HomeMy WebLinkAbout75C - PH MORTIMER MIXED USEREQUEST FOR
COUNCIL ACTION
CITY COUNCIL MEETING DATE:
DECEMBER 1, 2020
TITLE:
PUBLIC HEARING — APPEAL APPLICATION NO.
2020-02, APPEALING THE DECISION OF THE
PLANNING COMMISSION TO APPROVE AN
ADDENDUM TO THE TRANSIT ZONING CODE
ENVIRONMENTAL IMPACT REPORT FOR THE
4TH AND MORTIMER MIXED -USE PROJECT, AND
TO CONSIDER ENVIRONMENTAL REVIEW NO.
2018-13 AND AMENDMENT APPLICATION NO.
2020-04 TO ALLOW CONSTRUCTION OF THE 4TH
AND MORTIMER MIXED -USE PROJECT
LOCATED AT 409 AND 509 EAST FOURTH
STREET (PROPERTY OWNER: NORTHGATE
GONZALEZ RE, LLC AND APPLICANT: RED OAK
INVESTMENTS, LLC)
/s/ Kristine Ridq(
CITY MANAGER
CLERK OF COUNCIL USE ONLY:
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❑
As Recommended
❑
As Amended
❑
Ordinance on 1"Reading
❑
Ordinance on 2nd Reading
❑
Implementing Resolution
❑
Set Public Hearing For
CONTINUED TO
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RECOMMENDED ACTION
1. Adopt a resolution denying Appeal Application No. 2020-02 and upholding the Planning
Commission's approval of a resolution adopting an Addendum to the Environmental Impact
Report for the Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a mitigation
monitoring and reporting program for Site Plan Review No. 2020-03 and Variance No. 2020-06.
2. Adopt a resolution approving an Addendum to the Environmental Impact Report for the Transit
Zoning Code Project (SCH NO. 2006071100) and adoption of a mitigation monitoring and
reporting program for Amendment Application No. 2020-04.
3. Adopt an ordinance approving Amendment Application No. 2020-04 for Specific Development No.
84 (SD84).
PROPERTY OWNER AND APPLICANT INFORMATION
1. Owner: Northgate Gonzalez Real Estate
2. Applicant: Red Oak Investments, LLC
3. Project Representative: Andrew Nelson
PLANNING COMMISSION ACTION & BACKGROUND
At its regular meeting on October 12, 2020, and after receiving public testimony on the item, the
Planning Commission voted unanimously (7:0) to adopt a resolution approving an Addendum to the
Environmental Impact Report (EIR) for the Transit Zoning Code Project (SCH NO. 2006071100),
mitigation monitoring and reporting program, Site Plan Review No. 2020-03 (SPR) as conditioned,
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and Variance No. 2020-06 (VAR) as conditioned. The Planning Commission modified Condition No.
6 of Site Plan Review No. 2020-03 and Variance No. 2020-06 requiring a public art plan prior to
issuance of the certificate of occupancy, instead of prior to issuance of a building permit. The modified
condition also requires the art work to be completed within a year of completion of the project. In
addition, the Planning Commission recommended that the City Council adopt a resolution approving
an Addendum to the Environmental Impact Report for the Transit Zoning Code Project (SCH NO.
2006071100), mitigation monitoring and reporting program, and an ordinance approving Amendment
Application No. 2020-04 for Specific Development No. 84 (SD84).
On October 22, 2020, Michael Lozeau with Lozeau Drury, LLP, on behalf of the Supporters Alliance
for Environmental Responsibility (SAFER), submitted an appeal application pursuant to Section 41-
645 of the SAMC (Exhibit 1) appealing the Planning Commission's approval of the addendum to
the TZC EIR in connection with the approval of the SPR and VAR based on three main reasons,
including: (1) CEQA compliance; (2) HOO applicability; and (3) consideration of the Planning
Commission regarding public comment letter received. Subsequently, on November 3, 2020,
Lozeau Drury, LLP, on behalf of SAFER, provided a letter to the City further stating its concerns
about the project's exemption from HOO requirements that are contained in Santa Ana Municipal
Code Section 41-1900 et seq. (Exhibit 2).
DISCUSSION
Andrew Nelson, with Red Oak Investments, LLC, representing Northgate Gonzalez Real Estate, is
requesting approval of multiple entitlements to facilitate construction of a new mixed -use community
on two City blocks located at 409 East Fourth Street (Site A) and 509 East Fourth Street (Site B).
Specifically, the applicant is requesting approval of an addendum to the Environmental Impact Report
for the Transit Zoning Code (TZC) as well as an amendment application (AA) to modify the sub -
zoning designation of various parcels on Site B from the Urban Neighborhood 2 (UN-2) subzone to
the Urban Center (UC) sub -zone. The project would contain a total of 169 residential rental units and
11,361 square feet of commercial space.
It is recommended that the City Council approve the applicant's request due to the project's
satisfaction of meeting the intent of the TZC to promote a pedestrian -oriented environment with a mix
of land uses, facilitating the redevelopment of underutilized land with new development that is
compatible with the surrounding community, encouraging increased employment opportunities within
the City, the generation of additional property and sales taxes, and because the project will provide
additional high -quality housing stock.
Table 1: Proiect and Location Information
Item
Information
Project Address
409 East Fourth Street and 509 East Fourth Street
Nearest Intersection
Fourth and French streets and Fourth and Mortimer streets
General Plan Designation
Site A — District Center (DC)
Site B — Urban Neighborhood UN
Zoning Designation
Transit Zoning Code (Specific Development No. 84),
Downtown subzone (Site A) and Urban Neighborhood 2
subzone Site B
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Item
Information
Surrounding Land Uses
Commercial, Single- and Multi -Family North
Commercial and Single -Family East
Commercial and Multi -Family South
Commercial and Parkin West
Site Size
2.715 acres combined Site A: 1.423; Site B: 1.292 acres
Existing Site Development
Site A contains a commercial building (Northgate Gonzalez
Market) and a surface parking lot; Site B contains vacant
buildings and parcels.
Use Permissions
Mixed -use projects are permitted by Section 41-2006 and
Section 41-2007 of the SAMC.
Zoning Code Sections Affected
Uses
Table 2A, SAMC Sec. 41-2007. SPR
required pursuant to SAMC Sec. 41-
2007;
Development
Standards
Transit Zoning Code, SAMC Sec. 41-
2011, 41-2012 and 41-2023
Project Description
The project includes demolition of an existing Northgate Gonzalez Market and surface parking lot at
409 East Fourth Street (Site A) as well as the demolition of an existing commercial automobile service
building and ancillary structures at 509 East Fourth Street. The existing commercial facility, Ming's
Auto Repair, located at the northeast corner of Fourth and Mortimer streets (501 East Fourth Street),
is not part of the proposed project and will remain. Once the onsite buildings are demolished and
the sites are cleared, the applicant proposes to construct a mixed -use community on two
development sites, Site A and Site B, containing 169 residential units, 11,361 square feet of
leasable commercial area, and 422 onsite parking spaces. Table 2 on the next pages provides a
summary of the proposed project.
Table 2: Project Summary
Site A
Site B
Total
Site Area
1.423 acres
1.292 acres
2.715 acres
Residential
99 units
70 units
169 units
Amenities/Leasing
8,075 S.F.
None
8,075 S.F.
Office
Retail
11,361 S.F.
None
11,361 S.F.
Public/Common
15,345 S.F.
13,233 S.F.
28,578 S.F.
Open Space
Private Open
8,428 S.F.
2,832 S.F.
11,260 S.F.
Space
Parking
230 stalls
192 stalls
422 stalls
Residential and Commercial Components
Site A will contain a mixed -use commercial/residential structure with 99 residential units, a 3,847-
square-foot tenant suite designed for an eating establishment, 7,514 square feet of retail space, a
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resident and leasing lobby, site amenities, a bicycle storage room, and a four -and -a -half story,
aboveground parking garage with 230 parking spaces. The building frontage along Fourth Street,
and the intersections of Fourth and French street and Fourth and Mortimer streets, would be
seven -stories in height. The building would be five -stories in height along the French Street and
Mortimer Street frontages.
The proposed suite designed for an eating establishment would be located on the ground floor at
the corner of Fourth and French street and is designed to allow both indoor and outdoor dining.
Also fronting Fourth Street is the retail space and leasing office. The four -and -a -half story parking
garage would be located at the intersection of French and Fifth streets and will be accessed from
Fifth Street. Resident amenities will include a large pool, courtyard, and residential amenities on
the third level, and a rooftop deck on the seventh floor overlooking Fourth Street. A total of 23,773
square feet of open space, including 8,428 square feet of private open space and 15,345 square
feet of common open space will be included.
Site B is designed to be residential only and will contain 70 units and a four-story, aboveground
parking garage with 192 onsite parking spaces. The residential building will be accessed from a
lobby on Mortimer Street and would be five stories in height across the site. Along the Fourth Street
frontage, Site B would include a courtyard and residential units. The four-story parking garage
would be located at the corner of Fifth and Minter streets and will be accessed from Fifth Street.
Site B includes 16,065 square feet of open space, including 2,832 square feet of private open
space and 13,233 square feet of common open space.
Of the development's 169 units, 21 will be studios (12.5%), 38 will be one -bedroom (22.5%), 66
will be two -bedroom (39%), 9 will be three -bedroom (5%), and 35 will be four -bedroom units (21 %).
Units will range from 458 to 529 square feet for the studio units, 650 to 739 square feet for the
one -bedroom units, 938 to 1,185 square feet for the two -bedroom units, 961 to 1,237 square feet
for the three -bedroom units, and 1,325 to 1,520 square feet for the four -bedroom units. All units
will contain full kitchens, bedrooms, bathrooms, in -unit washer and dryers, and living/dining areas.
Architecture and Amenities
Both sites in the development have been carefully designed to be integrated within the existing
development pattern in Downtown Santa Ana. The design's primary objective is to complement
and expand the energy and character of downtown by taking cues from its urban scale and historic
character. The ground floor of Building A is designed in the Main Street Commercial architectural
style, consistent with identifiable patterns typical of downtown buildings. Building B's purely
residential design complements the existing multi -family developments along Fourth Street. A
landscape buffer is provided for each site creating a transitional space between the top of the
structure and the street level while also providing screening at the lower level of the garages
adjacent to the single-family residences. In addition, the building's architecture is designed to
lessen the massing of the project with its elevations featuring articulation, multiple volumes, and
varied architectural styles to mimic the appearance of multiple buildings. The building's varied
height from five -stories to seven -stories generates a smooth transition from the higher -density
character of the intersection of Fourth and French street to the lower -density character of the
single-family residences to the north and to the east.
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Each site has its own unique architectural vernacular defined by scale, facade articulation, roof
forms, materials, and detailing. A variety of window dimensions are provided where appropriate
while the header/sill trim details vary between both sites. Varied material/color palettes are featured
on both buildings, in addition to varied window recesses, and decorative elements. While color
palette is varied across both sites, care has been taken to provide a unified look to correspond to
the surrounding buildings. Both structures feature durable brick veneer, glass, smooth stucco
finishes, metal awnings, and textured blocks/panels. Lastly, the building will feature prominent
artwork/murals across both sites. To ensure that the art is reflective of Santa Ana and is a positive
cultural impact on the surrounding neighborhood, staff included a condition of approval that
requires the applicant to coordinate with the City's Arts and Culture Office and submit a Public Art
Plan to the Planning Division for review and approval.
The development will feature amenities commonly found at other upscale mixed -use
developments in the region. These include a large courtyard with a pool, spa, clubroom, fitness
room, and landscaping in the center of Site A; a roof terrace on the seventh floor of Site A,
overlooking Fourth and French streets; a leasing office and lounge in Site A; a bike locker in Site
A; and a ground -floor lobby and resident amenity area in Site B. In addition, the project features
private open space/decks for 59 units on Site A and 48 units on Site B. Conditions of approval
have been added to ensure the two -block project will be built and managed as a single community
and all amenities will be accessible to residents from either site.
Analysis of Appeal
Pursuant to Section 41-645(a) of the SAMC, appeals can only be made on a decision or
requirement made by the Planning Commission. Of the appeal reasons received, the only action
taken by the Planning Commission was the action to adopt a resolution approving the addendum
to the EIR for the TZC. The subsequent appeal items do not satisfy the requirements of SAMC
Section 41-645(a) and should not be considered because: (1) No decision or action was taken by
the Planning Commission regarding the HOO requirements because the HOO did not apply to the
project; and (2) consideration of a public comment letter received does not constitute decision or
requirement taken by the Planning Commission. Nonetheless, staff provides a comprehensive
response below on all appeal items received.
The appellant is requesting that the City Council overturn the Planning Commission's decision
approving the addendum to the TZC EIR for the 4th and Mortimer Mixed -Use project and provides
three main reasons to substantiate the request, including: (1) CEQA compliance; (2) HOO
applicability; and (3) Consideration of the Planning Commission regarding public comment letter
received:
California Environmental Quality Act (CEQA) Compliance
a. The appellant states that, "The City failed to comply with the California Environmental
Quality Act (CEQA) by failing to prepare a project -specific EIR for the project."
Summary of Appeal Reasoning: The appellant contends that because the 2010 TZC
EIR was a Program and not a Project EIR, State CEQA Guidelines Section 15152
precludes use of an addendum, State CEQA Guidelines Section 15162 and 15164
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cannot apply, and the City must prepare a Supplemental or Subsequent EIR. The
appellant further states that there is substantial evidence that the proposed project
will have new environmental impacts that were not analyzed in the 2010 EIR.
Moreover, the appellant states that: (1) There is significant evidence that the project
will result in significant indoor air quality impacts; (2) The project will have significant
impacts due to inconsistencies with the planning and zoning codes; (3) The project will
have significant impacts to historic resources; (4) The project fails to implement
mitigation measures required by the 2010 EIR; and (5) The project will have significant
adverse air quality and greenhouse gas impacts.
Staff Response: CEQA does permit the use of an addendum when the original EIR
being relied upon was a Program EIR. Public Resources Code Section 21166 and
CEQA Guidelines Section 15162 establish when an agency must prepare a
Supplemental or Subsequent EIR, and when an agency is permitted instead to
prepare an addendum. As established, one of the circumstances described in Public
Resources Code Section 21166 or CEQA Guidelines Section 15162 must be present
before either a Subsequent or Supplemental EIR is required. For the 4th and
Mortimer Mixed -use project, none of those conditions are present. These conditions
are:
1. Substantial changes are proposed which will require major revisions of the
previous EIR due to the involvement of new significant environmental effects
or a substantial increase in the severity of previously identified significant
effects;
2. Substantial changes occur with respect to the circumstances under which the
project is undertaken which will require major revisions of the previous EIR
due to the involvement of new significant effects or a substantial increase in
the severity of previously identified significant effects; or
3. New information has come to light showing new impacts, substantially more
severe impacts, that mitigation measures or alternatives previously found to
be infeasible would actually be feasible, or that mitigation measures or
alternatives previously not identified would reduce impacts.
This is also consistent with CEQA Guidelines section 15152(f), which the appellant
incorrectly claims prohibits use of addenda when the original EIR is a Program EIR.
Section 15152(f) states, "A later EIR shall be required when the initial study or other
analysis finds that the later project may cause significant effects on the environment
that were not adequately addressed in the prior EIR." For the subject project, the
"other analysis," includes the technical studies relating to shade and shadow, air
quality and greenhouse gas emissions, cultural resources, traffic, parking, noise and
vibration, Phase I environmental site assessment, hydrology, a preliminary water
quality management plan, and sewer capacity. In addition, the analysis includes the
text of the addendum, which found that no additional significant effects would occur
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beyond those already addressed in the 2010 EIR. Therefore, an addendum is the
appropriate CEQA document.
Land Use Impacts from Zone Change and Variance: The zone change and variance
for the project do not result in land use impacts. The addendum prepared for the 4th
and Mortimer Mixed -Use project analyzes whether the project (including its proposed
zone change and variance) would result in incompatibilities with surrounding existing
uses, result in the division of an established community, result in inconsistencies with
regional land use plans, and consistency with the general plan and TZC. The
addendum explains that the proposed zone change and the proposed variance on a
single block would accommodate the proposed building type, density and massing.
Further, the zone change and variance would improve consistency by permitting
aesthetic consistency between the two buildings proposed for the project, would
provide a better transition between lower and higher density than the current zoning
allows, and the proposed buildings (including building type, density, and massing)
would not result in any incompatibilities with adjacent buildings and uses.
Although the TZC provides for a mixture of development types situated within walking
distance of many modes of transit, it did not contemplate the precise route of the OC
Streetcar at the time of its adoption in 2010. The 4th and Mortimer Mixed -Use project
is proposed to be located adjacent to eastbound segments of the streetcar with a
stop immediately adjacent at the intersection of Fourth and French streets. As a
gateway project along the streetcar line, the proposed zoned change facilitates a
design that better reflects a sense of downtown and builds upon allowable planning
and architectural intensities, affirmatively addressing the pedestrian orientation and
circulation at all street frontages. Furthermore, the zone change acknowledges the
density and building envelope opportunities of the TZC to support the recent
investment in the streetcar and maximizing development potential along the
proposed routes. Thus, substantial evidence supports the addendum's conclusion
that no land use impact would occur.
Historic Resources: As explained in the addendum, none of the buildings on either
site are a historic resource. Moreover, none of the buildings are considered eligible
for listing on either the National Register or the California Register. The building on
Site B was considered potentially eligible for local listing in 1980 but due to the
building's significant alterations to the brick and stucco fagade, the double stepped
parapet fagade, the removal of the metal cap pieces and double -hung windows, the
building is no longer considered eligible for even local listing. There is no evidence
available to support a conclusion that the building is historically significant. Therefore,
demolition of the building does not constitute a new impact for purposes of CEQA.
As such, its demolition does not preclude use of an addendum.
Mitigation Measures from The Transit Zoning Code EIR: Should the City Council
approve the project, the City Council would also adopt the Mitigation Monitoring and
Reporting Program of the 2010 EIR. All mitigation measures from the 2010 EIR that
apply to individual projects within the TZC area would apply to this project. Some
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examples of the mitigation measures include, but are not limited to, exceeding
current Title 24 requirements by twenty -percent, ensuring that landscaping includes
a drought resistant plant palette, ensuring that the project's design features
incorporate light-colored roofing materials for energy conservation, and that the
building provides proper shielding for all new mechanical systems. Mitigation
Measures are made enforceable through the project's conditions of approval.
Further technical review of the appellant's findings regarding the substantial
evidence that the project will have several new environmental impacts not analyzed
in the 2010 EIR (e.g., significant indoor air quality impacts, significant adverse air
quality and greenhouse gas impacts, etc.) has been provided by the City's
environmental consultant, Rincon Consultants, Inc. Rincon's detail response letter
can be found as Exhibit 3 of this report.
The technical review concluded that building material manufacturer compliance and
regulations combined with the characteristics of formaldehyde would limit the
potential of human health risks to a less than significant level pursuant to the
Southern California Air Quality Management District (SCAQMD) significance
threshold of 10 per million. Therefore, health risks related to formaldehyde, including
impacts associated with the project, would not result in a new significant impact.
Moreover, the review concluded that air quality impacts were adequately assessed
according to methodologies recommended by the California Air Resources Board
(CARB) and the SCAQMD. Therefore, the project would not result in a significant risk
from airborne pollution or result in new or more severe impacts related to air quality
or greenhouse gas emissions. As such, the prepared addendum supports the
conclusion that changes to the project would not result in new or more severe
impacts, including those related to Aesthetics, Air Quality, Cultural Resources, Noise,
and Traffic, with implementation of applicable mitigation measures identified in the
2010 FEIR and included in the addendum discussion.
b. The appellant contends that under Sierra Club v. County of Sonoma (1992) 6
Cal.AppAth 1307 and Sierra Club v. County of San Diego (2014) 231 Cal.AppAth
1152, the fair argument test applies to the question of whether a subsequent EIR
should have been used.
Summary of Appeal Reasoning: The appellant states that CEQA contains a strong
presumption in favor of requiring a lead agency to prepare an EIR and that this
presumption is reflected in the fair argument standard. The appellant further provides
findings that the under the standard, a lead agency must prepare an EIR whenever
substantial evidence in the whole record before the agency supports fair argument
that project may have a significant effect on the environment.
Staff Response: Courts have held that the fair argument test applies only to
"preparation of an EIR in the first instance." Once an EIR has been prepared for a
project, CEQA Guidelines Section 21166 prohibits agencies from requiring a
subsequent or supplemental EIR unless substantial changes are proposed.
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For the subject project, the City has applied Section 21166 (see Section I(a) above)
and determined that substantial evidence supports the determination that the
changes required for the 4th and Mortimer Mixed -Use project (i.e., the site plan
review, zone change, and variance) do not result in new significant impacts and does
not require preparation of a Supplemental or Subsequent EIR. This determination is
subject to the substantial evidence standard, and not the fair argument test.
c. The appellant contends that the EIR for the Transit Zoning Code cannot have any
informational value relative to the 4th and Mortimer Mixed -Use Development Project,
because the 4th and Mortimer Mixed -Use Development Project seeks a zone change
and variance.
Summary of Appeal Reasoning: The appellant states that the 2010 EIR has no
informational value to the project and since the project exceeds the density and
massing analyzed in the 2010 EIR it is a new "project," and requires that the CEQA
process start at the beginning.
Staff Response: The appellant provides no legal citation for this statement, and the
statement is untrue. The TZC EIR analyzes and documents the environmental
impacts of zoning for the integration of new infill development into existing
neighborhoods, the provision of a range of housing options in downtown, and the
provision of a transit -supportive, pedestrian -oriented development framework to
support the addition of new transit infrastructure. The 4th and Mortimer Mixed -Use
project proposes a minor change to the zoning established in the TZC and analyzed
in the TZC EIR. The project is consistent with the objectives of the TZC, and, as
documented in the addendum, the TZC EIR's conclusions relating to aesthetics, air
quality, biological resources, cultural resources, hazardous materials, hydrology,
land use and planning, noise, population and housing, public services,
transportation, and utilities remain unchanged, even with implementation of the 4th
and Mortimer Mixed -Use project's zone change and variance. For each of these
resource areas, the analysis in the TZC EIR still applies and is still correct for the
downtown area. Therefore, the EIR has informational value relative to the 4th and
Mortimer Mixed -Use Development project.
d. The appellant contends that because the Transit Zoning Code EIR identified
significant and unavoidable impacts, State CEQA Guidelines section 15152(f) and
Communities for a Better Environment v. California Resources Agency (2002) 103
Cal.AppAth 98 the City cannot use an addendum.
Summary of Appeal Reasoning: The appellant states that State CEQA Guidelines
Section 15152(f) prohibits the use of an addendum when the original EIR identified
significant and unavoidable impacts. Furthermore, the appellant provides findings
that the Communities for a Better Environment v. California Resources Agency
(2002) 103 Cal.App.4th 98 holds that an addendum cannot be used where the original
EIR has identified significant and unavoidable impacts.
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Staff Response: CEQA Guidelines Section 15152(f) does not prohibit use of an
addendum where the original EIR identified significant and unavoidable impacts.
Instead, this section states, "A later EIR shall be required when the initial study or
other analysis finds that the later project may cause significant effects on the
environmental that were not adequately addressed in the prior EIR." As documented
in the technical reports prepared for the 4th and Mortimer Mixed -Use project and the
addendum, the 4th and Mortimer Mixed -Use project will not cause new significant
effects that were not previously disclosed in the TZC EIR.
Moreover, the cited court case does not apply. The case concludes that where a
subsequent project would result in new significant impacts (thus requiring a
subsequent or supplemental EIR), a statement of overriding considerations
specifically tied to that project must be adopted. Again, the subject project has no
new significant impacts, therefore no subsequent or supplemental EIR is required.
II. The appellant states that, "The City failed to comply with the Housing Opportunity Ordinance
("HOO") by failing to require the developer to include affordable housing units in the project."
Summary of Appeal Reasoning: The appellant claims that the project failed to comply with
the Housing Opportunity Ordinance (HOO) pursuant to the Santa Ana Municipal Code
(SAMC). Specifically, the appellant states that the HOO applies to the project because it
"exceeds densities allowed by current general plan and zoning" and as such the project
,'must provide inclusionary housing for low-income residents." The appellant specifically
sites SAMC Sections 41-1902(a) and (b). The appellant further provides findings regarding
the project inconsistency with the zoning, massing and density allowed by the current
general plan and zoning. The appellant suggests that the project requires amendments to
the zoning that will increase the residential density allowed by the general plan and zoning
code, thereby trigging the HOO and requiring that the developer provide affordable housing.
Staff Response: The HOO does not apply to the project because the project does not
exceed the residential density permitted in the general plan. As recently amended, the HOO
only applies when a project requires a general plan amendment. The proposed
development does not require a general plan amendment application.
Site A is zoned Transit Zoning Code (TZC) with a downtown subzone designation and has
a General Plan designation of District Center (DC). The development intensity in the DC for
the downtown area is based on a combination of floor area ratio (FAR) and zoning overlay
and/or development standards, but generally allows up to a maximum of 90 dwelling units
per acre (du/ac) and a maximum FAR of 3.0 (City of Santa Ana General Plan Land Use
Element, pg. A-11).
Site A is approximately 1.423-acres in size and is proposed to be developed as a mixed -
use commercial/residential structure with 99 residential units, a 3,847-square-foot eating
establishment, and 7,514 square feet of retail space. As proposed, Site A would have a
density of 69.6 du/ac and an FAR of 2.4. Therefore, Site A would not exceed the allowable
density nor the allowable FAR by the DC general plan designation.
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Site B is zoned TZC with an Urban Neighborhood 2 subzone (UN-2) designation and has a
General Plan Designation of Urban Neighborhood (UN). The residential density in the UN
is based on a combination of FAR and zoning development standards, but allows a
maximum FAR of 1.8 in the downtown area. The UN does not have a set maximum
allowable density as the DC general plan designation does (i.e., 90 du/ac), but instead relies
on the applicable zoning designation for the density.
In the TZC, the recommended residential densities are a range based on the allowable
building type, the maximum stories allowed, and the particular building size and massing
allowed. Moreover, a residential project can exceed the density range identified if it meets
the identified development standards (e.g., setbacks, open space, parking, etc.). The most
"intense" density range in the UN-2 zoning designation is based on the Hybrid Courtyard
housing type which ranges from 45-50 du/ac. Site B is approximately 1.292-acres in size
and is proposed to be developed as residential only with 70 residential units. As proposed,
Site B would have a density of 54.2 du/ac and FAR of 1.8. With approval of the variance
application and the amendment application, Site B would be in compliance with the
development standards in the TZC. Moreover, Site B would not exceed the density nor the
allowable FAR by the UN general plan designation.
The appellant's comment letter cites an outdated and superseded version of Section 41-
1902(b)(1). The HOO was amended on September 1, 2020, and the comment letter does
not reflect the amended language. The updated HOO was in full force and effect when the
Planning Commission took action on the project. While previously, Section 41-1902(b)(1)
applied the HOO to any project that exceeded the maximum density permitted by zoning,
the recent amendments remove this reference. As amended, the HOO now only applies
when a residential project proposes a residential density above the general plan permitted
density. As previously noted, the 4th and Mortimer Mixed -Use Development project is
consistent with the general plan and no general plan amendment is required for the project.
The project seeks only a zone change, on only a portion of the project site. Moreover, no
density allowance above that currently permitted by the site's general plan designation is
proposed. Therefore, the HOO does not apply.
III. The appellant states that, "The Planning Commission abused its discretion by failing to read
or consider comments submitted by Supporters Alliance for Environmental Responsibility
(SAFER)."
Summary of Appeal Reasoning: The appellant provided no additional information besides
that they believed the Planning Commission failed to consider the comments provided by
SAFER.
Staff Response: During the public comment section of the public hearing, Richard Drury
with Lozeau Drury, LLP, provided public comment on behalf of SAFER stating that they had
provided a comment letter the day of the public hearing, approximately an hour before the
start of the hearing. Furthermore, they stated their position that they did not think the project
75C-11
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should be approved unless proper CEQA analysis was conducted. Their findings were
consistent with the information provided in their appeal letter and attached to this report.
The Planning Commission considered Mr. Drury's public comment and received input from
the City Attorney and the City's environmental consultant regarding the whether the
addendum prepared for the project was the appropriate document. Both the City Attorney
and the consultant stated that no subsequent CEQA analysis was required for the project
other than the addendum which was prepared. Again, this was based on the fact that the
technical studies evidenced that an EIR Addendum to the previously -certified 2010 EIR was
the appropriate CEQA document to evaluate and disclose the project's impacts.
Analysis of the Issues
Section 41-664 of the SAMC requires a public hearing for the proposed amendment application to be
reviewed by the Planning Commission and the City Council, with the Planning Commission as a
recommending body and the City Council as the approving body. Since the project is seeking
approval of an amendment application for a zone change on Site B to change the subzone from UN-
2 to the Urban Center (UC), review and approval of an amendment application is required by the City
Council.
Amendment Application
The proposed project includes construction of two new Lined Block buildings, one of which would be
a maximum of seven stories in height with a floor area ratio (FAR) of 2.4 (Site A) and one that would
be five stories in height with an FAR of 1.8 (Site B). However, the UN-2 subzone does not include
Lined Block buildings as a permitted building type. Therefore, the project would require an
amendment application for a zone change on Site B from the UN-2 subzone to the Urban Center
(UC) subzone. The UC subzone was selected in order to maintain aesthetic consistency with the
proposed building on Site A. In addition, under the current UN-2 subzone, residential buildings with
densities of up to 50 dwelling units per acre (DU/acre) are permitted. The proposed project on Site B
involves development of a residential building with a density of approximately 54 DU/acre, which
represents a slightly higher intensity use than the UN-2 subzone recommended density range of up
to 50 DU/acre. However, Site B is surrounded by properties with higher intensity developments that
are zoned DT and UC to the west and south.
In addition, a review of the existing TZC map seen in Exhibit 8 demonstrates that it is was the original
intent of the TZC to place UC subzones as both a buffer and a transition between the uses permitted
in the high density Downtown (DT) subzone and the less intense UN-2 neighborhoods surrounding
it. While the adopted TZC allowed for the integration of new infill development into existing
neighborhoods, reuse of existing buildings, and creation of new mixed use and transit -oriented
development, it intended to transition the subzones with higher allowable densities to those that
permitted lower density ranges. With the exception of Site B, all of the adjacent DT subzone parcels
are surrounded by UC subzone parcels. The proposed change to the UC designation would be
consistent with the existing adjacent parcels that surround the DT subzone (see Figure 1 below).
75C-12
Appeal Application No. 2020-02, ER No. 2018-13 & AA No. 2020-04 — 4th and Mortimer Mixed -Use
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HL
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Figure 1. Proposed Transit Zoning Code Map
Although the TZC provides for a mixture of development types situated within walking distance of
many modes of transit (e.g., public transit, pedestrian, cyclists and automobiles), it did not
contemplate the precise route of the OC Streetcar at the time of its adoption in 2010. An eastbound
segment of the streetcar runs along the project site along Fourth Street with a stop immediately
adjacent to the project at Fourth and French streets. The Streetcar then proceeds northbound one
block to Mortimer Street, bisecting the two project sites and advancing to Santa Ana Boulevard
towards the Santa Ana Regional Transportation Center. As a gateway project along the streetcar line,
the UC subzone facilitates a design that better reflects a sense of downtown and builds upon
allowable planning and architectural intensities, affirmatively addressing the pedestrian orientation at
all street frontages, specifically along Fourth and Mortimer streets. Furthermore, the zone change
acknowledges the density and building envelope opportunities of the TZC to support the recent
investment in the streetcar and maximizing development potential along the proposed routes.
Lastly, the zone change to the UC subzone would provide for a more harmonious design on both
sites as they are being developed and managed together as one project. The building types under
the UN-2 subzone are limited to lower density and shorter building height developments such as the
Hybrid Court, Courtyard Housing, Live -Work, or Tuck -Under building type. Each of the allowable
building types under the UN-2 would have resulted in a design on Site B that looked arbitrarily carved
down and which presented an incongruous design. The UC subzone allows Site B to be designed in
the same building type as Site A while allowing each site to have a unique architectural vernacular
that complement the neighborhood and are integrated within the existing development pattern in
downtown. Though the proposed project would develop Site B at a slightly higher density use than
the existing TZC density range for UN-2, this use would be consistent with adjacent property uses
and the intent of the TZC by enhancing the pedestrian environment, creating opportunities for higher-
75C-13
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density transit -oriented residential development in proximity to jobs, and reactivating vacant land uses
adjacent to the historical Downtown shopping district.
Conformance to Transit Zoning Code Development Standards
The project has been designed to conform to the development standards in the Transit Zoning
Code, with the exception of the proposed building and massing standards on Site B. Furthermore,
with approval of the amendment application for the zone change on Site B, the project would
comply with the allowable building types. A full description of conformance to development
standards is provided in Exhibit 10 to this staff report.
Onsite Parking
The overall parking proposed for the project is 422 spaces, including 394 residential stalls and 28
commercial visitor stalls. The proposed residential parking provides a ratio of 2.3 parking spaces per
residential unit, with commercial parking provided at one space per 400 square feet of commercial
area, which meets and exceeds the minimum requirements of the TZC (2.15 spaces per unit and one
space per 400 square feet). Both parking garages will provide vehicular gates separating available
commercial parking spaces (e.g., guest, commercial, employee, etc.) from the residential parking
areas. Vehicular access will be provided from Fifth Street by one right -turn only driveway west of
Mortimer Street and one full access driveway east of Mortimer Street. The on -site circulation would
provide safe access for vehicle -pedestrian traffic and the driveway would provide sufficient throating
such that access to parking spaces is not impacted by internal vehicle queuing/stacking.
California Environmental Quality Act (CEQA)
An addendum to a previously certified EIR is prepared when a lead agency is asked to approve
modifications to an existing project for which an EIR has already been certified. An addendum
evaluates the requested modifications and determines whether subsequent EIR review is required.
Since none of the conditions specified in State CEQA Guidelines, section 15162 are present, an
Addendum to the previously -certified 2010 EIR was prepared for the 4th and Mortimer project.
Pursuant to State CEQA Guidelines section 15164(b), an addendum to a previously -certified EIR is
not circulated for public review. Pursuant to State CEQA Guidelines section 15164(d), the City
Council must consider the Addendum together with the TZC's original 2010 EIR before making a
decision on the project.
Previous CEQA Documentation
The 2010 EIR (SCH No. 2006071100) was prepared to evaluate the potential impacts associated
with the adoption of the Transit Zoning Code, which was anticipated to result in potential
development of approximately 4,075 residential units, 387,000 square feet of retail development,
and an additional 15.5 acres of open space within the City. Since the adoption of the TZC in 2010
there's been approximately 256 residential units and approximately 19,788 square feet of retail
development constructed. The remaining residential capacity is approximately 3,819 units and the
remaining retail square footage capacity is approximately 367,212 square feet.
The 2010 EIR considered the environmental impacts relating to aesthetics; air quality; biological
resources; cultural resources; hazards and hazardous materials; hydrology and water quality; land
use; noise; population, housing, and employment; public services; transportation and traffic;
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utilities and service systems; and climate change. A mitigation monitoring and reporting program
(MMRP), findings of fact, and a statement of overriding consideration were adopted with the 2010
EIR. As part of the 2020 Addendum to the 2010 EIR, the original MMRP must be readopted by the
Planning Commission. All mitigation measures in the original EIR and associated MMRP have
been enforced and are carried over within the 2020 Addendum, with exception of mitigation
measure MM4.4-1(a) as part of the Cultural Resources which was revised after consultation with
California Native American Tribes.
Addendum Conclusions
The Addendum focuses on the potential environmental impacts associated with the project,
including the site plan review application, variance, and amendment application that might cause a
change in the conclusions of the certified 2010 EIR, including changes in circumstances or new
information of substantial importance that would substantially change those conclusions.
To fully evaluate the proposed project's impacts on the site the development required preparation of
studies relating to shade and shadow, air quality and greenhouse gas emissions, traffic, parking,
hydrology, and sewer capacity, which were extensively peer reviewed by the City's CEQA consultant.
In addition, additional studies relating to cultural resources, noise and vibration were prepared by the
CEQA consultant (Attachments to the 2020 Addendum). In addition, the project is within a Transit
Priority Area. Under Senate Bill 743, aesthetic and parking impacts cannot be considered a significant
impact within a Transit Priority Area.
The 4th and Mortimer development project Addendum concludes no new or substantially greater
impacts would occur with implementation of the proposed development when compared to those
identified in the 2010 EIR and finds that no supplemental or subsequent EIR is required for the
proposed development. Therefore, the 2010 EIR's MMRP will continue to mitigate or lessen any
impacts already identified by the TZC's original 2010 EIR.
Economic Development
A fiscal and economic impact analysis prepared by RSG, Inc. and The Concord Group was submitted
for the project. The analysis estimates that the proposed development will result net positive fiscal
impacts to the City, the Business Improvement District, and create over 800 new temporary or
permanent jobs. Specifically, the analysis estimates the following impacts:
$5.4 million net new General Fund revenues associated with the project over a 25-year period,
resulting from:
o A total of $7.8 million in additional City General Fund revenue, including $2.9 million in
net new property tax revenues, construction period revenues, recurring site -specific
tax, and other Project impacts over a 25-year period, and
o $2.4 million in General Fund expenditures associated with the project over a 25-year
period
806 direct, indirect, or induced new jobs resulting from the project, of which 35 would be
permanent
Approximately $205,424 in Business Improvement District (BID) funds
75C-15
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Page 16
Table 3: Public Notification & Community Outreach
Public Notification, and Community Outreach each
Required
A community meeting was held on August 29, 2018 at 6:00 p.m. at 450
Measures
West Fourth Street (Latino Health Access) in accordance with the
provisions of the City's Sunshine Ordinance. This meeting was publicly
noticed in the OC Register, posted on the City's website, and
invitation/notices were mailed to property owners and occupants/tenants
in a 500-foot radius from the project site. An estimated 100 members of
the public attended, as well as City staff. The applicant provided all the
required information to the City after the meeting. Details from the
community meeting were posted to the project's webpage at
https://www.santa-ana.orq/pb/planning-division/major-planning-proiects-
and-monthly-development-protect-reports/4th-and.
Notification by mail was mailed to all property owners, occupants, and
other interested parties within 500 feet of the project site on November 20,
2020, in accordance with SAMC requirements. In addition, newspaper
posting was published in the Orange County Register on November 20,
2020, in accordance with SAMC requirements.
Additional
The applicant met with several interested groups, neighborhoods, and/or
Measures
individuals between August 2018 and September 2020. Meetings include
those with:
• Neighboring condominium associations and apartment buildings:
Spectrum Condominiums (450 E. 4th St.), Garden Court
Apartments (300 E. Santa Ana Blvd.) and Parks Apartments (510
Mortimer St.)
• Joint Meeting of Neighborhood Associations July 2020: French
Park, French Court, Logan, Lacy, Downtown and French Park
Plaza
• Business organizations and individual leaders associated with the
Santa Ana Business Council, Chamber of Commerce, Downtown
Inc.
• Historic preservation representative Tim Rush
• Eight individual property owners as a result of surveying every
residence across Fifth Street and Minter Street from development
site
CONCLUSION
Based on the analysis provided within this report, staff recommends that the City Council adopt a
resolution denying Appeal Application No. 2020-02 and upholding the Planning Commission's
approval of a resolution approving Addendum to the Environmental Impact Report for the Transit
Zoning Code Project (SCH NO.2006071100), mitigation monitoring and reporting program, Site Plan
Review No. 2020-03, and Variance No. 2020-06. Staff also recommends that the City Council adopt
a resolution approving an Addendum to the Environmental Impact Report for the Transit Zoning Code
75C-16
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Page 17
Project (SCH NO. 2006071100) mitigation monitoring and reporting program, and an ordinance
approving Amendment Application No. 2020-04 for Specific Development No. 84 (SD84).
FISCAL IMPACT
There is no fiscal impact associated with approval of this action.
Submitted By: Minh Thai, Executive Director - Planning and Building Agency
Exhibits: 1.
Appeal Application No. 2020-02 — Lozeau Drury, LLP
2.
Letter regarding 4th & Mortimer Project Housing Opportunity Ordinance
Compliance — Lozeau Drury, LLP
3.
Rincon's Response to Comments
4.
Resolution Denying Appeal Application 2020-02
5.
Resolution Approving 2020 Addendum
6.
Ordinance Approving AA No. 2020-04
7.
Planning Commission Staff Report
8.
Existing TZC Zoning Map
9.
Proposed TZC Zoning Map
10.
Conformance to Development and Parking Standards
11.
2020 EIR Addendum and Technical Appendices
12.
2010 Transit Zoning Code El
13.
Fiscal and Economic Impact Analysis
75C-17
EXHIBIT 1
Planning and Building Agency
Planning Division
20 Civic Center Plaza
P.O. Box 1988 (M-20)
Santa Ana, CA 92702
(714)647-5804
I. OWNER/APPLICANT
APPEAL APPLICATION
Applicant Michael Lozeau on behalf of Supporters' Alliance for Environmental Responsibility ("SAFER")
Full name of Person, Firm, or Corporation
1939 Harrison Street, Suite 150 Oakland, CA 94612 ( 510) 836-4200
Mailing Address Area Code Phone No.
Legal Owner Name: Block/Site A: LOS ALTOS XXI, L.P. / Block/Site: B GON-REY, L.P.
Legal Owner Address: Block/Site A: 1201 N Magnolia Ave. Anaheim, CA 92801
Block/Site B: 1201 N Magnolia Ave. Anaheim, CA 92801
Phone No.: (714 ) 687-7057 (714) 687-7075 Fax: ( )
(B o Site AT— (Block/Site B)
II. PROPERTY INFORMATION Transit Zoning Code;
Northgate Gonzalez Market, parking Downtown subzone; District Center & Urban
Land Use lot & vacant buildings Urban Neighborhood Neighborhood
Existing Land Use of Property and/or Building Zoning District General Plan Designation
Location 409 E Fourth St & 509 E Fourth St Fourth and French St & 4th & Mortimer Sts
Street Address Name of Nearest Intersecting Street
SEE REVERSE SIDE FOR SUBMITTAL REQUIREMENTS
III. REASON FOR REQUEST
In the following provided space, please clearly specify and explain the error(s) of decision or
requirement upon which you are basing this appeal. (If additional space is needed, please attach
additional comments to the back of this application.)
Please see attached
The city failed to comply with the California Environmental Quality Act by
failing to prepare a project -specific EIR for the project. (See details attached).
The city failed to comply with the Housing Opportunity Ordinance by
failing to require the developer to include affordable housing units in the project.
The Planning Commission abused its discretion by failing to read or consider
comments submitted by SAFER.
Applicant's Signature: Date:
APPEAL APPLICATION NO. OWL- 10Z� Z--t}(�
cmlcmr-frrnlappeal
5/00 75C-18
T 530.836.4200 1939 Harrison Street, Ste. 150 www.lozeaudrury.com
F 510.836.4205 Oakland, CA 94612 michael@lozeaudrury.com
Via Overnight Mail
October 21, 2020
Pedro Gomez, Associate Planner
Planning Division
City of Santa Ana
20 Civic Center Plaza, Ross Annex M-20
Santa Ana, CA 92701
Re: Filing Fee for Appeal of 4th & Mortimer Project
Dear Mr. Gomez:
Enclosed please find check no. 13227 for the amount of $456.16 dated October 21, 2020. This check is to
pay the filing fee associated with the attached Appeal of the decision made by the Planning Commission on
October 12, 2020 regarding the 4' & Mortimer Project (Site Plan Review No. 2020-03, Variance No. 2020-
06, Amendment Application No. 2020-04, and addendum to the Environmental Impact Report for the
Transit Zoning Code Project).
If you could please confirm receipt of this filing fee and appeal packet via email with my paralegal Komal
Toor (komal(a,lozeaudrurv.com) it would be greatly appreciated. Thank you very much for your time.
Sincerely,
Michael Lozeau
Lozeau Drury LLP
Attorneys for SAFER
75C-19
T 510.836.4200 I 1939 Harrison Street, Ste. 150 www.lozeaudrury.com
F 510.836.4205 Oakland, CA 94612 1 richard@lozeaudrury.com
VIA E-MAIL AND US MAIL
October 12, 2020
Chair Mark McLoughlin
and Commissioners
Planning Commission
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92702
eComments()santa-ana.org
Ali Pezeshkpour, AICP
Project Manager
Planning and Building Agency
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92702
APezeshkpour(c)santa-ana.org
Minh Thai, Executive Director
City of Santa Ana
Planning and Building Agency I M20
20 Civic Center Plaza
Santa Ana, CA 92702
mthai@santa-ana.org
Re: Comment on EIR Addendum for 4th & Mortimer Project (SCH NO.
2006071100)
Chair McLoughlin and Members of the Planning Commission:
I am writing on behalf of the Supporters' Alliance for Environmental Responsibility
("SAFER"), a California non-profit organization with members living in and around the City
of Santa Ana, regarding the 4th & Mortimer Project, proposed to be located on two city
blocks at 409 East 4th Street (Block A), and 509 East 4th Street (Block B). ("Project"). Staff
contends that the potential environmental effects of the Project have been fully addressed
by the Transit Zoning Code Environmental Impact Report certified a decade ago in 2010
("2010 EIR"). Fundamentally, the proposed Project is an entirely different project than
was analyzed in 2010 EIR ("2010 Project"). The proposed Project is inconsistent with the
zoning, massing and land use analyzed in the 2010 EIR, and therefore requires zone
changes. The proposed Project includes greater massing and higher population density
than analyzed in the 2010 EIR. Also the Proposed Project fails to incorporate numerous
mitigation measures required by the 2010 EIR. The Proposed Project will have several
new and different environmental impacts that were not analyzed in the 2010 EIR. Finally,
the 2010 EIR recognized that the 2010 Project would have many significant and
unmitigated environmental impacts. As such a new draft EIR is required to analyze and
mitigate the impacts of the proposed Project.
75C-20
4th and Mortimer CEQA Addendum
October 12, 2020
Page 2 of 15
A number of highly qualified experts have reviewed the proposed Project and its
environmental effects. Certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH,
and Dr. Paul Rosenfeld, Ph.D. and Matthew Hagemann, C. Hg. of environmental
consulting firm Soil Water Air Protection Enterprise ("SWAPE") have identified a number
of significant impacts from the proposed Project including air quality impacts, as well as
omissions and flaws in the documents relied upon by staff. These comments are attached
as Exhibits A and B.
By opting to proceed with an Addendum instead of the required EIR or
supplemental EIR ("SEIR"), the City of Santa Ana ("City") has deprived the members of
the public of the public review and circulation requirement available for EIRs. SAFER
urges the Commission not to adopt the Addendum or approve the Project, and instead to
direct staff to prepare a Draft EIR for the Project, and to circulate the Draft EIR for public
review and comment prior to Project approval.
PROJECT DESCRIPTION
The Project involves a residential and commercial development that would consist
of 169 residential units and 11,361 square feet of commercial retail space on two city
blocks, 409 East 4th Street (Block A) and 509 East 4th Street (Block B).
The City attempts to rely on a decade -old EIR certified in 2010 for the Transit
Zoning Code ("TZC"). The TZC area covers over 100 blocks and 450 acres in the central
core of Santa Ana. Under the TZC, Block A is currently zoned as "District Center -
Downtown subzone," and Block B is zoned as "Urban Neighborhood 2 subzone" (UN-2).
Block B is inconsistent with the zoning, massing and density studied in the 2010
EIR. The UN-2 zoning allows single-family duplexes, triplexes and quadraplexes,
courtyard housing and rowhouses. UN-2 does not allow "lined block buildings" such as
proposed by the Project. (Addendum 2-11). The Project exceeds the massing allowed in
the UN-2 zone and therefore requires a variance from section 41-2023 of the zoning
code. In particular, UN-2 requires that floors 3-5 of a building may cover no more than
85% of the ground floor, but the project proposes 100% coverage. (Addendum 2-11).
The Project exceeds the density allowed in UN-2. UN-2 allows density of up to 50
dwelling units per acres, but the Project proposes 54 DU/acres. (Addendum 3.6-5). For
these reasons, the Project proposes to rezone the property from UN-2 to Urban Center
(UC).
LEGAL STANDARD
CEQA contains a strong presumption in favor of requiring a lead agency to prepare
an EIR. This presumption is reflected in the fair argument standard. Under that standard,
a lead agency must prepare an EIR whenever substantial evidence in the whole record
before the agency supports a fair argument that a project may have a significant effect on
the environment. Pub. Res. Code § 21082.2; Laurel Heights Improvement Ass'n v.
Regents of the University of California (1993) ("Laurel Heights II") 6 Cal. 4th 1112, 1123;
75C-21
4th and Mortimer CEQA Addendum
October 12, 2020
Page 3 of 15
No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 82; Quail Botanical Gardens
v. City of Encinitas (1994) 29 Cal.AppAth 1597, 1602.
A. Addendum Standard.
The City relies on CEQA Guidelines § 15162 and 15164 to claim that no CEQA
review is required. The court of appeal recently stated, "The addendum is the other side
of the coin from the supplement to an EIR. This section provides an interpretation with a
label and an explanation of the kind of document that does not need additional public
review." "It must be remembered that an addendum is prepared where '(2) Only minor
technical changes or additions are necessary to make the EIR under consideration
adequate under CEQA; and (3) The changes to the EIR made by the addendum do
not raise important new issues about the significant effects on the environment.'
([Guideline] 15164, subd. (a).)" Save Our Heritage Org. v. City of San Diego, 28 Cal.
App. 5th 656, 664-65 (2018) (emphasis added).
Section 15164(a) of the State CEQA Guidelines states that "the lead agency or a
responsible agency shall prepare an addendum to a previously certified EIR if some
changes or additions are necessary, but none of the conditions described in Section
15162 calling for preparation of a subsequent EIR have occurred." Pursuant to Section
15162(a) of the State CEQA Guidelines, a subsequent EIR or Negative Declaration is
only required when:
(1) Substantial changes are proposed in the project which will require major revisions
of the previous EIR or negative declaration due to the involvement of new
significant environmental effects or a substantial increase in the severity of
previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the
project is undertaken which will require major revisions of the previous EIR or
Negative Declaration due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant
effects; or
(3) New information of substantial importance, which was not known and could not
have been known with the exercise of reasonable diligence at the time the
previous EIR was certified as complete or the negative declaration was adopted,
shows any of the following:
(A) The project will have one or more significant effects not discussed in the
previous EIR or negative declaration;
(B) Significant effects previously examined will be substantially more severe than
shown in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would,
in fact, be feasible and would substantially reduce one or more significant
effects of the project, but the project proponents decline to adopt the mitigation
measure or alternative; or
(D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more
75C-22
4th and Mortimer CEQA Addendum
October 12, 2020
Page 4 of 15
significant effects on the environment, but the project proponents decline to
adopt the mitigation measure or alternative.
B. Tiering Under CEQA
CEQA permits agencies to 'tier' EIRs, in which general matters and environmental
effects are considered in an EIR "prepared for a policy, plan, program or ordinance
followed by narrower or site -specific [EIRs] which incorporate by reference the discussion
in any prior [EIR] and which concentrate on the environmental effects which (a) are
capable of being mitigated, or (b) were not analyzed as significant effects on the
environment in the prior [EIR]." (Cal. Pub. Res. Code ("PRC") § 21068.5.) "[T]iering is
appropriate when it helps a public agency to focus upon the issues ripe for decision at
each level of environmental review and in order to exclude duplicative analysis of
environmental effects examined in previous [EIRs]." (PRC § 21093.) The initial general
policy -oriented EIR is called a programmatic EIR ("PEIR") and offers the advantage of
allowing "the lead agency to consider broad policy alternatives and program wide
mitigation measures at an early time when the agency has greater flexibility to deal with
basic problems or cumulative impacts." (14 CCR §15168.) CEQA regulations strongly
promote tiering of EIRs, stating that "[EIRs] shall be tiered whenever feasible, as
determined by the lead agency." (PRC § 21093.)
"Subsequent activities in the program must be examined in light of the program
EIR to determine whether an additional environmental document must be prepared." (14
CCR § 15168(c).) The first consideration is whether the activity proposed is covered by
the PEIR. Id. If a later project is outside the scope of the program, then it is treated as a
separate project and the PEIR may not be relied upon in further review. (Sierra Club v.
County of Sonoma (1992) 6 Cal.App.4th 1307.) The second consideration is whether the
"later activity would have effects that were not examined in the program EIR." (14 CCR §§
15168(c)(1).) A PEIR may only serve "to the extent that it contemplates and adequately
analyzes the potential environmental impacts of the project." (Sierra Nevada
Conservation v. County of El Dorado (2012) 202 Cal.AppAth 1156). If the PEIR does not
evaluate the environmental impacts of the project, a tiered EIR must be completed before
the project is approved. (Id.)
For these inquiries, the "fair argument test" applies. (Sierra Club, 6 Cal.AppAth
1307, 1318; see also Sierra Club v. County of San Diego (2014) 231 Cal.AppAth 1152,
1164 ("when a prior EIR has been prepared and certified for a program or plan, the
question for a court reviewing an agency's decision not to use a tiered EIR for a later
project 'is one of law, i.e., the sufficiency of the evidence to support a fair argument."').)
Under the fair argument test, a new EIR must be prepared "whenever it can be fairly
argued on the basis of substantial evidence that the project may have significant
environmental impact. (Id. at 1316 [quotations omitted].) When applying the fair argument
test, "deference to the agency's determination is not appropriate and its decision not to
require an EIR can be upheld only when there is no credible evidence to the contrary."
(Sierra Club, 6 Cal. App. 4th at 1312.) "[I]f there is substantial evidence in the record that
the later project may arguably have a significant adverse effect on the environment which
was not examined in the prior program EIR, doubts must be resolved in favor of
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environmental review and the agency must prepare a new tiered EIR, notwithstanding the
existence of contrary evidence." (Sierra Club, 6 Cal.App.4th at 1319.)
DISCUSSION
A. CEQA REQUIRES THE CITY TO PREPARE A TIERED EIR FOR THE PROJECT
INSTEAD OF AN ADDENDUM
The City has incorrectly applied the CEQA criteria for preparing an addendum
when, instead, the City should have applied CEQA's tiering provisions. The City relies on
CEQA Guidelines section 15164, which applies to preparing an addendum to an existing
EIR for a project. However, the 2010 EIR was not a project -specific EIR, which the CEQA
Guidelines define as an "EIR[which] examines the environmental impacts of a specific
development project." (14 CCR § 15161.) Rather, the 2010 EIR was a comprehensive
policy and regulatory guidance document for the private use and development of all
properties within the TZC area. Tiering is governed by CEQA Guidelines section 15152,
not sections 15162 and 15164.
The 2010 EIR made clear that the City was relying on CEQA's tiering provisions. li
states, "This EIR will be used to tier subsequent environmental analysis for future
development included within the Transit Zoning Code boundaries, as allowed by
Section 16162 of the CEQA Guidelines." (2010 DEIR 2-4). There is no question that
the 2010 TZC EIR was intended as a first tier CEQA document, and that second tier
CEQA documents would be required for specific project proposals. The 2010 EIR states
that it will "provide a basis for the preparation of subsequent environmental
documentation for future development within the Transit Zoning Code area." (2010 DEIR
2-1). Thus the 2010 EIR clearly contemplated that specific projects would be subject to
"subsequent environmental documentation." The 2010 EIR states, "the Transit Zoning
Code does not constitute a commitment to any specific project ... Thus, the EIR will
analyze these future actions at a programmatic level. Each future development
proposal undertaken within the Transit Zoning Code must be approved individually
by the City, as appropriate, in compliance with CEQA." (2020 DEIR 2-2). Despite
these clear assurances that the 2010 EIR was a programmatic EIR and that project -
specific environmental review would be required for individual projects, the City is now
attempting to avoid the very project -specific review that is promised the public in 2010.
The 2010 EIR is a Program EIR, which the CEQA Guidelines define as:
An EIR which may be prepared on a series of actions that can be characterized as
one large project and are related either:
(1) Geographically,
(2) As logical parts in the chain of contemplated actions,
(3) In connection with issuance of rules, regulations, plans, or other general criteria
to govern the conduct of a continuing program, or
(4) As individual activities carried out under the same authorizing statutory or
regulatory authority and having generally similar environmental effects which can
be mitigated in similar ways.
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(14 CCR § 15168.) Thus, instead of proceeding under the provisions of CEQA Guidelines
section 15164, the City should have proceeded under section 15152 provisions for
subsequent analysis for a Program EIR rather than an addendum to an existing project -
specific EIR.
B. THE 2010 EIR HAS NO INFORMATIONAL VALUE TO THE PROJECT.
As the California Supreme Court explained in San Mateo Gardens, subsequent
CEQA review provisions "can apply only if the project has been subject to initial
review; they can have no application if the agency has proposed a new project that
has not previously been subject to review." Friends of College of San Mateo Gardens
v. San Mateo, 1 Cal.5th 937, 950 (2016) ("San Mateo Gardens"); see also, Mattis Camp
Cmty. Assn v. Cty. of Placer, 53 Cal. App. 5th 569 (2020). As the Supreme Court
explains, "[a] decision to proceed under CEQA's subsequent review provisions must thus
necessarily rest on a determination — whether implicit or explicit — that the original
environmental document retains some informational value." Id. at 951 (emph. added).
Only if the original environmental document retains some informational value despite the
proposed changes, changes in circumstances or new substantial information does the
agency proceed to decide under CEQA's subsequent review provisions whether such
changes or substantial new information will require major revisions to the original
environmental document because of the involvement of new, previously unconsidered
significant environmental effects. 1 Cal.5th at 952. Reviewing the 2010 EIR, the City
cannot reasonably claim that it addresses the Project that exceeds the density and
massing analyzed in the 2010 EIR.
Since the Project exceeds the density and massing analyzed in the 2010, and
requires a variance, it has never undergone CEQA review, it is a new project, and the City
must start from the beginning of the CEQA process under section 21151, conduct an
initial study, and determine whether there is substantial evidence of a fair argument that
the project will have a significant environmental impact. Friends of College of San Mateo
Gardens v. San Mateo, 1 Cal.5th at 951. The City Council should require CEQA review
for the Project, and not approve the Project until CEQA review is completed.
C. A TIERED EIR IS REQUIRED TO ANALYZE AND MITIGATE SIGNIFICANT
UNAVOIDABLE IMPACTS IDENTIFIED IN THE 2010 EIR.
The 2010 EIR admitted that the program would have significant unavoidable
impacts in the areas of:
• Aesthetics: shadows. (2010 DEIR 1-11)
• Air Quality:
inconsistency with 2007 Air Quality Management Plan;
• construction emissions exceed significance thresholds;
• mobile source emissions of VOC, NOx, CO and PM-10 exceed significance
thresholds;
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construction and operation emissions are cumulatively considerable in
excess of significance thresholds for VOC, NOx, CO and PM-10. (2010
DEIR 1-11).
• Cultural Resources: The TZC area includes historic buildings and an historic
district. "The feasibility of retaining a historic structure/resource is determined on a
case -by -case basis." (2010 DEIR 1-12).
• Noise: significant noise and vibration from pile -driving and nearby rail operations.
(2010 DEIR 1-12).
• Traffic: Significant traffic impacts, includoing at the 1-5 northbound off -ramp at
Santa Ana Blvd. to an unacceptable level of service. (2010 DEIR 1-12).
Since the overall program will have significant unavoidable impacts, the City must
conduct project -level supplemental EIRs for specific projects proposed within the program
area. The supplemental EIRs are required to determine whether mitigation measures
exist to reduce the significant unavoidable impacts identified in the 2010 EIR.
In the case of Communities for a Better Environment v. Cal. Resources Agency
(2002) 103 Cal.App.4th 98, 122-125, the court of appeal held that when a "first tier" EIR
admits a significant, unavoidable environmental impact, then the agency must prepare
second tier EIRs for later phases of the project to ensure that those unmitigated impacts
are "mitigated or avoided." (Id. citing CEQA Guidelines §15152(f)) The court reasoned
that the unmitigated impacts were not "adequately addressed" in the first tier EIR since
they were not "mitigated or avoided." (Id.) Thus, significant effects disclosed in first tier
EIRs will trigger second tier EIRs unless such effects have been "adequately addressed,"
in a way that ensures the effects will be "mitigated or avoided." (Id.) Such a second tier
EIR is required, even if the impact still cannot be fully mitigated and a statement of
overriding considerations will be required. The court explained, "The requirement of a
statement of overriding considerations is central to CEQA's role as a public accountability
statute; it requires public officials, in approving environmental detrimental projects, to
justify their decisions based on counterbalancing social, economic or other benefits, and
to point to substantial evidence in support." (Id. at 124-125) The court specifically
rejected a prior version of the CEQA guidelines regarding tiering that would have allowed
a statement of overriding considerations for a program -level project to be used for a later
specific project within that program. (Communities for a Better Env't v. California Res.
Agency (2001) 103 Cal.App.4th 98, 124, disapproved on other grounds by Berkeley
Hillside Pres. v. City of Berkeley (2015) 60 Cal.4th 1086.) Even though "a prior EIR's
analysis of environmental effects may be subject to being incorporated in a later EIR for a
later, more specific project, the responsible public officials must still go on the record and
explain specifically why they are approving the later project despite its significant
unavoidable impacts." (Id., pp. 124-25.)
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D. THE ADDENDUM'S CONCLUSIONS ARE NOT SUPPORTED BY
SUBSTANTIAL EVIDENCE AND THERE IS SUBSTANTIAL EVIDENCE OF A
FAIR ARGUMENT THAT THE PROJECT WILL HAVE SIGNIFICANT
ENVIRONMENTAL IMPACTS.
Even if the addendum provisions applied to the Project (which they do not), a
supplemental EIR would be required to analyze new significant impacts of the Project
resulting from changes to the 2010 Project and new impacts that were not analyzed in the
2010 EIR.
1. There is Substantial Evidence that the Project Will Result in
Significant Indoor Air Quality Impacts.
Certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH, has conducted a
review of the proposed Project and relevant documents regarding the Project's indoor air
emissions. Indoor Environmental Engineering Comments (Exhibit A). Mr. Offerman
concludes that it is likely that the Project will expose future residents of the Project's
residential units to significant impacts related to indoor air quality, and in particular,
emissions of the cancer -causing chemical formaldehyde. Mr. Offermann is one of the
world's leading experts on indoor air quality and has published extensively on the topic.
See attached CV.
Mr. Offermann explains that many composite wood products typically used in
modern home construction contain formaldehyde -based glues which off -gas
formaldehyde over a very long time period. He states, "The primary source of
formaldehyde indoors is composite wood products manufactured with urea -formaldehyde
resins, such as plywood, medium density fiberboard, and particle board. These materials
are commonly used in building construction for flooring, cabinetry, baseboards, window
shades, interior doors, and window and door trims." Offermann Comment, pp. 2-3.
Mr. Offermann states:
Indoor air quality in homes is particularly important because occupants, on
average, spend approximately ninety percent of their time indoors with the majority
of this time spent at home (EPA, 2011). Some segments of the population that are
most susceptible to the effects of poor IAQ, such as the very young and the
elderly, occupy their homes almost continuously. Additionally, an increasing
number of adults are working from home at least some of the time during the
workweek.
Offermann Comment, p. 1.
Formaldehyde is a known human carcinogen. Mr. Offermann states that there is a
fair argument that residents of the Project will be exposed to a cancer risk from
formaldehyde of between 112 and 180 per million. (Offermann Comment, pp. 2-3.) This
is far above the South Coast Air Quality Management District (SCAQMD) CEQA
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significance threshold for airborne cancer risk of 10 per million. Even if the Project uses
modern "CARB-compliant" materials, Mr. Offermann concludes that formaldehyde will
create a cancer risk more than ten times above the CEQA significance threshold.
Offermann Comment, p. 3. Mr. Offermann concludes that this significant environmental
impact should be analyzed in an EIR and mitigation measures should be imposed to
reduce the risk of formaldehyde exposure.
Mr. Offermann concludes that this significant environmental impact should be
analyzed in an EIR and mitigation measures should be imposed to reduce the risk of
formaldehyde exposure. Id., pp. 4. Mr. Offermann identifies mitigation measures that are
available to reduce these significant health risks, including the installation of air filters and
a requirement that the applicant use only composite wood materials (e.g. hardwood
plywood, medium density fiberboard, particleboard) for all interior finish systems that are
made with CARB approved no -added formaldehyde (NAF) resins or ultra -low emitting
formaldehyde (ULEF) resins in the buildings' interiors. Offermann Comments, pp. 11-12
The City has a duty to investigate issues relating to a project's potential
environmental impacts, especially those issues raised by an expert's comments. See Cty.
Sanitation Dist. No. 2 v. Cty. of Kern, (2005) 127 Cal.App.4th 1544, 1597-98 ("under
CEQA, the lead agency bears a burden to investigate potential environmental impacts").
In addition to assessing the Project's potential health impacts to residents and workers,
Mr. Offermann identifies the investigatory path that the City should be following in
developing an EIR to more precisely evaluate the Project's future formaldehyde
emissions and establishing mitigation measures that reduce the cancer risk below the
SCAQMD level. Offermann Comments, pp. 5-9. Such an analysis would be similar in form
to the air quality modeling and traffic modeling typically conducted as part of a CEQA
review.
The failure to address the project's formaldehyde emissions is contrary to the
California Supreme Court's decision in California Building Industry Ass'n v. Bay Area Air
Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 ("CBIA"). At issue in CBIA was whether
the Air District could enact CEQA guidelines that advised lead agencies that they must
analyze the impacts of adjacent environmental conditions on a project. The Supreme
Court held that CEQA does not generally require lead agencies to consider the
environment's effects on a project. CBIA, 62 Cal.4th at 800-801. However, to the extent a
project may exacerbate existing adverse environmental conditions at or near a project
site, those would still have to be considered pursuant to CEQA. Id. at 801 ("CEQA calls
upon an agency to evaluate existing conditions in order to assess whether a project could
exacerbate hazards that are already present"). In so holding, the Court expressly held
that CEQA's statutory language required lead agencies to disclose and analyze
"impacts on a project's users or residents that arise from the project's effects on the
environment." Id. at 800 (emphasis added).)
The carcinogenic formaldehyde emissions identified by Mr. Offermann are not an
existing environmental condition. Those emissions to the air will be from the Project.
Residents will be users of the residential units, and employees will be users of the hotel
and offices. Currently, there is presumably little if any formaldehyde emissions at the site.
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Once the Project is built, emissions will begin at levels that pose significant health risks.
Rather than excusing the City from addressing the impacts of carcinogens emitted into
the indoor air from the project, the Supreme Court in CBIA expressly finds that this type of
effect by the project on the environment and a "project's users and residents" must be
addressed in the CEQA process.
The Supreme Court's reasoning is well-grounded in CEQA's statutory language.
CEQA expressly includes a project's effects on human beings as an effect on the
environment that must be addressed in an environmental review. "Section 21083(b)(3)'s
express language, for example, requires a finding of a 'significant effect on the
environment' (§ 21083(b)) whenever the 'environmental effects of a project will cause
substantial adverse effects on human beings, either directly or indirectly."' CBIA, 62
Cal.4th at 800 (emphasis in original). Likewise, "the Legislature has made clear —in
declarations accompanying CEQA's enactment —that public health and safety are of great
importance in the statutory scheme." Id., citing e.g., §§ 21000, subds. (b), (c), (d), (g),
21001, subds. (b), (d). It goes without saying that the thousands of future residents and
employees at the Project are human beings and the health and safety of those workers is
as important to CEQA's safeguards as nearby residents currently living near the project
site.
The Addendum fails to disclose, analyze, or mitigate these new significant impacts.
Because Mr. Offermann's expert review is substantial evidence of a fair argument of a
significant environmental impact to future users of the project, an EIR must be prepared
to disclose and mitigate those impacts.
2. The Project Will Have Significant Impacts Due to Inconsistencies
with the Planning and Zoning Code.
The proposed Project exceeds massing and density allowed by the zoning code.
Urban Neighborhood zone (UN-2) allows single-family, duplexes, triplexes, and
quadplexes, courtyard housing and rowhouses. The Project is much more intense than
quadplexes. UN-2 does not permit Lined Block buildings, such as the Project. (Addendum
2-11). The Project requires a variance for massing since Zoning Code section 41-2023
requires floors 3-5 may occupy no more than 85% of ground floor, but the Project
proposes 100% coverage. (Addedum 2-11). The UN-2 zone allows density up to 50
dwelling units per acre, but this Project has 54 DU/acre. (Addendum 3.6-5).
These inconsistencies with the zoning code and zoning designations are significant
impacts under CEQA that must be analyzed and mitigated in a supplemental EIR. Of
course, these impacts were not analyzed in the 2010 EIR since that document assumed
that future projects would comply with the designated zoning and land use laws.
Where a local or regional policy of general applicability, such as an ordinance, is
adopted in order to avoid or mitigate environmental effects, a conflict with that policy in
itself indicates a potentially significant impact on the environment. (Pocket Protectors v.
Sacramento (2005) 124 Cal.App.4th 903.) Indeed, any inconsistencies between a
proposed project and applicable plans must be discussed in an EIR. (14 CCR §
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15125(d); City of Long Beach v. Los Angeles Unif. School Dist. (2009) 176 Cal. App. 4th
889, 918; Friends of the Eel River v. Sonoma County Water Agency (2003) 108 Cal. App.
