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LAW OFFICE OF KARA E. GRANT <br />RK 15528 <br />Page 2 <br />- Trip credit was taken for the existing restaurant building on the site which may not <br />have been in operation when the traffic counts were taken. <br />- Updated traffic counts should be taken in 2019 rather than the 2016 counts that <br />were used in the revised 2019 Traffic Study. <br />- The Traffic Study should have used the latest ITE (Institute of Transportation <br />Engineers, 101" Edition Trip Generation, 2017 rather than the older 91" Edition, 2012 <br />document. <br />A Saturday peak hour traffic impact analysis needs to be performed for all of the <br />project scenarios. <br />The project only traffic volumes at study area intersections needs to be checked for <br />accuracy. It doesn't appear that they correlate to the project trip generation and trip <br />distribution. This needs to be verified. <br />A traffic safety analysis should be performed at the intersection of North Tustin <br />Avenue at 41h Street since the project will add a significant amount of traffic to that <br />intersection which has a collision rate higher than expect for this type of <br />intersection. <br />- No preliminary noise or vibration analysis report was prepared for the project. <br />Express Car Washes are High Noise Generators and their impacts need to be <br />quantified and it has to be determined if there are feasible appropriate mitigation <br />measures. This is typical for high Noise generating uses such as an Express Car <br />Wash. All of the Conditions of approval for the project require this to be done after <br />the fact when it may not be feasible to adequately mitigate the project. <br />Adjacent to the Express Car Wash Tunnel is an existing operating office building that <br />has sensitive medical uses. The Noise and Vibration analysis and mitigation <br />measures need to be determined before entitlement for the proposed use can be <br />granted. <br />These issues are further discussed in the Comments section of this letter. <br />I- T� group. <br />Inc.en� <br />nc. <br />75A-68 <br />