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® PLACEWORKS 0-18 The Commenter questions the viability of the project in a post-COVID environment. This is not a CEQA-related comment. Pursuant to the decision in California Building Industry Association (CBIA) v. Bay Area Air Quality Management District (BAAQMD) (Case No. S213478), CEQA evaluates a project's impact on the environment, not the environment's impact on a project. Therefore, this is not CEQA issue that needs to be evaluated in the Addendum. As indicated in Section 3, Project Description, the Proposed Project would be comprised of two buildings: a 16-story, 194-foot-tall residential and commercial building and a 10-story, 127.5-foot- tall hotel building. While the referenced staff report notes the DDA would allow the applicant to seek to convert the hotel to residential if the hotel is not financially sustainable after three years of operation, any such potential conversion of the hotel to other uses would require additional entitlements from the City and would trigger additional environmental review under CEQA. 0-19 Please refer to Response 0-1 and 0-8. 0-20 A helipad is not proposed and is not included in the project description. As a result, no environmental analysis of a helipad is necessary. 0-21 The Commenter raises questions related to geology and soils. It should be noted that the first level of the existing parking garage is partially subterranean, and the existing finished grade of the Project Site is approximately five feet below ground surface. The Proposed Project would require additional excavation to a finished grade of approximately 11 feet below ground surface. This will require the off site haul of approximately 23,055 cubic yards of material off -site. The Project Engineer has reviewed the proposed grading plans and has indicated that this material can be removed without any disruption to the Spurgeon Building or any other structures located in the vicinity of the Proposed Project. Potential geotechnical impacts are full discussed in Section 5.7, Geology and5oils, of the Addendum. Additionally, a grading permitshall be required for all grading work, in compliance with California Building Code (CBC) Chapter 33 and Appendix Chapter 33 and the Santa Ana Municipal Code (SAMC) and other applicable laws including the Federal Clean Water Act which for construction activity is regulated by the NPDES. The grading permit application will require submittal of a soils report. In addition, the City's Grading Plan Guidelines require that "[a]II cut slopes shall be investigated both during and after grading by the Geotechnical Engineer to determine if any slope stability problem exists. Should excavation disclose any geological hazards or potential geological hazards, the Geotechnical Engineer shall submit a recommended treatmentto the City Engineer for approval." Compliance with the CBC, SAMC, and the City's Grading Plan Guidelines will ensure that no impacts to adjacent structures will occur. 0-22 Please refer to Response 0-1. As noted above the Proposed Project is located in a Transit Priority Area (TPA) and therefore, aesthetic and parking impacts cannot be considered a significant impact. Additionally, the Appendix G Traffic Impact Analysis and Appendix B Technical Study Updates memorandum analyzed the project and on -site roadway and site access improvements. 0-23 Please refer to Response 0-5. As noted above the Proposed Project is located in a Transit Priority Area (TPA) and therefore, aesthetic and parking impacts cannot be considered a significant impact. 0-24 Potential impacts related greenhouse gas emissions (GHG) are fully discussed in Section 5.8, Greenhouse Gas Emissions, of the Addendum. In addition, a technical study for GHG has been prepared for the Proposed Project and included as Appendix D. As discussed in the Addendum, the impacts identified for the Proposed Project showed that the Proposed Project will result in approximately 2,731.12 MTCO2e/year which is below the screening threshold of 3,000 MTCO2e/year. Therefore, the Proposed Projectwould notexceed the threshold and project -related 75A-481 November 2020 1 Page 8