AgdaPkt 2017-09-11 Closed and Joint SA PFA

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POWLAN CASSIDY LAW 7.A. - Page 189 November 1, 2016 Page 2 As a starting point, we note that, while the MND states that mitigations have been incorporated into the Project and agreed to by the Project sponsor, no evidence of this assertion is presented in the MND. Moreover, much of the analysis in the MND simply cites various laws and regulations that purport to reduce impacts of the Project to a less than significant level. This analysis has at least two flaws: First, the analysis should lead to mitigation measures to be imposed on the Project flowing from the analysis leading to that conclusion, and the mitigation measures must be made conditions of approval of the Project. With respect to the analysis of the MND, the most serious flaw relates to traffic and parking. First, the baseline is flawed: The trips which were part of the now vacant warehouse are not properly "removed" from the traffic impact analysis. The baseline should assume a vacant building. Second, the analysis of traffic attributable to school trips both a.m. and p.m. understates the impacts of traffic volumes, drop offs by parents and parking, both on-site and off- site. Charter Street and surrounding streets are already significantly traffic impacted. The added traffic from student drop offs, and the resultant ingress and egress issues, present significant impacts that have not been mitigated. The notion that school staff can manage these impacts is not supported by any evidence, nor is there any evidence that staff are qualified to perform these functions. Also, the Project presents no plan for blocking the business driveways on Bay Road and Charter Street during parent drop offs. The MND also uses observations in the field rather than actual traffic counts, and also is based in part on conditions at other schools without any evidence of comparability. Finally, the analysis dismisses the safety issue presented by the limited access for large fire trucks, again relying on staff to manage in the event of a fire, a task for which they are not trained. The MND also fails to take into account cumulative traffic impacts: For instance, the MND does not mention or analyze the impact of the Stanford Outpatient Center parking lot adjacent to the Project, with parking for 278 employees, additional valet parking, and a shuttle service at 5 minute intervals during peak hours, and uses a demonstrably low cumulative growth for traffic. The analysis of parking impacts is also deficient. Parking is discussed "for infornational purposes only." Yet the area in which the Project is located is already overparked. On-site parking is not sufficient for staff. And parents coming to the school for meeting or events will further contribute to parking impacts. The analysis of air quality impacts and greenhouse gas emissions is also flawed because of the deficiencies in the traffic analysis. Clearly, idling cars will have an adverse effect on air quality, which appears understated, as well as contribute significantly to greenhouse gas emissions. Noise impacts also appear to be understated based on the traffic analysis. Moreover, the playground noise may become a nuisance to adjoining property owners. Finally, since the school will be directly under the instrument approach to San Carlos Airport, the noise analysis fails to account for the noise impacts of aircraft, a matter of some controversy because of, among other issues,use of the airport by Surf Air.