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Ms. Lindy Chan, Principal Planner
<br />City of Redwood City, Planning Services
<br />July 13, 2020
<br />Page 11
<br />The Draft EIR is deficient in that it generally fails to analyze safety impacts related to the
<br />addition of thousands of new cars to the roadway system in the Project neighborhood on a daily
<br />basis. CEQA Guideline section 15064.3 sets forth new criteria for the assessment of traffic
<br />impacts, and now encourages (and for EIRs circulated after July 1, 2020, requires) the use of
<br />metrics such as vehicle miles traveled (VMT), rather than level -of -service (LOS), to analyze
<br />project impacts on traffic. However, local agencies may still analyze and consider impacts on
<br />traffic congestion at intersections where appropriate, and must do so where, as here, such traffic
<br />congestion will cause significant impacts on air quality, noise, and safety issues caused by
<br />traffic. (Pub. Res. Code § 21099(b)(3).) Furthermore, lead agencies must still consider impacts
<br />on traffic congestion where required by any programs, plans, ordinances, or policies addressing
<br />the circulation system. (CEQA Guidelines, Appendix G.) Instead of analyzing and addressing
<br />any safety impacts anticipated by the increase in traffic to the area, the Draft EIR states that,
<br />"consistency with City policy related to LOS will be addressed through the proposed project's
<br />planning review process; the proposed project is subject to any resulting COAs [Conditions of
<br />Approval] as a result of that review process..." (Draft EIR at 3.5-21.) This deferred analysis of
<br />LOS impacts related to the increase in traffic congestion is improper, as it fails to provide the
<br />District and lead agency with a sufficient degree of analysis to make an intelligent judgment
<br />concerning the Project's environmental impacts. (CEQA Guidelines §§ 15121(a) and 15151;
<br />see, Madera Oversight Coalition, Inc. v. County of Madera (2011) 199 CA4th 48, 104 [holding
<br />that EIR must disclose information that is indispensable to a reasoned analysis of an issue],
<br />overruled on other grounds in Neighbors for Smart Rail v. Exposition Metro Line Constr.. Auth.
<br />(2013) 57 CA4th 439.)
<br />The Draft EIR likewise glosses over probable impacts caused by the increase in vehicular
<br />congestion on pedestrian use of the Project neighborhood. The Draft EIR notes that there are
<br />several existing deficiencies with pedestrian facilities within and in the vicinity of the Project
<br />site, including "sidewalk gaps, missing curb ramps, ADA non-compliance, and unmarking
<br />crosswalks (or low -visibility crosswalk striping)." (Draft EIR at 3.5-24.) The Draft EIR also
<br />notes that the Project would involve the addition of certain facilities intended to encourage the
<br />use of pedestrian facilities. However, the analysis completely fails to consider how the probable
<br />increase in traffic congestion to the area could exacerbate existing deficiencies with pedestrian
<br />facilities, thereby posing severe safety issues to pedestrian use of the Project neighborhood.
<br />Also, the impact discussion contained under TT -1 of the Draft EIR (beginning on p. 3.5-20) fails,
<br />as it does not provide sufficient information regarding whether the proposed Project complies
<br />with all applicable programs, plans, ordinances, or policies addressing the circulation system,
<br />including the El Camino Real Corridor Plan. As noted in the Draft EIR, this Plan has the
<br />objective to "improve traffic congestion and parking management." (Draft EIR at 3.5-7.) As the
<br />Draft EIR does not adequately address traffic congestion or parking, it is impossible to ascertain
<br />from the Draft EIR whether the Project would comply with this Plan.
<br />Finally, the Draft EIR's cumulative traffic impacts analysis is woefully deficient. As noted
<br />above, EIRs must discuss cumulative impacts of a project when the project's effects on the
<br />environment, viewed in conjunction with impacts of other past, present, or reasonably
<br />foreseeable future projects, is cumulatively considerable. (CEQA Guidelines § 15130(a).) (See,
<br />San Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 CA4th 713, 720.)
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