Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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Nevertheless, a VMT Screening Assessment Memorandum ("Memo") has been produced for the Project for informational purposes only, in response to this comment. The Memo presents the VMT screening criteria, analysis methodology and the conclusion. The approach and methodology outlined in this Memo was consistent with the City of Santa Ana Traffic Impact Study Guidelines (dated September 20199, which states that several types of projects can be screened out from a VMT assessment using identified criteria, indicating that these projects have the potential to reduce VMT per service population and result in a less -than - significant transportation impacts. Moreover, this Memo was thoroughly peer reviewed by the City's Traffic Engineer, who concluded that the VMT memo prepared for the Project shows the project is screened out from any full VMT analysis. Further, the Traffic Engineer confirmed that the Memo shows that the project is within a HQTA, and it is consistent with the SCAG RTP/SCS. Specifically, the Memo determines that the Project would not result in VMT impacts because it is located within a HQTA, where existing transit service provided by OCTA provides service intervals no longer than 15 minutes during the peak commute hours, and because the proposed land use was consistent with the RTP/SCS as contained in SCAG's adopted Connect SoCal (2020-2045 RTP/SCS). Therefore, in accordance with the City of Santa Ana's guidelines, the proposed Project was deemed to be exempt from the preparation of any further VMT analysis and may be presumed to have a less than significant CEQA-related transportation impact. c. The appellant contends that the Project requires new feasible mitigation measures to mitigate greenhouse gas impacts. The topic of GHG emissions impacts was not included in the CEQA Guidelines in place at the time the 2006 EIR was certified, and as such, was not included in the Certified EIR's analysis of the MEMU's potential impacts. However, both the existence of carbon dioxide and other greenhouse gases from fossil fuel combustion and other activities were known at the time the Certified EIR was approved. Since the approval of the Certified EIR, federal and state laws and regulations have been adopted to reduce GHG emissions, and the topic of GHG is included in the current version of the CEQA Guidelines. A detailed analysis of the Project's GHG Resolution No. 2023-xx City Council 18 — 327 10/ 3 f 24