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