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

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Ms. Lindy Chan, Principal Planner City of Redwood City, Planning Services October 27, 2020 Page 5 i. Traffic/Transportation/Circulation As explained in the District's prior comment letters, the Draft EIR was required to address potential effects related to traffic, including noise, air quality, and any other issues affecting schools. (Pub. Resources Code, §§ 21000, et seq.; Cal. Code Regs., tit. 14, §§ 15000, et seq.; Chawanakee, supra, 196 Cal.AppAth 1016.) Additionally, specifically related to traffic, the Draft EIR was required to analyze safety issues related to traffic impacts, such as reduced pedestrian safety, particularly as to students walking or bicycling to and from Sequoia High School; potentially reduced response times for emergency services and first responders traveling to these schools; and increased potential for accidents due to gridlock during school drop-off and pick up hours. Along these lines, the District requested in its July 13 letter that the Draft EIR analyze six essential categories of information related to existing and the anticipated vehicular traffic in the Project area, student pedestrian movement patterns to and from school sites in the Project area, and school transportation and busing activities to and from Sequoia High School. Rather than addressing the District's requests for additional analysis, the Final EIR asserts that all information and data required by CEQA in order for one to ascertain the Project's potential traffic/transportation impacts on the District and its students were provided in the Draft EIR, the Level of Service Analysis included in the Draft EIR, and the Transportation Analysis technical report included as Appendix TA to the Final EIR. (Final EIR at 3-8.) While these studies provide traffic counts and level of service data (which data shows that certain intersections frequented by District staff and students will become more congested as a result of the Project), neither the Draft EIR nor the Final EIR provides the District, members of the public generally, or the Project decision -makers with adequate information and analysis to conclude whether the Project will pose significant safety impacts to District students, families, and staff related to traffic and transportation. (See, Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts (2017) 3 Cal.5th 497, 516; and Banning Ranch Conservancy v. City of Newport Beach (2017) 2 Cal.5th 918, 941 [standing for the propositions that EIRs must contain good faith, reasoned analysis, and when certain data is key to the analysis of an issue, the data should be summarized in the body of the EIR to ensure that the information is presented in a manner that will adequately inform the public and decision -makers].) The Final EIR also goes to great lengths in explaining how the District's own programs, strategies, and safety measures would reduce any of the Project's safety impacts related to increased traffic and trips to Sequoia High School. (Final EIR at 3-8-3-9 ["the vehicle trips generated by the proposed project would increase traffic volumes in the vicinity of Sequoia High School on Brewster Avenue as students drive to or are picked up/dropped off, but there are existing programs and strategies used by SUHSD to reduce potential safety impacts from these trips"].) The Final EIR's reliance on the District's own programs and strategies as a means to reduce its Project's safety impacts is legally improper and contrary to the purpose of CEQA that lead agencies analyze and adopt feasible, enforceable mitigation measures needed to mitigate significant impacts of its projects. (See, Pub. Res. Code §§ 21002, 21081(a), & 21081.6(b); 14 Cal. Code. Regs. § 15126.4(a)(2).) Finally, through its July 13 letter, the District explained how the Draft EIR's cumulative traffic impacts analysis, by simply concluding that the "proposed project would result in a decrease per