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DocuSign Envelope ID: EF4B7707.6A52-4917-BE8B-C9000EAD9571 Bowery Mixed -Use Project May 21, 2020 Page 2 The City of Tustin has the following ongoing concerns which were not adequately addressed in the DEIR or the FOR. 1. The City of Santa Ana is continuing to take a noncom prehensive approach with new development proposed along the Red Hill Avenue corridor. The Bowery is the second significant mixed -use project to be considered recently in the area and prior to the completion of the Santa Ana General Plan Update, which is currently underway and contemplates land use intensifications in several areas of Santa Ana. This project sits squarely within one of the focus areas for the City's General Plan Update, an update that is already in the planning stages and thus, should be analyzed in the cumulative impacts analysis. The cumulative impacts of these large-scale projects need to be addressed comprehensively so that they can be properly identified and mitigated or avoided. Instead, the FEIR improperly defers the cumulative impacts analysis to some time after this project is considered for approval. Further, the consideration and adoption of multiple project - specific General Plan Amendments on a frequent basis is discouraged by State law and prohibited more than four (4) times per year for general law cities (such as the City of Tustin.) The City of Santa Ana has routinely adopted site -specific General Plan Amendments to accommodate higher density development in recent years throughout the City, prior to completing its comprehensive General Plan Update, and this is contrary to sound planning principles. 2. Walkways and paseos, unusable perimeter landscape areas, private open space such as balconies, and other passive open space areas are being credited toward The Bowery project's minimum park land requirement. These areas are not equivalent to usable park land that usually accommodates sports fields and larger recreational spaces that are in high use and demand throughout Orange County. It is interesting to note that at least one (1) of the Santa Ana Planning Commissioners also expressed a concern at the May 11, 2020 public hearing regarding walkways being counted as park space or open space. 3. The FEIR does not include mitigation measures to address the impacts to parks in Tustin. Instead, the FOR claims that impacts are not significant and that sports league park usage fees fund maintenance and improvements. Mitigation to fund park maintenance and improvements in Tustin should be required of The Bowery project due to its proximity to Tustin parks. Alternatively, a park should be included on or near The Bowery site, and/or the project density should be reduced. The Final EIR acknowledges that parks in Santa Ana and Tustin would generally be accessed by vehicle and that the parks are beyond a 12-minute walking distance. This acknowledgement supports the need to require a new park facility on, or adjacent to, The Bowery site. 4. The City of Tustin continues to be concerned about the use of discounts to reduce project trip generation and is reviewing the Final Traffic Impact Analysis traffic dated April 14, 2020 that was included in the Final EIR to determine other specific outstanding concerns and potential impacts to Tustin. Potential traffic Impacts have been grossly underestimated. 5. 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 both VMT and LOS analyses.