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team really wanted to provide an apples -to -apples comparison with this proposed project instead of making an <br />attempt to support the Developer's proposal, then they should have selected multi -family developments located <br />within similar single family residential areas. <br />6. This project violates Policy 2.10 of the Land Use Element of the City of Santa Ana General Plan: "Support new <br />development which is harmonious in scale and character with existing development in the area." I submitted <br />a comment to address the Draft EIR noting that the EIR fails to reflect the nature and character of the Park <br />Santiago neighborhood of which it is contained. However the project management team's response to this <br />comment was "The project site is not contained within the Park Santiago neighborhood.... The Park Santiago <br />neighborhood does not exist along N. Main Street. Thus it is appropriate that the EIR does not provide greater <br />weight to the residential neighborhood...." A check of the neighborhood maps provided by the City of Santa Ana <br />makes the claim by the project management team the project site is not part of the Park Santiago neighborhood <br />as a false claim (https://www.santa-ana.org/neighborhood-initiatives/community-engagement-and-volunteer- <br />opportunities). In making this false claim the project management team again indicates that it sides more closely <br />with the Developer than with the residents of Park Santiago. Again it should be reiterated, the six parcels <br />identified for use in this development, contrary to what the project management team is claiming, are part of the <br />Park Santiago neighborhood and any justification using an argument that the parcels are not is totally false and <br />should be rejected by the City Council. <br />7. The number of proposed parking spaces planned for the project has always been a major concern with the <br />residents of Park Santiago. With insufficient parking made available for the residents there will be renters who <br />will park their vehicles along Bush Street and Spurgeon Street. As evidence of this one only needs to view the <br />excessive number of vehicles from a nearby apartment complex parked along Santiago near 17th Street. The <br />Developer has planned for 904 spaces of which 150 (17%) are identified as tandem parking for the 496 units or a <br />rate of 1.80 parking spots per unit. The Request for Planning Commission Action in Table 9: Parking Per SAMC <br />Section 41-1322 Multi -family Dwellings notes that for a project of this size the Santa Ana Municipal Code (SAMC) <br />requires 1,420 spaces or a ratio of 2.86 spaces per unit. However, the project management team has elected to <br />disregard the SAMC requirements and allow the Developer to provide significantly less. However they again side <br />with the Developer by saying that the SAMC is outdated and the parking requirements were established in <br />1997. To assume that the number of vehicles per household unit has decreased in number since 1997 is a naive <br />statement, in fact the opposite is true. The project management team again has sided with the Developer and <br />will allow significantly less than the SAMC mandated 1,420 parking spots. An attempt is made to address the Park <br />Santiago residents' concerns regarding inadequate parking by making it a requirement to have a minimum of 952 <br />spaces or 2.0 spaces per unit. Compounding this decision the project management team has agreed with the <br />Developer's assertion that the 2.0 parking spots per unit can be obtained through the use of valet services. Valet <br />services for apartment dwellers is illogical. The project management team admitted during the January 14th <br />Planning Commission meeting that the use of valet parking to address a shortage of parking spaces had never <br />been used for a multi -family apartment complex in Santa Ana before. Besides, who will be waiting for a valet to <br />bring them their car so that they can run to the store for groceries? Where will the valet park these extra cars, in <br />the Park Santiago neighborhood? The City Council should not allow this project to violate the SAMC parking <br />requirements of 2.86 spaces per unit. Nor should the project be allowed to use valet services to meet the <br />requirement. <br />8. As noted in the Request For Planning Commission Action Table 6: Professional Zone Comparison, the project will <br />reduce the current set back from the east property line nearest to the existing homes on Spurgeon Street from <br />50 feet minimum to 40 feet 7 inches minimum. It also reduces the existing requirement of 25 feet maximum <br />height within approximately 240 feet of the east property line to 40 to 66 feet. Both of these changes will <br />significantly impact the home owners who reside on Spurgeon Street adjacent to the project and contributes to <br />the negative aesthetic impact which the EIR noted as being significant. By allowing these changes that the <br />Developer has requested, it once again shows that the project management team has placed the Developer's <br />needs over the concerns of the residents of Park Santiago. <br />9. The EIR identifies one "significant and unavoidable" impact associated with this project, which pertains to <br />aesthetics. CEQA guidelines Section 15126.6 (c) requires that "an EIR analyze a reasonable range of alternatives <br />to the proposed project that could feasibly avoid or reduce any significant unavoidable impacts of the <br />3 <br />