2 - COMBINED PUBLIC COMMENTS_2525 N MAIN STREET

Home Browse Search

Dale Helvig 2536 N. Valencia St. Santa Ana CA 92706 714‐541‐7254 helvig_denny@msn.com Page 3 of 17 EIR AREAS OF CONCERN 1. I think the single most important comment I can make on the EIR is what is printed in the Executive Summary of the EIR (page1‐1): “An EIR is a public document designed to provide the governmental agency decision‐ makers and the public with an analysis of potential environmental consequences”. An EIR is not the sole tool that should be used in evaluating a project. Community input, long‐term economic and social impacts should also be evaluated. 2. OMISSION OF THE MAIN PLACE TRANSFORMATION PROJECT. The EIR omitted looking at the Main Place Transformation Project. The EIR response is: “An environmental impact report’s evaluation of cumulative impacts may be based on a list of past, present, and probable future projects producing related impacts (CEQA Guidelines Section 15130(b)(1)(A)). “Probable future projects” include those for which an actual development application has been filed and for which actual environmental review is underway (San Franciscans for Reasonable Growth v. City & County of San Francisco (1984) 151 Cal.App.3d 61, 74). Based on the above, the Draft EIR includes a list of past, present, and probable future cumulative projects for which applications were submitted to lead agencies prior to publishing of the NOP on February 12, 2018.” This list forms the basis for the Draft EIR’s cumulative impacts analyses. Future projects for which applications were submitted to the City after the NOP was released, such as the Main Place Mall Transformation Project, are therefore not included in baseline conditions or the list of cumulative projects provided as Draft EIR Table 4‐1.” I contend that since the Main Place EIR was completed in the 1990’s it is a known probable future project. When you have two projects at least one of them needs to address the other in its cumulative list. Main Place should have been included in the EIR for the 2525 development. The fact that the new owner of Main Place submitted a new plan in May 2018 is irrelevant. The Main Place EIR did not evaluate the 2525 N. Main Residential Development, therefore the 2525 N. Main Residential Development EIR should have evaluated Main Place to ensure cumulative effects were addressed.