HomeMy WebLinkAbout2 - COMBINED PUBLIC COMMENTS_2525 N MAIN STREETFrom:Fregoso, Vince
Cc:Bernal, Sarah; Thai, Minh; Neal, Candida
Subject:RE: ECOMMENT: Planning Commission meeting for today comments
Date:Monday, January 14, 2019 5:01:07 PM
I will print 10 copies since Sarah is already at the Chambers setting up for the meeting.
Thanks,
Vince C. Fregoso, AICP
City of Santa Ana
Planning and Building Agency
20 Civic Center Plaza, M-20
Santa Ana, CA 92701
T: (714) 667-2713
F: (714) 973-1461
www.santa-ana.org/pba
From: Huizar, Maria
Sent: Monday, January 14, 2019 4:57 PM
To: eComment <eComment@santa-ana.org>
Cc: Bernal, Sarah <SBernal@santa-ana.org>; Thai, Minh <mthai@santa-ana.org>; Neal, Candida
<cneal@santa-ana.org>; Fregoso, Vince <VFregoso@santa-ana.org>
Subject: ECOMMENT: Planning Commission meeting for today comments
Below is communication received from Mr. Rush for the record.
From: timrush@bhhscaprops.com [mailto:timrush@bhhscaprops.com]
Sent: Monday, January 14, 2019 4:53 PM
To: Huizar, Maria <MHuizar@santa-ana.org>
Subject: Planning Commission meeting for today comments
Dear Chairman and Members of the Planning Commission ;
I wish to address two matters before you this evening……….
As I am a member of the Historic Resources Commission…….I want to clarify that my comments here
are made as a private citizen and not as a Commissioner.
RE; 609 N. Spurgeon, proposed 93 Unit for rent development on former Church site.
DISTRIBUTED AT MEETING ON 1/14/19
I am opposed to this development and to the applicants request for numerous variances. This site
and the surrounding area cannot support nor should it that type of density. The very fact that so
many variances are being requested ought to be a red flag as to the negative impact that this
development will have on the immediate neighborhood and the greater Historic French Park
neighborhood. I strongly urge you to vote NO on this applicants various requests. This project
needs more analysis……..but one thing we don’t need in Santa Ana is more low income housing.
RE; 2525 N. Main. I wish to go on record as being opposed to this project. The density levels
requested in this development are simply way out of scale for the area. This developer needs to
take his blue prints to the OC Register site and partner with Mike Harrah. That would be an
appropriate site for his vision. There is so much public opposition to this project………I need not
reiterate all the reasons against it. Please vote in opposition to the “receive and file” and requests
for a declaration of approval in any way of this proposal.
Thank you for your consideration,
Sincerely,
TIMOTHY D. RUSH
1225 South Broadway Street
Yost-Carleton House c.1926
Historic Wilshire Square
Santa Ana, 92707-1207
714-299-4455
From:Bernal, Sarah
Cc:Fregoso, Vince; Neal, Candida
Bcc:Angie Cano; Cynthia Contreras-Leo; David Benavides; Eric Alderete; Kenneth Nguyen; Lynnette Verino; Mark
McLoughlin
Subject:Public Comment: 2525 N Main St. Development_Medina
Date:Friday, January 04, 2019 10:55:56 AM
Commissioners:
The below communication regarding the project proposed at 2525 N. Main Street was received for
your review and consideration.
Thank you.
Sarah Bernal
Phone: 714-667-2732
City of Santa Ana, Planning and Building Agency
20 Civic Center Plaza, Santa Ana, CA 92702
City Hall is closed every other Friday. Click here for dates.
P Please consider the environment before printing this email. Thank you
From: kelly.medina@yahoo.com <kelly.medina@yahoo.com>
Sent: Thursday, January 3, 2019 9:18 PM
To: Kelaher, Selena <skelaher@santa-ana.org>; eComment <eComment@santa-ana.org>
Cc: Dale Helvig <helvig_denny@msn.com>; Henry's For Receiving Pics <netscpr@yahoo.com>;
Suzanne Mcdonald <oldmcdonald@sbcglobal.net>
Subject: 2525 N Main St. Development
To Whom it may concern:
I understand that on Monday, January 14, 2019, the 2525 N Main
St.Residential Development will be on the agenda of the Planning Commission, and that they
could very likely vote (yes or no) on the proposed development during this meeting. I am asking that the
commission vote NO and reject the proposed 480‐unit, high‐density apartment complex.
I have been a resident of Santa Ana for 58 years and seen a lot of changes in that time. I long ago
noticed that where they put up high-rise apartments in residential neighborhoods, the whole
neighborhood goes down in quality. As a case in point, think of the beautiful old homes mixed in with
apartments/condos just west of the 5, and south of 17th St. The character of the whole area just changed
for the worse. It is so congested and cold. The "neighborhoodness" of it disappeared.
I do not want that sort of thing to happen to our neighborhood. As a child, we had always admired the
lovely homes as we drove through this neighborhood on the way to Fashion Square (now Main Place).
Later, my sister moved to Park Santiago, and I vowed that one day, I would live there, too. In 1990, I my
dream was realized when I rented a garage apartment on Valencia. I finally bought a home on French St.
in 1997, and we raised our children here. We had a great opportunity to move to North Tustin in 2012, but
opted to stay because we love our neighbors, and there is such a great sense of community here. The
place is truly unique. People who visit us always marvel at what a beautiful, friendly neighborhood it is--
it's a tribute to Santa Ana!
I think that if you must change the zoning of the property at 2525 N Main, it ought to be to allow single
family homes there. If not that, then fewer, low-rise condominiums would work, too. What the developer
wants to build there will allow for just WAY TOO MANY people for that location. It does not fit the
character of the neighborhood, and would degrade the present quality of it.
The traffic on Main is already congested. In order to drive the 1.4 miles North toward St. Joseph Hospital
from there, you must encounter about 8 traffic lights. Adding all those cars to go into that tiny little
segment of land, right there, where the freeway offramp is, and where the only western egress from the
neighborhood is, will just make it nightmarish. Plus, imagine how that will be exacerbated when the
ALREADY APPROVED Main Place re-do is complete, not to mention the multiple-family housing that is
already going in by Town and Country/Main/Lawson. (they may be in Orange, but will definitely affect
traffic on Main Street and Memory Lane). No amount of money to improve the park or make traffic buffers
in the neighborhood is going to make up for the negative impact it will create in the general area, and to
our neighborhood in particular.
In addition, it seems to me that if the long-term city plans include making a mass transit corridor out of
Main Street (which I would like to see), then putting this development where they propose it to be would
prevent any future street widening to allow room for rails to be placed. Please do not allow the prospect of
immediate influx of monies from this developer persuade you to make the decision that will permanently
negatively change options for this bottlenecked part of the city.
Thank you for your consideration of this matter. Please act to block the presently proposed plan for 2525
N Main St.
Thank you!
Sincerely,
Kelly Medina
2329 N French St.
Santa Ana, CA 92706
714-558-8118
To the Planning Commission:
This is being written by a licensed Architect and Construction Manager for over 35 years. As a
person who has built over $800 Million of projects, I can tell you that this
proposed development at 2525 N. Main Street is a BAD idea for many reasons.
1. This property is adjacent to an historic neighborhood that has been in Santa Ana since the
1920’s. As one of the original neighborhoods of Santa Ana it would be WRONG to destroy this
beautiful neighborhood. This will negatively affect this neighborhood due to:
a. Increased traffic
b. Lack of visitor parking
c. Shadow casting on the adjacent homes by the tall structures
d. Additional load on utilities without plans for sewer, electrical, or water improvements.
2. As a planning concept, this design is a travesty. The lot coverage for this many units does
not allow sufficient open space to be adjacent to one story residential homes. Due to the height
of these condos, they will cast a large shadow on the homes in the adjacent neighborhood.
THIS IS WRONG. I believe that Santa Ana should have a Sun Rights zoning law, whereby a
new development or project cannot cast a shadow onto the surrounding properties. The sun
will go down at two in the backyards of the adjacent homes.
3. There have been several infill housing projects in the area between the Edgewood and Town
and Country Streets. Yet there have been no increases in the sewer system, or other utilities.
The adjacent neighbors will bear the burden of the cost to increase these utilities along Main
Street.
4. The answer to the question about rezoning to allow this mid-rise apartment /condo complex
is NO! Zoning was originally started as a means to control fire risk. Zoning defines like types of
buildings and like uses such as residential, commercial, etc. Since this property adjoins a
residential Type V construction neighborhood, it would be wrong to set this 5+ story
development next to one and two story homes. The set back is not sufficient to create a fire
break and the design does not appear to be Type I construction.
5. There are many more properties that could be improved with development on Main Street,
north of La Veta, and South of the Freeway. Even the Santa Ana Medical Arts center, a greatly
underutilized piece of property, could add to the adjacent neighborhood, with sufficient set-
backs to protect their sun rights.
In summation, in addition to the added traffic, with no planned widening of Main Street, this
development is too high and too dense to be on this property. This is the WRONG PROPERTY
TO REZONE FOR THIS PROJECT.
PLEASE vote NO on this project!
Sincerely,
Carol J.L. Minning2339 No. Poinsettia St.
Santa Ana, CA. 92706
From:Fregoso, Vince
Cc:Bernal, Sarah; Thai, Minh; Neal, Candida
Subject:RE: ECOMMENT: Planning Commission meeting for today comments
Date:Monday, January 14, 2019 5:01:07 PM
I will print 10 copies since Sarah is already at the Chambers setting up for the meeting.
Thanks,
Vince C. Fregoso, AICP
City of Santa Ana
Planning and Building Agency
20 Civic Center Plaza, M-20
Santa Ana, CA 92701
T: (714) 667-2713
F: (714) 973-1461
www.santa-ana.org/pba
From: Huizar, Maria
Sent: Monday, January 14, 2019 4:57 PM
To: eComment <eComment@santa-ana.org>
Cc: Bernal, Sarah <SBernal@santa-ana.org>; Thai, Minh <mthai@santa-ana.org>; Neal, Candida
<cneal@santa-ana.org>; Fregoso, Vince <VFregoso@santa-ana.org>
Subject: ECOMMENT: Planning Commission meeting for today comments
Below is communication received from Mr. Rush for the record.
From: timrush@bhhscaprops.com [mailto:timrush@bhhscaprops.com]
Sent: Monday, January 14, 2019 4:53 PM
To: Huizar, Maria <MHuizar@santa-ana.org>
Subject: Planning Commission meeting for today comments
Dear Chairman and Members of the Planning Commission ;
I wish to address two matters before you this evening……….
As I am a member of the Historic Resources Commission…….I want to clarify that my comments here
are made as a private citizen and not as a Commissioner.
RE; 609 N. Spurgeon, proposed 93 Unit for rent development on former Church site.
DISTRIBUTED AT MEETING ON 1/14/19
I am opposed to this development and to the applicants request for numerous variances. This site
and the surrounding area cannot support nor should it that type of density. The very fact that so
many variances are being requested ought to be a red flag as to the negative impact that this
development will have on the immediate neighborhood and the greater Historic French Park
neighborhood. I strongly urge you to vote NO on this applicants various requests. This project
needs more analysis……..but one thing we don’t need in Santa Ana is more low income housing.
RE; 2525 N. Main. I wish to go on record as being opposed to this project. The density levels
requested in this development are simply way out of scale for the area. This developer needs to
take his blue prints to the OC Register site and partner with Mike Harrah. That would be an
appropriate site for his vision. There is so much public opposition to this project………I need not
reiterate all the reasons against it. Please vote in opposition to the “receive and file” and requests
for a declaration of approval in any way of this proposal.
Thank you for your consideration,
Sincerely,
TIMOTHY D. RUSH
1225 South Broadway Street
Yost-Carleton House c.1926
Historic Wilshire Square
Santa Ana, 92707-1207
714-299-4455
From:Kelaher, Selena
To:Bernal, Sarah
Subject:FW: 2525 N Main comments
Date:Thursday, January 10, 2019 4:45:34 PM
Selena Kelaher, AICP
City of Santa Ana
Planning and Building Agency | M20
20 Civic Center Plaza | Post Office Box 1988 | Santa Ana, CA 92702
skelaher@santa-ana.org | Direct Phone: (714) 667-2740
From: Roger Allen [mailto:polopapa@hotmail.com]
Sent: Thursday, January 10, 2019 3:52 PM
To: Kelaher, Selena <skelaher@santa-ana.org>
Subject: 2525 N Main comments
Selena Kelaher, Associate Planner
City of Santa Ana, Planning and Building Agency
PO Box 1988
Santa Ana, CA 92702
This letter is regarding the final environmental impact report and the planning commission
meeting for the proposed development at 2525 N Main Street in Santa Ana.
My previous letter regarding the draft environmental impact report was included in the final
report but a couple of my comments were either misunderstood or directly dismissed. Here
are comments regarding the response in the environmental impact report (EIR).
My original comments note the historical aesthetics of the area it also notes the concern of
large multi-story buildings being surrounded by single and two story houses. The response in
the final EIR totally dismisses the historical part of my comment because the existing building
is on the site is ‘Modern’. There is no allowance or comment about the existing building as a
low rise brick building. With the setback and landscape of the current parking lot, the building
and grounds have less impact on the aesthetics of the neighborhood than a multi-story,
concrete and glass building with less setback.
My original letter noted several concerns regarding the safety and population density of the
project. My comment included reference to the historic Santiago Creek flooding and the retail
changes that are occurring just north of the project site at the main place mall. The response
directly dismisses these comments or ignores them as not relevant. My original comment
even noted the city code for the population density calculation. Interesting that the reference
is now a broken link and cannot be accessed.
The parking concerns noted in the original letter used my experience with stacked parking
(tandem parking) in another location. My experience is that many of the parking places in a
tandem configuration are not used or are inaccessible. This comment was dismissed because
my direct experience in another location does not apply to this project?
Another comment regarding the additional traffic was also dismissed. Seeing the other
documentation regarding how this project will not change the traffic are incredible and very
inventive. I am not sure how traffic in any location would not be impacted by ‘an additional
2812 trips’ per day as noted in the project documentation.
The final EIR has been submitted and I see how this project is going. I see the proposal for the
meeting on Monday. I am opposed to the development as proposed for the location at 2525
N Main. The size and content of the proposed project will impact the neighborhood and is
wrong for this location.
Roger Allen
Property Owner on Bush Street
Santa Ana, CA
From:Mitre-Ramirez, Norma
To:Bernal, Sarah; Magalona, Jocelyn
Cc:Huizar, Maria; Fregoso, Vince; Orozco, Norma; Rojano, Michael
Subject:FW: Planning Commission
Date:Tuesday, January 08, 2019 6:52:19 AM
Good Morning,
The following communication pertaining to an item on Planning Commission, has been
received for your review and consideration.
Kind Regards,
Norma Mitre
Assistant Clerk of the Council
City of Santa Ana | Clerk of the Council Office
20 Civic Center Plaza | Santa Ana, CA 92701
714-647-5237| nmitre@santa-ana.org
This email and any files or attachments transmitted with it may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe that you may have received this communication in
error, please advise the sender via reply email and immediately delete the email you received.
From: Bill Bonnett <billbonnett@gmail.com>
Sent: Monday, January 7, 2019 10:34 PM
To: eComment <eComment@santa-ana.org>
Subject: Planning Commission
To Planning Commission:
A Huge problem with the 2525 Main St. residential developments, environmental
impact report and its traffic study is that it Does Not take into consideration the Main
Place Mall Transformation Projects now being actively planned by the mall’s new
owner.
Main Place is only 1/2 mile from the proposed 2525 Main Street 480 Apartments.
The Main Place Mall has had the option to be significantly redeveloped for many
years with many approvals already in place.
Despite these many large increased density approvals already being in place, the
Environmental Impact Report did Not have to consider them in its studies.
Why not ?
There is No good reason Not to include these large new developments at Main Place
Mall, in the Traffic Impact studies, for the proposed 480 Apartments at 2525 Main.
A filing date “loophole” regarding when the Main Place Mall Transformation plans
were officially filed with the City, is Not an acceptable reason.
Shameful !
The new owner of the Main Place Mall is now proposing the following new
developments in the shopping mall parking lot areas.
1,900 new residential units ( Apartments)
400 Hotel Rooms
1,400,000 square feet of commercial space
750,000 square feet of office space ( office buildings)
Main Street is going to become completely overwhelmed with traffic.
The Planning Commission needs to insist that the Main Place Mall projects be
included in the EIR for 2525 Main St.
Signed,
Bill Bonnett
15 year resident homeowner of Santa Ana
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
January 10, 2019
Chairman McLoughlin and Planning Commissioners
City of Santa Ana
Santa Ana CA 92702
Subject: January 14, 2019 Planning Commission Meeting
It is extremely hard to condense over 4000 pages supplied by the applicant and city into a concise
document. I did my best.
Attachment 1 Letter to Planning Commissioners dated January 10, 2019
Attachment 1 Marked up copy of the Staff Report for the 2525 Main Residential Development
Attachment 3 Letter to Minh Thai, Executive Director, Planning dated
Subject: 2525 N. Main Residential Development Sunshine Meeting Rebuttal
Attachment 4 Letter to Mayor Pulido and Santa Ana City Councilmembers dated June 5, 2018
Subject: Specific Developments Next to Residential Zoning (R1)
Thank you for your time.
Respectfully,
Dale A Helvig
Chairman, North Santa Ana Preservation Association (NSAPA)
Attachment 1
Page 1 of 17
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
January 10, 2019
Chairman McLoughlin and Planning Commissioners
City of Santa Ana
Santa Ana CA 92702
Subject: Comments on the Staff Report for the 2525 Main Residential Development
The residents of Santa Ana are deeply concerned over the applicant’s desire to seek the approval of
several discretionary applications for developing their property. While we aren’t opposed to
development, we are opposed to the applicant asking for discretionary approvals that would allow
them to create something that is supported by few, other than people receiving funds from the
applicant and a few citizens of the community. We would like to see the Main Street gateway to
Santa Ana pop. One idea is to have Discovery Science Center pedestrian walkway span Main St. like
the one connecting the Performing Arts Center to So. Coast Plaza.
Changing the General Plan is serious. The Mayor of Laguna Niguel, Elaine Gennawey, put it well when
presented with a similar situation: “When you’re entering Laguna Niguel, you know you’re in Laguna
Niguel, and that’s by design,” Gennawey said. “Changing the general plan should only be done when
the change is to the greater benefit of the public. Increasing 35 homes to 60 is almost double the
number of homes, I can’t approve the change of the general plan because it’s not for the greater
benefit of the city or its residents.” We’re not Laguna Niguel, nor are we Los Angeles. We are Santa
Ana and proud of it. We don’t want McMansion’s and we don’t want high density or high intensity
developments encroaching upon single‐family homes like in Los Angeles.
The video presentation the applicant showed the Planning Commission at the November 26th
meeting said they are a locally family owned business. They are not. They live in Los Angeles with
one of the “owners” living in a McMansion in an otherwise nice neighborhood.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 2 of 17
THREE MAJOR ISSUES
1. DENSITY. Over the course of the past year the residents have repeatedly stated this project is
unacceptable. We have seen the project decrease from 87.1 dwelling units per acre (DUA) to 85.1
DUA, to 83.6 DUA and now the staff recommendation is 80.9 DUA. Not much of a change.
The80.9 DUA still is more than double ANY project other Specific Development that is next to R1
zoning in Santa Ana that is in existence or scheduled to be built. Table 5, Project Density
Compared to Approved Apartment Projects in the Staff Report to the Planning Commission leads
you to believe the 81 DUA is the new normal. What Table 5 does not allude to is all these
properties share a common boundary with commercial or industrial property. I have attached my
own Table of Specific Developments in Santa Ana Adjacent to Residential Developments (R1).
The densest property in this table is the Solare Apartment Homes, a 3‐story, 38.9 DUA apartment
complex located on 17th and English next to the Santa Ana River.
2. COMPATIBILITY WITH THE SURROUNDING AREA: We have not been opposed to the other
3666 units that have been added or will be added within 0.5 miles. We are opposed to, as the
applicant has told us, a project on our doorstep. The applicant wants to add a 6‐story
mega‐apartment complex next to homes that are of historic significance to the community
(General Plan Housing Element [page 56]). This is wrong. The applicant then wants to provide
funding to help the neighborhood obtain historic status. In addition, the building has an
ultra‐modern contemporary design with an exposed entertainment deck on the roof of the 5th
floor. Their architecture firm has stated this is what it must be due to the size. Santa Ana can and
should do much better than this.
3. QUALITY OF LIFE: This project, at this location, will impact the quality of life of the residents of
Santa Ana. It adds a very dense site to an already very congested area in Santa Ana. When
looking at the a.m. and p.m. peak traffic times and the 15 evaluated freeway access points
(30 data points) 22 of those data points currently receive a failing grade. Think of what it will be
like after the completion of all the other projects that are currently approved. The EIR lists many
General Plan Goals which are not environmentally related. However, when challenged or asked
to include others, the comments are dismissed. The fact remains this project will compromise the
quality of life of the residents of Santa Ana.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 3 of 17
EIR AREAS OF CONCERN
1. I think the single most important comment I can make on the EIR is what is printed in the
Executive Summary of the EIR (page1‐1):
“An EIR is a public document designed to provide the governmental agency decision‐
makers and the public with an analysis of potential environmental consequences”.
An EIR is not the sole tool that should be used in evaluating a project. Community input,
long‐term economic and social impacts should also be evaluated.
2. OMISSION OF THE MAIN PLACE TRANSFORMATION PROJECT. The EIR omitted looking at the
Main Place Transformation Project. The EIR response is:
“An environmental impact report’s evaluation of cumulative impacts may be based on a
list of past, present, and probable future projects producing related impacts (CEQA
Guidelines Section 15130(b)(1)(A)). “Probable future projects” include those for which an
actual development application has been filed and for which actual environmental review
is underway (San Franciscans for Reasonable Growth v. City & County of San Francisco
(1984) 151 Cal.App.3d 61, 74).
Based on the above, the Draft EIR includes a list of past, present, and probable future
cumulative projects for which applications were submitted to lead agencies prior to
publishing of the NOP on February 12, 2018.” This list forms the basis for the Draft EIR’s
cumulative impacts analyses. Future projects for which applications were submitted to the
City after the NOP was released, such as the Main Place Mall Transformation Project, are
therefore not included in baseline conditions or the list of cumulative projects provided as
Draft EIR Table 4‐1.”
I contend that since the Main Place EIR was completed in the 1990’s it is a known probable
future project. When you have two projects at least one of them needs to address the other in
its cumulative list. Main Place should have been included in the EIR for the 2525 development.
The fact that the new owner of Main Place submitted a new plan in May 2018 is irrelevant.
The Main Place EIR did not evaluate the 2525 N. Main Residential Development, therefore the
2525 N. Main Residential Development EIR should have evaluated Main Place to ensure
cumulative effects were addressed.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 4 of 17
EIR AREAS OF CONCERN (continued)
3. ERRORS IN THE REVIEW OF THE EIR. The Planning Department has admitted an error was made
in the evaluation of a comment made by a resident. They now realize the location of the
emergency access drive approach as proposed will potentially impact 3 out of 11 of the existing
100-foot palm trees within the public right‐of‐way on Edgewood. Most of the remaining
100-foot palm trees are in jeopardy as well. It is unacceptable that this issue was ignored. The
street needs to be widened but the EIR does not address this fact. There are other errors in the
EIR that they have overlooked as well.
4. IMPACTS RELATED TO AESTHETICS. It will remain significant and unavoidable after mitigation.
I have yet to see what mitigating steps have been taken to reduce the effects.
5. SETBACKS. East and West setbacks are less than the current professional zoning. Legado at the
Met was provided 30‐foot setbacks and MacArthur is even a wider street.
6. REGIONAL HOUSING NEEDS ALLOCATION (RHNA). According to the staff report the RHNA needs
allocation for the period 2014‐2021 is 405 units and the Total Remaining RHNA is 167. Using the
developers numbers this goal will be met without building the 2525 Main Residential
Development. The RHNA report will be completed in March of 2019.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 5 of 17
EIR AREAS OF CONCERN (continued)
7. ECONOMIC ANALYSIS. The revenue numbers in the EIR should be looked closely. The analysis is
for a development of 517 units. We know this isn’t the case. The values presented are nominal
and real value (2017$). The real net income in 2017$ over 25 years is $13.59 million (See Page
314 of the Exhibit File). This is $544K per year (2017$) over 25 years which is substantially less
than the reported $1.226 million per year being advertised by the applicant. The fiscal Impact
analysis in Exhibit 8 is an analysis prepared by The Concord Group (RSG was retained by The
Concord Group). You should look at Exhibit 8 for the full story. The economic analysis in the
staffing report quotes a FISCAL IMPACT ANALYSIS done in Dec. 2017. These number have yet to
be revised to reflect the reduced scope of the project.
8. ACCESS TO THE PROJECT SITE. This is still undetermined. One of the staff recommendations is
to remove access on Edgewood Road to reduce the potential for cut‐through traffic into the Park
Santiago neighborhood (Option C). However, the applicant is proposing to provide a secondary
access/egress point at the Santiago Park Drive/Walkie Way and Main Street intersection
(Option B). They state it’s not a required element of the project, but would allow for an
additional point of access to the development. However, approval would be required from the
Parks and Recreation Department, the State Office of Grants and Local Services and the National
Park Service. To my knowledge this communication channel has not even been exercised.
Approving the project with this unknown sets it up for failure as the use of the park for vehicular
access would require the replacement of lost park square footage. The building plan should be
based on the implementation of Exhibit "F” no matter what approval is granted.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 6 of 17
EIR AREAS OF CONCERN (continued)
9. PARK SANTIAGO. Park Santiago is not a registered historic district, but it is a historic resource
and should be treated as such. Under CEQA Guidelines § 15064.5(a), the term “historical
resources” includes the following:
“(4) The fact that a resource is not listed in, or determined to be eligible for listing in the
California Register of Historical Resources, not included in a local register of historical
resources (pursuant to section 5020.1(k) of the Public Resources Code), or identified in an
historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources
Code) does not preclude a lead agency from determining that the resource may be an
historical resource as defined in Public Resources Code sections 5020.1(j) or 5024.1.”
The EIR response to this comment is:
“This policy [Urban Design Element Policy 2.4] is not relevant to the proposed project. As
described in Section 4.4, Cultural/Historic Resources, Park Santiago is not identified by the
General Plan or other City designation as a historic district.”
The General Plan Housing Element [page 56] has a section titled Historic Neighborhood
Preservation. It states "Santa Ana has residential, commercial, and industrial areas that have
cultural or historic significance to the community. Residential neighborhoods include but are
not limited to [highlighted for emphasis], French Park, Floral Park, Wilshire Square, Eastside,
Washington Square, and Heninger Park residential neighborhoods. The City is also known for its
historic Mexican barrios, including the Logan, Lacy, Delhi, and Santa Anita neighborhoods, which
date to the late 1880s. Several of these are recognized as historical districts, while others are
not. In addition to preservation strategies for individual structures, the City could explore
strategies to identify and preserve neighborhoods or elements thereof that are locally
considered worthy of preservation efforts, but not necessarily individually eligible for a formal
state or national historic designation.”
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 7 of 17
EIR AREAS OF CONCERN (continued)
10. BUS SERVICE. There is a bus route along Main Street, but the bus stop is located 0.3 miles to the
north for the northbound route, southbound is conveniently located. However, these buses do
not support the needs of a major transit stop in accordance with CEQA requirements. The buses
do not stop every 15 minutes during peak hours.
§ 21064.3. MAJOR TRANSIT STOP “Major transit stop” means a site containing an
existing rail transit station, a ferry terminal served by either a bus or rail transit service,
or the intersection of two or more major bus routes with a frequency of service interval
of 15 minutes or less during the morning and afternoon peak commute periods.
The EIR response to this is: They even go to the point of
Response 37: [page 850 of 1024] The comment is incorrect. The 2016 RTP/SCS defines a
bus, as a transit mode comprised of rubbertired passenger vehicles operating on fixed‐
routes and schedules over roadways; and that Bus Rapid Transit is service that seeks to
reduce travel time through measures such as traffic signal priority, automatic vehicle
location, dedicated bus lanes, limited‐stop service and faster fare collection policies. As
described by the SCAG 2016 RTP/SCS Executive Summary, planning for additional housing
and jobs near transit includes provision of housing along bus transit corridors; and
expansion of transit includes new local and regional bus services. The RTP/SCS describes
that High Quality Transit Areas are defined as locations within one‐half mile of a fixed
guideway transit stop or a bus transit corridor where buses pick up passengers at a
frequency of every 15 minutes or less during peak commuting hours. There are currently
two express bus service stops (for Route 53) within 0.5‐mile of the project site….”
The EIR response provides an even more lame response
”…Additionally, the graphic provided in this response was taken from the
SCAG website related to transit planning activities to provide information
related to “what SCAG has in mind when they say public transportation”.
The fact is this route does NOT connect to both north and south “Major transit stops” and it does
NOT run every 15 minutes during the morning and afternoon peak commute periods.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 8 of 17
OTHER AREAS OF CONCERN
1. DISCOVERY SCIENCE CENTER. The Discovery Science Center serves about 525,000 visitors a year
and hopes to grow annual attendance to 1 million. We should be doing so much more to support
the Discovery Science Foundation. The future is in the children’s hands and the Discovery Science
Foundation does a tremendous amount of good in this area. The City of Santa Ana needs to assist
them in any way they can.
2. PARKING. Specific Development zoning means the city can bypass certain municipal codes to
accommodate development, it does not mean that it must. The Santa Ana Municipal Code
(SAMC) requires 1420 parking spots, the applicant wants 904 spaces and the staff
recommendation is for 2.0 spaces/unit or 952. Tandem parking was NOT in the original proposal,
it now has 150 stalls as they continue to squeeze the development. The applicant says 904 is
more than enough. I’m sure they said the same thing when seeking entitlements for Prisma. City
Place needed to post signs in their parking lot to inform the resident of Prisma of the following:
“NO PARKING BY PRISMA RESIDENTS OR GUESTS AT ANY TIME.” These signs were put up prior to
Prisma having a 50% occupancy rate. This is what we can expect if we don’t follow the SAMC.
3. PARKING STRUCTURE. The 9‐level parking structure will extend 2‐levels above the residential
building.
4. SUNSHINE MEETING SIGN‐IN SHEETS. Staff report indicate 263 people attended. Not everyone
was able to sign in since the doors were opened late and only 2 tables were used to get everyone
signed‐in. Over 450 people attended. Rebuttal is attached.
5. OPEN SPACE. Is the project taking open space credit for Juliet style balconies, I can’t tell.
6. CONDOMINIUMS. Applicant indicates desire to convert project to condominiums and I
understand this would have to be approved by the City. However, the damage will be done if we
allow this project with no further ability to control parking and occupancy. With this is mind it is
even more important to understand the effects of an uncontrolled population of people and
parking requirements. We need to know the maximum occupancy now.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 9 of 17
OTHER AREAS OF CONCERN (continued)
7. MASS TRANSIT. The project is touting proximity to mass transit (nearest northbound pickup is
0.4 miles). The project is touting proximity to the freeway. What transportation mode of do you
think will be used by the residents that need to earn $80‐$152K per year to afford this units?
It won’t be the bus. Traffic will be a nightmare! Parking will be a nightmare!
8. ENVISION MAP. Still can’t believe this is even being mentioned. The Envision Map is not an
approved City document. A parcel of land that is located across the street from 2525, and is less
than 8000 square feet, is also listed as a site for “Highrise (unlimited density)”. The applicant
assumed a risk when he based his purchase on a draft document. The map clearly stated:
“NOTE: "The map represents a conceptual effort [bolded for emphasis] and its contents are in
a draft format and do not represent any formal efforts to rezone or redesignate properties
shown. [bolded for emphasis] "
This map is no longer available, but it did provide a fair warning to anyone wishing to use the map.
9. ARCHITECTURAL STYLE. It is said in the reports that architectural styles of single‐family homes
often do not translate well to multi‐storied buildings. Orange Architects said this is true unless
the scale of the project is reduced.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 10 of 17
RESOLUTION NO. 2019‐xx – EXHIBIT 2
1. While we disagree with building this project, I would like to address the Development
Agreement. It is incomplete and has received NO INPUT from residents opposing the project.
I find the Developers Agreement Section 1 and Section 2 to be in direct conflict with Santa Ana
General Plan.
2. WHEREAS, the Development Agreement came before the Planning Commission for a duly
noticed public hearing on January 14, 2019. At that hearing, the Planning Commission
recommended that the City Council approve said Development Agreement; and
I recommend this not be approved for the following reasons:
2.1. WHEREAS, the Planning Commission has determined that by entering into the Development
Agreement: (i) the City will promote orderly growth and quality development on the Property
in accordance with the goals and policies set forth in the General Plan; and, (ii) significant
benefits will be created for City residents and the public generally from increased
employment, housing, parks and/or park improvements; and
The General Plan would need to be revised and some sections of the General Plan would be
placed in jeopardy. I’ll speculate and say the applicant will say the EIR address this.
However, this is not an environmental issue, it’s the Santa Ana General Plan.
General Plan Land Use Element [page 12]:
Goal 3 Preserve and improve the character and integrity of existing neighborhoods.
Policy 3.1 Support development which provides a positive contribution to neighborhood
character and identity.
Policy 3.2 Foster communication between the City, residents, and neighborhood
associations.
Policy 3.3 Coordinate City programs and activities in neighborhoods.
Policy 3.4 Continue proactive code enforcement programs and activities.
Policy 3.5 Encourage new development and/or additions to existing development that are
compatible in scale, and consistent with the architectural style and character of
the neighborhood.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 11 of 17
RESOLUTION NO. 2019‐xx – EXHIBIT 2 (continued)
Goal 4 Protect and enhance development sites and districts which are unique community
assets that enhance the quality of life.
Goal 5 Ensure that the impacts of development are mitigated.
Policy 5.1 Promote development which has a net community benefit, and enhances the
quality of life.
Policy 5.2 Protect the community from incompatible land uses.
Policy 5.3 Minimize the impact of future right‐of‐way expansion on existing development
and neighborhoods through the use of transportation system management
programs and traffic demand management to relieve traffic congestion.
Policy 5.4 Support land uses which are consistent with the Land Use Plan of the Land Use
Element.
Policy 5.5 Encourage development which is compatible with, and supportive of surrounding
land uses.
Policy 5.7 Anticipate that the intensity of new development will not exceed available
infrastructure capacity.
Policy 5.10 Support a circulation system which is responsive to the needs of pedestrians and
vehicular travel.
2.2. Goal 6. Reduce residential overcrowding to promote public health and safety.” The staff
report says this project supports This is not true.
2.2.1. A market rate project is not going to reduce overcrowding in Santa Ana. It will
increase the population in the surrounding area by 27% with the addition of over 1000
people to the area. To put it simply:
DENSITY =
POPULATION
LAND SPACE
2.2.2. Density will increase with this project and overcrowding will not decrease.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 12 of 17
RESOLUTION NO. 2019‐xx – EXHIBIT 2 (continued)
2.3. General Plan Land Use Element [page 60]:
"These areas [PAO] are typically adjacent to low density residential neighborhoods, or are
converted residential office uses.” The current land use designation is correct.
