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PALMIERI HENNESSEY LEIFER, LLP Honorable Mayor and City Councilmembers of the City of Santa Ana October 20, 2020 Page 8 There has been no analysis of the viability of this massive development particularly in a post-COVID environment. Again, while there is some mention of a conversion of the hotel to residential in the staff report, the Addendum does not address such a conversion. There has also been no consideration of the impacts on surrounding land uses from a fire protection or emergency services standpoint. As discussed herein, the Project will remove the existing ingress/egress from the Spurgeon Building. There has also been no analysis of the ability of emergency vehicles to utilize the alley North of the proposed Project to access the buildings that front on West Fourth Street. There has been no analysis of the fire protection/emergency services to serve this massive development. What is the evacuation plan? What will occur if there is an emergency that requires joint and simultaneous evacuation of this massive development as well as the properties fronting on West 4s' Street? Likewise, there has been no analysis of whether the developer intends to utilize the roof of the 16-story building as a helipad. There is no discussion at all. Does the developer want it, maybe want it, not want it? Will it never happen? The assumption must be that there is the flexibility to add that feature in the future. Yet, there is no analysis of the impacts on surrounding buildings and users. The Proiect will have a significant impact on Geology/Soils that has not been adequately analyzed: The Addendum does not adequately consider potential geological impacts from the proposed Project construction. The Project proposes subterranean parking and a large 16-story mixed use building. The Project will be large, heavy and require substantial excavation. Yet, the Addendum does not provide any updated geology studies or geotechnical reports. The City should not be recommending approval of a large scale residential/mixed use project without site - specific information about geotechnical risks and potential mitigation techniques. There is no support for the Addendum's claim that there will not be geologic or soil impacts. The Proiect will have a significant impact on Transportation that has not been adequately analyzed: There has not been an adequate analysis of the transportation, traffic and parking impacts or appropriate mitigation. As discussed above, the Project requires the demolition of the existing 400-plus public parking structure that serves the existing downtown Santa Ana buildings and businesses. There has been no analysis of whether the 220 public parking spaces to be replaced by the Project would be sufficient for the existing demand plus the demand associated with the mixed -use development. Further, the 16-story mixed use building will have two -access points off of the small alley to the North of the proposed building. There has been little to no analysis of the traffic impacts of having all vehicular access to the massive 16-story mixed use building from the small alley or the impacts to the neighboring properties that front on West