Jobs-Housing Balance and Traffic (Page 162-163)

The analysis of jobs-housing balance is flawed in that it does not address the balance according to income levels. The proposed Project will generate high-priced housing that will be affordable to a small percentage of Alameda?s residents, and a large number of lower income workers that will compete for the dwindling number of affordable residential units. In order for the discussion of jobs-housing imbalance to fulfill its purpose of informing the discussion of traffic impacts (see EIR page 157), the discussion of imbalances needs to be disaggragated by income levels. (Note that work done for the City of Alameda planning Department on the "Economic Development Strategic Plan" provides recent data on income levels, rental rates and home sales prices for Alameda, broken down as West End, Central Alameda, and Harbor Bay Island.) In addition, the discussion does not address the City?s powers as the landowner to use covenants attached to the property to encourage employers to hire local residents.

Additional Analysis Required: Reanalyze jobs-housing balance with information on income levels.

Trip Distribution (Page 263)

On page 162 and other locations, the EIR states that 9% of the Project's 4,600 job holders will reside in Alameda, and 4,190 will reside elsewhere. This analysis assumes that patterns of trip destinations and residential choice that prevailed when the military base was open will apply to the people that work and live in the Project. However, over the past few years, housing prices in Alameda have increased dramatically, displacing lower income renters. In turn, this has caused the employment locations of Alameda residents to change, and the residential locations of Alameda employees to change as well. This EIR should evaluate the income levels associated with the 4600 jobs created by the project and income levels needed to purchase the 500 market rate houses, and use that data to project trip distributions, rather than relying on older patterns that existed when the project site and NAS Alameda where in military use.

Additional Analysis Required: Revise assumptions based on current information about income levels and employee wages.

Parking Assumptions Inconsistent with Trip Generation Assumptions

Catellus is proposing to provide 50% more parking for Office and R&D uses than recommended by ITE (the industry standard). (page268) This is, in itself a problem for a Project that does not live within its traffic budget since the availability of excess parking will encourage single occupancy vehicle trips.

It is also a problem because the trip generation rates used (page 264) to calculate traffic impacts are also based on ITE numbers, which presumably rely on their parking numbers.

Additional Analysis Required: Calculate the impact of the increased parking. Consider a mitigation to reduce parking below the ITE levels.

Mitigation Measure T/C-1 (Page 273)

The mitigation for construction-period road closures in Alameda and Oakland, including Route 260, is for Alameda Public Works to approve the Traffic Control plan (TCP) prior to issuance of any building or grading permit. The TCP also should be submitted to Oakland and Caltrans for approval prior to issuance of permits.

Correction Required: Include responsible agency approval of mitigations.

Ensure physical feasibility of intersection improvements

Mitigation Measures that entail adding lanes at intersections: Several mitigation measures entail adding lanes at existing intersections, but in certain cases adequate right-of-way for the additional lane(s) does not appear to be available. These mitigations are not feasible for adequate right-of-way does not exist. The EIR should clearly state whether adequate right-of-way exists for the following:

• T/C-6: EB Atlantic at Webster, add left turn and right turn lane; NB Webster, add left turn lane.
  
• T/C-8 and T/C-15: NB Jackson at 6th, add left turn lane.
  
• T/C-10: SB Jackson at 5th, add left turn lane.
  
• T/C-12: NB Central and 8th, add a through lane.
  
• T/C-13: EB Main at Pacific, add a right turn lane, and NB Main, ad separate turn lanes.
  
• T/C-16: NB Oak St at 5th, add right turn lane.

Additional information Required: Provide requested information and adjust mitigations as necessary.

Mitigation Measure T/C-9 (Harrison/7th) (Page 286)

On page 277, the EIR shows over 100 seconds of delay at the intersection of Harrison and 7th Street, at the north end of the Posey Tube. The mitigation measure is to grade-separate the intersection by depressing the two right turn lanes and providing an at-grade pedestrian overpass. This measure would be costly, and no funding source is identified. Unless a funding source can be demonstrated, this measure should be deemed infeasible and removed from the EIR.

Additional information Required: Determine the approximate cost and source of funds for this mitigation so that it can be determined if it is realistic.

Mitigation Measure T/C-17 (Broadway/5th) (Page 293)

Page 279 shows over 250 seconds of delay at this intersection even after all mitigation measures in the Reuse EIR are assumed to be implemented, and therefore proposes reconstruction of the interchange between I-880 and Broadway/Jackson. This measure would be extremely costly, and no funding source is identified. Unless a funding source can be demonstrated, this measure should be deemed infeasible and removed from the EIR.

Additional information Required: Determine the approximate cost and source of funds for this mitigation so that it can be determined if it is realistic.

Mitigation Measure T/C-19 (TSM) (Page 299)

Despite all other mitigation measures proposed in the EIR, by the year 2020 congestion occurs on Route 260 and 4 local road segments, so an additional mitigation measure of a TSM Program is recommended. The placement of this measure at the end of the analysis implies it is a last resort. In the Final EIR, this measure should be the first mitigation measure identified, in keeping with its status as an adopted City Ordinance. One of the seven components of this mitigation measure is that "Employers could be encouraged to hire local residents and create incentive programs to attract local residents." As the land owner for the property, the City could attachment covenants to the sale of the land to ensure that employers do undertake these efforts, and to establish economic penalties if performance targets aren't met (i.e., the elimination of 290 peak hour trips at Webster Tube cited on page 300).

Correction Required: Reorganize mitigations to prioritize this mitigation, and strengthen by incorporating programs in the DDA.

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Cover Letter - Project Alternative - Analysis Failures - Deferred Mitigations
Report Organization - Land Use - Population and Housing - Traffic - Air Quality
Public Services - Noise - Drainage and Hydrology - Hazards

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