4th 859, 874 (EIR inadequate when Lead Agency failed to identify relationship of project
to relevant local plans).) A Project's inconsistencies with local plans and policies
constitute significant impacts under CEQA. (Endangered Habitats League, Inc. v. County
of Orange (2005) 131 Cal.App.4th 777, 783-4, 32 Cal.Rptr.3d 177; see also, County of El
Dorado v. Dept. of Transp. (2005) 133 Cal.App.4th 1376 (fact that a project may be
consistent with a plan, such as an air plan, does not necessarily mean that it does not
have significant impacts).) Californians for Alternatives to Toxics v. Department of Food
and Agriculture (2005) 136 Cal.App.4th 1, 17 ("[c]ompliance with the law is not enough to
support a finding of no significant impact under the CEQA."). The recent Georgetown
Preservation Society v. County of El Dorado (2018) 30 Cal.App.5th 358 echoes Pocket
Protectors. These both apply the fair argument standard to a potential inconsistency with
a plan adopted for environmental protection. Protect the Historic Amador Waterways v.
Amador Water Agency (2004) 116 Cal.App.4th 1099 holds that an EIR needs to analyze
any topic for which a fair argument of significant impact is raised.
Since the proposed Project is inconsistent with the zoning code, and requires a
zone change and variance, it will have significant impacts that must be analyzed in a
tiered EIR. These impacts were not analyzed in the 2010 EIR.
3. The Project Will Have Significant Impacts to Historic Resources.
The proposed Project may have significant impacts to historic resources, and the
City has failed to implement applicable mitigation measures from the 2010 EIR with
respect to this impact. The downtown zone is a National Historic District (2010 DEIR 1-5).
The 2010 DEIR required development to be "context -sensitive infill development." (Id.)
The Addendum admits that the Project site includes a historically significant building on
the Built Environment Resources Directory ("BERD") database. (Addendum 3.3-3). The
historic building is the Santa Ana Car Salon, located at 509-515 East 41h Street.
(Addendum Appendix C, Cultural Resources, p.3, 8). The historic resource is a "rare
example of the Western False Front Style in Santa Ana." (Id.) This historic building will
be demolished as part of the Project, and the Project will therefore have adverse impacts
on an historic resource.
The 2010 EIR required a case -by -case historic analysis for future projects, and
required that for each project an historic resource expert must be retained to conduct an
analysis and to suggest measures to minimize impacts. (2010 DEIR 1-24). However, no
such historic resource analysis was done for the Project due to "constraints surrounding
COVID-19." (Addendum 3.1-1).
Since the City has failed to implement mitigation measures required by the 2010
EIR, a subsequent EIR is required. If the agency fails to implement mitigation measures
required by a prior EIR, this requires CEQA review, even for an otherwise ministerial
project. Katzeff v. Dept. of Forestry (2010) 181 Cal.App.4th 601, 611, 614; Lincoln Place
Tenants v. City of Los Angeles (2005) 130 Cal.App.4th 1491, 1507-1508. The purpose of
this requirement "is to ensure that feasible mitigation measures will actually be
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implemented as a condition of development, and not merely adopted and then neglected
or disregarded." Federation of Hillside and Canyon Associations v. City of Los Angeles
(2000) 83 Cal.App.4th 1252, 1260-1261. The decision to abandon an adopted mitigation
measure is a discretionary decision.
An agency fails proceed in a manner required by law when it fails to comply with
adopted CEQA mitigation measures. Lincoln Place, 130 Cal.AppAth at 1508, 1510
("[h]aving placed these conditions ... the city cannot simply ignore them. Mitigating
conditions are not mere expressions of hope ... [i]n the present case the city failed to
proceed according to law ..."). "[T]his rule is applicable even if one of the smaller parts
might require only ministerial, rather than discretionary, approval." Katzeff, 181
Cal.AppAth at 611; Lincoln Place, 130 Cal.AppAth 1491, 1507 n22 ("it cannot be argued
CEQA does not apply to the ... demolition on the ground the demolition permits are
ministerial acts.")
Since the Project may have significant impacts to historic resources, and the City
has failed to comply with mitigation measures required by the 2010 EIR, a supplemental
EIR is required to analyze this impact.
4. The Project Fails to Implement Mitigation Measures Required by the
2010 EIR.
The Project fails to implement several mitigation measures required by the 2010
EIR. As discussed above, the failure to implement mitigation measures set forth in a prior
EIR itself requires preparation of a supplemental EIR.
In addition to the historic resources mitigation measure, the Addendum fails to
implement energy conservation and greenhouse gas mitigation measure 4.2-22, which
requires projects to exceed Title 24 energy standards by 20%. (2010 DEIR 1-18).
However, the Addendum fails to implement this measure, since the Project will merely
comply with Title 24, not exceed Title 24 by 20%.
The 2010 EIR included numerous air quality mitigation measures that are not
required in the Addendum for the Project. (2010 EIR 1-18, MM 4.2-21, 4.2-22). The
failure to implement these mitigation measures requires preparation of a supplemental
EIR.
5. The Project Will Have Significant Adverse Air Quality and
Greenhouse Gas Impacts.
We submit herewith the comments of Dr. Paul Rosenfeld, Ph.D. and Matthew
Hagemann, C. Hg, P.G. of the environmental consulting firm SWAPE. They conclude
that the Addendum's air quality analysis is riddled with errors due to unsubstantiated input
parameters used to estimate Project emissions. (SWAPE 1). Correcting for these errors,
SWAPE concludes that the Project will create a cancer risk from airborne pollution of up
to 210 per million. (SWAPE 18). This is over twenty times above the South Coast Air
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Quality Management District (SCAQMD) CEQA significance threshold of 10 per million.
SWAPE also calculates that the Project will have significant greenhouse gas impacts.
(SWAPE 23). SWAPE concludes that the Addendum fails to impose all feasible
mitigation measures to reduce the Project's air quality impacts.
Exceedance of Air District thresholds establishes a significant impact under CEQA.
Indeed, in many instances, such air quality thresholds are the only criteria reviewed and
treated as dispositive in evaluating the significance of a project's air quality impacts. See,
e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 (County applies
BAAQMD's "published CEQA quantitative criteria" and "threshold level of cumulative
significance"). See also Communities fora Better Environment v. California Resources
Agency (2002) 103 Cal.App.4th 98, 110-111 ("A 'threshold of significance' for a given
environmental effect is simply that level at which the lead agency finds the effects of the
project to be significant"). The California Supreme Court recently made clear the
substantial importance that a BAAQMD significance threshold plays in providing
substantial evidence of a significant adverse impact. Communities for a Better
Environment v. South Coast Air Quality Management Dist. (2010) 48 CalAth 310, 327
("As the [South Coast Air Quality Management] District's established significance
threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456
pounds per day] constitute substantial evidence supporting a fair argument for a
significant adverse impact").
An EIR is required to analyze and mitigate the Project's significant air quality and
greenhouse gas impacts.
E. EVEN IF THE 2010 EIR WERE STILL RELEVANT TO THE PROJECT, A
SUPPLEMENTAL OR SUBSEQUENT EIR IS NECESSARY BECAUSE
SUBSTANTIAL CHANGES WILL RESULT IN NEW AND MORE SIGNIFICANT
ENVIRONMENTAL IMPACTS.
Even assuming that the 2010 EIR had some relevance to evaluating the
environmental impacts of this Project, numerous substantial changes in the development
plans have occurred such as the increase in massing and density, new information of
substantial importance has arisen, and substantial changes in circumstances have taken
place that require a wholesale revision of the dated 2010 EIR.
When changes to a project's circumstances or new substantial information comes
to light subsequent to the certification of an EIR for a project, the agency must prepare a
subsequent or supplemental EIR if the changes are "[s]ubstantial" and require "major
revisions" of the previous EIR. Friends of Coll. of San Mateo Gardens v. San Mateo Cty.
Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 943. "[W]hen there is a change in plans,
circumstances, or available information after a project has received initial approval, the
agency's environmental review obligations "turn[ ] on the value of the new information to
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the still pending decisionmaking process." Id., 1 Cal.5th at 951-52. The agency must
"decide under CEQA's subsequent review provisions whether project changes will require
major revisions to the original environmental document because of the involvement of
new, previously unconsidered significant environmental effects." Id., 1 Cal.5th at 952.
Section 21166 and CEQA Guidelines § 15162 "do[] not permit agencies to avoid their
obligation to prepare subsequent or supplemental EIRs to address new, and previously
unstudied, potentially significant environmental effects." Id., 1 Cal.5th at 958.
The evidence indicates that the project considered by the 2010 EIR has undergone
significant changes to the project and its circumstances requiring substantial revisions to
that 10-year old EIR.
A. A New EIR is Required Because the Increase in Massing and Density is a
Substantial Change from the 2010 Project and there is Substantial
Evidence that the Project Will Result in Emissions of Formaldehyde to the
Air that Will Have a Significant Health Impact on Future Residents.
Even if the 201 EIR were somehow relevant to the current Project, the City would
still be required to prepare an SEIR. The increase in massing and density, the failure to
conduct a historic resource analysis, and zoning changes and variances required as part
of the Project is a substantial change from the 2010 project. "The purpose behind the
requirement of a subsequent or supplemental EIR or negative declaration is to explore
environmental impacts not considered in the original environmental document." Friends
of College of San Mateo Gardens v. San Mateo (2016) 1 Cal.5th 937, 949 (quoting Save
Our Neighborhood v. Lishman (2006) 140 Cal.AppAth 1288, 1296). For example, in the
case of Ventura Foothill Neighbors, a mere increase in the height of a building by 15 feet
required a supplemental EIR, not an addendum. Ventura Foothill Neighbors v. Cty. of
Ventura, 232 Cal. App. 4th 429 (2014).
As discussed above, the expert opinion of Mr. Offermann constitutes substantial
evidence that the residential component of the Project will result in a significant air quality
impact to residential occupants of the Project. This impact is significant and new. It could
not have been known in 2010 because the science in this area did not exist until 2015.
Accordingly, the City violated CEQA by not preparing an SEIR to analyze and mitigate
this new significant impact.
There is no substantial evidence in the record to support a conclusion that the
Project will not have a new significant indoor air quality impact as a result of significant
changes to the Project when compared to the project analyzed in the 2010 EIR.
Accordingly, the City's decision to prepare an Addendum rather than an SEIR is not
supported by substantial evidence, and approval of the Project based on the Addendum
would constitute an abuse of discretion.
For the above and other reasons, the Planning Commission should decline to
recommend the City Council approve the Addendum, and instead direct Planning Staff to
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prepare and circulate an EIR for public review. The City may not rely on the 10-year old
2010 EIR.
Sincerely,
Richard Toshiyuki Drury
LOZEAU DRURY LLP
75C-34
ATTACHMENT A
75C-35
IEE INDOOR ENVIRONMENTAL ENGINEERING HEE
1448 Pine Sheet, Suite 103 San Francisco, California 94109
Telephone: (415) 567-7700
E-mail: offermwnm IEE-SF.com
htto://w .ice-sfcom
Date: October 12, 2020
To: Richard Drury
Lozeau I Drury LLP
1939 Harrison Street, Suite 150
Oakland, California 94612
From: Francis J. Offermann PE CIH
Subject: Indoor Air Quality: 4a' and Mortimer Project, Santa Ana, CA
(IEE File Reference: P-4394)
Pages: 19
Indoor Air Quality Impacts
Indoor air quality (IAQ) directly impacts the comfort and health of building occupants, and
the achievement of acceptable IAQ in newly constructed and renovated buildings is a well -
recognized design objective. For example, IAQ is addressed by major high-performance
building rating systems and building codes (California Building Standards Commission,
2014; USGBC, 2014). Indoor air quality in homes is particularly important because
occupants, on average, spend approximately ninety percent of their time indoors with the
majority of this time spent at home (EPA, 2011). Some segments of the population that are
most susceptible to the effects of poor IAQ, such as the very young and the elderly, occupy
their homes almost continuously. Additionally, an increasing number of adults are working
from home at least some of the time during the workweek. Indoor air quality also is a
serious concern for workers in hotels, offices and other business establishments.
The concentrations of many air pollutants often are elevated in homes and other buildings
relative to outdoor air because many of the materials and products used indoors contain
and release a variety of pollutants to air (Hodgson et al., 2002; Offermann and Hodgson,
75C-36
2011). With respect to indoor air contaminants for which inhalation is the primary route of
exposure, the critical design and construction parameters are the provision of adequate
ventilation and the reduction of indoor sources of the contaminants
Indoor Formaldehyde Concentrations Impact. In the California New Home Study
(CNHS) of 108 new homes in California (Offermann, 2009), 25 air contaminants were
measured, and formaldehyde was identified as the indoor air contaminant with the highest
cancer risk as determined by the California Proposition 65 Safe Harbor Levels (OEHHA,
2017a), No Significant Risk Levels (NSRL) for carcinogens. The NSRL is the daily intake
level calculated to result in one excess case of cancer in an exposed population of 100,000
(i.e., ten in one million cancer risk) and for formaldehyde is 40 µg/day. The NSRL
concentration of formaldehyde that represents a daily dose of 40 µg is 2 µg/m3, assuming a
continuous 24-hour exposure, a total daily inhaled air volume of 20 m3, and 100%
absorption by the respiratory system. All of the CNHS homes exceeded this NSRL
concentration of 2 µg/m3. The median indoor formaldehyde concentration was 36 µg/m3,
and ranged from 4.8 to 136 µg/m3, which corresponds to a median exceedance of the 2
µg/m3 NSRL concentration of 18 and a range of 2.3 to 68.
Therefore, the cancer risk of a resident living in a California home with the median indoor
formaldehyde concentration of 36 µg/m3, is 180 per million as a result of formaldehyde
alone. The CEQA significance threshold for airborne cancer risk is 10 per million, as
established by the South Coast Air Quality Management District (SCAQMD, 2015).
Besides being a human carcinogen, formaldehyde is also a potent eye and respiratory
irritant. In the CNHS, many homes exceeded the non -cancer reference exposure levels
(RELs) prescribed by California Office of Environmental Health Hazard Assessment
(OEHHA, 2017b). The percentage of homes exceeding the RELs ranged from 98% for the
Chronic REL of 9 µg/m3 to 28% for the Acute REL of 55 µg/m3.
The primary source of formaldehyde indoors is composite wood products manufactured
with urea -formaldehyde resins, such as plywood, medium density fiberboard, and
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particleboard. These materials are commonly used in building construction for flooring,
cabinetry, baseboards, window shades, interior doors, and window and door trims.
In January 2009, the California Air Resources Board (CARB) adopted an airborne toxics
control measure (ATCM) to reduce formaldehyde emissions from composite wood
products, including hardwood plywood, particleboard, medium density fiberboard, and also
furniture and other finished products made with these wood products (California Air
Resources Board 2009). While this formaldehyde ATCM has resulted in reduced emissions
from composite wood products sold in California, they do not preclude that homes built
with composite wood products meeting the CARB ATCM will have indoor formaldehyde
concentrations below cancer and non -cancer exposure guidelines.
A follow up study to the California New Home Study (CNHS) was conducted in 2016-2018
(Chan et. al., 2019), and found that the median indoor formaldehyde in new homes built
after 2009 with CARB Phase 2 Formaldehyde ATCM materials had lower indoor
formaldehyde concentrations, with amedian indoor concentrations of 22.4 µg/m3 (18.2 ppb)
as compared to a median of 36 µg/m3 found in the 2007 CNHS.
Thus, while new homes built afterthe 2009 CARB formaldehyde ATCM have a38% lower
median indoor formaldehyde concentration and cancer risk, the median lifetime cancer risk
is still 112 per million for homes built with CARB compliant composite wood products.
This median lifetime cancer risk is more than 11 times the OEHHA 10 in a million cancer
risk threshold (OEHHA, 2017a).
With respect to 0 and Mortimer Project in Santa Ana, CA the buildings consist of multi-
family residential buildings and commercial buildings.
The employees of the commercial spaces are expected to experience significant indoor
exposures (e.g., 40 hours per week, 50 weeks per year). These exposures for employees are
anticipated to result in significant cancer risks resulting from exposures to formaldehyde
released by the building materials and furnishing commonly found in offices, warehouses,
residences and hotels.
7d6138
Because these commercial spaces will be constructed with CARB Phase 2 Formaldehyde
ATCM materials, and be ventilated with the minimum code required amount of outdoor
air, the indoor formaldehyde concentrations are likely similar to those concentrations
observed in residences built with CARB Phase 2 Formaldehyde ATCM materials, which
is a median of 22.4 µg/m3 (Chan et. al., 2019)
Assuming that the commercial spaces employees work 8 hours per day and inhale 20 m3
of air per day, the formaldehyde dose per work -day at the offices is 149 µg/day.
Assuming that these employees work 5 days per week and 50 weeks per year for 45 years
(start at age 20 and retire at age 65) the average 70-year lifetime formaldehyde daily dose
is 65.8 µg/day
This is 1.64 times the NSRL (OEHHA, 2017a) of 40 µg/day and represents a cancer risk
of 16.4 per million, which exceeds the CEQA cancer risk of 10 per million. This impact
should be analyzed in an environmental impact report ("EIR"), and the agency should
impose all feasible mitigation measures to reduce this impact. Several feasible mitigation
measures are discussed below and these and other measures should be analyzed in an EIR.
The residential occupants will potentially have continuous exposure (e.g., 24 hours per day,
52 weeks per year) to formaldehyde released by the building materials and furnishing
commonly found in residential construction. These exposures to formaldehyde are
anticipated to result in significant cancer risks.
Because these residences will be constructed with CARB Phase 2 Formaldehyde ATCM
materials and ventilated with the minimum code required amount of outdoor air, the indoor
residential formaldehyde concentrations are likely similar to those concentrations observed
in residences built with CARB Phase 2 Formaldehyde ATCM materials, which is a median
of 22.4 µg/m3 (Chan et. al., 2019)
Assuming that the residential occupants inhale 20 m3 of air per day, the average 70-year
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lifetime formaldehyde daily dose is 448 µg/day for continuous exposure in the residences.
This exposure represents a cancer risk of 112 per million, which is more than 11 times
SCAQMD's CEQA significance threshold for airborne cancer risk of 10 per million
(SCAQMD, 2015). For occupants that do not have continuous exposure, the cancer risk
will be proportionally less but still substantially over this CEQA cancer risk of 10 per
million (e.g. for 12/hour/day occupancy, more than 5 times the OEHHA cancer risk of 10
per million).
Appendix A, Indoor Formaldehyde Concentrations and the CARB Formaldehyde ATCM,
provides analyses that show utilization of CARB Phase 2 Formaldehyde ATCM materials
will not ensure acceptable cancer risks with respect to formaldehyde emissions from
composite wood products.
Even composite wood products manufactured with CARB certified ultra low emitting
formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of
formaldehyde below the CEQA cancer risks. The permissible emission rates for ULEF
composite wood products are only 11-15% lower than the CARB Phase 2 emission rates.
Only use of composite wood products made with no -added formaldehyde resins (NAF),
such as resins made from soy, polyvinyl acetate, or methylene diisocyanate can insure that
the CEQA cancer risk of 10 per million is met.
The following describes a method that should be used, prior to construction in the
environmental review under CEQA, for determining whether the indoor concentrations
resulting from the formaldehyde emissions of specific building materials/furnishings
selected exceed cancer and non -cancer guidelines. Such a design analyses can be used to
identify those materials/furnishings prior to the completion of the City's CEQA review and
project approval, that have formaldehyde emission rates that contribute to indoor
concentrations that exceed cancer and non -cancer guidelines, so that alternative lower
emitting materials/furnishings may be selected and/or higher minimum outdoor air
ventilation rates can be increased to achieve acceptable indoor concentrations and
incorporated as mitigation measures for this project.
76 140
Pre -Construction Building Materlal/Fumishlna Formaldehvde Emissions Assessment
This formaldehyde emissions assessment should be used in the environmental review under
CEQA to assess the indoor formaldehyde concentrations from the proposed loading of
building materials/furnishings, the area -specific formaldehyde emission rate data for
building materials/furnishings, and the design minimum outdoor air ventilation rates. This
assessment allows the applicant (and the City) to determine, before the conclusion of the
environmental review process and the building materials/furnishings are specified,
purchased, and installed, if the total chemical emissions will exceed cancer and non -cancer
guidelines, and if so, allow for changes in the selection of specific material/furnishings
and/or the design minimum outdoor air ventilations rates such that cancer and non -cancer
guidelines are not exceeded.
1.) Define Indoor Air Quality Zones. Divide the building into separate indoor air quality
zones, (IAQ Zones). IAQ Zones are defined as areas of well -mixed air. Thus, each
ventilation system with recirculating air is considered a single zone, and each room or
group of rooms where air is not recirculated (e.g. 100% outdoor air) is considered a separate
zone. For IAQ Zones with the same construction material/fumishings and design minimum
outdoor air ventilation rates. (e.g. hotel rooms, apartments, condominiums, etc.) the
formaldehyde emission rates need only be assessed for a single IAQ Zone of that type.
2.) Calculate Materlal/Fumishlna Loading. For each IAQ Zone, determine the building
material and furnishing loadings (e.g., m2 of materiaUm2 floor area, units of furnishings/m2
floor area) from an inventory of all potential indoor formaldehyde sources, including
flooring, ceiling tiles, furnishings, finishes, insulation, sealants, adhesives, and any
products constructed with composite wood products containing urea -formaldehyde resins
(e.g., plywood, medium density fiberboard, particleboard).
3.) Calculate the Formaldehyde Emission Rate. For each building material, calculate the
formaldehyde emission rate (µg/h) from the product of the area -specific formaldehyde
emission rate (µg/m2-h) and the area (m) of material in the IAQ Zone, and from each
furnishing (e.g. chairs, desks, etc.) from the unit -specific formaldehyde emission rate
(µg/unit-h) and the number of units in the IAQ Zone.
79v141
NOTE: As a result of the high-performance building rating systems and building codes
(California Building Standards Commission, 2014; USGBC, 2014), most manufacturers of
building materials furnishings sold in the United States conduct chemical emission rate
tests using the California Department of Health "Standard Method for the Testing and
Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using
Environmental Chambers," (CDPH, 2017), or other equivalent chemical emission rate
testing methods. Most manufacturers of building furnishings sold in the United States
conduct chemical emission rate tests using ANSI/BIFMA M7.1 Standard Test Method for
Determining VOC Emissions (BIFMA, 2018), or other equivalent chemical emission rate
testing methods.
CDPH, BIFMA, and other chemical emission rate testing programs, typically certify that a
material or furnishing does not create indoor chemical concentrations in excess of the
maximum concentrations permitted by their certification. For instance, the CDPH emission
rate testing requires that the measured emission rates when input into an office, school, or
residential model do not exceed one-half of the OEHHA Chronic Exposure Guidelines
(OEHHA, 2017b) for the 35 specific VOCs, including formaldehyde, listed in Table 4-1 of
the CDPH test method (CDPH, 2017). These certifications themselves do not provide the
actual area -specific formaldehyde emission rate (i.e., µg/m2-h) of the product, but rather
provide data that the formaldehyde emission rates do not exceed the maximum rate allowed
for the certification. Thus, for example, the data for a certification of a specific type of
flooring may be used to calculate that the area -specific emission rate of formaldehyde is
less than 31 µg/m2-h, but not the actual measured specific emission rate, which may be 3,
18, or 30 µg/m2-h. These area -specific emission rates determined from the product
certifications of CDPH, BIFA, and other certification programs can be used as an initial
estimate of the formaldehyde emission rate.
If the actual area -specific emission rates of a building material or furnishing is needed (i.e.
the initial emission rates estimates from the product certifications are higher than desired),
then that data can be acquired by requesting from the manufacturer the complete chemical
emission rate test report. For instance if the complete CDPH emission test report is
requested for a CDHP certified product, that report will provide the actual area -specific
79v 142
emission rates for not only the 35 specific VOCs, including formaldehyde, listed in Table
4-1 of the CDPH test method (CDPH, 2017), but also all of the cancer and
reproductive/developmental chemicals listed in the California Proposition 65 Safe Harbor
Levels (OEHHA, 2017a), all of the toxic air contaminants (TACs) in the California Air
Resources Board Toxic Air Contamination List (CARB, 2011), and the 10 chemicals with
the greatest emission rates.
Alternatively, a sample of the building material or furnishing can be submitted to a
chemical emission rate testing laboratory, such as Berkeley Analytical Laboratory
(httns://berkeleyanalytical.com), to measure the formaldehyde emission rate.
4.) Calculate the Total Formaldehyde Emission Rate. For each IAQ Zone, calculate the
total formaldehyde emission rate (i.e. µg/h) from the individual formaldehyde emission
rates from each of the building material/furnishings as determined in Step 3.
5.) Calculate the Indoor Formaldehyde Concentration. For each IAQ Zone, calculate the
indoor formaldehyde concentration (µg/m3) from Equation 1 by dividing the total
formaldehyde emission rates (i.e. µg/h) as determined in Step 4, by the design minimum
outdoor air ventilation rate (m3/h) for the IAQ Zone.
ELLL
Cin = (Equation 1)
Qoa
where:
Co = indoor formaldehyde concentration (µg/m3)
Etow = total formaldehyde emission rate (µg/h) into the IAQ Zone.
Qoa = design minimum outdoor air ventilation rate to the IAQ Zone (m3/h)
The above Equation 1 is based upon mass balance theory, and is referenced in Section
3.10.2 "Calculation of Estimated Building Concentrations" of the California Department
of Health "Standard Method for the Testing and Evaluation of Volatile Organic Chemical
Emissions for Indoor Sources Using Environmental Chambers", (CDPH, 2017).
79v 143
6.) Calculate the Indoor Exposure Cancer and Non -Cancer Health Risks. For each IAQ
Zone, calculate the cancer and non -cancer health risks from the indoor formaldehyde
concentrations determined in Step 5 and as described in the OEHHA Air Toxics Hot Spots
Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk
Assessments (OEHHA, 2015).
7.) Mitigate Indoor Formaldehydeposures of exceeding the CEQA Cancer and/or Non -
Cancer Health Risks. In each IAQ Zone, provide mitigation for any formaldehyde exposure
risk as determined in Step 6, that exceeds the CEQA cancer risk of 10 per million or the
CEQA non -cancer Hazard Quotient of 1.0.
Provide the source and/or ventilation mitigation required in all IAQ Zones to reduce the
health risks of the chemical exposures below the CEQA cancer and non -cancer health risks.
Source mitigation for formaldehyde may include:
1.) reducing the amount materials and/or furnishings that emit formaldehyde
2.) substituting a different material with a lower area -specific emission rate of
formaldehyde
Ventilation mitigation for formaldehyde emitted from building materials and/or
furnishings may include:
1.) increasing the design minimum outdoor air ventilation rate to the IAQ Zone.
NOTE: Mitigating the formaldehyde emissions through use of less material/furnishings, or
use of lower emitting materials/furnishings, is the preferred mitigation option, as mitigation
with increased outdoor air ventilation increases initial and operating costs associated with
the heating/cooling systems.
Further, we are not asking that the builder "speculate" on what and how much composite
materials be used, but rather at the design stage to select composite wood materials based
on the formaldehyde emission rates that manufacturers routinely conduct using the
California Department of Health "Standard Method for the Testing and Evaluation of
79v6144
Volatile Organic Chemical Emissions for Indoor Sources Using Environmental
Chambers," (CDPH, 2017), and use the procedure described earlier above (i.e. Pre -
Construction Building Material/Fumishing Formaldehyde Emissions Assessment) to
insure that the materials selected achieve acceptable cancer risks from material off gassing
of formaldehyde.
Outdoor Air Ventilation Impact. Another important finding of the CNHS, was that the
outdoor air ventilation rates in the homes were very low. Outdoor air ventilation is a very
important factor influencing the indoor concentrations of air contaminants, as it is the
primary removal mechanism of all indoor air generated contaminants. Lower outdoor air
exchange rates cause indoor generated air contaminants to accumulate to higher indoor air
concentrations. Many homeowners rarely open their windows or doors for ventilation as a
result of their concerns for security/safety, noise, dust, and odor concerns (Price, 2007). In
the CNHS field study, 32% of the homes did not use their windows during the 24-hour Test
Day, and 15% of the homes did not use their windows during the entire preceding week.
Most of the homes with no window usage were homes in the winter field session. Thus, a
substantial percentage of homeowners never open their windows, especially in the winter
season. The median 24-hour measurement was 0.26 air changes per hour (ach), with a range
of 0.09 ach to 5.3 ach. A total of 67% of the homes had outdoor air exchange rates below
the minimum California Building Code (2001) requirement of 0.35 ach. Thus, the relatively
tight envelope construction, combined with the fact that many people never open their
windows for ventilation, results in homes with low outdoor air exchange rates and higher
indoor air contaminant concentrations.
The 4"' and Mortimer Project located in Santa Ana, CA is close to roads with moderate to
high traffic (e.g., E. 4th Street, E. 5"' Street, French Street, Mortimer Street, and N. Minter
Street, etc.) as well as close to the AT&SF rail line. As a result of the outdoor vehicle traffic
noise, the Project site is likely to be a sound impacted site.
According to the 41' and Mortimer Project —Environmental Impact Report Addendum, SCH
#2006071100, (City of Santa Ana, 2020) the ambient noise level exceeds 65 dBA CNEL.
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As a result of the high outdoor noise levels, the current project will require a mechanical
supply of outdoor air ventilation to allow for a habitable interior environment with closed
windows and doors. Such a ventilation system would allow windows and doors to be kept
closed at the occupant's discretion to control exterior noise within building interiors.
PM2.5 Outdoor Concentrations Impact. An additional impact of the nearby motor vehicle
traffic associated with this project, are the outdoor concentrations of PM2.5. According to
the 4a' and Mortimer Project — Environmental Impact Report Addendum, SCH
#2006071100, (City of Santa Ana, 2020), the Project is located in South Coast Air Basin,
which is a State and Federal non -attainment area for PM2.5.
An air quality analyses should to be conducted to determine the concentrations of PM2.5 in
the outdoor and indoor air that people inhale each day. This air quality analyses needs to
consider the cumulative impacts of the project related emissions, existing and projected
future emissions from local PM2.5 sources (e.g. stationary sources, motor vehicles, and
airport traffic) upon the outdoor air concentrations at the Project site. If the outdoor
concentrations are determined to exceed the California and National annual average PM2.5
exceedence concentration of 12 µg/m3, or the National 24-hour average exceedence
concentration of 35 µg/m3, then the buildings need to have a mechanical supply of outdoor
air that has air filtration with sufficient removal efficiency, such that the indoor
concentrations of outdoor PM2.5 particles is less than the California and National PM2.5
annual and 24-hour standards.
It is my experience that based on the projected high traffic noise levels, the annual average
concentration of PM2.5 will exceed the California and National PM2.5 annual and 24-hour
standards and warrant installation of high efficiency air filters (i.e. MERV 13 or higher) in
all mechanically supplied outdoor air ventilation systems.
Indoor Air Quality Impact Mitigation Measures
The following are recommended mitigation measures to minimize the impacts upon indoor
quality:
796 16
Indoor Formaldehvde Concentrations Mitigation. Use only composite wood materials (e.g.
hardwood plywood, medium density fiberboard, particleboard) for all interior finish
systems that are made with CARB approved no -added formaldehyde (NAF) resins (CARB,
2009). CARB Phase 2 certified composite wood products, or ultra -low emitting
formaldehyde (ULEF) resins, do not insure indoor formaldehyde concentrations that are
below the CEQA cancer risk of 10 per million. Only composite wood products
manufactured with CARB approved no -added formaldehyde (NAF) resins, such as resins
made from soy, polyvinyl acetate, or methylene diisocyanate can insure that the OEHHA
cancer risk of 10 per million is met.
Alternatively, conduct the previously described Pre -Construction Building
Material/Fumishing Chemical Emissions Assessment, to determine that the combination of
formaldehyde emissions from building materials and furnishings do not create indoor
formaldehyde concentrations that exceed the CEQA cancer and non -cancer health risks.
It is important to note that we are not asking that the builder "speculate" on what and how
much composite materials be used, but rather at the design stage to select composite wood
materials based on the formaldehyde emission rates that manufacturers routinely conduct
using the California Department of Health "Standard Method for the Testing and
Evaluation of Volatile Organic Chemical Emissions for Indoor Sources Using
Environmental Chambers", (CDPH, 2017), and use the procedure described above (i.e.
Pre -Construction Building Material/Fumishing Formaldehyde Emissions Assessment) to
insure that the materials selected achieve acceptable cancer risks from material off gassing
of formaldehyde.
Outdoor Air Ventilation Mitigation. Provide each habitable room with a continuous
mechanical supply of outdoor air that meets or exceeds the California 2016 Building Energy
Efficiency Standards (California Energy Commission, 2015) requirements of the greater of
15 cfm/occupant or 0.15 cfm/ft2 of floor area. Following installation of the system conduct
testing and balancing to insure that required amount of outdoor air is entering each habitable
room and provide a written report documenting the outdoor airflow rates. Do not use
7 ] ��qf 1�
exhaust only mechanical outdoor air systems, use only balanced outdoor air supply and
exhaust systems or outdoor air supply only systems. Provide a manual for the occupants or
maintenance personnel, that describes the purpose of the mechanical outdoor air system and
the operation and maintenance requirements of the system.
PM2.5 Outdoor Air Concentration Mitigation. Install air filtration with sufficient PM2.5
removal efficiency (e.g. MERV 13 or higher) to filter the outdoor air entering the
mechanical outdoor air supply systems, such that the indoor concentrations of outdoor PM2.5
particles are less than the California and National PM2.5 annual and 24-hour standards.
Install the air filters in the system such that they are accessible for replacement by the
occupants or maintenance personnel. Include in the mechanical outdoor air ventilation
system manual instructions on how to replace the air filters and the estimated frequency of
replacement.
References
BIFA. 2018. BIFMA Product Safety and Performance Standards and Guidelines.
www.bifma.org/vage/standardsoverview
California Air Resources Board. 2009. Airborne Toxic Control Measure to Reduce
Formaldehyde Emissions from Composite Wood Products. California Environmental
Protection Agency, Sacramento, CA.
httns://www.arb.ca.gov/regact/2007/comywood07/fro-final.ndf
California Air Resources Board. 2011. Toxic Air Contaminant Identification List.
California Environmental Protection Agency, Sacramento, CA.
httns://www.arb.ca.gov/toxics/id/taclist.htm
California Building Code. 2001. California Code of Regulations, Title 24, Part 2 Volume 1,
Appendix Chapter 12, Interior Environment, Division 1, Ventilation, Section 1207: 2001
California Building Code, California Building Standards Commission. Sacramento, CA.
7 �f 1 8
California Building Standards Commission (2014). 2013 California Green Building
Standards Code. California Code of Regulations, Title 24, Part 11. California Building
Standards Commission, Sacramento, CA http://www.bsc.ca.gov/Home/CALGreen.aspx.
California Energy Commission, PIER Program. CEC-500-2007-033. Final Report, ARB
Contract 03-326. Available at: www.arb.ca.gov/research/anr/nast/03-326.ndf.
California Energy Commission, 2015. 2016 Building Energy Efficiency Standards for
Residential and Nonresidential Buildings, California Code of Regulations, Title 24, Part 6.
http://www.enerpy.ca.gov/2015nublications/CEC-400-2015-037/CEC-400-2015-037-
CMF.pdf
CDPH. 2017. Standard Method for the Testing and Evaluation of Volatile Organic
Chemical Emissions for Indoor Sources Using Environmental Chambers, Version 1.1.
California Department of Public Health, Richmond, CA.
https://www.cdph.ca.gov/Programs/CCDPHP/ DEODC/EHLB/IAQ/Pages/VOC.aspx.
Chan, W., Kim, Y., Singer, B., and Walker I. 2019. Ventilation and Indoor Air Quality in
New California Homes with Gas Appliances and Mechanical Ventilation. Lawrence
Berkeley National Laboratory, Energy Technologies Area, LBNL-2001200, DOI:
10.20357/B7QC7X.
City of Santa Ana. 2020. 4"' and Mortimer Project — Environmental Impact Report
Addendum, SCH #2006071100.
EPA. 2011. Exposure Factors Handbook: 2011 Edition, Chapter 16 — Activity Factors.
Report EPA/600/R-09/052F, September 2011. U.S. Environmental Protection Agency,
Washington, D.C.
Hodgson, A. T., D. Beal, J.E.R. McIlvaine. 2002. Sources of formaldehyde, other aldehydes
and terpenes in a new manufactured house. Indoor Air 12: 235-242.
7 L46f l49
OEHHA (Office of Environmental Health Hazard Assessment). 2015. Air Toxics Hot Spots
Program Risk Assessment Guidelines; Guidance Manual for Preparation of Health Risk
Assessments
OEHHA (Office of Environmental Health Hazard Assessment). 2017a. Proposition 65 Safe
Harbor Levels. No Significant Risk Levels for Carcinogens and Maximum Allowable Dose
Levels for Chemicals Causing Reproductive Toxicity. Available at:
httD://www.oehha.ca.2ov/DrOD65/ndf/safeharbor08l5l3.Ddf
OEHHA - Office of Environmental Health Hazard Assessment. 2017b. All OEHHA Acute,
8-hour and Chronic Reference Exposure Levels. Available at:
httD:Hoehha.ca.2ov/air/allrels.html
Offermann, F. J. 2009. Ventilation and Indoor Air Quality in New Homes. California Air
Resources Board and California Energy Commission, PIER Energy -Related Environmental
Research Program. Collaborative Report. CEC-500-2009-085.
https://www.arb.ca.gov/research/gpr/past/04-310.pdf
Offermann, F. J. and A. T. Hodgson. 2011. Emission Rates of Volatile Organic Compounds
in New Homes. Proceedings Indoor Air 2011 (121h International Conference on Indoor Air
Quality and Climate 2011), June 5-10, 2011, Austin, TX.
South Coast Air Quality Management District (SCAQMD). 2015. California Environmental
Quality Act Air Quality Handbook. South Coast Air Quality Management District,
Diamond Bar, CA, httv://www.agmd.gov/home/rules-compliance/cega/air-quality-
analysis-handbook
USGBC. 2014. LEED BD+C Homes v4. U.S. Green Building Council, Washington, D.C.
htty://www.usgbc.org/credits/homes/v4
796 190
APPENDIX A
INDOOR FORMALDEHYDE CONCENTRATIONS
AND THE
CARB FORMALDEHYDE ATCM
With respect to formaldehyde emissions from composite wood products, the CARB ATCM
regulations of formaldehyde emissions from composite wood products, do not assure
healthful indoor air quality. The following is the stated purpose of the CARB ATCM
regulation - The purpose of this airborne toxic control measure is to "reduce formaldehyde
emissions from composite wood products, and finished goods that contain composite wood
products, that are sold, offered for sale, supplied, used, or manufactured for sale in
California". In other words, the CARB ATCM regulations do not "assure healthful indoor
air quality", but rather "reduce formaldehyde emissions from composite wood products".
Just how much protection do the CARB ATCM regulations provide building occupants
from the formaldehyde emissions generated by composite wood products? Definitely some,
but certainly the regulations do not "assure healthful indoor air quality" when CARB Phase
2 products are utilized. As shown in the Chan 2019 study of new California homes, the
median indoor formaldehyde concentration was of 22.4 µg/m3 (18.2 ppb), which
corresponds to a cancer risk of 112 per million for occupants with continuous exposure,
which is more than 11 times the CEQA cancer risk of 10 per million.
Another way of looking at how much protection the CARB ATCM regulations provide
building occupants from the formaldehyde emissions generated by composite wood
products is to calculate the maximum number of square feet of composite wood product that
can be in a residence without exceeding the CEQA cancer risk of 10 per million for
occupants with continuous occupancy.
For this calculation I utilized the floor area (2,272 ft), the ceiling height (8.5 ft), and the
number of bedrooms (4) as defined in Appendix B (New Single -Family Residence Scenario)
ofthe Standard Method for the Testing and Evaluation of Volatile Organic Chemical Emissions for Indoor
Sources Using Environmental Chambers, Version 1.1, 2017, California Department of Public Health,
7G�f--11
Richmond, CA. https://www.edph.ca.gov/Programs/CCDPHP/
DEODC/EHLB/IAQ/Pages/VOC.aspx.
For the outdoor air ventilation rate I used the 2019 Title 24 code required mechanical
ventilation rate (ASHRAE 62.2) of 106 cfm (180 m3/h) calculated for this model residence.
For the composite wood formaldehyde emission rates I used the CARB ATCM Phase 2 rates
The calculated maximum number of square feet of composite wood product that can be in
a residence, without exceeding the CEQA cancer risk of 10 per million for occupants with
continuous occupancy are as follows for the different types of regulated composite wood
products.
Medium Density Fiberboard (MDF) — 15 ft2 (0.7% of the floor area), or
Particle Board —30 ft2 (1.3% of the floor area), or
Hardwood Plywood — 54 ft2 (2.4% of the floor area), or
Thin MDF — 46 ft2 (2.0 % of the floor area).
For offices and hotels the calculated maximum amount of composite wood product (% of
floor area) that can be used without exceeding the CEQA cancer risk of 10 per million for
occupants, assuming 8 hours/day occupancy, and the California Mechanical Code minimum
outdoor air ventilation rates are as follows for the different types of regulated composite
wood products.
Medium Density Fiberboard (MDF) — 3.6 % (offices) and 4.6% (hotel rooms), or
Particle Board — 7.2 % (offices) and 9.4% (hotel rooms), or
Hardwood Plywood — 13 % (offices) and 17% (hotel rooms), or
Thin MDF — 11 % (offices) and 14 % (hotel rooms)
Clearly the CARB ATCM does not regulate the formaldehyde emissions from composite
wood products such that the potentially large areas of these products, such as for flooring,
baseboards, interior doors, window and door trims, and kitchen and bathroom cabinetry,
could be used without causing indoor formaldehyde concentrations that result in CEQA
7 � 6 is
cancer risks that substantially exceed 10 per million for occupants with continuous
occupancy
Even composite wood products manufactured with CARB certified ultra low emitting
formaldehyde (ULEF) resins do not insure that the indoor air will have concentrations of
formaldehyde the meet the OEHHA cancer risks that substantially exceed 10 per million.
The permissible emission rates for ULEF composite wood products are only 11-15% lower
than the CARB Phase 2 emission rates. Only use of composite wood products made with
no -added formaldehyde resins (NAF), such as resins made from soy, polyvinyl acetate, or
methylene diisocyanate can insure that the OEHHA cancer risk of 10 per million is met.
If CARB Phase 2 compliant or ULEF composite wood products are utilized in construction,
then the resulting indoor formaldehyde concentrations should be determined in the design
phase using the specific amounts of each type of composite wood product, the specific
formaldehyde emission rates, and the volume and outdoor air ventilation rates of the indoor
spaces, and all feasible mitigation measures employed to reduce this impact (e.g. use less
formaldehyde containing composite wood products and/or incorporate mechanical systems
capable of higher outdoor air ventilation rates). See the procedure described earlier (i.e.
Pre -Construction Building Material/Furnishing Formaldehyde Emissions Assessment) to
insure that the materials selected achieve acceptable cancer risks from material off gassing
of formaldehyde.
Alternatively, and perhaps a simpler approach, is to use only composite wood products (e.g.
hardwood plywood, medium density fiberboard, particleboard) for all interior finish
systems that are made with CARB approved no -added formaldehyde (NAF) resins.
7G�f--13
Francis (Bud) J. Offermann III PE, CIH
Indoor Environmental Engineering
1448 Pine Street, Suite 103, San Francisco, CA 94109
Phone: 415-567-7700
Email: Offermann@iee-sf com
http://w .iee-sf.com
Education
M.S. Mechanical Engineering (1985)
Stanford University, Stanford, CA.
Graduate Studies in Air Pollution Monitoring and Control (1980)
University of California, Berkeley, CA.
B.S. in Mechanical Engineering (1976)
Rensselaer Polytechnic Institute, Troy, N.Y.
Professional Experience
President: Indoor Environmental Engineering, San Francisco, CA. December, 1981 -
present.
Direct team of environmental scientists, chemists, and mechanical engineers in
conducting State and Federal research regarding indoor air quality instrumentation
development, building air quality field studies, ventilation and air cleaning performance
measurements, and chemical emission rate testing.
Provide design side input to architects regarding selection of building materials and
ventilation system components to ensure a high quality indoor environment.
Direct Indoor Air Quality Consulting Team for the winning design proposal for the new
State of Washington Ecology Department building.
Develop a full-scale ventilation test facility for measuring the performance of air
diffusers; ASHRAE 129, Air Change Effectiveness, and ASHRAE 113, Air Diffusion
Performance Index.
Develop a chemical emission rate testing laboratory for measuring the chemical
emissions from building materials, furnishings, and equipment.
Principle Investigator of the California New Homes Study (2005-2007). Measured
ventilation and indoor air quality in 108 new single family detached homes in northern
and southern California.
Develop and teach IAQ professional development workshops to building owners,
managers, hygienists, and engineers.
75C-54
Air Pollution Engineer: Earth Metrics Inc., Burlingame, CA, October, 1985 to March,
1987.
Responsible for development of an air pollution laboratory including installation a forced
choice olfactometer, tracer gas electron capture chromatograph, and associated
calibration facilities. Field team leader for studies of fugitive odor emissions from sewage
treatment plants, entrainment of fume hood exhausts into computer chip fabrication
rooms, and indoor air quality investigations.
Staff Scientist: Building Ventilation and Indoor Air Quality Program, Energy and
Environment Division, Lawrence Berkeley Laboratory, Berkeley, CA. January, 1980 to
August, 1984.
Deputy project leader for the Control Techniques group; responsible for laboratory and
field studies aimed at evaluating the performance of indoor air pollutant control strategies
(i.e. ventilation, filtration, precipitation, absorption, adsorption, and source control).
Coordinated field and laboratory studies of air-to-air heat exchangers including
evaluation of thermal performance, ventilation efficiency, cross -stream contaminant
transfer, and the effects of freezing/defrosting.
Developed an in situ test protocol for evaluating the performance of air cleaning systems
and introduced the concept of effective cleaning rate (ECR) also known as the Clean Air
Delivery Rate (CADR).
Coordinated laboratory studies of portable and ducted air cleaning systems and their
effect on indoor concentrations of respirable particles and radon progeny.
Co -designed an automated instrument system for measuring residential ventilation rates
and radon concentrations.
Designed hardware and software for a multi -channel automated data acquisition system
used to evaluate the performance of air-to-air heat transfer equipment.
Assistant Chief Engineer: Alta Bates Hospital, Berkeley, CA, October, 1979 to January,
1980.
Responsible for energy management projects involving installation of power factor
correction capacitors on large inductive electrical devices and installation of steam meters
on physical plant steam lines. Member of Local 39, International Union of Operating
Engineers.
Manufacturing Engineer: American Precision Industries, Buffalo, NY, October, 1977 to
October, 1979.
756-55
Responsible for reorganizing the manufacturing procedures regarding production of shell
and tube heat exchangers. Designed customized automatic assembly, welding, and testing
equipment. Designed a large paint spray booth. Prepared economic studies justifying new
equipment purchases. Safety Director.
Project Engineer: Arcata Graphics, Buffalo, N.Y. June, 1976 to October, 1977.
Responsible for the design and installation of a bulk ink storage and distribution system
and high speed automatic counting and marking equipment. Also coordinated material
handling studies which led to the purchase and installation of new equipment.
PROFESSIONAL ORGANIZATION MEMBERSHIP
American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE)
• Chairman of SPC-145P, Standards Project Committee - Test Method for Assessing
the Performance of Gas Phase Air Cleaning Equipment (1991-1992)
• Member SPC-129P, Standards Project Committee - Test Method for Ventilation
Effectiveness (1986-97)
- Member of Drafting Committee
• Member Environmental Health Committee (1992-1994, 1997-2001, 2007-2010)
- Chairman of EHC Research Subcommittee
- Member of Man Made Mineral Fiber Position Paper Subcommittee
- Member of the IAQ Position Paper Committee
- Member of the Legionella Position Paper Committee
- Member of the Limiting Indoor Mold and Dampness in Buildings Position Paper
Committee
• Member SSPC-62, Standing Standards Project Committee - Ventilation for
Acceptable Indoor Air Quality (1992 to 2000)
- Chairman of Source Control and Air Cleaning Subcommittee
• Chairman of TC-4.10, Indoor Environmental Modeling (1988-92)
- Member of Research Subcommittee
• Chairman of TC-2.3, Gaseous Air Contaminants and Control Equipment (1989-92)
- Member of Research Subcommittee
American Society for Testing and Materials (ASTM)
• D-22 Sampling and Analysis of Atmospheres
- Member of Indoor Air Quality Subcommittee
• E-06 Performance of Building Constructions
American Board of Industrial Hygiene (ABIH)
American Conference of Governmental Industrial Hygienists (ACGIH)
• Bioaerosols Committee (2007-2013)
756-56
American Industrial Hygiene Association (AIHA)
Cal -OSHA Indoor Air Quality Advisory Committee
International Society of Indoor Air Quality and Climate (ISIAQ)
• Co -Chairman of Task Force on HVAC Hygiene
U. S. Green Building Council (USGBC)
- Member of the IEQ Technical Advisory Group (2007-2009)
- Member of the IAQ Performance Testing Work Group (2010-2012)
Western Construction Consultants (WESTCON)
PROFESSIONAL CREDENTIALS
Licensed Professional Engineer - Mechanical Engineering
Certified Industrial Hygienist - American Board of Industrial Hygienists
SCIENTIFIC MEETINGS AND SYMPOSIA
Biological Contamination, Diagnosis, and Mitigation, Indoor Air'90, Toronto, Canada,
August, 1990.
Models for Predicting Air Quality, Indoor Air'90, Toronto, Canada, August, 1990.
Microbes in Building Materials and Systems, Indoor Air '93, Helsinki, Finland, July,
1993.
Microorganisms in Indoor Air Assessment and Evaluation of Health Effects and Probable
Causes, Walnut Creek, CA, February 27, 1997.
Controlling Microbial Moisture Problems in Buildings, Walnut Creek, CA, February 27,
1997.
Scientific Advisory Committee, Roomvent 98, 61h International Conference on Air
Distribution in Rooms, KTH, Stockholm, Sweden, June 14-17, 1998.
Moisture and Mould, Indoor Air '99, Edinburgh, Scotland, August, 1999.
Ventilation Modeling and Simulation, Indoor Air '99, Edinburgh, Scotland, August,
1999.
Microbial Growth in Materials, Healthy Buildings 2000, Espoo, Finland, August, 2000.
756-57
Co -Chair, Bioaerosols X- Exposures in Residences, Indoor Air 2002, Monterey, CA, July
2002.
Healthy Indoor Environments, Anaheim, CA, April 2003.
Chair, Environmental Tobacco Smoke in Multi -Family Homes, Indoor Air 2008,
Copenhagen, Denmark, July 2008.
Co -Chair, ISIAQ Task Force Workshop; HVAC Hygiene, Indoor Air 2002, Monterey,
CA, July 2002.
Chair, ETS in Multi -Family Housing: Exposures, Controls, and Legalities Forum,
Healthy Buildings 2009, Syracuse, CA, September 14, 2009.
Chair, Energy Conservation and IAQ in Residences Workshop, Indoor Air 2011, Austin,
TX, June 6, 2011.
Chair, Electronic Cigarettes: Chemical Emissions and Exposures Colloquium, Indoor Air
2016, Ghent, Belgium, July 4, 2016.
SPECIAL CONSULTATION
Provide consultation to the American Home Appliance Manufacturers on the
development of a standard for testing portable air cleaners, AHAM Standard AC-1.
Served as an expert witness and special consultant for the U.S. Federal Trade
Commission regarding the performance claims found in advertisements of portable air
cleaners and residential furnace filters.
Conducted a forensic investigation for a San Mateo, CA pro se defendant, regarding an
alleged homicide where the victim was kidnapped in a steamer trunk. Determined the air
exchange rate in the steamer trunk and how long the person could survive.
Conducted in situ measurement of human exposure to toluene fumes released during
nailpolish application for a plaintiffs attorney pursuing a California Proposition 65
product labeling case. June, 1993.
Conducted a forensic in situ investigation for the Butte County, CA Sheriff's Department
of the emissions of a portable heater used in the bedroom of two twin one year old girls
who suffered simultaneous crib death.
Consult with OSHA on the 1995 proposed new regulation regarding indoor air quality
and environmental tobacco smoke.
75C-58
Consult with EPA on the proposed Building Alliance program and with OSHA on the
proposed new OSHA IAQ regulation.
Johnson Controls Audit/Certification Expert Review; Milwaukee, WI. May 28-29, 1997.
Winner of the nationally published 1999 Request for Proposals by the State of
Washington to conduct a comprehensive indoor air quality investigation of the
Washington State Department of Ecology building in Lacey, WA.
Selected by the State of California Attorney General's Office in August, 2000 to conduct
a comprehensive indoor air quality investigation of the Tulare County Court House.
Lawrence Berkeley Laboratory IAQ Experts Workshop: "Cause and Prevention of Sick
Building Problems in Offices: The Experience of Indoor Environmental Quality
Investigators", Berkeley, California, May 26-27, 2004.
Provide consultation and chemical emission rate testing to the State of California
Attorney General's Office in 2013-2015 regarding the chemical emissions from e-
cigarettes.
PEER -REVIEWED PUBLICATIONS:
F.J.Offermann, C.D.Hollowell, and G.D.Roseme, "Low -Infiltration Housing in
Rochester, New York: A Study of Air Exchange Rates and Indoor Air Quality,"
Environment International, 8, pp. 435-445, 1982.
W.W.Nazaroff, F.J.Offermann, and A.W.Robb, "Automated System for Measuring Air
Exchange Rate and Radon Concentration in Houses," Health Physics, 45, pp. 525-537,
1983.
F.J.Offermann, W.J.Fisk, D.T.Grimsrud, B.Pedersen, and K.L.Revzan, "Ventilation
Efficiencies of Wall- or Window -Mounted Residential Air -to -Air Heat Exchangers,"
ASHRAE Annual Transactions, 89-2B, pp 507-527, 1983.
W.J.Fisk, K.M.Archer, R.E Chant, D. Hekmat, F.J.Offermann, and B.Pedersen, "Onset of
Freezing in Residential Air -to -Air Heat Exchangers," ASHRAE Annual Transactions, 91-
1B, 1984.
W.J.Fisk, K.M.Archer, R.E Chant, D. Hekmat, F.J.Offermann, and B.Pedersen,
"Performance of Residential Air -to -Air Heat Exchangers During Operation with Freezing
and Periodic Defrosts," ASHRAE Annual Transactions, 91-1B, 1984.
F.J.Offermann, R.G.Sextro, W.J.Fisk, D.T.Grimsrud, W.W.Nazaroff, A.V.Nero, and
K.L.Revzan, "Control of Respirable Particles with Portable Air Cleaners," Atmospheric
Environment, Vol. 19, pp.1761-1771, 1985.
75d-59
R.G.Sextro, F.J.Offermann, W.W.Nazaroff, A.V.Nero, K.L.Revzan, and J.Yater,
"Evaluation of Indoor Control Devices and Their Effects on Radon Progeny
Concentrations," Atmospheric Environment, 12, pp. 429-438, 1986.
W.J. Fisk, R.K.Spencer, F.J.Offermann, R.K.Spencer, B.Pedersen, R.Sextro, "Indoor Air
Quality Control Techniques," Noyes Data Corporation, Park Ridge, New Jersey, (1987).
F.J.Offermann, "Ventilation Effectiveness and ADPI Measurements of a Forced Air
Heating System," ASHRAE Transactions , Volume 94, Part 1, pp 694-704, 1988.
F.J.Offermann and D. Int-Hout "Ventilation Effectiveness Measurements of Three
Supply/Return Air Configurations," Environment International, Volume 15, pp 585-592
1989.
F.J. Offermann, S.A. Loiselle, M.C. Quinlan, and M.S. Rogers, "A Study of Diesel Fume
Entrainment in an Office Building," IAO '89, The Human Equation: Health and
Comfort, pp 179-183, ASHRAE, Atlanta, GA, 1989.
R.G.Sextro and F.J.Offermann, "Reduction of Residential Indoor Particle and Radon
Progeny Concentrations with Ducted Air Cleaning Systems," submitted to Indoor Air,
1990.
S.A.Loiselle, A.T.Hodgson, and F.J.Offermann, "Development of An Indoor Air Sampler
for Polycyclic Aromatic Compounds", Indoor Air, Volt, pp 191-210, 1991.
F.J.Offermann, S.A.Loiselle, A.T.Hodgson, L.A. Gundel, and J.M. Daisey, "A Pilot
Study to Measure Indoor Concentrations and Emission Rates of Polycyclic Aromatic
Compounds", Indoor Air , Vol 4, pp 497-512, 1991.
F.J. Offermann, S. A. Loiselle, R.G. Sextro, "Performance Comparisons of Six Different
Air Cleaners Installed in a Residential Forced Air Ventilation System," IAQ'91, Healthy
Buildings, pp 342-350, ASHRAE, Atlanta, GA (1991).
F.J. Offermann, J. Daisey, A. Hodgson, L. Gundell, and S. Loiselle, "Indoor
Concentrations and Emission Rates of Polycyclic Aromatic Compounds", Indoor Air,
Vol 4, pp 497-512 (1992).
F.J. Offermann, S. A. Loiselle, R.G. Sextro, "Performance of Air Cleaners Installed in a
Residential Forced Air System," ASHRAE Journal, pp 51-57, July, 1992.
F.J. Offermann and S. A. Loiselle, "Performance of an Air -Cleaning System in an
Archival Book Storage Facility," IAO'92, ASHRAE, Atlanta, GA, 1992.
S.B. Hayward, K.S. Liu, L.E. Alevantis, K. Shah, S. Loiselle, F.J. Offermann, Y.L.
Chang, L. Webber, "Effectiveness of Ventilation and Other Controls in Reducing
Exposure to ETS in Office Buildings," Indoor Air '93, Helsinki, Finland, July 4-8, 1993.
756-60
F.J. Offermann, S. A. Loiselle, G. Ander, H. Lau, "Indoor Contaminant Emission Rates
Before and After a Building Bake -out," IA 93, Operating and Maintaining Buildings for
Health, Comfort, and Productivity, pp 157-163, ASHRAE, Atlanta, GA, 1993.
L.E. Alevantis, Hayward, S.B., Shah, S.B., Loiselle, S., and Offermann, F.J. "Tracer Gas
Techniques for Determination of the Effectiveness of Pollutant Removal From Local
Sources," IA '93, Operating and Maintaining Buildings for Health, Comfort, and
Productivity, pp 119-129, ASHRAE, Atlanta, GA, 1993.
L.E. Alevantis, Liu, L.E., Hayward, S.B., Offermann, F.J., Shah, S.B., Leiserson, K.
Tsao, E., and Huang, Y., "Effectiveness of Ventilation in 23 Designated Smoking Areas
in California Buildings," IAQ '94, Engineering Indoor Environments, pp 167-181,
ASHRAE, Atlanta, GA, 1994.
L.E. Alevantis, Offermann, F.J., Loiselle, S., and Macher, J.M., "Pressure and Ventilation
Requirements of Hospital Isolation Rooms for Tuberculosis (TB) Patients: Existing
Guidelines in the United States and a Method for Measuring Room Leakage", Ventilation
and Indoor air quality in Hospitals, M. Maroni, editor, Kluwer Academic publishers,
Netherlands, 1996.
F.J. Offermann, M. A. Waz, A.T. Hodgson, and H.M. Ammann, "Chemical Emissions
from a Hospital Operating Room Air Filter," IA '96, Paths to Better Building
Environments, pp 95-99, ASHRAE, Atlanta, GA, 1996.
F.J. Offermann, "Professional Malpractice and the Sick Building Investigator," IA '96,
Paths to Better Building Environments, pp 132-136, ASHRAE, Atlanta, GA, 1996.
F.J. Offermann, "Standard Method of Measuring Air Change Effectiveness," Indoor Air,
Vol 1, pp.206-211, 1999.
F. J. Offermann, A. T. Hodgson, and J. P. Robertson, "Contaminant Emission Rates from
PVC Backed Carpet Tiles on Damp Concrete", Healthy Buildings 2000, Espoo, Finland,
August 2000.
K.S. Liu, L.E. Alevantis, and F.J. Offermann, "A Survey of Environmental Tobacco
Smoke Controls in California Office Buildings", Indoor Air, Vol 11, pp. 26-34, 2001.
F.J. Offermann, R. Colfer, P. Radzinski, and J. Robertson, "Exposure to Environmental
Tobacco Smoke in an Automobile", Indoor Air 2002, Monterey, California, July 2002.
F. J. Offermann, J.P. Robertson, and T. Webster, "The Impact of Tracer Gas Mixing on
Airflow Rate Measurements in Large Commercial Fan Systems", Indoor Air 2002,
Monterey, California, July 2002.
M. J. Mendell, T. Brennan, L. Hathon, J.D. Odom, F.J.Offermann, B.H. Turk, K.M.
Wallingford, R.C. Diamond, W.J. Fisk, "Causes and prevention of Symptom Complaints
756-61
in Office Buildings: Distilling the Experience of Indoor Environmental Investigators",
submitted to Indoor Air 2005, Beijing, China, September 4-9, 2005.
F.J. Offermann, "Ventilation and IAQ in New Homes With and Without Mechanical
Outdoor Air Systems", Healthy Buildings 2009, Syracuse, CA, September 14, 2009.
F.J. Offermann, "ASHRAE 62.2 Intermittent Residential Ventilation: What's It Good
For, Intermittently Poor IAQ", IAQVEC 2010, Syracuse, CA, April 21, 2010.
F.J. Offermann and A.T. Hodgson, "Emission Rates of Volatile Organic Compounds in
New Homes", Indoor Air 2011, Austin, TX, June, 2011.
P. Jenkins, R. Johnson, T. Phillips, and F. Offermann, Chemical Concentrations in New
California Homes and Garages", Indoor Air 2011, Austin, TX, June, 2011.
W. J. Mills, B. J. Grigg, F. J. Offermann, B. E. Gustin, and N. E. Spingarm, "Toluene and
Methyl Ethyl Ketone Exposure from a Commercially Available Contact Adhesive",
Journal of Occupational and Environmental Hygiene, 9:D95-D102 May, 2012.
F. J. Offermann, R. Maddalena, J. C. Offermann, B. C. Singer, and H, Wilhelm, "The
Impact of Ventilation on the Emission Rates of Volatile Organic Compounds in
Residences", HB 2012, Brisbane, AU, July, 2012.
F. J. Offermann, A. T. Hodgson, P. L. Jenkins, R. D. Johnson, and T. J. Phillips,
"Attached Garages as a Source of Volatile Organic Compounds in New Homes", FIB
2012, Brisbane, CA, July, 2012.
R. Maddalena, N. Li, F. Offermann, and B. Singer, "Maximizing Information from
Residential Measurements of Volatile Organic Compounds", FIB 2012, Brisbane, AU,
July, 2012.
W. Chen, A. Persily, A. Hodgson, F. Offermann, D. Poppendieck, and K. Kumagai,
"Area -Specific Airflow Rates for Evaluating the Impacts of VOC emissions in U.S.
Single -Family Homes", Building and Environment, Vol. 71, 204-211, February, 2014.
F. J. Offermann, A. Eagan A. C. Offermann, and L. J. Radonovich, "Infectious Disease
Aerosol Exposures With and Without Surge Control Ventilation System Modifications",
Indoor Air 2014, Hong Kong, July, 2014.
F. J. Offermann, "Chemical Emissions from E-Cigarettes: Direct and Indirect Passive
Exposures", Building and Environment, Vol. 93, Part 1, 101-105, November, 2015.
F. J. Offermann, "Formaldehyde Emission Rates From Lumber Liquidators Laminate
Flooring Manufactured in China", Indoor Air 2016, Belgium, Ghent, July, 2016.
F. J. Offermann, "Formaldehyde and Acetaldehyde Emission Rates for E-Cigarettes",
Indoor Air 2016, Belgium, Ghent, July, 2016.
756-62
OTHER REPORTS:
W.J.Fisk, P.G.Cleary, and F.J.Offermann, "Energy Saving Ventilation with Residential
Heat Exchangers," a Lawrence Berkeley Laboratory brochure distributed by the
Bonneville Power Administration, 1981.
F.J.Offermann, J.R.Girman, and C.D.Hollowell, "Midway House Tightening Project: A
Study of Indoor Air Quality," Lawrence Berkeley Laboratory, Berkeley, CA, Report
LBL-12777, 1981.
F.J.Offermann, J.B.Dickinson, W.J.Fisk, D.T.Grimsrud, C.D.Hollowell, D.L.Krinkle, and
G.D.Roseme, "Residential Air -Leakage and Indoor Air Quality in Rochester, New York,"
Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-13100, 1982.
F.J.Offermann, W.J.Fisk, B.Pedersen, and K.L.Revzan, Residential Air -to -Air Heat
Exchangers: A Study of the Ventilation Efficiencies of Wall- or Window- Mounted
Units," Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-14358, 1982.
F.J.Offermann, W.J.Fisk, W.W.Nazaroff, and R.G.Sextro, "A Review of Portable Air
Cleaners for Controlling Indoor Concentrations of Particulates and Radon Progeny," An
interim report for the Bonneville Power Administration, 1983.
W.J.Fisk, K.M.Archer, R.E.Chant, D.Hekmat, F.J.Offermann, and B.S. Pedersen,
"Freezing in Residential Air -to -Air Heat Exchangers: An Experimental Study," Lawrence
Berkeley Laboratory, Berkeley, CA, Report LBL-16783, 1983.
R.G.Sextro, W.W.Nazaroff, F.J.Offermann, and K.L.Revzan, "Measurements of Indoor
Aerosol Properties and Their Effect on Radon Progeny," Proceedings of the American
Association of Aerosol Research Annual Meeting, April, 1983.
F.J.Offermann, R.G.Sextro, W.J.Fisk, W.W. Nazaroff, A.V.Nero, K.L.Revzan, and
J.Yater, "Control of Respirable Particles and Radon Progeny with Portable Air Cleaners,"
Lawrence Berkeley Laboratory, Berkeley, CA, Report LBL-16659, 1984.
W.J.Fisk, R.K.Spencer, D.T.Grimsrud, F.J.Offermann, B.Pedersen, and R.G.Sextro,
"Indoor Air Quality Control Techniques: A Critical Review," Lawrence Berkeley
Laboratory, Berkeley, CA, Report LBL-16493, 1984.
F.J.Offermann, J.R.Girman, and R.G.Sextro, "Controlling Indoor Air Pollution from
Tobacco Smoke: Models and Measurements,", Indoor Air, Proceedings of the 3rd
International Conference on Indoor Air Quality and Climate, Vol 1, pp 257-264, Swedish
Council for Building Research, Stockholm (1984), Lawrence Berkeley Laboratory,
Berkeley, CA, Report LBL-17603, 1984.
756 63
R.Otto, J.Girman, F.Offermann, and R.Sextro,"A New Method for the Collection and
Comparison of Respirable Particles in the Indoor Environment," Lawrence Berkeley
Laboratory, Berkeley, CA, Special Director Fund's Study, 1984.
A.T.Hodgson and F.J.Offermann, "Examination of a Sick Office Building," Lawrence
Berkeley Laboratory, Berkeley, CA, an informal field study, 1984.
R.G.Sextro, F.J.Offermann, W.W.Nazaroff, and A.V.Nero, "Effects of Aerosol
Concentrations on Radon Progeny," Aerosols, Science, & Technology, and Industrial
Applications of Airborne Particles, editors B.Y.H.Liu, D.Y.H.Pui, and H.J.Fissan, p525,
Elsevier, 1984.
K.Sexton, S.Hayward, F.Offermann, R.Sextro, and L.Weber, "Characterization of
Particulate and Organic Emissions from Major Indoor Sources, Proceedings of the Third
International Conference on Indoor Air Quality and Climate, Stockholm, Sweden, August
20-24,1984.
F.J.Offermann, "Tracer Gas Measurements of Laboratory Fume Entrainment at a Semi -
Conductor Manufacturing Plant," an Indoor Environmental Engineering R&D Report,
1986.
F.J.Offermann, "Tracer Gas Measurements of Ventilation Rates in a Large Office
Building," an Indoor Environmental Engineering R&D Report, 1986.
F.J.Offermann, "Measurements of Volatile Organic Compounds in a New Large Office
Building with Adhesive Fastened Carpeting," an Indoor Environmental Engineering
R&D Report, 1986.
F.J.Offermann, "Designing and Operating Healthy Buildings", an Indoor Environmental
Engineering R&D Report, 1986.
F.J.Offermann, "Measurements and Mitigation of Indoor Spray-Applicated Pesticides",
an Indoor Environmental Engineering R&D Report, 1988.
F.J.Offermann and S. Loiselle, "Measurements and Mitigation of Indoor Mold
Contamination in a Residence", an Indoor Environmental Engineering R&D Report,
1989.
F.J.Offermann and S. Loiselle, "Performance Measurements of an Air Cleaning System
in a Large Archival Library Storage Facility", an Indoor Environmental Engineering
R&D Report, 1989.
F.J. Offermann, J.M. Daisey, L.A. Gundel, and A.T. Hodgson, S. A. Loiselle, "Sampling,
Analysis, and Data Validation of Indoor Concentrations of Polycyclic Aromatic
Hydrocarbons", Final Report, Contract No. A732-106, California Air Resources Board,
March, 1990.
