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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 5 <br />experience does Santa Ana have with fire fighting a 16-story residential/hotel building <br />surrounded by smaller historic structures? What analysis is in the documentation? None. <br />Similarly, there has been no analysis of the deviation from the maximum 85% massing <br />standard. No analysis has been conducted to support the claims of the added views from the <br />"recessing" of the "building mass at the fourth and fifth levels." In fact, the massing proposed at <br />the fourth and fifth levels is at or nearly at the maximum allowable massing of 85%. It is not <br />like the third story deviates the maximum but the fourth and fifth levels try to compensate for <br />that by have a massing less than the maximum. The deviation from the floor area ratio standards <br />contributes to the height and massing impacts of the proposed project. <br />As discussed elsewhere herein, there is no analysis of the impacts from construction of <br />this massive Wilshire Blvd. -type of development just steps away from a 100-plus year old <br />building. What steps will be undertaken to make sure that the demolition, earth movement and <br />construction required for this massive project development will not impact the historic Spurgeon <br />Building or the surrounding historic Downtown area? <br />The proposed Project also deviates from the parking standards and requirements. The <br />proposed Project eliminates an existing 400-plus space public parking structure that currently <br />serves the downtown Santa Ana properties and businesses. The proposed Project seeks to <br />demolish that existing 400-plus space parking structure and the attendant improvements such as <br />the bridge structures from the parking structure to the nearby buildings, including the Spurgeon <br />Building. The Staff Report asserts that the Project proposes to replace the existing 400-plus <br />space public parking with 220 public parking spots. The Staff Report fails to recognize that such <br />parking spots will be utilized by the retail/commercial oriented uses being proposed as part of the <br />mixed -use development Project. There is no analysis as to the current parking usage of the <br />existing 400-plus parking structure nor any analysis as to whether the proposed 220 parking <br />spots will be sufficient for use of the downtown Santa Ana properties and businesses that <br />currently utilize and rely upon the 400-plus spaces in the existing parking structure. There is no <br />analysis of the impact to the parking situation during construction. How long will it take for <br />construction of the development? How long between demolition of 400-plus spaces to having <br />public use of 220 spaces? <br />The City's wholesale failure to analyze the very real impacts to historic site such as the <br />Spurgeon Building requires a denial at this time. In fact, there will be significant impacts to the <br />Spurgeon Building from these deviations. <br />