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MainPlace Transformation Project City Council Agenda Item 75D June 4, 2019 Page 2 contained no residential element, yet the Project proposes 1,900 residential units that have never been analyzed under CEQA. The 1983 EIR has no informational value to the residential element of the Project and is irrelevant to analyzing its environmental impacts. In addition, the circumstances surrounding the Project site have changed dramatically since 1983. For example, traffic has increased nearly 50% in some nearby locations. The 1983 EIR fails to address any of these changed circumstances. As a result, additonal environmental review of the Project must occur pursuant to the California Environmental Quality Act ("CEQA"). A number of highly qualified experts have reviewed the proposed hotel project and its environmental effects. Traffic engineer Daniel Smith. Jr., P.E., and Certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH, and environmental consulting firm SWAPE have identified a number of significant impacts from the proposed Project including traffic, and air quality impacts, as well as omissions and flaws in the documents relied upon by staff. These comments are attached as Exhibits A through C. By opting to proceed with an Addendum instead of the required EIR or SEIR, the City of Santa Ana ("City") has deprived the members of the public of the public review and circulation requirement available for EIRs. SAFER urges the Commission not to adopt the Addendum or approve the Project, and instead to direct staff to prepare a Draft EIR for the Project, and to circulate the Draft EIR for public review and comment prior to Project approval. PROJECT DESCRIPTION The Project involves adoption of a specific plan to facilitate the redevelopment of the existing MainPlace Mall into a regional, mixed -use village with additional commercial, office, residential, and hotel projects. The Project involves 1,400,000 square feet of commercial, 750,000 square feet of office, 400 rooms of hotel, and 1,900 residential units. In contrast, the 1983 EIR analyzed a mixed -use commercial center with 1,600,000 square feet of commercial space, 1,500,000 square feet of office space, and 1,200 hotel rooms. The Project site currently contains the 1,130,000 MainPlace Mall regional shopping center, three parking structures, and surface parking lots. The site is approximately 49 acres and is located northeast of the corner of Main Street and Main Place Drive. It is surrounded by the Santa Ana (I-5) Freeway to the west, the Garden Grove (SR-22) Freeway to the north, Main Street and commercial and mixed -use land uses to the east, and Main Place Drive and commercial -office land uses to the south. A midrise office building is located adjacent to the site at 2700 North Main Street. LEGALSTANDARD CEQA contains a strong presumption in favor of requiring a lead agency to prepare an EIR. This presumption is reflected in the fair argument standard. Under that standard, a lead agency must prepare an EIR whenever substantial evidence in the whole record before the agency supports a fair argument that a project may have a significant effect on the environment.