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SMITH L-NGINFERING L- MANAGLMLNT <br />99 <br />May 5, 2020 <br />Ms. Rebecca Davis <br />Lozeau Drury <br />1939 Harrison Street, Suite 150 <br />Oakland, CA 94612 <br />Subject: The Bowery Project, Santa Ana (SCH # 2019080011) <br />P20008 <br />Dear Ms. Davis: <br />At your request, I have reviewed the Final Environmental Impact Report (the <br />"FEIR" for The Bowery Mixed Use Project (the "Project ") in the City of Santa Ana <br />(the "City"). I have also reviewed the Draft Environmental Impact Report (the <br />"DEIR") for the Project and the Appendices supporting both documents. My <br />review is specific to Traffic and Circulation. <br />My qualifications to perform this review include registration as a Civil and Traffic <br />Engineer in California and over 50 years professional consulting engineering <br />practice in the traffic and transportation industry. I have both prepared and <br />performed adequacy reviews of numerous transportation and circulation sections <br />of environmental impact reports prepared under the California Environmental <br />Quality Act. My professional resume is attached. Findings of my review are <br />summarized below. <br />Excessive Deduction Of Traffic Credit For Prior Use of Project Site <br />Trip credits taken for prior use of the site are excessive from several <br />perspectives. First, the traffic analysis takes trip credit for the entire 212,121 <br />square feet of building area at full occupancy in an industrial park use. However, <br />by 2017, well before the time of circulation of the Notice of Preparation (NOP) <br />and the time the existing condition traffic counts were taken, the industrial park <br />I R A I I [( • „i :%ASPSIR I A 110A, • .%,AN,AQIS"I N I. <br />5.) I <,ww R,md, Union Cite, C--A 91587 teI: 510.459.9477 Ins: SIC).481), �),175 <br />