3.0 Comments on the Draft Eir and Responses to Comments
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3.0 COMMENTS ON THE DRAFT EIR AND RESPONSES TO COMMENTS 3.1 INDEX TO COMMENTS As described in Section 1.0, Introduction, all comments on the Draft Environmental Impact Report (EIR) received either in writing or orally at the public hearing have been coded, and the codes assigned to each comment are indicated on the written communication and the public hearing transcript that follow. All agencies, organizations, and individuals who commented on the Draft EIR are listed in Table 3.0‐1, Index to Comments, below. Table 3.0‐1 Index to Comments Commenter Code Agency/Organization/Individual – Name SA‐1 Department of Transportation – Lisa Carboni LA‐1 Alameda County Congestion Management Agency – Diane Stark LA‐2 City of Hayward – Gregory Jones LA‐3 San Francisco Bay Area Rapid Transit District – Val Menotti ORG‐1 Associated Students, Inc. California State University East Bay – Udeepto Maheshwari ORG‐2 Hayward Area Planning Association – Sherman Lewis ORG‐3 Professor of Geography and Environmental Studies – Karina Garbesi Geography Masters Student – Arpi Kupelian ORG‐4 Old Highlands Homeowners Association – Stuart M. Flashman I‐1 Jesus Armas I‐2 John and Diane Balloue I‐3 Harry Bruno I‐4 Linda Christo I‐5 Jed DeVaro I‐6 Ron Lewis I‐7 Peter D. Reimer Impact Sciences, Inc. 3.0-1 CSU East Bay Hayward Campus Master Plan Final EIR 961‐02 March 2009 3.0 Comments on the Draft EIR and Responses to Comments Commenter Code Agency/Organization/Individual – Name I‐8 Peter D. Reimer I‐9 Peter D. Reimer I‐10 David Rosen I‐11 Rob Simpson I‐12 Joy Rowen PH‐1 through 3 David Madson PH‐4 Ed Brightman PH‐5 Jennifer Eagan PH‐6 Susan Correia PH‐7 B. Goldman PH‐8 Ronn Patton PH‐9 through 12 Audrey LePell PH‐13 through 24 Rob Simpson PH‐25 Susan Opp PH‐26 Audrey LePell SA 1: State Agency; LA: Local Agency; Org: Organization; I: Individual; PH: Public Hearing 3.2 MASTER RESPONSES 3.2.1 Master Response 1, Traffic Demand Management (TDM) Program Definition Several comments raised concern regarding the lack of detail presented on the proposed Travel Demand Management (TDM) Plan, including how programs would be operated and funded, and specifically how transit service to the campus would be improved. The discussion below provides additional detail on the TDM programs proposed in the Master Plan and required by MP Mitigation Measure TRANS‐1. At the end of this response, proposed additions to the text of MP Mitigation Measure TRANS‐1a are given. Please see Master Response 2 for a discussion of how peak hour vehicle trips and parking demand are projected to be reduced by the TDM programs. Impact Sciences, Inc. 3.0-2 CSU East Bay Hayward Campus Master Plan Final EIR 961‐02 March 2009 3.0 Comments on the Draft EIR and Responses to Comments Baseline Data The Draft EIR presents data on the campus’ current commuting characteristics by mode, including vehicle trip counts at the two campus gateways; ridership on the Hill Hopper1 shuttle to/from Downtown Hayward BART and on AC Transit Route 92; and the small number of walking and bicycling trips from off‐campus locations. The existing ridership and load factors for Route 92 and the BART lines serving the campus are also provided. These data provide the baseline upon which the TDM programs outlined in the Master Plan, and correspondingly required by MP Mitigation Measure TRANS‐1a, will be developed. Improved Transit Service Studies of TDM programs at other campuses have indicated that the most effective programs provide a range of incentives to carpool, use transit, bike or walk, and disincentives to drive. In the first category, the most effective program is convenient, low‐cost or free transit service, which is why this appears at the top of the list in the Master Plan and Draft EIR MP Mitigation Measure TRANS‐1a. The proposed service would provide minimum 15‐minute headways from 6:00 AM to 10:00 PM, with adequate bus capacity to serve the projected growth in ridership due to the Master Plan growth, which includes a projected 50 percent increase in bus use, relative to current use levels on a per‐student basis. In Draft EIR Section 4.12.2.4, it is acknowledged that Route 92 already provides 15‐minute headways from 6:00 AM to 11:00 PM, and the Hill Hopper shuttle provided 25–30 minute headways from about 7:30 to 9:30 AM and 4:40 to 10:20 PM (at the time the Draft EIR was prepared—see footnote 1). However, additional buses would need to be added to serve the projected increase in demand, effectively shortening the headways significantly during the morning and afternoon/evening peak periods. Based on the increased transit ridership calculation (discussed further below), additional buses may be needed during the peak periods (7:00–9:00 AM and 5:00–7:00 PM). To achieve a 50 percent increase in ridership