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Response 19: The commenter is incorrect. The Draft EIR references to number of daily trips (from the traffic section) is associated with the average weekday trip rates. The traffic section, nor the traffic impact analysis include or evaluate Saturday or Sunday daily rates. As such, the air quality modeling utilized Saturday and Sunday trip rates based on ITE and CaIEEMod defaults which is appropriate and supported by substantial evidence and not in conflict with the traffic section of the Draft EIR. Comment 20: The comment states that the commercial -work trip length was manually increased in CaIEEMod and the Draft EIR fails to provide any justification for this increase. The comment further asserts that the model cannot be relied upon. Response 20: The commenter is misstates and misquotes the data presented in the EIR. The section where the commercial -work trip length was increased is related to the trucks accessing the existing industrial park land use. A 40-mile trip length for trucks is justified and recommended as a truck trip length by SCAQMD for industrial projects generating truck trips, the 40-mile trip length is derived from regional data published by SCAG. Comment 21: The comment asserts that the pass -by and diverted trip percentages are unjustified and states that the model overestimates the existing land use's mobile -related operational emissions and should not be relied upon to determine Project significance. The comment also states that the new values provided in the Draft EIR were not adequately justified either because the reduction in pass -by and diverted trips is not substantiated. The comment further states that for these reasons the air quality analysis is flawed and the EIR should be amended. Response 21: See Response to Comment 18 above. Comment 22: The comment asserts that the City failed to include all relevant projects in its cumulative Traffic impacts analysis and states that the analysis should be updated to include, the Congregate Care Facility (two miles south of the Project site) and Staybridge Hotel in Irvine (one mile west of the Project site). Response 22: Cumulative Projects that are foreseeable at the date of the NOP are required to be analyzed. A cumulative list was requested from the City of Irvine concurrent with release of the NOP. The Cumulative projects list was provided by the City of Irvine Planning department and was dated 8/2/2019, with the NOP being dated 8/5/2019. The list provided by the City of Irvine did not include the Congregate Care Facility, and only included a sign management plan for the Staybridge Hotel, which would not create any traffic. Therefore, the City did its due diligence to include cumulative projects expected to impact the opening year volumes. For the 2040 build out scenario, all cumulative projects were included in the OCTAM model, therefore, the trips generated by cumulative projects are included in the 2040 build out volumes. Comment 23: The comment asserts that the Draft EIR fails to adopt feasible mitigation measures related to construction air quality emissions and provides a list of measures to alleviate the significant impact of construction -related emissions. Response 23: As described in Section 5.2, Air Qualify, of the Draft EIR the Project would not result in a significant impact related to construction emissions. As detailed in Tables 5.2-7 and 5.2-9 emissions from construction activities would not exceed SCAQMD thresholds. Therefore, impacts would be less than significant, and no mitigation measures are required. 75C-201