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