756-64
L.A. Gundel, J.M. Daisey, and F.J. Offermann, "A Sampling and Analytical Method for
Gas Phase Polycyclic Aromatic Hydrocarbons", Proceedings of the 5th International
Conference on Indoor Air Quality and Climate, Indoor Air'90, July 29-August 1990.
A.T. Hodgson, J.M. Daisey, and F.J. Offermann "Development of an Indoor Sampling
and Analytical Method for Particulate Polycyclic Aromatic Hydrocarbons", Proceedings
of the 5th International Conference on Indoor Air Quality and Climate, Indoor Air '90,
July 29-August, 1990.
F.J. Offermann, J.O. Sateri, "Tracer Gas Measurements in Large Multi -Room Buildings",
Indoor Air '93, Helsinki, Finland, July 4-8, 1993.
F.J.Offermann, M. T. O'Flaherty, and M. A. Waz "Validation of ASHRAE 129 -
Standard Method of Measuring Air Change Effectiveness", Final Report of ASHRAE
Research Project 891, December 8, 1997.
S.E. Guffey, F.J. Offermann et. al., "Proceedings of the Workshop on Ventilation
Engineering Controls for Environmental Tobacco smoke in the Hospitality Industry",
U.S. Department of Labor Occupational Safety and Health Administration and ACGIH,
1998.
F.J. Offermann, R.J. Fiskum, D. Kosar, and D. Mudaari, "A Practical Guide to
Ventilation Practices & Systems for Existing Buildings", Heating/Piping/Air
Conditioning Engineering supplement to April/May 1999 issue.
F.J. Offermann, P. Pasanen, "Workshop 18: Criteria for Cleaning of Air Handling
Systems", Healthy Buildings 2000, Espoo, Finland, August 2000.
F.J. Offermann, Session Summaries: Building Investigations, and Design &
Construction, Healthy Buildings 2000, Espoo, Finland, August 2000.
F.J. Offermann, "The IAQ Top 10", Engineered Systems, November, 2008.
L. Kincaid and F.J. Offermann, "Unintended Consequences: Formaldehyde Exposures in
Green Homes, AIHA Synergist, February, 2010.
F.J. Offermann, " IAQ in Air Tight Homes", ASHRAE Journal, November, 2010.
F.J. Offermann, "The Hazards of E-Cigarettes", ASHRAE Journal, June, 2014.
PRESENTATIONS:
"Low -Infiltration Housing in Rochester, New York: A Study of Air Exchange Rates and
Indoor Air Quality," Presented at the International Symposium on Indoor Air Pollution,
Health and Energy Conservation, Amherst, MA, October 13-16,1981.
756-65
"Ventilation Efficiencies of Wall- or Window -Mounted Residential Air -to -Air Heat
Exchangers," Presented at the American Society of Heating, Refrigeration, and Air
Conditioning Engineers Summer Meeting, Washington, DC, June, 1983.
"Controlling Indoor Air Pollution from Tobacco Smoke: Models and Measurements,"
Presented at the Third International Conference on Indoor Air Quality and Climate,
Stockholm, Sweden, August 20-24, 1984.
"Indoor Air Pollution: An Emerging Environmental Problem", Presented to the
Association of Environmental Professionals, Bar Area/Coastal Region 1, Berkeley, CA,
May 29, 1986.
"Ventilation Measurement Techniques," Presented at the Workshop on Sampling and
Analytical Techniques, Georgia Institute of Technology, Atlanta, Georgia, September 26,
1986 and September 25, 1987.
"Buildings That Make You Sick: Indoor Air Pollution", Presented to the Sacramento
Association of Professional Energy Managers, Sacramento, CA, November 18, 1986.
"Ventilation Effectiveness and Indoor Air Quality", Presented to the American Society of
Heating, Refrigeration, and Air Conditioning Engineers Northern Nevada Chapter, Reno,
NV, February 18, 1987, Golden Gate Chapter, San Francisco, CA, October 1, 1987, and
the San Jose Chapter, San Jose, CA, June 9, 1987.
"Tracer Gas Techniques for Studying Ventilation," Presented at the Indoor Air Quality
Symposium, Georgia Tech Research Institute, Atlanta, GA, September 22-24, 1987.
"Indoor Air Quality Control: What Works, What Doesn't," Presented to the Sacramento
Association of Professional Energy Managers, Sacramento, CA, November 17, 1987.
"Ventilation Effectiveness and ADPI Measurements of a Forced Air Heating System,"
Presented at the American Society of Heating, Refrigeration, and Air Conditioning
Engineers Winter Meeting, Dallas, Texas, January 31, 1988.
"Indoor Air Quality, Ventilation, and Energy in Commercial Buildings", Presented at the
Building Owners &Managers Association of Sacramento, Sacramento, CA, July 21,
1988.
"Controlling Indoor Air Quality: The New ASHRAE Ventilation Standards and How to
Evaluate Indoor Air Quality", Presented at a conference "Improving Energy Efficiency
and Indoor Air Quality in Commercial Buildings," National Energy Management
Institute, Reno, Nevada, November 4, 1988.
"A Study of Diesel Fume Entrainment Into an Office Building," Presented at Indoor Air
'89: The Human Equation: Health and Comfort, American Society of Heating,
Refrigeration, and Air Conditioning Engineers, San Diego, CA, April 17-20, 1989.
756-66
"Indoor Air Quality in Commercial Office Buildings," Presented at the Renewable
Energy Technologies Symposium and International Exposition, Santa Clara, CA June 20,
1989.
"Building Ventilation and Indoor Air Quality", Presented to the San Joaquin Chapter of
the American Society of Heating, Refrigeration, and Air Conditioning Engineers,
September 7, 1989.
"How to Meet New Ventilation Standards: Indoor Air Quality and Energy Efficiency," a
workshop presented by the Association of Energy Engineers; Chicago, IL, March 20-21,
1989; Atlanta, GA, May 25-26, 1989; San Francisco, CA, October 19-20, 1989; Orlando,
FL, December 11-12, 1989; Houston, TX, January 29-30, 1990; Washington D.C.,
February 26-27, 1990; Anchorage, Alaska, March 23, 1990; Las Vegas, NV, April 23-24,
1990; Atlantic City, NJ, September 27-28, 1991; Anaheim, CA, November 19-20, 1991;
Orlando, FL, February 28 - March 1, 1991; Washington, DC, March 20-21, 1991;
Chicago, IL, May 16-17, 1991; Lake Tahoe, NV, August 15-16, 1991; Atlantic City, NJ,
November 18-19, 1991; San Jose, CA, March 23-24, 1992.
"Indoor Air Quality," a seminar presented by the Anchorage, Alaska Chapter of the
American Society of Heating, Refrigeration, and Air Conditioning Engineers, March 23,
1990.
"Ventilation and Indoor Air Quality", Presented at the 1990 HVAC & Building Systems
Congress, Santa, Clara, CA, March 29, 1990.
"Ventilation Standards for Office Buildings", Presented to the South Bay Property
Managers Association, Santa Clara, May 9, 1990.
"Indoor Air Quality", Presented at the Responsive Energy Technologies Symposium &
International Exposition (RETSIE), Santa Clara, CA, June 20, 1990.
"Indoor Air Quality - Management and Control Strategies", Presented at the Association
of Energy Engineers, San Francisco Bay Area Chapter Meeting, Berkeley, CA,
September 25, 1990.
"Diagnosing Indoor Air Contaminant and Odor Problems", Presented at the ASHRAE
Annual Meeting, New York City, NY, January 23, 1991.
"Diagnosing and Treating the Sick Building Syndrome", Presented at the Energy 2001,
Oklahoma, OK, March 19, 1991.
"Diagnosing and Mitigating Indoor Air Quality Problems" a workshop presented by the
Association of Energy Engineers, Chicago, IL, October 29-30, 1990; New York, NY,
January 24-25, 1991; Anaheim, April 25-26, 1991; Boston, MA, June 10-11, 1991;
Atlanta, GA, October 24-25, 1991; Chicago, IL, October 3-4, 1991; Las Vegas, NV,
December 16-17, 1991; Anaheim, CA, January 30-31, 1992; Atlanta, GA, March 5-6,
1992; Washington, DC, May 7-8, 1992; Chicago, IL, August 19-20, 1992; Las Vegas,
756 67
NV, October 1-2, 1992; New York City, NY, October 26-27, 1992, Las Vegas, NV,
March 18-19, 1993; Lake Tahoe, CA, July 14-15, 1994; Las Vegas, NV, April 3-4, 1995;
Lake Tahoe, CA, July 11-12, 1996; Miami, Fl, December 9-10, 1996.
"Sick Building Syndrome and the Ventilation Engineer", Presented to the San Jose
Engineers Club, May, 21, 1991.
"Duct Cleaning: Who Needs It ? How Is It Done ? What Are The Costs ?" What Are the
Risks ?, Moderator of Forum at the ASHRAE Annual Meeting, Indianapolis ID, June 23,
1991.
"Operating Healthy Buildings", Association of Plant Engineers, Oakland, CA, November
14, 1991.
"Duct Cleaning Perspectives", Moderator of Seminar at the ASHRAE Semi -Annual
Meeting, Indianapolis, IN, June 24, 1991.
"Duct Cleaning: The Role of the Environmental Hygienist," ASHRAE Annual Meeting,
Anaheim, CA, January 29, 1992.
"Emerging IAQ Issues", Fifth National Conference on Indoor Air Pollution, University of
Tulsa, Tulsa, OK, April 13-14, 1992.
"International Symposium on Room Air Convection and Ventilation Effectiveness",
Member of Scientific Advisory Board, University of Tokyo, July 22-24, 1992.
"Guidelines for Contaminant Control During Construction and Renovation Projects in
Office Buildings," Seminar paper at the ASHRAE Annual Meeting, Chicago, IL, January
26, 1993.
"Outside Air Economizers: IAQ Friend or Foe", Moderator of Forum at the ASHRAE
Annual Meeting, Chicago, IL, January 26, 1993.
"Orientation to Indoor Air Quality," an EPA two and one half day comprehensive indoor
air quality introductory workshop for public officials and building property managers;
Sacramento, September 28-30, 1992; San Francisco, February 23-24, 1993; Los Angeles,
March 16-18, 1993; Burbank, June 23, 1993; Hawaii, August 24-25, 1993; Las Vegas,
August 30, 1993; San Diego, September 13-14, 1993; Phoenix, October 18-19, 1993;
Reno, November 14-16, 1995; Fullerton, December 3-4, 1996; Fresno, May 13-14, 1997.
"Building Air Quality: A Guide for Building Owners and Facility Managers," an EPA
one half day indoor air quality introductory workshop for building owners and facility
managers. Presented throughout Region IX 1993-1995.
"Techniques for Airborne Disease Control", EPRI Healthcare Initiative Symposium; San
Francisco, CA; June 7, 1994.
756'-68
"Diagnosing and Mitigating Indoor Air Quality Problems", CIHC Conference; San
Francisco, September 29, 1994.
"Indoor Air Quality: Tools for Schools," an EPA one day air quality management
workshop for school officials, teachers, and maintenance personnel; San Francisco,
October 18-20, 1994; Cerritos, December 5, 1996; Fresno, February 26, 1997; San Jose,
March 27, 1997; Riverside, March 5, 1997; San Diego, March 6, 1997; Fullerton,
November 13, 1997; Santa Rosa, February 1998; Cerritos, February 26, 1998; Santa
Rosa, March 2, 1998.
ASHRAE 62 Standard "Ventilation for Acceptable IAQ", ASCR Convention; San
Francisco, CA, March 16, 1995.
"New Developments in Indoor Air Quality: Protocol for Diagnosing IAQ Problems",
AIHA-NC; March 25, 1995.
"Experimental Validation of ASHRAE SPC 129, Standard Method of Measuring Air
Change Effectiveness", 16th AIVC Conference, Palm Springs, USA, September 19-22,
1995.
"Diagnostic Protocols for Building IAQ Assessment", American Society of Safety
Engineers Seminar: `Indoor Air Quality — The Next Door'; San Jose Chapter, September
27, 1995; Oakland Chapter, 9, 1997.
"Diagnostic Protocols for Building IAQ Assessment", Local 39; Oakland, CA, October 3,
1995.
"Diagnostic Protocols for Solving IAQ Problems", CSU-PPD Conference; October 24,
1995.
"Demonstrating Compliance with ASHRAE 62-1989 Ventilation Requirements", AIHA;
October 25, 1995.
"IAQ Diagnostics: Hands on Assessment of Building Ventilation and Pollutant
Transport", EPA Region IX; Phoenix, AZ, March 12, 1996; San Francisco, CA, April 9,
1996; Burbank, CA, April 12, 1996.
"Experimental Validation of ASHRAE 129P: Standard Method of Measuring Air Change
Effectiveness", Room Vent `96 / International Symposium on Room Air Convection and
Ventilation Effectiveness'; Yokohama, Japan, July 16-19, 1996.
"IAQ Diagnostic Methodologies and RFP Development", CCEHSA 1996 Annual
Conference, Humboldt State University, Arcata, CA, August 2, 1996.
"The Practical Side of Indoor Air Quality Assessments", California Industrial Hygiene
Conference `96, San Diego, CA, September 2, 1996.
756-69
"ASHRAE Standard 62: Improving Indoor Environments", Pacific Gas and Electric
Energy Center, San Francisco, CA, October 29, 1996.
"Operating and Maintaining Healthy Buildings", April 3-4, 1996, San Jose, CA; July 30,
1997, Monterey, CA.
"IAQ Primer", Local 39, April 16, 1997; Amdahl Corporation, June 9, 1997; State
Compensation Insurance Fund's Safety & Health Services Department, November 21,
1996.
"Tracer Gas Techniques for Measuring Building Air Flow Rates", ASHRAE,
Philadelphia, PA, January 26, 1997.
"How to Diagnose and Mitigate Indoor Air Quality Problems"; Women in Waste; March
19, 1997.
"Environmental Engineer: What Is It?", Monte Vista High School Career Day; April 10,
1997.
"Indoor Environment Controls: What's Hot and What's Not", Shaklee Corporation; San
Francisco, CA, July 15, 1997.
"Measurement of Ventilation System Performance Parameters in the US EPA BASE
Study", Healthy Buildings/IAQ'97, Washington, DC, September 29, 1997.
"Operations and Maintenance for Healthy and Comfortable Indoor Environments",
PASMA; October 7, 1997.
"Designing for Healthy and Comfortable Indoor Environments", Construction
Specification Institute, Santa Rosa, CA, November 6, 1997.
"Ventilation System Design for Good IAQ", University of Tulsa 10t" Annual Conference,
San Francisco, CA, February 25, 1998.
"The Building Shell", Tools For Building Green Conference and Trade Show, Alameda
County Waste Management Authority and Recycling Board, Oakland, CA, February 28,
1998.
"Identifying Fungal Contamination Problems In Buildings", The City of Oakland
Municipal Employees, Oakland, CA, March 26, 1998.
"Managing Indoor Air Quality in Schools: Staying Out of Trouble", CASBO,
Sacramento, CA, April 20, 1998.
"Indoor Air Quality", CSOOC Spring Conference, Visalia, CA, April 30, 1998.
"Particulate and Gas Phase Air Filtration", ACGIH/OSHA, Ft. Mitchell, KY, June 1998.
756-70
"Building Air Quality Facts and Myths", The City of Oakland / Alameda County Safety
Seminar, Oakland, CA, June 12, 1998.
"Building Engineering and Moisture", Building Contamination Workshop, University of
California Berkeley, Continuing Education in Engineering and Environmental
Management, San Francisco, CA, October 21-22, 1999.
"Identifying and Mitigating Mold Contamination in Buildings", Western Construction
Consultants Association, Oakland, CA, March 15, 2000; AIG Construction Defect
Seminar, Walnut Creek, CA, May 2, 2001; City of Oakland Public Works Agency,
Oakland, CA, July 24, 2001; Executive Council of Homeowners, Alamo, CA, August 3,
2001.
"Using the EPA BASE Study for IAQ Investigation / Communication", Joint
Professional Symposium 2000, American Industrial Hygiene Association, Orange County
& Southern California Sections, Long Beach, October 19, 2000.
"Ventilation," Indoor Air Quality: Risk Reduction in the 21" Century Symposium,
sponsored by the California Environmental Protection Agency/Air Resources Board,
Sacramento, CA, May 3-4, 2000.
"Workshop 18: Criteria for Cleaning of Air Handling Systems", Healthy Buildings 2000,
Espoo, Finland, August 2000.
"Closing Session Summary: `Building Investigations' and `Building Design &
Construction', Healthy Buildings 2000, Espoo, Finland, August 2000.
"Managing Building Air Quality and Energy Efficiency, Meeting the Standard of Care",
BOMA, MidAtlantic Environmental Hygiene Resource Center, Seattle, WA, May 23'a,
2000; San Antonio, TX, September 26-27, 2000.
"Diagnostics & Mitigation in Sick Buildings: When Good Buildings Go Bad," University
of California Berkeley, September 18, 2001.
"Mold Contamination: Recognition and What To Do and Not Do", Redwood Empire
Remodelers Association; Santa Rosa, CA, April 16, 2002.
"Investigative Tools of the IAQ Trade", Healthy Indoor Environments 2002; Austin, TX;
April 22, 2002.
"Finding Hidden Mold: Case Studies in IAQ Investigations", AIHA Northern California
Professionals Symposium; Oakland, CA, May 8, 2002.
"Assessing and Mitigating Fungal Contamination in Buildings", Cal/OSHA Training;
Oakland, CA, February 14, 2003 and West Covina, CA, February 20-21, 2003.
756-71
"Use of External Containments During Fungal Mitigation", Invited Speaker, ACGIH
Mold Remediation Symposium, Orlando, FL, November 3-5, 2003.
Building Operator Certification (BOC), 106-IAQ Training Workshops, Northwest Energy
Efficiency Council; Stockton, CA, December 3, 2003; San Francisco, CA, December 9,
2003; Irvine, CA, January 13, 2004; San Diego, January 14, 2004; Irwindale, CA,
January 27, 2004; Downey, CA, January 28, 2004; Santa Monica, CA, March 16, 2004;
Ontario, CA, March 17, 2004; Ontario, CA, November 9, 2004, San Diego, CA,
November 10, 2004; San Francisco, CA, November 17, 2004; San Jose, CA, November
18, 2004; Sacramento, CA, March 15, 2005.
"Mold Remediation: The National QUEST for Uniformity Symposium", Invited
Speaker, Orlando, Florida, November 3-5, 2003.
"Mold and Moisture Control", Indoor Air Quality workshop for The Collaborative for
High Performance Schools (CHPS), San Francisco, December 11, 2003.
"Advanced Perspectives In Mold Prevention & Control Symposium", Invited Speaker,
Las Vegas, Nevada, November 7-9, 2004.
"Building Sciences: Understanding and Controlling Moisture in Buildings", American
Industrial Hygiene Association, San Francisco, CA, February 14-16, 2005.
"Indoor Air Quality Diagnostics and Healthy Building Design", University of California
Berkeley, Berkeley, CA, March 2, 2005.
"Improving IAQ = Reduced Tenant Complaints", Northern California Facilities
Exposition, Santa Clara, CA, September 27, 2007.
"Defining Safe Building Air", Criteria for Safe Air and Water in Buildings, ASHRAE
Winter Meeting, Chicago, IL, January 27, 2008.
"Update on USGBC LEED and Air Filtration", Invited Speaker, NAFA 2008
Convention, San Francisco, CA, September 19, 2008.
"Ventilation and Indoor air Quality in New California Homes", National Center of
Healthy Housing, October 20, 2008.
"Indoor Air Quality in New Homes", California Energy and Air Quality Conference,
October 29, 2008.
"Mechanical Outdoor air Ventilation Systems and IAQ in New Homes", ACI Home
Performance Conference, Kansas City, MO, April 29, 2009.
"Ventilation and IAQ in New Homes with and without Mechanical Outdoor Air
Systems", Healthy Buildings 2009, Syracuse, CA, September 14, 2009.
756 72
"Ten Ways to Improve Your Air Quality", Northern California Facilities Exposition,
Santa Clara, CA, September 30, 2009.
"New Developments in Ventilation and Indoor Air Quality in Residential Buildings",
Westcon meeting, Alameda, CA, March 17, 2010.
"Intermittent Residential Mechanical Outdoor Air Ventilation Systems and IAQ",
ASHRAE SSPC 62.2 Meeting, Austin, TX, April 19, 2010.
"Measured IAQ in Homes", ACI Home Performance Conference, Austin, TX, April 21,
2010.
"Respiration: IEQ and Ventilation", AIHce 2010, How IH Can LEED in Green buildings,
Denver, CO, May 23, 2010.
"IAQ Considerations for Net Zero Energy Buildings (NZEB)", Northern California
Facilities Exposition, Santa Clara, CA, September 22, 2010.
"Energy Conservation and Health in Buildings", Berkeley High SchoolGreen Career
Week, Berkeley, CA, April 12, 2011.
"What Pollutants are Really There ?", ACI Home Performance Conference, San
Francisco, CA, March 30, 2011.
"Energy Conservation and Health in Residences Workshop", Indoor Air 2011, Austin,
TX, June 6, 2011.
"Assessing IAQ and Improving Health in Residences", US EPA Weatherization Plus
Health, September 7, 2011.
"Ventilation: What a Long Strange Trip It's Been", Westcon, May 21, 2014.
"Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposures", Indoor
Air 2014, Hong Kong, July, 2014.
"Infectious Disease Aerosol Exposures With and Without Surge Control Ventilation
System Modifications", Indoor Air 2014, Hong Kong, July, 2014.
"Chemical Emissions from E-Cigarettes", IMF Health and Welfare Fair, Washington,
DC, February 18, 2015.
"Chemical Emissions and Health Hazards Associated with E-Cigarettes", Roswell Park
Cancer Institute, Buffalo, NY, August 15, 2014.
"Formaldehyde Indoor Concentrations, Material Emission Rates, and the CARB ATCM",
Harris Martin's Lumber Liquidators Flooring Litigation Conference, WQ Minneapolis
Hotel, May 27, 2015.
756 73
"Chemical Emissions from E-Cigarettes: Direct and Indirect Passive Exposure", FDA
Public Workshop: Electronic Cigarettes and the Public Health, Hyattsville, MD June 2,
2015.
"Creating Healthy Homes, Schools, and Workplaces", Chautauqua Institution,
Athenaeum Hotel, August 24, 2015.
"Diagnosing IAQ Problems and Designing Healthy Buildings", University of California
Berkeley, Berkeley, CA, October 6, 2015.
"Diagnosing Ventilation and IAQ Problems in Commercial Buildings", BEST Center
Annual Institute, Lawrence Berkeley National Laboratory, January 6, 2016.
"A Review of Studies of Ventilation and Indoor Air Quality in New Homes and Impacts
of Environmental Factors on Formaldehyde Emission Rates From Composite Wood
Products", AIHce2016, May, 21-26, 2016.
"Admissibility of Scientific Testimony", Science in the Court, Proposition 65
Clearinghouse Annual Conference, Oakland, CA, September 15, 2016.
"Indoor Air Quality and Ventilation", ASHRAE Redwood Empire, Napa, CA, December
1, 2016.
756-74
ATTACHMENT B
75C-75
SWA P E Technical Consultation, Data Analysis and
Litigation Support for the Environment
2656 291h Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949)887-9013
mhagemann@swape.com
Paul E. Rosenfeld, PhD
(310)795-2335
prosenfeld@swape.com
October 12, 2020
Richard Drury
Lozeau I Drury LLP
1939 Harrison Street, Suite 150
Oakland, CA 94618
Subject: Comments on 4`h and Mortimer Project (SCH No. 2006071100)
Dear Mr. Drury,
We have reviewed the October 2020 Environmental Impact Report Addendum ("Addendum") for the 41h
and Mortimer Project ("Project") located in the City of Santa Ana ("City"). The Project proposes to
demolish two existing buildings as well as construct a 93,117-SF mixed -use residential structure
containing 99 apartment units, a 74,986-SF multi -family residential structure containing 70 units, 8,075-
SF of leasing/amenity areas, 3,847-SF of restaurant space, 7,514-SF of retail space, and 422 parking
spaces on the 2.7-acre site.
Our review concludes that the Addendum fails to adequately evaluate the Project's air quality, health
risk, and greenhouse gas impacts. As a result, emissions and health risk impacts associated with
construction and operation of the proposed Project are underestimated and inadequately addressed. An
EIR should be prepared to adequately assess and mitigate the potential air quality, health risk, and
greenhouse gas impacts that the project may have on the surrounding environment.
Air Quality
Unsubstantiated Input Parameters Used to Estimate Project Emissions
The Addendum's air quality analysis relies on emissions calculated with CalEEMod.2016.3.2.1 CalEEMod
provides recommended default values based on site -specific information, such as land use type,
meteorological data, total lot acreage, project type and typical equipment associated with project type.
If more specific project information is known, the user can change the default values and input project-
1 CAPCOA (November 2017) CalEEMod User's Guide, http://www.aqmd.gov/docs/default-
source/ca I eemod/01_use r-39-s-gu id e2016-3-2_15 nove m be r2017. pdf?sfvrsn=4.
75C-76
specific values, but the California Environmental Quality Act ("CEQA") requires that such changes be
justified by substantial evidence.' Once all of the values are inputted into the model, the Project's
construction and operational emissions are calculated, and "output files" are generated. These output
files disclose to the reader what parameters were utilized in calculating the Project's air pollutant
emissions and make known which default values were changed as well as provide justification for the
values selected.'
When reviewing the Project's CaIEEMod output files, provided in the Air Quality Assessment as
Appendix B to the Addendum, we found that several model inputs were not consistent with information
disclosed in the Addendum. As a result, the Project's construction and operational emissions are
underestimated. A Project -specific EIR should be prepared to include an updated air quality analysis that
adequately evaluates the impacts that construction and operation of the Project will have on local and
regional air quality.
Use of an Underestimated CO2 Intensity Factor
Review of the Project's CaIEEMod output files demonstrates that the default CO2 intensity factor was
manually reduced from 702.44 pounds per megawatt hour ("Ibs/MWh") to 510.44 Ibs/MWh (see
excerpt below) (Appendix B, pp. 80, 112, 232).
I Table Name I Column Name I Default Value I New Value I
1671 ro. dbh , °leri ;t 66ilierellyFechtlr
............................. a..............................
702.44 1 510.44
As you can see in the excerpt above, the default CO2 intensity factor was artificially reduced by
approximately 27%. As previously mentioned, the CaIEEMod User's Guide requires any changes to
model defaults be justified.' According to the "User Entered Comments & Non -Default Data" table, the
justification provided for these changes is:
"CO2 Intensity Factor adjusted per the SCE 2018 CRSR. The report provides intensity factor of
CO2e, The CO2 intensity factor is calculated as 513-25*0.029-298*0.00617=510.4363 to avoid
double counting" (Appendix B, pp. 79, 111, 231).
However, review of the Edison International 2018 Sustainability Report demonstrates that the CO2
intensity factor is 513 Ibs/MWh.' As the Project fails to provide an adequate source for the values and
calculations utilized in the "User Entered Comments & Non -Default Data" table justification, we cannot
verify the revised value of 510.44 Ibs/MWh. As such, the Project should have used the 513 Ibs/MWh
carbon intensity value. This underestimation presents an issue, as CaIEEMod uses the CO2 intensity
'Ca I EEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9.
'Ca I EEMod User Guide, available at: http://www.caleemod.com/, p. 11, 12-13. A key feature oft he CaIEEMod
program is the "remarks" feature, where the user explains why a default setting was replaced by a "user defined"
value. These remarks are included in the report.
'CaIEEMod User Guide, available at: http://www.caleemod.com/, p. 2, 9
' Edison International 2018 Sustainability Report, available at: http://www.aamd.gov/docs/default-
source/caleemod/01 user-39-s-euide2016-3-2 15november2017.pdf?sfvrsn=4%20, p. 10
75C-77
factor to calculate the Project's greenhouse gas ("GHG") emissions associated with electricity use.' Thus,
by including an underestimated CO2 intensity factor, the model underestimates the Project's GHG
emissions and should not be relied upon to determine Project significance.
Use of an Underestimated Land Use Size
According to the Addendum, the proposed Project on Block A would include:
"a mixed -use residential structure containing 99 apartment units, with approximately 93,117
square feet of residential space, 8,075 square feet of leosinalomenity areas, a 3,847-square foot
restaurant, and 7,514 square feet of retail space. On Block B, a 70-unit multi -family residential
structure would be constructed, with 74,986 square feet of residential space, as well as an
aboveground parking structure with approximately 192 stalls" (emphasis added) (p. 2-10).
Thus, the Project would include 8,075-SF of leasing/amenity areas, in addition to the proposed 93,117-
SF of residential land use space on Block A and 74,986-SF of residential land use space on Block B. As
such, the Project's CalEEMod should have a total of 176,178-SF of residential land use space.7 However,
review of the Project's CalEEMod output files demonstrate that the model includes only 169,000-SF of
"Apartments Mid Rise" (see excerpt below) (Appendix B, pp. 78, 110, 230).
Lend uses
sdre
Metrlo WFaeapa
Floc, suhm Alm I
EOpW
Ewc ed Farki, wan Elwr
..............................1...........
MgM1 Tumprxr (Sl Opwn Reateurarrt) �
902.00
...................
$.�
Spore 1.0
1..__••__••__•I•__••__••__••__••_f__•___..__.._-0..................
OOOsgll 0.09
1888XIM '
.......
385000
9
.......
Apea sMy Rise
100.50
I]waeing Vhl I
18p.000W
eg3
S pMall
7.51
1000a O 0.17
7.5MM
0
As you can see in the excerpt above, the "Apartment Mid Rise" land use was underestimated by 7,178-
SF. This underestimation presents an issue, as the land use size feature is used throughout CalEEMod to
determine default variable and emission factors that go into the model's calculations. The square
footage of a land use is used for certain calculations such as determining the wall space to be painted
(i.e., VOC emissions from architectural coatings) and volume that is heated or cooled (i.e., energy
impacts). Furthermore, CalEEMod assigns each land use type with its own set of energy usage emission
factors.' By underestimating the proposed residential land use size, the model underestimates the
Project's construction -related and operational emissions and should not be relied upon to determine
Project significance.
Unsubstantiated Changes to Individual Construction Phase Lengths
Review of the Project's CalEEMod output files demonstrates that the model includes unsubstantiated
changes to the Project's anticipated individual construction phase lengths (see excerpt below) (Appendix
B, pp. 80, 112, 232).
6 "CalEEMod User's Guide." CAPCOA, November 2017, available at: http://www.caleemod.com/, p. 17.
7 (93,117-SF of residential space on Block A) + (8,075-SF of leasing/amenity areas on Block A) + (74,986-SF of
residential space on Block B) = 176,178-SF total.
e "CalEEMod User's Guide, Appendix D." CAPCOA, September 2016, available at:
http://www.agmd.gov/docs/default-source/caleemod/upgrades/2016.3/05 appendix-d2016-3-1.pdf?sfvrsn=2
75C-78
SHC4nSWs OnPha" NumDays 10,00 53.00
................. ............ i............................. --- ------------------------- ..........................
thLOra CtDnPhase NumDays 220.00 307.00
............... .............. d_....___._..__._.._..__._.._.>_----------------------------- --------------------------
thc( -Sftd Maw NumDays 20,00 23,00
............d............................. d•--- —_--- _________ ......_ .........
I--------------- Num0a --- 44.00
I........tionP... NumDays 10.00 24.00
As a result of these changes, the model includes a construction schedule as follows (Appendix B, pp. 84,
116, 237):
NUMW
......_I ... .........................
i •SiK Pray.....
1_______________.
•Silo
......_�........... ... .. ........
•Grating
1_______________.
-------
•Grading
1_____------- ____________
l___di
nO Construs
-
I...
1-------------
COOOng
As demonstrated in the excerpts above, the demolition construction phase is increased by 15%, from
the default value of 20 to 23 days; the site preparation remains at the default value of 3 days; the
grading construction phase is increased by approximately 633%, from the default value of 6 to 44 days;
the building construction phase is increased by approximately 40%, from the default value of 220 to 307
days; the paving construction phase is increased by 140%, from the default value of 10 to 24 days; and
the architectural coating phase is increased by 430%, from the default value of 10 to 53 days. As
previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be justified.'
According to the "User Entered Comments & Non -Default Data" table, the justification provided for
these changes is: "Estimated construction schedule based on construction questionnaire" (Appendix B,
pp. 79, 111, 231). However, the Addendum and associated documents fail to disclose a construction
questionnaire.
Furthermore, the Addendum states that "[c]onstruction is anticipated to take 21 to 24 months is
expected to begin in September 2021" (p. 2-11). However, while the total construction schedule is
approximately 21 months, from 9/1/2021 to 5/29/2023, the Addendum and associated documents fail
to provide the specific individual construction phase lengths. As a result, we cannot verify the reivsed
construction schedules and individual construction phase lengths included in the model.
These unsubstantiated changes improperly spread out construction emissions over a longer period of
time for some construction phases and not others. According to the CalEEMod User's Guide, each
construction phase is associated with different emissions activities (see excerpt below)."
'Ca I EEMod User Guide, available at: httD://www.caleemod.com/. p. 2, 9
10 "CalEEMod User's Guide." CAPCOA, November 2017, available at: httD://www.aamd.gov/docs/default-
source/caleemod/01 user-39-s-euide2016-3-2 15november2017.Ddf?sfvrsn=4, p. 31.
75C-79
Demolition involves removing buildings or structures
Site Preparation involves clearing vegetation (grubbing and treelstump removal) and
removing stones and other unwanted material or debris prior to grading.
Grading_involves the cut and fill of land to ensure that the proper base and slope is created
for the foundation.
Building Construction involves the construction of the foundation, structures and buildings.
Architectural Coatlno involves the application of coatings to both the interior and exterior of
buildings or structures, the painting of parking lot or parking garage striping, associated
signage and curbs, and the painting of the walls or other components such as stair railings
inside parking structures.
Paving involves the laying of concrete or asphalt such as in parking lots, roads, driveways,
or sidewalks.
As such, by disproportionately altering individual construction phase lengths without proper
justification, the model's calculations are altered and underestimate emissions. Thus, by including
unsubstantiated changes to the Project's anticipated individual construction phase lengths, the model
may underestimate the Project's maximum daily construction -related emissions and should not be
relied upon to determine the significance of the Project's air quality impacts.
Unsubstantiated Amount of Demolition
According to the CalEEMod User's Guide, "[h]aul trips are based on the amount of material that is
demolished, imported or exported assuming a truck can handle 16 cubic yards of material."11 Therefore,
the air model calculates a default number of hauling trips based upon the amount of demolition
material inputted into the model.
Regarding the amount of demolition required for Project construction, the Addendum states:
"The proposed project involves demolition of two existing buildings, Northgate Gonzalez Market
and Munoz Auto & Tire Repair" (p. 2-10).
Furthermore, review of the Project's CalEEMod output files demonstrates that the model calculated a
default value of 267 hauling truck trips (see excerpt below) (Appendix B, pp. 86, 118, 239).
Number 1 Number
Demolition •
5i 1100,
0.00
257.00
-•-----•-•-----•1-----'"_-_-_-'I•-•-•--b.-
SilePreparetion
-•.•-----------�"-------------I---•-----•
31—f-6.OD�
0
0.00:
---------1
Grernng
41—h1000,
0.00
000�
-- -- ----------------------
-►---------- I......
-
---------!
Builring ConsWction
81 19TOO,
48.00
0.00�
-----------'------
---------- i---•-----
---------�
Pevirg
61 15.00�
0.00
0.00:
Mchitedural Coating
1 39.00;
0.0
0.00•
" htto://www.agmd.gov/dots/default-source/caleemod/02 appendix-a2016-3-2.odf?sfvrsn=6. p. 14
75C-80
As you can see in the excerpt above, the model calculates 267 hauling truck trips for demolition.
According to the "User Entered Comments & Non -Default Data" table, the justification provided for
these changes is: "Estimated tons of demolished material based on AQconstruction questionnaire"
(Appendix B, pp. 79, 111, 231). However, this justification is incorrect for two (2) reasons. First, the
Addendum and associated documents fail to provide an AQ construction questionnaire, as referenced.
As such, we are unable to verify the inputted amount of demolition material as claimed. Second, the
Addendum fails to disclose the specific square footage of facilities to be demolished or the tons of debris
resulting from this demolition. Thus, we cannot verify that the hauling trip number calculated in the
model is the result of the input of the correct amount of demolition. As such, demolition may be
underestimated.
This potential underestimation presents an issue, as the total amount of demolition material is used by
CaIEEMod to determine emissions associated with this phase of construction. The three primary
operations that generate dust emissions during the demolition phase are mechanical or explosive
dismemberment, site removal of debris, and on -site truck traffic on paved and unpaved road.12 Thus, by
failing to substantiate the demolition of existing structures and hardscape, emissions associated with
fugitive dust, site removal, and exhaust from hauling trucks traveling to and from the site may be
underestimated. As a result, the model may underestimate the Project's construction -related emissions
and should not be relied upon to determine the significance of the Project's air quality impacts.
Use of Underestimated Operational Vehicle Trips
According to the Traffic Impact Analysis ("TIA"), provided by Appendix K to the Addendum, the proposed
Project is expected to generate 1,171 daily vehicle trips throughout operation (Appendix K, pp. 314,
Table 5-1). However, review of the "Project Traffic Generation Forecast Table" demonstrates that a 5%
non -auto trip reduction was applied to the Project's daily vehicle trip estimate, resulting in a reduction
of 59 vehicle trips (see excerpt below) (Appendix K, pp. 314, Table 5-1).
"CalEEMod User Guide, Appendix A, p. 11, available at: http://www.caleemod.com/
75C-81
Daily
Description 2-Way
/BI Proposed Project
221: Residential (169 Dil)
919
Internal Captu e7
-120
Residential Subtotal
799
O 820: Retail Shops (7.514 SF)
284
Internal Capture7
-163
Retail Subtotal
121
O 932: High -Turnover Restaurant (3.847 SF)
432
Internal Caphlre7
-181
Retail Subtotal
251
Total Project Trip Generation
1,171
%on -Auto Trip Adjustment (50/6)
-59
(Bj 'Net Project Trip Generation
1,112
As the above excerpt demonstrates, the TIA includes a 5% reduction to the trip generation calculations
to account for non -vehicle transport. Regarding the 5% non -auto trip reduction, the TIA states:
"Please note that a 5% non -auto trip reduction was applied to the trip generation to account for
other modes of transportation within a downtown area (i.e. public transit, walking, biking, etc.).
It is our understanding that the City of Santa Ana and Garden Grove have partnered with OCTA
to develop the "CC Streetcar" which will further enhance mobility throughout Downtown Santa
Ana, beyond the current transit opportunities that are now availability. In addition, the Santa
Ana Renaissance Specific Plon Traffic Study prepared by KOA dated January 2010 utilized a
similar 5% mode adjust" (Appendix K, pp. 312-313).
However, this justification is insufficient for three (3) reasons. First, while the TIA cites to the Santa Ana
Renaissance Specific Plon Traffic Study, which supposedly includes a similar adjustment, the TIA fails to
provide a source for the 5% non -auto trip reduction applied to the proposed Project. Second, simply
because a Traffic Study in 2010 includes a similar 5% mode adjustment does not substantiate the
inclusion of the reduction for the current Project. Third, the TIA fails to provide sufficient evidence that
the development of the "CC Streetcar" would specifically result in a 5% reduction in vehicle trips for the
proposed Project. As such, we cannot verify the 5% non -auto trip reduction, and the Addendum's
CaIEEMod model should have included 1,171 daily trips instead of 1,112 trips. By including an
unsubstantiated reduction to the Project's daily operational vehicle trips, the model underestimates the
Project's mobile -source operational emissions and should not be relied upon to determine Project
significance.
75C-82
Incorrect Application of Construction -Related Mitigation Measures
Review of the Project's CalEEMod output files demonstrates the model includes the following five (5)
construction -related mitigation measures: "Replace Ground Cover," "Water Exposed Area," "Water
Unpaved Roads," "Reduce Vehicle Speed on Unpaved Roads," and "Clean Paved Roads" (see excerpt
below) (Appendix B, pp. 86, 118, 239).
3.1 Mitigation Measures Construction
Replace Ground Cover
Water Exposed Area
Water Unpaved Roads
Reduce Vehicle Speed on Unpaved Roads
Clean Paved Roads
As a result, the model includes a 6% clean paved road reduction, 12% unpaved road moisture content,
and 15 miles per hour ("MPH") vehicle speed (see excerpt below) (Appendix B, pp. 80, 112, 232).
Table Nave I fd. Nave I DeiaWt Va.- I N,n VALe
t--------------- W-------------Mus------ -- h --
a___________
As previously mentioned, the CalEEMod User's Guide requires any changes to model defaults be
justified.13 According to the "User Entered Comments & Non -Default Data" table, the justification
provided for these changes is: "Per SCAQMD Rules and Regulations" (Appendix B, pp. 79, 111, 231).
Furthermore, in regard to the Project's construction emissions, the Addendum states:
"Emission data is pulled from 'mitigated' results, which include SCAQMD regulatory
requirements including Rule 403 and Rule 1113. SCAQMD Rule 403 Fugitive Dust applied. The
Rule 403 reduction/credits include the following: properly maintain mobile and other
construction equipment; replace ground cover in disturbed areas quickly; water exposed
surfaces three times daily; cover stockpiles with tarps; water all haul roads twice daily; and limit
speeds on unpaved roads to 15 miles per hour" (p. 3.2-4).
However, as the excerpt above demonstrates, while the Addendum indicates which mitigation measures
were included in the model, the Addendum does not explicitly require the Project to include onv of the
above -mentioned construction -related mitigation measures. Thus, the Addendum fails to demonstrate a
commitment to the implementation, monitoring, and enforcement of any construction -related
mitigation measures, and we cannot verify their inclusion in the model.
13 CalEEMod User Guide, available at: htto://www.caleemod.com/, p. 2, 9
e
75C-83
Furthermore, according to SCAQMD Rule 403, Projects can either water unpaved roads 3 times per day,
water unpaved roads 1 time per day and limit vehicle speeds to 15 mph, or apply a chemical stabilizer
(see excerpt below) (p. 403-21, Table 2). 14
Table 2 Woutintted)
FUGITIVE DUST
SOURCECATEGORY
CONTROL ACTIONS
Unpaved Roads
(48) Water all roads used for any vehicular tret£c at
least once per every two hours of active
operations [3 times per normal 8 hour work day];
OR
(4b) Water all roads used for any vehicular traffic
once daily and restrict vehicle speeds to 15 nules
per hour OR.
(4c) Apply a chemical stabilizer to all unpaved road
surfaces in sufficient quaoti[y and frequency to
maintain a stabilized surface.
As you can see in the above excerpt, to simply comply with SCAQM D Rule 403, the Project may either
water unpaved roads 3 times per day, water unpaved roads 1 time per day and limit vehicle speeds to
15 mph, or apply a chemical stabilizer. Thus, none of the measures included in the CaIEEMod model are
explicitly required by SCAQMD Rule 403, and we cannot verify their inclusion in the model. By including
construction -related mitigation measures without properly committing to their implementation, the
model may underestimate the Project's construction -related emissions and should not be relied upon to
determine Project significance.
IncorrectApplication of Operational Mitigation Measures
Review of the Project's CaIEEMod output files demonstrates that the model incorrectly includes several
mobile-, area-, and water -related operational mitigation measures. As a result, the Project's operational
emissions may be underestimated, and the model should not be relied upon to determine Project
significance.
First, the Project's CaIEEMod output files reveal that the model included the following two (2) mobile -
related operational mitigation measures: "Increase Density' and "Increase Diversity' (see excerpt
below) (Appendix B, pp. 102, 134, 255).
4.1 Mitigation Measures Mobile
Increase Density
Increase Diversity
Second, the Project's CaIEEMod output files reveal that the model included the "Use only Natural Gas
Hearths" area -related operational mitigation measure (see excerpt below) (Appendix B, pp. 106, 138
261).
14 "RULE 403. FUGITIVE DUST." SCAQMD, June 2005, available at: htto://www.agmd.gov/docs/default-source/rule-
b oo k/ r u l e-i v/ r u l e-403. o d f.
75C-84
6.1 Mitigation Measures Area
Use only Natural Gas Hearths
Third, the Project's CaIEEMod output files reveal that the model included the following five (5) water -
related operational mitigation measures: "Install Low Flow Bathroom Faucet," "Install Low Flow Kitchen
Faucet," "Install Low Flow Toilet," "Install Low Flow Shower," and "Use Water Efficient Irrigation System
(see excerpt below) (Appendix B, pp. 108, 140, 263).
7.1 Mitigation Measures Water
Install Low Flow Bathroom Faucet
Install Low Flow Kitchen Faucet
Install Low Flow Toilet
Install Low Flow Shower
Use Water Efficient Irrigation System
However, the inclusion of the above -mentioned energy-, mobile-, and water -related operational
mitigation measures is unsubstantiated according to the relevant guidance. According to the CaIEEMod
User's Guide:
"The mitigation measures included in CaIEEMod are largely based on the CAPCOA Quantifying
Greenhouse Gas Mitigation Measures (http://www.capcoa.org/wp-
conte nt/uploads/down loads/2010/09/CAPCOA-Qua ntificatio n- Repo rt-9-14-Fina I. pdf)
document. The CAPCOA measure numbers are provided next to the mitigation measures in
CaIEEMod to assist the user in understanding each measure by referencing back to the CAPCOA
document."15
However, review of CAPCOA's Quantifying Greenhouse Gas Mitigation Measures document
demonstrates that the Addendum fails to substantiate several of the mitigation measures included in
the model (see table below).
is "CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.caleemod.com/, p. 53.
16 "Quantifying Greenhouse Gas Mitigation Measures." CAPCOA, August 2010, available at:
http://www.ca ijcoa.org/wp-content/up loads/2010/11/CAPCOA-Qua nt ificati on-Report-9-14-Fi na I. pdf.
10
75C-85
Measure LUT-1 Increase Density
'The reductions in GHG emissions are quantified
based on reductions to VMT. The relationship
between density and VMT is described by its
elasticity."
VMT Reduction = A * B, where:
A = % increase in housing units orjobs/acre
B = Elasticity of VMT with respect to density
The following information needs to be provided by
the Project Applicant:
• Number of housing units per acre or jobs
per job acre
Measure LUT-3 Increase Diversity
"Having different types of land uses near one
As previously mentioned, the CalEEMod User's
Guide requires any changes to model defaults
be justified. Here, however, the "User Entered
Comments & Non -Default Data" table fails to
mention or substantiate the inclusion of this
measure whatsoever (Appendix B, pp. 79, 111,
231). While the Greenhouse Gas ("GHG")
Emissions Assessment, provided by Appendix D
to the Addendum, states that the Project
"would result in 169 dwelling units per acre
over the 2.715-acre site," the Addendum and
associated documents completely fail to
mention or evaluate the increased density
"based on reductions to VMT." as stated in the
measure (Appendix D, pp. 217). The Addendum
and associated documents also fail to mention
the % increase in housing units or jobs/acre or
the elasticity of VMT with respect to density, as
stated in the measure. Finally, the Addendum
and associated documents fail to provide any
calculations or assumptions used to include this
measure in the model. As such, this measure is
unsubstantiated, and the model should not be
relied upon to determine Project significance.
As previously mentioned, the CalEEMod User's
Guide requires any changes to model defaults
be justified. Here, however, the "User Entered
another can decrease VMTsince trips between land I Comments & Non -Default Data" table fails to
use types are shorter and may be accommodated
by non -auto modes of transport."
The following information needs to be provided by
the Project Applicant:
• Percentage of each land use type in the
project (to calculate land use index)
11
mention or substantiate the inclusion of this
measure whatsoever (Appendix B, pp. 79, 111,
231). In regard to Measure LUT-3, the GHG
Emissions Assessment states: "The measure
requires at least three different land uses
within 0.25 mile. The Project proposes
residential, retail, and restaurant uses, and
there are also residential, retail, and office land
uses within this distance from the Project"
(Appendix D, pp. 217). However, the
Addendum and associated documents fail to
provide the percentage of each land use type in
75C-86
the project to calculate the land use index, as
stated in the measure. As such, this measure is
unsubstantiated, and the model should not be
relied upon to determine Project significance.
Water Measures
Measure WUW-1 Install Low -Flow Water Fixtures
As previously mentioned, the CalEEMod User's
Guide requires any changes to model defaults
"Installing low flow or high -efficiency water fixtures
be justified. Here, however, the "User Entered
in buildings reduces water demand, energy
Comments & Non -Default Data" table fails to
demand, and associated indirect GHG emissions."
mention or substantiate the inclusion of this
The following information needs to be provided by
measure whatsoever (Appendix B. pp. 79, 111,
the Project Applicant:
231). While the Addendum states that the
• Total expected indoor water demand,
proposed Project's water demand is 29.6 acre -
without installation of low -flow or high-
feet per year ("AFY"), the Addendum fails to
efficiency fixtures (million gallons), AND
specify whether this total expected water
• Total expected indoor water demand, after
demand is after the installation of low -flow or
installation of low -flow or high -efficiency
high -efficiency fixtures. Thus, the Addendum
fixtures (million gallons), OR
and associated documents fail to provide the
• Commitment to low -flow or high -efficiency
total expected indoor water demand, without
water fixtures (toilets, showerheads, sink
installation of low -flow or high -efficiency
faucets, dishwashers, clothes washers, or
fixtures, and total expected indoor water
all of the above)
demand, after installation of low -flow or high -
efficiency fixtures, or a commitment to low -
flow or high -efficiency water fixtures, as is
required in the measure. Furthermore, the
Addendum states that "[t)he project would
utilize energy -efficient LED lighting, a drought
tolerant plant palette, and low -flow water
fixtures to increase building sustainability" (p.
3.5-3). However, the Addendum only states this
to demonstrate consistency with the City's
Climate Action Plan ("CAP"). Thus, the Project
fails to include low -flow water fixtures as a
product design feature or mitigation measure,
and the Addendum fails to demonstrate that
the Project actually intends to install low -flow
water fixtures at the Project site. As such, this
measure is unsubstantiated, and the model
12
75C-87
Measure WUW-4 Use Water -Efficient Landscape
Irrigation Systems
"Using water -efficient landscape irrigation
techniques such as "smart" irrigation technology
reduces outdoor water demand, energy demand,
and the associated GHG emissions."
The following information needs to be provided by
the Project Applicant:
• Total expected outdoor water demand,
without installation of smart landscape
irrigation controller (million gallons).
• (Optional) Project -specific percent
reduction in outdoor water demand, after
installation of smart landscape irrigation
controller. Percent reduction must be
verifiable. Otherwise, use the default value
of 6.1%.
should not be relied upon to determine Project
significance.
As previously mentioned, the CalEEMod User's
Guide requires any changes to model defaults
be justified. Here, however, the "User Entered
Comments & Non -Default Data" table fails to
mention or substantiate the inclusion of this
measure whatsoever (Appendix B, pp. 79, 111,
231). Furthermore, the Addendum states that
"water -efficient irrigation systems would be
used" (p. 3.5-4). However, the Addendum only
states this to demonstrate consistency with
CARB's 2017 Scoping Plan. Thus, the Project
fails to include water -efficient landscape
irrigation systems as a product design feature
or mitigation measure, and the Addendum fails
to demonstrate that the Project actually
intends to implement water -efficient landscape
irrigation techniques at the Project site.
Furthermore, the Addendum and associated
documents fail to provide the total expected
outdoor water demand, without installation of
smart landscape irrigation controller and/or the
Project -specific percent reduction in outdoor
water demand, after installation of smart
landscape irrigation controller, as required in
the measure. As such, this measure is
unsubstantiated, and the model should not be
relied upon to determine Project significance.
As shown above, the Addendum fails to justify several of the mitigation measures utilized in the
Project's CalEEMod model according to the relevant guidance. As a result, the inclusion of these
measures in the model is unsubstantiated and the model should not be relied upon to determine the
significance of GHG impacts from the Project.
Diesel Particulate Matter Health Risk Emissions Inadequately Evaluated
The Addendum concludes that the Project's health risk impacts would be less than significant without
conducting a quantified construction or operational health risk assessment ("HRA") (p. 6). Specifically,
regarding the health risk impacts associated with Project construction, the Addendum states:
13
75C-88
"California Office of Environmental Health Hazard Assessment has not identified short-term
health effects from DPM. Construction activities would be temporary and transient throughout
the site (i.e., move from location to location), and would not generate emissions in a fixed
location for extended periods of time. Construction activities would also be subject to and
would comply with California regulations limiting the idling of heavy-duty construction
equipment to no more than five minutes to further reduce nearby sensitive receptors' exposure
to temporary and variable DPM emissions. As such, project construction DPM impacts to
sensitive receptors would be less than significant and would not result in a substantial increase
in the severity of DMP impacts beyond those analyzed in the 2010 FEIR" (p. 3.2-7).
However, the Addendum's evaluation of the Project's health risk impacts, as well as the subsequent less
than significant impact conclusion, is incorrect for four (4) reasons.
First, the Addendum's claims that the health risk impacts associated with Project construction would be
less than significant because Project construction "would be temporary and transient," "would not
generate emissions in a fixed location for extended periods of time," and "would also be subject to and
would comply with California regulations limiting the idling of heavy-duty construction equipment" are
unsupported. As the Addendum fails to provide substantial evidence, including sources or calculations,
to substantiate these claims, we are unable to verify that they are correct. Without providing a
quantified construction HRA, the Addendum lacks substantial evidence to demonstrate that health risk
impacts associated with Project construction would be less than significant.
Second, by failing to prepare a construction HRA, the Project is inconsistent with the most recent
guidance published by the Office of Environmental Health Hazard Assessment ("OEHHA"), the
organization responsible for providing guidance on conducting HRAs in California. OEHHA released its
most recent Risk Assessment Guidelines: Guidance Manual for Preparation of Health Risk Assessments in
February 2015Y This guidance document describes the types of projects that warrant the preparation
of an HRA. Construction of the Project will produce emissions of diesel particulate matter ("DPM"), a
human carcinogen, through the exhaust stacks of construction equipment over a construction period of
approximately 21- to 24-months (p. 2-11). The OEHHA document recommends that all short-term
projects lasting at least two months be evaluated for cancer risks to nearby sensitive receptors." As the
Project's proposed 21- to 24-month construction duration vastly exceeds the 2-month requirement set
forth by OEHHA, it is clear that the Project meets the threshold requiring a quantified HRA under OEHHA
guidance (p. 2-11). Thus, we recommend that health risk impacts from Project construction be
evaluated in an EIR, per OEHHA guidelines, in order to determine the nature and extent of the Project's
health risk impacts.
Third, the Addendum fails to mention or evaluate the potential health risk impacts associated with
Project operation whatsoever. As previously stated, the TIA indicates that Project operation would
17 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
2015, available at: htti)://oehha.ca.aov/air/hot spots/hotspots2015.html
18 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
2015, available at: htti)://oehha.ca.aov/air/hot spots/2015/2015GuidanceManual.pdf. p. 8-18
14
75C-89
generate 1,112 daily vehicle trips, or 1,171 daily vehicle trips without the non -auto trip adjustment,
which will generate additional exhaust emissions and continue to expose nearby sensitive receptors to
DPM emissions (Appendix F, p. 10, Table 5-1). Furthermore, the omission of a quantified operational
HRA is inconsistent with the most recent guidance published by the Office of Environmental Health
Hazard Assessment ("OEHHA"). The OEHHA document recommends that exposure from projects lasting
more than 6 months be evaluated for the duration of the project, and recommends that an exposure
duration of 30 years be used to estimate individual cancer risk for the maximally exposed individual
resident ("MEIR").'9 Even though we were not provided with the expected lifetime of the Project, we
can reasonably assume that the Project will operate for at least 30 years, if not more. Therefore, we
recommend that health risk impacts from Project operation also be evaluated, as a 30-year exposure
duration vastly exceeds the 6-month requirement set forth by OEHHA. These recommendations reflect
the most recent state health risk policies, and as such, we recommend that an updated assessment of
health risk impacts posed to nearby sensitive receptors from Project operation be included in an EIR for
the Project.
Fourth, by claiming a less than significant impact without conducting a quantified HRA to disclose the
exposure levels to nearby, existing sensitive receptors as a result of Project construction and operation,
the Addendum fails to compare the excess health risk to the SCAQMD's specific numeric threshold of 10
in one million.20 Thus, the Addendum cannot conclude less than significant health risk impacts resulting
from Project construction and operation without quantifying emissions to compare to the proper
threshold.
Screening -Level Analysis Demonstrates Significant Impacts
In an effort to accurately estimate the emissions associated with the Project, we prepared an updated
CaIEEMod model, using the Project -specific information provided by the Addendum. In our updated
model, we corrected the CO2 intensity factor, residential land use size, and operational vehicle trip rates;
proportionally revised the construction phase lengths to achieve an overall construction period of 21
months; and omitted the unsubstantiated construction -related and operational mitigation measures.
Utilizing our updated model, and in an effort to demonstrate the potential health risk posed by Project
construction and operation to nearby, existing sensitive receptors utilizing a site -specific emissions
estimates, we prepared a simple screening -level HRA. The results of our assessment as described below,
demonstrate that the proposed Project may result in a significant impact not previously identified or
addressed in the Addendum.
In order to conduct our screening -level risk assessment we relied upon AERSCREEN, which is a screening
level air quality dispersion model." The model replaced SCREEN3, and AERSCREEN is included in the
19 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
2015, available at: http://oehha.ca.gov/air/hot spots/2015/2015GuidanceManual.pdf, p. 8-6, 8-15
21 "South Coast AQMD Air Quality Significance Thresholds." SCAQMD, April 2019, available at:
htti)://www.a a m d.gov/d ocs/defa ul t-source/cea a/hand book/scan and -a i r-a ua I ity-si gni fi ca nce-threshold s. pd f.
21 U.S. EPA (April 2011) AERSCREEN Released as the EPA Recommended Screening Model,
http://www.epa.gov/ttn/scram/guidance/clarification/20110411 AERSCREEN Release Memo.pdf
15
75C-90
OEHHA22 and the California Air Pollution Control Officers Associated ("CAPCOA" )` guidance as the
appropriate air dispersion model for Level 2 health risk screening assessments ("HRSAs"). A Level 2 HRSA
utilizes a limited amount of site -specific information to generate maximum reasonable downwind
concentrations of air contaminants to which nearby sensitive receptors may be exposed. If an
unacceptable air quality hazard is determined to be possible using AERSCREEN, a more refined modeling
approach is required prior to approval of the Project.
We prepared a preliminary HRA of the Project's construction and operational health -related impact to
residential sensitive receptors using the annual PM10 exhaust estimates from the SWAPE CalEEMod
output files. Consistent with recommendations set forth by OEHHA, we assumed residential exposure
begins during the third trimester stage of life. SWAPE's CalEEMod model indicates that construction
activities will generate approximately 188 pounds of DPM over the 636-day construction period. The
AERSCREEN model relies on a continuous average emission rate to simulate maximum downward
concentrations from point, area, and volume emission sources. To account for the variability in
equipment usage and truck trips over Project construction, we calculated an average DPM emission rate
by the following equation:
grams 188.4 lbs 453.6 grams 1 day 1 hour
Emission Rate = x x x = 0.001556 g/s
second 636 days lbs 24 hours 3,600 seconds
Using this equation, we estimated a construction emission rate of 0.001556 grams per second ("g/s").
Subtracting the 636-day construction period from the total residential duration of 30 years, we assumed
that after Project construction, the sensitive receptor would be exposed to the Project's operational
DPM for an additional 28.26 years, approximately. The Project's operational CalEEMod emissions
indicate that operational activities will generate approximately 64 pounds of DPM per year throughout
operation. Applying the same equation used to estimate the construction DPM rate, we estimated the
following emission rate for Project operation:
grams 64.4 lbs 453.6 grams 1 day 1 hour
Emission Rate (second) 365 days X lbs X 24 hours X 3,600 seconds — 0.000926 g/s
Using this equation, we estimated an operational emission rate of 0.000926 g/s. Construction and
operational activity was simulated as a 2.72-acre rectangular area source in AERSCREEN with dimensions
of 157 by 70 meters. A release height of three meters was selected to represent the height of exhaust
stacks on operational equipment and other heavy-duty vehicles, and an initial vertical dimension of one
and a half meters was used to simulate instantaneous plume dispersion upon release. An urban
meteorological setting was selected with model -default inputs for wind speed and direction distribution.
The AERSCREEN model generates maximum reasonable estimates of single -hour DPM concentrations
from the Project site. EPA guidance suggests that in screening procedures, the annualized average
22 "Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
2015, available at: htti)://oehha.ca.aov/air/hot spots/2015/2015GuidanceManual.pdf
23 CAPCOA (July 2009) Health Risk Assessments for Proposed Land Use Projects, htti)://www.cal)coa.ora/wp-
content/uploads/2012/03/CAPCOA HRA LU Guidelines 8-6-09.pdf.
16
75C-91
concentration of an air pollutant be estimated by multiplying the single -hour concentration by 10%.24
According to the Addendum, the nearest sensitive receptors are located approximately 55 feet, or 17
meters, from the Project boundary (p. 3.2-6). However, review of the AERSCREEN output files
demonstrates that the MEIR is located approximately 75 meters from the Project site. Thus, the single -
hour concentration estimated by AERSCREEN for Project construction is approximately 3.914 µg/m3
DPM at approximately 75 meters downwind. Multiplying this single -hour concentration by 10%, we get
an annualized average concentration of 0.3914 µg/m3 for Project construction at the MEIR. For Project
operation, the single -hour concentration estimated by AERSCREEN is 2.332 µg/m3 DPM at approximately
75 meters downwind. Multiplying this single -hour concentration by 10%, we get an annualized average
concentration of 0.2332 µg/m3 for Project operation at the MEIR.
We calculated the excess cancer risk to the MEIR using applicable HRA methodologies prescribed by
OEHHA. Consistent with the Addendum's proposed 21- to 24-month construction schedule, the
annualized average concentration for Project construction was used for the entire third trimester of
pregnancy (0.25 years) and the first 1.49 years of the infantile stage of life (0 — 2 years) (p. 2-11). The
annualized averaged concentration for operation was used for the remainder of the 30-year exposure
period, which makes up the remaining 0.51 years of the infantile stage of life, the entire child stage of
life (2 —16 years), and the entire the adult stage of life (16 — 30 years).
Consistent with OEHHA, as recommended by the SCAQMD, BAAQMD, and SJVAPCD guidance, we used
Age Sensitivity Factors ("ASF") to account for the heightened susceptibility of young children to the
carcinogenic toxicity of air pollution.",z6," According to this guidance, the quantified cancer risk should
be multiplied by a factor of ten during the third trimester of pregnancy and during the first two years of
life (infant) as well as multiplied by a factor of three during the child stage of life (2 —16 years). We also
included the quantified cancer risk without adjusting for the heightened susceptibility of young children
to the carcinogenic toxicity of air pollution in accordance with older OEHHA guidance from 2003. This
guidance utilizes a less health protective scenario than what is currently recommended by SCAQMD, the
air quality district with jurisdiction over the City, and several other air districts in the state. Furthermore,
in accordance with the guidance set forth by OEHHA, we used the 95`h percentile breathing rates for
""Screening Procedures for Estimating the Air Quality Impact of Stationary Sources Revised." EPA, 1992, available
at: htti)://www.ei)a.gov/ttn/scram/guidance/guide/EPA-454R-92-019 OCR.pdf; see also "Risk Assessment
Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February 2015, available at:
htti)s://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.1)df p. 4-36.
25 "Draft Environmental Impact Report (DEIR) for the Proposed The Exchange (SCH No. 2018071058)." SCAQMD,
March 2019, available at: http://www.agmd.gov/docs/default-source/cega/comment-
letters/2019/march/RVC190115-03.pdf?sfvrsn=8, p. 4.
26 "California Environmental Quality Act Air Quality Guidelines." BAAQMD, May 2017, available at:
http://www.baagmd.gov/—/media/files/planning-and-research/cega/cega guidelines may2017-pdf.pdf?la=en, p.
56; see also "Recommended Methods for Screening and Modeling Local Risks and Hazards." BAAQMD, May 2011,
available at:
http://www. baag md.gov/—/media /Files/Planning%20a nd%2OResea rch/CEQA/BAAQMD%20M ode I i ng%2OApp roa c
h.ashx, p. 65, 86.
27 "Update to District's Risk Management Policy to Address OEHHA's Revised Risk Assessment Guidance
Document." SIVAPCD, May 2015, available at: https://www.vallevair.org/busind/pto/staff-report-5-28-15.pdf, p. 8,
20, 24.
17
75C-92
infants.28 Finally, according to SCAQMD guidance, we used a Fraction of Time At Home ("FAH") Value of
1 for the 3rd trimester and infant receptors.29 We used a cancer potency factor of 1.1 (mg/kg-day)-' and
an averaging time of 25,550 days. The results of our calculations are shown below.
The Maximum Exposed Individual at an Existing Residential Receptor (MEIR)
Cancer
Duration
Concentration
Breathing
Cancer Risk
Activity
ASF
Risk with
(years)
(ug/m3)
Rate (L/kg-day)
without ASFs*
ASFs*
Construction
0.25
0.3914
361
5.3E-07
10
5.3E-06
3rd Trimester
3rd Trimester
0.25
5.3E-07
5.3E-06
Duration
Exposure
Construction
1.49
0.3914
1090
9.6E-06
10
9.6E-05
Operation
0.51
0.2332
1090
1.9E-06
10
1.9E-05
Infant Exposure
Infant
2.00
1.2E-05
1.2E-04
Duration
Exposure
Operation
14.00
0.2332
572
2.8E-05
3
8.4E-05
Child Exposure
Child
14.00
2.8E-05
8.4E-05
Duration
Exposure
Operation
14.00
0.2332
261
9.4E-06
1
9.4E-06
Adult Exposure
Adult14.00
9.4E-06
9.4E-06
Duration
Exposure
Lifetime Exposure
Lifetime
30.00
5.0E-05
2.1E-04
Duration
Exposure
*We, along with CARB and SCAQMD, recommend using the more updated and health protective 2015 OEHHA guidance, which includes ASFs.
As demonstrated in the table above, the excess cancer risk to adults, children, infants, and during the 3rd
trimester of pregnancy at the MEIR located approximately 75 meters away, over the course of Project
construction and operation, utilizing age sensitivity factors, are approximately 9.4, 84, 120, and 5.3 in
one million, respectively. The excess cancer risk over the course of a residential lifetime (30 years),
utilizing age sensitivity factors, is approximately 210 in one million. The infant, child, and lifetime cancer
risks all exceed the SCAQMD threshold of 10 in one million, thus resulting in a potentially significant
impact not previously addressed or identified by the Addendum. Utilizing age sensitivity factors is the
most conservative, health -protective analysis according to the most recent guidance by OEHHA and
reflects recommendations from the air district. Results without age sensitivity factors are presented in
2s "Supplemental Guidelines for Preparing Risk Assessments for the Air Toxics'Hot Spots' Information and
Assessment Act," July 2018, available at: http://www.agmd.gov/docs/default-source/planning/risk-
assessment/ab2588supplementalauidelines.pdf, p. 16.
"Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
2015, available at: httl)s://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.1)df
21 "Risk Assessment Procedures for Rules 1401, 1401.1, and 212." SCAQMD, August 2017, available at:
http://www.ag m d.aov/d ocs/default-sou rce/ru le-book/Proposed-
Rules/1401/riskassessmentprocedures 2017 080717.pdf, p. 7.
18
75C-93
the table above, although we do not recommend utilizing these values for health risk analysis.
Regardless, the excess cancer risk to adults, children, infants, and during the 3'd trimester of pregnancy
at the MEIR located approximately 75 meters away, over the course of Project construction and
operation, without age sensitivity factors, are approximately 9.4, 28, 12, and 0.53 in one million,
respectively. The excess cancer risk over the course of a residential lifetime (30 years), without age
sensitivity factors, is approximately 50 in one million. The infant, child, and lifetime cancer risks, without
age sensitivity factors, all exceed the SCAQMD threshold of 10 in one million, thus resulting in a
potentially significant impact not previously addressed or identified by the Addendum. While we
recommend the use of age sensitivity factors, health risk impacts exceed the SCAQMD threshold
regardless.
An agency must include an analysis of health risks that connects the Project's air emissions with the
health risk posed by those emissions. Our analysis represents a screening -level HRA, which is known to
be conservative and tends to err on the side of health protection. 30 The purpose of the screening -level
construction and operational HRA shown above is to demonstrate the link between the proposed
Project's emissions and the potential health risk. Our screening -level HRA demonstrates that
construction and operation of the Project could result in a potentially significant health risk impact,
when correct exposure assumptions and up-to-date, applicable guidance are used. Therefore, since our
screening -level HRA indicates a potentially significant impact, the City should prepare a Project -specific
EIR with an HRA which makes a reasonable effort to connect the Project's air quality emissions and the
potential health risks posed to nearby receptors. Thus, the City should prepare an updated, quantified
air pollution model as well as an updated, quantified refined health risk assessment which adequately
and accurately evaluates health risk impacts associated with both Project construction and operation.
