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The Bowery Mixed -Use Project CEQA Comment May 11, 2020 Page 2 Traffic engineer Dan Smith also reviewed the EIR and provided expert comments detailing numerous deficiencies in the EIR's traffic impact analysis. In particular, the analysis violates CEQA because it relies on a hypothetical baseline, rather than actual conditions that existed at the time environmental analysis began. As a result, the baseline traffic level is significantly higher than it should be, which artificially reduced the traffic impacts created by the Project when compared to the baseline levels of traffic. Mr. Smith's expert comments and CV are attached hereto as Exhibit B. In addition, environmental consulting firm Soil/Water/Air Protection Enterprise ("SWAPE") has reviewed the Project, the DEIR, and the FEIR. SAFER concludes that the Project's analysis and mitigation of impacts related to hazardous materials are inadequate. SWAPE's expert comments, as well as the CVs of the SWAPE's consultants who prepared the comments are attached hereto as Exhibit C. A revised FIR should be prepared and recirculated prior to Project approval to analyze all impacts and require implementation of all feasible mitigation measures, as described more fully below. I. PROJECT DESCRIPTION The Project is a mixed -use development that includes up to 1,150 multi -family residential units and up to 80,000 square feet of commercial retail and restaurant space on a 14.58 acre site in Santa Ana, California. The Project includes demolition of three existing buildings and removal of all existing improvements, landscaping, and pavement. hi its place, the Project would develop three mixed -use buildings, each of which would be 6-stores, and one residential building that would be 5-stories in height. Each building would have an adjacent parking structure. Two parking structures would provide 7-levels of above -ground parking and two would provide 6 levels of above -ground parking. In addition, the Project would also develop two one-story retail/restaurant commercial buildings and a surface parking lot. The Project would provide a total of 174,555 square feet of exterior open space area, with each of the four residential buildings having a recreation space that includes a pool, spa/hot tub, outdoor kitchen, seating areas, fitness center, and club room. At full occupancy, the Project would house approximately 2,081 residents, and the commercial space would generate 320 employees. The Project site is designated as Professional and Administrative Office ("PAO") in the General Plan, and has a zoning designation of Light Industrial (M-1). The Project seeks to change the General Plan land use designation to District Center and to change the zone to Specific Development. The Project site is currently developed with three partially occupied industrial buildings, parking areas, and vehicle circulation drives. The buildings are currently used by various lessees, including 119,121 square feet that is used by warehousing and distribution operations, 5,000 square feet being used for research and development, and 30,000 square feet being used as