between BART and the campus, three key operational elements must be considered in addition to providing enough buses during peak periods: (1) continuing to offer free service to students, faculty and staff; (2) minimizing the trip time; and (3) coordinating the arrivals of buses with the BART trains. The additional cost associated with increasing the bus‐capacity and frequency as ridership grows can be allocated in a number of ways, including increased parking permit prices, adding a transit fee to the student registration fee, and re‐negotiating faculty/staff benefits to include the transit cost. As noted above, these are issues that must be studied before they can be 1 It is noted that as of January 2009, the Hill Hopper shuttle has been replaced by expanded service by AC transit Route 92. The University has contracted with AC Transit for this service so students, faculty, and staff may ride the Route 92 bus for free with a University ID. Impact Sciences, Inc. 3.0-3 CSU East Bay Hayward Campus Master Plan Final EIR 961‐02 March 2009 3.0 Comments on the Draft EIR and Responses to Comments approved and implemented. The trip time can be reduced by minimizing intermediate stops and ensuring the service runs directly between the Hayward Campus and the Downtown BART station via Carlos Bee Boulevard and Mission Boulevard. AC Transit has agreed to coordinate Route 92 departure times with arrival times from BART. Coordinating the arrivals with BART trains will further improve overall trip times for BART riders. Coordinating the schedule with starting times for classes would also encourage students to use transit, but class schedules differ for different weekdays, and the BART schedule is a more important consideration. These operational elements will be considered and studied when the University develops its TDM Implementation Plan. The analysis of a potential “rapid bus” service or “real transit,” provided by the Hayward Area Planning Association (HAPA) (Comment Letter ORG‐2) contains many of the capital and operating elements that the University will consider in determining the best way to provide increased and enhanced service between Downtown Hayward BART and the campus as part of the University’s TDM Implementation Plan. However, the University disagrees that improved transit service can eliminate the mid‐term (10‐ to 15‐year) need for a parking structure to replace lost spaces and serve some growth in parking demand (see Master Response 2). Provision of Free or Discounted Transit Passes The provision of free or substantially discounted transit passes, including a universal AC Transit pass, and/or blocks of BART tickets, would have a significant effect on the use of these modes. Before the University can commit to providing these benefits, a financial and operational study must be performed to determine the most efficient way to fund and operate the programs. MP Mitigation Measure TRANS‐1a requires the University to perform these studies in order to prepare a TDM Implementation Plan that will identify “the steps necessary to plan for, fund, implement and monitor the effectiveness of the measures…” The mitigation measure thus requires the program to be considered, without mandating the implementation of programs that may or may not be feasible and thus may or may not produce the desired shift to non‐single‐occupant‐vehicle modes. Parking Permit Pricing and Supply Management The primary “disincentive” element of the campus TDM program is the parking management. When driving and parking is cheaper and more convenient than taking transit, ridesharing, walking or biking, commuters will not hesitate to choose this option. Thus, the aim of the parking management element is to increase permit costs and manage supply, so that the cost is comparable to or higher than taking transit, and so that the parking supply is not overabundant (but not so constrained that parking demand is forced into adjacent neighborhoods). Increased permit revenues can also be used to help fund new Impact Sciences, Inc. 3.0-4 CSU East Bay Hayward Campus Master Plan Final EIR 961‐02 March 2009 3.0 Comments on the Draft EIR and Responses to Comments parking construction as well as improved shuttle service to BART. In addition to phased price increases over time, the pricing structure should also be adjusted, so as to bring monthly/quarterly permit prices more in line with the daily rate. A sampling of other UC and CSU campuses indicates that CSU East Bay’s current permit prices are relatively low, at $51 per quarter for students and faculty/staff (refer to Table 3.0‐2, Parking Permit Cost Comparison). On a monthly basis, this translates to about $17 per month, as compared to an average rate of $62 per month for commuter students, $67 per month for commuter faculty/staff, and $55 per month for resident students at eight other California universities.