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PALMIERI <br />HENNESSEY <br />LEIFER, LLP <br />Honorable Mayor and City Councilmembers of <br />the City of Santa Ana <br />October 20, 2020 <br />Page 2 <br />with companion sites fronting on 4 s Street are not attached to the Project site. None of the <br />documents discuss the fact that at/near the proposed Project site, there is a placard honoring <br />longtime Santa Ana downtown development director Roger Kooi. <br />Again incredibly, The Addendum fails to refer to the obvious fact that the Spurgeon <br />Building and its 4" Street companion buildings have been operationally tied to the Project <br />Site for decades. They are literally tied together by a bridge. They are tied by parking; <br />access; multiple levels and locations of entry points, emergency egress, service access; <br />utility operations, and air, light and view considerations, among others. As it does not refer <br />to the Spurgeon Building and its site, the Addendum does not analyze these shared <br />operational aspects with the Project site concerning the Spurgeon Building or any of its <br />companion buildings and their sites. Environmental analysis is patently invalid and <br />inadequate if it does not address the elephant, or in this situation, the several elephants in the <br />room. <br />The owners of the Spurgeon Building have received some documents and information in <br />response to a public records act request. The City's failure to produce but a few pages of <br />documents means that the City does not have documents in its possession or has not provided a <br />full and complete production prior to this City Council meeting. <br />The environmental documentation for the proposed massive mixed -use development <br />Project ignores site -specific impacts and then attempts to shield its inadequacy by the improper <br />strategy of suggesting that analysis is deferred until the future. Analysis deferred is analysis <br />denied. Moreover, the "Addendum" tries to support itself on a decade -old EIR that itself made <br />clear that it was not designed to analyze this Project. In the present consideration, the City, its <br />staff or both are playing a shell game with the public. Where is the analysis? "Look back to the <br />FIR, it must be there. If it isn't, we will analyze many issues in the future." <br />The analytical omissions, sad to say, are not surprising. For this neighborhood and the <br />vast majority of neighborhoods in Orange County, this Wilshire Boulevard -type supermassive <br />project bends or breaks all development standards. At the same time, its proponents attempt to <br />circumvent meaningful review, analysis and monitoring constraints. The developer -preferred <br />project avoids consideration of any alternatives to the supermassive project. <br />These are not minor analytical omissions. Rather, these are analytic deficiencies that <br />prevent the City from acting pursuant to law in a purported determination that the proposed <br />Project meets the required legal standards for approval under CEQA, the Government Code, and <br />the Municipal and Zoning Codes. <br />