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