3B Public Hearing 2007 0904 - Laserfiche WebLink

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RUTAN . ,UTORI<EY; ^'r L,'W Mayor and Members of the City Council of the City of San Leandro August 29, 2007 Page 5 measures which are designed to mlIllIDlze the project's significant impacts by substantially reducing or avoiding them. Only when such mitigation measures have been proposed and required may an agency make the conclusion that the environmental effects are significant and unavoidable. ' Noise Impacts . The EIR failed to adequately address, analyze or mitigate construction-related noise impacts. . The EIR failed to adequately address or analyze the impacts of noise effects on sensitive receptors. Transportlltion and Circulation Impacts · A fundamental problem with the traffic analysis is that it is based upon the assumption that certain programs and policies, which may not ever be approved or implemented, will definitely be implemented. For example, in calculating the Strategy Area trip generation, the EIR used trip generation rates from the Institute of Transportation Engineers ("'ITE") Trip Generation Manual and significantly reduced the trip generation calculations based upon the assumption that the proposed Bus Rapid Transit System (''BRT'') will be adopted and implemented. The proposed BRT has not been approved in any fonn, and may never be approved or funded, yet the whole trip generation analysis is based upon the assumption that the BRT is a certainty. This skews the entire traffic analysis and potentially creates additional significant effects at street locations where impacts are currently identified as less than significant. The traffic analysis should have been conducted wuler current conditions, not assuming that the proposed BRT service will be implemented. Further, because the actual implementation of the proposed BRT service is a mandatory part of the project for the purposes of the EIRs traffic analysis, the full impact of the construction and operation of the BRT service should have been studied in the EIR as well. . Page 4.12-29 of the EIR. indicates that numerous specific street and traffic modification projects "are considered part of the [EIR's] project description/, and the entire traffic analysis and conclusions regarding significant impacts are based upon the assumption that those specifically-identified projects will actually be constructed. If those roadway projects are considered to be part of the EIR's actual "project description" then the potential environmental effects must be fully analyzed under all CEQA criteria. Instead, the EIR provides only cursory analysis of each mandatory project which in no way complies with the requirements of CEQA. . · The traffic study upon which the transportation and circulation impacts analysis was based has an inadequate baseline and is based upon outdated information. 2901023592-0015 83993 LOI 108129107