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The comment's assumption that the existing land use designation allows for lower density development on the
<br />project site is inaccurate. Draft EIR Section 6.0, Afternatives, describes build out of the site pursuant to the existing
<br />General Plan and zoning designations. As described, Build Out of the Existing Zoning Alternative, would result in
<br />building setbacks of 15-feet from the front and side property lines and 50-feet setback when the site backs to
<br />residential areas. The maximum office building structure that could be developed under the existing zoning code
<br />requirements would be 3-stories high and 387,465 square feet (floor area ratio of 1.5), which would require 1,161
<br />parking spaces.
<br />In comparison, the 256 residential units would be provided within approximately 277,281 square feet of residential
<br />structures, which is 110,184 square feet less of occupiable building space allowed under the existing zoning. These
<br />units would be setback a minimum of 90-feet from the eastern property line, which is 40 more feet of setback than
<br />under the existing zoning requirements.
<br />The Build Out Under the Existing Zoning Alternative would result in approximately 1,275 employees at full capacity
<br />(Draft EIR page 6-23), whereas, the 256 multi -family residential units would result in 502 residents at full occupancy,
<br />which is 773 fewer persons onsite. Also, development under the existing General Plan and zoning designations
<br />would result in 3,774 daily vehicular trips, 449 in the a.m. peak hour and 446 in the p.m. peak hour, as detailed in
<br />Table 6-3 of the Draft EIR. In comparison, the project's 256 multi -family residential units would generate 1,393 daily
<br />vehicular trips, 92 in the a.m. peak hour and 113 in the p.m. peak hour (based on the ITE trip generation rate).
<br />Hence, the project would result in 2,381 fewer daily vehicular trips, 357 fewer a.m. peak hour, and 333 fewer p.m.
<br />peak hour trips than build out of the project site under the existing General Plan and zoning. Therefore, the existing
<br />land use and zoning designations of the project site do not allow for lower density development, but a higher density
<br />development with more occupiable square footage, persons on site, and vehicular trips than the 256 multi -family unit
<br />project.
<br />Refer to Response 4 regarding the baseline conditions included in the EIR.
<br />Comment 6: The comment states that CEQA compliance must occur before the City approves a project. The
<br />comment also provides case law information regarding lead agency independent review requirements. The comment
<br />states that if an EIR bases its cumulative impact analysis on general plan projections it must explain why the
<br />projections are a realistic indicator of impacts, and that general plan projections are an inadequate basis for the
<br />cumulative impact analysis if the plan's projections exclude relevant data. The comment further states that this is
<br />particularly true in situations like the project, which was originally envisioned at higher density, the analyses that flow
<br />from the estimates may be flawed.
<br />Response 6: The Draft EIR and both Clarification documents were prepared by RE Consulting, under contract to the
<br />City. RE Consulting is the Citys consultant's, not the applicant's. By engaging RE Consulting to prepare the EIR, the
<br />City has exercised its independent judgment in preparation of the environmental analysis. CEQA allows a lead
<br />agency to hire experts to help it prepare these technical documents. (Pub. Resources Code, section 21082.1.)
<br />The EIR does not base its cumulative impact analysis on general plan data or projections. The City of Santa Ana's
<br />existing General Plan is dated and the City is in the process of preparing a comprehensive update to its General
<br />Plan. As detailed in Section 4.9, Population and Housing, demographic data is from the California Department of
<br />Finance, SCAG 2017 Local Profile for the City of Santa Ana, and U.S. Census data, and projections are from the
<br />Southern California Association of Governments (SCAG). In addition to this demographic data, the cumulative
<br />analysis was based on a list of past, present and probable future cumualtive projects for which applications were
<br />submitted to lead agencies prior to publishing of the Notice of Preparation, as detailed in Section 4.0, Environmental
<br />Setting and Impact Analysis, of the Draft EIR.
<br />11A-112
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