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Jordan R.Sisson 801 South Grand Avenue,111h Floor L j� Los Angeles,California 90017 GK [1, '�l�/ Office:(951)405-8127 Direct:(951)542-2735 LAND USE,ENVIRONMENTAL&MuNicIPAL LAwYERB E-mail:jordan@gideonlaw.net www.gideonlaw.net April 17, 2023 VIA EMAIL; Ali Pezeshkpour,AICP,Planning Manager City of Santa Ana Planning and Building Agency P.O. Box 1988 (M-20) Santa Ana, CA 92702 apezeshkpour@santa-ana.org RE: EIR NOTICE OF PREPARATION COMMENTS ON THE BRISTOL SPECIFIC PLAN Dear Ali Pezeshkpour: On behalf of UNITE HERE Local 11 ("Local 11"),this office respectfully provides the following comments to the City of Santa Ana ("City")' in response to the Notice of Preparation ("NOP")2 involving the proposed Related Bristol Specific Plan ("Specific Plan") for the redevelopment of the 41-acre site located at 3600 South Bristol Street currently occupied predominately with retail and restaurant uses,as well as some medical office,financial, and fitness uses ("Site").Under the Specific Plan,the Site would be redeveloped in three phases and include up to 3,750 residential units, 250 hotel rooms, 200 units of senior continuum care, and 350,000 square feet of retail and restaurant uses ("Project"). For purposes of the Project's review under the California Environmental Quality Act ("CEQA"),the City intends to prepare a Supplemental Environmental Impact Report("SEIR")to the City's General Plan Final Recirculated Program EIR(SCH # 2020029087) ("PEIR") for the City's 2021-2029 General Plan"Housing Element"update. (See NOP,p. 1.) In addition to certification of the SEIR,the Project includes various local approvals,including: (i) adoption of the Specific Plan; (ii) Zoning Map Amendment to change the zoning of the Site; (iii) a Tentative Tract Map to delineate parcel boundaries and public rights-of-way; (iv)John Wayne Airport Land Use Commission review; and (v) a development agreement detailing development rights and public benefits pursuant Government Code Section 65864 et seq. (collectively"Entitlements"). (Id.,at p. 6.) Local 11 provides the following NOP comments with respect to the forthcoming SEIR and Entitlements (collectively"Project Approvals").First, the City should circulate the SEIR and full Final PEIR for a 65-day comment period.Under CEQA,a supplemental EIR must be circulated for public review and comment in the same manner as a draft EIR and can be circulated with the previous draft or final EIRs. (See CEQA Guidelines§ 15163(c) &(d).)Additionally,when approving a project,the decision-making body shall consider the previous EIR as revised by the supplemental EIR. (Id.,subd. (e).) Here, according to documents retrieved from the Office of Public Resources ("OPR"),the original 3-volume, 2,505-page Draft PEIR was circulated for 65 days starting August 3, 1 Herein,page citations are either the stated pagination (i.e.,"p.#") or PDF-page location (i.e.,"PDF p.#") 2 See NOP,https://files.ceganetopr.ca.gov/259509-9/attachment/wEIF21frWV03Jr8jcgHhBLRz 3 3XJ W30 Me6_EuAdGAPxO7pzLQJiQL4o3 Djviw9YOWvcVBLzi92XF-WCnO.