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<br /> <br /> <br /> <br /> <br /> <br />May 5, 2020 <br /> <br /> <br /> <br /> <br />Ms. Rebecca Davis <br />Lozeau Drury <br />1939 Harrison Street, Suite 150 <br />Oakland, CA 94612 <br /> <br /> <br />Subject: The Bowery Project, Santa Ana (SCH # 2019080011) <br /> P20008 <br /> <br />Dear Ms. Davis: <br /> <br />At your request, I have reviewed the Final Environmental Impact Report (the <br />“FEIR” for The Bowery Mixed Use Project (the “Project “) in the City of Santa Ana <br />(the “City”). I have also reviewed the Draft Environmental Impact Report (the <br />“DEIR”) for the Project and the Appendices supporting both documents. My <br />review is specific to Traffic and Circulation. <br /> <br />My qualifications to perform this review include registration as a Civil and Traffic <br />Engineer in California and over 50 years professional consulting engineering <br />practice in the traffic and transportation industry. I have both prepared and <br />performed adequacy reviews of numerous transportation and circulation sections <br />of environmental impact reports prepared under the California Environmental <br />Quality Act. My professional resume is attached. Findings of my review are <br />summarized below. <br /> <br />Excessive Deduction Of Traffic Credit For Prior Use of Project Site <br /> <br />Trip credits taken for prior use of the site are excessive from several <br />perspectives. First, the traffic analysis takes trip credit for the entire 212,121 <br />square feet of building area at full occupancy in an industrial park use. However, <br />by 2017, well before the time of circulation of the Notice of Preparation (NOP) <br />and the time the existing condition traffic counts were taken, the industrial park