial) suffixes from certain properties
within the SD84 Zoning District boundary as designated on the City of Santa Ana Zoning Map.
Refer to Section 3.2 – Project Description.
Following preliminary review of proposed ZOA No. 2024-02 and AA No. 2024-03 amendments,
the City, as the Lead Agency, has determined that the project is subject to CEQA (Public
Resources Code (PRC) §§21000-21177; 14 CCR §§15000, et seq.). This Addendum to Transit
Zoning Code (SD 84A and 84B) Environmental Impact Report (“TZC EIR”) (SCH No.
2006071100) has been prepared to demonstrate that, pursuant to the standards contained in
CEQA Guidelines Section 15162, this project is within the scope of the TZC EIR. As a result,
the City does not need to prepare a subsequent or supplemental EIR as the TZC EIR fully
analyzed the potential impacts associated with the proposed amendments. This is consistent
with Section 8.06 of the City’s Local Guidelines for Implementing CEQA.
1.2 Statutory Authority and Requirements
CEQA Guidelines Section 15164 states the following with respect to an Addendum to an EIR:
a) The lead agency or responsible agency shall prepare an addendum to a previously
certified EIR if some changes or additions are necessary but none of the conditions
described in Section 15162 calling for preparation of a subsequent EIR have occurred.
b) An addendum to an adopted negative declaration may be prepared if only minor
technical changes or additions are necessary or none of the conditions described in
Section 15162 calling for the preparation of a subsequent EIR or negative declaration
have occurred.
c) An addendum need not be circulated for public review but can be included in or
attached to the final EIR or adopted negative declaration.
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d) The decision making body shall consider the addendum with the final EIR or adopted
negative declaration prior to making a decision on the project.
e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to Section
15162 should be included in an addendum to an EIR, the lead agency’s findings on the
project, or elsewhere in the record. The explanation must be supported by substantial
evidence.
CEQA Guidelines Section 15162, Subsequent EIRs and Negative Declarations, states the
following with respect to a Subsequent EIRs:
(a) When an EIR has been certified or a negative declaration adopted for a project, no
subsequent EIR shall be prepared for that project unless the lead agency determines,
on the basis of substantial evidence in the light of the whole record, one or more of the
following:
(1) Substantial changes are proposed in the project which will require major revisions of
the previous EIR or negative declaration due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects;
(2) Substantial changes occur with respect to the circumstances under which the project
is undertaken which will require major revisions of the previous EIR or Negative
Declaration due to the involvement of new significant environmental effects or a
substantial increase in the severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have
been known with the exercise of reasonable diligence at the time the previous EIR
was certified as complete or the Negative Declaration was adopted, shows any of
the following:
(A) The project will have one or more significant effects not discussed in the
previous EIR or negative declaration;
(B) Significant effects previously examined will be substantially more severe than
shown in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would in
fact be feasible, and would substantially reduce one or more significant effects of
the project, but the project proponents decline to adopt the mitigation measure or
alternative; or
(D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more significant
effects on the environment, but the project proponents decline to adopt the
mitigation measure or alternative.
(b) If changes to a project or its circumstances occur or new information becomes available
after adoption of a negative declaration, the lead agency shall prepare a subsequent
EIR if required under subdivision (a). Otherwise the lead agency shall determine
whether to prepare a subsequent negative declaration, an addendum, or no further
documentation.
1.3 Incorporation by Reference
The TZC Final EIR, including the original Draft EIR (DEIR), and has been made available for
public review at the Lead Agency office (City of Santa Ana). The Final EIR is incorporated into
this Addendum by reference.
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This Addendum is available for public inspection at the City at 20 Civic Center Plaza, Santa
Ana, CA, and on the City’s website at https://www.santa-ana.org/environmental-impact-report-
transit-zoning-code/.
2.0 BACKGROUND
The TZC was established in June 2010, which is located in the area west of Interstate 5, north
of First Street, and between Grand Avenue and Flower Street, and south of Civic Center Drive
in the City of Santa Ana. The TZC provided new zoning for all of the properties contained within
its boundary. However, some properties with existing M1 and M2 zoning and/or existing
industrial businesses also received an overlay district designation which allowed for the
continuation of industrial land uses on those properties and allows for the option of future
mixed-use development to be exercised at the discretion of the property owner. The purpose
was to establish a transit-supportive, pedestrian-oriented development framework to support
the addition of new transit infrastructure; preserve and reinforce the existing character and
pedestrian nature of the City by strengthening urban form through improved development and
design standards; encourage alternative modes of transportation; provide for a range of
housing options; and allow for the reuse of existing structures. On June 7, 2010, the City
adopted the TZC and certified the TZC Final EIR (SCH No. 2006071100).
The TZC Final EIR provides a program-level and project-level analysis of the environmental
impacts resulting from implementation of the TZC. The majority of the analysis is done at the
program level; however, a project-level analysis is provided for the development proposal to
demolish 30,000 square feet of existing structures on eleven Redevelopment Agency-owned
parcels and to construct 220 affordable residential units. The TZC Final EIR concluded full
implementation of the TZC would result in significant and unavoidable impacts with respect to
the following: aesthetics, air quality, cultural resources, noise, transportation, and climate
change. The TZC Final EIR’s background and environmental impact conclusions are cited
throughout this Addendum.
In July 2019, the City Council adopted Ordinance No. NS-2970, amending the Transit Zoning
Code to modify certain design criteria regarding height, massing, open space location, driveway
standards, lot dimensions, and parking alternatives, and determined that this ordinance was
exempt from the California Environmental Quality Act pursuant to State CEQA Guidelines,
section 15061(b)(3). This amendment did not include changes to land uses or permit types
within the TZC. In support of the TZC amendment, the City Council also approved a General
Plan amendment, establishing numerous mixed-use General Plan land use designations for the
entirety of the TZC. Refer to Figure 1 – Existing Transit Zoning Code area and Figure 2 Transit
Zoning Code Designations, below.
However, due to the continued application of the industrial overlay zones within the TZC,
implementation of the new General Plan land use designations immediately resulted in zoning
inconsistencies and land use conflicts with the new General Plan.
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Figure 1 – Transit Zoning Code Area
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Figure 2 – Existing Transit Zoning Code Designations
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3.0 DESCRIPTION OF PROPOSED PROJECT
The proposed amendments would modify the list of land uses and permit types, including the
following:
• Deletion of industrial land uses
• Amend nonconforming regulations, including the addition of an amortization process
• Amend and add operational standards for allowed uses and nonconforming uses
• Delete the Industrial Overlay (I-OZ) zone from text and maps
• Delete the M1 (Light Industrial) and M2 (Heavy Industrial) suffixes from certain
properties within the SD84 Zoning District boundary as designated on the City of Santa
Ana Zoning Map
Implementation of the proposed amendments do not include nor require implementation of any
site-specific development projects.
Table 1 – Current and Proposed Text Regulations, below lists the proposed amendments and is
followed by a summary of each. Figure 2.5 Proposed Transit Zoning Code Designations depicts
the removal of I-OZ from the map.
Table 1 – Current and Proposed Text Regulations
Code Section
Title Existing Zoning Code Regulations Proposed Zoning Code Regulations
Application of
Article
SAMC Section 41-2001 establishes the land
uses and standards applicable to the TZC -
primarily for new uses.
The update to text of this Section
clarifies that the regulations apply to
existing uses, whether conforming or
nonconforming, change in land use or
tenancy requiring issuance of Certificate
of Occupancy.
Organization SAMC Section 41-2001.5 establishes the
contents and organization of the TZC
regulations
The update to the text is necessary to
encompass the new Section 41-2009
(Operational Standards for
Nonconforming Industrial Uses).
Nonconforming
Buildings,
Structures and
Uses
SAMC Section 41-2002 establishes the
regulations for nonconforming buildings,
structures or uses within the TZC boundary.
The provisions contain minimal limits for
rehabilitation of buildings and structures and
their expansion for both residential and non-
residential uses.
The update to text of this Section will
further limit some rehabilitation of
buildings and structures, with specific
emphasis on nonconforming industrial
uses. These updated provisions
include:
• Requiring rehabilitation or expansion
of buildings and structures, occupied by
any nonconforming use to comply with
the new operational standards
contained in Section 41-2009.
• Prohibits expansion of a building or
structure occupied by a nonconforming
industrial use.
• Discontinuation of nonconforming
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Code Section
Title Existing Zoning Code Regulations Proposed Zoning Code Regulations
noxious uses through amortization.
• Elimination of certain nonconforming
uses and structures
• Establishes a process for enacting
amortization periods for eliminating
certain nonconforming uses.
• References to SAMC and State law
for abatement of public nuisances.
• Establishes authority for voluntary
compliance agreements between the
City and nonconforming uses.
The Industrial
Overlay (I-OZ)
Zone
SAMC Section 41-2004 establishes an
overlay zone applied to M1 and M2 zoned
properties located within the TZC boundary.
Section 41-2004 is deleted in its
entirety, removing the I-OZ Zone from
the TZC to eliminate industrial land use
type zoning altogether.
Application for
Discretionary
Approvals
SAMC Section 41-2005 establishes the
process and timing of vesting for certain
uses approved with a discretionary permit.
Section 41-2005 is renumbered as 41-
2004, and the update to the text of this
Section adds clarification for effects of
the amendments to the TZC dependent
upon status of an application in the City
process of review, approval, and/or
building permit issuance, if required.
Zones
Established
SAMC Section 41-2006 contains the
regulations for zoning districts, land uses,
and permit types within the TZC.
The update to the text of this Section
deletes the I-OZ Zone, including
replacing Figure 2.1, the Regulating
Plan (map) with a new Figure 2.1
removing the I-OZ Zone designation
from all parcels within the TZC
boundary.
Uses
Permitted
SAMC Section 41-2007 provides the
allowable land uses and permit types
required to establish a land use by each
zoning district within the TZC.
The update to the text of this Section
clarifies application of the use
standards by zoning district as follows:
• Modifies Table 2A containing the Use
Standards by adding and reclassifying
certain land use types appropriate to
the TZC land use subcategories
• Deletes certain land use types that are
inconsistent with the intent and purpose
of the TZC, including the deletion of the
Small-Scale Industry land use
subcategory in its entirety.
Operational
Standards
SAMC Section 41-2008 primarily regulates
new uses within the TZC.
The update to the text of this Section
further limits certain operations to
ensure greater compatibility between
residential and non-residential land
uses.
Operational
Standards for
Nonconforming
Industrial Uses
SAMC Section 41-2009 is an entirely new
set of regulations specific to existing
nonconforming industrial uses within the
TZC.
The new Section establishes
regulations for operation of any existing,
legally established, nonconforming
industrial use. The regulations cover
general standards, enclosed
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Code Section
Title Existing Zoning Code Regulations Proposed Zoning Code Regulations
operations, air emissions and dust,
light, glare, and heat, ground vibration,
outdoor storage and screening,
hazardous materials, liquid and solid
waste, site maintenance, truck parking
and loading, and hours of operation.
Definitions SAMC Section 41-2080 contains the
definitions applicable to terms and land uses
of the TZC.
The update to the text of this Section
provides clarification for certain land
use types (artisan/craft product with
limited on-site production, commercial
recreation facility – indoor, and research
and development), adds definitions for
land use types (business support
services, pet day care facility and trade
school, nonconforming industrial, and
noxious use), and deletes
corresponding definitions for land use
types that were deleted as part of the
amendments to SAMC Section 41-
2006.
Source: Planning Commission Staff Report
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Figure 2.5 – Proposed Transit Zoning Code Designations
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Analysis of the Amendments
The proposed amendments to the Sections of the TZC under the topic headings of Application
of Article, Organization, Application for Discretionary Approvals, and Definitions are largely to
ensure internal consistency related to the more substantive changes being proposed for the
TZC to address irreconcilable land use conflicts, described as follows:
• Nonconforming Structures and Uses - Section 41-2002 regulates the nonconforming
building, structure or use specifically within the TZC. The regulations are unique to the
TZC and do not apply citywide. The regulations determine under certain circumstances
when a nonconforming structure or use can rehabilitate both structural or nonstructural;
or expand conditions that would allow expansion. Due to the concerns enumerated
within this report related to nonconforming industrial uses within the TZC, the
amendments to this section increasingly limit rehabilitation of structures to those types
of improvements that address compliance with the new Section 41-2009 operational
standards for nonconforming industrial uses; and disallow the expansion of any
nonconforming industrial use. This Section also includes new provisions to establish a
process for the discontinuance of nonconforming uses, specifically noxious uses, and
the elimination of those uses or structures through an amortization hearing process. The
tools that these new regulations provide are necessary to address the environmental
impacts that lead to the adoption of the Moratorium, provide the framework to initiate the
process to eliminate noxious industrial land uses from the TZC, and align with the
adopted EJ policies of the General Plan.
• The Industrial Overlay (I-OZ) Zone – Section 41-2004 created an “exception” zone for
properties within the TZC that contained M1 or M2 industrial zoning, uses and
structures, when the TZC was adopted in 2010. In order to be both consistent and to
promulgate the General Plan land use designations within the TZC, the removal of this
overlay zone is necessary. The zone currently gives deference to the property owner of
these parcels with an industrial overlay to decide when and whether to redevelop their
properties in a manner that would remove the industrial structure and use, replacing it
with an allowable use and conforming to the design standards of the TZC. Eliminating
the I-OZ Zone will cause these properties to become nonconforming as to use and
structure, subjecting them to the regulations as amended and added to Section 41-
2002, including discontinuance of nonconforming use or structure though amortization.
With the deletion of the entirety of the text of Section 41-2004, Section 41-2005
Application for Discretionary Approvals is renumbered as Section 41-2004.
• Zones Established and Uses Permitted – Amendments to Sections 41-2006 and 41-
2007, respectively, include parallel deletion of the I-OZ Zone affecting the Regulating
Plan (TZC zoning map) and the corresponding Use Standards tables regulating the land
use and permit types for each of the remaining zones of the TZC. Table 2A categorizes
land uses into broad subheadings for both residential and nonresidential land uses. The
nonresidential land uses are further categorized into commercial-oriented versus
industrial-oriented types of uses. The amendments will eliminate the Small-Scale
Industry sub-category altogether, since the majority of these uses are industrial uses
incompatible with residential uses. The purpose of the TZC is to promote transit-oriented
mixed-use development, which pairs residential and nonresidential land uses either
horizontally or vertically on a site or within a building. Compatibility of allowable land use
types is critical, particularly given the history of the negative impacts from industrial uses
remaining in the area and in close proximity to existing and new residential areas.
Amending this Section also replaces the TZC zoning map figure to ensure consistency
with the City’s Official Zoning Map and General Plan Land Use Map in accordance with
requirements of State law, Government Code Section 65860.
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• Operational Standards and Operational Standards for Nonconforming Industrial Uses –
Section 41-2008 contains operational standards applicable to all uses within the TZC
boundary. This Section is largely unchanged, with clarification and strengthening of
certain regulations to address any possible industrial type function of an allowable land
use type as listed in the tables of Section 41-2007. These amendments affected any
possible manufacturing related activities, sound, screening walls and eliminated any
vehicular service on Sundays. Section 41-2009 establishes new regulations governing
existing industrial uses made nonconforming with the removal of the I-OZ Zone within
the TZC, and include general standards, enclosed operations, air emissions and dust,
light, glare, and heat, ground vibration, outdoor storage and screening, hazardous
materials, liquid and solid waste, site maintenance, truck parking and loading, and hours
of operation. The amendments to Section 41-2008 and creation of new regulations
under Section 41-2009 ensure that existing nonconforming uses comply with very
specific operational standards and/or face amortization that leads ultimately to
discontinuance of use, effectively reestablishing the TZC area with residential uses and
allowing certain nonresidential uses compatible to such residential and/or mixed-use
development.
4.0 ENVIRONMENTAL SETTING
The City of Santa Ana is located in Orange County and serves as the County seat. The City is
in the western central portion of Orange County, approximately 30 miles southwest of the City
of Los Angeles and 10 miles northeast of the City of Newport Beach (refer to Figure 3, Regional
Location). As shown in Figure 4, Citywide Aerial, the City is bordered by the City of Orange and
unincorporated areas of Orange County to the north, the City of Tustin to the east, the cities of
Irvine and Costa Mesa to the south, and the cities of Fountain Valley and Garden Grove to the
west. The TZC area is shown in blue on both Figure 3 and Figure 4, and a detailed view is
shown on Figure 1 in Section 2.0.
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Figure 3 – Regional Location
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Figure 4 – Citywide Aerial
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At the local level, the TZC area is located in the central urban core of the City and comprises
over 100 blocks and 450 acres, and is generally bounded by I-5 to the north and east, First
Street to the south, and Flower Street to the west. Refer to Figure 1 in the Background section.
The majority of the City is urbanized, with residential and nonresidential development, and
mobility and public facilities all contributing to Santa Ana’s existing built environment. The City’s
incorporated boundaries encompass approximately 27.4 square miles. Residential land uses
occupy almost 40 percent of the land within the current City boundaries, accounting for 5,226
acres. Other predominant land uses include commercial (1,588 acres) and industrial (1,628
acres).
While Santa Ana is a densely populated urban center with one of the most diverse international
populations in Orange County, it can generally be characterized as a City of neighborhoods.
Santa Ana has over 65 neighborhoods which are distinguished by their history, architecture,
housing types, amenities, and unique character.
The Specific Development (SD) No. 84 Zoning District, also known as the TZC, is located in the
central urban core of the City and comprises over 100 blocks and 450 acres, and is generally
bounded by First Street, Flower Street, Civic Center Drive, Grand Avenue, and the Santa Ana
(I-5) Freeway.
The TZC area includes the Orange County Civic Center consisting of City, County and federal
buildings, City, Downtown, the Logan and Lacy neighborhoods, which are among the City’s
most historic in age and are established residential communities. Additional land uses include a
mix of residential, commercial and industrial uses. The TZC area overlaps portions of two of the
City’s five focus areas, which are suited for new growth and development under the GPU: the
Grand Avenue Avenue/17th Street Focus Area and the West Santa Ana Boulevard Focus Area.
The Grand Avenue Avenue/17th Street Focus Area is primarily business oriented with office
and commercial storefronts and large apartment complexes. The West Santa Ana Boulevard
Focus Area is characterized as a mix of residential, commercial and industrial.
5.0 ENVIRONMENTAL ANALYSIS
The Initial Study/Notice of Preparation of the DEIR (Appendix A) concluded certain topics to be
“Effects Not Found to Be Significant” according to Section 15128 of the CEQA Guidelines as
having less than significant or no impacts, and therefore were not included in the Final EIR.
Agricultural Resources. The Initial Study concluded that the soils within the Transit Zoning Code
(SD 84A and SD 84B) area are not candidates for listing as prime farmland, unique farmland, or
farmland of statewide importance. In addition, no farmland or agricultural activity exists on or in
the vicinity of the Transit Zoning Code, and no portion is under a Williamson Act contract. The
Initial Study concluded no that no impacts would occur.
Geology and Soils. The Transit Zoning Code (SD 84A and SD 84B) area is located in an area
of minimal geologic hazards. Any development within the project area would be designed in
accordance with applicable building code requirements, which account for seismic
groundshaking. The Initial Study concluded that no and less than significant impacts to would
occur.
Mineral Resources. The Initial Study determined that implementation of the Transit Zoning
Code (SD 84A and SD 84B) would not result in the loss of availability of either a known mineral
resource of value to the state or region, or a locally important mineral resource recovery site,
because no such sites exist within the project area. The Initial Study concluded that
implementation of the Transit Zoning Code (SD 84A and SD 84B) would not result in the loss of
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availability of a locally important mineral resource delineated on a local general plan, specific
plan, or other land use plan.
Because the TZC Final EIR was certified in 2010, certain topics that were later added to the
state CEQA Guidelines checklist were not included. The Tribal Cultural Resources topic was
added to the CEQA Guidelines in 2017. Although added as a separate topic, the TZC DEIR
Cultural Resources section did include an evaluation of Native American resources in Section
4.4.1 – Environmental Setting and Section 4.4.2 – Regulatory Framework. Impact 4.4-1
included MM 4.4-1(a) that required construction monitoring by a tribe.
The TZC EIR included a Global Climate Change topic, which included greenhouse gas
emissions. The Greenhouse Gas Emissions topic was added to the CEQA Guidelines in 2018.
Greenhouse Gas Emissions was discussed in Section 4.13.2 – Existing Conditions,
Section 4.13.2 – Regulatory Framework, and Section 4.13.4 – Project Impacts and Mitigation
Measures.
The Energy and Wildfire topics were added to the CEQA Guidelines in 2018. Although added
as separate topics, Energy is discussed within Sections 4.12.12 and 4.12.13 of the Utilities and
Service Systems topic of the TZC EIR.
Wildfire (i.e. wildland fires), is discussed within Section 4.5.3 of the Hazards and Hazardous
Materials topic of the TZC EIR.
Although these topics were added following certification of the TZC Final EIR, they were
discussed and analyzed in the respective sections identified above and do not represent new
impacts not previously addressed.
Sections 5.1 through 5.13, below, analyzes the potentially significant impacts that could occur
as a result of implementing the proposed project through the adoption of the proposed text
regulations identified in Table 1 – Current and Proposed Text Regulations. Each topical section
lists impact statements and mitigation measures from the TZC EIR, and provides an analysis
and conclusion. Each TZC EIR conclusion includes a reference to the EIR impact statement
(ex., Impact 4.1-3) and includes its associated significance finding.
5.1 AESTHETICS/VISUAL RESOURCES
This section analyzes the effects to aesthetics and visual resources from implementing the
proposed zoning code regulations.
Would the project:
a. Have a substantial adverse effect on a scenic vista?
b. Substantially damage scenic resources, including, but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway?
c. Substantially degrade the existing visual character or quality of the site and its
surroundings?
d. Create a new source of substantial light or glare, which would adversely affect day or
nighttime views in the area?
e. A project would be considered to create significant shade/shadow impacts if
shade/shadow from the project results in a substantial loss of sunlight in a residential
area or other sensitive receptor. Other sensitive receptors would include schools and
parks.
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TZC EIR Conclusions
• Implementation of the Transit Zoning Code (SD 84A and SD 84B) would not
substantially damage scenic resources within a State scenic highway, and no further
analysis is necessary in this EIR. (DEIR Section 4.1.3: Effects Found to Have No
Impact)
• Development under the Transit Zoning Code (SD 84A and SD 84B) would contribute to
the image of, and add to the aesthetic quality of the City. As such, development under
the proposed project would not degrade the existing visual quality of the area or obstruct
key existing views and/or vistas in the vicinity. (Impact 4.1-1: Less Than Significant
without mitigation)
• Future development under the Transit Zoning Code (SD 84A and SD 84B) would
improve the existing visual character. (Impact 4.1-2: Less Than Significant without
mitigation)
• Long-term cumulative development occurring pursuant to the Transit Zoning Code, and
associated infrastructure improvements would result in new sources of increased
daytime glare. (Impact 4.1-3: Less Than Significant with mitigation)
• Long-term cumulative development occurring pursuant to the Transit Zoning Code
would result in new sources of spillover light. (Impact 4.1-4: Less Than Significant with
mitigation)
• Long-term cumulative development occurring pursuant to the Transit Zoning Code (SD
84A and SD 84B) would result in a substantial increase in shade/shadows over sensitive
uses. (Impact 4.1-5: Significant and Unavoidable and no feasible mitigation)
TZC EIR FEIR Mitigation Measures
MM4.1-1 Proposed new structures shall be designed to maximize the use of textured or other
non-reflective exterior surfaces and non-reflective glass. Building materials shall be reviewed by
the City of Santa Ana prior to issuance of building permits for each project. (Impact 4.1-3)
MM4.1-2 All exterior lighting and advertising (including signage) shall be directed onto the
specific location intended for illumination (e.g., parking lots, driveways, and walkways) and
shielded away from adjacent properties and public rights-of-way to minimize light spillover onto
adjacent areas. (Impact 4.1-4)
MM4.1-3 Prior to issuance of a building permit for a specific development project, the applicant
shall submit a lighting plan to the City for review and approval. The plan shall specify the
lighting type and placement to ensure that the effects of security and other outdoor lighting are
minimized on adjacent uses and do not create spillover effects. The plan shall specifically
incorporate the following design features:
o All projects shall incorporate project design features to shield light and/or glare from
vehicles entering or exiting parking lots and structures that face sensitive uses (e.g.,
schools, hospitals, senior housing, or other residential properties) by providing barriers
so that light from vehicle headlights would not illuminate off-site sensitive uses.
o All projects shall incorporate project design features to provide landscaping, physical
barriers, screening, or other buffers to minimize project-generated illumination from
entering off-site areas and to prevent glare or interference with vehicular traffic, in
accordance with the City’s Municipal Code. (Impact 4.1-4)
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January 2025 17 Environmental Analysis
MM4.1-4 For any proposed structure that would exceed four stories in height, applicants shall
submit a site-specific shade/shadow report with renderings representing the level of
shade/shadows associated with the proposed development at the following times: 9:00 A.M.,
12:00 P.M., 3:00 P.M. PST for the both the winter and summer solstices. An additional
rendering for the 5:00 P.M. PST time period shall be prepared for the summer solstice period.
Typically, a variety of criteria are used to determine the significance of a shadow impact,
including the following:
o Affected land use (criticality of direct sunlight for the use).
o Duration (hours per day in shadow); time of day (critical time period for direct sunlight).
o Season (time of year use would be shadowed).
o Extent (percentage of use that would be shadowed).
o Preexisting condition (shadow condition due to existing buildings, landscaping, or other
features).
o Type (solid or dappled shadow).
The report shall include any feasible design considerations that would reduce the extent of
shadows cast by a proposed structure. The analysis and the project design plans shall be
forwarded to the Planning and Building Agency for review and approval. (Impact 4.1-5)
Project Analysis and Conclusion
The City determined that no impacts related to State Scenic Highways would result from
implementation of the project because no scenic highways are located within the TZC area.
Impacts related to visual and aesthetic quality (Impact 4.1-1) and visual character (Impact 4.1-
2) were below the level of significance and did not require mitigation. Impacts related to daytime
glare (Impact 4.1-3) and spillover light (Impact 4.1-4) were less than significant with the
implementation of mitigation measures. Long-term development related shade and shadows
(Impact 4.1-5) were found to be significant and unavoidable and that specific economic, social,
or other considerations make mitigation infeasible. Specifically, no additional feasible mitigation
measures exist that would avoid or substantially reduce these impacts.
Implementation of the project through the proposed adoption of the text regulations identified in
Table 1 – Current and Proposed Text Regulations does not trigger new aesthetic and visual
resources impacts requiring preparation of a supplemental or subsequent EIR because the
project modifies the list of land uses and permit types (refer to Table 1 – Current and Proposed
Text Regulations) including the deletion of industrial land uses; amend nonconforming
regulations including the additional of an amortization process; amend and add operational
standards for allowed uses and nonconforming uses; and delete the Industrial Overlay (I-OZ)
zone from text and maps; and delete the M1 (Light Industrial) and M2 (Heavy Industrial)
suffixes from certain properties within the TZC area. Thus, there are no new land uses being
introduced or different development standards that would have aesthetic or visual resource
impacts. In particular, the proposed amendments will establish regulations for nonconforming
uses, including light and glare. These regulations and standards will cover general standards,
enclosed operations, light, glare, and outdoor storage and screening. No direct or indirect glare
or heat, whether from floodlights or from high-temperature processes (including combustion or
welding or otherwise) shall be visible or felt at the property line. Lighting must be shielded,
boxed, or directed at a downward angle so as to minimize the generation of light and glare and
to assure that there is no spillover of light and glare that will impact drivers or pedestrians on
the public streets, on site activities, and adjoining or nearby properties. No activity shall be
permitted which causes excessive light and glare to be transmitted or reflected to surrounding
properties at a level resulting in detrimental impacts to adjacent properties. Light sources shall
generally not be permitted in landscaped, buffer, or setback areas except for those illuminating
Planning Commission 1 – 92 3/6/2025
January 2025 18 Environmental Analysis
pedestrian walkways. Lighting used to illuminate parking areas shall be designed, located, and
installed to be shielded and downlit and to reflect away from any nearby residential areas.
Lighting for advertising signs shall not create glare or light which extends to surrounding
properties.
Any future development within the TZC area requiring discretionary action would be subject to a
project-level CEQA review at the time an application is filed for an individual project. In addition,
compliance with the existing regulations and proposed regulations will assure that potential
impacts are not exacerbated, which will result in a beneficial impact to aesthetics and visual
resources. Mitigation measures MM4.1-1 through MM4.1-4 would continue to apply. Therefore,
the project does not trigger new aesthetics impacts requiring the preparation of a subsequent or
supplemental EIR. There would be no new or more significant impacts to aesthetics and visual
resources.
5.2 AIR QUALITY
This section analyzes the effects to air quality from implementing the proposed zoning code
regulations.
Would the project:
a. Conflict with or obstruct implementation of the applicable air quality plan?
b. Violate any air quality standard or contribute substantially to an existing or projected air
quality violation?
c. Result in a cumulatively considerable net increase of any criteria pollutant for which the
proposed project region is in non-attainment under an applicable federal or State
ambient air quality standard (including releasing emissions which exceed quantitative
thresholds for ozone precursors)?
d. Expose sensitive receptors to substantial pollutant concentrations?
e. Create objectionable odors affecting a substantial number of people?
TZC EIR Conclusions
• The project would not create substantial objectionable odors. (Impact 4.2-1: Less Than
Significant with mitigation)
• The project would not create short-term quantities of criteria pollutants above the
significance thresholds published by SCAQMD. (Impact 4.2-2: Less Than Significant
with mitigation)
• Operation of the project would increase local traffic volumes, but would not expose
sensitive receptors to substantial localized carbon monoxide (CO) concentrations.
(Impact 4.2-3: Less Than Significant without mitigation)
• The anticipated population increase of 12,225 new residents as a result of the long -term
cumulative development pursuant to the Transit Zoning Code is consistent with the
SCAG growth projections for Santa Ana and, therefore, would not conflict with or
obstruct implementation of the Air Quality Management Plan. (Impact 4.2-4: Less Than
Significant without mitigation)
• Construction activities associated with the construction of individual projects within the
Transit Zoning Code area, including the Developer project, would contribute
substantially to an existing or projected air quality violation for criteria air pollutants.
(Impact 4.2-5: Significant and Unavoidable with mitigation)
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January 2025 19 Environmental Analysis
• Operation of the proposed project would exceed South Coast Air Quality Management
District standards for VOC, NOX, CO, and PM10 and would result in a projected air
quality violation. (Impact 4.2-6: Significant and Unavoidable and no feasible mitigation)
• Construction and operation of the proposed project would result in a cumulatively
considerable net increase of criteria pollutants for which the proposed project region is
in nonattainment under an applicable federal or state ambient air quality standard.
(Impact 4.2-7: Significant and Unavoidable and no feasible mitigation)
TZC EIR Mitigation Measures
MM4.2-1 Trash receptacles within the Transit Zoning Code (SD 84A and SD 84B) will be
required to have lids that enable convenient collection and loading and will be emptied on a
regular basis, in compliance with City of Santa Ana regulations for the collection of solid waste.
