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11-26-18_AGENDA PACKET
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11-26-18_AGENDA PACKET
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<br />1 <br /> <br /> <br />2656 29th Street, Suite 201 <br />Santa Monica, CA 90405 <br /> <br />Matt Hagemann, P.G, C.Hg. <br /> (949) 887‐9013 <br />November 20, 2018 <br />Richard Drury <br />Lozeau Drury LLP <br />410 12th Street, Suite 250 <br />Oakland, CA 94607 <br />Subject: Comments on the Magnolia at the Park Multi‐Family Residential Project <br />Dear Mr. Drury, <br />We have reviewed the August 2018 Draft Environmental Impact Report (DEIR) and November 2018 Final <br />Environmental Impact Report (FEIR) for the Magnolia at the Park Multi‐Family Residential Project <br />(“Project”) located in the City of Santa Ana (“City”). The Project proposes to demolish an existing 81,172 <br />square foot office building and a 442‐space parking lot. The Project also proposes to construct 405,290 <br />square feet of residential buildings consisting of 496 multi‐family units, as well as a 9‐level parking <br />structure on the 5.93‐acres site. <br />Our review concludes that the DEIR and FEIR fail to adequately evaluate and mitigate the Project’s Air <br />Quality impacts. As a result, health risk impacts associated with construction and operation of the <br />proposed Project are underestimated and inadequately addressed. A revised EIR should be prepared to <br />adequately assess and mitigate the potential health risk impacts the Project may have on surrounding <br />receptors. <br />Air Quality <br />Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated <br />The DEIR concludes that the proposed Project would have a less than significant impact on the health of <br />sensitive receptors without conducting a quantitative health risk assessment (HRA) for construction or <br />operation of the proposed Project. The DEIR fails to conduct a quantified HRA for nearby existing <br />sensitive receptors and instead solely relies upon an HRA which evaluates cancer risk posed new on‐site <br />receptors. Based on the HRA for new, on‐site receptors, the DEIR concludes that the Project would have <br />a less than significant health risk impact (p. 4.2‐18). The DEIR justifies this analysis by stating, <br />“Because the proposed project is located within an urban community within 500‐feet of I‐5 that <br />has a substantial daily vehicle and truck volume, the contaminants generated from the roadway <br />were identified by the HRA prepared for the proposed project to provide risk estimates related <br />to air contaminants from I‐5 that are reflective of anticipated exposures experienced at the
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