Item 18 - Appeal Application Nos. 2023-02 and 2023-03 for Cabrillo Town Center project

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City of Santa Ana — Cabrillo Town Center Project August 17, 2023 Page 3 of 4 VMT area; or (3) presumed to have less than a significant VMT impact because it is a local serving retail project of less than 50,000 sgft., is a neighborhood school, or will generate less than 110 daily trips. Id. at 2. Given that the Project is located outside of the Resolution's identified transit priority and low VMT areas; is predominantly a housing project, i.e., not local -serving retail or a school; and will generate approx. 2,751 daily trips, 875 more daily trips than the existing land use on the project site, the Project fails to satisfy any of the Resolution's three VMT screens. Thus, the City's Resolution requires a VMT analysis with the Orange County Transportation Analysis Model ("OCTAM"), which has not been done. Id. at 5. A subsequent EIR must be prepared which includes such analysis by the City's own requirements. B. The City's Transportation Mitigation Requirement is Infeasible for the Project In addition to failing to comply with the Resolution requirement to prepare a VMT analysis with OCTAM for the Project, the Project further likely runs afoul to the Resolution's mandate that "[o]nce a significant impact is identified, the project's VMT per capita should be mitigated to be at or less than 15% below the existing Countywide VMT [service population]." Exhibit A at 5. This is because, as noted by transportation expert Noman Marshall, should a significant VMT impact be determined after a VMT analysis with OCTAM is conducted for the Project "[a]chieving significant VMT mitigation at this Project site may be impossible". Id. Specifically, parking measures which encourage residents to shift trips from autos to walking, biking, and transit, such as limiting residential parking supply and unbundling residential parking costs from property cost, do not work well in auto -oriented areas Eke the Project site which is auto -oriented. Id. at 8. Moreover, unbundling residential parking costs is in fact explicitly prohibited by the City. Accordingly, should a significant impact be determined during the necessary VMT analysis for the Project, which is likely the case given the Metro EIR and Project's Revised Traffic Circulation Analysis findings, the Project will further conflict with the City's Resolution since its transportation mitigation requirement is infeasible. Thus, for this reason too, a subsequent EIR must be conducted in order to assess whether the Project can adequately mitigate the Project's transportation impacts and whether the Project conflicts with the City's Resolution. City Council 18 — 292 10/3/2023