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E P I D SOLUTIONS,INC <br />WHERE EXPERIENCE AND PASSION MEET <br />Date: August 9, 2024 <br />Prepared by: Meaghan Truman, Associate Environmental Planner III <br />To: Ali Pezeshkpour, apezeshkpour@santa-ana.org <br />Site: Related Bristol Specific Plan Project <br />Subject: Late Comment Letters on the DEIR for the Related Bristol Specific Plan Project <br />Received before August 10, 2024 (SCH No. 2020029087) <br />Dear Mr. Pezeshkpour, <br />The 45-day public comment period for the SEIR of the Related Bristol Specific Plan Project began July 6, <br />2023, and ended on August 21, 2023, as documented on the City's website, the Orange County Clerk's <br />website, and State Clearinghouse. <br />Under CEQA, a lead agency is required to consider comments on the Draft SEIR and to prepare written <br />responses, if a comment is received within the public comment period. (Pub. Resources Code, § 21091, <br />subd. (d); CEQA Guidelines, § 15088.) When a comment letter is received after the close of the public <br />comment period, however, a lead agency does not have an obligation to respond. (Pub. Resources Code, <br />§ 21091, subd. (d)(1); Pub. Resources Code, § 21092.5, subd. (c)("Nothing in this section requires the lead <br />agency to respond to comments not received within the comment periods specified in this division, to <br />reopen comment periods, or to delay acting on a negative declaration or environmental impact report.").) <br />Although a lead agency is not required to respond to late comments, it may choose to do so. (Gray v. <br />County of Madera (2008) 167 Cal. App. 4th 1099, 1110 (Gray), citing Pub. Resources Code, § 21091, <br />subd. (d)(1); CEQA Guidelines, § 15088; Gilroy Citizens for Responsible Planning v. City of Gilroy (2006) <br />140 Cal.AppAth 911, 925, fn. 10 (Gilroy Citizens)). <br />The three letters were received by the City of Santa Ana after the 45-day public comment period for the <br />Draft SEIR ended on August 21, 2023. However, the City of Santa Ana has elected to prepare the <br />following written responses with the intent of conducting a comprehensive and meaningful evaluation of the <br />proposed Project. The number designations in the responses are correlated to the bracketed and identified <br />portions in the comment letter. EPD Solutions, Inc. has reviewed the letter and provided responses for the <br />Lead Agency's consideration in review of the Related Bristol Specific Plan Project at the August 12, 2024, <br />Planning Commission Hearing. As further detailed in the individual responses to comments below, none of <br />the comments indicate that there would be a substantial increase in the severity of a previously identified <br />environmental impact that would not be mitigated, or that there would be any of the other circumstances <br />requiring recirculation as described in CEQA Guidelines Section 15088.5. No new significant environmental <br />impact would result from the project or from a new mitigation measure proposed to be implemented, there <br />is no substantial increase in the severity of an environmental impact, no feasible project alternative or <br />mitigation measure considerably different from others previously analyzed would lessen the environmental <br />impacts of the Project, and the Draft and Final SEIR are not fundamentally inadequate and conclusory in <br />nature. <br />Please find the letter and response to comments attached. <br />Respectfully, <br />Meaghan Truman <br />