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The Bowery Mixed -Use Project CEQA Comment May 11, 2020 Page 11 3. The EIR makes excessive assumptions of trip reductions from internalization and passer-by attraction. The EIR assumes that internal trips and attracted passers-by will account for 31.5 percent of the Project's gross trip generation in the AM traffic peak hour and 42 percent of the Project's gross trip generation in the PM traffic peak hour. Smith, p. 4. When combined with the improper deductions taken for the abandoned prior use as an industrial park, deductions eliminate 47.2 percent of the gross AM peak trip generation and 54 percent of the gross PM peak trip generation. Id. This analysis assumes internalization rates and attracted passerby rates at the maximum end of the range provided for in the Trip Generation Handbook, 3'a Edition. Id. In doing so, the EIR makes another in a series of assumptions, all most favorable to the Project, and all minimizing trip and traffic generation. CEQA requires more than merely disclosing the most generous interpretation of potential impacts. CEQA requires a lead agency to disclose the full scope of potential impacts. By relying solely on the most favorable assumptions, with no discussion of the possibility of greater impacts, the EIR misleads the public and decision makers, and fails as an informational document. 4. The EIR fails to adequately respond to comments on traffic by the Orange County Transportation Agency. In its comments on the DEIR, the Orange County Transportation Agency identifies numerous roadways for which the DEIR's description of roadway cross-section is wrong. FEIR, 2-35 to 2-37. In response, "the FEIR corrects the text of the relevant table but fails to analyze whether the changes have any consequential impact on the outcomes of impact analysis." Smith. p. 4. Overstating the number of lanes on several roadways could have significant consequences on the Project's traffic impacts and the mitigation required for those impacts. The FEIR must be revised to address the impact of these changes on the traffic analysis. 5. As a result of numerous deficiencies, the EIR's traffic analysis violates CEQA. Based on the above deficiencies, Mr. Smith correctly concludes as follows: Because the DEIR improperly deducted trips for a prior use of the Project site that was not present when the NOP was circulated nor when baseline traffic counts for the analysis were taken, because it unreasonably treats 18,000 square feet of unspecified retail commercial as a "shopping center" rather than a logical specific use or range of uses that would occupy a retail floor area of this size and because the analysis consistently makes assumptions most favorable to the Project with regard to trip internalization and passer- by attraction, the FEIR should not be certified, the traffic analysis should be redone and the environmental document should be recirculated in "draft" status.