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the traffic generated from the partially vacant building space, the traffic analysis assumed that the site was fully occupied. The comment asserts that this resulted in understatement of project traffic impacts. Response 6: The baseline used for the traffic study was calculated using existing traffic counts taken at the project study intersections. The traffic counts were collected in April and May 2019 and were used to calculate the existing and opening year traffic conditions. The existing counts were also used as the base for post -processing OCTAM model data. As a result, the baseline is not hypothetical, as the commenter asserts. Rather, the baseline is based on actual observed conditions within the project study area within one year of the circulation of the EIR. The commenter is incorrect in the assertion that the traffic analysis does not rely on the baseline traffic conditions at the time of the NOP. Credit for existing land uses was taken in the project trip generation, which provides a more realistic analysis of the project impacts, as the existing uses are present on -site and could be re -operated without any discretionary action by the City. The vacancy at the project site has occurred only around a year prior to the NOP in response to the expectation of selling the property for the existing project. Therefore, it is appropriate to consider the existing use at full capacity. With no project, it would be expected that the existing use would reoccupy the space to the maximum entitlement of the site. The comment also asserts that the trip generation prepared for the existing land uses is too high based on the existing use of the site. However, as stated previously, the credit for existing land uses is based on the previous use of the site, not on the existing site operation. The credit for existing land uses was reviewed and approved by the Cities of Santa Ana, Tustin and Irvine prior to preparation of the technical analysis. None of the Cities raised any significant concern about the methodology and no comments to this regard were received during the public comment period. Comment 7: This comment states that The EIR improperly classifies 18,000 square feet of retail in the Project as a shopping center; that 18,000 square feet does not constitute a shopping center, and further asserts that by using the shopping center land use traffic generation rate, the EIR underestimates that traffic that would be generated by the proposed Project. Response 7:. In the FEIR, the square feet of retail increased from 18,000 square feet of retail to 31,000 square feet of retail. The specific retail use is not known at the time of preparing the EIR, so shopping center was used. This is common with multi -family and mixed -use projects and is consistent with other previously approved projects in the City such as the nearby Heritage project located at 2001 E. Dyer Road. Therefore, it is appropriate for the project to use shopping center for the retail portion of the project. Furthermore, the commenter asserts that the size of the shopping center is consistent with a boutique grocery store or pharmacy. However, both grocery and pharmacy uses would require one larger retail space. The project proposes a number of smaller retail spaces, which is consistent with the description of "Shopping Center" as provided in the Institute of Transportation Engineers (ITE), Trip Generation, 1 Oth Edition. That description states "A shopping center is an integrated group of commercial establishments that is planned, developed, owned, and managed as a unit". ITE provides separate rates for grocery and pharmacy, neither of which are applicable to the project. Furthermore, the ITE database for land use 820 — Shopping Center includes 21 studies of shopping centers that are 31,000 square feet or smaller. There is sufficient data to establish a trip generation rate for smaller shopping centers. In addition, a Study by Kimley-Horn and Associates, Trip -Generation Rates for Urban Infill Land Uses in California (2009) discusses appropriate trip rates for infill mixed -use development projects. One of those rates for retail is shopping center, which can range from shopping centers less than 190,000 square feet to individual businesses within buildings. The Bowery comfortably falls within that range, making the use of shopping center appropriate. Finally, the comment states that ITE's Shopping Center category is meant for structures of 400,000 square feet of retail or more. This statement is not supported by the description provided in Trip Generation, or by 75C-109