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PALMIM HENNESSEY LEIFER, LLP October 20, 2020 VIA E-MAIL: eCommentna,santa-ana.org Honorable Mayor and City Councilmembers of the City of Santa Ana 20 Civic Center Plaza Santa Ana, CA 92702 Michael H. Leifer Direct Dial: (949) 851-7294 E-mail: mleifer@palmierilawgroup.com Re: Public Hearing Agenda Item 75A - Environmental Review No. 2019-85 for Density Bonus Agreement Application No. 2020-01, Site Plan Review No. 2020-01, Site Plan Review No. 2020-02, and Disposition and Development Agreement with Caribou Industries for the 3rd and Broadway Development At 201 West 3rd Street Objection/Comment Letter Dear Honorable Mayor and City Council Members: File No.: - This office represents Coalition Against Santa Ana Irresponsible Development which includes citizens of and property owners in Santa Ana including the owners of the historic Spurgeon Building (202-212 West 4d' Street, Santa Ana). The owners of the Spurgeon Building are very concerned about the impact of the proposed 3`d & Broadway Mixed -Use Development Project. This letter is submitted in opposition to the proposed actions considered by the City Council relating to the proposed Project and the environmental review of same. The City appears to be giving a "pass" to this Project on a number of issues. The City is relying on a decade -old EIR relating to a zoning change and an inadequate Addendum that has failed to analyze the environmental impacts from this massive Wilshire Blvd. -like development. The City is also relying on outdated mitigation measures and proposing a Mitigation Monitoring and Reporting Program for the Addendum that does not include tangible mitigation measures. Instead the mitigation measures proposed rely on future analysis and considerations and aspirational measures. The end result is a massive Project that is "not ready for prime time." Ironically, the Addendum refers to a decade -old EIR to suggest that it analyzed things that it clearly did not. Neither the Addendum nor the EIR address the slightly older redevelopment of the downtown by various owners and the Redevelopment Agency. Most notably, the Addendum fails to analyze the potential significant environmental impacts on the historic Spurgeon Building as redeveloped or the companion buildings as redeveloped that are located just steps away from this massive proposed mixed -use Project. Incredibly, the Addendum omits discussion of or reference to the historic Spurgeon Building. The Addendum pretends that the Spurgeon building and site as redeveloped (along 2 Park Plaza, Suite 550, Irvine, CA 92614-2518 (949) 851-7388 1 www.paimierilawgroup.com