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Recent advances in structural glass engineering have contributed to a proliferation of <br />glass windows on building facades. This proliferation is readily observable in newer <br />buildings and in recent project planning documents, and it is represented by a <br />worldwide 20% increase in glass manufacturing for building construction since 2016. <br />Glass markets in the USA experienced 5% growth inboth 2011 and 2016, and was <br />forecast to grow 2.3% per year since 2016 (TMCapital 2019). Increasing window to wall <br />ratios and glass facades have become popular for multiple reasons, including a growing <br />demand for `daylighting.' Glass is also a prominant feature of the proposed project, <br />according to depictions of the buildings in the Staff Report. I estimated >70% of fagades <br />could be composed of glass, including glass railings and glass walls. The depictions in <br />the Staff Report include additional contributing collision hazards such as large <br />transparent glass panels, interior lighting, nearby trees, and entrapment spaces interior <br />to the building structures. Entrapment spaces would include `The Social,' `The <br />Hangout,' `Outdoor Escape,' `Fireside,' `The Dinner Party,' `The Backyard,' `Garden <br />Lounge,' `Public Plaza,' and `Entertainment Garden.' Birds entering these species grow <br />increasingly desperate to get out, flying back and forth until colliding with a perceived <br />escape that happens to be a glass panel. <br />City of Santa Ana (2007, 2018) did not address the issue of bird -window collisions. The <br />only window issue addressed was potential glare, to which the 2007 EIR specified on <br />page i-5, "Proposed new structures shall be designed to maximize the use of textured or <br />other nonreflective exterior surfaces and non -reflective glass." The only mitigation <br />measures formulated to minimize bird impacts included preconstruction surveys for <br />nesting birds, timing of tree removals to avoid the nesting season, and careful use of <br />construction vehicles (MM-OZ 4.3-1). No measures were proposed to minize bird - <br />window collision mortality. <br />Glass -facades of buildings intercept and kill many birds, but these facades are <br />differentially hazardous to birds based on spatial extent, contiguity, orientation, and <br />other factors. At Washington State University, Johnson and Hudson (1976) found 266 <br />bird fatalities of 41 species within 73 months of monitoring of a three-story glass <br />walkway (no fatality adjustments attempted). Prior to marking the windows to warn <br />birds of the collision hazard, the collision rate was 84.7 per year. At that rate, and not <br />attempting to adjust the fatality estimate for the proportion of fatalities not found, 4,235 <br />birds were likely killed over the 50 years since the start of their study, and that's at a <br />relatively small building fagade (Figure 1). Accounting for the proportion of fatalities <br />not found, the number of birds killed by this walkway over the last 50 years would have <br />been about 12,705. And this is just for one 3-story, glass -sided walkway between two <br />college campus buildings. <br />5 <br />