HomeMy WebLinkAboutCorrespondence - #22 - Response to Late CommentsE P I D SOLUTIONS,INC
WHERE EXPERIENCE AN'N nAgc"p" "':F-
Date: September 17, 2024
Prepared by: Meaghan Truman, Associate Environmental Planner III
To: Ali Pezeshkpour, apezeshkpour@santa-ana.org
Site: Related Bristol Specific Plan Project
Subject: Late Comment Letters on the Supplemental EIR for the Related Bristol Specific Plan
Project Received before September 17, 2024 (SCH No. 2020029087)
Dear Mr. Pezeshkpour,
The 45-day public comment period for the Supplemental EIR of the Related Bristol Specific Plan Project
began July 6, 2023, and ended on August 21, 2023, as documented on the City's website, the Orange
County Clerk's website, and State Clearinghouse.
Under CEQA, a lead agency is required to consider comments on the Draft SEIR and to prepare written
responses, if a comment is received within the public comment period. (Pub. Resources Code, § 21091, subd.
(d); CEQA Guidelines, § 15088.) When a comment letter is received after the close of the public comment
period, however, a lead agency does not have an obligation to respond. (Pub. Resources Code, § 21091,
subd. (d)(1); Pub. Resources Code, § 21092.5, subd. (c)("Nothing in this section requires the lead agency to
respond to comments not received within the comment periods specified in this division, to reopen comment
periods, or to delay acting on a negative declaration or environmental impact report.").) Although a lead
agency is not required to respond to late comments, it may choose to do so. (Gray v. County of Madera
(2008) 167 Cal. App. 4th 1099, 1 1 10 (Gray), citing Pub. Resources Code, § 21091, subd. (d)(1); CEQA
Guidelines, § 15088; Gilroy Citizens for Responsible Planning v. City of Gilroy (2006) 140 Cal.App.4th
911, 925, fn. 10 (Gilroy Citizens)).
The letters were received by the City of Santa Ana after the 45-day public comment period for the Draft
Supplemental EIR ended on August 21, 2023. However, the City of Santa Ana has elected to prepare the
following written responses with the intent of conducting a comprehensive and meaningful evaluation of the
proposed Project. The number designations in the responses are correlated to the bracketed and identified
portions in the comment letter. EPD Solutions, Inc. has reviewed the letters and provided responses for the
Lead Agency's consideration in review of the Related Bristol Specific Plan Project at the September 17,
2024, City Council Hearing. As further detailed in the individual responses to comments below, none of the
comments indicate that there would be a substantial increase in the severity of a previously identified
environmental impact that would not be mitigated, or that there would be any of the other circumstances
requiring recirculation as described in CEQA Guidelines Section 15088.5. No new significant environmental
impact would result from the project or from a new mitigation measure proposed to be implemented, there
is no substantial increase in the severity of an environmental impact, no feasible project alternative or
mitigation measure considerably different from others previously analyzed would lessen the environmental
impacts of the Project, and the Draft and Final SEIR are not fundamentally inadequate and conclusory in
nature.
Please find the letters and response to comments attached.
Respectfully,
Meaghan Truman
Letter CC1: Support Comment Letters (1 page) Late Comment letter
Letters of Support
On behalf of Related Bristol, we sincerely appreciate all of the stakeholders who have taken the
time and effort to participate in our community outreach process. We have been greatly
encouraged that the Project has been well -received and express sincere gratitude to our
supporterswho share our vision and aspirations for Related Bristol, Santa Ana, and Orange
County.
Key Supporters Include:
Business Organizations & Companies
• Santa Ana Chamber of Commerce
• Travel Santa Ana
• Orange County Business Council
• Orange County Hispanic Chamber of
Commerce
• Apartment Association of Orange County
• California Apartment Association
• Octane
• S&A Management
Nonprofit Organizations
• Hope Builders
• Goodwill of Orange County
• Girl Scouts of Orange County (Santa Ana
Chapter)
• FridaTheater &DTSAArtWalk
• Kidworks
• Orange County United Way
• Mater Dei High School
• Cristo Rey Orange County High School
(Santa Ana)
■watwrco
Bristol
Existing Metro Town Square Retail Tenants
• Alberlson'sNon's
• Hans' Homemade Ice Cream
• The Boiling Crab
• Grounded Planet, Inc.
• Wang Cho 2BQ
• South Coast Pediatric Dentistry
Neighborhood Associations, Community
Groups, and Individuals
• G7 Neighborhood Leaders Alliance
(represents leadership of 17 city
neighborhood associations)
• Lee DeLeon, President and Founder of
Templo Calvario church
• Sal Tinajero
• Jeffrey Katz (Floral Park)
• Irma Jauregui (Wilshire Square)
• Michael Hixson (Sandpointe)
• Timothy Rush (Wilshire Square)
• Pam and Larry Marshburn (South Coast
Shores)
• Maurizio Bertoldi (South Coast Shores)
• Astrid and Michal Collins (Metro Classic)
• Katherine Freeman (Republic Homes)
• Elizabeth Hapsburg, People for Housing
• Kevin Ting, Santa Ana resident
• Hundreds of other individuals
31WSouth &iutoi.St, Santa Ana • (77A1716•5G30 • vmw.ialatedbrmtot.com
2
2
CC1.1
Flores, Dora
From:
Ryan Chase <
Sent:
Friday, September 13, 2024 4:03 PM
To:
eComment
Subject:
Related Bristol
Attention: This email originated from outside of City of Santa Arta. Use caution when opening attachments or links,
Dear Mayor & Councilmembers,
My name is Ryan Chase, a principal at S & A Management, and a 4th-generation property owner in Santa Ana since 1919_
I know you are busy so will keep my comments simple.
Please approve the Related Bristol project_ It will deliver enormous economic benefit and positive press to the city, with nearly $3 billion in private
investment, thousands ofjobs, millions of annual tax revenue and I I acres of open space that will be programmed for year-round activities to attract local
residents and visitors alike.
Related is as reputable a developer as they come, and Related Bristol is a HUGE opportunity to develop a dynamic new destination with energy, impottance
and attraction in the south end of Santa Ana. A project of this size will transform South Bristol Street into a new gateway to our city, as well as send a positive
message to the outside development and business community that Santa Ana is thinking BIG and open for business.
As a family deeply committed to this amazing city and desirous to see it continue to grow, we believe Related Bristol is a project that must go forward, the
alternative would be a travesty and felt for generations to come, similarly to when the City rejected the proposal for South Coast Plaza many years ago. Please
approve this visionary proposal which will deliver dividends to our city for generations to come.
