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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. In the State of California, and ITE, there is a push to encourage more mixed -use projects because of the reduction of travel. To not utilized the approved and accepted rates would defeat the purpose of constructing a mixed use project. Comment 30: 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. Response 30: As stated in response 9, the response to Orange County Transportation Agency's (OCTA) comments provided in the FEIR do 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 31: This comment asserts that as a result of numerous deficiencies, the EIR's traffic analysis violates CEQA. Response 31: As described in the previous responses, as well as in response 10, 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 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 traffic section of the EIR, as well as the supporting Traffic Impact Analysis, appropriately analyses the foreseeable impacts and provides reasonable mitigation measures and is therefore consistent with the intent and standards of CEQA. Comment 32: This comment is from a letter prepared by Smith Engineering and Management, which summarizes the existence of contaminated soils onsite and states that on its own, Mitigation Measure HAZ-1 is insufficient to ensure mitigation of impacted soils and that engagement of the DTSC is necessary. The comment further states that a soil mitigation plan is not an instrument that is used by DTSC. The comment provides suggested mitigation language and provides activities that asserts are from the DTSC comment letter. In addition, the comment describes the oversight authority of the RWQCB. Response 32: As described previously In Response 16, contaminated soils would be excavated and removed during Project excavation and grading activities pursuant to the regulations of DTSC, California Integrated Waste Management Board, RWQCB, OCFA, and the OCHCA. Mitigation Measure HAZ-1 requires approval of a Soil Management Plan (SMP) to ensure that excavation of contaminated soils be completed pursuant to existing DTSC and RWQCB requirements. Therefore, the mitigation related to removal of the contaminated soils includes engagement of the DTSC, as necessary. In addition, contrary to the comment, the DTSC comment letter (included in the Final EIR) does not include this list of requirements for a removal action work plan. 75C-119