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The Bowery Mixed -Use Project 2. Response to Comments Letter A8: City of Tustin Comment 1: This comment describes the proposed Project and states that the City is concerned with the significant changes in land uses (i.e., from commercial and industrial buildings to residential mixed use) along Red Hill Avenue, Warner Avenue, and Dyer Road that are proposed by the Project and have occurred recently with the approval and construction of The Heritage project at 2001 East Dyer Road. The comment also states that the City of Santa Ana has already demonstrated that land use intensifications will likely continue, as evidenced by proposed land use changes in the Santa Ana General Plan Update, and while individually each project may cause relatively modest changes in traffic patterns or imparts to parks, the cumulative impacts are likely to be substantial. Therefore, the comment states that there should be some overall projections of the anticipated changes in land uses, so the cumulative impacts related to traffic and parks and the associated mitigation can be documented. The comment also states that the Santa Ana General Plan Update or a focused General Plan Amendment for the Red Hill Avenue corridor should be completed before the proposed Project is considered so that cumulative impacts are properly analyzed and mitigated. Response 1: This comment provides concerns related to overall growth from land use intensifications and related cumulative impacts. Cumulative impacts are evaluated throughout Chapter 5 of the Draft EIR pursuant to the requirements of CEQA. The EIR is a "Project" EIR. As described in CEQA Guidelines Section 15161, a "Project" EIR should focus primarily on the changes in the environment that would result from the development project. A project EIR's evaluation of cumulative impacts may be based on a list of past, present, and probable future projects producing related impacts (CEQA Guidelines Section 15130(b)(1)(A)). "Probable future projects" include those for which an actual development application has been filed and for which actual environmental review is underway (San Franciscans for Reasonable Growth Y. City & County of San Francisco (1984) 151 Cal.App.3d 61, 74). The City of Santa Ana sets the date of the project's Notice of Preparation (NOP) as the reasonable cutoff date for determining what projects have environmental review underway and should be included in the cumulative impacts analysis (See Gray Y. County of Madera (2008) 167 Cal.App.4th 1099, 1128 [reasonable to set a project's application date as the cutoff]). Cumulative CEQA review for future projects that submitted applications after publication of the NOP for the proposed Project would include the proposed Project in their cumulative analyses, as appropriate. In addition, CEQA Guidelines Section 15130(b)(1) states that it is appropriate for cumulative analysis to utilize projections contained in an adopted local, regional or statewide plan, related planning document, or regionally accepted criteria thresholds; or a reasonable combination of the two. For example, pursuant to CEQA, the cumulative noise analyses in the Draft EIR is based on identification of the closest project on the list of known projects and whether if it within hearing distance of the project site; whereas the cumulative analyses of air quality emissions are based on emissions thresholds identified by the South Coast Air Quality Management District (SCAQMD). The cumulative population and household analyses, and related growth impacts (such as park and recreation) is based upon a combination of the Southern California of Governments (SCAG) growth projections and the list of known cumulative projects within the Santa Ana, Irvine, and Tustin, and Newport Beach area. Similarly, cumulative traffic analyses are based on the growth projections from the Orange County Transportation Analysis Model (OCTAM) and the number of vehicular trips from the list of cumulative projects within the traffic study area that is provided in the Draft EIR. Based on these growth projections, the Draft EIR includes mitigation measures to reduce cumulative impacts. The cumulative analyses differ with each environmental topic because the geographic scope and other parameters of each cumulative analysis discussion can vary, and mitigation Is incorporated as needed, as described for each environmental topical section in the Draft EIR. Thus, based on the CEQA requirements for a "project" EIR, the Draft EIR has properly analyzed and mitigated cumulative impacts. City of Santa Ana 2.55 Final EIR April 2020