Thank you,
Ryan Chase, Principal S & A Management
Flores, Dora
From: Brett Hollenbeck <
Sent: Saturday, September 14, 2024 10:06 AM
To: eComment
Subject: SUPPORT Item #22 Related Bristol
Attention: This email originatcd from outside of City of Santa Ana. Use caution when opening attachments or EnIcs
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 3,000 new housing units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project_
Sincerely,
Brett Hollenbeck
Flores, Dora
From: Jordyn Kieft <
Sent: Saturday, September 14, 2024 10:30 AM
To: eComment
Subject: Related Bristol project support
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members,
I'm writing to express my strong support for the Related Bristol project, which will transform an aging shopping center
into a vibrant neighborhood with over 1,000 new house units. This development offers a fantastic opportunity to reuse a
prime location in Santa Ana, right across from South Coast Plaza, bringing much -needed housing and revitalization to the
area, and I urge the Council to vote yes on this project.
Sincerely,
Jordyn Kieft
Flores, Dora
From:
Patricia Heilig
Sent:
Saturday, September 14, 2024 10:34 AM
To:
eComment
Subject:
SUPPORT Item #22 Related Bristol
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging shopping center
into a vibrant neighborhood with over 3,000 new housing units. This development offers a fantastic opportunity to reuse
a prime location in Santa Ana, right across from South Coast Plaza, bringing much -needed housing and revitalization to
the area, and I urge the Council to vote yes on this project.
Sincerely,
Patricia Heilig
Sent from my (Phone
Flores, Dora
From:
Brent Stoll <
Sent:
Saturday, September 14, 2024 10:40 AM
To:
eComment
Subject:
SUPPORT Item #22 Related Bristol
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging shopping center
into a vibrant neighborhood with over 3,000 new housing units. This development offers a fantastic opportunity to reuse
a prime location in Santa Ana, right across from South Coast Plaza, bringing much -needed housing and revitalization to
the area, and I urge the Council to vote yes on this project.
Sincerely,
Sent from my iPhone
- Brent
Flores, Dora
From: a waisanen <
Sent: Saturday, September 14, 2024 10:47 AM
To: eComment
Subject: Support for the Related Bristol Project
Attention: This email originatcd from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members,
I'm writing to express my strong support for the Related Bristol Project, which will transform an aging
shopping center into a vibrant neighborhood with over 1,000 new housing units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project_
Sincerely, Elenora uraisanen
Flores, Dora
From: Robert Morse <
Sent: Saturday, September 14, 2024 11:32 AM
To: eComment
Subject: SUPPORT Item #22 Related Bristol
Attention: This email originatcd from outside of City of Santa Ana. Use caution when opening attachments or EnIcs
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 3,000 new housing units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project_
Sincerely,
Robert "SantaBob" Morse
Commission to End Homelessness
Continuum of Care
Life on the Streets Ministry
Flores, Dora
From:
Bade Apalt <
Sent:
Saturday, September 14, 2024 8:03 PM
To:
eComment
Subject:
SUPPORT Item #22 Related Bristol
Attention: This email originatcd from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 3,000 new housing units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project_
Sincerely,
IN
Flores, Dora
From: Justin Truong <
Sent: Saturday, September 14, 2024 11:36 PM
To: eComment
Subject: SUPPORT Item #22 Related Bristol
Attention: This email originatcd from outside of City of Santa Ana. Use caution when opening attachments or EnIcs
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 3,000 new housing units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project_
Sincerely,
Justin Truong
Flores, Dora
From:
Dale Helvig <
Sent:
Sunday, September 15, 2024 3:50 PM
To:
Amezcua, Valerie; Phan, Thai; Vazquez, Benjamin; Lopez, Jessie; Bacerra, Phil;
Hernandez, Johnathan; Penaloza, David; eComment
Cc:
Carvalho, Sonia R.; Nunez, Alvaro; Thai, Minh; Hall, Jennifer
Subject:
2024-09-15 Letter to City Council -Support of Item 22 Related -Bristol
Attachments:
2024-09-15 Letter to City Council -Support of Item 22 Related-Bristol.pdf
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
See attached file.
Dale Helvig
Resident, Santa Ana
12
Dale Helvig
Resident, Santa Ana CA 92706
September 15, 2024
Mayor Amezcua and Santa Ana City Councilmembers
City of Santa Ana
20 Civic Center Plaza, 8'n Floor
Santa Ana CA 92702
Subject: Support of Item 22— Related Bristol Mixed Use Project
I will state the obvious...... this is once in a generation project. This is a project that is a win -win
for the City of Santa Ana. The city needs revenue and wants housing, this project provides both
while changing the landscape into a vibrant looking mixed -use complex that will support the
city's needs for many, many years.
The Planning Department did a very thorough review, and the Planning Commission has
provided you their approval. Do you part and approve this project.
Thank you for your time and consideration.
Respectfully,
Dale A Helvig
Resident, Santa Ana
cc: Alvaro Nunez,
City Manager, Santa Ana
Sonia Carvalho,
City Attorney, Santa Ana
Minh Thai,
Executive Director, Planning
Page 1 of 1
2024-09-15 Letter to City Council -Support of Item 22 Related -Bristol
13
Flores, Dora
From:
Sent: Sunday, September 15, 2024 5:42 PM
To: eComment
Subject: Related project on Bristol
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Members of the Santa Ana City Council,
I am writing to voice my support for the Related Bristol development project in Santa Ana, a venture that holds the
potential to advance our collective goals of equity and shared prosperity.
At a time when housing is a fundamental right denied to many, the addition of up to 3,750 residential units is a crucial
step toward ensuring that everyone in our community has a safe and affordable place to live. This project represents a
move toward dismantling the barriers that prevent working people from accessing housing.
The development's inclusion of 350,000 square feet of commercial space, 250 hotel rooms, and 200 senior care units
promises to create jobs and stimulate our local economy. This is an opportunity to prioritize the needs of the many over
the profits of the few, fostering a more just and equitable society.
Furthermore, the 13 acres of open space will provide vital communal areas for recreation and solidarity, enhancing our
community's well-being. The $22 million community benefits package is a testament to the project's commitment to
reinvesting in our public infrastructure and services.
I urge you to support this project, which aligns with our shared vision of a fairer, more inclusive Santa Ana.
In solidarity,
Santa Ana Resident
1A
Flores, Dora
From: Carl Benninger <
Sent: Sunday, September 15, 2024 9:06 PM
To: eComment
Subject: Related project on Bristol
Attention: This email orighratcd from outside of City of Santa Ana. Use caution when opening attachrnents or linics.
This project is good for the city and area. Vote yes for this project.
15
Flores, Dora
From:
Devin Valdez <
Sent:
Monday, September 16, 2024 8:24 AM
To:
eComment
Subject:
Santa Ana - Related Bristol
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members,
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 1,000 new house units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project.