2.4. General Plan Land Use Element: [page A‐22]
“The Museum District located between the Downtown and Main Place/City Place District
Centers is proposed as a major office/cultural center which will be developed over the next 15
to 20 years. The area will focus upon the expanded Bowers Museum, the Discovery Science
Center and the construction of additional museums and cultural centers.”
2.5. [Page 4 of 9] “the Orange County Transportation Agency bus routes which connect to the
Anaheim Regional Transportation Authority which provides rail service throughout California
and is immediately adjacent to Santiago Park and Santiago Creek Bike Trail which connects to
regional bike trails.”
This is a half‐truth. There is a bus route along Main Street, but the bus stop is located 0.3
miles to the north for the northbound route, southbound is conveniently located. However,
these buses do not support the needs a major transit stop in accordance with CEQA
requirements. The buses do not every 15 minutes during peak hours.
§ 21064.3. MAJOR TRANSIT STOP “Major transit stop” means a site containing an
existing rail transit station, a ferry terminal served by either a bus or rail transit service,
or the intersection of two or more major bus routes with a frequency of service interval
of 15 minutes or less during the morning and afternoon peak commute periods.
The fact is neither of the northbound or southbound routes connect to both the north and
south “Major transit stops” and, neither the northbound or southbound routes run every
15 minutes during the morning and afternoon peak commute periods as required by
§ 21064.3. MAJOR TRANSIT STOP.
2.6. GATEWAY. Staff report states: In addition, the of the General Plan identifies the site as a
Gateway. I respectfully disagree. The northern gateway is Main Place/City Place.
[Urban Design Element page 15 and A‐16]
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 13 of 17
DEVELOPMENT AGREEMENT NO. 2018‐01
1. The City Attorney should review this document PRIOR to it being presented to the Planning
Commission. It is poorly written and does not protect the City or the residents that will be
impacted.
2. WHEREAS. “WHEREAS” should be added to state the Project Site is located within the
boundaries of the Park Santiago neighborhood.
3. WHEREAS. I disagree with most of these RECITALS. I don’t believe it is in the best the best
interests of the citizens of the City of Santa Ana.
3.1. to realize significant economic, recreational, park, open space, educational, social and
public facilities benefits
3.2. will enable the CITY to fund much needed capital improvements and provide much needed
public services and will therefore also have a major, beneficial economic impact on the City;
and
3.3. Agreement and the Project are consistent with the Santa Ana General Plan and any specific
plan applicable thereto; and
3.4. development of the Property in accordance with this Agreement will provide substantial
benefits to CITY and will further important policies and goals of CITY;
3.5. the best interests of the citizens of the City of Santa Ana and the public health, safety and
welfare will be served by entering into this Agreement; and
4. GENERAL PROVISIONS.
4.1. [2.4] Term of Agreement is listed as four years. It should be 55 years.
4.2. [2.7] Termination. This Agreement shall be deemed terminated and of no further effect
upon the occurrence of any of the following events:
(a) Expiration of the stated Term of this Agreement as set forth in Section 2.4
(which is the term of four (4) years).
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 14 of 17
DEVELOPMENT AGREEMENT NO. 2018‐01 (continued)
1. PUBLIC BENEFITS
1.1. PUBLIC ART. Dollar value of art should be provided versus relying on accounting to
determine value. It should also be identified that this Public Art should be installed at a
prime location visible to the public.
1.2. SANTIAGO PARK MAINTENANCE & IMPROVEMENT CONTRIBUTION. What’s with the
constant need to address the entry monument? Aren’t the monuments consistent with
other monuments within the City? Is the One Hundred Thousand Dollars ($100,000) for the
maintenance of the neighborhood entry monuments in addition to the $1.4M?
1.3. PARK SANTIAGO NEIGHBORHOOD BENEFITS PACKAGE. OWNER has met with residents of
Park Santiago and has agreed to provide the following.
The owner met with members of the PSNA and made a presentation. However, NO
negotiations occurred at this or any subsequent meeting.
(c) Park Santiago Neighborhood Benefits. OWNER has met with residents of Park
Santiago and has agreed to provide the following amenities:
(1) Limited access to onsite amenities in a manner to be determined by OWNER as
reasonably acceptable to Planning and Building Agency Executive Director.
This is a meaningless statement. Reasonably acceptable is undefined.
(2) Amazon locker location
(3) Security patrol in the residential neighborhood and Santiago Park
a. Patrol area: Project, Park Santiago and Park Santiago area as depicted on
attached Exhibit "H"
b. Type of patrol: Periodic roving security twenty‐four (24) hours a day.
c. Term: 55 years subject to annual review during which review it may be
determined that such term shall end earlier.
(Hard to enforce if DA is only in effect for four years (see GENERAL
PROVISIONS page 5). It also does not address who is part of the review
process and who has the authority to terminate the agreement.
(4) Neighborhood entry monuments will be installed by OWNER. (Again….why?)
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 15 of 17
DEVELOPMENT AGREEMENT NO. 2018‐01 (continued)
(d) Park Santiago Historic District. City shall survey residents to determine community
support for the designation of the Santiago Park Neighborhood Association as a
historical district on the City's Historical Register. If, in the City's reasonable opinion,
the community is generally supportive of pursuing the historic register designation,
Owner shall pay all costs and expenses associated with processing the application,
including reimbursing the City for costs incurred conducting the survey and any
environmental review, up to a not to exceed amount of one hundred fifty thousand
dollars ($150,000). (It’s interesting the applicant would support a historic district
designation when they say the area isn’t historic)
(e) Park Santiago Public Improvements and Traffic Calming. Subject to the approval by
the Executive Director of Public Works Agency and the Executive Director of
Planning and Building Agency and meeting City design specifications and standards,
OWNER shall design and construct the public improvements identified below prior
to formal approval for occupancy or the issuance of a Certificate of Occupancy.
Owner shall be solely responsible for all aspects of the public improvements
including, but not limited to, the analysis, design, engineering, construction and
inspection/ administration of:
(1) Santiago Park neighborhood improvements at up to three locations on
Edgewood and/or Bush Street to achieve traffic calming. Improvements may be
based on input from the Santiago Park Neighborhood Association and may
include, but not be limited to, bulb‐outs, traffic circles and medians within the
neighborhood streets.
(2) Santiago Park Neighborhood entry monuments at Main Street/Edgewood Road,
Santa Clara Avenue/Lincoln Avenue, and Santiago Street/17th Street based on
input from the Santiago Park Neighborhood Association.
(3) Street lighting enhancements by replacing all existing non‐LED light and/or
fixture with LED light and/or fixture throughout the Santiago Park
Neighborhood. (I believe this has already been completed by the City)
(4) A street light at the Santiago Park Drive / Main Street intersection.
(5) Decorative concrete pavement within the intersection of Main Street/Walkie
Way and Main Street/Santiago Park Drive.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 16 of 17
1.4. Public Improvement Maintenance Agreement. [4.4.2]
This is mentioned 21 times, but a Maintenance Agreement does not exist.
1.5. Santiago Park. [4.6] In consideration for the use of certain roadways to access the Project,
as more particularly described/depicted on Exhibit F.
This should be decided prior to approval.
1.6. Overcrowding Mitigation Implementation Plan. [4.8] The City of Santa Ana has one of the
highest average number of people per household in the nation at 4.34 people per
household. Owner commits to limit occupancy of the residential units within the project
site to levels in compliance with local, state and federal fair housing standards.
Hard to enforce once the project is converted to condominiums. This is a major reason this
project should not go in.
1.7. Procedure. [6.3] If OWNER fails to take the necessary actions, the Commission may
recommend to the City Council modification or termination of this Agreement.
They violate the agreement, so we terminate it. How absurd is that!
1.8. Emergency Evacuation Plan. An Emergency Evacuation Plan should be submitted and
approved prior to granting approval. It an Emergency Evacuation Plan cannot be approved
not only for residents of the project, but for surrounding area as well, the project should not
be approved.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Page 17 of 17
OTHER AREAS
1. GENERAL PLAN LAND USE ELEMENT. Table A‐1 Development Intensity Standards. FAR of 2.28!
2. GENERAL PLAN LAND USE ELEMENT. Exhibit A‐5. Exhibit revised to show property as a Major
Development Area.
3. Appendix A: Parking Memo. This analysis fails to identify the occupancy of the respective
building when performing this analysis. Without knowing that, this analysis is meaningless.
Respectfully,
Dale A Helvig
Chairman, North Santa Ana Preservation Association (NSAPA)
cc: Raul Godinez II
Santa Ana City Manager
Minh Thai
Executive Director, Planning
Candida Neal,
Planning Manager
Vince Fregoso,
Principle Planner
Selena Kelaher
Associate Planner
Alberta Christy
Chair, Historic Resources Commission
Phil Schaefer,
Vice Chair, Historic Resources Commission
Tim Rush
Historic Resources Commissioner
Michael O’Valle,
President, Park Santiago Neighborhood Association (PSNA)
Attachment 2
JANUARY 14, 2019
TITLE:
PUBLIC HEARING ‐ FINAL ENVIRONMENTAL
IMPACT REPORT NO. 2018‐01, DEVELOPMENT
AGREEMENT NO. 2018‐01, GENERAL PLAN
AMENDMENT NO. 2018‐06 AND AMENDMENT
APPLICATION NO. 2018‐10 FOR THE PROPOSED
MULTI‐FAMILY DEVELOPMENT LOCATED AT
2525 NORTH MAIN STREET
{STRATEGIC PLAN NO. 3, 2}
Vince Fregoso, AICP
APPROVED
As Recommended
As Amended
Set Public Hearing For
DENIED
Applicant's Request
Staff Recommendation
CONTINUED TO
Prepared by Selena Kelaher, AICP
RECOMMENDED ACTION
Recommend that the City Council:
1. Adopt a resolution certifying Final Environmental Impact Report No. 2018‐01 (SCH No.
2018021031), adopt environmental findings of fact pursuant to the California Environmental
Quality Act, adopt a Statement of Overriding Considerations, adopt Mitigation Monitoring
and Repotting Program and approve the proposed project.
2. Adopt an ordinance approving the Development Agreement No, 2018‐01.
3. Adopt a resolution approving General Plan Amendment No. 2018‐06.
4. Adopt an ordinance approving Amendment Application No. 2018‐10 for Specific
Development No. 93.
Executive Summary
Jeremy Ogulnick, representing AC 2525 Main, LLC, submitted an application for several
entitlements to facilitate the development of a 517‐unit multi‐family housing project (87 du/ac)
on a 5.93‐acre site at 2525 North Main Street. Based on early staff and public feedback the
applicant elected to reduce the request to 496 units (84 du/ac). Specifically, the applicant is
requesting the certification of the Final environmental impact report (EIR) for the project, along
with the mitigation monitoring and reporting program and statement of overriding considerations.
2525 North Main Street
January 14, 2019
Page 2
Other entitlements requested include a development agreement between the City and
applicant/owner, a general plan amendment to redesignate the property from Professional &
Administrative Office (PAO) to District Center (DC), and an amendment application to rezone the
property from Professional (P) to Specific Development No. 93 (SD‐93).
Staff is recommending the conditional approval of the project subject to project modifications
such as:
• Reduce the density to 81 dwelling units per acre, a maximum of 476 units
• Revise the unit mix; reduce the number of studio and one‐bedroom units to 70
percent of the project and increase the number of two and three‐bedrooms to 30
percent of the project
• Provide parking at a capacity of 2.0 spaces per unit
• Provide courtyards along the north elevation
Project Location and Site Description
The subject site is a 5.93‐acre parcel located at the northeast comer of Main Street and Edgewood
Road. Regional access to the site is provided from the Santa Ana (I‐5) Freeway via Main Street, a
6‐lane arterial roadway, and via the State Route 22 (SR‐22) Freeway. The properties immediately
adjacent to the site include Santiago Park to the north, single‐family residential homes to the
south and east and the Discovery Science Center of Orange County is across Main Street to the
west. The project site is located on North Main Street, an urban corridor within the City. The site
is also located at a main entry point to the Park Santiago Neighborhood, a residential
neighborhood predominantly comprised of detached single‐family dwellings.
The site is currently improved with an 81,172 square foot, two‐story office building with 442
parking spaces and associated mature trees and landscaping. The building has been vacant since
summer 2017 and was last occupied by Wells Fargo. The Discovery Science Center of Orange
County leases the parking lot for employee and overflow parking.
Table 1: Project Location Information
Item Information
Project Address 2525 North Main Street
Nearest Intersection Main Street and Edgewood Road
General Plan
Designation
Existing: Professional &
Administrative Office PAO
Proposed: District Center (DC)
Zoning Designation Existing: Professional (P) Proposed: Specific Development No. 93
SD‐93
Surrounding Land Uses North Santiago Park — Open Space
East Single‐Family Residential — R1
Commented [DH1]: Exactly. A residential
neighborhood predominantly comprised of
detached single‐family dwellings.
2525 North Main Street
January 14, 2019
Page 3
Item Information
South Single‐Family Residential — R1
West Discovery Science Center — SD‐65
Property Size 5.93 acres (258,310 square feet)
Existing Site
Development
The site contains a two‐story, 81,172 square foot office building with 442 parking
spaces
Applicable Zoning Code
Sections
Existing: SAMC Chapter 41, Article Ill,
Division 8 (Professional)
Proposed: SAMC Chapter 41, Article III,
Division 26 (Specific Development)
Entitlements SAMC Chapter 41, Article V, Division II
(Amendments and Change to District Boundaries)
Background and Chronology
City records indicate that the site was occupied by a variety of uses, including a mortuary, gas
station, medical center and single‐family residences in the 1970s. At that time, the site had two
zoning designations of General Commercial along Main Street and Single‐Family Residence to the
east. In 1980, General Plan Amendment No. 1980‐20, Amendment Application No. 832 and
Conditional Use Permit No. 1980‐07 were approved, amending the general plan designation to
Professional and Administrative Office and changing the zoning to the Limited
Professional/Specific Development District (LP/SD) to allow for the construction of the existing
two‐story office building with 269 parking spaces on 4.66 acres of the subject site. A 1.27‐acre
parcel located at the corner of Main Street and Edgewood Road remained as General Commercial.
In 1996, General Plan Amendment No. 1996‐04 and Amendment Application No. 1996‐04 were
approved to amend the General Plan and zoning designations of several properties along Main
Street, between the I‐5 Freeway and Main Place Drive/Memory Lane, including the subject
property. The amendments provided consistency with the mid‐rise offices and were intended to
create a gateway to the Main Place District Center from downtown. The subject property was
amended to the current designations of Professional and Administrative Office and zoning was
amended to Professional. In the early 2000s, the property at the corner of the site (previously a
medical office building) was combined with the subject site to expand the parking lot for the office
building.
Project Description
The applicant is proposing to demolish the existing office building and develop a high density
multi‐family residential development on the site. The original proposal included the development
of 517 residential units wrapped around an 8‐level parking structure. However based on staff and
public feedback, the applicant elected to reduce the request to 496 units. The revised project
would result in approximately 930,705 square feet of development (572,075 square feet of
residential buildings and 358,630 square feet of parking structure and common open space
structures) at a density of 84 dwelling units per acre, with an average unit size of 972 square feet.
The floor area ratio is 2.21 which is derived by calculating the square footage of the gross building
square footage (residential development and common open space, excluding the parking
structure square footage) by size of the property. The unit mix varies from studio units, one‐
Commented [DH2]: It’s a 9‐level parking
structure with 2 levels of the parking
structure extending above the residential
portion of the building. (See page 4)
2525 North Main Street
January 14, 2019
Page 4
bedroom units, two‐bedroom units, and three‐bedroom units, with 38 different floor plans
proposed. The unit breakdown can be found on Table 2 on the following page.
The residential buildings will range from 2‐stories in height (24 feet) at the eastern portion of the
site, and will tier up to 5‐stories with mezzanines (approximately 78 feet) along Main Street. The
tallest element of the building will be approximately 95 feet in height as measured from the
rooftop amenity/recreation deck.
Table 2: Applicant Proposed Unit Mix and Unit Square Footage
Unit Type Number of Units (%)Square Footage of Units
Studios 73 592 ‐ 740
One‐Bedrooms 307 62% 634 ‐ 1,091
Two‐Bedrooms 88 18% 909 ‐ 1,472
Three‐Bedrooms 28 5%1,360 ‐ 1,520
Total 496 units 100%
The main entry for the project would be via a driveway on Main Street. The driveway will lead to
an internal drop‐off area, the leasing office and guest parking spaces before leading into the gated
parking structure. The parking structure is located closer to Main Street, further away from the
single‐family homes to the east, with the residential buildings wrapped around the structure to
screen from views at the ground level. Two levels of the parking structure would extend above
the residential portion of the building.
The applicant is proposing to provide a secondary access/egress point at the Santiago Park
Drive/Walkie Way and Main Street intersection. This option is not a required element of the
project, but would allow for an additional point of access to the development. If constructed, use
of the park for vehicular access would require the replacement of lost park square footage with
new park land of equal or greater size, utility and value. In addition, approval would be required
from the Parks and Recreation Department, the State Office of Grants and Local Services and the
National Park Service.
The parking structure totals 358,630 square feet, with 8‐levels above grade and 1‐level below
grade. A total of 904 parking spaces are proposed which is a ratio of 1.8 spaces per unit. A total
of 150 tandem spaces (17 percent of the overall parking spaces) will be provided. The applicant
has provided a parking study of similar type multi‐family projects that identifies a parking demand
of 1.354 space per unit which would forecasts parking needs to be 672 spaces for the project.
Table 3 below provides a breakdown of the proposed parking for the project.
Commented [DH3]: How is it possible to
approve a project when access points are
unknown? If this option were to be pursued
the design of the project would need to be
changes to accommodate the land swap,
unless they plan to have that layout
approved upfront.
Commented [DH4]: The parking study that
was performed fails to mention the
occupancy rate at the time of study. This
omission makes the study invalid for the
purpose of any comparison.
2525 North Main Street
January 14, 2019
Page 5
Table 3: Applicant Proposed Parking
Unit Type Units Rate Stalls Provided
Studios 73 1.00 73
One‐Bedroom 307 1.00 307
Two‐Bedrooms 88 2.00 176
Three‐Bedrooms 28 3.00 84
Guest Parking 496 .23 114
Tandem Stalls 150
Total 496 1.80 904 spaces
The project has incorporated a contemporary architectural design. Elements such as stone
veneer, multiple brick veneers, metal panels, ceramic tile, metal canopies, flat and metal seamed
roofs all assist in conveying a modern design. The color scheme encompasses earth tones of tans,
browns and greys. Courtyards are provided along Main Street, Edgewood Road and the internal
east elevation to break up the massing and create distinct building sections. In addition, units
along Edgewood Road will front the street, providing direct street access and assisting in
activating the street.
A combination of common and private open spaces will be incorporated into the project design.
Approximately, 34,630 square feet of common open space will be dispersed throughout the
project. These areas will consist of ground level courtyards with amenities such as a pool and spa,
seating areas, tables and chairs, shade trellis, fire pits, and enhanced landscaping. A rooftop
amenity deck will also be provided that will include a pool and spa, cabanas, fire pits, lounge
chairs, shade structures, a club room, and a fitness center. Other common area amenities such as
a wellness room, chef's kitchen, dog wash room, bike repair room, bike share, Amazon parcel
lockers, and entertainment room, will be incorporated into the building and will provide residents
with opportunities for on‐site services and entertainment space. In addition, private open space
in the form of patios or balconies will be provided for each unit. These spaces will range from 53
to 77 square feet in size.
An upscale and elaborate landscape pallet is proposed for this project. The applicant is proposing
to retain the mature Ficus trees along the east property line. An arborist report was prepared,
with mitigation measures included to ensure the trees remain in a healthy condition pre‐ and
post‐construction. The report also identified 8 trees (7 Sweet Gum trees and 1 Cypress tree) along
the eastern property line that are in an unhealthy condition and are recommended for removal.
Additional trees similar in size and type to the mature trees will be planted to fill in areas where
trees were removed or are missing. In addition, the applicant will raise the height of the wall
adjacent to the single‐family dwellings from six to eight feet in height.
Given the number of parcels affiliated with this proposal, the lots will need to be combined into
a single development parcel. Prior to issuance of building permits, a voluntary lot merger will
need to be applied for and be approved. This application is ministerial, with no Planning
Commission or City Council action required.
Commented [DH5]: As explained to me by
Orange Architects, Contemporary style is
needed due to the size of the project.
Commented [DH6]: If this means front
doors will be on Edgewood then this is the
first we’ve heard of this. We have been told
the only access would be the Amazon
lockers.
Commented [DH7]: How is this going to be
accomplished for each unit? It is hard to
imagine how this will look based on the
drawing provided. It looks like units on the
outside of structures will have private open
space facing the streets and interior units will
have private open space facing each other,
not so private.
Commented [DH8]: Appendix B Tree
Evaluation and Preservation Study, Executive
Summary states “The largest trees on site,
the #117 Aleppo pine, Pinus halepensis; and
#121 cypress, an unknown Cupressus species,
may date back to a previous site use, but are
probably no more than 70 or 80 years old.
The Aleppo Pine has a life expectancy of over
150 years
(https://selectree.calpoly.edu/tree‐
detail/pinus‐halepensis). We had an
independent arborist look at the tree and his
evaluation is the tree is healthy, properly
trimmed and expected to live another 100
years. It should NOT be removed.
2525 North Main Street
January 14, 2019
Page 6
This project is required to comply with the City’s Housing Oppo rtunity Ordinance (HOO). To satisfy
the provisions of the HOO, applicant is proposing to pay an in‐lieu fee in excess of $6,000,000.
See Table 4 below for a breakdown of the proposed HOO fee.
Table 4: Housing Opportunity Fee Summary
Habitable Square Footage Inclusionary Housing Fee Estimated Fee
404,746 $15 per square foot $6,071,190
*As measured from the exterior walls of the residential units. This calculation does not include exterior
hallways, common areas, landscape, open space or exterior stairways*
Analysis of the Issues
Environmental Impact Report
The applicant submitted a development proposal that requires the approval of several
discretionary applications. Given the size and location of the project, as well as the proposed
zoning and general plan modifications, extensive environmental review was needed. After
completion of the Initial Study for the project, it was determined that the California
Environmental Quality Act (CEQA) required the preparation and certification of an environmental
impact report (EIR) for this project. The purpose of an EIR is to identify the significant effects on
the environment of a project, to identify alternatives to the project, and to indicate the manner
in which those significant effects can be mitigated or avoided. To determine what potential
effects would be caused by the project, the EIR analyzed issues related to Aesthetics; Air Quality;
Biological Resources; Cultural/Historic Resources; Greenhouse Gas Emissions; Hazards and
Hazardous Materials; Land Use and Planning; Noise; Population and Housing; Public Services;
Transportation and Circulation; Tribal Cultural Resources; Utilities and Service Systems; and
Energy.
On February 12, 2018, the Initial Study and Notice of Preparation were released to solicit
comments regarding the scope and content of the Draft EIR (DEIR). A scoping meeting was held
on March 1, 2018 with approximately 164 people in attendance and a total of 163 written
comment letters were received at the conclusion of the 30‐day public comment period.
The comments were reviewed and additional areas of analysis and studies were added to the
scope of the Draft EIR as appropriate. The comments are included as Appendix A of the Draft EIR.
The Draft EIR analyzed the direct and indirect impacts resulting from construction and operation
of the proposed project. In addition to analyzing fourteen environmental topic areas, the EIR also
evaluated three options for access and egress to the project. The analysis included Main Street
access only as proposed (Option A), access from Main Street plus a secondary access/egress
driveway at the Main Street and Walkie Way/Santiago Park intersection (Option B), and
access/egress from both Main Street and Edgewood Road (Option C).
Three project alternatives were also analyzed within the document. These included a no build
alternative, where the existing approximately 80,000 square foot building would remain as is and
be reoccupied by an office use (Alternative 1); a reduced multi‐family project consisting of a
Commented [DH9]: FYI…
At $210,000 to $240,000 to build a low
income housing unit this equates to 25 to 29
units.
Commented [DH10]: This should be a red
flag to everyone!
Commented [DH11]: I do not see the
additional areas of analysis that were added.
This should be identified.
2525 North Main Street
January 14, 2019
Page 7
30 percent reduction in density (Alternative 2); and build out of the site under the existing
Professional zoning district development standards, which could result in an approximately
390,000 square foot two and three‐story office building (Alternative 3).
The Draft EIR determined that the proposed project would require mitigation related to
aesthetics, air quality, biological resources, hazardous materials, construction noise and vibration,
interior noise, and tribal resources. Impacts related to aesthetics would remain significant and
unavoidable after mitigation.
On August 7, 2018, the Draft EIR was circulated for review and comment to public, City Council,
Planning Commission, local, regional and state agencies, and interested parties for a 45‐day public
comment review period. In addition, a Planning Commission public hearing was held on August
27, 2018 where staff presented the EIR process and environmental information to the Planning
Commission and pubic and received public comments on the DEIR. To allow for additional time
for public review and comment, and at the request of the North Santa Ana Preservation Alliance,
the City extended the DEIR public comment period by an additional two weeks. At the close of
the review and comment period on October 4, 2018, a total of 44 comment letters were received
on the Draft EIR.
The City has evaluated the comments received from persons and agencies on the Draft EIR and
completed detailed Response to Comments, revisions to the Draft EIR including clarifications
and/or corrections to typographical errors, and a Mitigation Monitoring and Reporting Program
(MMRP). The response to comments, MMRP and Final EIR were published on November 15, 2018
for public review. The Draft EIR, responses to comments document, revisions to the Draft EIR, and
the MMRP constitute the Final EIR for the project (Exhibit 1).
The EIR identified one significant and unavoidable impact associated with this project, which
pertains to aesthetics. Based on the City's visual criteria related to scale, height and setbacks, it
was determined that the project would result in a substantial change in views from existing
conditions and would result in a significant and unavoidable impact to the aesthetics. As a result
of this impact that cannot be mitigated to a less than significant level, adoption of a Statement of
Overriding Considerations is required prior to approving the project. A Statement of Overriding
Considerations is the process through which decision makers balance the economic, legal, social,
and technological or other benefits of the proposed project against its unavoidable
environmental impacts.
Commented [DH12]: The 390,000 square
foot building that is referenced is a
theoretical building size and not one that can
actually be built in Santa Ana.
The building would be two‐thirds that size
(roughly 257,000 square feet).
Commented [DH13]: I’m having a real hard
time finding what mitigation is taking place.
Even so, this remains a significant and
unavoidable impact to Park Santiago.
Commented [DH14]: Some of the detailed
comments are incorrect. A list will be
provided to the City staff.
Commented [DH15]: and would result in a
significant and unavoidable impact to the
aesthetics.
Mitigation measures for aesthetics are not
even addressed.
2525 North Main Street
January 14, 2019
Page 8
Development Agreement
The development agreement (DA) is a legal contract between the developer and the City
that defines the terms and nature of development proposed for the project site. This
agreement establishes development intensity, permitted uses and standards for the term
of the agreement. In exchange for the City vesting approval of the proposed project, the
development agreement requires certain improvements and public benefits as part of the
project (Exhibit 2). For example, the DA will memorialize requirements for public art,
monetary contribution to fund physical improvements to Santiago Park, Park Santiago
residents benefits such as access to on site amenities, security patrol of the residential
neighborhood and Santiago Park, assistance in designating the Park Santiago
Neighborhood Association as a historic district, and monetary contribution to Park
Santiago Neighborhood Improvements and Traffic Calming for improvements such as
street calming, traffic diversion, entry monuments, and street light upgrades. If approved,
the agreement will include both deal points and project conditions for the project.
Highlights of the DA include:
1. Term of Agreement. The right to build the project as entitled for a period of four
years, with an opportunity for up to two, consecutive one‐year extensions.
Extensions shall be subject to approval by both the Owner and the City Manager.
Prior to granting an extension, the Owner shall pay $50,000 to the City’s General
Fund to compensate the City for lost revenue to be received by the City had the
project been completed within the first four years.
2. Public Art. The Owner shall create, install, and maintain a public art project with a
value equivalent to 0.5% of the total construction cost of the project. The work(s)
of art shall be in place prior to issuance of the first certificate of occupancy for the
project and shall be maintained in perpetuity by the property owner.
3. Santiago Park Improvement Funds. Provide funding for Santiago Park Maintenance
and Improvements in the amount of $1,400,000 to the City for the construction of
park improvements or the owner shall be authorized by the City to construct the
park improvements at the owners sole cost and expense up to $1,400,000. These
park maintenance funds shall be deposited with the City within 180 days after the
issuance of the first building permit for the purpose of completing park
improvements including, but not limited to, installation of irrigation, landscaping,
security lighting and bike trail enhancements as shown in Exhibit G to the
Development Agreement. An additional $100,000 will be paid to the City prior to
the issuance of the first building permit for the maintenance o f neighborhood entry
monuments.
4. Park Santiago Neighborhood Benefits Package. The Developer shall provide Park
Santiago Neighborhood residents with access to on‐site amenities, Amazon lockers,
24‐hour roving security patrol within the Park Santiago Neighborhood and Santiago
Commented [DH16]: The potential for a 6‐
year construction period is unacceptable. Do
NOT give them an extension. A fee of
$250,000 if not completed on time.
Commented [DH17]: Should include text
“at a prime location visible to the public,”
Who is part of the art selection process? We
would like a resident to participate.
Commented [DH18]: This money should
not be used to support Option B access.
Commented [DH19]: What is so wrong
with the current monuments?!
Commented [DH20]: Hourly? every shift?
Daily?
Not very specific.
2525 North Main Street
January 14, 2019
Page 9
Park as shown on Exhibit H to the Development Agreement for a 55‐year period
unless determined during an annual review that the term shall end earlier.
5. Historic District Application. If desired by the majority of the Park Santiago
Neighborhood property owners, the applicant shall pay all costs and expenses
associated with processing the application for historic district consideration,
including reimbursing the City for costs incurred conducting the survey and any
environmental review, up to and not to exceed the amount of $150,000.
6. Park Santiago Public Improvements. The Owner shall be responsible for the
analysis, design, engineering, construction and inspection/administration of traffic
calming/improvements at up to three locations on Edgewood and/or Bush Street
to achieve traffic calming, entry monuments at three location at Main
Street/Edgewood Road, Santa Clara Avenue/Lincoln Avenue and Santiago Street/
17th Street, replacement of all non LED street lights and/or fixtures with LED street
lights and/or fixtures throughout the Park Santiago Neighborhood, and installation
of a street light and decorative concrete pavement within the intersection at the
Walkie Way/Santiago Park Drive and Main Street intersection.
7. Parking. Per the conditions of approval (Exhibit I to the Development Agreement)
the applicant shall increase number of spaces or capacity to increase the onsite
ratio of parking, including the use of valet parking, to an equivalent of two (2) spaces
per unit.
8. Unit Mix. Per the conditions of approval (Exhibit I to the Development Agreement)
the applicant shall increase the number of family units to a minimum of thirty
percent (30%) of the proposed units to contain 2 & 3 bedrooms.
The agreement also includes provisions for an overcrowding management plan, live work
preference plan, local sourcing plan, construction management and property maintenance plans.
The development agreement has been signed by the applicant indicating agreement to the terms.
The agreement is not considered final until the City Council has reviewed and approved the
agreement and the agreement is executed by all parties.
General Plan Amendment
To allow for the construction of a multi‐family residential development on this parcel, a general
plan amendment is required. Currently, the land use designation for this site is Professional and
Administrative Office (PAO), which applies to areas that are predominately professional offices
and/or administrative offices or areas where such development is encouraged. This project will
require an amendment to the Land Use Element to amend the General Plan Land Use designation
of the site to District Center (DC) with a density of 81 dwelling units per acre (reduced from 87
du/ac based on staff recommended changes) or a floor area ratio of 2.21 (Exhibit 3).
Commented [DH21]: This seems like a
contradiction. Why would they support a
historic district designation when they say
the area isn’t historic?
Commented [DH22]: I believe the city has
already performed the LED upgrade in Park
Santiago.
Commented [DH23]: What is equivalent?
Why not the SAMC limit?
Commented [DH24]: The current land use
designation is in accordance with the General
Plan Land Use Element [page 60]: "These
areas [PAO] are typically adjacent to low
density residential neighborhoods, or are
converted residential office uses.”
2525 North Main Street
January 14, 2019
Page 10
The purpose for maintaining and supporting professional office areas are to increase employment
opportunities for local residents, enhance the diversity of the Citys economic base, to develop
mutually beneficial and supportive business clusters in the City and to support uses that create
little to no nuisances to nearby residents or businesses. Several properties to the north and west
across Main Street are designated as PAO therefore work to create a professional business
district. Areas such as this northern gateway of the City provide a rich employment base for many
residents of the City and those in the region who work in the area.
District Centers are major activity areas of the City. Currently, several areas to the northwest,
northeast, south of the Santa Ana 1‐5 freeway and along Main Street north of Seventeenth Street
are designated as District Centers. District Centers are designed to serve as anchors to the City's
commercial corridors and to accommodate higher density development projects. These areas are
to be developed with an urban character that includes a mixture of high‐rise offices, commercial
and multi‐family residential uses which provide shopping, business, cultural and housing
opportunities within close proximity to each other, close to transportation opportunities and in
prime development focus areas. Residential development within these areas are allowed at a
density of up to 90 acres.
If approved, the project could support several goals and policies of the Housing Element. First,
the project would be consistent with Goal 2, which encourages diversity of quality housing,
affordability levels, and living experiences that accommodate Santa Ana's residents and
workforce of all household types, income levels and age groups to foster an inclusive community.
Second, the project would support Goal 4, to provide adequate rental and ownership housing
opportunities and supportive services. Further, the project would be consistent with Policy HE2.2
to create District Centers with high intensity, mixed‐use urban villages and pedestrian oriented
experiences. Finally, the project would be consistent with Policy HE‐2.4 to facilitate diverse types,
prices and sizes of housing. The project would also be consistent with goals of the Land Use
Element, including Goal 1 to promote a balance of land uses to address basic community needs,
and Goal 6 to reduce residential overcrowding to promote public health and safety. The proposed
project will provide additional market rate housing in the City, thereby assisting in addressing the
shortage of available housing within the region. The project will also provide additional housing
options for those seeking housing within the jobs rich northern area of the City. The upscale multi‐
family development will also support Urban Design Element Goal 1 to improve the physical
appearance of the City through development of a district that projects a sense of place, positive
community image, and quality environment.
The City has recently initiated the process to update its General Plan, which is the blueprint for
future development. A key component of the update is to focus new growth and development
along major corridors reducing the pressure for growth in low density neighborhoods and to
identify areas for future development, including but not limited to higher density residential
development. The northern section of the City, including the project site, has been identified as
a potential area for more intense development. This North Main Street area is in the process of
being studied in greater depth as the update process continues, with direction on the potential
land use designation of the area expected within the next year.
