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1 2656 29th Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887‐9013 November 20, 2018 Richard Drury Lozeau Drury LLP 410 12th Street, Suite 250 Oakland, CA 94607 Subject: Comments on the Magnolia at the Park Multi‐Family Residential Project Dear Mr. Drury, We have reviewed the August 2018 Draft Environmental Impact Report (DEIR) and November 2018 Final Environmental Impact Report (FEIR) for the Magnolia at the Park Multi‐Family Residential Project (“Project”) located in the City of Santa Ana (“City”). The Project proposes to demolish an existing 81,172 square foot office building and a 442‐space parking lot. The Project also proposes to construct 405,290 square feet of residential buildings consisting of 496 multi‐family units, as well as a 9‐level parking structure on the 5.93‐acres site. Our review concludes that the DEIR and FEIR fail to adequately evaluate and mitigate the Project’s Air Quality impacts. As a result, health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. A revised EIR should be prepared to adequately assess and mitigate the potential health risk impacts the Project may have on surrounding receptors. Air Quality Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated The DEIR concludes that the proposed Project would have a less than significant impact on the health of sensitive receptors without conducting a quantitative health risk assessment (HRA) for construction or operation of the proposed Project. The DEIR fails to conduct a quantified HRA for nearby existing sensitive receptors and instead solely relies upon an HRA which evaluates cancer risk posed new on‐site receptors. Based on the HRA for new, on‐site receptors, the DEIR concludes that the Project would have a less than significant health risk impact (p. 4.2‐18). The DEIR justifies this analysis by stating, “Because the proposed project is located within an urban community within 500‐feet of I‐5 that has a substantial daily vehicle and truck volume, the contaminants generated from the roadway were identified by the HRA prepared for the proposed project to provide risk estimates related to air contaminants from I‐5 that are reflective of anticipated exposures experienced at the 26 27 2-277