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Response to Letter CC4: Louis Steers, dated September 16, 2024
<br />This comment letter was received after the public review and comment period ended (July 6, 2023, through
<br />August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
<br />respond to letters received outside of the noticed comment period. However, the following responses have
<br />been prepared to provide clarity regarding the environmental concerns that have been raised.
<br />Comment CC4.1: This comment states that the commenter opposes the proposed Project due to the increase
<br />in congestion around nearby roadways, the loss of affordable shopping options in the area, and the lack of
<br />open space provided for the large increase in population to the area.
<br />Response CC4.1: The comment does not raise any specific environmental concern with the analysis within the
<br />Draft Supplemental EIR. Draft Supplemental EIR Section 5.1 3, Transportation, details that Senate Bill (SB)
<br />743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic
<br />congestion as the basis for determining significant impacts. As part of the 2019 amendments to the State
<br />CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of
<br />greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land
<br />uses" (Public Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level
<br />of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant
<br />impact on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public
<br />Resources Code Section 21099(b)(2), the Supplemental EIR focuses on analysis of Vehicle Miles Traveled
<br />(VMT) criteria and improvements to the circulation system along the Project's frontage to accommodate
<br />buildout of the proposed Project, pursuant to the City's recent General Plan Update. Further yet, the
<br />Supplemental EIR is not required to analyze impacts related to traffic congestion. Nevertheless, a Traffic
<br />Impact Analysis was prepared for the Project and is publicly available on the City's Project website. This
<br />comment will be forwarded to all decision makers as part of the staff report for the Project.
<br />In regard to the affordability of the stores within the proposed Project site, CEQA is an environmental
<br />protection statute that is concerned with physical changes to the environment (CEQA Guidelines Section
<br />15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of
<br />historic or aesthetic significance (CEQA Guidelines Section 15360). The Project's potential economic and
<br />social effects are not considered effects on the environment (CEQA Guidelines Sections 15064(e) and
<br />15131(a)). Thus, consistent with CEQA, the Draft Supplemental EIR includes an analysis of the Project's
<br />potentially significant physical impacts on the environment and does not include substantial discussion of the
<br />Project's economic or social effects. Because no environmental impacts related to the affordability of the
<br />stores would occur, mitigation measures are not required.
<br />As discussed on page 5.12-8 of the Draft SEIR, while the proposed Project would provide approximately
<br />17.21 acres of public and private open space, inclusive of 13.1 acres of publicly accessible open space and
<br />recreational facilities onsite, per the requirements of the Related Bristol Specific Plan, the proposed Project's
<br />provision of parkland would not meet the City of Santa Ana's GPU performance standard of 3 acres of
<br />parkland for every 1,000 residents, either on the site or cumulatively. As the existing ratio of acreage of
<br />parks and recreational facilities to existing City population results in a parkland deficiency of approximately
<br />154.44 acres, development of the proposed Project would continue to result in a deficiency in parkland
<br />throughout the City of Santa Ana. The Project proposes to provide approximately 1.4 acres of publicly
<br />accessible open space per 1,000 residents, which exceeds the approximately 1.2 acres per 1,000 residents
<br />currently existing within the City.
<br />In order to comply with the GPU policy of 3 acres of parkland per 1,000 residents, the proposed Project
<br />would require 27.7 acres of parkland or the dedication of approximately 67.3 percent of the Project site.
<br />While the proposed Project would provide approximately 17.21 acres of public and private open space
<br />onsite, inclusive of 13.1 acres of publicly accessible open space and facilities, and would comply with
<br />applicable Municipal Code requirements, the proposed Project would not provide 27.7 acres of parkland
<br />and recreation facilities onsite and would not meet the City of Santa Ana's performance standard for
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