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The Bowery Mixed -Use Project CEQA Comment May 11, 2020 Page 10 p. 2. But Mr. Smith observes that 18,000 square feet of retail does not make a shopping center. Id. He explains: 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 Trader Joe's or a Walgreens Pharmacy. Smith, pp. 3-4. By inappropriately relying on the Shopping Center land use category, the FIR greatly underestimates the Project's trip generation. Table 1, below, compares the significant difference in trips generated by a Shopping Center compared to a Pharmacy or Supermarket land use category. For example, a Shopping Center land use would generate only 37.75 daily trips per 1,000 square feet, while a Supermarket would generate 106.78 daily trips, nearly three times as many. Table 2 — Trip Rates Per 1,000 Square Feet Based on Land Use Category Land Use Category Daily AM Peak PM Peak Supermarket 106.78 3.82 9.24 Pharmacy 90.08 2.94 8.51 Shopping Center 37.75 0.94 3.81 Table 2 compares the trips generated for the Projects 18,000 square feet of retail when the three different land use categories are applied. Table 3 — Trip Rates for 18,000 Square Feet of Retail Based on Land Use Category Land Use Category Daily AM Peak PM Peak Supermarket 1,922 69 166 Pharmacy 1,622 53 153 Shopping Center 680 17 69 Mr. Smith concludes that these difference in trip generation rates, `when added to adjustment of the improper credit for the prior use, take on cumulative significance." Smith, p. 3. There is no evidence to support the EIRs use of the Shopping Center land use category for the Project's 18,000 square feet of retail when that category is meant for structures of 400,000 square feet of retail or more. As a result, there is no evidence to support the EIR's findings regarding the severity of the Project's traffic impact.