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Honorable Mayor Pulido Santa Ana City Council January 21, 2020 Page 4 environmental review unless meaningfully distinguished by the lead agency. (Guidelines, § 15125(a).) Here, the Project proposes a large-scale planned residential development that is inconsistent with the General Plan's policies and goals. (See Pet'n & Exs. A, B [public comments discussing General Plan inconsistencies and inadequacies in the FEIR in great detail].) Under the terms of the existing entitlements and Project description described in the FEIR, while public hearing was still open, the Project is capable of a much higher maximum density at full buildout and includes substantial, significant new mitigation measures not properly subject to meaningful public review. For example, the Project's description and baseline conditions do not sufficiently address or incorporate the following anticipated or reasonably foreseeable impacts, among others: 1. Impacts from the new offset intersection configurations and proposed curb cuts, which will add significant backup traffic to existing traffic and which may block existing intersections; 2. Impacts from the new shared parking agreement with the Discovery Science Center: and 3. Cumulative impacts from the simultaneous addition of 1,900 residential units, 400 hotel rooms, 1,400,000 square feet of commercial space, and up to 750,000 square feet of office space as part of the nearby MainPlace Mall Transformation Project,2 located at 2800 N. Main St., which is approximately .5 miles from the subject Project. Additionally, Councilmember Solorio proposed unclear substantive amendments referred to as a "mitigation measure' being added to the Development Agreement, DA- 2018-01, for the first time after Mayor Pulido had already closed the public hearing on the proposed entitlements. (City Council Meeting Video, Nov. 19, 2019, Hon. Mayor Pulido, at 5:03:25-5:03:30 ["close the public hearing and bring it to Council for consideration"]; with City Council Meeting Video, Nov. 19, 2019, Councilmember Solorio, at 5:46:42 ["Finally, I do have something that I would like my colleagues to consider to add into the development agreement [.... ]'; id., Councilmember Solorio, at 5:48:20 ["City Attorney what might we need to do to add that in to the development agreement just as part of the motion uh spell that out..."]; Councilmember Iglesias, also proposed terrace revisions that were withdrawn.) As such, the Project description and baseline remain inaccurate and inconsistent —a problem that permeates every aspect of this stale FEIR's underlying environmental review. The addition of significant new mitigation measures further compounds this 2 Information regarding the MainPlace Mall Transformation Project is available at https://www.santa- ana org/ob/planning-division/maior-planning-proiects-and-documents/mainplace-mall-transformation- rp oiect (last accessed Jan. 21, 2020, at 2:06 p.m. PST). 4516.101 / 8600269.1