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Ms. Rebecca Davis May 5, 2020 Page 4 Table 3 — Trip Rates for 18,000 Square Feet of Retail Based on Land Use Category Land Use Category Daily AM Peak PM Peak Supermarket 1,922 69 166 Pharmacy 1,622 53 153 Shopping Center 680 17 69 With the same percentage of internal and attracted passerby trips the DEIR assumes for the shopping center use category, the boutique supermarket generates 882 more net daily, 28 more net AM peak and 28 more net PM peak trips than the improperly applied shopping center category. With the same percentage of internal and attracted passerby trips the DEIR assumes for the shopping center use category, the pharmacy generates 1668 more net daily, 15 more net AM peak and 13 more net PM peak trips than the improperly applied shopping center category. While these differences, particularly in the peak hours, may seem small, when added to adjustment of the improper credit for the prior use, take on cumulative significance. Excessive Assumptions of Trip Reductions Due To Internalization and Passer-by Attraction The DEIR assumes that internal trips and attracted passers-by will account for 31.5 percent of the Project's gross trip generation in the AM traffic peak hour and 42 percent of the Project's gross trip generation in the PM traffic peak hour. Coupled with the improper deductions taken for the abandoned prior use of the site, deductions eliminate 47.2 percent of the gross AM peak trip generation and 54 percent of the gross PM peak trip generation. The analysis appears to have assumed internalization and attracted passer-by rates at maximum percentages of the ranges observed in Trip Generation Handbook, 3rd Edition. Making a series of assumptions, all the most favorable to the Project possible, is not consistent with the good faith effort to disclose impact that CEQA demands. The analysis should be recompiled with more moderate percentage assumptions for internalization and passer-by attraction. Consequences of Improper Descriptions of Roadway Cross Sections Is Not Analyzed In a comment now labeled A6-5 in the FEIR response, the Orange County Transportation Agency identifies several roadways where the DEIR's description of the roadway cross-section is in error. In response, the FEIR corrects the text of the relevant table but fails to analyze whether the changes have any consequential impact on the outcomes of impact analysis. It would seem that I R A I I [( • „i :%ASPSIR I A 110A, • .%,AN,AQIS"I N I. 5.)I I I <,w , R,md, Union Cite, C--A 91587 tel: 510.459.9477 Ins: SIC).481), �),178