Sincerely,
Devin Valdez
IV
Flores, Dora
From: sharon Ohara <
Sent: Monday, September 16, 2024 12:46 PM
To: eComment
Subject: SUPPORT Item #22 Related Bristol
Attention: This email originatcd from outside of City of Santa Ana. Use caution when opening attachments or EnIcs
Dear Santa Ana City Council Members
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 3,000 new housing units. This development offers a
fantastic opportunity to reuse a prime location in Santa Ana, right across from South Coast Plaza, bringing
much -needed housing and revitalization to the area, and I urge the Council to vote yes on this project_
sincerely, S h a ro n O H a ra
17
Flores, Dora
From: Elizabeth Hansburg P4H<elizabeth@peopleforhousing.org>
Sent: Monday, September 16, 2024 2:04 PM
To: eComment; !City Clerk
Subject: SUPPORT Item #22 Related Bristol
Attachments: Support Related Bristol P41-10C 9-16-2024.pdf
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
Dear Santa Ana City Council Members,
I'm writing to express my strong support for the Related Bristol project, which will transform an aging
shopping center into a vibrant neighborhood with over 3,000 new housing units. Please find attached our
organization's Letter of support. Thank you for your consideration.
Sincerely,
Elizabeth Hansburg
Co -Founder & Director
aa�t F O R NpGe
4�F1
18
VOR %1pG.r/
a Fighting for a future of abundant housing in Orange County.
peopleforhousing.org
Honorable Valerie Amezcua
Mayor, City of Santa Ana
20 Civic Center Plaza
Santa Ana, CA 92701
September 16, 2024
Dear Mayor Amezcua and Members of the City Council,
I am writing in support of the project before you— Related Bristol— which seeks to add 3750
much -needed new housing units to Orange County, creating a new neighborhood and new
destination on an otherwise crumbling, auto -oriented shopping center. Given the scarcity of empty,
developable land in Orange County, this project is a rare and unique opportunity to provide new
housing in a high quality, infill environment. We know that projects like Related Bristol are the future of
sustainability—both economic and environmental —in today's increasingly urban Orange County.
After two years of extensive community outreach, public presentations, environmental reviews and
millions of dollars spent on design working with the city, I hope this project is approved under its
current design and unprecedented benefits package, which includes new community open space and
funding for affordable housing. It would be a mistake to discard these efforts, and given the
requirements of the Housing Accountability Act, whatever development would replace it would have
much -needed housing, but would not generate the same level of synergy or sales tax from the mixed
use and experiential retail contained in the current proposal.
The need for housing is real and pressing, and every unit we can add to the regional housing supply
will help address the shortage that is felt by everyone. The quality of the design and planning with
which Related Bristol will set a precedent for future infill development in Orange County. I urge you to
vote yes and move this project forward.
Sincerely,
Elizabeth Hansburg
Cofounder, Director
From: Jane Davis
To: eComment
Subject: Public Hearing 3600 Bristol
Date: Tuesday, September 17, 2024 1:51:45 PM
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or
links.
Attn: City Council
I would like to express support for the project at 3600 Bristol.
From the information that I have read, I believe this project would be a significant
improvement to this section of Santa Ana.
Jane Davis
Property owner
Santa Ana
20
Response to Letter CC1: Support Comment Letters, dated September 10, 2024 through September 17,
2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC1.1: The first packet of letters of support was provided by the applicant team and includes
attached letters of support from a mix of residents, local and civil organizations, nonprofits, business and
regional stakeholders. Further comment letters in support of the Project were received from residents.
Response CC1.1: The comments express support for the Project and do not raise any specific environmental
concerns with the analysis within the Draft Supplemental EIR or requirements of the proposed Specific Plan.
The Draft Supplemental EIR was prepared pursuant to CEQA Statute and the CEQA Guidelines in order to
provide a meaningful discussion of the proposed Project and its resulting potential environmental impacts as
a means of public disclosure. Thus, no further response is required or provided; however, this comment will
be forwarded to all decision makers as part of the Staff Report for the Project. The letters of support
included in the commenter letter provided by the Applicant team have been included in this memo as
Attachment A.
21
Letter CC2: Shelly (1 pages) Late Comment letter
From: Shelly
TO: eComment
Subject: Notice of public Hearing requesting entitlements faciitate the new plan mixed urban village
Date: Monday, September 9, 2024 10:59:09 PM
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or
links.
Hi
I am not going to be available to attend the meeting regarding this matter because I
am working and paying my bills. I would like my voice to be heard by the City of Santa
Ana which I pay taxes to.
I am against the city taking out all of our shopping places while being encouraged to
walk to them. I don't understand why we need more units when there are a ton
available for rent on Alton that nobody in this are can afford,
I am deeply against taking away our resources for shopping while we pay a higher tax
then newport beach. 9.75 on our purchases when other citties pay 7.7
Has anyone in this city checked out how mamy of the nebuilds on Alton are
occupied? And what those builers promised?
If they are all vacant, I really feel Iikt this is a waste of money and a land grab. People
don't want to have reenters insurance in CA. But its being forced on people.
If it were you buying a 1 bedroom condo for 400K in Santa Ana what would you
expect out of the City where you decided to purchase it?
I urge you calm this 4000 plus units amd respect the people in the area and their
morning route.
If you look at the blocks around here with all the new built stuff, we still have
homeless, and nobody can rent those units. I think putting more units that nobody can
afford doesnt help, and creates more traffic.
i will share this email with my neighbors.the HOA, and the local news statition.
Please explain why your new complixes are not filled and you need to take out our
shopping areas to build more space? Something doesn't settle right.
22
CC2.1
Response to Letter CC2: Shelly, dated September 9, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC2.1: This comment states that the Project would remove needed stores and replace them with
more housing units in an area where additional units are not needed. The comment further states that the
additional units would not assist in reducing the homeless population in the area and would result in an
increase in traffic to the area. The comment concludes by stating that the already built new complexes are
not filled and thus this additional development is unnecessary.
Response CC2.1: This comment does not provide substantial evidence of a significant environmental impact.
The Project site has been designated as a District Center by the City of Santa Ana General Plan where
intense mixed -use development is encouraged. As discussed in Section 5.8, Land Use and Planning, of the
Draft Supplemental EIR, the proposed Project would be consistent with its General Plan designation. The
proposed Project would provide housing proximate to local employment centers, commercial retail services
and restaurants for onsite residents and employees working nearby. In addition, the proposed Project would
provide onsite open space and recreation activities that would integrate into the existing communities around
the site. Thus, the redevelopment of the site and change to the area has been planned for by the City.
In regard to the affordability of the units within the proposed Project site, the proposed Specific Plan does
not include specific requirements for affordable units. However, the proposed Project would result in a
residential density of 91 du/ac, which would allow the potential for each proposed residential or mixed -use
development to include affordable residential units. Section 3.6 of the proposed Specific Plan describes that
the City of Santa Ana has established an Affordable Housing Opportunity and Creation Ordinance
(AHOCO) to encourage the development of housing that is affordable to a range of households with varying
income levels. The Ordinance is applicable to new residential projects within the Specific Plan area that meet
certain criteria. As implementing projects in the Specific Plan area are submitted to the City for review, they
would be required to comply with the City's AHOCO or the Project's Development Agreement when
approved. In addition, affordable housing is an economic and social issue. CEQA is an environmental
protection statute that is concerned with physical changes to the environment (CEQA Guidelines Section
15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of
historic or aesthetic significance (CEQA Guidelines Section 15360). The Project's potential economic and
social effects are not considered effects on the environment (CEQA Guidelines Sections 15064(e) and
15131(a)). Thus, consistent with CEQA, the Draft Supplemental EIR includes an analysis of the Project's
potentially significant physical impacts on the environment and does not include substantial discussion of the
Project's economic or social effects. Because no environmental impacts related to affordable housing would
occur, mitigation measures are not required.
