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PALMIERI HENNESSEY LEIFER, LLP Honorable Mayor and City Councilmembers of the City of Santa Ana October 20, 2020 Page 7 West Fourth Street including the Spurgeon Building. The bridges and related stairway structures span the alley between the existing parking structure and the Spurgeon Building (and other buildings fronting on West Fourth Street). The bridges and related stairway structures are attached to the historic Spurgeon Building. Yet no analysis has been conducted concerning the environmental impacts to the Spurgeon Building caused by the removal of those structures. The bridge and related stairway structures also include emergency and incidental ingress, egress from the Spurgeon Building (and other buildings). There are also utility structures that connect to the Spurgeon Building that are part of the existing bridge and related stairway structure. No analysis has been conducted concerning the impacts to the historic Spurgeon Building caused by the removal of those structures. As discussed elsewhere herein, there has also been no consideration of the impacts on surrounding land uses, including the historic Spurgeon Building, from a fire protection or emergency services standpoint. Likewise, as discussed above, the proposed Project seeks to deviate significantly from the standards considered in the 2010 FIR. The height, mass, and floor area ratios will all cause adverse impacts to the Spurgeon Building. The adverse impacts from those deviations have not been analyzed and should be considered in an environmental review. The owners of the Spurgeon Building are concerned that the development activity to demolish the existing parking structure including the bridge and stairway system that serves and is connected to the Spurgeon Building, as well as the development and construction activities that will be required to construct a 16-story building within a few feet of the historic Spurgeon Building that was constructed more than 100-years ago, will cause significant and irreversible impacts to the historic landmark in the City of Santa Ana. Further analysis is needed and required. The Project will have a significant impact on Land Use that has not been adequately analyzed: The proposed Project will deviate from the existing land use plan, policy or regulations. As discussed above, the Project requires a number of questionable waivers/incentives/concessions from the design standards that were studied in the 2010 EIR. The deviations in height, massing, floor area ratio, etc. cause significant impacts that were not analyzed in the 2010 FIR and have not been considered or analyzed in the Addendum. As a result of the lack of analysis, the Addendum proposes no mitigation measures.