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Ms. Rebecca Davis May 5, 2020 Page 3 trips in PCEs in the AM peak hour and 33 PCE trips in the PM peak hour. This is less than 21 percent of the 159 PC trip deduction for traffic of existing use allowed from the Project trip generation per DEIR Table 5.14-5. The allowance of an undeserved extra 126 trip deduction amounts to an understatement of almost 21 percent from the net PM peak trip generation of 604 trips for the Project assumed in the analysis. This flaw alone is sufficient to significantly alter findings of impact and mitigation requirements. The 18,000 Square Feet of Unspecified Retail in the Project Is Not a Shopping Center The DEIR estimates the trip generation of the 18,000 square feet of unspecified retail in the Project at average rates for Land Use Category 820, Shopping Center per Trip Generation,10l^ Edition. However, 18,000 square feet of retail is not a shopping center. Shopping centers only generate trips at the average rates employed in the subject analysis when they reach a size of about 400,000 square feet of floor area. Small footprint retail normally generates trips at much higher peak and daily rates per thousand square feet than the shopping center average. The 18,000 square feet of retail in the Project is about the typical size of a boutique grocery like a TraderJoe's or a Walgreens Pharmacy. A Supermarket (Land Use Category 850) generates trips at rates of 106.78 trips per thousand square feet daily, 3.82 per thousand in the AM peak hour and 9.24 per thousand in the PM peak hour. A Pharmacy with no drive -up window (Land Use Category 880) generates trips at rates of 90.08 trips per thousand square feet daily, 2.94 per thousand in the AM peak and 8.51 per thousand in the PM peak. This starkly contrasts with the Shopping center rates of 37.75 trips per thousand square feet daily, 0.94 per thousand in the AM peak and 3.81 per thousand in the PM peak. Table 2 —Trip Rates Per 1,000 Square Feet Based on Land Use Category Land Use Category Dail AM Peak PM Peak Supermarket 106.78 3.82 9.24 Phan-nacy 90.08 2.94 8.51 Shopping Center 37.75 0.94 3.81 If the DEIR had analyzed the 18,000 square feet of retail as a supermarket, it would generate 1922 gross trips daily, 69 gross AM peak trips and 166 gross PM peak trips. Analyzed as a Category 880 Pharmacy, the same floor area of retail generates 1621 gross daily trips, 53 in the AM peak and 153 in the PM peak. These are significantly higher than the 680 daily, 17 AM peak and 69 PM peak gross trips the DEIR predicts for this floor area as a so called shopping center. lIZ,IIIt •'1't NC P JY. T I IU]" "In NCLN1-N! 5311 1 Hood. I ,ioc Cay.(A 9458J td::,10.4SJ19477 r.te: 510.4N) 9178 27 28 75C-81