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impacts over the 98-unit development plan, the 51-unit development plan did not result in a comparable improvement to levels-of-service in part because the 98-unit development has minimal impacts on the community. Public comment questioned the traffic impacts from the second units that are allowed on these lots reflecting §65852.2 of the California Government Code. As a use considered by the City to be incidental to the function of the primary structure/residence allowed for these lots, staff considers the potential traffic from second units to be covered by the traffic analysis completed for the 98-unit development plan, which is approximately double the size of the 51-unit plan. Therefore, staff considers the traffic generated by the second units, even if every lot of the 51-unit plan were to have a second unit, to be covered by the FEIR. The proposed regional and local trails and the staging area would also generate trips. However, there is no established trip generation rate for these facilities. To analyze the possible effects on trip generation that these facilities would have, Dowling developed an estimate by customizing the regional park rate based on the number of individual picnic sites proposed with the neighborhood park of the 98-unit plan. On this basis, the trails/staging facility would generate approximately 60 total trips, with fewer than five trips during the a.m./p.m. peak hours. Staff does not believe that this trip volume would significantly affect the development's peak-hour levels-of-service analyses or the traffic levels on Hearst Drive. Intersections The Oak Grove traffic study identified several intersections that require mitigation from the current "existing plus approved" roadway geometries to maintain an acceptable level of service. Table 3 on the following page is derived from the Dowling report and identifies the intersections operating at LOS "E" or "F" for the existing/approved/project traffic scenario. PUD-33 Page 22 of 59 June 13, 2007