(Impact 4.2-1)
MM4.2-2 The construction contractor should ensure that no more than 5 acres per day are
actively graded or developed. (Impact 4.2-2)
MM4.2-3 The construction contractor should ensure that all active disturbed surfaces should be
watered three times per day throughout the construction period. (Impact 4.2-2)
MM4.2-4 The construction contractor should ensure that the mass grading, fine grading, and
structure construction are conducted at separate time periods and do not overlap with one
another. (Impact 4.2-2)
MM4.2-5 The construction contractor should ensure that all haul roads are watered three (3)
times per day. (Impact 4.2-2)
MM4.2-6 The construction contractor should ensure that all traffic on unpaved roads is reduced
to 15 mph or less. (Impact 4.2-2)
MM4.2-7 Project applicants shall require by contract specifications that all diesel-powered
equipment used will be retrofitted with after-treatment products (e.g., engine catalysts) to the
extent that they are readily available in the South Coast Air Basin. Contract specifications shall
be included in project construction documents, which shall be reviewed by the City of Santa
Ana prior to issuance of a grading permit. (Impact 4.2-5)
MM4.2-8 Project applicants shall require by contract specifications that all heavy-duty diesel-
powered equipment operating and refueling at the project site use low-NOX diesel fuel to the
extent that it is readily available and cost effective (up to 125 percent of the cost of California
Air Resources Board diesel) in the South Coast Air Basin (this does not apply to diesel-powered
trucks traveling to and from the project site). Contract specifications shall be included in project
construction documents, which shall be reviewed by the City of Santa Ana prior to issuance of a
grading permit. (Impact 4.2-5)
MM4.2-9 Project applicants shall require by contract specifications that alternative fuel
construction equipment (i.e., compressed natural gas, liquid petroleum gas, and unleaded
gasoline) be utilized to the extent that the equipment is readily available and cost effective in
the South Coast Air Basin. Contract specifications shall be included in project construction
documents, which shall be reviewed by the City of Santa Ana prior to issuance of a grading
permit. (Impact 4.2-5)
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January 2025 20 Environmental Analysis
MM4.2-10 Project applicants shall require by contract specifications that construction
equipment engines be maintained in good condition and in proper tune per manufacturer’s
specification for the duration of construction. Contract specifications shall be included in project
construction documents, which shall be reviewed by the City of Santa Ana prior to issuance of a
grading permit. (Impact 4.2-5)
MM4.2-11 Project applicants shall require by contract specifications that construction
operations rely on the electricity infrastructure surrounding the construction site rather than
electrical generators powered by internal combustion engines to the extent feasible. Contract
specifications shall be included in project construction documents, which shall be reviewed by
the City of Santa Ana prior to issuance of a grading permit. (Impact 4.2-5)
MM4.2-12 As required by South Coast Air Quality Management District Rule 403—Fugitive
Dust, all construction activities that are capable of generating fugitive dust are required to
implement dust control measures during each phase of project development to reduce the
amount of particulate matter entrained in the ambient air. These measures include the
following:
o Application of soil stabilizers to inactive construction areas.
o Quick replacement of ground cover in disturbed areas.
o Watering of exposed surfaces three times daily.
o Watering of all unpaved haul roads three times daily.
o Covering all stock piles with tarp.
o Reduction of vehicle speed on unpaved roads.
o Post signs on-site limiting traffic to 15 miles per hour or less.
o Sweep streets adjacent to the project site at the end of the day if visible soil material is
carried over to adjacent roads.
o Cover or have water applied to the exposed surface of all trucks hauling dirt, sand, soil,
or other loose materials prior to leaving the site to prevent dust from impacting the
surrounding areas.
o Install wheel washers where vehicles enter and exit unpaved roads onto paved roads to
wash off trucks and any equipment leaving the site each trip. (Impact 4.2-5)
MM4.2-13 The developer shall require by contract specifications that construction-related
equipment, including heavy-duty equipment, motor vehicles, and portable equipment, shall be
turned off when not in use for more than 30 minutes. Diesel-fueled commercial motor vehicles
with gross vehicular weight ratings of greater than 10,000 pounds shall be turned off when not
in use for more than 5 minutes. Contract specifications shall be included in the proposed project
construction documents, which shall be approved by the City of Santa Ana. (Impact 4.2-5)
MM 4.2-14 The developer shall require by contract specifications that construction parking be
configured to minimize traffic interference during the construction period and, therefore, reduce
idling of traffic. Contract specifications shall be included in the proposed project construction
documents, which shall be approved by the City of Santa Ana. (Impact 4.2-5)
MM 4.2-15 The developer shall require by contract specifications that temporary traffic controls
are provided, such as a flag person, during all phases of construction to maintain smooth traffic
flow. Contract specifications shall be included in the proposed project construction documents,
which shall be approved by the City of Santa Ana. (Impact 4.2-5)
MM 4.2-16 The developer shall require by contract specifications that construction activities that
affect traffic flow on the arterial system by scheduled to off-peak hours (9:00 A.M. to 3:00 P.M.).
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January 2025 21 Environmental Analysis
Contract specifications shall be included in the proposed project construction documents, which
shall be approved by the City of Santa Ana. (Impact 4.2-5)
MM4.2-17 Upon issuance of building or grading permits, whichever is issued earliest,
notification shall be mailed to owners and occupants of all developed land uses within ¼ mile of
any project within the Transit Zoning Code (SD 84A and SD 84B) boundaries greater than four
stories in height or 25,000 sf in area providing a schedule for major construction activities that
will occur through the duration of the construction period. In addition, the notification will include
the identification and contact number for a community liaison and designated construction
manager that would be available on site to monitor construction activities. The construction
manager shall be responsible for complying with all project requirements related to PM10
generation. The construction manager will be located at the on-site construction office during
construction hours for the duration of all construction activities. Contract information for the
community liaison and construction manager will be located at the construction office, City Hall,
the police department, and a sign on site. (Impact 4.2-5)
MM4.2-18 The developer shall require by contract specifications that the architectural coating
(paint and primer) products used would have a VOC rating of 125 grams per liter or less.
Contract specifications shall be included in the proposed project construction documents, which
shall be reviewed and approved by the City of Santa Ana. (Impact 4.2-5)
MM4.2-19 The developer shall require by contract specifications that materials that do not
require painting be used during construction to the extent feasible. Contract specifications shall
be included in the proposed project construction documents, which shall be reviewed and
approved by the City of Santa Ana. (Impact 4.2-5)
MM4.2-20 The developer shall require by contract specifications that pre-painted construction
materials be used to the extent feasible. Contract specifications shall be included in the
proposed project construction documents, which shall be reviewed and approved by the City of
Santa Ana. (Impact 4.2-5)
MM4.2-21 As individual components of the Transit Zoning Code (SD 84A and SD 84B) are
implemented, an air quality impact analyses will be completed to determine their independent
significance levels. Mitigation is to be incorporated at the individual component level to bring the
individual components to less than significant on a site-by-site basis. (Impact 4.2-6)
MM4.2-22 Prior to issuance of a building permit, the applicant shall demonstrate that the design
of the proposed buildings or structures exceeds current Title 24 requirements (Title 24, Part 6
of the California Code of Regulations; The Energy Commission adopted the 2008 Standards on
April 23, 2008, and the Building Standards Commission approved them for publication on
September 11, 2008. The 2008 Residential Compliance Manual was adopted by the
Commission on December 17, 2008, and the 2008 Non-residential Compliance Manual was
adopted January 14, 2009.Energy Efficiency Standards for Residential and Non Residential
Buildings, as amended November 1, 2005; Cool Roof Coatings performance standards as
amended September 11, 2006) by a minimum of 20 percent, subject to review by the County
Building Official. Documentation of compliance with this measure shall be provided to the
Planning Department and Building Official for review and approval prior to issuance of the
permit. Installation of the identified design features or equipment will be confirmed by the
County Building Official prior to certificate of occupancy. Any combination of the following
design features may be used to fulfill this mitigation provided that the total increase in efficiency
meets or exceeds 20 percent:
o Increase in insulation such that heat transfer and thermal bridging is minimized
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January 2025 22 Environmental Analysis
o Limit air leakage through the structure or within the heating and cooling distribution
system to minimize energy consumption
o Incorporate dual-paned or other energy efficient windows
o Incorporate energy efficient space heating and cooling equipment
o Incorporate energy efficient light fixtures
o Incorporate energy efficient appliances
o Incorporate energy efficient domestic hot water systems
o Incorporate solar panels into the electrical system
o Incorporate cool roofs/light-colored roofing
o Or other measures that will increase the energy efficiency of building envelope in a
manner that when combined with the other options listed above exceeds current Title 24
Standards (Title 24, Part 6 of the California Code of Regulations; Energy Efficiency
Standards for Residential and Non Residential Buildings, as amended November 1,
2005; Cool Roof Coatings performance standards as amended September 11, 2006) by
a minimum of 20 percent. (Impact 4.2-6)
MM4.2-23 Prior to issuance of a building permit, the applicant shall provide a landscape plan for
the Project that includes shade trees around main buildings, particularly along southern
elevations where practical, and will not interfere with loading dock locations or other operational
constraints. Documentation of compliance with this measure shall be provided to the City
Building Official for review and approval. (Impact 4.2-6)
MM4.2-24 Prior to issuance of a building permit, the applicant shall demonstrate that the
proposed building or structure designs incorporate exterior storage areas for recyclables and
green waste and adequate recycling containers located in public areas. Documentation of
compliance with this measure shall be provided to the City Building Official for review and
approval. Installation of the identified design features or equipment will be confirmed by the City
Building Official prior to issuance of certificate of occupancy. (Impact 4.2-6)
MM4.2-25 The applicant shall provide education and publicity about reducing waste and
available recycling services to future tenants. The education and publicity materials shall be
provided to the City for review and approval by the Planning Department. (Impact 4.2-6)
MM4.2-26 All showerheads, lavatory faucets, and sink faucets within the residential units shall
comply with the California Energy Conservation flow rate standards. (Impact 4.2-6)
MM4.2-27 Low-flush toilets shall be installed within all commercial and residential (including
Congregate Care) units as specified in California State Health and Safety Code Section
17921.3. (Impact 4.2-6)
MM4.2-28 All commercial/industrial/common area irrigation areas shall be capable of being
operated by a computerized irrigation system which includes an onsite weather station/ET gage
capable of reading current weather data and making automatic adjustments to independent run
times for each irrigation valve based on changes in temperature, solar radiation, relative
humidity, rain, and wind. In addition, the computerized irrigation system shall be equipped with
flow-sensing capabilities, thus automatically shutting down the irrigation system in the event of
a mainline break or broken head. These features will assist in conserving water, eliminating the
potential of slope failure due to mainline breaks, and eliminating over-watering and flooding due
to pipe and/or head breaks. (Impact 4.2-6)
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January 2025 23 Environmental Analysis
MM4.2-29 Landscape designers shall ensure that Project landscaping of
commercial/industrial/common areas uses drought-tolerant and smog-tolerant trees, shrubs,
and groundcover to ensure long-term viability and conserve water and energy. (Impact 4.2-6)
MM4.2-30 Landscape designers shall ensure that the landscape plan includes drought resistant
trees, shrubs, and groundcover within the parking lot and perimeter. (Impact 4.2-6)
MM4.2-31 Project designers shall ensure that design features incorporate light-colored roofing
materials that will deflect heat away from the building and conserve energy. (Impact 4.2-6)
MM4.2-32 The Project designers shall ensure that designs include all illumination elements to
have controls to allow selective use as an energy conservation measure. (Impact 4.2-6)
MM4.2-33 Prior to issuance of a building permit, the applicant shall demonstrate that measures
have been included to promote ride sharing programs such as, but not necessarily including,
publishing ride sharing information for all of the tenants, designating a certain percentage of
parking spaces for ride sharing vehicles, designating adequate passenger loading and
unloading and waiting areas for ride sharing vehicles, and providing a website or message
board for coordinating rides. Documentation of compliance with this measure shall be provided
to the City Building Official for review and approval. Installation of the identified design features
or equipment will be confirmed by the City Building Official prior to issuance of certificate of
occupancy. (Impact 4.2-6)
MM4.2-34 Prior to issuance of a building permit, the applicant shall demonstrate that measures
have been included to provide adequate bicycle parking near building entrances to promote
cyclist safety, security, and convenience. Documentation of compliance with this measure shall
be provided to the City Building Official for review and approval. Installation of the identified
design features or equipment will be confirmed by the City Building Official prior to issuance of
certificate of occupancy. (Impact 4.2-6)
MM4.2-35 Prior to issuance of any certificate of occupancy, the applicant shall demonstrate that
all interior building lighting supports the use of compact fluorescent light bulbs or equivalently
efficient lighting to the satisfaction of the City Building Official. (Impact 4.2-6)
MM4.2-36 Tenants shall be responsible to ensure that preferential parking spaces are allocated
to ultra-low emission vehicles and alternative fueled vehicles to encourage the use of alternative
fuels and ultra-low emission vehicles. (Impact 4.2-6)
MM4.2-2 through MM4.2-29 would also apply to this impact. (Impact 4.2-7)
Project Analysis and Conclusion
The City determined that impacts related to increased local traffic volumes (Impact 5.2-3) and
SCAG growth projections (Impact 4.2-4) were below the level of significance and did not require
mitigation. Impacts related to objectionable odors (Impact 4.2-1), criteria pollutants (Impact 4.2-
2), contribute to an air quality violation (Impact 4.2-5) were less than significant with the
implementation of mitigation measures. Impacts related to exceeding criteria pollutants during
operations (Impact 4.2-6) and construction (Impact 4.2-7) were significant and unavoidable, and
that specific economic, social, or other considerations make infeasible additional mitigation.
Specifically, no additional feasible mitigation measures exist that would avoid or substantially
reduce these impacts.
Planning Commission 1 – 98 3/6/2025
January 2025 24 Environmental Analysis
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of a supplemental or subsequent EIR because the
project modifies the list of land uses and permit types including the deletion of industrial land
uses; amend nonconforming regulations including the additional of an amortization process;
amend and add operational standards for allowed uses and nonconforming uses; and delete
the Industrial Overlay (I-OZ) zone from text and maps; and delete the M1 (Light Industrial) and
M2 (Heavy Industrial) suffixes from certain properties within the TZC area. Thus, there are no
new land uses being introduced that would have air quality impacts. The proposed amendments
will introduce new regulations for nonconforming industrial use that would discontinue
nonconforming noxious uses, establish screening walls, eliminate vehicle servicing on Sundays.
These regulations would reduce dust and lessen air quality emissions. No land use shall
generate or cause any visible dust, gases, or smoke to be emitted into the atmosphere. Uses,
activities, and processes shall not operate in a manner that emits dust, fumes, odors, smoke, or
particulate matter, unless authorized under Federal, State, or local law. Sources of air
emissions shall comply with all rules established by the Environmental Protection Agency (Code
of Federal Regulations, Title 40), the California Air Resources Board, and the South Coast Air
Quality Management District. These regulations will have a beneficial impact to air quality.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. In addition, compliance with the existing regulations and proposed amendments will
assure that potential impacts are not exacerbated, which will result in a beneficial impact to air
quality. Mitigation measures MM4.2-1 through MM4.2-36 would continue to apply. Therefore,
the project does not trigger new air quality impacts requiring the preparation of a subsequent or
supplemental EIR. There would be no new or more severe significant impacts to air quality.
5.3 BIOLOGICAL RESOURCES
This section analyzes the effects to biological resources from implementing the proposed
zoning code regulations.
Would the project:
a. Have a substantial adverse effect, either directly or through habitat modifications, on any
species identified as a candidate, sensitive, or special status species in local or regional
plans, policies, or regulations, or by the California Department of Fish and Wildlife or
U.S. Fish and Wildlife Service?
b. Have a substantial adverse effect on any riparian habitat or other sensitive natural
community identified in local or regional plans, policies, regulations or by the California
Department of Fish and Game or U.S. Fish and Wildlife Service?
c. Have a substantial adverse effect on federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological
interruption, or other means?
d. Interfere substantially with the movement of any native resident or migratory fish or
wildlife species or with established native resident or migratory wildlife corridors, or
impede the use of native wildlife nursery sites?
e. Conflict with any local policies or ordinances protecting biological resources, such as a
tree preservation policy or ordinance?
f. Conflict with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
TZC EIR Conclusions
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January 2025 25 Environmental Analysis
• No endangered, rare, threatened, or special status plant species (or associated
habitats) or wildlife species designated by the USFWS, CDFG, or CNPS are known to
occur or expected to occur within the Transit Zoning Code (SD 84A and SD 84B) area.
(DEIR Section 4.3.3: Effects Found to Have No Impact)
• No riparian habitat or other sensitive natural communities are located in these areas.
(DEIR Section 4.3.3: Effects Found to Have No Impact)
• The Transit Zoning Code (SD 84A and SD 84B) area is not in proximity to, nor does it
contain, wetland habitat or a blueline stream. (DEIR Section 4.3.3: Effects Found to
Have No Impact)
• The Transit Zoning Code (SD 84A and SD 84B) is surrounded by urban uses on all four
sides, including two highways, and, therefore, does not function as a wildlife movement
corridor. (DEIR Section 4.3.3: Effects Found to Have No Impact)
• Implementation of the project would not conflict with any local policies or ordinances
protecting biological resources. (DEIR Section 4.3.3: Effects Found to Have No Impact)
• No conflict with an adopted habitat conservation plan, Orange County NCCP/HCP or
other local, regional, or state habitat conservation plan would occur, and there would be
no impact. (DEIR Section 4.3.3: Effects Found to Have No Impact)
• Long-term cumulative development occurring pursuant to the Transit Zoning Code
would not result in a potential reduction in nesting opportunities for resident and
migratory avian species of special concern. (Impact 4.3-1: Less Than Significant without
mitigation)
TZC EIR Mitigation Measures
MM4.3-1 To ensure that avian species of concern, protected migratory species (e.g., MBTA), or
raptors species are not injured or disturbed by construction in the vicinity of nesting habitat, the
project applicant shall implement the following measures:
1. Tree removal shall be restricted to the period between August 30 and February 15, to
the extent feasible, to avoid the breeding season of any migratory species that could be
using the area, and to discourage nesting in the vicinity of an upcoming construction
area. If it is not feasible to remove trees outside this window then, prior to the beginning
of mass grading, including grading for major infrastructure improvements, during the
period between February 15 and August 30, all trees within 250 feet of any grading or
earthmoving activity shall be surveyed for active nests by a qualified biologist no more
than 30 days prior to disturbance. If active nests are found, and the site is within 250
feet of potential construction activity, a temporary fence shall be erected, where
appropriate, around the tree(s) at a distance of up to 250 feet, depending on the
species, from the edge of the canopy to prevent construction disturbance and intrusions
on the nest area. The appropriate buffer shall be determined in consultation with the City
of Santa Ana Park Naturalist or a designee.
2. No construction vehicles shall be permitted within restricted areas (i.e., protection
zones), unless directly related to the management or protection of the legally protected
species.
3. If a legally protected species nest is located in a tree designated for removal, the
removal shall be deferred until after August 30, or until the adults and young of the year
are no longer dependent on the nest site as determined by a qualified biologist. (Impact
4.3-1)
Project Analysis and Conclusion
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January 2025 26 Environmental Analysis
The City determined that impacts related to endangered, rare, threatened, or special status
plant species or associated habitats or wildlife species, riparian habitat and sensitive natural
communities, wetlands or blue line streams, wildlife movement corridors, habitat conservation
plans, and biological resource policies would not have any impacts. Impacts to avian species
were less than significant with implementation of the mitigation measures.
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of a supplemental or subsequent EIR because the
TZC area is intended to be developed for urban uses and located in an area that is completely
developed for urban uses. Because TZC area is a heavily disturbed and graded area consisting
of industrial and residential uses, and the project does not introduce any new types of land use,
and instead removes the industrial overlay zone, there will be no impacts to biological
resources.
Any future development within the TZC area requiring discretionary action would be subject to a
project-level CEQA review at the time an application is filed for an individual project. In addition,
compliance with the existing regulations and proposed regulations will assure that potential
impacts are not exacerbated, which will result in a beneficial impact to biological resources. The
project does not trigger new biological resource impacts requiring the preparation of a
subsequent or supplemental EIR. Mitigation measure MM4.3-1 would continue to apply. There
would be no new or more significant impacts to biological resources.
5.4 CULTURAL RESOURCES
This section analyzes the effects to cultural resources and tribal cultural resources from
implementing the proposed zoning code regulations.
Would the project:
a. Cause a substantial adverse change in the significance of a historical resource as
defined in §15064.5 of the CEQA Guidelines?
b. Cause a substantial adverse change in the significance of an archaeological resource
pursuant to §15064.5 of the CEQA Guidelines?
c. Directly or indirectly destroy a unique paleontological resource or unique geologic
feature?
d. Disturb any human remains, including those interred outside of dedicated cemeteries?
TZC EIR Conclusions
• Long-term cumulative development occurring pursuant to the Transit Zoning Code could
cause a substantial adverse change in the significance of an archaeological resource or
disturb human remains. (Impact 4.4-1: Less Than Significant with mitigation)
• Long-term cumulative development occurring pursuant to the Transit Zoning Code has
the potential to directly or indirectly destroy a unique paleontological resource or unique
geologic feature. (Impact 4.4-2: Less Than Significant with mitigation)
• The adoption of the Transit Zoning Code (SD 84A and SD 84B) would result in
substantial adverse change in the significance of a historical resource as defined in
Section 15064.5 of the CEQA Guidelines. (Impact 4.4-3: Significant and Unavoidable
and no feasible mitigation)
TZC EIR Mitigation Measures
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January 2025 27 Environmental Analysis
MM4.4-1(a) Prior to any earth-disturbing activities (e.g., excavation, trenching, grading) that
could encounter undisturbed soils, the project applicant shall retain an archaeologist who meets
the Secretary of the Interior’s Professional Qualifications Standards for Archaeology to
determine if the project could result in a substantial adverse change in the significance of an
archaeological resource pursuant to Section 15064.5 of the CEQA Guidelines or disturb human
remains. The investigation shall include, as determined appropriate by the archaeologist and
the City of Santa Ana, an updated records search of the South Central Coastal Information
Center (SCCIC) of the California Historical Resources Information System (CHRIS), updated
Native American consultation, and a pedestrian survey of the area proposed for development.
The results of the investigation shall be documented in a technical report or memorandum that
identifies and evaluates any archaeological resources within the development area and includes
recommendations and methods for eliminating or avoiding impacts on archaeological resources
or human remains. The measures shall include, as appropriate, subsurface testing of
archaeological resources and/or construction monitoring by a qualified professional and, if
necessary, appropriate Native American monitors identified by the applicable tribe (e.g., the
Gabrieliño Tongva Nation) and/or the Native American Heritage Commission. The methods
shall also include procedures for the unanticipated discovery of human remains, which shall be
in accordance with Section 5097.98 of the State Public Resources Code and Section 7050.5 of
California’s Health and Safety Code. The technical report or memorandum shall be submitted to
the City of Santa Ana for approval. As determined necessary by the City, environmental
documentation (e.g., CEQA documentation) prepared for future development within the project
site shall reference or incorporate the findings and recommendations of the technical report or
memorandum. The project applicant shall be responsible for implementing methods for
eliminating or avoiding impacts on archaeological resources identified in the technical report or
memorandum. Projects that would not encounter undisturbed soils and would therefore not be
required to retain an archaeologist shall demonstrate non-disturbance to the City through the
appropriate construction plans or geotechnical studies prior to any earth-disturbing activities.
Projects that would include any earth disturbance (disturbed or undisturbed soils) shall comply
with MM4.4-2(b). (Impact 4.4-1)
MM4.4-1(b) If evidence of an archaeological site or other suspected historical resource as
defined by CEQA Guidelines Section 15064.5, including darkened soil representing past human
activity (“midden”), that could conceal material remains (e.g., worked stone, fired clay vessels,
faunal bone, hearths, storage pits, or burials) are discovered during any project-related earth-
disturbing activities (including projects that would not encounter undisturbed soils), all earth-
disturbing activity within 100 feet of the find shall be halted and the City of Santa Ana shall be
notified. The project applicant shall retain an archaeologist who meets the Secretary of the
Interior’s Professional Qualifications Standards for Archaeology to assess the significance of
the find. Impacts to any significant resources shall be mitigated to a less-than-significant level
through data recovery or other methods determined adequate by the archaeologist and that are
consistent with the Secretary of the Interior's Standards for Archaeological Documentation. Any
identified cultural resources shall be recorded on the appropriate DPR 523 (A-L) form and filed
with the SCCIC. (Impact 4.4-1)
MM4.4-2(a) Prior to any earth-disturbing activities (e.g., excavation, trenching, grading) that
could encounter undisturbed soils, the project applicant shall retain a professional
paleontologist to determine if the project could directly or indirectly destroy a unique
paleontological resource or site or unique geologic feature. The investigation shall include, as
determined appropriate by the paleontologist and the City of Santa Ana, a paleontology records
check and a pedestrian survey of the area proposed for development. The results of the
investigation shall be documented in a technical report or memorandum that identifies the
paleontological sensitivity of the development area and includes recommendations and
methods for eliminating or avoiding impacts on paleontological resources or unique geologic
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features. The technical report or memorandum shall be submitted to the City for approval. As
determined necessary by the City, environmental documentation (e.g., CEQA documentation)
prepared for future development within the project site shall reference or incorporate the
findings and recommendations of the technical report or memorandum. The project applicant
shall be responsible for implementing methods for eliminating or avoiding impacts on
paleontological resources or unique geologic features identified in the technical report or
memorandum. Projects that would not encounter undisturbed soils and would therefore not be
required to retain a paleontologist shall demonstrate non-disturbance to the City through the
appropriate construction plans or geotechnical studies prior to any earth-disturbing activities.
Projects that would include any earth disturbance (disturbed or undisturbed soils) shall comply
with MM4.4-3(b). (Impact 4.4-2)
MM4.4-2(b) Should paleontological resources (i.e., fossil remains) be identified at a particular
site during project construction, the construction foreman shall cease construction within 100
feet of the find until a qualified professional can provide an evaluation. Mitigation of resource
impacts shall be implemented and funded by the project applicant and shall be conducted as
follows:
1. Identify and evaluate paleontological resources by intense field survey where impacts
are considered high
2. Assess effects on identified sites
3 Consult with the institutional/academic paleontologists conducting research
investigations within the geological formations that are slated to be impacted
4. Obtain comments from the researchers
5. Comply with researchers’ recommendations to address any significant adverse effects
where determined by the City to be feasible
In considering any suggested mitigation proposed by the consulting paleontologist, the City of
Santa Ana staff shall determine whether avoidance is necessary and feasible in light of factors
such as the nature of the find, project design, costs, applicable policies and land use
assumptions, and other considerations. If avoidance is unnecessary or infeasible, other
appropriate measures (e.g., data recovery) shall be instituted. Work may proceed on other
parts of the project site while mitigation for paleontological resources is carried out. (Impact 4.4-
2)
MM4.4-3 Prior to development activities that would demolish or otherwise physically affect
buildings or structures 50 years old or older or affect their historic setting, the project applicant
shall retain a cultural resource professional who meets the Secretary of the Interior’s
Professional Qualifications Standards for Architectural History to determine if the project would
cause a substantial adverse change in the significance of a historical resource as defined in
Section 15064.5 of the CEQA Guidelines. The investigation shall include, as determined
appropriate by the cultural resource professional and the City of Santa Ana, the appropriate
archival research, including, if necessary, an updated records search of the South Central
Coastal Information Center (SCCIC) of the California Historical Resources Information System
(CHRIS) and a pedestrian survey of the proposed development area to determine if any
significant historic-period resources would be adversely affected by the proposed development.
The results of the investigation shall be documented in a technical report or memorandum that
identifies and evaluates any historical resources within the development area and includes
recommendations and methods for eliminating or reducing impacts on historical resources. The
technical report or memorandum shall be submitted to the City Santa Ana for approval. As
determined necessary by the City, environmental documentation (e.g., CEQA documentation)
prepared for future development within the project site shall reference or incorporate the
findings and recommendations of the technical report or memorandum. The project applicant
shall be responsible for implementing methods for eliminating or reducing impacts on historical
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January 2025 29 Environmental Analysis
resources identified in the technical report or memorandum. Such methods could include, but
not be limited to, written and photographic recordation of the resource in accordance with the
level of Historic American Building Survey (HABS) documentation that is appropriate to the
significance (local, state, national) of the resource. (Impact 4.4-3)
Project Analysis and Conclusion
The City determined that impacts related to archaeological resources (Impact 4.4-1) unique
paleontological resources (Impact 4.4-2), and disturbing human remains were less than
significant with the implementation of mitigation measures. Impacts related to historical
resources (Impact 4.4-3) were found to be significant and unavoidable and that specific
economic, social, or other considerations make infeasible additional mitigation. Specifically, no
additional feasible mitigation measures exist that would avoid or substantially reduce these
impacts.
The TZC EIR states that there are 80 designated historic properties that are listed on the Santa
Ana Register of Historical Properties, five that are listed on the California Points of Historical
Interest, and one that is listed on the California Historical Landmarks within and adjacent to the
TZC area.
The TZC area has already been subject to extensive disruption from previous development and
may contain artificial fill materials. The proposed adoption of the text regulations identified in
Table 1 – Current and Proposed Text Regulations would not require preparation of a
supplemental or subsequent EIR because specific development projects are neither included
nor required, nor would the project introduce new land uses that would have impact to cultural
or tribal cultural resources that could otherwise make the long-term significant and unavoidable
historical resource impacts more severe.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. In addition, compliance with the existing regulations and proposed amendments will
assure that potential impacts are not exacerbated. Mitigation measures MM4.4-1(a), MM4.4-
1(b), MM4.4-2(a), MM4.2(b), and MM4.4-3 would continue to apply. In addition, compliance with
the existing regulations and proposed regulations identified in Table 1 – Current and Proposed
Text Regulations will assure that potential impacts are not exacerbated, which will result in a
beneficial impact to cultural resources. Therefore, the project does not trigger new cultural or
tribal cultural resource impacts requiring the preparation of a subsequent or supplemental EIR.
There would be no new or more severe significant impacts to cultural and tribal cultural
resources.
5.5 HAZARDS AND HAZARDOUS MATERIALS
This section analyzes the effects to hazards and hazardous materials from implementing the
proposed zoning code regulations.
Would the project:
a. Create a significant hazard to the public or the environment through the routine
transport, use, or disposal of hazardous materials?
b. Create a significant hazard to the public or the environment through reasonably
foreseeable upset and accident conditions involving the release of hazardous materials
into the environment?
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c. Emit hazardous emissions or handle hazardous or acutely hazardous materials,
substances, or waste within one-quarter mile of an existing or proposed school?
d. Be located on a site which is included on a list of hazardous materials sites compiled
pursuant to Government Code Section 65962.5 and, as a result, would it create a
significant hazard to the public or the environment?
e. For a project located within an airport land use plan or, where such a plan has not been
adopted, within two miles of a public airport or public use airport, would the project result
in a safety hazard for people residing or working in the project area?
f. For a project within the vicinity of a private airstrip, would the project result in a safety
hazard for people residing or working in the project area?
g. Impair implementation of or physically interfere with an adopted emergency response
plan or emergency evacuation plan?
h. Expose people or structures to a significant risk of loss, injury, or death involving
wildland fires, including where wildlands are adjacent to urbanized areas or where
residences are intermixed with wildlands?
TZC EIR Conclusions
• A private airstrip/heliport is not known to be located within the Transit Zoning Code (SD
84A and SD 84B) area, nor is the Transit Zoning Code (SD 84A and SD 84B) area
located in close proximity to a private airstrip/heliport. (DEIR Section 4.5.3: Effects
Found to Have No Impact)
• The Transit Zoning Code (SD 84A and SD 84B) area is located in a dense urban
environment and is surrounded by existing development. There are no wildland areas,
nor wildland interface areas located in the vicinity. Consequently, no wildland fires would
affect, or be affected by, implementation of the proposed Transit Zoning Code (SD 84A
and SD 84B). (DEIR Section 4.5.3: Effects Found to Have No Impact)
• Long-term cumulative development occurring pursuant to the Transit Zoning Code could
involve the transportation, use, storage, and/or disposal of hazardous materials, such as
diesel exhaust. (Impact 4.5-1: Less Than Significant without mitigation)
• Construction activities associated with implementation of the proposed Transit Zoning
Code (SD 84A and SD 84B) would result in the release of hazardous materials to the
environment through reasonably foreseeable upset and accident conditions. (Impact
4.5-2: Less Than Significant with mitigation)
• Construction activities associated with the implementation of the Transit Zoning Code
would result in the handling of hazardous materials, substances, or waste within one-
quarter mile of an existing school. (Impact 4.5-3: Less Than Significant without
mitigation)
• The Transit Zoning Code (SD 84A and SD 84B) includes sites which are included on a
list of hazardous materials sites and as a result, would create a significant hazard to the
public or environment. (Impact 4.5-4: Less Than Significant with mitigation)
• Construction activities associated with the implementation of the Transit Zoning Code
could result in a safety hazard for people residing or working in the project area. (Impact
4.5-5: Less Than Significant with mitigation)
• The Transit Zoning Code could impair the implementation of, or physically interfere with,
an adopted emergency response plan or emergency evacuation plan resulting in a
significant impact. (Impact 4.5-6: Less Than Significant with mitigation)
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January 2025 31 Environmental Analysis
TZC EIR Mitigation Measures
MM4.5-1 When sites that are listed in the EDR Report initiate project development, the project
applicant shall prepare a Phase I ESA for the proposed site. The Phase I ESA shall be
prepared in accordance with ASTM E-1527-05 “Standard Practice for Environmental Site
Assessments: Phase I Environmental Site Assessment Process” (November 1, 2006). The
purpose of a Phase I ESA is to identify environmental conditions at a proposed project site that
may suggest environmental contamination. The Phase I ESA report shall be prepared by a CA
EPA Registered Environmental Assessor or similarly qualified individual prior to initiating any
construction activities at the site.