Commented [DH25]: We believe in this:
increasing employment opportunities for
local residents, enhance the diversity of the
City’s economic base, develop mutually
beneficial and supportive business clusters in
the City and to support uses that create little
to no nuisances to nearby residents or
businesses. This is what the PAO zoning is all
about!
Commented [DH26]: 2525 should not be a
District Center!
Commented [DH27]: To avoid being rent
poor (more than 30 percent of income is used
on rent)
An occupant would need to earn a minimum
of $80K to rent a studio and $152K to rent
the smallest 3‐bedroom to avoid being rent
poor.
Commented [DH28]: Adding a complex at
over 80 dwelling units per acre does NOT
decrease overcrowding.
It will increase the Park Santiago
neighborhood population anywhere from 21
percent to 27 percent.
2525 North Main Street
January 14, 2019
Page 11
Amendment Application
Currently, the zoning designation for this site is Professional (P) which permits a variety of
business uses that aim to create a professional business environment and prohibits residential
uses. To allow the construction of a multi‐family residential development on this parcel, an
amendment application (zone change) is required. Staff is recommending that a zone change to
a Specific Development No. 93 (SD‐93) designation be conditionally approved subject to staff
recommended changes to the project. The SD designation will allow a residential development
and will ensure consistency between zoning and the General Plan, assuming the associated
general plan amendment is approved (Exhibit 4).
When considering a zone change it is important to look at the surrounding land uses and
economic factors. The jobs to housing balance is evaluated by comparing project‐generated jobs
and housing units to forecasts of employment and housing, in addition an imbalance in the ratio
can indicate air quality and traffic problems associated with commuting. Based on SCAG profiles
and projections, Santa Ana is a jobs rich area with 2.06 jobs per housing unit. SCAG considers an
area as balanced when the jobs‐housing ratio is 1.36, therefore providing more housing would
reduce the ratio to 2.05. Furthermore, in the second quarter of 2018, the City's office occupancy
rate was 13.4 percent, which is higher than the neighboring central cities of Anaheim (10.4%),
Orange (11.5%) and Tustin (10.9%) and the County as a whole (12.6%). Therefore, the change
from Professional to Specific Development would not be a significant impact to professional office
districts.
In addition, use of the site for residential development is supported as the location has elements
to make the site a viable residential development. The elements include having regional access
to freeway and transportation systems, the site is within close proximity to educational, cultural
activities, employment centers, and retail and commercial shopping opportunities. Furthermore,
several nearby properties and properties along Main Street are designated as Specific
Developments. The property would be developed at a higher density than the nearby
single‐family residential uses. However, multi‐family uses are often used in planning and zoning
practice to buffer higher intensity uses like commercial or industrial uses from single‐family
residential uses and multi‐family and single‐family uses are more compatible in nature to each
other.
The Specific Development No. 93 (SD‐93) is established for the purpose of protecting and
promoting the public health, safety and general welfare of the City and its residents. This new
zoning designation for the site is crafted to be consistent with the proposed project. If the zone
change is approved, a series of site‐specific objectives, policies and development standards will
be used to guide the development of the project. Specifically, the SD‐93 document includes a
menu of development standards which specify setbacks, parking, height and landscape
requirements and includes provisions for construction and maintenance to allow the exclusive
entitlement of the residential project. The SD‐93 document has been framed to include staff
recommended changes to the project and prohibits future modifications to enlarge the size of
the project. Approval of the proposal would allow for the construction of a high density residential
Commented [DH29]: The current land use
designation is in accordance with the General
Plan Land Use Element [page 60]: "These
areas [PAO] are typically adjacent to low
density residential neighborhoods, or are
converted residential office uses.”
Commented [DH30]: The City’s office
occupancy rate is could be due to the fact
congestion is high due to the density and
subsequent traffic it creates. The EIR has
failing graded ot the surrounding freeway
access points around this project.
Commented [DH31]: From the General
Plan Land Use Element:
The Museum District located between the
Downtown and Main Place/City Place District
Centers is proposed as a major office/cultural
center which will be developed over the next
15 to 20 years. The area will focus upon the
expanded Bowers Museum, the Discovery
Science Center and the construction of
additional museums and cultural centers.
Commented [DH32]: You’ve got to be
kidding me!
Commented [DH33]: Setbacks at Legado
are 30 feet from the street.
2525 North Main Street
January 14, 2019
Page 12
development in an urbanized setting that is within close proximity to neighborhood services and
amenities.
If approved, the zone change would need to be approved in conjunction with the proposed
general plan amendment. This would result in a project that is consistent with the goals and
objectives of City's General Plan land use designation of District Center. The project will promote
an urban development where office, retail and residential activities would coexist in close
proximity and in a mixed‐use setting. Further, the project will contribute towards the
improvement of the character of the northern section of the City. Finally, the development,
through the construction of the proposed public improvements and site amenities, will contribute
to the enhancement of the area and serve as a buffer between commercial and high intensity
uses and the lower density residential area.
Public Comments
A significant number of public comments have been received on this project, mainly voicing
concerns or opposition to the project. Over the last year emails (approximately 400 emails are on
file), letters and phone calls were received and small group meetings and study sessions have
been conducted. A list of the major comments received are summarized in the sections below.
Community Meetings
On November 15, 2017, 27 calendar days after the application was submitted, the developer held
a Sunshine Meeting at the Discovery Cube of Orange County and overviewed plans for a 517‐unit
development, 5‐stories in height, with 910 parking spaces and access from Edgewood Road.
Signin sheets indicate 263 people attended. Minutes of the meeting including community
comments made at the meeting and the applicant's responses were prepared by the applicant
(Exhibit 5).
In early 2018 (January 30, 2018 and February 15, 2018), planning staff coordinated meetings with
the developer and the North Santa Ana Preservation Alliance representatives. Approximately 20
people attended the small group meetings, including the developer, members of the North Santa
Preservation Alliance, nearby neighborhood representatives and planning staff. The applicant
shared a revised plan that included 505 units, a revised unit mix, the removal of the parking
structure access from Edgewood Road, and modifications to the architectural style.
A Planning Commission study session was conducted on August 27, 2018 where staff presented
information on the project description, the draft environmental impact report, entitlements,
vicinity, building heights, access options, unit mix, parking, and areas of consideration. The
applicant also provided a presentation that overviewed the project, amenities, community
benefits, concerns and support, traffic, changes made by the applicant to the project, and project
benefits. Thirty‐two (32) verbal comments were received (three in support and 29 in opposition)
and nine written comments were received (one in support and eight in opposition).
On September 5, 2018, the developer, members of North Santa Ana Preservation Alliance,
and City planning staff met to discuss the proposed project. A list of questions, comments and
Commented [DH34]: NSAPA does not
recommend this zone change and General
Plan Amendment change.
Commented [DH35]: This is not nor should
it be a District Center for the purpose of
raising the density of Park Santiago by
27 percent.
Commented [DH36]: The applicant
counters with his presentation of a few
people that support the project. The 400
emails should out‐way the few the applicant
presents.
Commented [DH37]: Not everyone signed
in since the doors were opened late and only
2 tables were used to get everyone signed‐in.
Over 450 people attended.
Commented [DH38]: I have provided my
response to Exhibit 5.
Commented [DH39]: The January 30, 2018
was a total bust. The applicant
representative committed to a
comprehensive update to the plan and they
failed. At the February 15th meeting the
applicant said they fired the representative.
We didn’t believe them and as you know, Ms.
Sapetto is still employed by the applicant and
is under investigation .
Commented [DH40]: This meeting was
scheduled 20 days into a 45 day review
period for the DEIR. The review period was
even extended due to the comments that
needed to be made. It is no wonder only
32 people expressed verbal comments.
2525 North Main Street
January 14, 2019
Page 13
concerns were raised by the neighborhood. In follow up on September 24, 2018, information
requested at the previous meeting was provided by staff to members of the North Santa Ana
Presentation Alliance.
Most recently, on November 26, 2018 the public hearing for the project was continued to January
14, 2019 and a second study session was conducted where staff presented information on the
project, the Draft EIR, comments received, the Final EIR and dr aft development agreement terms.
The applicant also played a video overviewing the project. During public comments 58 verbal
comments were received (25 in support; 31 in opposition and two neutral) and 11 written
comments were received (two in support and nine in opposition). One comment letter on the
DEIR from Lozeau Drury LLP was received and written response to the comments was drafted
(Exhibit 6).
Density
The revised project has reduced the density from 87 dwelling units per acre to 84 dwelling units
per acre or a floor area ratio of 2.21. Per the General Plan, the maximum floor area ratio of the
subject property and the properties to the north and west is 1.5 and the maximum dwelling units
per acre of the residential properties to the east and west is 7 dwelling units per acre. As
proposed, the project has higher density and floor area ratio than the surrounding properties.
With the staff recommended changes to the project, the maximum density of the project will be
further reduced to 81 dwelling units per acre which is within the range of densities approved for
other multi‐family projects in the City.
Table 5: Project Density Compared to Approved Apartment Projects
Projects Density Zone Status
The Nineteen01
1901 East First Street 49 du/ac Metro‐East Mixed Use Overlay Constructed
The Line
3630 Westminster Avenue 58 du/ac Harbor Mixed Use Specific Plan Under Construction
The Heritage
2001 East Dyer Road 65 du/ac Specific Development No. 88 Under Construction
The Marke
100 East MacArthur Boulevard 74 du/ac Specific Development No. 76 Constructed
Prisma (301)
301 East Jeanette Lane 91 du/ac Specific Development No. 59 Constructed
The Madison
200 North Cabrilio Park Drive 94 du/ac Metro‐East Mixed Use Overlay Entitled 2018
Elan
1660 East First Street 94 du/ac Metro‐East Mixed Use Overlay Entitled 2018
2525 North Main St. 81 du/ac Specific Development No. 93 Proposed
Commented [DH41]: What is not
mentioned is the continued concern of
density. We were told that
Commented [DH42]: No mention of the
October22, 2018 Planning Commission
meeting where several people voiced the
objection to the move to have a special
Planning Commission meeting on
November 5th.
Commented [DH43]: At 496 units, this is
83.6 du/ac. This is the staff recommendation
number which is still out of the ballpark.
This is the only project that is adjacent to
single family homes.
2525 North Main Street
January 14, 2019
Page 14
Height
The height limits of the Professional zone are a maximum of 35 feet/3‐stories or a maximum of
25 feet/2‐stories within the rear 50 percent of the lot. The office building to the north is 10‐stories
(approximately 160 feet in height), the Discovery Cube to the west is approximately 110 feet in
height, and the single‐family dwellings to the south and east are one‐story (approximately 18 feet
in height). The proposed project would be similar in height to the buildings along Main Street,
however the 5‐story residential buildings would be 3‐stories taller than the maximum allowable
height in the R‐1 zone of (2‐stories, 27 feet). The SD‐93 development standards for the east
portion of the building require the height to tier from five to two stories as shown on the site plan
to create a transition in the building heights to the neighborhood to the east. Table 6: Professional
Zone Comparison
Development Standard Professional Zone Proposed Project
Building Height 35 feet (3‐stories) maximum
25 feet (2‐stories) maximum within
rear 50% of lot (approx. 240 feet
from the east property line)
5‐stories with mezzanines (65 feet)
8‐level parking structure with
rooftop amenities (90 feet)
No building within 40 feet of the
east property line
Maximum 25 feet (2 stories) within
40 to 66 feet of the east property
line
Front Setback
(west property line)
15 feet minimum 12 feet, 6 inches
Street Side Setback
(south property line)
15 feet minimum 15 feet
Interior Side Setback
(north property line)
5 feet minimum 7 feet, 6 inches
Rear Setback
(east property line)
50 feet minimum 40 feet, 7 inches
Commented [DH44]: This office building is
a quarter mile away.
Commented [DH45]: Discovery Cube at
110 feet is not occupied.
Commented [DH46]: It is a 9‐level parking
structure with 2 levels Two levels of the
parking structure would extend above the
residential portion of the building (See page
4)
Commented [DH47]: As compared to the
current setback requirement of a maximum
of 25 feet within 240 feet of the east
property line.
Developer’s presentation is:
5th floor 116 feet
4th floor 91 feet
3rd floor 66 feet
2nd floor 42 feet
1st floor 42 feet.
Commented [DH48]: Setbacks at Legado at
the Met are 30 feet.
Commented [DH49]: Setbacks at Legado at
the Met are 30 feet.
Commented [DH50]: Setbacks should be
15 feet.
Commented [DH51]: The applicant is
reducing the current setback requirements.
They even present it as 42 feet versus the 40
feet, 7 inhes as described here in the staff
report. Not much of a difference but it still
shows the character of the applicant when
they can’t convey the facts.
2525 North Main Street
January 14, 2019
Page 15
Table 7: Project Height Compared to Approved Apartment Projects
Projects Height
The Marke 5 levels
The Nineteen01 5 levels
Prisma 301 5 levels
The Line 5 levels + 6 levels of parking
The Heritage 5 levels
The Madison 7 levels
Elan 7 levels
2525 North Main St. (proposed) 5 levels with mezzanines + 8 levels of parking
Bulk/Scale
Bulk describes the mass of a building and scale refers to the proportional relationship of the size
of the building to other structures. The project is in scale with the commercial buildings along
Main Street and significantly larger in scale than the residential homes to the south and east. The
project has been designed with courtyards to reduce the bulk of the building and will also be
tiered on the east from 2‐stories to 5‐stories.
Shade/Shadow
Section 4.1 of the Draft EIR analyzed shade and shadow impacts. Shade and shadow studies were
prepared for each calendar month. For CEQA purposes, impacts are considered significant if
shadow‐sensitive uses would be shaded by the project‐related structures for more than 3 hours
between the hours of 9:00 a.m. and 3:00 p.m. between fall and spring, or for more than 4 hours
between the hours of 9:00 a.m. and 5:00 p.m. between spring and fall when compared to existing
conditions. The CEQA threshold has been used in the past by Santa Ana for other projects. As
proposed, the project would cast shadows on the residential properties, but not for more than 3
hours between fall and spring or for more than 4 hours between spring and fall.
Neighborhood Character
The Park Santiago neighborhood is characterized by large one‐story and two‐story homes with a
variety of architectural styles (Minimal Traditionalist, Colonial Revival, Craftsman, Spanish, and
Ranch). The project site also has street frontage along North Main Street which is described in
the General Plan as an opportunity for the establishment of a cohesive, height intense, mixed
activity center with a strong presence in the region. The project is not in character with the
neighborhood, which it shares two sides with, as the neighborhood is comprised of single‐family
dwellings and the project is a high density multi‐family housing project. The proposed project
however, has a modern contemporary design with a variety of materials that would fit the design
intent of North Main Street. It is common for high density multi‐family projects to have a different
architectural style than surrounding single‐family dwellings as the architectural styles of
single‐family homes often do not translate well to multi‐storied buildings.
Commented [DH52]: Another way of
saying 5 levels with mezzanine is
entertainment deck on the roof of the 5th
floor.
The parking structure is 9 levels, with 2 levels
Two levels of the parking structure would
extend above the residential portion of the
building (See page 4).
Commented [DH53]: Interesting point
here is the structures have limited shading
effect but the proposed trees that will be
installed will have a major shading effect on
the existing residential homes along the
eastern border of the property.
Commented [DH54]: As it says, the project
is not in character with neighborhood. The
property in question is part of the Park
Santiago Neighborhood Association. It is not
a part of any District Center.
Commented [DH55]: Our point exactly.
This could be one of the reasons the property
is designated PAO.
2525 North Main Street
January 14, 2019
Page 16
Historic Neighborhood
The City of Santa Ana has two National Register Districts, Downtown Santa Ana and French Park.
Park Santiago is not a registered historic district. A total of 32 historic homes have been
documented in Park Santiago of the approximately 1,173 homes in the neighborhood with the
majority of the homes being more than 50 years old. As part of the EIR (Section 4.4), Cogstone
prepared a Historic Resources Report and concluded that the historic homes in Park Santiago will
not have the setting and feeling aspects of integrity reduced by construction of the proposed
project and thus there is no reduction in the historic significance of the homes. Future opportunity
for the neighborhood to become a historic district still remains and is a public benefit deal point
in the Development Agreement.
Project Access
Vehicular access is proposed via a driveway on Main Street which would only allow for right‐in
and right‐out turn movements as Main Street has a median that separates north‐south street
traffic. As proposed, to enter the site when traveling southbound on Main Street residents would
have to make a U‐turn at Edgewood Road, and to exit the development and travel southbound
on Main Street residents would have make a right‐hand turn (northbound on Main Street) and
make a U‐turn at Walkie Way or Main Place Drive. The Traffic Impact Analysis prepared for the
project analyzed the impacts of having Main Street as the sole and primary access point and found
that operations would not exceed a threshold of significance (DEIR Access Option A).
Use of Santiago Park
The applicant is proposing secondary access through Santiago Park which would utilize the
existing traffic signal at Main Street and Walkie Way/Santiago Park Drive. This would allow for all
directional movements to and from the property and reduce the U‐turn movements described
above. This access option, is not a required element for the project, however it was studied as a
secondary access option (DEIR Access Option B) in the Traffic Impact Analysis and found to have
a less than significant impact.
Various portions of the park were developed with Land & Water Conservation grant funding. As
a result, a 6(f)(3) boundary map placed the entire park under federal protection to be preserved
as outdoor recreational use. Any proposed changes to the park, such as the proposed vehicular
access, will require review by the City's Parks & Recreation Department, the Office of Grants and
Local Services and National Park Service and replacement of land with new park land of equal
utility and value. The estimated square footage to improve the park for vehicular access is 10,000
square feet, in turn the applicant is proposing to provide 10,000 square feet of their property to
the City for park purposes. At this time, the City has not been begun conversations with the Office
of Grants and Local Services or the National Park Service, but the City would support use of the
park as long as replacement parkland is provided and monetary funds are contributed to the City
for Santiago Park Maintenance & Improvements.
Commented [DH56]: Park Santiago is a
Historical resource and it should be treated
as such.
Under CEQA Guidelines Section 15064.5(a),
the term “historical resources” includes the
following:
1) A resource listed in, or determined to be
eligible by the State Historical Resources
Commission, for listing in the California
Register of Historical Resources (Public
Resources Code, Section 5024.1).
2) A resource included in a local register of
historical resources, as defined in Section
5020.1(k) of the Public Resources Code or
identified as significant in a historical
resource survey meeting the requirements of
Section 5024.1(g) of the Public Resources
Code, will be presumed to be historically or
culturally significant. Public agencies must
treat any such resource as significant unless
the preponderance of evidence demonstrates
that it is not historically or culturally
significant.
The EIR response to this is:
“This policy [Urban Design Element Policy 2.4
] is not relevant to the proposed project. As
described in Section 4.4, Cultural/Historic
Resources, Park Santiago is not identified by
the General Plan or other City designation as
a historic district.”
... [1]
Commented [DH57]: The only way to
access the property from the north is to
make a U‐turn. This is absurd.
Commented [DH58]: Likewise, the only
way to travel south is to make a U‐turn at
Walkie Way or Main Place Drive.
Commented [DH59]: An example from the
Traffic Analysis in regards ot the access at the
22 Freeway:
“With the addition of project traffic, the
intersection would continue to operate at an
unsatisfactory LOS E in the a.m. peak hour
and LOS F in the p.m. peak hour. Therefore,
and the proposed project would not result in
exceedance of the Caltrans criteria, and no ... [2]
Commented [DH60]: This secondary access
should be fully understood prior to making a
determination as to the feasibility of
implementing it. It could drastically change
the layout of the entire Northern area of the
property.
Commented [DH61]: The applicant should
assume this would happen and plan
accordingly.
2525 North Main Street
January 14, 2019
Page 17
Traffic
A Traffic Impact Analysis was prepared by Translutions, Inc. for the project. The study was peer
reviewed by the Citys Public Works Agency and Kimley‐Horn an on‐call traffic engineering firm
The study evaluated 16 intersections, 10 roadway segments, 6 neighborhood intersections, 10
neighborhood roadway segments and 15 freeway segments (DEIR Section 4.1 1). Impacts were
analyzed for the existing conditions (2018), expected project opening year (2020) and future
conditions (2040). The 2020 conditions include the planned Caltrans improvement project which
will add one continuous High Occupancy Vehicle (HOV) lane in each direction along the
northbound and southbound I‐5 freeway between SR‐55 and SR‐57, which would result in the
removal of the I‐5 HOV northbound entrance and southbound exit ramps at the intersection of
N. Main Street/Edgewood Road I‐5 ramps. Based on the Institute of Traffic Engineers (ITE) trip
generation rates, the project is estimated to generate 2,698 daily trips.
Table 8: Proposed Project Trip Generation
AM Peak Hour
7:00 to 9:00 a.m.
PM Peak Hour
4:00 to 6:00 p.m.
Land Use In Out Total In Out Total Daily
Trip Generation
Rates
0.09 0.27 0.36 0.27 0.17 0.44 5.44
Proposed Project
Trip Generation
(496 units)
46 133 179 133 86 219 2,698
The City of Santa Ana uses a rating criteria known as Level of Service (LOS) to assess the severity
of traffic congestion at intersections and roadway segments. The LOS criteria uses an "A" to "F"
rating scale; an "A" rating meaning traffic conditions have the least amount of traffic congestion
(free flowing traffic) and an "F" rating meaning traffic conditions will have the most traffic
congestion (forced or breakdown of traffic flow). As a standard practice, the City has adopted an
operational LOS rating of D as the minimum acceptable LOS for intersections and roadway
segments, except that for intersections and roadway segments that fall within major
development areas, the City adopted a LOS rating of E as the minimum acceptable LOS. LOS is
obtained by calculating the ratio of vehicles at an intersection or roadway segment versus the
vehicle capacity of that intersection or roadway segment (Vehicles/Capacity).
The City acknowledges that the proposed project would generate additional traffic and that
would result in an increase in vehicle trips on area roadways (2,698 trips). However, the project
and implementation of any of the three access options would not exceed a threshold identified
by the City or Caltrans (Pages 4.11‐12 to 4.11‐23 of the DEIR).
2525 North Main Street
January 14, 2019
Page 18
Parking
The project proposes 904 parking spaces (1.8 parking spaces per unit). A parking study of two
similar multi‐family projects that identified a parking demand of 1.354 space per unit which would
forecasts parking needs to be 672 spaces for the project less than the applicant's proposed 904
(Exhibit 7). For comparison purposes a table has been prepared to compare the City's multifamily
parking standards (SAMC Section 41‐1322) to the number or units and bedrooms proposed by
the applicant. The multi‐family parking standards were last updated in 1997. Over the last 10
years, multi‐family projects similar in character to the proposed project have been constructed
and/or approved with parking ratios ranging from 1.6 to 2.20 parking space per unit. Therefore,
staff is recommending that the parking capacity of the project be increased to 2.0 parking spaces
per unit (with staff recommended changes to maximum density 476 units would equate to
required capacity for a minimum of 952 spaces).
Table 9: Parkinq Per SAMC Section 41‐1322 Multi‐family Dwellings
Unit Type Units Rate Required Spaces
Total # of units 496 496
Studios 73 1.00 73
One Bedrooms 307 1.00 307
Two Bedrooms 88 2.00 176
Three Bedrooms 28 3.00 84
Subtotal 1,136
Guest Parkin 1,136 .25 284
Total 1,420 spaces
(2.86 spaces per unit)
Commented [DH62]: The City has the
SAMC for a reason.
2525 North Main Street
January 14, 2019
Page 19
Table 10: Santa Ana Multi‐Family Project Parking Supply & Ratio
Parking Parking Ratio Tandem Parking
Project Name Units Total Residential Guest Total Residential Number Percent
The Marke 300 660 600 60 2.2 2.0 262 44%
Nineteen01 254 559 559 2.2 2.2 ‐‐ ‐‐
Prisma 301 182 364 328 36 2.0 1.8 234 71%
Elan 603 1,209 1,209 2.0 2.0 70 6%
The Heritage 1,221 2,231 2,231 1.8 1.8 ‐‐ ‐‐
The Madison 260 468 468 1.8 1.8 104 22%
The Line 228 359 342 17 1.6 1.5 ‐‐ ‐‐
2525
North
Main St.
Proposed 496 904 780 124 1.8 1.6 150 17%
Required by
SAMC 496 1,420 1,136 284
Notes:
Parking Ratio Total = Total Parking Spaces / Units
Residential Ratio = Residential Parking Spaces / Units
Percent Tandem Stalls = Number of Tandem Stalls / Units
Regional Housing Needs Allocation
Santa Ana's Regional Housing Needs Allocation (RHNA) is 405 units for the planning period of
2014 through 2021. RHNA progress is reported annually to the state and is tracked by the number
of building permits issued at the time that the report is completed. From 2014 to 2017, building
permits were issued for 916 dwelling units, approximately 59 percent of the overall target; 87
very low, 70 low and 10 moderate units remain to fulfill the City's Regional Housing Need
Allocation. Residential development has continued and the 2018 report will be completed in
March of 2019.
Commented [DH63]: At this parking ratio
(1.8) the owners of City Place needed to post
signs in their parking lot to inform the
resident of Prisma of the following: “NO
PARKING BY PRISMA RESIDENTS OR GUESTS
AT ANY TIME.” These signs were put up prior
to having 50% occupancy. This is what we can
expect if we don’t follow the Santa Ana
Municipal Code.
Commented [DH64]: In addition to being
drastically short of parking, it doesn’t address
staff parking needs.
Commented [DH65]: I believe this will
show Santa Ana's Regional Housing Needs
Allocation (RHNA) IS MET.
2525 North Main Street
January 14, 2019
Page 20
Table 11: Regional Housing Needs Allocation Progress 2014‐2017
Income RHNA
Allocation
New
Housing Units
2014
New
Housing Units
2015
New
Housing
Units
New
Housing
Units
2017
Total
Housing
units by
Income
Total Remaining
RHNA by Income
Levels
Very Low 156 20 0 0 49 69 87
Low 122 20 0 12 20 52 70
Moderate 37 0 11 5 11 27 10
Above
Moderate 90 241 127 285 115 768 0
Total: 405 281 138 302 195 916 167
Apartment Product Type
The applicant is proposing a high density multi‐family housing project with no condominium map
proposed at this time. Should an application to convert the project to condominiums be filed, the
application would be processed in accordance with Santa Ana Municipal Code Chapter 34, Article
IX, Common Interested Developments and Conversions Projects, Division 2, Residential
Conversion Projects. Given that the proposed project is a market rate development, rents are
expected to range from $2,000 to $3,700, consistent with similar development in the City such as
The Marke, The Nineteen01 and Prisma. The community has expressed preference for the
property to remain as a professional office building; however, if residential development were to
occur the community would prefer detached single‐family dwellings or townhomes.
No General Plan Amendment, No Zone Change ‐ Spot Zoning
Comments have been received that the land use designation should remain Professional and
Administrative Office and zoning as Professional. Comments have also been received in regards
to "spot zoning" which is generally referred to when zoning standards are changed for one
property and provides for use of the property that is different than surrounding area. Case law
has established that there are several things to consider regarding the property size,
surroundings, and public benefits. The property is a large 5.93‐acre parcel that could be
developed as one large property or subdivided into several properties. Although, the subject site
does not share a property line with another District Center due to geographic features such as
Santiago Creek and the I‐5 freeway, there are District Center properties to the north and south of
the site along Main Street. In addition, several nearby properties are Specific Developments,
therefore amending the zoning of the property to Specific Development No. 93 would not be an
unusual circumstance. Furthermore, approximately 25 percent of the properties along Main
Street north of the I‐5 freeway will be a District Center with Specific Development plan.
Commented [DH66]: History dictates this
entitlement will be sold before a shovel hits
the ground. The new owner will be back
before the city council looking to make
adjustments. See the number of times
Legado at the Met and The Heritage have
changed hands and adjustments have been
requested.
Commented [DH67]: With 38 floor plans,
these are the starting prices.
To avoid being rent poor (more than 30
percent of income is used on rent)
An occupant would need to earn a minimum
of $80K to rent a studio and $152K to rent
the smallest 3‐bedroom to avoid being rent
poor.
Commented [DH68]: Single‐family
dwellings or low‐ density townhomes.
Commented [DH69]: From the General
Plan Land Use Element:
The Museum District located between the
Downtown and Main Place/City Place District
Centers is proposed as a major office/cultural
center which will be developed over the next
15 to 20 years. The area will focus upon the
expanded Bowers Museum, the Discovery
Science Center and the construction of
additional museums and cultural centers.
2525 North Main Street
January 14, 2019
Page 21
Envisioning Map
Early in the General Plan update process (late 2015/early 2016) Planning Division staff drafted an
envisioning map which identified study areas and areas that could potentially have an increase in
development, density and building heights. The North Main Street corridor (north of 17th Street)
including the subject property was identified as an area that may be considered for high‐rise
development and unlimited density. The map did not go through a formal adoption process and
included a note that, "The map represents a conceptual effort and its contents are in a draft
format and do not represent any formal efforts to rezone or redesignate properties shown." As
mentioned previously, the North Main Street area is still being analyzed as part of the
comprehensive General Plan update.
Cumulative Impacts
As part of the EIR a list of cumulative projects was drafted including projects in the vicinity within
the City of Santa Ana and City of Orange for which development applications were submitted,
approved and/or under construction at or prior to the release of the NOP. The project list includes
39 commercial and residential projects. Key topics raised or commented on relative to the
cumulative impacts were population and traffic among others that are analyzed in the EIR.
The Persons Per Household Evaluation within the EIR determined that the number of persons per
dwelling unit is anticipated to be 1.6 per studio, 1.6 per one‐bedroom, 2.7 per two‐bedroom and
3.9 per three‐bedroom which with the applicant's proposed project would be 955 residents. In
addition, 1 ,236 multi‐family units are proposed within the City of Santa Ana and 3,324 multifamily
units within the City of Orange (5,056 units total). The total cumulative housing growth from all
of the projects listed equals 7.4 percent, which is consistent with SCAG's growth estimates of 8.4
percent increase.
In 2020, the project and cumulative projects are anticipated to generate 4,306 a.m. peak hour
trips, 4,359 p.m. peak hour trips, and 49,842 daily trips. In 2020, with the cumulative project trips,
all study area intersections are forecast to operate at satisfactory levels of service, except for the
Main Street/Santa Clara/l‐5 northbound on ramp and the SR‐22 eastbound ramps at Town and
Country Road in both the a.m. and p.m. peak hours. However, the SR‐22 eastbound ramps at
Town and Country Road also operate at unsatisfactory conditions under existing conditions. In
2040, the intersections are anticipated to operate at an unsatisfactory level of service with or
without the project.
Impacts to Public Services
Section 4.10 of the Draft EIR analyzed the impacts of the project on fire service, police service and
parks and recreation service. CEQA focuses on the physical effects of the project (i.e. new or
expanded facilities), therefore an increase in staffing or calls for service would not, by itself, be
considered a physical change in the environment. As proposed the project would result in a less
than significant impact to public services.
Commented [DH70]: Still can’t believe this
is even being mentioned. The Envision Map
is not an approved City document. A parcel
of land that is located across the street from
2525, and is less than 8000 square feet, is
also listed as a site for “Highrise (unlimited
density)”.
Commented [DH71]: This is a fair warning
to anyone wishing to use this map.
Commented [DH72]: What is missing is the
Main Place Transformation Project. The City
has restricted the scope of the r2525 EIR to
development applications that were
submitted, approved and/or under
construction at or prior to the release of the
NOP. CEQA 15130. DISCUSSION OF
CUMULATIVE IMPACTS requires either a list
of past, present, and probable future projects
producing related or cumulative impacts,
including, if necessary, those projects outside
the control of the agency, or A summary of
projections contained in an adopted local,
regional or statewide plan, or related
planning document, that describes or
evaluates conditions contributing to the
cumulative effect.
The Main Place EIR was approved in the
1990’s and is a known project. The fact that
the new owner submitted a plan in May 2018
is irrelevant. The Main Place EIR did not
evaluate the 2525 N. Main Residential
Development. And the 2525 N. Main
Residential Development EIR did not ... [3]
Commented [DH73]: From the Magnolia
At The Park Website: There will be:
• a maximum of 2 residents allowed in
studios and one‐bedroom units,
• a maximum of 4 residents in two bedroom
units, and
• a maximum of 5 residents in
three bedroom units.
... [4]
Commented [DH74]: Over 1500 of these
units are slated for the areas south of the SR‐
22 and North of I‐5 (within 0.5 miles of 2525
N. Main St.) BEFORE you even count the 496
units for this project and BEFORE the
1900 units at Main Place are considered.
Commented [DH75]: Its already
unsatisfactory so we shouldn’t worry about
it. What is not mentioned is the EIR also
states that for the 15 surrounding freeway
intersections during the peak times (a.m. and
p.m.) the CURRENT grade for these 22 of the
30 data points is a failing grade.
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Focus Areas & Transit
Bristol Street Corridor (SP-1)
Harbor Mixed Use Transit Corridor (SP-2)
Midtown (SP-3)
Transit Zoning Code (SD-84)
Neighborhoods
Opportunity Corridors
Downtown Boundary
Metrolink Rail
OCTA Bus Routes
Building Type
Clean Production/Commercial Mixed-Use
Highrise (unlimited density)
Up to 6 Stories (100 dwelling units per acre)
Up to 4 Stories (100 dwelling units per acre)
¯0 10.5
Miles
Envisioning
Santa Ana
Concepts for future incentive
areas and rezoning efforts
Prepared by Santa Ana PBA
12/8/2016
Note: This map represents a conceptual effort and its
contents are in a draft format and do not represent any
formal efforts to rezone or redesignate properties shown.
Dated November 16, 2015.
EXCERPT FROM ENVISION MAP
Document1 Page 1 of 1 2018‐01‐25
2525 North Main Street
January 14, 2019
Page 22
Impacts to Utilities
Sections 4.13 and 4.14 of the Draft EIR analyzed the impacts of the project on water supply,
wastewater, drainage, water quality, and energy. Technical reports including a Water Supply
Assessment, Sewer Analysis and Hydrology Report were prepared for the project. As proposed
the project would result in a less than significant impact to utilities and services.
Noise
Section 4.8 of the Draft EIR analyzed noise impacts related to construction operations and
operational noise from HVAC equipment, parking facilities, trash removal and use of the outdoor
open space. Based on the SAMC noise standards the project would not general noise levels that
would exceed noise standards. To mitigate construction noise two mitigation measures are
proposed, one to require a 50‐foot buffer along the east property line for large mobile
construction equipment and installation of a temporary noise barrier such as vinyl acoustic
curtains or quilted blankets attached to the east property line wall or temporary fence posts.
Privacy
Privacy concerns regarding windows on the east elevation and visibility from the rooftop amenity
deck into backyards or homes were raised. A rendering of eastern views from the rooftop has
been provided, views of the single‐family dwellings are out of the line of sight from the amenity
deck as it is located closer to Main Street. In addition, staff has included a requirement within the
Specific Development for clerestory or opaque windows along the building wall that is at the
40 foot setback.
