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CORRESPONDENCE - 75E (GENERAL COMMENTS)
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CORRESPONDENCE - 75E (GENERAL COMMENTS)
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3/11/2019 12:38:42 PM
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2/19/2019 11:32:06 AM
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City Clerk
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75E
Date
2/19/2019
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Alternatives <br />No Project Alternative <br />This alternative compares impacts of the proposed project with re -occupation at full capacity of <br />the existing office building. This assumption is unfounded based on the historical occupancy of <br />the office building. My family has lived in the neighborhood on Edgewood Road since 1963, so <br />we are very familiar with the operations of the office building since its construction. We have <br />never observed this building to be 100% occupied and would venture to say that the parking lot <br />was no more than 50% full at its peak operation. The analysis of the No Project Alternative <br />should be based on the realistic historic occupancy of the building, not an unrealistic potential <br />future occupation. <br />The aesthetic impacts discussion concludes that the landscaping would deteriorate and <br />improvements to existing landscape would not occur, Similar to the assumption that the office <br />would be at full capacity, this is highly speculative. City of Santa Ana Municipal Code (Article X <br />Property Maintenance), "protect[s] the city's neighborhoods against blighting and deteriorating <br />influences or conditions that contribute to the downgrading of neighborhood aesthetics and <br />property values by establishing minimum standards...". The analysts in the DEIR should assume <br />that the City would enforce its own regulations. <br />Reduced Alterative <br />Under this alterative, there is a reduction in the number of residential units by 30% and would <br />also result in increased setbacks and reduced building heights. The aesthetic impacts <br />discussion states that under this scenario, the Reduced Project Alternative would also <br />substantially change the scale, height, and setbacks in comparison to existing views of the <br />project site. As stated on p, 6-7, CEQA requires the alternatives selected for comparison in the <br />EIR shall avoid or substantially lessen one or more of the significant impacts. Aesthetics was <br />the only impact for the Proposed Project found to be Significant and Unavoidable, therefore it is <br />reasonable to assume that the Alternatives should focus on avoiding or substantially lessening <br />the impact to Aesthetics. The analysis in the Reduced Alternative fails to fully flesh out <br />reasonable design alternatives that would avoid or substantially lessen the impact to Aesthetics. <br />The analysis should include a discussion of a Reduced Alternative that is lower in height and <br />overall scale. This may be accomplished through encroachments in the setbacks compared to <br />the existing office building but may not be as severe as the Proposed Project. To that effort, the <br />EIR must take this into consideration and evaluate more than one way to reduce the size of the <br />project, reconfigure the building, break up the mass of the building, consider different setback <br />options, etc. <br />Thank you for consideration of our comments. <br />Regards, <br />? <br />r <br />Sara and colt Trask <br />
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