If recommended in the Phase I ESA, the project sponsor shall undertake (or require the
responsible party to undertake) a Phase II ESA soil sampling plan; or if any environmental
contamination is identified by the Phase I ESA, the project sponsor shall implement (or require
the responsible party to implement) the recommendations of the report to further investigate
and to remove any soil contamination. (Impact 4.5-2)
MM4.5-2 In the event that previously unknown or unidentified soil and/or groundwater
contamination that could present a threat to human health or the environment is encountered
during construction in the Transit Zoning Code (SD 84A and SD 84B) area, construction
activities in the immediate vicinity of the contamination shall cease immediately. If
contamination is encountered, a Risk Management Plan shall be prepared and implemented
that (1) identifies the contaminants of concern and the potential risk each contaminant would
pose to human health and the environment during construction and post-development and (2)
describes measures to be taken to protect workers, and the public from exposure to potential
site hazards. Such measures could include a range of options, including, but not limited to,
physical site controls during construction, remediation, long-term monitoring, post-development
maintenance or access limitations, or some combination thereof. Depending on the nature of
contamination, if any, appropriate agencies shall be notified (e.g., Santa Ana Fire Department).
If needed, a Site Health and Safety Plan that meets Occupational Safety and Health
Administration requirements shall be prepared and in place prior to commencement of work in
any contaminated area. (Impact 4.5-2)
MM4.5-3 Prior to the demolition of structures that were constructed before 1980, a thorough
investigation shall be completed to determine if asbestos, lead, or PCBs exist on the site. All
demolition that could result in the release of lead and/or asbestos must be conducted according
to Cal/OSHA standards. (Impact 4.5-2)
MM4.5-4 For development of structures that exceed 200 feet in height above ground level at a
development site, applicants shall file a Notice of Proposed Construction or Alteration with the
FAA (FAA Form 7460-1). Following the FAA’s aeronautical evaluation of the project, projects
must comply with conditions of approval imposed or recommended by the FAA. Subsequent to
the FAA findings, the project shall be reviewed by the ALUC for consistency analysis. (Impact
4.5-5)
MM4.5-5 Prior to initiation of construction activities, any development within the Transit Zoning
Code (SD 84A and SD 84B) Area shall have a completed traffic control plan, prepared by the
project proponent that will be implemented during construction activities. This may include, but
is not limited to, the maintenance of at least one unobstructed lane in both directions on
surrounding roadways. At any time if only a single lane is available, the developer shall provide
a temporary traffic signal, signal carriers (i.e., flagpersons), or other appropriate traffic controls
to allow travel in both directions. If construction activities require the complete closure of a
roadway segment, the developer shall provide appropriate signage indicating alternative routes.
(Impact 4.5-6)
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MM4.5-6 The City Public Works Department shall consult with the Santa Ana Police
Department and the Santa Ana Fire Department to disclose temporary closures and alternative
travel routes in order to ensure adequate access for emergency vehicles when construction of
future projects would result in temporary land or roadway closures. (Impact 4.5-6)
MM4.5-7 The Santa Ana Fire Department, in consultation with other applicable City
Departments (e.g., Police), shall update their Emergency Preparedness Plan prior to occupancy
of the first project developed under the Transit Zoning Code (SD 84A and SD 84B), to address
the potential for the accidental release of hazardous materials that may be used, stored, and/or
transported in association with operation of project implementation. (Impact 4.5-6)
MM4.5-8 Project applicants shall submit evacuation plans on a project by project basis that
shall be reviewed and approved by the City Police and Fire Departments. (Impact 4.5-6)
Project Analysis and Conclusion
The City determined that impacts related to people residing or working in the vicinity of a private
airstrip/heliport and wildland areas would have no impact (DEIR Section 4.5.3: Effects Found to
Have No Impact). Impacts related to transportation, storage and disposal of hazardous
materials (Impact 4.5-1) and handling of hazardous materials near a school (Impact 4.5-3) were
below the level of significance and did not require mitigation. Impacts related to reasonably
upset of hazardous materials into the environment (Impact 4.5-2), hazardous materials sites
(Impact 4.5-4), construction safety hazards for people or residing in the TZC area (Impact 4.5-
5) and interference with an adopted emergency response plan (Impact 4.5-6) were less than
significant with the implementation of mitigation measures.
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of a supplemental or subsequent EIR because
specific development projects are neither included nor required. The new regulations would
require that no material or waste shall be deposited upon a subject parcel in such form or
manner that it may be transferred off the parcel by natural causes or forces and that all
materials or wastes which might cause fumes or dust, or which constitute a fire hazard, or
which may be edible by or otherwise be attractive to rodents or insects shall be stored outdoors
only in closed containers. Land or buildings shall not be used or occupied in any manner so as
to create any fire, explosive or other hazard. All activities involving the use or storage of
combustible, explosive, caustic, or otherwise hazardous materials shall comply with all
applicable local, State, and Federal safety standards and shall be provided with adequate
safety devices against the hazard of fire and explosion, and adequate firefighting and fire
suppression equipment in compliance with City of Santa Ana regulations. The burning of waste
materials in open fires without written approval of the Fire Department is prohibited. No
activities shall be permitted which emit dangerous radioactivity at any point nor shall electrical
disturbances which adversely affect the operation of any equipment, other than that of the
creator of such disturbances, be allowed. No use, activity or process shall cause
electromagnetic interference with normal radio and television reception, or with the function of
other electronic equipment beyond the property line of the site in which it is situated. All uses,
activities and processes shall comply with applicable Federal Communications Commission
regulations.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. Mitigation measures MM4.5-1 through MM4.5-8 would continue to apply. Therefore, the
project does not trigger new hazards and hazardous materials impacts requiring the preparation
of a subsequent or supplemental EIR. In addition, compliance with the existing regulations and
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January 2025 33 Environmental Analysis
proposed amendments will assure that potential impacts to hazards and hazardous materials
are not exacerbated. There would be no new or more severe significant impacts to hazards and
hazardous materials.
5.6 HYDROLOGY AND WATER QUALITY
This section analyzes the effects to hydrology and water quality from implementing the
proposed zoning code regulations.
Would the project:
a. Violate any water quality standards or waste discharge requirements?
b. Substantially deplete groundwater supplies or interfere substantially with groundwater
recharge such that there would be a net deficit in aquifer volume or a lowering of the
local groundwater table level (e.g., the production rate of pre-existing nearby wells
would drop to a level that would not support existing land uses or planned uses for
which permits have been granted)?
c. Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of stream or river, in a manner that would result in substantial
erosion or siltation on or off site?
d. Substantially alter the existing drainage pattern of the site or area, including through the
alteration of the course of a stream or river, or substantially increase the rate or amount
of surface runoff in a manner that would result in flooding on or off site?
e. Create or contribute runoff water which would exceed the capacity of existing or planned
stormwater drainage systems or provide substantial additional sources of polluted
runoff?
g. Otherwise substantially degrade water quality?
h. Place housing within a 100-year flood hazard area as mapped on a federal Flood
Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map?
i. Place within a 100-year flood hazard area structures, which would impede or redirect
flood flows?
j. Expose people or structures to a significant risk of loss, injury, or death involving
flooding, including flooding as a result of the failure of a levee or dam?
k. Expose people or structures to a significant risk of loss, injury, or death involving
inundation by seiche, tsunami, or mudflow?
TZC EIR Conclusions
• The Transit Zoning Code (SD 84A and SD 84B) area is not located within a 100-year
flood hazard area as mapped on a federal Flood Hazard Boundary or Flood Insurance
Rate Map or other flood hazard delineation map, and is not within the 100-year or 500-
year flood hazard area. (DEIR Section 4.6.3: Effects Found to Have No Impact)
• The Transit Zoning Code (SD 84A and SD 84B) area is not within the 100-year flood
hazard area, (DEIR Section 4.6.3: Effects Found to Have No Impact)
• The Transit Zoning Code (SD 84A and SD 84B) area is not located in the flood
inundation area of the Prado Dam or the Santiago Dam. (DEIR Section 4.6.3: Effects
Found to Have No Impact)
• The proposed Transit Zoning Code (SD 84A and SD 84B) would not expose people to a
significant risk of loss, injury, or death involving inundation by a seiche, tsunami, or
mudflow because the project site is not located near a coastal area, large water body, or
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January 2025 34 Environmental Analysis
unstable and exposed hills or slopes. (DEIR Section 4.6.3: Effects Found to Have No
Impact)
• Implementation of the Transit Zoning Code would not violate water quality standards,
waste discharge, or otherwise substantially degrade water quality. (Impact 4.6-1: Less
Than Significant with mitigation)
• The majority of the Transit Zoning Code (SD 84A and SD 84B) area is already
developed and because the project area is not used for groundwater recharge, the
operation of future development under the proposed project would not interfere
substantially with groundwater recharge. (Impact 4.6-2: Less Than Significant without
mitigation with mitigation)
• Development under the Transit Zoning Code (SD 84A and SD 84B) could alter the
existing drainage pattern of the area and potentially result in erosion and siltation.
(Impact 4.6-3: Less Than Significant)
• Future development in the Transit Zoning Code (SD 84A and SD 84B) could alter the
existing drainage pattern and potentially result in increased downstream flooding
through the addition of impervious surfaces, or exceeding the capacity of existing or
planned stormwater drainage systems. (Impact 4.6-4: Less Than Significant with
mitigation)
TZC EIR Mitigation Measures
MM4.6-1 In order to comply with the current version of the Drainage Area Master Plan (DAMP),
future development projects in the Transit Zoning Code (SD 84A and SD 84B) area shall
prepare Storm Drain Plans, Stormwater Pollution Prevention Plans (SWPPP), and Water
Quality Management Plans (WQMP) conforming to the current National Pollutant Discharge
Elimination System (NPDES) requirements, prepared by a Licensed Civil Engineer or
Environmental Engineer, shall be submitted to the Public Works Agency for review and
approval.
a. A SWPPP shall be prepared and updated as needed during the course of construction to
satisfy the requirements of each phase of the development. The plan shall incorporate all
necessary Best Management Practices (BMPs) and other City requirements to eliminate
polluted runoff until all construction work for the project is completed. The SWPPP shall include
treatment and disposal of all dewatering operation flows, and for nuisance flows during
construction. The SWPPP may include, but would not necessarily be limited to, the following
applicable measures:
o Minimum required pavement widths for residential streets needed to comply with all
zoning and applicable ordinances
o Use permeable materials for private sidewalks, driveways, parking lots, or interior
roadway surfaces
o Reduce the overall imperviousness associated with parking lots by using pervious
materials in spillover parking areas
o Direct rooftop runoff to pervious areas and avoid routing rooftop runoff to the roadway or
the stormwater conveyance system
o Biofilters including vegetated swales and strips
o Extended/dry detention basins
o Infiltration basin
o Infiltration trenches or vaults
o Catch basin inserts
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o Continuous flow deflection/separation systems
o Storm drain inserts
o Media filtration
o Foundation planting
o Catch basin screens
o Normal flow storage/separation systems
o Clarifiers
o Filtration systems
o Primary waste water treatment systems
o Dry Wells
o Cistern
b. A WQMP shall be prepared, maintained, and updated as needed to satisfy the requirements
of the adopted NPDES program. The plan shall incorporate water quality measures for all
improved phases of the project. (Impact 4.6-1 and Impact 4.6-3)
MM4.6-2 Prior to issuance of grading permits for future development projects in the Transit
Zoning Code (SD 84A and SD 84B) area, applicants shall submit site-specific Hydrology and
Hydraulic Studies to the Public Works Department for review and approval. If existing facilities
are not adequate to handle runoff that may be generated by the proposed development, then
the applicant shall propose feasible remedies to assure that adequate drainage facilities will be
available prior to issuance of occupancy permits. The applicant may propose storm drain
improvements to be constructed in order to meet project needs. If necessary storm drain
upgrades cannot be implemented prior to issuance of occupancy permits, on site detention
facilities or other methods acceptable to the City shall be included with new development
projects to ensure that post-construction runoff does not exceed pre-development quantities.
(Impact 4.6-4)
MM4.6-3 During the design of individual projects, applicants shall minimize impervious area by
incorporating landscaped areas over substantial portions of a proposed project area.
Furthermore, impervious areas shall be directly connected to landscaped areas or bioretention
facilities to promote filtration and infiltration of stormwater. (Impact 4.6-4)
MM4.6-4 During the design of individual projects, applicants shall control structural source
through storm drain stenciling and signage, coverage of trash area to minimize direct
precipitation, efficient irrigation to minimize runoff into stormwater conveyance system, slope
and channel protection to decrease potentials for erosions of slopes, and use of deep-rooted,
drought tolerant plant species for erosion control. (Impact 4.6-4)
Project Analysis and Conclusion
The City determined that impacts related to within a 100-year flood hazard area, flood
inundation area, inundation from the Prado Dam, a seiche, tsunami, or mudflow would have no
impacts (DEIR Section 4.6-3). Impacts related to interference with groundwater recharge
(Impact 4.5-1), alteration to existing drainage patterns (Impact 4.6-3) and increased
downstream flooding (Impact 4.6-4) were less than significant with the implementation of
mitigation measures.
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of specific development projects, introduce new land
uses nor increase the intensity the existing uses. The new regulations would require liquid or
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January 2025 36 Environmental Analysis
solid wastes discharged from future development projects be properly treated and would
therefore not pollute or contaminate any water courses or groundwater.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. Mitigation measures MM4.6-1 through MM4.6-4 would continue to apply. Therefore, the
project does not trigger new hydrology and water quality impacts requiring the preparation of a
subsequent or supplemental EIR. In addition, compliance with the existing regulations and
proposed amendments will assure that potential impacts are not exacerbated. Therefore, there
would be no new or more severe significant impacts to hydrology and water quality.
5.7 LAND USE
This section analyzes the effects on land use from implementing the proposed zoning code
regulations.
Would the project:
a. Introduce new land uses that would result in conflicts of use?
b. Physically divide an established community?
c. Conflict with any applicable land use plan, policy, or regulation of an agency with
jurisdiction over the project (including, but not limited to the general plan, specific plan,
local coastal program, or zoning ordinance) adopted for the purpose of avoiding or
mitigating an environmental effect.?
d. Conflict with any applicable habitat conservation plan or natural community conservation
plan?
TZC EIR Conclusions
• The Transit Zoning Code (SD 84A and SD 84B) area is not located within either a
natural community plan or applicable habitat conservation plan. The Transit Zoning
Code (SD 84A and SD 84B) area does not contain any critical or sensitive habitat.
(DEIR Section 4.6.3: Effects Found to Have No Impact)
• The Transit Zoning Code (SD 84A and SD 84B) would not result in conflicts of use.
(Impact 4.7-1: Less Than Significant without mitigation)
• The proposed Transit Zoning Code (SD 84A and SD 84B) would not physically divide an
established community. (Impact 4.7-2: Less Than Significant without mitigation)
• The proposed Transit Zoning Code (SD 84A and SD 84B) would conflict with the Santa
Ana General Plan by adopting standards and land uses not currently allowed within the
proposed Transit Zoning Code (SD 84A and SD 84B) area; however, as part of the
proposed project, the General Plan would be amended to incorporate the proposed land
uses and development standards. (Impact 4.7-3: Less Than Significant without
mitigation)
TZC EIR Mitigation Measures
All impacts were below the level of significance and mitigation measures are not necessary nor
recommended.
Planning Commission 1 – 111 3/6/2025
January 2025 37 Environmental Analysis
Project Analysis and Conclusion
The City determined that impacts related to conflicts with a natural community plan or
applicable habitat conservation plan would have no impacts (DEIR Section 4.6.3: Effects Found
to Have No Impact). Impacts related to incompatible land uses (Impact 4.7-1), potential to
divide an established community (Impact 4.7-2), and conflicts with the Santa Ana General Plan
(Impact 4.7-3) were below the level of significance and did not require mitigation.
The proposed zoning ordinance amendments are consistent with various goals and policies of
the Santa Ana General Plan, as required by Government Code Section 65860, by timely
addressing current inconsistencies within an area of the City prioritized for addressing
environmental justice and impacts were found to be less than significant. In effect, the
amendments are necessary to address numerous policies of the General Plan that the current
TZC is found to be inconsistent with, that without such amendments, will continue the path of
irreconcilable land use patterns within the TZC area. Specifically, these policies include Policy
LU-1.1 (Compatible Uses), Policy LU-2.4 (Cost and Benefit of Development), Policy LU-3.8
(Sensitive Receptors), Policy LU-3.9 (Noxious, Hazardous, Dangerous, and Polluting Uses),
Policy LU-3.11 (Air Pollution Buffers), Policy LU-4.3 (Sustainable Land Use Strategies), Policy
LU-4.6 (Healthy Living Conditions), Policy CM-3.2 (Healthy Neighborhoods), Policy EP-1.9
(Avoid Conflict of Uses), Policy EP-3.3 (Mitigate Impacts), Policy CN-1.5 (Sensitive Receptor
Decisions), Policy CM-3.2 (Healthy Neighborhoods), and Policy HE-5.5 (Community
Development), which are targeted at correcting past land use planning practices that have
placed an unequitable environmental and health burden on certain neighborhoods now termed
disadvantaged communities.
The proposed amendments support these goals and policies by:
• Fostering the compatibility between residential and nonresidential land uses within
the TZC to enhance livability and promote healthier lifestyles.
• Resolving the conflict of industrial land uses and sensitive receptors being in close
proximity to each other that pose health hazards by eliminating an overlay zone that
promulgated continuation of industrial uses without recourse.
• Improving the health of the existing and future residents of the TZC by regulating the
operations of noxious, hazardous, dangerous, and polluting uses by giving priority to
the discontinuance of those uses.
• Responding to overarching EJ policies to develop and implement land use and
zoning strategies to separate existing sensitive uses from heave industrial facilities
and emission sources.
• Continuing to support the creation of healthy neighborhoods by addressing land use
conflicts and incompatible uses through the elimination of the I-OZ zone and
associated industrial land use types from the list of allowable land uses within the
TZC.
• Developing and adopting new regulations to address facilities that emit high levels
increased pollution near sensitive receptors within EJ (Environmental Justice) area
boundaries, which includes areas of the TZC.
• Avoiding potential land use conflicts in the future by prohibiting the location of
noxious land uses in proximity to sensitive receptors
• Creating a sustainable land use plan for the area that phases out land uses that are
causing a substantial drain on City and other public agency resources in addressing
the impacts from irreconcilable land use conflicts in the TZC area.
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January 2025 38 Environmental Analysis
Additionally, the proposed amendments implement and/or contribute to achieving the following
specific action programs of the General Plan, most particularly directly addressing LU3.3
through discontinuing nonconforming industrial uses through amortization:
LU1.1 - Development Code Update. Prepare a comprehensive update to the zoning
code to ensure that the City’s zoning regulations align with the General Plan’s goals and
policies. Update the Metro East Mixed-Use Overlay District to remove the portion within
the 17th Street and Grand Avenue Focus Area. Update the Midtown Specific Plan.
LU3.3 - Healthy lifestyles. Collaborate with residents and industry stakeholders to create
a program to incentivize and amortize the removal of existing heavy industrial uses
adjacent to sensitive uses.
CN1.4 - Health risk criteria. Establish criteria for requiring health risk assessments for
existing and new industries, including the type of business, thresholds, and scope of
assessment. Review existing and establish new regulation to reduce and avoid
increased pollution near sensitive receptors within environmental justice area
boundaries.
CN1.7 - Truck idling. Evaluate strategies to reduce truck idling found or reported in
areas with sensitive receptors, with a priority placed on environmental justice areas.
CN1.11 - Public education. Augment existing outreach programs to improve public
awareness of State, regional and local agencies’ roles and resources to identify,
monitor, and address air quality and other environmental hazards in the community.
HE5.C – Healthy Neighborhoods Initiatives. Update the City’s zoning code development
and operational standards for industrial zones to address incompatibility with adjacent
uses, including minimum distance requirements to buffer heavy industrial uses from
sensitive receptors. Conduct a study to evaluate and establish appropriate minimum
distances and landscape buffers between polluting industrial uses from sensitive
receptors such as residences.
HE44.A – Fair Housing. Ensure all City programs and activities relating to housing and
community development are administered in a manner that affirmatively furthers fair
housing.
Implementation of the proposed adoption of the text regulations identified in Table 1 – Current
and Proposed Text Regulations does not trigger new land use impacts that might otherwise
occur with a development project requiring preparation of a supplemental or subsequent EIR.
The new regulations would provide that any nonconforming business that operates in an
unlawful manner, including but not limited to, frequent code violations, police calls, or loitering
complaints, or is not in good standing with the City, including, but limited to constant service
calls or lapses in Business License renewal, will lose its nonconforming status, enabling the City
to take corrective action as it deems appropriate, including business license revocation or
terminating utility services or connections. For the purposes of this section, “frequent” is defined
as more than one violation, call, or complaint per month during any twelve month period, and
“constant service calls” is defined as more than one service call per month during any twelve
(12) month period.
Thus, the project would not physically divide an established community, or conflict with any land
use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an
environmental impact. In addition, compliance with the existing regulations and proposed
amendments will assure that potential impacts are not exacerbated. Therefore, the project does
not trigger new land use impacts requiring the preparation of a subsequent or supplemental
EIR. There would be no new or more severe significant impacts to land use.
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5.8 NOISE
This section analyzes the effects to noise from implementing the proposed zoning code
regulations.
Would the project:
a. Expose persons to or generate noise levels in excess of standards established in the
local general plan or noise ordinance, or applicable standards of other agencies?
b. Expose persons to or generate excessive groundborne vibration or groundborne noise
levels?
c. Cause a substantial permanent increase in ambient noise levels in the project vicinity
above levels existing without the project?
d. Cause a substantial temporary or periodic increase in ambient noise levels in the project
vicinity above levels existing without the project?
TZC EIR Conclusions
• The project is not located within an airport land use plan or within 2 miles of a public
airport or public use airport. (DEIR Section 4.8.3: Effects Found to Have No Impact)
• Construction activities associated with the proposed project would generate noise levels
that exceed the noise standards established by the City of Santa Ana Municipal Code.
(Impact 4.8-1: Less Than Significant with mitigation)
• Operation of the proposed project could expose noise-sensitive land uses to noise levels
that exceed the standards established by the City of Santa Ana General Plan. (Impact
4.8-2: Less Than Significant with mitigation)
• Operation of the proposed project would not expose sensitive receptors on or off site to
excessive groundborne vibration or groundborne noise levels, (Impact 4.8-3: Less Than
Significant without mitigation)
• Occupants of the proposed residential units would not be exposed to potentially
significant vibration levels. (Impact 4.8-4: Less Than Significant without mitigation)
• Physical impact from an increase in ambient noise levels could occur from the
construction activities associated with the proposed project, an adverse effect on the
nearby residents would not occur. (Impact 4.8-5: Less Than Significant)
• No temporary or periodic noise impacts to on- or off-site receptors due to operation of
the project. (Impact 4.8-6: Less Than Significant without mitigation)
• Operation of the proposed project would not generate increased local traffic volumes
that would cause a substantial permanent increase in ambient noise levels in the project
vicinity. (Impact 4.8-7: Less Than Significant without mitigation)Operation of the
Southern California Regional Rail Authority’s (SCRRA) rail line would potentially expose
noise-sensitive land uses located within the Transit Zoning Code (SD 84A and SD 84B)
area to noise levels that exceed the standards established by the City of Santa Ana
General Plan. (Impact 4.8-8: Significant and Unavoidable and no feasible mitigation)
• Construction activities associated with the proposed project would generate or expose
persons or structures to excessive groundborne vibration. (Impact 4.8-9: Significant and
Unavoidable and no feasible mitigation)
TZC EIR Mitigation Measures
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MM4.8-1 All construction activity within the City shall be conducted in accordance with Section
18-314(e) of the City of Santa Ana Municipal Code. (Impact 4.8-1 and Impact 4.8-9)
MM4.8-2 Each project applicant shall require by contract specifications that the following
construction best management practices (BMPs) be implemented by contractors to reduce
construction noise levels:
Two weeks prior to the commencement of construction, notification must be provided to
property owners within 300 feet of a project site disclosing the construction schedule,
including the various types of activities that would be occurring throughout the duration of
the construction period
Ensure that construction equipment is properly muffled according to industry standards and
be in good working condition
Place noise-generating construction equipment and locate construction staging areas away
from sensitive uses, where feasible
Schedule high noise-producing activities between the hours of 8:00 A.M. and 5:00 P.M. to
minimize disruption on sensitive uses
Implement noise attenuation measures, which may include, but are not limited to, temporary
noise barriers or noise blankets around stationary construction noise sources
Use electric air compressors and similar power tools rather than diesel equipment, where
feasible
Construction-related equipment, including heavy-duty equipment, motor vehicles, and
portable equipment, shall be turned off when not in use for more than 30 minutes
Construction hours, allowable workdays, and the phone number of the job superintendent
shall be clearly posted at all construction entrances to allow for surrounding owners and
residents to contact the job superintendent. If the City or the job superintendent receives a
complaint, the superintendent shall investigate, take appropriate corrective action, and
report the action taken to the reporting party.
Contract specifications shall be included in the proposed project construction documents,
which shall be reviewed by the City prior to issuance of a grading permit. (Impact 4.8-1)
MM4.8-3 Each project applicant shall require by contract specifications that construction
staging areas along with the operation of earthmoving equipment within the project area would
be located as far away from vibration and noise sensitive sites as possible. Contract
specifications shall be included in the proposed project construction documents, which shall be
reviewed by the City prior to issuance of a grading permit. (Impact 4.8-1 and Impact 4.8-9)
MM4.8-4 Each project applicant shall require by contract specifications that heavily loaded
trucks used during construction would be routed away from residential streets. Contract
specifications shall be included in the proposed project construction documents, which shall be
reviewed by the City prior to issuance of a grading permit. (Impact 4.8-1 and Impact 4.8-9)
MM4.8-5 When residential uses would be located in areas with noise levels in excess of 60 dBA
CNEL (either through conversion of use/structure or new construction), the project applicant
shall provide noise barriers around private open space areas, including patios and balconies, as
necessary. The height and density of the barriers shall be sufficient to reduce the exterior noise
levels within private open space areas to a CNEL of 65 dBA or less. (Impact 4.8-2)
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MM4.8-6 Prior to issuance of building permits, building plans shall specify the STC rating of
windows and doors for all residential land uses. Window and door ratings shall be sufficient to
reduce the interior noise level to a CNEL of 45 dBA or less, and shall be determined by a
qualified acoustical consultant as part of the final engineering design of the project. (Impact 4.8-
2)
MM4.8-7 Each project applicant shall provide proper shielding for all new HVAC systems used
by the proposed residential and mixed use buildings to achieve an attenuation of 15 dBA at 50
feet from the equipment. (Impact 4.8-2)
MM4.8-8 The City shall provide a written statement to each applicant for projects located within
400 feet of the SCRRA tracks that shall be provided for each residential unit and resident,
notifying them of potential noise and vibration issues associated with the railroad tracks,
including the following:
Notice of Disclosure
Each owner’s [or renter’s] interest is subject to the fact that trains operate at different
times of the day and night on the railway tracks immediately adjacent to a project site;
and that by accepting the conveyance of an interest [or lease agreement] in that project,
owner [or renter] accepts all impacts generated by the trains.
Posting of Notice of Disclosure in each residential unit.
Prior to offering the first residential unit for purchase, lease, or rent, the property owner
or developer shall post a copy of the Notice of Disclosure in every unit in a conspicuous
location. Also, a copy of the Notice of Disclosure shall be included in all materials
distributed for the Project, including but not limited to: the prospectus, informational
literature, and residential lease and rental agreements. (Impact 4.8-8)
Project Analysis and Conclusion
The City determined that no impacts related to the proximity public use airport would not result
in impacts would result. Impacts related to exposure of sensitive receptors from excessive
groundborne vibration (Impact 4.8-3), potentially significant vibration levels (Impact 4.8-4),
ambient noise increase (Impact 4.8-5), periodic noise impacts (Impact 4.8-6), and noise from
increased traffic volumes (Impact 4.8-7) were below the level of significance and did not require
mitigation. Impacts from noise levels exceeding City noise standards (Impact 4.8-1) and
exposure to noise-sensitive land uses (Impact 4.8-2) were less than significant with the
implementation of mitigation measures. Impacts causing groundborne vibration and
development exposure near the Southern California Regional Rail Authority’s (SCRRA) rail line
(Impact 4.8-8) and construction activities from project implementation (Impact 4.8-9) were found
to be significant and unavoidable. Specific economic, social, or other considerations make
infeasible additional mitigation. Specifically, no additional feasible mitigation measures exist that
would avoid or substantially reduce these impacts.
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of a supplemental or subsequent EIR because
specific development projects are neither included nor required. The new regulations would limit
daily operations times and days of week, and maximum noise that could be generated from
existing uses. No industrial use shall generate ground vibration perceptible without instruments
at any point along the property line of the site except for motor vehicle operations. No vibration
shall be produced that is transmitted through the ground and is discernible without the aid of
instruments by a reasonable person at the property lines of the site. Vibrations from temporary
construction, demolition, and vehicles that enter and leave the subject parcel are exempt from
this standard.
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Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. Mitigation measures MM4.8-1 through MM4.8-8 would continue to apply. In addition,
compliance with the existing regulations and proposed amendments will assure that potential
impacts are not exacerbated. This will result in a beneficial impact. Therefore, the existing less
than significant and significant and unavoidable noise impacts would not result in new or
different impacts.
5.9 POPULATION, HOUSING AND EMPLOYMENT
This section analyzes the effects to population, housing and employment from implementing
the proposed zoning code regulations.
Would the project:
a. Induce substantial unplanned population growth in an area, either directly (for example,
by proposing new homes and businesses) or indirectly (for example, through extension
of roads or other infrastructure)?
b. Displace substantial numbers of existing housing, necessitating the construction of
replacement housing elsewhere?
c. Displace substantial numbers of people, necessitating the construction of replacement
housing elsewhere?
TZC EIR Conclusions
• Implementation of the proposed project would accommodate projected population and
housing growth. (Impact 4.9-1: Less Than Significant without mitigation)
• Construction of development projects pursuant to the Transit Zoning Code (SD 84A and
SD 84B) could displace existing people or housing. However, this displacement would
not necessitate the construction of additional replacement housing elsewhere. (Impact
4.9-2: Less Than Significant without mitigation)
TZC EIR Mitigation Measures
All impacts were below the level of significance and mitigation measures are not necessary nor
recommended.
Project Analysis and Conclusion
The City determined that impacts related to accommodating population and housing growth
Impact 4.9-1) and displacement of existing housing (Impact 4.9-2) were below the level of
significance and did not require mitigation.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. The proposed adoption of the text regulations identified in Table 1 – Current and
Proposed Text Regulations would not require development of housing units. The new
regulations would provide architectural standards to any future development that would regulate
the manner in which individual parcels and blocks are developed to create diverse and
pedestrian-oriented development that would be consistent with the TZC area. In addition, there
shall be no increase in the number of dwelling units unless the site on which the structure is
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January 2025 43 Environmental Analysis
located complies with the off-street parking and open space requirements of the SAMC.
Therefore, the existing less than significant population, housing and employment impacts would
not result in new or different impacts nor would it increase unplanned growth and does not
trigger new population and housing impacts requiring the preparation of a subsequent or
supplemental EIR.
5.10 PUBLIC SERVICES
This section analyzes the effects to public services and recreational and park facilities from
implementing the proposed zoning code regulations.
Would the project:
a. Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for fire protection?
b. Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for police protection?
c. Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for schools?
d. Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for library services?
e. Result in substantial adverse physical impacts associated with the provision of new or
physically altered governmental facilities, or the need for new or physically altered
governmental facilities, the construction of which could cause significant environmental
impacts, in order to maintain acceptable service ratios, response times or other
performance objectives for park services?
TZC EIR Conclusions
• Construction of new projects pursuant to the Transit Zoning Code (SD 84A and SD 84B)
would increase the demand for fire protection services, but it would not require the
construction of new or physically altered facilities to accommodate the increased
demand or maintain acceptable response times. (Impact 4.10-1: Less Than Significant
with mitigation)
• Operation of the proposed project would increase the demand for police services,
thereby requiring additional staffing, although it would not require the construction of
new or physically altered facilities or personnel to accommodate the increased demand.
