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City of Santa Ana– First American Mixed-Use Project [114 and 117 East Fifth Street] – Comments to City Council November 18, 2019 Page 10 of 13 (3) The 2017 CARB Scoping Plan cannot be relied upon to determine Project significance; (4) Incorrect and unsubstantiated analysis in the Addendum demonstrates significant GHG impact since the Project would result in a net increase of 2,231 metric tons of CO2 equivalents per year; and (5) Updated CalEEMod analysis indicates significant impact by exceeding the threshold of 3.9 MT CO2e/year As a result, the City must prepare an EIR which analyzes all of the deficiencies and issues raised by Mr. Hagemann and Mr. Rosenfeld hereinabove. III. THE PROJECT IS INCONSISTENT WITH THE GENERAL PLAN AND THE TRANSIT ZONING CODE State planning and zoning laws require charter cities like the City of Santa Ana to adopt a general plan containing all the mandatory elements set forth in Government Code section 65302. Gov’t Code §§ 65700(a), 65300. Charter cities own ordinances can require zoning ordinances and development projects’ consistencies with the applicable general plan. Id. §§ 65803, 65860(d). City of Santa Ana’s own ordinances require that development projects, including those requiring discretionary approval, must be consistent with the general plan and any applicable specific plans. See Santa Ana Municipal Code sections 27-21, 41-668(a)(3), 41-670(1). As such, the Project must be consistent with the General Plan. A. The Addendum Fails to Analyze the Project’s Compliance with the Housing Element of the General Plan The Housing Element of the General Plan prioritizes and promotes the City to provide affordable housing to its low to moderate income residents and workforce and eminently stresses the importance of affordable housing in the following way: • The Housing Element acknowledges that the demographics of the City of Santa Ana is comprised of residents with moderate-paying occupations that average less than $53,000 annually. Housing Element, p. 12. • The Housing Element also provides that approximately 75% of Santa Ana households fall in the income categories of extremely low to moderate income. Housing Element, p. 14.