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=A <br />wV <br />wZ <br />2M <br />3J <br />WJ <br />ZO <br />rd <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />acre, with 511 parking spaces proposed. (City Council Agenda, Item 75E, Staff Rept., Part 1, <br />Nov. 19, 2019.) The Project's intensity stands in harsh contrast to the nearby, far less intensive <br />land uses, including the designated open space Santiago Park to the north and the single family <br />residential homes in an R-I zone directly to the east and south. (See City Council Agenda, Nov. <br />19, 2019, Public Hearing Item 75E.) <br />20. Proposed Project approvals included adoption of (i) a resolution certifying the <br />Final EIR; (ii) an ordinance approving a development agreement between the City and Applicant, <br />No. 2018-01 ("Development Agreement"); (iii) a resolution approving a general plan amendment <br />to amend the land use designation of the Property from "Professional and Administrative Office" <br />to "District Center'; and (iv) an ordinance approving an amendment application to rezone the <br />Property from "Professional" to "Special Development No. 93" (collectively, "Entitlements"). <br />21. On October 16, 2019, the City submitted the "Clarification to the 2525 N. Main <br />Street (Magnolia at the Park) Multi -Family Residential Project Final Environmental Impact <br />Report, State Clearinghouse Number: 2018021031, City of Santa Ana: DP No. 2017-34 <br />("October Clarifications"). <br />22. In the October Clarifications, the City determined, without factual support, that the <br />Final EIR did not need to be recirculated despite the new and substantial modifications that only <br />first appeared in the October Clarifications to the Second Plan still not the final Project. <br />(October 2019 Clarifications, p. 2.) <br />23. On October 28, 2019, the Planning Commission again recommended that the City <br />Council not certify the Final FIR and deny the proposed development and all related <br />Entitlements. (Planning Commission Minutes, Oct. 28, 2019; see also Staff Rept., Part 1, Nov. <br />19, 2019.) <br />24. One or more of Petitioner's members, among others, objected orally and/or in <br />writing at the City Council's November 19, 2019, public hearing regarding the Development <br />Agreement, the Final EIR, and the related Entitlements, thus satisfying the requirements with <br />respect to administrative exhaustion. True and correct copies of Petitioner's written objections <br />are attached hereto as Exhibit A and Exhibit B, respectively, and are incorporated by reference <br />4516.101 / 8560319.1 _ 6 - <br />VERIFIED PETITION FOR WRIT OF MANDATE/MANDAMUS <br />