(Impact 4.10-2: Less Than Significant with mitigation)
• Construction of new residential units within the project area would generate new
students that could require the addition of new classroom facilities, thereby requiring
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January 2025 44 Environmental Analysis
new or physically altered facilities to accommodate additional students in Santa Ana
Unified School District (SAUSD) schools. (Impact 4.10-3: Less Than Significant)
• Construction of new residential units within the project area would generate new library
users that could require the addition of new library facilities. (Impact 4.10-4: Less Than
Significant without mitigation)
• All properties identified as having new development potential to be built out pursuant to
the provisions of the Transit Zoning Code (SD 84A and SD 84B) these new projects
would generate a need for new or physically altered park facilities in order to maintain
acceptable service ratios. (Impact 4.10-5: Less Than Significant without mitigation)
TZC EIR Mitigation Measures
MM4.10-1 Prior to an issuance of a building permit, individual projects in the Transit Zoning
Code (SD 84A and SD 84B) area shall perform a water supply, fire flow test and fire protection
system design analysis to ensure that proposed projects are in accordance to meet standard
fire protection design requirements. (Impact 4.10-1)
MM4.10-2 Any development that would exceed two stories in height shall submit site-specific
security plans to the SAPD for review prior to issuance of a building permit. (Impact 4.10-2)
MM4.10-3 No developer within the Transit Zoning Code (SD 84A and SD 84B) boundaries shall
utilize a frequency of 800 MHz, which is reserved for emergency services. (Impact 4.10-2)
MM4.10-4 Individual project developers shall pay school impact fees prior to the issuance of
occupancy permits. (Impact 4.10-3)
MM4.10-5 Prior to issuance of a building permit for a residential development project, or
change of use from non-residential to residential within the Transit Zoning Code (SD 84A and
SD 84B) area, project applicants shall pay to the City of Santa Ana the Park Acquisition and
Development Fee. (Impact 4.10-5)
Project Analysis and Conclusion
The City determined that impacts related to the provision of library services (Impact 4.10-4) and
recreation park facilities (Impact 4.10-5) were below the level of significance and did not require
mitigation. Impacts related to fire services (Impact 4.10-1), Police services (Impact 4.10-2) and
generation of new school children (Impact 4.10-3) were less than significant with the
implementation of mitigation measures.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. Mitigation measures MM4.10-1 through MM4.10-5 would continue to apply.
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of a supplemental or subsequent EIR because
specific development projects are neither included nor required. In addition, compliance with the
existing regulations and proposed amendments will assure that potential impacts are not
exacerbated, which will result in a beneficial impact to public services. Therefore, the existing
less than significant and significant and public services impacts would not result in new or
different impacts.
5.11 TRANSPORTATION
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This section analyzes the effects on transportation from implementing the proposed zoning
code regulations.
Would the project:
a. Cause an increase in traffic which is substantial in relation to the existing traffic load and
capacity of the street system (i.e., result in a substantial increase in either the number of
vehicle trips, the volume to capacity ratio on roads, or congestion at intersections)?
b. Exceed, either individually or cumulatively, a level of service standard established by the
county congestion management agency for designated roads or highways?
c. Result in a change in air traffic patterns, including either an increase in traffic levels or a
change in location that results in substantial safety risks?
d. Substantially increase hazards due to a design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm equipment)?
e. Result in inadequate emergency access?
f. Result in inadequate parking capacity
g. Conflict with adopted policies, plans, or programs supporting alternative transportation
(e.g., bus turnouts, bicycle racks)
TZC EIR Conclusions
• Operation of the proposed project would result in impacts related to neighborhood traffic
in the adjacent residential areas to the Transit Zoning Code (SD 84A and SD 84B) area.
(Impact 4.11-1: Less Than Significant with mitigation)
• Long-term cumulative development pursuant to the implementation of the Transit Zoning
Code would exceed standards established by the Orange County Transportation
Authority within the study area. (Impact 4.11-2: Less Than Significant without mitigation)
• Development projects constructed pursuant to the standards contained within the
Transit Zoning Code would not result in a change in air traffic patterns. (Impact 4.11-3:
Less Than Significant) without mitigation
• Development projects constructed pursuant to the Transit Zoning Code would not
increase hazards due to a design future or incompatible uses. (Impact 4.11-4: Less
Than Significant without mitigation)
• Development projects constructed pursuant to the Transit Zoning Code could result in
inadequate emergency access. (Impact 4.11-5: Less Than Significant without mitigation)
• Long-term cumulative development under the implementation of the Transit Zoning
Code would not result in inadequate parking capacity. (Impact 4.11-6: Less Than
Significant without mitigation)
• The Transit Zoning Code would not conflict with adopted policies, plans, or programs
supporting alternative transportation. (Impact 4.11-7: Less Than Significant)
• Long-term cumulative development under implementation of the Transit Zoning Code
would cause an increase in traffic which is substantial in relation to the existing traffic
load and capacity of the street system. (Impact 4.11-8: Less Than Significant with
mitigation)
• Long-term cumulative development under implementation of the Transit Zoning Code
would result in impacts related to freeway ramps in the vicinity of the Transit Zoning
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Code area. (Impact 4.11-9: Less Than Significant with mitigation and Significant and
Unavoidable due to a public agency (Caltrans) approval other than the City)
TZC EIR Mitigation Measures
MM4.11-1 The City of Santa Ana shall, during any roadway improvement within the Transit
Zoning Code boundaries, evaluate, consider, and implement as appropriate the traffic calming
measure(s), including but not limited to the following:
o Curb extensions at local intersections
o Short medians at entries to wide streets
o Traffic circles at oversized intersections
o Speed humps
o Turn restrictions (Impact 4.11-1)
MM4.11-2 As part of the project, the City of Santa Ana and the project sponsors shall work with
the transit providers to implement various transit-related measures to improve and expand bus
system service within the Transit Zoning Code (SD 84A and SD 84B) area. These measures
may include, but are not limited to, the following:
o Adding bus stops to the Transit Zoning Code (SD 84A and SD 84B) area along existing
roadways
o Changing bus service headways to respond to increased demand
o Changing bus service destinations to respond to changing demand
o Adding local shuttle service for employees and patrons of the Transit Zoning Code (SD
84A and SD 84B) area
o The details of bus service improvements shall be determined in coordination with OCTA.
The following recommendations would help encourage public transit patronage for
project-related trips:
o Bus Stop Locations—Relocation of existing bus stops and the provision of additional
bus stops should be considered to accommodate transit users at convenient
locations.
o Days of Operation—The City should work with OCTA to consider changes to route
times to serve nighttime and weekend project visitors and employees.
o Headway—The City should work w would be appropriate to reduce them Code (SD
84A and SD 84B) area.
MM4.11-3 The City of Santa Ana Public Works Agency shall monitor the traffic signals within
the Transit Zoning Code study area once every five years to ensure that traffic signal timing is
optimized. (Impact 4.11-8)
MM4.11-4 The City of Santa Ana shall institute a program for systematic mitigation of impacts
as development proceeds within the Transit Zoning Code to ensure mitigation of the individual
improvements. The program shall prescribe the method of participation in the mitigation
program by individual projects and guide the timely implementation of the mitigation measures.
The program shall include the following elements:
A funding and improvement program should be established to identify financial resources
adequate to construct all identified mitigation measures in a timely basis.
All properties that redevelop within the Transit Zoning Code should participate in the
program on a fair share per new development trip basis. The fair share should be based
upon the total cost of all identified mitigation measures, divided by the peak hour trip
generation increase forecast.
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January 2025 47 Environmental Analysis
This rate per peak hour trip should be imposed upon the incremental traffic growth for any
new development within the Transitioning Code.
The program should raise funds from full development of the Transit Zoning Code to fund all
identified mitigation measures.
The program should monitor phasing development of the Transit Zoning Code and defer or
eliminate improvements if the densities permitted in the Transit Zoning Code are not
occurring.
Program phasing should be monitored through preparation of specific project traffic impact
studies for any project that is expected to include more than 100 dwelling units or 100,000
sf of non-residential development. Traffic impact studies should use traffic generation rates
that are deemed to be most appropriate for the actual development proposed.
Properties within Santa Ana and within one-half mile of the Transit Zoning Code that
redevelop to result in higher traffic generation should also participate in the program to
insure equity.
The City may elect to implement appropriate mitigation measures as a condition of approval
of the proposed developments, where appropriate. All or part of the costs of these
improvements may be considered to be a negotiated credit toward the program, however
the program must be administered in a manner that assures that it can fund necessary
improvements to maintain adequate level of service at all intersections within this study. If
funding of priority improvements cannot be assured, credit for construction of lower priority
improvements may not be assured or may be postponed until more program funds are
available. (Impact 4.11-8)
MM4.11-5 Main Street at First Street—Install a second northbound and southbound left-turn
lanes and a dedicated northbound right-turn lane for 2030 and 2035 conditions. (Impact 4.11-8)
MM4.11-6 Lacy Street at Santa Ana Boulevard—Install a traffic signal and provide exclusive
left-turn lane for both northbound and southbound directions for both 2030 and 2035 conditions.
(Impact 4.11-8)
MM4.11-7 Lacy Street at First Street—Install a traffic signal for both 2030 and 2035 conditions,
a traffic signal, and provide exclusive left-turn lane for both northbound and southbound
directions for both 2030 and 2035 conditions. (Impact 4.11-8)
MM4.11-8 Santiago Street at Washington Avenue—Install a traffic signal and provide one
exclusive left-turn lane for both eastbound and westbound traffic for 2035 conditions only.
(Impact 4.11-8)
MM4.11-9 Santiago Street at Civic Center Drive—Install a traffic signal and provide: one
exclusive left-turn lane, one through lane, and one shared through and right-turn lane on
northbound and southbound approaches; and one exclusive left-turn lane and one shared
through and right lane on eastbound and westbound approaches. The improvement is only
needed for 2035 conditions. (Impact 4.11-8)
MM4.11-10 Santiago Street at Santa Ana Drive—Construct a second southbound left-turn lane
for 2035 conditions. The improvement is only needed for 2035 conditions. (Impact 4.11-8)
MM4.11-11 Santiago Street a Fourth Street—Install a traffic signal. The lane configuration for
the signal is recommended as 1 Left, 1 Through, 1 Through+ Right for all approaches. (Impact
4.11-8)
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January 2025 48 Environmental Analysis
MM4.11-12 Standard Street at First Street—Construct third eastbound and westbound shared
through-right lanes for 2035 conditions. The improvement is only needed for 2035 conditions.
(Impact 4.11-8)
MM4.11-13 Grand Avenue at Santa Ana Boulevard—Construct a third southbound through lane
and eastbound right-turn overlap signal phasing. (Impact 4.11-8)
MM4.11-14 Grand Avenue at First Street—Construct a third eastbound shared through/right-
turn lane, a third westbound shared through/right-turn lane, and a third northbound through lane
with dedicated northbound right-turn lane for 2035 conditions. The improvement is only needed
for 2035 conditions. (Impact 4.11-8)
MM4.11-15 Grand Avenue at I-5 Northbound Ramps—Construct a second westbound right-turn
lane and for the I-5 northbound off ramp under both 2030 and 2035 conditions. (Impact 4.11-8)
MM4.11-16 I-5 at Santa Ana Blvd.—Northbound Off-Ramp—The City of Santa Ana Department
of Public Works shall coordinate with Caltrans for the installation of a second ramp lane for the
I-5 northbound off ramp. The improvement shall be implemented to mitigate 2035 conditions.
(Impact 4.11-9)
Project Analysis and Conclusion
The City determined that impacts related to exceeding standards from the Orange County
Transportation Authority (Impact 4.111-2), change in air traffic patterns (Impact 4.11-3),
hazards due to a design future or incompatible uses (Impact 4.11-4), inadequate emergency
access (Impact 4.11-5), inadequate parking capacity (Impact 4.11-6), and alternative
transportation (Impact 4.11-7) were below the level of significance and did not require
mitigation. Impacts related to neighborhood traffic (Impact 4.11-1) and traffic increases to the
existing traffic load (Impact 4.11-8) were less than significant with the implementation of
mitigation measures. Impacts related to development near freeway ramps (Impacts 4.11-9)
were found to be significant and unavoidable and that specific economic, social, or other
considerations make infeasible additional mitigation. Specifically, no additional feasible
mitigation measures exist that would avoid or substantially reduce these impacts.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. Mitigation measures MM4.11-1 through MM4.11-16 would continue to apply.
The proposed adoption of the text regulations identified in Table 1 – Current and Proposed Text
Regulations would not require preparation of a supplemental or subsequent EIR because
specific development projects are neither included nor required. The new regulations would
provide recharging spaces for electric vehicles. Also, all truck parking areas must be on paved
surfaces and the parking, loading or unloading of trucks associated with a business on public
streets is prohibited. In addition, compliance with the existing regulations and proposed
amendments will assure that potential impacts are not exacerbated. This will result in a
beneficial impact to transportation. Therefore, the existing less than significant and significant
and unavoidable transportation impacts would not result in new or different impacts.
5.12 UTILITIES AND SERVICE SYSTEMS
This section analyzes the effects to utilities and service systems from implementing the
proposed zoning code regulations.
Would the project:
Planning Commission 1 – 123 3/6/2025
January 2025 49 Environmental Analysis
a. Require or result in the construction of new water treatment facilities or expansion of
existing facilities, the construction of which could cause significant environmental
effects?
b. Require new or expanded water entitlements and resources if there are not sufficient
water supplies available to serve the project from existing entitlements and resources?
TZC EIR Conclusions
• Long-term cumulative development pursuant to the Transit Zoning Code (SD 84A and
SD 84B) would generate an additional demand for water, but would not require water
supplies in excess of existing entitlements and resources or result in the need for new or
expanded entitlements. (Impact 4.12-1: Less Than Significant without mitigation)
• Long-term cumulative development pursuant to the Transit Zoning Code (SD 84A and
SD 84B) would not require or result in the construction of new or expanded water
treatment facilities, the construction of which could cause significant environmental
effects. (Impact 4.12-2: Less Than Significant)without mitigation
• Long-term cumulative development pursuant to the Transit Zoning Code (SD 84A and
SD 84B) would not exceed wastewater treatment requirements of the Orange County
Sanitation District. (Impact 4.12-3: Less Than Significant without mitigation)
• Long-term cumulative development pursuant to the Transit Zoning Code (SD 84A and
SD 84B) could require the construction of new or expanded wastewater conveyance
systems, the construction of which would not cause significant environmental effects.
(Impact 4.12-4: Less Than Significant with mitigation)
• Long-term cumulative development pursuant to the Transit Zoning Code (SD 84A and
SD 84B) would not increase wastewater generation such that treatment facilities would
be inadequate to serve the project’s projected demand in addition to the provider’s
existing commitments. (Impact 4.12-5: Less Than Significant without mitigation)
• Long-term cumulative development pursuant to the Transit Zoning Code would not
generate solid waste that exceeds the permitted capacity of landfills serving the area.
(Impact 4.12-6: Less Than Significant without mitigation)
• Long-term cumulative development under the implementation of the Transit Zoning
Code (SD 84A and SD 84B) would comply with all applicable federal, state, and local
statutes and regulations related to solid waste. (Impact 4.12-7: Less Than Significant
without mitigation)
• Long-term cumulative development pursuant to the Transit Zoning Code (SD 84A and
SD 84B) would increase the demand for electricity and gas, but would not require or
result in the construction of new energy production or transmission facilities, the
construction of which could cause a significant environmental impact. (Impact 4.12-8:
Less Than Significant without mitigation)
TZC EIR Mitigation Measures
MM4.12-1 Individual project applicants shall prepare site-specific sewer evaluations, including
flow monitoring and modeling, during the project design to determine the adequacy of the
existing sewer pipe capacity in the affected project area lines. The evaluation shall be submitted
to the City of Santa Ana or OCSD, as appropriate, for review and approval prior to issuance of
building permits. Any recommendations made in the site-specific sewer evaluations shall be
incorporated into the design of each individual project. (Impact 4.12-4)
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MM4.12-2 Individual non-residential project applicants are encouraged to apply for Southern
California Edison’s “Savings By Design” program. The program is aimed at generating an
overall reduction in energy use through design methods and incentive programs by maintaining
a 15% or greater exceedance of Title 24. (Impact 4.12-8)
MM4.12-3 Individual development projects within the boundaries of the Transit Zoning Code
(SD 84A and SD 84B) shall implement energy conservation measures (such as energy-efficient
lighting and microprocessor controlled HVAC equipment) to reduce the demand for electricity
and natural gas as part of the project design. The energy conservation measures shall be
subject to modification as new technologies are developed, or if current technology becomes
obsolete, through replacement and shall be reviewed by the Planning and Building Agency prior
to issuance of a building permit. (Impact 4.12-8)
MM4.12-4 Individual development projects within the boundaries of the Transit Zoning Code
(SD 84A and SD 84B) shall implement energy conservation measures (such as energy-efficient
lighting and microprocessor controlled HVAC equipment) to reduce the demand for electricity
and natural gas as part of the project design. The energy conservation measures shall be
subject to modification as new technologies are developed, or if current technology becomes
obsolete, through replacement and shall be reviewed by the Planning and Building Agency prior
to issuance of a building permit. (Impact 4.12-8)
Project Analysis and Conclusion
The City determined that impacts related to additional water demand (Impact 4.12-1), expanded
water treatment facilities (Impact 4.12-2), exceed wastewater treatment requirements (Impact
4.12-3), increase wastewater generation (Impact 4.12-5), generate solid waste exceeding
permitted capacity (Impact 4.12-6), and compliance with applicable federal, state, and local
solid waste regulations (Impact 4.12-7) were below the level of significance and did not require
mitigation. Impacts related to new or expanded wastewater conveyance systems (Impact 4.12-
4) and an increased demand for electricity and gas (Impact 4.12-8) were less than significant
with the implementation of mitigation measures.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual
project. Mitigation measures MM4.12-1 through MM4.12-4 would continue to apply.
The new regulations identified in Table 1 – Current and Proposed Text Regulations would
provide any nonconforming business that operates in an unlawful manner, including but not
limited to, frequent code violations, police calls, or loitering complaints, or is not in good
standing with the City, including, but limited to constant service calls or lapses in Business
License renewal, will lose its nonconforming status, enabling the City to take corrective action
as it deems appropriate, including business license revocation or terminating utility services or
connections. Also, in addition, compliance with the existing regulations and proposed
amendments will assure that potential impacts are not exacerbated which will result in a
beneficial impact to utilities and service systems. Therefore, the existing less than significant
utilities and service systems impacts would not result in new or different impacts requiring the
preparation of a subsequent or supplemental EIR.
5.13 GLOBAL CLIMATE CHANGE
This section analyzes the effects to global climate change from implementing the proposed
zoning code regulations.
Would the project:
Planning Commission 1 – 125 3/6/2025
January 2025 51 Environmental Analysis
a. Generate greenhouse gas emissions, either directly or indirectly, that may have a
significant impact on the environment?
b. Generate greenhouse gas emissions, conflict with any applicable plan, policy or
regulation of an agency adopted for the purpose of reducing the emissions of
greenhouse gas?
TZC EIR Conclusions
• Long-term cumulative development pursuant to the Transit Zoning Code at full build-out
would result in significant localized air quality impacts for operational level emissions. As
a whole, this impact is significant for operational emissions due to the size of the Transit
Zoning Code (SD 84A and SD 84B) area. (Impact 4.13-1: Significant and Unavoidable
and no feasible mitigation)
• Long-term cumulative development pursuant to the Transit Zoning Code at full build-out
has the potential to conflict with AB 32. The Project as a whole is significant for
operational emissions due to the size of the Transit Zoning Code (SD 84A and SD 84B)
area. (Impact 4.13-2: Significant and Unavoidable and no feasible mitigation)
TZC EIR Mitigation Measures
MM4.13-1 All diesel fueled construction equipment shall be classified EPA Tier II or better
emission efficiencies. (Impact 4.3-1)
MM4.13-2 All construction equipment shall be shut off when not in use and shall not idle for
more than five minutes, unless actively engaged in construction activities.
MM4.13-3 Queuing of trucks on- and offsite shall be limited to periods when absolutely
necessitated by grading or construction activities. (Impact 4.3-1)
MM4.13-3 Queuing of trucks on- and offsite shall be limited to periods when absolutely
necessitated by grading or construction activities. (Impact 4.3-1)
MM4.13-4 All on-road construction trucks and other vehicles greater than 10,000 pounds shall
be shut off when not in use and shall not idle for more than 5 minutes. (Impact 4.3-1)
MM4.13-5 To the extent feasible, all diesel- and gasoline-powered construction equipment shall
be replaced with equivalent electric equipment.
MM4.13-6 Project plans and specifications shall include policies and procedures for the reuse
and recycling of construction and demolition waste (including, but not limited to, soil, vegetation,
concrete, lumber, metal, and cardboard). (Impact 4.3-1)
MM4.13-7 Project plans and specifications shall include education for construction workers
about reducing waste and using available recycling services. (Impact 4.3-1)
MM4.13-8 Prior to issuance of a building permit, the applicant shall demonstrate that the design
of the proposed buildings or structures meets or exceeds the most recent Title 24 requirements
(Title 24, Part 6 of the California Code of Regulations; Energy Efficiency Standards for
Residential and Non Residential Buildings; Cool Roof Coatings performance standards),
subject to review by the City Building Official. Documentation of compliance with this measure
shall be provided to the Planning and Building Agency and Building Official for review and
approval prior to issuance of the permit. Installation of the identified design features or
Planning Commission 1 – 126 3/6/2025
January 2025 52 Environmental Analysis
equipment will be confirmed by the City Building Official prior to certificate of occupancy. The
following design features should be considered by the applicant as a way to achieve Title 24
compliance in excess of the minimum requirement:
o Increase in insulation such that heat transfer and thermal bridging is minimized
o Limit air leakage through the structure or within the heating and cooling distribution
system to minimize energy consumption
o Incorporate dual-paned or other energy efficient windows
o Incorporate energy efficient space heating and cooling equipment
o Incorporate energy efficient light fixtures
o Incorporate energy efficient appliances
o Incorporate energy efficient domestic hot water systems
o Incorporate solar panels into the electrical system
o Incorporate cool roofs/light-colored roofing
Or other measures that will increase the energy efficiency of building envelope in a manner that
when combined with the other options listed above exceeds current Title 24 Standards (Title 24,
Part 6 of the California Code of Regulations; Energy Efficiency Standards for Residential and
Non Residential Buildings, as amended September 11, 2008; Cool Roof Coatings performance
standards as amended September 11, 2006) by a minimum of 20 percent. (Impact 4.3-1)
MM4.13-9 Prior to issuance of a building permit, applicants for individual projects shall provide
a landscape plan that includes shade trees around main buildings, particularly along southern
elevations where practical, and will not interfere with loading dock locations or other operational
constraints. Documentation of compliance with this measure shall be provided to the Planning
and Building Agency for review and approval. (Impact 4.3-1)
MM4.13-10 All showerheads, lavatory faucets, and sink faucets within the residential units, and
where feasible within non-residential developments, shall comply with the California Energy
Conservation flow rate standards. (Impact 4.3-1)
MM4.13-11 Low-flush toilets shall be installed within all Congregate Care units as specified in
California State Health and Safety Code Section 17921.3.
MM4.13-12 Project designers should consider design features to incorporate light-colored
roofing materials that will deflect heat away from the building and conserve energy. (Impact 4.3-
1)
MM4.13-13 Landscape designers shall ensure that landscaping of common areas for
Industrial/Commercial projects uses drought-tolerant and smog-tolerant trees, shrubs, and
groundcover to ensure long-term viability and conserve water and energy. (Impact 4.3-1)
MM4.13-14 Landscape designers shall ensure that the landscape plan for
Industrial/Commercial projects includes drought resistant trees, shrubs, and groundcover within
the parking lot and perimeter. (Impact 4.3-1)
MM4.13-15 Individual project applicants shall ensure that designs for Industrial/Commercial
projects include all illumination elements to have controls to allow selective use as an energy
conservation measure. (Impact 4.3-1)
MM4.13-16 The applicant for Industrial/Commercial projects should promote ride sharing
programs such as, but not necessarily including, publishing ride sharing information for all of
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January 2025 53 Environmental Analysis
the tenants, designating a certain percentage of parking spaces for ride sharing vehicles,
designating adequate passenger loading and unloading and waiting areas for ride sharing
vehicles, and providing a website or message board for coordinating rides. Prior to issuance of
a building permit, the applicant shall demonstrate that measures have been included to provide
adequate bicycle parking near building entrances to promote cyclist safety, security, and
convenience pursuant to SAMC Chapter 41 regarding bicycle parking standards and Chapter
16 of the Santa Ana Citywide Design Guidelines regarding Bikeway Support Facilities
Guidelines. Documentation of compliance with this measure shall be provided to the City
Building Official for review and approval. Installation of the identified design features or
equipment will be confirmed by the City Building Official prior to issuance of certificate of
occupancy. (Impact 4.3-1)
MM4.13-17 Prior to issuance of any certificate of occupancy, the applicant shall demonstrate
that all Multi-family/Industrial/Commercial projects’ interior building lighting supports the use of
compact fluorescent light bulbs or equivalently efficient lighting to the satisfaction of the Building
Official. (Impact 4.3-1)
MM4.13-18 Applicants for Multi-family/Industrial/Commercial projects shall consider providing
preferential parking spaces for ultra-low emission vehicles and alternative fueled vehicles to
encourage the use of alternative fuels and ultra-low emission vehicles. (Impact 4.3-1)
MM4.13-19 Prior to issuance of a building permit, the applicant shall demonstrate that the
proposed Multi-family/ Industrial/Commercial uses building or structure designs incorporate
exterior storage areas for recyclables and green waste and adequate recycling containers
located in public/common areas pursuant to the adopted standards. Documentation of
compliance with this measure shall be provided to the Planning and Building Agency for review
and approval. Installation of the identified design features or equipment will be confirmed by the
City Building Official prior to issuance of certificate of occupancy. (Impact 4.3-1)
MM4.13-20 All common area irrigation areas for Multi-family/Industrial/Commercial projects
shall consider systems that are capable of being operated by a computerized irrigation system
which includes an onsite weather station/ET gage capable of reading current weather data and
making automatic adjustments to independent run times for each irrigation valve based on
changes in temperature, solar radiation, relative humidity, rain, and wind. In addition, the
computerized irrigation system shall also consider the ability to be equipped with flow-sensing
capabilities, thus automatically shutting down the irrigation system in the event of a mainline
break or broken head. These features will assist in conserving water, eliminating the potential of
slope failure due to mainline breaks, and eliminating over-watering and flooding due to pipe
and/or head breaks. (Impact 4.3-1)
MM4.13-21 Consideration of installation of solar roofs on homes and businesses to offset the
increasing demand for energy and natural gas. (Impact 4.3-1)
MM4.13-22 Project applicants shall, where feasible, incorporate passive solar design features
into the buildings, which may include roof overhangs or canopies that block summer shade, but
that allow winter sun, from penetrating south facing windows. (Impact 4.3-1)
MM4.13-23 Use Energy Efficient Roofing Materials. All roofing materials used in
commercial/retail buildings at the Mixed-Use Retail Development shall be Energy Star®
certified. All roof products shall also be certified to meet American Society for Testing and
Materials (ASTM) high emissivity requirements. (Impact 4.3-1)
MM4.13-24 All commercial/industrial projects shall, where feasible, include up to 10%
renewable energy sources within the project. (Impact 4.3-1)
Planning Commission 1 – 128 3/6/2025
January 2025 54 Environmental Analysis
MM4.13-1 through MM4.13-24 would also apply to this impact. (Impact 4.3-2)
Project Analysis and Conclusion
The City determined that long-term development related to localized air quality impacts from
operational emissions (Impact 4.13-1) and operational emissions due to the size of the TZC
area with the potential to conflict with AB 32 (Impact 4.13-2) were found to be significant and
unavoidable and that specific economic, social, or other considerations make infeasible
additional mitigation. Specifically, no additional feasible mitigation measures exist that would
avoid or substantially reduce these impacts.
Any future development within the TZC area requiring discretionary action would continue to be
subject to a project-level CEQA review at the time an application is filed for an individual project
Mitigation measures MM 4.13-1 through MM4.13.24 would continue to apply.
The new regulations in Table 1 – Current and Proposed Text Regulations would provide that no
land use shall generate or cause any visible dust, gases, or smoke to be emitted into the
atmosphere and that uses, activities, and processes shall not operate in a manner that emits
dust, fumes, odors, smoke, or particulate matter, unless authorized under Federal, State, or
local law. This will result in a beneficial impact to climate change/greenhouse gas emissions.
Therefore, the existing significant and unavoidable global climate change impacts would not
result in new or different impacts requiring the preparation of a subsequent or supplemental
EIR.
5.14 MANDATORY FINDINGS OF SIGNIFICANCE
Would the project:
a. Does the project have the potential to substantially degrade the quality of the
environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or
wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or
animal community, reduce the number or restrict the range of a rare or endangered
plant or animal or eliminate important examples of the major periods of California history
or prehistory?
b. Does the project have potential to achieve short-term environmental goals to the
disadvantage of long-term environmental goals?
c. Does the project have impacts that are individually limited, but cumulatively
considerable? (“Cumulatively considerable” means that the incremental effects of a
project are considerable when viewed in connection with the effects of past projects, the
effects of other current projects, and the effects of probable future projects)?
d. Does the project have environmental effects which will cause substantial adverse effects
on human beings, either directly or indirectly?
As detailed herein, on the basis of substantial evidence in the light of the whole record, a
Subsequent or Supplemental EIR is not appropriate for the project because none of the criteria
permitting such a document under State CEQA Guidelines section 15162 are met.
Project implementation does not include nor require implementation of specific development
projects. The majority of the City is urbanized, with residential and nonresidential development,
and mobility and public facilities all contributing to Santa Ana’s existing built environment.
The proposed text amendments to SAMC Sections 41-2001, 41-2001.5, 41-2002, 41-2004, 41-
2005, 41-2006, 41-2008, 41-2009, and 41-2008 would merely update to clarify that the
Planning Commission 1 – 129 3/6/2025
January 2025 55 Environmental Analysis
regulations apply to existing uses, further limit some rehabilitation of existing buildings and
structures, clarify the effects of amendments to the TZC, further limit certain existing operations
to ensure greater compatibility between residential and non-residential land uses, and to
establish regulations for operation of any existing, legally established, nonconforming industrial
uses. Section 41-2001.5 is updated to encompass new SAMC Section 21-2009, which
establishes regulations for operation of any existing, legally established, nonconforming
industrial use. Section 41-2004 deletes the Overlay I-OZ zone from the text and map.
Implementation of these SAMC amendments would not require implementation of any specific
developments or direct physical changes to the environment, and therefore would not be in
conflict with the GPU and no intensification of land uses would result.
The City of Santa Ana, which includes the TZC area, is not within a NCCP/HCP area, and
therefore would not conflict with an adopted NCCP/HCP plan. No direct or indirect substantial
adverse effects on human beings would occur.
5.15 CONCLUSION
This project proposes amendments to the Transit Zoning Code (SD-84) by way of ZOA No.
2024-02 and AA No. 2024-03. These proposed amendments would modify the list of land uses
and permit types including the deletion of industrial land uses; amend nonconforming
regulations including the addition of an amortization process; amend and add operational
standards for allowed uses and nonconforming uses; delete the Industrial Overlay (I-OZ) zone
from text and maps; and delete the M1 (Light Industrial) and M2 (Heavy Industrial) suffixes from
certain properties within the SD-84 Zoning District boundary as designated on the City of Santa
Ana Zoning Map. Refer to Section 3.0 – Description of the Proposed Project.
This project would not result in new or more severe environmental impacts than previously
addressed in the TZC FEIR, nor has any new information regarding the potential for new or
more severe significant environmental impacts have been identified because the project
basically limits industrial uses and would not lead to the expansion or intensification of new,
expanded or more intensive uses. Therefore, there will be no new or more severe impacts as
the result of the implementation of this project, beyond the impacts that have already been
analyzed in the TZC FEIR.
In taking action on any of the approvals, the decision-making body of the lead agency must
consider the whole of the data presented in the TZC FEIR. As outlined in this Addendum
analysis, all impacts of the project were fully examined in the TZC FEIR, and the proposed
changes do not require substantial changes to the prior-certified EIR or previously adopted
mitigation measures. Therefore, the preparation of an Addendum to the existing certified EIR is
the appropriate CEQA document to support the City’s consideration of the project, as outlined in
CEQA Guidelines Sections 15162 and 15164.
Planning Commission 1 – 130 3/6/2025
Planning and Building Agency
www.santa-ana.org/pb
Item # 1
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Planning Commission Staff Report
February 24, 2025
Topic: Resolution to make findings and adopt Addendum to the Transit Zoning Code
Environmental Impact Report (State Clearinghouse Number No. 2006071100), Zoning
Ordinance Amendment (ZOA) No. 2024-02 and Amendment Application (AA) No. 2024-
03 amending certain sections of Article XIX (The Transit Zoning Code, Specific
Development No. 84) of Chapter 41 (Zoning) of the Santa Ana Municipal Code (SAMC)
addressing industrial land uses, nonconformities, and operating standards, and amending
the City of Santa Ana Zoning Map to remove the Light Industrial (M1) and Heavy Industrial
(M2) suffixes from certain properties within the SD-84 district boundary.
