AgdaPkt 2020-11-09 Joint SA PFA - Laserfiche WebLink

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Ms. Lindy Chan, Principal Planner City of Redwood City, Planning Services July 13, 2020 Page 12 With regard to cumulative traffic impacts, the Draft EIR simply concludes that the "proposed project would result in a decrease per capita VMT in Redwood City," and so would pose less than significant cumulative impacts. (Draft EIR at 3.5-28.) The Draft EIR fails, however, to analyze whether the proposed Project, when viewed in conjunction with the numerous other projects in the City, could pose traffic impacts not related to VMT, including impacts related to traffic congestion and pedestrian safety. As noted in the Prior Comment Letters, the Project's anticipated traffic and safety impacts on the District, combined with the anticipated impacts of the vast number of development projects that have recently been approved in the area, are cumulatively considerable. All of these impacts are exacerbated by the rapidity at which the City is approving development projects in the area, as the District and City are unable to accommodate the massive influx of students through facilities, infrastructure, and related improvements. The traffic impacts of the Project must be analyzed in conjunction with the anticipated impacts of all the other development being considered and approved in this area. ii. Noise Despite identifying noise impacts as one of the topics to be analyzed in the Project EIR, the Draft EIR fails to consider noise impacts. The District strongly objects to this disregard of noise impacts. The City's disregard of noise impacts is based on its Initial Study which assumes (1) that only 291 residential units would be constructed as part of the Project (see, Initial Study at 4.13-11) (along with the associated lower traffic estimates), and (2) the District's Sequoia High School is located 1.5 miles away from the proposed Project. Presumably under the above assumption, the City does not list Sequoia High School as a "sensitive receptor" near the Project site. All of these assumptions are incorrect. While the City purports to analyze the updated Project's anticipated noise impacts in Chapter 6 of the Draft EIR (p. 6.6), this analysis contains no analysis or quantifiable data that would allow the public and lead agency to understand the noise impacts of the proposed, updated Project. It is, therefore, insufficient for purposes of CEQA. Further, the noise analysis contained in the Draft EIR and the Initial Study does not specifically consider whether noise and/or vibration generated from construction and operation of the Project will cause significant impacts on the District's educational program at Sequoia High School. Noise impacts could disrupt classes, prevent students from being able to be outside due to overwhelming outside noise that would affect teachers' abilities to monitor and direct students because they cannot be heard, and lastly, could affect the interior of buildings students are housed in. For these reasons, the District requested that the following information be discussed and analyzed in the Draft EIR: 19. Any noise sources and volumes which may affect school facilities, classrooms, and outdoor school areas. Because this information was not included, the Draft EIR fails to serve its informational purpose.