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development. Put simply, the City of Santa Ana risks losing a valuable opportunity to <br />support an area -wide economic revitalization on a marquis parcel of property. <br />I. Site Overview <br />The 2525 Main Street project ("Project') is situated on 5.93 acres of property <br />located at the Northeast corner of Main Street and Edgewood Road. The property has <br />historically served as a transitional buffer between the Park Santiago Neighborhood <br />consisting of approximately 1,100 homes built between 1899 and 1970 with a number of <br />homes on the City's historic register. The site has historically been used for light <br />commercial and office uses since the 1920s. The Santa Ana (now Orange County) <br />Register reported over the years that the site was utilized as a grocer, auto repair, and <br />chapel/mortuary. A two-story office building was developed on the property in 1981. <br />11. Development Proposal. <br />The Project attempts to shoehorn 405,000 square feet of high -density residential <br />development containing 496 rental units onto the 5.93 acre project site. This results in a <br />density of 83.6 units per acre. The Project is supported by a 9 level parking garage <br />consisting of 904 parking spaces (1.8 spaces per unit). <br />III. Spot Zoning. <br />The Project constitutes an example of spot -zoning. Spot zoning occurs where <br />the City creates an island of one type of use that has significantly greater <br />development rights than surrounding properties. See, e.g., Foothill Communities <br />Coalition v. County of Orange, 222 Cal. App. 41h 1302 (Cal. App. 4u Dist 2014). <br />Although spot zoning is not necessarily unlawful, the City must make a <br />finding/provide a compelling justification for spot zoning. For example, in Foothill <br />Communities, the court determined spot zoning was appropriate to accommodate a <br />senior housing project Creating a cloistered/gated apartment community with <br />sparse setbacks is entirely inconsistent with established development patterns in <br />the immediate area and creates an island of high -density residential development in <br />an area that is otherwise comprised of benign office development and a well - <br />established historic single-family neighborhood. It is likely the applicant will <br />respond by arguing that the project is not spot -zoning because it is commensurate <br />with densities contemplated for projects adjacent to the Main Place Mall. However, <br />such projects are located across a 6 lane highway and are approximately 1,000 feet <br />away. <br />IV. CEQA Violations/EIRDefects <br />The following constitutes an overview of significant errors that cloud the entire <br />proceeding and reflect what appears to be carelessness by the applicant and the <br />information provided to the City's EIR consultant. It is my sincere hope that the City's <br />