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May 6, 2021 <br />Page 15 <br /> <br /> <br />5005-003acp <br /> <br /> printed on recycled paper <br />The Project will generate significant levels of vehicle miles travelled <br />(“VMT”).62 The statement that the Project would generate less VMT than the <br />average in the area is not supported by substantial evidence.63 Mr. Smith <br />determined that the Checklist miscalculated the Project trip generation.64 Absent <br />this correct calculation, the City’s traffic calculations are not supported by <br />substantial evidence. Mr. Smith found that the “extra discounting on the <br />residential trips in the PM peak eliminates 45 of the 71 (over 63 percent) of <br />residential trips… the discount of residential trips amounts to almost 29 percent of <br />the 156 net new PM peak hour trips that are ultimately assigned to the street <br />system. So, this one error alone is sufficient to result in substantial <br />understatement of the Project’s impacts on PM peak hour delay/level of service and <br />traffic queues.”65 Additionally, Mr. Smith found that the exit into Hyde Street for <br />large trucks may constitute a safety issue that was not analyzed or mitigated in the <br />Checklist.66 This discrepancy and the issues addressed in Mr. Smith’s comments <br />constitute inadequate traffic analysis and must be remedied in an Infill EIR to <br />satisfy CEQA. <br /> <br />B. The Project Will Result in More Significant Effects to Air Quality, <br />Health Risk, GHGs, Hazards, Noise, Traffic, and Cumulative <br />Impacts Than Analyzed in the General Plan EIR and Is <br />Inconsistent With General Plan Policies <br /> <br />The Project will result in more significant environmental impacts than was <br />represented in the 2035 General Plan EIR. An effect is more significant if <br />substantial new information shows that: (1) mitigation measures that were <br />previously rejected as infeasible are in fact feasible, and such measures are not <br />included in the project; (2) feasible mitigation measures considerably different than <br />those previously analyzed could substantially reduce a significant effect described in <br />the prior EIR, but such measures are not included in the project; or (3) an <br />applicable mitigation measure was adopted in connection with a planning level <br />decision, but the lead agency determines that it is not feasible for the infill project <br />to implement that measure.67 <br /> <br /> <br />62 Smith Comments, p. 2. <br />63 Appendix F Section 2.6.1; Smith Comments, p. 2. <br />64 Smith Comments, p. 2. <br />65 Smith Comments, p. 4. <br />66 Smith Comments, p. 6. <br />67 14 CFR § 15183.3(d)(1)(D). <br />105