Item 26 - Public Hearing Regarding Bristol Project

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Response to Comment L17: Nhu Nguyen dated August 12, 2024 Comment L17.1: This comment expresses concern over the number of units proposed for the Specific Plan. The comment claims that the area does not have capacity for the potential growth induced from the Project resulting in additional traffic on Bristol Street and Macarthur Boulevard. Response L17.1: The comment does not raise any specific environmental concern with the analysis within the Draft Supplemental EIR or requirements of the proposed Specific Plan. As detailed throughout the Draft Supplemental EIR, specifically in Sections 3.0 Project Description, and 5.8 Land Use and Planning, the proposed Project is within the General Plan allowable density for the site. The existing General Plan District Center High (DC-5) land use designation has an allowable density of 125 dwelling units per acre (du/ac) and maximum height of 25 stories, and the proposed development would result in a maximum density of 91 du/ac, which is 34 du/ac below the maximum allowed by DC-5, which was evaluated previously by the City in the GPU FEIR. Therefore, additional demands from buildout of the site have also been cumulatively evaluated as part of buildout of the City. Draft SEIR Section 5.13 Transportation, details that Senate Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the State CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land uses" (Public Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section 21099(b)(2), the SEIR focuses on analysis of Vehicle Miles Traveled (VMT) criteria and improvements to the circulation system along the Project's frontage to accommodate buildout of the proposed Project, pursuant to the City's recent General Plan Update. Further yet, the SEIR is not required to analyze impacts related to traffic congestion. Nevertheless, a Traffic Impact Analysis was prepared for the Project and is publicly available on the City's Project website. This comment will be forwarded to all decision makers as part of the staff report for the Project. In regard to school services, as discussed in Section 5.11 Public Services, the need for additional school facilities is addressed through compliance with school impact fee assessment. SB 50 (Chapter 407 of Statutes of 1998) sets forth a state school facilities construction program that includes restrictions on a local jurisdiction's ability to condition a project on mitigation of a project's impacts on school facilities in excess of fees set forth in the Government Code. These fees are collected by school districts at the time of issuance of building permits for commercial, industrial, and residential projects. The existing Santa Ana Unified School District development impact fee is $4.08 per square foot for all new residential development, and $0.66 per square foot for new commercial development. Pursuant to Government Code Section 65995 applicants pay developer fees to the appropriate school districts at the time building permits are issued; and payment of the adopted fees provides full and complete mitigation of school impacts. As described in Section 3.0, Project Description, of the Draft SEIR, an administrative Police Department Substation (no transfers or bookings) would be located within the commercial use area of the Project site. The substation would provide space for the expansion of policing services in the southern portion of the City and would provide the ability to quickly respond to emergency calls from within the Project site. The specific location would be determined prior to construction of the first phase of the proposed Project. Also, in Section 5.11 Public Services, it describes that the proposed Project would address typical residential security concerns by providing low -intensity security lighting, security cameras, electronic access to buildings, and onsite security personnel. Pursuant to the City's existing permitting process, the Police Department would review and approve the final site plans to ensure that the City's Crime Prevention 39