In regard to increases in traffic congestion, as detailed in Draft SEIR Section 5. 13 Transportation, Senate Bill
(SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or
traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the
State CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of
greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land
uses" (Public Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level
of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant
impact on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public
Resources Code Section 21099(b)(2), the Supplemental EIR focuses on analysis of Vehicle Miles Traveled
(VMT) criteria and improvements to the circulation system along the Project's frontage to accommodate
buildout of the proposed Project, pursuant to the City's recent General Plan Update. Further yet, the
Supplemental EIR is not required to analyze impacts related to traffic congestion. Nevertheless, a Traffic
Impact Analysis was prepared for the Project and is publicly available on the City's Project website.
23
Letter CC3: Neal Lauzon on behalf of IBEW Orange County (1 Page) Late Comment Letter
IBEW ORANGE COUNT'
309 N. Rampart St., Suite M, Orange, CA 92868 Neal H. Lauzon
(714) 939-3131 www.ibewoc.com Business Manager
via email: eComment@santa-ana.org
September 16, 2024
City of Santa Ana City Council
20 Civic Center Plaza, M-30
Santa Ana, CA 92701
Re: 9/17/24 AGENDA ITEM 22, Action 4
Related Bristol Specific Plan — IN NEED OF A BUILDING TRADES PLA
Council:
At its September 17`h meeting, Santa Ana City Council intends to present during public hearing various
items concerning the Related Bristol Specific Plan, a proposed mixed -use development in the City of
Santa Ana. Regarding Action 4 (Item 22), IBEW Local 441 stands conditionally opposed to the adoption of
a development agreement absent a Project Labor Agreement with the LA/OC Building Trades.
PLAs offer security and benefits and should always be included on projects with the scope and magnitude
of Related Bristol. Additionally, IBEW 441's own apprenticeship training center, OC ETI, is located in
Santa Ana. Without a Project Labor Agreement, our apprentices, local resident journeymen, and
veterans will not be given the opportunity to work in the city in which they live and train.
IBEW 441 hopes to endorse this mixed -use project in the future as the development agreement is
reimagined with the inclusion of an LA/OC Building Trades PLA.
Sincerely,
Neal H. Lauzon
Business Manager
:dm/jc
OPEIU #537/AFL-CIO, CLC
24
CC3.1
Response to Letter CCI Neal Lauzon dated September 16, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC3.1: This comment states that IBEW Local 441 stands conditionally opposed to the adoption of
a development agreement absent a project labor agreement with the Los Angeles/Orange County Building
Trades. The comment states a project labor agreement offers benefits and should be included in projects of
the magnitude of Related Bristol.
Response to Comment CC3.1: The comment does not raise any specific environmental concern with the
analysis within the Draft Supplemental EIR or requirements of the proposed Specific Plan. CEQA is an
environmental protection statute that is concerned with physical changes to the environment (CEQA Guidelines
Section 15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and
objects of historic or aesthetic significance (CEQA Guidelines Section 15360). The Project's potential
economic and social effects are not considered effects on the environment (CEQA Guidelines Sections
15064(e) and 15131(a)). Thus, consistent with CEQA, the Draft Supplemental EIR includes an analysis of the
Project's potentially significant physical impacts on the environment and does not include substantial discussion
of the Project's economic or social effects. This comment will be forwarded to City decisionmakers as part of
the Staff Report for the Project.
25
Letter CC4: Louis Steers (2 pages) Late Comment letter
Flores, Dora
From: Louis Steers <
Sent: Monday, September 16, 2024 3:13 PM
To: eComment
Subject: Agenda Item #22
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
I strongly urge a non approval of various entitlements to facilitate the
establishment of a new Specific Plan (SP) and construction of new, mixed
use urban village for the following concerns:
1. Current congestion on Bristol and MacArthur and to my knowledge no
plan to widen current streets. This project will cause more traffic issues
for the residents residing in neighborhoods around the proposed urban
village.
2. The proposed tenants of the urban village will take away the
"affordable" shopping for current neighborhood residents and favor more
upscale establishments and discriminate against the current population of
the neighborhood. In addition it will cause an increase in vehicle traffic as
residents commute to the stores in their price range.
3. The village's proposed 3750 residential units, 200 units of senior
continuum of care living, 250 room key hotel and the 350,000 square feet
of commercial space is astronomical increase of population on the
proposed site which the 13.1 acres of publicly accessible open space does
not remediate
4. Although Independent this urban village is parallel to the other
"village" planned for Bear and Sunflower with increased housing and
office space which will further increase traffic congestion on McArthur,
Bristol, Bear and Sunflower.
I encourage all planning commission and council members to physically
be present in the neighborhood and see what I am addressing. Backed up
traffic getting on to freeways on Bear and commute traffic coming off the
freeways on both Bear and Bristol.
0
CC4.1
I know that progress and upgraded shopping and housing cannot be
stopped and is a positive plan on paper.... but please consider the reality of
the impact this project will have on the real lives of the current residents as con'
you cast your vote.
Thank you for your attention to this matter I
Sincerely
Louis Steers
Santa Ana, CA 92704
27
Response to Letter CC4: Louis Steers, dated September 16, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC4.1: This comment states that the commenter opposes the proposed Project due to the increase
in congestion around nearby roadways, the loss of affordable shopping options in the area, and the lack of
open space provided for the large increase in population to the area.
Response CC4.1: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR. Draft Supplemental EIR Section 5.1 3, Transportation, details that Senate Bill (SB)
743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic
congestion as the basis for determining significant impacts. As part of the 2019 amendments to the State
CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of
greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land
uses" (Public Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level
of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant
impact on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public
Resources Code Section 21099(b)(2), the Supplemental EIR focuses on analysis of Vehicle Miles Traveled
(VMT) criteria and improvements to the circulation system along the Project's frontage to accommodate
buildout of the proposed Project, pursuant to the City's recent General Plan Update. Further yet, the
Supplemental EIR is not required to analyze impacts related to traffic congestion. Nevertheless, a Traffic
Impact Analysis was prepared for the Project and is publicly available on the City's Project website. This
comment will be forwarded to all decision makers as part of the staff report for the Project.
