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Planning staff will require a comprehensive staff level review, re -write and re -circulation of the draft EIR. A. Missing Objectives. As a threshold matter, the California Environmental Quality Act requires the City to commission a disinterested report that carefully evaluates the environmental impacts of a project. A cornerstone of this evaluation is a clear articulation of both the Applicant and City's collective objectives. See CEQA Guidelines, Section 15124(b). The project is therefore reviewed to determine the degree to which the project and/or alternatives meet these objectives. The applicant's objectives are of course obvious: the development of its proposed residential product. By contrast, the City's objectives are to be gleaned from, among other sources —the General Plan. Unfortunately, the Draft EIR cherry picks objectives that drive the analysis to policies encouraging the development of housing but give passing lip service to elements of the General Plan requiring due consideration of economic preservation and development. The EIR adopts the following objectives: • Redevelop existing underutilized parcels to implement development of new high - quality housing. • Increase hie -quality housing near existing employment centers. • Promote an improved jobs/housing balance by locating attractive new housing in proximity to employment centers. • Provide housing in close proximity to commercial areas, freeway, and transit. • Redevelop existing land uses that would utilize existing infrastructure, including: water, sewer, arterial roadways, transit, and freeways. • Implement capital investment to enhance the City's economic and fiscal viability pursuant to the City of Santa Ana Strategic Plan. • Provide a safe, high -quality, modem residential community with open space and various recreation amenities. (Emphasis added). The EIR should include objectives designed to review the project against the economic impact associated with a loss of office or other valuable commercial space. Support for such an objective can be found in the Economic Element of the General Plan and the Economic Development provisions of the Strategic Plan. The Element establishes that the City is uniquely situated to compete for a diverse range of businesses due to its location and proximity to John Wayne Airport. The Economic Element (which is as relevant today as when it was adopted) requires the City evaluate projects to determine whether (among other things) they: Increase employment opportunities for local residents. Maintain and enhance the diversity of the City's economic base. Increase Santa Ana's share of the regional economy.