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that the Project only use composite wood materials that are CARB approved no -added formaldehyde (NAF) resins or ultralow emitting formaldehyde (ULEF) resins. Response 26: This comment is not Project specific and is general in nature. The comment does not provide any examples or citations of where analysis within the EIR is flawed. As described in Responses 19, 21, 22, and 25, pursuant to the Project would utilize products that have to be manufactured or imported pursuant to TSCA Title VI and California Proposition 65 safe harbor standards. As a result, formaldehyde within Project buildings would not exceed the SCAQMD significance threshold of 10 per million and Project impacts would be less than significant. Comment 27: This comment is an attachment from Smith Engineering and Management, which states that in response to the requested, the EIR traffic analysis has been reviewed. The review asserts that the Project will have significant impacts on traffic and that the EIR relies on a hypothetical traffic baseline rather than conditions that exist at the time environmental analysis begins. The comment asserts that this resulted in understatement of Project traffic impacts. Response 27: As stated in Response to Comment 6 above, the baseline used for the traffic study was calculated using counts taken at the project study intersections, which is not hypothetical. The credit taken was in the project trip generation, which provides a more realistic analysis of the projects impacts without double counting trips. 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. Comment 28: 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 28: As stated in Response to Comment 7 above, the FEIR had an increase in the square feet of retail, 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 multiple and mixed -use projects and is consistent with other previously approved projects in the City such as the Heritage project. Therefore, it is appropriate for the project to use shopping center for the retail portion of the project. 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. Comment 29: 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. Response 29: As stated in response 8, the project appropriately uses the internal trip capture rate and passer-by attraction rates provided by the Institute of Transportation Engineers (ITE) Trip Generation Handbook 3rd 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 75C-118