RECOMMENDED ACTIONS
Recommend that the Planning Commission recommend that the City Council:
1) Adopt a resolution to make findings pursuant to Public Resources Code Section
21166 and to adopt the Addendum to the Transit Zoning Code Environmental
Impact Report (State Clearinghouse Number No. 2006071100). Pursuant to the
California Environment Quality Act (CEQA), and based on independent review and
analysis, and the administrative record as a whole, that, in exercising its
independent judgement, amend TZC SD-84 Final EIR with an addendum that the
City Council find that pursuant to CEQA Guidelines Section 15162, no subsequent
Environmental Impact Report (EIR) is required for the adoption of the proposed
Ordinances; and pursuant to CEQA Guidelines Section 15164, an addendum to
the Transit Zoning Code EIR was accordingly prepared.
2) Adopt an ordinance to approve Zoning Ordinance Amendment (ZOA) No. 2024-02
amending certain sections of Article XIX (The Transit Zoning Code, Specific
Development No. 84 (SD-84)) of Chapter 41 (Zoning) of the Santa Ana Municipal
Code including amendments to the regulations, overlay districts and maps in the
zoning district; modifying the authorized land uses and permit types; establishing
revised non-conforming use regulations, including the addition of an
amortization/termination of use process and adding operational standards for
certain permitted and non-conforming uses.
3) Adopt an ordinance to approve Amendment Application (AA) No. 2024-03
amending the zoning by removing the M1 (Light Industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD-84 zoning district
boundary as designated on the City of Santa Ana Zoning Map.
Exhibit 6: February 24, 2025 Planning Commission Staff Report (without attachments)_____________________________________________________________________
Planning Commission 1 – 131 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 2
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EXECUTIVE SUMMARY
On April 16, 2024, the City Council adopted a 45-day moratorium on the approval,
commencement, establishment, relocation, or expansion of industrial uses within the
Transit Zoning Code/Specific Development (SD) No. 84 Zoning District through adoption
of Urgency Interim Ordinance No. NS-3063. The purpose of the moratorium was to
immediately offer protection of public health, safety, and welfare from industrial uses
significantly causing pollution burden to adjacent residential neighborhoods within the SD-
84 Zoning District. On May 7, 2024, the City Council issued a report to the public, pursuant
to Section 65858(d) of the California Government Code, describing the City’s measures
to alleviate conditions that led to the adoption of the moratorium. On May 21, 2024, the
City Council adopted Ordinance No. NS-3064 to extend the moratorium for an additional
ten (10) months and fifteen (15) days pursuant to the Government Code as necessary to
provide sufficient time for staff to continue with data tracking and reporting, research
appropriate regulations, and coordinate with outside regulatory agencies and City
departments to determine whether further, permanent action is necessary and to
generate recommendations to the Planning Commission and City Council.
Based upon this City Council direction, and the research and analysis of the issues herein,
staff has prepared Ordinances amending certain sections of Chapter 41 (Zoning) of the
Santa Ana Municipal Code (SAMC), Article XIX. The Transit Zoning Code/Specific
Development (SD) No. 84 Zoning District. The first Ordinance proposes amendments that
would modify the list of land uses and permit types, including the deletion of industrial
land uses; amend nonconforming regulations, including the addition of an amortization
process/termination of use process; amend and add operational standards for allowed
uses and nonconforming uses; and delete the Industrial Overlay (I-OZ) zone from text
and maps. The second Ordinance deletes the M1 (Light Industrial) and M2 (Heavy
Industrial) suffixes from certain properties within the SD-84 Zoning District boundary as
designated on the City of Santa Ana Zoning Map.
DISCUSSION
The Transit Zoning Code/Specific Development No. 84
The Specific Development (SD) No. 84 Zoning District, also known as the Transit Zoning
Code (TZC), is located in the central urban core of the City and comprises over 100 blocks
and 450 acres. The TZC includes the Civic Center, Downtown, and the Logan and Lacy
neighborhoods, which are among the City’s most historic in age and as established
residential communities. The TZC is generally bounded by First Street, Flower Street,
Civic Center Drive, Grand Avenue, and the Santa Ana (I-5) Freeway. Prior to the
implementation of the TZC, the area consisted of a wide range of civic, commercial,
industrial, and residential land uses regulated by varying zoning districts.
In June 2010, the City Council adopted Ordinance No. NS-2804, creating the TZC, which
purpose was to establish a transit-supportive, pedestrian-oriented development
framework to support the addition of new transit infrastructure; preserve and reinforce the
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existing character and pedestrian nature of the City by strengthening urban form through
improved development and design standards; encourage alternative modes of
transportation; provide for a range of housing options; and allow for the reuse of existing
structures. In July 2019, the City Council adopted Ordinance No. NS-2970, amending the
TZC to modify certain design criteria regulating height, massing, open space location,
driveway standards, lot dimensions, and parking alternatives. The amendment did not
include changes to land uses or permit types within the TZC.
When originally adopted, the TZC provided new zoning for all properties contained within
its boundary. However, some properties with existing M1 and M2 zoning and/or exiting
industrial businesses, also received an overlay district designation which allowed for the
continuation of industrial land uses on those properties. The development of mixed-use
on these properties consistent with the new zoning they received as part of the TZC
adoption is at the discretion of the property owner. In support of the TZC, the City Council
also approved a General Plan amendment, establishing numerous mixed-use General
Plan land use designations for the entirety of the TZC. However, due to the continued
application of the industrial overlay zones within the TZC, the implementation of the new
General Plan land use designations immediately resulted in zoning inconsistencies and
land use conflicts with the new General Plan.
Since establishment of the TZC, and specifically in the Logan and Lacy neighborhoods,
industrial uses have remained, changed ownership, undergone expansions or
intensifications, and have continued to create numerous land use conflicts and
disturbances that affect surrounding residential communities. Specifically, in the Logan
neighborhood alone, these land uses create quality of life, health and safety, and other
trespass issues for residential properties that often directly abut these industrial land
uses. These issues include odors, dust, traffic, noise, vibrations, and other documented
impacts that have taken place for nearly a decade and a half despite the change to the
new General Plan land use designations.
Historically Disadvantaged Communities and Senate Bill (SB) 1000
Prior to the adoption of the TZC, the City permitted industrial uses within the Logan and
Lacy neighborhoods in close proximity to sensitive land uses such as residences and
schools. The Logan neighborhood represents one of Orange County’s oldest barrios,
established as early as 1886, and was one of the few areas where Mexicans and those
of Mexican descent could purchase land due to racially restrictive covenants during the
first half of the 20th century. Further, as a neighborhood, the area was established before
the modern practice of separating or regulating impactful land uses, also known as
zoning. The Logan neighborhood itself was largely settled by 1900, before the practice of
zoning was enshrined by Village of Euclid v. Ambler Realty Co. in 1926. By that time, the
neighborhood contained a mix of residential, industrial, commercial, and related land
uses, in some cases side-by-side, with issues further exacerbated by rail lines, fuel
storage depots, and the construction of the Santa Ana Freeway (I-5) between 1947 and
1956.
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Comprehensive data analysis and mapping tools generated by the Office of
Environmental Health Hazard Assessment (OEHHA) and California Environmental
Protection Agency (CalEPA), the Center for Diseases Control/Agency for Toxic
Substances and Disease Registry (CDC/ATSDR), the United States Environmental
Protection Agency (EPA), and California Healthy Places Index (HPI) reveal concerning
information regarding environmental conditions impacting residents in the Logan and
Lacy neighborhoods. Recent CalEnviroScreen 4.0 data confirms that these
neighborhoods rank at 90 percent or above among California’s most pollution-burdened
communities, with Environmental Justice (EJ) maps showing higher exposure to
Particulate Matter (PM) 2.5, Air Toxics Cancer Risk, Hazardous Waste Proximity, Diesel
Particulate Matter, and Toxic Releases to Air. This information is included as Exhibit 4 to
this staff report. These multiple sources of environmental exposure and pollution burden
communities of color, including the Logan and Lacy neighborhoods, present an alarming
set of challenges that affect residents’ quality of life and life expectancy with continued
heavy industrial uses nearby.
Senate Bill (SB) 1000 went into effect in 2016, requiring local governments to address
pollution and other hazards that disproportionately impact low-income and communities
of color within their jurisdiction to proactively plan for and address environmental concerns
when developing and updating components of the General Plan. The City and community
worked to ensure that the new General Plan included SB 1000 requirements of
addressing EJ through facilitating transparency and public engagement in the planning
and decision-making processes, reducing harmful pollutants and the associated health
risks in disadvantaged communities, and promoting equitable access to health-inducing
benefits such as healthy housing options. Of note, the City’s new General Plan mixed-
use land use designations in the TZC area were largely left intact, including those in the
Lacy and Logan neighborhoods, when the General Plan Update was adopted in 2022.
Environmental Justice/Disadvantaged Communities (DACs) Profile: Logan and Lacy
Neighborhood Impacts
For the Logan and Lacy neighborhoods, incompatible land uses allowed from past zoning
decisions, including the industrial overlay zones, have perpetuated the practices of
locating industrial uses or other noxious and unwanted uses near communities of color.
The Logan and Lacy neighborhoods have a population of 5,907 within 1,564 households,
a median household income of $56,864, average household size of nearly four persons,
median age 27 years, and per-capita income of $23,495. Seventy-four percent are renter-
occupied units based on demographic forecasts for 2023. Nearly 25 percent of the
population is under 14 years of age and 14 percent are 55 years of age and older. Nearly
three percent of the population attended up to 12th grade with no diploma, over 31 percent
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are high school graduates, and nearly 97 percent of the working population over 16 years
of age are employed.1
These data illustrate that the Logan and Lacy neighborhoods are within the second and
third highest scored census tracts in Santa Ana, each with a composite score of 90
percent or greater, ranking in the 90th percentile or greater of census tracts in the State,
and identified as “disadvantaged communities” by the Office of Environmental Health
Hazard Assessment (OEHHA) in its CalEnviroScreen model. Failure to address ongoing
irreconcilable land use conflicts that are the target of this moratorium will further
exacerbate the ongoing demographic and environmental justice challenges that these
two neighborhoods within the TZC have grappled with since their founding.
Code Enforcement and Immediate Ongoing Issues
In the Logan and Lacy neighborhoods within the TZC, the Code Enforcement Division
has investigated over 35 commercial and industrial properties in the past 12 months and
currently has 16 active open cases that have been issued Notice of Violations and
administrative citations for the following types of violations: illegal storage, land use,
zoning, property and landscape maintenance, unpermitted work, business license, and
certificate of occupancy. These violations include issues of odors, dust, traffic, noise,
vibrations, and other documented impacts. The proximity of active open industrial cases
during a short period is creating a public nuisance that is harming public health, safety,
and general welfare of the two residential neighborhoods from the concentration of open
code enforcement cases nearby.
Since June 2023, the TZC communities have experienced a marked increase in impacts
stemming from the irreconcilable industrial and residential land use conflicts in the Logan
and Lacy neighborhoods. Residents in the TZC have voiced and emailed complaints and
public health concerns to City staff regarding emitted contaminants and zoning violations
from industrial businesses in the neighborhoods. Concerns that range from air pollution
and smoke, toxic release exposures, idling trucks on residential streets, lead exposure,
illegal storage, unpermitted uses, loud noise at night, and other property maintenance
pose an immediate public health threat that is straining public resources to continuously
investigate and address these matters. Specifically, a fire incident at a crematory located
in the neighborhood alarmed neighbors at 9:18 p.m. on August 29, 2023. Residents
shared with City officials’ video of high flames escaping the stack on the rooftop,
screeching noise that continued nonstop for ten minutes, and what was described as a
foul odor attributed to the fire. As City staff followed up with external regulatory agencies
issuing permits to operate this facility, and quickly, staff observed the limitations from
regulatory agencies and their compartmentalized processes to investigate and act on
enforcement measures. On August 9, 2024, the City received a complaint with photos of
1 ESRI Community Analyst summary data, which utilizes U.S. Census Bureau sources (2017-2021
American Community Survey & 2020 Decennial Census Data), enhanced by ESRI’s forecasts and
aggregations, covering demographics like population, income, age, and employment.
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the the same crematory in which the complainant observed bodies stored in a container
outside the facility. A City code enforcement inspector issued an abatement notice that
same day; the bodies and container were removed and the case was closed on August
13, 2024 by code enforcement staff.
Since 2022, the City has enhanced community services by restructuring its Planning
Division to contain a Neighborhood Initiatives and Environmental Services (NIES) section,
which oversees, among other functions, environmental justice efforts in Santa Ana and
regional coordination to address such issues. Staff encountered difficulty in achieving
desired enforcement outcomes with external regulatory agencies such as South Coast
Air Quality Management District (SCAQMD), California Department of Consumer Affairs
Cemetery and Funeral Bureau (CFB), and Orange County Fire Authority (OCFA) with
several heavy industrial business operators in the TZC. This is supported through internal
correspondence and phone conversations with staff from these agencies to understand
their investigation and compliance processes. To address issues of industrial operators,
including recycling and waste processing facilities near schools and residential areas, the
City adopted new regulations such as a Noxious Uses Ordinance (Ordinance No. NS-
3044, adopted June 20, 2023) to include a notification requirement to the City by the
property owner to obtain a permit from a regulatory public agency; a requirement of a
1,000 linear foot distance buffer measured from the outermost boundary of the subject
property; and a conditional use permit requirement from a regulatory public agency to
handle, store, emit, or discharge particulate materials, exhaust emissions, or regulated
compounds, or chemicals near a public park, school (K-12), or property zoned for
residential purposes.
City staff have also researched commercial real estate acquisition data and current for-
sale properties to identify any trends that could potentially generate an increase in the
application of the City’s Noxious Uses Ordinance for proposed or expanded industrial
uses. From September 2022 to date, 15 properties (six commercial, three office, and six
industrial businesses) sold. Three of those businesses (800-808 E. Washington Avenue,
1045 N. Fuller Street, and 923 N. Logan Street) are located in the Logan neighborhood.
Currently, multi-tenant industrial and manufacturing warehouse spaces on the market for
lease located in the TZC.
Recent City Council Actions and Direction to Address TZC Land Use Conflicts
On April 16, 2024, the City Council adopted a 45-day moratorium on the approval,
commencement, establishment, relocation, or expansion of industrial uses within the TZC
through adoption of Urgency Interim Ordinance No. NS-3063. The purpose of the
moratorium was to immediately offer protection of public health, safety, and welfare from
industrial uses significantly causing pollution burden to adjacent residential
neighborhoods within the TZC.
On May 7, 2024, the City Council issued a report to the public, pursuant to Section
65858(d) of the California Government Code, describing the City’s measures to alleviate
conditions that led to the adoption of the moratorium.
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On May 21, 2024, the City Council adopted Ordinance No. NS-3064 to extend the
moratorium for an additional ten (10) months and fifteen (15) days pursuant to the
Government Code as necessary to provide sufficient time for staff to continue with data
tracking and reporting, research appropriate regulations, and coordinate with outside
regulatory agencies and City departments to determine whether further, permanent action
is necessary and to generate recommendations to the Planning Commission and City
Council. As part of its approval, the City Council expressed a desire for City staff to begin
evaluating permanent solutions to the irreconcilable land use conflicts in the TZC area in
as timely a manner as possible, which resulted in immediate evaluation of the zoning
code text and map amendments consistent with direction provided for City Council
consideration as part of this request.
Review of City Department Activities
Immediately following the adoption of the Moratorium, City staff conducted an interagency
meeting that included representatives from multiple City departments: the Planning Division,
Building Safety Division, Code Enforcement Division, Business License, and Information
Technology. Additionally, engagement with additional agencies such as the Santa Ana
Police Department (SAPD), Public Works Agency, and the Community Development
Agency’s Economic Development Division has produced critical information illustrating the
extent to which industrial activities interface with residential land uses in the TZC area,
specifically and most concentrated in the Logan and Lacy neighborhoods.
Data based on Business License and Economic Development records indicate that
application of the moratorium affects approximately 127 industrial businesses in the TZC.
All businesses must obtain appropriate permits before operating: commercial locations
require a Certificate of Occupancy from the Planning Department, while residential-based
operations need a Home Occupation Permit. Of the affected businesses, approximately
three have active applications for permits, primarily seeking to legalize unpermitted work on
industrial properties.
City staff reviewed public safety data from SAPD and OCFA to assess community
concerns regarding emergency responses in the TZC. SAPD records show a total of
18,736 calls for service between March 2023 and July 2024, with 226 of those occurring
between April and July 2024 within the Logan and Lacy neighborhoods. These calls
encompassed a wide range of incidents, including patrol checks, disturbances, and traffic-
related issues. Notably, 1,909 calls involved collisions, vehicle impoundments, domestic
violence, and SAMC violations. OCFA data from 2022 to August 2024 indicates 238 calls
for advanced life support emergencies. In 2022, 29 calls were related to respiratory
issues, chest pain, and cardiac arrest, with a subsequent 7-percent increase in health-
related calls in 2023. While the data reflects a broad spectrum of emergency responses,
the concentration of industrial businesses in the TZC raises the possibility that some of
these calls, particularly those related to respiratory issues and traffic incidents, may be
influenced by industrial operations. Further analysis is needed to determine the specific
correlation between industrial activity and public safety concerns in the area.
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OCFA data for 2024 reported 312 service calls in the Logan and Lacy neighborhoods. A
substantial majority, exceeding 250, were EMS-related, indicating a high demand for
emergency medical services. Other incidents included traffic and pedestrian accidents,
fire responses (including unauthorized burning and a brush fire), and alarm activations.
Some calls were cancelled or resulted in 'no incident found,' suggesting potential areas
for improved dispatch accuracy. The volume and variety of these calls highlight the impact
of the area's mixed land use, where dense residential areas, commercial activity, and
industrial operations contribute to a wide range of emergency response needs.
Currently, City staff have an internal process established which tracks and monitors
incoming notice of compliance and notice of violations given to a particular
business/operator. City Code Enforcement activities and implementation of the City’s
Noxious Uses Ordinance continue being monitored at these facilities. Code Enforcement
staff data reports show enforcement activity beyond the Logan and Lacy neighborhoods
within the TZC, where at the time of adoption of the moratorium, 16 active open cases were
issued Notice of Violations and administrative citations for the following types of violations:
illegal storage, land use, zoning, property and landscape maintenance, unpermitted work,
business license, and certificate of occupancy. Such violations include issues of odors, dust,
traffic, noise, vibrations, and other documented impacts. Recent code enforcement
complaints on properties in the Logan neighborhood involve complaints for recurring
unpermitted work and land use violations that involve large commercial vehicles blocking
street access and impacting nearby residents. Code Enforcement Division follow-up has
resulted in larger administrative citations, continued enforcement, and onsite meetings with
business owners.
Currently, 21 open code enforcement violations or compliance reviews from industrial
businesses are recorded with the City of Santa Ana, underscoring the need for close
monitoring within the TZC area. The profile highlights the critical role of regulatory agencies
in overseeing these businesses to mitigate potential environmental and public health risks.
Review of Records and Activities of External Agencies
Data from outside regulatory agencies assist City staff in further understanding activities
between external regulatory agencies and industrial businesses that may place additional
impacts on public health, safety, and welfare in affected neighborhoods adjacent to industrial
businesses in the TZC. This information would enable City staff to understand the correlation
and environmental burdens that may be attributed to permitted activities for industrial
businesses in historically environmentally disadvantaged communities, specifically the
Logan and Lacy neighborhoods.
On April 25, 2024, City staff initiated public records requests from outside regulatory
agencies, such as the South Coast Air Quality Monitoring District (SCAQMD), Santa Ana
Regional Water Quality Control Board (SARWQCB), the Department of Toxic Substances
Control (DTSC), and others responsible for issuing specific types of permits for industrial
uses in the TZC. Such agencies are responsible for permit issuance, compliance activities,
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and/or monitoring hazardous clean-up sites, or other industrial facility-related activities for
sites located within the TZC.
The City has responses to its Public Records Act request from SCAQMD, the Santa Ana
Regional Water Quality Control Board (SARWQB), and the Orange County Environmental
Health Division Certified Unified Program Agency (CUPA). Records show SCAQMD
issued two notices to comply with one industrial business on August 2023 and April 2024
for failure to maintain records, such as temperature graphs, poundage logs, and source test
data. SCAQMD issued several permits to construct and to operate to the new operator of
this same facility, which is currently in compliance with SCAQMD. Two notices of violation
to one industrial business for operating a paint spray booth without a valid permit to operate
from SCAQMD.
The report from the SARWQCB from 2023 shows five (5) active industrial businesses in the
TZC that were in violation of their permit for providing a late report or incomplete and/or
insufficient information for their Stormwater Pollution Prevention Plan (SPPP).
Public records from the Certified Unified Program Agency (CUPA) for Orange County,
spanning 2022-2024, reveal a pattern of non-compliance with environmental and
hazardous materials regulations among industrial businesses within the TZC. While some
2023 violations related to Hazardous Material Business Plan staff training and reporting
were later corrected, current records indicate four businesses still have multiple open
violations. These ongoing issues include non-compliance with documentation for
hazardous waste transportation and disposal, as well as deficiencies in industrial
stormwater reporting requirements. Notably, records from 2022-2024 show repeated
failures to submit required stormwater reports and deficiencies in hazardous waste
management and emergency response planning, including missing documentation and
training. These violations highlight potential risks to public health and the environment.
The proposed amendments for the TZC aim to strengthen the City's land use regulatory
oversight, providing a necessary tool to address these deficiencies and safeguard the
health, safety, and welfare of the TZC community.
Air emission complaints continue to be reported to SCAQMD. These complaints included
one involving black smoke and another regarding unpermitted soil vapor extraction
equipment onsite. SCAQMD staff has clarified that for air quality complaints they receive,
their inspector is required to be physically present to observe the activity from the facility
described in the complaint to determine if the complaint warrants further investigation or
enforcement action in accordance with SCAQMD Rules 401 (Visible Emissions), 402 (Public
Nuisance), and 403 (Fugitive Dust). Therefore, although community members continue to
share concerns with City and SCAQMD staff, the turnaround time for an SCAQMD inspector
to be physically present at an SCAQMD-permitted facility to investigate an air quality
complaint, especially if a complaint is reported after working hours or on weekends, is
ineffective in addressing the immediate needs of the community.
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Public Outreach
Following City Council's extension of the SD-84 TZC Moratorium on May 21, 2024, the
Planning and Building Agency has been developing proposed regulations for the TZC
district, encompassing the Downtown, Lacy, and Logan neighborhoods. This effort includes
updates to permitted uses (including the removal of industrial uses), operational standards,
non-conforming use regulations (including a new amortization process), and reflects
ongoing input from affected business owners, residents, community stakeholders, and
industrial/commercial brokers gathered since July 2024, including a Community Information
Meeting on October 22, 2024, and culminating in a series of meetings through February 20,
2025.
The draft amendments to the TZC were released to the public on January 15, 2025, and
were made available on the City’s Moratorium webpage. These amendments address the
permitted uses table, nonconforming regulations, amortization, and operational standards,
and are designed to prepare for the TZC Moratorium's expiration on April 15, 2025. Staff
met with business owners and brokers on January 30, 2025, to discuss the draft regulations
and met with the Lacy and Logan neighborhoods meeting on February 19, 2025, and again
with a focus group of industrial businesses on February 20, 2025. Staff have continued to
update the TZC (SD-84) Moratorium project webpage with additional updates, including the
Study Session and Public Hearing Notice and recent Planning Commission’s Study Session
PowerPoint presentation.
City staff have also prepared two Frequently Asked Questions (FAQ) documents to clarify
information regarding the Moratorium, affected businesses, the proposed zoning
amendments, legal concerns, community engagement, and opportunities to participate in
the public hearing process. The first FAQ became available prior to the City’s project
informational meeting on October 22, 2024, and the second FAQ is included with this staff
report (Exhibit 5).
Current Code and Proposed Amendments to Text, Figures and Maps
Based upon the City Council’s actions and direction enacting the moratorium combined with
the research and analysis of the issues herein, staff has prepared the proposed zoning
ordinance (ZOA No. 2024-02) and zoning map (AA No. 2024-03) amendments. The
proposed amendments would modify the list of land uses and permit types including the
deletion of industrial land uses; amend nonconforming regulations including the addition of
an amortization/termination of use process; amend and add operational standards for
allowed uses and nonconforming uses; delete the Industrial Overlay (I-OZ) zone from text
and maps; and delete the M1 (Light Industrial) and M2 (Heavy Industrial) suffixes from
certain properties within the TZC boundary as designated on the City of Santa Ana Zoning
Map.
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Table 1: ZOA No. 2024-02 Current and Proposed Text Regulations
Code Section Title Existing Zoning Code Regulations Proposed Zoning Code Regulations
Application of Article SAMC Section 41-2001 establishes the
land uses and standards applicable to
the TZC - primarily for new uses.
The update to text of this Section
clarifies that the regulations apply to
existing uses, whether conforming or
nonconforming, change in land use or
tenancy requiring issuance of Certificate
of Occupancy.
Organization SAMC Section 41-2001.5 establishes
the contents and organization of the
TZC regulations
The update to the text is necessary to
encompass the new Section 41-2009
(Operational Standards for
Nonconforming Industrial Uses).
Nonconforming
Buildings, Structures
and Uses
SAMC Section 41-2002 establishes the
regulations for nonconforming
buildings, structures or uses within the
TZC boundary. The provisions contain
minimal limits for rehabilitation of
buildings and structures and their
expansion for both residential and non-
residential uses.
The update to text of this Section will
further limit some rehabilitation of
buildings and structures, with specific
emphasis on nonconforming industrial
uses. These updated provisions include:
•Requiring rehabilitation or expansion
of buildings and structures, occupied
by any nonconforming use to comply
with the new operational standards
contained in Section 41-2009.
•Prohibits expansion of a building or
structure occupied by a
nonconforming industrial use.
•Discontinuation of nonconforming
noxious uses through amortization.
•Elimination of certain nonconforming
uses and structures
•Establishes a process for enacting
amortization periods for eliminating
certain nonconforming uses.
•References to SAMC and State law
for abatement of public nuisances.
•Establishes authority for voluntary
compliance agreements between the
City and nonconforming uses.
The Industrial
Overlay (I-OZ) Zone
SAMC Section 41-2004 establishes an
overlay zone applied to M1 and M2
zoned properties located within the
TZC boundary.
Section 41-2004 is deleted in its entirety,
removing the I-OZ Zone from the TZC to
eliminate industrial land use type zoning
altogether.
Application for
Discretionary
Approvals
SAMC Section 41-2005 establishes the
process and timing of vesting for
certain uses approved with a
discretionary permit.
Section 41-2005 is renumbered as 41-
2004, and the update to the text of this
Section adds clarification for effects of
the amendments to the TZC dependent
upon status of an application in the City
process of review, approval, and/or
building permit issuance, if required.
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Code Section Title Existing Zoning Code Regulations Proposed Zoning Code Regulations
Zones Established SAMC Section 41-2006 contains the
regulations for zoning districts, land
uses, and permit types within the TZC.
The update to the text of this Section
deletes the I-OZ Zone, including
replacing Figure 2.1, the Regulating Plan
(map) with a new Figure 2.1 removing
the I-OZ Zone designation from all
parcels within the TZC boundary.
Uses Permitted SAMC Section 41-2007 provides the
allowable land uses and permit types
required to establish a land use by
each zoning district within the TZC.
The update to the text of this Section
clarifies application of the use standards
by zoning district as follows:
•Modifies Table 2A containing the Use
Standards by adding and reclassifying
certain land use types appropriate to
the TZC land use subcategories
•Deletes certain land use types that are
inconsistent with the intent and
purpose of the TZC, including the
deletion of the Small-Scale Industry
land use subcategory in its entirety.
Operational
Standards
SAMC Section 41-2008 primarily
regulates new uses within the TZC.
The update to the text of this Section
further limits certain operations to ensure
greater compatibility between residential
and non-residential land uses.
Operational
Standards for
Nonconforming
Industrial Uses
SAMC Section 41-2009 is an entirely
new set of regulations specific to
existing nonconforming industrial uses
within the TZC.
The new Section establishes regulations
for operation of any existing, legally
established, nonconforming industrial
use. The regulations cover general
standards, enclosed operations, air
emissions and dust, light, glare, and
heat, ground vibration, outdoor storage
and screening, hazardous materials,
liquid and solid waste, site maintenance,
truck parking and loading, and hours of
operation.
Definitions SAMC Section 41-2080 contains the
definitions applicable to terms and land
uses of the TZC.
The update to the text of this Section
provides clarification for certain land use
types (artisan/craft product with limited
on-site production, commercial
recreation facility – indoor, and research
and development), adds definitions for
land use types (automobile repair,
automobile service, business support
services, craft and specialized
automotive restoration service, pet day
care facility and trade school), and
deletes corresponding definitions for land
use types that were deleted as part of
the amendments to SAMC Section 41-
2006.
Planning Commission 1 – 142 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 13
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7
Analysis of the Issues
The proposed amendments to the Sections of the TZC under the topic headings of
Application of Article, Organization, Application for Discretionary Approvals, and Definitions
are largely to ensure internal consistency related to the more substantive changes being
proposed for the TZC to address irreconcilable land use conflicts, described as follows:
•Nonconforming Structures and Uses - Section 41-2002 regulates the nonconforming
building, structure or use specifically within the TZC. The regulations are unique to
the TZC and do not apply citywide. The regulations determine under certain
circumstances when a nonconforming structure or use can rehabilitate both structural
or nonstructural; or expand conditions that would allow expansion. Due to the
concerns enumerated within this report related to nonconforming industrial uses
within the TZC, the amendments to this section increasingly limit rehabilitation of
structures to those types of improvements that address compliance with the new
Section 41-2009 operational standards for nonconforming industrial uses; and
disallow the expansion of any nonconforming industrial use. This Section also
includes new provisions to establish a process for the discontinuance of
nonconforming uses, specifically noxious uses, and the elimination of those uses or
structures through an amortization hearing process. The tools that these new
regulations provide are necessary to address the environmental impacts that lead to
the adoption of the Moratorium, provide the framework to initiate the process to
eliminate noxious industrial land uses from the TZC, and align with the adopted EJ
policies of the General Plan.
•The Industrial Overlay (I-OZ) Zone – Section 41-2004 created an “exception” zone
for properties within the TZC that had already contained M1 or M2 industrial zoning,
uses and structures, when the TZC was adopted in 2010. In order to be both
consistent and to promulgate the new General Plan land use designations within the
TZC, the removal of this overlay zone is necessary. The zone currently gives
deference to the property owner of these parcels with an industrial overlay to decide
when and whether to redevelop their properties in a manner that would remove the
industrial structure and use, replacing it with an allowable use and conforming to the
design standards of the TZC. Eliminating the I-OZ Zone will cause these properties
to become nonconforming as to use and structure, subjecting them to the regulations
as amended and added to Section 41-2002, including discontinuance of
nonconforming use or structure though amortization. With the deletion of the entirety
of the text of Section 41-2004, Section 41-2005 Application for Discretionary
Approvals is renumbered as Section 41-2004.
•Zones Established and Uses Permitted – Amendments to Sections 41-2006 and 41-
2007, respectively, include parallel deletion of the I-OZ Zone affecting the Regulating
Plan (TZC zoning map) and the corresponding Use Standards tables regulating the
land use and permit types for each of the remaining zones of the TZC. Table 2A
categorizes land uses into broad subheadings for both residential and nonresidential
land uses. The nonresidential land uses are further categorized into commercial-
Planning Commission 1 – 143 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 14
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7
oriented versus industrial-oriented types of uses. The amendments will eliminate the
Small-Scale Industry sub-category altogether, since the majority of these uses are
industrial uses incompatible with residential uses. The purpose of the TZC is to
promote transit-oriented mixed-use development, which pairs residential and
nonresidential land uses either horizontally or vertically on a site or within a building.
Compatibility of allowable land use types is critical, particularly given the history of
the negative impacts from industrial uses remaining in the area and in close proximity
to existing and new residential areas. Amending this Section also replaces the TZC
zoning map figure to ensure consistency with the City’s Official Zoning Map and
General Plan Land Use Map in accordance with requirements of State law,
Government Code Section 65860.