In regard to the affordability of the stores within the proposed Project site, CEQA is an environmental
protection statute that is concerned with physical changes to the environment (CEQA Guidelines Section
15358(b)). The environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of
historic or aesthetic significance (CEQA Guidelines Section 15360). The Project's potential economic and
social effects are not considered effects on the environment (CEQA Guidelines Sections 15064(e) and
15131(a)). Thus, consistent with CEQA, the Draft Supplemental EIR includes an analysis of the Project's
potentially significant physical impacts on the environment and does not include substantial discussion of the
Project's economic or social effects. Because no environmental impacts related to the affordability of the
stores would occur, mitigation measures are not required.
As discussed on page 5.12-8 of the Draft SEIR, while the proposed Project would provide approximately
17.21 acres of public and private open space, inclusive of 13.1 acres of publicly accessible open space and
recreational facilities onsite, per the requirements of the Related Bristol Specific Plan, the proposed Project's
provision of parkland would not meet the City of Santa Ana's GPU performance standard of 3 acres of
parkland for every 1,000 residents, either on the site or cumulatively. As the existing ratio of acreage of
parks and recreational facilities to existing City population results in a parkland deficiency of approximately
154.44 acres, development of the proposed Project would continue to result in a deficiency in parkland
throughout the City of Santa Ana. The Project proposes to provide approximately 1.4 acres of publicly
accessible open space per 1,000 residents, which exceeds the approximately 1.2 acres per 1,000 residents
currently existing within the City.
In order to comply with the GPU policy of 3 acres of parkland per 1,000 residents, the proposed Project
would require 27.7 acres of parkland or the dedication of approximately 67.3 percent of the Project site.
While the proposed Project would provide approximately 17.21 acres of public and private open space
onsite, inclusive of 13.1 acres of publicly accessible open space and facilities, and would comply with
applicable Municipal Code requirements, the proposed Project would not provide 27.7 acres of parkland
and recreation facilities onsite and would not meet the City of Santa Ana's performance standard for
28
parkland, either on the site or cumulatively through the availability of parks and recreation facilities citywide.
As discussed in the GPU FEIR, the City of Santa Ana is essentially fully built out and there is a lack of available
vacant land to develop substantial new parks or expand existing facilities. Therefore, there would be no
feasible mitigation measures that would be able to reduce the proposed Project's contribution to significant
impacts related to the City's unsatisfactory level of resident to parkland ratio. As such, impacts would be
significant and unavoidable, which is consistent with the findings of the GPU FEIR. This comment will be
forwarded to all decision makers as part of the Staff Report for the Project.
29
Letter CC4: Bonnie Hanson (1 page) Late Comment Letter
Flores, Dora
From: Bonnie Hanson <
Sent: Monday, September 16, 2024 3:47 PM
To: eComment
Subject: The meeting on 9/17/24 about proposed West side of 3600 Bristol St. area changes
Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links.
To: The City of Santa Ana
Planning and Building Agency
Regarding: The Proposed Changes to the West Bristol Plaza Area (3600 Bristol St.)
Relating to: Application (AA #2303-03) and other appropriate items relating to the above
September 16, 2024
Regarding the proposed extreme and expansive changes to the large area on the West side of Bristol Street, between
MacArthur and Susan Street, I am quite concerned —and many of my neighbors here are concerned with me.
My late husband and I bought a home in this area (on So. Lowell St.) in 1977, and after moving here with our three sons,
I have enjoyed living here in this middle-class area ever since. We appreciated the attitude of our friendly, multi -ethnic
neighbors here-- more welcome than we found in our previous neighborhood in Tustin —where we experienced a lot of CC5.1
prejudice against less -wealthy residents. We were also persuaded to move here by the wide assortment of affordable
stores, restaurants (including fast-food ones), and other helpful businesses such as banks and dental and eye care. We
gladly became involved in our local community, including a local church.
In 2017, after my dear husband died, I sold my home. But deciding where to move next was no brainer—ever since
then. I've lived in the South Coast Villas apartment complex within a few minutes' walking distance of Bristol St. Having
given up my car (I'm now 92), 1 can still get around this area with my cart, shopping for groceries, prescriptions, fast
food, and many other needs. Good exercise and independence. The many businesses on the West side of Bristol, as
well as those on the East side, help meet my needs and those of many of my neighbors, from little ones to senior
citizens like me. Like most of those in the area, I'm on a modest income, mostly Social Security.
Many months ago, when I first heard of these proposed changes, and an open meeting was held at nearby Saddleback
High School, to introduce the changes, I attended. I had a list of questions to ask about this proposal, as follows:
QUESTIONS:
1. What about businesses in this area now —like B of A, Vons, Chase, McDonalds? Will they all be invited to
stay? If so, in new buildings? And what about their businesses from now till new buildings completed? How CC5.2
long is change expected to take?
2. What about added traffic congestion?
3. How will this impact South Coast Plaza?
4. What about the usual temporary Christmas Tree sales area?
5. What about increased parking needs with less space?
6. How will this huge increase in use affect local power and water supplies? Sewer lines?
7. What about increased traffic impact on the 405/Bristol, Bristol/Sunflower, Bristol/MacArthur intersections?
That night, I kept waiting for a chance to ask those questions, but never got it. They are still important questions to ask
about this project. Is it a great step forward for the city of Santa Ana, for the residents in this area, for the businesses CC5.3
already in this area, for all of Orange County? Or just a chance for some property owners to grab a lot of dough, no
matter how it affects others?
Thank you for this opportunity for my thoughts on this very important matter.
Sincerely,
30
Response to Letter CCS: Bonnie Hanson, dated September 16, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC5.1: This comment states the commenter is concerned about the Project and that the commenter
has enjoyed living in Santa Ana. The comment states that the commenter lives in the area and shops at the
Project site and that the businesses help the community.
Response CC5.1: The comment is introductory in nature and does not raise a specific issue with the adequacy
of the Draft Supplemental EIR or raise any other CEQA issue. Therefore, no further response is required or
provided.
Comment CC5.2: The comment discusses that the commenter went to a meeting regarding the Project at
Saddleback High School and had a list of questions. The comments asks what will happen to the businesses
in the area now and whether they will be invited to stay and what will happen during construction. The
comment asks how long construction will take. The comment asks about added traffic congestion and how
the Project will impact South Coast Plaza. The comment asks about the temporary Christmas Tree sales area
and the need for increased parking. The comment asks how the increase will affect local power, water
supplies, and sewer lines. The comment asks about increased traffic on the 405/Bristol, Bristol/Sunflower,
and Bristol/MacArthur intersections.
Response CC5.2: The comment does not raise a specific issue with the adequacy of the Draft Supplemental
EIR or raise any other CEQA issue. Regarding the existing businesses and construction timing, as described
in Chapter 6 of the Specific Plan, construction of Phase 1 is expected to commence in the first quarter of
2026 with completion in the first quarter of 2030. Existing land uses in the Phase 2 and Phase 3 areas would
be operational while Phase 1 is under construction. Phase 2 is expected to commence in the second quarter
of 2030 with completion in the fourth quarter of 2032. Phase 3 is expected to commence in the first quarter
of 2033 with completion in the second quarter of 2036. However, as the Project is a Specific Plan, future
businesses that would operate within the Project are unknown.
