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0 COX CASTLE <br />N ICHOLSON <br />April 17, 2018 <br />Cox, Castle & Nicholson LLP <br /> <br /> <br /> <br /> <br /> <br />VIA E-MAIL (JARABE@SANTA-ANA.ORG; ECOMMENT@SANTA-ANA.ORG) <br />Honorable Mayor Pulido and Members of the City Council <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />Re: The Madison Mixed -Use Development Traffic Impact Analysis <br />Dear Honorable Mayor Pulido and Members of the City Council: <br />This letter is written on behalf of our client, the owner of the Xerox office building at <br />1851 East First Street (the "Xerox Building") with respect to the application for approval of The <br />Madison. This correspondence follows up on our letter to you of April 2, 2018 articulating <br />various traffic -related concerns, which were first presented to the Planning Commission in <br />November 2017 and which remain unresolved since that time. <br />To provide the City with additional information regarding the nature and extent of our <br />client's concerns, we commissioned LSA to peer review The Madison Mixed -Use Development <br />Revised Traffic Impact Analysis Report (report, Linscott, Law & Greenspan, Engineers, August <br />4, 2017) (the "Traffic Report") from a technical standpoint, particularly as relates to the <br />assessment of driveway and access operations off of Xerox Centre Drive. We respectfully <br />submit a report memorializing LSA's review and findings (the "LSA Peer Review"), which is <br />enclosed with this letter for the City's review. <br />As discussed in greater detail in the LSA Peer Review, LSA identified significant <br />deficiencies in the Traffic Report's queuing and site access analysis. Queues shown in the <br />Traffic Report do not reflect existing observed conditions at the intersection of Cabrillo Park <br />Drive and Xerox Centre Drive, resulting in unaddressed site access impacts, and impacts <br />associated with the size and configuration of the loading zone are similarly unaddressed. Given <br />this evidence of potential significant traffic impacts, the determination that the project is <br />categorically exempt from CEQA is unsupported by substantial evidence, and CEQA review of <br />the project is warranted. The Peer Review's findings and analysis also amply support a "fair <br />argument" that new unexamined impacts, which were never analyzed in the MEMU Overlay <br />District EIR, could arise, potentially requiring additional analysis and circulation of a <br />supplemental EIR to satisfy the requirements of CEQA. <br />www.c0xca9de.conr Los Angeles I Orange County ( San Francisco <br />