Comments Responses Rtc-1002
Total Page：16
File Type：pdf, Size：1020Kb
COMMENTS RESPONSES 396 HAYES STREET, SAN FRANCISCO, CA 94102 LAUREL L. IMPETT, AICP T: 415 552-7272 F: 415 552-5816 Urban Planner www.smwlaw.com [email protected] July 17, 2012 Via Email Mayor Jerry Sanders and Members of the City Council City of San Diego City Administration Building 202 “C” Street San Diego, California 92101 [email protected] [email protected] Re: One Paseo Draft EIR Dear Mayor Sanders and Members of the City Council: On behalf of Cleveland National Forest Foundation (“CNFF”), we have reviewed the draft environmental impact report (“EIR”) for One Paseo, a massive mixed-use development project consisting of almost two million square feet of retail, office, residential and open space uses. If this Project were proposed in an urban area with convenient access to transit service, it 326.1 As discussed in responses to comments 4.1 and 10.40, the proposed would be considered “smart growth.” Yet because the Carmel Valley currently has no access to project is considered consistent with the City of Villages Strategy, which 326.1 convenient transit and because transit service is not contemplated to serve the Project until at least 2035, it is decidedly not a “smart growth” project. embraces the principles of smart growth. The project site is identified as having a moderate “Village Propensity” (see Figure LU-1 of the General Moreover, One Paseo would exacerbate already excessive levels of traffic Plan). As also discussed in response to comment 10.40, transit is planned 326.2 congestion on local and regional streets, intersections, freeways and freeway ramps. Yet, rather to serve the area by the year 2030. Furthermore, as indicated in response than mitigate the Project’s significant traffic impacts by contributing to transit service in the area to comment 10.38, the project site is specifically identified in SANDAG’s 326.3 or implementing transportation demand management measures, the Project simply proposes road RCP as a “Town Center” smart growth opportunity area. and intersection projects to “mitigate” traffic impacts. It also ignores recommendations of SANDAG’s Independent Transit Planning Review Services Report (May 2006) and SANDAG’s 326.2 326.4 RTP/SCS which recognize the importance of regulating the amount of parking to discourage The Final EIR acknowledges that implementation of the proposed project travel by automobile. would result in significant impacts to traffic; some of which may not be reduced to below a level of significance because timely implementation Perhaps most important, the DEIR rejects without sufficient basis an off-site of identified mitigation measures cannot be assured by the applicant alternative. As discussed below, One Paseo is simply the wrong project for the Carmel Valley since they are under the control of Caltrans. (See response to comment because it lacks a public transit network that would allow Project occupants to travel without an 4.3 for a discussion of project traffic impacts.) 326.5 automobile. Alternative sites exist, within urban areas that are currently served by adequate public transportation. Such alternative locations, possibly even redevelopment sites, would minimize and possibly eliminate altogether the Project’s significant transportation impacts. RTC-1002 COMMENTS RESPONSES 326.3 As discussed in response to comment 6.7, the project applicant is proposing a TDM Plan which would include a variety of strategies to reduce project traffic including providing a shuttle. Initial implementation of the shuttle program would include one to two shuttles running at half-hour intervals during am/pm peak times and over the lunch hour. The shuttle would provide service to the Sorrento Valley Coaster station. The TDM Plan would be implemented in addition to the roadway improvements required by Mitigation Measures 5.2-1 through 12. 326.4 As discussed in response to comment 6.7, the Revised Project includes many of the elements identified in the SANDAG parking policies study which would reduce reliance on the private automobile, and include sidewalks and bicycle lanes throughout the project and a shuttle service for residents, employees and shopping patrons associated with the development. The mixed-use nature of the project also reduces reliance on the automobile. 