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Daily <br />Description 2-Way <br />/BI Proposed Project <br />221: Residential (169 Dil) <br />919 <br />Internal Captu e7 <br />-120 <br />Residential Subtotal <br />799 <br />O 820: Retail Shops (7.514 SF) <br />284 <br />Internal Capture7 <br />-163 <br />Retail Subtotal <br />121 <br />O 932: High -Turnover Restaurant (3.847 SF) <br />432 <br />Internal Caphlre7 <br />-181 <br />Retail Subtotal <br />251 <br />Total Project Trip Generation <br />1,171 <br />%on -Auto Trip Adjustment (50/6) <br />-59 <br />(Bj 'Net Project Trip Generation <br />1,112 <br />As the above excerpt demonstrates, the TIA includes a 5% reduction to the trip generation calculations <br />to account for non -vehicle transport. Regarding the 5% non -auto trip reduction, the TIA states: <br />"Please note that a 5% non -auto trip reduction was applied to the trip generation to account for <br />other modes of transportation within a downtown area (i.e. public transit, walking, biking, etc.). <br />It is our understanding that the City of Santa Ana and Garden Grove have partnered with OCTA <br />to develop the "CC Streetcar" which will further enhance mobility throughout Downtown Santa <br />Ana, beyond the current transit opportunities that are now availability. In addition, the Santa <br />Ana Renaissance Specific Plon Traffic Study prepared by KOA dated January 2010 utilized a <br />similar 5% mode adjust" (Appendix K, pp. 312-313). <br />However, this justification is insufficient for three (3) reasons. First, while the TIA cites to the Santa Ana <br />Renaissance Specific Plon Traffic Study, which supposedly includes a similar adjustment, the TIA fails to <br />provide a source for the 5% non -auto trip reduction applied to the proposed Project. Second, simply <br />because a Traffic Study in 2010 includes a similar 5% mode adjustment does not substantiate the <br />inclusion of the reduction for the current Project. Third, the TIA fails to provide sufficient evidence that <br />the development of the "CC Streetcar" would specifically result in a 5% reduction in vehicle trips for the <br />proposed Project. As such, we cannot verify the 5% non -auto trip reduction, and the Addendum's <br />CaIEEMod model should have included 1,171 daily trips instead of 1,112 trips. By including an <br />unsubstantiated reduction to the Project's daily operational vehicle trips, the model underestimates the <br />Project's mobile -source operational emissions and should not be relied upon to determine Project <br />significance. <br />75C-82 <br />