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Silva. IlRogers Acanfia, June 29, 2023 Talia Nimmer Mitchel M. Tsai, Attorney at Law Pasadena CA 91101 : Subject: Cabrillo Town Center Project, Santa Ana Review of Environmental Noise Analysis Dear Talia: We have completed a review of environmental noise analysis that supported the City Planning Commission staff recommendation to approve of the Site Plan Review and Tentative Tract Map for the Cabrillo Town Center project in Santa Ana. Here are our findings: OVERVIEW The project site is within the bounds of the Metro East Mixed Use (MEMU) Overlay Zone in the City of Santa Ana. • In its Site Plan Review and Tentative Tract Map evaluation, the City of Santa Ana Planning Commission has relied on the findings and recommendations of the MEMU Environmental Impact Report dated March 2007 and Supplemental Impact Report dated August 2018. • The closing paragraph on page 12 of the Planning Commission Staff Report dated April 24, 2023 includes this statement: "The previously prepared 2007 EIR and 2018 SEIR adequately described the project's environmental setting, significant impacts and alternatives, and mitigation measures related to each impact. " We disagree. In our opinion, there are aspects of the noise analysis in the MEMU EIR/SEIR that do not adequately describe the environmental setting of the Cabrillo Town Center project. We also find that the evaluation of noise impacts in the MEMU EIR/SEIR does not capture the full scope of likely noise sources associated with a large mixed -use project and is based on thresholds of significance that overlook key local regulations. • Additional study— including field work— is required to adequately evaluate the potential noise impacts of the Cabrillo Town Center project and determine additional mitigation measures/features necessary to adequately protect neighboring residential uses. AMBIENT NOISE BASELINE, OVERLOOKED SENSITIVE RECEIVERS Section 4.9 of the MEMU EIR reports results of a series of noise measurements made at a total of 15 monitoring locations in and around the MEMU area, as shown in Figure 4.9-1 and described in table 4.9-3. These measurements do not adequately characterize the baseline noise condition at sensitive receivers around the project site because: - They are short-term (15-minute), daytime readings only and do not therefore capture the quieter evening and nighttime periods, when any noise impacts from the project will be more disruptive to nearby receivers. 2355 Westwood boua evoacl, Swilo 411 Ios Angea es, CA90064 fel: 310 234 0939 rogersoroustics.roan