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Mr. Richard Drury May 30, 20t9 Page 3 actual trip generation of the approved project as estimated in the 1983 FEIR, an opposite conclusion would be reached. The daily trip generation estimated for the original project in 1983 was 57,245 daily trips, 10,056 daily trips lower than the Addendum estimates for completion of the original project and 3805 PM peak hour trips lower than the Addendum estimates for the current Proposal plus the completed portions of the original project. Hence, the conclusion that the proposed Project would result in no worse traffic conditions than completion is the result of introduction of new information that was not known and could not be known at the time of the 1983 FEIR. The Addendum Computations That Purport To Demonstrate the Proposed Project Would Result in Acceptable Intersection Traffic Conditions Are the Result of Nuanced Differences in Assumptions in the Intersection Capacity Utilization Computation Procedure Rather than Differences in Current Project vs Approved Project Trip Generation In the Addendum Intersection Capacity Utilization (ICU) computations, the Addendum analysts assume left turn lane capacities 11.75 percent higher than in the computations supporting the FEIR. In the case of double left turn lanes, the Addendum assumes left turn capacities that are 17.56 percent to 26.87 percent higher than assumed in the FEIR ICU calculations. This inconsistency has a tremendous effect on overall ICU rate and Level of Service (LOS) grading. Also, the Addendum computations assume a Peak Hour Factor of 1.0 — that is an assumption that traffic would approach each intersection and intersection approach at a constant flow rate over the course of the peak hour. In the 1983 ICU calculations, it would have been conventional for the actual observed peak hour factor for the intersection, and perhaps for each approach individually, to have been considered. Consideration of the actual peak hour factor, which accounts for the actual surges and ebbs in approach flows by comparing the approach rate in the busiest 15 minutes to the peak hour as a whole, results in a worse ICU than if a constant approach rate is assumed. Hence, the traffic performance computations in the Addendum are not directly comparable to or consistent with those in the FEIR and minimize the propensity to disclose impacts. Current Traffic Has Changed Dramatically From That Underlying the 1983 FEIR Traffic has changed dramatically in the vicinity of the project site. This is illustrated by changes in traffic volume measured on the three freeways that closely approach the site. Caltrans traffic census records posted on the internet only provide data from years 1993 to 2016. The changes over this period near the Project site are shown on the table below. 'I'R Al PIC I'R:% N 5 P o It T AI' I ON AI A N AG LM L N I' 5311 Lown' Road. Union Gtv, CA 94587 tel: SW.4899477 60x: 510.48994M