Correspondence - #22 - Response to Late Comments

Home Browse Search

Response to Letter CC7: Pete, dated September 17, 2024 This comment letter was received after the public review and comment period ended (July 6, 2023, through August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to respond to letters received outside of the noticed comment period. However, the following responses have been prepared to provide clarity regarding the environmental concerns that have been raised. Comment CC7.1: This comment states that the 13 acres of public open space proposed by the Project would not be useful for those residing outside of the proposed development as there are no opportunities to host organized sports. The comment further states that the Development Agreement should include provisions for weekend organized sports in the community, and that much of the open space will actually be private for the residences within the Project site and would be unavailable to other residences in the area. Response CC7.1: The comment does not raise any specific environmental concern with the analysis within the Draft Supplemental EIR or requirements of the proposed Specific Plan. As discussed on page 5.12-8 of the Draft SEIR, the proposed Project would provide approximately 17.21 acres of total open space, with 13.1 acres being available to the public. While there are designated private open space areas proposed for the Project site, those areas are not included in the 13.1 acres of public open space that would be available to anyone in the community to access. As discussed on page 5.12-5 of the Draft EIR, the 13.1 acres of public open space will include a central park, two plaza spaces, a green link/paseo, and other open spaces such as landscaped parkways and programmable roads that could be used for public recreational areas. While the proposed open space areas may not be able to accommodate organized sport activities such as soccer or baseball, parks and open space come in a variety of forms, and the open space provided by the proposed Project would be consistent with Policy OS-1.5 of the Santa Ana General Plan Open Space Element to "provide a mix of community, neighborhood, and special -use parks, along with greenway corridors, natural areas, and landscape areas, to meet community needs for greenspace, recreation space, social space, and trail connectivity." This comment will be forwarded to City decisionmakers as a part of the Staff Report for the Project. Comment CC7.2: This comment states that implementation of the proposed Project would result in major traffic congestion on the surrounding roadways especially when combined with "The Village" which is adjacent to the proposed Project. The comment recommends additional mitigation in order to alleviate traffic congestion. Response CC7.2: The comment does not raise any specific environmental concern with the analysis within the Draft Supplemental EIR or requirements of the proposed Specific Plan. In regard to increases in traffic congestion, as detailed in Draft SEIR Section 5. 13 Transportation, Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the State CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses" (Public Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the Supplemental EIR focuses on analysis of Vehicle Miles Traveled (VMT) criteria and improvements to the circulation system along the Project's frontage to accommodate buildout of the proposed Project, pursuant to the City's recent General Plan Update. Further yet, the Supplemental EIR is not required to analyze impacts related to traffic congestion. Nevertheless, a Traffic Impact Analysis was prepared for the Project and is publicly available on the City's Project website. This comment will be forwarded to City decisionmakers as a part of the Staff Report for the Project. Comment CC7.3: This comment states that the proposed Public Benefit Agreement is not sufficient to meet the needs of the surrounding community who will be impacted the most by the construction of the proposed Project. The commenter further states that while there may be future economic benefits of the proposed 37