55A - SAN LORENZO SEWER LIFT STATION

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• Mr. Steve Worrall January 13, 2012 Page 9 • (RFEIR, p. 70. See also RFEIR p. 72 [ "...while Alternative Site No. 2 could be constructed more quickly than indicated in the RDEIR... "].) Reduced construction time results in reduced impacts. With respect to water quality and hydrology, the FRIER asserts with no substantial evidence that the 16 -foot deep, 50 -foot long sewer by -pass required for the Project somehow has less impact than the additional sewer pipe required for Alternative No. 2. 2. Alternative Site 3. In our prior objection letter of October 31, 2011, we provided substantial evidence to show that Alternative Site 3, 2835 S. Bristol Street, results in less construction - related traffic impacts and that the impacts from odors are, to put it blund , fabricated. This is confirmed in Mr. Dickson's attached report. e z 1v i e- 51 � 3. Alternative Site 5. Mr. Dickson's prior alternatives analysis provided to the City on August 27, 2010 indicated that use of this site would require approximately 100 feet less force main and gravity sewer than the San Lorenzo site. His report attached hereto also indicates that use of this site will not require construction of a temporary by -pass. This will result in less land disturbance, which the City identifies elsewhere in the RDEIR as resulting in a lesser impact to water quality and hydrology. Table 5 -1 should be revised accordingly. Use of Alternative Site 5 will also shorten Phase 2 by at least four week. A shorter construction time leads to reduced air quality impacts than the San Lorenzo site. Again, Table 5 -1 should be revised accordingly The purported parking impact is not as severe as suggested. The operational deficiency, according to the Santa Ana Municipal Code, will only be six spaces — approximately 4% — and only temporarily. Section 41 -638.1 of the Code recognizes that less than Code required parking will not always create a potentially significant impact by providing for minor exceptions to off - street parking requirements. This is equally applicable to any alternative for which a potentially significant parking impact is claimed. The analysis also asserts that the alternative would be "legally infeasible" because it would result in a violation of the City's Municipal Code requirements for off - street parking. This is incorrect. The Municipal Code provides for exceptions to off -street parking requirements and there is nothing to preclude the City from taking an action that 55A -142