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City of Santa Ana – The Bowery <br />May 11, 2020 <br />Page 2 of 28 <br />the EIR for the Project. (Citizens for Clean Energy v City of Woodland (2014) 225 Cal. App. <br />4th 173, 191 [finding that any party who has objected to the Project’s environmental <br />documentation may assert any issue timely raised by other parties].) <br />Moreover, Commenters request that the Lead Agency provide notice for any and all <br />notices referring or related to the Project issued under the California Environmental <br />Quality Act (“CEQA”), Pub. Resources Code § 21000 et seq, and the California <br />Planning and Zoning Law (“Planning and Zoning Law”), Gov. Code §§ 65000– <br />65010. Pub. Resources Code §§ 21092.2, and 21167(f) and Gov. Code § 65092 require <br />agencies to mail such notices to any person who has filed a written request for them <br />with the clerk of the agency’s governing body. <br />The City must seriously consider proposing that the Applicant provide additional <br />community benefits such as requiring local hire and paying prevailing wages to benefit <br />the City. Moreover, it would be beneficial for the City to require the Applicant to hire <br />workers: (1) who have graduated from a Joint Labor Management apprenticeship <br />training program approved by the State of California, or have at least as many hours of <br />on-the-job experience in the applicable craft which would be required to graduate from <br />such a state approved apprenticeship training program and; (2) who are registered <br />apprentices in an apprenticeship training program approved by the State of California. <br />I. EXPERTS <br />This comment letter includes comments from air quality and greenhouse gas experts <br />Matt Hagemann, P.G., C.Hg. and Paul Rosenfeld, Ph.D. concerning the DEIR. Their <br />comments, attachments, and Curriculum Vitae (“CV”) are attached hereto and are <br />incorporated herein by reference. <br />Matt Hagemann, P.G., C.Hg. (“Mr. Hagemann”) has over 30 years of experience in <br />environmental policy, contaminant assessment and remediation, stormwater <br />compliance, and CEQA review. He spent nine years with the U.S. EPA in the RCRA <br />and Superfund programs and served as EPA’s Senior Science Policy Advisor in the <br />Western Regional Office where he identified emerging threats to groundwater from <br />perchlorate and MTBE. While with EPA, Mr. Hagemann also served as Senior <br />Hydrogeologist in the oversight of the assessment of seven major military facilities <br />undergoing base closer. He led numerous enforcement actions under provisions of <br />the Resource Conservation and Recovery Act (RCRA) and directed efforts to improve <br />hydrogeologic characterization and water quality monitoring.