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The Applicant Fails to Quantify the Project's VIVIT Impacts As Required <br />SB 743 requires that vehicle miles traveled ("VMT") impacts be analyzed under CEQA. These impacts <br />have not been analyzed for the proposed project. <br />The City of Santa Ana has adopted Resolution No. 2019-049 entitled A Resolution of the City Council of <br />the City of Santa Ana Adopting "Vehicle Miles Traveled" Thresholds of Significance for purposes of <br />Analyzing Transportation Impacts Under the California Environmental Quality Act. The City of Santa Ana <br />Traffic Impact Study Guidelines attached to the Resolution states: <br />The City of Santa Ana has identified Vehicle Miles Traveled (VMT) as the metric for <br />transportation impact analysis in all traffic studies in accordance with California <br />Environmental Quality Act (CEQA) and California Senate Bill 743 (SB 743). The City of <br />Santa Ana has prepared these Traffic Impact Study (TIS) Guidelines for assessing <br />potential transportation impacts of proposed development projects, General Plan <br />Amendments, and changes to the zoning in the City. <br />For land use projects (including this proposed project), the Resolution identifies three categories where <br />projects can be screened from more complete VMT analysis: <br />• Transit Priority Area (TPA), <br />• Low VMT area, <br />• Project type. <br />Figure 1 reproduces the vicinity map from the Revised Traffic Circulation Analysis. <br />Figure 1: Vicinity Map <br />01 <br />'i% <br />rip I <br />�Ixr <br />III FDG' RE 1- 1 <br />2 <br />