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794 Sawnee Bean Road <br />Thetford Center VT 05075 <br />Norman Marshall, President <br />(802)356-2969 <br />nmarshall@smartmobility.com <br />August 3, 2023 <br />Talia Nimmer <br />Mitchell M. Tsai, Attorney At Law <br />139 South Hudson Avenue Suite 200 <br />Pasadena, CA 91101 <br />Subject: Comments on the Cabrillo Town Center Project <br />Dear Ms. Nimmer, <br />I have reviewed vehicle miles traveled ("VMT") impacts of the proposed 20 Civic Center Plaza project in <br />Santa Ana as described in the Planning Commission Staff Report, dated April 24, 2023, and the attached <br />Revised Traffic Circulation Analysis, dated November 18, 2022. 1 make the following findings: <br />1) SB 743 requires that vehicle miles traveled ("VMT") impacts be analyzed under CEQA. These <br />impacts have not been analyzed for the proposed project. <br />2) The City of Santa Ana has adopted a Resolution and Guidelines for evaluating project VMT <br />impacts that include three categories of projects that are screened from complete analysis. The <br />proposed project does not satisfy any of these screens. As the project fails to satisfy any of the <br />City's three VMT screens, the City's Resolution requires a VMT analysis with the Orange County <br />Transportation Analysis Model ("OCTAM"). This OCTAM analysis is required for this project and <br />has not been done. <br />3) If the OCTAM analysis results in a significant VMT impact, the Guidelines require mitigation to <br />"15% below the existing Countywide VMT/SP" [Service Population]. <br />4) The proposed project is in an auto -oriented, VMT-inefficient part of the City of Santa Ana, and <br />the project's location also will largely preclude significant mitigation of its VMT impacts. One of <br />the VMT-reduction measures recommended by the California Air Pollution Control Officers <br />Association (CAPCOA), unbundling residential parking costs and rents, is prohibited by the City <br />of Santa Ana. <br />