CORRESPONDENCE - 75E (IN OPPOSITION)

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zoning at the time of the EIR publication should be deleted from the EIR. The Draft EIR published in August 2018 should be withdrawn, and a revised Draft EIR should compare the proposed project only to the zoning that is current at. the time of EIR publication. 14.4.7.8 Reguiationsthat Reduce the Potential' Impacts. This section of the DEIR is in error. The current zoning of P is a regulation that does not permit the proposed project. 15.4.7.9 Mitigation Measures. This section of the DEIR is in error. The proposed project increases the density from the adiacent neighborhood from 7 DW/A to 84 DW/A, for an increase of 12 times of the existing neighborhood. This is highly significant and required to be mitigated. 1fi: 4.7.10 level of ftnifican€e-After Mitigation. This section needs to be re -written once land use and potential mitigations are considered with respect to the current zoning. Section 4.9 Population and Housing Section 4.9.3 Environmental Setting Housing Thefirst paragraph ofthe Housing section concludes that housing types in the City of Santa Ana,Tity of Orange, and County of Orange show a "generally similar breakdown of unit type". But the housing type data in Table 4.9-2 shows that Santa Ana has a much higher percentage of multi -family housing with 5 or more units (32.1%) than the City of Orange (18.2%) or the County of Orange (25.8%). These percentages are not generally similar. The DEIR should be revised and reissued noting that City of SantaAn4 has neLdydoublethe percentage of multifamily housing with 5 or moreunits than Citns of Orange, and nearly 30% more than the County of Orange. The third paragraph notes overcrowding in 35% of the units in Santa Ana. Therefore, overcrowding should be expected in 35% of the units in the proposed project. The DEIR should be revised and reissued with the assumption of 35% overcrowding at full occupancy. And with overcrowding... where are all the people going to park? Not enough parking spaces are provided, hence, all extra cars will be parking up and down PSNA streets. Also, people will be parking from the Discovery Center up and down our streets. With all the proposed apartments scheduled at Main Place Mall, the Discovery Center will not be able to rent spaces from Main Place Mail even for the employees to park, let alone all the guests. 4.9.6 Environmental Impacts Housing and Population Table 4.9-6. Anticipated Residents at Full Occupancy, uses "US -Census Data for a.market area that represents similar multi -family residential housing types...."". This basis for the persons per unit for each unit type makes no sense, and ignores the overcrowding in Santa Ana documented in the third paragraph of the Housing section. The persons per unit should be based on averages for Santa Ana, where multiple occupants cohabitate in a single unit and the persons per unit are much higher than presented in Table 4:9-6. The DEIR should be revised and reissued with Table 4.9 -6 -revised forknown living conditions and overcrowding in Santa Ana. All sections of the DEIR that rely on the data in Table 4.9-6 should also be re-evaluated in the revised DEIR. This section relies on US Census average household size to describe the single family residences that comprise the Park Santiago neighborhood. The DEIR should be revised using the actual SFR household size in the zip code, or for the City of Santa Ana, for the County of Orange. 4.9.7 Cumulative Impacts The cumulative impacts consider the wide area on Figure 4-1, and Section 4.9.7 uses growth statistics over that area. In the third paragraph, a conclusion is drawn for just the Main Street corridor, which includes multi -family housing projects 6, 7, 8, 22, and 25 on Figure 4-1. The conclusion for the entire study area does not necessarily apply to the density of multifamily housing planned for the Main Street corridor. Section 4.9.7 should be revised to evaluate the,Cumulative impacts of this project and projects 6, 7, 8, 22, and 25 on the Main Street corridor, and the DEIR should be reissued with the revised evaluation. 4.9.9 Mitigation Measures The need for mitigation measures should be evaluated for cumulative impact in the Main Street corridor of this proiect with multi -family housing projects 6, 7, 8, 22, and 25.