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Honorable Members of the Santa Ana City Council The Bowery Project FEIR August 18, 2020 Page 3 minute walking distance), it is likely to be impacted by the proposed project. The FEIR, however, does not evaluate the project's potential impacts to this park. 5. The project's potential traffic impacts have been grossly understated. First, the Santa Ana and City of Tustin level of service (LOS) Guidelines require a Clearance Interval or "Lost Time" input of 5 seconds (or .05). (Santa Ana Guidelines Excerpt, Attachment E.) This input has been erroneously left out of the project's Intersection Capacity Utilization (ICU) calculation. When corrected with the lost time reflected in the ICU calculation, the project would adversely impact the intersection of Red Hill Avenue/Warner, a major intersection adjacent to the project, resulting in an unacceptable level of service/significant impact during the PM peak hour (i.e., no -project and with -project PM ICU=0.794/LOS "D" and ICU=0.899/ LOS "D," respectively, would be 0.844/LOS "D" and 0.949/LOS "E", respectively). This was not disclosed in the EIR, nor was any correction / mitigation identified to address this unacceptable level of service / significant impact. Even if Santa Ana takes the position that LOS is not a relevant CEQA consideration, this error undermines Santa Ana's conclusion that the proposed project is consistent with its General Plan. (Santa Ana Municipal Code § 27-21; General Plan Policies 1.4, 1.6, 4.3.) This EIR should not be certified, and this project should not be approved, until these fatal flaws are corrected. 6. Further, in reviewing the project trip generation (the project land uses from January 2020), the pass -by and internal trip discounts show a peak hour reduction ranging between 28% and 48%. The highest reduction applies to the PM peak outbound project traffic. Using such percentages is not a conservative approach, and appears to minimize the need for project mitigation. The high PM peak outbound traffic percentage discount is particularly problematic because the Red Hill Avenue/Warner Avenue intersection is nearing an unacceptable operating capacity (i.e., ICU > 0.90 or above) in the PM peak hour with the project. Any reduction in the PM peak hour discounts would show an adverse impact to the intersection by the project. This approach masks the true nature and scope of the project's impacts. When the current industrial land use trips are subtracted, the results show even greater trip discount percentages. (Attachment D.) To analyze off -site traffic impacts for a project as intense as the Bowery (a daily trip generation of 15,303, and AM and PM peak hour trips of 1,012 and 1,315) that replaces non-residential with residential/mixed-use, a traffic model such as the Irvine Transportation Analysis Model (ITAM) should have been used with proposed project land uses input into the "model run." Trip discounts are reflected in forecasts and are derived in the traffic modeling process. Traffic models take into account trips from all land uses and their relationship to each other (i.e., employment to home) and not just for a single project. The ITE Trip Generation Handbook, utilized in the Bowery traffic study, lacks the interaction with local and regional traffic such as presented in a traffic model and should only be used when a model is not available. As also mentioned in the City of Tustin's previous comments, the nearby Heritage Mixed -Use Project used a more conservative approach. Specifically, it used a 5% internal discount and did not consider pass -by trips. Notably, the Heritage Project identified an impact to the Red Hill Avenue/Warner Avenue intersection. It is curious at best that the project does not have any impact at this intersection, especially when the Heritage project is further from the intersection, with less development intensity and trip generation. Without the use of the traffic model such as 1514217.1