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Mr. Jonathan Hayes March 15, 2017 Page 2 of 3 by the 1409 Project applicants, and the City did not provide sufficient input as to the scope or methodology used by the by Hexagon Transportation Consultants, Inc. (the "Consultants"). There are severe shortcomings with the Developer Traffic Study. What's worse than the glaring deficiencies in the Developer Traffic Study is that the City conducted no peer-review of the Developer Traffic Study, nor did it undertake any effort, whatsoever, in analyzing key intersections and traffic impacts in adjacent neighborhoods. ... D. The Developer Traffic Study Omitted Key Intersections. Moreover, the LOS deterioration at key intersections impacted by the 1409 Project has not been studied. We contend that all intersections within a half-mile radius of the Project should be studied, but the most glaring omissions to the misleading traffic "study" are as follows: • El Camino Real (SR 82)/ James: This intersection is hugely relevant to the project. It is the gateway to the closest public transportation hub where a large number of vehicles, pedestrians, and buses coalesce. Sequoia High School is right across the street, and Sequoia Station is on the other side. It is already very dangerous for pedestrians (mainly high school students) to cross El Camino, and it is nearly impossible for cars to make a right hand turn onto El Camino from Sequoia Station/ Caltrain. Since the project assumes that pedestrians will be using Caltrain, it is beyond negligent to omit this intersection. • El Camino Real(SR 82)Whipple: This intersection (and indeed all intersections along Whipple both east and west-bound) will be severely impacted by the 1409 Project. The project will result in major Cut-Through Traffic for vehicles getting to 280 and Alameda de las Pulgas. • El Camino (SR 82)/Roosevelt: This intersection (and indeed all intersections along Whipple both east and west-bound) will be severely impacted by the 1409 Project. The project will result in major Cut-Through Traffic for vehicles getting to 280 and Alameda de las Pulgas.” Response: The intersection of El Camino Real and James Avenue was analyzed in the Downtown Precise Plan DEIR and predicted to operate at level of service (LOS) C or better under all scenarios including cumulative. The proposed project at 1409 El Camino Real would add a very small number of through trips on El Camino Real at this intersection (13 northbound and 1 southbound during the AM peak hour, and 5 northbound and 12 southbound during the PM peak hour), which represents less than 0.5% of the roadway capacity and would cause a less than significant impact. The intersection of El Camino Real and Whipple Avenue was analyzed in the Downtown Precise Plan DEIR and found to have a significant impact under project and cumulative conditions. Physical improvements that would mitigate the impact would require acquiring additional right of way and Caltrans approval, so the impact was considered unavoidable. The proposed development at 1409 El Camino Real is expected to add nearly the same number of trips at the El Camino/Whipple intersection as at the El Camino/James intersection. Therefore, the project by itself would have a less than significant impact. In addition, this intersection was counted in November, 2014 for the 150 El Camino Real and 20 Avondale Avenue Traffic Study Report. The intersection was found to operate at LOS D or better during the peak hours in that study, which is better than the existing (2010) level 8.A. - Page 123