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RUTAN <br />Mayor Miguel Pulido <br />March 3, 2014 <br />Page 2 <br />Maps confirms the Initial Study's conclusions — the Sexlinger Property is within a large swath of <br />land that covers all of Santa Ana, and is designated "Urban and Built Up Land." (Exhibits A -1, <br />A -2; see also Exhibit B [showing survey area boundary]; see generally http: / /www.conservation. <br />ca. gov /dlrp /fmmp/Pages/Index.aspx) <br />Indeed, under published FMMP criteria, the Sexlinger Property simply cannot qualify as <br />Prime Farmland, Important Farmland, or Farmland of Statewide Importance. To fall within any <br />of those categories, the property must have been "used for irrigated agricultural production at <br />some time during the four years prior to the Important Farmland Map date. (Exhibit C.) Since <br />the most recent FMMP map was updated through 2010, and since the land has not been irrigated <br />for agricultural production since before 2000, the Sexlinger Property simply cannot satisfy the <br />criteria for Prime Farmland, Important Farmland, or Farmland of Statewide Importance. <br />Leaving no doubt over the legitimacy of the City's conclusions regarding agricultural <br />lands, the California Environmental Quality Act ( "CEQA ") allows local agencies to also use the <br />Land Evaluation Site Assessment (LESA) model to evaluate whether a project could potentially <br />have an impact on agricultural resources. (Initial Study, p. 24; Pub. Res. Code § 21061.2; CEQA <br />Guidelines Appx. G; http: / /www.consrv.ca .gov /dlrp/Pages /qh— lesa.aspx.) Under that model, a <br />site is given a score (up to a total of 50 points) for both (1) Land Evaluation, and (2) Site <br />Assessment. Both scores must be greater than 20 points to find a potential impact to agricultural <br />resources. (LESA Manual [attached as Exhibit D], p. 28.) The Site Assessment score accounts <br />for (1) project size (30% weighting), (2) water resource availability (30% weighting), (3) <br />surrounding agricultural lands (30% weighting), and (4) surrounding protected resource lands <br />(10% weighting). (LESA Manual, pp. 14 -31.) <br />Here, the Project is 5 acres in size, so it receives a Project Size score of 0. (LESA <br />Manual, p. 14.) The Project site has no existing irrigation system, and is not amenable to dryland <br />production, and so it receives a Water Resource Availability score of 0. (LESA Manual, pp. 18, <br />20.) Since less than 40% of the parcels within 1/4 mile of the Project site are used for agricultural <br />production, it receives a Surrounding Agricultural Lands score of 0. (LESA Manual, p. 25.) <br />Finally, since less than 40% of the parcels within i/4 mile of the Project site are protected <br />resources that are compatible with or supportive of agricultural uses, it receives a Surrounding <br />Protected Resource Lands score of 0. (LESA Manual, p. 28.) Based on these scores, the total <br />LESA Site Assessment score for the Sexlinger Property cannot reach the 20 points required to <br />find a significant impact to agricultural resources. (LESA Manual, pp. 30 -31.) <br />The flaws in TOOC's argument concerning the variance for Lot 12 are two -fold. First, <br />TOOC mistakenly focuses on the shape of the overall Sexlinger parcel in performing its variance <br />analysis. The variance, however, is sought for Lot 12 — not for the overall project. Lot 12 has an <br />abnormal shape and configuration as a result of City staffs correct determination that creating a <br />curved street through the project area would have a beneficial traffic calming effect. That curve, <br />680/030670 -0001 <br />6747449.1 a03103/14 <br />