•Operational Standards and Operational Standards for Nonconforming Industrial
Uses – Section 41-2008 contains operational standards applicable to all uses within
the TZC boundary. This Section is largely unchanged, with clarification and
strengthening of certain regulations to address any possible industrial type function
of an allowable land use type as listed in the tables of Section 41-2007. These
amendments affected any possible manufacturing related activities, sound,
screening walls and eliminated any vehicular service on Sundays. Section 41-2009
establishes new regulations governing existing industrial uses made nonconforming
with the removal of the I-OZ Zone within the TZC, and include general standards,
enclosed operations, air emissions and dust, light, glare, and heat, ground vibration,
outdoor storage and screening, hazardous materials, liquid and solid waste, site
maintenance, truck parking and loading, and hours of operation. The amendments
to Section 41-2008 and creation of new regulations under Section 41-2009 ensure
that existing nonconforming uses comply with very specific operational standards
and/or face amortization that leads ultimately to discontinuance of use, effectively
reestablishing the TZC area with residential uses and allowing certain nonresidential
uses compatible to such residential and/or mixed-use development.
Profile of Industrial Businesses Affected with Proposed Regulations
The SD-84 Transit Zoning Code (TZC) area is characterized by a diverse mix of
approximately 127 industrial businesses. These businesses range from automotive services
(the most common industry type) and manufacturing to warehousing and recycling centers.
Data compiled from city and external regulatory agencies, including CalEPA, SCAQMD, and
CERS, reveal that these businesses operate under various permits related to hazardous
materials, air quality, and water quality.
Key business characteristics include the storage and use of hazardous materials such as
motor oil, solvents, and various chemicals, as well as the operation of equipment like
emergency generators and internal combustion engines. Notably, several businesses,
particularly those engaged in manufacturing (spray booths, metal processing) and chemical
storage, handle substances like xylene, resins, mineral oils, and acids, posing potential risks
related to air and water contamination, as well as fire and health hazards. Heavier industrial
operators, such as open air recycling and sorting facilities in the TZC have been creating a
Planning Commission 1 – 144 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 15
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7
range of issues in the neighborhood. Issues range from: 1) air pollution – dust and participate
matter from the sorting process that can become airborne, leading to respiratory problems
and reduced air quality, VOCs released from decomposing materials, and odors; 2) water
pollution from stormwater runoff that can carry contaminants, including debris, chemicals,
or bacteria, from a facility to nearby waterways; 3) noise pollution from heavy machinery,
trucks, and sorting equipment generating noise; 4) visual blight from the constant movement
of trucks and equipment and from the piles of trash, debris, and recycling materials that
detract from the aesthetic appeal of the community. The secondary effects affect residents’
quality of life with increased traffic hazards and living next to these heavier industrial uses
and the risks being exposed to these issues on a daily basis.
General Plan Consistency
The proposed zoning ordinance amendments are consistent with various goals and policies
of the Santa Ana General Plan, as required by Government Code Section 65860, by timely
addressing current inconsistencies within an area of the City prioritized for addressing EJ.
In effect, the amendments are necessary to address numerous policies of the General Plan
that the current TZC is found to be inconsistent with, that without such amendments, will
continue the path of irreconcilable land use patterns within the TZC. Specifically, these
policies include Policy LU-1.1 (Compatible Uses), Policy LU-2.4 (Cost and Benefit of
Development), Policy LU-3.8 (Sensitive Receptors), Policy LU-3.9 (Noxious, Hazardous,
Dangerous, and Polluting Uses), Policy LU-3.11 (Air Pollution Buffers), Policy LU-4.3
(Sustainable Land Use Strategies), Policy LU-4.6 (Healthy Living Conditions), Policy CM-
3.2 (Healthy Neighborhoods), Policy EP-1.9 (Avoid Conflict of Uses), Policy EP-3.3 (Mitigate
Impacts), Policy CN-1.5 (Sensitive Receptor Decisions), Policy CM-3.2 (Healthy
Neighborhoods), and Policy HE-5.5 (Community Development), which are targeted at
correcting past land use planning practices that have placed an unequitable environmental
and health burden on certain neighborhoods now termed disadvantaged communities. The
proposed amendments support these goals and policies by:
•Fostering the compatibility between residential and nonresidential land uses within
the TZC to enhance livability and promote healthier lifestyles, and improve public
health and quality of life;
•Resolving the development of industrial land uses and sensitive receptors being in
close proximity to each other that pose health hazards by eliminating an overlay zone
that promulgated continuation of industrial uses without recourse;
•Improving the health of the existing and future residents of the TZC by regulating the
operations of noxious, hazardous, dangerous, and polluting uses by giving priority to
the discontinuance of those uses;
•Responding to overarching EJ policies to develop and implement land use and
zoning strategies to separate existing sensitive uses from heavy industrial facilities
and emission sources;
•Continuing to support the creation of healthy neighborhoods by addressing land use
conflicts and incompatible uses through the elimination of the I-OZ zone and
associated industrial land use types from the list of allowable land uses within the
TZC;
Planning Commission 1 – 145 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 16
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7
•Developing and adopting new regulations to address facilities that emit increased
pollution new sensitive receptors within EJ area boundaries, which includes areas of
the TZC;
•Avoiding potential land use conflicts in the future by prohibiting the location of noxious
land uses in proximity to sensitive receptors; and
•Creating a sustainable land use plan for the area that phases out land uses that are
causing a substantial drain on City and other public agency resources in addressing
the impacts from irreconcilable land use conflicts in the TZC area.
Additionally, the proposed amendments implement and/or contribute to achieving the
following specific action programs of the General Plan, most particularly directly addressing
LU3.3 through the creation of a discontinuance of nonconforming industrial uses through
amortization:
LU1.1 - Development Code Update. Prepare a comprehensive update to the zoning code
to ensure that the City’s zoning regulations align with the General Plan’s goals and policies.
Update the Metro East Mixed-Use Overlay District to remove the portion within the 17th
Street and Grand Avenue Focus Area. Update the Midtown Specific Plan.
LU3.3 - Healthy lifestyles. Collaborate with residents and industry stakeholders to create a
program to incentivize and amortize the removal of existing heavy industrial uses adjacent
to sensitive uses.
CN1.4 - Health risk criteria. Establish criteria for requiring health risk assessments for
existing and new industries, including the type of business, thresholds, and scope of
assessment. Review existing and establish new regulation to reduce and avoid increased
pollution near sensitive receptors within environmental justice area boundaries.
CN1.7 - Truck idling. Evaluate strategies to reduce truck idling found or reported in areas
with sensitive receptors, with a priority placed on environmental justice areas.
CN1.11 - Public education. Augment existing outreach programs to improve public
awareness of State, regional and local agencies’ roles and resources to identify, monitor,
and address air quality and other environmental hazards in the community.
HE5.C – Healthy Neighborhoods Initiatives. Update the City’s zoning code development and
operational standards for industrial zones to address incompatibility with adjacent uses,
including minimum distance requirements to buffer heavy industrial uses from sensitive
receptors. Conduct a study to evaluate and establish appropriate minimum distances and
landscape buffers between polluting industrial uses from sensitive receptors such as
residences.
HE44.A – Fair Housing. Ensure all City programs and activities relating to housing and
community development are administered in a manner that affirmatively furthers fair
housing.
Planning Commission 1 – 146 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 17
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Santa Ana’s current General Plan champions implementation policies, including 77 EJ
actions that address air quality, noxious uses, water safety, residential lead exposure in
the soil, and other environmental public health conditions. The proposed Transit Zoning
Code amendments align with both the General Plan's EJ policies and the original land
use designations applicable to the area since the adoption of the Transit Zoning Code in
2010.
ENVIRONMENTAL IMPACT
The California Environmental Quality Act (CEQA) requires public agencies and local
governments to measure the environmental impacts of development projects or other
major land use decisions, and to limit or avoid those impacts if possible. CEQA Guidelines
Section 15164 states the following with respect to an Addendum to an EIR:
a) The lead agency or responsible agency shall prepare an addendum to a previously
certified EIR if some changes or additions are necessary but none of the conditions
described in Section 15162 calling for preparation of a subsequent EIR have occurred.
b) An addendum to an adopted negative declaration may be prepared if only minor
technical changes or additions are necessary or none of the conditions described in
Section 15162 calling for the preparation of a subsequent EIR or negative declaration
have occurred.
c) An addendum need not be circulated for public review but can be included in or
attached to the final EIR or adopted negative declaration.
d) The decision-making body shall consider the addendum with the final EIR or adopted
negative declaration prior to making a decision on the project.
e) A brief explanation of the decision not to prepare a subsequent EIR pursuant to
Section 15162 should be included in an addendum to an EIR, the lead agency’s
findings on the project, or elsewhere in the record. The explanation must be supported
by substantial evidence.
Additionally, CEQA Guidelines Section 15162, Subsequent EIRs and Negative
Declarations, states the following with respect to a Subsequent EIRs:
(a) When an EIR has been certified or a negative declaration adopted for a project, no
subsequent EIR shall be prepared for that project unless the lead agency determines,
on the basis of substantial evidence in the light of the whole record, one or more of
the following:
(1) Substantial changes are proposed in the project which will require major
revisions of the previous EIR or negative declaration due to the involvement of
new significant environmental effects or a substantial increase in the severity
of previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the
project is undertaken which will require major revisions of the previous EIR or
Negative Declaration due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified
significant effects; or
Planning Commission 1 – 147 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 18
3
3
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7
(3) New information of substantial importance, which was not known and could not
have been known with the exercise of reasonable diligence at the time the
previous EIR was certified as complete or the Negative Declaration was
adopted, shows any of the following:
(A)The project will have one or more significant effects not discussed in the
previous EIR or negative declaration;
(B)Significant effects previously examined will be substantially more severe
than shown in the previous EIR;
(C)Mitigation measures or alternatives previously found not to be feasible
would in fact be feasible, and would substantially reduce one or more
significant effects of the project, but the project proponents decline to
adopt the mitigation measure or alternative; or
(D)Mitigation measures or alternatives which are considerably different
from those analyzed in the previous EIR would substantially reduce one
or more significant effects on the environment, but the project
proponents decline to adopt the mitigation measure or alternative.
(b) If changes to a project or its circumstances occur or new information becomes
available after adoption of a negative declaration, the lead agency shall prepare a
subsequent EIR if required under subdivision (a). Otherwise, the lead agency shall
determine whether to prepare a subsequent negative declaration, an addendum, or
no further documentation.
ZOA No. 2024-02 and AA No. 2024-03 are considered a project as defined by the CEQA.
The City, as the Lead Agency, has determined that it is subject to CEQA guidelines and
regulations (Public Resources Code (PRC) Sections 21000-21177). An Addendum to the
Transit Zoning Code Environmental Impact Report (EIR) (State Clearing House (SCH)
No. 2006071100) has been prepared by the City. Based on its independent review and
analysis, and the administrative record as a whole, and, in the exercising its independent
judgement, hereby finds that pursuant to CEQA Guidelines Section 15162, no
subsequent EIR would be required for the proposed project; and pursuant to CEQA
Guidelines Section 15164, an addendum to the Transit Zoning Code EIR is required for
the adoption of the Ordinances.
Specifically, pursuant to CEQA Guidelines Section 15162, the City finds on the basis of
substantial evidence in light of the whole record, that: (1) no substantial changes are
proposed in the project which will require major revisions of the EIR due to the
involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects; (2) no substantial changes have
occurred with respect to the circumstances under which the project is undertaken which
will require major revisions of the EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously identified
significant effects; and (3) there is no new information of substantial importance, which
was not known and could not have been known with the exercise of reasonable diligence
at the time the EIR was certified as complete, that shows any of the following: (A) the
project will have one or more significant effects not discussed in the EIR; (B) significant
effect previously examined will be substantially more severe than shown in the EIR; (C)
Planning Commission 1 – 148 3/6/2025
ZOA No. 2024-02 & AA No. 2024-03 (Transit Zoning Code Amendments)
February 24, 2025
Page 19
3
3
6
7
mitigation measures or alternatives previously found not to be feasible would in fact be
feasible and would substantially reduce one or more significant effects of the project, but
the project proponents decline to adopt the mitigation measure or alternative; or (D)
mitigation measures or alternative which are considerably different from those analyzed
in the EIR would substantially reduce one or more significant effects on the environment,
but the project proponents decline to adopt the mitigation measure or alternative.
Additionally, as detailed in the General Plan Consistency subsection of this report, the
proposed Ordinances are consistent with numerous General Plan goals and policies that
were evaluated as part of the General Plan Update Program EIR. The proposed
Ordinances also satisfy and further implementation actions of the General Plan Update.
FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBITS
1. Resolution of the City Council and Addendum to the TZC EIR
2. Ordinance for Zoning Ordinance Amendment (ZOA) No. 2024-02
3. Ordinance for Amendment Application (AA) No. 2024-03
4. Environmental Health Data and Reports
5. Frequently Asked Questions (FAQ)
6. City Council Staff Report and Exhibits for the Adopted TZC Moratorium
7. Copy of Public Hearing Notice
Submitted By: Margarita Macedonio, Principal Planner
Approved By: Ali Pezeshkpour, AICP, Acting Executive Director, Planning and Building
Agency
Planning Commission 1 – 149 3/6/2025
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NOTICE OF STUDY SESSION
&
PUBLIC HEARING
BEFORE THE SANTA ANA
PLANNING COMMISSION
The City of Santa Ana encourages
the public to participate in the
decision-making process. This
notice is provided consistent with
applicable State and local law, in
addition to being provided to those
persons who have expressed an
interest in the proposed action. We
encourage those with questions or
comments to contact us prior to
either or both the Study Session
and/or Public Hearing.
Please be advised that the City will
hold a Study Session concerning
the following, more fully described
below:Zoning Ordinance
Amendment (ZOA) No. 2024-02 and
Amendment Application (AA) No.
2024-03 to amend the Transit Zoning
Code (Specific Development (SD)
No. 84) zoning district of Chapter 41
(Zoning)during the regular
meeting of the Planning
Commission on the following date
and time:
Study Session Date:Monday,
February 10, 2025 Time: 5:30 PM
Further, NOTICE IS HEREBY
GIVEN that the Planning
Commission of the City of Santa Ana
will hold a public hearing to receive
public testimony and take action on
Zoning Ordinance Amendment
(ZOA) No. 2024-02 and Amendment
Application (AA) No. 2024-03 to
amend the Transit Zoning Code
(Specific Development (SD) No. 84)
zoning district of Chapter 41
(Zoning).
Public Hearing Date:Monday,
February 24, 2025 Time: 5:30 PM
Project Location :The area within
the Transit Zoning Code/Specific
Development (SD) No. 84 Zoning
District, as depicted in the attached
map.
Project Applicant:City of Santa
Ana
Proposed Project:Planning
Commission recommendation that
the City Council adopt Zoning
Ordinance Amendment (ZOA) No.
2024-02 and Amendment Application
(AA) No. 2024-03 to amend the
Transit Zoning Code (Specific
Development (SD) No. 84) zoning
district of Chapter 41 (Zoning) of the
Santa Ana Municipal Code and to
amend the City's Zoning Map. The
proposed amendments include
removal of industrial uses from the
permitted uses table, updates to the
nonconforming regulations, a new
amortization process, and new
operational standards applicable to
businesses within the zoning district.
The proposal also includes removing
Planning Commission 1 – 150 3/6/2025
the Light Industrial (M1)and Heavy
Industrial (M2)suffixes from
certain properties within the SD-84
zoning district,as shown on the
City's Zoning Map.
En viron mental Impact:In
accordance with CEQA and the
CEQA Guidelines,an addendum has
been prepared to the City of Santa
Ana's Transit Zoning Code (SD-84)
Environmental Impact Report
(EIR)to demonstrate that,pursuant
to the standards contained in CEQA
Guidelines Section 15162,this project
is within the scope of the Transit
Zoning Code (SD-84)EIR No.2006-
02,State Clearinghouse (SCH)No.
2006071100,certified by the City of
Santa Ana on June 7,2010.The
Transit Zoning Code (SD-84)EIR
fully analyzed the potential impacts
associated with the proposed code
amendments.This is consistent with
Section 8.06 of the City's Local
Guidelines for Implementing CEQA.
Meeting Details:This matter will
be heard in the City Council
Chambers,22 Civic Center Plaza,
Santa Ana,CA 92701.Members of
the public may at tend this me eting
in person or join via Zoom.For the
most up-to-date information on how
to participate virtually in this
meeting,please visit
https://www.santa-
ana.org/planning-and-building-
meeting-participation/.
Written Commen ts:If you are
unable to participate in the meeting,
you may send written comments by
e-mail to PBAeComments@santa-
ana.org (reference the Agenda Item
#in the subject line)or by mail to
Nuvia Ocampo,Recording
Secretary,City of Santa Ana,20
Civic Center Plaza ---M20,Santa
Ana,CA 92701.Deadline to submit
written comments is 3 :30 p.m.on
the day of the meeting.Comments
received after the deadline may not
be distributed to the Commission but
will be made part of the record.
Where To Get More Information :
Additional details regarding the
proposed action(s),including the
full text of the discretionary item,
may be found on the City website 72
hours prior to the public hearing at
https://santa-
ana.primegov.com/public/portal.
Who To Contact For Questions:
Should you have any project
questions,please contact Principal
Community Planner Margarita
Macedonio with the Planning
Division by phone at (714)667-2288 or
by email at MMacedonio@santa-
ana.org.
Note:If you challenge the decision
on the above matter,you may be
limited to raising only those issues
you or someone else raised at the
public hearing described in this
notice,or in written correspondence
delivered to the Planning
Commission or City Council of the
City of Santa Ana at,or prior to,the
public hearing.
N u c n liên l c b ng ti ng Vi t,xi n
i n tho i cho Kristie Ha (714)667-
2206.
1/31/25
CNS-3891625#
ORA NGE CO UNTY REGISTER
Planning Commission 1 – 151 3/6/2025
CITY OF SANTA ANA
Planning and Building Agency
20 Civic Center Plaza ● P.O. Box 1988
Santa Ana, California 92702
www.santa-ana.org/pba
NOTICE OF STUDY SESSION
&
PUBLIC HEARING
BEFORE THE SANTA ANA PLANNING COMMISSION
The City of Santa Ana encourages the public to participate in the decision-making process. This
notice is provided consistent with applicable State and local law, in addition to being provided
to those persons who have expressed an interest in the proposed action. We encourage those
with questions or comments to contact us prior to either or both the Study Session and/or
Public Hearing.
Please be advised that the City will hold a Study Session concerning the following, more fully
described below: Zoning Ordinance Amendment (ZOA) No. 2024-02 and Amendment Application
(AA) No. 2024-03 to amend the Transit Zoning Code (Specific Development (SD) No. 84) zoning district
of Chapter 41 (Zoning) during the regular meeting of the Planning Commission on the following
date and time:
Study Session Date: Monday, February 10, 2025 Time: 5:30 PM
Further, NOTICE IS HEREBY GIVEN that the Planning Commission of the City of Santa Ana will hold
a public hearing to receive public testimony and take action on Zoning Ordinance Amendment (ZOA)
No. 2024-02 and Amendment Application (AA) No. 2024-03 to amend the Transit Zoning Code (Specific
Development (SD) No. 84) zoning district of Chapter 41 (Zoning).
Public Hearing Date: Monday, February 24, 2025 Time: 5:30 PM
Project Location: The area within the Transit Zoning Code/Specific Development (SD) No. 84
Zoning District, as depicted in the attached map.
Project Applicant: City of Santa Ana
Proposed Project: Planning Commission recommendation that the City Council adopt Zoning
Ordinance Amendment (ZOA) No. 2024-02 and Amendment Application (AA) No. 2024-03 to amend
the Transit Zoning Code (Specific Development (SD) No. 84) zoning district of Chapter 41 (Zoning) of
the Santa Ana Municipal Code and to amend the City’s Zoning Map. The proposed amendments
include removal of industrial uses from the permitted uses table, updates to the nonconforming
regulations, a new amortization process, and new operational standards applicable to businesses
within the zoning district. The proposal also includes removing the Light Industrial (M1) and Heavy
Industrial (M2) suffixes from certain properties within the SD-84 zoning district, as shown on the City’s
Zoning Map.
Environmental Impact: In accordance with CEQA and the CEQA Guidelines, an addendum has been
prepared to the City of Santa Ana’s Transit Zoning Code (SD-84) Environmental Impact Report (EIR)
to demonstrate that, pursuant to the standards contained in CEQA Guidelines Section 15162, this
project is within the scope of the Transit Zoning Code (SD-84) EIR No. 2006-02, State Clearinghouse
Planning Commission 1 – 152 3/6/2025
(SCH) No. 2006071100, certified by the City of Santa Ana on June 7, 2010. The Transit Zoning Code
(SD-84) EIR fully analyzed the potential impacts associated with the proposed code amendments. This
is consistent with Section 8.06 of the City’s Local Guidelines for Implementing CEQA.
Meeting Details: This matter will be heard in the City Council Chambers, 22 Civic Center Plaza, Santa
Ana, CA 92701. Members of the public may attend this meeting in person or join via Zoom. For
the most up-to-date information on how to participate virtually in this meeting, please visit
https://www.santa-ana.org/planning-and-building-meeting-participation/.
Written Comments: If you are unable to participate in the meeting, you may send written comments
by e-mail to PBAeComments@santa-ana.org (reference the Agenda Item # in the subject line) or by
mail to Nuvia Ocampo, Recording Secretary, City of Santa Ana, 20 Civic Center Plaza – M20, Santa
Ana, CA 92701. Deadline to submit written comments is 3:30 p.m. on the day of the meeting.
Comments received after the deadline may not be distributed to the Commission but will be made part
of the record.
Where To Get More Information: Additional details regarding the proposed action(s), including the full
text of the discretionary item, may be found on the City website 72 hours prior to the public hearing at
https://santa-ana.primegov.com/public/portal.
Who To Contact For Questions: Should you have any project questions, please contact Principal
Community Planner Margarita Macedonio with the Planning Division by phone at (714) 667-2288 or by
email at MMacedonio@santa-ana.org.
Note: If you challenge the decision on the above matter, you may be limited to raising only those issues
you or someone else raised at the public hearing described in this notice, or in written correspondence
delivered to the Planning Commission or City Council of the City of Santa Ana at, or prior to, the public
hearing.
Nếu cần liên lạc bằng tiếng Việt, xin điện thoại cho Kristie Ha (714) 667-2206.
City of Santa Ana
Transit Zoning Code Area
Planning Commission 1 – 153 3/6/2025
1
Ocampo, Nuvia
From:Odalis Osornio <odalis.osornio@yahoo.com>
Sent:Tuesday, February 4, 2025 1:06 PM
To:eComments, PBA
Subject:Support for SD-84 Transit Zoning Code Amendment
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC. The health and safety of our community, especially our children and
families, should remain a top priority, and the industrial uses in the zone are eroding the quality of life
for us residents. I am a mother of two toddlers and we cannot walk by there to go to the park around
the neighborhood due to transient's hanging around all over our neighborhood and not feeling safe.
Due to all the drugs being done in plain sight. This metal dump is just causing more and more
problems to our community.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Oddallis Osornio
Resident of Santa Ana
FYI: 10,000 resident estimate is based on press release from city (linked below) which states that the
TZC is approximately 450 acres (.7 square miles) and that “Lacy and Logan are more densely
populated than Santa Ana as a whole, with a combined population density of 15,531.7 persons per
square mile.”
https://www.santa-ana.org/city-of-santa-ana-moves-to-protect-oldest-neighborhoods-from-industrial-
pollution-under-historic-environmental-justice-initiative/
Planning Commission 1 – 154 3/6/2025
1
Ocampo, Nuvia
From:Ryan Friesen <rykfri@gmail.com>
Sent:Wednesday, February 5, 2025 8:05 AM
To:eComments, PBA
Subject:Support for SD-84 Transit Zoning Code Amendment
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
My name is Ryan and I am writing as a homeowner (and landlord) in the Transit Zoning Code area to strongly
urge you to approve the amendments to the TZC. The health and safety of our community is a top priority for
me and my wife, and the industrial uses in the zone are incompatible with the quality of life we want.
Santa Ana is a great place to live and work, but litter and waste, chemical pollution on the streets, and air
pollution are key indicators that industrial neighbors are not being good stewards.
Metal recyclers and waste dumps have their place, just not 200 feet away from an elementary school and a
neighborhood park. These types of industries, though essential, need to be placed outside of the residential and
transit-oriented development zone we are working to build. The City Council has twice agreed unanimously that
industrial uses in this zone have placed an inequitable environmental and health burden on those of us in the
Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022 compels you to address
these inequities by permanently banning industrial uses in the Transit Zoning Code.
Please do not allow outside business interests to override the concerns of the approximately 10,000 residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Ryan Friesen
703 N. Poinsettia St.
Homeowner in Ward 6
Planning Commission 1 – 155 3/6/2025
1
Ocampo, Nuvia
From:Adam Toogood <adamtoogood@gmail.com>
Sent:Thursday, February 6, 2025 3:12 PM
To:eComments, PBA
Subject:Support for SD-84 Transit Zoning Code Amendment
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC. The health and safety of our community, especially our children and
families, should remain a top priority, and the industrial uses in the zone are eroding the quality of life
for us residents. The littering caused by these businesses is disrupting our living environment and
posing a risk to my children’s health. The roads in our neighborhood are already risky to my children’s
lives but also mine and my wife’s. The speed at which these local businesses go through our streets
is dangerous to all lives.
Plus, we feel that the highlighted portion below will also badly affect our neighborhood with increased
traffic and more noise to a residential zone from what is already a noisy structure.
Planning Commission 1 – 156 3/6/2025
2
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Planning Commission 1 – 157 3/6/2025
3
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Adam Toogood
Resident of Santa Ana
FYI: 10,000 resident estimate is based on press release from city (linked below) which states that the
TZC is approximately 450 acres (.7 square miles) and that “Lacy and Logan are more densely
populated than Santa Ana as a whole, with a combined population density of 15,531.7 persons per
square mile.”
https://www.santa-ana.org/city-of-santa-ana-moves-to-protect-oldest-neighborhoods-from-industrial-
pollution-under-historic-environmental-justice-initiative/
Planning Commission 1 – 158 3/6/2025
1
Ocampo, Nuvia
From:Mayra Rangel <c21.mayra@yahoo.com>
Sent:Thursday, February 6, 2025 8:54 PM
To:eComments, PBA
Subject:Support for SD-84 Transit Zoning Code Amendment
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC. The health and safety of our community, especially our children and
families, should remain a top priority, and the industrial uses in the zone are eroding the quality of life
for us residents.
There are several businesses in the area that emit a foul odor, making it impossible to open our windows or
spend time outside without being overwhelmed by the smell. Walking my dog around the neighborhood is a
challenge due to the poor air quality, contaminated sidewalks, trash, and the constant presence of transients
using drug paraphernalia. It’s heartbreaking to see young children attending Garfield Elementary exposed to
these conditions every day.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
M.Rangel
Resident of Santa Ana
Planning Commission 1 – 159 3/6/2025
1
Ocampo, Nuvia
From:Kevin Tranter <kevint@austinhardwoods.net>
Sent:Friday, February 7, 2025 12:54 PM
To:eComments, PBA
Subject:Confirmation of retail use by Austin Hardwoods
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Minh/Margarita,
Thank you for visiting our site last week. We were pleased that you both agreed our facility qualifies primarily as retail
use. As we mentioned, the City of Santa Ana classifies us as retail and issues us a retail operating permit annually. Our
understanding is that retail uses are permitted as of right in the UN-2 district adopted in or about 2010. We acknowledge
our retail use may require a CUP because it exceeds 20,000 square feet. We have never been asked to apply for a CUP,
but we are confident our operations meet all compatibility requirements as a retail use under the City’s CUP requirements.
As you know, we have occupied this site for 24 years without complaints and our continued use does not impose any
objectionable impacts on current or future neighbors.
Retail use has been planned on our property since at least 2002, consistent with our long-term operations. Austin
Hardwoods is happy that its operations comply both with the M-1 zoning designation AND the new UC classification.
Given the above information, our understanding is that our operations are consistent with both the moratorium and the
proposed SD-84 Plan. In other words, our use continues to be permitted as retail under the prior M-1 Zoning and the
proposed UC (Urban Center) Zoning. Unless the city wishes us to apply for a CUP to allow our operations to operate in
more than 20,000 square feet, we do not require any additional permits.
Again, thank you for meeting with us on site and confirming verbally that Austin Hardwoods & Hardware appears to be a
well-operated, clean, and self- contained retail use.
Please confirm our understanding of the above as soon as possible. If you have any questions, please call as soon as
possible.
Sincerely,
Judith Lomax
Kevin Tranter 949-294-8600
Planning Commission 1 – 160 3/6/2025
1
Ocampo, Nuvia
From:Betsy Lewis <betslewis@gmail.com>
Sent:Friday, February 7, 2025 1:07 PM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update.
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to
strongly urge you to approve the amendments to the TZC. The
health and safety of our community, especially our children and
families, should remain a top priority, and the industrial uses in the
zone are eroding the quality of life for us residents. Almost daily
when we go out for walks we see metal scraps left behind by
patrons of Bruce Metal.
Metal recyclers and waste dumps have no place 200 feet away
from an elementary school, and a crematorium has no place
around the corner from homes and a neighborhood park. These
types of industries bring noise, air pollution, and health risks that
are incompatible with the residential and transit-oriented
development we are working to build. The City Council has twice
agreed unanimously that industrial uses in this zone have placed
an inequitable environmental and health burden on those of us in
the Logan and Lacy neighborhoods. The General Plan adopted by
the City Council in 2022 compels you to address these inequities by
approving the proposed amendments.
Please do not allow outside business interests to override the
concerns of the approximately 10,000 residents who live here and
deal with these health and safety concerns everyday.
Planning Commission 1 – 161 3/6/2025
2
Sincerely,
John and Betsy Lewis
Resident of Santa Ana
Sent from my iPhone
Planning Commission 1 – 162 3/6/2025
1
Ocampo, Nuvia
From:Christine Schweer <cschweer15@gmail.com>
Sent:Monday, February 10, 2025 9:23 AM
To:eComments, PBA
Cc:Todd
Subject:Agenda item ZOA No. 2024-02 & AA No. 2024-03
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
My name is Todd Schweer, and I am a business partner at Boyce Industries, located at 1105
N. Poinsettia St, Santa Ana, in the Logan Lacy neighborhood. I became a partner with my
stepfather, Edward Boyce, in July of 2008. Ed purchased this property in 1978 and has since
built a successful pressure washer sales and service company.
In 2008, at the height of the recession, I moved my wife and children from Michigan to
California, with the goal of continuing our family’s legacy and improving the future for our
children. This business has meant so much to me, especially as I’ve watched it grow and
become a vital part of the community.
I am deeply concerned about the SD 84 Transit Authority proposal and how it could
potentially threaten our ability to continue this family legacy. This is especially significant to
me given my son’s rare genetic health condition, that has left him blind and which limits his
independence. It has always been my hope that he would work alongside me, learn the trade,
and grow into an independent adult. This year marks a significant milestone as he has just
recently turned 18.
Over the past 15 years, I’ve strived to enhance the business which includes the Boyce
Industries property—both inside and out—breathing new life into an older structure. Like
many other local business owners have shared, our company, Boyce Industries, has also
been a strong supporter of the community, providing jobs and teaching young people
valuable skills that will help them in the future. We are invested in this neighborhood and
the people who reside within these boundaries, and we care deeply about its well-being.
Planning Commission 1 – 163 3/6/2025
2
Thank you for your consideration. As a legacy business, we are committed to continuing our
growth and development alongside the neighborhood that has been our home for nearly 50
years.
Planning Commission 1 – 164 3/6/2025
1
Ocampo, Nuvia
From:Kelly Kraus-Lee <kellyakraus@gmail.com>
Sent:Monday, February 10, 2025 10:31 AM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC. The industrial uses in the zone, including the dump, crematorium, tow truck
business and metal recycling facility, are eroding the quality of life for us residents. I have entire
streets I cannot walk or drive down because of these businesses. People are loitering around the
metal recycling facility all day, stripping metal and doing drugs. Multiple pleas to the business owner
have fallen on deaf ears. The dump trucks line up on Poinsettia, blocking access to my neighborhood
and the local school all day while polluting the air. Tow trucks and semi trucks speed down the
streets, ignoring stop signs and endangering the lives of residents, including children walking to/from
Garfield Elementary School.
You are going to hear a lot from "responsible business owners" who are "loyal members of the community," but
don't let them fool you. These business owners are nowhere to be seen when needing to address the multitude of
quality of life issues their businesses create everyday. They do not actually live here, they just extract resources
and leave a fog of pollution before they get on the 5 freeway to return to their families in another city. There are
approximately 10,000* people who live in the TZC and the city needs to listen to us, not outside business
owners. This is one of the most densely populated neighborhoods in the city, why should us residents unduly
bear the negative impacts on our city by industrial businesses?