Staff Recommended Changes
Since the initial project submittal, the applicant has made changes to the project to address both
staff's and the public's comments. Changes made include:
1. Reduced the number of units from 517 to 476 (Reduction of 41 units ‐ 8%).
2. Removed access on Edgewood Road to reduce the potential for cut‐through traffic into
the Park Santiago neighborhood.
3. Reduced the height of the building along the east side from 5‐stories (78 feet) to 2‐stories
(25 feet).
4. Revised the architectural style.
5. Increased the number of family units from 20 percent of the project to 30 percent.
6. Increased the effective parking ratio from 1.76 to 2.0 per unit through the use of valet.
Commented [DH76]: We do NOT want the
property rezoned to SD.
Commented [DH77]: Reduce number of
units to 20 DUA.
Commented [DH78]: Maintain current
height restrictions of PAO zoning.
Commented [DH79]: Apply the SAMC
requirements.
2525 North Main Street
January 14, 2019
Page 23
Staff is recommending additional modifications to the project based on previously constructed
and approved multi‐family development projects in the City, planning and design principles, the
character of the nearby residential neighborhood, and the community's concerns. The proposed
changes include:
1. Number of units: Reduce units to a maximum of 476 units (81 dwelling units per acre).
2. Unit Mix: Increase number of family units to 30 percent (two‐ and three‐bedroom units).
3. Parking Management: Increase number of spaces or capacity to increase the onsite ratio
of onsite parking to an equivalent of 2.00 spaces per unit. Further, a parking management
plan shall be submitted that maintains this ratio prior to Certificate of Occupancy and
throughout the life of the project. Provisions to meet this standard may include an onsite
valet parking service.
4. Design: Incorporate two courtyards into the portion of the project that is located along the
north property line adjacent to Santiago Park.
The staff recommended changes to the development discussed above will be codified in the
Specific Development as follows:
Table 12: Specific Development ‐ Development Standards
Development Standard Specific Development Section
Number of Units Section 3 a
Unit Mix Section 3 b
Parking Section 10
Design
(North Building Elevation)
Section 12 (b)(3)
Economic Analysis
The proposed project would convert an office development into a residential development. A
fiscal and economic impact analysis was prepared by RSG, Inc. in 2017 analyzing the 517‐unit
project (Exhibit 8). In brief, RSG anticipates the following fiscal outcomes over a 25‐year forecast
period:
• Approximately $33.5 million in revenue to the City’s General Fund (construction
period revenues, recurring property tax revenue, utility user tax, residential sales
tax and business tax)
• Approximately $10.0 million in expenditures from the City General Fund (public
services)
• The net new General Fund revenue is projected to be approximately $23.5 million
from the acquisition and development of the Project.
Commented [DH80]: The fiscal Impact
Analysis in Exhibit 8 is an analysis prepared
by The Concord Group (RSG was retained by
The Concord Group)
The financial number are not accurately
represented. You should look at Exhibit 8 for
the full story. The net income in 2017$ is
$13.59 million, not $23.5 million.
Income is based on 517 units.
2525 North Main Street
January 14, 2019
Page 24
Table 13: Public Notification
Public Notification & Community Outreach
Required Measures A Sunshine Ordinance Community Meeting was held on November 15, 2017 from
6:00 p.m. to 7:30 p.m. A total of 263 people signed in.
A public notice will be posted on the project site on January 4, 2019.
Notification by mail will be mailed on January 4, 2019 to all property owners and
occupants within 500 feet of the project site and notification will be provided to
all interested parties that have requested to receive a notice with contact
information on file with the City
Newspaper posting will be published in the Orange County Register on January
4, 2019.
Conclusion
Staff is supportive of General Plan Amendment No. 2018‐01 and Amendment Application No.
2018‐10 for the site as redevelopment of the site with a residential development will provide
additional housing in a prime location that is accessible to retail and employment opportunities
with multimodal transportation options and the project provide general fund revenue. In
addition, public benefits of the Development Agreement include: public art, monetary
contribution to the Santiago Park Maintenance & Improvement Fund, access to on‐site amenities
for Park Santiago residents, security patrol of the residential neighborhood and Santiago Park,
assistance in designating the Park Santiago Neighborhood Association as a historic district, and
monetary contribution to Park Santiago Neighborhood Improvements and Traffic Calming and
Parking, for improvements such as street calming, traffic diversion, entry monuments, and street
light retrofits. The project will also enhance the City's economic and fiscal viability through the
increase in property tax values as well as an increase in sales tax generated from the residents.
Strategic Plan Alignment
Approval of this item supports the City's efforts to meet Goal No. 3 Economic Development,
Objective No. 2 (create new opportunities for business/job growth and encourage private
development through new General Plan and Zoning Ordinance policies).
Associate Planner
SK/VF:sb
S:Planning Commission/2010/1‐14‐19
Commented [DH81]: Not everyone signed
in since the doors were opened late and only
2 tables were used to get everyone signed‐in.
Over 450 people attended.
Commented [DH82]: Street light retrofit
has already been completed by the City.
Commented [DH83]: Its in conflict with:
General Plan Land Use Element:
• Goal 3 Preserve and improve the character
and integrity of neighborhoods.
• Goal 4 Protect and enhance development
sites and districts which are unique
community assets that enhance the quality of
life.
OR in general,
• Increase employment opportunities for
local residents.
OR
• Maintain and enhance the diversity of the
City’s economic base.
2525 North Main Street
January 14, 2019
Page 25
Exhibits: 1. EIR Resolution, Findings of Fact, Statement of Overriding Considerations, MMRP
& EIR Link
2. Development Agreement Resolution & Agreement
3. General Plan Amendment Resolution & Exhibits
4. Amendment Application Resolution & Exhibits
5. Sunshine Meeting Minutes & Sign‐in
6. Response to Lozeau Drury LLP 11‐26‐18 Letter
7. Parking Analysis
8. Economic Analysis
9. Vicinity Map
10. Site Photos
11. Overall Site Plan
12. Floor Plans
13. Building Elevations
14. Renderings
15. Landscape Plan
2525 North Main Street
January 14, 2019
Page 26
ERRORS IN THE REVIEW OF THE EIR. The Planning Department has admitted an error was
made in the evaluation of a comment made by a resident. They now realize the location of the
emergency access drive approach as proposed will potentially impact 3 out of 11 of the existing
100‐foot palm trees within the public right‐of‐way on Edgewood. Most of the remaining
100‐foot palm trees are in jeopardy as well. It is unacceptable that this issue was ignored. The
street needs to be widened but the EIR does not address this fact. There are other errors in
the EIR that they have overlooked as well.
Page 16: [1] Commented [DH56] Dale Helvig 1/7/2019 3:04:00 PM
Park Santiago is a Historical resource and it should be treated as such.
Under CEQA Guidelines Section 15064.5(a), the term “historical resources” includes the following:
1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in
the California Register of Historical Resources (Public Resources Code, Section 5024.1).
2) A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public
Resources Code or identified as significant in a historical resource survey meeting the requirements of Section
5024.1(g) of the Public Resources Code, will be presumed to be historically or culturally significant. Public
agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it
is not historically or culturally significant.
The EIR response to this is:
“This policy [Urban Design Element Policy 2.4 ] is not relevant to the proposed project. As described in Section
4.4, Cultural/Historic Resources, Park Santiago is not identified by the General Plan or other City designation as a
historic district.”
However, the General Plan Urban Design Element [page 11] identifies Park Santiago and Riverview West as
examples of similar design districts.
The General Plan Housing Element [page 56] goes on to talk about Historic Neighborhood Preservation. It states
"Santa Ana has residential, commercial, and industrial areas that have cultural or historic significance to the
community. Residential neighborhoods include, but are not limited to, French Park, Floral Park, Wilshire Square,
Eastside, Washington Square, and Heninger Park residential neighborhoods. The City is also known for its historic
Mexican barrios, including the Logan, Lacy, Delhi, and Santa Anita neighborhoods, which date to the late 1880s.
Several of these are recognized as historical districts, while others are not. In addition to preservation strategies for
individual structures, the City could explore strategies to identify and preserve neighborhoods or elements
thereof that are locally considered worthy of preservation efforts, but not necessarily individually eligible for a
formal state or national historic designation.”
Page 16: [2] Commented [DH59] Dale Helvig 1/7/2019 3:54:00 PM
An example from the Traffic Analysis in regards ot the access at the 22 Freeway:
“With the addition of project traffic, the intersection would continue to operate at an unsatisfactory LOS E in the a.m. peak
hour and LOS F in the p.m. peak hour. Therefore, and the proposed project would not result in exceedance of the Caltrans
criteria, and no impacts at other intersections would occur. Thus, impacts to intersections in the existing plus project with
Option A would be less than significant.
It’s bad, it will stay bad, so it’s OK. Amazing!
EIR response: “Because the project would result in limited peak hour trips, it would not result in a change to the existing MOE
[Measure of Effectiveness]”.
Page 21: [3] Commented [DH72] Dale Helvig 1/8/2019 10:02:00 AM
What is missing is the Main Place Transformation Project. The City has restricted the scope of the r2525 EIR to
development applications that were submitted, approved and/or under construction at or prior to the release of
the NOP. CEQA 15130. DISCUSSION OF CUMULATIVE IMPACTS requires either a list of past, present, and
probable future projects producing related or cumulative impacts, including, if necessary, those projects outside
the control of the agency, or A summary of projections contained in an adopted local, regional or statewide
plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect.
The Main Place EIR was approved in the 1990’s and is a known project. The fact that the new owner submitted
a plan in May 2018 is irrelevant. The Main Place EIR did not evaluate the 2525 N. Main Residential
Development. And the 2525 N. Main Residential Development EIR did not evaluate the Main Place. How is this
looking at cumulative effects?
Page 21: [4] Commented [DH73] Dale Helvig 1/8/2019 10:30:00 AM
From the Magnolia At The Park Website: There will be:
• a maximum of 2 residents allowed in studios and one‐bedroom units,
• a maximum of 4 residents in two bedroom units, and
• a maximum of 5 residents in three bedroom units.
"Magnolia will control occupancy through an on site management team and a comprehensive lease agreement."
At a total of 496 Units this means:
73 studios 146 residents
307 one‐bedroom units
614 residents
88 two‐bedroom units 352 residents
28 three‐bedroom units 140 residents
Total of 1252 residents.
Attachment 3
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View
Page 1 of 2 2018‐11‐13
Tuesday, November 13, 2018
Minh Thai, Executive Director, Planning
Planning and Building Agency ● M‐20
20 Civic Center Plaza
Santa Ana CA 92702
Subject: 2525 N. Main Residential Development Sunshine Meeting Rebuttal
The applicant, AC 2525 Main LLC, submitted to the city a Sunshine Ordinance Community Meeting
Report. NSAPA finds the report lacking in facts and it does not represent the meeting that was held
on November 15, 2017. The rebuttal was written in February 2018, after the applicant finally
submitted their version. A far cry from the requirement to provide timely and detailed minutes of
the meeting including a written record of the comments provided by the community members. I
would like to offer my viewpoint on how the meeting was conducted. In addition, please include this
with the package be given to the Planning Commission.
Prior to responding line‐by‐line I would like to list a few glaring oversites on their part.
1. The meeting was attended by 400‐500 concerned residents. The applicant, AC 2525 Main
LLC, had sign‐in sheets and should be able to provide an accurate count on attendees. The shear
number of people attending is indicative of the community concerns regarding this project and it
should be included in the report.
2. The notes do not address a straw poll that was held at the meeting where attendees were asked if
they wanted apartments built at 2525 N. Main St. The verbal response was overwhelming, 99%
voted nay with only 4‐5 people voting yea.
3. The report makes no reference to the raw negative emotion exhibited by an overwhelming
majority of the residents in attendance.
4. The applicant made a mockery of the Sunshine Ordinance.
5. The applicant did very little preparation and coordination work for the Sunshine meeting.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View
Page 2 of 2 2018‐11‐13
6. The applicant believed the project would take 1.5 years to entitle.
7. The project is under‐parked.
8. The applicant said the City would gain 30.6 million in taxes, over a 25 years. Avoids mentioning the
revenue that could be generated by a 200‐300k square foot office building.
Respectfully,
Dale A Helvig
Chairman, North Santa Ana Preservation Association (NSAPA)
cc: Raul Godinez II
Santa Ana City Manager
Candida Neal,
Planning Manager
Vince Fregoso,
Principle Planner
Selena Kelaher
Associate Planner
Mark McLoughlin
Chairman, Planning Commission
Phil Schaefer,
Vice Chair, Historic Resources Commission
Sarah Bernal
Recording Secretary
Michael O’Valle,
President, Park Santiago Neighborhood Association (PSNA)
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 1 of 14 2018‐11‐13 Comments from November 15, 2017 Sunshine Ordinance Meeting Regarding 2525 Main Residential Development A presentation by the Applicant’s team was made to outline the development process and the review that the City of Santa Ana will conduct including the environmental review. A brief description of the project design was provided as well as discussion of anticipated benefits to the community. Comments and questions were received from the attendees. Responses have been provided. Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 1. Why buy a property to rezone? The site was identified in 2015 by the City of Santa Ana as a likely rezone site and the City placed it on its Envision Map, designating it as residential with unlimited height and unlimited density. In addition, the site should be residential because the proposed residential use next to single family residential is a prototypical manner in which cities are planned. Typically, it is much more common for home owners to resist commercial uses next to their homes, not a residential use. In fact, the State of California is now focusing on requiring EIRs to study the impacts of commercial uses adjacent to homes. I personally don’t recall any mention being made about the Envision map designating the site as residential with unlimited height and unlimited density. On the Envision map it clearly states: “Note: This map represents a conceptual effort and its contents are in a draft format and do not represent any formal efforts to rezone or re‐designate properties shown. Dated November 16, 2015” We are against any rezoning, whether that is “typical” or not. We have coexisted with the 2525 office building very nicely since its construction, and before it, with the site’s previous tenants. In any case, current zoning limits the height of the building to 3 floors and setback to 50 feet. 2. Build an office project. Office would create significantly more traffic than the existing use, for instance, a 5‐story office building would generate approximately 10,000 daily trips compared to approximately 2,812 daily trips for the proposed use (if the existing building were occupied it would create 2,938 daily trips). Additionally, office vacancy in this sub‐market is approximately 20%, whereas multi‐family vacancy is less than 3%. Clearly the need for housing in Santa Ana is one of the most extreme. It is well known that Santa Ana is one of the most overcrowded/dense cities in terms of people to housing ratios (for every 1 housing unit, there are 4.5 people; whereas Irvine is 1 to 2.6 and Newport Beach is 1 to 2.2). The existing housing ratio in Santa Ana is detrimental, by creating a shortfall of housing results in over‐crowding and unaffordable housing options. The reference to a 5‐story office complex is not relevant. The property is zoned P (PROFESSIONAL), which limits the building to 3‐stories. The applicant makes the point that Santa Ana is one of the most overcrowded/dense cities in terms of people to housing ratios. This is our point as well, Santa Ana does not need more housing, it needs more jobs and places for high quality jobs. Where do these stats come from? I see no quoted reports.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 2 of 14 2018‐11‐13 Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 3. Putting Single family units on site will solve crime issue. We are in the process of researching and studying the effects that a larger amount of people will have on crime in the area. We will share the data with the community once it is completed. Crime. Since January 1, 2017 only one police call was made on the 2525 N. Main St. property, and that was for a traffic accident. If crime/vandalism of their building started after they purchased the property, then either it hasn’t been reported or it did not exist. Either way it is poor oversite. In either and then neglected it. Added November 13, 2018: One year later and still no data. 4. No apartments. We are hopeful that the quality of the community will change these opinions and the neighbors will take the time to learn and better understand about the community and City benefits. We don’t understand what they mean by “the quality of the community will change these opinions…”. The project does not fit with the existing community. The residents bought property based upon the existing quality of community and its surrounding areas. The developer is suggesting change which can only be detrimental to that quality by increasing existing housing density and population transiency of the immediate area. Rezoning to unlimited height and unlimited density does nothing to improve community and city benefits.5. No re‐zoning. We are hopeful that the quality of the community will change these opinions and the neighbors will take the time to learn and better understand about the community and City benefits Applicant is providing a duplicate response that adds no real value. Our simple answer is the property is zoned professional so we will respond with simple answer that this property is zoned P (PROFESSIONAL), and it should stay that way. The fact the applicant paid an outrageous price based on an Envision map is not our concern. There are many examples of repurposing property without having to destroy it. Look at the southwest section of the Orange Circle. On the Envision map it clearly states: “Note: This map represents a conceptual effort and its contents are in a draft format and do not represent any formal efforts to rezone or redesignate properties shown. Dated November 16, 2015”6. Need to disclose previous mortuary use on site to people. As a part of the environmental impact report, it will investigate all former uses and of course the report will be made public I take this as a commitment to perform a full Environmental Impact Report (EIR). 7. Would you rezone a property next to your neighborhood? We believe in urban areas the future of housing is denser than in years past. The data is overwhelming that developing multi‐family in close proximity to job centers will reduce traffic, reduce environmental issues, and is less taxing on the infrastructure. Response does not address the question. We believe that people will migrate to areas that have affordable housing, no matter where the location. Don’t destroy the quality of life for single family home owners. We need high paying job locations.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 3 of 14 2018‐11‐13 Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 8. On this site you can put 40 single family/for sale homes and they will sell. The cost of urban infill sites such as this one (17mm) make it cost prohibitive to develop single family. In addition, this is a major thoroughfare with a mixture of uses and significant freeway noise, all making for the site to be incompatible for single family residences. So what is 17mm? The applicant admits it is a major thoroughfare with a mixture of uses and significant freeway noise. So why expose even more people to these issues? So…all the houses on Bush and any other street bordering 17th/5 fwy are now incompatible for single family residences? The increase in property values for those properties (we need proof) refutes that claim. We want no rezoning. It is incompatible for any housing. We agree with the developer with one addition…the major thoroughfare with a mixture of uses and significant freeway noise make this site incompatible for any residences…which is why it must remain zoned as it currently is for a maximum 3 story office building. 9. Oppose apartments of any kind. It is our understanding the neighbor’s impression of an apartment project is not consistent with what we intend to develop. In the upcoming weeks, we will launch a website detailing the quality of construction and vast amenities. The project will resemble a fine resort, not some of the underwhelming projects from years ago. Keep in mind, the folks that will occupy this community will make a minimum income of $58,000 per year, with an average income of $85,000 a year. We don’t buy it and would like to see how these numbers were derived. Based on current rents projections and assuming 30% of one’s income should be towards rent the minimum income for a studio apartment ($2000) would be $80,000. and a 3 bedroom ($3800) would be $152,000. Where are these jobs and do you really believe people not going to use cars? The average income of the overcrowded areas will not change and the density of this property will only drastically increase. 10. Our neighborhood is a jewel, don’t want your project it will damage our neighborhood. It is our intention to leave the community better than we found it. We intend to post on our website all of the benefits the project will bring to the City and the Community. Can’t wait to see this! 11. Rezone would take away our quality of life, some business use ok. Again, we are hopeful that the quality of the community will change these opinions and the neighbors will take the time to learn and better understand about the community and City benefits. Third time answer has been provided.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 4 of 14 2018‐11‐13 Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 12. If the rezoning is going to happen, why are we even talking? The City of Santa Ana has a process for review of the application that includes an environmental review before Planning Commission and City Council hearings. The developer would not have acquired this site had City staff not identified it as an unlimited density and unlimited height residential site over 3 years ago. Nevertheless, the site is not re‐zoned, City staff, Planning Commission and City Council will take into account both the needs of the City and the existing community in coming to a determination if the site is ultimately rezoned. Please be mindful that Main Street and its businesses, which include the hospitals, retail and services, are supportive of more quality housing stock to its workforce. In addition, the project application will be following the process of City review including the CEQA environmental process before any decisions are made. Third time for this response as well. Our answer remains this property is zoned P (PROFESSIONAL), and it should stay that way. The fact the applicant paid an outrageous price based on an Envision map identified it as an unlimited density and unlimited height residential site over 3 years ago is not our concern. On the Envision map it clearly states: “Note: This map represents a conceptual effort and its contents are in a draft format and do not represent any formal efforts to rezone or redesignate properties shown. Dated November 16, 2015” 13. So it is a foregone conclusion that the re zone will happen? The City of Santa Ana has a process for review of the application that includes an environmental review before Planning Commission and City Council hearings. The developer would not have acquired this site had City staff not identified it as an unlimited density and unlimited height residential site over 3 years ago. Nevertheless, the site is not re‐zoned, City staff, Planning Commission and City Council will take into account both the needs of the City and the existing community in coming to a determination if the site is ultimately rezoned. Please be mindful that Main Street and its businesses, which include the hospitals, retail and services, are supportive of more quality housing stock to its workforce. In addition, the project application will be following the process of City review including the CEQA environmental process before any decisions are made. Fourth time with this response as well. 14. Why bring apartments to this neighborhood? Office vacancy in this sub‐market is approximately 20%, whereas multifamily vacancy is less than 3%. Clearly the need for housing in Santa Ana is extreme. . It is well known that Santa Ana is one of the most overcrowded/dense cities in terms of people to housing ratios (for every 1 housing unit, there are 4.5 people; whereas Irvine is 1 to 2.6 and Newport Beach is 1 to 2.2). The existing housing ratio in Santa Ana is detrimental, by creating a shortfall of housing results in over‐crowding and unaffordable housing options. Duplicate answer.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 5 of 14 2018‐11‐13 Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 15. We need apartments but not on this site. There are a lot of apartments planned for adjacent areas We find the location of this site, adjacent to both public transportation and major thoroughfares (the 5 Freeway and the 22 Freeway) make it ideal for multi‐family housing, not to mention the adjacent retailers and employers are in desperate need for high income households in the submarket, along with knowledgeable workers (those workers with specific skill sets). Please keep in mind that the culture has changed in that professionals today are renting in far greater numbers than the previous generation. In addition, we would sell these units as condominiums, once the market allows us to do so, however, post‐recession lenders still have not loosened their requirements making it difficult for many to qualify for mortgage financing. Whether they are apartments or condominiums, it doesn’t make a difference. The concept of condominiums was not even discussed at this meeting so why is it mentioned here? 16. Not appropriate for our neighborhood. We find the location of this site, adjacent to both public transportation and major thoroughfares (the 5 Freeway and the 22 Freeway) make it ideal for multi‐family housing, not to mention the adjacent retailers and employers are in desperate need for high income households in the submarket, along with knowledgeable workers (those workers with specific skill sets). Please keep in mind that the culture has changed in that professionals today are renting in far greater numbers than the previous generation. In addition, we would sell these units as condominiums, once the market allows us to do so, however, post‐recession lenders still have not loosened their requirements making it difficult for many to qualify for mortgage financing. Duplicate answer.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 6 of 14 2018‐11‐13 Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 17. Is there any research about how it works to have apartments adjacent to older neighborhoods? The site is situated on a main thoroughfare with all different types of uses, situating a multi‐family community next to services will reduce the use of cars and support the other adjacent retailers. We are studying potential means to mitigate cut‐through traffic into Santiago Park either through reconfiguration of the existing egress, or a gate. In general, most cities are planned with multi‐family housing next to single family housing with commercial next to the multi‐family. The site makes much more sense as a multi‐family residential use. Typically residents are unhappy when commercial uses are next to their homes, not residential uses. That is why this site was identified three years ago by staff to be rezoned for residential. In addition, the park is having vagrant issues and this problem will be somewhat mitigated with professionals living at this location, because it will create a deterrent via a nighttime presence. “will reduce the use of cars” GIVE US A BREAK! We know cut through traffic will increase. I interpret the statement of “most cities are planned with multi‐family housing next to single family housing with commercial next to the multi‐family” two ways: 1) a city will implement this if they are designing an ideal situation and it is known ahead of time. It does not state if cities are in the practice of rezoning at the expense of single family homes and 2) it discusses the idea of zoning buffers, a concept that the Planning Commission is trying to rectify. Having an unlimited density and unlimited height residential site next to a residential site defies this concern. 18. Our community opposed apartments being built in our vicinity in the 1960’s and they did not get built. The vision and the needs of the City have changed. The City now is greatly in need of housing stock in order to prevent overcrowding and to provide affordable housing options. Again, the previous generations were able to navigate their families into home ownership, but the environment has changed and the barriers to acquire a home are significant and real. Overcrowding occurs when an entity continues to provide high density living spaces, period. 19. What is the Sunshine Ordinance? A City Ordinance that requires a community meeting to be held by the applicant after the application is filed to educate about the proposed project and obtain input. The community input that was provided was inadequately recorded by applicant. The applicant has made a mockery of the Sunshine Ordinance. 20. Why doesn’t developer put money in a property in a broken neighborhood in Santa Ana? The developer has been active in Orange County and has developed in all types of neighborhoods. The existing office building was developed as a boiler room/call center for Wells Fargo; it is now obsolete because this type of use has been farmed out to other countries. The site will be developed, and again, this type of use will provide for needs of the retailers, of the adjacent employers, produce significant revenue for the City, and is situated on a public transit corridor, ideal for reducing the use of automobiles. The building is not obsolete. The developer has no vision. We live in homes that were built as early as 1889.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 7 of 14 2018‐11‐13 Land Use: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 21. This neighborhood has been here for 100 years We know this is a fantastic neighborhood and it is our objective to leave the neighborhood better than we found it. Again, the site is not in Park Santiago, it is on a main thoroughfare, and its position is ideal to work in harmony with the adjacent retail, restaurants, office and main transit corridors. Keep in mind that for decades, this site has been a different use than the single family homes located in Park Santiago and it is our understanding that the issues were minimal. The issues have been minimal. The applicant’s proposal is a major change. The project site is located within Park Santiago, just look at all the city maps. It may be located on a major thoroughfare, but it is not near any mass transit stations. 22. No rezoning, no GPA, no apartments Please refer to responses to comments 4 and 5 Even they got tired of repeating themselves. 23. Don’t want to be packed in like sardines. The density of this project is consistent with hundreds of other Southern California projects, including those found in Santa Ana, Irvine, Newport Beach, Costa Mesa, Anaheim and Huntington Beach. The projects have added tremendous value to both the cities and the communities they are situated in by providing quality housing, bringing quality folks to the neighborhood, and supporting local businesses. The proposed project will provide more than 10x the revenue compared to the existing structure, thereby helping to reduce any fiscal challenges the City currently faces. The City is in need of a variety of new services and better services and this can only be achieved through expansion of its tax base. The rubber meets the road. The promise in the sky of increased revenues at the expense of existing homeowners. It does not evaluate income from repurposing the land and in fact was not even discussed outside of flashing a slide. 24. Concerned about privacy, people would be able to see into backyards of adjacent houses. We have purposely oriented the unit windows toward the park, toward the courtyards and away from any of the adjacent neighbor homes. We currently are studying sight lines and in the event it is determined that this is an issue, the developer will either revise the design, pay for fencing and/or landscaping to screen the backyards. It is our understanding that the adjacent 9‐story office building (which is far higher) has not created privacy issues for the adjacent homes. It is also our intention to bury existing power lines, thereby beautifying the adjacent neighborhood. Could be the privacy issues from the 9‐story office building was addressed by the 100‐year old eucalyptus trees. And the 9‐story office building is up the street and not even adjacent to 2525 N. Main St. Again, not discussed at Sunshine meeting. 25. This project would ruin our quality of life. Please refer to responses to comments 21, 23 and 24. No comment.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 8 of 14 2018‐11‐13 Traffic and Parking: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 1. Where are the 900 cars? There will be a parking structure that the buildings are wrapped around. The center of the site will contain a 7‐level parking structure; the residences will be constructed around the garage, allowing residents to park on the same level as their home. This type of development is both ideal for the residents and screens and screens the parking structure from surrounding area views. Proposal was for an 8‐story parking structure. Are they already reducing the onsite parking? 2. Streets aren’t wide enough to accommodate apartments. We will work with our traffic engineers, architects and City staff to make the egress away from Park Santiago community and towards Main Street. You can’t fit a round peg into a square hole. This will be interesting. 3. Cowan Heights residents cut through our streets already. We believe you have a wonderful community and we will look into any means to mitigate this and any existing nuisance. It occurs now, what will be different except the increased volume? 4. Nearby Apartments are not full and traffic is already miserable. Santa Ana is among the worst cities in terms of housing shortages in the nation, in fact, Santa Ana’s housing share of the housing stock in 2000 was 34% of the housing in the vicinity (including Santa Ana, Costa Mesa, Newport Beach, Irvine, Tustin); however, by 2015 Santa Ana’s share was down to 27%. As noted above, Santa Ana vacancy rate is less than 3%, it is virtually impossible to have a lower vacancy rate; it is clearly indicative of a housing under‐supply. There have been countless studies and articles over the last 3.5 years documenting Orange County’s housing shortage, resulting in folks paying far too much for housing, increasing traffic, increasing pollution, and destroying the quality of life (because people end up spending hours a day in their cars commuting). If Orange County’s housing shortage is not solved, it will drive out workers and drag down the region’s robust economy. Without more places for workers to live, more 20 and 30‐somethings will leave and business will struggle to recruit high quality employees. Does not even address the traffic issue. The applicant makes the point that Santa Ana is one of the most overcrowded/dense cities in terms of people to housing ratios. This is our point as well, Santa Ana does not need more housing, it needs more jobs and places for high quality jobs 5. Need to account for all the future apartments in Santa Ana and Orange in area in traffic analysis. The traffic study area is extensive and will address the appropriate area as determined by City staff and will analyze up to 2040 traffic. We don’t need a study. Just sit on the corner of Main And Edgewood any weekday morning or evening and you can see the serious problems that currently exist. 6. Need to assume 2 persons per apartment, this is Santa Ana, there won’t be 1 person in an apartment. We have taken into account data from apartment communities in determining the quantity of parking that is necessary to operate an organized and quality community. Data does not equate to reality. Even millennials need cars.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 9 of 14 2018‐11‐13 Traffic and Parking: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 7. There is a huge problem with cars running through Park Santiago now. We will work with our traffic engineers, architects and City staff to make the egress away from Park Santiago community and towards Main Street. The only difference we see is it will increase the volume of cut‐through traffic. 8. You think there will be a benefit of reduced traffic with apartments instead of commercial? Office would create significantly more traffic than the existing use, for instance a 5‐story buildings would generate approximately 10,000 daily trips compared to the approximately 2,812 daily trips for the proposed residential use (if the existing building were fully occupied it would create approximately 2,938 daily trips). Same response as LAND USE #2: The reference to a 5‐story office complex is not relevant. The property is zoned P (PROFESSIONAL), which limits the building to 3‐stories. The applicant makes the point that Santa Ana is one of the most overcrowded/dense cities in terms of people to housing ratios. This is our point as well, Santa Ana does not need more housing, it needs more jobs and places for high quality jobs. 9. What is a trip? The movement of one car in or out. No comment 10. How many trips anticipated for project? You have to assume 90% of people will leave in the morning and come home at same time in evening. Based on the traffic engineer’s study, the proposed project would generate 2,812 trips per day, whereas the existing building if fully used would generate 2,938 trips per day. I don’t believe it. 11. How many parking stalls are currently on site? There are 441 stalls on site. Count again. 12. The number of parking spaces on site don’t correlate to traffic. Business uses highlight cars coming in and out all day, in addition, they have visitors and services that create trips throughout the day. Employees also contribute to the trip count with multiple daily trips. It is also only on given days, not 24/7. 13. Look at current traffic now. Please keep in mind that the proposed project will result in less daily trips than the current structure would if fully leased and operational. We respectfully disagree. 14. People park on our streets on Spurgeon now, it will get worse. We are providing ample parking, it will exceed the parking needs of the project. In fact, we would be open to discussion of providing guest parking for the Park Santiago community. Guest parking, handicap parking should be considered for any multi‐family living project. We can’t believe the applicant would mention guest parking for the community when they talk about 1.52 spots per unit (1.52 is a made‐up number) for the Park Santiago community.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 10 of 14 2018‐11‐13 Traffic and Parking: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 15. Where will Discovery Science Center park? the Discovery Science Center has plans for a new garage on their rocket lot. Discovery Science Center fully supports our project. Has Discovery Science Center publicly made this endorsement? Can someone look into this? 16. Take into consideration, Park Santiago only has three access points, traffic at Edgewood and Main is already impacted. Our main egress will be off of Main Street. Residents leaving the project on Edgewood can only turn right out to Main. In addition, we are open to exploring other means to help any existing issues with cut‐thrus. Exactly. Edgewood would be choked off. 17. More traffic will result in more accidents. As stated previously, the current use produces more daily trips than the proposed use. Does nothing to address the accidents at the intersection that currently exists without the building being occupied. 18. There should be no entrance to the project on Edgewood, keep project traffic on Main. Our main egress will be off of Main Street. Residents leaving the project on Edgewood can only turn right out to Main. In addition, we are open to exploring other means to help any existing issues with cut‐thrus. Edgewood egress/ingress is unacceptable. 19. Parking on neighborhood streets is already a problem. 2525 N. Main is not in Park Santiago. Residents will be provided with ample parking on site. The logistics of parking blocks away from their homes makes little sense. Again, the community will be over‐parked, not under‐parked. Unless it is a minimum of 2 spaces per unit it is not enough. Does not even address guest/handicap parking/electric vehicle stations. 20. Can we see the traffic study? The City will review the traffic analysis and it will be a part of the environmental document, which will be an EIR, which the community will be able to review and comment on as a part of the City review process Looking forward to reviewing the full EIR.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 11 of 14 2018‐11‐13 Affordable Housing: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 1. What is a market rate unit? It is housing that is either sold or leased at the price the market bears. No comment 2. Would you save money including inclusionary housing? No. No comment 3. Will there be inclusionary housing, the application says there will be low and very low units included? When the application was submitted on site inclusionary was considered, but the project will propose to pay in‐lieu fees and not include on site. Application has inclusionary housing. Proposing to pay in‐lieu fees does not sound legally binding. 4. Have you made any promises to groups about affordable housing? No, in our business we meet with affordable housing developers to see what projects are planned, This project will require payment of a fee in excess of $6,500,00 in order to subsidize much needed affordable housing throughout the City. Again, this does not seem legally binding. 5. No affordable units on site It is not our current plan to provide any affordable units on site. Not the current plan, but it could be in future plans according to filing..
