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South has been (on average) 30 minutes and commute times have been increasing. As set forth above, staff should require a comprehensive assessment of various alternatives assuming either the existing zoning or an overlay accommodating either mixed use (with a significant density reduction) or other commercial zoning districts. The analysis should provide a comparative assessment both in terms of AM/PM peak hour trips and vehicular traffic in the evenings and on weekends. Put simply, while an office may have a higher AM/PM peak, offices generate virtually no traffic beyond 6PM and on weekends/holidays. By contrast, a residential project generates trips 24/7/365. It is also unrealistic to assume that residents will commute via mass transit. Again, these assumptions appear to be premised on the installation of a monorail which had been promised as part of the Main Street Concourse plan. No such system was built. In my experience, although a small fraction of residents may rely on busses, the bulk of residents will utilize cars. This is precisely why an office should be developed because it promotes existing residents to work in the community within which they already reside. V. Conclusion. The area immediately adjacent to the project site is comprised of one of the hidden gems of Santa Ana —the Park Santiago neighborhood. As a land use professional, I was stunned at the intensity of use proposed for the subject property given the nature of the City's zoning and land use scheme. It is evident that the proponent believes the City is desperate for revenue and has advanced a series of financial projections that are either unrealistic or do not take into account the long-term damage of depriving the City of a viable business hub. The subject project may be appropriate in the City's downtown core. However, the subject site was clearly contemplated to serve as a transition/buffer between the Park Santiago neighborhood and Main Street corridor. In my personal opinion, the project is poorly planned and poorly conceived. I respectfully request the Planning Commission and City Council deny the application outright. At a minimum, the EIR should be dramatically revised and re -circulated as a draft for Planning Commission review. Given the timing for the EIR's circulation, I must respectfully reserve the right to supplement these comments. Sincerely, // Mark A. Rothenberg