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Initial Study/Mitigated Negative Declaration Preparation Kimsey -Horn's approach to preparing key sections of the IS/MND is similar to the discussion set forth above for an EIR preparation, although the amount of detail in the existing conditions and impact analyses Is appropriately reduced to address the specifics of the project. Sections not required for an IS/MND include, but are not limited to, a discussion of the Project Objectives, the Alternatives analyses, discussions of Significant Irreversible Impacts; Growth -Inducing impacts; and the Cumulative analyses (except where explicitly required by a threshold of significance). Kimley-Horn will prepare the Screencheck IS/MND and submit the document electronically (i,e. PDF and Word) to the City/Project Applicant for review and comment. Once comments have been received, Kimley-Horn will prepare a second IS/MND, and then an Approval Draft, for final review and approval for public distribution. Public Review Kimley-Morn will be responsible for the reproduction and distribution of CDs of the IS/MND, Notice of Intent (NO1) to Adopt MND, and NOC to the State Clearinghouse (if applicable) to those on the City's mailing distribution list. This effort will Include coordinating the preparation of the document in PDF format for use in CDs and inclusion on the City's website. Kimley-Horn will post the NOI with the County Clerk, Additionally, Kimley-Horn can prepare an abbreviated NOI for publication in a newspaper of local circulation to announce the public review period. Responses to Comments, Errata, and Mitigation Monitoring and Reporting Program According to CEOA Guidelines Section 15074, a lead agency does not need to prepare a formal response to comments document, but rather, the decision-making body must consider the IS/MND together with any comment received during the public review process. However, it is common practice for lead agencies to provide the decision-making body with a set of written responses to all comments received for their use In deliberations on whether to approve the project. The preparation of these documents is similar to the process set forth for the EIR, as described above; however, fewer comment letters are anticipated to be received in the preparation of an IS/MND. Phase 1 Environmental Site Assessments Under recently -enacted environmental laws, the ownership, leasing, or transfer of real estate can result in a serious liability situation. If it is determined that contamination exists as a result of past operational or waste disposal activities, anyone in the chain of ownership may be liable for the cost of cleanup, which in turn could impair or eliminate the value of the affected property. The 1986 Superfund Amendment and Reauthorization Act (SARA) established an "innocent purchaser" defense to environmental liability. This "innocent purchaser" defense is applicable If the owner, at the time of acquisition, made "all appropriate inquiry into the previous ownership and uses of the property" and conducted "appropriate inspection" prior to the transfer of deed and found no evidence of hazardous substances. It was out of this legislation that the environmental assessment came into being. The environmental assessment can provide the basic supporting documentation for the "innocent purchaser" defense and protect against corporate or personal liability. The environmental assessment is geared toward assisting the client property transaction and/or providing pertinent information on environmental site conditions relating to; • The existence of hazardous waste and petroleum compounds on the property, and • The existence or probable sources of hazardous waste or petroleum site contamination at properties adjacent to the client's property. City of Santa Ana I EVOC77009.17 21 Kimley>Morn