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451 <br /> <br />~ection 5: "Failure to Process and Prepare Adequate Environmental <br />Documentation" <br /> <br />The following responses als0 address those written objections <br />contained in the .script presented at the hearing by Bryan Conley <br />entitled, "Education First." <br /> <br />(Comment: Mr. Krupp of CSA, Inc. makes comments in reference to a <br />Janua~ 13, 1992 letter from CSA, Inc. to Ms. Cynthia Nelson, <br />Executive Director, Santa Ana Redevelopment Agency. Mr. Krupp <br />also makes comments regarding Ms. Nelson's response in a February <br />10, 1992 letter to CSA, Inc. anda follow-up letter from CSA, Inc. <br />dated February 12, 1992 to Mr. Robert Hoffman, Redevelopment <br />Manager, Santa Ana Redevelopment Agency. Mr. Krupp's comments <br />relate to his opinion that an Environm.enta! Impact Report (EIR) <br />should have been prepared for the project instead of aNegative <br />Declaration. <br /> <br />~p: An EIR w.as prepared for the South Harbor Boulevard <br /> ment Plan In 1982. The EIR was a Program EIR as <br />allowed by Section 15168(a)(3). of the CEQA Guidelines. Section <br />15180(b) of the CEQA Guidelines also states that, "An EIR on a <br />redevelopment plan sh. all be treated as a program EIR with no <br />subsequent EIRs required for individual components of the <br />redevelopment plan unless a subsequent EIR or a supplement to an <br />EIR would be required by Section 15162 or 15163." <br /> <br />An Initial Study was completed .for the proposed Plan Amendment. <br />Through the process of completing.the Initml Study, it was <br />determined that the propose.d public works projects would not have a <br />significant impact on the environment. As a result, the Negative <br />Declaration prepared for the Plan Amendment was the appropriate <br />environmental document for this project because a Program EIR had <br />been prepared for the original Plan in 1982. <br /> <br />Comment: Mr. Krupp makes reference to Sec. tion 33333.3 of. the <br />Health and Safety Code that refers to the Notice of Preparation to the <br />EIR and a copy of the EIR .shall be sent to each affected taxing entity <br />and the fiscal review comrmttee. <br /> <br />Resnonse: The Negative Declaration was submitted to all affected <br />taxihg agencies and the fiscal review committee in compliance with <br />the applicable Health and Safety Codes. <br /> <br />Comment: The Enviro.nmental Checklist Form was notprepared in <br />accordance with subdivision (g) of Section 15063 of the CEQA <br />Guidelines. The City did not consult with the District with regar, d t.o <br />the resources affected by the Plan'.s Amendment to which the District <br />is responsible for and did not obtain the recommen.dation of the <br />District as to whether an EIR or Negative Declaration should be <br />prepared. <br /> <br />21 <br /> <br /> <br />