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E � P � D SOLUTIONS,INC
<br />V, R I, 1,, P' I II IE N I, E A N 11 P A',39 II ,I , f t,Ar E IE €'
<br />Date: October 1, 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 Supplemental EIR for the Related Bristol Specific Plan
<br />Project Received before October 1, 2024 (SCH No. 2020029087)
<br />Dear Mr. Pezeshkpour,
<br />The 45-day public comment period for the Supplemental EIR of the Related Bristol Specific Plan Project
<br />began July 6, 2023, and ended on August 21, 2023, as documented on the City's website, the Orange
<br />County Clerk's 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, subd.
<br />(d); CEQA Guidelines, § 15088.) When a comment letter is received after the close of the public comment
<br />period, however, a lead agency does not have an obligation to respond. (Pub. Resources Code, § 21091,
<br />subd. (d)(1); Pub. Resources Code, § 21092.5, subd. (c)("Nothing in this section requires the lead agency to
<br />respond to comments not received within the comment periods specified in this division, to reopen comment
<br />periods, or to delay acting on a negative declaration or environmental impact report.").) Although a lead
<br />agency is not required to respond to late comments, it may choose to do so. (Gray v. County of Madera
<br />(2008) 167 Cal. App. 4th 1099, 1 1 10 (Gray), citing Pub. Resources Code, § 21091, subd. (d)(1); CEQA
<br />Guidelines, § 15088; Gilroy Citizens for Responsible Planning v. City of Gilroy (2006) 140 Cal.App.4th
<br />911, 925, fn. 10 (Gilroy Citizens)).
<br />The letters were received by the City of Santa Ana after the 45-day public comment period for the Draft
<br />Supplemental EIR 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 letters and provided responses for the
<br />Lead Agency's consideration in review of the Related Bristol Specific Plan Project at the October 1, 2024
<br />City Council Hearing. As further detailed in the individual responses to comments below, none of the comments
<br />indicate that there would be a substantial increase in the severity of a previously identified environmental
<br />impact that would not be mitigated, or that there would be any of the other circumstances requiring
<br />recirculation as described in CEQA Guidelines Section 15088.5. No new significant environmental impact
<br />would result from the project or from a new mitigation measure proposed to be implemented, there is no
<br />substantial increase in the severity of an environmental impact, no feasible project alternative or mitigation
<br />measure considerably different from others previously analyzed would lessen the environmental impacts of
<br />the Project, and the Draft and Final SEIR are not fundamentally inadequate and conclusory in nature.
<br />Please find the letters and responses to comments attached.
<br />Respectfully,
<br />Meaghan Truman
<br />
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