Greenhouse Gas
Failure to Adequately Evaluate Greenhouse Gas Impacts
The Addendum estimates that the Project would generate net annual GHG emissions of 1,493 metric
tons of CO2 equivalents per year ("MT CO2e/year') (p. 3.5-2, Table 3.5-1). As a result, the Addendum
concludes that the Project would result in a service population efficiency value of 2.0 metric tons of CO2
equivalents per service population per year ("MT CO2e/SP/year"), based on a service population value of
747 people (see excerpt below) (p. 3.5-2, Table 3.5-1).
""Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments." OEHHA, February
2015, available at: https://oehha.ca.aov/media/downloads/crnr/2015auidancemanual.pdf, p. 1-5
19
75C-94
Table 3.5-1 Conshucfion and
GHG Emissions
CORiructlon Emissions Amortned over 30 Years 29,
operabomaEmisgons
Area
36
Energy
597
Waste
33
Water
29
Mobile
733
Total Project Emissions
Project 5e Moe Population (Residents andEmployees)
U
Total Project Emissions per service population
IMTC%e per service papulatlmn per year)
2AID FEIR Emissions
99,AU
201D FEIR service Population
11,794
Total 2010 FEIR Emissions per service population
93
[MTCoye perservice population per year)
However, the Addendum fails to compare the Project's emissions to the relevant SCAQMD quantitative
GHG threshold, instead relying upon the City of Santa Ana's 2010 Programmatic Final EIR ("FEIR"),
stating:
"[T]he project would not result in any new or substantially more severe GHG emissions impacts
than what was analyzed in the 2010 FEIR and project GHG emissions would not be significant"
(p. 3.5-2).
Finally, the Addendum relies upon the Project's consistency with the City of Santa Ana's Climate Action
Plan ("CAP") and CARB's 2017 Scoping Plan in order to conclude that the Project would result in a less
than significant GHG impact (p. 3.5-3 - 3.5-4). However, the Addendum's quantitative and qualitative
GHG analyses, as well as the subsequent less than significant impact conclusion, are incorrect for seven
(7) reasons.
(1) The Addendum's quantitative GHG analysis relies upon an incorrect and unsubstantiated air
model;
(2) The Addendum's quantitative GHG analysis relies upon an overestimated service population;
(3) The Addendum fails to apply the relevant SCAQMD quantitative GHG threshold;
(4) The Addendum fails to identify a potentially significant GHG impact;
(5) The Addendum incorrectly relies upon the City's CAP;
(6) The Addendum fails to demonstrate that the Project would be consistent with CARB's Scoping
Plan; and
(7) SWAPE's updated analysis indicates a potentially significant GHG impact.
20
75C-95
(1) Incorrect and Unsubstantiated Quantitative GHG Analysis
As discussed above, the Addendum estimates that the Project would generate net annual GHG
emissions of 1,493 MT CO2e/year, resulting in a service population efficiency of 2.0 MT CO2e/SP/year (p.
3.5-2, Table 3.5-1). However, the Addendum's quantitative GHG analysis should not be relied upon, as it
relies upon an unsubstantiated air model. As previously discussed, when we reviewed the Project's
CaIEEMod output files, provided in the Air Quality Assessment as Appendix B to the Addendum, we
found that several of the values inputted into the model are not consistent with information disclosed in
the Addendum and associated documents. As a result, the model underestimates the Project's GHG
emissions, and the Addendum's quantitative GHG analysis should not be relied upon to determine
Project significance. An EIR should be prepared that adequately assesses the potential GHG impacts that
construction and operation of the proposed Project may have on the surrounding environment.
(2) Reliance Upon an Overestimated Service Population
As discussed above, the Addendum concludes that the Project would result in a service population
efficiency value of 2.0 MT CO2e/SP/year, based on a service population value of 747 people (p. 3.5-2,
Table 3.5-1). However, the Addendum's quantitative GHG analysis is unsubstantiated, as it relies upon
an unsupported service population of 747 people. According to CAPCOA's CEQA & Climate Change
report, service population is defined as "the sum of the number of residents and the number of jobs
supported by the project."31 The Addendum indicates that the proposed Project would provide housng
for up to 507 residents, "[u]sing the household size ratio from the 2010 FOR of 3.0 persons per
household" (p. 3.9-5). However, this household size ratio should not be relied upon as it is from
approximately 10 years ago and fails to take into account the type of housing development or number
of units per structure. Rather, the more recent 2020 Draft Program Environmental Impact Report
("DPEIR") for the City of Santa Ana General Plan Update reveals that this value is incorrect. Rather, the
DPEIR indicates that structures including over 50 units would have household size ratios of 2.77- and
2.45-persons per household 2018 and 2045, respectively (see excerpt below).32
Table 4: Persons per Household Assumptions
Units in Structure
2000
2010
2011
2D12
2D13
2D14
2015
2016
2017
2018
2045
Citywide
4.37
4.30
4.26
4.41
4.14
3.97
4.33
4.20
4.11
3.97
3.62
Single family'
5.09
4.92
4.98
4.94
4.84
4.81
5-OD
4.95
4.73
4.693
4.30^
Mugs-famil2
4.07
4.01
3.86
4.15
3.82
3.51
4.01
3.66
3.74
3.583
3.124
2 to 4
440
484
409
477
390
356
449
4.37
4.01
403
343
5 tc 19
393
378
375
431
369
355
401
3.85
3.53
399
3 60
20 to 49
467
420
435
449
431
381
4.1 D
420
3.92
50 or more
3.71
3.58
3.67
3.55
3.71
3.19
3A3
3.18
3.74
2.77
2.41
" CAPCOA (Jan. 2008) CEQA & Climate Change, p. 71-72, http://www.capcoa.org/wp-
conte nt/up load s/2012/03/CAPCOA-W h ite-Pa per. pd f.
32 "Santa Ana General Plan Update Draft Program Environmental Impact Report." August 2020, available at:
htti)s://www.sa nta-a na.ora/sites/d efa u It/files/D b/ae ne ra (-
plan/documents/Draft%20EIR/Complete%20Draft%20PEIR.i)df, p. B-b-11, Table 4.
21
75C-96
Thus, the Addendum should have relied upon a household size ratio of 2.45-persons per household, in
order to maintain consistency with the City's General Plan and conduct the most conservative analysis.
As such, the Addendum should have estimated a residential service population value of 407 people.33
Furthermore, the Addendum fails to disclose any calculations used to estimate the number of jobs
supported by the Project. However, the DPEIR indicates that commercial land uses generate
approximately 1 employee per 500-SF of building space (see excerpt below).34
Table 3: Employment Factors
Em fie merit Generation Factors
Land Use
Existing Factor
Buildout Factor
Commercial
500 sq_ fl_ Imp
500 s _ fl_ I em
Office I Office Park
286 s _ It Imp
364 s _ ft I ern
Business Park! R80
300
s .fit. I em p.
333 sq. It I em
Light Industrial
400
s _ fl_ Imp _
500 s _ fit Imp
Heavy Industrial.
500s _fl_Imp _
KID s _ft Imp
Warehouse
300 s . ft.1 em .
800 s . B. I em
Medical
400 sIt Imp _
222 sft Imp
Govemment Office
286 sq. ff. l emp.
286 sq. it I emp.
Hospital
400 s . R.1 em .
364 s . ft I em
Religious Institution
800 sq It Imp _
aw s _ ft I ern
Hotel I Motel
0.91 room
0.91 roan
School
0.11 student
011 student
Park
0. 751 acre
0 751 acre
As such, we estimate that the Project would create approximately 23 new employees.35 Thus, we
estimate that the Project's total service population would be approximately 430 people.36 As a result,
the Addendum's service population is overestimated, and the subsequent quantitative GHG analysis
should not be relied upon.
(3) Failure to Apply the Relevant SCAQMD Threshold
As discussed above, the Addendum estimates that the Project would generate net annual GHG
emissions of 1,493 MT COze/year, resulting in a service population efficiency value of 2.0 MT
COze/SP/year (p. 3.5-2, Table 3.5-1). However, while the Addendum quantifies the Project's GHG
emissions, the Addendum fails to mention or compare the Project's annual GHG emissions to the
applicable SCAQMD thresholds. This is incorrect, as the SCAQMD provides GHG thresholds that can be
used to determine a project's significance.
In September 2016, Governor Brown signed Senate Bill 32, enacting HEALTH & SAFETY CODE § 38566.37
This statute ("SB 32") requires California to achieve a new, more aggressive 40% reduction in GHG
33 Calculated: 169 units * 2.41 persons per household = 407 residents.
34 "Santa Ana General Plan Update Draft Program Environmental Impact Report." August 2020, available at:
https://www.sa nta-a na.ora/sites/d efa u It/files/p b/ae ne ra (-
plan/documents/Draft%20EIR/Complete%2ODraft%20PEIR.pdf, p. 3-b-11, Table 3.
" Calculated: (3,850-SF of "High Turnover (Sit Down Restaurant)" + 7,510-SF of "Strip Mall") / (500 SF/Employee) _
23 employees.
36 Calculated: 23 employees + 407 residents = 430 people.
37 HEALTH & SAFETY CODE 38566, available at:
htti)s://Ieginfo.legislature.ca.gov/faces/codes displav5ection.xhtml?lawCode=HSC§ionNum=38566.
22
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emissions over the 1990level by the end of 2030. As a result, the Project should comply with SB 32,
which requires a more aggressive GHG threshold. Thus, we recommend that the Project rely upon the
SCAQMD efficiency threshold of 3.0 MT CO,e/year for the year 2035, which was calculated based on a
40% reduction from the 2020 GHG efficient target.38 By failing to compare the Project's estimated GHG
emissions to the SCAQMD GHG threshold, the Addendum leaves a gap in its quantitative GHG analysis.
(4) Failure to Identify a Potentially Significant GHG Impact
The Addendum's incorrect and unsubstantiated air model indicates a potentially significant GHG impact,
when applying the relevant SCAQMD efficiency threshold of 3.0 MT CO,e/year for the year 2035.39
Specifically, the Addendum estimates that the Project would generate net annual GHG emissions of
1,493 MT CO2e/year (p. 3.5-2, Table 3.5-1). Furthermore, as described above, we estimate that the
Project's service population would be 430 people. Dividing the Project's GHG emissions, as estimated by
the Addendum, by a service population value of 430 people, we find that the Project would emit
approximately 3.47 MT CO2e/SP/year (see table below).41
Addendum Service Population Efficiency
Project Phase Proposed Project
(MT CO2e/year)
Total
1493.00
Service Population
430
Service Population Efficiency
3.47
Threshold
Exceed?
3.0
Yes
When we compare the Project's per service population GHG emissions to the SCAQMD 2035 efficiency
target of 3.0 MT CO2e/SP/year, we find that the Project would result in a significant GHG impact not
previously identified or addressed by the Addendum. According to CEQA Guidelines § 15064.4(b), if
there is substantial evidence that the possible effects of a particular project are still cumulatively
considerable notwithstanding compliance with the adopted regulations or requirements, a full CEQA
analysis must be prepared for the project. Therefore, a Project -specific EIR should be prepared and
recirculated for the Project, and mitigation should be implemented where necessary, per CEQA
Guidelines.
(S) Incorrect Reliance on the City's CAP
As previously mentioned, the Addendum relies upon the Project's consistency with the City's CAP in
order to conclude that the Project would result in a less than significant GHG impact (p. 3.5-3 - 3.5-3).
""Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15." SCAQMD, September
2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(ghg)-cega-
significance-thresholds/year-2008-2009/ghg-meeting-15/ghg-meeting-15-minutes.pdf, p. 2.
39 "Minutes for the GHG CEQA Significance Threshold Stakeholder Working Group #15." SCAQMD, September
2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(ghg)-cega-
significance-thresholds/year-2008-2009/aha-meeting-15/aha-meeting-15-minutes.adf, p. 2.
40 Calculated: (1,493 MT CO2e/year) / (430 service population) = (3.47 MT CO2e/SP/year).
23
75C-98
However, review of the City's CAP demonstrates that the CAP is designed to help the City achieve it's
2020 GHG reduction goal and needs to be updated in order to meet the City's 2035 GHG reduction
goal.41 Specifically, the CAP states:
"The measures in this CAP are projected to accomplish the goal of a 15% reduction in
community -wide emissions bv2020, and to nearly reach the 30% reduction by 2035 goal, as
shown in Figure 3.1. It is anticipated that new policy and technology options for reducing
emissions may become available before 2035; the CAP will need to be updated and additional
measures mayneed to be added to meet the 2035 goal. The CAP measures affecting municipal
operations are projected to accomplish both the 30% reduction by 2020 goal and the 40%
reduction by 2035 goal" (emphasis added).41
As such, the City of Santa Ana's CAP is only applicable to projects that will be fullyoperational bv2020,
as the CAP should be updated to meet the City's 2035 GHG reduction goal. Given that it is already
October 2020 and the Project has yet to be approved, we know that the Project will not become
operational by 2020. Thus, the City's CAP is inapplicable to the proposed Project, and the Addendum's
reliance upon the City's CAP is incorrect. As a result, the Addendum's less than significant impact
conclusion regarding the City's CAP should not be relied upon.
(6) Failure to Demonstrate Consistency with CARB's 2017Scoping Plan
As discussed above, the Addendum relies upon the Project's consistency with the CARB's 2017 Scoping
Plan in order to conclude that the Project would result in a less than significant GHG impact (p. 3.5-3 -
3.5-4). However, review of CARB's 2017 Scoping Plan reveals that the proposed Project is inconsistent
with numerous measures, including but not limited to the analysis below:
Measures — Construction
Require construction vehicles to operate with the Here, the Addendum states that "[a]pplicable
highest tier engines commercially available construction mitigation measures include all diesel
fuel construction equipment classified U.S.
Environmental Protection Agency (U.S. EPA) Tier II
or better" (p. 3.5-1). However, Tier 4 Final engines
are the highest tier commercially available. As
such, the Project fails to require construction
vehicles to operate with the highest tier engines
commercially available, as the measure requires.
Furthermore, the Addendum fails to evaluate the
41 "Santa Ana Climate Action Plan." ICLEI-USA, December 2015, available at: https://www.santa-
ana.org/sites/default/files/Documents/climate action plan.pdf, p. 26.
42 "Santa Ana Climate Action Plan." ICLEI-USA, December 2015, available at: https://www.santa-
ana.org/sites/default/files/Documents/climate action plan.pdf, p. 26.
43 California Air Resources Board ("CARB") (Jan. 2017) 2017 Scoping Plan, Appendix B-Local Action, availableat:
htti)s://ww3.arb.ca.gov/cc/scoi)ingi)lan/2030si) appb localaction final.pdf, p. 8-10.
24
75C-99
feasibility of implementing this measure. As such,
we are unable to verify that it will actually be
implemented, monitored, and enforced on the
Project site. As such, the proposed Project is not
consistent with this measure and the Addendum
lacks substantial evidence to support its
consistency determination.
Divert and recycle construction and demolition
Here, while the Addendum briefly discusses
waste, and use locally -sourced building materials
Mitigation Measure 4.13-6 which incorporates the
with a high recycled material content to the
"reuse and recycling of construction and
greatest extent feasible
demolition waste," the Addendum and associated
documents fail to demonstrate that the Project will
implement, monitor, and enforce this measure on
the Project site (p. 3.5-1). Furthermore, the
Addendum also fails to mention or discuss the
feasibility of using locally -sourced building
materials with a high recycled material content, as
the measure indicates. As such, the proposed
Project is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Minimize tree removal, and mitigate indirect GHG
Here, the Addendum and associated documents
emissions increases that occur due to vegetation
fail to mention or minimize tree removal
removal, loss of sequestration, and soil disturbance
whatsoever. Furthermore, the Addendum and
associated documents fail to mitigate the indirect
GHG emissions increases that occur due to
vegetation removal, loss of sequestration, and soil
disturbance, as the measure discusses. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Increase use of electric and renewable fuel
Here, while the Addendum mentions using electric
powered construction equipment and require
construction equipment, the Addendum fails to
renewable diesel fuel where commercially
mention or require renewable diesel fuel where
available
commercially available, as the measure states (p.
3.4-2). As such, the proposed Project is not
consistent with this measure and the Addendum
lacks substantial evidence to support its
consistency determination.
Require diesel equipment fleets to be lower
Here, the Addendum fails to evaluate the feasibility
emitting than any current emission standard
of or require diesel equipment fleets to be lower
emitting, as the measure discusses. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Measures —operation
25
75C-100
Require on -site EV charging capabilities for parking
Here, the GHG Assessment states that "[t)he
spaces serving the project to meet jurisdiction-
Project includes energy efficient features in
wide EV proliferation goals.
compliance with the 2019 Title 24 Energy Efficiency
Standards such as energy efficient appliances and
electric vehicle charging stations" (Appendix D, pp.
225). However, the GHG Assessment states this
only to demonstrate consistency with the City's
CAP, and does not include EV charging spaces in
the Project description or design features.
Furthermore, the Addendum fails to demonstrate
that the Project will actually implement, monitor,
and enforce this measure at the Project site. As
such, the proposed Project is not consistent with
this measure and the Addendum lacks substantial
evidence to support its consistency determination.
Allow for new construction to install fewer on -site
Here, the Addendum and associated documents
parking spaces than required by local municipal
fail to mention or allow the Project to install fewer
building code, if appropriate
on -site parking spaces than required by local
municipal building code. As such, the proposed
Project is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Dedicate on -site parking for shared vehicles
Here, the Addendum and associated documents
fail to mention or require on -site parking for
shared vehicles. As such, the proposed Project is
not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Require on -site renewable energy generation
Here, the Addendum and associated documents
fail to mention or require on -site renewable energy
generation. As such, the proposed Project is not
consistent with this measure and the Addendum
lacks substantial evidence to support its
consistency determination.
Require cool roofs and "cool parking" that
Here, while the Mitigation Monitoring and
promotes cool surface treatment for new parking
Reporting Program, provided as Appendix K to the
facilities as well as existing surface lots undergoing
Addendum, states that the Project will exceed
resurfacing
current Cool Roof Coatings performance standards,
the Addendum and associated documents fail to
mention or require "cool parking," as the measure
states (Appendix K, pp. 1,734). Furthermore, the
Addendum and associated documents fail to
mention or require that existing surface lots
undergo resurfacing. As such, the proposed Project
is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
26
75C-101
Require organic collection in new developments
Here, the Addendum and associated documents
fail to mention or require organic collection in new
developments whatsoever. As such, the proposed
Project is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Achieve Zero Net Energy performance building
Here, the Addendum and associated documents
standards prior to dates required by the Energy
fail to demonstrate that the Project would achieve
Code
Zero Net Energy performance building standards
prior to dates required by the Energy Code, as the
measure describes. As such, the proposed Project
is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Require preferential parking spaces for park and
Here, the Addendum and associated documents
ride to incentivize carpooling, vanpooling,
fail to mention or require preferential parking
commuter bus, electric vehicles, and rail service
spaces for park and ride to incentivize carpooling,
use
vanpooling, commuter bus, electric vehicles, and
rail service use, as the measure states. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Require a transportation management plan for
Here, the Addendum and associated documents
specific plans which establishes a numeric target
fail to mention or require a transportation
for non-SOV travel and overall VMT
management plan for specific plans which
establishes a numeric target for non-SOV travel
and overall VMT, as the measure indicates. As
such, the proposed Project is not consistent with
this measure and the Addendum lacks substantial
evidence to support its consistency determination.
Develop a rideshare program targeting commuters
Here, the Addendum and associated documents
to major employment centers
fail to mention or require the development of a
rideshare program targeting commuters to major
employment centers. As such, the proposed
Project is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Require the design of bus stops/shelters/express
Here, while Addendum states that "[tjhe location
lanes in new developments to promote the usage
of the project site is in close proximity to several
of mass -transit
bus stops," the Addendum and associated
documents fail to mention or require the design of
bus stops/shelters/express lanes in new
developments to promote the usage of mass -
transit (p. 3.4-6). As such, the proposed Project is
not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
27
75C-102
Require gas outlets in residential backyards for use
Here, the Addendum and associated documents
with outdoor cooking appliances such as gas
fail to mention or require gas outlets in residential
barbeques if natural gas service is available
backyards for use with outdoor cooking appliances
such as gas barbeques if natural gas service is
available. As such, the proposed Project is not
consistent with this measure and the Addendum
lacks substantial evidence to support its
consistency determination.
Require the installation of electrical outlets on the
Here, the Addendum and associated documents
exterior walls of both the front and back of
fail to mention or require electrical outlets on the
residences to promote the use of electric
exterior walls of both the front and back of
landscape maintenance equipment
residences to promote the use of electric
landscape maintenance equipment. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Require the design of the electric outlets and/or
Here, the Addendum and associated documents
wiring in new residential unit garages to promote
fail to mention or require the design of the electric
electric vehicle usage
outlets and/or wiring in new residential unit
garages to promote electric vehicle usage. As such,
the proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Require the installation of energy conserving
Here, the Addendum and associated documents
appliances such as on -demand tank -less water
fail to mention or require the installation of energy
heaters and whole -house fans
conserving appliances such as on -demand tank -less
water heaters and whole -house fans, as the
measure indicates. As such, the proposed Project is
not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Require each residential and commercial building
Here, the Addendum states that "[n]atural gas and
equip buildings with energy efficient AC units and
electricity would be used for heating and cooling
heating systems with programmable
systems" (p. 3.4-3). As such, the Addendum fails to
thermostats/timers
mention or specify that such heating and cooling
systems are energy efficient, as the measure
specifies. Furthermore, the Addendum and
associated documents fail to mention or require
that each residential or commercial building have
AC units and heating systems with programmable
thermostats/timers. As such, the proposed Project
is not consistent with this measure and the
Addendum lacks substantial evidence to support its
consistency determination.
Require large-scale residential developments and
Here, the Addendum and associated documents
commercial buildings to report energy use, and set
fail to mention or require that the Project report
specific targets for per -capita energy use
energy use, or set specific targets for per -capita
28
75C-103
energy use. As such, the proposed Project is not
consistent with this measure and the Addendum
lacks substantial evidence to support its
consistency determination.
Require the use of energy -efficient lighting for all
Here, the while the Addendum states that the
street, parking, and area lighting
"project would use utilize energy -efficient LED
lighting," the Addendum and associated
documents fail to mention or specify that energy -
efficient lighting would be require for all street,
parking, and area lighting, as the measure states
(p. 3.5-3). As such, the proposed Project is not
consistent with this measure and the Addendum
lacks substantial evidence to support its
consistency determination.
Require the landscaping design for parking lots to
Here, the Addendum and associated documents
utilize tree cover and compost/mulch
fail to mention or require the landscaping design
for parking lots to utilize tree cover and
compost/mulch, as the measure indicates. As such,
the proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Incorporate water retention in the design of
Here, the Addendum and associated documents
parking lots and landscaping, including using
fail to mention or incorporate water retention in
compost/mulch
the design of parking lots and landscaping,
including using compost/mulch. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
Require the development project to propose an
Here, the Addendum and associated documents
off -site mitigation project which should generate
fail to mention or require the Project to propose an
carbon credits equivalent to the anticipated GHG
off -site mitigation project to generate carbon
emission reductions. This would be implemented
credits, as required. As such, the proposed Project
via an approved protocol for carbon credits from
is not consistent with this measure and the
California Air Pollution Control Officers Association
Addendum lacks substantial evidence to support its
(CAPCOA), the California Air Resources Board, or
consistency determination.
other similar entities determined acceptable by the
local air district
Require the project to purchase carbon credits
Here, the Addendum and associated documents
from the CAPCOA GHG Reduction Exchange
fail to require the Project to purchase carbon
Program, American Carbon Registry (ACR), Climate
credits whatsoever. In addition, the Addendum and
Action Reserve (CAR) or other similar carbon credit
associated documents fail to mention the CAPCOA
registry determined to be acceptable by the local
GHG Reduction Exchange Program, ACR, CAR, or
air district
other similar carbon credit registries. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination.
29
75C-104
Consider generating or purchasing local and
California -only carbon credits as the preferred
mechanism to implement its offsite mitigation
measure for GHG emissions and that will facilitate
the State's efforts in achieving the GHG emission
reduction goal
Here, the Addendum and associated documents
fail to consider or indicate that the proposed
Project will generate or purchase any local or
California -only carbon credits. As such, the
proposed Project is not consistent with this
measure and the Addendum lacks substantial
evidence to support its consistency determination
As the above table indicates, the Addendum and associated documents fail to provide sufficient
information and analysis to determine Project consistency with various measures under CARB's 2017
Scoping Plan. Thus, we cannot verify that the Project would be consistent with CARB's 2017 Scoping
Plan, as stated in the Addendum. As a result, we recommend that an EIR be prepared to include further
information and analysis demonstrating the Project's consistency.
(7) Updated Analysis Indicates a Potentially Significant GHG Impact
Applicable thresholds and site -specific modeling demonstrate that the proposed Project would result in
a significant GHG impact not previously mitigated by the Addendum. The CalEEMod output files,
modeled by SWAPE with Project -specific information, disclose the Project's mitigated emissions, which
include approximately 996 MT CO2e of total construction emissions (sum of 2021, 2022, and 2023) and
approximately 1,993 MT CO2e/year of net annual operational emissions (sum of area, energy, mobile,
waste, and water -related emissions), for a net annual GHG emissions of 2,026 MT CO2e/year.
Furthermore, as described above, we estimate that the Project's total service population would be
approximately 430 people. When dividing the Project's GHG emissions (amortized construction +
operational) by a service population value of 430 people, we find that the Project would emit
approximately 4.71 MT CO2e/SP/year.44 As demonstrated in the table below, the service population
efficiency value of 4.71 MT CO2e/SP/year exceeds the SCAQMD 2035 efficiency target of 3.0 MT
CO2e/SP/year (see table below).41
SWAPE Service Population Efficiency
Proposed
Project Phase Project (MT
Construction (amortized over 30 years)
33.21
Area
37.63
Energy
599.40
Mobile
1,214.56
Waste 66.11
Water 75.23
"Calculated: (2,026.12 MT CO2e/year) / (430 service population) _ (4.71 MT CO2e/SP/year).
45 "Minutes for the GHG CECA Significance Threshold Stakeholder Working Group #15." SCAQMD, September
2010, available at: http://www.agmd.gov/docs/default-source/cega/handbook/greenhouse-gases-(aha)-cega-
sianificance-thresholds/year-2008-2009/aha-meeting-15/aha-meeting-15-minutes.pdf, p. 2.
30
75C-105
Total 2,026.12
Service Population 430
Service Population Efficiencv 4.71
Threshold 3
Exceed? Yes
As the above table indicates, the Project's service population efficiency exceeds the SCAQMD 2035
efficiency target of 3.0 MT CO2e/SP/year, respectively, thus resulting in a significant impact not
previously mitigated in the Addendum. As previously stated, according to CEQA Guidelines § 15064.4(b),
if there is substantial evidence that the possible effects of a particular project are still cumulatively
considerable notwithstanding compliance with the adopted regulations or requirements, a full CEQA
analysis must be prepared for the project. Therefore, a Project -specific EIR should be prepared and
recirculated for the Project, and mitigation should be implemented where necessary, per CEQA
Guidelines.
SWAPE has received limited discovery regarding this project. Additional information may become
available in the future; thus, we retain the right to revise or amend this report when additional
information becomes available. Our professional services have been performed using that degree of
care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants
practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is
made as to the scope of work, work methodologies and protocols, site conditions, analytical testing
results, and findings presented. This report reflects efforts which were limited to information that was
reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or
otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by
third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
(,, I C_Z, �J A
Paul E. Rosenfeld, Ph.D.
31
75C-106
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5C-209
Start date and time 10/08/20 14:58:45
AERSCREEN 16216
4th and Mortimer Construction
4th and Mortimer Construction
----------------- DATA ENTRY VALIDATION -----------------
METRIC ENGLISH
** AREADATA **
Emission Rate:
Area Height:
Area Source Length
Area Source Width:
Vertical Dimension
Model Mode:
0.156E-02 g/s
3.00 meters
157.00 meters
70.00 meters
1.50 meters
URBAN
Population: 332725
Dist to Ambient Air:
** BUILDING DATA **
0.123E-01 lb/hr
9.84 feet
515.09 feet
229.66 feet
4.92 feet
1.0 meters
3. feet
75C-210
No Building Downwash Parameters
** TERRAIN DATA **
No Terrain Elevations
Source Base Elevation: 0.0 meters
Probe distance: 5000. meters
No flagpole receptors
No discrete receptors used
** FUMIGATION DATA **
No fumigation requested
** METEOROLOGY DATA **
0.0 feet
16404. feet
Min/Max Temperature: 250.0 / 310.0 K -9.7 / 98.3 Deg F
Minimum Wind Speed: 0.5 m/s
75C-211
Anemometer Height: 10.000 meters
Dominant Surface Profile: Urban
Dominant Climate Type: Average Moisture
Surface friction velocity (u*): not adjusted
DEBUG OPTION ON
AERSCREEN output file:
2020.10.08 4thandMortimer Construction.out
*** AERSCREEN Run is Ready to Begin
No terrain used, AERMAP will not be run
**************************************************
SURFACE CHARACTERISTICS & MAKEMET
Obtaining surface characteristics...
75C-212
Using AERMET seasonal surface characteristics for Urban with Average Moisture
Season
Albedo
Bo
zo
Winter
0.35
1.50
1.000
Spring
0.14
1.00
1.000
Summer
0.16
2.00
1.000
Autumn
0.18
2.00
1.000
Creating met files aerscreen_01_01.sfc & aerscreen_01_01.pfl
Creating met files aerscreen_02_01.sfc & aerscreen_02_01.pfl
Creating met files aerscreen_03_01.sfc & aerscreen_03_01.pfl
Creating met files aerscreen_04_01.sfc & aerscreen_04_01.pfl
Buildings and/or terrain present or rectangular area source, skipping probe
FLOWSECTOR started 10/08/20 14:59:34
********************************************
Running AERMOD
Processing Winter
Processing surface roughness sector 1
75C-213
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 5
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 10
******** WARNING MESSAGES ********
*** NONE ***
75C-214
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 20
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 25
******** WARNING MESSAGES ********
*** NONE ***
********************************************
75C-215
Running AERMOD
Processing Spring
Processing surface roughness sector 1
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 5
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 10
75C-216
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 20
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 25
75C-217
******** WARNING MESSAGES ********
*** NONE ***
********************************************
Running AERMOD
Processing Summer
Processing surface roughness sector 1
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 5
******** WARNING MESSAGES ********
*** NONE ***
75C-218
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 10
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 20
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
75C-219
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 25
******** WARNING MESSAGES ********
*** NONE ***
********************************************
Running AERMOD
Processing Autumn
Processing surface roughness sector 1
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 5
75C-220
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 10
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 20
75C-221
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 25
******** WARNING MESSAGES ********
*** NONE ***
FLOWSECTOR ended 10/08/20 14:59:45
REFINE started 10/08/20 14:59:45
AERMOD Finishes Successfully for REFINE stage 3 Winter sector 0
******** WARNING MESSAGES ********
*** NONE ***
REFINE ended 10/08/20 14:59:46
AERSCREEN Finished Successfully
With no errors or warnings
75C-222
Check log file for details
***********************************************
Ending date and time 10/08/20 14:59:48
75C-223
Concentration Distance Elevation Diag Season/Month Zo sector Date
HO U* W* DT/DZ ZICNV ZIMCH M-0 LEN ZO BOWEN ALBEDO REF WS HT
REF TA HT
0.30467E+01 1.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.33827E+01 25.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36935E+01 50.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.39144E+01 75.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
* 0.39459E+01 79.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.27307E+01 100.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.18815E+01 125.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.14398E+01 150.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11524E+01 175.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.95248E+00 200.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.80642E+00 225.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.69567E+00 250.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.60877E+00 275.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.53971E+00 300.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.48264E+00 325.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.43557E+00 350.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
75C-224
310.0 2.0
0.39621E+00 375.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.36244E+00 400.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.33335E+00 425.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.30808E+00 450.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.28604E+00 475.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.26665E+00 500.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.24930E+00 525.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.23383E+00 550.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.21997E+00 575.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.20750E+00 600.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.19623E+00 625.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.18599E+00 650.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.17661E+00 675.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.16803E+00 700.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.16016E+00 725.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.15289E+00 750.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.14615E+00 775.00 0.00
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-225
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.13992E+00 800.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.13413E+00 825.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12877E+00 850.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12376E+00 875.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11908E+00 900.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11470E+00 925.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11060E+00 950.01
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.10674E+00 975.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.10311E+00 1000.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.99699E-01 1025.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.96478E-01 1050.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.93435E-01 1075.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.90557E-01 1100.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.87831E-01 1125.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.85243E-01 1150.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.82786E-01 1175.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-226
0.80444E-01 1200.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.78210E-01 1225.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.76082E-01 1250.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.74052E-01 1275.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.72105E-01 1300.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.70528E-01 1325.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.68742E-01 1350.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.67033E-01 1375.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.65397E-01 1400.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.63828E-01 1425.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.62324E-01 1450.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.60879E-01 1475.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.59492E-01 1500.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.58159E-01 1525.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.56877E-01 1550.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.55642E-01 1575.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.54454E-01 1600.00
-1.30 0.043 -9.000 0.020 -999
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-227
0.53309E-01
1625.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.52204E-01
1650.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.51139E-01
1675.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.50111E-01
1700.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.49118E-01
1725.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.48159E-01
1750.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.47232E-01
1775.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.46335E-01
1800.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.45467E-01
1825.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.44627E-01
1850.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.43814E-01
1875.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.43026E-01
1900.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.42262E-01
1924.99
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.41521E-01
1950.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.40803E-01
1975.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.40106E-01
2000.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.39429E-01
2025.00
0.00
5.0
Winter
0-360
10011001
75C-228
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.38772E-01
2050.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.38133E-01
2075.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.37513E-01
2100.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.36909E-01
2125.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.36323E-01
2150.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.35752E-01
2175.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.35197E-01
2200.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.34656E-01
2225.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.34130E-01
2250.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.33617E-01
2275.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.33118E-01
2300.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.32631E-01
2325.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.32157E-01
2350.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.31694E-01
2375.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.31242E-01
2400.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.30802E-01
2425.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
75C-229
0.30373E-01
2449.99
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.29953E-01
2475.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.29544E-01
2500.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.29144E-01
2525.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.28754E-01
2550.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.28372E-01
2575.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.27999E-01
2600.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.27635E-01
2625.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.27278E-01
2650.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.26930E-01
2675.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.26589E-01
2700.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.26256E-01
2725.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.25929E-01
2750.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.25610E-01
2775.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.25298E-01
2800.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.24991E-01
2825.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.24692E-01
2850.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
75C-230
0.24399E-01
2875.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.24111E-01
2900.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23829E-01
2925.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23553E-01
2950.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23283E-01
2975.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23018E-01
3000.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.22758E-01
3025.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.22503E-01
3050.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.22253E-01
3075.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.22007E-01
3100.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21767E-01
3125.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21531E-01
3150.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21299E-01
3175.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21071E-01
3200.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20848E-01
3225.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20629E-01
3250.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20414E-01
3275.00
0.00
0.0
Winter
0-360
10011001
75C-231
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20203E-01
3300.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19995E-01
3325.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19791E-01
3350.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19591E-01
3375.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19394E-01
3400.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19200E-01
3425.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19010E-01
3450.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18823E-01
3475.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18639E-01
3500.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18459E-01
3525.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18281E-01
3550.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18106E-01
3575.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17934E-01
3600.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17765E-01
3625.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17599E-01
3650.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17436E-01
3675.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
75C-232
0.17275E-01
3700.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17116E-01
3725.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16960E-01
3750.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16807E-01
3775.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16655E-01
3800.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16507E-01
3825.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16360E-01
3849.99
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16216E-01
3875.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16074E-01
3900.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15934E-01
3925.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15796E-01
3950.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15660E-01
3975.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15527E-01
4000.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15395E-01
4025.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15265E-01
4050.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15137E-01
4075.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15011E-01
4100.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
75C-233
0.14887E-01
4125.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14764E-01
4150.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14643E-01
4175.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14524E-01
4200.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14407E-01
4225.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14291E-01
4250.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14177E-01
4275.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14064E-01
4300.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13953E-01
4325.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13843E-01
4350.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13735E-01
4375.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13628E-01
4400.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13523E-01
4425.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13419E-01
4450.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13317E-01
4475.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13216E-01
4500.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13116E-01
4525.00
0.00
0.0
Winter
0-360
10011001
75C-234
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.13018E-01 4550.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12920E-01 4575.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12824E-01 4600.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12730E-01 4625.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12636E-01 4650.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12544E-01 4675.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12453E-01 4700.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12363E-01 4725.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12274E-01 4750.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12186E-01 4775.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12099E-01 4800.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.12013E-01 4825.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11929E-01 4850.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11845E-01 4875.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11763E-01 4900.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.11681E-01 4925.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-235
0.11600E-01
-1.30 0.043 -9.000
310.0 2.0
0.11521E-01
-1.30 0.043 -9.000
310.0 2.0
0.11442E-01
-1.30 0.043 -9.000
310.0 2.0
r• 00 0 00'
o0 1
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter 0-360 10011001
6.0 1.000 1.50 0.35 0.50 10.0
75C-236
Start date and time 10/08/20 14:59:50
AERSCREEN 16216
4th and Mortimer Operation
4th and Mortimer Operation
----------------- DATA ENTRY VALIDATION -----------------
METRIC ENGLISH
** AREADATA **
Emission Rate:
Area Height:
Area Source Length
Area Source Width:
Vertical Dimension
Model Mode:
0.926E-03 g/s
3.00 meters
157.00 meters
70.00 meters
1.50 meters
URBAN
Population: 332725
Dist to Ambient Air:
** BUILDING DATA **
0.735E-02 lb/hr
9.84 feet
515.09 feet
229.66 feet
4.92 feet
1.0 meters
3. feet
75C-237
No Building Downwash Parameters
** TERRAIN DATA **
No Terrain Elevations
Source Base Elevation: 0.0 meters
Probe distance: 5000. meters
No flagpole receptors
No discrete receptors used
** FUMIGATION DATA **
No fumigation requested
** METEOROLOGY DATA **
0.0 feet
16404. feet
Min/Max Temperature: 250.0 / 310.0 K -9.7 / 98.3 Deg F
Minimum Wind Speed: 0.5 m/s
75C-238
Anemometer Height: 10.000 meters
Dominant Surface Profile: Urban
Dominant Climate Type: Average Moisture
Surface friction velocity (u*): not adjusted
DEBUG OPTION ON
AERSCREEN output file:
2020.10.08_4thandMortimer_Operation.out
*** AERSCREEN Run is Ready to Begin
No terrain used, AERMAP will not be run
**************************************************
SURFACE CHARACTERISTICS & MAKEMET
Obtaining surface characteristics...
75C-239
Using AERMET seasonal surface characteristics for Urban with Average Moisture
Season
Albedo
Bo
zo
Winter
0.35
1.50
1.000
Spring
0.14
1.00
1.000
Summer
0.16
2.00
1.000
Autumn
0.18
2.00
1.000
Creating met files aerscreen_01_01.sfc & aerscreen_01_01.pfl
Creating met files aerscreen_02_01.sfc & aerscreen_02_01.pfl
Creating met files aerscreen_03_01.sfc & aerscreen_03_01.pfl
Creating met files aerscreen_04_01.sfc & aerscreen_04_01.pfl
Buildings and/or terrain present or rectangular area source, skipping probe
FLOWSECTOR started 10/08/20 15:00:33
********************************************
Running AERMOD
Processing Winter
Processing surface roughness sector 1
75C-240
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 5
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 10
******** WARNING MESSAGES ********
*** NONE ***
75C-241
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 20
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Winter sector 25
******** WARNING MESSAGES ********
*** NONE ***
********************************************
75C-242
Running AERMOD
Processing Spring
Processing surface roughness sector 1
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 5
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 10
75C-243
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 20
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Spring sector 25
75C-244
******** WARNING MESSAGES ********
*** NONE ***
********************************************
Running AERMOD
Processing Summer
Processing surface roughness sector 1
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 5
******** WARNING MESSAGES ********
*** NONE ***
75C-245
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 10
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 20
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
75C-246
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Summer sector 25
******** WARNING MESSAGES ********
*** NONE ***
********************************************
Running AERMOD
Processing Autumn
Processing surface roughness sector 1
*****************************************************
Processing wind flow sector 1
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 0
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 2
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 5
75C-247
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 3
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 10
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 4
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 15
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 5
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 20
75C-248
******** WARNING MESSAGES ********
*** NONE ***
*****************************************************
Processing wind flow sector 6
AERMOD Finishes Successfully for FLOWSECTOR stage 2 Autumn sector 25
******** WARNING MESSAGES ********
*** NONE ***
FLOWSECTOR ended 10/08/20 15:00:43
REFINE started 10/08/20 15:00:43
AERMOD Finishes Successfully for REFINE stage 3 Winter sector 0
******** WARNING MESSAGES ********
*** NONE ***
REFINE ended 10/08/20 15:00:45
AERSCREEN Finished Successfully
With no errors or warnings
75C-249
Check log file for details
***********************************************
Ending date and time 10/08/20 15:00:47
75C-250
Concentration Distance Elevation Diag Season/Month Zo sector Date
HO U* W* DT/DZ ZICNV ZIMCH M-0 LEN ZO BOWEN ALBEDO REF WS HT
REF TA HT
0.18149E+01 1.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.20150E+01 25.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.22002E+01 50.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.23318E+01 75.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
* 0.23505E+01 79.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.16266E+01 100.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.11208E+01 125.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.85766E+00 150.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.68647E+00 175.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.56738E+00 200.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.48038E+00 225.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.41440E+00 250.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.36264E+00 275.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.32150E+00 300.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.28750E+00 325.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
310.0 2.0
0.25946E+00 350.00 0.00 0.0 Winter 0-360 10011001
-1.30 0.043 -9.000 0.020 -999. 21. 6.0 1.000 1.50 0.35 0.50 10.0
75C-251
310.0 2.0
0.23602E+00 375.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.21590E+00 400.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.19858E+00 425.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.18352E+00 450.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.17039E+00 475.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.15884E+00 500.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.14851E+00 525.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.13929E+00 550.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.13104E+00 575.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.12361E+00 600.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.11689E+00 625.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.11079E+00 650.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.10520E+00 675.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.10009E+00 700.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.95407E-01 725.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.91074E-01 750.00 0.00
-1.30 0.043 -9.000 0.020 -999. 21
310.0 2.0
0.87061E-01 775.00 0.00
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
6.0 1.000 1.50
0.0 Winter
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-252
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.83348E-01 800.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.79903E-01 825.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.76704E-01 850.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.73720E-01 875.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.70932E-01 900.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.68325E-01 925.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.65880E-01 950.01
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.63585E-01 975.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.61424E-01 1000.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.59389E-01 1025.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.57471E-01 1050.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.55659E-01 1075.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.53944E-01 1100.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.52320E-01 1125.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.50779E-01 1150.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.49315E-01 1175.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-253
0.47920E-01 1200.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.46589E-01 1225.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.45321E-01 1250.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.44112E-01 1275.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.42952E-01 1300.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.42013E-01 1325.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.40949E-01 1350.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.39931E-01 1375.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.38956E-01 1400.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.38022E-01 1425.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.37126E-01 1450.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.36265E-01 1475.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.35439E-01 1500.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.34645E-01 1525.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.33881E-01 1550.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.33145E-01 1575.00
-1.30 0.043 -9.000 0.020 -999
310.0 2.0
0.32438E-01 1600.00
-1.30 0.043 -9.000 0.020 -999
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0.00 0.0 Winter
21. 6.0 1.000 1.50
0.00 5.0 Winter
21. 6.0 1.000 1.50
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
0-360 10011001
0.35 0.50 10.0
75C-254
0.31755E-01
1625.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.31098E-01
1650.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.30463E-01
1675.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.29851E-01
1700.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.29259E-01
1725.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.28688E-01
1750.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.28136E-01
1775.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.27601E-01
1800.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.27084E-01
1825.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.26584E-01
1850.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.26100E-01
1875.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.25630E-01
1900.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.25175E-01
1924.99
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.24734E-01
1950.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.24306E-01
1975.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23891E-01
2000.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23488E-01
2025.00
0.00
5.0
Winter
0-360
10011001
75C-255
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.23096E-01
2050.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.22715E-01
2075.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.22346E-01
2100.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21986E-01
2125.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21637E-01
2150.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.21297E-01
2175.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20966E-01
2200.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20644E-01
2225.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20331E-01
2250.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.20025E-01
2275.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19728E-01
2300.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19438E-01
2325.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.19155E-01
2350.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18880E-01
2375.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18611E-01
2400.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.18349E-01
2425.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
75C-256
0.18093E-01
2449.99
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17843E-01
2475.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17599E-01
2500.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17361E-01
2525.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.17128E-01
2550.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16901E-01
2575.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16679E-01
2600.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16462E-01
2625.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16249E-01
2650.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.16042E-01
2675.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15839E-01
2700.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15640E-01
2725.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15446E-01
2750.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15256E-01
2775.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.15069E-01
2800.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14887E-01
2825.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14709E-01
2850.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
75C-257
0.14534E-01
2875.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14363E-01
2900.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14195E-01
2925.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.14031E-01
2950.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13869E-01
2975.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13711E-01
2999.99
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13556E-01
3025.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13405E-01
3050.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13256E-01
3074.99
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.13109E-01
3100.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12966E-01
3125.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12826E-01
3150.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12687E-01
3175.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12552E-01
3200.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12419E-01
3225.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12288E-01
3250.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12160E-01
3275.00
0.00
0.0
Winter
0-360
10011001
75C-258
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.12034E-01
3300.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11911E-01
3325.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11789E-01
3350.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11670E-01
3375.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11553E-01
3400.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11437E-01
3425.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11324E-01
3450.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11213E-01
3475.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.11103E-01
3500.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10996E-01
3525.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10890E-01
3550.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10786E-01
3575.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10683E-01
3600.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10583E-01
3625.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10484E-01
3650.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10386E-01
3675.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
75C-259
0.10290E-01
3700.00
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10196E-01
3725.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10103E-01
3750.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.10011E-01
3775.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.99215E-02
3800.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.98329E-02
3825.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.97456E-02
3849.99
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.96597E-02
3875.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.95751E-02
3900.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.94917E-02
3925.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.94096E-02
3950.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.93287E-02
3975.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.92491E-02
4000.00
0.00
15.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.91705E-02
4025.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.90932E-02
4050.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.90169E-02
4075.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.89418E-02
4100.00
0.00
10.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
75C-260
0.88677E-02
4125.00
0.00
5.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.87947E-02
4149.99
0.00
20.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.87228E-02
4175.00
0.00
25.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.86518E-02
4200.00
0.00
0.0
Winter
0-360
10011001
-1.30 0.043 -9.000
0.020
-999.
21.
6.0
1.000 1.50
0.35
0.50 10.0
310.0 2.0
0.85818E-02
4225.00
0.00
5.0
Winter
0-360
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75C-263
Syl�APE TechninaConsuRation,Data Analyslsand
■■•• L L@igalion Support for the Environment
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
1640 51h St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887-9013
Email: mhagemann@swape.com
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine
years with the U.S. EPA in the RCRA and Superfund programs and served as EPA's Senior Science
Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from
perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of
the assessment of seven major military facilities undergoing base closure. He led numerous enforcement
actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working
with permit holders to improve hydrogeologic characterization and water quality monitoring.
Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the
application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt
has trained the technical staff in the States of California, Hawaii, Nevada, Arizona and the Territory of
Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.
Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 - present);
• Geology Instructor, Golden West College, 2010 - 2014;
• Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003);
75C-264
• Executive Director, Orange Coast Watch (2001— 2004);
• Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989-
1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 — 2000);
• Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 —
1998);
• Instructor, College of Marin, Department of Science (1990—1995);
• Geologist, U.S. Forest Service (1986—1998); and
• Geologist, Dames & Moore (1984—1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt's responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports
since 2003 under CEQA that identify significant issues with regard to hazardous waste, water
resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic
hazards. Make recommendations for additional mitigation measures to lead agencies at the
local and county level to include additional characterization of health risks and
implementation of protective measures to reduce worker exposure to hazards from toxins
and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities.
• Manager of a project to provide technical assistance to a community adjacent to a former
Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns.
• Lead analyst and testifying expert in the review of environmental issues in license applications
for large solar power plants before the California Energy Commission.
• Manager of a project to evaluate numerous formerly used military sites in the western U.S.
• Manager of a comprehensive evaluation of potential sources of perchlorate contamination in
Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the
review of releases of gasoline to sources drinking water at major refineries and hundreds of gas
stations throughout California.
• Expert witness on two cases involving MTBE litigation.
• Expert witness and litigation support on the impact of air toxins and hazards at a school.
• Expert witness in litigation at a former plywood plant.
With Komex H2O Science Inc., Matt's duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony
by the former U.S. EPA Administrator and General Counsel.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking
water treatment, results of which were published in newspapers nationwide and in testimony
against provisions of an energy bill that would limit liability for oil companies.
• Research to support litigation to restore drinking water supplies that have been contaminated by
MTBE in California and New York.
75C-265
Expert witness testimony in a case of oil production -related contamination in Mississippi.
Lead author for a multi -volume remedial investigation report for an operating school in Los
Angeles that met strict regulatory requirements and rigorous deadlines.
75C-266
• Development of strategic approaches for cleanup of contaminated sites in consultation with
clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange
County beaches from multiple sources of contamination including urban runoff and the discharge of
wastewater. In reporting to a Board of Directors that included representatives from leading Orange
County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection
of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the
development of countywide water quality permits for the control of urban runoff and permits for the
discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including
Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business
institutions including the Orange County Business Council.
HvdrogeologK
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to
characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point
Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army
Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of
monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and
groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory
analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation
development through work on four national U.S. EPA workgroups, including the Superfund
Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of
groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to
show zones of vulnerability, and the results were adopted and published by the State of Hawaii and
County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the
Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included
the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for
the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities
through designation under the Safe Drinking Water Act. He prepared geologic reports,
conducted public hearings, and responded to public comments from residents who were very
concerned about the impact of designation.
4
75C-267
Reviewed a number of Environmental Impact Statements for planned major developments,
including large hazardous and solid waste disposal facilities, mine reclamation, and water
transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance
with Subtitle C requirements.
• Reviewed and wrote "part B" permits for the disposal of hazardous waste.
• Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed
the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
• Wrote contract specifications and supervised contractor's investigations of waste sites.
With the National Park Service, Matt directed service -wide investigations of contaminant sources to
prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the
Clean Water Act to control military, mining, and landfill contaminants.
• Conducted watershed -scale investigations of contaminants at parks, including Yellowstone and
Olympic National Park.
• Identified high -levels of perchlorate in soil adjacent to a national park in New Mexico
and advised park superintendent on appropriate response actions under CERCLA.
• Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a
national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while
serving on a national workgroup.
• Co-authored two papers on the potential for water contamination from the operation of personal
watercraft and snowmobiles, these papers serving as the basis for the development of nation-
wide policy on the use of these vehicles in National Parks.
• Contributed to the Federal Multi -Agency Source Water Agreement under the Clean Water
Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection
Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the
potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking
water supplies.
• Shaped EPA's national response to these threats by serving on workgroups and by contributing
to guidance, including the Office of Research and Development publication, Oxygenates in
Water: Critical Information and Research Needs.
• Improved the technical training of EPA's scientific and engineering staff.
• Earned an EPA Bronze Medal for representing the region's 300 scientists and engineers in
negotiations with the Administrator and senior management to better integrate scientific
principles into the policy -making process.
• Established national protocol for the peer review of scientific documents.
75C-268
Geology
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for
timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical
models to determ ne slope stability.
• Coordinated his research with community members who were concerned with natural resource
protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the
city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later
listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern
Oregon. Duties included the following:
Supervised year -long effort for soil and groundwater sampling.
Conducted aquifer tests.
Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching•
From 1990 to 1998, Matt taught at least one course per semester at the community college and university
levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in
environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater
contamination.
• Served as a committee member for graduate and undergraduate students.
• Taught courses in environmental geology and oceanography at the College of Marin.
Matt taught physical geology (lecture and lab and introductory geology at Golden West College in
Huntington Beach, California from 2010 to 2014.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public
Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and
Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las
Vegas, NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at
schools in Southern California, Los Angeles.
75C-269
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE
Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater
Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust,
Phoenix, AZ (served on conference organizing comm ttee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy
of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water
Supplies. Invited presentation to the Inter -Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited
presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of
the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a
meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address
Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental
Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater
(and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage
Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and
State Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished
report.
75C-270
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage
Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential W a t e r Quality Concerns Related
to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft
Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright
Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund
Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air
Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic
Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui,
October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu,
Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air
and Waste Management Association Publication VIP-61.
Hagemann, M.F., 1994. Groundwater Characterization and Cleanup at Closing Military Bases
in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater
Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of
Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL-
contaminated Groundwater. California Groundwater Resources Association Meeting.
0
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Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of
Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examination, 2009-
2011.
75C-272
Technical Consultation, Data Analysis and SOIL WATER AIR PROTECTION ENTERPRISE
•■ !1 G y 2656 29th Street, Suite 201
Litigation Support for the Environment Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: mosenfeld(a)s aoexom
Paul Rosenfeld, Ph.D. Chemical Fate and Transport & Air Dispersion Modeling
Principal Environmental Chemist
Education:
Risk Assessment & Remediation Specialist
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on VOC filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment
Professional Experience:
Dr. Rosenfeld is the Co -Founder and Principal Environmental Chemist at Soil Water Air Protection Enterprise
(SWAPE). His focus is the fate and transport of environmental contaminants, risk assessment, and ecological
restoration. Dr. Rosenfeld has evaluated and modeled emissions from unconventional oil drilling, oil spills, boilers,
incinerators and other industrial and agricultural sources relating to nuisance and personal injury. His project
experience ranges from monitoring and modeling of pollution sources as they relate to human and ecological health.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites
containing petroleum, chlorinated solvents, pesticides, radioactive waste, PCBs, PAHs, dioxins, farans, volatile
organics, semi -volatile organics, perchlorate, heavy metals, asbestos, PFOA, unusual polymers, MtBE, fuel
oxygenates and odor. Dr. Rosenfeld has evaluated greenhouse gas emissions using various modeling programs
recommended by California Air Quality Management Districts.
Professional History:
Soil Water Air Protection Enterprise (SWAPE), 2003 to present; Principal and Founding Partner
UCLA School of Public Health, 2007 to 2011, Lecturer (Assistant Researcher)
UCLA School of Public Health, 2003 to 2006, Adjunct Professor
UCLA Environmental Science and Engineering Program, 2002-2004, Doctoral Intern Coordinator
UCLA Institute of the Environment, 2001-2002, Research Associate
Komex H2O Science, 2001 to 2003, Senior Remediation Scientist
National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001, Adjunct Professor
Anteon Corp., San Diego, 2000-2001; Remediation Project Manager
Ogden (now Amec), San Diego, 2000-2000, Remediation Project Manager
Bechtel, San Diego, California, 1999 — 2000, Risk Assessor
King County, Seattle, 1996-1999, Scientist
James River Corp., Washington, 1995-96, Scientist
Big Creek Lumber, Davenport, California, 1995, Scientist
Plumas Corp., California and USFS, Tahoe 1993-1995, Scientist
Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993, Scientist
Bureau of Land Management, Kremmling Colorado 1990, Scientist
October 2015
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Publications
Chen, J. A., Zapata, A R., Sutherland, A. J., Molmen, D. R— Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C.,
(2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated
Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and
Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113-125.
Feng L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and
Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal
of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and faran blood lipid concentrations in populations living
near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air
Pollution, 123 (17), 319-327.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid
Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two
Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins
And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527-
000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near
a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for
Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater,
Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food,
Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing,
Rosenfeld P.E., and Suffet, I.H. (Mel) (2007). Anatomy of an Odor Wheel. Water Science and Technology.
Rosenfeld, P.E., Clark, J.J.J., Hensley A.R., Suffet, I.H. (Mel) (2007). The use of an odor wheel classification for
evaluation of human health risk criteria for compost facilities. Water Science And Technology.
October 2015 2 Rosenfeld CV
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Rosenfeld, P.E., and Suffer I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science
and Technology.49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffer (2004). The Value of An Odor -Quality -Wheel Classification Scheme
For The Urban Environment. Water Environment Federation's Technical Exhibition and Conference (WEFTEC)
2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffer, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities,
and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffer I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science
and Technology, 49(9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from
Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffer, M. (2002). Compost Demonstration Project, Sacramento California Using
High -Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management
Board Public Affairs Office, Publications Clearinghouse (MS-6), Sacramento, CA Publication #442-02-008.
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water
Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal
of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor
emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and
Biosolids Odorants. Water Environment Research, 73, 388-393.
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and
distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users
Network, 7(1).
Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids
Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters
thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third
World. Bachelors Thesis. University of California.
October 2015 3 Rosenfeld CV
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Presentations:
Rosenfeld, P.E., Sutherland, A, Hesse, R., Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile
organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American
Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J. Sutherland, A.J.; Wisdom -Stack, T., Sahai, R.K.; Hesse, R.C.;
Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng L., Gonzalez, J., Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom -Stack, T. Sahai, R.K. La, M., Hesse,
R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis,
Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS)
Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United
States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted
from Tuscon, AZ.
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United
States" Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the
United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture
conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in
populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air
Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and
Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing
Facility. The 23'd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from
University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium -Contaminated Water Into A
Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23'd Annual International
Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst
MA.
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment
Facility Emissions. The 23'd Annual International Conferences on Soils Sediment and Water. Lecture conducted
from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3-
Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture
conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAIL and Metal Exposure in Florala,
Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 — 25, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on
Halogenated Persistent Organic Pollutants — DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia
Hotel in Oslo Norway.
October 2015 4 Rosenfeld CV
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Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting &
Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey's C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel,
Philadelphia, PA.
Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton
Hotel, Irvine California.
Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3-TCP. PEMA
Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey's Groundwater
Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from
Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related
Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and
Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability
and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental
Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ.
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento,
California.
Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh
International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical
Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus
Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California
CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA
Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
October 2015 5 Rosenfeld CV
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Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and
Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water
Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture
conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.
Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High -Carbon Wood Ash to Control Odor at a
Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from
Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water
Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted
from Ocean Shores, California.
Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery
Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation With High -Carbon Wood -Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil
Science Society ofAmerica. Lecture conducted from Salt Lake City Utah.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from
Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from
Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.
Rosenfeld, RE, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation With High -Carbon Wood -Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three
Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim
California.
October 2015
Rosenfeld CV
75C-278
Teaching E%nerience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science
100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on
the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Same Fe, New
Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage
tanks.
National Ground Water Association, Successful Remediation Technologies Course in Chicago Illinois. April 1,
2002. Focused on fate and transport of contaminants associated with Superfand and RCRA sites.
California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San
Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation
Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry,
Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of
Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on
VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of
polymers and ash on VOC emissions from biosolids. 1997.
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered
Poplar trees with resistance to round -up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the
Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts
in West Indies. 1993.
October 2015 7 Rosenfeld CV
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Deposition and/or Trial Testimony:
In The Superior Court of the State of California, County of Alameda
Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants
Case No.: RG14711115
Rosenfeld Deposition, September, 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants
Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants
Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants
Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.
Civil Action NO. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico
Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward
DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant
Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17'h Judicial Circuit, in and For Broward County, Florida
Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant
Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma
Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City
Landfill, et al. Defendants.
Case No. 5:12-cv-01152-C
Rosenfeld Deposition: July 2014
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case Number cc-11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
October 2015
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75C-280
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants
Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition: October 2012
In the Court of Common Pleas for the Second Judicial Circuit, State of South Carolina, County of Aiken
David Anderson, et al., Plaintiffs, vs. Norfolk Southern Corporation, et al., Defendants.
Case Number: 2007-CP-02-1584
In the Circuit Court of Jefferson County Alabama
Jaeanette Moss Anthony, et al., Plaintiffs, vs. Drummond Company Inc., et al., Defendants
Civil Action No. CV 2008-2076
Rosenfeld Deposition: September 2010
In the Ninth Judicial District Court, Parish of Rapides, State of Louisiana
Roger Price, et al., Plaintiffs, vs. Roy O. Martin, L.P., et al., Defendants.
Civil Suit Number 224,041 Division G
Rosenfeld Deposition: September 2008
In the United States District Court, Western District Lafayette Division
Ackle et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.
Case Number 2:07CV 1052
Rosenfeld Deposition: July 2009
In the United States District Court for the Southern District of Ohio
Carolyn Baker, et al., Plaintiffs, vs. Chevron Oil Company, et al., Defendants.
Case Number 1:05 CV 227
Rosenfeld Deposition: July 2008
In the Fourth Judicial District Court, Parish of Calcasieu, State of Louisiana
Craig Steven Arabic, et al., Plaintiffs, vs. Citgo Petroleum Corporation, et al., Defendants.
Case Number 07-2738 G
In the Fourteenth Judicial District Court, Parish of Calcasieu, State of Louisiana
Leon B. Brydels, Plaintiffs, vs. Conoco, Inc., et al., Defendants.
Case Number 2004-6941 Division A
In the District Court of Tarrant County, Texas, 153`d Judicial District
Linda Faust, Plaintiff, vs. Burlington Northern Santa Fe Rail Way Company, Witco Chemical Corporation
A/K/A Witco Corporation, Solvents and Chemicals, Inc. and Koppers Industries, Inc., Defendants.
Case Number 153-212928-05
Rosenfeld Deposition: December 2006, October 2007
Rosenfeld Trial: January 2008
In the Superior Court of the State of California in and for the County of San Bernardino
Leroy Allen, et al., Plaintiffs, vs. Nutro Products, Inc., a California Corporation and DOES 1 to 100,
inclusive, Defendants.
John Loney, Plaintiff, vs. James H. Didion, Sr., Nutro Products, Inc., DOES 1 through 20, inclusive,
Defendants.
Case Number VCVVSO44671
Rosenfeld Deposition: December 2009
Rosenfeld Trial: March 2010
In the United States District Court for the Middle District of Alabama, Northern Division
James K. Benefield, et al., Plaintiffs, vs. International Paper Company, Defendant.
Civil Action Number 2:09-cv-232-WHA-TFM
Rosenfeld Deposition: July 2010, June 2011
October 2015
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In the Superior Court of the State of California in and for the County of Los Angeles
Leslie Hensley and Rick Hensley, Plaintiffs, vs. Peter T. Hoss, as trustee on behalf of the Cone Fee Trust,
Plains Exploration & Production Company, a Delaware corporation, Rayne Water Conditioning, Inc., a
California Corporation, and DOES 1 through 100, Defendants.
Case Number SC094173
Rosenfeld Deposition: September 2008, October 2008
In the Superior Court of the State of California in and for the County of Santa Barbara, Santa Maria Branch
Clifford and Shirley Adelhelm, et al., all individually, Plaintiffs, vs. Unocal Corporation, a Delaware
Corporation; Union Oil Company of California, a California corporation, Chevron Corporation, a
California corporation; ConocoPhillips, a Texas corporation, Kerr-McGee Corporation, an Oklahoma
corporation; and DOES 1 though 100, Defendants.
Case Number 1229251 (Consolidated with case number 1231299)
Rosenfeld Deposition: January 2008
In the United States District Court for Eastern District of Arkansas, Eastern District of Arkansas
Harry Stephens Farms, Inc, and Harry Stephens, individual and as managing partner of Stephens
Partnership, Plaintiffs, vs. Helena Chemical Company, and Exxon Mobil Corp., successor to Mobil
Chemical Co., Defendants.
Case Number 2:06-CV-00166 JMM (Consolidated with case number 4:07CV00278 JMM)
Rosenfeld Deposition: July 2010
In the United States District Court for the Western District of Arkansas, Texarkana Division
Rhonda Brasel, et al., Plaint/is, vs. Weyerhaeuser Company and DOES 1 through 100, Defendants.
Civil Action Number 07-4037
Rosenfeld Deposition: March 2010
Rosenfeld Trial: October 2010
In the District Court of Texas 21 s° Judicial District of Burleson County
Dennis Davis, Plaintiff, vs. Burlington Northern Santa Fe Rail Way Company, Defendant.
Case Number 25,151
Rosenfeld Trial: May 2009
In the United States District Court of Southern District of Texas Galveston Division
Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and
on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.
Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants
Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
October 2015 10 Rosenfeld CV
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EXHIBIT 2
T 510,836.4200 1939 Harrison Street, Ste, 150
F 510,836.4205 Oakland, CA 94612
VIA E-MAIL AND OVERNIGHT MAIL
November 3, 2020
Mayor Miguel Pulido and
Members of the City Council
City of Santa Ana
Daisy Gomez, Clerk of the Council
20 Civic Center Plaza
Santa Ana,CA 92701
mpulido - santa-ana.org
dgomez@santa-ana.org.
eComments(a)santa-ana.org
Ali Pezeshkpour, AICP
Project Manager
Planning and Building Agency
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92702
APezeshkpour(aDsanta-ana.org
wwwlozeaudrury.com
rich artl@lozea u dru ry.ccm
Minh Thai, Executive Director
City of Santa Ana
Planning and Building Agency I M20
20 Civic Center Plaza
Santa Ana, CA 92702
mthai@santa-ana.org
Re: 4tn & Mortimer Project -- Housing Opportunity Ordinance
Mayor Pulido and Honorable Members of the City Council:
I am writing on behalf of the Supporters' Alliance for Environmental Responsibility
("SAFER"), a California non-profit organization with members living in and around the City
of Santa Ana, regarding the 4th & Mortimer Project, pro�osed to be located on two city
blocks at 409 East 4th Street (Block A), and 509 East 4t Street (Block B). ("Project"). This
letter addresses the Project's failure to comply with the Housing Opportunity Ordinance
("HOO"), Santa Ana Municipal Code sections 41-1900, et seq.
The HOO applies to the Project because the Project exceeds densities allowed by
current General Plan and zoning. As such the Project must provide inclusionary housing
for low-income residents. However, the Project includes only full market -rate housing and
provides no affordable housing and no in lieu payments for affordable housing. As such
the Project must be rejected for failure to comply with the HOO.
The HOO applies to "any new Residential Project located within the city, including
new construction, and condominium conversions which exceed the General Plan
prescribed densities." (Sec. 41-1902(a)). Section 41-1902(b) states:
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October 12, 2020
Page 2 of 2
The requirements of this Article shall apply to any new Residential Project
proposed in connection with an application to do any of the following:
(1) Increase the permitted residential density of the subject property above
the density permitted by applicable zoning at the time of the application.
The inclusionary requirement shall only apply to the incremental
increase in the number of units beyond that which is allowed by the
applicable zoning.
(2) Increase in the permitted residential density or percentage of residential
development allowed due to the City initiated zone changes after
November28, 2011." (Sec.41-1902(b))
Block B of the Project is inconsistent with the zoning, massing and density allowed
by the current General Plan and Zoning. The UN-2 zoning allows single-family duplexes,
triplexes and quadraplexes, courtyard housing and rowhouses. UN-2 does not allow
"lined block buildings" such as proposed by the Project. (Addendum 2-11). The Project
exceeds the massing allowed in the UN-2 zone and therefore requires a variance from
section 41-2023 of the zoning code. In particular, UN-2 requires that floors 3-5 of a
building may cover no more than 85% of the ground floor, but the project proposes 100%
coverage. (Addendum 2-11). The Project exceeds the density allowed in UN-2. UN-2
allows density of up to 50 dwelling units per acres, but the Project proposes 54 DU/acres.
(Addendum 3.6-5). For these reasons, the Project proposes to rezone the property from
UN-2 to Urban Center (UC).
Since the Project requires amendments to the zoning that will increase the
residential density allowed by the General Plan and Zoning code, the HOO applies to the
Project and the developer must be required to provide affordable housing. Since the
Project includes no affordable housing, it must be rejected by the City.
Richard Toshiyuki Drury
LOZEAU DRURY LLP
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EXHIBIT 3
Responses to Comments on the EIR Addendum
Responses to Comments on the EIR
Addendum
This section includes comments received during the circulation of the Environmental Impact Report
(EIR) Addendum prepared for the 4th and Mortimer Project (project). The EIR Addendum analyzes
changes to the previously approved Transit Zoning Code (hereafter referred to as the "approved
project" or "approved TZC"), for which the City of Santa Ana (City) certified a programmatic Final EIR
in 2010 (hereafter referred to as the "2010 FEIR").
The City received a public comment letter on the Addendum on October 12, 2020. The letter was
written by Richard Toshiyuki Drury (hereafter referred to as the "commenter") of Lozeau Drury LLP
on behalf of the Supporters' Alliance for Environmental Responsibility (SAFER), a California non-
profit organization.
The comment letter is included after the responses below and has been numbered sequentially and
each issue raised by the commenter has been assigned a number. The responses to each comment
identify first the number assigned to each issue. Response 1, for example, indicates that the
response is for the first issue raised in the comment letter.
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COMMENTER: Richard Toshiyuki Drury, Lozeau Drury LLP, on behalf of Supporters' Alliance for
Environmental Responsibility (SAFER)
DATE: October 12, 2020
Response 1
The commenter provides an introductory statement and notes that the comments on the
Addendum are submitted on behalf of SAFER and its members living near and around the City of
Santa Ana. The commenter states that the project is an entirely different project than the project
that was analyzed in the 2010 FEIR and requires a new EIR to analyze and mitigate the project's
impacts based on the project's: (1) consistency with the zoning, massing, land use, population
density analyzed in the 2010 FEIR; (2) exclusion of numerous mitigation measures required by the
2010 FEIR; (3) new and different environmental impacts that were not analyzed in the 2010 FEIR;
and (4) relation to the approved TZC which was determined in the 2010 FEIR to result in significant
an unmitigable environmental impacts.
