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Mr. Richard Drury May 30, 2019 Page 2 while residential trips are predominantly oriented to non-residential concentrations — the uses proposed to be swapped have very different trip distributions. In addition, under CEQA, addenda are not allowed if there are changed circumstances since the prior EIR or if there is new information that was not known in 1983. In the 35' years since the FEIR was certified, 37' years since baseline traffic data was collected, traffic and circulation circumstances are certain to have changed and there clearly is new information that was not known in 1983. We explore the above issues in the paragraphs below The Addendum Bases Its Trip Generation on New Information That Was Not Known in 1983, That Is Inconsistent With the Trip Generation Analysis That Was Performed in the 1983 FEIR and That Results In Opposite Conclusions from an Actual Comparison of Trip Generation of the Currently Proposed Project to that Analyzed in the 1983 FEIR In the Addendum, trip generation for the currently proposed Project plus completed portions of the project as approved in the 1983 FEIR and for the full project as studied in the 1983 FEIR were both compiled using the current edition of the Institute of Transportation Engineers Trip Generation 10th Edition (released 2017) and current conventional understanding of internalization at mixed use complexes and capture of passerby traffic. The original trip generation estimates for the project analyzed in the 1983 FEIR were compiled based on trip rates embedded in the then current traffic model in use in Santa Ana known as the MMTS/SATC model (rates probably derivative in some way from the then current Trip Generation, 401 Edition) and verified by comparison to actual observed trip generation at 8 large similar office complexes in Southern California. There was no adjustment for internalization of trips or passerby attraction. Using its own current trip generation estimates for both the current Project and the original 1983 project, the Addendum concludes in Table T-6 that the currently proposed Project would generate 6251 fewer daily trips and 995 fewer PM peak hour trips than would completion of the original 1983 approved project. Consequently, it is able to make intersection and roadway performance computations that appear to demonstrate that the proposed Project would produce traffic conditions that are no worse than what would occur with completion of the originally approved project. However, this is a distorted result. However, if the Addendum had compared the trip generation of the current proposed project (total of completed part of original plus current proposal) to the 'I'R Al 1711 I'R:\N 5 P OR T A r I ON • M.AN AGEM GN -f 5311 Lowrjr Road, Union Chi-, CA 94587 tel: 510A 9.9#77 tax: 510.4829478