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March 20, 2000
Julie Caporgno [Sent By FAX:
408-277-3250]
Department of Planning, Building & Code
Enforcement
801 North First Street, Room 400
San Jose, CA 95110-1795
RE: Comments on Draft EIR for
Coyote Valley Research Park
Dear Julie Caporgno:
LandWatch Monterey County would
like to submit the following comments on the Draft
Environmental Impact Report prepared for the
proposed Coyote Valley Research Park:
- We believe that the Draft
EIR is inadequate in its analysis of the adverse
effects that the proposed project would
have--particularly on affected areas not within
the City of San Jose--and that the Draft EIR has
inadequately analyzed responsible and reasonable
alternatives that could eliminate or mitigate
these adverse effects. Specifically, the Draft
EIR does not adequately address the project's
direct and indirect impacts on the regional
environment. The impacts on transportation
systems, air quality, regional housing, and
agricultural land are all significantly
underestimated.
- Traffic impacts were
evaluated by using the City of San Jose's
TRANPLAN traffic model to forecast the
geographic distribution of home-based trips
resulting from the project. This model is not an
appropriate tool for estimating traffic due to
the location of the project at the edge of its
modeling domain and the outdated land uses it
contains. More fundamentally, a four step
network travel model such as the City's does not
incorporate and is therefore insensitive to the
relationship between housing price and employee
housing choice. Housing rental and sale prices
in Santa Clara County are higher than in
equidistant locations to the south in San
Benito, Monterey, and Santa Cruz counties. This
means that workers at the proposed project
location will be expected to commute from these
areas--and this is not accounted for in the
model used.
The TRANPLAN model forecasts that 80% of the
employees would commute north from the project
site and 20% south. To illustrate the role
played by this distribution, if project work
trips were to have been distributed evenly,
i.e., 50% to the north, 30% to south Santa Clara
County and 20% to Monterey, Santa Cruz and San
Benito counties, the project's impact on travel
and housing within the three counties would be
150% greater than projected, i.e., 8,750 ADT and
2,353 residential unit demand in contrast to
3,500 and 941, respectively. Other travel
forecast models with current data or coverage
are available and should be used to prepare a
revised traffic analysis. These models include
the Center for Urban Analysis TRANPLAN model of
Santa Clara County, which covers the entire
County, the MTC model, which uses 1990 census
data, and the AMBAG model, also using 1990
census data and capable of incorporating Santa
Clara County. Unless a new analysis is done,
using a more appropriate model, and one that
redistributes the projected trips more
accurately to reflect the probable commute
patterns to the project site, the EIR will be
legally deficient, since it will not accurately
demonstrate the adverse effects that can be
reasonably expected from the project.
For data on housing price and supply, various
sources are available to determine whether raw
travel model distributions make sense in
relation to the supply of available housing in
the impact area. These include records of land
and housing sales, annual vacancy rates from the
Department of Finance, a traffic impact fee
study being prepared by Hexagon for the San
Benito County Council of Governments, and a jobs
housing balance study being prepared by CCS
Planning and Engineering for ABAG and AMBAG, and
zip codes of residences for current employees in
the vicinity of the site.
Adequate air quality and housing impact analyses
depend on a revised and adequate traffic impact
assessment. Until that is completed, it is
impossible to identify all feasible mitigation
measures. This is a fundamental flaw in the
current Draft EIR.
- The Draft EIR finds that the
project would generate 732 lb/day of reactive
organic gases and 1,271 lb/day of oxides of
nitrogen emissions. This emission increase has
been found to have a significant impact on
regional air quality. Mitigation measures
included in the project would reduce emission
between 5 and 15%, still leaving the impact at a
significant level. Additional feasible
mitigation measures that should be evaluated
include retrofitting stationary sources of air
pollution in the immediate project area,
contributing to the purchase of
alternative-fueled transit and school buses and
retrofitting off-road heavy-duty equipment.
- The DEIR should also find
that the project would have a significant impact
on transport of air pollution to the North
Central Coast Air Basin.
- The indirect impacts of the
project on transportation, air quality, housing,
infrastructure, and agricultural land should be
identified in accordance with CEQA Guidelines
(Section 15126.2). AMBAG has identified the
potential for 15,000 secondary jobs as a result
of the proposed project, which would
significantly affect the regional resources
identified above.
- The Draft EIR says that the
project's growth inducing impacts would be
significant and unavoidable. This is not true. A
mitigation measure requiring the project
proponent to meet the project's housing demand
on site or in a location convenient to the
project site could mitigate most of the adverse
impacts to the point of insignificance. The
alternatives analysis should include the
evaluation of a mixed-use alternative that
combines the proposed project with residential
and commercial development. Such an alternative,
while requiring higher density development,
could accomplish the objectives of the project
while still reducing significant impacts.
- An alternative location
other than the Fremont location should be
evaluated. A project location in the East Bay
could perhaps be more readily accommodated
without the significant impacts the proposed
project would have on prime agricultural land,
open space, traffic, regional air pollution,
noise, loss of trees, visual impacts, and growth
inducement.
Thank you for responding to
these comments, as CEQA requires. Since we believe
that the Draft EIR is basically flawed, as
indicated above, we urge the City to redo this
Draft, to respond to the deficiencies identified,
and then to recirculate a new Draft EIR for further
comment.
Very truly
yours,
Gary A. Patton, Executive
Director
LandWatch Monterey County
cc: Association of Monterey Bay
Area Governments
County of Monterey
City of Salinas
City of Oakland
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