326.5 As discussed in response to comment 63.5, the Draft EIR appropriately concludes that there are no other sites in the project area (i.e., Carmel Valley) that are suitable for the project. Carmel Valley is essentially built out, and there are no other vacant parcels in Carmel Valley similar in size to the project site (23.6 acres) that could support the mix and density of proposed land uses within the development. Even if a potential site existed within the Carmel Valley community, locating the proposed project at that location would likely result in similar impacts related to neighborhood character and traffic. With respect to the other “potential” locations in the City of San Diego, acquisition of other sites in a timely manner by the project applicant is not considered feasible. The ability for an applicant to acquire an offsite location in a timely manner is a well-recognized consideration in evaluating the feasibility of an off-site alternative (Goleta II, supra, 52 Cal.3d at p.575). RTC-1003 COMMENTS RESPONSES Mayor Jerry Sanders and Members of the City Council July 17, 2012 Page 2 Project Description The Project entails a mixed-use development encompassing 1,857,440 gross square feet (“sf”) consisting of approximately 270,000 sf of commercial retail, approximately 557,440 sf of commercial office, approximately 100,000 sf consisting of a 150-room hotel, and approximately 930,000 sf consisting of 608 multi-family residential units. A total of 4,089 parking spaces would be provided throughout the site in subsurface garages, one above-ground parking structure, and small surface lots. See DEIR Table 3-1. Although the DEIR asserts that the Project is intended to promote sustainable 326.6 The project is designed to take advantage of the bus rapid transit which development principles and smart growth (at 12-1), the document never mentions the possibility is planned in the area by the year 2030. In the meantime, as discussed in of meeting travel demand via public transit. In fact, the Project Objectives simply assert that the response to comment 6.7, the project does include a shuttle that would Project is intended to provide a mix of land uses within close proximity to major roads and regional freeways and existing community amenities. Id. By offering convenient access to provide access to the Sorrento Valley Coaster station until such time as 326.6 major roads and freeways and by offering an abundance of free parking, One Paseo will greatly public bus service is available. facilitate auto-based travel. While the DEIR mentions that transit will ultimately service the Carmel Valley, this transit is not even contemplated to be built until 2035. Moreover, because funding becomes more speculative with each passing year, transit service to Carmel Valley may never be implemented. Transportation Impacts The DEIR Fails to Adequately Analyze and Mitigate the Project’s Transportation Impacts. 326.7 As discussed in response to comment 10.40, the traffic impact analysis One Paseo would generate 26,961 average daily vehicle trips, with 1,538 trips in for the project did not assume any reduction in project-generated traffic the AM peak period and 2,932 trips in the PM peak period. DEIR at 5.2-11. Yet, the Project to account for the anticipated availability of bus service to the site. The could actually generate far more traffic than the DEIR discloses since the DEIR consultants only reductions applied related to the documented trip savings associated discounted the trip generation rates to take into account the mixed-use development. One Paseo with mixed-use projects, in which project residents and workers would be 326.7 is an entirely auto-based development. No evidence exists that residents and visitors will not drive between each of the uses in the development, especially because the Project includes able to take advantage of restaurant and shopping opportunities without ample, free parking. Abundant, free parking encourages motorists to drive rather than walk relying on their cars. The traffic impact analysis also accounted for the between destinations. Consequently, the DEIR should not have discounted the Project’s trip potential for some residents to work in the proposed commercial uses on generation estimates. the site. Because One Paseo is entirely auto-based, it comes as no surprise that the Project The appropriateness of including trip reductions for mixed-use projects would result in numerous significant impacts to roadway/arterial segments, intersections, freeway ramps and freeway segments. Yet mitigation for the Project’s transportation impacts is is discussed on pages 3-3 and 3-4 of the TIA in Appendix C to the Draft 100 percent auto-based. It is important to recognize that the only way transit will come to EIR. As described there, the 6% reduction used in the traffic analysis is fruition in the region is to discourage auto-based travel and invest in public transit infrastructure. conservative in comparison to the observed trip generation of existing Despite this fact, the DEIR does not require the applicant to make any contribution (e.g. pro-rata mixed-use developments. share) to transit agencies such as MTS. Nor does the DEIR propose any type of shuttle or dial-a- 326.8 ride transit service that could take Project occupants to the COASTER line, bus or light-rail 326.8 stations. As discussed in response to comment 6.7, the project applicant is proposing a TDM Plan that includes a private shuttle that would provide service to the Sorrento Valley Coaster station until planned public bus service is available to the project site.