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S� PE Technical Consultation, Data Analysis and <br />Litigation Support for the Environment <br />2656 29`" 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 />November 6, 2020 <br />Paige Fennie <br />Lozeau Drury LLP <br />1939 Harrison Street, Suite 150 <br />Oakland, CA 94612 <br />Subject: Comments on the Central Pointe Mixed -Use Development <br />Dear Ms. Fennie, <br />We have reviewed the October 2020 Staff Report ("Staff Report") for the Central Pointe Mixed -Use <br />Development Project ("Project"), as well as the June 2018 Draft Subsequent Environmental Impact <br />Report ("2018 DSEIR"), for the Metro East Mixed -Use Overlay District Expansion and Elan Development <br />Projects ("Approved Project"), located in the City of Santa Ana ("City"). The Project proposes to <br />construct 644 multi -family residential units, including associated amenities and open space, 15,130-SF of <br />commercial land use space, as well as 1,318 parking spaces on the 8.03-acre Project site. <br />Our review concludes that the Staff Report fails to adequately evaluate the Project's hazards and <br />hazardous materials, air quality, health risk, and greenhouse gas impacts. As a result, emissions and <br />health risk impacts associated with construction and operation of the proposed Project are <br />underestimated and inadequately addressed. A subsequent EIR should be prepared to adequately assess <br />and mitigate the potential hazards and hazardous materials, air quality, health risk, and greenhouse gas <br />impacts that the project may have on the surrounding environment. <br />Hazards and Hazardous Materials <br />No Phase I Environmental Site Assessment (ESA) has been prepared for the Project site, located at 1801 <br />E. Fourth Street. In the October 26, 2020 Staff Report, the City relies upon the 2007 City of Santa Ana <br />Metro East Mixed Use Overlay Zone EIR to evaluate Hazards and Hazardous Materials. The City also <br />relies upon the 2018 Metro East Mixed -Use Overlay District Expansion and Elan Development Projects <br />