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 12 of 14 2018‐11‐13 Crime: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 1. Is there security on site? Currently there are workers on site during the day, after dusk and until dawn we have on site security. No comment 2. Is the property as is bringing crime to the neighborhood? Yes, we have had significant vandalism and theft of copper pipes, copper wire and fixtures. The damage is in excess of hundreds of thousands of dollars. Currently there are dozens of vagrants camping/living in the riverbed and under the overpass from Main Street. If the applicant currently has workers on site during the day, and site security after dusk and until dawn, why the significant vandalism and theft of copper pipes, copper wire and fixtures? Did they wait until they had a problem to address it? It seems so. Not the pro‐active group that I would want to do business with. 3. Increasing the population won’t decrease crime. Crime is simply a reality of a urban location. We believe putting residents at this location will result in a nighttime presence, especially in the park, thereby deterring crime. In addition, we will have 24 hour security that will patrol the park and Park Santiago (if the community would like this benefit provided). Crime was not a problem until the applicant took control of the property. Enough said. 4. 1.2 million a year to the General Fund will provide 3 police officers that is nothing. This amount of revenue will provide significantly more than 3 officers. Importantly, the City, like most City’s needs to find more sources of revenue to provide much needed services. The proposed project, unlike others, is a budget surplus for the City, it is a wonderful opportunity to bring much needed professional housing to the City and additional revenue. Money, money, MONEY! 5. Putting single family on the site will solve the crime issue. We believe the more people the greater, in deterring crime in the area. Responsible landlords will help deter crime. 6. We have one of the first neighborhood watch groups, why haven’t you come to talk to us? We have reached out to the community group and to date they were not available to meet. Neighborhood watch is different than neighborhood association. 7. It is insulting that you talk about crime in our neighborhood. We are hopeful that crime will be mitigated in the future. Hope, without hope all is lost. Being a responsible landlord will help deter crime. 8. Was there vandalism when the building was used as a call center? We do not have a crime report for the area, we have made a request for any such reports. No comment. Added November 13, 2018: One year later and still no data.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 13 of 14 2018‐11‐13 Environmental: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 1. How many persons will the project bring? Approximately 850 people. What control can you possible but in place to stop multiple families from living in one unit? 2. We have a drought where will water come from? Currently we are not in a drought, but we are aware historically there has been an issue. We have verified that there is more than enough water for this and many other projects. In addition, this question will be addressed in the environmental review. At some point in time, after every single‐family home is converted into a multi‐family residence we will be without water. Sarcastic, yes. The point is there is a breaking point and no one knows what it is. 3. Look at all surrounding projects, will they be considered? Existing and proposed development will be addressed in the environmental review. EIR! 4. What is the impact on current water supply? This will be addressed in the environmental review. EIR! Other: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 1. Are you on the Next Door site? No. No comment. 2. Have you made any contributions to City Council persons, have you been promised anything? The project entity has not and nothing has been promised. No comment 3. Don’t care if project brings money for Santa Ana, we shop in Orange. We hope and suspect it is not the sentiment of the majority of the homeowners in Park Santiago. We want to make the community better than we found it and we are confident we will do that. Keep in mind that current Park Santiago residents will have access to all the onsite amenities, that includes pools, spas, full size gym, rock climbing wall, lounge, roof top pool and much more. I think it is the sentiment of homeowners in Park Santiago. Access to grocery stores, Home Depot, auto repairs is far easier traffic wise than heading south.
Rebuttal to Developers View on Sunshine Meeting Sunshine Meeting Report ‐ Neighborhood Rebuttal‐Table View Page 14 of 14 2018‐11‐13 Other: COMMENT QUESTION REPORTED TO DEVELOPER DEVELOPER RESPONSE: NEIGHBORHOOD RESPONSE: 4. How many developments has Vineyard been involved in that required zone changes, were they successful? Did they back up to residential neighborhoods? The ownership group has been involved in dozens of like projects, and many of these involved successfully rezoning. Many were adjacent to single family homes and in our experience, this type of zoning is most compatible with single family homes (not an office building). Most cities are planned with single family next to multi‐family, then retail and commercial uses (typically there is a mixed‐sue area with multi‐family and commercial). This is why more than 3 years ago the City targeted this site for multi‐family housing and this use would be most beneficial to the City. A recent project was approved at Dyer and Red Hill in an industrial area. “Many were adjacent to single family homes and in our experience, this type of zoning is most compatible with single family homes (not an office building).” It is not compatible, and it does not agree with the City of Santa Ana General Plan. It’s all a smoke screen. 5. Is the powerpoint available to the Park Santiago HOA? We will shortly launch a website with all the information that we attempted to present at the Sunshine meeting. Can’t wait! 6. Why didn’t you meet with us before you submitted the application? We tried to meet but the meeting agenda had already been set, we are trying to set a meeting soon. When? 7. Will you meet with the HOA? Yes. When? 8. We don’t need this project for Santiago Park to be restored, we have paid taxes and City owes us the park restoration. It is our understanding the City does not have funding and certainly has not committed funds to rehab the park. The project will pay significant taxes that go directly to the City’s general fund. Councilmember Solorio provided the community the status of the “GAS HOUSE AREA DEVELOPMENT AT SANTIAGO PARK” at his meeting in August.
Attachment 4
Page 1 of 21
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714‐541‐7254 helvig_denny@msn.com
Tuesday, June 5,2018
Mayor Pulido and Santa Ana City Councilmembers
City of Santa Ana
20 Civic Center Plaza, 8th Floor
Santa Ana CA 92702
Subject: 2525 Main Residential Development
This is a repeat of the May 15, 2018 letter with updated attachments.
The first Specific Development, SD‐1 was approved on April 29, 1976. Over the past 42 years an
additional 91 Specific Developments have come before the City Council. Of those only 17 have been
approved in which they had an adjacent property line with Residential Development; and of those
17 only 2 had a height restriction greater than 35 feet. This being the SD‐21, OC Register Building on
Grand Avenue and the recently approved SD‐92, Tiny Tim Plaza on 5th Street, which is limited to
45 feet.
The applicant of 2525 Main Street Development is proposing to construct a five‐story building
apartment building wrapped around an eight‐story parking structure with a height in excess of
85 feet.
I encourage you to look at the attached list of which highlights these 17 SD/R1 projects. You’ll quickly
see how far out of the norm the 2525 project is, and realize this project is not good for Santa Ana.
Sincerely,
Dale A Helvig
Chairman, North Santa Ana Preservation Association (NSAPA)
Summary of Specific Developments in Santa Ana Adjacent to
Residential Developments (R1)
Page 2 of 21
cc:
citycouncil@santa‐ana.org
Raul Godinez II
Santa Ana City Manager
Minh Thai
Executive Director, Planning
Candida Neal,
Planning Manager
Vince Fregoso,
Principle Planner
Phil Schaefer,
Vice Chair, Historic Resources Commission
Michael O’Valle,
President, Park Santiago Neighborhood Association (PSNA)
Summary of Specific Developments in Santa Ana Adjacent to
Residential Developments (R1)
Page 3 of 21
Location
Height
Restriction Stories
Density
(Dwelling Units per Acre) Notes
1 SD‐06 35 Feet 2 Story 18.0 Woodlake Condominiums
NO LONGER NEXT TO R1 ZONING.
2 SD‐07 35 Feet 2 Story 8.0 Aspen Village Apartments
NO LONGER NEXT TO R1 ZONING.
3 SD‐11 35 Feet 11.5 Amberwood Town Homes
4 SD‐15 2 Story Residential Condominiums
5 SD‐17 2 Story Single Family Homes
6 SD‐21 150 Feet OC Register Building
7 SD‐35 36 Feet 2 Story 22.0 Single Family Homes
8 SD‐36 35 Feet 3 Story 38.9 Solare Apartment Homes
9 SD‐41 35 Feet 3 Story San Tropez Luxury Apartments
10 SD‐42 2 Story 10 Single Family Homes
11 SD‐44 2 Story
Denied by the City Council
on June 15, 1987.
Santa Fe Village Apartments
NO LONGER NEXT TO R1 ZONING.
12 SD‐46 35 Feet 2 Story 2 units with a total
maximum of 23 beds
Heart of Jesus Retreat Center
13 SD‐50 35 Feet 2 Story Single Family Homes
14 SD‐53 2 Story Seventeen single‐family lots with seventeen
single‐family dwelling units
15 SD‐77 35 Feet 2 Story One (1) single family
dwelling for each
6000 square foot lot
Single Family Homes
16 SD‐83 35 Feet 2 Story 15.0
17 SD‐92 45 Feet ~21.9 Tiny Tim Plaza: Fifty‐one (51) multiple‐family
dwelling units for affordable housing,
including one (1) onsite manager's unit.
PROPOSED PROJECT AT 2525 N. Main Street:
> 85 Feet 5 Story 84.1 Effectively a six story because entertainment
deck on top; a wrap around eight‐story parking
structure w/ 910 parking spaces.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 4 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 1 SD‐06 / R1 January 28, 1980 McArthur & Greenville (East of Fairview) NS‐1364 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING: DWELLING UNITS PERMITTED: a) crop agriculture b) single family dwellings c) cluster or attached family dwellings d) apartments e) condominiums f) tennis centers g) accessory buildings and uses determined to be incidental and necessary to the primary use subject to the approval of the Planning Commission. The height limit of main buildings and structures is 35 feet and accessory buildings and structures 20 feet provided, however, the Planning Commission shall have the right to limit the number of stories in any, or all of the buildings in the SD #6 district or the height of any other structure when it finds that existing or proposed developments on adjacent properties or properties across a street or alley would be adversely affected unless such a limitation were imposed. Required parking shall be provided as follows:a) two 2 fully enclosed garages and one uncovered parking space for each dwelling within the development except for the following use b) apartments: (1) bachelor apartment: one (1) parking space per unit (2) one‐bedroom apartment: one and one half (1.5) parking spaces per unit. (3) two‐bedroom apartment: one and four‐fifths (1.8) parking spaces per unit. (4) three and more bedroom apartment: two (2) parking spaces per unit plus one‐half space for each bedroom over three. Included in the above parking requirements will be a minimum of one (1) fully enclosed garage or carport per unit. The decision of whether fully enclosed garages are required will be determined by the City as a condition of approval of plans and drawings as provided for in Division 26 of the Santa Aha Municipal Code. A percentage of uncovered parking spaces may be designed as compact car spaces provided that the City determines that the developer has provided adequate information to justify the inclusion of compact car parking spaces as a specific percentage of the total open space parking to be provided. In addition to the above stated parking space requirements guest parking shall be required as follows: one fifth (0.2) parking spaces per unit for the first one hundred 100 units and one tenth (0.1) parking spaces per unit for each additional unit. Woodlake Condominiums Not more than eighteen 18 dwelling units per one 1 acre of net developable land area shall be permitted. NO LONGER NEXT TO R1 ZONING.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 5 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 2 SD‐07 / R1‐PRD May 24, 1977 McArthur/Raitt NS‐1365 PERMITTED USES: HEIGHT RESTRICTIONS:REQUIRED PARKING:DWELLING UNITS PERMITTED:a) crop agriculture b) single family dwellings c) cluster or attached family dwellings d) condominiums e) accessory buildings and uses determined to be incidental and necessary to the primary use subject to the approval of the Planning Commission. The height limit of main buildings and structures is 35 feet and accessory buildings and structures 20 feet provided however the Planning Commission shall have the right to limit the number of stories in any or all the buildings in the SD 7 District or the height of any other structure when it finds that existing or proposed developments on adjacent properties or properties across a street or alley would be adversely affected unless such a limitation were imposed. Required parking shall be provided as follows:two 2 fully enclosed garages and one uncovered parking space for each dwelling within the development. Aspen Village Apartments Not more than 8.0 dwelling units per one 1 acre of net developable land shall be permitted. NO LONGER NEXT TO R1 ZONING
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 6 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 3 SD‐11 / R1 April 3, 1978 Hazard/Rosita NS‐1411 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:DWELLING UNITS PERMITTED:a) single family dwellings b) cluster or attached family dwellings c) condominiums d) accessory buildings and uses determined to be incidental and necessary to the primary use subject to the approval of the Planning Commission. The height limit of main buildings and structures is thirty‐ five (35) feet and accessory buildings and structures twenty (20) feet provided, however, the Planning Commission shall have the right to limit the number of stories in any or all the buildings in the SD #11 District or the height of any other structure when it finds that existing or proposed developments on adjacent properties or properties across a street or alley would be adversely affected unless such a limitation were imposed. Two (2) fully enclosed garages and one (1) uncovered parking space for each three‐bedroom dwelling unit within the development. One (1) fully enclosed garage and one (1) uncovered parking space for each dwelling unit having two bedrooms or less. Amberwood Town Homes Not more than 11.5 dwelling units per one 1 acre of net developable land shall be permitted.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 7 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 4 SD‐15 / R1‐PRD June 18, 1979 Edinger/Raitt NS‐1491 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:DWELLING UNITS PERMITTED:Residential Condominiums NONE DESCRIBED NONE DESCRIBED NONE DESCRIBED Two Story
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 8 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 5 SD‐17 / R1 May 2, 1983 4TH/Raitt NS 1679 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:NONE DESCRIBED NONE DESCRIBED NONE DESCRIBED NONE DESCRIBED
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 9 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 6 SD‐21 / R1 May 24, 1984 Grand Avenue NS‐1733 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:a) Up to three hundred thousand (300,000) square feet of professional and administrative offices [50,000 square feet existing]. b) Up to one hundred thirty thousand (130,000) square feet of newspaper plant production facilities [70,000 square feet existing]. c) Up to three hundred thousand (300,000) square feet of production support facilities [150,000 square feet existing]. d) Up to sixty thousand (60,000) square feet of office storage facilities [0 square feet existing]. e) Parking facilities to serve permitted uses. f) Equipment and vehicle maintenance accessory to permitted uses. g) Microwave transmission devices at ground level or on the roof of each building. h) Satellite dishes at ground level or on the roof of each building. A. No building or structure shall exceed one hundred fifty (150) feet in height north of Sixth Street and one hundred (100) feet in height south of Sixth Street. B. No building or structure, including mechanical appurtenances and communications facilities located on a roof and exclusive of the first thirty‐five (35) feet of a structure, shall intercept a plane that rises one (1) foot for every two (2) linear feet drawn from the nearest point of adjacent property lines zoned R1 (single‐family residential). A. Off‐street parking shall be provided in the manner, prescribed in Article IV of Chapter 41 of the Santa Ana Municipal Code in effect on the effective date of this ordinance, except as provided herein. B. Up to sixty (60%) of the spaces may be compact car spaces. C. Visitor parking have a maximum of twenty‐five compact car spaces. OC Register Building
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 10 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 7 SD‐35 / R1‐PRD January 6, 1986 5th and Santa Ana River NS‐1825 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:A 220 unit apartment project consisting of 14 two‐story structures and associated recreation facilities A two‐story residential structure not to exceed an elevation of 36 feet from grade 220 Covered/187 Uncovered Wellington Place 22 Dwelling Units per Acre
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 11 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 8 SD‐36 / R1 December 16, 1985 17th/English NS‐1824 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:A 24 unit apartment project consisting of ten three‐story structures with 24 units each. Three story residential structures not to exceed an elevation of 35 feet from grade. 240 Covered/206 Uncovered Solare Apartment Homes 38.9 Dwelling Units per Acre Unit Breakdown 1 Bedroom/1 Bath 36 625 Sq. Ft. 2 Bedroom/1 Bath 60 832 Sq. Ft. 2 Bedroom/2 Bath 144 825 Sq. Ft.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 12 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 9 SD‐41 / R1 October 20, 1986 Westminster/Nancy Lane NS‐1872 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:130 unit residential apartment complex No structure shall exceed 35 feet within 15 feet of R1 zoned property. Every structure in excess of 35 feet shall provide an additional one‐foot setback to the required buffer yards for each foot that the structure exceeds 35 feet. Structures shall be limited in height to 50 feet or four (4) stories. Total 299 spacesSubterranean 157 At grade 142 San Tropez Luxury Apartments Two 30‐unit three story 60 units Two 18‐unit three story 56 units Four 8‐unit two story 52 units One 2‐unit two story 2 units
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 13 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 10 SD‐42 / R1 December 1, 1986 La Bonita/Progresso NS‐1882 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:Forty‐eight single‐family lots with forty‐eight single family dwelling units, consisting of three floor plans each, shall have an attached two car garage with private streets. Typical two‐story construction above new grade Attached 2 Car Garage (Optional 3 Car Garage on Specified Lots) 10 Dwelling Units per AcreUnit Breakdown Plan 1: 3 Bedroom 2¾ Bath 1213 Sq. Ft. Plan 2: 3 Bedroom 2½ Bath 1313 Sq. Ft.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 14 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 11 SD‐44 / R1 June 15, 1987 Between Mc Arthur & Sunflower on Raitt AMENDMENT APPLICATION NO. 976 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:Specific Development No. 44 was a 104 unit condominium project that was denied by the City Council on June 15, 1987. Please contact the Planning Commission Secretary at (714) 667‐2700 for more information on this file. Denied by the City Council on June 15, 1987. Denied by the City Council on June 15, 1987. Santa Fe Village Apartments Denied by the City Council on June 15, 1987. NO LONGER NEXT TO R1 ZONING.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 15 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 12 SD‐46 / R1‐PRD September 19, 1988 Segerstrom/Greenville NS‐1977 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:A. Residential for convent only; B. Religious education and ancillary uses No building shall exceed 35 feet within 15 feet of any residentially zoned property. Spires, clerestories and religious symbols such as crosses can extend past the building height but no more than a maximum height of 41 feet. North parking lot: 62 spacesNon‐ integrated south parking lot: 10 spaces Total parking provided: 72 spaces Heart of Jesus Retreat Center 2 units with a total maximum of 23 beds Retreat Buildings as follows: Phase One Construction: One 8000 square foot retreat center which includes four classrooms and a multi‐purpose hall Phase Two Construction: One 3000 square foot dining and kitchen facility and outdoor patio area Phase Three Construction: One 5000 square foot chapel and sacristy Phase Four Construction: One two story 5000 square foot convent.
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 16 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 13 SD‐50 / R1 March 20, 1989 West Na Pali Dr near Euclid/McFadden NS‐2003 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:One family residential Height limit 35 feet None Listed None Listed
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 17 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 14 SD‐53 / R1 August 7, 1989 Morse Dr. Hazard & Harbor Blvd. NS‐2019 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:Seventeen single‐family lots with seventeen single‐family dwelling units, consisting of two floor plans, each shall have an attached two car garage with private streets. Typical two‐story construction above new grade Attached 2 Car Garage
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 18 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 15 SD‐77 / R1 November 21, 2005 Aster/Farmers NS‐2705 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:1) One (1) single family dwelling for each 6000 square foot lot 2) One (1) temporary real estate office devoted to the sale of real estate in the tract in which it is located which use shall be for a period not to exceed one (1) year 3) Accessory buildings and structures, except as otherwise provided in Section 4, determined to be incidental and necessary to the primary use, subject to the approval of the Planning Commission 4) Childcare facilities providing care to not more than eight (8) children. The following uses are permitted upon the approval of a conditional use permit in accordance with the Santa Ana Municipal Code 1) Neighborhood and community service centers 2) Garages for more than four 4 vehicles 3) Childcare facilities caring for more than eight 8 but no more than fourteen (14) children 4) Accessory structures exceeding fifteen (15) feet in height or more than one (1) story The height limit for main buildings and structures is 35 feet and for accessory buildings and other structures is 15 feet. Accessory structures more than 15 feet in height will require a Conditional Use Permit. The Planning Commission shall have the right to limit the number of stories in any, or all, of the buildings in the SD‐77 district or the height of any other structure when it finds that existing or proposed developments on adjacent properties or properties across a street or alley would be adversely affected unless such a limitation were imposed. Next to Interstate 5:
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 19 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 16 SD‐83 / R1 December 3, 2007 1600 West Memory Lane NS‐2790 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING: Permanent rental housing to people with developmental and physical disabilities earning less than 30‐60% of Area Median Income for Orange County A handicap accessible affordable apartment community A visually harmonious development as viewed both internally and externally particularly from adjacent Santa Ana scenic corridor and bikeway A development that is consistent with the Medium Density designation of the General Plan and that implements the spirit and [intent] of the policies of the General Plan. The height limit for main buildings and related structures is 35 feet and for accessory buildings and other structures is 15 feet. Accessory structures more than 15 feet in height will require a Conditional Use Permit. Vista Del Rio Apartments The maximum authorized residential density for the Vista del Rio is 15 dwelling units per acre The following general development standards are applicable to multiple family dwellings and consistent with Site Plan Attachment A 1 Residential Unit Size The minimum unit size for the project shall be a minimum of: Studio units 543 square feet One‐bedroom units 627 square feet Two‐bedroom units 897 square feet
Specific Developments in Santa Ana Adjacent to Residential Developments (R1) Page 20 of 21 SPECIFIC DEVELOPMENT / ADJACENT ZONE DATE APPROVED BY COUNCIL CROSS STREETS ORDINANCE NO. 17 SD‐92 / R1 (Tiny Tim Plaza) January 16,2018 5th/Hawley NS‐2935 PERMITTED USES: HEIGHT RESTRICTIONS: REQUIRED PARKING:a) Fifty‐one (51) multiple‐family dwelling units for affordable housing, including one (1) onsite manager' s unit. b) Ancillary onsite community ‐serving or social service uses. The lobby will be accessible 24‐hour a day to residents and staff. c) Home occupations, pursuant to Section 41‐192.1 of the Santa Ana Municipal Code. d) Any commercial use permitted by Section 41‐377 of the Santa Ana Municipal Code. No structure shall exceed 45 feet in height, as measured from the lowest adjacent grade of a structure to the top of the structure. (1) 94 total parking spaces for the affordable residential component. (2) All commercial uses on the entire project site shall be parked at a rate of 1 space per 300 square feet of gross floor area. (3) Prior to occupancy a parking management plan shall be submitted to the Planning Division for review, identifying parking per unit, services provider parking and guest parking. The plan is subject to approval of the Planning Manager. Tiny Tim Plaza (Not Developed)
Page 21 of 21
From:Bernal, Sarah
Bcc:Angie Cano; Cynthia Contreras-Leo; David Benavides; Eric Alderete; Kenneth Nguyen; Lynnette Verino; Mark
McLoughlin
Subject:PUBLIC COMMENT_2525 N Main Street_JANIS
Date:Monday, January 07, 2019 9:06:35 AM
The below communication pertaining to an item to be considered by Planning Commission, has been
received for your review and consideration.
Sarah Bernal
Phone: 714-667-2732
City of Santa Ana, Planning and Building Agency
20 Civic Center Plaza, Santa Ana, CA 92702
City Hall is closed every other Friday. Click here for dates.
P Please consider the environment before printing this email. Thank you
From: joseph janis <oldcorps@att.net>
Sent: Sunday, January 6, 2019 7:49 PM
To: eComment <eComment@santa-ana.org>
Subject: Fw: High Density Apartment Devlopment at 2525 N Main st
Having lived in NE Santa Ana for 49 years, I submit that the consideration to approve this development
will cause a tremendous traffic problem the likes that one cannot comprehend. I believe that a traffic flow
analysis shall show that such development is not feasible and certainly not in the best interests of the
Neighborhoods involved nor a good way to build our Santa Ana Community. Thank you for your time and
consideration in this matter.
Very respectfully,
J.J.Janis
814 E 20th St
Santa Ana
January 09, 2019
To The Planning Commission,
My wife and I wholeheartedly support the proposed zoning change and the development at 2525 North
Main Street, now known as The Addington. We have lived in Park Santiago since 1992 and have lived in
Santa Ana since 1978. Our children walked to their nearby Hoover Elementary School. My wife recently
retired from SAUSD. She taught 2nd and 3rd grades at Jefferson Elementary School. My first job as an
architect was on Main Street at GPRA at a building that was later replaced by Ralph Allen’s building. We
both know our City well and have seen it grow and struggle over the years.
I was the project architect on the Stadium Parking Structure and the Library Parking Structure while I
worked for IBI Group. I was proud of the two Santa Ana parking structures that garnered AIA Honor
Awards. I am also a past President of the Park Santiago Neighborhood Association. I continued
involvement with the neighborhood as a member of the Park Committee. In that committee I was
instrumental in gathering and leading a group of designers to develop a conceptual design for Santiago
Park. With neighborhood input we submitted our design to the Park Department head, Ron Ono. That
conceptual design included the introduction of a bridge from the play area to the north side of the park.
The City implemented parts of the design. We are hopeful the City completes the vision that was started
quite a few years ago.
We continue to support this City and we believe that Main Street needs to be a vibrant economically
sound artery. There are many reasons that the development at 2525 Main Street is worthwhile. The City
needs to grow its tax base, we all know. This development will attract other businesses and support the
businesses that already exist. We want to have many more opportunities to walk to without having to get
in our car. Santa Ana needs a Main Street that is attractive, exciting and active like the ones in Anaheim,
Fullerton, Irvine and Huntington Beach.
Many cities with single family housing have been enriched with added dense adjacent developments on
its edges and have seen large increases in property values. Park Santiago neighborhood property values
would benefit from high end dense residential that is attractive and with loads of amenities. The same
development would benefit Main Place and the surrounding restaurants and other businesses to continue
making Main Street vibrant. We believe the development would benefit the neighborhood we live in. But
this development is also about all of Santa Ana not just about one neighborhood. The Addington would
benefit all of the City’s residents, not just my neighbors.
Traffic will continue to increase regardless. All the growth that will occur in this City and neighboring
cities will increase traffic on Main Street. That is a given. Even if this development does not occur, traffic
will occur. That is the nature of traffic and growth. Unfortunately we are behind on developing mass
transit that will have to happen one day. As usual we do not plan until the crisis gets everyone on board.
It would be nice to see walk-up units along Edgewood and along the Santiago Park side. Walk-up units
would create a more attractive street than fences, would help create a better residential scale on the street
frontages, would bring added eyes and ears to keep the streets and park safe and would better integrate the
residents together as a neighborhood instead of keeping them apart. Especially since even our own
children may live there next to us.
Please approve the zoning change and this development.
Thank you
Lewis and Jeanette Wood
2522 North Poinsettia Street
Santa Ana CA 92706-1725
January 7, 2019
Honorable Planning Commission
City of Santa Ana
PO Box 1988
Santa Ana, CA 92702
RE: 2525 N. Main Street
Dear Chairman and Commissioners:
With the upcoming hearing and associated decision which will impact the future of the
City of Santa Ana, its citizens and the residents of Park Santiago, I hope that you have
had the opportunity to review all the project materials and public comments and have
taken to heart the ongoing testimony at the public hearings.
As a person who has spent my career in land development (primarily residential), I have
been in the developer’s shoes and now I am on the other side. I believe I can
professionally see both sides unbiasedly and look at the overall possible merits and
potential problems of the proposed project. I’ve always believed development is a
balance and I understand that this proposed project is a fine balance between
development and fees.
I am not opposed to development at this location – development which follows good
planning guidelines using honesty in analyzing the project and in the project
documentation.
In my professional opinion, this is not the case with the proposed project. There are
obvious errors and gross negligence in the methodology used in analyzing the project
and therefore, the documents produced are flawed and surely challengeable under
CEQA.
At the proposed density, the project does not fit at this location.
In order to protect the City of Santa Ana as good stewards, I urge the Planning
Commission to do the following:
• Deny the project as currently proposed by the Applicant with 84/DUA (496 units)
• Deny the Staff Report of 81/DUA (476 units)
• Request the Applicant and Staff to redesign the project to less than 38/DUA
(30/DUA would be a more "reasonable" number of DUAs which the location
can support), along with a combination of 2 and 3 stories, 3 stories orientated
Page 2
City of Santa Ana Planning Commission
January 7, 2019
along Main Street and the north side of Santiago Park and 2 stories adjacent to
the existing single family homes along Edgewood and the eastern
boundary/Spurgeon, 25’ setback along Edgewood Road, 90’ setback along the
eastern property line, minimum of 2 parking spaces per unit and architecture of
Spanish/Mission/Monterey style.
Again, thank you for your ongoing service to the City of Santa Ana. I know that you will
also conclude that the correct option for this property is to reduce the density and
intensity to 30/DUA which is much more compatible with the existing historic single
family, primarily single-story neighborhood of Park Santiago.
Respectfully Submitted,
Diane Fradkin
Diane Fradkin
2402 N. Oakmont Ave
Park Santiago
714-914-8047
cc: Minh Thai
Selena Kelaher
Vince Fregoso
City of Santa Ana
RE: Opposing 2525 Main St. Development
City of Santa Ana Planning Commissioners:
I am a homeowner in the Park Santiago Neighborhood. Santa Ana is an already dense city and
does not need any more market-rate housing. As a Planning Commission, part of your job is to
ensure there exists an overall plan for the City of Santa Ana that is not driven by developer
interests but by community interests.
I chose Park Santiago because of its character and its pedestrian friendly streets. It is one of the
only neighborhoods in Santa Ana that offers this, which is why my family and I chose this
specific neighborhood. If you move forward with this project, you are taking away the character
of Park Santiago. The built environment affects the quality of life of its residents and the 2525
Main Street would only further strain the already inadequate roadways in Santa Ana, including
Main Street, which is a congested artery already.
The Planning Commission should reject the EIR and should give a “No” recommendation to
Council. There should not be a Development Agreement and it should also reject the zoning
amendments. All of these are subsidies that are being given away to the developer with zero
tangible community benefits to the residents of Park Santiago and to the residents of Santa
Ana. Santa Ana needs more green space, community gardens, it does not need another
apartment building that would bring in an entire population.
If the Planning Commission approves this project, you are forcing the residents to reassess
whether they want to call City of Santa Ana home. I want to live in a well-planned, diverse city
where community interests are taken into account. But the lack of cohesive planning and the
lack of transparency in the planning process in the City of Santa Ana is astounding. Our family
would reconsider whether we would want to stay in the City of Santa Ana and most likely would
not since we know that this project would negatively alter the character of Park Santiago and
would create horrible parking issues and cars cutting through the neighborhood.
I strongly oppose this project.
Respectfully,
Flor Barajas-Tena
2015 Valencia Street
Santa Ana, CA 92706
Via Email and Hand Delivery
November 26, 2018
Planning Commission
c/o Selena Kelaher, AICP
City of Santa Ana
Planning and Building Agency | M20
20 Civic Center Plaza
Santa Ana, CA 92702
skelaher@santa-ana.org
Minh Thai, Executive Director
City of Santa Ana
Planning and Building Agency | M20
20 Civic Center Plaza
Santa Ana, CA 92702
mthai@santa-ana.org
Raul Godinez, City Manager
City of Santa Ana
City Manager’s Office
20 Civic Center Plaza, 8th Floor
Santa Ana, CA 92701
rgodinez@santa-ana.org
Re: Comment on Final Environmental Impact Report, 2525 N. Main
Street Multi-Family Residential Project (aka Magnolia at the Park)
SCH 2018021031, DP No. 2017-34
Honorable Members of the Planning Commission, Ms. Thai, Mr. Godinez and Ms.
Kelaher:
I am writing on behalf of the Laborers International Union of North America,
Local Union No. 652 and its members living in and near the City of Santa Ana
(“LIUNA”), regarding the Draft Environmental Impact Report (“DEIR”) and Final
Environmental Impact Report (“FEIR”) prepared for the Project known as 2525 N.
Main Street Multi-Family Residential Project (aka Magnolia at the Park) SCH
2018021031, DP No. 2017-34, including all actions related or referring to the
proposed project that would demolish the existing 81,172 square foot vacant two-
story office building and 442 space surface parking lot to redevelop the 5.93-acre
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 2
site with 405,290 square feet of residential buildings that would provide 496 market-
rate multi-family residential units located at 2525 North (N.) Main Street, in the
northern portion of the City of Santa Ana approximately 500 feet east of Interstate 5
(I-5) (“Project”).
After reviewing the DEIR and FEIR (collectively, “EIR”), we conclude that the
EIR fails as an informational document and fails to impose all feasible mitigation
measures to reduce the Project’s impacts. Commenters request that the Planning
and Building Agency address these shortcomings in a revised draft environmental
impact report (“RDEIR”) and recirculate the RDEIR prior to considering approvals for
the Project. We reserve the right to supplement these comments during review of
the Final EIR for the Project and at public hearings concerning the Project. Galante
Vineyards v. Monterey Peninsula Water Management Dist., 60 Cal. App. 4th 1109,
1121 (1997).
PROJECT DESCRIPTION
The Project would demolish the existing 81,172 square foot vacant two-story
office building and 442 space surface parking lot to redevelop the 5.93-acre site with
405,290 square feet of residential buildings that would provide 496 multi-family
rental residential units. The Project would provide only market-rate housing, with no
units designated for low or moderate income residents. Of the units, 77 percent
would be studios or one-bedroom units, 18 percent would be two-bedroom units,
and 6 percent would be three-bedroom units. The residences would be provided
within 5-story buildings topped with mezzanines that would be approximately 65-feet
in height along the western and central portion of the site; and would tier down to 2-
story, approximately 20-foot high structures on the eastern portion of the site. The
residential units would be wrapped around a central parking structure that would
have 8-levels of parking above ground, and 1 level of underground parking. The
parking structure would be located in the west central portion of the project site and
would provide direct access to the leasing office and walkways to residential units.
The proposed project would require the following discretionary approvals from
the City of Santa Ana:
General Plan Amendment (GPA) Land Use Change from PAO (Professional
& Administration Office) to a District Center (DC) designation
Amendment Application (AA) for a zone change from Professional (P) to a
Specific Development (SD) designation
Development Agreement
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 3
LEGAL STANDARD
CEQA requires that an agency analyze the potential environmental impacts of
its proposed actions in an environmental impact report (“EIR”) (except in certain
limited circumstances). See, e.g., Pub. Res. Code § 21100. The EIR is the very heart
of CEQA. Dunn-Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652. “The ‘foremost
principle’ in interpreting CEQA is that the Legislature intended the act to be read so
as to afford the fullest possible protection to the environment within the reasonable
scope of the statutory language.” Comms. for a Better Env’t v. Calif. Resources
Agency (2002) 103 Cal. App. 4th 98, 109.
CEQA has two primary purposes. First, CEQA is designed to inform decision
makers and the public about the potential, significant environmental effects of a
project. 14 Cal. Code Regs. (“CEQA Guidelines”) § 15002(a)(1). “Its purpose is to
inform the public and its responsible officials of the environmental consequences of
their decisions before they are made. Thus, the EIR ‘protects not only the
environment but also informed self-government.’” Citizens of Goleta Valley v. Board
of Supervisors (1990) 52 Cal.3d 553, 564. The EIR has been described as “an
environmental ‘alarm bell’ whose purpose it is to alert the public and its responsible
officials to environmental changes before they have reached ecological points of no
return.” Berkeley Keep Jets Over the Bay v. Bd. of Port Comm’rs. (2001) 91 Cal.
App. 4th 1344, 1354 (“Berkeley Jets”); County of Inyo v. Yorty (1973) 32 Cal.App.3d
795, 810.
Second, CEQA requires public agencies to avoid or reduce environmental
damage when “feasible” by requiring “environmentally superior” alternatives and all
feasible mitigation measures. CEQA Guidelines § 15002(a)(2) and (3); see also
Berkeley Jets, 91 Cal. App. 4th 1344, 1354; Citizens of Goleta Valley v. Board of
Supervisors (1990) 52 Cal.3d 553, 564. The EIR serves to provide agencies and the
public with information about the environmental impacts of a proposed project and to
“identify ways that environmental damage can be avoided or significantly reduced.”
