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18 <br /> <br />significantly worsen previously identified impacts) to previously evaluated intersections <br />or whether the project would create impacts to intersections not previously evaluated in <br />the DTPP EIR. <br /> <br />Study intersections for the analysis were selected using engineering judgement. <br />Intersections closest to the project are the most likely to experience impacts – the <br />farther you get from a project, the more dispersed trips will be and the less likely they <br />will create impacts. Assuming that trips are concentrated on a limited number of routes <br />increases the likelihood that they will generate an impact – a conservative approach <br />when analyzing the effects of a project. <br /> <br />Intersections studied for analysis are those that are most likely to have a significant <br />impact (worsen previously identified impacts, or create a new impact) when project trips <br />are added. Study intersections are those intersections estimated to receive the most <br />project trips and those with high existing traffic volumes. Due to the project’s proximity <br />to US 101 and existing land uses (there is more and higher density development around <br />the US 101 corridor than the I-280 corridor), the majority of trips to and from the project <br />are expected to come via US 101. This land use pattern has not changed significantly <br />since the DTPP EIR was completed so the assumed trip distribution for the project <br />followed the trip distribution patterns assumed for the DTPP EIR. <br /> <br />Appellant contends that three intersections along El Camino Real (State Route 82) <br />should have been studied—the intersections at James Avenue, Whipple Avenue and <br />Roosevelt Avenue. <br /> <br />In fact, potential impacts to these intersections have been considered. As to El Camino <br />Real/James Avenue, the intersection was analyzed in the DTPP EIR and had a level of <br />service of C in the AM and PM peak hours in all analysis scenarios (with DTPP <br />implementation (including under cumulative conditions). Based on this level of service <br />and the relatively small number of trips (12% of the total) estimated to pass through the <br />intersection from the project, the project wasn’t expected to generate a new impact and <br />as such was not identified for more detailed analysis. (See, e.g., March 15, 2017 <br />Hexagon letter, which also stated that all intersections west of El Camino would <br />experience a less than significant impact as a result of the project.) <br /> <br />As to El Camino Real/Whipple Avenue, the DTPP identified a significant impact under <br />project and cumulative conditions, but the City Council found that the impact would be <br />unavoidable since mitigation would require Caltrans approval to widen El Camino Real. <br />In addition, as with the El Camino Real/James Avenue intersection, the project will add <br />very few trips through the El Camino Real/Whipple Avenue intersection, and a <br />November 2014 traffic count found that the intersection is operating at a better level of <br />service, LOS D, than had been found during the DTPP EIR analysis (LOS E in the AM <br />and LOS F in the PM peak hour). (See March 15, 2017 Hexagon letter.) <br /> <br />As to El Camino Real/Roosevelt Avenue, the intersection was not selected for additional <br />analysis largely because new impacts were anticipated due to the relatively small <br />8.A. - Page 18