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Kunzman Associates, ("Traffic Impact Analysis") (A.R., pp. 323-399) and the 895,520
<br />square feet of High-Cube Warehouse identified in the City's response to Rialto's
<br />comment in the City's Apri122, 2008 response to comments incorporated into the Final
<br />EIR. (A.R., p. 2689)
<br />It is unclear where the Court obtained the 1,081,782 square footage number to be
<br />allocated for High-Cube Warehouse uses. It may be a typographical error. The number
<br />used consistently throughout the Project's Traffic Impact Analysis and the EIR's traffic
<br />analysis is 1,086,782. This number is used in Table 4.11-3 of the EIR, which is the basis
<br />for the Project impact analysis in the EIR. (A.R., p. 2144) (Table 4.11-3 of the EIR,
<br />Exhibit A This number is also used on pages 1, 19, and 21 (Table 2) of the Traffic
<br />Impact Analysis. (A.R., pp. 329, 347, 349)
<br />There is one consistent set of square footage numbers used in the Project's Traffic
<br />Impact Analysis and the EIR's traffic analysis. These numbers are: 1,086,782 square feet
<br />of High-Cube Warehouse uses, and 278,666 square feet for Industrial Park uses, for a
<br />total of 1,365,448 square feet. These square footage numbers are the basis for the
<br />Project's traffic calculations.3 The designation of Industrial Park for the 278,666 square
<br />feet of non High-Cube uses was specifically chosen because it assumes the highest, and
<br />thus most conservative, trip generation rate (6.96 trips per 1,000 square feet) (A.R., 2144)
<br />among the uses permitted on the Property. Therefare, the EIR analyzed a worst case
<br />scenario of the trip generation and resulting traffic impacts from Industrial Park uses.
<br />A conceptual site plan was prepared for the project. The site plan contained a
<br />related legend, and was included in the introduction section of the EIR to show the
<br />expected layout of the site. (A.R., 1904) This site plan was prepared eight months before
<br />the EIR was submitted and, although the expected building placement is accurate, it
<br />contains an outdated conceptual use plan prepared by proj ect architects. The breakdown
<br />of uses within the interior of each building shown on the conceptual site plan was never
<br />intended to be, and in fact was never used as, the basis of any traffic analysis.
<br />When responding to Rialto's EIR comment letter, the City mistakenly referred to
<br />the 895,520-square foot warehouse area line item in the legend of the conceptual site plan
<br />rather than citing the correct High-Cube Warehouse number of 1,086,782 used as the
<br />basis of all traffic analysis. The consultants also incorrectly cited the conceptual site plan
<br />for the total square footage of the Project. The total square footage for the Project
<br />consistently used in the Traffic Impact Analysis and the EIR's traffic analysis is
<br />1,365,448 square feet, not 1,365,450 square feet as stated in the conceptual site plan.
<br />Both the Traffic Impact Analysis and the EIR's traffic analysis consistently used
<br />1,086,782 as the square footage allocated to High-Cube Warehouse. (A.R., pp. 2144,
<br />329, 347, 349) Thus, although the incorrect number was used in the response to
<br />3 The Traffic Impact Analysis and traffic analysis of the EIR also accounted for the traffic generated by the
<br />Truck Parking Facility based on the number of truck parking stalls rather than square footage. (A.R., p.
<br />349, A.R., p. 2144)
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