This comment is a general introduction to the commenter's claims of how the project is different
from the approved project that was analyzed in the 2010 FEIR, how the Addendum is flawed, and
why the use of an Addendum in lieu of an EIR is inappropriate. The primary objective of the
approved TZC is to provide zoning for the integration of new infill development into existing
neighborhoods encompassing over 100 blocks and 450 acres in the central core of Santa Ana.
Specifically, the 2010 FEIR analyzed the potential development of 4,075 new residential units,
approximately 351,000 square feet (sf) of retail development, and the addition of new open space.
Since development in the TZC area has not exceeded these numbers, the proposed project is within
the development parameters that were analyzed under the 2010 FEIR and is consistent with the
type of project that was envisioned under the TZC.
Generally, an addendum to a previously certified EIR is prepared when a lead agency is asked to
issue a discretionary decision regarding a project, but none of the proposed actions meet the
conditions that trigger the need for a subsequent or supplemental EIR. As noted in the Addendum,
and pursuant to Public Resources Code (PRC) Section 21166 (Subsequent or Supplemental Impact
Report; Conditions) and CEQA Guidelines Section 15162(a) (Subsequent EIRs and Negative
Declarations), the proposed project did not require a subsequent or supplemental EIR or negative
declaration because the lead agency determined, through environmental review, that none of the
following conditions triggered the need for these environmental documents:
(1) Substantial changes are proposed in the project which will require major revisions of the
previous EIR or negative declaration due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant effects;
(2) Substantial changes would occur with respect to the circumstances under which the project is
undertaken which will require major revisions of the previous EIR or negative declaration due to
the involvement of new significant environmental effects or a substantial increase in the
severity of previously identified significant effects; or
(3) New information of substantial importance, which was not known and could not have been
known with the exercise of reasonable diligence at the time the previous EIR was certified as
complete or the negative declaration was adopted, shows any of the following:
A. The project will have one or more significant effects not discussed in the previous EIR or
negative declaration;
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B. Significant effects previously examined will be substantially more severe than shown in the
previous EIR;
C. Mitigation measures or alternatives previously found not to be feasible would in fact be
feasible and would substantially reduce one or more significant effects of the project, but
the project proponents decline to adopt the mitigation measure or alternative; or
D. Mitigation measures or alternatives which are considerably different from those analyzed in
the previous EIR would substantially reduce one or more significant effects on the
environment, but the project proponents decline to adopt the mitigation measure or
alternative.
According to CECtA Guidelines Section 15164 (Addendum to an EIR or Negative Declaration), the
lead agency shall prepare an addendum if none of the conditions specified in CEQA Guidelines
Section 15162 are met. Primarily, Section 3, Environmental Impact -Analysis, of the Addendum
supports the conclusion that changes to the proposed project would not result in new or more
severe impacts than those of the approved project disclosed in the previously certified 2010 FEIR
and would not require a major revision to the 2010 FEIR. The Addendum also includes applicable
mitigation measures identified in the 2010 FEIR. Therefore, the City is within its discretion to
proceed with an addendum as the appropriate environmental document for the project under
CECA. In addition, the comment does not provide any specific examples of where analysis within
the Addendum is inadequate, where additional information is needed, what mitigation measures
are excluded, or what impacts are new and different than those analyzed in the 2010 FEIR. The
commenter does provide additional detail to their claims further into the comment letter and,
therefore, individual responses to each claim are provided based on order of appearance
throughout the remaining responses of this section.
Response 2
The commenter identifies experts that have reviewed the project, including certified Industrial
Hygienist, Francis "Bud" Offermann, PE, CIH; and Dr. Paul Rosenfeld, Ph.D. and Matthew Hagemann,
C. Hg. of Soil Water Air Protection Enterprise (SWAPE). The commenter generally states that these
experts have identified significant impacts associated with the project's air quality impacts and have
identified omissions and flaws in the documents relied upon by City Staff.
This comment and the identified experts' separate analyses, which are attached as Exhibits A and B
to the comment letter, are acknowledged but do not raise specific concerns regarding the project's
air quality impacts or other alleged flaws in the Addendum and associated documents. Responses to
the commenter's concerns based on the findings of Mr. Offermann and SWAPE are provided in
Responses 10 through 12 and Response 18, respectively, of this section.
Response 3
The commenter states that use of an addendum instead of an EIR or supplemental EIR deprived the
public from a public review period and other circulation requirements associated with EIRs. On
behalf of SAFER, the commenter asks that the City not adopt the Addendum or otherwise approve
the project and, instead, direct City Staff to prepare an EIR for public review circulation and
comment prior to approval.
As described in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CEC1A
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Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Although
the project did not require a public review period (per CEQA Guidelines Section 15164(c)), the
project was presented to the public during a Planning Commission meeting held on October 12,
20201 and the Addendum and 2010 FEIR are considered by the City in making a decision about the
project. Furthermore, although not required under an addendum, the City is responding to this
public comment letter and any other public comments related to the project.
Response 4
The commenter summarizes the proposed project, including the project's location, zoning, massing,
density, and associated discretionary actions. In particular, the commenter summarizes the project's
inconsistency with the Urban Neighborhood 2 subzone (UN-2) requirements studied in the 2010
FEIR.
This comment is an introduction and summary of the project and does not pertain to the adequacy
of the environmental analysis in the Addendum.
Response 5
The commenter provides a summary of CEQA requirements through references to case law and
statutes related to use of an addendum and tiering an analysis under CEQA.
The intent of this comment is to provide a regulatory background and does not pertain to the
adequacy of the EIR Addendum.
Response 6
The commenter states that CEQA requires the City to prepare a tiered EIR, which is governed by
CEQA Guidelines Section 15152 (Tiering) of the CEQA Guidelines, instead of an addendum, which is
governed by CEQA Guidelines Sections 15162 and 15164. The commenter notes that the 2010 FEIR
states "This EIR will be used to tier subsequent environmental analysis for future development
included within the Transit Zoning Code boundaries, as allowed by Section 15152 of the CEQA
Guidelines."
As described in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CECA
Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Therefore,
the City is within its discretion to proceed with an addendum as the appropriate environmental
document for the project under CEQA.
Response 7
The commenter states that, based on references to case law (i.e., Friends of College of San Mateo
Gardens v. San Mateo County Community College Dist. (2016) 1 Cal.5th 937, 944) and subsequent
Supreme Court rulings, that subsequent review provisions under CEQA are dependent on the
determination that the original environmental document retains "some informational value"
despite the proposed changes. The commenter adds that the City cannot claim that the 2010 FEIR
retains informational value or addresses the project's impacts since the project exceeds the density
I
Planning Commission Agenda. Monday, October 12, 2020. Open Meeting.
httos://santaana.granicus.com/GeneratedAgendaViewer.K)ho?view id=2&clip id=2999.
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and massing originally analyzed in the 2010 FEIR. The commenter concludes that the project is a
new project that has not undergone CEQA review and "must start from the beginning of the CEQA
process" with an initial study prior to approval.
The 2010 FEIR retains both relevance and informational value to the proposed project. Courts may
only reject an agency's use of a previously certified EIR if it is "wholly irrelevant." As discussed in
Response 1, Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion
that changes to the project would not result in new or more severe impacts than those of the
approved project previously disclosed in the 2010 FEIR and would not require a major revision to
the 2010 FEIR. Therefore, the City shall proceed with an addendum as the appropriate
environmental document for the project under CEQA.
Response 8
The commenter summarizes the 2010 FEIR's significant and unavoidable impacts (i.e., those related
to Aesthetics, Air Quality, Cultural Resources, Noise, and Traffic) and, based on a reference to case
law, adds that the City is required to conduct project -level supplemental EIRs for specific projects
proposed in the program area to analyze and determine whether mitigation measures exist to
reduce these significant and unavoidable impacts.
As described in Response 1, the project does not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CEQA
Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Although
the 2010 FEIR identified significant and unavoidable impacts, the question is whether the project
analyzed in an addendum would result in new or more severe impacts than those of the approved
project. Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that
changes to the project would not result in new or more severe impacts, including those related to
Aesthetics, Air Quality, Cultural Resources, Noise, and Traffic, with implementation of applicable
mitigation measures identified in the 2010 FEIR and included in the Addendum discussion. Appendix
K to the Addendum includes the Mitigation Monitoring and Reporting Program (MMRP) of the 2010
FEIR for reference.
Response 9
The commenter states that, even if addendum provisions under CEQA applied to the project, a
supplemental EIR would still be required to analyze new significant impacts of the project resulting
from changes to the approved project and new impacts that were not analyzed in the 2010 FEIR.
As described in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CEQA
Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Primarily,
Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that changes to
the project would not result in new or more severe impacts than those of the approved project
previously disclosed in the 2010 FEIR and would not require a major revision to the 2010 FEIR.
Therefore, the City is within its discretion to proceed with an addendum as the appropriate
environmental document for the project under CECA.
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Response 10
The commenter provides an introduction to Industrial Hygienist, Francis "Bud" Offermann, PE, CIH,
and describes that, based on Mr. Offermann's findings, many composite wood products typically
used in modern home construction contain formaldehyde -based glues which off -gas formaldehyde.
The comment asserts that there is a fair argument that residents of the project will be exposed to a
cancer risk from formaldehyde between 112 and 180 per million, above the South Coast Air Quality
Management District (SCAQMD) CEQA significance threshold for airborne cancer risk of 10 per
million. The commenter further asserts that, even if the project uses modern California Air
Resources Board (CARB)-compliant materials, formaldehyde will create a cancer risk more than
10 times above the CEQA significance threshold and requests the implementation of mitigation
measures to reduce this risk.
The comment does not describe how the formaldehyde related cancer risk of between 112 and
180 per million would occur and does not identify any project -specific conditions (other than the
fact that the project's construction may use wood building materials) that would lead to impacts.
Current federal and State regulations limit the potential formaldehyde emissions from building
materials. On June 1, 2018, the United States Toxic Substances Control Act (TSCA) Title VI was
implemented, which requires that composite wood products sold, supplied, offered for sale,
manufactured, or imported in the United States meet new emission standards for formaldehyde
from composite wood products in order to reduce exposures to formaldehyde and avoid adverse
health effects. Typical composite wood products include hardwood plywood, medium -density
fiberboard, and particleboard, as well as household and other finished goods containing these
products. The new emission limits include the following:
Hardwood Plywood: 0.05 parts per million (ppm)
Particleboard: 0.09 ppm
Medium -density fibreboard: 0.11 ppm
Thin Medium -density fibreboard: 0.13 ppm
These emission levels were determined to be in compliance with and result in less exposure (e.g.,
daily intake) than the California Proposition 65 safe harbor level for formaldehyde (40 micrograms
[[ig]/day), which is based on Proposition 65's risk criterion of 1 in 100,000. Therefore, products
manufactured to TSCA Title VI and California Proposition 65 safe harbor standards, which is now
required by the United States Environmental Protection Agency (USEPA) for all products
manufactured or imported into the United States, would not generate formaldehyde emissions that
would exceed the SCAQMD significance threshold of 10 per million. The CalGreen Building Code also
includes similar formaldehyde limits for building products. By law, project construction materials
would have to comply with these formaldehyde requirements, as all products manufactured or
imported in the United States are required to meet these regulations.
Furthermore, according to the United States National Library of Medicine's Hazardous Substances
Database, formaldehyde is readily biodegradable and complete degradation of formaldehyde can be
accomplished in less than 30 days, and formaldehyde in the air can be degraded in less than four
days. Most, if not all, formaldehyde residue in furniture can be expected to be off -gassed and
released shortly after it is manufactured (i.e., 30 days after manufacture), meaning that the amount
of formaldehyde residue in furniture and indoor air would be expected to approach zero within
30 days. Cancer effects are produced following extensive, long-term exposures for usually more
than seven years. Wood -pressed furniture would not have enough formaldehyde to off -gas for that
length of time (or any length of time generally exceeding five days).
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Building material manufacturer compliance with existing regulations combined with the
characteristics of formaldehyde would limit the potential of human health and cancer risks to a less
than significant level pursuant to the SCAQMD significance threshold of 10 per million. Therefore,
health risks related to formaldehyde, including impacts associated with the project, would not result
in a new significant impact.
Response 11
The commenter restates Mr. Offermann's conclusion that the significant formaldehyde impact
should be analyzed in an EIR and mitigation measures should be implementation to reduce the risk
of formaldehyde exposure. The commenter lists a few of Mr. Offermann's recommended mitigation
measures, such as requiring the use of no -added -formaldehyde composite wood products, requiring
air ventilation systems that would reduce formaldehyde levels.
As described in Response 10, the project would not exceed SCAQMD significance thresholds for
formaldehyde. The project would be implemented pursuant to existing formaldehyde requirements,
as all products manufactured or imported in the United States are required to meet these
regulations. Application of these mandatory regulations would limit the potential of human health
and cancer risks and avoid impacts related to formaldehyde. Therefore, no new significant impact
would occur, and new mitigation measures related to formaldehyde are not necessary for the
proposed project.
Response 12
The commenter states that the City has a duty to investigate issues relating to a project' s potential
environmental impacts, particularly those impacts raised by an expert's comments and those
impacts on a project's users or residents that arise from the project's effects on the environment.
The commenter states that the carcinogenic formaldehyde emissions identified by Mr. Offermann
are not an existing environmental condition, rather those emissions would be a result from
implementation of the project and are required to be addressed in the CEQA process. The
commenter adds that the Addendum fails to disclose, analyze, or mitigate these new significant
impacts.
As discussed in Response 10, the project would be implemented pursuant to formaldehyde
requirements, as all products manufactured or imported in the United States are required to meet
these regulations. This would limit the potential of human health and cancer risks to a less than
significant level pursuant to the SCAQMD significance threshold of 10 per million. As described in
Response 10, the project would not exceed SCAQMD significance thresholds for formaldehyde and
no new impact would occur.
Response 13
The commenter summarizes the project's inconsistencies with the current UN-2 zone and
associated zone change and variance, and states that these inconsistences with the zoning code and
designations are significant impacts under CEQA that require analysis and mitigation in a
supplemental EIR. The commenter states that these impacts were not analyzed in the 2010 FEIR
since it was assumed that future projects would comply with the designated zoning and land use
laws.
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As discussed in Response 7, to support the use of the 2010 FEIR and that the 2010 FEIR retains
relevance and has informational value, the City may rely on evidence of the similarities in the
project to the approved project analyzed in the 2010 FEIR. Section 3, Environmental Impact Analysis,
of the Addendum supports the conclusion that changes to the project (e.g., associated zone change
and variance) would not result in new or more severe impacts than those of the approved project
previously disclosed in the 2010 FEIR and would not require a major revision to the 2010 FEIR.
Rather, with approval of the zone change and variance, the proposed project would comply with the
setback, parking, landscaping, massing and floor area ratio requirements of the approved TZC. As
noted in the 2010 FEIR, the TZC was found to initially conflict with the Santa Ana General Plan by
adopting standards and land uses not previously allowed in the proposed TZC area. However, as
part of the approved TZC, the General Plan was amended to incorporate the proposed land uses and
development standards and provide consistency between the General Plan and the TZC. With
approval of the requested discretionary actions, the proposed project would also be consistent with
the local land designation and development standards. Therefore, the City is within its discretion to
proceed with an addendum as the appropriate environmental document for the project under
CEQA.
Response 14
The commenter states that the project would have a significant impact to historic resources due to
the demolition of the Santa Ana Car Salon located at 509-515 East 4th Street, which is listed on the
Built Environment Resources Directory (BERD) for Orange County.
As discussed in Section 3.3, Cultural Resources and Tribal Cultural Resources, of the Addendum,
Rincon also referenced the National Register of Historic Places (NRHP), California Register of
Historical Resources (CRHR), California Points of Historical Interest (PHI) and Landmarks lists,
California Office of Historic Preservation Archaeological Determinations of Eligibility (ADOE), and
Santa Ana Register of Historic Properties (RHP) in addition to the BERD for Orange County. Review
of the NRHP, CRHR, PHI and Landmark Lists, ADOE and the Santa Ana RHP were negative for the
project site. The comment is correct in that review of the BERD identified the on -site Santa Ana Car
Salon as previously recorded and found locally eligible as a historic resource in 1980. However, the
resource record for this property was also not identified through the CHRIS records searches. While
the Santa Ana Car Salon was an example of the Western False Front Style in Santa Ana at the time it
was recorded in 1980, the area surrounding the property was surveyed again in 2006 and the
property was not identified as potentially eligible at that time. The property's historical significance
was reexamined as part of the Cultural Resources Study conducted for the project dated April 2019,
which is included as Appendix C to the Addendum. The Cultural Resources Study found that, since
its last recordation, the property has been significantly altered such that it no longer embodies a
particular architectural style. Therefore, it is ineligible for listing in the NRHP, CRHR and on the City
of Santa Ana RHP and does not qualify as a historical resource as defined by CECA. The project
would not have an impact to historic resources due to the demolition of the Santa Ana Car Salon
and no impact would occur that would require preparation of an EIR.
Response 15
The commenter states that 2010 FEIR requires a case -by -case historic analysis for future projects
conducted by a historic resource expert and adds that no such historic resource analysis was done
for the project due to "constraints surrounding COVID-19."
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As discussed in Response 14, a Cultural Resources Study was conducted for the project in April 2019
in accordance with CEQA and is included as Appendix C to the Addendum. The Cultural Resources
Study was specifically prepared in accordance with the requirements of Mitigation Measure 4.4-3
from the 2010 FEIR and guidelines outlined by the Office of Historic Preservation. An independent
CHRIS records search was not completed for the current project due to "constraints surrounding
COVID-19" given the adequate coverage provided by the previous searches. However, other efforts
included background and archival research, a Native American Heritage Commission (NAHC) Sacred
Lands File (SLF) search, a field survey of the project site, the evaluation of one property for historical
significance, and a discussion of potential project -related impacts which found that no new impact
to historic resources would occur.
Response 16
The commenter states that, since the City failed to implement mitigation measures required by the
2010 FEIR, the City has failed to proceed in a manner required by law and a subsequent EIR is
required. The commenter specifies that the project would have significant impacts to a historic
resource and, because the City failed to comply with mitigation measures required by the 2010 FEIR,
a supplemental EIR is required to analyze the project.
As described in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CEQA
Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Section 3,
EnvironmentallmpactAnalysis, of the Addendum supports the conclusion that changes to the
project would not result in new or more severe impacts and includes applicable mitigation measures
identified in the 2010 FEIR. Appendix K to the Addendum includes the MMRP of the 2010 FEIR for
reference to applicable mitigation measures. Furthermore, as discussed in Response 14, the Santa
Ana Car Salon is ineligible for listing in the NRHP, CRHR and on the City of Santa Ana RHP and does
not qualify as a historical resource as defined by CEQA. The project would not result in a new or
significant impact to historic resources.
Response 17
The commenter states that, in addition to the historic resources mitigation measure in the 2010
FEIR, the City failed to implement mitigation measures related to energy conservation, greenhouse
gas emissions, and air quality. The commenter specifies that the 2010 FEIR requires projects to
exceed Title 24 energy standards by 20 percent, whereas the project would only comply with Title
24 and not exceed it. The commenter restates that, because the City failed to comply with
mitigation measures required by the 2010 FEIR, a supplemental EIR is required to analyze the
project.
As discussed in Response 14, the Santa Ana Car Salon is ineligible for listing in the NRHP, CRHR and
on the City of Santa Ana RHP and does not qualify as a historical resource as defined by CEQA.
Therefore, the project would not have an impact to historic resources and no mitigation is required.
As described in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CECIA
Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Section 3,
Environmental Impact Analysis, of the Addendum supports the conclusion that changes to the
project would not result in new or more severe impacts related to energy conservation, greenhouse
gas emissions, and air quality and includes applicable mitigation measures identified in the 2010
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FEIR. With respect to Title 24, the project is required to comply with the standards set by the 2010
FEIR to minimize the wasteful, inefficient, or unnecessary consumption of energy resources during
project operation.
Response 18
The commenter states that, based on conclusions from Dr. Paul Rosenfeld, Ph.D. and Matthew
Hagemann, C. Hg, P.G. of the environmental consulting firm SWAPE, the Addendum's air quality
analysis is flawed due to unsubstantiated input parameters used estimate the project's air quality
emissions. The commenter adds that SWAPE concluded that the project would create a cancer risk
from airborne pollution of up to 210 per million — over 20 times above the SCAQMD significance
threshold of 10 per million. The commenter states that SWAPE also calculated significance
greenhouse gas impacts associated with the project. The commenter concludes that the Addendum
fails to implement all feasible mitigation measures to reduce the project's air quality emissions and
adds that an EIR is required to analyze and mitigate the project's significant air quality and
greenhouse gas emissions impacts.
According to the Air Quality Assessment conducted for the project, which is included as Appendix B
to the Addendum, emissions were modeled using the California Emissions Estimator Model version
2016.2.3 (CalEEMod). CalEEMod is a Statewide land use emissions computer model designed to
quantify potential criteria pollutant emissions associated with both construction and operations
from a variety of land use projects. Air quality impacts were adequately assessed according to
methodologies recommended by CARB and the SCAQMD. Regulatory measures that apply to the
project include compliance with SCAQMD Rules 402 and 403 (prohibition of nuisances, watering of
inactive and perimeter areas, track out requirements, etc.) and SCAQMD Rule 1113 (low -Volatile
Organic Compound paint) and were included in CalEEMod. Furthermore, the air quality and
greenhouse gas emissions associated with the project and reported in the Addendum conservatively
do not take credit for the emissions currently associated with the existing uses that would be
removed.
As discussed in the Air Quality Assessment and Section 3.2, Air Quality, of the Addendum,
construction would result in the generation of diesel particulate matter (DPM) emissions from the
use of off -road diesel equipment. The amount to which the receptors are exposed (a function of
concentration and duration of exposure) is the primary factor used to determine health risk (i.e.,
potential exposure to Toxic Air Contaminant [TAC] emission levels that exceed applicable
standards). Health -related risks associated with diesel -exhaust emissions are primarily linked to
long-term exposure and the associated risk of contracting cancer. The use of diesel trucks would be
most prevalent during the temporary construction period of the project rather than during
operation of the project. Current models and methodologies for conducting health risk assessments
are associated with longer -term exposure periods of 9, 30, and 70 years, which do not correlate well
with the temporary and highly variable nature of construction activities. DPM emissions from the
21-month construction period of the project would represent a range of 2.5 to 19.4 percent of the
typical exposure duration used in health risk assessments. The closest sensitive receptors are
located adjacent to the site, approximately 55 feet from the project site boundary. Project
construction involves phased activities in several areas across the site and the project would not
require the extensive use of heavy-duty equipment or diesel trucks in any one location over the
duration of construction, which would limit the exposure of any proximate individual sensitive
receptor to TACs. The project would not result in a significant cancer risk from airborne pollution. As
such, Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that
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changes to the project would not result in new or more severe impacts related to air quality or
greenhouse gas emissions and includes applicable mitigation measures identified in the 2010 FOR.
Response 19
The commenter states that any changes to a project's circumstances or the addition of new
substantial information subsequent to the certification of an EIR for a project requires that an
agency prepare a subsequent or supplemental EIR if the changes are "substantial" and require
"major revisions" to the previous EIR. The commenter concludes that the project considered by the
2010 FEIR has undergone significant changes and requires revisions to the 2010 FEIR.
As described in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions (i.e., does not meet CEQA's definition of a
"substantial change") described in PRC Section 21166 and CEQA Guidelines Sections 15162 and
15164 were met to trigger the need for these documents. Primarily, Section 3, Environmental
Impact Analysis, of the Addendum supports the conclusion that changes to the project would not
result in new or more severe impacts than those of the approved project previously disclosed in the
2010 FEIR and would not require a major revision to the 2010 FEIR. Therefore, the City is within its
discretion to proceed with an addendum as the appropriate environmental document for the
project under CEQA.
Response 20
The commenter states that an EIR is require because the: (1) project's increase in massing and
density and associated zone change and variance are a substantial change from the approved
project, and (2) the Addendum failed to include a historic resource analysis.
As discussed in Response 13, Section 3, Environmental Impact Analysis, of the Addendum supports
the conclusion that changes to the project (e.g., associated zone change and variance) would not
result in new or more severe impacts than those of the approved project previously disclosed in the
2010 FEIR and would not require a major revision to the 2010 FEIR. Rather, with approval of the
zone change and variance, the proposed project would comply with the setback, parking,
landscaping, massing and floor area ratio requirements of the approved TZC. Furthermore, as
discussed in Responses 14 and 15, a Cultural Resources Study was conducted for the project in April
2019 in accordance with CEQA and is included as Appendix C to the Addendum.
Response 21
The commenter reiterates the conclusion of Mr. Offermann that the project would result in a
significant air quality impact related to formaldehyde for residential occupants of the project. The
commenter adds that this impact is new when compared to the 2010 FEIR because the science in
this area did not exist until 2015 and states that the City violated CEQA by not preparing an EIR to
analyze and mitigate this new impact.
As described in Response 10, the project would not exceed SCAQMD significance thresholds for
formaldehyde. The project would be implemented pursuant to existing formaldehyde requirements,
as all products manufactured or imported in the United States would be required to meet these
regulations. Application of these mandatory regulations would limit the potential of human health
and cancer risks and avoid impacts related to formaldehyde.
75C-295
City of Santa Ana
4th and Mortimer Project
Response 22
The commenter states that the City's decision to prepare an addendum instead of an EIR is not
supported by evidence and adds that approval of the project based on the Addendum would
constitute an abuse of the City's discretion. The commenter also states that the City may not rely on
the 10-year 2010 FEIR and requests that the Planning Commission decline to recommend the City
Council approval of the Addendum and, instead, direct Planning Staff to prepare and circulate an EIR
for public review.
As discussed in Response 1, the project did not require a subsequent or supplemental EIR or
negative declaration because none of the conditions described in PRC Section 21166 and CEQA
Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Primarily,
Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that changes to
the project would not result in new or more severe impacts than those of the approved project
previously disclosed in the 2010 FEIR and would not require a major revision to the 2010 FEIR.
Therefore, the City is within its discretion to proceed with an addendum as the appropriate
environmental document for the project under CEQA. Furthermore, as discussed in Response 7, to
support the use of the 2010 FEIR and that the 2010 FEIR retains relevance and has "some
informational value," the City may rely on evidence of the similarities in the project to the approved
project analyzed in the 2010 FEIR, and does not have to necessarily show that the impacts from the
project were analyzed in the 2010 FEIR or that the 2010 FEIR adequately analyzed the approved
project with the proposed changes under current CEQA standards.
75C-296
T 510.836.4200 I 1939 Harrison Street, Ste. 150 www.lozeaudrury.com
F 510.836.4205 Oakland, CA 94612 richard@lozeaudrury.com
VIA E-MAIL AND US MAIL
October 12, 2020
Chair Mark McLoughlin
and Commissioners
Planning Commission
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92702
eComments(asanta-ana.org
Ali Pezeshkpour, AICP
Project Manager
Planning and Building Agency
City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92702
APezeshkpour(c)santa-ana.org
Minh Thai, Executive Director
City of Santa Ana
Planning and Building Agency I M20
20 Civic Center Plaza
Santa Ana, CA 92702
mthai@santa-ana.org
Re: Comment on EIR Addendum for 4th & Mortimer Project (SCH NO.
2006071100)
Chair McLoughlin and Members of the Planning Commission:
I am writing on behalf of the Supporters' Alliance for Environmental Responsibility
("SAFER"), a California non-profit organization with members living in and around the City
of Santa Ana, regarding the 4th & Mortimer Project, proposed to be located on two city
blocks at 409 East 4th Street (Block A), and 509 East 4th Street (Block B). ("Project"). Staff
contends that the potential environmental effects of the Project have been fully addressed
by the Transit Zoning Code Environmental Impact Report certified a decade ago in 2010
("2010 EIR"). Fundamentally, the proposed Project is an entirely different project than
was analyzed in 2010 EIR ("2010 Project"). The proposed Project is inconsistent with the
zoning, massing and land use analyzed in the 2010 EIR, and therefore requires zone
changes. The proposed Project includes greater massing and higher population density
than analyzed in the 2010 EIR. Also the Proposed Project fails to incorporate numerous
mitigation measures required by the 2010 EIR. The Proposed Project will have several
new and different environmental impacts that were not analyzed in the 2010 EIR. Finally,
the 2010 EIR recognized that the 2010 Project would have many significant and
unmitigated environmental impacts. As such a new draft EIR is required to analyze and
mitigate the impacts of the proposed Project.
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A number of highly qualified experts have reviewed the proposed Project and its
environmental effects. Certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH,
and Dr. Paul Rosenfeld, Ph.D. and Matthew Hagemann, C. Hg. of environmental
consulting firm Soil Water Air Protection Enterprise ("SWAPE") have identified a number
of significant impacts from the proposed Project including air quality impacts, as well as
omissions and flaws in the documents relied upon by staff. These comments are attached
as Exhibits A and B.
By opting to proceed with an Addendum instead of the required EIR or
supplemental EIR ("SEIR"), the City of Santa Ana ("City") has deprived the members of
the public of the public review and circulation requirement available for EIRs. SAFER
urges the Commission not to adopt the Addendum or approve the Project, and instead to
direct staff to prepare a Draft EIR for the Project, and to circulate the Draft EIR for public
review and comment prior to Project approval.
PROJECT DESCRIPTION
The Project involves a residential and commercial development that would consist
of 169 residential units and 11,361 square feet of commercial retail space on two city
blocks, 409 East 4th Street (Block A) and 509 East 4th Street (Block B).
The City attempts to rely on a decade -old EIR certified in 2010 for the Transit
Zoning Code ("TZC"). The TZC area covers over 100 blocks and 450 acres in the central
core of Santa Ana. Under the TZC, Block A is currently zoned as "District Center -
Downtown subzone," and Block B is zoned as "Urban Neighborhood 2 subzone" (UN-2).
Block B is inconsistent with the zoning, massing and density studied in the 2010
EIR. The UN-2 zoning allows single-family duplexes, triplexes and quadraplexes,
courtyard housing and rowhouses. UN-2 does not allow "lined block buildings" such as
proposed by the Project. (Addendum 2-11). The Project exceeds the massing allowed in
the UN-2 zone and therefore requires a variance from section 41-2023 of the zoning
code. In particular, UN-2 requires that floors 3-5 of a building may cover no more than
85% of the ground floor, but the project proposes 100% coverage. (Addendum 2-11).
The Project exceeds the density allowed in UN-2. UN-2 allows density of up to 50
dwelling units per acres, but the Project proposes 54 DU/acres. (Addendum 3.6-5). For
these reasons, the Project proposes to rezone the property from UN-2 to Urban Center
(UC).
LEGAL STANDARD
2
3
0
CEQA contains a strong presumption in favor of requiring a lead agency to prepare
an EIR. This presumption is reflected in the fair argument standard. Under that standard,
a lead agency must prepare an EIR whenever substantial evidence in the whole record 5
before the agency supports a fair argument that a project may have a significant effect on
the environment. Pub. Res. Code § 21082.2; Laurel Heights Improvement Ass'n v.
Regents of the University of California (1993) ("Laurel Heights II") 6 Cal. 4th 1112, 1123;
75C-298
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No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 82; Quail Botanical Gardens
v. City of Encinitas (1994) 29 Cal.AppAth 1597, 1602.
A. Addendum Standard.
The City relies on CEQA Guidelines § 15162 and 15164 to claim that no CEQA
review is required. The court of appeal recently stated, "The addendum is the other side
of the coin from the supplement to an EIR. This section provides an interpretation with a
label and an explanation of the kind of document that does not need additional public
review." "It must be remembered that an addendum is prepared where '(2) Only minor
technical changes or additions are necessary to make the EIR under consideration
adequate under CEQA; and (3) The changes to the EIR made by the addendum do
not raise important new issues about the significant effects on the environment.'
([Guideline] 15164, subd. (a).)" Save Our Heritage Org. v. City of San Diego, 28 Cal.
App. 5th 656, 664-65 (2018) (emphasis added).
Section 15164(a) of the State CEQA Guidelines states that "the lead agency or a
responsible agency shall prepare an addendum to a previously certified EIR if some
changes or additions are necessary, but none of the conditions described in Section
15162 calling for preparation of a subsequent EIR have occurred." Pursuant to Section
15162(a) of the State CEQA Guidelines, a subsequent EIR or Negative Declaration is
only required when:
(1) Substantial changes are proposed in the project which will require major revisions
of the previous EIR or negative declaration due to the involvement of new
significant environmental effects or a substantial increase in the severity of
previously identified significant effects;
(2) Substantial changes occur with respect to the circumstances under which the
project is undertaken which will require major revisions of the previous EIR or
Negative Declaration due to the involvement of new significant environmental
effects or a substantial increase in the severity of previously identified significant
effects; or
(3) New information of substantial importance, which was not known and could not
have been known with the exercise of reasonable diligence at the time the
previous EIR was certified as complete or the negative declaration was adopted,
shows any of the following:
(A) The project will have one or more significant effects not discussed in the
previous EIR or negative declaration;
(B) Significant effects previously examined will be substantially more severe than
shown in the previous EIR;
(C) Mitigation measures or alternatives previously found not to be feasible would,
in fact, be feasible and would substantially reduce one or more significant
effects of the project, but the project proponents decline to adopt the mitigation
measure or alternative; or
(D) Mitigation measures or alternatives which are considerably different from those
analyzed in the previous EIR would substantially reduce one or more
5
cont.
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significant effects on the environment, but the project proponents decline to
adopt the mitigation measure or alternative.
B. Tiering Under CEQA
CEQA permits agencies to 'tier' EIRs, in which general matters and environmental
effects are considered in an EIR "prepared for a policy, plan, program or ordinance
followed by narrower or site -specific [EIRs] which incorporate by reference the discussion
in any prior [EIR] and which concentrate on the environmental effects which (a) are
capable of being mitigated, or (b) were not analyzed as significant effects on the
environment in the prior [EIR]." (Cal. Pub. Res. Code ("PRC") § 21068.5.) "[T]iering is
appropriate when it helps a public agency to focus upon the issues ripe for decision at
each level of environmental review and in order to exclude duplicative analysis of
environmental effects examined in previous [EIRs]." (PRC § 21093.) The initial general
policy -oriented EIR is called a programmatic EIR ("PEIR") and offers the advantage of
allowing "the lead agency to consider broad policy alternatives and program wide
mitigation measures at an early time when the agency has greater flexibility to deal with
basic problems or cumulative impacts." (14 CCR §15168.) CEQA regulations strongly
promote tiering of EIRs, stating that "[EIRs] shall be tiered whenever feasible, as
determined by the lead agency." (PRC § 21093.)
"Subsequent activities in the program must be examined in light of the program 5
EIR to determine whether an additional environmental document must be prepared." (14
CCR § 15168(c).) The first consideration is whether the activity proposed is covered by Cont.
the PEIR. Id. If a later project is outside the scope of the program, then it is treated as a
separate project and the PEIR may not be relied upon in further review. (Sierra Club v.
County of Sonoma (1992) 6 Cal.App.4th 1307.) The second consideration is whether the
"later activity would have effects that were not examined in the program EIR." (14 CCR §§
15168(c)(1).) A PEIR may only serve "to the extent that it contemplates and adequately
analyzes the potential environmental impacts of the project." (Sierra Nevada
Conservation v. County of El Dorado (2012) 202 Cal.AppAth 1156). If the PEIR does not
evaluate the environmental impacts of the project, a tiered EIR must be completed before
the project is approved. (Id.)
For these inquiries, the "fair argument test" applies. (Sierra Club, 6 Cal.AppAth
1307, 1318; see also Sierra Club v. County of San Diego (2014) 231 Cal.AppAth 1152,
1164 ("when a prior EIR has been prepared and certified for a program or plan, the
question for a court reviewing an agency's decision not to use a tiered EIR for a later
project 'is one of law, i.e., the sufficiency of the evidence to support a fair argument."').)
Under the fair argument test, a new EIR must be prepared "whenever it can be fairly
argued on the basis of substantial evidence that the project may have significant
environmental impact. (Id. at 1316 [quotations omitted].) When applying the fair argument
test, "deference to the agency's determination is not appropriate and its decision not to
require an EIR can be upheld only when there is no credible evidence to the contrary."
(Sierra Club, 6 Cal. App. 4th at 1312.) "[I]f there is substantial evidence in the record that
the later project may arguably have a significant adverse effect on the environment which
was not examined in the prior program EIR, doubts must be resolved in favor of
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environmental review and the agency must prepare a new tiered EIR, notwithstanding the 5
existence of contrary evidence." (Sierra Club, 6 Cal.App.4th at 1319.)
cont.
DISCUSSION
A. CEQA REQUIRES THE CITY TO PREPARE A TIERED EIR FOR THE PROJECT
INSTEAD OF AN ADDENDUM
The City has incorrectly applied the CEQA criteria for preparing an addendum
when, instead, the City should have applied CEQA's tiering provisions. The City relies on
CEQA Guidelines section 15164, which applies to preparing an addendum to an existing
EIR for a project. However, the 2010 EIR was not a project -specific EIR, which the CEQA
Guidelines define as an "EIR[which] examines the environmental impacts of a specific
development project." (14 CCR § 15161.) Rather, the 2010 EIR was a comprehensive
policy and regulatory guidance document for the private use and development of all
properties within the TZC area. Tiering is governed by CEQA Guidelines section 15152,
not sections 15162 and 15164.
The 2010 EIR made clear that the City was relying on CEQA's tiering provisions. It
states, "This EIR will be used to tier subsequent environmental analysis for future
development included within the Transit Zoning Code boundaries, as allowed by
Section 16162 of the CEQA Guidelines." (2010 DEIR 2-4). There is no question that
the 2010 TZC EIR was intended as a first tier CEQA document, and that second tier
CEQA documents would be required for specific project proposals. The 2010 EIR states
that it will "provide a basis for the preparation of subsequent environmental
documentation for future development within the Transit Zoning Code area." (2010 DEIR
2-1). Thus the 2010 EIR clearly contemplated that specific projects would be subject to 6
"subsequent environmental documentation." The 2010 EIR states, "the Transit Zoning
Code does not constitute a commitment to any specific project ... Thus, the EIR will
analyze these future actions at a programmatic level. Each future development
proposal undertaken within the Transit Zoning Code must be approved individually
by the City, as appropriate, in compliance with CEQA." (2020 DEIR 2-2). Despite
these clear assurances that the 2010 EIR was a programmatic EIR and that project -
specific environmental review would be required for individual projects, the City is now
attempting to avoid the very project -specific review that is promised the public in 2010.
The 2010 EIR is a Program EIR, which the CEQA Guidelines define as:
An EIR which may be prepared on a series of actions that can be characterized as
one large project and are related either:
(1) Geographically,
(2) As logical parts in the chain of contemplated actions,
(3) In connection with issuance of rules, regulations, plans, or other general criteria
to govern the conduct of a continuing program, or
(4) As individual activities carried out under the same authorizing statutory or
regulatory authority and having generally similar environmental effects which can
be mitigated in similar ways.
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(14 CCR § 15168.) Thus, instead of proceeding under the provisions of CEQA Guidelines
section 15164, the City should have proceeded under section 15152 provisions for
subsequent analysis for a Program EIR rather than an addendum to an existing project -
specific EIR.
B. THE 2010 EIR HAS NO INFORMATIONAL VALUE TO THE PROJECT.
As the California Supreme Court explained in San Mateo Gardens, subsequent
CEQA review provisions "can apply only if the project has been subject to initial
review; they can have no application if the agency has proposed a new project that
has not previously been subject to review." Friends of College of San Mateo Gardens
v. San Mateo, 1 Cal.5th 937, 950 (2016) ("San Mateo Gardens"); see also, Mattis Camp
Cmty. Assn v. Cty. of Placer, 53 Cal. App. 5th 569 (2020). As the Supreme Court
explains, "[a] decision to proceed under CEQA's subsequent review provisions must thus
necessarily rest on a determination — whether implicit or explicit — that the original
environmental document retains some informational value." Id. at 951 (emph. added).
Only if the original environmental document retains some informational value despite the
proposed changes, changes in circumstances or new substantial information does the
agency proceed to decide under CEQA's subsequent review provisions whether such
changes or substantial new information will require major revisions to the original
environmental document because of the involvement of new, previously unconsidered
significant environmental effects. 1 Cal.5th at 952. Reviewing the 2010 EIR, the City
cannot reasonably claim that it addresses the Project that exceeds the density and
massing analyzed in the 2010 EIR.
Since the Project exceeds the density and massing analyzed in the 2010, and
requires a variance, it has never undergone CEQA review, it is a new project, and the City
must start from the beginning of the CEQA process under section 21151, conduct an
initial study, and determine whether there is substantial evidence of a fair argument that
the project will have a significant environmental impact. Friends of College of San Mateo
Gardens v. San Mateo, 1 Cal.5th at 951. The City Council should require CEQA review
for the Project, and not approve the Project until CEQA review is completed.
C. A TIERED EIR IS REQUIRED TO ANALYZE AND MITIGATE SIGNIFICANT
UNAVOIDABLE IMPACTS IDENTIFIED IN THE 2010 EIR.
The 2010 EIR admitted that the program would have significant unavoidable
impacts in the areas of:
• Aesthetics: shadows. (2010 DEIR 1-11)
• Air Quality:
inconsistency with 2007 Air Quality Management Plan;
• construction emissions exceed significance thresholds;
• mobile source emissions of VOC, NOx, CO and PM-10 exceed significance
thresholds;
no
cont.
7
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construction and operation emissions are cumulatively considerable in
excess of significance thresholds for VOC, NOx, CO and PM-10. (2010
DEIR 1-11).
• Cultural Resources: The TZC area includes historic buildings and an historic
district. "The feasibility of retaining a historic structure/resource is determined on a
case -by -case basis." (2010 DEIR 1-12).
• Noise: significant noise and vibration from pile -driving and nearby rail operations.
(2010 DEIR 1-12).
• Traffic: Significant traffic impacts, includoing at the 1-5 northbound off -ramp at
Santa Ana Blvd. to an unacceptable level of service. (2010 DEIR 1-12).
Since the overall program will have significant unavoidable impacts, the City must
conduct project -level supplemental EIRs for specific projects proposed within the program
area. The supplemental EIRs are required to determine whether mitigation measures
exist to reduce the significant unavoidable impacts identified in the 2010 EIR.
In the case of Communities for a Better Environment v. Cal. Resources Agency
(2002) 103 Cal.App.4th 98, 122-125, the court of appeal held that when a "first tier" EIR
admits a significant, unavoidable environmental impact, then the agency must prepare
second tier EIRs for later phases of the project to ensure that those unmitigated impacts
are "mitigated or avoided." (Id. citing CEQA Guidelines §15152(f)) The court reasoned
that the unmitigated impacts were not "adequately addressed" in the first tier EIR since
they were not "mitigated or avoided." (Id.) Thus, significant effects disclosed in first tier
EIRs will trigger second tier EIRs unless such effects have been "adequately addressed,"
in a way that ensures the effects will be "mitigated or avoided." (Id.) Such a second tier
EIR is required, even if the impact still cannot be fully mitigated and a statement of
overriding considerations will be required. The court explained, "The requirement of a
statement of overriding considerations is central to CEQA's role as a public accountability
statute; it requires public officials, in approving environmental detrimental projects, to
justify their decisions based on counterbalancing social, economic or other benefits, and
to point to substantial evidence in support." (Id. at 124-125) The court specifically
rejected a prior version of the CEQA guidelines regarding tiering that would have allowed
a statement of overriding considerations for a program -level project to be used for a later
specific project within that program. (Communities for a Better Env't v. California Res.
Agency (2001) 103 Cal.App.4th 98, 124, disapproved on other grounds by Berkeley
Hillside Pres. v. City of Berkeley (2015) 60 Cal.4th 1086.) Even though "a prior EIR's
analysis of environmental effects may be subject to being incorporated in a later EIR for a
later, more specific project, the responsible public officials must still go on the record and
explain specifically why they are approving the later project despite its significant
unavoidable impacts." (Id., pp. 124-25.)
cont.
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D. THE ADDENDUM'S CONCLUSIONS ARE NOT SUPPORTED BY
SUBSTANTIAL EVIDENCE AND THERE IS SUBSTANTIAL EVIDENCE OF A
FAIR ARGUMENT THAT THE PROJECT WILL HAVE SIGNIFICANT
ENVIRONMENTAL IMPACTS.
Even if the addendum provisions applied to the Project (which they do not), a
supplemental EIR would be required to analyze new significant impacts of the Project 9
resulting from changes to the 2010 Project and new impacts that were not analyzed in the
2010 EIR.
1. There is Substantial Evidence that the Project Will Result in
Significant Indoor Air Quality Impacts.
Certified Industrial Hygienist, Francis "Bud" Offermann, PE, CIH, has conducted a
review of the proposed Project and relevant documents regarding the Project's indoor air
emissions. Indoor Environmental Engineering Comments (Exhibit A). Mr. Offerman
concludes that it is likely that the Project will expose future residents of the Project's
residential units to significant impacts related to indoor air quality, and in particular,
emissions of the cancer -causing chemical formaldehyde. Mr. Offermann is one of the
world's leading experts on indoor air quality and has published extensively on the topic.
See attached CV.
Mr. Offermann explains that many composite wood products typically used in
modern home construction contain formaldehyde -based glues which off -gas
formaldehyde over a very long time period. He states, "The primary source of
formaldehyde indoors is composite wood products manufactured with urea -formaldehyde
resins, such as plywood, medium density fiberboard, and particle board. These materials
are commonly used in building construction for flooring, cabinetry, baseboards, window
shades, interior doors, and window and door trims." Offermann Comment, pp. 2-3.
10
Mr. Offermann states:
Indoor air quality in homes is particularly important because occupants, on
average, spend approximately ninety percent of their time indoors with the majority
of this time spent at home (EPA, 2011). Some segments of the population that are
most susceptible to the effects of poor IAQ, such as the very young and the
elderly, occupy their homes almost continuously. Additionally, an increasing
number of adults are working from home at least some of the time during the
workweek.
Offermann Comment, p. 1.
Formaldehyde is a known human carcinogen. Mr. Offermann states that there is a
fair argument that residents of the Project will be exposed to a cancer risk from
formaldehyde of between 112 and 180 per million. (Offermann Comment, pp. 2-3.) This
is far above the South Coast Air Quality Management District (SCAQMD) CEQA
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significance threshold for airborne cancer risk of 10 per million. Even if the Project uses
modern "CARB-compliant" materials, Mr. Offermann concludes that formaldehyde will
create a cancer risk more than ten times above the CEQA significance threshold.
Offermann Comment, p. 3. Mr. Offermann concludes that this significant environmental
impact should be analyzed in an EIR and mitigation measures should be imposed to
reduce the risk of formaldehyde exposure.
Mr. Offermann concludes that this significant environmental impact should be
analyzed in an EIR and mitigation measures should be imposed to reduce the risk of
formaldehyde exposure. Id., pp. 4. Mr. Offermann identifies mitigation measures that are
available to reduce these significant health risks, including the installation of air filters and
a requirement that the applicant use only composite wood materials (e.g. hardwood
plywood, medium density fiberboard, particleboard) for all interior finish systems that are
made with CARB approved no -added formaldehyde (NAF) resins or ultra -low emitting
formaldehyde (ULEF) resins in the buildings' interiors. Offermann Comments, pp. 11-12
The City has a duty to investigate issues relating to a project's potential
environmental impacts, especially those issues raised by an expert's comments. See Cty.
Sanitation Dist. No. 2 v. Cty. of Kern, (2005) 127 Cal.App.4th 1544, 1597-98 ("under
CEQA, the lead agency bears a burden to investigate potential environmental impacts").
In addition to assessing the Project's potential health impacts to residents and workers,
Mr. Offermann identifies the investigatory path that the City should be following in
developing an EIR to more precisely evaluate the Project's future formaldehyde
emissions and establishing mitigation measures that reduce the cancer risk below the
SCAQMD level. Offermann Comments, pp. 5-9. Such an analysis would be similar in form
to the air quality modeling and traffic modeling typically conducted as part of a CEQA
review.
The failure to address the project's formaldehyde emissions is contrary to the
California Supreme Court's decision in California Building Industry Ass'n v. Bay Area Air
Quality Mgmt. Dist. (2015) 62 Cal.4th 369, 386 ("CBIA"). At issue in CBIA was whether
the Air District could enact CEQA guidelines that advised lead agencies that they must
analyze the impacts of adjacent environmental conditions on a project. The Supreme
Court held that CEQA does not generally require lead agencies to consider the
environment's effects on a project. CBIA, 62 Cal.4th at 800-801. However, to the extent a
project may exacerbate existing adverse environmental conditions at or near a project
site, those would still have to be considered pursuant to CEQA. Id. at 801 ("CEQA calls
upon an agency to evaluate existing conditions in order to assess whether a project could
exacerbate hazards that are already present"). In so holding, the Court expressly held
that CEQA's statutory language required lead agencies to disclose and analyze
"impacts on a project's users or residents that arise from the project's effects on the
environment." Id. at 800 (emphasis added).)
The carcinogenic formaldehyde emissions identified by Mr. Offermann are not an
existing environmental condition. Those emissions to the air will be from the Project.
Residents will be users of the residential units, and employees will be users of the hotel
and offices. Currently, there is presumably little if any formaldehyde emissions at the site.
75C-305
10
cont.
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Once the Project is built, emissions will begin at levels that pose significant health risks.
Rather than excusing the City from addressing the impacts of carcinogens emitted into
the indoor air from the project, the Supreme Court in CBIA expressly finds that this type of
effect by the project on the environment and a "project's users and residents" must be
addressed in the CEQA process.
The Supreme Court's reasoning is well-grounded in CEQA's statutory language.
CEQA expressly includes a project's effects on human beings as an effect on the
environment that must be addressed in an environmental review. "Section 21083(b)(3)'s
express language, for example, requires a finding of a 'significant effect on the
environment' (§ 21083(b)) whenever the 'environmental effects of a project will cause
substantial adverse effects on human beings, either directly or indirectly."' CBIA, 62
Cal.4th at 800 (emphasis in original). Likewise, "the Legislature has made clear —in
declarations accompanying CEQA's enactment —that public health and safety are of great
importance in the statutory scheme." Id., citing e.g., §§ 21000, subds. (b), (c), (d), (g),
21001, subds. (b), (d). It goes without saying that the thousands of future residents and
employees at the Project are human beings and the health and safety of those workers is
as important to CEQA's safeguards as nearby residents currently living near the project
site.
The Addendum fails to disclose, analyze, or mitigate these new significant impacts.
Because Mr. Offermann's expert review is substantial evidence of a fair argument of a
significant environmental impact to future users of the project, an EIR must be prepared
to disclose and mitigate those impacts.
2. The Project Will Have Significant Impacts Due to Inconsistencies
with the Planning and Zoning Code.
The proposed Project exceeds massing and density allowed by the zoning code.
Urban Neighborhood zone (UN-2) allows single-family, duplexes, triplexes, and
quadplexes, courtyard housing and rowhouses. The Project is much more intense than
quadplexes. UN-2 does not permit Lined Block buildings, such as the Project. (Addendum
2-11). The Project requires a variance for massing since Zoning Code section 41-2023
requires floors 3-5 may occupy no more than 85% of ground floor, but the Project
proposes 100% coverage. (Addedum 2-11). The UN-2 zone allows density up to 50
dwelling units per acre, but this Project has 54 DU/acre. (Addendum 3.6-5).
These inconsistencies with the zoning code and zoning designations are significant
impacts under CEQA that must be analyzed and mitigated in a supplemental EIR. Of
course, these impacts were not analyzed in the 2010 EIR since that document assumed
that future projects would comply with the designated zoning and land use laws.
Where a local or regional policy of general applicability, such as an ordinance, is
adopted in order to avoid or mitigate environmental effects, a conflict with that policy in
itself indicates a potentially significant impact on the environment. (Pocket Protectors v.
Sacramento (2005) 124 Cal.App.4th 903.) Indeed, any inconsistencies between a
proposed project and applicable plans must be discussed in an EIR. (14 CCR §
12
cont.
W]
75C-306
4th and Mortimer CEQA Addendum
October 12, 2020
Page 11 of 15
15125(d); City of Long Beach v. Los Angeles Unif. School Dist. (2009) 176 Cal. App. 4th
889, 918; Friends of the Eel River v. Sonoma County Water Agency (2003) 108 Cal. App.
4th 859, 874 (EIR inadequate when Lead Agency failed to identify relationship of project
to relevant local plans).) A Project's inconsistencies with local plans and policies
constitute significant impacts under CEQA. (Endangered Habitats League, Inc. v. County
of Orange (2005) 131 Cal.App.4th 777, 783-4, 32 Cal.Rptr.3d 177; see also, County of El
Dorado v. Dept. of Transp. (2005) 133 Cal.App.4th 1376 (fact that a project may be
consistent with a plan, such as an air plan, does not necessarily mean that it does not
have significant impacts).) Californians for Alternatives to Toxics v. Department of Food
and Agriculture (2005) 136 Cal.App.4th 1, 17 ("[c]ompliance with the law is not enough to
support a finding of no significant impact under the CEQA."). The recent Georgetown
Preservation Society v. County of El Dorado (2018) 30 Cal.App.5th 358 echoes Pocket
Protectors. These both apply the fair argument standard to a potential inconsistency with
a plan adopted for environmental protection. Protect the Historic Amador Waterways v.
Amador Water Agency (2004) 116 Cal.App.4th 1099 holds that an EIR needs to analyze
any topic for which a fair argument of significant impact is raised.
Since the proposed Project is inconsistent with the zoning code, and requires a
zone change and variance, it will have significant impacts that must be analyzed in a
tiered EIR. These impacts were not analyzed in the 2010 EIR.
3. The Project Will Have Significant Impacts to Historic Resources.
The proposed Project may have significant impacts to historic resources, and the
City has failed to implement applicable mitigation measures from the 2010 EIR with
respect to this impact. The downtown zone is a National Historic District (2010 DEIR 1-5).
The 2010 DEIR required development to be "context -sensitive infill development." (Id.)
The Addendum admits that the Project site includes a historically significant building on
the Built Environment Resources Directory ("BERD") database. (Addendum 3.3-3). The
historic building is the Santa Ana Car Salon, located at 509-515 East 41h Street.
(Addendum Appendix C, Cultural Resources, p.3, 8). The historic resource is a "rare
example of the Western False Front Style in Santa Ana." (Id.) This historic building will
be demolished as part of the Project, and the Project will therefore have adverse impacts
on an historic resource.
13
cont.
101
The 2010 EIR required a case -by -case historic analysis for future projects, and
required that for each project an historic resource expert must be retained to conduct an 15
analysis and to suggest measures to minimize impacts. (2010 DEIR 1-24). However, no
such historic resource analysis was done for the Project due to "constraints surrounding
COVID-19." (Addendum 3.1-1).
Since the City has failed to implement mitigation measures required by the 2010
EIR, a subsequent EIR is required. If the agency fails to implement mitigation measures
required by a prior EIR, this requires CEQA review, even for an otherwise ministerial 16
project. Katzeff v. Dept. of Forestry (2010) 181 Cal.App.4th 601, 611, 614; Lincoln Place
Tenants v. City of Los Angeles (2005) 130 Cal.App.4th 1491, 1507-1508. The purpose of
this requirement "is to ensure that feasible mitigation measures will actually be
75C-307
4th and Mortimer CEQA Addendum
October 12, 2020
Page 12 of 15
implemented as a condition of development, and not merely adopted and then neglected
or disregarded." Federation of Hillside and Canyon Associations v. City of Los Angeles
(2000) 83 Cal.App.4th 1252, 1260-1261. The decision to abandon an adopted mitigation
measure is a discretionary decision.
An agency fails proceed in a manner required by law when it fails to comply with
adopted CEQA mitigation measures. Lincoln Place, 130 Cal.AppAth at 1508, 1510
("[h]aving placed these conditions ... the city cannot simply ignore them. Mitigating
conditions are not mere expressions of hope ... [i]n the present case the city failed to
proceed according to law ..."). "[T]his rule is applicable even if one of the smaller parts
might require only ministerial, rather than discretionary, approval." Katzeff, 181
Cal.AppAth at 611; Lincoln Place, 130 Cal.AppAth 1491, 1507 n22 ("it cannot be argued
CEQA does not apply to the ... demolition on the ground the demolition permits are
ministerial acts.")
Since the Project may have significant impacts to historic resources, and the City
has failed to comply with mitigation measures required by the 2010 EIR, a supplemental
EIR is required to analyze this impact.
4. The Project Fails to Implement Mitigation Measures Required by the
2010 EIR.
The Project fails to implement several mitigation measures required by the 2010
EIR. As discussed above, the failure to implement mitigation measures set forth in a prior
EIR itself requires preparation of a supplemental EIR.
In addition to the historic resources mitigation measure, the Addendum fails to
implement energy conservation and greenhouse gas mitigation measure 4.2-22, which
requires projects to exceed Title 24 energy standards by 20%. (2010 DEIR 1-18).
However, the Addendum fails to implement this measure, since the Project will merely
comply with Title 24, not exceed Title 24 by 20%.
The 2010 EIR included numerous air quality mitigation measures that are not
required in the Addendum for the Project. (2010 EIR 1-18, MM 4.2-21, 4.2-22). The
failure to implement these mitigation measures requires preparation of a supplemental
EIR.
5. The Project Will Have Significant Adverse Air Quality and
Greenhouse Gas Impacts.
16
cont.
17
We submit herewith the comments of Dr. Paul Rosenfeld, Ph.D. and Matthew
Hagemann, C. Hg, P.G. of the environmental consulting firm SWAPE. They conclude
that the Addendum's air quality analysis is riddled with errors due to unsubstantiated input 18
parameters used to estimate Project emissions. (SWAPE 1). Correcting for these errors,
SWAPE concludes that the Project will create a cancer risk from airborne pollution of up
to 210 per million. (SWAPE 18). This is over twenty times above the South Coast Air
75C-308
4th and Mortimer CEQA Addendum
October 12, 2020
Page 13 of 15
Quality Management District (SCAQMD) CEQA significance threshold of 10 per million.
SWAPE also calculates that the Project will have significant greenhouse gas impacts.
(SWAPE 23). SWAPE concludes that the Addendum fails to impose all feasible
mitigation measures to reduce the Project's air quality impacts.
Exceedance of Air District thresholds establishes a significant impact under CEQA.
Indeed, in many instances, such air quality thresholds are the only criteria reviewed and
treated as dispositive in evaluating the significance of a project's air quality impacts. See,
e.g. Schenck v. County of Sonoma (2011) 198 Cal.App.4th 949, 960 (County applies
BAAQMD's "published CEQA quantitative criteria" and "threshold level of cumulative
significance"). See also Communities fora Better Environment v. California Resources
Agency (2002) 103 Cal.App.4th 98, 110-111 ("A 'threshold of significance' for a given
environmental effect is simply that level at which the lead agency finds the effects of the
project to be significant"). The California Supreme Court recently made clear the
substantial importance that a BAAQMD significance threshold plays in providing
substantial evidence of a significant adverse impact. Communities for a Better
Environment v. South Coast Air Quality Management Dist. (2010) 48 CalAth 310, 327
("As the [South Coast Air Quality Management] District's established significance
threshold for NOx is 55 pounds per day, these estimates [of NOx emissions of 201 to 456
pounds per day] constitute substantial evidence supporting a fair argument for a
significant adverse impact").
An EIR is required to analyze and mitigate the Project's significant air quality and
greenhouse gas impacts.
E. EVEN IF THE 2010 EIR WERE STILL RELEVANT TO THE PROJECT, A
SUPPLEMENTAL OR SUBSEQUENT EIR IS NECESSARY BECAUSE
SUBSTANTIAL CHANGES WILL RESULT IN NEW AND MORE SIGNIFICANT
ENVIRONMENTAL IMPACTS.
Even assuming that the 2010 EIR had some relevance to evaluating the
environmental impacts of this Project, numerous substantial changes in the development
plans have occurred such as the increase in massing and density, new information of
substantial importance has arisen, and substantial changes in circumstances have taken
place that require a wholesale revision of the dated 2010 EIR.
When changes to a project's circumstances or new substantial information comes
to light subsequent to the certification of an EIR for a project, the agency must prepare a
subsequent or supplemental EIR if the changes are "[s]ubstantial" and require "major
revisions" of the previous EIR. Friends of Coll. of San Mateo Gardens v. San Mateo Cty.
Cmty. Coll. Dist. (2016) 1 Cal.5th 937, 943. "[W]hen there is a change in plans,
circumstances, or available information after a project has received initial approval, the
agency's environmental review obligations "turn[ ] on the value of the new information to
75C-309
18
Cont.
19
4th and Mortimer CEQA Addendum
October 12, 2020
Page 14 of 15
the still pending decisionmaking process." Id., 1 Cal.5th at 951-52. The agency must
"decide under CEQA's subsequent review provisions whether project changes will require
major revisions to the original environmental document because of the involvement of
new, previously unconsidered significant environmental effects." Id., 1 Cal.5th at 952.
Section 21166 and CEQA Guidelines § 15162 "do[] not permit agencies to avoid their
obligation to prepare subsequent or supplemental EIRs to address new, and previously
unstudied, potentially significant environmental effects." Id., 1 Cal.5th at 958.
The evidence indicates that the project considered by the 2010 EIR has undergone
significant changes to the project and its circumstances requiring substantial revisions to
that 10-year old EIR.
A. A New EIR is Required Because the Increase in Massing and Density is a
Substantial Change from the 2010 Project and there is Substantial
Evidence that the Project Will Result in Emissions of Formaldehyde to the
Air that Will Have a Significant Health Impact on Future Residents.
Even if the 201 EIR were somehow relevant to the current Project, the City would
still be required to prepare an SEIR. The increase in massing and density, the failure to
conduct a historic resource analysis, and zoning changes and variances required as part
of the Project is a substantial change from the 2010 project. "The purpose behind the
requirement of a subsequent or supplemental EIR or negative declaration is to explore
environmental impacts not considered in the original environmental document." Friends
of College of San Mateo Gardens v. San Mateo (2016) 1 Cal.5th 937, 949 (quoting Save
Our Neighborhood v. Lishman (2006) 140 Cal.AppAth 1288, 1296). For example, in the
case of Ventura Foothill Neighbors, a mere increase in the height of a building by 15 feet
required a supplemental EIR, not an addendum. Ventura Foothill Neighbors v. Cty. of
Ventura, 232 Cal. App. 4th 429 (2014).
As discussed above, the expert opinion of Mr. Offermann constitutes substantial
evidence that the residential component of the Project will result in a significant air quality
impact to residential occupants of the Project. This impact is significant and new. It could
not have been known in 2010 because the science in this area did not exist until 2015.
Accordingly, the City violated CEQA by not preparing an SEIR to analyze and mitigate
this new significant impact.
There is no substantial evidence in the record to support a conclusion that the
Project will not have a new significant indoor air quality impact as a result of significant
changes to the Project when compared to the project analyzed in the 2010 EIR.
ILei
cont.
%8411
21
Accordingly, the City's decision to prepare an Addendum rather than an SEIR is not
supported by substantial evidence, and approval of the Project based on the Addendum
would constitute an abuse of discretion.
22
CONCLUSION
For the above and other reasons, the Planning Commission should decline to
recommend the City Council approve the Addendum, and instead direct Planning Staff to
75C-310
4th and Mortimer CEQA Addendum
October 12, 2020
Page 15 of 15
prepare and circulate an EIR for public review. The City may not rely on the 10-year old 22
2010 EIR. cont.
Sincerely,
Richard Toshiyuki Drury
LOZEAU DRURY LLP
75C-311
EXHIBIT 4
LS 12.1.20
RESOLUTION NO. 2020-xx
A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF SANTA ANA DENYING APPEAL
APPLICATION NO. 2020-02 AND UPHOLDING
THE DETERMINATION OF THE PLANNING
COMMISSION TO APPROVE AN ADDENDUM
TO THE ENVIRONMENTAL IMPACT REPORT
FOR THE TRANSIT ZONING CODE PROJECT
(SCH NO. 2006071100) AND ADOPTION OF A
MITIGATION MONITORING AND REPORTING
PROGRAM FOR SITE PLAN REVIEW NO. 2020-
03 AND VARIANCE NO. 2020-06 FOR A NEW
MIXED -USE RESIDENTIAL AND COMMERCIAL
DEVELOPMENT FOR THE PROPERTIES
LOCATED AT 409 EAST FOURTH STREET
(SITE A) AND 509 EAST FOURTH STREET
(SITE B)
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTA ANA AS
FOLLOWS:
Section 1. The City Council of the City of Santa Ana hereby finds, determines
and declares as follows:
A. On October 12, 2020, the Planning Commission of the City of Santa Ana
held a duly noticed public hearing to consider various entitlements
including Site Plan Review No. 2020-03, Variance No. 2020-06, and
Amendment Application 2020-04 to allow the construction of a new mixed -
use residential and commercial development consisting of 169 residential
rental units and 11,361 square feet of commercial space at 409 and 509
East Fourth Street. After receiving public testimony on the item, the
Planning Commission voted unanimously (7:0) to adopt a resolution
approving an Addendum to the Environmental Impact Report (EIR) for the
Transit Zoning Code Project, mitigation monitoring and reporting program,
Site Plan Review No. 2020-03 as conditioned, and Variance No. 2020-06
as conditioned. In addition, the Planning Commission recommended that
the City Council adopt a resolution approving an Addendum to the
Environmental Impact Report for the Transit Zoning Code Project,
mitigation monitoring and reporting program, and an ordinance approving
Amendment Application No. 2020-04 for Specific Development No. 84
(SD84).
B. On October 22, 2020, Michael Lozeau with Lozeau Drury, LLP, on behalf
of the Supporters Alliance for Environmental Responsibility (SAFER)
hereinafter referred to as "Appellant', submitted an appeal application
Resolution No. 2020-xx
Page 1 of 7
75C-312
pursuant to Section 41-645 of the Santa Ana Municipal Code (SAMC)
requesting that the City Council reconsider the Planning Commission's
decision based on the following reasons:
California Environmental Quality Act (CEQA) compliance.
Specifically, the Appellant states that the "City failed to comply with
the CEQA by failing to prepare a project -specific EIR for the
project";
The Appellant states that, "The City failed to comply with the
Housing Opportunity Ordinance (HOO) by failing to require the
developer to include affordable housing units in the project"; and
III. The Appellant states that, "The Planning Commission abused its
discretion by failing to read or consider comments submitted by
SAFER."
C. Pursuant to SAMC Section 41-645 (a), appeals can only be made on a
decision or requirement made by the Planning Commission. Of the above -
mentioned appeal reasons, the only action taken by the Planning
Commission was the action to adopt a resolution approving the addendum
to the EIR for the TZC. The subsequent appeal items do not satisfy the
requirements of SAMC Section 41-645 (a) and should not be considered
as part of the appeal:
No decision or action was taken by the Planning Commission
regarding the HOO requirements because the HOO did not apply to
the project; and
Consideration of a public comment letter received does not
constitute "a decision or requirement made by the Planning
Commission".
Nonetheless, a comprehensive response and findings are provided below
on all appeal items received.
D. On December 1, 2020, the City Council conducted a duly noticed public
hearing on Appeal Application No. 2020-02 and found that:
The City complied with the California Environmental Quality Act (CEQA)
requirements by preparing an addendum to the previously certified 2010
Transit Zoning Code Environmental Impact report (EIR). CEQA does
permit the use of an addendum when the original EIR being relied upon
was a Program EIR. Public Resources Code Section 21166 and State
CEQA Guidelines Section 15162 clearly establish when an agency must
prepare a Supplemental or Subsequent EIR, and when an agency is
permitted instead to prepare an Addendum. If an agency determines
that one of the conditions described in Public Resources Code section
Resolution No. 2020-xx
Page 2 of 7
75C-313
21166 or State CEQA Guidelines section 15162 is present, the agency
must prepare either a Subsequent EIR or a Supplemental EIR. When
none of those conditions are present, but it is necessary to make
changes to a previous EIR, the agency may prepare an addendum. This
process applies regardless of whether the original EIR is a Program or
Project EIR. Nothing in State CEQA Guidelines section 15152
(describing the process for utilizing a Supplemental or Subsequent EIR
or negative declaration) prohibits use of an addendum where none of
the conditions of Public Resources Code section 21166 or State CEQA
Guidelines section 15162 are present. Nothing in State CEQA
Guidelines sections 15162 or 15164 prohibit use of an addendum where
the original EIR is a Program, and not a Project, EIR.
As established in these sections of the Public Resources Code and the
State CEQA Guidelines, one of the circumstances described in Public
Resources Code section 21166 or State CEQA Guidelines section
15162 must be present before either a Subsequent or Supplemental
EIR is required. Here, none of those conditions are present. These
conditions are:
Substantial changes are proposed which will require major
revisions of the previous EIR due to the involvement of new
significant environmental effects or a substantial increase in
the severity of previously identified significant effects;
ii. Substantial changes occur with respect to the circumstances
under which the project is undertaken which will require major
revisions of the previous EIR due to the involvement of new
significant effects or a substantial increase in the severity of
previously identified significant effects; or
iii. New information has come to light showing new impacts,
substantially more severe impacts, that mitigation measures
or alternatives previously found to be infeasible would actually
be feasible, or that mitigation measures or alternatives
previously not identified would reduce impacts.
