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CORRESPONDENCE - 75A
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CORRESPONDENCE - 75A
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10/21/2020 3:42:17 PM
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10/20/2020
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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 9 <br />Fourth Street and the impacts to access for emergency vehicles as well as emergency egress from <br />the buildings that front on West Fourth Street. <br />The Project will have a significant impact on Aesthetics that has not been adequately <br />analyzed: As discussed above, the proposed Project seeks numerous waivers/concessions to <br />deviate from standards which will cause significant aesthetic impacts that have not been <br />adequately studied or mitigated. The shadow analysis is just one example of the significant <br />impacts caused by the deviations from the height, massing and floor area ratio standards. The <br />historic Spurgeon Building and other existing buildings and land uses will be dwarfed by the <br />proposed project and live within its shadow. Those impacts have not been analyzed or mitigated. <br />There has not been an adequate analysis of Greenhouse Gas impacts: Neither the Project <br />nor the underlying documents comply with the provisions of AB 32, Executive Order No. S-03- <br />05 and California Air Resources Board regulations ("GHG Mandates") as they have been <br />interpreted by both the California Supreme Court and California Courts of Appeal. See Center <br />for Biological Diversity v. California Department of Fish and Wildlife (2015) 62 CalAtb 204; <br />Sierra Club v. County of San Diego (2014) 231 Cal.App.4a' 1152.) It is mandatory for local <br />jurisdictions such as the City of Santa Ana to take affirmative steps to reduce Green House Gases <br />("GHGs"0 with feasible mitigation and valid climate action plans which implement statewide <br />policy of minimizing GHG as described in AB32. This Project, the 2010 EIR and the Addendum <br />fail to do that. <br />Mitigation Monitoring and Reporting Program is deficient. <br />As discussed above, because of the environmental documents' deficient analysis of the <br />impacts to the environment from the proposed Project, appropriate mitigation measures have not <br />been proposed. Further, even the mitigation measure that are being proposed are largely <br />ineffective and without any real oversight. As one example only, the proposed "mitigation" for <br />the impact to cultural and historic resources simply further defers analysis by requiring a <br />technical report at some later date. The proposed mitigation does not provide any requirement <br />for future public notice and review. <br />The "mitigation" to conduct future analysis is not sufficient. Critical public review <br />particularly to preserve historic resources is key. The time to analyze and provide the public <br />with information is now not some later date when critical review will be no opportunity for <br />public notice and review of such <br />Further, there is no effort for any monitoring of actual construction activities for <br />compliance. <br />
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