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Comment 24: The comment asserts that the Draft EIR fails to adopt feasible mitigation measures related to greenhouse gas emissions and provides a list of measures to alleviate the significant impact of the Project. Response 24: As described in Section 5.6, Greenhouse Gas Emissions, of the Draft EIR the Project incorporates various sustainable design features that would reduce GHG emissions and would be developed pursuant to the 2019 Title 24/CalGreen standards. However, there are no feasible Project measures that would reduce vehicular emissions, and approximately 60 percent of the GHG emissions would be generated by Project mobile sources (vehicle trips) (Draft EIR page 5.6-14). Thus, neither the Project Applicant nor the City of Santa Ana can substantively or materially affect reductions in Project mobile -source emissions. The commenter has not demonstrated how additional mitigation, would quantifiably reduce mobile source missions or how a local shuttle program would be feasible for this type of Project. Therefore, even with the implementation of all reasonable measures, the GHG emissions still exceed thresholds and the impact is considered significant and unavoidable. Comment 25: The comment provides a summary of CEQA requirements related to General Plan and zoning consistency through references to case law and asserts that the proposed DC land use designation is reserved for major activity areas in the City that serve as anchors to the City's commercial corridors and are developed with an urban character that includes a mixture of high rise office, commercial, and residential uses. The comment states that the proposed change is inconsistent with the General Plan's guidance on designation of DCs because the Project site area is designated for light industrial and commercial use and is not connected to any of the City's existing commercial corridors, and is not a major activity area in the City. In addition, the comment states that although the Project is adjacent to the City of Tustin's Legacy Specific Plan area, it is largely vacant and would not connect to any of the City's major activity centers. Response 25: The comment is inaccurate. The General Plan Land Use Element does not indicate that the DC land use designation is reserved for major activity areas in the City that serve as anchors connected to the City's commercial corridors. Page A-22 of the General Plan Land Use Element describes various existing District Centers in the City that are developed with a mix of housing and commercial uses. Specifically, the Land Use Element states that the Heritage District (designated DC and located 0.25 mile from the Project site on Red Hill Avenue), "allows for mixed -use development with higher density residential and supportive commercial and office uses within proximity to surrounding employment centers". Similarly, the proposed Project provides mixed -use development with higher density residential and supportive commercial retail uses within proximity to surrounding employment centers. The Land Use Element also states that District Centers are considered to be the City's "major development areas:' The most intense development in the City is targeted to these areas. As described in Section 5.9, Land Use and Planning, of the Draft EIR, the Project site is located within an urban area that is either fully developed, under development, or planned for urban development and is within a major activity center that includes employment, retail, commercial, hotel, and high density residential development (under construction at the Heritage Project in the City of Santa Ana (approximately 1,400 feet from the Project site) and other cumulative projects listed in Table 5-1 and shown in Figure 5-1 of the Draft EIR. Also, as described in the Draft EIR the Tustin Legacy Land Use Plan, which is across Red Hill Avenue from the Project site is being implemented to become a new mixed -use urban center providing: single-family residential, multi -family residential, mixed -use, commercial retail, office, schools, parks, and other public facilities. As the proposed Project under the DC designation would provide multi -family residential and commercial retail uses it would be consistent with the Tustin Legacy Land Use Plan, as further detailed in 75C-202