This is also consistent with CEQA Guidelines section 15152(f), which
the Appellant incorrectly claims prohibits use of addenda when the
original EIR is a Program EIR. Section 15152(f) states, "A later EIR
shall be required when the initial study or other analysis finds that the
later project may cause significant effects on the environment that were
not adequately addressed in the prior EIR." For the subject project, the
"other analysis" (including technical studies and the text of the
Addendum) found that no additional significant effects would occur
beyond those already addressed in the 2010 EIR. An addendum is
therefore the appropriate CEQA document.
Resolution No. 2020-xx
Page 3 of 7
75C-314
II. That the City has complied with the Housing Opportunity Ordinance
(HOO) requirements. The HOO does not apply to the project because
the project does not exceed the residential density permitted in the
General Plan. As recently amended, the HOO only applies when a
project requires a General Plan Amendment.
The Appellant's comment letter cites to an outdated and superseded
version of Section 41-1902(b)(1). The HOO was amended on
September 1, 2020, and the comment letter does not reflect the
amended language. While previously, Section 41-1902(b)(1) applied the
HOO to any project that exceeded the maximum density permitted by
zoning, the recent amendments remove this reference. As amended,
the HOO now only applies when a residential project proposes a
residential density above the General Plan permitted density. The 4th
and Mortimer Mixed -Use Development project is consistent with the
General Plan. No General Plan Amendment is required for the Project.
The Project seeks only a zone change, on only a portion of the project
site. No density allowance above that currently permitted by the site's
General Plan designation is proposed. Therefore, the HOO does not
apply.
III. The Planning Commission did not abuse its discretion and did consider
comments submitted by Lozeau Drury, LLP, on behalf of SAFER. The
Planning Commission considered Mr. Drury's public comment and
received input from the City Attorney and the City's environmental
consultant regarding the whether the addendum prepared for the project
was the appropriate document. Both the City Attorney and the
consultant were confident that no subsequent CEQA analysis was
required for the project other than the addendum which was prepared.
Again, this was based on the fact that the technical studies evidenced
that an EIR Addendum to the previously -certified 2010 EIR was the
appropriate CEQA document to evaluate and disclose the project's
impacts. Therefore, the Planning Commission did consider Mr. Drury's
comments and concerns but agreed with staffs recommendation that
the addendum was the appropriate environmental document.
Section 2. The City Council, after hearing, considering and weighing all
evidence in the record presented on behalf of all parties and being fully informed of the
application, the Planning Commission's decision, and the appeal, hereby finds and
determines that the Planning Commission's decision was not made in error, that the
Planning Commission's decision was not an abuse of discretion by the Planning
Commission and that the Planning Commission's decision was supported by substantial
evidence in the record.
Section 3. In accordance with the California Environmental Quality Act
(CEQA), the Planning Commission of the City of Santa Ana hereby finds, determines,
and declares as follows:
Resolution No. 2020-xx
Page 4 of 7
75C-315
Based on the substantial evidence set forth in the record, including but not
limited to the Environmental Impact Report (EIR) for the Transit Zoning Code Project
(SCH NO. 2006071100) and the 2020 4'h and Mortimer Mixed -Use Development EIR
Addendum, the City Council finds that an addendum is the appropriate document for
disclosing the changes to the subject properties, and that none of the conditions
identified in Public Resources Code section 21166 and State CEQA Guidelines
section 15162 requiring subsequent environmental review have occurred, because:
A. The project does not constitute a substantial change that would require major
revisions of the 2010 EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously
identified significant effects.
B. There is not a substantial change with respect to the circumstances under which
the project will be developed that would require major revisions of the 2010 EIR
due to the involvement of new significant environmental effects or a substantial
increase in the severity of the previously identified significant effects.
C. New information of substantial importance has not been presented that was not
known and could not have been known with the exercise of reasonable
diligence at the time the 2010 EIR was certified or adopted, showing any of the
following: (i) that the modifications would have one or more significant effects
not discussed in the earlier environmental documentation; (ii) that significant
effects previously examined would be substantially more severe than shown in
the earlier environmental documentation; (iii) that mitigation measures or
alternatives previously found not to be feasible would in fact be feasible and
would substantially reduce one or more significant effects, but the Applicant
declined to adopt such measures; or (iv) that mitigation measures or
alternatives considerably different from those analyzed previously would
substantially reduce one or more significant effects on the environment, but
which the Applicant declined to adopt.
Further, the City Council finds that, pursuant to State CEQA Guidelines Section 15164,
only minor changes or additions to the 2010 EIR are necessary to address the proposed
project. In making this finding, the City Council has considered both the Addendum and
the certified, final 2010 EIR.
Section 4. The Applicant shall indemnify, protect, defend and hold the City
and/or any of its officials, officers, employees, agents, departments, agencies,
authorized volunteers, and instrumentalities thereof, harmless from any and all claims,
demands, lawsuits, writs of mandamus, and other and proceedings (whether legal,
equitable, declaratory, administrative or adjudicatory in nature), and alternative dispute
resolution procedures (including, but not limited to arbitrations, mediations, and such
other procedures), judgments, orders, and decisions (collectively "Actions"), brought
against the City and/or any of its officials, officers, employees, agents, departments,
agencies, and instrumentalities thereof, that challenge, attack, or seek to modify, set
aside, void, or annul, any action of, or any permit or approval issued by the City and/or
Resolution No. 2020-xx
Page 5 of 7
75C-316
any of its officials, officers, employees, agents, departments, agencies, and
instrumentalities thereof (including actions approved by the voters of the City) for or
concerning the project, whether such Actions are brought under the Ralph M. Brown
Act, California Environmental Quality Act, the Planning and Zoning Law, the Subdivision
Map Act, Code of Civil Procedure sections 1085 or 1094.5, or any other federal, state or
local constitution, statute, law, ordinance, charter, rule, regulation, or any decision of a
court of competent jurisdiction. It is expressly agreed that the City shall have the right to
approve, which approval will not be unreasonably withheld, the legal counsel providing
the City's defense, and that Applicant shall reimburse the City for any costs and
expenses directly and necessarily incurred by the City in the course of the defense.
City shall promptly notify the Applicant of any Action brought and City shall cooperate
with Applicant in the defense of the Action.
Section 5. The City Council of the City of Santa Ana hereby denies Appeal
Application No. 2020-02, thereby upholding the Planning Commission's approval of an
Addendum to the Environmental Impact Report (EIR) for the Transit Zoning Code
Project (SCH NO. 2006071100), mitigation monitoring and reporting program, Site Plan
Review No. 2020-03 as conditioned, and Variance No. 2020-06 as conditioned. This
decision is based upon the evidence submitted at the abovesaid hearing, which
includes, but is not limited to: the Request for City Council Action dated December 1,
2020, and exhibits attached thereto, and the public testimony, written and oral, all of
which are incorporated herein by this reference.
ADOPTED this day of 2020.
Miguel A. Pulido
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By: � C -
Lisa Storck
Assistant City Attorney
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
Resolution No. 2020-xa
Page 6 of 7
75C-317
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, DAISY GOMEZ, Clerk of the Council, do hereby attest to and certify the attached
Resolution No. 2020-xx to be the original resolution adopted by the City Council of the
City of Santa Ana on 2020.
Date:
Clerk of the Council
Resolution No. 2020-xx
Page 7 of 7
75C-318
EXHIBIT 5
LS 12.1.20
RESOLUTION N0, 2020-xx
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA APPROVING AND ADOPTING AN
ADDENDUM TO THE ENVIRONMENTAL IMPACT
REPORT FOR THE TRANSIT ZONING CODE PROJECT
(SCH NO. 2006071100) FOR AMENDMENT APPLICATION
NO. 2020-04 AND ADOPTION OF A MITIGATION
MONITORING AND REPORTING PROGRAM FOR THE 4TH
AND MORTIMER MIXED -USE DEVELOPMENT PROJECT
LOCATED AT 409 AND 509 EAST FOURTH STREET
WHEREAS, Andrew Nelson, with Red Oak Investments, LLC, representing
Northgate Gonzalez Real Estate (hereinafter referred to as "Applicant'), is requesting
approval of Amendment Application No. 2020-04, as conditioned, to allow the
construction of a new mixed -use residential and commercial development consisting of
169 residential rental units and 11,361 square feet of commercial space at 409 and 509
East Fourth Street; and
WHEREAS, the subject property contains 2.715 acres at two separate but
adjacent sites at 409 and 509 East Fourth Street, currently developed with a
commercial building (Northgate Gonzalez Market), surface parking lot, and vacant
buildings and parcels; and
WHEREAS, the Transit Zoning Code was adopted in 2010 as a result of interest
in developing transit -oriented mixed -use residential and commercial projects in its
project area. The Transit Zoning Code was amended in 2019 to modernize and refine
development standards to further these interests. The regulating plan, which establishes
land uses and development standards, allows a variety of housing and commercial
projects, including mixed -use residential communities, live/work units, hotels, and
offices; and
WHEREAS, the City Council of the City of Santa Ana certified the Environmental
Impact Report (SCH No. 2006071100) and adopted a mitigation monitoring and
reporting program for the Transit Zoning Code, which allows a mixture of residential,
commercial, and limited industrial land uses; and
WHEREAS, the entitlements sought for the proposed mixed -use development
project include a Site Plan Review application, Variance application, and an
Amendment Application; and
WHEREAS, in 2010, the City Council certified the Final Environmental Impact
Report ("2010 EIR") for the Transit Zoning Code Project ("Originally Approved Plan"),
Resolution No. 2020-xx
Page 1 of 8
75C-319
which analyzed the potentially significant environmental impacts of a mixed -use plan
area consisting of new residential, commercial, and industrial development; and
WHEREAS, pursuant to the 2010 EIR, the subject site may be developed with a
mixed -use development consisting of residential and commercial land uses; and
WHEREAS, when compared against the Originally Approved Plan, the proposed
mixed -use development will not result in any new or intensified significant impacts; and
WHEREAS, pursuant to the California Environmental Quality Act (Public
Resources Code section 21000 et seq.) ("CEQA") and the State CEQA Guidelines (14
Cal. Code Regs. 15000 et seq.), the City is the Lead Agency for the proposed
development; and
WHEREAS, pursuant to CEQA, when taking subsequent discretionary actions in
furtherance of a project for which an EIR has already been certified, the Lead Agency is
prohibited from requiring a subsequent or supplemental EIR unless at least one of the
circumstances identified in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 are present; and
WHEREAS, City staff has evaluated the proposed project and considered
whether, in light of the impacts associated with its development, any supplemental or
subsequent environmental review is required pursuant to Public Resources Code
section 21166 or State CEQA Guidelines section 15162; and
WHEREAS, the analysis contained in the 4th and Mortimer Mixed -Use
Development project's EIR Addendum ("2020 Addendum") concludes that none of the
circumstances described in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 have occurred, and thus no supplemental or subsequent EIR
is required; and
WHEREAS, the proposed Project is within a transit priority area (TPA) as defined
by Public Resources Code (PRC) Section 21099(a)(7). A TPA is an area within one-half
mile of a major transit stop that is existing (or planned under certain conditions). A major
transit stop includes the intersection of two or more major bus routes with a frequency of
service interval of 15 minutes or less during the morning and afternoon peak commute
periods (PRC § 21064.3). The Project site is within 0.5 miles of the intersection of Bus
Routes 53, 55, 64, 83, 206 and 462 with transit stops located throughout Main Street,
Civic Center Drive, Fifth Street, Santa Ana Boulevard and First Street. Furthermore, the
Santa Ana Metrolink Station and Santa Ana Regional Transportation Center is located
less than 0.5 miles to the east at Santa Ana Boulevard and Santiago Street. The transit
frequency at the stops along Main Street and First Street is every 15-minutes during the
morning and afternoon peak commute periods and therefore qualifies as a high -quality
transit corridor. Lastly, the project is located within a 0.5 miles of a high -quality transit
corridor (routes along Main Street and First Street), plus the future OC Streetcar, which
would further enhance mobility throughout Downtown Santa Ana, beyond the current
Resolution No. 2020-xx
Page 2 of 8
75C-320
transit opportunities that are now availability. Therefore, under SB 743, aesthetic and
parking impacts cannot be considered a significant impact within TPA's; and
WHEREAS, on October 12, 2020 at a duly noticed public hearing, the Planning
Commission considered the 2020 EIR Addendum for Site Plan Review No. 2020-03 and
Variance No. 2020-06 when recommending that the City Council approve the Project;
and
WHEREAS, on December 1, 2020 at a duly noticed public hearing, the City
Council considered the 2020 EIR Addendum for Amendment Application No. 2020-04;
and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have
occurred.
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA ANA
DOES RESOLVE, DETERMINE, FIND AND ORDER AS FOLLOWS:
SECTION 1. The above recitals are true and correct and incorporated herein by
reference.
SECTION 2. State CEQA Guidelines section 15164 requires lead agencies to
prepare an addendum to a previously certified EIR if some changes or additions to the
project are necessary, but none of the conditions requiring preparation of a subsequent
EIR are present. The City Council has reviewed and considered the 2010 EIR and the
2020 Addendum, and finds that these documents taken together contain a complete
and accurate reporting of all of the potential environmental impacts associated with the
proposed development. The City Council further finds that the 2020 Addendum has
been completed in compliance with CEQA and the State CEQA Guidelines. The City
Council further finds and determines that the EIR Addendum reflects the City's
independent judgment.
SECTION 3. Based on the substantial evidence set forth in the record, including
but not limited to the 2010 EIR and the 2020 Addendum, the City Council finds that an
addendum is the appropriate document for disclosing the changes to the subject
property, and that none of the conditions identified in Public Resources Code section
21166 and State CEQA Guidelines section 15162 requiring subsequent environmental
review have occurred, because:
(a) The proposed development does not constitute a substantial change that
would require major revisions of the 2010 EIR due to the involvement of
new significant environmental effects or a substantial increase in the
severity of previously identified significant effects.
(b) There is not a substantial change with respect to the circumstances under
which the proposed development will be developed that would require
major revisions of the 2010 EIR due to the involvement of new significant
Resolution No. 2020-xx
Page 3 of 8
75C-321
environmental effects or a substantial increase in the severity of the
previously identified significant effects.
(c) New information of substantial importance has not been presented that
was not known and could not have been known with the exercise of
reasonable diligence at the time the 2010 EIR was certified or adopted,
showing any of the following: (i) that the modifications would have one or
more significant effects not discussed in the earlier environmental
documentation; (ii) that significant effects previously examined would be
substantially more severe than shown in the earlier environmental
documentation; (iii) that mitigation measures or alternatives previously
found not to be feasible would in fact be feasible and would substantially
reduce one or more significant effects, but the Applicant declined to adopt
such measures; or (iv) that mitigation measures or alternatives
considerably different from those analyzed previously would substantially
reduce one or more significant effects on the environment, but which the
Applicant declined to adopt.
The City Council further finds that, pursuant to State CEQA Guidelines section
15164, only minor changes or additions to the 2010 EIR are necessary to address the
proposed project. In making this finding, the City Council has considered both the
Addendum and the certified, final EIR.
SECTION 4. The City Council hereby finds that mitigation measures identified in
the 2010 EIR remain applicable to the Transit Zoning Code, with exception of mitigation
measure MM4.4-1(a) as part of the Cultural Resources which has been revised after
consultation with California Native American Tribes. These findings are described more
specifically in the Mitigation Monitoring and Reporting Program ("MMRP") attached
hereto as Exhibit A. The City Council therefore hereby adopts those mitigation
measures identified as remaining applicable to the Transit Zoning Code, through the
MMRP attached hereto and incorporated herein as Exhibit A.
SECTION 5. The City Council hereby approves and adopts the 2020 4th and
Mortimer Mixed -Use Development EIR Addendum related to Amendment Application
No. 2020, attached hereto and incorporated herein as Exhibit B.
SECTION 6. The Applicant shall indemnify, protect, defend and hold the City
and/or any of its officials, officers, employees, agents, departments, agencies,
authorized volunteers, and instrumentalities thereof, harmless from any and all
claims, demands, lawsuits, writs of mandamus, and other and proceedings (whether
legal, equitable, declaratory, administrative or adjudicatory in nature), and alternative
dispute resolution procedures (including, but not limited to arbitrations, mediations,
and such other procedures), judgments, orders, and decisions (collectively "Actions"),
brought against the City and/or any of its officials, officers, employees, agents,
departments, agencies, and instrumentalities thereof, that challenge, attack, or seek
to modify, set aside, void, or annul, any action of, or any permit or approval issued by
Resolution No. 2020-xx
Page 4 of 8
75C-322
the City and/or any of its officials, officers, employees, agents, departments,
agencies, and instrumentalities thereof (including actions approved by the voters of
the City) for or concerning the project, whether such Actions are brought under the
Ralph M. Brown Act, California Environmental Quality Act, the Planning and Zoning
Law, the Subdivision Map Act, Code of Civil Procedure sections 1085 or 1094.5, or
any other federal, state or local constitution, statute, law, ordinance, charter, rule,
regulation, or any decision of a court of competent jurisdiction. It is expressly agreed
that the City shall have the right to approve, which approval will not be unreasonably
withheld, the legal counsel providing the City's defense, and that Applicant shall
reimburse the City for any costs and expenses directly and necessarily incurred by
the City in the course of the defense. City shall promptly notify the Applicant of any
Action brought and City shall cooperate with Applicant in the defense of the Action.
SECTION 7. The City Council directs staff to prepare, execute and file a CEQA
Notice of Determination with the Orange County Clerk's Office within five working days
of the City Council approval of Amendment Application No. 2020 for the 4th and
Mortimer Mixed -Use Development Project.
SECTION 8. The 2010 EIR and the 2020 EIR Addendum, and any other
documents and materials that constitute the record of proceedings upon which these
findings have been based are on file, are incorporated herein by reference and are
available for public review at Santa Ana City Hall, Planning and Building Agency, M20,
20 Civic Center Plaza, Santa Ana, California 92701. The custodian of these records is
Daisy Gomez, City Clerk for the City.
SECTION 9. This resolution shall take effect immediately upon its adoption by
the City Council, and the Clerk of the Council shall attest to and certify the vote adopting
this resolution.
ADOPTED this day of 2020.
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By; �-- �_ C 4G�__
Lisa E. Storck
Assistant City Attorney
Miguel A. Pulido
Mayor
Resolution No. 2020-xx
Page 5 of 8
75C-323
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, DAISY GOMEZ, Clerk of the Council, do hereby attest to and certify the attached
Resolution No. 2020-xx to be the original resolution adopted by the City Council of the
City of Santa Ana on , 2020.
Date:
Clerk of the Council
City of Santa Ana
Resolution No. 2020-xx
Page 6 of 8
75C-324
EXHIBIT A
MITIGATION MONITORING AND REPORTING PROGRAM
The Mitigation Monitoring and Reporting Program (MMRP) is available online at:
https://www.santa-ana.orq/pb/planning-division/major-planning-projects-and-monthly-
development-project-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-325
EXHIBIT B
4T" AND MORTIMER EIR ADDENDUM
The 4th and Mortimer Mixed -Use Development Project EIR Addendum and
Technical Appendices are available online at:
https://www.santa-ana.orq/pb/planning-division/major-planning-projects-and-
monthly-development-project-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-326
EXHIBIT 6
LS 10.12.20
ORDINANCE NO. NS-XXXX
AN ORDINANCE OF THE CITY COUNCIL APPROVING
AMENDMENT APPLICATION NO. 2020-04 MODIFYING
THE SUB -ZONING DESIGNATION OF THE PROPERTIES
LOCATED AT 501, 507, 509, 515, AND 519 EAST FOURTH
STREET AND THOSE AT 502, 506, 510, 514, 520 EAST
FIFTH STREET FROM SPECIFIC DEVELOPMENT NO. 84,
URBAN NEIGHBORHOOD 2 (UN-2) SUB -ZONE, TO THE
URBAN CENTER (UC) SUB -ZONE
THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES ORDAIN AS FOLLOWS:
Section 1. The City Council of the City of Santa Ana hereby finds, determines
and declares as follows:
WHEREAS, Chapter 41, Article 1, Division 1, Section 41-1 of the
Municipal Code establishes the necessity of
businesses, trades and industries; regulating t
regulation; the location, height, bulk and size
yards and open space; the City is divided into
and area as may be considered best suited tc
for their enforcement; and
Santa Ana
segregating the location of residences,
he use of buildings, structures, and land
of buildings and structures, the size of
land -use districts of such number, shape
carry out these regulations and provide
WHEREAS, the regulations are considered necessary in order to: encourage
the most appropriate use of land, conserve and stabilize property value, provide
adequate open spaces for light and air and to prevent and fight fires, prevent undue
concentration of population, lessen congestion on streets and highways, and promote
the health, safety and general welfare of the people, all as part of the general plan of
the City; and
WHEREAS, the City of Santa Ana has adopted a zoning map which has since
been amended from time to time; and
WHEREAS, Andrew Nelson, with Red Oak Investments, LLC, representing
Northgate Gonzalez Real Estate (hereinafter referred to as "Applicant"), seeks to
develop the 4th and Mortimer Mixed -use Development Project ("proposed Project'), on a
1.423-acre site at 409 East Fourth Street and a 1.292-acre site at 501, 507, 509, 515,
and 519 East Fourth Street and 502, 506, 510, 514, 520 East Fifth Street (collectively
referred to as "509 East Fourth Street") in Santa Ana, California ("Project Site"); and
WHEREAS, during the City's entitlement and environmental review process, and
in response to comments and concerns raised by the City and public, the Applicant has
proposed the subject mixed -use Project; and
Ordinance No. NS-XXXX
Page 1
75C-327
WHEREAS, the entire Project as currently proposed entails, among other things,
(1) demolition of an existing commercial grocery market, surface parking lot, an existing
commercial auto building, and ancillary structures on the Project Site; (2)
redevelopment of the Project Site with a residential and commercial mixed -use
development consisting mixed -use residential and commercial development consisting
of two separate buildings located on two development sites at 409 (Site A) and 509
(Site B) East Fourth Street, with up to 169 residential rental units, 11,361 square feet of
commercial space, 422 on -site parking spaces, and onsite landscaping and amenities;
(3) approval of Site Plan Review No. 2020-03 to allow the construction of two structures
over four stories in height; (4) approval of Variance No. 2020-06 to allow an increase in
the allowable building size and massing for Site B; and (5) approval of Amendment
Application (AA) No. 2020-04, which would change the zoning of Site B from Specific
Development No. 84, Urban Neighborhood 2 (UN-2) sub -zone, to the Urban Center
(UC) sub -zone; and
WHEREAS, the requested Amendment Application would modify the zoning
designation of Site B from Specific Development No, 84, Urban Neighborhood 2 (UN-2)
sub -zone, to Specific Development No. 84, Urban Center (UC) to facilitate the
construction of the proposed Project; and
WHEREAS, in accordance with the California Environmental Quality Act
(CEQA), the City Council of the City of Santa Ana hereby finds, determines, and
declares as follows:
Based on the substantial evidence set forth in the record, including but not
limited to the Environmental Impact Report (EIR) for the Transit Zoning Code Project
(SCH NO. 2006071100) and the 2020 41h and Mortimer Mixed -Use Development EIR
Addendum, the City Council finds that an addendum is the appropriate document for
disclosing the changes to the subject properties, and that none of the conditions
identified in Public Resources Code section 21166 and State CEQA Guidelines
section 15162 requiring subsequent environmental review have occurred, because:
A. The project does not constitute a substantial change that would require major
revisions of the 2010 EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously
identified significant effects.
B. There is not a substantial change with respect to the circumstances under which
the project will be developed that would require major revisions of the 2010 EIR
due to the involvement of new significant environmental effects or a substantial
increase in the severity of the previously identified significant effects.
C. New information of substantial importance has not been presented that was not
known and could not have been known with the exercise of reasonable
diligence at the time the 2010 EIR was certified or adopted, showing any of the
following: (i) that the modifications would have one or more significant effects
not discussed in the earlier environmental documentation; (ii) that significant
Ordinance No. NS-XXXX
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75C-328
effects previously examined would be substantially more severe than shown in
the earlier environmental documentation; (iii) that mitigation measures or
alternatives previously found not to be feasible would in fact be feasible and
would substantially reduce one or more significant effects, but the Applicant
declined to adopt such measures; or (iv) that mitigation measures or
alternatives considerably different from those analyzed previously would
substantially reduce one or more significant effects on the environment, but
which the Applicant declined to adopt.
WHEREAS, the 2020 4th and Mortimer Mixed -Use Development EIR
Addendum analyzed the impacts related to the proposed amendment to the zoning
map and Specific Development No. 84; and
WHEREAS, on October 12, 2020, the Planning Commission conducted a duly
noticed public hearing to consider the 2020 4th and Mortimer Mixed -Use Development
EIR Addendum, Site Plan Review No. 2020-03, Variance No. 2020-06, and Amendment
Application No. 2020-04 described above. After hearing all relevant testimony from
staff, the public and the City's consultant team, the Planning Commission voted to
recommend that the City Council adopt a resolution approving an Addendum to the EIR
for the Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a
mitigation monitoring and reporting program for Amendment Application No. 2020-04,
and to adopt an ordinance approving Amendment Application No. 2020-04 for Specific
Development No. 84 (SD84).
WHEREAS, on December 1, 2020, the City Council conducted a duly noticed
public hearing to consider the 2020 4th and Mortimer Mixed -Use Development EIR
Addendum and Amendment Application No. 2020-04 and at which hearing members of
the public were afforded an opportunity to comment upon the Project. After hearing all
relevant testimony from staff, the public and the City's consultant team, the City Council
voted to adopt a resolution approving an Addendum to the Environmental Impact Report
for the Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a
mitigation monitoring and reporting program for Amendment Application No. 2020-04,
and to adopt an ordinance approving Amendment Application No. 2020-04 for Specific
Development No. 84 (SD84).
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA ANA
DOES RESOLVE, DETERMINE, FIND, AND ORDER AS FOLLOWS:
SECTION 2. CALIFORNIA ENVIRONMENTAL QUALITY ACT: The City Council has
reviewed and approved an Addendum to the Environmental Impact Report for the
Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a mitigation
monitoring and reporting program for Amendment Application No. 2020-04.
SECTION 3. AMENDMENT APPLICATION: The Amendment Application consists of
amendments to the zoning map changing the zoning of Site B from Specific
Development No. 84, Urban Neighborhood 2 (UN-2) sub -zone, to the Urban Center
Ordinance No. NS-XXXX
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75C-329
(UC) sub -zone, as shown in Exhibit A and Exhibit B respectively, attached hereto and
incorporated herein by reference.
SECTION 4. LOCATION OF DOCUMENTS: The Amendment Application, Addendum
to the Environmental Impact Report for the Transit Zoning Code Project (SCH NO.
2006071100) and all supporting documents are online, on file and available for public
review at Santa Ana City Hall, 20 Civic Center Plaza, Santa Ana, California 92702,
SECTION 5. GENERAL PLAN CONSISTENCY: The City Council hereby finds that
the proposed Amendment Application is compatible with the objectives, policies, and
general plan land use programs in that:
A. The proposed Amendment Application will not adversely affect the public
health, safety, and welfare in that the Amendment Application will not result in
incompatible land uses on adjacent properties, inconsistencies with any
General Plan goals or policies, or adverse impacts to the environment.
B. The amendment application to change the zoning designation of Site B from
Specific Development No. 84, Urban Neighborhood 2 (UN-2) sub -zone, to the
Urban Center (UC) sub -zone is consistent with Santa Ana Municipal Code
section 41-593.1 for the following reasons:
(1) Protecting and enhancing the value of properties by encouraging the
use of good design principles and concepts, as related to the division of
property, site planning and individual improvements with full recognition
of the significance and effect they have on the proper planning and
development of adjacent and nearby properties.
The project's site plan has been designed to integrate the project
site into the surrounding community. Both parking garages will
provide vehicular gates separating available commercial parking
spaces (e.g., guest, commercial, employee, etc.) from the
residential parking areas. Vehicular access will be provided from
Fifth Street by one right -turn only driveway west of Mortimer Street
and one full access driveway east of Mortimer Street. The on -site
circulation would provide safe access for vehicle -pedestrian traffic
and the driveway would provide sufficient throating such that
access to parking spaces is not impacted by internal vehicle
queuing/stacking. Pedestrian access points would be provided by
residential lobbies access along French and Mortimer Street. These
access points have been designed to ensure the safety of residents
and visitors of the project site, as well as commuters, employees,
and residents of the surrounding community.
(2) Encouraging, securing and maintaining the orderly and harmonious
appearance, attractiveness and aesthetic development of structures
Ordinance No. NS-XXXX
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75C-330
and grounds in order that the most appropriate use and value thereof
be determined and protected.
Both sites in the development have been carefully designed to be
integrated within the existing development pattern in Downtown
Santa Ana. Each site has its own unique architectural vernacular
defined by scale, facade articulation, roof forms, materials, and
detailing. Both of these blocks are designed in closely related
and established California Contemporary architectural style,
which complements the neighborhood in which the development
is located.
The overall development will feature amenities commonly found
at other upscale mixed -use developments in the region. These
include a large courtyard with pool, spa, clubroom, fitness room,
and landscaping in the center of Site A; a roof terrace on the 7th
floor of Site A, overlooking Fourth and French streets; a leasing
office and lounge in Site A; a bike locker in Site A; and a ground -
floor lobby and resident amenity area in Site B. In addition, the
project features private open space/decks for 59 units on Site A
and 48 on Site B. The two -block project will be built and is
conditioned to be managed as a single community and all
amenities will be accessible to residents from either site.
(3) Providing a method whereby specific development plans are to be
based on the general plan as well as other regulations, programs, and
legislation as may, in the judgment of the city, be required for the
systematic execution of the general plan.
The project site has a General Plan designation of District Center
on Site A and Urban Neighborhood on Site B. The District
Center -Downtown District and Urban Neighborhood land use
designation accommodates high-rise office, commercial, and
mixed -use residential uses with an emphasis on streets that
accommodate all modes of transportation for this land use
designation. The allowable floor area ratio (FAR) for District
Center and Urban Neighborhood land use designation would be
a maximum of 3.0 and 1.80, respectively. The proposed project
would include construction of two new buildings, one of which
would be seven stories in height with an FAR of 2.4 (Site A) and
one that would be five stories in height with an FAR of 1.8 (Site
B), consistent with the allowable FAR as part of the General
Plan.
Furthermore, the project is consistent with several goals and
policies of the General Plan, including the Economic
Ordinance No. NS-XXXX
Page 5
75C-331
Development Element and Land Use Element. Land Use
Element Goal 1 promotes a balance of land uses to address
basic community needs. Policy 1.1 promotes medium density
housing in and around the downtown area and Policy 1.2
supports high density residential development within the City's
District Centers as a part of a mixed use development. The
project will involve construction of a mixed -use residential and
commercial building on Site A with a density of 69.6 du/ac, and a
multi -family residential building on Site B with a density of 54.2
dufac, on two adjacent city blocks in downtown, within the Transit
Zoning Code area. Therefore, the Project will be consistent with
the General Plan Land Use Element.
4) Recognizing the interdependence of land values and aesthetics and
providing a method to implement this interdependence in order to
maintain the values of surrounding properties and improvements and
encouraging excellence of property development, compatible with the
general plan for, and character of, the city, with due regard for the
public and private interests involved.
The project is consistent with the Land Use Element Goal 2
which promotes land uses that enhance the City's economic and
fiscal viability. Policy 2.7 support projects that contribute to the
redevelopment and revitalization of the central City urban areas.
The development proposes to redevelop to City blocks currently
occupied by a commercial building, surface parking lot, and
vacant and unimproved buildings and parcels. Policy 2.10
supports new development that is harmonious in scale and
character with existing development in the area. Both sites in the
development have been carefully designed to be integrated
within the existing development pattern in Downtown Santa Ana.
The mixture of land uses on the project site, including residential,
commercial, and open space, will contribute to the formation a
dynamic downtown core. The commercial and open space
components will serve both residents and visitors of the project
site, as well as the large daytime employee population working in
the project site's immediate vicinity.
(5) Ensuring that the public benefits derived from expenditures of public
funds for improvements and beautification of streets and public facilities
shall be protected by exercise of reasonable controls over the character
and design of private buildings, structures and open spaces.
The project is consistent with Economic Development Element
Goal 2 maintains and enhances the diversity of the City's
economic base. Policy 2.3 encourages the development of
Ordinance No. NS-XXXX
Page 6
75C-332
mutually beneficial and supportive business clusters within the
community. The construction of this project will contribute toward
an economically balanced community by providing housing and
commercial retail opportunities (e.g., restaurant, retail sales, etc.)
for different demographics in an area rich with employment
opportunities, commercial development, and market -rate
housing. In addition, a fiscal and economic impact analysis
estimates that the proposed development will result net positive
fiscal impacts to the City, the Business Improvement District, and
over 800 new temporary or permanent jobs. Specifically, the
analysis estimates $5.4 million net new General Fund revenues
associated with the project over a 25-year period. The mixed -use
development will utilize existing water, sewer, and drainage
infrastructure and will not result in the expansion of infrastructure.
In addition, the Project will not result in the need for expansion of
new or altered police or fire facilities.
SECTION 6. INDEMNIFICATION.
A. General Indemnification. The Applicant shall indemnify, protect, defend and
hold the City and/or any of its officials, officers, employees, agents, departments,
agencies, authorized volunteers, and instrumentalities thereof, harmless from any
and all claims, demands, lawsuits, writs of mandamus, and other and proceedings
(whether legal, equitable, declaratory, administrative or adjudicatory in nature), and
alternative dispute resolution procedures (including, but not limited to arbitrations,
mediations, and such other procedures), judgments, orders, and decisions
(collectively "Actions"), brought against the City and/or any of its officials, officers,
employees, agents, departments, agencies, and instrumentalities thereof, that
challenge, attack, or seek to modify, set aside, void, or annul, any action of, or any
permit or approval issued by the City and/or any of its officials, officers, employees,
agents, departments, agencies, and instrumentalities thereof (including actions
approved by the voters of the City) for or concerning the project, whether such
Actions are brought under the Ralph M. Brown Act, California Environmental Quality
Act, the Planning and Zoning Law, the Subdivision Map Act, Code of Civil Procedure
sections 1085 or 1094.5, or any other federal, state or local constitution, statute, law,
ordinance, charter, rule, regulation, or any decision of a court of competent
jurisdiction. It is expressly agreed that the City shall have the right to approve, which
approval will not be unreasonably withheld, the legal counsel providing the City's
defense, and that Applicant shall reimburse the City for any costs and expenses
directly and necessarily incurred by the City in the course of the defense. City shall
promptly notify the Applicant of any Action brought and City shall cooperate with
Applicant in the defense of the Action.
B. Further Indemnification. Within five (5) days of receipt of a referendum
petition by the City, Applicant shall deposit Fifty Thousand Dollars ($50,000)
("Referendum Deposit") with the City. City may use the funds to pay any and all costs
associated with said referendum measure. If at any time the Referendum Deposit
account has Five Thousand Dollars ($5,000) or less remaining, Applicant shall, within
Ordinance No. NS-XXXX
Page 7
75C-333
three (3) days of receiving notice from the City, deposit with the City additional funds
as requested by the City to cover all costs and expenses associated with processing
the referendum and holding the related election. Following certification of the election
results, any funds remaining in the Referendum Deposit account shall be returned to
the Applicant.
SECTION 7. If any section, subsection, sentence, clause, phrase or portion of this
ordinance for any reason held to be invalid or unconstitutional by the decision of any
court of competent jurisdiction, such decision shall not affect the validity of the
remaining portions of this ordinance. The City Council of the City of Santa Ana hereby
declares that it would have adopted this ordinance and each section, subsection,
sentence, clause phrase or portion thereof irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases, or portions be declared invalid or
unconstitutional.
SECTION 8. CITY COUNCIL ACTIONS: The City Council hereby takes the
following actions:
1. The City Council hereby adopts an Ordinance approving Amendment Application
No. 2020-04 as follows:
A. Subject to compliance with the approved Addendum to the Environmental
Impact Report for the Transit Zoning Code Project (SCH NO. 2006071100)
and adopted mitigation monitoring and reporting program for Amendment
Application No. 2020-04, the properties at 501, 507, 509, 515, and 519 East
Fourth Street and 502, 506, 510, 514, 520 East Fifth Street shall be
amended to Specific Development No. 84 Urban Center (UC) sub -zone as
set forth in Exhibit A and Exhibit B, attached hereto and incorporated herein
by reference.
B. The Amendment Application shall not take effect unless and until the
Planning Commission reviews and approved the EIR Addendum,
Environmental Review No. 2018-113, Variance No. 2020-06 and Site Plan
Review No. 2020-03, and the City Council reviews and approves the EIR
Addendum, Environmental Review No. 2018-113 for the subject project.
SECTION 9. EXECUTION OF ORDINANCE. The Mayor shall sign this Ordinance and
the Clerk of the Council shall attest and certify to the adoption thereof.
ADOPTED this day of 2020.
Miguel A. Pulido
Mayor
Ordinance No, NS-XXXX
Page 8
75C-334
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
By: &'/ , C C
Lisa E. Storck
Assistant City Attorney
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, DAISY GOMEZ, Clerk of the Council, do hereby attest to and certify that the attached
Ordinance No. NS-XXXX to be the original ordinance adopted by the City Council of the
City of Santa Ana on , 2020, and that said ordinance was published
in accordance with the Charter of the City of Santa Ana.
Date:
Daisy Gomez
Clerk of the Council
City of Santa Ana
Ordinance No. NS-XXXX
Page 9
75C-335
EXHIBIT 7
REQUEST FOR
Planning Commission Action
PLANNING COMMISSION MEETING DATE:
OCTOBER 12, 2020
TITLE:
PUBLIC HEARING — ENVIRONMENTAL REVIEW NO.
2018-13, SITE PLAN REVIEW NO. 2020-03, VARIANCE
NO.2020-06 AND AMENDMENT APPLICATION NO.2020-
04 TO ALLOW CONSTRUCTION OF A NEW MIXED -USE
DEVELOPMENT AT 409 AND 509 EAST FOURTH STREET
Prepared by Pedro Gomez, AICP
PLANNING COMMISSION SECRETARY
APPROVED
❑
As Recommended
❑
As Amended
❑
Set Public Hearing For
DENIED
❑
Applicant's Request
❑
Staff Recommendation
CONTINUED TO
0 r
Executive Director Planning Ma age
RECOMMENDED ACTION
1. Adopt a resolution approving Addendum to the Environmental Impact Report for the Transit
Zoning Code Project (SCH NO. 2006071100) and adoption of a mitigation monitoring and
reporting program for Site Plan Review No. 2020-03 and Variance No. 2020-06.
2. Adopt a resolution approving Site Plan Review No. 2020-03 for anew mixed -use development
project over four stories in height as conditioned.
3. Adopt a resolution approving Variance No. 2020-06 for an increase in the allowable building
size and massing as conditioned.
4. Recommend that the City Council:
a. Adopt a resolution approving an Addendum to the Environmental Impact Report for the
Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a mitigation
monitoring and reporting program for Amendment Application No. 2020-04.
b. Adopt an ordinance approving Amendment Application No. 2020-04 for Specific
Development No. 84 (SD84).
Executive Summary
Andrew Nelson, with Red Oak Investments, LLC, representing Northgate Gonzalez Real Estate, is
requesting approval of multiple entitlements to facilitate construction of a new mixed -use community
on two City blocks located at 409 East Fourth Street (Site A) and 509 East Fourth Street (Site B).
Specifically, the applicant is requesting approval of an addendum to the Environmental Impact Report
for the Transit Zoning Code (TZC), as well as a site plan review (SPR) to allow construction of two
buildings over four stories in height, a variance to allow a reduction in required massing standards,
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and an amendment application (AA) to amend the designation on various parcels from the Urban
Neighborhood 2 (UN-2) subzone to the Urban Center (UC) subzone. The project would contain a
total of 169 residential rental units and 11,361 square feet of commercial space.
Staff is recommending approval of the applicant's request due to the project's satisfaction of meeting
the intent of the TZC to promote a pedestrian -oriented environment with a mix of land uses, facilitating
the redevelopment of underutilized land, encouraging increased employment opportunities within the
City, the generation of additional property and sales taxes, and because the project will provide
additional high -quality housing stock.
Table 1: Proiect and Location Information
d
Project Address
409 East Fourth Street and 509 East Fourth Street
Nearest Intersection
Fourth and French streets and Fourth and Mortimer streets
General Plan Designation
Site A — District Center (DC)
Site B — Urban Neighborhood UN
Zoning Designation
Transit Zoning Code (Specific Development No. 84), Downtown subzone
Site A and Urban Neighborhood 2 subzone Site B
Surrounding Land Uses
Commercial, Single- and Multi -Family (North)
Commercial and Single -Family (East)
Commercial and Multi -Family South
Commercial and Parkin (West)
Site Size
2.715 acres combined Site A: 1.423; Site B: 1.292 acres)
Existing Site Development
Site A contains a commercial building (Northgate Gonzalez Market) and a
surface parkin lot; Site B contains vacant buildings and parcels.
Use Permissions
Mixed -use projects are permitted by Section 41-2006 and Section 41-
2007 of the SAMC.
Zoning Code Sections Affected
Uses
Table 2A, SAMC Sec. 41-2007. SPR required
pursuant to SAMC Sec. 41-2007;
Development Standards
Transit Zoning Code, SAMC Sec. 41-2011,
41-2012 and 41-2023
Proiect Description
The project includes demolition of an existing Northgate Gonzalez Market and surface parking lot at
409 East Fourth Street (Site A) as well as the demolition of an existing commercial automobile service
building and ancillary structures at 509 East Fourth Street. The existing commercial facility, Ming's
Auto Repair, located at the northeast corner of Fourth and Mortimer streets (501 East Fourth Street),
is not part of the proposed project and will remain. Once the onsite buildings are demolished and
the sites are cleared, the applicant proposes to construct a mixed -use community on two
development sites, Site A and Site B, containing 169 residential units, 11,361 square feet of
leasable commercial area, and 422 onsite parking spaces. Table 2 on the following page provides
a summary of the proposed project.
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Table 2: Project Summary
Site Area
1.423 acres
1.292 acres
2.715 acres
Residential
99 units
70 units
169 units
Amenities/Leasing
Office
8,075 S.F.
None
8,075 S.F.
Retail
11,361 S.F.
None
11,361 S.F.
Public/Common
Open Space
15,345 S.F.
13,233 S.F.
28,578 S.F.
Private Open
Space
8,428 S.F.
2,832 S.F.
11,260 S.F.
Parking
230 stalls
192 stalls
422 stalls
Residential and Commercial Components
Site A will contain a mixed -use commercial/residential structure with 99 residential units, a 3,847-
square-foot tenant suite designed for an eating establishment, 7,514 square feet of retail space, a
resident and leasing lobby, site amenities, a bicycle storage room, and a four -and -a -half story,
aboveground parking garage with 230 parking spaces. The building frontage along Fourth Street,
and the intersections of Fourth and French street and Fourth and Mortimer streets, would be
seven -stories in height. The building would be five -stories in height along the French Street and
Mortimer Street frontages.
The proposed suite designed for an eating establishment would be located on the ground floor at
the corner of Fourth and French street and is designed to allow both indoor and outdoor dining.
Also fronting Fourth Street is the retail space and leasing office. The four -and -a -half story parking
garage would be located at the intersection of French and Fifth streets and will be accessed from
Fifth Street. Resident amenities will include a large pool, courtyard, and residential amenities on
the third level, and a rooftop deck on the seventh floor overlooking Fourth Street. A total of 23,773
square feet of open space, including 8,428 square feet of private open space and 15,345 square
feet of common open space will be included. .
Site B is designed to be residential only and will contain 70 units and a four-story, aboveground
parking garage with 192 onsite parking spaces. The residential building will be accessed from a
lobby on Mortimer Street and would be five stories in height across the site. Along the Fourth Street
frontage, Site B would include a courtyard and residential units. The four-story parking garage
would be located at the corner of Fifth and Minter streets and will be accessed from Fifth Street.
Site B includes 16,065 square feet of open space, including 2,832 square feet of private open
space and 13,233 square feet of common open space.
Of the development's 169 units, 21 will be studios (12.5 percent), 38 will be one -bedroom (22.5
percent), 66 will be two -bedroom (39 percent), 9 will be three -bedroom (5 percent), and 35 will be
four -bedroom units (21 percent). Units will range from 458 to 529 square feet for the studio units,
650 to 739 square feet for the one -bedroom units, 938 to 1,185 square feet for the two -bedroom
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units, 961 to 1,237 square feet for the three -bedroom units, and 1,325 to 1,520 square feet for the
four -bedroom units. All units will contain full kitchens, bedrooms, bathrooms, in -unit washer and
dryers, and living/dining areas.
Architecture and Amenities
Both sites in the development have been carefully designed to be integrated within the existing
development pattern in Downtown Santa Ana. The design's primary objective is to complement
and expand the energy and character of downtown by taking cues from its urban scale and historic
character. The ground floor of Building A is designed in the Main Street Commercial architectural
style, consistent with identifiable patterns typical of downtown buildings. Building B's purely
residential design complements the existing multi -family developments along Fourth Street. A
landscape buffer is provided for each site creating a transitional space between the top of the
structure and the street level while also providing screening at the lower level of the garages
adjacent to the single-family residences. In addition, the building's architecture is designed to
lessen the massing of the project with its elevations featuring articulation, multiple volumes, and
varied architectural styles to mimic the appearance of multiple buildings. The building's varied
height from five -stories to seven -stories generates a smooth transition from the higher -density
character of the intersection of Fourth and French street to the lower -density character of the
single-family residences to the north and to the east.
Each site has its own unique architectural vernacular defined by scale, facade articulation, roof
forms, materials, and detailing. A variety of window dimensions are provided where appropriate
while the header/sill trim details vary between both sites. Varied material/color palettes are featured
on both buildings, in addition to varied window recesses and decorative elements. While color
palette is varied across both sites, care has been taken to provide a unified look to correspond to
the surrounding buildings. Both structures feature durable brick veneer, glass, smooth stucco
finishes, metal awnings, and textured blocks/panels. Lastly, the building will feature prominent
artwork/murals across both sites. To ensure that the art is reflective of Santa Ana and is a positive
cultural impact on the surrounding neighborhood, staff included a condition of approval that
requires the applicant to coordinate with the City's Art and Culture Office and submit a Public Art
Plan to the Planning Division for review and approval.
The development will feature amenities commonly found at other upscale mixed -use
developments in the region. These include a large courtyard with a pool, spa, clubroom, fitness
room, and landscaping in the center of Site A; a roof terrace on the seventh floor of Site A,
overlooking Fourth and French streets; a leasing office and lounge in Site A; a bike locker in Site
A; and a ground -floor lobby and resident amenity area in Site B. In addition, the project features
private open space/decks for 59 units on Site A and 48 units on Site B. Conditions of approval
have been added to ensure the two -block project will be built and managed as a single community
and all amenities will be accessible to residents from either site.
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Proiect and Site Backaround
The Transit Zoning Code (TZC) was adopted in July 2010 and provides a framework for mixed -use,
residential, commercial, and limited industrial activities in a large section of central Santa Ana loosely
bound by Flower Street, the Santa Ana (1-5) Freeway, Civic Center Drive, Grand Avenue, and First
Street. The plan area contains six subzones that allow various types and ranges of intensity, as well
as two industrial overlay districts where industrial uses in place at the time of the code's adoption are
allowed to continue. The Downtown subzone in which the project is proposed (Site A) and the Urban
Center (proposed subzone for Site B) allow a variety of mixed -use developments that are intended
to contribute to creating a dynamic, transit -oriented area for residents, business owners, and visitors,
and to lessen the need for automobile dependence. Amendments to the TZC in July 2019 modernized
certain sections of the code and furthered the goals and vision of the plan area.
Site A (409 East Fourth Street) is currently improved with a single -story commercial building
approximately 14,000 square feet in size, operating as a grocery store (Northgate Gonzalez Market).
The store was constructed between 1995. and 1996. In 1906, Site A was occupied by uses such as
single-family dwellings, a religious institution, and a telegraph office. Between 1949 and 1963, the
site was occupied by uses such as agricultural and auto storage, manufacturing (e.g., mattress
production and neon signs), motorcycle repairs, and upholstering and printing.
Site B (509-515 East Fourth Street) is improved with a vacant single -story, commercial building built
in 1921 and approximately 11,000 square feet in size, spanning two parcels and which last operated
as Munoz Auto Repair & Tire Service. By 1949, many of the single-family dwellings had been
demolished on the site and replaced with larger industrial and or commercial buildings. Aside from
the period between 1932 and1939 when the site was a partially used as a grain/feed supply, Site B
primarily functioned in an auto -related capacity from 1923 to 1972. La Opinion Daily Newspaper/La
Opinion Periodical, a Spanish -language newspaper, appears to have been associated with the
property for a short period in the early 1980s.
In August 2018, the applicant submitted the proposed mixed -use development, which was one of the
first major mixed -use developments proposed in Downtown Santa Ana since the TZC was adopted
in 2010. Since submitting the application, the applicant has met with nearby neighborhood
associations, business leaders, and other interested parties. A full list of neighborhood outreach
efforts and details on the Sunshine Ordinance community meeting is provided in Table 3 of this report.
Analysis of the Issues
Section 41-2005 of the SAMC requires developments proposing over four stories in height to apply
for a Site Plan Review (SPR) with the Planning Commission. As the buildings in the proposed
development contain five and seven stories, approval of a SPR application is required by the Planning
Commission. Furthermore, pursuant to SAMC Section 41-638, the Planning Commission is
authorized to review and approve variances from the provisions of the Municipal Code when it
appears that findings in compliance with section 41-638 (a)(2) of the SAMC have been established.
Since the project requires approval of a variance for an increase in the allowable building size and
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massing standards for Site B, review and approval is required by the Planning Commission. Lastly,
Section 41-664 of the SAMC requires a public hearing for the proposed amendment application to be
reviewed by the Planning Commission and the City Council, with the Planning Commission as a
recommending body and the City Council as the approving body. Since the project is seeking
approval of an amendment application for a zone change on Site B to change the subzone from UN-
2 to the Urban Center (UC), review and approval of an amendment application is required by the
Planning Commission and City Council.
Amendment Application
The proposed project includes construction of two new Lined Block buildings, one of which would be
a maximum of seven stories in height with a floor area ratio (FAR) of 2.4 (Site A) and one that would
be five stories in height with an FAR of 1.8 (Site B). However, the UN-2 subzone does not include
Lined Block buildings as a permitted building type. Therefore, the project would require an
amendment application for a zone change on Site B from the UN-2 subzone to the Urban Center
(UC) subzone. The UC subzone was selected in order to maintain aesthetic consistency with the
proposed building on Site A. In addition, under the current UN-2 subzone, residential buildings with
densities of up to 50 dwelling units per acre (DU/acre) are permitted. The proposed project on Site B
involves development of a residential building with a density of approximately 54 DU/acre, which
represents a slightly higher intensity use than the UN-2 subzone allowable density range of no more
than 50 DU/acre. However, Site B is surrounded by properties with higher intensity developments
that are zoned DT and UC to the west and south.
In addition, a review of the existing TZC map seen in Exhibit 12 demonstrates that it is was the original
intent of the TZC to place UC subzones as both a buffer and a transition between the uses permitted
in the high density Downtown (DT) subzone and the less intense UN-2 neighborhoods surrounding
it. While the adopted TZC allowed for the integration of new infill development into existing
neighborhoods, reuse of existing buildings, and creation of new mixed use and transit -oriented
development, it intended to transition the subzones with higher allowable densities to those that
permitted lower density ranges. With the exception of Site B, all of the adjacent DT subzone parcels
are surrounded by UC subzone parcels. The proposed change to the UC designation would be
consistent with the existing adjacent parcels that surround the DT subzone.
Although the TZC provides for a mixture of development types situated within walking distance of
many modes of transit (e.g., public transit, pedestrian, cyclists and automobiles), it did not
contemplate the precise route of the OC Streetcar at the time of its adoption in 2010. An eastbound
segment of the streetcar runs along the project site along Fourth Street with a stop immediately
adjacent to the project at Fourth and French streets. The streetcar then proceeds northbound one
block to Mortimer Street, bisecting the two project sites and advancing to Santa Ana Boulevard
towards the Santa Ana Regional Transportation Center. As a gateway project along the streetcar line,
the UC subzone facilitates a design that better reflects a sense of downtown and builds upon
allowable planning and architectural intensities, affirmatively addressing the pedestrian orientation at
all street frontages, specifically along Fourth and Mortimer streets. Furthermore, the zone change
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acknowledges the density and building envelope opportunities of the TZC to support the recent
investment in the streetcar and maximizing development potential along the proposed routes.
Lastly, the zone change to the UC subzone would provide for a more harmonious design on both
sites as they are being developed and managed together as one project. The building types under
the UN-2 subzone are limited to lower density and shorter building height developments such as the
Hybrid Court, Courtyard Housing, Live -Work, or Tuck -Under building type. Each of the allowable
building types under the UN-2 would have resulted in a design on Site B that looked arbitrarily carved
down and which presented an incongruous design. The UC subzone allows Site B to be designed in
the same building type as Site A while allowing each site to have a unique architectural vernacular
that complement the neighborhood and are integrated within the existing development pattern in
downtown. Though the proposed project would develop Site B at a slightly higher density use than
the existing TZC density range for UN-2, this use would be consistent with adjacent property uses
and the intent of the TZC by enhancing the pedestrian environment, creating opportunities for higher -
density trans it -oriented residential development in proximity to jobs, and reactivating vacant land uses
adjacent to the historical Downtown shopping district.
Variance Application
The proposed project is requesting a variance from Santa Ana Municipal Code (SAMC) Section 41-
2023(i)(5) for an increase in the allowable building size and massing standards for the lined block
building proposed on Site B. The TZC requires that portions of buildings between three and five
stories be only 85 percent of the ground floor's volume. As proposed, the third through fifth floor would
be 100 percent of the building's ground floor volume, exceeding the allowable ratio by 15 percent on
each floor. Therefore, a variance application would be required to facilitate the construction of the
building on Site B. Pursuant to SAMC Section 41-638, a variance application can be granted for relief
from the development standards of the zoning district. Variances may be granted when it can be
shown that there exists a special circumstance related to the property depriving of its uses that are
afforded to other properties and that a variance is necessary for the preservation and enjoyment of
substantial property rights, will not be detrimental to the public or surrounding property, and will not
adversely affect the General Plan. In analyzing the variance request, staff believes that the following
analysis warrants staffs recommendation of approval of the variance.
Site B has a smaller than average lot depth and lot width, compared to most lots in the downtown
area. Lots in the downtown area range in lot depth and width but are on average 250 feet by 250 feet.
While portions of Site B meet the average lot width and depth, a majority of Site B is smaller -than -
average. Site A takes advantage of a full city block with complete street frontages along every street
while Site B is interrupted by an adjacent parcel not part of the project, and approximately 6,200
square feet in size, or 50 feet by 124 feet. This results in Site B having smaller -than -average street
frontages along Mortimer and Fourth streets. Without the increase in the allowable building size and
massing standards, the project would need to be redesigned, resulting in several impacts to the
feasibility of the site's development. These impacts would include a loss off-street parking spaces by
requiring a reduction in size of the parking structure; an incompatible design and unbalanced
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composition of massing the project site; and/or a smaller building footprint that would reduce the
building's interior floor area and individual unit sizes.
The adjacent automotive repair and commercial space on Site B offers collective massing relief
for the site. Although not part of the project, this parcel's relative size means that if redeveloped, it
will always be to a lower building and massing scale than the proposed five -story structure on Site
B. When viewed collectively, the amount of "stepback" or reduction in floor volume would exceed
the required 85% of ground floor requirement and would be roughly comparable to the third floor
stepback accomplished by the courtyard on Site A. Further, the Citywide Design Guidelines
encourage new buildings to be compatible with surrounding character, including building style, form,
size, materials, and roofline. Specifically, Chapter 8 (Downtown Development Guidelines), Section
8.6 encourages the height and scale of new buildings complement existing structures and provide a
sense of human scale and proportion. As the two blocks are being developed together they're
designed with appropriate congruity and diversity in both style and articulation. Both buildings rise
with balanced "U-shaped" courtyard design facing Fourth Street and vary significantly with a two-
story height variation. A two -block development where one block looks arbitrarily carved down by
a forced stepback would present as an incompatible design and could cause an unbalanced
composition of massing along Fourth Street, inconsistent with the architectural vernacular and
intentions of the TZC.
Conformance to Transit Zoning Code Development Standards
The project has been designed to conform to the development standards in the Transit Zoning
Code, with the exception of the proposed building and massing standards on Site B. Furthermore,
with approval of the amendment application for the zone change on Site B, the project would
comply with the allowable building types. A full description of conformance to development
standards is provided in Exhibit 14 to this staff report.
Onsite Parking
The overall parking proposed for the project is 422 spaces, including 394 residential stalls and 28
commercial visitor stalls. The proposed residential parking provides a ratio of 2.3 parking spaces per
residential unit, with commercial parking provided at one space per 400 square feet of commercial
area, which meets and exceeds the minimum requirements of the TZC. Both parking garages will
provide vehicular gates separating available commercial parking spaces (e.g., guest, commercial,
employee, etc.) from the residential parking areas. Vehicular access will be provided from Fifth Street
by one right -turn only driveway west of Mortimer Street and one full access driveway east of Mortimer
Street. The on -site circulation would provide safe access for vehicle -pedestrian traffic and the
driveway would provide sufficient throating such that access to parking spaces is not impacted by
internal vehicle queuing/stacking.
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California Environmental Qualitv Act (CEQA
The proposed development required preparation of studies relating to shade and shadow, air quality
and greenhouse gas emissions, cultural resources, traffic, parking, noise and vibration, Phase I
environmental site assessment, hydrology, a preliminary water quality management plan, and sewer
capacity. In addition, a fiscal impact and economic impact analysis was prepared by RSG, Inc. and
The Concord Group. The technical studies evidenced that an EIR Addendum to the previously -
certified 2010 EIR is the appropriate CEQA document to evaluate and disclose the project's impacts.
An addendum to a previously certified EIR is prepared when a lead agency is asked to approve
modifications to an existing project for which an EIR has already been certified. An addendum
evaluates the requested modifications and determines whether subsequent EIR review is required.
Since none of the conditions specified in State CEQA Guidelines, section 15162 are present, an
Addendum to the previously -certified 2010 EIR was prepared for the 4th and Mortimer Mixed -Use
Development project.
Pursuant to State CEQA Guidelines section 15164(b), an addendum to a previously -certified EIR is
not circulated for public review. The Addendum is included with this staff report as Exhibit 15.
Pursuant to State CEQA Guidelines section 15164(d), the Planning Commission must consider the
Addendum together with the 2010 EIR before making a decision on the project.
Previous CEQA Documentation
The 2010 EIR (SCH No. 2006071100) was prepared to evaluate the potential impacts associated
with the adoption of the Transit Zoning Code, which was anticipated to result in potential
development of approximately 4,075 residential units, 387,000 sf of retail development, and an
additional 15.5 acres of open space within the City.
The 2010 EIR considered the environmental impacts relating to aesthetics; air quality; biological
resources; cultural resources; hazards and hazardous materials; hydrology and water quality; land
use; noise; population, housing, and employment; public services; transportation and traffic;
utilities and service systems; and climate change. A mitigation monitoring and reporting program
(MMRP), findings of fact, and a statement of overriding consideration were adopted with the 2010
EIR. As part of the 2020 Addendum to the 2010 EIR, the original MMRP must be readopted by the
Planning Commission. All mitigation measures in the original EIR and associated MMRP have
been enforced and are carried over within the 2020 Addendum, with exception of mitigation
measure MM4.4-1(a) as part of the Cultural Resources which was revised after consultation with
California Native American Tribes.
Addendum Conclusions
The 4th and Mortimer development project Addendum concludes no new or substantially greater
impacts would occur with implementation of the proposed development when compared to those
identified in the 2010 EIR. To fully evaluate the proposed project's impacts on the site's existing
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structures, technical studies provided by the applicant, including shade and shadow, air quality
and greenhouse gas emissions, traffic, parking, hydrology, and sewer capacity, were extensively
peer reviewed by the City's CEQA consultant. In addition, additional studies relating to cultural
resources, noise and vibration were prepared by the CEQA consultant.
Aesthetics
Consistent with 2010 EIR Mitigation Measure 4.1-4, a shade and shadow analysis was conducted
for the proposed project. The proposed project's seven -story building on Block A and a five -story
building on Block B would shade adjacent land uses, including structures to the east and southeast
in the summer months, and structures to the north, northeast, and northwest in the winter months.
For the purposes of analyzing shade/shadow impacts, a significant impact would occur when
shadow -sensitive uses (e.g., residential structures, schools, churches, parks, etc.) would be
shaded by a project -related structure for more than three hours between the hours of 9:00 A.M.
and 3:00 P.M. Pacific Standard Time (PST) (between late October and early April), or for more
than four hours between the hours of 9:00 A.M. and 5:00 P.M. PST (between early April and late
October).
The Site Shadow Study indicates that none of the shadow sensitive uses surrounding the project
sites would be shaded by either building for more than three hours between 9:00 A.M. and 3:00
P.M. during the Winter Solstice. Likewise, shadow sensitive land uses would not be shaded by
project structures for more than five hours between 9:00 A.M. and 5:00 P.M. during the summer.
Therefore, impacts would be less than significant. As such, the proposed project would not
contribute to the significant shadow impacts identified in the 2010 EIR, nor would it result in a new
significant impact or substantially increase the severity of a previously identified significant impact
with respect to shade and shadow beyond those analyzed in the 2010 EIR.
Cultural Resources
The State CEQA Guidelines for the preparation of an addendum do not specifically require
adherence to Assembly Bill 52 (AB 52), which requires meaningful consultation with California Native
American Tribes on potential impacts on tribal cultural resources, as defined in Public Resources
Code Section 21074. However, considering that the EIR was approved and adopted in 2010 prior to
the AB52 being enacted (July 2015) staff felt the need to incorporate tribal review into the
environmental review processes. Tribal cultural resources are sites, features, places, cultural
landscapes, sacred places, and objects with cultural value to a California Native American tribe that
are either eligible or listed in the California Register of Historical Resources or local register of
historical resources. In order minimize impacts on potential resources on the project site mitigation
measure MM4.4-1(a) has been revised to be inclusive of any locally affiliated Tribe identified by the
Native American Heritage Commission.
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Transportation
A traffic impact analysis (TIA) was prepared and conducted by Linscott, Law & Greenspan,
Engineers (LLG) and peer reviewed by the City's CEQA consultant to determine the potential traffic
impacts associated with the proposed project. The traffic analysis evaluated the existing operating
conditions at six key study intersections within the project vicinity immediately bordering the subject
property, estimated the trip generation potential of the proposed project, and forecasted future
near -term (Year 2024) and long-term (Year 2045) operating conditions without and with the
proposed Project. Two of the six intersections were also evaluated for the approved TZC, including
Fourth Street at French Street and Fifth Street at Mortimer Street.
The TIA's Level of Service (LOS) investigations at these key locations were used to evaluate the
potential traffic -related impacts associated with area growth, cumulative projects and the proposed
project. The TIA indicates that the proposed project would not result in an increase in intersection
traffic impacts beyond those analyzed in the 2010 EIR for the approved TZC. Furthermore, TIA
indicates that the proposed project would result in a net reduction of 173 daily vehicle trips to the
project site compared to existing commercial uses.
Economic Development
A fiscal and economic impact analysis prepared by RSG, Inc. and The Concord Group was submitted
for the project. The analysis estimates that the proposed development will result net positive fiscal
impacts to the City, the Business Improvement District, and create over 800 new temporary or
permanent jobs. Specifically, the analysis estimates the following impacts:
• $5.4 million net new General Fund revenues associated with the project over a 25-year period,
resulting from:
o A total of $7.8 million in additional City General Fund revenue, including $2.9 million in
net new property tax revenues, construction period revenues, recurring site -specific
tax, and other Project impacts over a 25-year period, and
o $2.4 million in General Fund expenditures associated with the project over a 25-year
period
806 direct, indirect, or induced new jobs resulting from the project, of which 35 would be
permanent
Approximately $205,424 in Business Improvement District (BID) funds
Table 3: Public Notification & Community Outreach
Required Measures A community meeting was held on August 29, 2018 at 6:00 p.m. at 450 West Fourth
Street (Latino Health Access) in accordance with the provisions of the City's Sunshine
Ordinance. This meeting was publicly noticed in the OC Register, posted on the City's
website, and invitation/notices were mailed to property owners and occupants/tenants in
a 500-foot radius from the project site. An estimated 100 members of the public attended,
as well as City staff. The applicant provided all the required information to the City after
the meeting, Details from the community meeting were posted to the project's webpape
75C-346
SPR No. 2020-03/ VAR No.
October 12, 2020
Page 12
2020-06/AA No. 2020-04-4th and Mortimer Mixed -Use Development
Public Notification, and Community Outreach each
at https://www.santa-ana.org/pb/plannin -division/major-plannina-r)rolects-and-mon I -
development-project-reports/4th-and.
Notification by mail was mailed to all property owners, occupants, and other interested
parties within 500 feet of the project site on October 2, 2020, in accordance with SAMC
requirements. In addition, newspaper posting was published in the Orange County
Register on October 2, 2020, in accordance with SAMC re uirements.
Additional Measures
The applicant met with several interested groups, neighborhoods, and/or individuals
between August 2018 and September 2020. Meetings include those with:
• Neighboring condominium associations and apartment buildings: Spectrum
Condominiums (450 E. 4th St.), Garden Court Apartments (300 E. Santa Ana
Blvd.) and Parks Apartments (510 Mortimer St.)
• Joint Meeting of Neighborhood Associations July 2020: French Park, French
Court, Logan, Lacy, Downtown and French Park Plaza
• Business organizations and individual leaders associated with the Santa Ana
Business Council, Chamber of Commerce, Downtown Inc.
• Historic preservation representative Tim Rush
• Eight individual property owners as a result of surveying every residence across
Fifth Street and Minter Street from development site
Conclusion
Based on the analysis provided within this report, staff recommends that the Planning Commission
adopt a resolution approving an Addendum to the Environmental Impact Report forthe Transit Zoning
Code Project (SCH NO.2006071100), mitigation monitoring and reporting program, Site Plan Review
No. 2020-03 as conditioned, and Variance No. 2020-06 as conditioned. In addition, staff recommends
that the Planning Commission recommend that the City Council adopt a resolution approving an
Addendum to the Environmental Impact Report for the Transit Zoning Code Project (SCH NO.
2006071100) mitigation monitoring and reporting program, and an ordinance approving Amendment
Application No. 2020-04 for Specific Development No. 84 (SD84).
/W- /,W ? C.
Pedro Gomez, AICP
Associate Planner
PG:sb
S:\Planning Commission\2020\10-12-20\4th and Mortimer -Addendum, SPR, VAR, and AA\ SPR-2020-03, VAR-2020-06, AA-2020-04 -4th and Mortimer_10.12.20pc
Exhibits:
1. Planning Commission Resolution (EIR Addendum, Site Plan Review, and Variance)
2. City Council Resolution (EIR Addendum)
3. City Council Ordinance (Amendment Application)
4. Vicinity Zoning and Aerial Map
75C-347
SPR No. 2020-03/ VAR No. 2020-06/AA No. 2020-04 — 4ch and Mortimer Mixed -Use Development
October 12, 2020
Page 13
5. Site Photos
6. Site Plan
7. Unit Floor Plans
8. Building Elevations
9. Building Perspectives
10. Building Materials
11. Conceptual Landscape Plans
12. Existing TZC Zoning Map
13. Proposed TZC Zoning Map
14. Conformance to Development and Parking Standards
15. 2020 EIR Addendum and Technical Appendices
16. 2010 Transit Zoning Code EIR
17. Fiscal and Economic Impact Analysis
75C-348
EXHIBIT 1
75C-349
LS 10.12.20
RESOLUTION NO. 2020-xx
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF SANTA ANA APPROVING AND ADOPTING
AN ADDENDUM TO THE ENVIRONMENTAL IMPACT
REPORT FOR THE TRANSIT ZONING CODE PROJECT
(SCH NO. 2006071100) FOR SITE PLAN REVIEW NO.
