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City of Santa Ana– First American Mixed-Use Project [114 and 117 East Fifth Street] – Comments to City Council November 18, 2019 Page 6 of 13 and to encourage other agencies to use the device as a way of making minor corrections in EIRs without recirculating the EIR. The addendum is the other side of the coin from the supplement to an EIR. This section provides an interpretation with a label and an explanation of the kind of document that does not need additional public review. The need for this section was shown by the many telephone calls received in the Resources Agency asking how to handle this situation.” (Cal. Natural Resources Agency, Amendments to the State CEQA Guidelines, Text of Adopted Amendments with Statement of Reasons (Dec. 30, 1982), pp.100--101.) The Project encompasses as mixed-use development consisting of two separate buildings located on two development sites at 114 (Site A) and 117 (Site B) East Fifth Street, which would contain a total of up to 220 residential rental units, 12,350 square feet of commercial space, and 332 onsite parking spaces. 11/19/19 Staff Report, p. 1- 2. While the Project site is zoned Transit Zoning Code, the 2010 EIR for the Transit Zoning Code By the City’s own admission, the Transit Zoning Code was adopted in July 2010 and provides a framework for various development activities in a large section of central Santa Ana, loosely bound by Flower Street, the Santa Ana (I-5) Freeway, Civic Center Drive, Grand Avenue, and First Street. 11/19/19 Staff Report, p. 4. While the 2010 EIR for the Transit Zoning Code envisioned the development of various sites with residential, commercial and industrial development, project specific analyses were not included. The 2010 EIR simply did not contemplate the Project as currently proposed. As such, the City was required to prepare an EIR, rather than an Addendum, which is only allowed where only minor technical changes or additions are being made from the prior EIR. Here, there was no prior EIR that analyzed the specific impacts of the Project. The City’s blatant ignorance of the project-specific EIR requirement has dire consequences which gravely jeopardizes the informational and public input purpose of CEQA. Unlike an EIR, there is no public comment or circulation requirement. See 14 Cal. Code Regs. § 15164. Once an addenda is issued, it could be approved by the decision-making body of an agency without the notifying the public. Moreover, the City here gets away with a much curtailed analyses in the Addendum (mere 100 pages) outside of the more rigorous and detailed EIR (which can exceed over 1,000 pages). Also, if this were truly the case that the City did indeed complete a prior project- specific EIR, the City would still have been required to prepare a subsequent or