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Honorable Members of the Santa Ana City Council The Bowery Project FEIR August 18, 2020 Page 4 ITAM to run the project, a more conservative approach as used for the Heritage Mixed -Use Project would be a 5% internal discount and no accounting for or minimal pass -by trip reductions. It should be noted that in the January 2020 version of the traffic study, the Red Hill Avenue/Warner Avenue intersection was significantly impacted by the project. Changes to the land use breakdown were made to eliminate this significant project impact. The EIR used a manual assignment and additive approach to forecast project traffic. This methodology is flawed and unsupported for such an intense project as the Bowery - especially when a traffic model such as ITAM is available to test the project. The trip pattern changes to/from the project site affect local intersections as well as the region. A traffic model can capture the trip redistribution that inherently occurs when replacing non-residential uses with residential uses, especially with a mixed -use component. Since it does not appear a traffic model was used to analyze the proposed project, the impacts to intersections may well be different than those disclosed in the EIR. The use of a traffic model produces more logical and consistent results between no -project and with -project that potentially shows greater project impacts than presented in the report. No reasonable explanation is provided to support this approach, and it is not supported by substantial evidence. 8, The long-term bu]Idout traffic forecast volumes for the Red Hill Avenue/Warner Avenue intersection are inconsistent with the traffic forecast volumes at the same intersection in the following traffic studies: Tustin Legacy Specific Plan (2017), Stantec Heritage Mixed Use Project (2015), Linscott, Law & Greenspan Engineers Santa Ana General Plan Update (2020), IBI Group Bowery Mixed -Use Project (2020), Environment I Planning I Development Solutions For consistency, use of the ]TAM should be the basis for the traffic forecasts in the Tustin area. 9. The stacking analysis of the signalized project driveway on Warner Avenue should include all project trips not just net trips in which the previous industrial trips are removed. A stacking analysis will show if all project trips can be accommodated in the proposed left -turn pocket into the site or spill out into the number one lane which can impede through traffic on Warner Avenue. This could be a safety concern resulting in rear -end collisions when oncoming traffic, especially the northbound left -turns, are not aware of the back-up. 10. The traffic analysis is flawed because it does not use existing conditions as the baseline. The traffic analysis projects existing traffic impacts based on a trip generation model for industrial uses as if the site was being fully utilized, which has not been the case since at least 2017. That in turn inflates the appearance of existing traffic and makes the increase in traffic caused by the project appear smaller than it actually will be. The use of the incorrect baseline analysis affects VMT and LOS and air quality analyses, 11. The FEIR appears to ignore the fact that the project is a residential use proposed in the middle of an industrial and office/professional area. The FEIR concludes that the residents would have 1514217.1