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S P CG Technical Consultation, Data Analysis and Litigation Support for the Environment 2656 2911 Street, Suite 201 Santa Monica, CA 90405 Matt Hagemann, P.G, C.Hg. (949) 887-9013 mha�emann@swape,com Paul E. Rosenfeld, PhD (310) 795-2335 prosenfeld@swape.com September 23, 2022 Victoria Yundt Lozeau I Drury LLP 1939 Harrison Street, Suite 150 Oakland, CA 94618 Subject: Comments on the 1700 Garry Avenue Project Dear Ms. Yundt, We have reviewed the August 2022 Planning Commission Staff Report ("Staff Report") for the 1700 E Garry Avenue Project ("Project") located in the City of Santa Ana ("City"). The Project proposes to demolish 105,558-square-feet ("SF") of office space and construct 81,500-SF of warehousing and distribution space, 10,000-SF of office space, and 145 parking spaces on the 5.2-acre site. Our review concludes that the Staff Report fails to adequately evaluate the Project's health risk and greenhouse gas impacts. As a result, emissions and health risk impacts associated with construction and operation of the proposed Project are underestimated and inadequately addressed. An Environmental Impact Report ("EIR") should be prepared to adequately assess and mitigate the potential health risk and greenhouse gas impacts that the Project may have on the environment. Regarding the preparation of a health risk analysis ("HRA"), the General Plan Update Final Recirculated Program Environmental Impact Report ("GPU EIR") incorporates Mitigation Measure ("MM") AQ-3. The Environmental Analysis ("EA"), provided as Exhibit 10 to the Staff Report, elaborates on MM AQ-3, stating: "AQ-3 Prior to discretionary approval by the City of Santa Ana, project applicants for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel- powered transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use (e.g.,