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the quality of life in the City." As discussed above, there are little economic benefits of car washes, they <br />occupy prime commercial property and provide few employment opportunities within the City. <br />Accordingly, approving the Russell Fischer Car Wash Project is completely contrary to Policy 2.5, as <br />well as 2.6, which is to encourage employment opportunities, and Policy 2.9 — to support developments <br />with safe and attractive business environments, since the Russell Fischer Car Wash Project has adverse <br />environmental impacts, including traffic and noise, which are discussed in the following section. <br />2. The Car Wash Project Will Have Significant Impacts on Traffic and Noise. <br />a) The Car Wash Proiect's Revised Traffic Study is Incomplete and <br />Outdated; Current/Complete Data Indicates Significant Impacts on Traffic. <br />In order for the Russell Fischer Car Wash Project to be categorically exempt from CEQA review <br />as an infill development project, the Car Wash Project must not result in any significant effects relating <br />to traffic, noise, air quality, or water quality. <br />Robert I{ahn, P.E. of RIK- Engineering Group, Inc., prepared a peer review of the Russell Fischer <br />Car Wash Project revised Traffic Study, dated May 17, 2019, prepared by Linscott, Law & Greenspan. <br />Attached as Exhibit D is RK Engineering's Peer Review (the "Peer Review"). In light of the Planning <br />Commission's inadequate notice for the hearing on the Russell Fischer Car Wash Project (discussed <br />below), the Conklin were unable to obtain an expert to conduct this analysis before that hearing. At the <br />September 9te hearing, the Conklins requested the Commission to continue the hearing on the Russell <br />Fischer Car Wash Project to afford them and other affected parties adequate time to protect their <br />interests. The Commission did not continue the hearing. In short, RK Engineering ("RKE") finds the <br />Russell Fischer Car Wash Project failed to evaluate critical data, which if included would likely have <br />shown a significant impact on traffic. <br />First, the revised traffic study for the Russell Fischer Car Wash Project failed to evaluate <br />weekend traffic and trip generation data. RK Engineering found that the traffic study only reviewed <br />weekday (7-9 am and 4-6 pm) traffic conditions. Express car washes, like the proposed Russell Fischer <br />car wash, actually have peak traffic generation on Saturdays at approximately 1:00 pm or 2:00 pm. <br />Also, the commercial area around the site would have significant traffic conditions on a Saturday. <br />Omitting weekend data from the traffic analysis has a significant effect on the findings set forth in the <br />revised traffic study. (See Exhibit D, pp. 3-5.) <br />RKE has recently collected substantial trip generation data for other express car washes located <br />in Santa Ana. That trip generation data is included as Table 4-1 to the Peer Review (see Exhibit D). <br />Significantly, the Saturday trip generation for each of the car washes analyzed is 50% higher on <br />Saturdays than during the weekday conditions. Like these express car washes, the Russell Fischer car <br />wash will similarly have weekend trip generations that are 50% higher than weekday conditions, and the <br />revised traffic study omits this data entirely — this is a serious omission that appears throughout the <br />study. In addition, it is possible that the Russell Fischer Car Wash Project could have even higher than <br />13 <br />75A-23 <br />