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CORRESPONDENCE - 75A (COMMENT)
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CORRESPONDENCE - 75A (COMMENT)
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10/16/2019 12:29:49 PM
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City Clerk
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75A
Date
10/15/2019
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21 <br />31 <br />4 <br />impacts on the environment requiring the preparation of an Environmental Impact Report ("EIR" ), <br />subsequent EIR, MND or subsequent MND. But even without the impacts from the car wash, the <br />substantial environmental impacts identified as part of the original MND still apply to the Revised <br />which precludes the City from utilizing a categorical exemption for the Revised Project <br />5 11 regardless of how it is analyzed. <br />10 <br />11 <br />12 <br />13 <br />14 <br />Petitioners seek a writ of mandate from this Court to set aside the Notice of <br />Exemption, Environmental Review No. 2019-69 (the "NOE") filed by the City of Santa Ana, the <br />City Council of the City of Santa Ana, the Planning Commission of the City of Santa Ana, and <br />Does 1 through 20 (collectively referred to as, "Respondents" or the "City"), to set aside <br />Respondents' determination that the Revised Project, including the Revised Project at 301 N. <br />Tustin Avenue, Santa Ana, in the County of Orange, is categorically exempt from CEQA <br />environmental review as an in -fill development project pursuant to 14 Cal. Code Regs. Sec. <br />15332, and to order Respondents to conduct environmental review, including the preparation of an <br />Subsequent EIR, MND, or Subsequent MND, as required by CEQA. <br />15 4. This Petition also seeks to set aside all other approvals Respondents have granted <br />16 for the Revised Project, including Conditional Use Permit No. 2019-30, Amendment to Variance <br />17 No, 2018-10, and Conditional Use Permit No. 2019-31, for failing to comply with CEQA. <br />18 5. In addition, this Petition requests that the Court compel Respondents to provide <br />19 public notice of all CEQA determinations, all public hearings or meetings discussing a CEQA <br />20 determination with adequate time for the public to meaningfully participate, and further to provide <br />21 notice to businesses and residents within a sufficient radius of the Revised Project so that <br />22 interested parties may meaningfully prepare and appear to protect their interests, and Respondents <br />23 may receive important input from the public, including those affected by the Revised Project. <br />24 6. On September 9, 2019, Respondents improperly approved the Revised Project and <br />25 filed the NOE the following day, September 10, 2019. Accordingly, this Petition is filed within <br />26 the 35-day statute of limitations prescribed under CEQA section 21167(d). <br />27 /// <br />28 <br />3 <br />PETITION FOR WRIT OF MANDATE <br />
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