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MARK A. ROTHENBERG, ESQ. <br />2042 NORTH Ross STREET <br />SANTA ANA, CALI FOR NIA 92706 <br />MARK1 IAA@ME.COM <br />November 18, 2019 <br />VIA EMAIL <br />Ms. Selena Kelaher <br />Associate Planner <br />Planning and Building Agency <br />City of Santa Ana <br />PO Box 1988 <br />Santa Ana, California 92702 <br />Re: Letter of Objection/Comments/Magnolia at the Park/Draft EIR (State Clearing <br />House No. 2018021031-Santa Ana DP No. 2017-34 <br />Dear Mr. Kelaher: <br />This letter supplements my prior written policy and legal objections to the proposed 2525 <br />North Main Street Project (the "Project") dated September 12, 2018 (incorporated and restated <br />herein despite the project's modifications). The Project subordinates adjacent neighborhoods to <br />the blight associated with an overly intensive, under -parked, and aesthetically uninteresting <br />development. I am a resident of Santa Ana, a land use practitioner and professor of land use law. <br />My prior letter was not adequately responded to in the EIR and the issues raised continue to plague <br />the redesigned project. In addition and as summarized below, the amendment to the General Plan, <br />re -zoning, and adoption of the development agreement constitute extraordinarily poor planning <br />and appear violative of California law (including the Brown Act). <br />Request for Deferral to Mid -January <br />As a threshold matter, the City has scheduled consideration of the Project on November <br />211 (one week prior to Thanksgiving). Given the magnitude and lasting impacts associated with <br />the City's decision and the arrival of the Thanksgiving, Christmas, and New Years, I respectfully <br />request that the City defer consideration of the application until mid -January to ensure that all <br />impacted residents are afforded a reasonable opportunity to offer comment and attend Council <br />meetings. As explained below, the description of the project in notices must be revised to reflect <br />the shifting of a portion of the Discovery Cube's business operations (parking) to the Project site. <br />Piecemeal General Planning <br />The subject property is a marquis property in the City. Unfortunately, the City has not <br />completed its General Plan update. From information available online, it appears that the City's <br />