2020-03 AND VARIANCE NO. 2020-06 AND ADOPTING A
MITIGATION MONITORING AND REPORTING PROGRAM
FOR THE 4T" AND MORTIMER MIXED -USE
DEVELOPMENT PROJECT LOCATED AT 409 AND 509
EAST FOURTH STREET
WHEREAS, Andrew Nelson, with Red Oak Investments, LLC, representing
Northgate Gonzalez Real Estate (hereinafter referred to as "Applicant'), is requesting
approval of Site Plan Review No. 2020-03 and Variance No. 2020-06, as conditioned, to
allow the construction of a new mixed -use residential and commercial development
consisting of 169 residential rental units and 11,361 square feet of commercial space at
409 and 509 East Fourth Street; and
WHEREAS, the subject property contains 2.715 acres at two separate but
adjacent sites at 409 and 509 East Fourth Street, currently developed with a
commercial building (Northgate Gonzalez Market), surface parking lot, and vacant
buildings and parcels; and
WHEREAS, the Transit Zoning Code was adopted in 2010 as a result of interest
in developing transit -oriented mixed -use residential and commercial projects in its
project area. The Transit Zoning Code was amended in 2019 to modernize and refine
development standards to further these interests. The regulating plan, which establishes
land uses and development standards, allows a variety of housing and commercial
projects, including mixed -use residential communities, live/work units, hotels, and
offices; and
WHEREAS, the City Council of the City of Santa Ana certified the Environmental
Impact Report (SCH No. 2006071100) and adopted a mitigation monitoring and
reporting program for the Transit Zoning Code, which allows a mixture of residential,
commercial, and limited industrial land uses; and
WHEREAS, the entitlements sought for the proposed mixed -use development
project include a Site Plan Review application, Variance application, and an
Amendment Application; and
WHEREAS, in 2010, the City Council certified the Final Environmental Impact
Report ("2010 EIR") for the Transit Zoning Code Project ("Originally Approved Plan"),
Resolution No. 2020-xx
Page 1 of 8
75C-350
which analyzed the potentially significant environmental impacts of a mixed -use plan
area consisting of new residential, commercial, and industrial development; and
WHEREAS, pursuant to the 2010 EIR, the subject site may be developed with a
mixed -use development consisting of residential and commercial land uses; and
WHEREAS, when compared against the Originally Approved Plan, the proposed
mixed -use development will not result in any new or intensified significant impacts; and
WHEREAS, pursuant to the California Environmental Quality Act (Public
Resources Code section 21000 et seq.) ("CEQA") and the State CEQA Guidelines (14
Cal. Code Regs. 15000 et seq.), the City is the Lead Agency for the proposed
development; and
WHEREAS, pursuant to CEQA, when taking subsequent discretionary actions in
furtherance of a project for which an EIR has already been certified, the Lead Agency is
prohibited from requiring a subsequent or supplemental EIR unless at least one of the
circumstances identified in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 are present; and
WHEREAS, City staff has evaluated the proposed project and considered
whether, in light of the impacts associated with its development, any supplemental or
subsequent environmental review is required pursuant to Public Resources Code
section 21166 or State CEQA Guidelines section 15162; and
WHEREAS, the analysis contained in the 4th and Mortimer Mixed -Use
Development project's EIR Addendum ("2020 Addendum") concludes that none of the
circumstances described in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 have occurred, and thus no supplemental or subsequent EIR
is required; and
WHEREAS, the proposed Project is within a transit priority area (TPA) as defined
by Public Resources Code (PRC) Section 21099(a)(7). A TPA is an area within one-half
mile of a major transit stop that is existing (or planned under certain conditions). A major
transit stop includes the intersection of two or more major bus routes with a frequency of
service interval of 15 minutes or less during the morning and afternoon peak commute
periods (PRC § 21064.3). The Project site is within 0.5 miles of the intersection of Bus
Routes 53, 55, 64, 83, 206 and 462 with transit stops located throughout Main Street,
Civic Center Drive, Fifth Street, Santa Ana Boulevard and First Street. Furthermore, the
Santa Ana Metrolink Station and Santa Ana Regional Transportation Center is located
less than 0.5 miles to the east at Santa Ana Boulevard and Santiago Street. The transit
frequency at the stops along Main Street and First Street is every 15-minutes during the
morning and afternoon peak commute periods and therefore qualifies as a high -quality
transit corridor. Lastly, the project is located within a 0.5 miles of a high -quality transit
corridor (routes along Main Street and First Street), plus the future OC Streetcar, which
would further enhance mobility throughout Downtown Santa Ana, beyond the current
Resolution No. 2020-xx
Page 2 of 8
75C-351
transit opportunities that are now availability. Therefore, under SB 743, aesthetic and
parking impacts cannot be considered a significant impact within TPA's; and
WHEREAS, on October 12, 2020 at a duly noticed public hearing, the Planning
Commission considered the 2020 EIR Addendum for Site Plan Review No. 2020-03 and
Variance No. 2020-06; and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have
occurred.
NOW THEREFORE, THE PLANNING COMMISSION OF THE CITY OF SANTA
ANA DOES RESOLVE, DETERMINE, FIND AND ORDER AS FOLLOWS:
SECTION 1. The above recitals are true and correct and incorporated herein by
reference.
SECTION 2. State CEQA Guidelines section 15164 requires lead agencies to
prepare an addendum to a previously certified EIR if some changes or additions to the
project are necessary, but none of the conditions requiring preparation of a subsequent
EIR are present. The Planning Commission has reviewed and considered the 2010 EIR
and the 2020 Addendum, and finds that these documents taken together contain a
complete and accurate reporting of all of the potential environmental impacts associated
with the proposed development. The Planning Commission further finds that the 2020
Addendum has been completed in compliance with CEQA and the State CEQA
Guidelines. The Planning Commission further finds and determines that the EIR
Addendum reflects the City's independent judgment.
SECTION 3. Based on the substantial evidence set forth in the record, including
but not limited to the 2010 EIR and the 2020 Addendum, the Planning Commission finds
that an addendum is the appropriate document for disclosing the changes to the subject
property, and that none of the conditions identified in Public Resources Code section
21166 and State CEQA Guidelines section 15162 requiring subsequent environmental
review have occurred. because:
(a) The proposed development does not constitute a substantial change that
would require major revisions of the 2010 EIR due to the involvement of
new significant environmental effects or a substantial increase in the
severity of previously identified significant effects.
(b) There is not a substantial change with respect to the circumstances under
which the proposed development will be developed that would require
major revisions of the 2010 EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of the
previously identified significant effects.
(c) New information of substantial importance has not been presented that
was not known and could not have been known with the exercise of
Resolution No. 2020-xx
Page 3 of 8
75C-352
reasonable diligence at the time the 2010 EIR was certified or adopted,
showing any of the following: (i) that the modifications would have one or
more significant effects not discussed in the earlier environmental
documentation; (ii) that significant effects previously examined would be
substantially more severe than shown in the earlier environmental
documentation; (iii) that mitigation measures or alternatives previously
found not to be feasible would in fact be feasible and would substantially
reduce one or more significant effects, but the applicant declined to adopt
such measures; or (iv) that mitigation measures or alternatives
considerably different from those analyzed previously would substantially
reduce one or more significant effects on the environment, but which the
Applicant declined to adopt.
SECTION 4. The Planning Commission hereby finds that mitigation measures
identified in the 2010 EIR remain applicable to the Transit Zoning Code, with exception
of mitigation measure MM4.4-1(a) as part of the Cultural Resources which has been
revised after consultation with California Native American Tribes. These findings are
described more specifically in the Mitigation Monitoring and Reporting Program
("MMRP") attached hereto as Exhibit A. The Planning Commission therefore hereby
adopts those mitigation measures identified as remaining applicable to the Transit
Zoning Code, through the MMRP attached hereto and incorporated herein as Exhibit A.
SECTION 5. The Planning Commission hereby approves and adopts the 2020
4th and Mortimer Mixed -Use Development EIR Addendum related to Site Plan Review
No. 2020-03 and Variance No. 2020-06, attached hereto and incorporated herein as
Exhibit B.
SECTION 6. The Applicant shall indemnify, protect, defend and hold the City
and/or any of its officials, officers, employees, agents, departments, agencies,
authorized volunteers, and instrumentalities thereof, harmless from any and all
claims, demands, lawsuits, writs of mandamus, and other and proceedings (whether
legal, equitable, declaratory, administrative or adjudicatory in nature), and alternative
dispute resolution procedures (including, but not limited to arbitrations, mediations,
and such other procedures), judgments, orders, and decisions (collectively "Actions"),
brought against the City and/or any of its officials, officers, employees, agents,
departments, agencies, and instrumentalities thereof, that challenge, attack, or seek
to modify, set aside, void, or annul, any action of, or any permit or approval issued by
the City and/or any of its officials, officers, employees, agents, departments,
agencies, and instrumentalities thereof (including actions approved by the voters of
the City) for or concerning the project, whether such Actions are brought under the
Ralph M. Brown Act, California Environmental Quality Act, the Planning and Zoning
Law, the Subdivision Map Act, Code of Civil Procedure sections 1085 or 1094.5, or
any other federal, state or local constitution, statute, law, ordinance, charter, rule,
regulation, or any decision of a court of competent jurisdiction. It is expressly agreed
that the City shall have the right to approve, which approval will not be unreasonably
withheld, the legal counsel providing the City's defense, and that Applicant shall
Resolution No. 2020-xx
Page 4 of 8
75C-353
reimburse the City for any costs and expenses directly and necessarily incurred by
the City in the course of the defense. City shall promptly notify the Applicant of any
Action brought and City shall cooperate with Applicant in the defense of the Action.
SECTION 7. The Planning Commission directs staff to prepare, execute and file
a CEQA Notice of Determination with the Orange County Clerk's Office within five
working days of the Planning Commission's approval of Site Plan Review No. 2020-03
and Variance No. 2020-06 for the 4th and Mortimer Mixed -Use Development Project.
SECTION 8. The 2010 EIR and the 2020 EIR Addendum, and any other
documents and materials that constitute the record of proceedings upon which these
findings have been based are on file, are incorporated herein by reference and are
available for public review at Santa Ana City Hall, Planning and Building Agency, M20,
20 Civic Center Plaza, Santa Ana, California 92701. The custodian of these records is
Daisy Gomez, City Clerk for the City.
SECTION 9. This resolution shall take effect immediately upon its adoption by
the Planning Commission, and the Recording Secretary shall attest to and certify the
vote adopting this resolution.
ADOPTED this 12th day of October, 2020 by the following vote:
AYES: Commissioners:
NOES: Commissioners:
ABSENT: Commissioners:
ABSTENTIONS: Commissioners:
APPROVED AS TO FORM:
Sonia R. Carvalho, City Attorney
By:
Lisa E. Storck
Assistant City Attorney
Mark McLoughlin
Chairperson
Resolution No. 2020-xx
Page 5 of 8
75C-354
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, SARAH BERNAL Recording Secretary, do hereby attest to and certify the attached
Resolution No. 2020-xx to be the original resolution adopted by the Planning
Commission of the City of Santa Ana on October 12, 2020.
Date:
Recording Secretary
City of Santa Ana
Resolution No. 2020-xx
Page 6 of 8
75C-355
EXHIBIT A
MITIGATION MONITORING AND REPORTING PROGRAM
The Mitigation Monitoring and Reporting Program (MMRP) is available online at:
httr)s://www.santa-ana.ora/pb/plannino-division/major-Dlannino-projects-and-monthly-
development-project-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-356
EXHIBIT B
4T" AND MORTIMER EIR ADDENDUM
The 4th and Mortimer Mixed -Use Development Project EIR Addendum and
Technical Appendices are available online at:
https:Hvjww.santa-ana.orq/pb/planning-division/major-planning-projects-and-
monthly-development-project-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-357
LS 10.12.20
:7 9tel101I1Eel0n[61WQ0Qi=
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF SANTA ANA APPROVING SITE PLAN
REVIEW NO. 2020-03 AS CONDITIONED FOR A NEW
MIXED -USE RESIDENTIAL AND COMMERCIAL
DEVELOPMENT FOR THE PROPERTIES LOCATED AT
409 EAST FOURTH STREET (SITE A) AND 509 EAST
FOURTH STREET (SITE B)
BE IT RESOLVED BY THE PLANNING COMMISSION OF THE CITY OF
SANTA ANA AS FOLLOWS:
Section 1. The Planning Commission of the City of Santa Ana hereby finds,
determines and declares as follows:
A. Andrew Nelson, with Red Oak Investments, LLC, representing Northgate
Gonzalez Real Estate (hereinafter referred to as "Applicant'), is seeking
approval of various entitlements including Site Plan Review No. 2020-03,
Variance No. 2020-06, and Amendment Application 2020-04 to allow the
construction of a new mixed -use residential and commercial development
consisting of 169 residential rental units and 11,361 square feet of
commercial space at 409 and 509 East Fourth Street; and
B. The aApplicant has requested approval of Site Plan Review No. 2020-03
as conditioned, to allow the construction of structures over four stories in
height as part of the new mixed -use residential and commercial
development at 409 and 509 East Fourth Street; and
C. The Transit Zoning Code was adopted in 2010 as a result of interest in
developing mixed -use residential and commercial projects in its project
area. The Transit Zoning Code was amended in 2019 to modernize and
refine development standards to further these interests. The regulating
plan, which establishes land uses and development standards, allows a
variety of housing and commercial projects, including mixed -use
residential communities, live/work units, hotels, and offices.
D. On October 12, 2020, the Planning Commission of the City of Santa Ana
held a duly noticed public hearing regarding Site Plan Review No. 2020-03
and at that time considered all testimony, written and oral.
E. Sections 41-2007 and 41-593.5 of the Santa Ana Municipal Code (SAMC)
requires a review by the Planning Commission of all plans for
developments of over four stories within the Transit Zoning Code (Specific
Development No. 84) to ensure the project is in conformity with the
overlay zone plan.
75C-358
F. The zoning designation for the subject property is Specific Development
No. 84, Downtown and Urban Neighborhood-2 sub -zone.
G. The Planning Commission determines that pursuant to SAMC Sections
41-2007 and 41-593.5, the project is in compliance with all applicable
development standards outlined within the Specific Development (SD No.
84/Transit Zoning Code), with the exception of required building size, type,
and massing, which are being considered separately as and subject to
approval of Variance No. 2020-06 and Amendment Application No. 2020-
04.
Section 2. The Applicant shall indemnify, protect, defend and hold
the City and/or any of its officials, officers, employees, agents, departments,
agencies, authorized volunteers, and instrumentalities thereof, harmless from any
and all claims, demands, lawsuits, writs of mandamus, and other and proceedings
(whether legal, equitable, declaratory, administrative or adjudicatory in nature), and
alternative dispute resolution procedures (including, but not limited to arbitrations,
mediations, and such other procedures), judgments, orders, and decisions
(collectively "Actions"), brought against the City and/or any of its officials, officers,
employees, agents, departments, agencies, and instrumentalities thereof, that
challenge, attack, or seek to modify, set aside, void, or annul, any action of, or any
permit or approval issued by the City and/or any of its officials, officers, employees,
agents, departments, agencies, and instrumentalities thereof (including actions
approved by the voters of the City) for or concerning the project, whether such
Actions are brought under the Ralph M. Brown Act, California Environmental Quality
Act, the Planning and Zoning Law, the Subdivision Map Act, Code of Civil Procedure
sections 1085 or 1094.5, or any other federal, state or local constitution, statute, law,
ordinance, charter, rule, regulation, or any decision of a court of competent
jurisdiction. It is expressly agreed that the City shall have the right to approve, which
approval will not be unreasonably withheld, the legal counsel providing the City's
defense, and that Applicant shall reimburse the City for any costs and expenses
directly and necessarily incurred by the City in the course of the defense. City shall
promptly notify the Applicant of any Action brought and City shall cooperate with
Applicant in the defense of the Action.
Section 3. In accordance with the California Environmental Quality Act
(CEQA), the Planning Commission of the City of Santa Ana hereby finds, determines,
and declares as follows:
Based on the substantial evidence set forth in the record, including but not
limited to the 2010 EIR and the 2020 EIR Addendum, the Planning Commission
finds that an addendum is the appropriate document for disclosing the changes
to the subject properties, and that none of the conditions identified in Public
Resources Code section 21166 and State CEQA Guidelines section 15162
requiring subsequent environmental review have occurred, because:
75C-359
A. The project does not constitute a substantial change that would
require major revisions of the 2010 EIR due to the involvement of
new significant environmental effects or a substantial increase in
the severity of previously identified significant effects.
B. There is not a substantial change with respect to the circumstances
under which the project will be developed that would require major
revisions of the 2010 EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of the
previously identified significant effects.
C. New information of substantial importance has not been presented
that was not known and could not have been known with the
exercise of reasonable diligence at the time the 2010 EIR was
certified or adopted, showing any of the following: (i) that the
modifications would have one or more significant effects not
discussed in the earlier environmental documentation; (ii) that
significant effects previously examined would be substantially more
severe than shown in the earlier environmental documentation; (iii)
that mitigation measures or alternatives previously found not to be
feasible would in fact be feasible and would substantially reduce
one or more significant effects, but the Applicant declined to adopt
such measures; or (iv) that mitigation measures or alternatives
considerably different from those analyzed previously would
substantially reduce one or more significant effects on the
environment, but which the Applicant declined to adopt.
Section 4. The Planning Commission of the City of Santa Ana, after conducting
the public hearing, hereby approves Site Plan Review No. 2020-03 as conditioned in
Exhibit A, attached hereto and incorporated as though fully set forth herein. This decision
is based upon the evidence submitted at the above said hearing, which includes, but is
not limited to: the Request for Planning Commission Action dated October 12, 2020, and
exhibits attached thereto; and the public testimony, written and oral, all of which are
incorporated herein by this reference.
Section 5. Site Plan Review No. 2020-03 shall not be effective unless and until the
Planning Commission reviews and approves the EIR Addendum, Environmental Review
No. 2018-113, and Variance No. 2020-06 and the City Council reviews and approves the
EIR Addendum, Environmental Review No. 2018-113, and Amendment Application No.
2020-04 for the subject project. If said approvals are held to be invalid or unconstitutional
by the decision of any court of competent jurisdiction, or otherwise denied, then this
variance shall be null and void and have no further force and effect.
ADOPTED this 12th day of October, 2020 by the following vote:
75C-360
AYES: Commissioners:
NOES: Commissioners:
ABSENT: Commissioners:
ABSTENTIONS: Commissioners:
Mark McLoughlin
Chairperson
APPROVED AS TO FORM:
Sonia R. Carvalho, City Attorney
By:
Lisa E. Storck
Assistant City Attorney
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, SARAH BERNAL Recording Secretary, do hereby attest to and certify the attached
Resolution No. 2020-xx to be the original resolution adopted by the Planning
Commission of the City of Santa Ana on October 12, 2020.
Date:
Recording Secretary
City of Santa Ana
75C-361
EXHIBIT A
Conditions for Approval for Site Plan Review No. 2020-03
Site Plan Review No. 2020-03 is approved subject to compliance, to the reasonable
satisfaction of the Planning Manager, with applicable sections of the Santa Ana Municipal
Code, the California Administrative Code, the California Building Standards Code, and all
other applicable regulations. In addition, it shall meet the following conditions of approval:
The Applicant must comply with each and every condition listed below Prior to exercising
the rights conferred by this site plan review.
The Applicant must remain in compliance with all conditions listed below throughout the
life of the development project. Failure to comply with each and every condition may result
in the revocation of the site plan review.
1. All proposed site improvements must conform to the Site Plan Review (DP No. 2018-
28) and the staff report exhibits incorporated herein by reference. -
2. Any amendment to this site plan review, including modifications to approved materials,
finishes, architecture, site plan, landscaping, unit count, mix, and square footages must
be submitted to the Planning Division for review. At that time, staff will determine if
administrative relief is available or if the site plan review must be amended.
3. A final detailed amenity plan must be reviewed and approved prior to issuance of any
building permits. The plan shall include details on the hardscape design, lighting
concepts and outdoor furniture for amenity, plaza, or courtyard areas as well as an
installation plan. The exact specifications for these items are subject to the review and
approval by the Planning Division.
4. Prior to issuance of building permits, the Applicant shall submit a construction schedule
and staging plan to the Planning Division for review and approval. The plan shall
include construction hours, staging areas, parking and site security/screening during
project construction.
5. Prior to the issuance of a building permit, a full landscape and irrigation plan is to be
submitted for review and approval. The landscape plan shall: (1) conform to the
commercial landscape standards, Citywide Design Guidelines, and the City's Water
Efficient Landscape Ordinance, and (2) contain regularly -spaced vines installed along
the entire lengths of the new perimeter wall and the trash enclosure so as to form a
natural graffiti deterrent.
6. Prior to the issuance of a building permit, a Public Art Plan must be submitted to the
Planning Division for review and approval. The aApplicant shall work with the City's
Arts & Culture Office to identify local artist, and receive recommendations on
establishing a process for selecting and displaying such local artwork.
75C-362
7. Prior to installation of landscaping, the Applicant shall submit photos and specifications
of all trees to be installed on the project site for review and approval by the Planning
Division. Specifications shall include, at a minimum, the species, box size (24 inches
minimum), brown trunk height (10-foot minimum), and name and location of the
supplier.
8. A Resident Storage Plan shall be provided for the project prior to issuance of certificate
of occupancy. Storage shall be available at no cost to the residents.
9. After project occupancy, landscaping and hardscape materials must be maintained as
shown on the approved landscape plans.
10. All mechanical equipment shall be screened from view from public and courtyard
areas.
11. The Applicant shall be responsible for maintaining the premises free of graffiti. All
graffiti shall be removed within 24 hours of occurrence.
12. A residential property manager shall be on site at all times that the project is occupied
and the developer and on -site management shall at all times maintain a 24-hour
emergency contact and contact information on file with the City.
13. Residents of both development sites in the Project (Site A and Site B) shall have
access to resident amenities, onsite parking, and open space areas in both sites in
perpetuity.
14. No more than one individual lease shall be permitted per unit. Leasing of individual
bedrooms shall not be permitted.
15.A Property Maintenance Agreement must be recorded against the property. The
agreement will be subject to review and applicability by the Planning and Building
Agency, the Community Development Agency, the Public Works Agency, and the
City Attorney to ensure that the property and all improvements located thereupon
are properly maintained, Developer (and the owner of the property upon which the
authorized use and/or authorized improvements are located if different from the
Applicant) shall execute a maintenance agreement with the City of Santa Ana which
shall be recorded against the property and which shall be in a form reasonably
satisfactory to the City Attorney. The maintenance agreement shall contain
covenants, conditions and restrictions relating to the following:
(a) Compliance with operational conditions applicable during any period(s) of
construction or major repair (e.g., proper screening and securing of the
construction site; implementation of proper erosion control, dust control and
noise mitigation measure; adherence to approved project phasing etc.);
75C-363
(b) Compliance with ongoing operational conditions, requirements and
restrictions, as applicable (including but not limited to hours of operation, security
requirements, the proper storage and disposal of trash and debris, enforcement
of the parking management plan, and/or restrictions on certain uses,
(c) Ongoing compliance with approved design and construction parameters,
signage parameters and restrictions as well as landscape designs, as applicable;
(d) Ongoing maintenance, repair and upkeep of the property and all
improvements located thereupon (including but not limited to controls on the
proliferation of trash and debris about the property; the proper and timely removal
of graffiti; the timely maintenance, repair and upkeep of damaged, vandalized
and/or weathered buildings, structures and/or improvements; the timely
maintenance, repair and upkeep of exterior paint, parking striping, lighting and
irrigation fixtures, walls and fencing, publicly accessible bathrooms and bathroom
fixtures, landscaping and related landscape improvements and the like, as
applicable);
(e) If Developer and the owner of the property are different (e.g., if the Applicant
is a tenant or licensee of the property or any portion thereof), both the Applicant
and the owner of the property shall be signatories to the maintenance agreement
and both shall be jointly and severally liable for compliance with its terms.
(f) The maintenance agreement shall further provide that any party responsible
for complying with its terms shall not assign its ownership interest in the property
or any interest in any lease, sublease, license or sublicense, unless the
prospective assignee agrees in writing to assume all of the duties, obligations
and responsibilities set forth under the maintenance agreement.
(g) The maintenance agreement shall contain provisions relating to the
enforcement of its conditions by the City and shall also contain provisions
authorizing the City to recover costs and expenses which the City may incur
arising out of any enforcement and/or remediation efforts which the City may
undertake in order to cure any deficiency in maintenance, repair or upkeep or to
enforce any restrictions or conditions upon the use of the property. The
maintenance agreement shall further provide that any unreimbursed costs and/or
expenses incurred by the City to cure a deficiency in maintenance or to enforce
use restrictions shall become a lien upon the property in an amount equivalent to
the actual costs and/or expense incurred by the City.
(h) The execution and recordation of the maintenance agreement shall be a
condition precedent to the issuance of final approval for any construction permit
related to this entitlement.
75C-364
LS 10.12.20
RESOLUTION NO. 2020-xx
A RESOLUTION OF THE PLANNING COMMISSION OF
THE CITY OF SANTA ANA APPROVING VARIANCE NO.
2020-06 AS CONDITIONED TO ALLOW AN INCREASE IN
THE ALLOWABLE BUILDING SIZE AND MASSING ON
SITE B AS PART OF A NEW MIXED -USE RESIDENTIAL
AND COMMERCIAL DEVELOPMENT FOR THE
PROPERTIES LOCATED AT 409 EAST FOURTH STREET
(SITE A) AND 509 EAST FOURTH STREET (SITE B)
BE IT RESOLVED BY THE PLANNING COMMISSION OF THE CITY OF
SANTA ANA AS FOLLOWS:
Section 1. The Planning Commission of the City of Santa Ana hereby finds,
determines and declares as follows:
A. Andrew Nelson, with Red Oak Investments, LLC, representing Northgate
Gonzalez Real Estate (hereinafter referred to as "Applicant"), is seeking
approval of various entitlements including Site Plan Review No. 2020-03,
Variance No. 2020-06, and Amendment Application No. 2020-04 to allow
the construction of a new mixed -use residential and commercial
development consisting of 169 residential rental units and 11,361 square
feet of commercial space at 409 and 509 East Fourth Street; and
B. The Applicant has requested approval of Variance No. 2020-06 as
conditioned, to exceed the allowable building size and massing standards
on Site B as part of the new mixed -use residential and commercial
development at 409 and 509 East Fourth Street; and
C. Santa Ana Municipal Code (SAMC) Section 41-2023(i)(5) of the Transit
Zoning Code requires that the maximum ratio of each lined block story,
between three and five stories, be 85 percent of the project's ground
floor's volume.
D. The Applicant is proposing an increase in the allowable maximum ratio for
the building on 509 East Fourth Street (Site B) for the third through fifth
floor, where each floor would be 100 percent of the building's ground floor
volume, exceeding the allowable ratio by 15 percent of the ground and
second floor volumes on each of floors three through five.
E. Pursuant to SAMC Section 41-638, the Planning Commission is
authorized to review and approve the variance for this project as set forth
by the Santa Ana Municipal Code.
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F. On October 12, 2020, the Planning Commission of the City of Santa Ana
held a duly noticed public hearing regarding Variance No. 2020-06 and at
that time considered all testimony, written and oral.
G. The Planning Commission of the City of Santa Ana has considered the
information and determines that following findings, which must be
established in order to grant Variance No. 2020-06, have been established
as required by SAMC Section 41-638:
That because of special circumstances applicable to the subject
property, including size, shape, topography, location or
surroundings, the strict application of the zoning ordinance is found
to deprive the subject property of privileges not otherwise at
variance with the intent and purpose of the provisions of this
Chapter.
The project site has a special circumstance related to its
existing shape and location. Site B has a smaller than
average lot depth and lot width, compared to most lots in the
downtown area. Lots in the downtown area average 250 feet
by 250 feet. While portions of Site B meet the average lot
width and depth, a majority of Site B is smaller -than -
average. Site A takes advantage of a full city block with
complete street frontages along every street while Site B is
interrupted by an adjacent parcel not part of the project, and
approximately 6,200 square feet in size, or 50 feet by 124
feet. This results in Site B having smaller -than -average
street frontages along Mortimer and Fourth Streets. Without
the increase in the allowable building size and massing
standards, the project would need to be redesigned,
resulting in several impacts to the feasibility of the site's
development. These impacts would include a loss off-street
parking spaces by requiring a reduction in size of the parking
structure; an incompatible design and unbalanced
composition of massing the project site; and/or a smaller
building footprint that would reduce the building's interior
floor area and individual unit sizes.
2. That the granting of a variance is necessary for the preservation
and enjoyment of one (1) or more substantial property rights.
Granting this variance is necessary for the preservation and
enjoyment of substantial property rights. An increase in the
allowable maximum ratio would allow for a design that takes
into account Downtown Santa Ana's smaller -than -average
lot depths as well as the interruption of the adjacent parcel,
account for engineering and design challenges of buildings
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75C-366
when step -backs are required on upper levels. Moreover, an
increase in the allowable maximum ratio would avoid a two -
block development where one block looks arbitrarily carved
down by a forced stepback and avoid an incompatible
design that could cause an unbalanced composition of
massing along Fourth Street, inconsistent with the
architectural vernacular and intentions of the Transit Zoning
Code.
3. That the granting of a variance will not be materially detrimental to
the public welfare or injurious to surrounding property.
The granting of the variance will not be detrimental to the
public or surrounding properties. A shade and shadow
analysis was conducted for the proposed project. The Site
Shadow Study indicates that none of the sensitive uses
surrounding the project sites would be shaded by either
building for more than three hours between 9:00 A.M. and
3:00 P.M. during the Winter Solstice. Likewise, sensitive land
uses would not be shaded by project structures for more
than five hours between 9:00 A.M. and 5:00 P.M. during the
summer. As such, the proposed project would not result in a
new significant impact or substantially increase the severity
of a previously identified significant impact with respect to
shade and shadow beyond those analyzed in the 2010 ElR.
Moreover, the adjacent automotive repair and commercial
space on Site B offers collective massing relief for the site.
Although not part of the project, this parcel's size means that
if redeveloped, it will always be to a lower building and
massing scale than the proposed five -story structure on Site
B. When viewed collectively, the amount of "stepback" or
reduction in floor volume would exceed the required 85% of
ground floor requirement and would be roughly comparable
to the third floor stepback accomplished by the courtyard on
Site A. Further, the Citywide Design Guidelines encourage
new buildings to be compatible with surrounding character,
including building style, form, size, materials, and roofline.
Specifically, Chapter 8 (Downtown Development
Guidelines), Section 8.6 encourages that the height and
scale of new buildings complement existing structures and
provide a sense of human scale and proportion. As the two
blocks are being developed together they're designed with
appropriate congruity and diversity in both style and
articulation. Both buildings rise with balanced "U-shaped"
courtyard design facing Fourth Street and vary significantly
with a two-story height variation. A two -block development
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75C-367
where one block looks arbitrarily carved down by a forced
stepback would present as an incompatible design and could
cause an unbalanced composition of massing along Fourth
Street, inconsistent with the architectural vernacular and
intentions of the Transit Zoning Code.
4. That the granting of a variance will not adversely affect the General
Plan of the city.
The variance for increase in the allowable maximum ratio will
not adversely affect the General Plan. The project site has a
General Plan designation of District Center on Site A and
Urban Neighborhood on Site B. The District Center -
Downtown District and Urban Neighborhood land use
designation accommodates high-rise office, commercial, and
mixed -use residential uses with an emphasis on streets that
accommodate all modes of transportation for this land use
designation. The allowable floor area ratio (FAR) for District
Center and Urban Neighborhood land use designation would
be a maximum of 3.0 and 1.80, respectively. The proposed
project would include construction of two new buildings, one
of which would be seven stories in height with an FAR of 2.4
(Building A) and one that would be five stories in height with
an FAR of 1.8 (Building B), consistent with the allowable
FAR as part of the General Plan. Furthermore, the project is
consistent with several goals and policies of the General
Plan, including the Economic Development Element, Land
Use Element, and Urban Design Element. Land Use
Element Goal 1 promotes a balance of land uses to address
basic community needs. Policy 1.1 promotes medium
density housing in and around the downtown area and Policy
1.2 supports high -density residential development within the
City's District Centers as a part of a mixed -use development.
The project will involve construction of a mixed -use
residential and commercial building on Site A with a density
of 69.6 du/ac, and a multi -family residential building on Site
B with a density of 54.2 du/ac, on two adjacent city blocks in
downtown, within the Transit Zoning Code area. Land Use
Element Goal 2 promotes land uses that enhance the City's
economic and fiscal viability. Policy 2.7 support projects that
contribute to the redevelopment and revitalization of the
central City urban areas. The development proposes to
redevelop two City blocks currently occupied by a
commercial building, surface parking lot, and vacant and
unimproved buildings and parcels. Policy 2.10 supports new
development, which is harmonious in scale and character
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75C-368
with existing development in the area. Both sites in the
development have been carefully designed to be integrated
within the existing development pattern in Downtown Santa
Ana.
Economic Development Element Goal 2 maintains and
enhances the diversity of the City's economic base. Policy
2.3 encourages the development of mutually beneficial and
supportive business clusters within the community. The
construction of this project will contribute toward an
economically balanced community by providing housing and
commercial retail opportunities (e.g., restaurant, retail sales,
etc.) for different demographics in an area rich with
employment opportunities, commercial development, and
market -rate housing. In addition, a fiscal and economic
impact analysis estimates that the proposed development
will result net positive fiscal impacts to the City, the Business
Improvement District, and over 800 new temporary or
permanent jobs. Specifically, the analysis estimates $5.4
million net new General Fund revenues associated with the
project over a 25-year period.
Urban Design Element Goal 1 improves the physical
appearance of the City through development of districts that
project a sense of place, positive community image and
quality environment. Specifically, Policy 1.5 enhances
architectural forms, textures, colors, and materials for all
projects. The project's storefront widths, window heights,
setbacks, and other architectural features have been
carefully evaluated to ensure a seamless transition from
existing buildings to the new project. Each site has its own
unique architectural vernacular defined by scale, facade
articulation, roof forms, materials, and detailing. Both of
these blocks are designed in closely related and established
California Contemporary architectural style, which
complements the neighborhood in which the project site is
located.
Section 2. The Applicant shall indemnify, protect, defend and hold the City
and/or any of its officials, officers, employees, agents, departments, agencies,
authorized volunteers, and instrumentalities thereof, harmless from any and all claims,
demands, lawsuits, writs of mandamus, referendum, and other proceedings (whether
legal, equitable, declaratory, administrative or adjudicatory in nature), and alternative
dispute resolution procedures (including, but not limited to arbitrations, mediations, and
such other procedures), judgments, orders, and decisions (collectively "Actions"),
brought against the City and/or any of its officials, officers, employees, agents,
departments, agencies, and instrumentalities thereof, that challenge, attack, or seek to
I1=11r,Me, Rew-WO18bT
75C-369
modify, set aside, void, or annul, any action of, or any permit or approval issued by the
City and/or any of its officials, officers, employees, agents, departments, agencies, and
instrumentalities thereof (including actions approved by the voters of the City) for or
concerning the project, whether such Actions are brought under the Ralph M. Brown
Act, California Environmental Quality Act, the Planning and Zoning Law, the Subdivision
Map Act, Code of Civil Procedure sections 1085 or 1094.5, or any other federal, state or
local constitution, statute, law, ordinance, charter, rule, regulation, or any decision of a
court of competent jurisdiction. It is expressly agreed that the City shall have the right to
approve, which approval will not be unreasonably withheld, the legal counsel providing
the City's defense, and that Applicant shall reimburse the City for any costs and
expenses directly and necessarily incurred by the City in the course of the defense.
City shall promptly notify the Applicant of any Action brought and City shall cooperate
with Applicant in the defense of the Action.
Section 3. In accordance with the California Environmental Quality Act
(CEQA), the Planning Commission of the City of Santa Ana hereby finds, determines,
and declares as follows:
Based on the substantial evidence set forth in the record, including but not
limited to the 2010 EIR and the 2020 4th and Mortimer Mixed -Use Development
EIR Addendum, the Planning Commission finds that an addendum is the
appropriate document for disclosing the changes to the subject properties, and
that none of the conditions identified in Public Resources Code section 21166
and State CEQA Guidelines section 15162 requiring subsequent environmental
review have occurred. because:
A. The project does not constitute a substantial change that would
require major revisions of the 2010 EIR due to the involvement of
new significant environmental effects or a substantial increase in
the severity of previously identified significant effects.
B. There is not a substantial change with respect to the circumstances
under which the project will be developed that would require major
revisions of the 2010 EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of the
previously identified significant effects.
C. New information of substantial importance has not been presented
that was not known and could not have been known with the
exercise of reasonable diligence at the time the 2010 EIR was
certified or adopted, showing any of the following: (i) that the
modifications would have one or more significant effects not
discussed in the earlier environmental documentation; (ii) that
significant effects previously examined would be substantially more
severe than shown in the earlier environmental documentation; (iii)
that mitigation measures or alternatives previously found not to be
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feasible would in fact be feasible and would substantially reduce
one or more significant effects, but the applicant declined to adopt
such measures; or (iv) that mitigation measures or alternatives
considerably different from those analyzed previously would
substantially reduce one or more significant effects on the
environment, but which the Applicant declined to adopt.
Section 4. The Planning Commission of the City of Santa Ana, after conducting the
public hearing, hereby approves Variance No. 2020-06 as conditioned in "Exhibit A"
attached hereto and incorporated as though fully set forth herein. This decision is based
upon the evidence submitted at the above said hearing, which includes, but is not limited
to: the Request for Planning Commission Action dated October 12, 2020, and exhibits
attached thereto; and the public testimony, written and oral, all of which are incorporated
herein by this reference.
Section 5. Variance No. 2020-06 shall not be effective unless and until the Planning
Commission reviews and approved the EIR Addendum, Environmental Review No. 2018-
113, and Site Plan Review No. 2020-03 and the City Council reviews and approves the
EIR Addendum, Environmental Review No. 2018-113, and Amendment Application No.
2020-04 for the subject project. If said approvals are held to be invalid or unconstitutional
by the decision of any court of competent jurisdiction, or otherwise denied, then this
variance shall be null and void and have no further force and effect.
ADOPTED this 12th day of October, 2020 by the following vote:
AYES: Commissioners:
NOES: Commissioners:
ABSENT: Commissioners:
ABSTENTIONS: Commissioners:
APPROVED AS TO FORM:
Sonia R. Carvalho, City Attorney
By:
Lisa E. Storck
Mark McLoughlin
Chairperson
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75C-371
Assistant City Attorney
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, SARAH BERNAL Recording Secretary, do hereby attest to and certify the attached
Resolution No. 2020-xx to be the original resolution adopted by the Planning
Commission of the City of Santa Ana on October 12, 2020.
Date:
Recording Secretary
City of Santa Ana
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EXHIBIT A
Conditions for Approval for Variance No. 2020-06
Variance No. 2020-06 is approved subject to compliance, to the reasonable satisfaction of
the Planning Manager, with applicable sections of the Santa Ana Municipal Code, the
California Administrative Code, the California Building Standards Code, and all other
applicable regulations. In addition, they shall meet the following conditions of approval:
The Applicant must comply with each and every condition listed below Prior to exercising
the rights conferred by this variance.
The Applicant must remain in compliance with all conditions listed below throughout the
life of the development project. Failure to comply with each and every condition may result
in the revocation of the site plan review.
1. All proposed site improvements must conform to the Site Plan Review (DP No. 2018-
28) and the staff report exhibits incorporated herein by reference.
2. Any amendment to this site plan review, including modifications to approved materials,
finishes, architecture, site plan, landscaping, unit count, mix, and square footages must
be submitted to the Planning Division for review. At that time, staff will determine if
administrative relief is available or if the site plan review must be amended.
3. A final detailed amenity plan must be reviewed and approved prior to issuance of any
building permits. The plan shall include details on the hardscape design, lighting
concepts and outdoor furniture for amenity, plaza, or courtyard areas as well as an
installation plan. The exact specifications for these items are subject to the review and
approval by the Planning Division.
4. Prior to issuance of building permits, the Applicant shall submit a construction schedule
and staging plan to the Planning Division for review and approval. The plan shall
include construction hours, staging areas, parking and site security/screening during
project construction.
5. Prior to the issuance of a building permit, a full landscape and irrigation plan is to be
submitted for review and approval. The landscape plan shall: (1) conform to the
commercial landscape standards, Citywide Design Guidelines, and the City's Water
Efficient Landscape Ordinance, and (2) contain regularly -spaced vines installed along
the entire lengths of the new perimeter wall and the trash enclosure so as to form a
natural graffiti deterrent.
6. Prior to the issuance of a building permit, a Public Art Plan must be submitted to the
Planning Division for review and approval. The applicant shall work with the City's Arts
& Culture Office to identify local artists, and receive recommendations on establishing
a process for selecting and displaying such local artwork.
75C-373
7. Prior to installation of landscaping, the Applicant shall submit photos and specifications
of all trees to be installed on the project site for review and approval by the Planning
Division. Specifications shall include, at a minimum, the species, box size (24 inches
minimum), brown trunk height (10-foot minimum), and name and location of the
supplier.
8. A Resident Storage Plan shall be provided for the project prior to issuance of certificate
of occupancy. Storage shall be available at no cost to the residents.
9. After project occupancy, landscaping and hardscape materials must be maintained as
shown on the approved landscape plans.
10. All mechanical equipment shall be screened from view from public and courtyard
areas.
11. The Applicant shall be responsible for maintaining the premises free of graffiti. All
graffiti shall be removed within 24 hours of occurrence.
12. A residential property manager shall be on site at all times that the project is occupied
and the developer and on -site management shall at all times maintain a 24-hour
emergency contact and contact information on file with the City.
13. Residents of both development sites in the Project (Site A and Site B) shall have
access to resident amenities, onsite parking, and open space areas in both sites in
perpetuity.
14. No more than one individual lease shall be permitted per unit. Leasing of individual
bedrooms shall not be permitted.
15.A Property Maintenance Agreement must be recorded against the property. The
agreement will be subject to review and applicability by the Planning and Building
Agency, the Community Development Agency, the Public Works Agency, and the
City Attorney to ensure that the property and all improvements located thereupon
are properly maintained, Developer (and the owner of the property upon which the
authorized use and/or authorized improvements are located if different from the
Applicant) shall execute a maintenance agreement with the City of Santa Ana which
shall be recorded against the property and which shall be in a form reasonably
satisfactory to the City Attorney. The maintenance agreement shall contain
covenants, conditions and restrictions relating to the following:
(a) Compliance with operational conditions applicable during any period(s) of
construction or major repair (e.g., proper screening and securing of the
construction site; implementation of proper erosion control, dust control and
noise mitigation measure; adherence to approved project phasing etc.);
(b) Compliance with ongoing operational conditions, requirements and
restrictions, as applicable (including but not limited to hours of operation, security
requirements, the proper storage and disposal of trash and debris, enforcement
of the parking management plan, and/or restrictions on certain uses,
75C-374
(c) Ongoing compliance with approved design and construction parameters,
signage parameters and restrictions as well as landscape designs, as applicable;
(d) Ongoing maintenance, repair and upkeep of the property and all
improvements located thereupon (including but not limited to controls on the
proliferation of trash and debris about the property; the proper and timely removal
of graffiti; the timely maintenance, repair and upkeep of damaged, vandalized
and/or weathered buildings, structures and/or improvements; the timely
maintenance, repair and upkeep of exterior paint, parking striping, lighting and
irrigation fixtures, walls and fencing, publicly accessible bathrooms and bathroom
fixtures, landscaping and related landscape improvements and the like, as
applicable);
(e) If Developer and the owner of the property are different (e.g., if the Applicant
is a tenant or licensee of the property or any portion thereof), both the Applicant
and the owner of the property shall be signatories to the maintenance agreement
and both shall be jointly and severally liable for compliance with its terms.
(f) The maintenance agreement shall further provide that any party responsible
for complying with its terms shall not assign its ownership interest in the property
or any interest in any lease, sublease, license or sublicense, unless the
prospective assignee agrees in writing to assume all of the duties, obligations
and responsibilities set forth under the maintenance agreement.
(g) The maintenance agreement shall contain provisions relating to the
enforcement of its conditions by the City and shall also contain provisions
authorizing the City to recover costs and expenses which the City may incur
arising out of any enforcement and/or remediation efforts which the City may
undertake in order to cure any deficiency in maintenance, repair or upkeep or to
enforce any restrictions or conditions upon the use of the property. The
maintenance agreement shall further provide that any unreimbursed costs and/or
expenses incurred by the City to cure a deficiency in maintenance or to enforce
use restrictions shall become a lien upon the property in an amount equivalent to
the actual costs and/or expense incurred by the City.
(h) The execution and recordation of the maintenance agreement shall be a
condition precedent to the issuance of final approval for any construction permit
related to this entitlement.
75C-375
EXHIBIT 2
75C-376
LS 10.12.20
:0 9tel1011rEelan[.II►EQ11941 ST.J
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF
SANTA ANA APPROVING AND ADOPTING AN
ADDENDUM TO THE ENVIRONMENTAL IMPACT
REPORT FOR THE TRANSIT ZONING CODE PROJECT
(SCH NO. 2006071100) FOR AMENDMENT APPLICATION
NO. 2020-04 AND ADOPTION OF A MITIGATION
MONITORING AND REPORTING PROGRAM FOR THE 4T"
AND MORTIMER MIXED -USE DEVELOPMENT PROJECT
LOCATED AT 409 AND 509 EAST FOURTH STREET
WHEREAS, Andrew Nelson, with Red Oak Investments, LLC, representing
Northgate Gonzalez Real Estate (hereinafter referred to as "Applicant'), is requesting
approval of Amendment Application No. 2020-04, as conditioned, to allow the
construction of a new mixed -use residential and commercial development consisting of
169 residential rental units and 11,361 square feet of commercial space at 409 and 509
East Fourth Street; and
WHEREAS, the subject property contains 2.715 acres at two separate but
adjacent sites at 409 and 509 East Fourth Street, currently developed with a
commercial building (Northgate Gonzalez Market), surface parking lot, and vacant
buildings and parcels; and
WHEREAS, the Transit Zoning Code was adopted in 2010 as a result of interest
in developing transit -oriented mixed -use residential and commercial projects in its
project area. The Transit Zoning Code was amended in 2019 to modernize and refine
development standards to further these interests. The regulating plan, which establishes
land uses and development standards, allows a variety of housing and commercial
projects, including mixed -use residential communities, live/work units, hotels, and
offices; and
WHEREAS, the City Council of the City of Santa Ana certified the Environmental
Impact Report (SCH No. 2006071100) and adopted a mitigation monitoring and
reporting program for the Transit Zoning Code, which allows a mixture of residential,
commercial, and limited industrial land uses; and
WHEREAS, the entitlements sought for the proposed mixed -use development
project include a Site Plan Review application, Variance application, and an
Amendment Application; and
WHEREAS, in 2010, the City Council certified the Final Environmental Impact
Report ("2010 EIR") for the Transit Zoning Code Project ("Originally Approved Plan"),
Resolution No. 2020-xx
Page 1 of 8
75C-377
which analyzed the potentially significant environmental impacts of a mixed -use plan
area consisting of new residential, commercial, and industrial development; and
WHEREAS, pursuant to the 2010 EIR, the subject site may be developed with a
mixed -use development consisting of residential and commercial land uses; and
WHEREAS, when compared against the Originally Approved Plan, the proposed
mixed -use development will not result in any new or intensified significant impacts; and
WHEREAS, pursuant to the California Environmental Quality Act (Public
Resources Code section 21000 et seq.) ("CEQA") and the State CEQA Guidelines (14
Cal. Code Regs. 15000 et seq.), the City is the Lead Agency for the proposed
development; and
WHEREAS, pursuant to CEQA, when taking subsequent discretionary actions in
furtherance of a project for which an EIR has already been certified, the Lead Agency is
prohibited from requiring a subsequent or supplemental EIR unless at least one of the
circumstances identified in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 are present; and
WHEREAS, City staff has evaluated the proposed project and considered
whether, in light of the impacts associated with its development, any supplemental or
subsequent environmental review is required pursuant to Public Resources Code
section 21166 or State CEQA Guidelines section 15162; and
WHEREAS, the analysis contained in the 4th and Mortimer Mixed -Use
Development project's EIR Addendum ("2020 Addendum") concludes that none of the
circumstances described in Public Resources Code section 21166 or State CEQA
Guidelines section 15162 have occurred, and thus no supplemental or subsequent EIR
is required; and
WHEREAS, the proposed Project is within a transit priority area (TPA) as defined
by Public Resources Code (PRC) Section 21099(a)(7). A TPA is an area within one-half
mile of a major transit stop that is existing (or planned under certain conditions). A major
transit stop includes the intersection of two or more major bus routes with a frequency of
service interval of 15 minutes or less during the morning and afternoon peak commute
periods (PRC § 21064.3). The Project site is within 0.5 miles of the intersection of Bus
Routes 53, 55, 64, 83, 206 and 462 with transit stops located throughout Main Street,
Civic Center Drive, Fifth Street, Santa Ana Boulevard and First Street. Furthermore, the
Santa Ana Metrolink Station and Santa Ana Regional Transportation Center is located
less than 0.5 miles to the east at Santa Ana Boulevard and Santiago Street. The transit
frequency at the stops along Main Street and First Street is every 15-minutes during the
morning and afternoon peak commute periods and therefore qualifies as a high -quality
transit corridor. Lastly, the project is located within a 0.5 miles of a high -quality transit
corridor (routes along Main Street and First Street), plus the future OC Streetcar, which
would further enhance mobility throughout Downtown Santa Ana, beyond the current
Resolution No. 2020-xx
Page 2 of 8
75C-378
transit opportunities that are now availability. Therefore, under SB 743, aesthetic and
parking impacts cannot be considered a significant impact within TPA's; and
WHEREAS, on October 12, 2020 at a duly noticed public hearing, the Planning
Commission considered the 2020 EIR Addendum for Site Plan Review No. 2020-03 and
Variance No. 2020-06 when recommending that the City Council approve the Project;
and
WHEREAS, on November 17, 2020 at a duly noticed public hearing, the City
Council considered the 2020 EIR Addendum for Amendment Application No. 2020-04;
and
WHEREAS, all other legal prerequisites to the adoption of this Resolution have
occurred.
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA ANA
DOES RESOLVE, DETERMINE, FIND AND ORDER AS FOLLOWS:
SECTION 1. The above recitals are true and correct and incorporated herein by
reference.
SECTION 2. State CEQA Guidelines section 15164 requires lead agencies to
prepare an addendum to a previously certified EIR if some changes or additions to the
project are necessary, but none of the conditions requiring preparation of a subsequent
EIR are present. The City Council has reviewed and considered the 2010 EIR and the
2020 Addendum, and finds that these documents taken together contain a complete
and accurate reporting of all of the potential environmental impacts associated with the
proposed development. The City Council further finds that the 2020 Addendum has
been completed in compliance with CEQA and the State CEQA Guidelines. The City
Council further finds and determines that the EIR Addendum reflects the City's
independent judgment.
SECTION 3. Based on the substantial evidence set forth in the record, including
but not limited to the 2010 EIR and the 2020 Addendum, the City Council finds that an
addendum is the appropriate document for disclosing the changes to the subject
property, and that none of the conditions identified in Public Resources Code section
21166 and State CEQA Guidelines section 15162 requiring subsequent environmental
review have occurred, because:
(a) The proposed development does not constitute a substantial change that
would require major revisions of the 2010 EIR due to the involvement of
new significant environmental effects or a substantial increase in the
severity of previously identified significant effects.
(b) There is not a substantial change with respect to the circumstances under
which the proposed development will be developed that would require
major revisions of the 2010 EIR due to the involvement of new significant
Resolution No. 2020-xx
Page 3 of 8
75C-379
environmental effects or a substantial increase in the severity of the
previously identified significant effects.
(c) New information of substantial importance has not been presented that
was not known and could not have been known with the exercise of
reasonable diligence at the time the 2010 EIR was certified or adopted,
showing any of the following: (i) that the modifications would have one or
more significant effects not discussed in the earlier environmental
documentation; (ii) that significant effects previously examined would be
substantially more severe than shown in the earlier environmental
documentation; (iii) that mitigation measures or alternatives previously
found not to be feasible would in fact be feasible and would substantially
reduce one or more significant effects, but the Applicant declined to adopt
such measures; or (iv) that mitigation measures or alternatives
considerably different from those analyzed previously would substantially
reduce one or more significant effects on the environment, but which the
Applicant declined to adopt.
SECTION 4. The City Council hereby finds that mitigation measures identified in
the 2010 EIR remain applicable to the Transit Zoning Code, with exception of mitigation
measure MM4.4-1(a) as part of the Cultural Resources which has been revised after
consultation with California Native American Tribes. These findings are described more
specifically in the Mitigation Monitoring and Reporting Program ("MMRP") attached
hereto as Exhibit A. The City Council therefore hereby adopts those mitigation
measures identified as remaining applicable to the Transit Zoning Code, through the
MMRP attached hereto and incorporated herein as Exhibit A.
SECTION 5. The City Council hereby approves and adopts the 2020 4th and
Mortimer Mixed -Use Development EIR Addendum related to Amendment Application
No. 2020, attached hereto and incorporated herein as Exhibit B.
SECTION 6. The Applicant shall indemnify, protect, defend and hold the City
and/or any of its officials, officers, employees, agents, departments, agencies,
authorized volunteers, and instrumentalities thereof, harmless from any and all
claims, demands, lawsuits, writs of mandamus, and other and proceedings (whether
legal, equitable, declaratory, administrative or adjudicatory in nature), and alternative
dispute resolution procedures (including, but not limited to arbitrations, mediations,
and such other procedures), judgments, orders, and decisions (collectively "Actions"),
brought against the City and/or any of its officials, officers, employees, agents,
departments, agencies, and instrumentalities thereof, that challenge, attack, or seek
to modify, set aside, void, or annul, any action of, or any permit or approval issued by
the City and/or any of its officials, officers, employees, agents, departments,
agencies, and instrumentalities thereof (including actions approved by the voters of
the City) for or concerning the project, whether such Actions are brought under the
Ralph M. Brown Act, California Environmental Quality Act, the Planning and Zoning
Law, the Subdivision Map Act, Code of Civil Procedure sections 1085 or 1094.5, or
Resolution No. 2020-xx
Page 4 of 8
75C-380
any other federal, state or local constitution, statute, law, ordinance, charter, rule,
regulation, or any decision of a court of competent jurisdiction. It is expressly agreed
that the City shall have the right to approve, which approval will not be unreasonably
withheld, the legal counsel providing the City's defense, and that Applicant shall
reimburse the City for any costs and expenses directly and necessarily incurred by
the City in the course of the defense. City shall promptly notify the Applicant of any
Action brought and City shall cooperate with Applicant in the defense of the Action.
SECTION 7. The City Council directs staff to prepare, execute and file a CEQA
Notice of Determination with the Orange County Clerk's Office within five working days
of the City Council approval of Amendment Application No. 2020 for the 4th and
Mortimer Mixed -Use Development Project.
SECTION 8. The 2010 EIR and the 2020 EIR Addendum, and any other
documents and materials that constitute the record of proceedings upon which these
findings have been based are on file, are incorporated herein by reference and are
available for public review at Santa Ana City Hall, Planning and Building Agency, M20,
20 Civic Center Plaza, Santa Ana, California 92701. The custodian of these records is
Daisy Gomez, City Clerk for the City.
SECTION 9. This resolution shall take effect immediately upon its adoption by
the City Council, and the Clerk of the Council shall attest to and certify the vote adopting
this resolution.
ADOPTED this day of 2020.
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
0
Lisa E. Storck
Assistant City Attorney
Miguel A. Pulido
Mayor
Resolution No. 2020-xx
Page 5 of 8
75C-381
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, DAISY GOMEZ, Clerk of the Council, do hereby attest to and certify the attached
Resolution No. 2020-xx to be the original resolution adopted by the City Council of the
City of Santa Ana on 12020.
Date:
Clerk of the Council
City of Santa Ana
Resolution No. 2020-xx
Page 6 of 8
75C-382
EXHIBIT A
MITIGATION MONITORING AND REPORTING PROGRAM
The Mitigation Monitoring and Reporting Program (MMRP) is available online at:
httr)s://www.santa-ana.ora/pb/plannino-division/major-Dlannino-projects-and-monthly-
development-project-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-383
EXHIBIT B
4T" AND MORTIMER EIR ADDENDUM
The 4th and Mortimer Mixed -Use Development Project EIR Addendum and
Technical Appendices are available online at:
https://www.santa-ana.orq/pb/planning-division/major-planning-projects-and-
monthly-development-project-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-384
EXHIBIT 3
75C-385
ORDINANCE NO. NS-XXXX
AN ORDINANCE OF THE CITY COUNCIL APPROVING
AMENDMENT APPLICATION NO. 2020-04 MODIFYING
THE SUB -ZONING DESIGNATION OF THE PROPERTIES
LOCATED AT 501, 507, 509, 515, AND 519 EAST FOURTH
STREET AND THOSE AT 502, 506, 510, 514, 520 EAST
FIFTH STREET FROM SPECIFIC DEVELOPMENT NO. 84,
URBAN NEIGHBORHOOD 2 (UN-2) SUB -ZONE, TO THE
URBAN CENTER (UC) SUB -ZONE
THE CITY COUNCIL OF THE CITY OF SANTA ANA DOES ORDAIN AS FOLLOWS:
Section 1. The City Council of the City of Santa Ana hereby finds, determines
and declares as follows:
WHEREAS, Chapter 41, Article 1, Division 1, Section 41-1 of the Santa Ana
Municipal Code establishes the necessity of segregating the location of residences,
businesses, trades and industries; regulating the use of buildings, structures, and land
regulation; the location, height, bulk and size of buildings and structures, the size of
yards and open space; the City is divided into land -use districts of such number, shape
and area as may be considered best suited to carry out these regulations and provide
for their enforcement; and
WHEREAS, the regulations are considered necessary in order to: encourage
the most appropriate use of land, conserve and stabilize property value, provide
adequate open spaces for light and air and to prevent and fight fires, prevent undue
concentration of population, lessen congestion on streets and highways, and promote
the health, safety and general welfare of the people, all as part of the general plan of
the City; and
WHEREAS, the City of Santa Ana has adopted a zoning map which has since
been amended from time to time; and
WHEREAS, Andrew Nelson, with Red Oak Investments, LLC, representing
Northgate Gonzalez Real Estate (hereinafter referred to as "Applicant"), seeks to
develop the 4th and Mortimer Mixed -use Development Project ("proposed Project"), on a
1.423-acre site at 409 East Fourth Street and a 1.292-acre site at 501, 507, 509, 515,
and 519 East Fourth Street and 502, 506, 510, 514, 520 East Fifth Street (collectively
referred to as "509 East Fourth Street") in Santa Ana, California ("Project Site"); and
WHEREAS, during the City's entitlement and environmental review process, and
in response to comments and concerns raised by the City and public, the Applicant has
proposed the subject mixed -use Project; and
Ordinance No. NS-XXXX
Page 1
75C-386
WHEREAS, the entire Project as currently proposed entails, among other things,
(1) demolition of an existing commercial grocery market, surface parking lot, an existing
commercial auto building, and ancillary structures on the Project Site; (2)
redevelopment of the Project Site with a residential and commercial mixed -use
development consisting mixed -use residential and commercial development consisting
of two separate buildings located on two development sites at 409 (Site A) and 509
(Site B) East Fourth Street, with up to 169 residential rental units, 11,361 square feet of
commercial space, 422 on -site parking spaces, and onsite landscaping and amenities;
(3) approval of Site Plan Review No. 2020-03 to allow the construction of two structures
over four stories in height; (4) approval of Variance No. 2020-06 to allow an increase in
the allowable building size and massing for Site B; and (5) approval of Amendment
Application (AA) No. 2020-04, which would change the zoning of Site B from Specific
Development No. 84, Urban Neighborhood 2 (UN-2) sub -zone, to the Urban Center
(UC) sub -zone; and
WHEREAS, the requested Amendment Application would modify the zoning
designation of Site B from Specific Development No. 84, Urban Neighborhood 2 (UN-2)
sub -zone, to Specific Development No. 84, Urban Center (UC) to facilitate the
construction of the proposed Project; and
WHEREAS, in accordance with the California Environmental Quality Act
(CEQA), the City Council of the City of Santa Ana hereby finds, determines, and
declares as follows:
Based on the substantial evidence set forth in the record, including but not
limited to the Environmental Impact Report (EIR) for the Transit Zoning Code Project
(SCH NO. 2006071100) and the 2020 4th and Mortimer Mixed -Use Development EIR
Addendum, the City Council finds that an addendum is the appropriate document for
disclosing the changes to the subject properties, and that none of the conditions
identified in Public Resources Code section 21166 and State CEQA Guidelines
section 15162 requiring subsequent environmental review have occurred, because:
A. The project does not constitute a substantial change that would require major
revisions of the 2010 EIR due to the involvement of new significant
environmental effects or a substantial increase in the severity of previously
identified significant effects.
B. There is not a substantial change with respect to the circumstances under which
the project will be developed that would require major revisions of the 2010 EIR
due to the involvement of new significant environmental effects or a substantial
increase in the severity of the previously identified significant effects.
C. New information of substantial importance has not been presented that was not
known and could not have been known with the exercise of reasonable
diligence at the time the 2010 EIR was certified or adopted, showing any of the
following: (i) that the modifications would have one or more significant effects
not discussed in the earlier environmental documentation; (ii) that significant
Ordinance No. NS-XXXX
Page 2
75C-387
effects previously examined would be substantially more severe than shown in
the earlier environmental documentation; (iii) that mitigation measures or
alternatives previously found not to be feasible would in fact be feasible and
would substantially reduce one or more significant effects, but the Applicant
declined to adopt such measures; or (iv) that mitigation measures or
alternatives considerably different from those analyzed previously would
substantially reduce one or more significant effects on the environment, but
which the Applicant declined to adopt.
WHEREAS, the 2020 4th and Mortimer Mixed -Use Development EIR
Addendum analyzed the impacts related to the proposed amendment to the zoning
map and Specific Development No. 84; and
WHEREAS, on October 12, 2020, the Planning Commission conducted a duly
noticed public hearing to consider the 2020 4th and Mortimer Mixed -Use Development
EIR Addendum, Site Plan Review No. 2020-03, Variance No. 2020-06, and Amendment
Application No. 2020-04 described above. After hearing all relevant testimony from
staff, the public and the City's consultant team, the Planning Commission voted to
recommend that the City Council adopt a resolution approving an Addendum to the EIR
for the Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a
mitigation monitoring and reporting program for Amendment Application No. 2020-04,
and to adopt an ordinance approving Amendment Application No. 2020-04 for Specific
Development No. 84 (SD84).
WHEREAS, on November 17, 2020, the City Council conducted a duly noticed
public hearing to consider the 2020 4th and Mortimer Mixed -Use Development EIR
Addendum and Amendment Application No. 2020-04 and at which hearing members of
the public were afforded an opportunity to comment upon the Project. After hearing all
relevant testimony from staff, the public and the City's consultant team, the City Council
voted to adopt a resolution approving an Addendum to the Environmental Impact Report
for the Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a
mitigation monitoring and reporting program for Amendment Application No. 2020-04,
and to adopt an ordinance approving Amendment Application No. 2020-04 for Specific
Development No. 84 (SD84).
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA ANA
DOES RESOLVE, DETERMINE, FIND, AND ORDER AS FOLLOWS:
SECTION 2. CALIFORNIA ENVIRONMENTAL QUALITY ACT: The City Council has
reviewed and approved an Addendum to the Environmental Impact Report for the
Transit Zoning Code Project (SCH NO. 2006071100) and adoption of a mitigation
monitoring and reporting program for Amendment Application No. 2020-04.
SECTION 3. AMENDMENT APPLICATION: The Amendment Application consists of
amendments to the zoning map changing the zoning of Site B from Specific
Development No. 84, Urban Neighborhood 2 (UN-2) sub -zone, to the Urban Center
Ordinance No. NS-XXXX
Page 3
75C-388
(UC) sub -zone, as shown in Exhibit A and Exhibit B respectively, attached hereto and
incorporated herein by reference.
SECTION 4. LOCATION OF DOCUMENTS: The Amendment Application, Addendum
to the Environmental Impact Report for the Transit Zoning Code Project (SCH NO.
2006071100) and all supporting documents are online, on file and available for public
review at Santa Ana City Hall, 20 Civic Center Plaza, Santa Ana, California 92702.
SECTION 5. GENERAL PLAN CONSISTENCY: The City Council hereby finds that
the proposed Amendment Application is compatible with the objectives, policies, and
general plan land use programs in that:
A. The proposed Amendment Application will not adversely affect the public
health, safety, and welfare in that the Amendment Application will not result in
incompatible land uses on adjacent properties, inconsistencies with any
General Plan goals or policies, or adverse impacts to the environment.
B. The amendment application to change the zoning designation of Site B from
Specific Development No. 84, Urban Neighborhood 2 (UN-2) sub -zone, to the
Urban Center (UC) sub -zone is consistent with Santa Ana Municipal Code
section 41-593.1 for the following reasons:
(1) Protecting and enhancing the value of properties by encouraging the
use of good design principles and concepts, as related to the division of
property, site planning and individual improvements with full recognition
of the significance and effect they have on the proper planning and
development of adjacent and nearby properties.
The project's site plan has been designed to integrate the project
site into the surrounding community. Both parking garages will
provide vehicular gates separating available commercial parking
spaces (e.g., guest, commercial, employee, etc.) from the
residential parking areas. Vehicular access will be provided from
Fifth Street by one right -turn only driveway west of Mortimer Street
and one full access driveway east of Mortimer Street. The on -site
circulation would provide safe access for vehicle -pedestrian traffic
and the driveway would provide sufficient throating such that
access to parking spaces is not impacted by internal vehicle
queuing/stacking. Pedestrian access points would be provided by
residential lobbies access along French and Mortimer Street. These
access points have been designed to ensure the safety of residents
and visitors of the project site, as well as commuters, employees,
and residents of the surrounding community.
(2) Encouraging, securing and maintaining the orderly and harmonious
appearance, attractiveness and aesthetic development of structures
Ordinance No. NS-XXXX
Page 4
75C-389
and grounds in order that the most appropriate use and value thereof
be determined and protected.
Both sites in the development have been carefully designed to be
integrated within the existing development pattern in Downtown
Santa Ana. Each site has its own unique architectural vernacular
defined by scale, facade articulation, roof forms, materials, and
detailing. Both of these blocks are designed in closely related
and established California Contemporary architectural style,
which complements the neighborhood in which the development
is located.
The overall development will feature amenities commonly found
at other upscale mixed -use developments in the region. These
include a large courtyard with pool, spa, clubroom, fitness room,
and landscaping in the center of Site A; a roof terrace on the 7th
floor of Site A, overlooking Fourth and French streets; a leasing
office and lounge in Site A; a bike locker in Site A; and a ground -
floor lobby and resident amenity area in Site B. In addition, the
project features private open space/decks for 59 units on Site A
and 48 on Site B. The two -block project will be built and is
conditioned to be managed as a single community and all
amenities will be accessible to residents from either site.
(3) Providing a method whereby specific development plans are to be
based on the general plan as well as other regulations, programs, and
legislation as may, in the judgment of the city, be required for the
systematic execution of the general plan.
The project site has a General Plan designation of District Center
on Site A and Urban Neighborhood on Site B. The District
Center -Downtown District and Urban Neighborhood land use
designation accommodates high-rise office, commercial, and
mixed -use residential uses with an emphasis on streets that
accommodate all modes of transportation for this land use
designation. The allowable floor area ratio (FAR) for District
Center and Urban Neighborhood land use designation would be
a maximum of 3.0 and 1.80, respectively. The proposed project
would include construction of two new buildings, one of which
would be seven stories in height with an FAR of 2.4 (Site A) and
one that would be five stories in height with an FAR of 1.8 (Site
B), consistent with the allowable FAR as part of the General
Plan.
Furthermore, the project is consistent with several goals and
policies of the General Plan, including the Economic
Ordinance No. NS-XXXX
Page 5
75C-390
Development Element and Land Use Element. Land Use
Element Goal 1 promotes a balance of land uses to address
basic community needs. Policy 1.1 promotes medium density
housing in and around the downtown area and Policy 1.2
supports high density residential development within the City's
District Centers as a part of a mixed use development. The
project will involve construction of a mixed -use residential and
commercial building on Site A with a density of 69.6 du/ac, and a
multi -family residential building on Site B with a density of 54.2
du/ac, on two adjacent city blocks in downtown, within the Transit
Zoning Code area. Therefore, the Project will be consistent with
the General Plan Land Use Element.
4) Recognizing the interdependence of land values and aesthetics and
providing a method to implement this interdependence in order to
maintain the values of surrounding properties and improvements and
encouraging excellence of property development, compatible with the
general plan for, and character of, the city, with due regard for the
public and private interests involved.
The project is consistent with the Land Use Element Goal 2
which promotes land uses that enhance the City's economic and
fiscal viability. Policy 2.7 support projects that contribute to the
redevelopment and revitalization of the central City urban areas.
The development proposes to redevelop to City blocks currently
occupied by a commercial building, surface parking lot, and
vacant and unimproved buildings and parcels. Policy 2.10
supports new development that is harmonious in scale and
character with existing development in the area. Both sites in the
development have been carefully designed to be integrated
within the existing development pattern in Downtown Santa Ana.
The mixture of land uses on the project site, including residential,
commercial, and open space, will contribute to the formation a
dynamic downtown core. The commercial and open space
components will serve both residents and visitors of the project
site, as well as the large daytime employee population working in
the project site's immediate vicinity.
(5) Ensuring that the public benefits derived from expenditures of public
funds for improvements and beautification of streets and public facilities
shall be protected by exercise of reasonable controls over the character
and design of private buildings, structures and open spaces.