CEQA Guidelines §15002(a)(2). If the project will have a significant effect on the
environment, the agency may approve the project only if it finds that it has
“eliminated or substantially lessened all significant effects on the environment where
feasible” and that any unavoidable significant effects on the environment are
“acceptable due to overriding concerns.” Pub.Res.Code (“PRC”) § 21081; CEQA
Guidelines § 15092(b)(2)(A) & (B).
The EIR is the very heart of CEQA. Dunn-Edwards v. BAAQMD (1992) 9
Cal.App.4th 644, 652. CEQA requires that a lead agency analyze all potentially
significant environmental impacts of its proposed actions in an EIR. PRC §
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 4
21100(b)(1); CEQA Guidelines § 15126(a); Berkeley Jets, 91 Cal.App.4th 1344,
1354. The EIR must not only identify the impacts, but must also provide “information
about how adverse the impacts will be.” Santiago County Water Dist. v. County of
Orange (1981) 118 Cal.App.3d 818, 831. The lead agency may deem a particular
impact to be insignificant only if it produces rigorous analysis and concrete
substantial evidence justifying the finding. Kings County Farm Bureau v. City of
Hanford (1990) 221 Cal.App.3d 692. “The ‘foremost principle’ in interpreting CEQA
is that the Legislature intended the act to be read so as to afford the fullest possible
protection to the environment within the reasonable scope of the statutory
language.” Communities for a Better Env’t v. Calif. Resources Agency (2002) 103
Cal.App.4th 98, 109.
While the courts review an EIR using an “abuse of discretion” standard, “the
reviewing court is not to ‘uncritically rely on every study or analysis presented by a
project proponent in support of its position. A ‘clearly inadequate or unsupported
study is entitled to no judicial deference.’” Berkeley Jets, 91 Cal. App. 4th 1344,
1355 (emphasis added), quoting, Laurel Heights Improvement Assn. v. Regents of
Univ. of Cal. (1988) 47 Cal.3d 376, 391 409, fn. 12. A prejudicial abuse of discretion
occurs “if the failure to include relevant information precludes informed
decisionmaking and informed public participation, thereby thwarting the statutory
goals of the EIR process.” San Joaquin Raptor/Wildlife Rescue Center v. County of
Stanislaus (1994) 27 Cal. App. 4th 713, 722]; Galante Vineyards v. Monterey
Peninsula Water Management Dist. (1997) 60 Cal. App. 4th 1109, 1117; County of
Amador v. El Dorado County Water Agency (1999) 76 Cal. App. 4th 931, 946.
The lead agency must evaluate comments on the draft EIR and prepare
written responses in the final EIR (“FEIR”). (PRC §21091(d)) The FEIR must
include a “detailed” written response to all “significant environmental issues” raised
by commenters. As the court stated in City of Long Beach v. LA USD (2009) 176
Cal.App.4th 889, 904:
The requirement of a detailed written response to comments helps to ensure
that the lead agency will fully consider the environmental consequences of a
decision before it is made, that the decision is well informed and open to
public scrutiny, and that public participation in the environmental review
process is meaningful.
The FEIR’s responses to comments must be detailed and must provide a
reasoned, good faith analysis. (14 CCR §15088(c )) Failure to provide a
substantive response to comment render the EIR legally inadequate. (Rural Land
Owners Assoc. v. City Council (1983) 143 Cal.App.3d 1013, 1020)
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 5
The responses to comments on a draft EIR must state reasons for rejecting
suggested mitigation measures and comments on significant environmental issues.
“Conclusory statements unsupported by factual information” are not an adequate
response. (14 CCR §15088(b, c); Cleary v. County of Stanislaus (1981) 118
Cal.App.3rd 348) The need for substantive, detailed response is particularly
appropriate when comments have been raised by experts or other agencies.
(Berkeley Keep Jets v. Bd. of Port Comm’rs (2001) 91 Cal.App.4th 1344, 1367;
People v. Kern (1976) 72 Cal.app.3d 761) A reasoned analysis of the issue and
references to supporting evidence are required for substantive comments raised.
(Calif. Oak Found. v. Santa Clarita (2005) 133 Cal.App.4th 1219)
The FEIR abjectly fails to meet these legal standards, as it is riddled with
conclusory statements lacking any factual support or analysis.
DISCUSSION
1. The EIR Fails to Analyze Indoor Air Quality Impacts.
We submit herewith the comments of indoor air quality expert, Francis
Offermann, PE, CIH. (Exhibit A). Mr. Offermann, a Certified Industrial Hygienist,
concludes that it is likely that the Project will expose future residents to significant
impacts related to indoor air quality, and in particular, emissions for the cancer-
causing chemical formaldehyde. Mr. Offermann is one of the world’s leading experts
on indoor air quality and has published extensively on the topic.
Mr. Offermann explains that many composite wood products typically used in
modern home construction contain formaldehyde-based glues which off-gas
formaldehyde over a very long time period. He states, “The primary source
formaldehyde indoors is composite wood products manufactured with urea-
formaldehyde resins, such as plywood, medium density fiberboard, and particle
board. These materials are commonly used in residential building construction for
flooring, cabinetry, baseboards, window shades, interior doors, and window and
door trims.”
Formaldehyde is a known human carcinogen. Mr. Offermann states that
there is a fair argument that residents of the Project will be exposed to a cancer risk
from formaldehyde of approximately 180 per million. This is far above the South
Coast Air Quality Management District (SCAQMD) CEQA significance threshold for
airborne cancer risk of 10 per million.
Even if the Project uses modern “CARB-compliant” materials, Mr. Offermann
concludes that formaldehyde will create a cancer risk of 126 per million, which is
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 6
more than ten times above the SCAQMD CEQA significance threshold. Mr.
Offermann concludes that this significant environmental impact should be analyzed
in an EIR and mitigation measures should be imposed to reduce the risk of
formaldehyde exposure.
When a Project exceeds a duly adopted CEQA significance threshold, as
here, this alone establishes a fair argument that the project will have a significant
adverse environmental impact and an EIR is required. Indeed, in many instances,
such air quality thresholds are the only criteria reviewed and treated as dispositive in
evaluating the significance of a project’s air quality impacts. See, e.g. Schenck v.
County of Sonoma (2011) 198 Cal.App.4th 949, 960 (County applies BAAQMD’s
“published CEQA quantitative criteria” and “threshold level of cumulative
significance”). See also Communities for a Better Environment v. California
Resources Agency (2002) 103 Cal.App.4th 98, 110-111 (“A ‘threshold of
significance’ for a given environmental effect is simply that level at which the lead
agency finds the effects of the project to be significant”). The California Supreme
Court made clear the substantial importance that an air district significance threshold
plays in providing substantial evidence of a significant adverse impact. Communities
for a Better Environment v. South Coast Air Quality Management Dist. (2010) 48
Cal.4th 310, 327 (“As the [South Coast Air Quality Management] District’s
established significance threshold for NOx is 55 pounds per day, these estimates [of
NOx emissions of 201 to 456 pounds per day] constitute substantial evidence
supporting a fair argument for a significant adverse impact”). Since expert evidence
demonstrates that the Project will exceed the BAAQMD’s CEQA significance
threshold, there is a fair argument that the Project will have significant adverse and
an EIR is required.
Mr. Offermann suggests several feasible mitigation measures, such as
requiring the use of no-added-formaldehyde composite wood products, which are
readily available. Mr. Offermann also suggests requiring air ventilation systems
which would reduce formaldehyde levels. Since the EIR does not analyze this
impact at all, none of these or other mitigation measures are considered.
2. The EIR Fails to Address or Adequately Mitigate Significant Soil
Contamination Impacts.
The California Department of Toxic Substances Control (“DTSC”) has
submitted a comment letter pointing out deficiencies in the EIR related to soil and
groundwater contamination at the Project site. DTSC points out that soil and
groundwater at the Project site contains levels of the cancer-causing and toxic
chemicals, benene, toluene, ethylbenzene, xylene and methyl-tertiary butyl ether
(MTBE) above residential standards. DTSC commented that the EIR failed to
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 7
analyze the possibility of soil-vapor intrusion – a process by which toxic vapors enter
the building constructed on the contaminated soil. DTSC also pointed out that the
soil on the Project site is contaminated with arsenic – a known human carcinogen.
In both cases, the EIR dismissed DTSC’s comments, failed to conduct
additional analysis and failed to adopt adequate mitigation measures. This is a
patently inadequate response to expert comments from a State Agency. A Revised
DEIR is required to analyze these impacts and to respond to DTSC’s comments.
In response to DTSC’s comments, the FEIR merely states that a soil
mitigation plan will be developed at a later time. CEQA does not allow such deferral
of mitigation. Mitigation measures must be set forth in the EIR, so that the public
can analyze the adequacy of the mitigation measures. The EIR fails to comply with
this requirement.
Feasible mitigation measures for significant environmental effects must be set
forth in an EIR for consideration by the lead agency's decision makers and the public
before certification of the EIR and approval of a project. The formulation of mitigation
measures generally cannot be deferred until after certification of the EIR and
approval of a project. Guidelines, section 15126.4(a)(1)(B) states: "Formulation of
mitigation measures should not be deferred until some future time. However,
measures may specify performance standards which would mitigate the significant
effect of the project and which may be accomplished in more than one specified
way." "A study conducted after approval of a project will inevitably have a diminished
influence on decisionmaking. Even if the study is subject to administrative approval,
it is analogous to the sort of post hoc rationalization of agency actions that has been
repeatedly condemned in decisions construing CEQA." (Sundstrom v. County of
Mendocino (1988) 202 Cal.App.3d 296, 307.) "[R]eliance on tentative plans for future
mitigation after completion of the CEQA process significantly undermines CEQA's
goals of full disclosure and informed decisionmaking; and[,] consequently, these
mitigation plans have been overturned on judicial review as constituting improper
deferral of environmental assessment." (Communities for a Better Environment v.
City of Richmond (2010) 184 Cal.App.4th 70, 92.)
LIUNA is very concerned about the soil contamination identified by DTSC.
Construction workers, such as LIUNA members, will be exposed to higher levels of
soil and groundwater contamination than anyone else since they will be involved in
direct excavation of potentially contaminated soil and groundwater. It is critical to
LIUNA that adequate mitigation measures be identified prior to Project construction,
not after contaminated soil is discovered.
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 8
3. The EIR Fails to Adequately Mitigate the Project’s Significant Traffic
Impacts.
CalTrans has submitted at least two comment letters concluding that the EIR
fails to adequately analyze and mitigate the Project’s significant traffic impacts. In
particular, CalTrans expressed concern over the Project’s impacts on nearby I-5 and
SR22. In CalTrans’ second comment letter, the agency concluded that the FEIR
failed to adequately respond to CalTrans’ initial comments. The FEIR’s dismissive
response to an expert agency’s comments itself renders the EIR legally inadequate.
Furthermore, the EIR improperly abrogates responsibility for mitigating the
Project’s traffic impacts. The EIR states that CalTrans has authority to adopt certain
mitigation measures, and as a result, the City of Santa Ana would not adopt or
impose mitigation. CEQA does not allow the lead agency to abrogate its
responsibility to mitigate significant impacts, even if those impacts are within the
jurisdiction of another agency. The lead agency is responsible for ensuring that
impacts are mitigated, even if it is necessary to cooperate with other responsible
agencies. In Lexington Hills v. State of Calif. (1988) 200 Cal.App.3d 415, the court
held that a CEQA lead agency cannot delegate responsibility to develop mitigation
measures to a responsible agency, even if the responsible agency has more
expertise in a particular area. The lead agency must use its authority to analyze the
entire project and to devise mitigation measures. Id. at 433-435. See also, Citizens
for Quality Growth v. City of Mount Shasta (1988) 198 Cal.App.3d 433, 443 (Lead
agency cannot refrain from considering means of exercising its own regulatory
power simply because another agency has general authority over the impacted
natural resource. City could not delegate mitigation measure development for
project impacts to wetlands to US Army Corps of Engineers).
4. The Project Lacks Affordable Housing in Conflict with the General
Plan.
The Project does not include any affordable housing units, in complete
disregard of the applicable General Plan policies. All of the rental units will be
market-rate, and none will be designated or deed-restricted for low or moderate
income residents. This is of particular concern to LIUNA members who are
increasingly priced out of the area.
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 9
The General Plan Housing Element Policy 2.3 requires housing for all income
levels. Yet, the Project includes only market-rate housing, with not a single unit set
aside for low or moderate income residents. This is unacceptable given the area’s
extreme shortage of affordable housing. Furthermore, the EIR does not analyze
whether it is feasible to include income-restricted housing, as has been done
throughout the State.
The Final EIR rejects comments made concerning affordable housing,
arguing that the issue is socio-economic and not environmental, and therefore not
within the scope of CEQA. This is mistaken. It is well-established that urban decay
is a CEQA issue. The lack of affordable housing has led to an increase in
homelessness, which is a prime contributor to urban decay. In Bakersfield Citizens
for Local Control v. City of Bakersfield (2004) (124 Cal.App.4th 1184) (Bakersfield
Citizens), the court expressly held that an EIR must analyze a project’s potential to
cause urban decay if there is substantial evidence showing that the project may lead
to such impacts. The court pointed out that CEQA requires the project proponent to
discuss the project’s economic and social impacts where “[a]n EIR may trace a chain
of cause and effect from a proposed decision on a project through anticipated
economic or social changes resulting from the project to physical changes caused in
turn by the economic and social changes.” (CEQA Guidelines §§ 15131(a) and
15064(f).)
Where a local or regional policy of general applicability, such as an ordinance,
is adopted in order to avoid or mitigate environmental effects, a conflict with that
policy in itself indicates a potentially significant impact on the environment. (Pocket
Protectors v. Sacramento (2005) 124 Cal.App.4th 903.) Indeed, any inconsistencies
between a proposed project and applicable plans must be discussed in an EIR. (14
CCR § 15125(d); City of Long Beach v. Los Angeles Unif. School Dist. (2009) 176
Cal. App. 4th 889, 918; Friends of the Eel River v. Sonoma County Water Agency
(2003) 108 Cal. App. 4th 859, 874 (EIR inadequate when Lead Agency failed to
identify relationship of project to relevant local plans).) A Project’s inconsistencies
with local plans and policies constitute significant impacts under CEQA.
(Endangered Habitats League, Inc. v. County of Orange (2005) 131 Cal.App.4th
777, 783-4, 32 Cal.Rptr.3d 177; see also, County of El Dorado v. Dept. of Transp.
(2005) 133 Cal.App.4th 1376 (fact that a project may be consistent with a plan, such
as an air plan, does not necessarily mean that it does not have significant impacts).)
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 10
A Recirculated Draft EIR should be prepared to analyze the impacts of the
Project’s lack of affordable housing and the impact on urban decay. It should
propose feasible mitigation measures, such as requiring more affordable housing in
the Project, contributions to low-income housing funding, etc.
5. The EIR Fails to Adequately Analyze or Mitigate the Project’
Significant Air Quality Impacts.
The expert consulting firm, Soil, Water, Air Protection Enterprise (SWAPE),
demonstrates that the EIR improperly calculates air quality impacts. SWAPE
calculates that the Project will have highly significant airborne cancer risk impacts,
far above CEQA significance thresholds. SWAPE calculates that the Project will
create an airborne cancer risk from construction and operation of the Project of 220
per million – far above the SCAQMD CEQA significance threshold of 10 per million.
Most of this cancer risk is created by diesel engine exhaust associated with
construction and operation of the Project.
SWAPE states:
As demonstrated above, the excess cancer risk to adults, children, infants,
and 3rd trimester gestations at a sensitive receptor located approximately 25
meters away, over the course of Project construction and operation, are
approximately 10, 92, 110, and 5.5 in one million, respectively. Furthermore,
the excess cancer risk over the course of a residential lifetime (30 years) is
approximately 220 in one million. Consistent with OEHHA guidance, exposure
was assumed to begin in the 3rd trimester stage of pregnancy to provide the
most conservative estimates of air quality hazards. The infantile, child, adult,
and lifetime cancer risks all exceed the SCAQMD’s threshold of 10 in one
million, thus resulting in a potentially significant impact not previously
addressed or identified by the DEIR or FEIR.
The EIR also conducts a different health risk assessment that allegedly
shows a cancer risk less than 10 per million. However, the HRA used in the EIR
fails to comply with the recent California Office of Environmental Health Hazard
Assessment (OEHHA) methodology. The lead agency is required to use the
November 26, 2018
Comment on Environmental Impact Report, 2525 N. Main Street Multi-Family Residential Project
(aka Magnolia at the Park) SCH 2018021031, DP No. 2017-34
page 11
agency-approved methodology, not some other obsolete methodology. Endangered
Habitats League v. Orange (2005) 131 Cal.App.4th 777.
Since the Project will create significant airborne cancer risks, a Revised Draft
EIR is required to analyze this risk and propose all feasible mitigation measures.
CONCLUSION
For the foregoing reasons, and for the reasons set forth by other commenters
(which are incorporated herein by reference), the EIR for the Project is legally
inadequate. A revised draft EIR is required to analyze and mitigate the proposed
Project’s significant impacts.
Sincerely,
Richard Drury
EXHIBIT A
INDOOR ENVIRONMENTAL ENGINEERING
1448 Pine Street, Suite 103 San Francisco, California 94109
Telephone: (415) 567-7700
E-mail: offermann@IEE-SF.com
http://www.iee-sf.com
Date: November 21, 2018
To: Richard T. Drury
Lozeau | Drury LLP
410 12th Street, Suite 250
Oakland, California 94607
From: Francis J. Offermann PE CIH
Subject: Indoor Air Quality: Magnolia at the Park - Santa Ana
IEE File Reference: P-4198
Pages: 10
Indoor Air Quality Impacts
Indoor air quality (IAQ) directly impacts the comfort and health of building occupants, and
the achievement of acceptable IAQ in newly constructed and renovated buildings is a well-
recognized design objective. For example, IAQ is addressed by major high-performance
building rating systems and building codes (California Building Standards Commission,
2014; USGBC, 2014). Indoor air quality in homes is particularly important because
occupants, on average, spend approximately ninety percent of their time indoors with the
majority of this time spent at home (EPA, 2011). Some segments of the population that are
most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy
their homes almost continuously. Additionally, an increasing number of adults are working
from home at least some of the time during the workweek. Indoor air quality also is a
serious concern for workers in hotels, offices and other business establishments.
The concentrations of many air pollutants often are elevated in homes and other buildings
relative to outdoor air because many of the materials and products used indoors contain
and release a variety of pollutants to air (Hodgson et al., 2002; Offermann and Hodgson,
2
2011). With respect to indoor air contaminants for which inhalation is the primary route of
exposure, the critical design and construction parameters are the provision of adequate
ventilation and the reduction of indoor sources of the contaminants.
Indoor Formaldehyde Concentrations Impact. In the California New Home Study (CNHS)
of 108 new homes in California (Offermann, 2009), 25 air contaminants were measured,
and formaldehyde was identified as the indoor air contaminant with the highest cancer risk
as determined by the California Proposition 65 Safe Harbor Levels (OEHHA, 2017), No
Significant Risk Levels (NSRL) for carcinogens. The NSRL is the daily intake level
calculated to result in one excess case of cancer in an exposed population of 100,000 (i.e.,
ten in one million cancer risk) and for formaldehyde is 40 µg/day. The NSRL concentration
of formaldehyde that represents a daily dose of 40 µg is 2 µg/m3, assuming a continuous
24-hour exposure, a total daily inhaled air volume of 20 m3, and 100% absorption by the
respiratory system. All of the CNHS homes exceeded this NSRL concentration of 2 µg/m3.
The median indoor formaldehyde concentration was 36 µg/m3, and ranged from 4.8 to 136
µg/m3, which corresponds to a median exceedance of the 2 µg/m3 NSRL concentration of
18 and a range of 2.3 to 68.
Therefore, the cancer risk of a resident living in a California home with the median indoor
formaldehyde concentration of 36 µg/m3, is 180 per million as a result of formaldehyde
alone. Assuming this project will be built using typical materials and construction methods
used in California, there is a fair argument that future residents will experience a cancer risk
from formaldehyde of approximately 180 per million. The CEQA significance threshold
for airborne cancer risk is 10 per million, as established by the South Coast Air Quality
Management District (SCAQMD, 2015). There is a fair argument that this project will
expose future residents to a significant airborne cancer risk of 180 per million, which is 18
times above the CEQA significance threshold. This impact should be analyzed in an
environmental impact report (“EIR”), and the agency should impose all feasible mitigation
measures to reduce this impact. Several feasible mitigation measures are discussed below
and these and other measures should be analyzed in an EIR.
3
Besides being a human carcinogen, formaldehyde is also a potent eye and respiratory
irritant. In the CNHS, many homes exceeded the non-cancer reference exposure levels
(RELs) prescribed by California Office of Environmental Health Hazard Assessment
(OEHHA, 2017). The percentage of homes exceeding the RELs ranged from 98% for the
Chronic REL of 9 µg/m3 to 28% for the Acute REL of 55 µg/m3.
The primary source of formaldehyde indoors is composite wood products manufactured
with urea-formaldehyde resins, such as plywood, medium density fiberboard, and particle
board. These materials are commonly used in residential building construction for flooring,
cabinetry, baseboards, window shades, interior doors, and window and door trims.
In January 2009, the California Air Resources Board (CARB) adopted an airborne toxics
control measure (ATCM) to reduce formaldehyde emissions from composite wood
products, including hardwood plywood, particleboard, medium density fiberboard, and also
furniture and other finished products made with these wood products (California Air
Resources Board 2009). While this formaldehyde ATCM has resulted in reduced emissions
from composite wood products sold in California, they do not preclude that homes built
with composite wood products meeting the CARB ATCM will have indoor formaldehyde
concentrations that are below cancer and non-cancer exposure guidelines.
A follow up study to the California New Home Study (CNHS) was conducted in 2016-2018
(Chan et. al., 2018), and found that the median indoor formaldehyde in new homes built
after the 2009 CARB formaldehyde ATCM had lower indoor formaldehyde concentrations,
with a median indoor concentrations of 25 µg/m3 as compared to a median of 36 µg/m3
found in the 2007 CNHS.
Thus, while new homes built after the 2009 CARB formaldehyde ATCM have a 30% lower
median indoor formaldehyde concentration and cancer risk, the median lifetime cancer risk
is still 125 per million for homes built with CARB compliant composite wood products
which is more than 12 times the NSRL 10 in a million cancer risk.
Assuming that the residential dwelling units for this project are constructed with CARB
4
Phase 2 Formaldehyde ATCM materials, and are ventilated with the minimum code
required amounts of outdoor air, the indoor formaldehyde concentrations are likely similar
to those concentrations observed in residences built with CARB Phase 2 Formaldehyde
ATCM materials (Chan et. al., 2018), which is a median of 25 µg/m3.
For the occupants of these residential dwelling units, they will potentially have continuous
exposure (e.g. 24 hours per day, 52 weeks per year) and assuming inhalation of 20 m3 of
indoor air per day, the average 70-year lifetime formaldehyde daily dose is 500 µg/day.
This exposure represents a cancer risk of 125 per million, which is more than 12 times the
CEQA cancer risk of 10 per million.
Outdoor Air Ventilation Impact. Another important finding of the CNHS, was that the
outdoor air ventilation rates in the homes were very low. Outdoor air ventilation is a very
important factor influencing the indoor concentrations of air contaminants, as it is the
primary removal mechanism of all indoor air generated air contaminants. Lower outdoor air
exchange rates cause indoor generated air contaminants to accumulate to higher indoor air
concentrations. Many homeowners rarely open their windows or doors for ventilation as a
result of their concerns for security/safety, noise, dust, and odor concerns (Price, 2007). In
the CNHS field study, 32% of the homes did not use their windows during the 24‐hour Test
Day, and 15% of the homes did not use their windows during the entire preceding week.
Most of the homes with no window usage were homes in the winter field session. Thus, a
substantial percentage of homeowners never open their windows, especially in the winter
season. The median 24‐hour measurement was 0.26 ach, with a range of 0.09 ach to 5.3 ach.
A total of 67% of the homes had outdoor air exchange rates below the minimum California
Building Code (2001) requirement of 0.35 ach. Thus, the relatively tight envelope
construction, combined with the fact that many people never open their windows for
ventilation, results in homes with low outdoor air exchange rates and higher indoor air
contaminant concentrations.
The Magnolia at the Park project in Santa Ana is a multi-family residential project and is
located close to roads with high traffic (e.g. I-5 and SR-55), and as a result has been
5
determined to be a sound impacted site according to Noise Impact Analysis in Appendix H
of the Draft EIR (Urban Crossroads, 2018).
As a result of the high traffic related outdoor noise levels, the current project will require
the need for mechanical supply of outdoor air ventilation air to allow for a habitable interior
environment with closed windows and doors. Such a ventilation system would allow
windows and doors to be kept closed at the occupant’s discretion to control exterior noise
within residential interiors. This applies to both the residential and commercial portions of
this development.
PM2.5 Outdoor Concentrations Impact. An additional impact of the nearby motor vehicle
traffic associated with this project, are the increased outdoor concentrations of PM2.5. The
Health Risk Assessment Report for this project (Stantec, 2016), states in Table 6 that the
cancer risk from traffic is 21.1 per million, which exceeds the SCAQMD threshold of 10
per million.
San Francisco is a leader in issuing regulations to remove PM2.5 from impacted areas. The
San Francisco Department of Public Health, 2014. Article 38, Enhanced Ventilation
Required for Urban Infill Sensitive Use Developments, requires that air filtration, with a
minimum efficiency of MERV 13 be installed to remove PM2.5 from mechanically supplied
outdoor air in all PM2.5 impacted areas. All areas within 500 feet of any freeway or high-
traffic road way (defined as urban roads with 100,000 vehicles/day or rural roads with
50,000 vehicles/day), unless air dispersion modeling shows total (traffic and ambient)
outdoor concentrations of less than an annual average of 10 µg/m3 PM2.5, are defined as
PM2.5 impacted areas.
Santa Ana is an EPA non-attainment area for PM2.5., with exceedences of both the EPA
maximum annual average concentration of 12 µg/ m3 and the EPA maximum 24-hour
average of 35 µg/m3.
It is my experience that based on the projected high traffic noise level, the annual average
concentration of PM2.5 will be substantially higher than 10 µg/m3, and warrant installation
6
of MERV 13 air filters in all mechanically supplied outdoor air ventilation systems. This
applies to both the residential and commercial portions of this development.
Indoor Air Quality Impact Mitigation Measures
The following are recommended mitigation measures to minimize the impacts upon indoor
quality:
- indoor formaldehyde concentrations
- outdoor air ventilation
- PM2.5 outdoor air concentrations
Indoor Formaldehyde Concentrations Mitigation. Use only composite wood materials (e.g.
hardwood plywood, medium density fiberboard, particleboard) for all interior finish
systems that are made with CARB approved no-added formaldehyde (NAF) resins or ultra-
low emitting formaldehyde (ULEF) resins (CARB, 2009).
Outdoor Air Ventilation Mitigation. Provide each habitable room with a continuous
mechanical supply of outdoor air that meets or exceeds the California 2016 Building Energy
Efficiency Standards (California Energy Commission, 2015) requirements of the greater of
15 cfm/occupant or 0.15 cfm/ft2 of floor area. Following installation of the system conduct
testing and balancing to insure that required amount of outdoor air is entering each habitable
room and provide a written report documenting the outdoor air flow rates. Do not use
exhaust only mechanical outdoor air systems, use only balanced outdoor air supply and
exhaust systems or outdoor air supply only systems. Provide a manual for the occupants
(residential and commercial), that describes the purpose of the mechanical outdoor air
system and the operation and maintenance requirements of the system.
PM2.5 Outdoor Air Concentration Mitigation. Install air filtration with a minimum efficiency
of MERV 13 to filter the outdoor air entering the mechanical outdoor air supply system.
Install the air filters in the system such that they are accessible for replacement by the
7
occupants (residential and commercial). Include in the mechanical outdoor air ventilation
system manual instructions on how to replace the air filters and the estimated frequency of
replacement.
8
References
California Air Resources Board. 2009. Airborne Toxic Control Measure to Reduce
Formaldehyde Emissions from Composite Wood Products. California Environmental
Protection Agency, Sacramento, CA.
https://www.arb.ca.gov/regact/2007/compwood07/fro‐final.pdf
California Building Code. 2001. California Code of Regulations, Title 24, Part 2 Volume 1,
Appendix Chapter 12, Interior Environment, Division 1, Ventilation, Section 1207: 2001
California Building Code, California Building Standards Commission. Sacramento, CA.
California Building Standards Commission (2014). 2013 California Green Building
Standards Code. California Code of Regulations, Title 24, Part 11. California Building
Standards Commission, Sacramento, CA http://www.bsc.ca.gov/Home/CALGreen.aspx.
California Energy Commission, 2015. 2016 Building Energy Efficiency Standards for
Residential and Nonresidential Buildings, California Code of Regulations, Title 24, Part 6.
http://www.energy.ca.gov/2015publications/CEC-400-2015-037/CEC-400-2015-037-
CMF.pdf
Chan, W., Kim, Y., and Singer, B. 2018. Indoor Air Quality in New California Homes with
Mechanical Ventilation, Proceedings of Indoor Air 2018, Philadelphia, PA.
EPA. 2011. Exposure Factors Handbook: 2011 Edition, Chapter 16 – Activity Factors.
Report EPA/600/R-09/052F, September 2011. U.S. Environmental Protection Agency,
Washington, D.C.
Hodgson, A. T., D. Beal, J.E.R. McIlvaine. 2002. Sources of formaldehyde, other aldehydes
and terpenes in a new manufactured house. Indoor Air 12: 235–242.
9
OEHHA (Office of Environmental Health Hazard Assessment). 2017. Proposition 65 Safe
Harbor Levels. No Significant Risk Levels for Carcinogens and Maximum Allowable Dose
Levels for Chemicals Causing Reproductive Toxicity. Available at:
http://www.oehha.ca.gov/prop65/pdf/safeharbor081513.pdf
OEHHA - Office of Environmental Health Hazard Assessment. 2017. All OEHHA Acute,
8-hour and Chronic Reference Exposure Levels. Available at:
http://oehha.ca.gov/air/allrels.html
Offermann, F. J. 2009. Ventilation and Indoor Air Quality in New Homes. California Air
Resources Board and California Energy Commission, PIER Energy‐Related Environmental
Research Program. Collaborative Report. CEC‐500‐2009‐085.
https://www.arb.ca.gov/research/apr/past/04-310.pdf
Offermann, F. J. and A. T. Hodgson (2011). Emission Rates of Volatile Organic Compounds
in New Homes. Proceedings Indoor Air 2011 (12th International Conference on Indoor Air
Quality and Climate 2011). June 5-10, 2011, Austin, TX USA.
Price, Phillip P., Max Sherman, Robert H. Lee, and Thomas Piazza. 2007. Study of
Ventilation Practices and Household Characteristics in New California Homes. California
Energy Commission, PIER Program. CEC-500-2007-033. Final Report, ARB Contract 03-
326. Available at: www.arb.ca.gov/research/apr/past/03-326.pdf.
San Francisco Department of Public Health, 2014. Article 38, Enhanced Ventilation
Required for Urban Infill Sensitive Use Developments.
https://www.sfdph.org/dph/EH/Air/Article38.asp
South Coast Air Quality Management District (SCAQMD). 2015. California Environmental
Quality Act Air Quality Handbook. South Coast Air Quality Management District,
Diamond Bar, CA,http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-
handbook
10
Stantec Consulting Services. 2016. Health Risk Assessment Report AMG Development
Project, City of Santa Ana, CA.
Urban Crossroads. 2018. Magnolia at the Park Noise Impact Analysis City of Santa Ana.
Draft EIR, Appendix H.
USGBC. 2014. LEED BD+C Homes v4. U.S. Green Building Council, Washington, D.C.
http://www.usgbc.org/credits/homes/v4
EXHIBIT B
1
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887‐9013
November 20, 2018
Richard Drury
Lozeau Drury LLP
410 12th Street, Suite 250
Oakland, CA 94607
Subject: Comments on the Magnolia at the Park Multi‐Family Residential Project
Dear Mr. Drury,
We have reviewed the August 2018 Draft Environmental Impact Report (DEIR) and November 2018 Final
Environmental Impact Report (FEIR) for the Magnolia at the Park Multi‐Family Residential Project
(“Project”) located in the City of Santa Ana (“City”). The Project proposes to demolish an existing 81,172
square foot office building and a 442‐space parking lot. The Project also proposes to construct 405,290
square feet of residential buildings consisting of 496 multi‐family units, as well as a 9‐level parking
structure on the 5.93‐acres site.
Our review concludes that the DEIR and FEIR fail to adequately evaluate and mitigate the Project’s Air
Quality impacts. As a result, health risk impacts associated with construction and operation of the
proposed Project are underestimated and inadequately addressed. A revised EIR should be prepared to
adequately assess and mitigate the potential health risk impacts the Project may have on surrounding
receptors.
Air Quality
Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated
The DEIR concludes that the proposed Project would have a less than significant impact on the health of
sensitive receptors without conducting a quantitative health risk assessment (HRA) for construction or
operation of the proposed Project. The DEIR fails to conduct a quantified HRA for nearby existing
sensitive receptors and instead solely relies upon an HRA which evaluates cancer risk posed new on‐site
receptors. Based on the HRA for new, on‐site receptors, the DEIR concludes that the Project would have
a less than significant health risk impact (p. 4.2‐18). The DEIR justifies this analysis by stating,
“Because the proposed project is located within an urban community within 500‐feet of I‐5 that
has a substantial daily vehicle and truck volume, the contaminants generated from the roadway
were identified by the HRA prepared for the proposed project to provide risk estimates related
to air contaminants from I‐5 that are reflective of anticipated exposures experienced at the
2
project site. The modeling conducted by the HRA includes freeway volumes from Caltrans,
spatial distribution of mobile source activity traversing the freeway in relation to the proposed
site and was prepared pursuant to SCAQMD methodology” (p. 4.2‐17 – 4.2‐18).
The DEIR goes on to conclude,
“The HRA calculations determined that the cancer risk from exposure to diesel and gasoline fuel
emissions to the maximum exposed residential receptor totaled 7.57 in one million, which
would not exceed the SCAQMD significance threshold of 10 in one million. Overall, impacts
related to exposures associated with both toxic and criteria pollutants would be less than
significant” (p. 4.2‐18).
This significance determination is incorrect, as the Project Applicant cannot claim that the Project would
result in a less than significant health risk impact without properly assessing the risk posed to existing
sensitive receptors as a result of diesel particulate matter (DPM) emissions that will be emitted during
Project activities. As a result, until the construction and operational health risk impacts posed to nearby
existing sensitive receptors resulting specifically from the proposed Project are adequately quantified
and compared to applicable thresholds, the DEIR cannot make any conclusions with regards to the
Project’s health risk impacts.
