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Also, the project is within the land use build out assumptions of the General Plan. As described in Response 5, development of the project site pursuant to the existing General Plan land use and zoning designations would result in greater square footage, persons onsite, and vehicular trips than the 256 multi -family unit project. Thus, the project is within (and would not exceed) the General Plan Land Use Element build out conditions. Comment 7: The comment states that the FOR may fail to identify, discuss or mitigate potential impacts related to transportation. The comment asserts that southbound traffic on N. Main Street between Edgewood Road and Walkie Way have the potential to increase and block intersections because the project would reduce the distance between the intersections, while adding traffic. The comment states that the traffic technical study calculated the back up, but it was not evaluated or mitigated. Response 7: Page 4.11-10 of the Draft EIR describes that the City's thresholds of significance are based on the Level of Service (LOS) at intersections and roadway segments. There are no thresholds for queuing impacts under CEQA per the City's General Plan, traffic analysis guidelines, or the Orange County CMP. As detailed in the October Clarification to the FEIR, all of the Main Street intersections and roadway segments are forecast to operate at satisfactory levels of service with project traffic. Specifically, Tables T-2 and T-3 show that the intersection and roadway LOS would not change with implementation of the project and that impacts would be less than significant pursuant to the City's thresholds of significance. Additionally, all of the Main Street intersections near the project site are signalized or right-in/right-out. The traffic signal metering will prevent blocking of intersections. It should be noted that queue spillovers occur on most congested intersections, and traffic signals are timed to minimize queue spillovers. Furthermore, the project will extend the southbound left turn pocket to Edgewood Road, which will allow for left turning traffic to enter the left turn lane instead of waiting in the southbound through lane, which would result in lessening the through queues on Main Street at Edgewood Road. Comment 8: The comment states that once the FOR is revised to include an accurate project description, the additional substantive issues may be raised and addressed. The comment further states that supplemental information and evidence may be submitted up to the final public hearing. Response 8: As described in Response 3, the October Clarification to the FEIR provides a detailed description of the 256 multi -family unit project and does not need revision. The City of Santa Ana provided many opportunities for public comment on the project and EIR throughout the development approval process. Comment 9: The comment describes the requirements for recirculation of an EIR and explains that new information in an EIR is significant if it involves a substantial adverse effect. The comment also states that the FOR incorporates substantial and significant new information because it includes an Arborist Report with measures to mitigate potential impacts to trees. The comment states that the Arborist Report identifies eight unhealthy trees that are recommended for removal and asserts that the removal requires review of the City's Environmental and Transportation Advisory Committee. The comment also asserts that the western mastiff bat is a special status species and could be affected by the tree removal, and that this is not adequately addressed in the EIR. The comment asserts that the Arborist Report is a new mitigation measure, and thus the EIR may fail to inform decision makers about impacts. The comment further asserts that this involves changes to significant and unavoidable impacts resulting in the inability of agencies and the public to comment, and that the EIR should be recirculated. Response 9: The Arborist Report to which this comment refers was not significant new information. The Arborist Report was included as Appendix B of the Draft EIR and was circulated for public review and comment as part of the EIR. As included on page 3-18 of the Draft EIR, Project Description Feature (PDF)-1 is to incorporate the existing mature trees along the eastern and southern project site boundaries, as identified by the Arborist Report. Page 3-8 of the Draft EIR also describes that PDFs will be included in the Mitigation Monitoring and Reporting Program and would be monitored to ensure completion in the same manner as mitigation measures. Hence, the measures 11A-113