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a critical examination of the data which supports the trip rates, which includes samples from sites with 2,000 square feet to more than 2,000,000 square feet. Comment 8: This comment asserts that the EIR makes excessive assumptions of trip reductions from internalization and passer-by attraction, which when combined with improper deductions from existing land uses, makes a series of assumptions that are favorable to the Project. The comment further states that CEQA requires a lead agency to disclose the full scope of potential impacts and asserts that by relying on the most favorable assumptions, the EIR fails as an informational document. Response 8: The project appropriately uses the internal trip capture rate and passer-by attraction rates provided by the ITE Trip Generation Handbook 3'd Edition. These rates come from multiple studies taken throughout the country and are the most current rates provided by the ITE. Once again, these rates are also consistent with previously approved projects in the City such as the Heritage Project. Therefore, it is appropriate for the project to take credit for internal capture and pass -by trips to analyze a more realistic impact. It is not required in CEQA to overestimate and mitigate unrealistic projects impacts. CEQA requires a good faith analysis of realistic project impacts. Utilizing these rates provide a realistic analysis of the projects impacts due to the nature of a mixed -use project. This comment also states that the internal trip capture and pass -by reductions were the maximum end of the range provided in the Trip Generation Handbook, 31d Edition. This statement is incorrect. The pass -by reductions were taken from the average pass -by reductions shown in the Trip Generation Handbook, 31d Edition. Additionally, the internal trip capture was calculated using the NCHRP Report 684 spreadsheet which is consistent with the Trip Generation Handbook methodology. This method does not provide a range of internal trip capture reductions, but rather calculates the internal and external trips based on project characteristics and trip generation. Comment 9: This comment states that the EIR fails to adequately respond to comments on traffic by the Orange County Transportation Agency. The comment asserts that the correction of text related to roadway cross sections in the Final EIR failed to analyze whether the changes have any consequential impact on the outcomes of impact analysis. The comment further asserts that overstating the number of lanes on several roadways could have significant consequences on the Project's traffic impacts and that the EIR should be revised to address the impact of these changes on the traffic analysis. Response 9: The response to Orange County Transportation Agency's (OCTA) comments provided in the FEIR adequately respond to OCTA's comments. Many of the text changes did not correspond to the study intersections analysis and would not have any impact on the results. The text changes that did correspond to study intersections were updated in both the text and analysis, so any impact on the analysis was accounted for and shown in the FEIR. Comment 10: This comment asserts that as a result of numerous deficiencies, the EIR's traffic analysis violates CEQA. Response 10: As described in the previous responses, the EIR's traffic analysis adequately analyses the projects transportation impacts and honors the intent of CEQA. All of the assumptions and reductions made are in accordance with widely accepted rates from ITE and consistent with previously approved projects in the City such as the Heritage project. It is not required to overanalyze and mitigate unrealistic impacts under CEQA. The intent of CEQA is to accurately analyze a project's impacts and mitigate reasonable and foreseeable impacts. The scope of the Traffic Impact Analysis as well as the final analysis was reviewed 75C-110