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The October Clarification to the FOR provides a detailed description of the modified project. As described, the site
<br />was previously proposed for development of 496 multi -family residential units, and therefore, the site is capable of
<br />accommodating more multi -family units than currently proposed (256 units, 58 dwelling units per acre). However, the
<br />modified project would require City approval of the same General Plan Amendment and Amendment Application
<br />(zoning amendment) that are required by the Original Project. These amendments would change the land use
<br />designation of the site from Professional & Administration Office (PAO) to District Center (DC) and an Amendment
<br />Application (zone change) from Professional (P) to Specific Development (SD) to provide site specific development
<br />standards. The SD would specify the allowable number of units permitted pursuant to the City Council approval. In
<br />addition, the project entitlements include a Development Agreement, which specifies the project details, including:
<br />number of dwelling units, open space area, parking, and other requirements of the project. Therefore, based on the
<br />proposed SD regulations and Development Agreement requirements, the project would be limited to a maximum of
<br />256 units (58 dwelling units per acre), pursuant to the City Council's approval.
<br />Comment 4: The comment summarizes the law on baseline in an EIR and explains that the baseline is a
<br />fundamental component as it provides a starting point from which all future comparisons are made. The comment
<br />states that the baseline must reflect the existing condition, applicable plan designations, and zoning for the site. The
<br />comment asserts that the FEIR's impact analysis and conclusions are based on the approval of the proposed
<br />entitlements.
<br />Response 4: The EIR provides a complete description of the existing environmental setting, including the existing
<br />general plan and zoning designations. Draft EIR Sections 3.1 through 3.4 provide descriptions of the regional setting,
<br />project location, project site, and adjacent areas. In addition, each environmental topic area includes a specific
<br />discussion of the environmental setting. For example, the noise analysis provides noise measurements of existing
<br />ambient noise, the traffic analysis provides existing traffic on roadways and at intersections in the study area, the
<br />aesthetics section provides text descriptions and pictures of the existing setting. Such detail is provided within each
<br />topic of the EIR. The analysis of each section evaluates the potential impacts of the proposed project on the existing
<br />environment, pursuant to the direction and thresholds of CEQA. This includes comparison of the existing noise,
<br />traffic, aesthetic and other environments to those that would exist with construction and operation of the project.
<br />Similarly, the EIR provides a description of the existing land use and zoning designations and the potential impacts to
<br />land use and planning that would occur with implementation of the proposed project. Pursuant to CEQA it is
<br />appropriate to assume the approval of the project, including entitlements, to identify the potential impacts that would
<br />occur with project implementation.
<br />Comment 5: The comment states that the project fails to consider its impacts relative to the applicable general,
<br />regional, and specific plans. The comment states that the EIR must discuss and evaluate inconsistencies with the
<br />project and the applicable plans. The comment also states that the existing land use designations allow for a much
<br />lower maximum density for the project site that is consistent with the general and regional plans, but inconsistent with
<br />the high -density development proposed by the project. The comment asserts that the FOR evaluates the project
<br />against a false or shifting baseline that is inconsistent with existing baseline conditions, and thus, the FOR is likely
<br />legally insufficient.
<br />Response 5: As described in Section 4.0, Environmental Setting and Impact Analysis, the baseline used in the Draft
<br />EIR was the existing conditions at the time that the Notice of Preparation was released. Section 4.7, Land Use and
<br />Planning, of the Draft EIR provides a complete description of the existing land use and planning conditions, graphics
<br />that show the existing land use and zoning of the project site and surrounding areas, and a discussion of the
<br />applicable regional and local land use plans. The EIR includes a detailed consistency analysis with the project
<br />relevant policies of the Southem California Associations of Governments (SCAG) Regional Transportation Plan and
<br />Sustainable Communities Strategy, and the City of Santa Ana General Plan goals, policies, and objectives. As
<br />described in Response 1, the EIR includes an assessment of the project's compliance with the General Plan policies
<br />that are relevant to the proposed project and, pursuant to CEQA thresholds, determined that the project would not
<br />conflict with any policies that were adopted for the purpose of avoiding or mitigating an environmental effect.
<br />11A-111
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