By failing to prepare a construction or an operational HRA for existing sensitive receptors, the DEIR is
inconsistent with recommendations set forth by the Office of Environmental Health Hazard Assessment
(OEHHA), the organization responsible for providing recommendations for health risk assessments in
California. In February of 2015, OEHHA released its most recent Risk Assessment Guidelines: Guidance
Manual for Preparation of Health Risk Assessments, which was formally adopted in March of 2015.1 This
guidance document describes the types of projects that warrant the preparation of a health risk
assessment. Construction of the Project will produce emissions of DPM, a human carcinogen, through
the exhaust stacks of construction equipment over a construction period of 18 months (p. 3‐18). The
OEHHA document recommends that all short‐term projects lasting at least two months be evaluated for
cancer risks to nearby sensitive receptors.2 Therefore, per OEHHA guidelines, health risk impacts from
Project construction should have been evaluated by the DEIR. Furthermore, once construction of the
Project is complete, the Project will operate for a long period of time. During operation, the Project will
generate vehicle trips, which will generate additional exhaust emissions, thus continuing to expose
nearby sensitive receptors to emissions. The OEHHA document recommends that exposure from
projects lasting more than 6 months should be evaluated for the duration of the project, and
recommends that an exposure duration of 30 years be used to estimate individual cancer risk for the
maximally exposed individual resident (MEIR).3 Even though we were not provided with the expected
1 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/hotspots2015.html
2 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8‐18
3 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf, p. 8‐6, 8‐15
3
lifetime of the Project, we can reasonably assume that the Project will operate for at least 30 years, if
not more. Therefore, health risks from Project operation should have also been evaluated by the DEIR,
as a 30‐year exposure duration vastly exceeds the 2‐month and 6‐month requirements set forth by
OEHHA. These recommendations reflect the most recent health risk policy, and as such, an updated
assessment of health risks to nearby sensitive receptors from construction and operation should be
included in a revised California Environmental Quality Act (CEQA) evaluation for the Project.
In an effort to demonstrate the potential risk posed by the Project to nearby sensitive receptors, we
prepared a simple screening‐level HRA. The results of our assessment, as described below, demonstrate
that construction and operational DPM emissions may result in a potentially significant health risk
impact that was not previously identified or evaluated in either the DEIR or FEIR.
In order to conduct our screening level risk assessment, we relied upon AERSCREEN, which is a
screening‐level air quality dispersion model. 4 The model replaced SCREEN3, which is included in OEHHA5
and CAPCOA6 guidance as the appropriate air dispersion model for Level 2 health risk screening
assessments (“HRSAs”). A Level 2 HRSA utilizes a limited amount of site‐specific information to generate
maximum reasonable downwind concentrations of air contaminants to which nearby sensitive receptors
may be exposed. If an unacceptable air quality hazard is determined to be possible using AERSCREEN, a
more refined modeling approach is required prior to approval of the Project.
We prepared a preliminary health risk screening assessment of the Project's construction and
operational impacts to sensitive receptors using the estimates from the DEIR’s air models for
construction and operation The DEIR states that the closest sensitive receptors to the Project site are
single‐family residences near the Project site (p. 4.2‐11). Thus, a receptor distance of 25 meters was
used in our analysis. Consistent with recommendations set forth by OEHHA, we used a residential
exposure duration of 30 years, starting from the third trimester of pregnancy. We also assumed that
construction and operation of the Project would occur consecutively, with no gaps between each Project
phase. Our calculated annual emissions indicate that construction activities will generate approximately
378 pounds7 of DPM over a 536‐day construction period. The AERSCREEN model relies on a continuous
average emissions rate to simulate maximum downwind concentrations from point, area, and volume
emissions sources. To account for the variability in construction equipment usage over the many phases
of Project construction, we calculated an average DPM emission rate for construction by the following
equation.
4 “AERSCREEN Released as the EPA Recommended Screening Model,” USEPA, April 11, 2011, available at:
http://www.epa.gov/ttn/scram/guidance/clarification/20110411_AERSCREEN_Release_Memo.pdf
5 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf
6 “Health Risk Assessments for Proposed Land Use Projects,” CAPCOA, July 2009, available at:
http://www.capcoa.org/wp‐content/uploads/2012/03/CAPCOA_HRA_LU_Guidelines_8‐6‐09.pdf
7 The DEIR fails to provide CalEEMod output files containing the annual emissions estimates for the Project’s
construction air model. Therefore, we used the maximum daily DPM emissions estimates from the DEIR’s
construction air model summer output file, provided in the Magnolia at the Park Air Quality Impact Analysis, to
then calculate an annual DPM emissions estimate (Appendix I, pp. 577).
4
𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑅𝑎𝑡𝑒 ቀ 𝑔𝑟𝑎𝑚𝑠
𝑠𝑒𝑐𝑜𝑛𝑑ቁൌ 377.6 𝑙𝑏𝑠
536 𝑑𝑎𝑦𝑠 ൈ 453.6 𝑔𝑟𝑎𝑚𝑠
𝑙𝑏 ൈ 1 𝑑𝑎𝑦
24 ℎ𝑜𝑢𝑟𝑠 ൈ 1 ℎ𝑜𝑢𝑟
3,600 𝑠𝑒𝑐𝑜𝑛𝑑𝑠 ൎ 𝟎.𝟎𝟎𝟑𝟔𝟗𝟖
𝒈𝒔ൗ
Subtracting the 536‐day construction duration from the total residential exposure duration of 30 years,
we assumed that after Project construction, the MEIR would be exposed to the Project’s operational
DPM emissions for an additional 28.5 years approximately (10,414 days). The operational CalEEMod
model’s annual emissions indicate that operational activities will generate approximately 161 pounds of
DPM per year. Applying the same equation used to estimate the construction DPM emission rate, we
estimated the following emission rate for Project operation.
𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛 𝑅𝑎𝑡𝑒 ቀ 𝑔𝑟𝑎𝑚𝑠
𝑠𝑒𝑐𝑜𝑛𝑑ቁൌ 161 𝑙𝑏𝑠
365 𝑑𝑎𝑦𝑠 ൈ 453.6 𝑔𝑟𝑎𝑚𝑠
𝑙𝑏 ൈ 1 𝑑𝑎𝑦
24 ℎ𝑜𝑢𝑟𝑠 ൈ 1 ℎ𝑜𝑢𝑟
3,600 𝑠𝑒𝑐𝑜𝑛𝑑𝑠 ൎ 𝟎.𝟎𝟎𝟐𝟑𝟏𝟔
𝒈𝒔ൗ
Construction and operational activity was simulated as a 5.95‐acre rectangular area source in
AERSCREEN, with dimensions of 172 meters by 140 meters. A release height of three meters was
selected to represent the height of exhaust stacks on construction equipment and other heavy‐duty
vehicles, and an initial vertical dimension of one and a half meters was used to simulate instantaneous
plume dispersion upon release. An urban meteorological setting was selected with model‐default inputs
for wind speed and direction distribution.
The AERSCREEN model generates maximum reasonable estimates of single‐hour DPM concentrations
from the Project site. EPA guidance suggests that in screening procedures, the annualized average
concentration of an air pollutant be estimated by multiplying the single‐hour concentration by 10%.8
There are residences located approximately 25 meters away from the Project boundary. The single‐hour
concentration estimated by AERSCREEN for Project construction is approximately 4.047 µg/m3 DPM at
approximately 25 meters downwind. Multiplying this single‐hour concentration by 10%, we get an
annualized average concentration of 0.4047 µg/m3 for construction. For Project operation, the single‐
hour concentration in AERSCREEN is approximately 2.534 µg/m3 DPM at approximately 25 meters
downwind. Again, multiplying this single‐hour concentration by 10%, we get an annualized average
concentration of 0.2534 µg/m3 for operation.
We calculated the excess cancer risk to the residential receptors located closest to the Project site using
applicable HRA methodologies prescribed by OEHHA and the South Coast Air Quality Management
District (SCAQMD). Consistent with the construction schedule proposed by the DEIR, the annualized
average concentration for construction was used for the entire 3rd trimester of pregnancy (0.25 years),
and the first 1.22 years of the infantile stage of life (0‐2 years). The annualized average concentration for
operation was used for the remainder of the 30‐year exposure period, which makes up the remainder of
the infantile stage of life, the entirety of the child stage of life (2 to 16 years), and the entirety of the
adult stage of life (16 to 30 years). Consistent with OEHHA guidance, we used Age Sensitivity Factors
(ASFs) to account for the heightened susceptibility of young children to the carcinogenic toxicity of air
8 http://www.epa.gov/ttn/scram/guidance/guide/EPA‐454R‐92‐019_OCR.pdf
5
pollution.9 According to the updated guidance, quantified cancer risk should be multiplied by a factor of
ten during the third trimester of pregnancy and the first two years of life (infant) and should be
multiplied by a factor of three during the child stage of life (2 to 16 years). Furthermore, in accordance
with guidance set forth by OEHHA, we used 95th percentile breathing rates for infants.10 Finally,
according to SCAQMD guidance, we used a Fraction of Time At Home (FAH) Value of 1 for the 3rd
trimester, infant, and child receptors and we used a FAH Value of 0.73 for the adult receptors.11 We
used a cancer potency factor of 1.1 (mg/kg‐day)‐1 and an averaging time of 25,550 days. The results of
our calculations are shown below.
The Maximum Exposed Individual at an Existing Residential Receptor (MEIR)
Activity Duration
(years)
Concentration
(µg/m3)
Breathing Rate
(L/kg‐day) ASF Cancer Risk
Construction 0.25 0.4047 361 10 5.5E‐06
3rd Trimester Duration 0.25 3rd Trimester Exposure 5.5E‐06
Construction 1.22 0.4047 1090 10 8.1E‐05
Operation 0.78 0.2534 1090 10 3.2E‐05
Infant Exposure Duration 2.00 Infant Exposure 1.1E‐04
Operation 14.00 0.2534 572 3 9.2E‐05
Child Exposure Duration 14.00 Child Exposure 9.2E‐05
Operation 14.00 0.2534 261 1 1.0E‐05
Adult Exposure Duration 14.00 Adult Exposure 1.02E‐05
Lifetime Exposure Duration 30.00 Lifetime Exposure 2.2E‐04
As demonstrated above, the excess cancer risk to adults, children, infants, and 3rd trimester gestations
at a sensitive receptor located approximately 25 meters away, over the course of Project construction
and operation, are approximately 10, 92, 110, and 5.5 in one million, respectively. Furthermore, the
excess cancer risk over the course of a residential lifetime (30 years) is approximately 220 in one million.
Consistent with OEHHA guidance, exposure was assumed to begin in the 3rd trimester stage of
pregnancy to provide the most conservative estimates of air quality hazards. The infantile, child, adult,
and lifetime cancer risks all exceed the SCAQMD’s threshold of 10 in one million, thus resulting in a
potentially significant impact not previously addressed or identified by the DEIR or FEIR.
9 “Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf
10 “Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics ‘Hot Spots’ Information and
Assessment Act,” June 5, 2015, available at: http://www.aqmd.gov/docs/default‐source/planning/risk‐
assessment/ab2588‐risk‐assessment‐guidelines.pdf?sfvrsn=6, p. 19
“Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.” OEHHA, February
2015, available at: https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf
11 “Risk Assessment Procedures for Rules 1401, 1401.1, and 212.” SCAQMD, August 2017, available at:
http://www.aqmd.gov/docs/default‐source/rule‐book/Proposed‐
Rules/1401/riskassessmentprocedures_2017_080717.pdf, p. 7
6
It should be noted that our analysis represents a screening‐level HRA, which is known to be more
conservative, and tends to err on the side of health protection.12 The purpose of a screening‐level HRA,
however, is to determine if a more refined HRA needs to be conducted. If the results of a screening‐
level health risk are above applicable thresholds, then the Project needs to conduct a more refined HRA
that is more representative of site‐specific concentrations. Our screening‐level HRA demonstrates that
construction and operation of the Project could result in a potentially significant health risk impact,
when correct exposure assumptions and up‐to‐date, applicable guidance are used. As a result, refined
construction and operational HRAs must be prepared to examine air quality impacts generated by
Project construction and operation using site‐specific meteorology. An updated EIR should be prepared
to adequately evaluate the Project’s health risk impact and should include additional mitigation
measures to reduce these impacts to a less‐than‐significant level.
Mitigation Measures Available to Reduce Diesel Particulate Matter Emissions
Our HRA demonstrates that the Project’s construction‐related DPM emissions could result in significant
health risk impacts. Therefore, additional mitigation measures must be identified and incorporated into
an updated EIR to reduce these emissions to a less than significant level. Additional mitigation measures
can be found in CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures, which attempt to reduce
Greenhouse Gas (GHG) levels, as well as reduce Criteria Air Pollutants such as particulate matter.13 DPM
is a byproduct of diesel fuel combustion, and is emitted by on‐road vehicles and by off‐road construction
equipment. Mitigation for DPM emissions should include consideration of the following measures in an
effort to reduce construction emissions.
Require Implementation of Diesel Control Measures
The Northeast Diesel Collaborative (NEDC) is a regionally coordinated initiative to reduce diesel
emissions, improve public health, and promote clean diesel technology. The NEDC recommends that
contracts for all construction projects require the following diesel control measures:14
All diesel onroad vehicles on site for more than 10 total days must have either (1) engines that
meet EPA 2007 onroad emissions standards or (2) emission control technology verified by EPA15
or the California Air Resources Board (CARB)16 to reduce PM emissions by a minimum of 85
percent.
All diesel generators on site for more than 10 total days must be equipped with emission control
technology verified by EPA or CARB to reduce PM emissions by a minimum of 85 percent.
12 http://oehha.ca.gov/air/hot_spots/2015/2015GuidanceManual.pdf p. 1‐5
13http://www.capcoa.org/wp‐content/uploads/2010/11/CAPCOA‐Quantification‐Report‐9‐14‐Final.pdf
14 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015‐09/documents/nedc‐model‐contract‐sepcification.pdf
15 For EPA’s list of verified technology: http://www3.epa.gov/otaq/diesel/verification/verif‐list.htm
16 For CARB’s list of verified technology: http://www.arb.ca.gov/diesel/verdev/vt/cvt.htm
7
All diesel vehicles, construction equipment, and generators on site shall be fueled with ultra‐low
sulfur diesel fuel (ULSD) or a biodiesel blend17 approved by the original engine manufacturer
with sulfur content of 15 parts per million (ppm) or less.
Repower or Replace Older Construction Equipment Engines
The NEDC recognizes that availability of equipment that meets the EPA’s newer standards is limited.18
Due to this limitation, the NEDC proposes actions that can be taken to reduce emissions from existing
equipment in the Best Practices for Clean Diesel Construction report.19 These actions include but are not
limited to:
Replacement of older equipment with equipment meeting the latest emission standards.
Engine replacement can include substituting a cleaner highway engine for a nonroad engine. Diesel
equipment may also be replaced with other technologies or fuels. Examples include hybrid switcher
locomotives, electric cranes, LNG, CNG, LPG or propane yard tractors, forklifts or loaders.
Replacements using natural gas may require changes to fueling infrastructure.20 Replacements often
require some re‐engineering work due to differences in size and configuration. Typically, there are
benefits in fuel efficiency, reliability, warranty, and maintenance costs.21
Install Retrofit Devices on Existing Construction Equipment
PM emissions from alternatively‐fueled construction equipment can be further reduced by installing
retrofit devices on existing and/or new equipment. The most common retrofit technologies are retrofit
devices for engine exhaust after‐treatment. These devices are installed in the exhaust system to reduce
emissions and should not impact engine or vehicle operation. 22 It should be noted that actual emissions
reductions and costs will depend on specific manufacturers, technologies and applications. Should the
Applicant be unable to obtain Tier 4 Interim or Tier 4 Final off‐road equipment engines for all pieces of
equipment with 50 hp or greater, the Applicant should consider use of engines that meet Tier 3 off‐road
emission standards and engines that are retrofitted with an ARB Level 2 or Level 3 Verified Diesel
Emissions Control Strategy (VDECS).
17 Biodiesel lends are only to be used in conjunction with the technologies which have been verified for use with
biodiesel blends and are subject to the following requirements:
http://www.arb.ca.gov/diesel/verdev/reg/biodieselcompliance.pdf
18http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf
19http://northeastdiesel.org/pdf/BestPractices4CleanDieselConstructionAug2012.pdf
20 Alternative Fuel Conversion, EPA, available at: https://www.epa.gov/greenvehicles/alternative‐vehicle‐fuels
21 Cleaner Fuels, EPA, available at: https://www.epa.gov/verified‐diesel‐tech/verified‐technologies‐list‐clean‐diesel
22 Retrofit Technologies, EPA, available at: https://www.epa.gov/sites/production/files/2016‐
03/documents/420f10027.pdf
8
Use Electric and Hybrid Construction Equipment
CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures23 report also proposes the use of electric
and/or hybrid construction equipment as a way to mitigate DPM emissions. When construction
equipment is powered by grid electricity rather than fossil fuel, direct emissions from fuel combustion
are replaced with indirect emissions associated with the electricity used to power the equipment.
Furthermore, when construction equipment is powered by hybrid‐electric drives, emissions from fuel
combustion are also greatly reduced. Electric construction equipment is available commercially from
companies such as Peterson Pacific Corporation,24 which specialize in the mechanical processing
equipment like grinders and shredders. Construction equipment powered by hybrid‐electric drives is
also commercially available from companies such as Caterpillar25. For example, Caterpillar reports that
during an 8‐hour shift, its D7E hybrid dozer burns 19.5 percent fewer gallons of fuel than a conventional
dozer while achieving a 10.3 percent increase in productivity. The D7E model burns 6.2 gallons per hour
compared to a conventional dozer which burns 7.7 gallons per hour.26 Fuel usage and savings are
dependent on the make and model of the construction equipment used. The Project Applicant should
calculate project‐specific savings and provide manufacturer specifications indicating fuel burned per
hour.
Implement a Construction Vehicle Inventory Tracking System
CAPCOA’s Quantifying Greenhouse Gas Mitigation Measures27 report recommends that the Project
Applicant provide a detailed plan that discusses a construction vehicle inventory tracking system to
ensure compliances with construction mitigation measures. The system should include strategies such
as requiring engine run time meters on equipment, documenting the serial number, horsepower,
manufacture age, fuel, etc. of all onsite equipment and daily logging of the operating hours of the
equipment. Specifically, for each onroad construction vehicle, nonroad construction equipment, or
generator, the contractor should submit to the developer’s representative a report prior to bringing said
equipment on site that includes:28
Equipment type, equipment manufacturer, equipment serial number, engine manufacturer,
engine model year, engine certification (Tier rating), horsepower, and engine serial number.
The type of emission control technology installed, serial number, make, model, manufacturer,
and EPA/CARB verification number/level.
23http://www.capcoa.org/wp‐content/uploads/2010/11/CAPCOA‐Quantification‐Report‐9‐14‐Final.pdf
24 Peterson Electric Grinders Brochure, available at:http://www.petersoncorp.com/wp‐
content/uploads/peterson_electric_grinders1.pdf
25 Electric Power Products, available at:http://www.cat.com/en_US/products/new/power‐systems/electric‐power‐
generation.html
26http://www.capcoa.org/wp‐content/uploads/2010/11/CAPCOA‐Quantification‐Report‐9‐14‐Final.pdf
27http://www.capcoa.org/wp‐content/uploads/2010/11/CAPCOA‐Quantification‐Report‐9‐14‐Final.pdf
28 Diesel Emission Controls in Construction Projects, available at:
http://www2.epa.gov/sites/production/files/2015‐09/documents/nedc‐model‐contract‐sepcification.pdf
9
The Certification Statement29 signed and printed on the contractor’s letterhead.
Furthermore, the contractor should submit to the developer’s representative a monthly report that, for
each onroad construction vehicle, nonroad construction equipment, or generator onsite, includes: 30
Hour‐meter readings on arrival on‐site, the first and last day of every month, and on off‐site
date.
Any problems with the equipment or emission controls.
Certified copies of fuel deliveries for the time period that identify:
o Source of supply
o Quantity of fuel
o Quality of fuel, including sulfur content (percent by weight).
In addition to these measures, we also recommend that the Applicant implement the following
mitigation measures, called “Enhanced Exhaust Control Practices,”31 that are recommended by the
Sacramento Metropolitan Air Quality Management District (SMAQMD):
1. The project representative shall submit to the lead agency a comprehensive inventory of all off‐
road construction equipment, equal to or greater than 50 horsepower, that will be used an
aggregate of 40 or more hours during any portion of the construction project.
The inventory shall include the horsepower rating, engine model year, and projected
hours of use for each piece of equipment.
The project representative shall provide the anticipated construction timeline including
start date, and name and phone number of the project manager and on‐site foreman.
This information shall be submitted at least 4 business days prior to the use of subject
heavy‐duty off‐road equipment.
The inventory shall be updated and submitted monthly throughout the duration of the
project, except that an inventory shall not be required for any 30‐day period in which no
construction activity occurs.
2. The project representative shall provide a plan for approval by the lead agency demonstrating
that the heavy‐duty off‐road vehicles (50 horsepower or more) to be used in the construction
project, including owned, leased, and subcontractor vehicles, will achieve a project wide fleet‐
average 45% particulate reduction and 20% NOX reduction compared to the most recent
California Air Resources Board (ARB) fleet average.
This plan shall be submitted in conjunction with the equipment inventory.
29 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015‐09/documents/nedc‐model‐contract‐sepcification.pdf The
NEDC Model Certification Statement can be found in Appendix A.
30 Diesel Emission Controls in Construction Projects, available
at:http://www2.epa.gov/sites/production/files/2015‐09/documents/nedc‐model‐contract‐sepcification.pdf
31http://www.airquality.org/ceqa/Ch3EnhancedExhaustControl_10‐2013.pdf
10
Acceptable options for reducing emissions may include use of late model engines, low‐
emission diesel products, alternative fuels, engine retrofit technology, after‐treatment
products, and/or other options as they become available.
The District’s Construction Mitigation Calculator can be used to identify an equipment
fleet that achieves this reduction.
3. The project representative shall ensure that emissions from all off‐road diesel‐powered
equipment used on the project site do not exceed 40% opacity for more than three minutes in
any one hour.
Any equipment found to exceed 40 percent opacity (or Ringelmann 2.0) shall be
repaired immediately. Non‐compliant equipment will be documented and a summary
provided to the lead agency monthly.
A visual survey of all in‐operation equipment shall be made at least weekly.
A monthly summary of the visual survey results shall be submitted throughout the
duration of the project, except that the monthly summary shall not be required for any
30‐day period in which no construction activity occurs. The monthly summary shall
include the quantity and type of vehicles surveyed as well as the dates of each survey.
4. The District and/or other officials may conduct periodic site inspections to determine
compliance. Nothing in this mitigation shall supersede other District, state or federal rules or
regulations.
These measures offer a cost‐effective, feasible way to incorporate lower‐emitting design features into
the proposed Project, which subsequently reduces emissions released during Project construction. An
updated EIR must be prepared to include DPM‐related mitigation measures, as well as include an
updated air quality analysis to ensure that the necessary mitigation measures are implemented to
reduce construction emissions and reduce health risk impacts to a less than significant level.
Furthermore, the Project Applicant needs to demonstrate commitment to the implementation of these
measures prior to Project approval, to ensure that the Project’s emissions are reduced to the maximum
extent possible.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Hadley Nolan
1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887‐9013
Email: mhagemann@swape.com
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine
years with the U.S. EPA in the RCRA and Superfund programs and served as EPA’s Senior Science
Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from
perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of
the assessment of seven major military facilities undergoing base closure. He led numerous enforcement
actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working
with permit holders to improve hydrogeologic characterization and water quality monitoring.
Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the
application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt
has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of
Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.
Positions Matt has held include:
•Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 – present);
•Geology Instructor, Golden West College, 2010 – 2014;
•Senior Environmental Analyst, Komex H2O Science, Inc. (2000 ‐‐ 2003);
• Executive Director, Orange Coast Watch (2001 – 2004);
• Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989–
1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 – 2000);
• Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 –
1998);
• Instructor, College of Marin, Department of Science (1990 – 1995);
• Geologist, U.S. Forest Service (1986 – 1998); and
• Geologist, Dames & Moore (1984 – 1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt’s responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports
since 2003 under CEQA that identify significant issues with regard to hazardous waste, water
resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic
hazards. Make recommendations for additional mitigation measures to lead agencies at the
local and county level to include additional characterization of health risks and
implementation of protective measures to reduce worker exposure to hazards from toxins
and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities.
• Manager of a project to provide technical assistance to a community adjacent to a former
Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns.
• Lead analyst and testifying expert in the review of environmental issues in license applications
for large solar power plants before the California Energy Commission.
• Manager of a project to evaluate numerous formerly used military sites in the western U.S.
• Manager of a comprehensive evaluation of potential sources of perchlorate contamination in
Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the
review of releases of gasoline to sources drinking water at major refineries and hundreds of gas
stations throughout California.
• Expert witness on two cases involving MTBE litigation.
• Expert witness and litigation support on the impact of air toxins and hazards at a school.
• Expert witness in litigation at a former plywood plant.
With Komex H2O Science Inc., Matt’s duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony
by the former U.S. EPA Administrator and General Counsel.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking
water treatment, results of which were published in newspapers nationwide and in testimony
against provisions of an energy bill that would limit liability for oil companies.
• Research to support litigation to restore drinking water supplies that have been contaminated by
MTBE in California and New York.
2
• Expert witness testimony in a case of oil production‐related contamination in Mississippi.
• Lead author for a multi‐volume remedial investigation report for an operating school in Los
Angeles that met strict regulatory requirements and rigorous deadlines.
3
• Development of strategic approaches for cleanup of contaminated sites in consultation with
clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange
County beaches from multiple sources of contamination including urban runoff and the discharge of
wastewater. In reporting to a Board of Directors that included representatives from leading Orange
County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection
of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the
development of countywide water quality permits for the control of urban runoff and permits for the
discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including
Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business
institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to
characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point
Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army
Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of
monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and
groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory
analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation
development through work on four national U.S. EPA workgroups, including the Superfund
Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of
groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to
show zones of vulnerability, and the results were adopted and published by the State of Hawaii and
County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the
Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included
the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for
the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities
through designation under the Safe Drinking Water Act. He prepared geologic reports,
conducted public hearings, and responded to public comments from residents who were very
concerned about the impact of designation.
4
• Reviewed a number of Environmental Impact Statements for planned major developments,
including large hazardous and solid waste disposal facilities, mine reclamation, and water
transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance
with Subtitle C requirements.
• Reviewed and wrote ʺpart Bʺ permits for the disposal of hazardous waste.
• Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed
the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
• Wrote contract specifications and supervised contractor’s investigations of waste sites.
With the National Park Service, Matt directed service‐wide investigations of contaminant sources to
prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the
Clean Water Act to control military, mining, and landfill contaminants.
• Conducted watershed‐scale investigations of contaminants at parks, including Yellowstone and
Olympic National Park.
• Identified high‐levels of perchlorate in soil adjacent to a national park in New Mexico
and advised park superintendent on appropriate response actions under CERCLA.
• Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a
national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while
serving on a national workgroup.
• Co‐authored two papers on the potential for water contamination from the operation of personal
watercraft and snowmobiles, these papers serving as the basis for the development of nation‐
wide policy on the use of these vehicles in National Parks.
• Contributed to the Federal Multi‐Agency Source Water Agreement under the Clean Water
Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection
Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the
potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking
water supplies.
• Shaped EPA’s national response to these threats by serving on workgroups and by contributing
to guidance, including the Office of Research and Development publication, Oxygenates in
Water: Critical Information and Research Needs.
• Improved the technical training of EPAʹs scientific and engineering staff.
• Earned an EPA Bronze Medal for representing the region’s 300 scientists and engineers in
negotiations with the Administrator and senior management to better integrate scientific
principles into the policy‐making process.
• Established national protocol for the peer review of scientific documents.
5
Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for
timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical
models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource
protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the
city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later
listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern
Oregon. Duties included the following:
• Supervised year‐long effort for soil and groundwater sampling.
• Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university
levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in
environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater
contamination.
• Served as a committee member for graduate and undergraduate students.
• Taught courses in environmental geology and oceanography at the College of Marin.
Matt taught physical geology (lecture and lab and introductory geology at Golden West College in
Huntington Beach, California from 2010 to 2014.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public
Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and
Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las
Vegas, NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at
schools in Southern California, Los Angeles.
6
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE
Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater
Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust,
Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy
of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water
Supplies. Invited presentation to the Inter‐Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited
presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of
the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a
meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address
Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental
Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater
(and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage
Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and
State Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished
report.
7
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage
Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential Water Quality Concerns Related
to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft
Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright
Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund
Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air
Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic
Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui,
October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu,
Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air
and Waste Management Association Publication VIP‐61.
Hagemann, M.F., 1994. Groundwater Characterization and Cleanup at Closing Military Bases
in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater
Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of
Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL‐
contaminated Groundwater. California Groundwater Resources Association Meeting.
8
Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of
Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examination, 2009‐
2011.
9
HADLEY KATHRYN NOLAN
SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Mobile: (678) 551-0836
Office: (310) 452-5555
Fax: (310) 452-5550
Email: hadley@swape.com
EDUCATION
UNIVERSITY OF CALIFORNIA, LOS ANGELES B.S. ENVIRONMENTAL SCIENCES & ENVIRONMENTAL SYSTEMS AND SOCIETY JUNE 2016
PROJECT EXPERIENCE
SOIL WATER AIR PROTECTION ENTERPRISE SANTA MONICA, CA
AIR QUALITY SPECIALIST
SENIOR PROJECT ANALYST: CEQA ANALYSIS & MODELING
• Modeled construction and operational activities for proposed land use projects using CalEEMod to quantify criteria air pollutant
and greenhouse gas (GHG) emissions.
• Organized presentations containing figures and tables that compare results of criteria air pollutant analyses to thresholds.
• Quantified ambient air concentrations at sensitive receptor locations using AERSCREEN, a U.S. EPA recommended screening level
dispersion model.
• Conducted construction and operational health risk assessments for residential, worker, and school children sensitive receptors.
• Prepared reports that discuss adequacy of air quality and health risk analyses conducted for proposed land use developments
subject to CEQA review by verifying compliance with local, state, and regional regulations.
SENIOR PROJECT ANALYST: GREENHOUSE GAS MODELING AND DETERMINATION OF SIGNIFICANCE
• Evaluated environmental impact reports for proposed projects to identify discrepancies with the methods used to quantify and
assess GHG impacts.
• Quantified GHG emissions for proposed projects using CalEEMod to produce reports, tables, and figures that compare emissions
to applicable CEQA thresholds and reduction targets.
• Determined compliance of proposed land use developments with AB 32 GHG reduction targets, with GHG significance thresholds
recommended by Air Quality Management Districts in California, and with guidelines set forth by CEQA.
PROJECT ANALYST: ASSESSMENT OF AIR QUALITY IMPACTS FROM PROPOSED DIRECT TRANSFER FACILITY
• Assessed air quality impacts resulting from implementation of a proposed Collection Service Agreement for Exclusive Residential
and Commercial Garbage, Recyclable Materials, and Organic Waste Collection Services for a community.
• Organized tables and maps to demonstrate potential air quality impacts resulting from proposed hauling trip routes.
• Conducted air quality analyses that compared quantified criteria air pollutant emissions released during construction of direct
transfer facility to the Bay Area Air Quality Management District’s (BAAQMD) significance thresholds.
• Prepared final analytical report to demonstrate local and regional air quality impacts, as well as GHG impacts.
PROJECT ANALYST: EXPOSURE ASSESSMENT OF LEAD PRODUCTS FOR PROPOSITION 65 COMPLIANCE DETERMINATION
• Calculated human exposure and lifetime health risk for over 300 lead products undergoing Proposition 65 compliance review.
• Compiled and analyzed laboratory testing data and produced tables, charts, and graphs to exhibit emission levels.
• Compared finalized testing data to Proposition 65 Maximum Allowable Dose Levels (MADLs) to determine level of compliance.
• Prepared final analytical lead exposure Certificate of Merit (COM) reports and organized supporting data for use in environmental
enforcement statute Proposition 65 cases.
ACCOMPLISHMENTS
• Academic Honoree, Dean’s List, University of California, Los Angeles MAR 2013, MAR 2014, JAN 2015, JAN 2016
From:Huizar, Maria
To:Bernal, Sarah; Thai, Minh
Cc:!City Clerk
Subject:ECOMMENT: Planning Commission
Date:Thursday, January 10, 2019 5:16:48 PM
For your Planning Commission meeting packet. Thank you.
From: Alan Fuller [mailto:alan.fuller@live.com]
Sent: Thursday, January 10, 2019 5:16 PM
To: eComment <eComment@santa-ana.org>
Subject: Planning Commission
Planning Commission
Regarding 2525 North Main Street, Santa Ana, Ca
Dear Commissioners:
I do not support the proposed 496 unit development at the entrance to the Park
Santiago neighborhood.
The best use for this property would be for the Discovery Science Museum. It would
be excellent for their offices and parking for visitors.
In objecting, the most obvious reason is the size and density of the development.
Nearly 500 apartments next to a 1200 home neighborhood are excessive. If it is to be
rezoned, the density should be a maximum of 20 units per acre, not the 83 as
proposed. The homes along Memory Lane are only three stores, which seems more
appropriate.
I do not feel the traffic study adequately addresses the taking of Walkie Way for
egress to the development. The additional cars entering and leaving at Walkie Way,
only 150 yards from Edgewood and the north bound 5 freeway off ramp will have cars
backed up onto the freeway as well as south bound cars back to Main Place Mall.
There are only 4 places where we can enter and exit our neighborhood and making
Edgewood unusable would have major negative impact.
I feel the developer has been unethical in his dealings with our neighborhood by
compensating individuals to support his project at the last commission meeting. I feel
that the letter in support from the Discovery Science Museum was obtained by the
developer offering financial support for the parking structure they need.
I live in this neighborhood that is about 100 years old. It should be guarded and
protected from this development.
Sincerely,
Alan H Fuller
2422 Santiago
Santa Ana, CA
From:Kelaher, Selena
To:Bernal, Sarah
Cc:Fregoso, Vince
Subject:FW: Final EIR for 2525 North Main Street, Multi-family Residential Project (State Clearinghouse Number
2018021031)
Date:Wednesday, November 28, 2018 8:23:00 AM
Hi Sarah,
Please include this email in the record for public comments for the 1/14/19 PC meeting.
Thank you,
Selena Kelaher, AICP
City of Santa Ana
Planning and Building Agency | M20
20 Civic Center Plaza | Post Office Box 1988 | Santa Ana, CA 92702
skelaher@santa-ana.org | Direct Phone: (714) 667-2740
From: Darcie L. Cancino [mailto:darcielc@gmail.com]
Sent: Tuesday, November 27, 2018 7:48 PM
To: Kelaher, Selena <skelaher@santa-ana.org>
Cc: Fregoso, Vince <VFregoso@santa-ana.org>; Pulido, Miguel <MPulido@santa-ana.org>; Solorio,
Jose <JSolorio@santa-ana.org>
Subject: Re: Final EIR for 2525 North Main Street, Multi-family Residential Project (State
Clearinghouse Number 2018021031)
Ms. Kelaher, please see my comments on the final EIR for 2525 North Main Street, Multi-Family
Residential Project (State Clearinghouse Number 2018021031). I orally shared an abbreviated version of
these comments with the Planning Commission at the meeting held on November 26, 2018. I ask this
email be made a part of the project records and documentation.