In regard to traffic congestion, the Draft Supplemental EIR Section 5.13 Transportation, details that Senate
Bill (SB) 743 changes include the elimination of auto delay, LOS, and similar measures of vehicular capacity
or traffic congestion as the basis for determining significant impacts. As part of the 2019 amendments to the
State CEQA Guidelines, SB 743 directed that the revised CEQA Guidelines "shall promote the reduction of
greenhouse gas emissions, the development of multimodal transportation networks, and a diversity of land
uses" (Public Resources Code Section 21099[b][1 ]); and that "automobile delay, as described solely by level
of service or similar measures of vehicular capacity or traffic congestion, shall not be considered a significant
impact on the environment" (Public Resources Code Section 21099[b][2]). As such, pursuant to Public
Resources Code Section 21099(b)(2), the Supplemental EIR is not required to analyze impacts related to
traffic congestion. Nevertheless, a Traffic Impact Analysis was prepared for the Project and is publicly
available on the City's Project website.
Regarding parking, as discussed on page 5.16-7 of the Draft SEIR, the Project is located on an infill site
within a TPA as defined under Public Resources Code Section 21099; therefore, the Project's parking impacts
are not considered significant effects on the environment.
Regarding the Project's impact on South Coast Plaza, the Project would not result in any changes to the
existing operations at South Coast Plaza. Regarding the electricity demands of the proposed Project, as
detailed in Draft Supplemental EIR Section 5.3, Energy, Southern California Edison Company (SCE) has the
capacity to continue providing service to the Project site at buildout of the Project. Also, as described on
page 5.3-1 1 of the Draft Supplemental EIR, the proposed Project would be required to comply with most
current Title 24 Building Energy Efficiency Standards and Section 1 10.10 of the 2022 California Energy
Code for solar panels. Further, Mitigation Measure GHG-2 requires the proposed Project to meet CALGreen
Tier 2 voluntary energy efficiency standards, which surpass the building code energy efficiency
31
requirements, and would provide for high performance solar panels and installation of solar battery systems
to provide storage of energy generated onsite.
In regard to water demands resulting from the Project, an analysis of potential water demand resulting
from the Project was conducted as part of the Draft Supplemental EIR as a Water Supply Assessment
(Appendix P to the Draft Supplemental EIR). As discussed on page 5.15-1 1 of the Draft Supplemental EIR,
the Water Supply Assessment determined that the proposed Project would result in an increase of 802,359
gallons per day or 899 acre-feet per year. This volume of water supply was accounted for in the City's
2015 UWMP (as determined by the GPU FEIR). Additionally, as detailed in Table 5.15-5 of the Draft
Supplemental EIR, the City has an additional supply of 5,500 to 6,500 AFY beyond that anticipated to be
needed by the 2020 UWMP projections. Therefore, the City would have sufficient water supplies available
to serve the Project and projected growth.
Regarding sewer demands resulting from the Project, Section 5.15, Utilities and Service Systems, details on
page 5.15-5 that a Sewer Analysis Report (Draft Supplemental EIR Appendix Q) was prepared to determine
whether the sewer system would be able to adequately handle the wastewater flows from the proposed
Project in addition to existing flows. The analysis determined that the existing commercial development on
the Project site generates an average flow of 0.0534 cubic feet per second (cfs) with a peak flow of 0.160
cfs. The proposed Project would generate an average flow of 1.177 cfs with a peak flow of 3.530 cfs. Thus,
the proposed Project would result in an increase of flows by an average daily flow of 1.1236 cfs and a
peak flow of 3.370 cfs. Based on results of the Sewer Analysis Report (Appendix Q), the proposed Project
would install a new onsite sewer system that would connect to the existing 78-inch OCSD sewer main within
the Sunflower Avenue right-of-way. The Sewer Analysis Report determined that the Sunflower Avenue OCSD
sewer main has a maximum capacity of 96.8 cfs and has adequate capacity to accommodate the additional
wastewater flows from the proposed Project. Also, each specific infrastructure improvement would be further
verified through the City's development review and permitting process to ensure appropriate design
capacities.
Comment CC5.3: This comment states that the commenter never got a chance to ask the previous questions
at the meeting at Saddleback High School. The comment asks if the Project is a great step forward or if it is
just a chance for property owners to make money.
Response CC5.3: The comment does not raise a specific issue with the adequacy of the Draft Supplemental
EIR or raise any other CEQA issue. Therefore, no further response is required or provided. This comment will
be forwarded to City decisionmakers as part of the Staff Report for the Project.
32
Letter CC6: Thomas Drennan (1 page) Late Comment Letter
l represent 20,000 Memembers of the International Union of Operating Engineers Local 12_ iUOE Local 12
is also a Trade Union part of the OC/La Building Trades. I am respectfully requesting that the City Council
postpone the agreement with Bristol Related, and allow more time for an agreement to be reached. The
day of hand shake deals and giving my word as being golden are over. Without an agreement local hire,
Helmets to hats, and h9C3 requirements will not be able to be met. Many Local trade Unions will not even
be on the job site. 2 trade Unions will monopolize the work and will not pay area standards.
Same may say this is not our fight or not our problem. you may be right_ When it is not our fight and not
our problem and people call on the Building Trades or Local 12, We came running and do what we can.
We never leave our friends standing alone.
Take a look at OC Vibe. a 5 Billion dollar private money project (very similar) just like this one has an
agreement, right down the road_ why the different standard? Why allow such a different standard or
different set of rules on this project? it makes no sense to let so many Trade ]Unions with Local Hire
apprentices, veterans, and Journey persons miss out on this opportunity to work on such a great project in
such a great project
Thank You
Thomas Drennan
33
CC6.1
Response to Letter CC6: Thomas Drennan, dated September 17, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC6.1: This comment states that the commenter represents 20,000 members of the International
Union of Operating Engineers Local 12, which is a trade union part of the OC/LA Building Trades and that
the commenter requests that the City Council postpone the agreement with Bristol Related to allow more time
for a labor agreement to be reached. The comment states that without a local hire agreement, many local
trade unions will not be on the job site. The comment says to look at OC V!be, which has a labor agreement
and that it doesn't make sense to have so many local hire individuals miss out on working on such a great
project.
Response CC6.1: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR or requirements of the proposed Specific Plan. CEQA is an environmental protection
statute that is concerned with physical changes to the environment (CEQA Guidelines Section 15358(b)). The
environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic
significance (CEQA Guidelines Section 15360). The Project's potential economic and social effects are not
considered effects on the environment (CEQA Guidelines Sections 15064(e) and 151 31(a)). Thus, consistent
with CEQA, the Draft Supplemental EIR includes an analysis of the Project's potentially significant physical
impacts on the environment and does not include substantial discussion of the Project's economic or social
effects, such as labor agreements. This comment will be forwarded to City decisionmakers as part of the
Staff Report for the Project.
