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8-10 CECA requires that cumulative traffic impacts be addressed through either a list-based or plan-based approach. Redwood City, because it is located in San Mateo County, has access to the regional travel demand model developed by the C/CAG. By using this model as the basis for developing traffic projections, the EIR takes into account the total anticipated traffic load associated with regional development planned to occur in the area as a result of regional employment and household growth (documented in projections published by the Association of Bay Area Governments (ABAG». The model uses the ABAG employment and household projections to generate traffic and distribute it to each of the Traffic Analysis Zones (TAZ's) in the model. Subsequent to the traffic distribution, the model assigns traffic volumes to the road network taking into account vehicle speeds, roadway capacity and travel distance. The model always assigns traffic volumes by the "shortest-travel-time" method. As the model assigns traffic to each road, the calculated vehicle speed is reduced, thereby increasing the travel time. As travel times on various links increase, the model accounts for the implications of cumulative traffic congestion on the road system by shifting traffic from more congested road corridors to less congested corridors. The end result forecast takes into consideration the whole traffic load, its relationship to multiple directional movements, and driver behavior in choosing the quickest route. As indicated in the EIR and acknowledged by the appellant, there will be more traffic congestion in the future. Each of these impacts is identified (Impact B3, 84, B5, B7, B8 and 89). For some of these traffic impacts, there is no practical mitigation and this was noted in the EIR as significant and unavoidable. For other of the adverse impacts mitigation measures were crafted that reduce what was otherwise a significant change in the LOS to less than significant (see, for example, Impact B5 and Mitigation measures 85a & b). The purpose of the EIR is to identify the traffic impacts and define mitigation measures if available. The EIR meets this mandate. The EIR conservatively overstates the cumulative traffic impacts for the downtown area. As indicated in the EIR, many of the road corridors (e.g., EI Camino Real, Woodside Road, US 101) are anticipated to operate at unacceptable levels. This regional effect will cause drivers to adjust their driving behavior (e.g., leave work early, tele-commute, and patronize mixed-use destinations) to avoid the peak hour traffic congestion. Current best practices cannot accurately model these behavior changes and therefore these changes are not considered in the EIR analysis. With regard to the contention that the cumulative traffic impact on emergency response was not considered, attention is directed to pages 199-201 of the DEIR. The discussion of cumulative traffic impacts and the effect on emergency response time points out that due to the close proximity of two fire stations (one within 2.5 to 3 minutes from the project site and the other within 4 to 4.5 minutes), along with multiple access routes into the downtown area and normal traffic preemption for emergencies, no adverse impacts on the Fire Department's ability to respond were identified. Additionally, on page 68 of the FEIR, in response to a comment (Paul Mendelowitz, Comment 1) it is noted that delays at the intersections with the least satisfactory operations 5