I am a 20-year resident of Park Santiago. I submitted a comment letter on the draft EIR and it is labeled in
the final EIR as Letter P-5. I am opposed to Magnolia because of the density, scale, and proximity to a
historic neighborhood comprised solely of single family homes. It is not responsible or compatible
development and is not harmonious with the neighborhood. There has never been a high-density project
like this approved that is directly adjacent to single family homes.
But I have a few key comments on the final EIR beyond these general statements.
I am frankly shocked at the lack of impartiality and objective consideration in the EIR. Virtually every
impact was found to be “less than significant.” Our very real concerns about traffic and density were
treated with patronizing dismissal.
The EIR’s conclusion that Magnolia will generate “minimal traffic if any” through Park Santiago is
ludicrous. Based on the maximum number of occupants per unit, there is a potential for over thirteen-
hundred residents at Magnolia. It is inevitable these tenants are going to use Park Santiago streets as a
more convenient means to access points east. Cut-through traffic in the neighborhood is going to
explode. The developer has promised to pay for “traffic calming” enhancements to neighborhood streets,
but why would this be necessary if there will be zero traffic impact from the project? Clearly, there will be
a significant increase in traffic on Park Santiago streets.
Traffic on Main Street will be made worse, harming the City and the entire region, because ingress and
egress to Magnolia will require residents traveling southbound on Main to make an unsafe u-turn at
Edgewood; and residents leaving Magnolia wanting to travel southbound on Main will need to make a u-
turn at Walkie Way. This flow is going to impede traffic as well as create hazardous situations. (The
proposed entrance to Magnolia’s parking structure through the park at Walkie Way is not approved and is
at this point thus is not a viable alternative to even consider.)
Another key flaw is that one of Magnolia’s buildings at the northeast tip directly behind the single family
residences is five stories, not two, but my observation on this was basically ignored, other than a
response that Magnolia buildings will face inward and not overlook the single family homes to the east—
as though tenants cannot just turn their heads when looking out their windows and standing on their
balconies! But the building in question does not face inward. It is diagonally situated towards the homes
on Spurgeon Street.
The EIR continues to omit that there are an additional 1,900 housing units, 400-room hotel, and office
space planned at the “Main Place Transformation” project. Without these critical pieces of information, the
EIR is a flawed and misleading document.
I’m also concerned with the plan to eventually sell Magnolia units as condominiums. Upon conversion, all
the lofty promises of “neighborhood benefits" made by the developer will vanish.
It is also essential that the presentation materials you and Mr. Fregoso projected at the November 26
meeting be made publicly available and posted on the Major Planning Projects and Documents page of
the City website. The slides were unreadable during the meeting due to the poor lighting and tiny font.
Park Santiago residents are not against responsible development that will enhance our city and provide
much-needed housing where it makes sense. But this project is unsuited for the location and will bring
irreversible harm to Park Santiago, a jewel of Santa Ana, as well as the City overall.
Thank you,
Mrs. Darcie L. Cancino
909 E. Grovemont St.
Santa Ana, CA 92706
714-402-2582
On November 14, 2018 at 6:47:12 PM, Kelaher, Selena (skelaher@santa-ana.org) wrote:
Good Evening,
The Final EIR for the 2525 North Main Street, Multi-family Residential
Project (State Clearinghouse Number 2018021031) is available online at:
www.santa-ana.org/pb/planning-division/major-planning-projects-and-
documents/2525-n-main-residential-development
The public hearing regarding this matter is scheduled to be heard by the
Planning Commission on Monday, November 26, 2018 at 5:30 p.m. in
the City Council Chamber, 22 Civic Center Plaza, Santa Ana, California
92701.
Should you have any questions feel free to contact me at (714) 667-2740 or
skelaher@santa-ana.org.
Thank you,
Selena Kelaher, AICP
City of Santa Ana
Planning and Building Agency | M20
20 Civic Center Plaza | Post Office Box 1988 | Santa Ana, CA 92702
skelaher@santa-ana.org | Direct Phone: (714) 667-2740
From:ahfuller43@roadrunner.com
To:eComment
Subject:2525 N. Main
Date:Sunday, January 13, 2019 5:01:14 PM
I am opposed to the proposed development as proposed!
There should not be any housing development allowed within 50 feet of a major freeway offramp that would impede
offramp travel due to vehicles entering or exiting on busy Main St.
The proposed generation of approximately 1000 cars trying to get home at night or leaving in the morning so close
to freeway access would bottleneck not only our busy Main St travel but also backup freeway exits and entrances at
this location.
This is NOT the appropriate use for this parcel. Leave the parcel as zoned for professional/office use.
Marilyn Fuller
714 834-9073
Park Santiago resident for 42 years!
Sent from my iPad
From:Susan Gabrych
To:eComment
Subject:Planning Commission/ Re: 2525 North Main St.
Date:Saturday, January 12, 2019 5:08:51 PM
Dear Commissioners,
As a homeowner in Park Santiago for 20 years I have very definite opinions regarding this new development
proposal. I oppose it based on its size, scale, and location.
Yes, infilling and redeveloping urban areas is one way to address California's housing crisis. However, you cannot
destroy nice, intact neighborhoods simply to increase housing units and tax revenue. Infill should be to the scale of
the surrounding area, not DOUBLING the population density of the neighborhood with one development!
Also, the number of cars required for so many tenants would make getting onto Main Street from Edgewood and
vice versa nearly impossible during commute hours.
WHAT ARE THE CITY PLANNERS THINKING? I hope they are not "thinking" like the "planners of Santa Ana's
Past"? Let's review. Are they thinking like the city planners who dismissed Walt Disney's plans for an amusement
park (Disneyland) as some sort of "carnival"? How about the planners who didn't want South Coast Plaza annexed
into the city? Then there were the planners who allowed beautiful old homes to be torn down in the seventies and
eighties for poorly designed, out of scale, high density apartments turned into eyesores. And the coup de grace: One
Broadway Plaza, the 37-story figment of Mike Harrah's imagination and the planning commission's dereliction of
duty!
What makes Irvine so desirable and home values so high? Of course, it's good planning as in SMART planning. I
urge the Planning Commission to remember the citizens of Park Santiago and all of Santa Ana and to make the
smart decision by doing your job. I urge you to turn down the Final Environmental Impact Report (No. 2018-1) for
this too large, too dense project.
Thank you.
Susan Gabrych
Homeowner/ Park Santiago
Sent from my iPad
Sent from my iPad
January 14, 2019
Commissioner Mark McLoughlin
Chair, Planning Commission
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA, 92701
Re: Support for proposed development 2525 North Main Street
Dear Chairman McLoughlin and Honorable Commissioners:
We first wrote to you in August 2018 to offer support for the much-needed apartment homes
proposed for 2525 North Main Street. Our support has not wavered in the past six months, and
all of our reasons for support remain; the most urgent is the chronic housing shortage in
Orange County and throughout California, which drives up rents and home prices. The ever-
increasing cost of housing has led to crisis levels of homelessness and an exodus of the state’s
young college-educated workforce to states with lower housing costs.
We are writing to you again with renewed enthusiasm because housing delayed is housing
denied. The only solution to the housing shortage is to build more homes. The proposed
development at 2525 N. Main St. offers the opportunity to add nearly 500 new homes to
Santa Ana’s housing inventory and make a dent in Orange County’s housing shortage. At the
same time, the greatest barrier to building more homes and meeting the state’s housing
needs is NIMBY opposition. This fact has been documented by, the California Legislative
Analyst’s Office (LAO) and the Southern California Association of Governments (SCAG).
We wish to alert you to the changing political climate regarding local government approval of
housing developments. In 2017 multiple laws were passed that placed additional restrictions
on local government’s ability to deny housing development (SB 35, SB 167, AB 678, and AB
1515). The 2018 Legislature advanced new funding mechanisms for affordable housing, and
voters showed their approval in their passage of SB 2 & SB 3 in November 2018. Most recently,
Governor Gavin Newsom presented his budget, which includes housing funding, and his plans
to set regional housing goals and to hold cities accountable for meeting those goals . He went so
far as to say that cities that block housing developments risk losing state funding for
transportation.
PeopleForHousing.org
OCYimby.org
People for Housing OC
P.O. Box 6942
Fullerton, CA 92834
These recent developments point to a change in state policy— both by the Legislature and the
Governor: local control regarding the approval of new housing development is being taken
away from cities where decision makers continue to bend to NIMBY opposition and deny new
housing. If Santa Ana wishes to retain its ability to guide development within its boundaries, it
would be prudent to approve housing projects that are proposed in appropriate locations. As
we stated in our August letter, we believe this project is appropriate for the following reasons:
This project’s location is ideal for moderate density development – located on a major
thoroughfare between two major job centers, St. Joseph’s and Children’s Hospitals and
Downtown Santa Ana. It is also located across the street from the Discovery Cube
Science Center and similarly scaled office buildings in the area.
This project will add to the revitalization of the Main Place Mall, and the residents will
provide a customer base for the improvements coming to this major retail center.
This new housing is located in an already high-value area. Gentrification and
displacement are very real problems in many communities, including some Santa An a
neighborhoods; however this development will not demolish any existing housing or
displace any current residents.
This project will restore activity to a currently vacant commercial site. This is precisely
the type of turnover we need in Orange County. The Orange County Business Council
released a report outlining the potential to redevelop defunct commercial sites and
add much-needed housing.
I urge you to consider all of the above factors, and despite NIMBY opposition, approve the new
apartment homes proposed for 2525 N. Main Street.
Sincerely,
Elizabeth Hansburg
Elizabeth Hansburg
Co-Founder & Director
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714-541-7254 helvig_denny@msn.com
January 14, 2019
Chairman McLoughlin and Planning Commissioners
City of Santa Ana
Santa Ana CA 92702
Subject: January 14, 2019 Planning Commission Meeting
I would like to address these points tonight at the meeting but believe I can’t fit them in my
2 minutes along with all that other information I want to provide.
1) This is NOT moderate density apartments. It is high-density apartments.
2) The Envision map should not be used a reference point by the applicant. It is a clearly identified
draft document
3) These are market rate apartments with rents projected to be between $2000 for a studio to
over $3800 for a three bedroom.
4) This property is listed in City documents as being part of Park Santiago.
5) It has been mentioned several times that there are over 3700 housing units scheduled to be
built within 0.5 miles of the 2525 site. We are only opposed to the additional 496 units this
applicant wants.
6) Where is the accident report that was requested by a commissioner at the November 26th
meeting?
7) The property at 2525 is not currently zoned for residential. It is correctly zoned Professional,
Administrative Office. Build on it accordingly.
8) This project is a round peg is square hole. Not every project deserves to be built just because of
a perceived financial windfall. Look at the dollars closely. The net new General Fund revenue
in real value (2017$) is projected to be approximately $13.6 million, or $544K per year. Not the
reported nominal value of $23. 5million, or $940K per year. This also assumes a vacant lot for
the next 25 years.
9) According to the EIR, fifteen freeway segments analyzed have a failing Level of Service (LOS) in
25 of the 30 data points measured. The EIR says traffic is not significant.
10) The EIR for Main Place, competed in the 1990’s, did not address the 2525 project; the EIR for
2525 did not address the Main Place projects. The EIR for 2525 did not look at cumulative
affects by ignoring the Main Place project.
11) The listed population of 955 is not as the EIR states “conservative”. The “extensive” leasing
agreement they reference allows up to 1252 residents without being is violation of the lease.
Dale Helvig
2536 N. Valencia St. Santa Ana CA 92706
714-541-7254 helvig_denny@msn.com
12) Just last week the City admitted the final EIR is incorrect. The location of the emergency access
drive approach as proposed will potentially impact three of the existing 100 foot, 100 year old
palm trees located within the public right-of-way on Edgewood. With the widening of
Edgewood the remaining 100 foot palms could be impacted as well.
DENSITY =
POPULATION
LAND SPACE
Respectfully,
Dale A Helvig
Chairman, North Santa Ana Preservation Association (NSAPA)
cc: Raul Godinez II
Santa Ana City Manager
Minh Thai
Executive Director, Planning
Candida Neal,
Planning Manager
Vince Fregoso,
Principle Planner
Selena Kelaher
Associate Planner
Alberta Christy
Chair, Historic Resources Commission
Phil Schaefer,
Vice Chair, Historic Resources Commission
Tim Rush
Historic Resources Commissioner
Michael O’Valle,
President, Park Santiago Neighborhood Association (PSNA)
From:Kelaher, Selena
To:Bernal, Sarah
Subject:FW: 2525 N. Main Street- Support
Date:Monday, January 14, 2019 8:21:50 AM
Selena Kelaher, AICP
City of Santa Ana
Planning and Building Agency | M20
20 Civic Center Plaza | Post Office Box 1988 | Santa Ana, CA 92702
skelaher@santa-ana.org | Direct Phone: (714) 667-2740
From: Tim Johnson [mailto:tjohnsoncpa65@gmail.com]
Sent: Monday, January 14, 2019 8:17 AM
To: eComment <eComment@santa-ana.org>; Pulido, Miguel <MPulido@santa-ana.org>; Solorio,
Jose <JSolorio@santa-ana.org>; Villegas, Juan <JVillegas@santa-ana.org>; Sarmiento, Vicente
<VSarmiento@santa-ana.org>; Kelaher, Selena <skelaher@santa-ana.org>; Neal, Candida
<cneal@santa-ana.org>; Thai, Minh <mthai@santa-ana.org>; Reyna, Roman <RReyna@santa-
ana.org>; Penaloza, David <DPenaloza@santa-ana.org>; Iglesias, Cecilia <CIglesias@santa-ana.org>
Subject: 2525 N. Main Street- Support
Dear Planning Commission, Mayor, City Councilmembers, and Select Planning Department Staff…I
am writing you today in order to provide my perspective and support for the proposed development
at 2525 N. Main Street. I am attaching below my correspondence previously submitted on
November 26th. Not all of you may have seen this due to the election and changes on the
commission, so I am including for additional information. I have lived in Northern part of Santa Ana
for about 13 years now and am about 1 mile away from the development site and drive by 2525
quite often. We own our home and rooted in the community and truly want is best for our
neighborhood, community, and the City as a whole.
Overall, I believe that the City of Santa Ana can and will benefit from this project. The City needs to
evolve and property development should be part of that evolution. We have far too many
underutilized parcels that are not generating the property tax revenue that our city needs. Having a
vibrant North Main Street is also a benefit for our community. I understand that change can be hard
to accept and that the unknown may be scary especially for those with preconceived negative
notions about traffic, occupants of mult-family homes, nature of young folks, etc... In order to move
our city forward, we need to find additional revenue sources and attract residents of all housing
types including high amenity market rate apartments especially when those market rate apartments
are not gentrifying existing areas (i.e. displacing existing residents in a different economic housing
position).
The financial benefits of this project are substantial and should not be overlooked or passed upon:
· General Fund: This project will provide almost $1M per year in additional net available
funds ($33.5M in revenue less $10M in expenditures) over a 25 year period. The city needs
additional revenue sources and development of undertuiltized parcels needs to be part of
the plan. I pray that our city council and city staff utilize these additional funds responsibly.
· Low Income Housing: Provision of over $6M of in-lieu fees. This will not solve our low
income and homeless housing issues but it certainly will help.
· Santiago Park: The additional $1.4M allocated to the park for improvements will
otherwise likely not happen without this development (or one of similar nature).
I am glad that the developer has made changes to the project. The Planning Department’s
suggested changes, which I presume the developer finds acceptable, seems to also be moves in the
right direction which hopefully will help garner support although I doubt that it will to the “no
apartment” supporters. The changes that I have seen, which I find substantial, from the time that I
attended the Sunshine Ordinance (at which time I was originally opposed to the project) through
now include:
· Decreased number of units (density and bulk)
· Change of entrance away from Edgewood
· Terraced structure on the backside of the property adjacent to Park Santiago
neighborhood (2 stories at the back)
· Providing of security patrol for the surrounding neighbors and park
· Funding for improvements at Santiago Park
· Increased parking ratios
· Raising the height of the wall to adjacent single family neighbors
· Inclusion of a Public Art project
· Providing of $1.4M to improve Santiago Park
· Inclusion of Amazon Lockers for the surrounding neighbors
· Providing funds for Park Santiago neighbors to apply for historic district designation
The alternative use of the property which presumably would be to remain a professional office
building designation likely with a 3 story building (dropped down to 2 sotry in the back although the
way the parcels are drawn this may not be 100% required by a savy developer) will bring more traffic
to our area of the city and likely will not provide the additional community benefits (public art,
Edgewood entrance or lack therof, neighborhood security, park improvements, etc…). Overall, I
believe that this project may be better off than the reasonable alternative.
Lastly, the city’s own planning department who are trained in these matters support the project.
There are also other neighbors in the community who support it but will not speak up because they
believe that their neighbors will not look kindly upon them which is unfortunate in our great
community. Again, I support this project and hope that after listening to all stakeholders in the
community, reviewing the EIR, reviewing the staff reports, and also considering the city as a whole
and not just one area, that you will support it also.
Thank you for your service to the residents of Santa Ana.
Here is my prior email from November 26th:
Dear Planning Commission through ecomments, Councilmembers, Mayor, Selena Kelaher, Candida
Neal and Minh Neal…I am writing you this email to express my thoughts on the 2525 N. Main
development. I am unable to attend the Planning Commission's meeting on November 26th but I
am hopeful that you will have an opportunity to read this email and consider it as part of your
planning session tonight. I also hope that you closely consider the thoughts, needs, and desires of
the surrounding community, EIR, the Planning Department Staff, and the Developer as well as the
needs of the City of Santa Ana as whole.
As you know, there is a fair amount of public opposition to this project. I for one was previously very
opposed to this project. However, the more that I learn about it and also the needs of our city, the
more I become in favor it. I am not alone in this thought process. Even though the most vocal
crowd will be opposed, rest assured that there are a fair number of residents in the area who are in
favor of this type of development for a variety of reasons. There are some that are even afraid to
speak up because they do not want to be viewed as not being neighborly or they once opposed it
and now are neutral or even in support of it when weighing the alternatives. The North Santa Ana
Preservation Alliance (NSAPA) does not speak for everyone in our end of town.
I would like to address what I believe to be the main opposition:
The Developer Is Not Listening to Us!
You will likely hear folks say that the Developer is not listening to NSAPA. This is simply not true.
Yes, it is still a residential development, which they are opposed to, however the Developer has
made significant changes to the project based upon community feedback during council meetings,
neighborhood meetings, direct discussions, etc… Some of these changes may be considered minor
while others are quite extensive and likely changed the economics of the project for the Developer.
For example:
· There is no longer an egress on Edgewood which will significantly reduce cut through
traffic. This looks to have been in response to the community concern about cut through
traffic in PS. Now for a resident of 2525 to leave through PS, it will not be an easy way to go
but requiring at least one U-Turn and a left turn and the traffic lights associated with such.
· They increased the set back against the back wall. This is not required by code by the
way. This was in response to the community being concerned about the project being too
close to residential back yards.
· They are doing a "stair step" on the levels in the back of the project- from 3 to 4 to 5
stories. Again, this appears to have been in response to the community being concerned
about the project looking into their backyards.
· They changed the look of the project. This was in response to folks not liking the
original concept drawings. They also offered to meet with NSAPA members if the current
look of the project was not acceptable. It is my belief that this type of meeting did not take
place.
· They have reduced the density.
· They have increased the parking ratio above industry norms and increased the ratio as
they have decreased density. They have also removed general pedestrian access on
Edgewood I believe. These are in direct response to concerns of overflow parking into PS
especially the no pedestrian access. Most folks will not want to park in PS because of the
distance they will need to walk to get to their apartment because there is no access on
Edgewood.
· They are providing security patrol for PSNA. This appears to have been in response to
concerns about crime in the area.
· They are trying to be a good neighbor by sharing. They are providing an Amazon Locker
area solely for PSNA. They are also allowing PS residents to utilize the amenities of the
project.
· They are providing significant funding to the park (Park Santiago)…this is huge in my
opinion. It is something that
Building Usage
Unfortunately, I think that a lot of folks do not realize that the project site is currently zoned for a 3
story office project with 3 stories of parking (likely 4 with one sub-terranean). The reality of the
situation is that the site should not remain underutilized. It will not remain a small footprint 2 story
building with a massive amount of surface parking- that is not feasible nor should the city want it. I
personally believe that a 3-story building, which likely will be around 387K square feet, can have
even more of a detrimental effect when compared to the current alternative for 2525.
I believe that most folks who are opposed to the development and using items such as traffic,
parking, visual look, etc…as reasons to be opposed are comparing it to the existing state for that
parcel which is a small underutilized (or even unutilized) office space with a vast amount of surface
parking. It is not good for the fiscal impact to the city. It is not good for the surrounding businesses
and it very well may not be the best for the surrounding residents.
The No Project/No Build alternative in the EIR, although an alternative, simply is not a realistic
alternative and it will also deprive the city of some benefits. By not developing the property to its
highest and best use, the city will lose out on valuable property taxes. The amount of money that
this project could provide to the city will be substantial in both recurring property taxes and also
one-time fees. The funds will not only help with annual general fund obligations but also with our
housing crisis in the city- both low income and market rate. The low income fees that they will have
to pay is tremendous and can certainly be put to good use by the city.
Although the project cannot and should not be viewed in an economic bubble, the revenue side
certainly has to be of high importance especially considering the fiscal crisis we are in at a time when
the economy is supposedly doing relatively well. The amount of money that a developer would need
to invest in rehabbing the current property simply is not a realistic use of their capital when
compared to the annual cash flow potentially provided. A reasonable investor will strive to increase
cash flow and the current building would not provide that return.
The North end of Santa Ana is a great community. We desire strong businesses to be located here.
We desire to have a nice grocery store like a Trader Joe's. If we desire those things, unfortunately, it
can be said that additional high income residents will strengthen the case for a grocery store like a
Trader Joe's to consider the area. I personally would not like it at that location simply because of the
traffic generation but there certainly are other areas that could possibly support it.
Key Comparisons- 2525 vs Current Zoning
When comparing the current proposed housing development versus the existing zoning of a 3-story
office building, it is important to consider the following:
· Traffic- An office building of this size will produce more traffic than the 2525 proposal.
If traffic is a concern of the opposition, then they should not be in favor of the current zoning
but instead be in favor of something else. A 3-story office building as allowed under the
current zoning simply has the potential to be much worse for our community traffic-wise as
compared to a residential alternative. Certainly, the residential proposal may generate more
traffic during off-peak times such as late night and weekends but that is not when traffic is
bad/worst on Main Street…it is bad during peak commute times which is where a residential
development has a better traffic impact as compared to the existing office use.
· Traffic Flow- An office building will not have just one entrance on Main. Instead, it will
have its entrance on Edgewood as is currently provided for. They may be able to add a
secondary entrance on Main, however since the entrance is already on Edgewood, a
developer of the property as an office building can keep it there. This appears to be worse
for the Park Santiago neighborhood and the resulting cut through traffic. Not to mention
that those travelling North on I-5 will simply exit 17th Street and cut all the way through Park
Santiago making a morning commute even worse with cut through traffic. With the current
Main Street only exit/entrance, the cut through traffic, although likely not eliminated, should
be significantly less than the existing proposal.
· Parking- An office building of this size will likely provide enough parking for tenants and
guests. However, this size of a building will also often have paid parking. This means that
some guests and even some tenants may be tempted to save the parking fees and park in
the residential area. Overflow parking is a concern of the neighbors but it should also be a
concern under the existing allowed zoning. With the residential usage, there seems to be
ample parking with the new proposal (2 spots per unit) whereas with an office usage there
will be an economic advantage by parking in the Park Santiago streets because they will be
able to save parking money.
· Green Space- We all love green space. I believe that the current housing development
proposal would provide for more overall green space. Now, it will not necessarily be public
greenspace, but it will be good for the environment and since the Park Santiago residents
may be able to use it, it may also be good for them in certain instances. Currently, the
property is a dilapidated and underutilized office building and a surface parking lot- a lot of
asphalt. A new development will certainly bring more greenspace to the corner lot.
· Low Income Housing Fees- We have a lot of concern about housing the homeless and
otherwise our city's homeless problems in our area town. An office redevelopment will not
provide the in-lieu of fees associated with a multi-family residential development. These
fees, which likely will exceed $6M, will help our city with our affordable housing crisis.
· Visual Appearance- 2525 will be situated next to a very charming and historic
neighborhood and in close proximity to others. Looks are important to neighbors. The
develop has expressed his availability to discuss the visual appearance of the project,
however I do not believe that anyone from NSAPA took him up on this offer. Additionally,
will a 3 story, 387 square foot office building provide all that much of a better visual
experience as you enter Park Santiago? We also must consider that even though the setback
against Spurgeon may be larger in an office usage, they will likely have 3 stories at that
setback line as opposed to the proposed 2-story building under the 2525 proposal
· Availability of Housing- Yes, the prices of these apartments will be high. They may be
the highest in Santa Ana. They are also in an area of town that has the highest single family
residence values in the city. Our city is in need of housing. Our city is need of all types of
housing. By having more supply of housing, even premium priced housing, we should see
some relief of housing stock. Plus, it will help due to the low income housing fees paid by
the developer to provide even more housing.
· Population Density- Sure, an office building will not bring additional housing to Santa
Ana on that site. We will hear folks say that Santa Ana is already so very densely populated.
Well, our end of town is an outlier in Santa Ana. The Park Santiago neighborhood has a
density of 7.19K per square mile, West Floral Park is at 6.21K per square mile while Floral
Park is at 5.85K per mile (all according to this research site:
https://statisticalatlas.com/place/California/Santa-Ana/Population) . The average for Santa
Ana is 12.29K per square mile. Some neighborhoods have population density of in escess of
40K per mile (Cornerstone Village at 63.13K, 41.96K for Willard, etc…our end of town is
definitely an outlier and much less densely populated than the majority of Santa Ana. If we
cannot have additional housing in our part of town, how do we justify it in other parts of
town that are much more densely populated? Whether we want to admit it or not, when
our vacancy rates are as low as they are right now, which is essentially just vacant turn over
time, we have a housing issue to deal with. The entire city has a housing issue to consider.
Even the areas of town that are less densely populated should be considering how we can be
part of the solution.
We need to consider that if this project is stopped, which I don't think they should, that the next one
may be worse for all parties (including the city due to residential development fees) and due to the
current zoning on that property, we may be stuck with what we can get. We have an opportunity
right now to be sure that any positive changes to the project that can be made, are considered.
Residential Property Values
There is a lot of concern about what a high density development will do for our property values.
Sure, there may be a short term decrease as those who are so opposed to living next to apartments
decide to sell their homes despite the residents of 2525 quite possibly paying more per month for
their rent than our cost of ownership. However, I believe that the residents of 2525 will be the
future home buyers of our houses when we are ready to move on. If they are willing to pay the
prices proposed, they will soon be trying to buy a home- and hopefully in our great neighborhoods.
Additionally, if folks do move, which I hope that they do not, they likely will be replaced by new
buyers who will pay higher property taxes due to Prop 13 value resets to fair value. This is not a
reason to approve the project but just a silver lining in case folks do intend to move because of this
project.
Conclusion
There are positives that can come about from this project if we keep an open mind when comparing
it to the existing 3-story building zoning…less traffic, more city revenue, more low income housing
availability through development fees, etc…. Yes, there are negatives such as a possible lack of fit
with the Park Santiago neighborhood and also a change from the current status quo of a vacant
building and these need to be weighed and considered when viewing this project.
Please consider all voices and not just those that speak the loudest or in the most numbers, but also
consider the entire city. We cannot look at this in a bubble but must look at what is best for the
whole city. As a resident of North Santa Ana, I want the best not only for my current neighbors, but
my fellow residents who live in a completely different part of town and also future neighbors who do
not even know they will be moving into Santa Ana in the future. I trust you will also and as such,
please consider all aspects of this project when determining the best course of action.
Thanks for your consideration.
From:Cathy Morehead
To:eComment
Subject:2015 Envision Map and Staff EIR report
Date:Sunday, January 13, 2019 9:46:25 PM
Attachments:image.png
Dear Planning Commission,
I have spent several hours trying to find ANY valid reason why the attached map call
the 'Envisioning Santa Ana Plan' is being included as part of the Staff Report for the
2525 Main EIR . I have carefully searched the City of Santa Ana web site and read the
front to back the 'City of Santa Ana General Plan Housing Element' and no where other
than Vineyards marketing material and their reference to it on the EIR does this exist.
In fact it even says on their marketing material this is conceptual from the City of
Santa Ana does not represent any efforts to rezone or redesignate properties shown.
The map was prepared by Santa Ana Planning and Building department in 2015. The
developer stated in the Sunshine notes as the reason he purchased the property. What
does he know that the rest of us do not?
This is the second instance the Planning Department according to the Developer has
presented the 2525 Main project was a go without virtually any restrictions. First it
was no height restrictions for the project and now this map, what is going on? Is this
not the cart before the horse?
Why is the Envision map which has not been put on record anywhere for the
public to see nor formally approved , being used in the Staff recommendation
report of the EIR? Is this project potentially going to be approved based
statements like this? Please read page 20 below from the Staff report for
2525 Main.
Thank you,
Cathy Morehead
Cathy Morehead + Associates
C. 714-381-3340
www.CathyMorehead.com
From:Mitre-Ramirez, Norma
To:Bernal, Sarah; Magalona, Jocelyn; Fregoso, Vince
Cc:Huizar, Maria; Thai, Minh; Orozco, Norma; Rojano, Michael
Subject:FW: Support development at 2525 main st
Date:Monday, January 14, 2019 10:07:21 AM
The following communication pertaining to an item on tonight’s Planning Commission meeting, has
been received for your review and consideration.
Kind Regards,
Norma Mitre
Assistant Clerk of the Council
City of Santa Ana | Clerk of the Council Office
20 Civic Center Plaza | Santa Ana, CA 92701
714-647-5237| nmitre@santa-ana.org
This email and any files or attachments transmitted with it may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe that you may have received this communication in
error, please advise the sender via reply email and immediately delete the email you received.
From: Alfredo Quitral <asq1961@gmail.com>
Sent: Friday, January 11, 2019 5:40 PM
To: eComment <eComment@santa-ana.org>
Subject: Support development at 2525 main st
I support this project and residents of Park Santiago should not block opportunity for all is
Santa Ana
From:Mitre-Ramirez, Norma
To:Bernal, Sarah; Fregoso, Vince; Magalona, Jocelyn
Cc:Thai, Minh
Subject:FW: Jan 14 City of Santa Ana Planning Commission Meeting
Date:Wednesday, January 16, 2019 4:35:53 PM
Good Afternoon,
I’m not sure if you received the additional correspondence regarding 2525 N. Main from Mr.
and Mrs. Rosenberg.
Kind Regards,
Norma Mitre
Assistant Clerk of the Council
City of Santa Ana | Clerk of the Council Office
20 Civic Center Plaza | Santa Ana, CA 92701
714-647-5237| nmitre@santa-ana.org
This email and any files or attachments transmitted with it may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe that you may have received this communication in
error, please advise the sender via reply email and immediately delete the email you received.
From: olerose@aol.com <olerose@aol.com>
Sent: Tuesday, January 15, 2019 12:00 PM
To: eComment <eComment@santa-ana.org>
Cc: ejrosenb@aol.com
Subject: Jan 14 City of Santa Ana Planning Commission Meeting
DATE: January 15, 2019
TO: City of Santa Ana Planning Commission
RE: 2525 North Main Street Development Project
Due to yesterday's rainfall and local intersection flooding, my spouse and I
were not able to attend the city's public meeting on a contemplated high-rise,
high-density residential structure at 2525 North Main Street.
Barely a mile away, near 22 Freeway on/off ramps and the Town and County
Senior residential complex, there are TWO new high-rise, high-density
apartments with no landscaping and no easement -- these structures are sited
NOT DISTRIBUTED - RECEIVED AFTER
DEADLINE OF 1/14/19 @ 3:00 P.M.
virtually on top of public sidewalks. No provision for future street-lane
expansion here! And now a developer wants to add a third mega-tenement on
nearby Main Street...
Didn't Santa Ana learn anything from the mindless multi-residential building
spree that took place south of 17th /east of Bristol in the 1960 - 1970 era?
We are homeowners in the Jack Fisher Park neighborhood, coping with almost
daylong traffic jams on Bristol, 17th Street, and Main. WE SAY "NO" to this
new project.
Mr. & Mrs. Eric Rosenberg
olerose@aol.com/
From:Mitre-Ramirez, Norma
To:Bernal, Sarah; Magalona, Jocelyn; Thai, Minh
Cc:Huizar, Maria; Thai, Minh; Orozco, Norma; Rojano, Michael
Subject:FW: 2525 Main St/ Magnolia at the Park
Date:Monday, January 14, 2019 5:14:27 PM
The following communication pertaining to an item on tonight’s Planning Commission meeting, has
been received for your review and consideration.
Kind Regards,
Norma Mitre
Assistant Clerk of the Council
City of Santa Ana | Clerk of the Council Office
20 Civic Center Plaza | Santa Ana, CA 92701
714-647-5237| nmitre@santa-ana.org
This email and any files or attachments transmitted with it may contain privileged or otherwise confidential
information. If you are not the intended recipient, or believe that you may have received this communication in
error, please advise the sender via reply email and immediately delete the email you received.
From: Angela Solis <angelasolis@sbcglobal.net>
Sent: Monday, January 14, 2019 2:41 PM
To: eComment <eComment@santa-ana.org>
Cc: Angela Solis <angelasolis@sbcglobal.net>; Dale Helvig <helvig_denny@msn.com>
Subject: 2525 Main St/ Magnolia at the Park
Dear Commissioners:
I do not support the proposed 496 unit development, Magnolia at the Park, at the
entrance to the Park Santiago neighborhood, at the northeast corner of North Main
Street and Edgewood Road
This development will DESTROY this quaint neighborhood.
The most obvious reason is the size and density of the development. 496 apartments
next to a historic neighborhood is excessive. I do not feel the traffic study has been
adequately addressed. Edgewood is essential to entering and exiting our
neighborhood and the project will congest it and the surrounds streets with cars
& traffic which will have a negative impact on our neighborhood and home values.
In addition to obstruction of views, noise & crime.
I am opposed to this project because I have worked hard to afford a home in a
quiet, clean, non crowded historic and caring neighborhood.
Any of the surrounding businesses that have supported this project do not seem
empathetic to those that live in the neighborhood after the work day ends.
Our neighborhood should be guarded and protected from this development.
In conclusion,This is the WRONG PROPERTY TO REZONE FOR THIS PROJECT.
DISTRIBUTED AT THE MEETING ON 1/14/19
PLEASE vote NO on this project!
Thank you to all my fellow neighbors that have provided the Commissioners
with detailed information on the impact, your tireless efforts are appreciate.
Sincerely,
Angela Solis
Angela Solis
Phone: 310-503-6039
angelasolis@sbcglobal.net