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