34
Letter CC7: Pete (2 pages) Late Comment Letter
COUNCIL MEETING
RELATED DEVELOPMENT SOUTH BRISTOL
17 SEP 2024
13 ACRES
In various meetings, we've heard folks positively gush about the great 13 acre "park" in this
development. Realistically, this is open space only for the residents. No one from outside the
development will be going there specifically to enjoy the park, walk the dog, or have fun with the kids.
(maybe with an ice cream from Hans') there is nothing in the renderings that resembles a play area or
sports facility, much less public restrooms.
If there is no playing field, it can't possibly take any pressure off of any of the parks that currently host
multiple soccer games, basketball, etc. on every weekend. (more residents will exacerbate the
situation) If there is a provision for that, it will be difficult for people to use it.
Where are "outside" visitors going to park? They're not going to use valet. Currently in many Santa Ana
parks, the leagues bring their own goals, corner flags, etc. That won't be an option. How will they gain
access to the area to unload / load equipment?
It won't be a convenient walk . How are they going to get their picnic baskets (?), beer and soda coolers,
and chairs / umbrellas to the site? That issue currently exists; several parks are under-utilized (for
sports) because of access issues. (e.g. Lili King... really can't park unless we pay off / twist the arms of
SALISD. Sandpointe... constant street parking already filled.
There are folks that think the addition of 13 acres to the City resume is a great thing; and any increase
helps. But the over-all value to everyone outside of the property is marginal. There will be resistance to
any organized sports if it upsets in any way the atmosphere of expensive luxury apartments. Referees'
whistles, boisterous players, cheering, fans and their kids are not part of this development; not to
mention evening practices and pick-up games. If you visit a "league play" day in a Santa Ana park, you
know that activity would not work in this development.
If this is truly a windfall for the city, it should have provisions for weekend organized sports for the
community. It should be ironclad in the Development Agreement. We know from sad experience that
terms of Development Agreements are not always met (see Nexus NS2691). Any less -active amenities,
tennis or pickle ball, for example, will undoubtedly be restricted by "reservations," card or code access,
lack of restroom access, and parking issues. And consider that tennis / pickleball in Sandpointe isn't
exactly booked solid.
The open space is private. Santa Ana Parks has not been a part of the discussion. There are no
guarantees; and this isn't the windfall that some proclaim it to be. It is illusional.
EIR / Quality of Life
The area surrounding this proposed development will be subject to high disruptions in the quality of life;
up to 15-20 years of construction issues, culminating in a 260% increase in "unmitigable" traffic by phase
II. They propose to use commercial ride sharing, which only INCREASES the number of trips V. a
personal vehicle.
Macarthur is already the de facto alternate for issues on the 405.
This is in an area that already has some of the busiest intersections in the County. Between Thanksgiving
and Lunar New Year, the area is already frequently gridlocked.
35
CC7.1
CC7.2
There is a development under construction now at Macarthur and the 55 freeway.
THE VILLAGE (adjacent to this proposal, and across from South Coast Plaza) has already been presented. CC7.2
Think what a project like this would do to the area where you live. Cont.
The Development Agreement must contain more mitigation for the area. Remember, the owners of this
property also own property on the East side of Bristol. Perhaps parts of this could contain modified right
turn / access -egress provisions to mitigate the issues.
"PUBLIC BENEFIT FUNDS"
$22,000,000 has been suggested for "Public Benefit". Considering the current costs of just about
everything, this is absurdly inadequate. What does it cost to fully reconstruct 2 miles of Macarthur Blvd?
( Hint: roadway reconstruction costs have been rising by 24% per year; UP 69% since December of
2020.)* The increase in construction traffic alone will accelerate the need for work on Macarthur and
other arterials, already in jeopardy. This will need to be done before the RELATED project is fully
contributory. Traffic on Flower, Sunflower, Macarthur, and Fairview will greatly increase, with a need for
increased maintenance. The proposed funds will be exhausted just maintaining** what we have, and
nothing will improve or be mitigated. The majority of the funds proposed need to be allocated to the
area that will be most impacted by the development. There needs to be local citizen input, with full
voting on how funds would be used.
CC7.3
The developer has touted the economic boon (sales tax, real estate taxes / valuation, increased
economic activity) this will be for the City. That `largess" is in the future: 10-15 years. But the area will
suffer and degrade in the interim. There will be an immediate decrease in funds from businesses, and
increase in infrastructure deterioration. The investment of the Public Benefit funds in the immediate
area is needed to off -set this impact, AND to ensure that the area is prepared and attractive to future
residents, investors, and retail customers. If this does not happen, if the funds are parsed throughout
the city on short-term pet projects and feel -good promotions, the development will not deliver the
future projected gains. We must maintain the long view on the investment of the area. Remember the
pain, economic impact, and ongoing traffic issues of the trolley? And how we were hamstrung by the
County? The City needs to utilize the funds to offset the issues, anticipated and unanticipated, for the
local area. This project impact will be an order of magnitude greater in volume and duration; in the area
that is a large (largest?) contributor to the City budget. The project will undoubtedly impact that budget
when we can least afford it, the next 2-6 years.
More Public Benefit from the developer, spent in the area around the development, with active input
from the residents and businesses most impacted.
*https://enotrans.org/article/fhwa-highway-construction-costs-continued-to-grow-at-24-annua I -rate/
**https://www.santa-ana.org/documents/draft-2022-pavement-plan CC7.4
"the arterial network will change from "Good" to "Fair" condition from FY2022123 to FY2028129
...level of funding is insufficient to stabilize the backlog since the unfunded deferred M&R projects
will increase by43 percent for the arterial network and increase by35 percent for the local network.
9-1
Response to Letter CC7: Pete, dated September 17, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC7.1: This comment states that the 13 acres of public open space proposed by the Project would
not be useful for those residing outside of the proposed development as there are no opportunities to host
organized sports. The comment further states that the Development Agreement should include provisions for
weekend organized sports in the community, and that much of the open space will actually be private for
the residences within the Project site and would be unavailable to other residences in the area.
Response CC7.1: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR or requirements of the proposed Specific Plan. As discussed on page 5.12-8 of the
Draft SEIR, the proposed Project would provide approximately 17.21 acres of total open space, with 13.1
acres being available to the public. While there are designated private open space areas proposed for the
Project site, those areas are not included in the 13.1 acres of public open space that would be available to
anyone in the community to access. As discussed on page 5.12-5 of the Draft EIR, the 13.1 acres of public
open space will include a central park, two plaza spaces, a green link/paseo, and other open spaces such
as landscaped parkways and programmable roads that could be used for public recreational areas. While
the proposed open space areas may not be able to accommodate organized sport activities such as soccer
or baseball, parks and open space come in a variety of forms, and the open space provided by the
proposed Project would be consistent with Policy OS-1.5 of the Santa Ana General Plan Open Space
Element to "provide a mix of community, neighborhood, and special -use parks, along with greenway
corridors, natural areas, and landscape areas, to meet community needs for greenspace, recreation space,
social space, and trail connectivity." This comment will be forwarded to City decisionmakers as a part of the
Staff Report for the Project.
