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SheppardMullin City of Santa Ana August 19, 2015 Page 2 alternative (as identified in the FEIR but not fully studied) is preferable to the proposed Project because it meets most of the City's stated Project objectives (i.e. alleviating traffic congestion) and cuts the total number of impacted private parcels in half (from 62 to 30). We ask that the City consider the concerns stated herein, and supplement the FEIR to fully study the 100 ROW Project alternative. Second, and even if the City decided not to pursue the 100 ROW alternative, the proposed Project can be re -engineered such that it results in only a partial acquisition of Wells Fargo's Property. For example, we note that the proposed Project will be 106' wide in the segment fronting the Cherry Aerospace Fastening property. However, the proposed Project is currently configured to be 110' wide in the segment fronting the Wells Fargo Property. The re- engineering of the proposed Project segment fronting the Wells Fargo Property from 110' to 106' (or thereabouts) would likely result in only a partial acquisition and allow Wells Fargo to continue on with its business operations on the Property (the branch at the Property is among Wells Fargo's busiest and most profitable in Orange County) and save the City acquisition costs. Accordingly, we ask the City to re-engineer the proposed Project from 110' to a ROW width that results in only a partial take of the Property. Third, and finally, the proposed Project and each of the Project alternatives studied in the FEIR appear aimed solely at avoiding impacts to public facilities to the substantial detriment of private residences and businesses. We ask that the City give consideration to all impacted private property interests by re-engineering the proposed Project in a manner that avoids complete takes where possible. Should you have any question or otherwise wish to discuss the above, please do not hesitate to contact me at your convenience. Very truly ur , � Sean .O'Connor� for SHEPPARD, MULLIN, RICHTER & HAMPTON LLP SMRH:453438812.2