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S'�►B ® Technical Consultation, Data Analysis and ■!APE Litigation Support for the Environment 2656 29`h Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949)887-9013 mhaxemann@swaoe.com May 28, 2019 Richard Drury Lozeau Drury LLP 1939 Harrison Street, Suite 150 Oakland, CA 94612 Subject: Comments on the MainPlace Mall Transformation Project Dear Mr. Drury, We have reviewed the May 2019 Addendum to the Fashion Square Commercial Center Final Environmental Impact Report ("2019 Addendum"), the 1996 Addendum to the Environmental Impact Report for Proposed MainPlace/Santa Ana Expansion ("1996 Addendum"), and the 1983 Final Environmental Impact Report for the Fashion Square Commercial Center ("1983 EIR") for the MainPlace Mall Transformation Project ("Project") located in the City of Santa Ana ("City"). The existing MainPlace Mall consists of 1,130,000 square feet of commercial space and 4,882 parking spaces. The 2019 Addendum proposes to retain the existing 1,130,000 square feet of commercial space and partially demolish the existing parking areas in order to construct 270,000 square feet of additional commercial space, 750,000 square feet of office space, a 400-room hotel, and 1,900 residential dwelling units on the 49.04-acre site. Our review concludes that the 2019 Addendum fails to adequately evaluate the Project's Hazards and Hazardous Waste, Air Quality, and Greenhouse Gas (GHG) impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. As neither the 2019 Addendum nor the 1983 EIR adequately evaluate the Project's Air Quality and GHG impacts, and because the currently proposed 2019 Addendum Project differs significantly from the project evaluated by the 1983 EIR, a full Environmental Impact Report (EIR) should be prepared to adequately assess and mitigate the potential air quality and health risk impacts that the currently proposed Project may have on the surrounding environment. Hazards and Hazardous Waste Failure to Evaluate Potential Impacts Neither the 2019 Addendum nor the 1983 EIR adequately evaluate potential hazardous waste issues because a Phase I Environmental Site Assessment (ESA) was not conducted for the Project Site.