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<br />2656 29th Street, Suite 201 <br />Santa Monica, CA 90405 <br />Matt Hagemann, P.G, C.Hg. <br /> (949) 887-9013 <br /> mhagemann@swape.com <br />Paul E. Rosenfeld, PhD <br /> (310) 795-2335 <br /> prosenfeld@swape.com <br />September 23, 2022 <br />Victoria Yundt <br />Lozeau | Drury LLP <br />1939 Harrison Street, Suite 150 <br />Oakland, CA 94618 <br />Subject: Comments on the 1700 Garry Avenue Project <br />Dear Ms. Yundt, <br />We have reviewed the August 2022 Planning Commission Staff Report (“Staff Report”) for the 1700 E <br />Garry Avenue Project (“Project”) located in the City of Santa Ana (“City”). The Project proposes to <br />demolish 105,558-square-feet (“SF”) of office space and construct 81,500-SF of warehousing and <br />distribution space, 10,000-SF of office space, and 145 parking spaces on the 5.2-acre site. <br />Our review concludes that the Staff Report fails to adequately evaluate the Project’s health risk and <br />greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and <br />operation of the proposed Project are underestimated and inadequately addressed. An Environmental <br />Impact Report (“EIR”) should be prepared to adequately assess and mitigate the potential health risk <br />and greenhouse gas impacts that the Project may have on the environment. <br />Air Quality Diesel Particulate Matter Emissions Inadequately Evaluated <br />Regarding the preparation of a health risk analysis (“HRA”), the General Plan Update Final Recirculated <br />Program Environmental Impact Report (“GPU EIR”) incorporates Mitigation Measure (“MM”) AQ-3. The <br />Environmental Analysis (“EA”), provided as Exhibit 10 to the Staff Report, elaborates on MM AQ-3, <br />stating: <br />“AQ-3 Prior to discretionary approval by the City of Santa Ana, project applicants for new <br />industrial or warehousing development projects that 1) have the potential to generate 100 or <br />more diesel truck trips per day or have 40 or more trucks with operating diesel- powered <br />transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use (e.g.,