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City of Santa Ana — Cabrillo Town Center Project Appeal <br />October 3, 2023 <br />Page 5of5 <br />would not increase ambient noise levels". (Staff Report, Exh. 10 at p. 21.) However, <br />the City's assertion is contrary to CEQA since the very existence of potential outdoor <br />impacts and mitigation measures, which the Metro EIR failed to analyze, constitutes <br />new information of substantial importance. <br />iv. Land Use Impacts <br />Finally, a subsequent EIR is necessary because there is a colorful argument that the <br />Project is contrary to the General Plan since, as the City admits, the Project would be <br />solely "a market -rate residential development with no units dedicated to affordable <br />housing for lower -income residents." (Staff Report, Exh. 10 at p. 12.) <br />Although the City contends that the Project, and its lack of any affordable housing <br />units, is still consistent with the General Plan because "it would increase the housing <br />stock of market -rate and affordable housing units through payment of an in -lieu fee" <br />(id.), such assertion should be studied and quantified in an EIR rather than just <br />accepted as true given California's ongoing homeless problem and housing crisis. <br />In sum, SMSWRCC respectfully requests that the City uphold its appeal and require a <br />subsequent EIR for the Project in order for the Project to be CEQA compliant and to <br />provide both the City and the public with a meaningful understanding of the Project's <br />environmental impacts. If the City has any questions, feel free to contact my office. <br />Sincerely, <br />110 <br />Talia Nimmer <br />Attorneys for Southwest Mountain <br />States Regional Council of Carpenters <br />