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19 <br /> <br />number of project trips that would pass through it and the intersection’s level of service. <br />A recent transportation impact study report (1629 Main Street, TJKM 7/19/16) <br />substantiates this assessment and established an LOS of B in the AM and PM peak <br />hours in all analysis scenarios. Additional recent analysis, the November 2016 Existing <br />Conditions Memorandum #3: Transportation, shows that the intersection currently <br />operates at LOS C during the AM peak hour and LOS B during the PM peak hour, and <br />that the proposed project is projected to add approximately 45 vehicles during peak <br />hours. This will increase impacts at the intersection, but operation will continue to be at <br />acceptable levels (LOS D or better). (See March 15, 2017 Hexagon letter.) <br /> <br />(d) Appellant’s Contention: The City applied improper trip reduction rates to calculate <br />project trip generation. The City should have used results from the “MXD” model <br />based on updated input variables. (Appeal, p. 13.) <br /> <br />City Response: Analysis of traffic conditions and impacts may properly be <br />performed pursuant to various alternative models and methodologies. There is no one <br />model or methodology used universally by the transportation profession, and the City <br />retains discretion to determine how to best perform the analysis. <br /> <br />Using trip generation rates published by the Institute of Transportation Engineers (ITE), <br />is one acceptable approach. These rates are based on data gathered from across the <br />United States. Thus, for example, when evaluating the trips generated by an office <br />building, ITE draws upon data from suburban office parks along with urban buildings <br />and thus will typically overestimate the trips generated by an office building in a dense, <br />mixed-use downtown like Redwood City. <br /> <br />The Mixed-Use Trip Generation (MXD) Model is a newer approach to estimating vehicle <br />trips. The model was developed by the U.S. Environmental Protection Agency (EPA), in <br />collaboration with ITE, using multiple data sources from various regions and whose <br />results were validated with specific projects. It is generally considered to more <br />accurately estimate trips generated by a development in a mixed-use environment. The <br />MXD model has been validated and is being used by multiple agencies throughout the <br />country. <br /> <br />The MXD Model can be used to modify ITE calculations. The Model makes adjustments <br />to ITE’s standard trip generation rates acknowledging that the standard rates are largely <br />based on data from isolated sites that are accessible only by car. More specifically, the <br />MXD Model is used to estimate the internal capture of trips within large (over 5 acre) <br />mixed-use developments as well as walking and transit use for trips starting or ending in <br />mixed-use developments. <br /> <br />The MXD model was used for the DTPP EIR to provide a more accurate estimate of <br />trips generated by Downtown-uses because the area is compact, pedestrian oriented, <br />and has a mix of land uses close to public transit (Caltrain and SamTrans service), <br />shopping, employment, and community services. For the DTPP EIR, ITE’s standard trip <br />generation rates were first used to estimate total trips generated by development within <br />8.A. - Page 19