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CUP No. 2025-10 – Footlab Orange County (400 W. Warner Avenue) April 28, 2025 Page 8 of 11 4 9 7 7 challenges posed by requiring that all business activities be conducted and located within an enclosed structure, staff has determined that there would be an undue hardship to the Applicant and recommends relief be provided from the standards. Therefore, staff is recommending that the Planning Commission modify the requirements outlined in Section 41-482 of the SAMC as part of the CUP approval to allow ancillary business activities outdoors. Staff provides additional analysis below. Outdoor Business Operations In staff’s analysis of the proposed use, requiring all business activities to be conducted and located within an enclosed structure would cause an undue hardship to the Applicant due to the soccer field size requirements and related disproportionate economic burden. Soccer requires a playing surface far larger than what is practical or economically feasible for most indoor facilities. Pursuant to FIFA regulations, a standard outdoor soccer field for adult play measures between 100 to 130 yards (300 to 390 feet) in length and 50 to 100 yards (150 to 300 feet) in width. Even scaled-down youth or recreational fields require substantial square footage. Moreover, the ceiling heights, wall structures, and floor loads of most indoor structures are not designed to accommodate such expansive and dynamic play areas, particularly in densely populated urban areas like Santa Ana, where industrial space is limited and expensive. As designed, the Applicant proposes three interior soccer fields, two at approximately 52 feet by 81 feet and the third at approximately 53 feet by 112 feet. In addition, the applicant proposes two additional outdoor soccer fields both at approximately 102 feet by 165 feet. All proposed fields are substantially smaller in size than the standard outdoor soccer field, yet they still cannot be accommodated entirely within an enclosed structure. Moreover, outdoor soccer fields provide affordable, flexible, and inclusive spaces for youth and adult leagues, family recreation, and community engagement. Limiting a widely played sport to indoor settings would restrict participation, particularly for those without the financial means or transportation access to reach more limited and privatized indoor venues, ultimately limiting the viability of Applicant’s business. Conditional Use Permit No. 2025-10 The proposed indoor sports facility is consistent with the intent of the Light Industrial (M1) zoning district, which allows limited commercial or recreational uses that do not interfere with industrial operations or adversely impact adjacent properties. The adaptive reuse of the building for recreation supports the City’s efforts to revitalize underutilized industrial corridors, particularly along Warner Avenue, where a mix of light manufacturing, warehousing, and service-oriented businesses coexist. The nearest sensitive land uses are single-family residential homes and Esqueda Elementary School, which are located approximately between 100 to 200 feet to the north and northwest of the site. The building’s existing location and the proposed site design would lessen the potential impacts to the sensitive receptors, given that the primary uses would be entirely enclosed, with no sound amplification that could contribute to off-site noise. Moreover, the peak