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Santa Ana General Plan Update <br />CEQA Findings of Fact and Statement <br />Of Overriding Considerations -55- October 2021 <br />VI. FINDINGS REGARDING ALTERNATIVES <br />CEQA requires that an EIR include a discussion of reasonable project alternatives that would <br />“feasibly attain most of the basic objectives of the project but would avoid or substantially lessen <br />any significant effects of the project, and evaluate the comparative merits of the alternatives” <br />(CEQA Guidelines § 15126.6[a]). <br />As discussed above, the PEIR identified significant impacts in a number of categories. The <br />following impacts could be mitigated below a level of significance: air quality, biological resources, <br />cultural resources, geology and soils, noise, tribal cultural resources impacts. The following <br />impacts cannot be mitigated below a level of significance: certain air quality, cultural resources, <br />greenhouse gas (GHG) emissions, noise, population and housing, and recreation impacts. <br />The PEIR analyzed four alternatives to the proposed project that could reduce some, if not all, of <br />the impacts. <br />A. ALTERNATIVES CONSIDERED AND REJECTED DURING THE SCOPING/PROJECT <br />PLANNING <br />“Among the factors that may be used to eliminate alternatives from detailed consideration in an <br />EIR are: (i) failure to meet most of the basic project objectives, (ii) infeasibility, or (iii) inability to <br />avoid significant environmental impacts” (CEQA Guidelines § 15126.6[c]). <br />Alternative Circulation Element – Roadway Classifications. The proposed circulation element <br />in the GPU evolved over a long process and coordination with the Orange County Transportation <br />Authority (OCTA). During this process, alternative packages of arterial roadway classifications <br />were considered that involved roadways in OCTA’s Master Plan of Arterial Highways (MPAH). <br />The majority of reclassifications proposed were identified for bicycle facility safety improvements <br />in the City’s Safe Mobility Santa Ana (SMSA) Plan, prepared in 2016. Most of the reclassifications <br />identified were for roadways where bicycle and pedestrian safety improvements would require <br />roadway reconfiguration and a reduction in the number of existing or planned travel lanes. Many <br />of the SMSA recommendations across the city have already been, or are in the process of being, <br />implemented along arterial roadways without reducing the number of lanes. <br />A cursory review of two optional roadway reclassification packages was conducted to determine <br />whether these optional plans would have the potential to eliminate significant impacts of the <br />proposed GPU and meet most the project objectives. It was determined that a detailed evaluation <br />of this alternative was not needed to provide a reasonable range of EIR project alternatives. <br />Transportation/traffic impacts of the proposed project were determined to be less than significant <br />(VMT/SP falls below the significance threshold for the GPU without mitigation). Although these <br />alternatives may have some potential to reduce VMT (by reducing the number of travel lanes for <br />some roadways) and thereby also potentially reduce air quality, greenhouse gas, and traffic noise <br />impacts, these alternatives would also result in more inconsistencies with the MPAH and result in <br />more traffic congestion. Although traffic congestion is no longer a CEQA consideration, the GPU <br />sets forth standards for level of service that will be considered by decision-makers. Moreover, the