The project is consistent with Economic Development Element
Goal 2 maintains and enhances the diversity of the City's
economic base. Policy 2.3 encourages the development of
Ordinance No. NS-XXXX
Page 6
75C-391
mutually beneficial and supportive business clusters within the
community. The construction of this project will contribute toward
an economically balanced community by providing housing and
commercial retail opportunities (e.g., restaurant, retail sales, etc.)
for different demographics in an area rich with employment
opportunities, commercial development, and market -rate
housing. In addition, a fiscal and economic impact analysis
estimates that the proposed development will result net positive
fiscal impacts to the City, the Business Improvement District, and
over 800 new temporary or permanent jobs. Specifically, the
analysis estimates $5.4 million net new General Fund revenues
associated with the project over a 25-year period. The mixed -use
development will utilize existing water, sewer, and drainage
infrastructure and will not result in the expansion of infrastructure.
In addition, the Project will not result in the need for expansion of
new or altered police or fire facilities.
SECTION 6. INDEMNIFICATION.
A. General Indemnification. The Applicant shall indemnify, protect, defend and
hold the City and/or any of its officials, officers, employees, agents, departments,
agencies, authorized volunteers, and instrumentalities thereof, harmless from any
and all claims, demands, lawsuits, writs of mandamus, and other and proceedings
(whether legal, equitable, declaratory, administrative or adjudicatory in nature), and
alternative dispute resolution procedures (including, but not limited to arbitrations,
mediations, and such other procedures), judgments, orders, and decisions
(collectively "Actions"), brought against the City and/or any of its officials, officers,
employees, agents, departments, agencies, and instrumentalities thereof, that
challenge, attack, or seek to modify, set aside, void, or annul, any action of, or any
permit or approval issued by the City and/or any of its officials, officers, employees,
agents, departments, agencies, and instrumentalities thereof (including actions
approved by the voters of the City) for or concerning the project, whether such
Actions are brought under the Ralph M. Brown Act, California Environmental Quality
Act, the Planning and Zoning Law, the Subdivision Map Act, Code of Civil Procedure
sections 1085 or 1094.5, or any other federal, state or local constitution, statute, law,
ordinance, charter, rule, regulation, or any decision of a court of competent
jurisdiction. It is expressly agreed that the City shall have the right to approve, which
approval will not be unreasonably withheld, the legal counsel providing the City's
defense, and that Applicant shall reimburse the City for any costs and expenses
directly and necessarily incurred by the City in the course of the defense. City shall
promptly notify the Applicant of any Action brought and City shall cooperate with
Applicant in the defense of the Action.
B. Further Indemnification. Within five (5) days of receipt of a referendum
petition by the City, Applicant shall deposit Fifty Thousand Dollars ($50,000)
("Referendum Deposit") with the City. City may use the funds to pay any and all costs
associated with said referendum measure. If at any time the Referendum Deposit
account has Five Thousand Dollars ($5,000) or less remaining, Applicant shall, within
Ordinance No. NS-XXXX
Page 7
75C-392
three (3) days of receiving notice from the City, deposit with the City additional funds
as requested by the City to cover all costs and expenses associated with processing
the referendum and holding the related election. Following certification of the election
results, any funds remaining in the Referendum Deposit account shall be returned to
the Applicant.
SECTION 7. If any section, subsection, sentence, clause, phrase or portion of this
ordinance for any reason held to be invalid or unconstitutional by the decision of any
court of competent jurisdiction, such decision shall not affect the validity of the
remaining portions of this ordinance. The City Council of the City of Santa Ana hereby
declares that it would have adopted this ordinance and each section, subsection,
sentence, clause phrase or portion thereof irrespective of the fact that any one or more
sections, subsections, sentences, clauses, phrases, or portions be declared invalid or
unconstitutional.
SECTION 8. CITY COUNCIL ACTIONS: The City Council hereby takes the
following actions:
1. The City Council hereby adopts an Ordinance approving Amendment Application
No. 2020-04 as follows:
A. Subject to compliance with the approved Addendum to the Environmental
Impact Report for the Transit Zoning Code Project (SCH NO. 2006071100)
and adopted mitigation monitoring and reporting program for Amendment
Application No. 2020-04, the properties at 501, 507, 509, 515, and 519 East
Fourth Street and 502, 506, 510, 514, 520 East Fifth Street shall be
amended to Specific Development No. 84 Urban Center (UC) sub -zone as
set forth in Exhibit A and Exhibit B, attached hereto and incorporated herein
by reference.
B. The Amendment Application shall not take effect unless and until the
Planning Commission reviews and approved the EIR Addendum,
Environmental Review No. 2018-113, Variance No. 2020-06 and Site Plan
Review No. 2020-03, and the City Council reviews and approves the EIR
Addendum, Environmental Review No. 2018-113 for the subject project.
SECTION 9. EXECUTION OF ORDINANCE. The Mayor shall sign this Ordinance and
the Clerk of the Council shall attest and certify to the adoption thereof.
ADOPTED this day of 12020.
Miguel A. Pulido
Mayor
Ordinance No. NS-XXXX
Page 8
75C-393
APPROVED AS TO FORM:
Sonia R. Carvalho
City Attorney
0
Lisa E. Storck
Assistant City Attorney
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, DAISY GOMEZ, Clerk of the Council, do hereby attest to and certify that the attached
Ordinance No. NS-XXXX to be the original ordinance adopted by the City Council of the
City of Santa Ana on , 2020, and that said ordinance was published
in accordance with the Charter of the City of Santa Ana.
Date:
Daisy Gomez
Clerk of the Council
City of Santa Ana
Ordinance No. NS-XXXX
Page 9
75C-394
EXHIBIT 4
75C-395
9/22/2020
SPR 2020-03, VAR 2020-06, AA 2020-04 - 4th and Mortimer Mixed -Use
Development Project
409 and 509 East Fourth Street
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EXHIBIT 14
75C-436
Conformance to Development and Parking Standards
Required by the Transit Zoning Code
Provided
Lined Block Building Type Height (Table DT-1):
Site A:
1. Minimum - 2 stories
2. Maximum - 10 Stories
5 to 7 Stories
Lined Block Building Type Height (Table UC-1):
Site B:
1. Minimum - 2 stories
5 Stories
2. Maximum - 5 Stories
Parking Driveway Width (Table DT-5):
2-Way Driveway: Project's driveway width varies from
2-Way Driveway: 20'0" minimum and 25'0" maximum.
20'0" to 25'0".
Parking Driveway Width (Table UC-4):
2-Way Driveway: 20'0" minimum and 25'0" maximum.
Parking (Table DT-6):
The overall parking proposed for the project is 422 spaces,
1. Standard: 2 stalls per unit minimum and 0.15 stalls per
including 394 residential stalls and 28 commercial visitor
unit guest, and 1/400 square feet of commercial
stalls. This is surplus of 30 parking spaces above the total
space.
required of 392 spaces-
0 Results in 213 residential and 28 commercial
parking spaces required (241 total)
The proposed residential parking provides a ratio of 2.3
parking spaces per residential unit.
Parking (Table UC-5):
1. Standard: 2 stalls per unit minimum and 0.15 stalls per
unit guest, and 1/300 square feet of commercial
space-
0 Results in 151 residential parking spaces
required
Setbacks (Table DT-2):
Site A:
1. Front Yard - 0'0" min, 0'0" max
2. Street Side - 0'0" min, 10'0" max
Complies;
3. Side Yard - 0'0" min, no max
1. Front Yard - 0'0"
4. Rear Yard - 15'0" min, no max
2. Side Yards - T-7" - 22'-5" (max)
5. Alley Yard - TO" min, no max
Site B:
Setbacks (Table UC-2):
1. Front Yard - 0'0" min, 0'0" max
1. Front Yard - 0'0"
2. Street Side - 0'0" min, 10'0" max
2. Side Yards - 2'-6" - 15'-8" (max)
3. Side Yard -0'0" min, no max
4. Rear Yard - 15'0" min, no max
Frontage Type (Table DT-4):
1. Arcade - Min 50% of Frontage
Site A:
2. Gallery -Min 50% of Frontage
3. Shopfront - Min 75% of Frontage
4'h Street: 100% Shopfront,
4. Forecourt - Max 50% of Frontage (remainder of
frontage per permitted types)
Site B:
Frontage Type (Table UC-):
4'h Street: 50% Forecourt
1. Shopfront- Min 65% of Frontage
4'h Street: 25% Stoop
2. Forecourt - Max 50% of Frontage (remainder of
frontage per permitted types)
3. Stoop - Max 50% of Frontage
Building Types Allowed (Table BT-1):
Lined Block
Flex Block, Lined Block, Stacked Dwellings, Courtyard
Housing,Live-Work Tuck Under
Lined Block Width and Depth (Table BT-1):
Site A:
1. Width- Min 125'0" and Max 300'0"
1. Width - 242'0"
2. Depth -Minimum 100'0"
2. Depth - 243'0"
75G-4137
Required by the Transit Zoning Code
Provided
Site B:
1. Width— 185'-0" - 236'0"
2. Depth — 241'0"
Lined Block Access Standards (Sec. 41-2023):
All requirements met and shown in plan sheets-
1 -
The main entrance to each ground floor shall be
directly from the street-
2-
Entrance to residential portions of the building shall be
through a dedicated street level lobby, or through a
dedicated podium lobby accessible from the street of
through a side yard-
3-
Access to each unit above the second level, not
accessed through a podium, shall be through an
interior corridor of at least 6'0" with recessed doors or
seating alcoves/offsets at least every 100'0".
4.
Each level of the building shall have access to the
garage via an elevator.
Lined Block Parking Standards (Sec. 41-2023):
The buildings provide parking via an above -ground garage-
1 .
All parking shall be in an underground or above-
All dwellings will have indirect access to parking stalls.
ground garage, tuck under parking, or combination
thereof-
2-
Dwellings shall have indirect access to their parking
stall(s)-
Lined Block Open Space Standards (Sec. 41-2023):
Site A & Site B:
1.
The common open space shall be designated as a
courtyard, or in the front as a forecourt. This area
1. Required (Common + Private): 26,190 SF
shall be equal to 15% of the lot and shall be open to
2- Provided (Common + Private): 39,838 SF
the sky-
2-
Minimum courtyard width of 20'0" when running EW
All requirements met and shown in plan sheets.
and 15'0" when running NS.
3.
20'0" wide courts only permit architectural projections
on two opposing sides-
4-
Private open space for each dwelling unit and no less
than 50 SF and not less than 6'0" in each direction-
5-
Private open space can be substituted for common
open space or common interior space at an equivalent
square footage. The minimum dimension of this space
shall be 15'0" in each direction.
Lined Block Landscape Standards (Sec. 41-2023):
1. Complies
1.
If a front yard is present, one 24" box tree per 25'0"
2. Complies
lineal feet shall be provided.
3. Complies
2.
Six (6) 5-gallon shrubs and ten (10) 1-gallon size
4. Complies
shrubs or ground cover per required tree.
5. Complies
3.
Courtyards located above garages shall avoid the
6. Complies
sensation of forced podium hardscape.
7. Complies
4.
Trees in the front yard may not exceed 12-15' in height
at maturity and must be suitable for built in concrete
planters or containers with a 36-inch width-
5-
One 36" box tree is required per courtyard that meets
the minimum dimensions. For courtyards that exceed
minimum dimensions, two or more 24-inch box small
size trees may be substituted-
6-
If a rear yard is present, at least one (1) 36" box tree
per 30'0" lineal feet shall be planted-
7-
If a side yard is present, at least one (1) 24" box tree
per 30'0" lineal feet shall be provided -
"bit
Required by the Transit Zoning Code
Provided
Lined Block Frontage Standards (Sec. 41-2023):
All requirements met and shown in plan sheets.
Entry door oriented to street/courtyard when fronting to
one. Service rooms -oriented backing to corridors.
Building Size and Massing Standards (Sec. 41-2023):
Building Height Ratios:
1-4 (Standards Noted and Met)
5. Max Height Ratios:
Site A:
a. Ground Floor — 100%
b. Level 2 — 100%
1. Ground Floor — 100%
c. Level 3-5 — 85%
2. Level 2 — 49%
d.Level 6-85%
3. Level 3-81%
4. Level 4 — 81 %
5. Level 5 — 81 %
6. Level 6 — 63%
7. Level 7 — 60%
Site B: — Approval of a Variance Required for an
increase in allowable building size and massing
1. Ground Floor— 100%
2. Level 2 — 100%
3. Level 3-5 — 100%
7v5b-4139
EXHIBIT 15
75C-440
SPR No. 2020-02 & AA No. 2020-04, "4th and Mortimer Mixed -Use Development'
409 and 509 East Fourth Street
The 2020 EIR Addendum and Technical Appendices are available online at:
https://www.santa-ana.org/pb/planning-division/maior-planning-proiects-and-monthly-development-
proiect-reports/4th-and
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
Exhibit 15 — 2020 EIR Addendum and Technical Appendices
75C-441
EXHIBIT 16
75C-442
SPR No. 2020-02 & AA No. 2020-04, "4th and Mortimer Mixed -Use Development'
409 and 509 East Fourth Street
The 2010 Transit Zoning Code EIR and Technical Appendices are available online at:
https://www.sa nta-a na.org/tra nsit-zon i ng-code-environmental-i m pact -report
Or by visiting:
Planning and Building Agency — Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
Exhibit 16 — 2010 Transit Zoning Code EIR
75C-443
EXHIBIT 17
75C-444
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June 3, 2020
Richard M. Gollis, Principal
THE CONCORD GROUP
369 San Miguel Drive, Suite 265
Newport Beach, CA 92660
17877 01.1-EiTE AVE. 714 541 4W15
SUNFE 450 LN"WEBRSO.[om
IRVINE. CA 97674 WE BRSG.COM
DEVELOPMENT FISCAL IMPACT ANALYSIS
4TH + MORTIMER MIXED -USE PROJECT, DOWNTOWN SANTA ANA
Dear Mr. Gollis:
Via Electronic Mail
RSG, Inc. ("RSG") was retained by The Concord Group ("TCG") to perform a fiscal and economic
impact analysis for the development of a proposed mixed -use apartment and retail project
("Project") in downtown Santa Ana, California. TCG obtained this analysis on behalf of the
property owner/developer, Red Oak Investments ("Developer'), which recently submitted an
application for redevelopment of the subject property with the City of Santa Ana's ("City") Planning
and Building Services Department.
The Project site sits along 41h street covering two blocks divided by Mortimer Street for a total
Project area of 2.72 acres. If approved, the Project would consist of one mixed -used building and
one residential building, each on their own block. Currently, Northgate Market sits within the
proposed development site, and an automotive repair shop sits adjacent to it.
This letter describes our analysis, methodology, and anticipated recurring fiscal impacts resulting
from development of the Project. As is typical at this stage, our conclusions could evolve as the
application moves forward through the design and environmental review process.
As is consistent with other Downtown Santa Ana projects analyzed by RSG, the construction
period was assumed to be over three years. Part of the work would begin in 2021 (36 percent),
with a majority taking place in 2022 (51 percent), leading to the remainder in 2023 (13 percent).
The Project would open in the third construction year. Fiscal impacts from that year are reduced
to reflect a partial year. RSG anticipates the following fiscal outcomes over a 25-year forecast
period:
$2.9 million (net present value, discounted at 4 percent) in net new property tax revenues
to the City General Fund.
A combined $2 million in sales taxes that includes $1 million from the City's base rate, and
$987,230 from the City's Measure X additional tax rate inclusive of the sunset date (net
present value, discounted at 4 percent).
A total of $7.8 million (net present value, discounted at 4 percent) in additional City General
Fund revenue, including construction period revenues, recurring site -specific tax, and
other Project impacts.
Over the same 25-year period, the City General Fund expenditures associated with the
Project total $2.4 million (net present value, discounted at 4 percent)
IRVINE IN, BERKELEY • VISTA
75C-445
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 2
As a result, the net new General Fund revenue (revenues less expenditures) is projected to be
approximately $5.4 million (net present value, discounted at 4 percent) if the Project were
developed as proposed.
Table 1 summarizes the 25-year fiscal impact of the Project. Table 2 provides the corresponding
forecast of the same impacts on the following page.
Table 1
NET NEW RECURRING GENERAL FUND FISCAL IMPACTS
4th and Mortimer
Revenue
25-Year Recurring
Nominal NPV 4.0%
Property Tax
$ 5,373,270
$ 2,993,993
Property Tax In -Lieu
3,739,484
2,086,226
Sales Tax
1,913,260
1,019,241
Measure X (2018) Sales Tax Increase
1,522,027
987,230
Utility User Tax
938,109
499,754
Business Tax
313,235
166,868
Total Revenues
$ 13,799,385
$ 7,753,312
Less City Expenditures $ (4,495,985) $(2,390,794)
NET NEW REVENUE TOTAL $ 9,303,400 $ 5,362,518
Sources: City of Santa Ana, County of Orange, California State Board of Equalization, ESRI
Business Analyst Online, and RSG, Inc.
75C-446
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75C-447
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 4
PROJECT DESCRIPTION
The Project site is located on the 400 and 500 blocks of East 4m Street (also known as Calle
Quatro), between French and Minter Streets, in the East End District of Downtown Santa Ana.
Downtown Santa Ana is a vibrant, historic destination for locals and visitors to the City, known as
a center of commerce and culture for the Latinx community, arts and entertainment, and historic
buildings repurposed for contemporary use. Two business improvement districts overlay "DTSA,"
Downtown Inc and the Santa Ana Business Council. Within them are the renowned Yost Theater,
Frida Cinema, 4m Street Market, and part of the project site. Across 41h Street from the Project
site is The Spectrum Condominiums, a four-story residential complex over ground floor parking
(five -stories).
Figure 1 shows the location of the Project Site
Figure 1: Project Site
75C-448
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 5
Source: Goog/e Maps
The Project site consists of 10 parcels on the two blocks, separated by Mortimer Street. Excluded
from the Project site is a 2,887 square foot parcel currently used as an automotive repair shop
(Ming's Auto).
As shown in Figure 2, the 252,368 square foot (gross building area) Project would result in the
demolition of the existing improvements and construction featuring 169 market rate multifamily
units, 11,361 square feet of ground floor commercial space, and two parking structures.
On the western 400 block, currently a single parcel occupied by the Northgate Gonzalez Market,
the Developer is proposing a seven -story mixed -use building. The seven -story building will include
99 multifamily units, 7,514 square -feet of retail space, 3,847 square -feet of restaurant space,
8,007 square -feet of amenities, leasing, and deck space, and 17,989 square -feet of open space.
On the eastern 500 block of 4" Street, the remaining nine parcels would include a five -story
residential building and parking structure, with 70 multifamily units and 8,623 square -feet of open
space.
Figure 2: Site Plan
Fifth Sheet
Source: KTGY Group Inc., Red Oak Investments
There are currently 169 residential units planned for construction, the breakdown of which
includes 21 studio (12 percent of all units), 38 one -bedroom (22 percent), 66 two -bedroom (39
percent), 9 three -bedroom (5 percent), and 35 four -bedroom (21 percent) units. Based on
occupancy rates from prior projects, RSG estimates 153 units will be occupied at any given time.
Figure 3 presents a rendering of the project as currently proposed:
75C-449
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 6
Figure 4 exhibits the unit mix.
Figure 3
Figure 4
4th + Mortimer
Unit Breakdown
Studio 1 BR 2 BR 3 BR 4 BR
Source: KTGY Group Inc., Red Oak Investments
75C-450
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 7
RECURRING FISCAL IMPACTS
Property Tax Revenue
All property taxes in the state of California are levied at a rate of 1 percent. The City's share of
the 1 percent property tax levy is 19.4%, as provided by the County of Orange ("County") Auditor -
Controller. The Developer provided RSG with the Project costs that consisted of $5 million for
land, and $77 million for hard and soft costs. This $82 million adjusted for inflation over the
construction period, would amount to an assessed valuation of $86.4 million at buildout. To
accurately portray the effect of the Project to the City, property tax revenues presented in this
report are net of any existing revenues. The existing site is currently valued at $6.3 million. When
adjusted for inflation over the construction period the value is $6.9 million, providing the City an
estimated $13,375 in year 2023 absent the construction of the Project. The new development
would provide $167,657 to the City in that same year. Therefore, the net new property tax
revenues to the City would be $154,282 at buildout.
Table 3
NET NEW PROPERTY TAX REVENUE
4th and Mortimer
At Buildout
Existing Assessed Value $ 6,894,078
Proposed Project Assessed Valuation' 86,420,908
Net New Value $ 79,526,830
City Property Tax Rate 19.4%
Annual Estimate
Existing Property Tax Revenues
$ 13,375
New Property Tax Revenues
$ 167,657
Net New Property Tax Revenues
$ 154,282
Source: County of Orange Auditor Controller, RSG, Inc.
' Inflated pursuant to the construction schedule
To project future property taxes, RSG assumed 2 percent inflation on property tax revenues over
the 25-year projection period, resulting in $2.9 million (net present value, discounted at 4 percent)
in net new property tax revenues for the City General Fund.
Property Tax in -lieu of Motor Vehicle License Fee Revenue
Established in 1935, the Motor Vehicle License Fee ("MVLF") was essentially a tax on vehicle
ownership. It is collected by the State annually when vehicles are registered and was historically
allocated to cities and counties based upon a statutory formula. In 2004, during the State's budget
crisis, about 90 percent of each city's MVLF revenue was replaced with property tax revenue, and
cities in particular began to receive an allocation of property tax from the Educational Revenue
Augmentation Fund ("ERAF") in an amount equal to what they would have received in MVLF
under an older MVLF allocation formula. Under current law, the property tax in -lieu of MVLF
75C-451
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 8
revenue increases based on assessed value growth in a jurisdiction, so estimated revenues are
based on changes in assessed value created by the Project.
Based on the City's 2019-20 secured property tax roll, the total assessed value of all Property in
the City is $26.3 billion. When adjusting for inflation during the construction period, the Project's
net new assessed valuation ($79.5 million) increases the City's assessed value by 0.33 percent.
The MVLF increase from the Project is calculated from the percent increase in assessed value.
This gives us $107,186 in estimated In -Lieu MVLF revenues at build -out (see Table 4). As
depicted above, the City is expected to receive $2 million (net present value, discounted at 4
percent) in In -Lieu MVLF revenues through 2047.
Table 4
PROPERTY TAX IN -LIEU OF MOTOR VEHICLE LICENSE FEES
4th and Mortimer
2019-20 City Assessed Value
$ 26,369,891,977
Project Assessed Value'
86,420,908
City Assessed Value with Project
26,456,312,885
Increase in Assessed Value
0.33%
Santa Ana 2019-20 VLF
32,705,877
Santa Ana VLF with Project
32,813,063
Annual Estimate
Property Tax In -lieu Revenue
$ 107,186
Source: County of Orange Auditor Controller, RSG, Inc.
' Inflated pursuant to the construction schedule
Utility User Tax
The City assesses a utility user tax of 5.5 percent on electricity, gas, water, and telephone
revenues generated within Santa Ana. Utility costs were estimated by RSG based on a review of
similar projects and utility costs in Orange County. Residential utility expenditures were assumed
to be: $104 per month for phone, $57 for electricity, $23 for gas, and $30 for water. This amounts
to $2,890 annually in 2020 dollars. From the Developer's estimates of 3,847 square feet of
restaurant and 7,514 square feet of retail, RSG was able to use US Energy Information
Administration ("EIA") estimates to extrapolate commercial utility expenses. Retail establishments
average around $1.50 per square foot in energy expenses, while restaurants average $4.44 per
square foot.
Based on these assumptions, RSG estimates that utility user tax revenues generated by the
Project, reduced to account for a partial year, will be an estimated $24,333 at buildout. This adds
up to $499,754 (net present value, discounted at 4 percent) over the 25-year projection period
(see Table 2).
75C-452
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 9
Table 5 showcases the Utility User Tax at buildout below.
Table 5
UTILITY USER TAX REVENUE
4th and Mortimer
Energy Expenditures per Household $ 2,890
Occupied Households 153
Total Residential Energy Expenses $ 441,083
Total Commercial Energy Expenses' $ 67,443
City Tax Rate 5.5%
Full -Year Buildout Revenues $ 27,969
Partial -Year Buildout Revenues $ 24,333
Sources: US Energy Information Administration, RSG, Inc., ESRI BAO
'EIA estimates of $1.40 per SF for Retail and $4.44 for restaurant
Sales Taxes
The Project is expected to increase sales taxes through both the new businesses and new
residents. The methodology and assumptions for both differ but are necessary for accuracy.
Resident -Derived Sales Tax
To determine the resident share, RSG obtained average annual household expenditures for
households within a 1-mile radius of the Project from ESRI Business Analyst. By adjusting the
household expenditures based on taxable and non-taxable sales, RSG estimates that each
household would spend an average of $17,836 at buildout. Based on experience with previous
projects in the City, an estimated 65 percent of those expenditures would be subject to Santa
Ana's sales tax.
The State and County sales tax receive 6 percent and 0.75 percent of taxable sales, respectively.
In addition, the City levies its own sales tax at a rate of 1 percent. In 2018, Santa Ana voters
approved an additional sales tax of 1.5 percent that would then decrease to 1 percent in 2029
until expiring in 2039. RSG took this increase into consideration when analyzing the affects the
new residents would have on the City's General Fund.
Using ESRI's Business Analyst Online software,
expenditures the average new household wou
vacancy rate from Census data, 2.7 percent, t
Multiplying the households and the expenditure
sales of $1.9 million. From there, the taxable s
rate and the Measure X additional rates (1 percent and
derived sales tax revenue from the base tax rate is
o
s
RSG was able to estimate the amount of taxable
Id make in the City. RSG then estimated the
come up with 165 total occupied households.
together produced an estimate of total taxable
ales were multiplied by both the City's base tax
1.5 percent). Therefore, the residential
an estimated $17,697 at buildout. The
75C-453
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 10
additional tax from Measure X would yield $26,545 at buildout and decrease to $21,131 in 2029
(adjusted for 3% inflation) before ceasing in 2039.
Table 6
RESIDENT -DERIVED SALES TAX REVENUE
4th and Mortimer
Households and Sales at Buildout
Average Household Taxable Expenditures
$ 17,836
Occupied Households
153
Percent within Santa Ana
65%
Total Taxable Sales
$ 1,769,689
City Share of Sales Tax
Measure X (2018) Additional Sales Tax'
Resident -Derived Sales Tax Revenues Annual Estimate
(Base Rate) $ 17,697
(2018 Addition) $ 26,545
(2029 Decrease to 1%) $ 21,131
Source: ESRI BAO, City of Santa Ana
'Measure X additional sales tax decreases from 1.5% to 1 % in 2029.
Business -Derived Sales Tax
The Project includes 7,514 square feet of retail space and 3,847 square feet of restaurant space.
These new businesses will generate sales taxes separate from the new residents. Since the
Developer does not yet know the exact tenants that will fill the space, RSG estimated an average
of $300 of sales per square foot for the retail, and $350 per square foot for the restaurant. As a
result, the retail and restaurant businesses will generate taxable sales of $2.4 million and $1.4
million at buildout, respectively.
RSG estimates the base sales tax revenues at buildout to be $39,345. Table 7 below presents
this information. In addition, Measure X will generate $59,018 for that year as well. However, in
2029 Measure X revenues will decrease to $36,007 before being eliminated altogether in 2039.
75C-454
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 11
Table 7
BUSINESS -DERIVED SALES TAX REVENUE
4th and Mortimer
Sales at Buildout
General Retail
2,463,225
Restaurant 1,471, 302
$ 3,934,527
City Share of Sales Tax
1%
Measure X (2018) Additional Sales Tax' 1.5%
Business -Derived Sales Tax Revenues Annual Estimate
(Base Rate) $ 39,345
(2018 Addition) $ 59,018
(2029 Decrease to 1%) $ 36,007
Source: California State Board of Equalization, RSG, Inc.
'Measure X additional sales tax decreases from 1.5% to 1 % in 2029
For the City base rate, combined resident and business sales taxes at buildout would be an
estimated $50,828. Measure X combined taxes would be $76,242. Both are adjusted for inflation
during the construction period and for the partial year at opening. This provides for a 25-year total
of $1.02 million from the base rate and $987,230 from Measure X.
Business Tax
The City assesses a business tax on retail, restaurant, and residential property management
companies. Table 8 below showcases the new revenues from the Project. Retail and restaurant
business taxes are assessed based on annual sales while management company business taxes
are assessed based on unit count. The combined business tax revenues are an estimated $8,125
at buildout, or $166,868 over 25 years (net present value, discounted at 4 percent).
Table 8
BUSINESS TAX REVENUES
4th and Mortimer
Multifamily Residential Tax
Retail Tax
Restaurant Tax
6,573
1,621
1,145
Full -Year Business Taxes at Buildout $ 9,339
Partial -Year Business Taxes at Buildout $ 8,125
Sources: City of Santa Ana, RSG, Inc
75C-455
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 12
CITY EXPENDITURES
RSG estimated the additional population that will move into the Project to estimate the total added
expenditures to the City General Fund for servicing the new residents. Consistent with other
recent analyses prepared by RSG on projects in Santa Ana, RSG assumed that each studio would
house 1.25 residents, each one -bedroom unit would house 1.75 residents, each two -bedroom
unit would house 3.25 residents, each three -bedroom unit would house 4 residents, and each
four -bedroom unit would house 5.25. Overall, this works out to an average household size of 3.12
residents per unit, which RSG considers reasonable.
RSG estimates at full occupancy the Project could hold 527 residents. Taking into account that a
small percentage of the units will normally be vacant due to turnover, we estimate the fiscal
impacts based on residents' time spent in the City. This is done by calculating the full-time
equivalent (FTE) residents, defined as those who spend a vast majority of their daily consumption
in Santa Ana. The assumption being that new residents who work out of the City, do not consume
products in the City during the time they are gone.
RSG gathered data from the US Census and ESRI Business Analyst Online to estimate the FTE
residents of the Project. Approximately 13 percent of Santa Ana residents work within Santa Ana,
which, in effect means that the City is servicing these resident -employees 100 percent of the time.
Another 37 percent of Santa Ana residents work outside the city. Assuming the residents that
work outside of the city are outside City limits from 9 am to 5 pm, Santa Ana is servicing these
residents approximately 73 percent of the time. The city's remaining residential population (about
51 percent), is serviced by the City 100 percent of the time. Accounting for all residents and
employees based on the percent of time spent in the city, the Project will generate a daily (24/7)
population of 476 persons.
RSG identified variable costs, as opposed to fixed costs, by department in the City of Santa Ana
FY 2019-20 Adopted Budget. Variable costs are City expenditures that increase or decrease
based on the resident and employee population. The City Manager and City Attorney offices, for
example, are fixed costs that will not vary based on population, but the Police and Fire
departments will vary based on population. With that said, RSG estimates expenditure increases
of $120,441 during the first full year of operations. Over a 25-year projection period, the Project
will add $2.4 million in City expenditures (net present value, discounted at 4 percent).
75C-456
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 13
Table 9
SUMMARY OF RECURRING CITY EXPENDITURES'
CITY OF SANTA ANA
4th + Mortimer
Current City
Project -derived
Total City
Percent
City Department
Expenditures
City Expenditures
Expenditu res3
Increase
City Manager's Office
$ 2,708,440
$ -
$ 2,708,440
0.00%
Non -Departmental & Intertund Transfers
61,098,660
-
61,098,660
0.00%
Clerk of the Council Office
1,682,560
17
1,682,577
0.00%
City Attorney's Office
3,219,780
-
3,219,780
0.00%
Personnel Services
2,490,360
50
2,490,410
0.00%
Finance & Management Services
9,671,190
228
9,671,418
0.00%
Bowers Museum Corporation
1,473,430
-
1,473,430
0.00%
Parks, Recreation and Community Services
26,836,790
1,551
26,838,341
0.01%
Police Department
131,568,820
75,973
131,644,793
0.06%
Fire Services
45,640,920
32,376
45,673,296
0.07%
Planning & Building Agency
13,227,380
24
13,227,404
0.00%
Public Works Agency
13,155,830
-
13,155,830
0.00%
Community Development Agency
3,353,520
-
3,353,520
0.00%
Base Estimate in 2020-21
$ 316,127,681
$ 110,221
$ 316,237,901
0.03%
Total in 2023.24
120,441
r For this analysis, RSG identified departmental costs in the City of Santa Ana FY 2019-20 Budget that are variable costs, as opposed to fixed costs.
Variable costs are expenditures by the City that increase or decrease based on the residential and employee population in the City. For example, City
Council and Human Resources salaries and wages generally are fixed costs that do not vary based on population. Meanwhile, the Fire Services and Parks
& Community Services departments will likely experience service cost increases due to the added population.
z Current expenditures are based on adopted expenditures in the City of Santa Ana's FY 2019-20 Budget.
3 Sum of current City expenditures and project -derived City expenditures. Assuming project opened in 2020-21.
Sources: City of Santa Ana, RSG, Inc., US Census Bureau
EMPLOYMENT
Development and ongoing operation of the Project will generate employment opportunities, add
labor income to the market area, and add value to the gross regional product. For this analysis,
RSG used the IMPLAN model to measure the economic impacts of the Project using County -wide
data. IMPLAN is an input-output analysis software tool that tracks the interdependence among
various producing and consuming sectors of the economy. According to MIG, Inc., the creators
of IMPLAN, the software measures the relationship between a given set of demands for final
goods and services and the inputs required to satisfy those demands. IMPLAN publishes
countywide data on an annual basis; this analysis utilized the most recent available County of
Orange dataset (2018) to calculate direct, indirect, and induced impacts.
The IMPLAN inputs are investment (development costs) and gross business operating income of
the Project and the resulting outputs are economic impacts, including employment generation,
labor income, and gross regional product. Jobs are the primary impacts calculated by IMPLAN.
RSG analyzed both temporary and permanent economic impacts. For temporary construction
impacts the Developer's Project costs exclusive of land costs were used ($77 million). From there
construction costs were divided based on square footage, between multi -family (95 percent) and
75C-457
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 14
non-residential (5 percent). For permanent impacts, the estimated sales from the residential
complex, the restaurant space, and the retail space were used. IMPLAN breaks down the
resulting employment and other effects into three categories: direct, indirect, and induced:
• Direct Effects — Refers to the direct effects that occur on the Project site resulting from
development costs and operational sales revenue.
Indirect Effects — Changes in sales, jobs, and/or income within the businesses that supply
goods and services to the Project. Indirect effects do not occur directly on the Project -site
but are an indirect effect to surrounding or related businesses.
Induced Effects — Regional changes resulting from additional spending earned either
directly or indirectly from the Project.
RSG utilizes the FTE conversion of total employment generally preferred in Public Policy. FTE
employment numbers, as opposed to residents, present total employment through the lens of
hours worked; summarizing then dividing by how many 40-hour work weeks are generated by the
investment. The IMPLAN analysis concludes that the temporary construction component of the
Project will result in 510 direct FTE jobs, 47 indirect FTE jobs, and 214 induced FTE jobs the
majority of which will be in Santa Ana.
The permanent impacts attributed to the Project are 35 FTE jobs related to the operations of both
the residential building itself, as well as the retail and restaurant components of the Project. This
includes 25 direct, 4 indirect, and 5 induced jobs to the region.
Table 10 outlines the aforementioned FTE jobs generated by the Project.
75C-458
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 15
Table 10
PROJECTED EMPLOYMENT (FTE)
4th and Mortimer
Temporary (Construction) Jobs
Direct
510
Indirect
47
Induced
214
Subtotal
771
Permanent Jobs
Direct
25
Indirect
4
Induced
5
Subtotal
35
Total Temporary & Permanent Jobs
Direct
535
Indirect
51
Induced
219
Total
806
Source: IMPLAN
NON -GENERAL FUND FISCAL IMPACTS
Business Improvement District
In 1984, a Business Improvement District ("BID") was established in Downtown Santa Ana. BIDS
are assessment districts in which business owners pay special levies that go toward various
improvements and promotions within the district. The City collects the funds and provides them
to Downtown Inc. and Santa Ana Business Council, which coordinate events such as First
Saturday Art -Walk, Savor Santa Ana, Boca De Oro Literary Festival, Santa Ana Media Summit,
Outdoor Cinema Series, and the Santa Ana Sidewalk Sales, events that advertise the downtown
area and bring foot traffic for local businesses.
The commercial component of the Project is located within the BID, so Project commercial
businesses would be charged BID fees like the other businesses in the area. Businesses are
levied according to the following guidelines:
• Retail Sale of Goods, Hotel and Motels, Theaters, and Food Establishments, shall pay an
amount equal to one and one- half times their annual business license fee.
• Commercial Rental Property, Rental Property, Residential and Rooming Houses shall pay
an amount equal to one -quarter times their annual business license fee.
75C-459
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 16
• All other businesses, including Professions, Trades and Services shall pay an amount
equal to their annual business license fee.
Based on the City's business license fee schedules, the BID fees for the residential component
is estimated to be $2,282. The BID fees for the retail and restaurant spaces combined is estimated
to be $3,143 annually. While these funds do not directly benefit the general fund, they will increase
funding going towards these downtown events and promotions, which does ultimately help the
City.
Table 11
BUSINESS IMPROVEMENT DISTRICT FEES
4th and Mortimer
Residential Fee $ 2,282
Retail and Restaurant Fee 3,143
Total $ 5,424
2020 Total BID Estimates $ 200,000
Added by Project 5,424
% Added 2.7%
Total BID Revenues $ 205,424
Source: Santa Ana Business License Tax Fee Schedules, BID 2020 Assessment Report
In closing, it is our privilege to assist The Concord Group and your client Red Oak Investments
with predevelopment activities on this project. Please let us know if you have any questions or
comments pertaining to the findings of this report.
Sincerely,
9L� -
James Simon, Principal
75C-460
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EXHIBIT 10
Conformance to Development and Parking Standards
Required by the Transit Zoning Code
Provided
Lined Block Building Type Height (Table DT-1):
Site A:
1. Minimum - 2 stories
2. Maximum - 10 Stories
5 to 7 Stories
Lined Block Building Type Height (Table UC-1):
Site B:
1. Minimum - 2 stories
5 Stories
2. Maximum - 5 Stories
Parking Driveway Width (fable DT-5):
2-Way Driveway: Project's driveway width varies from
2-Way Driveway: 20'0" minimum and 25'0" maximum.
20'0" to 25'0".
Parking Driveway Width (fable UC-4):
2-Way Driveway: 20'0" minimum and 25'0" maximum.
Parking (fable DT-6):
The overall parking proposed for the project is 422 spaces,
1. Standard: 2 stalls per unit minimum and 0.15 stalls per
including 394 residential stalls and 28 commercial visitor
unit guest, and 1/400 square feet of commercial
stalls. This is surplus of 30 parking spaces above the total
space.
required of392 spaces.
o Results in 213 residential and 28 commercial
parking spaces required (241 total)
The proposed residential parking provides a ratio of 2.3
parking spaces per residential unit.
Parking (Table UC-5):
1. Standard: 2 stalls per unit minimum and 0.15 stalls per
unit guest, and 1/300 square feet of commercial
space.
o Results in 151 residential parking spaces
required
Setbacks (Table DT-2):
Site A:
1. Front Yard -0'0" min, 0'0" max
2. Street Side - 0'0" min, 10'0" max
Complies;
3. Side Yard - 0'0" min, no max
1. Front Yard - 0'0"
4. Rear Yard - 15'0" min, no max
2. Side Yards - 3'-7" - 22'-5" (max)
5. Alley Yard - 3'0" min, no max
Site B:
Setbacks (Table UC-2):
1. Front Yard - 0'0" min, 0'0" max
1. Front Yard - 0'0"
2. Street Side - 0'0" min, 10'0" max
2. Side Yards - 2'-6" - 15'-8" (max)
3. Side Yard - 0'0" min, no max
4. Rear Yard - 15'0" min, no max
Frontage Type (Table DT-4):
1. Arcade - Min 50% of Frontage
Site A:
2. Gallery - Min 50% of Frontage
3. Shopfront - Min 75% of Frontage
4'h Street: 100% Shopfront,
4. Forecourt - Max 50% of Frontage (remainder of
frontage per permitted types)
Site B:
Frontage Type (fable UC-):
4'h Street: 50% Forecourt
1. Shopfront - Min 65% of Frontage
41h Street: 25% Stoop
2. Forecourt - Max 50% of Frontage (remainder of
frontage per permitted types)
3. Stoop - Max 50% of Frontage
Building Types Allowed (Table BT-1):
Lined Block
Flex Block, Lined Block, Stacked Dwellings, Courtyard
Housing, Live -Work, Tuck Under
Lined Block Width and Depth (Table BT-1):
Site A:
1. Width - Min 125'0" and Max 300'0"
1. Width - 242'0"
2. Depth - Minimum 100'0"
2. Depth - 243'0"
75C-463
Required by the Transit Zoning Code
Provided
Site B:
1. Width — 185'-0" - 236'0"
2. Depth — 241'0"
Lined Block Access Standards (Sec. 41-2023):
All requirements met and shown in plan sheets.
1.
The main entrance to each ground floor shall be
directly from the street.
2.
Entrance to residential portions of the building shall be
through a dedicated street level lobby, or through a
dedicated podium lobby accessible from the street of
through a side yard.
3.
Access to each unit above the second level, not
accessed through a podium, shall be through an
interior corridor of at least 6'0" with recessed doors or
seating alcoves/offsets at least every 100'0".
4.
Each level of the building shall have access to the
garage via an elevator.
Lined Block Parking Standards (Sec. 41-2023):
The buildings provide parking via an above -ground garage.
1.
All parking shall be in an underground or above-
All dwellings will have indirect access to parking stalls.
ground garage, tuck under parking, or combination
thereof.
2.
Dwellings shall have indirect access to their parking
stal I (s ).
Lined Block Open Space Standards (Sec. 41-2023):
Site A & Site B:
1.
The common open space shall be designated as a
courtyard, or in the front as a forecourt. This area
1. Required (Common + Private): 26,190 SF
shall be equal to 15% of the lot and shall be open to
2. Provided (Common + Private): 39,838 SF
the sky.
2.
Minimum courtyard width of 20'0" when running EW
All requirements met and shown in plan sheets.
and 15'0" when running INS.
3.
20'0" wide courts only permit architectural projections
on two opposing sides.
4.
Private open space for each dwelling unit and no less
than 50 SF and not less than 6'0" in each direction.
5.
Private open space can be substituted for common
open space or common interior space at an equivalent
square footage. The minimum dimension of this space
shall be 15'0" in each direction.
Lined Block Landscape Standards (Sec. 41-2023):
1. Complies
1.
If a front yard is present, one 24" box tree per 25'0"
2. Complies
lineal feet shall be provided.
3. Complies
2.
Six (6) 5-gallon shrubs and ten (10) 1-gallon size
4. Complies
shrubs or ground cover per required tree.
5. Complies
3.
Courtyards located above garages shall avoid the
6. Complies
sensation of forced podium hardscape.
7. Complies
4.
Trees in the front yard may not exceed 12-15' in height
at maturity and must be suitable for built in concrete
planters or containers with a 36-inch width.
5.
One 36" box tree is required per courtyard that meets
the minimum dimensions. For courtyards that exceed
minimum dimensions, two or more 24-inch box small
size trees may be substituted.
6.
If a rear yard is present, at least one (1) 36" box tree
per 30'0" lineal feet shall be planted.
7.
If a side yard is present, at least one (1) 24" box tree
per 30'0" lineal feet shall be provided.
75C-464
Required by the Transit Zoning Code
Provided
Lined Block Frontage Standards (Sec. 41-2023):
All requirements met and shown in plan sheets.
Entry door oriented to street/courtyard when fronting to
one. Service rooms -oriented backing to corridors.
Building Size and Massing Standards (Sec. 41-2023):
Building Height Ratios:
1-4 (Standards Noted and Met)
5. Max Height Ratios:
Site A:
a.Ground Floor — 100%
b. Level 2 — 100%
1. Ground Floor — 100%
c. Level 3-5 — 85%
2. Level 2 — 49%
d. Level 6 — 85%
3. Level 3 — 81 %
4. Level 4 — 81 %
5. Level 5 — 81 %
6. Level 6 — 63%
7. Level 7 — 60%
Site B: — Approval of a Variance Required for an
increase in allowable building size and massing
1. Ground Floor — 100%
2. Level 2 — 100%
3. Level 3-5 — 100%
75C-465
EXHIBIT 11
AA No. 2020-04, "4th and Mortimer Mixed -Use Development"
409 and 509 East Fourth Street
The2020 EIR Addendum and Technical Appendices are available online at:
https://www.santa-ana.org/pb/plan n ine-division/maior-plan n ine-Proiects-and-monthly-development-
proiect-re ports/4th-and
Or by visiting:
Planningand Building Agency —Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-466
EXHIBIT 12
AA No. 2020-04, "4th and Mortimer Mixed -Use Development"
409 and 509 East Fourth Street
The2010 Transit Zoning Code EIR anclTechnical Appendices are available online at:
h ttps://www.sa nta-a na.o rg/tra ns it-zo n in g-cod a-enyi ro nmenta I-im pact -re port
Or by visiting:
Planningand Building Agency —Planning Division Public Counter
20 Civic Center Plaza
Santa Ana, CA 92701
75C-467
EXHIBIT 13
SET TEA COMMUNITIES
EICI PEfl'FUfTUI S_
June 3, 2020
Richard M. Gollis, Principal
THE CONCORD GROUP
369 San Miguel Drive, Suite 265
Newport Beach, CA 92660
0672CALLETTE AVE. n4 541 4565
SUITE 350 INFOOD W EARSO.COPT
RVINE. CA 92614 WEBI75G:COM
DEVELOPMENT FISCAL IMPACT ANALYSIS
4TH + MORTIMER MIXED -USE PROJECT, DOWNTOWN SANTA ANA
Dear Mr. Gollis:
Via Electronic Mail
RSG, Inc. ("RSG") was retained by The Concord Group ("TCG") to perform a fiscal and economic
impact analysis for the development of a proposed mixed -use apartment and retail project
("Project") in downtown Santa Ana, California. TCG obtained this analysis on behalf of the
property owner/developer, Red Oak Investments ("Developer'), which recently submitted an
application for redevelopment of the subject property with the City of Santa Ana's ("City") Planning
and Building Services Department.
The Project site sits along 41h street covering two blocks divided by Mortimer Street for a total
Project area of 2.72 acres. If approved, the Project would consist of one mixed -used building and
one residential building, each on their own block. Currently, Northgate Market sits within the
proposed development site, and an automotive repair shop sits adjacent to it.
This letter describes our analysis, methodology, and anticipated recurring fiscal impacts resulting
from development of the Project. As is typical at this stage, our conclusions could evolve as the
application moves forward through the design and environmental review process.
As is consistent with other Downtown Santa Ana projects analyzed by RSG, the construction
period was assumed to be over three years. Part of the work would begin in 2021 (36 percent),
with a majority taking place in 2022 (51 percent), leading to the remainder in 2023 (13 percent).
The Project would open in the third construction year. Fiscal impacts from that year are reduced
to reflect a partial year. RSG anticipates the following fiscal outcomes over a 25-year forecast
period:
• $2.9 million (net present value, discounted at 4 percent) in net new property tax revenues
to the City General Fund.
• A combined $2 million in sales taxes that includes $1 million from the City's base rate, and
$987,230 from the City's Measure X additional tax rate inclusive of the sunset date (net
present value, discounted at 4 percent).
• A total of $7.8 million (net present value, discounted at 4 percent) in additional City General
Fund revenue, including construction period revenues, recurring site -specific tax, and
other Project impacts.
• Over the same 25-year period, the City General Fund expenditures associated with the
Project total $2.4 million (net present value, discounted at 4 percent)
RVINI, • ULNKLLLr • VISIA
75C-468
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 2
As a result, the net new General Fund revenue (revenues less expenditures) is projected to be
approximately $5.4 million (net present value, discounted at 4 percent) if the Project were
developed as proposed.
Table 1 summarizes the 25-year fiscal impact of the Project. Table 2 provides the corresponding
forecast of the same impacts on the following page.
Table 1
NET NEW RECURRING GENERAL FUND FISCAL IMPACTS
4th and Mortimer
Revenue
25-Year Recurring
Nominal NPV 4.0%
Property Tax
$ 5,373,270
$ 2,993,993
Property Tax In -Lieu
3,739,484
2,086,226
Sales Tax
1,913,260
1,019,241
Measure X (2018) Sales Tax Increase
1,522,027
987,230
Utility User Tax
938,109
499,754
Business Tax
313,235
166,868
Total Revenues
$ 13,799,385
$ 7,753,312
Less City Expenditures $ (4,495,985) $(2,390,794)
NET NEW REVENUE TOTAL $ 9,303,400 $ 5,362,518
Sources: City of Santa Ana, County of Orange, California State Board of Equalization, ESRI
Business Analyst Online, and RSG, Inc.
75C-469
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75C-470
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 4
PROJECT DESCRIPTION
The Project site is located on the 400 and 500 blocks of East 4m Street (also known as Calle
Quatro), between French and Minter Streets, in the East End District of Downtown Santa Ana.
Downtown Santa Ana is a vibrant, historic destination for locals and visitors to the City, known as
a center of commerce and culture for the Latinx community, arts and entertainment, and historic
buildings repurposed for contemporary use. Two business improvement districts overlay "DTSA,"
Downtown Inc and the Santa Ana Business Council. Within them are the renowned Yost Theater,
Frida Cinema, 4m Street Market, and part of the project site. Across 41h Street from the Project
site is The Spectrum Condominiums, a four-story residential complex over ground floor parking
(five -stories).
Figure 1 shows the location of the Project Site
Figure 1: Project Site
75C-471
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 5
Source: Goog/e Maps
The Project site consists of 10 parcels on the two blocks, separated by Mortimer Street. Excluded
from the Project site is a 2,887 square foot parcel currently used as an automotive repair shop
(Ming's Auto).
As shown in Figure 2, the 252,368 square foot (gross building area) Project would result in the
demolition of the existing improvements and construction featuring 169 market rate multifamily
units, 11,361 square feet of ground floor commercial space, and two parking structures.
On the western 400 block, currently a single parcel occupied by the Northgate Gonzalez Market,
the Developer is proposing a seven -story mixed -use building. The seven -story building will include
99 multifamily units, 7,514 square -feet of retail space, 3,847 square -feet of restaurant space,
8,007 square -feet of amenities, leasing, and deck space, and 17,989 square -feet of open space.
On the eastern 500 block of 4" Street, the remaining nine parcels would include a five -story
residential building and parking structure, with 70 multifamily units and 8,623 square -feet of open
space.
Figure 2: Site Plan
Fifth Sheet
Source: KTGY Group Inc., Red Oak Investments
There are currently 169 residential units planned for construction, the breakdown of which
includes 21 studio (12 percent of all units), 38 one -bedroom (22 percent), 66 two -bedroom (39
percent), 9 three -bedroom (5 percent), and 35 four -bedroom (21 percent) units. Based on
occupancy rates from prior projects, RSG estimates 153 units will be occupied at any given time.
Figure 3 presents a rendering of the project as currently proposed:
75C-472
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 6
Figure 4 exhibits the unit mix.
Figure 3
Figure 4
4th + Mortimer
Unit Breakdown
Studio 1 BR 2 BR 3 BR 4 BR
Source: KTGY Group Inc., Red Oak Investments
75C-473
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 7
RECURRING FISCAL IMPACTS
Property Tax Revenue
All property taxes in the state of California are levied at a rate of 1 percent. The City's share of
the 1 percent property tax levy is 19.4%, as provided by the County of Orange ("County") Auditor -
Controller. The Developer provided RSG with the Project costs that consisted of $5 million for
land, and $77 million for hard and soft costs. This $82 million adjusted for inflation over the
construction period, would amount to an assessed valuation of $86.4 million at buildout. To
accurately portray the effect of the Project to the City, property tax revenues presented in this
report are net of any existing revenues. The existing site is currently valued at $6.3 million. When
adjusted for inflation over the construction period the value is $6.9 million, providing the City an
estimated $13,375 in year 2023 absent the construction of the Project. The new development
would provide $167,657 to the City in that same year. Therefore, the net new property tax
revenues to the City would be $154,282 at buildout.
Table 3
NET NEW PROPERTY TAX REVENUE
4th and Mortimer
At Buildout
Existing Assessed Value $ 6,894,078
Proposed Project Assessed Valuation' 86,420,908
Net New Value $ 79,526,830
City Property Tax Rate 19.4%
Annual Estimate
Existing Property Tax Revenues
$ 13,375
New Property Tax Revenues
$ 167,657
Net New Property Tax Revenues
$ 154,282
Source: County of Orange Auditor Controller, RSG, Inc.
' Inflated pursuant to the construction schedule
To project future property taxes, RSG assumed 2 percent inflation on property tax revenues over
the 25-year projection period, resulting in $2.9 million (net present value, discounted at 4 percent)
in net new property tax revenues for the City General Fund.
Property Tax in -lieu of Motor Vehicle License Fee Revenue
Established in 1935, the Motor Vehicle License Fee ("MVLF") was essentially a tax on vehicle
ownership. It is collected by the State annually when vehicles are registered and was historically
allocated to cities and counties based upon a statutory formula. In 2004, during the State's budget
crisis, about 90 percent of each city's MVLF revenue was replaced with property tax revenue, and
cities in particular began to receive an allocation of property tax from the Educational Revenue
Augmentation Fund ("ERAF") in an amount equal to what they would have received in MVLF
under an older MVLF allocation formula. Under current law, the property tax in -lieu of MVLF
75C-474
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 8
revenue increases based on assessed value growth in a jurisdiction, so estimated revenues are
based on changes in assessed value created by the Project.
Based on the City's 2019-20 secured property tax roll, the total assessed value of all Property in
the City is $26.3 billion. When adjusting for inflation during the construction period, the Project's
net new assessed valuation ($79.5 million) increases the City's assessed value by 0.33 percent.
The MVLF increase from the Project is calculated from the percent increase in assessed value.
This gives us $107,186 in estimated In -Lieu MVLF revenues at build -out (see Table 4). As
depicted above, the City is expected to receive $2 million (net present value, discounted at 4
percent) in In -Lieu MVLF revenues through 2047.
Table 4
PROPERTY TAX IN -LIEU OF MOTOR VEHICLE LICENSE FEES
4th and Mortimer
2019-20 City Assessed Value
$ 26,369,891,977
Project Assessed Value'
86,420,908
City Assessed Value with Project
26,456,312,885
Increase in Assessed Value
0.33%
Santa Ana 2019-20 VLF
32,705,877
Santa Ana VLF with Project
32,813,063
Annual Estimate
Property Tax In -lieu Revenue
$ 107,186
Source: County of Orange Auditor Controller, RSG, Inc.
' Inflated pursuant to the construction schedule
Utility User Tax
The City assesses a utility user tax of 5.5 percent on electricity, gas, water, and telephone
revenues generated within Santa Ana. Utility costs were estimated by RSG based on a review of
similar projects and utility costs in Orange County. Residential utility expenditures were assumed
to be: $104 per month for phone, $57 for electricity, $23 for gas, and $30 for water. This amounts
to $2,890 annually in 2020 dollars. From the Developer's estimates of 3,847 square feet of
restaurant and 7,514 square feet of retail, RSG was able to use US Energy Information
Administration ("EIA") estimates to extrapolate commercial utility expenses. Retail establishments
average around $1.50 per square foot in energy expenses, while restaurants average $4.44 per
square foot.
Based on these assumptions, RSG estimates that utility user tax revenues generated by the
Project, reduced to account for a partial year, will be an estimated $24,333 at buildout. This adds
up to $499,754 (net present value, discounted at 4 percent) over the 25-year projection period
(see Table 2).
75C-475
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 9
Table 5 showcases the Utility User Tax at buildout below.
Table 5
UTILITY USER TAX REVENUE
4th and Mortimer
Energy Expenditures per Household $ 2,890
Occupied Households 153
Total Residential Energy Expenses $ 441,083
Total Commercial Energy Expenses' $ 67,443
City Tax Rate 5.5%
Full -Year Buildout Revenues $ 27,969
Partial -Year Buildout Revenues $ 24,333
Sources: US Energy Information Administration, RSG, Inc., ESRI BAO
'EIA estimates of $1.40 per SF for Retail and $4.44 for restaurant
Sales Taxes
The Project is expected to increase sales taxes through both the new businesses and new
residents. The methodology and assumptions for both differ but are necessary for accuracy.
Resident -Derived Sales Tax
To determine the resident share, RSG obtained average annual household expenditures for
households within a 1-mile radius of the Project from ESRI Business Analyst. By adjusting the
household expenditures based on taxable and non-taxable sales, RSG estimates that each
household would spend an average of $17,836 at buildout. Based on experience with previous
projects in the City, an estimated 65 percent of those expenditures would be subject to Santa
Ana's sales tax.
The State and County sales tax receive 6 percent and 0.75 percent of taxable sales, respectively.
In addition, the City levies its own sales tax at a rate of 1 percent. In 2018, Santa Ana voters
approved an additional sales tax of 1.5 percent that would then decrease to 1 percent in 2029
until expiring in 2039. RSG took this increase into consideration when analyzing the affects the
new residents would have on the City's General Fund.
Using ESRI's Business Analyst Online software, RSG was able to estimate the amount of taxable
expenditures the average new household would make in the City. RSG then estimated the
vacancy rate from Census data, 2.7 percent, to come up with 165 total occupied households.
Multiplying the households and the expenditures together produced an estimate of total taxable
sales of $1.9 million. From there, the taxable sales were multiplied by both the City's base tax
rate and the Measure X additional rates (1 percent and 1.5 percent). Therefore, the residential
derived sales tax revenue from the base tax rate is an estimated $17,697 at buildout. The
75C-476
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 10
additional tax from Measure X would yield $26,545 at buildout and decrease to $21,131 in 2029
(adjusted for 3% inflation) before ceasing in 2039.
Table 6
RESIDENT -DERIVED SALES TAX REVENUE
4th and Mortimer
Households and Sales at Buildout
Average Household Taxable Expenditures
$ 17,836
Occupied Households
153
Percent within Santa Ana
65%
Total Taxable Sales
$ 1,769,689
City Share of Sales Tax
Measure X (2018) Additional Sales Tax'
Resident -Derived Sales Tax Revenues Annual Estimate
(Base Rate) $ 17,697
(2018 Addition) $ 26,545
(2029 Decrease to 1%) $ 21,131
Source: ESRI BAO, City of Santa Ana
'Measure X additional sales tax decreases from 1.5% to 1 % in 2029.
Business -Derived Sales Tax
The Project includes 7,514 square feet of retail space and 3,847 square feet of restaurant space.
These new businesses will generate sales taxes separate from the new residents. Since the
Developer does not yet know the exact tenants that will fill the space, RSG estimated an average
of $300 of sales per square foot for the retail, and $350 per square foot for the restaurant. As a
result, the retail and restaurant businesses will generate taxable sales of $2.4 million and $1.4
million at buildout, respectively.
RSG estimates the base sales tax revenues at buildout to be $39,345. Table 7 below presents
this information. In addition, Measure X will generate $59,018 for that year as well. However, in
2029 Measure X revenues will decrease to $36,007 before being eliminated altogether in 2039.
75C-477
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 11
Table 7
BUSINESS -DERIVED SALES TAX REVENUE
4th and Mortimer
Sales at Buildout
General Retail
2,463,225
Restaurant 1,471, 302
$ 3,934,527
City Share of Sales Tax
1%
Measure X (2018) Additional Sales Tax' 1.5%
Business -Derived Sales Tax Revenues Annual Estimate
(Base Rate) $ 39,345
(2018 Addition) $ 59,018
(2029 Decrease to 1%) $ 36,007
Source: California State Board of Equalization, RSG, Inc.
'Measure X additional sales tax decreases from 1.5% to 1 % in 2029
For the City base rate, combined resident and business sales taxes at buildout would be an
estimated $50,828. Measure X combined taxes would be $76,242. Both are adjusted for inflation
during the construction period and for the partial year at opening. This provides for a 25-year total
of $1.02 million from the base rate and $987,230 from Measure X.
Business Tax
The City assesses a business tax on retail, restaurant, and residential property management
companies. Table 8 below showcases the new revenues from the Project. Retail and restaurant
business taxes are assessed based on annual sales while management company business taxes
are assessed based on unit count. The combined business tax revenues are an estimated $8,125
at buildout, or $166,868 over 25 years (net present value, discounted at 4 percent).
Table 8
BUSINESS TAX REVENUES
4th and Mortimer
Multifamily Residential Tax
Retail Tax
Restaurant Tax
6,573
1,621
1,145
Full -Year Business Taxes at Buildout $ 9,339
Partial -Year Business Taxes at Buildout $ 8,125
Sources: City of Santa Ana, RSG, Inc
75C-478
Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 12
CITY EXPENDITURES
RSG estimated the additional population that will move into the Project to estimate the total added
expenditures to the City General Fund for servicing the new residents. Consistent with other
recent analyses prepared by RSG on projects in Santa Ana, RSG assumed that each studio would
house 1.25 residents, each one -bedroom unit would house 1.75 residents, each two -bedroom
unit would house 3.25 residents, each three -bedroom unit would house 4 residents, and each
four -bedroom unit would house 5.25. Overall, this works out to an average household size of 3.12
residents per unit, which RSG considers reasonable.
RSG estimates at full occupancy the Project could hold 527 residents. Taking into account that a
small percentage of the units will normally be vacant due to turnover, we estimate the fiscal
impacts based on residents' time spent in the City. This is done by calculating the full-time
equivalent (FTE) residents, defined as those who spend a vast majority of their daily consumption
in Santa Ana. The assumption being that new residents who work out of the City, do not consume
products in the City during the time they are gone.
RSG gathered data from the US Census and ESRI Business Analyst Online to estimate the FTE
residents of the Project. Approximately 13 percent of Santa Ana residents work within Santa Ana,
which, in effect means that the City is servicing these resident -employees 100 percent of the time.
Another 37 percent of Santa Ana residents work outside the city. Assuming the residents that
work outside of the city are outside City limits from 9 am to 5 pm, Santa Ana is servicing these
residents approximately 73 percent of the time. The city's remaining residential population (about
51 percent), is serviced by the City 100 percent of the time. Accounting for all residents and
employees based on the percent of time spent in the city, the Project will generate a daily (24/7)
population of 476 persons.
RSG identified variable costs, as opposed to fixed costs, by department in the City of Santa Ana
FY 2019-20 Adopted Budget. Variable costs are City expenditures that increase or decrease
based on the resident and employee population. The City Manager and City Attorney offices, for
example, are fixed costs that will not vary based on population, but the Police and Fire
departments will vary based on population. With that said, RSG estimates expenditure increases
of $120,441 during the first full year of operations. Over a 25-year projection period, the Project
will add $2.4 million in City expenditures (net present value, discounted at 4 percent).
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Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 13
Table 9
SUMMARY OF RECURRING CITY EXPENDITURES'
CITY OF SANTA ANA
4th + Mortimer
Current City
Project -derived
Total City
Percent
City Department
Expenditures
City Expenditures
Expenditu res3
Increase
City Manager's Office
$ 2,708,440
$ -
$ 2,708,440
0.00%
Non -Departmental & Intertund Transfers
61,098,660
-
61,098,660
0.00%
Clerk of the Council Office
1,682,560
17
1,682,577
0.00%
City Attorney's Office
3,219,780
-
3,219,780
0.00%
Personnel Services
2,490,360
50
2,490,410
0.00%
Finance & Management Services
9,671,190
228
9,671,418
0.00%
Bowers Museum Corporation
1,473,430
-
1,473,430
0.00%
Parks, Recreation and Community Services
26,836,790
1,551
26,838,341
0.01%
Police Department
131,568,820
75,973
131,644,793
0.06%
Fire Services
45,640,920
32,376
45,673,296
0.07%
Planning & Building Agency
13,227,380
24
13,227,404
0.00%
Public Works Agency
13,155,830
-
13,155,830
0.00%
Community Development Agency
3,353,520
-
3,353,520
0.00%
Base Estimate in 2020-21
$ 316,127,681
$ 110,221
$ 316,237,901
0.03%
Total in 2023.24
120,441
r For this analysis, RSG identified departmental costs in the City of Santa Ana FY 2019-20 Budget that are variable costs, as opposed to fixed costs.
Variable costs are expenditures by the City that increase or decrease based on the residential and employee population in the City. For example, City
Council and Human Resources salaries and wages generally are fixed costs that do not vary based on population. Meanwhile, the Fire Services and Parks
& Community Services departments will likely experience service cost increases due to the added population.
z Current expenditures are based on adopted expenditures in the City of Santa Ana's FY 2019-20 Budget.
3 Sum of current City expenditures and project -derived City expenditures. Assuming project opened in 2020-21.
Sources: City of Santa Ana, RSG, Inc., US Census Bureau
EMPLOYMENT
Development and ongoing operation of the Project will generate employment opportunities, add
labor income to the market area, and add value to the gross regional product. For this analysis,
RSG used the IMPLAN model to measure the economic impacts of the Project using County -wide
data. IMPLAN is an input-output analysis software tool that tracks the interdependence among
various producing and consuming sectors of the economy. According to MIG, Inc., the creators
of IMPLAN, the software measures the relationship between a given set of demands for final
goods and services and the inputs required to satisfy those demands. IMPLAN publishes
countywide data on an annual basis; this analysis utilized the most recent available County of
Orange dataset (2018) to calculate direct, indirect, and induced impacts.
The IMPLAN inputs are investment (development costs) and gross business operating income of
the Project and the resulting outputs are economic impacts, including employment generation,
labor income, and gross regional product. Jobs are the primary impacts calculated by IMPLAN.
RSG analyzed both temporary and permanent economic impacts. For temporary construction
impacts the Developer's Project costs exclusive of land costs were used ($77 million). From there
construction costs were divided based on square footage, between multi -family (95 percent) and
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Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 14
non-residential (5 percent). For permanent impacts, the estimated sales from the residential
complex, the restaurant space, and the retail space were used. IMPLAN breaks down the
resulting employment and other effects into three categories: direct, indirect, and induced:
• Direct Effects — Refers to the direct effects that occur on the Project site resulting from
development costs and operational sales revenue.
Indirect Effects — Changes in sales, jobs, and/or income within the businesses that supply
goods and services to the Project. Indirect effects do not occur directly on the Project -site
but are an indirect effect to surrounding or related businesses.
Induced Effects — Regional changes resulting from additional spending earned either
directly or indirectly from the Project.
RSG utilizes the FTE conversion of total employment generally preferred in Public Policy. FTE
employment numbers, as opposed to residents, present total employment through the lens of
hours worked; summarizing then dividing by how many 40-hour work weeks are generated by the
investment. The IMPLAN analysis concludes that the temporary construction component of the
Project will result in 510 direct FTE jobs, 47 indirect FTE jobs, and 214 induced FTE jobs the
majority of which will be in Santa Ana.
The permanent impacts attributed to the Project are 35 FTE jobs related to the operations of both
the residential building itself, as well as the retail and restaurant components of the Project. This
includes 25 direct, 4 indirect, and 5 induced jobs to the region.
Table 10 outlines the aforementioned FTE jobs generated by the Project.
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Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 15
Table 10
PROJECTED EMPLOYMENT (FTE)
4th and Mortimer
Temporary (Construction) Jobs
Direct
510
Indirect
47
Induced
214
Subtotal
771
Permanent Jobs
Direct
25
Indirect
4
Induced
5
Subtotal
35
Total Temporary & Permanent Jobs
Direct
535
Indirect
51
Induced
219
Total
806
Source: IMPLAN
NON -GENERAL FUND FISCAL IMPACTS
Business Improvement District
In 1984, a Business Improvement District ("BID") was established in Downtown Santa Ana. BIDS
are assessment districts in which business owners pay special levies that go toward various
improvements and promotions within the district. The City collects the funds and provides them
to Downtown Inc. and Santa Ana Business Council, which coordinate events such as First
Saturday Art -Walk, Savor Santa Ana, Boca De Oro Literary Festival, Santa Ana Media Summit,
Outdoor Cinema Series, and the Santa Ana Sidewalk Sales, events that advertise the downtown
area and bring foot traffic for local businesses.
The commercial component of the Project is located within the BID, so Project commercial
businesses would be charged BID fees like the other businesses in the area. Businesses are
levied according to the following guidelines:
• Retail Sale of Goods, Hotel and Motels, Theaters, and Food Establishments, shall pay an
amount equal to one and one- half times their annual business license fee.
• Commercial Rental Property, Rental Property, Residential and Rooming Houses shall pay
an amount equal to one -quarter times their annual business license fee.
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Richard M. Gollis, Principal
THE CONCORD GROUP
June 3, 2020
Page 16
• All other businesses, including Professions, Trades and Services shall pay an amount
equal to their annual business license fee.
Based on the City's business license fee schedules, the BID fees for the residential component
is estimated to be $2,282. The BID fees for the retail and restaurant spaces combined is estimated
to be $3,143 annually. While these funds do not directly benefit the general fund, they will increase
funding going towards these downtown events and promotions, which does ultimately help the
City.
Table 11
BUSINESS IMPROVEMENT DISTRICT FEES
4th and Mortimer
Residential Fee $ 2,282
Retail and Restaurant Fee 3,143
Total $ 5,424
2020 Total BID Estimates $ 200,000
Added by Project 5,424
% Added 2.7%
Total BID Revenues $ 205,424
Source: Santa Ana Business License Tax Fee Schedules, BID 2020 Assessment Report
In closing, it is our privilege to assist The Concord Group and your client Red Oak Investments
with predevelopment activities on this project. Please let us know if you have any questions or
comments pertaining to the findings of this report.
Sincerely,
James Simon, Principal
75C-483