KIMLEY HORN AND ASSOCIATES, INC. (2)

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Mitigation Monitoring and Reporting Program (MMRP); Findings of Fact and Statement of Overriding Consideration Kimley-Horn will develop MMRPs using the City's format and will clearly identify all components of the Mitigation Program, responsible parties, and a timeframe for implementation. We can also prepare Findings of Facts and Statements of Overriding Considerations if necessary and appropriate for the document type. Initial Study/Mitigated Negative Declaration Preparation (IS/MND) Kimley-Horn's approach to preparing key sections of an IS/MND is similar to our approach to an EIR preparation, although the amount of detail in the existing conditions and impact analyses is appropriately reduced to address the specifics of the project. Sections not required for an IS/MND include, but are not limited to, a discussion of the project objectives, the alternatives analyses, discussions of significant irreversible impacts, growth -inducing impacts, and the cumulative analyses (except where explicitly required by a threshold of significance). Addendum Preparation An addendum can be prepared to a previous EIR or Mitigated Negative Declaration. The State CEQA Guidelines, Section 15164, provides general guidance regarding addendums; however, it defers to CEQA Guidelines Section 15162 to determine whether circumstances warrant the preparation of additional CEQA documentation. Pursuant to Section 15162(a) of the State CEQA Guidelines, additional CEQA documentation beyond an addendum would only be required if the proposed project creates new significant impacts or impacts that are more severe than those disclosed in previous CEQA document. This finding must consider factors such as changes in the scope of the proposed project; any changes in surrounding circumstances that have occurred since the Final EIR was certified; and the discovery of new information that was not known at the time the EIR or Mitigated Negative Declaration was prepared. The addendum test is the ability to provide substantial evidence showing that the proposed project would not create new significant adverse impacts or increase the severity of a significant adverse impact identified in the previous CEQA document. CEQA Guidelines Section 15183 Analysis Preparation The State CEQA Guidelines Section 15183 allows for a streamlined environmental review process for projects that are consistent with the densities established by existing zoning, community plan, or general plan policies for which an EIR was certified. Under CEQA Guidelines Section 15183, a subsequent project is relieved from further environmental review if it meets the criteria of Section 15183(c): all significant impacts were either addressed in a prior EIR or can be substantially mitigated by the imposition of uniformly applied development policies or standards. The analysis demonstrates and/or validates that there are no site -specific or cumulative impacts associated with the project that have not already been fully addressed in a previous environmental document or cannot be substantially mitigated through the application of uniformly applied standards and policies that would be applied to the project. All project requirements are identified in the analysis and are made a condition of project approval. Categorical Exemption Preparation Kimley-Horn will work with City staff to determine which State CEQA Guidelines exemption classification would be appropriate for the project. Most typically, documentation is prepared to support a Section 15301: Class 1: Existing Facilities; Section 15302: Replacement or Reconstruction; Section 15302: Class 3: New Construction or Conversion of Small Structures; Section 15304: Class 4, Minor Alterations to Land; and Section 15332: Class 32, In -Fill Development Projects. Notices and Distribution of Documents Kimley-Horn can prepare all necessary CEQA notices, including Notices of Preparation, Notices of Availability, Notices of Completion, and Notices of Determination. We can be responsible for all reproduction and distribution of documents. We will also provide the environmental documents in a web -ready format for use by the City. City of Santa Ana Planning Division I Evoc77014.2020 KimleyoHorn