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generation minus the net trip generation for the existing uses? The method for this calculation was not included/explained in the revised traffic study, and RYE was unable to decipher it from the text of the report. RKE commented that this is significant because it "could affect all of the traffic analysis for the future conditions with the project." Accordingly, the method used to calculate the project only volumes must be clarified so its accuracy and completeness can be evaluated. Fourth, the 2019 revised traffic study is inaccurate because it does not use current data or current conditions in its analysis of the effects of the Russell Fischer Car Wash Project on traffic. RKE identified this inaccuracy several times throughout the study. For instance, the revised traffic study evaluation of near -term traffic conditions was for the year 2019. RKE found that this is not a realistic timeframe, since it is nearly the last quarter of year 2019 and the Car Wash Project has not yet been approved and would need a period for construction. Accordingly RKE found that a much later time frame should be evaluated for near -term conditions, and suggests an Opening Year of 2020 or 2021. Similarly, the near -term traffic analysis shown on page 3-91 needs to be a more realistic year than Year 2019, since Year 2019 is nearly over. The traffic counts mentioned on page 3-72 of the revised traffic study were taken in October of 2016, three years ago, even though the revised traffic study was prepared in 2019. RKE found that the revised traffic study should have been updated with more current traffic counts in 2019 to reflect existing conditions. The outdated traffic counts affect the overall analysis of whether the Russell Fischer Car Wash Project has a significant impact on traffic. Moreover, the revised traffic study for the Russell Fischer Car Wash Project tools a trip credit for the traffic from the sit-down restaurant building that used to exist on the site at 301 N. Tustin Avenue. RK Engineering found that this would only be valid if the restaurant was in full operation when the traffic counts were taken. Nonetheless, the restaurant closed and the building has been cleared from the site. Since the 2016 traffic counts used in the revised traffic study should be updated to reflect 2019 traffic conditions, this restaurant trip credit cannot be utilized. Accordingly, the trip counts used in the revised traffic study are inaccurate. Lastly, as shown on page 3-82, the traffic study used the ITE (Institute of Transportation Engineers) 9th Edition of Trip Generation rates which was published in 2012. This manual was updated in the ITE Trip generation, 10th Edition published in 2017. RK Engineering commented that the latest manual should have been used since both the original traffic study and the 2019 revised traffic study were done significantly after the new ITE Trip Generation data was available. Accordingly, on page 3- 101, Table 6-2 needs to use the more current ITE loth Edition Trip Generation for all of the cumulative projects. In light of the foregoing, the Russell Fischer Car Wash Project is not categorically exempt from CEQA review as an infill development project because the traffic study is incomplete and outdated, and thus insufficient to support the Planning Commission's determination that the Project will have no significant effects relating to traffic (CEQA § 15332(4)). The review and data provided by RKE shows 15 75A-25