Sincerely,
Kelly Kraus-Lee
Resident of Santa Ana
*10,000 resident estimate is based on press release from city (linked below) which states that the
TZC is approximately 450 acres (.7 square miles) and that “Lacy and Logan are more densely
populated than Santa Ana as a whole, with a combined population density of 15,531.7 persons per
square mile.”
https://www.santa-ana.org/city-of-santa-ana-moves-to-protect-oldest-neighborhoods-from-industrial-
pollution-under-historic-environmental-justice-initiative/
Planning Commission 1 – 165 3/6/2025
1
Ocampo, Nuvia
From:Christy Taylor <Christy@christy-taylor.com>
Sent:Monday, February 10, 2025 11:45 AM
To:eComments, PBA
Cc:Christy Taylor
Subject:Transit Zoning Code SD-84 draft regulations
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana,
I am wriƟng to you regarding the draŌ regulaƟons for the Transit zoning
code SD‐84. I am an owner of the building at 21 Fuller Street, Santa Ana. I
believe that our building is in the area that the regulaƟons are being re‐
draŌed for.
When we purchased the building in 2016, we were told by the City that
this would always be zoned as general industrial. Now I am learning that
the City is considering rezoning this property and as a result the property
would not only lose value, but would narrow the scope of the type of
business that could occupy and operate in the building. I am very
troubled by what the City is doing and never once has the City
approached me to get my input or concerns. I have not received any
informaƟon from the City.
Our tenant is equally disturbed given they don’t know how this will
impact their operaƟons and they employ 20 employees locally and
several others in other locaƟons. In fact, they have employees who live
in Santa Ana.
I have tried to call our Council member David Pendaloza several Ɵmes,
only to be sent to voicemail with no returned calls. I was just now sent
Planning Commission 1 – 166 3/6/2025
2
informaƟon and given this email where I could write to the City. I would
really appreciate a phone call so that I have someone who can explain
why the City is trying to change the zoning, impact our tenant and reduce
the value of our building. My number is 707‐815‐6488.
Thank you,
Christy Taylor
Planning Commission 1 – 167 3/6/2025
1
Ocampo, Nuvia
From:Gabriella Orozco <orozcog3@gmail.com>
Sent:Monday, February 10, 2025 12:14 PM
To:eComments, PBA
Subject:No 2024-02
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Many businesses located near residential areas are open on weekdays as well ad weekends which does not allow
residents to enjoy home life. Businesses near my own home work early morning and late nights no matter weekday or
weekend!
Sent from my iPhone
Planning Commission 1 – 168 3/6/2025
1
Ocampo, Nuvia
From:Sean Aguinaga <sean.a@hey.com>
Sent:Monday, February 10, 2025 12:23 PM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the amendments to
the TZC - with one change.
Storage units are industrial uses. They do not belong in a transit zone. People’s boxes full of stuff cannot
ride trains or make use of public transit. Nor do these facilities address our housing shortage or promote
a healthy street-business interface.
Remove the CUP exemption for storage units that was lobbied for by Extra Space Storage from this plan,
seen here:
Planning Commission 1 – 169 3/6/2025
2
The health and safety of our community, especially our children and families, should remain a top priority, and
the industrial uses in the zone are eroding the quality of life for us residents. Toxic dust comes in through my
windows. Trash is blown all over from Maddison materials and Men-Cal.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a crematorium
has no place around the corner from homes and a neighborhood park. These types of industries bring noise, air
pollution, and health risks that are incompatible with the residential and transit-oriented development we are
Planning Commission 1 – 170 3/6/2025
3
working to build. The City Council has twice agreed unanimously that industrial uses in this zone have placed
an inequitable environmental and health burden on those of us in the Logan and Lacy neighborhoods. The
General Plan adopted by the City Council in 2022 compels you to address these inequities by approving the
proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000 residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Sean Aguinaga
Resident of Santa Ana
Planning Commission 1 – 171 3/6/2025
1
Ocampo, Nuvia
From:Stephanie Wells <sw.stephwells@gmail.com>
Sent:Monday, February 10, 2025 12:32 PM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update.
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC with one change:
Storage units are industrial uses. They do not belong in a transit zone. People’s boxes full of stuff cannot
ride trains or make use of public transit. Nor do these facilities address our housing shortage or promote a
healthy street-business interface.
Remove the CUP exemption for storage units that was lobbied for by Extra Space Storage from this plan.
The health and safety of our community, especially our children and families, should remain a top
priority, and the industrial uses in the zone are eroding the quality of life for us residents. I moved to
Santa Ana in 2021 and in just 3.5 years of living in this city my asthma symptoms have returned. My
last asthma attack was 21 years ago. But ever since I started walking our dog in the neighborhood
I’ve noticed difficulty in breathing again and had to ask the doctor for an inhaler as back up. My dog
has gotten sick when accidentally eating things off the ground. It feels unhygienic and scary to walk in
my own neighborhood. I feel unsafe to walk alone. There are smells, loud machinery noises, and
debrees on the streets that can hurt our pets, children, elders, and even our cars as we drive over it. I
am disappointed. I invested in Santa Ana by purchasing a home in 2021, I am the process of plannjng
for a new small business in Santa Ana and I constantly rally and try to give Santa Ana positive market
exposure but I need the city’s help to make this neighborhood better.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Stephanie
Resident of Santa Ana
Planning Commission 1 – 172 3/6/2025
1
Ocampo, Nuvia
From:Leonel Flores <mpnacorg@gmail.com>
Sent:Monday, February 10, 2025 2:50 PM
To:eComments, PBA
Cc:Erika; Jose J Rea; Aylin Camacho; keila; Maya Cheav; Orange County Environmental
Justice; Kayla Asato; Jocelyn Sanchez; samantha@ocej.org; Sydney Cheung
Subject:Transit Zoning Code (SD-84)
Attachments:2.10.25 Letter to the Planning Commission.pdf
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Good Afternoon,
Here is our public comment letter in support of Transit Zoning Code (SD-84).
Have a great day,
--
Leonel Flores
Programs Manager
l
GREEN-MPNA
mpnacorg@gmail.com
EJProgramManager@mpnagreen.org
Connect with us!
The information contained in this electronic transmission, including any and all attachments, is intended only
for review and use by the individual(s) to whom the transmission is addressed, and may contain privileged and
confidential information. If the reader of this transmission is not the intended addressee, you are hereby
notified that any review, dissemination, distribution or copying of this transmission, or any attachments, is
strictly prohibited. If you receive this transmission in error, please immediately notify the sender by reply
email and destroy any and all electronic and paper copies.
Planning Commission 1 – 173 3/6/2025
February 10th, 2025
RE: Draft SD-84 Zoning Code Comment Period for February 10, 2025
Dear Planning Commission:
We, the undersigned organizations, submit this letter in support of the SD-84 Transit
Zoning Code. OCEJ and GREEN-MPNA see this as the next step in phasing out the polluting
industry in the city, and improving our air quality. GREEN-MPNA and OCEJ appreciate the
city’s efforts to reduce air polluting industries by eliminating M1 and M2 zoning in the Logan
and Lacy neighborhoods.
GREEN-MPNA and OCEJ would like to see a similar moratorium set in place in
Southeast Santa Ana. The Madison Park, Cedar Evergreen Co-op, Cornerstone Village, Delhi
and nearby areas have an overconcentration of industries that contribute to the continuation of air
pollution from the nearby freeways and emissions of harmful toxins from industrial use in the
surrounding areas. In 2022, a UCI study examined the correlation of pediatric asthma rates in
Santa Ana to the proximity of an industrial source. This study determined that students who lived
less than 0.5km from an industrial source were more likely to have pediatric asthma. We know
that Southeast Santa Ana is in the highest percentile bracket for pollution burden based on the
CalEnviroScreen 4.0 map which confirms it is necessary for these types of zoning changes in our
community as well.
For the last 7 years, OCEJ and GREEN-MPNA have been leaders for environmental
justice in the city of Santa Ana, advocating for policy changes like this. In 2021, the leadership
of OCEJ, GREEN-MPNA, and the CUAL Committee attributed to the adoption of 77 EJ
implementation actions in the city’s general plan update that revolved around reducing exposure
to pollution, improving public facilities, promoting healthy food, creating safe and sanitary
housing, and enhancing civic engagement. In 2022, the city took the first step towards
implementing regulations on polluting industry by adopting a Noxious Use Ordinance that would
address industries with ongoing violations. OCEJ and GREEN MPNA request that the city
expedite and extend this moratorium to be implemented in Southeast Santa Ana. OCEJ, GREEN-
MPNA, and our partners continue to support and work with residents and the city of Santa Ana
Planning Commission 1 – 174 3/6/2025
to amplify residents’ needs and urge a continued collaboration to reduce the pollution burdens in
Southeast Santa Ana.
To summarize, we commend the city for taking this step, and we want to express our
support for the adoption of SD-84 Transit Zoning Code. We look forward to engaging with the
city for environmental justice, and reducing the pollution burdens our residents face.
Sincerely,
Leonel Flores, Program Manager Samantha Guerrero, Executive Director
GREEN MPNA Orange County Environmental Justice (OCEJ)
Planning Commission 1 – 175 3/6/2025
1
Ocampo, Nuvia
From:Bob Adams <Bob@adamsiron.com>
Sent:Monday, February 10, 2025 4:06 PM
To:eComments, PBA
Subject:SD-84
Attachments:SKM_C224e T25021017260.pdf
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Honorable Commissioners,
For submission into the administraƟve record for the above‐referenced maƩer for tonight’s study session and for the
February 24, 2025 Planning Commission Public Hearing, I submit the aƩached proposed redline changes to the draŌ
ordinance that I strongly urge the Commissioners to consider. These changes were the result of careful consideraƟon of
important stakeholder concerns aŌer several meeƟngs with upper management of the Planning Department concerning
the ordinance.
I will be supplemenƟng and further explaining this request via oral tesƟmony at tonight’s meeƟng.
Respecƞully submiƩed,
Bob Adams
Planning Commission 1 – 176 3/6/2025
Planning Commission 1 – 177 3/6/2025
Planning Commission 1 – 178 3/6/2025
Planning Commission 1 – 179 3/6/2025
Planning Commission 1 – 180 3/6/2025
Planning Commission 1 – 181 3/6/2025
Planning Commission 1 – 182 3/6/2025
1
Ocampo, Nuvia
From:jadechiarini@gmail.com
Sent:Tuesday, February 11, 2025 10:50 AM
To:eComments, PBA
Subject:Planning study sessions comment
Follow Up Flag:Follow up
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Preserving Santa Ana’s Legacy: A Call for Collaboration on TZC (SD-84) Zoning Changes
For generations, residents and business have worked together. This collaboration is heart of Santa Ana, shaping
its culture, providing jobs, and fostering a sense of community. Many of us are not just business owners—we
are residents, neighbors, and active members of this city. We have invested our lives in building something
meaningful here, not only for ourselves but for the community and future generations. Yet, the proposed TZC
(SD-84) zoning changes threaten to upend this legacy with little collaboration or clarity.
One of the most concerning aspects of this proposal is the lack of engagement with the business
community. We have had one collaboration at the train station on this issue. While residents’ voices are crucial,
businesses also play an essential role in the fabric of Santa Ana. We don’t just operate here—we live here, we
contribute to the local economy, and we support the city in countless ways. Our voices deserve to be heard as
well. A truly inclusive process would involve business owners and residents working together to shape policies
that serve the entire community, not just one segment of it.
The proposed zoning changes are written so broadly that they leave more questions than answers. What will
happen to long-standing businesses? Will they be forced out due to unclear or impractical regulations? How will
these changes impact our ability to grow and adapt in an evolving economy? Uncertainty is not just unsettling—
it can be devastating for businesses that have thrived here for decades. Without clear guidelines and a
collaborative approach, businesses face an unpredictable future that could lead to closures and displacement.
If these changes are implemented as they stand, many businesses—some of which have operated in Santa Ana
for generations—will be forced to shut down or relocate. This isn’t just about economics; it’s about identity,
culture, and history. Families who have poured their hearts into their businesses will lose everything they’ve
built. The city will lose not just businesses but the very essence of what makes Santa Ana unique.
Santa Ana’s motto is clear: To enhance the quality of life and provide for a safe, healthy, prosperous, and
livable environment in partnership with the community.
Right now, businesses are being left out of that partnership. We believe in Santa Ana, and we want to be part of
the solution. Let’s come together—residents, business owners, and city officials—to create zoning regulations
that reflect the true spirit of our city.
We urge city leaders to pause this process and engage in meaningful discussions with the business community.
Together, we can craft zoning changes that protect Santa Ana’s heritage while allowing for responsible growth.
Collaboration, transparency, and clarity must be at the center of this conversation.
Planning Commission 1 – 183 3/6/2025
2
Santa Ana is more than just a place—it’s a home, a community, and a legacy worth fighting for. Let’s ensure
that any changes made truly reflect the voices of all who call it home.
Jade Chiarini
Planning Commission 1 – 184 3/6/2025
1
Ocampo, Nuvia
From:Christy Taylor <Christy@christy-taylor.com>
Sent:Tuesday, February 11, 2025 1:36 PM
To:eComments, PBA
Cc:Christy Taylor
Subject:Transit Proposal Rezoning SD-84
Follow Up Flag:Follow up
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Dear Planning Commissioners and CommiƩee,
I want to thank you for the Ɵme you provided last evening for hearing the
comments from the various parƟcipants. As a business and building
owner, I am extremely concerned about the proposals impact on our
business, employees and the value of our building. I agree with the
statement that was made last night about the fact that this proposal is
taking a “sledge hammer” vs. using a scalpel to address the businesses
that may be out of compliance.
It appears that there are 3‐4 companies that may be out of compliance,
however that is not ALL of the businesses who operate within the
regulatory bounds every day. Why is it that those businesses are not
being addressed versus aƩacking all of the businesses in this area? We
have invested in our businesses and properƟes, pay taxes, employ people
but yet it is being proposed to change our zoning, potenƟally force us to
leave and our building has already been devalued.
The devaluaƟon of our building took place the day the moratorium was
put in place. Should we want to lease our building, the moratorium has
made it virtually impossible to lease it as a business license will not be
issued. There are buildings on Fuller street that have already
experienced this. As a maƩer of fact, one building could not find a
Planning Commission 1 – 185 3/6/2025
2
tenant, so the building stands almost empty. As a result, the homeless
have moved in. We have more drug paraphernalia and usage, along with
smeared feces on our building than we have ever had before. This is a
result of the moves already made by the City.
Should this proposal be passed and our zoning be changed, it will
decrease the value of our property by at least $2M. It will narrow the
scope of who we can lease the building to. Why is this happening to us
when we are not the issue???
As I listened to comments last night, it is clear that the planning group
has not done an economic study ‐ one that includes loss of employment,
taxes, devaluaƟon of property and most importantly the cost of legal fees
to fight this. There are clear liabiliƟes for the city. This consƟtutes
unlawful seizure property, the AmorƟzaƟon plan is a liability and where is
the compensaƟon for our losses?
Several of the Commissioners spelled out the basics of what is missing
from the work done to date. Why haven’t these acƟons been taken?
I can understand the concern of the residences, but in fact they moved to
the area with the zoning that was already in place. If there is a concern
about environmental issues, why was the low‐income housing built
behind Fuller right next to a freeway where fumes and toxins are present
24/7?
I truly hope that this basic work will be completed, that the liabiliƟes be
assessed and that someone will reach out to us to talk about our
business, the loss of value of our property that has already taken place. I
have called several Ɵmes, and no one has responded.
Thank you again for addressing these issues.
Planning Commission 1 – 186 3/6/2025
3
Best,
Christy Taylor
1021 Fuller St, Santa Ana
Planning Commission 1 – 187 3/6/2025
1
Ocampo, Nuvia
From:Richard Chiarini <richardchiarini@hotmail.com>
Sent:Wednesday, February 12, 2025 8:24 AM
To:eComments, PBA
Subject:Public Comment on TZC (SD-84) Zoning Changes – Need for More Time &
Collaboration
Follow Up Flag:Follow up
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Dear Santa Ana Planning Commission,
I am writing to express my concerns regarding the proposed TZC (SD-84) zoning changes and to ask how we
can realistically resolve complex zoning issues in just a few weeks when these challenges have been evolving
since the late 1800s.
Santa Ana’s zoning and land-use history is deeply intertwined with generations of businesses, and residents who
have built their lives and livelihoods here . This dates back to the building of the rail in Logan.
There has been little meaningful engagement with the business community throughout this process.. I urge the
Planning Commission to allow more time for open dialogue, collaborative problem-solving, and transparency in
this process. Rushing these changes without properly addressing long-term concerns will only create greater
instability for the very people who make Santa Ana thrive.
How can we work together to find balanced, sustainable solutions that respect both the city’s growth, the
businesses and residents who call Santa Ana home? We are ready and willing to collaborate.
Thank you for your time and consideration.
Richard Chiarini
Planning Commission 1 – 188 3/6/2025
1
Ocampo, Nuvia
From:Garrett Greiwe <Garrett@supremeabr.com>
Sent:Tuesday, February 18, 2025 1:24 PM
To:eComments, PBA
Subject:Impact of Rezoning on Supreme Abrasives and the Community
Attachments:Letter to Plannign Commission of Sanat Ana - Impact of Rezoning on Supreme
Abrasives and the Community 2.10.2025.docx
Follow Up Flag:Follow up
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Planning Commission 1 – 189 3/6/2025
To: Planning Commission of Santa Ana
Subject: Impact of Rezoning on Supreme Abrasives and the Community
Good Evening,
My name is Garrett Greiwe and I am the President of Supreme Abrasives, a business that has proudly
operated right here in Santa Ana on Fuller Street. For years, we have contributed to this city—not just as a
company but as a vital part of the local economy. Today, I stand before you to address a matter of critical
importance: the city’s decision to rezone the area where our business is located and the profound
consequences this will have on our company, our employees, and the greater Santa Ana community.
As a manufacturer of essential goods with a distribution location in Santa Ana, we rely on our current location
to serve our customers efficiently. The proposed rezoning threatens to push us out of Santa Ana entirely. This
is not just a logistical inconvenience; it is a fundamental disruption to our business operations. We employ 20
hardworking individuals in California, three of whom are residents of Santa Ana. These are not just numbers—
these are families who depend on their jobs to make ends meet, to pay rent, to put food on the table. If the city
moves forward with this rezoning, these employees face the very real risk of losing their jobs as we are left with
no choice but to relocate the remainder of our company out of state. Our current location serves as a
distribution location for the products we make; our production has already been forced out of California to more
business-friendly states.
But it’s not just our company and employees who will suffer. Supreme Abrasives does business with other
companies in Santa Ana. We purchase goods and services locally. We buy meals, shop in stores, and
contribute to the city’s tax base. Our departure would mean less economic activity, fewer dollars circulating in
the local economy, and a direct negative impact on the businesses that depend on us.
Beyond the financial impact, there is a larger issue at stake: the message this rezoning sends to businesses
like ours. If a company that has been a part of this community for years can be forced out due to policy
changes, what does that say to other businesses considering Santa Ana as their home? It creates uncertainty,
discourages investment, and ultimately stifles economic growth. I would bet every business owner and
building owner represented here today is second guessing their future here in this great city.
I urge the city to reconsider this rezoning decision. Instead of pushing businesses out, we should be fostering
an environment where companies like ours can thrive. Supreme Abrasives wants to stay in Santa Ana,
continue employing local residents, and keep contributing to this community. But if this zoning change
proceeds, we will be forced to leave, taking jobs, revenue, and economic stability with us.
Let’s work together to find a solution that supports businesses, protects jobs, and ensures a prosperous future
for all of Santa Ana. Thank you.
Kind Regards,
Garrett Greiwe
President – Supreme Abrasives
Planning Commission 1 – 190 3/6/2025
1
Ocampo, Nuvia
From:Nate Paladino <natepaladino@gmail.com>
Sent:Tuesday, February 18, 2025 2:46 PM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update
Follow Up Flag:Follow up
Flag Status:Flagged
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Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the amendments to
the TZC, with one change - storage units are industrial uses and do not belong in a transit zone.
The health and safety of our community, especially our children and families, should remain a top priority. As
found in the research from UCI, industrial zone proximity is associated with increased pediatric asthma. This is
a vibrant area where people live, raise families, walk, and thrive, and we should ensure that we're not putting
our safety and health at risk.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a crematorium
has no place around the corner from homes and a neighborhood park. These types of industries bring noise, air
pollution, and health risks that are incompatible with the residential and transit-oriented development we are
working to build. The City Council has twice agreed unanimously that industrial uses in this zone have placed
an inequitable environmental and health burden on those of us in the Logan and Lacy neighborhoods. The
General Plan adopted by the City Council in 2022 compels you to address these inequities by approving the
proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000 residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Nate Paladino,
Resident of Santa Ana
Planning Commission 1 – 191 3/6/2025
1
Ocampo, Nuvia
From:Christy Taylor <Christy@christy-taylor.com>
Sent:Tuesday, February 18, 2025 3:04 PM
To:eComments, PBA
Cc:Christy Taylor
Subject:City of Santa Ana’s planned removal of Industrial uses in SD-84 TZC area
Follow Up Flag:Follow up
Flag Status:Flagged
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Dear Commissioners,
Good aŌernoon. I am wriƟng about the proposed removal of industrial
uses in SD‐84 TZC area. I aƩended the last meeƟng and it was clear that
we have 4 major offenders that are causing the issues: the trash handling,
scrap metal & recycle, and crematorium faciliƟes, not the remaining 160
businesses that employ individuals, pay taxes and put money back into
the city of Santa Ana.
While I understand there are concerns from the residents, wouldn’t it be
beƩer to find a soluƟon that deals with these businesses rather than
destroying businesses who contribute tax dollars and dollars into the
local economy? Is there a reason why we can’t work on a soluƟon that
focuses on the offenders and not disrupt businesses that don’t pollute?
I have consulted an aƩorney about the proposed plans. Here are the
issues he has raised from a legal perspecƟve:
ViolaƟon of California’s AmorƟzaƟon Doctrine
o In effect the proposal appears to consƟtute unconsƟtuƟonal
taking under both state and federal law.
o I believe that Commission Leo raised this during the
Commissioner’s session at the last meeƟng.
Planning Commission 1 – 192 3/6/2025
2
PotenƟal violaƟon of CEQA
o While we haven’t seen the CEQA document, eliminaƟng
industrial zones in favor of transit oriented development may
force small businesses out without miƟgaƟng measures, leading
to a CEQA challenge.
UnconsƟtuƟonal Regulatory Taking (FiŌh and Fourteenth
Amendments)
o Under Penn Central TransportaƟon Co. v. New York City, a
government acƟon consƟtutes a taking if it significantly
devalues property or restricts its economic use without just
compensaƟon.
o The City’s plan to phase out nonconforming uses without
providing compensaƟon could be challenged as a regulatory
taking, violaƟng both the U.S. and California ConsƟtuƟons.
ViolaƟon of the Equal ProtecƟon Clause (Fourteenth Amendment)
If these zoning changes disproporƟonately impact certain
businesses or property owners, parƟcularly minority‐owned
businesses or industries with limited relocaƟon opƟons, there
could be a basis for an equal protecƟon claim.
If similar businesses in other parts of the city are exempt, the law
could be deemed arbitrary and discriminatory.
ViolaƟon of California Government Code § 65863 (No Net Loss of
Business Use)
o This law requires that rezoning decisions do not eliminate
essenƟal business and employment opportuniƟes without
ensuring adequate replacement zoning.
o If these zoning changes reduce viable locaƟons for industrial or
commercial uses, they may be legally challenged for failing to
preserve economic diversity in Santa Ana.
Unfair Business CompeƟƟon and AnƟ‐Trust ViolaƟons
Planning Commission 1 – 193 3/6/2025
3
o If the rezoning disproporƟonately benefits large developers
over exisƟng small businesses, it could be argued that the city is
engaging in anƟ‐compeƟƟve pracƟces.
o Developers benefiƟng from public funds or favorable rezoning
changes could create grounds for a legal challenge under
California’s Unfair CompeƟƟon Law (UCL).
My preference is not to pursue a legal route, but it clear that there are
issues with the current plan. I have heard from many other
business/building owners that they too have consulted with aƩorneys
and are prepared to take acƟon against the City.
I would really encourage you to not approve the current proposal and
instead deal with the 4 offenders who are causing the key issues.
Thank you,
Christy Taylor
1021 Fuller Street
Santa Ana
Planning Commission 1 – 194 3/6/2025
1
Ocampo, Nuvia
From:Cedric Owens <cedricpowens44@gmail.com>
Sent:Wednesday, February 19, 2025 7:45 AM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84)
Follow Up Flag:Follow up
Flag Status:Flagged
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Subject: Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Cedric Owens
Resident of Santa Ana
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School District
Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
FYI: 10,000 resident estimate is based on press release from city (linked below) which states that the TZC is
approximately 450 acres (.7 square miles) and that “Lacy and Logan are more densely populated than Santa Ana as a
whole, with a combined population density of 15,531.7 persons per square mile.”
https://www.santa-ana.org/city-of-santa-ana-moves-to-protect-oldest-neighborhoods-from-industrial-pollution-under-
historic-environmental-justice-initiative/
Planning Commission 1 – 195 3/6/2025
2
Planning Commission 1 – 196 3/6/2025
1
Ocampo, Nuvia
From:Rachel Kraus-Lee <rkrauslee@gmail.com>
Sent:Wednesday, February 19, 2025 10:09 PM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update.
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Rachel Kraus-Lee
Resident of Santa Ana
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School District
Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
Planning Commission 1 – 197 3/6/2025
1
Ocampo, Nuvia
From:Christy Taylor <Christy@christy-taylor.com>
Sent:Thursday, February 20, 2025 9:36 AM
To:eComments, PBA
Cc:Christy Taylor
Subject:Transit Rezoning SD-84 TZC area - Property Issues
Follow Up Flag:Follow up
Flag Status:Flagged
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Dear Commissioners,
I have wriƩen to you several Ɵmes and aƩended the last meeƟng where
the Transit project for eliminaƟng industrial uses was discussed. Based on
what was presented at the last meeƟng, I sƟll support focusing on the
offenders and not eliminaƟng industrial zoning which effects our building
and the business at 1021 Fuller Street, along with all of the other
businesses who are not creaƟng problems for the community. Our
businesses are contribuƟng to employment, paying our taxes and
contribuƟng economically to the City of Santa Ana.
I wanted to bring to your aƩenƟon a very real issue that has resulted
from the Moratorium that has been in place. The Moratorium has
prohibited building owners from leasing their space, not only creaƟng
tremendous financial hardship for the owners, but this has created a
whole host of other issues as it relates to the homeless who have moved
in to the Fuller Street area given a vacant building next to our building.
Yesterday, a homeless man started a fire in the parking area on the
property right next to ours. The building does not have a tenant due to
the Moratorium. We have had trash, needles, drug paraphernalia and
excrement and other items leŌ on our property for a long Ɵme. This is a
daily occurrence. However, in the past several months the homeless issue
Planning Commission 1 – 198 3/6/2025
2
and destroying property has goƩen worse. AŌer the fire occurred, the
individual then went onto our property and destroyed the opƟcal lens
that allows us to open our gate. We have lost count of the cost to replace
and protect items on our property. Our employees are afraid at Ɵmes to
enter the building given the presence of the homeless and drug addicts.
We have called the City of Santa Ana repeatedly to come deal with the
variety of issues. This includes the police, the fire department,
paramedics, etc. Yesterday we once again called the Fire
department. This obviously has a tremendous impact on the City services
and tax dollars.
We would encourage any of you to come visit Fuller Street to see what is
happening as a result of the moratorium. We would also encourage you
not to support the current re‐zoning proposal as wriƩen, liŌ the
moratorium and allow this area to be back in business as we were before,
conƟnuing to employ people, pay our taxes and contribute to the
community.
Thank you,
Christy Taylor
Planning Commission 1 – 199 3/6/2025
1
Ocampo, Nuvia
From:Kim Riker <kriker@ricedw.com>
Sent:Thursday, February 20, 2025 9:43 AM
To:eComments, PBA
Subject:COMMENTS re: SD-84 Transit Zoning Code (TZC) Amendments
Follow Up Flag:Follow up
Flag Status:Flagged
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With regard to the SD‐84 Transit Zoning Code (TZC) Amendments, I appreciate your taking Ɵme to read my 3 concerns
that I would have presented as a 3rd generaƟon business owner.
1. The draŌ regulaƟons treat similar acƟviƟes differently in various secƟons. For example, my property is to be
zoned “Urban Center.” We are an administraƟve office of 5 people that operates from 8 am to 5 pm and we sit
inside all day and type on computers. I believe this should put us in the “Business Support Service” Land Use
Type (page 19), and we would simply need a “P” Permit (meaning we could simply carry on our business as we
are now). However, because we provide business support service to a construcƟon company, our administraƟve
services may put us in to the “Professional” category (page 20), thereby requiring a “P(1)” Permit type. This
means we could only perform our administraƟve services “only on second or upper floors, or behind retail or
service ground floor use.” So, though we perform the exact same type of administraƟve work as Business
Support Service, but service a construcƟon company, we would then be required to add a retail space in front
of our office? Or build a second story and allow a retailer to move in downstairs? This would increase vehicle
and foot traffic, make more noise, and increase our business footprint in what seems to be contrary to the
purpose of these regulaƟons. The categorizaƟon of services in these Land Use Type charts is arbitrary and
illogical in many cases, and this specific one makes no sense in our case. We make zero noise and only have 5
people in our office, but your regulaƟons may require that we increase this, impacƟng the community.
2. The result of these regulaƟons would be a taking of our property by the government. My mother owns the
property next door, at Brown and Poinseƫa, which is zoned UN‐2. It is a building purpose‐built in reliance on the
locaƟon being made an “Enterprise Zone” by the City of Santa Ana years ago when it wanted to encourage
businesses to move to this area. These regulaƟons would render this property useless, as building “mixed use”
residences would be required. The property is not large enough to do this. Therefore, as menƟoned by a speaker
last night, this would consƟtute a taking under the 5th Amendment to the U.S. ConsƟtuƟon. There are many
instances of California case law that support this.
3. I understand the need to make changes to improve the area we are in, but forcing businesses out of the city and
taking away local jobs from the 100 employees affected by my business and the one next door is not the way.
My building is at the corner of 6th and Poinseƫa, a corner the police and code enforcement know well, as we are
across from Bruce Metals and I report on graffiƟ to our building and trash dumped on our sidewalk almost daily.
Perhaps we can just focus on heavy industry in our area? Or work with the community to clean up the space
related to the two recycling yards on 6th Street? I do not believe that living near the freeway is any more
unhealthful to residents than being near our (non‐recycling) businesses.
Thank you,
Kim Riker
Rice Drywall, Inc.
919 E. 6th Street
Planning Commission 1 – 200 3/6/2025
2
Santa Ana, CA 92701
Ph: (714) 543‐5400
Planning Commission 1 – 201 3/6/2025
1
Ocampo, Nuvia
From:Contracts <contracts@mztco.com>
Sent:Thursday, February 20, 2025 10:02 AM
To:eComments, PBA
Subject:Opposition to Proposed SD-84 Transit Zoning Code Change
Attachments:Zoning Opposition.pdf
Follow Up Flag:Follow up
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Good morning,
On behalf of Macro-Z-Technology Company, a business that has proudly called the Logan neighborhood home since
2002, I am writing to express our strong opposition to the proposed changes to the Transit Zoning Code.
For over two decades, we have invested in this community, fostering relationships with local businesses, residents, and
charitable organizations such as the OC Food Bank and Project Hope Alliance. Our commitment to Santa Ana extends
beyond business – we actively support local initiatives and strive to contribute to the wellbeing of our neighbors. Through
these efforts, we have built strong partnerships and a deeply rooted connection to the Logan neighborhood, which is now
under threat due to the City’s proposed zoning changes.
Furthermore, our company is not a polluter nor a noxious user. We operate responsibly, adhering to all environmental
regulations, and have maintained a clean and safe business that coexists harmoniously with the surrounding community.
The broad stroke elimination of industrial zoning unfairly targets businesses like ours that have contributed positively to
the neighborhood for years.
Adding to our concerns, we now face the very real fear of being forced out of our long-standing location through an unjust
amortization process. The proposed regulations would make it impossible for us to continue our operations, despite our
compliance with all laws and our contributions to the community. The amortization process, as outlined, does not provide
fair compensation nor adequate time for businesses like ours to transition, effectively making it an unjust taking of
property and livelihood.
The proposed zoning amendments constitute an unjustified overreach that disregards the commitments made to the
business community. These regulations threaten to erase a vital sector of Santa Ana’s economy in favor of high-density
residential development, despite the lack of adequate infrastructure and parking. This shift is not only detrimental to
existing residents but also destabilizes the very neighborhoods it claims to improve.
