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<br />. <br /> <br />CK <br />'D <br /> <br />,- <br /> <br />Charles, Kane & Dye LLP <br /> <br />April 18, 2005 <br /> <br />REFER TO FILE NO.: <br />20500.001 <br /> <br />VIA E-MAIL (dbott@ci.santa-ana.ca.us ) <br />& OVERNITE EXPRESS <br /> <br />City of Santa Ana <br />20 Civic Center Plaza <br />Santa Ana, CA 92702 <br />Attn: Mr. Dan Bott <br /> <br />Re: Draft Environmental Impact Report for Mac Arthur Place South <br /> <br />Ladies and Gentlemen: <br /> <br />Please be advised that this office represents the Doubletree Club Hotel/ Orange County <br />Airport located at 7 Hutton Centre Drive, Santa Ana, California ("Doubletree Club"). In this <br />regard, I have reviewed the Draft Env~~n~ IlJi);pact Report for MacArthur Place South <br />dated March, 2005 ("EIR"). In s ", y, the l~ is deficient because it fails to address <br />significant parking issues resulting fr the pr project, as more specifically described <br />below: <br /> <br /> <br />1. equf.ement that prior to the issuance of <br />building permits, the proposed develo .... . d " a parking plan in cooperation with the <br />City of Santa Ana, the importance of the parking issues created by the proposed project <br />demand that such parking plan be developed, discussed and approved as a part of this EIR. <br />Given the high density of the proposed project, the implication of a mitigation measure to <br />render the impacts of the parking requirements as "less than significant" cannot be determined <br />at this time without a parking study. Accordingly, the conclusions reached in the EIR as to <br />parking are wholly inadequate and lacking in merit. The parking study must be completed as <br />a vital component to the EIR. <br /> <br />2. In addition to those concerns raised by the residents in the SandPointe <br />community, Doubletree Club has specific recorded rights to park an additional 50 vehicles in <br />Hutton Centre. Copies of these recorded parking rights are attached for your review. As you <br />will note, these parking spaces may be relocated from time to time and must now be relocated <br />because of the proposed project. Given the loss of existing parking as a result of the overall <br />build-out of the Hutton Centre, and the increased parking demands specifically created by the <br />proposed project, Doubletree Club has attempted to obtain without success from the project <br />developers assurances as to the availability and location of its additional fifty (50) parking <br />spaces. The only response from the project developers has been that such parking will be <br /> <br />1920 Main Street, Suite 1070 · Irvine, CA 92614 · TEL: 949.852.8868 · FAX: 949.852.9878 . www.ckdcounsel.com <br /> <br />75B-279 <br />