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Received at City Council <br />Meeting 2/19/2019 <br />September 15, 2018 <br />Vince Fregoso, Associate Planner <br />City of Santa Ana Planning and Building Agency <br />20 Civic Center Plaza, Ross Annex (M-20) <br />PC Box 1088 <br />Santa Ana, CA 92702 <br />Sent by first class mail and email <br />Re: Magnolia at the Park Multi -Family Residential Project; 2525 N. Main Street; <br />ECH#2010021031 <br />Dear Mr. Fregoso, <br />This letter is in response to the Draft Environmental Impact Report (DEIR) for the project <br />identified above. The comments provided below focus on the project's impacts to Aesthetics, <br />Land Use Planning, and Transportation as well as the project Alternatives as detailed below: <br />Aesthetics: <br />The impact conclusions pertaining to Aesthetics are inconsistent within the DEIR. Section 1.5 of <br />the DEIR states that "due to the project's location adjacent to Santiago Park and Edgewood <br />Road near N. Bush Street [the project] would result in a substantial difference in scale, height, <br />and property setbacks that is considered significant pursuant to the City's criteria related to <br />visual character. Thus, the visual change in height, scale, and setbacks from Santiago Park, <br />Edgewood Road, and N. Bush Street that would result from the proposed project would be <br />significant and unavoidable." Table 1-1 in DEIR Section 1.7 then lists Impact AES -2 as "leas <br />than significant". Conversely, Section 4.1 (pp. 4.1-18 and 4.1-28) states that the impact is <br />significant and unavoidable. Correction to the Section 1.7 is required.. <br />CEQA requires under Section 21002 that a lead agency not approve projects if there are <br />feasible mitigation measures available which would substantially lessen the significant <br />environmental effects of a project. The DEIR identifies Mitigation Measure AES -1 to reduce the <br />impact through the preservation of trees and extension of a wall along the eastern boundary. <br />The project's significant impacts are due to the visual change in height, scale and setback. The <br />DEIR fails to identify mitigation measures to specifically address these impacts. Mitigation <br />measures which specifically address these impacts, such as increasing the setbacks, <br />reconfiguration of thebuilding on the site or a reduction in height, should be analyzed and <br />included. <br />Land Use Planning: <br />As stated on DEIR page 4.7-14, the project would have an impact if it conflictjsj with any <br />applicable land use plan, policy, or regulation of an agency with jurisdiction over the project <br />(including, but not limited to the general plan, specific plan, local coastal program, or zoning <br />ordinance) adopted to the purpose of avoiding or mitigating an environmental effect; or if the <br />Project is inconsistent with General Plan policies." <br />Santa Ana General Pian Policy 2.2 states that new development most be consistent with the <br />scale, bulk, and pattern of existing development" and Policy 2.11 states that "new <br />developments most reinforce or help establish district character." The analysis of these policies <br />