The City’s push to remove industrial zoning under the guise of “environmental justice” lacks substantiated evidence and
disproportionately harms long standing businesses. If justice is the true intent, the City should focus on equitable policies
that support both small-business and residential stakeholders rather than facilitating a land grab for high-density
developers. The lack of an updated Environmental Impact Report further highlights the rushed and flawed nature of this
process.
We urge the City to reject the proposed zoning changes that would eliminate small businesses in the Logan neighborhood,
to reconsider the consequences of these drastic changes, and to work collaboratively with the business community to find
solutions that support economic stability and growth.
Thank you for your time and consideration. We look forward to your response and the opportunity to engage in a
meaningful dialogue.
Planning Commission 1 – 202 3/6/2025
2
Macro‐Z‐Technology Company
841 East Washington Avenue
Santa Ana, CA 92701
(714) 564‐1130 Phone
(714) 564‐1144 Fax
Planning Commission 1 – 203 3/6/2025
Planning Commission 1 – 204 3/6/2025
Planning Commission 1 – 205 3/6/2025
1
Ocampo, Nuvia
From:MAYRA RUIZ <office@knightstotherescue.com>
Sent:Thursday, February 20, 2025 12:31 PM
To:eComments, PBA
Subject:Impact of Proposed Industrial Zoning Changes on Knight Towing
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing to express my deep concern regarding the proposed elimination of industrial zoning in
Santa Ana and the severe impact it will have on my business, Knight Towing.
My husband and I started this business 22 years ago with nothing but hard work and determination. We
are required to operate within a 10-mile radius. The forced relocation due to zoning changes means we
will lose critical contracts, putting our livelihood at serious risk. Furthermore, there are no other
permitted towing locations available within Santa Ana, making it impossible for us to continue
operating within the city we have long served.
It is incredibly disheartening that a city I was born and raised in, the city where my husband and I built
our business from the ground up, is now pushing us out. What makes this even worse is the lack of
clarity on whether the City of Santa Ana intends to provide relocation assistance or compensate
businesses like mine for the revenue we will lose due to these changes. Are we expected to absorb
these devastating financial losses on our own?
This decision will have long-term consequences—not just for our business but also for our employees
and the essential towing services we provide. I urge you to reconsider the impacts of this proposal and
work with affected businesses to find a viable solution.
I appreciate your time and look forward to your response.
Mayra Ruiz
Knight Towing
1001 N Logan ST
Santa Ana, CA 92701
714-667-0373
714-604-3339
Www.KnightsToTheRescue.com
Planning Commission 1 – 206 3/6/2025
1
Ocampo, Nuvia
From:LMFTGonzalez <LMFTGonzalez@proton.me>
Sent:Thursday, February 20, 2025 5:54 PM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update.
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Support for Transit Zoning Code/Specific Development No. 84 (SD-84)
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the amendments to
the TZC, with one change - storage units are industrial uses and do not belong in a transit zone.
The health and safety of our community, especially our children and families, should remain a top priority. As
found in the research from UCI, industrial zone proximity is associated with increased pediatric asthma.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a crematorium
has no place around the corner from homes and a neighborhood park. These types of industries bring noise, air
pollution, and health risks that are incompatible with the residential and transit-oriented development we are
working to build. The City Council has twice agreed unanimously that industrial uses in this zone have placed
an inequitable environmental and health burden on those of us in the Logan and Lacy neighborhoods. The
General Plan adopted by the City Council in 2022 compels you to address these inequities by approving the
proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000 residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Martha E. Gonzalez, LMFT Resident of Santa Ana 714-495-1626
Sent from Proton Mail for iOS
Planning Commission 1 – 207 3/6/2025
1
Ocampo, Nuvia
From:Liberty Dickinson <liberty@liberty-finearts.com>
Sent:Friday, February 21, 2025 5:18 AM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Subject: Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Liberty Dickinson
Resident of Santa Ana
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School District
Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
FYI: 10,000 resident estimate is based on press release from city (linked below) which states that the TZC is
approximately 450 acres (.7 square miles) and that “Lacy and Logan are more densely populated than Santa Ana as a
whole, with a combined population density of 15,531.7 persons per square mile.”
https://www.santa-ana.org/city-of-santa-ana-moves-to-protect-oldest-neighborhoods-from-industrial-pollution-under-
historic-environmental-justice-initiative/
Planning Commission 1 – 208 3/6/2025
2
921 E.Santa Ana Blvd.
Santa Ana, CA 92701
714-507-6330
Inspiration exists but it has to find you working.
Instagram.com/libertydickinsonart
Planning Commission 1 – 209 3/6/2025
1
Ocampo, Nuvia
From:Red Leaf Loft <redleafloft@gmail.com>
Sent:Friday, February 21, 2025 5:43 AM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Cedric Volk
Planning Commission 1 – 210 3/6/2025
1
Ocampo, Nuvia
From:Red Leaf Loft <redleafloft@gmail.com>
Sent:Friday, February 21, 2025 5:43 AM
To:eComments, PBA
Subject:Support for Transit Zoning Code/Specific Development No. 84 (SD-84) Update
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to approve the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000
residents who live here and deal with these health and safety concerns everyday.
Sincerely,
Cedric Volk
Planning Commission 1 – 211 3/6/2025
1
Ocampo, Nuvia
From:Kelly Kraus-Lee <kellyakraus@gmail.com>
Sent:Friday, February 21, 2025 5:31 PM
To:eComments, PBA
Subject:Support for Amendment to Transit Zoning Code/Specific Development No. 84 (SD-84)
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to support the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.*
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the thousands of residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Kelly Kraus-Lee
Resident of Santa Ana
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School District
Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
Planning Commission 1 – 212 3/6/2025
1
Ocampo, Nuvia
From:Sarah Rinelli <sarah@rinellilawgroup.com>
Sent:Friday, February 21, 2025 5:48 PM
To:eComments, PBA
Subject:Support for Amendment to Transit Zoning Code/Specific Development No. 84 (SD-84)
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to support the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.*
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the thousands of residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Sarah M. Rinelli, Esq.
Business owner and resident of Santa Ana, 92701
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School District
Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
Sarah M. Rinelli, Esq.
Rinelli Law Group, P.C.
P.O. Box 10298
Santa Ana, CA 92711-0298
(949) 674-6591
sarah@rinellilawgroup.com
CONFIDENTIALITY:
Planning Commission 1 – 213 3/6/2025
2
The information contained in this e-Mail message, including any accompanying documents or attachments, is from the Rinelli Law Group, P.C. and is intended only for
the use of the individual or entity named above, and is privileged and confidential. If you are not the intended recipient, be aware that any disclosure, dissemination,
distribution, copying or use of the contents of this message is strictly prohibited. If you have received this message in error, please notify us by telephoning Sarah M.
Rinelli at (949) 674-6591, return the e-Mail message, and destroy (delete) the original.
Planning Commission 1 – 214 3/6/2025
1
Ocampo, Nuvia
From:jason nguyen <jnguyendds@yahoo.com>
Sent:Friday, February 21, 2025 8:33 PM
To:eComments, PBA
Subject:Heavy pollution
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to support the
amendments to the TZC, with one change - storage units are industrial uses and do not belong in a
transit zone.
The health and safety of our community, especially our children and families, should remain a top
priority. As found in the research from UCI, industrial zone proximity is associated with increased
pediatric asthma.*
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a
crematorium has no place around the corner from homes and a neighborhood park. These types of
industries bring noise, air pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has twice agreed unanimously
that industrial uses in this zone have placed an inequitable environmental and health burden on those
of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in 2022
compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the thousands of residents
who live here and deal with these health and safety concerns everyday.
Sincerely,
Dr Jason Nguyen
Yahoo Mail - Email Simplified
Planning Commission 1 – 215 3/6/2025
1
Ocampo, Nuvia
From:Ryan Madden <ryanpmadden@gmail.com>
Sent:Friday, February 21, 2025 9:15 PM
To:eComments, PBA
Subject:Support for Amendment to Transit Zoning Code/Specific Development No. 84 (SD-84)
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge
you to support the amendments to the TZC, with one change - storage units
are industrial uses and do not belong in a transit zone.
The health and safety of our community, especially our children and
families, should remain a top priority. As found in the research from UCI,
industrial zone proximity is associated with increased pediatric asthma.*
Metal recyclers and waste dumps have no place 200 feet away from an
elementary school, and a crematorium has no place around the corner from
homes and a neighborhood park. These types of industries bring noise, air
pollution, and health risks that are incompatible with the residential and
transit-oriented development we are working to build. The City Council has
twice agreed unanimously that industrial uses in this zone have placed an
inequitable environmental and health burden on those of us in the Logan
and Lacy neighborhoods. The General Plan adopted by the City Council in
2022 compels you to address these inequities by approving the proposed
amendments.
Please do not allow outside business interests to override the concerns of
the thousands of residents who live here and deal with these health and
safety concerns everyday.
Sincerely,
Ryan P. Madden
Resident of Santa Ana
Planning Commission 1 – 216 3/6/2025
2
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School District
Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
Planning Commission 1 – 217 3/6/2025
1
Ocampo, Nuvia
From:Roger Simon <roger@pioneertrailersales.com>
Sent:Sunday, February 23, 2025 9:48 AM
To:eComments, PBA
Subject:ZONING ORDINANCE AMENDMENT AMENDING SECTIONS OF ARTICLE XIX (THE
TRANSIT ZONING CODE, SD NO. 84) OF THE SANTA ANA MUNICIPAL CODE (SAMC)
ADDRESSING INDUSTRIAL LAND USES, NONCONFORMITIES, AND OPERATING
STANDARDS, AND AMENDING THE CITY OF SANTA ANA ZONING...
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
We are not property owners or residents of the area included in this proposed amendment but we are very
concerned about it and urge you not to adopt it. We are owners of business property close to this area and our
family depends on rental income from it. This change will drive businesses out of Santa Ana, including some
that the City of Santa Ana, its agencies and departments depend on for materials and services, increasing costs
to the City while diminishing its tax base and revenues. This change will send a chilling message to business
owners in Santa Ana that the same could happen in their area.
Sincerely - Roger
Planning Commission 1 – 218 3/6/2025
1
Ocampo, Nuvia
From:Barney Richer <bricher@gmail.com>
Sent:Sunday, February 23, 2025 10:57 AM
To:eComments, PBA
Cc:Ramirez, Frida; Penaloza, David; Barney Richer
Subject:Amendment Application No. 2024-03
Attachments:4076962871595930991.heic; -6648894922711158278.heic;
-6464989058942883764.heic; 6171766880068526500.heic; 2591939775744021259.heic
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
To whom it may concern,
My name is Barney Richer, a local resident/homeowner living across the street from the Train station and would
like to express my support for the above referenced Amendment.
I believe that it is crucial for this to pass in order to create a safe and healthy environment for all residents of the
area as for far too long local businesses such as Bruce's Metals and the Madison/Ware Waste Facility have been
allowed to create unhealthy environments for all of us.
I am especially concerned with Madison Disposal as they are in my opinion the largest of the offenders. They
are in constant violation of the AQMD requirements by allowing dust and debris to leave their facility on a
daily basis causing dust and other particles to blanket the area for miles around their property. This includes the
freshly renovated Train Station that will now be covered in dust again after it was just painted. Worse than the
dust is the long term health issues that local long time residents have expressed everytime this topic comes up.
I believe they had a chance to properly install a misting system and have failed to do so over the last 20ish years
that they have been operating there. If you look at other professionally run waste sites that reside in high
density areas they are completely surrounded by misters running full time 24 hours a day while Madison often
has no mister but rather just a man with a garden hose. In addition they are taking over the newly paved
road/bike path by using public streets as a cue for their customers making access to the Train Station difficult
for residents and businesses residing to the South and West. What other businesses are allowed to use public
streets to form a line for their drive through business? At the very least they should have made an attempt to
cue trucks on their own property but again they have missed that opportunity to be a good neighbor.
Given Madison's failure to be a good neighbor and to evolve with the overall Transportation Hub Development
vision their lease should be canceled and they should be relocated regardless of how the vote for this
amendment turns out.
I can go on about the issues at Bruce Metals with drug addicts stripping stolen wire and back- flow devices on
the street in front of the property and openly doing drugs while kids from Garfield Elementary need to walk
past. However I won't drone on about this as I believe it has all been fairly well documented by others.
Please see the attached photos that I took under duress from the management of Madison as they post signs in
front of the property that no photos are allowed and make aggressive attempts to curtail it. I wonder why that
is? I think you all know the answer to that and I hope you will do the right thing.
Planning Commission 1 – 219 3/6/2025
2
Thank you all for your time and service to our community.
Barney Richer
946 E Santa Ana Blvd
Santa Ana
Planning Commission 1 – 220 3/6/2025
1
Ocampo, Nuvia
From:Jackie <Jacqueline.Michael@exprealty.com>
Sent:Sunday, February 23, 2025 2:40 PM
To:eComments, PBA
Cc:Sara.albaqui@gmail.com; tylerlapointe@me.com; errnmc@yahoo.com
Subject:Transit Zoning Code public comments
Attachments:IMG_1610.jpeg; IMG_1611.jpeg; IMG_1605.jpeg; IMG_1476.mp4
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Hello,
I am a Realtor and concerned homeowner located in the Lacy Crossing community. I purchased my property in
November of 2022 and was told then, that the industrial businesses around the residential community would be
shutting down, but I have yet to see that happen.
In the mean time, my family and neighbors quality of life has been disrupted dealing with the inconsideration of
the industrial businesses around us that consist of Recycling centers, car junk yards, and land full of toxic
materials and chemicals being brought in from construction sites to sort through.
There are multiple industrial properties operating Without a business license and has been confirmed through
the Santa Ana business license office.
One of the properties is located at 1008 E. 4th Street Santa Ana, CA. This property has put our health at risk
with the air quality due to no upkeep, dirt ground, and the semi trucks in and out of the business, operating
outside residential noise ordinances, and is a sore eye bringing down the value of the home properties around it.
Attached are current pictures and videos of an example of a property operating WITHOUT a business license
and needs to cease operations immediately.
The decision to keep the moratorium in favor of removing all industrial overlay in the Lacy community is of the
upmost importance or the city’s effort to revitalize the city will fall short and the community itself will go
downhill.
Please hear our cries and support a safer and beautiful Santa Ana for the new million dollar communities and its
residents!
Thanks,
Jackie Michael
eXp Realty of Southern California, Inc.
Realtor, DRE # 02226270
Jacqueline.Michael@exprealty.com
+1 (714) 309-6811
Planning Commission 1 – 221 3/6/2025
Planning Commission 1 – 222 3/6/2025
Planning Commission 1 – 223 3/6/2025
Planning Commission 1 – 224 3/6/2025
1
Ocampo, Nuvia
From:LMFTGonzalez <LMFTGonzalez@proton.me>
Sent:Sunday, February 23, 2025 8:01 PM
To:eComments, PBA
Subject:Transit Zoning
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Planning Commission,
I am writing as a resident of the Transit Zoning Code area to strongly urge you to support the amendments to the
TZC, with one change - storage units are industrial uses and do not belong in a transit zone.
The health and safety of our community, especially our children and families, should remain a top priority. As found
in the research from UCI, industrial zone proximity is associated with increased pediatric asthma.*
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a crematorium has
no place around the corner from homes and a neighborhood park. These types of industries bring noise, air
pollution, and health risks that are incompatible with the residential and transit-oriented development we are working
to build. The City Council has twice agreed unanimously that industrial uses in this zone have placed an inequitable
environmental and health burden on those of us in the Logan and Lacy neighborhoods. The General Plan adopted
by the City Council in 2022 compels you to address these inequities by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the thousands of residents who live here
and deal with these health and safety concerns everyday.
Sincerely,
Martha E. Gonzalez, LMFT
Resident of Santa Ana
Planning Commission 1 – 225 3/6/2025
1
Ocampo, Nuvia
From:mike@tardifsheetmetal.com
Sent:Monday, February 24, 2025 10:45 AM
To:eComments, PBA
Cc:eComment
Subject:ZONING ORDINANCE AMENDMENT (ZOA) NO. 2024-02
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Re: Planning Commission Public Hearing SD‐84 Transit Zoning Code
To the Santa Ana Planning Commission – Feb. 24, 2025
During the Study Session ‐‐ 2 weeks ago ‐ Staff stated:
“Just like we did for the Related Bristol project; we don’t intend to publish that Staff Report 72 hours before.
We intend to publish it with ample Ɵme for the community and the Commission to really read, digest, and
develop thoughƞul and meaningful quesƟons for discussion.”
The report was published only 73 hours before this hearing. Your informaƟon packets are 250 pages. That
extra hour does not consƟtute “ample Ɵme” for Commissioners or the community to engage meaningfully.
I formally object to this hearing proceeding today, because the City failed to honor its commitment to provide
significantly more than the minimum 72‐hour noƟce for public documents to be released.
AddiƟonally, Staff made inaccurate and misleading statements during the Study Session. They claimed:
“When the City decides to engage in amorƟzaƟon, that’s when the individual business is evaluated for what
potenƟally is an equitable return on an amorƟzaƟon period.”
Similar remarks about “recouping” investments were made in the Frequently Asked QuesƟons secƟon of your
packets and at group meeƟngs.
Commissioners, this is misleading. AmorƟzaƟon here is simply a mandated Ɵmeline for business removal—no
“equitable return” or “recoupment” is involved. It’s a deadline, plain and simple.
A Commissioner asked:
“At this point, we have a moratorium in place ‐ everything is on pause. No occupancy permits, no equipment
installaƟons ‐ everything is preƩy much halted in the overlay zones?”
Staff replied:
“The moratorium is on the establishment, intensificaƟon, or enlargement of industrial businesses. RouƟne
permits, like replacing damaged equipment, are not affected.”
That’s false. One business owner had to hire an aƩorney and spend $12,000 during the moratorium to secure
a permit for equipment installaƟon. Another was denied a CerƟficate of Occupancy just to add their son’s
name to the business ‐ again, requiring costly legal intervenƟon to resolve.
Your informaƟon packets are 250 pages, the public informaƟon, was not made available by Staff within the
Ɵmeframe they promised. The highly complicated DraŌ RegulaƟons were only made available to the public 5
weeks ago. The City has not sponsored or encouraged discussions and collaboraƟon between businesses and
neighborhoods.
This all shows a paƩern of misinformaƟon and an unfair burden on both businesses and residents.
Planning Commission 1 – 226 3/6/2025
2
I respecƞully request that the Commission delay consideraƟon of this proposed ordinance for 90 days – and
for City Staff to sponsor and conduct transparent and meaningful discussions and collaboraƟon between the
City, businesses and neighborhoods.
Thank you,
Mike Tardif
Planning Commission 1 – 227 3/6/2025
1
Ocampo, Nuvia
From:Roberta Flores <r.flores@uci.edu>
Sent:Monday, February 24, 2025 1:18 PM
To:eComments, PBA
Subject:Amendments to the TZC
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear City of Santa Ana Planning Commission,
I am wriƟng as a resident of Santa Ana to strongly urge you to approve the amendments to the TZC, with one change ‐
storage units are industrial uses and do not belong in a transit zone.
The health and safety of our community, especially our children and families, should remain a top priority. As found in
the research from UCI, industrial zone proximity is associated with increased pediatric asthma.*
Metal recyclers and waste dumps have no place 200 feet away from an elementary school, and a crematorium has no
place around the corner from homes and a neighborhood park. These types of industries bring noise, air polluƟon, and
health risks that are incompaƟble with the residenƟal and transit‐oriented development we are working to build. The
City Council has twice agreed unanimously that industrial uses in this zone have placed an inequitable environmental
and health burden on those of us in the Logan and Lacy neighborhoods. The General Plan adopted by the City Council in
2022 compels you to address these inequiƟes by approving the proposed amendments.
Please do not allow outside business interests to override the concerns of the approximately 10,000 residents who live
here and deal with these health and safety concerns every day.
Sincerely,
Roberta Flores
Resident of Santa Ana
*Mock K, Palma AM, Wu J, Billimek J, Lu KD. Breathing Room: Industrial Zoning and Asthma Incidence Using School
District Health Records in the City of Santa Ana, California. Int J Environ Res Public Health. 2022 Apr 15;19(8):4820. doi:
10.3390/ijerph19084820. PMID: 35457688; PMCID: PMC9032322.
FYI: 10,000 resident esƟmate is based on press release from city (linked below) which states that the TZC is
approximately 450 acres (.7 square miles) and that “Lacy and Logan are more densely populated than Santa Ana as a
whole, with a combined populaƟon density of 15,531.7 persons per square mile.”
hƩps://www.santa‐ana.org/city‐of‐santa‐ana‐moves‐to‐protect‐oldest‐neighborhoods‐from‐industrial‐polluƟon‐under‐
historic‐environmental‐jusƟce‐iniƟaƟve/
Planning Commission 1 – 228 3/6/2025
1
Ocampo, Nuvia
From:Mark Law <mlaw92626@gmail.com>
Sent:Monday, February 24, 2025 2:29 PM
To:eComments, PBA
Subject:Planning Commission Meeting 02/24/2025 written comments
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
February 24, 2025
My name is Mark Law. I am one of 3 members of FLP Investments LLC, the owner of the
building and property at 911 N. Poinsettia St. We bought the building in 2001 after a year-long
search and were pleased with the location and architecture that Burke developed for the 8
buildings they built in the project, working closely with the city of Santa Ana. Imagine our
surprise in 2010, 8 short years after our building was first occupied, when the City of Santa Ana
presented the Renaissance Plan in which they would take away our entitled zoning and rezone
our property residential and open space with no compensation to us, the existing property
owner. Needless to say, there was outrage among the property and business owners, many
meetings, and the result was the industrial overlay on the underlying residential zoning. While
not satisfied, the property and business owners finally concluded they could live with this
zoning structure.
Fast forward 15 years, now the city feels, in the words of the executive director of the city
planning committee, that change has not happened fast enough. Their solution is to remove the
overlay and subject the business and property owners to a steep devaluation of their property
and huge financial and human cost to the existing businesses to relocate. The rationale was
presented to us at the train station by Margarita saying that this decision was based on
‘environmental justice’ because the surrounding neighborhoods were being subjected to some
of the highest levels of air pollution in the state. There were no studies presented that took into
account all of the pollution factors surrounding these neighborhoods. There was only an
example of a homeowner who was getting ash deposits on his BBQ from the ‘industrial
area’. Margarita said there was a recent fire that highlighted the potential dangers coming from
the ‘industrial area’. After the audience questioned her about the fire, and was asked if it
involved the crematorium, she finally acquiesced and said it was. When she was asked if there
had been any other fires, she responded that she hadn’t heard of any others. It was subsequently
made obvious that the ash on the BBQ had emanated from the crematorium as well. One
Planning Commission 1 – 229 3/6/2025
2
business out of 120+ businesses was their only example. The business which has occupied our
building at 911 Poinsettia is an industrial distributor, selling hose, fittings, valves and the like to
customers who are repairing their hydraulic and pneumatic equipment. The business gets one
UPS and FEDEX delivery in the morning, and one pickup in the late afternoon. That is less
UPS, FEDEX, and Amazon traffic than any Orange County residential neighborhood these
days. The business is quiet and clean and has never had a complaint from the surrounding
neighborhoods. I know that many of the businesses in the Transit District are just as quiet and
clean.
We feel that the city is acting in bad faith here, threatening our constitutional rights as property
owners. The reason change has not occurred in the last 15 years since the Renaissance Plan is
that buying up property in the transit district for a residential project does not pencil at current
market values for the property. If the city thinks that artificially driving down the value of the
existing properties so that residential developers may consider developments in the transit
district is fair to the existing property owners, they are missing current realities. One glaring
example of this transpired in Irvine recently when the city council was considering a large
warehouse taking up a city block in the Irvine Business Center (IBC). The city denied approval
but negotiated with the owners that if they built a residential project they could keep their
industrial zoning for the property. The city did this to avoid litigation for devaluing the
property. The City of Santa Ana may want to consider things from this perspective as well.
Mark Law
FLP Investments LLC
714-812-2014
mlaw92626@gmail.com
Planning Commission 1 – 230 3/6/2025
1
Ocampo, Nuvia
From:Hugo Ortega <pwrpro331@yahoo.com>
Sent:Monday, February 24, 2025 2:35 PM
To:eComments, PBA
Cc:kellyakraus@gmail.com; Ramirez, Frida; Penaloza, David; Hugo Ortega
Subject:Zoning Meeting Tonight
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Good afternoon.
I would like to submit some pictures for tonight's meeting and would like to send you a quick highlight of points during the
presentation. The pictures will be very helpful, so please let me know if there is anything else I need to do to include them
for display.
-recycling businesses attract transients who disassemble and break down recycling materials in front of their businesses,
leaving a mess.
-the same folks also pass through our complex on trash day rummaging through our garbage containers and sometimes
leave a mess that is not picked up by trash services.
-I have seen folks actually stripping insulation off of cables. Where those cables came from, nobody knows, but this would
entice folks to steak cabling, irrigation valves and any metal components at reach, which has happened in our complex.
-the main bike path going from the train station to downtown passes right in front of the dump (last two pictures below).
This dump has a horrid smell most of the time and the line of trucks waiting to dump garbage does not lead me to believe
that anyone in their right mind would take this route downtown.
-there are trucks loading and offloading potentially hazardous waste and recycling material, making me question the
health hazard these facilities present.
-the trucks line the streets to load and offload, leaving little or no room to maneuver when passing through with a car.
Nobody likes a noisy, polluting, disrespectful neighbors who are just fixated on what is good for them (in this case, their
bottom line). I request the city council take this matter seriously and is able to make progress for the betterment of all
affected areas.
Thank you!
Hugo Ortega, MBA
25A Signal Captain (Ret.)
U.S. Army
Planning Commission 1 – 231 3/6/2025
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Planning Commission 1 – 232 3/6/2025
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Planning Commission 1 – 233 3/6/2025
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Planning Commission 1 – 234 3/6/2025
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Planning Commission 1 – 235 3/6/2025
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Planning Commission 1 – 237 3/6/2025
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Planning Commission 1 – 238 3/6/2025
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Ocampo, Nuvia
From:Tatiana Magdalena Flores <tatianmf@uci.edu>
Sent:Monday, February 24, 2025 2:55 PM
To:eComments, PBA
Subject:Santa Ana Planning Commission Meeting E-Comment
Follow Up Flag:Follow up
Flag Status:Flagged
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Officials,
I am writing to express my strong support for the Proposed Project, which includes the removal of industrial
uses from the permitted uses table, updates to the nonconforming regulations, the establishment of a new
amortization process, and the elimination of the Light Industrial and Heavy Industrial suffixes from the SD-84
zoning district.
I commend the city for taking steps to prioritize the health and safety of Santa Ana residents by reducing
industrial land use in areas where people live, work, and play. This initiative represents a critical step toward
improving air quality, reducing noise pollution, and enhancing overall community well-being.
Additionally, I would like to ask the city to extend these protections to the southeastern portion of Santa Ana,
which contains a significant industrial corridor. This area exemplifies the disproportionate burden of
environmental hazards on historically marginalized communities, exacerbating health risks for children, adults,
and the elderly. Addressing these longstanding environmental injustices is essential to ensuring that all Santa
Ana residents have the opportunity to live in a safe and healthy environment.
Thank you for your leadership on this issue. I appreciate your consideration and encourage the city to take bold
action to protect the health and future of all Santa Ana residents.
Sincerely,
Tatiana Flores
---
Tatiana M. Flores (she/her/ella)
CLIMATE Justice Initiative Fellow 2024 - 2025
University of California, Irvine
Planning Commission 1 – 239 3/6/2025
1
Ocampo, Nuvia
From:Leonel Flores <mpnacorg@gmail.com>
Sent:Monday, February 24, 2025 3:22 PM
To:eComments, PBA; Ocampo, Nuvia
Cc:Erika; Jose J Rea; Aylin Camacho; Orange County Environmental Justice;
samantha@ocej.org; Kayla Asato; keila; Sydney Cheung; Maya Cheav
Subject:Support Transit Zoning Code (SD-84) Public Comment
Attachments:_2_24 SD-84 Zoning Code Comment Letter to the Planning Commission.pdf
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Good Afternoon,
Please accept this letter as public comment in support of Transit Zoning Code (SD-84).
Have a great day,
--
Leonel Flores
Programs Manager
l
GREEN-MPNA
mpnacorg@gmail.com
EJProgramManager@mpnagreen.org
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The information contained in this electronic transmission, including any and all attachments, is intended only
for review and use by the individual(s) to whom the transmission is addressed, and may contain privileged and
confidential information. If the reader of this transmission is not the intended addressee, you are hereby
notified that any review, dissemination, distribution or copying of this transmission, or any attachments, is
strictly prohibited. If you receive this transmission in error, please immediately notify the sender by reply
email and destroy any and all electronic and paper copies.
Planning Commission 1 – 240 3/6/2025
February 24th, 2025
RE: Draft SD-84 Zoning Code Comment Period for February 24, 2025
Dear Planning Commission:
We, the undersigned organizations and residents, submit this letter in support of the
SD-84 Transit Zoning Code (TZC). OCEJ, GREEN-MPNA, community partners, and the
residents of Santa Ana see this as the next step in phasing out polluting industries in the city, and
improving our air quality. We appreciate the city’s efforts to reduce air polluting industries that
pose a risk to the community’s health by placing a pause on new permits for heavy industrial
uses, prohibiting the expansion of nonconforming industrial use, establishing a set of operating
standards, removing the exemption for storage facilities, and eliminating M1 and M2 zoning in
the Logan and Lacy neighborhoods. We fully support the goal of the proposed regulations
protecting the health, safety, and welfare of existing and future residents of the TZC through the
use of the new amortization process to phase out and discontinue high-polluting nonconforming
industrial uses in the community. We demand that the City be consistent with the general plan
policies that are aimed to correct past land use planning practices that have placed an inequitable
environmental and health burden on certain neighborhoods now termed disadvantaged
communities.
GREEN-MPNA and OCEJ would like to see a similar moratorium set in place in
Southeast Santa Ana. The Madison Park, Cedar Evergreen Co-op, Cornerstone Village, Delhi,
and nearby neighborhoods have an overconcentration of industries that contribute to the
continuation of air pollution from the nearby freeways and emissions of harmful toxins from
industrial use in the surrounding areas. Residents from the area have made complaints in the past
and have been silenced or unheard. In some instances, residents do not feel comfortable making
complaints in fear of retaliation from the city. In 2022, a UCI study examined the correlation of
pediatric asthma rates in Santa Ana to the proximity of an industrial source. This study
determined that students who lived less than 0.5km from an industrial source were more likely to
have pediatric asthma. We also know that Southeast Santa Ana is in the highest percentile
bracket for pollution burden based on the CalEnviroScreen 4.0 map which confirms it is
necessary for these types of zoning changes in our community as well. We ask that you hear the
Planning Commission 1 – 241 3/6/2025
communities ongoing concerns and complaints and address regulatory compliance issues of
industrial businesses in Southeast Santa Ana.
For the last 7 years, OCEJ and GREEN-MPNA have been leaders for environmental
justice in the city of Santa Ana, advocating for policy changes like this. In 2021, the leadership
of OCEJ, GREEN-MPNA, and the CUAL Committee attributed to the adoption of 77 EJ
implementation actions in the city’s general plan update that revolved around reducing exposure
to pollution, improving public facilities, promoting healthy food, creating safe and sanitary
housing, and enhancing civic engagement. In 2022, the city took the first step towards
implementing regulations on polluting industry by adopting a Noxious Use Ordinance that would
address industries with ongoing violations. OCEJ and GREEN MPNA request that the city
expedite and extend this moratorium to be implemented in Southeast Santa Ana. We also ask for
more urgency implementing the 77 EJ policies that are not yet reflected in the changes that are
being made across Santa Ana’s disadvantaged communities. OCEJ, GREEN- MPNA, and our
partners continue to support and work with residents and the city of Santa Ana to amplify
residents’ needs and urge a continued collaboration to reduce the pollution burdens in Southeast
Santa Ana.
To summarize, we commend the city for taking this step, and we want to express our
support for the adoption of SD-84 Transit Zoning Code. We look forward to engaging with the
city for environmental justice, and reducing the pollution burdens our residents face.
Sincerely,
Leonel Flores, Program Manager Samantha Guerrero, Executive Director
GREEN MPNA Orange County Environmental Justice (OCEJ)
Planning Commission 1 – 242 3/6/2025
Tomas Castro, OC Climate Equity Advocate and Organizer
Climate Action Campaign
Planning Commission 1 – 243 3/6/2025