Comment CC7.2: This comment states that implementation of the proposed Project would result in major
traffic congestion on the surrounding roadways especially when combined with "The Village" which is
adjacent to the proposed Project. The comment recommends additional mitigation in order to alleviate traffic
congestion.
Response CC7.2: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR or requirements of the proposed Specific Plan. In regard to increases in traffic
congestion, as detailed in Draft SEIR Section 5. 13 Transportation, Senate Bill (SB) 743 changes include the
elimination of auto delay, LOS, and similar measures of vehicular capacity or traffic congestion as the basis
for determining significant impacts. As part of the 2019 amendments to the State CEQA Guidelines, SB 743
directed that the revised CEQA Guidelines "shall promote the reduction of greenhouse gas emissions, the
development of multimodal transportation networks, and a diversity of land uses" (Public Resources Code
Section 21099[b][1 ]); and that "automobile delay, as described solely by level of service or similar measures
of vehicular capacity or traffic congestion, shall not be considered a significant impact on the environment"
(Public Resources Code Section 21099[b][2]). As such, pursuant to Public Resources Code Section
21099(b)(2), the Supplemental EIR focuses on analysis of Vehicle Miles Traveled (VMT) criteria and
improvements to the circulation system along the Project's frontage to accommodate buildout of the proposed
Project, pursuant to the City's recent General Plan Update. Further yet, the Supplemental EIR is not required
to analyze impacts related to traffic congestion. Nevertheless, a Traffic Impact Analysis was prepared for
the Project and is publicly available on the City's Project website. This comment will be forwarded to City
decisionmakers as a part of the Staff Report for the Project.
Comment CC7.3: This comment states that the proposed Public Benefit Agreement is not sufficient to meet
the needs of the surrounding community who will be impacted the most by the construction of the proposed
Project. The commenter further states that while there may be future economic benefits of the proposed
37
Project, the area will suffer and degrade during the Project's extensive construction. The commenter states
that the public benefits must be invested into the surrounding area who will be impacted the most by the
construction, and there should be community input on where the public benefits should be spent.
Response CC7.3: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR or requirements of the proposed Specific Plan. CEQA is an environmental protection
statute that is concerned with physical changes to the environment (CEQA Guidelines Section 15358(b)). The
environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic
significance (CEQA Guidelines Section 15360). The Project's potential economic and social effects are not
considered effects on the environment (CEQA Guidelines Sections 15064(e) and 151 31(a)). Thus, consistent
with CEQA, the Draft Supplemental EIR includes an analysis of the Project's potentially significant physical
impacts on the environment and does not include discussion of allocation of Development Agreement funds.
This comment will be forwarded to City decisionmakers as part of the Staff Report for the Project.
Comment CC7.4: This comment provides links to the Eno Center for Transportation website and the City of
Santa Ana 2022 Pavement Management Program.
Response CC7.4: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR or requirements of the proposed Specific Plan. The commenter does not provide
additional data or specific measures for consideration or incorporation under this specific comment.
Therefore, no further revisions to the Draft EIR are required. This comment will be forwarded to City
decisionmakers as part of the Staff Report for the Project.
38
Letter CC8: Local Union 582 (1 page) Late Comment Letter
s s
.t
�r+�� cawor�, v�rcarnis,
LoCa# 592 orange Cmmty, Califom[a
United Association of Idurntrymrn and
Apprentices of the Plumbing and Ripe
Fitting Industry of the United States and Canada
Viatmail: cComment(asanta-aJta.ot„
September 171h, 2024
City of Santa Ana City Council
20 Civic Center Place, M-30
Santa Ana Ca 42701
RE: 9f17f24 AGENDA ITEM 22, ACTION 4
Related Bristol 5pwitie Platt- 11V NEED OF BUILDING 'FRAMES PLA
Council. -
Robert James
Bawme,x Uwwger.
FrrrwwAz! veire4wY. T�ewurer
Today tit the Scpte tuber 176 city council meeliri& thr city of Santa Ana City Council will be holding a public
hearing on items of the Related Bristol Project Specific Plea,which is a Proposed mixed use deveiopment in
the City of Santa Ana. Witb regards of Action 4 (Jtem22j TIA Local 582 stands apposed to the acceptance of
this development as a Project Labor Agreement (PLA) with the LA/OC Building 1`rades is absent
Project Labor Agreements hold henefi% for our members that live in the city of Santa Ana, such as local hire
standari[s and Veterans first wh ich help our nnernbers work closer to home atfd tl}at helps Our members spend
rnom time at home with their i:ami I im- Local 582 has hundreds of its members that reside in the city of Santa
Ana and work in other ommties speDding hours a days in their cars Comm using.
IJA Local 582 hopes and wants to endorse this mixed -use project if a PLA with the LAW Building Trades
will be included moving forward with this project_
Thank you_
>
ccrc3y.
Hor y Hillebracht
Busmess Agent
Local Union 582
Plumbers and Sbmi fitteers and Welders
Ornnar. f 4linty
1916 W- Chapman Ave., orange. California 92868-2608 (714) 97"582 FAX (?14) 978-I582
1,1 Amri daoon of kuencymanend nppW1iceg offt Pi=hnrgand Pipc Fading Indamy of the United Stara wW i,�xindn
39
Cc#.1
Response to Letter CCB: Local Union 582, dated September 17, 2024
This comment letter was received after the public review and comment period ended (July 6, 2023, through
August 23, 2023). As stated in Section 15088 of the CEQA Guidelines, Lead Agencies are not required to
respond to letters received outside of the noticed comment period. However, the following responses have
been prepared to provide clarity regarding the environmental concerns that have been raised.
Comment CC8.1: This comment summarizes the Project and states that it is going to City Council on
September 17. The comment states that UA Local 582 is opposed to the acceptance of this development as
a Project Labor Agreement (PLA) with the LA/OC Building Trades absent. The comment states that Project
Labor Agreements have benefits for members living in Santa Ana and would help them work closer to home.
The comment states that UA Local 582 wants to support the Project if a PLA with the LA/OC Buildings Trades
is included.
Response CC8.1: The comment does not raise any specific environmental concern with the analysis within the
Draft Supplemental EIR or requirements of the proposed Specific Plan. CEQA is an environmental protection
statute that is concerned with physical changes to the environment (CEQA Guidelines Section 15358(b)). The
environment includes land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic
significance (CEQA Guidelines Section 15360). The Project's potential economic and social effects are not
considered effects on the environment (CEQA Guidelines Sections 15064(e) and 151 31(a)). Thus, consistent
with CEQA, the Draft Supplemental EIR includes an analysis of the Project's potentially significant physical
impacts on the environment and does not include substantial discussion of the Project's economic or social
effects, such as labor agreements. This comment will be forwarded to City decisionmakers as part of the
Staff Report for the Project.
40