HomeMy WebLinkAbout7.3 BART Dublin/Pleasanton Extension AGENDA STATEMENT
CITY COUNCIL MEETING DATE: October 30, 1989
REPORT PREPARED BY: Laurence L. Tong, Planning Director
SUBJECT: Review of City of Dublin comments on Draft EIR
for BART Dublin/Pleasanton Extension Project
EXHIBITS ATTACHED: Exhibit A: Letter to BART dated October 23,
1989 with attachments from TJKM and Meyers,
Nave, Riback & West
RECOMMENDATION: i) Provide any additions or revisions to the
�/ 1 comments
FINANCIAL STATEMENT: None
DESCRIPTION:
At the Council meeting of October 9, 1989, the Council directed Staff to
complete its analysis of the Draft Environmental Impact Report (DEIR) for the
BART Dublin/Pleasanton Extension Project and provide the comments to BART by
October 23, 1989. Staff completed its analysis and provided the attached
comments to BART on October 23, 1989.
The comments include, but are not limited to the following concerns with
the DEIR:
- The need to consider only existing or funded freeway improvements,
rather than assuming that the I-580/I-680 interchange and downtown
Dublin connections are completed and operational.
- The need for additional analysis of traffic impacts and mitigation
measures on the Dublin Boulevard/San Ramon Road intersection.
- The need to consider updated information regarding downtown Dublin
street improvements and the "new" street south of Dublin Boulevard as
a mitigation measure.
- The need for a parking structure in downtown Dublin to avoid the
displacement of existing Dublin businesses.
- The need to consider that the Hacienda Drive extension north of Dublin
Boulevard extension is not on the Dublin General Plan and that traffic
volumes on Dougherty Road are understated.
It would be appropriate for the Council to review the comments and
provide any needed additions or revisions.
ITEM NO. 7. 3 COPIES TO: Planning File
Development Services Building & Safety 829-0822
Dublin, CA 94568
P.O. Box 2340 Er, " :'ering/Public Works 829-4927
� '
October 23, 1989
Marianne A. Payne
Dublin/Pleasanton Extension Project
Bay Area Rapid Transit District
P. 0. Box 12688
Oakland, CA 94604-2688
Re: Comments on Draft EIR for Dublin/Pleasanton Extension Project
Dear Marianne:
Thank you for giving the City of Dublin the opportunity to review and comment
on the Draft Environmental Impact Report (DEIR) for the Dublin/Pleasanton
Extension Project. The City Staff has reviewed the document and has found it
to be complete and adequate with the exception of the comments identified in
this letter and in the attachments.
1. The DEIR needs to consider a parking structure in Dublin for the West
Dublin/Pleasanton Station to avoid the significant impacts of
acquisition and displacement of existing Dublin businesses. Section
2.3.4 Project Description (page 2-23, 2-26) indicates the need for 1800
parking spaces in Dublin and 1800 parking spaces in Pleasanton. The
proposed project calls for surface parking in Dublin, but because of
limited space, a parking structure is proposed in Pleasanton._ Section
4.2.3 Socioeconomic and Land Use (page 4-43, 4-44) , needs to consider a
parking structure in Dublin to mitigate or avoid the significant impacts
caused by business displacement in Dublin.
2. Ridership forecasts need to be more fully and adequately explained.
(See attached TJKM letter dated October 18, 1989, comment #1) .
3. The DEIR needs to analyze an additional alternative that considers only
existing or funded freeway improvements. (See TJKM attachment, comment
#3) .
4. Additional analysis of the traffic impact on the Dublin Boulevard/San
Ramon Road intersection is needed. (See TJKM attachment, comment #4) .
5. The DEIR needs to recognize and consider that the Hacienda Drive
extension north of Dublin Boulevard extension is not indicated on the
Dublin General Plan, and that the traffic volumes on Dougherty Road are
understated. (See TJKM attachment, comment #7) .
6. The DEIR needs to consider the up to date anticipated street improvement
in downtown Dublin. (See TJKM attachment, comment #8, and attached
' Meyers, Nave, Riback & West letter dated October 20, 1989, major concern
#4) .
7. Additional analysis of parking space demand is needed. (See TJKM
attachment, comment #9) .
gla
5
8. The DEIR needs to analyze other potential business displacements and
public property acquisitions in Dublin including the potential need to
acquire property from the Dublin Civic Center, Sports Grounds and
private businesses. (See TJKM attachment, comment #11) .
9. The project description needs to be clarified. (See Meyers, Nave,
Riback & West attachment, major concern #1) .
10. The alternatives need additional analysis. The analysis of the "No
Project" alternative needs to compare the proposed project to what is
now existing in the proje.et area. (See Meyers, Nave, Riback & West
attachment, major concern #2) .
11. The cumulative effects need additional analysis. (See Meyers, Nave
Riback & West attachment, major concern #3) .
12. Figure 2.7 (page 2-25) does not accurately show the proposed Dublin
Parking lot for the West Dublin/Pleasanton Station Area. It needs to
show the proposed 17 acre parking lot and the impact on existing Dublin
businesses.
13. Section 5.2.1 Three-Station Alternative Transportation (page 5-18) -
"Therefore, Alternative 2 would be capable of eliminating significant
impacts associated with the proposed project which cannot be mitigated" .
The DEIR needs to be clarified. Would operations at the Regional
Street/Dublin Boulevard intersection (LOS E) be considered a significant
impact?
14. Section 5.2.2 Three-Station Alternative Socioeconomic and Land Use (page
5-20) corrections are needed. The proposed parking site is outside of
the East Dublin Specific Plan Study Area. The county-owned parcel is
within Dublin City Limits.
15. Other comments: See TJKM attachment, comments #2, 5, 6, 10, 12, 13 and
Meyers, Nave, Riback & West attachment, minor comments #1 to 12.
The comments presented in this letter, along with the attachments from TJKM
and Meyers, Nave, Riback & West are official City of Dublin comments on the
DEIR for the Dublin/Pleasanton Extension Project. The City Staff would be
happy to discuss these items with you at our scheduled meeting on October 24,
1989.
Sincerely,
• V
Laurence L. Tong,
Planning Director
LLT/df
Attachments
cc:. City Council Members
Richard Ambrose, City Manager .
Libby Silver, Assistant City Attorney
Lee Thompson, Public Works Director
Chris Kinzel, TJKM
- 2
• RECEIVED
'M MEMORANDUM OCT 1 9 1989
DUBUN PLANNING
DATE: October 18, 1989
TO: Larry Tong,Planning Director
FROM: Chris Kinzel
SUBJECT: Review of BART DEIR
At your request, we have reviewed the traffic aspects of the Draft Environmental
• Impact Report for the BART Dublin/Pleasanton Extension Project. We obtained
from the BART staff a copy of the Transportation Draft Technical Report prepared
by Barton-Aschman Associates, Inc. That report, which forms the technical
transportation input for the Draft Environmental Impact Report (DEIR), was the
focus of most of our reviews. Our review concentrated on the two potential stations
in Dublin. We have identified a series of comments and observations on the DEIR:
1. There is not a lot of information given on the ridership forecasts; the
patronage data seems to be a "given" in the DEIR and not subject to
question or scrutiny. These forecasts are the central data in analysis of
both traffic and parking impacts at and near the stations and,
therefore, are of great significance concerning impacts and mitigation
requirements. We understand newer forecasts are being prepared.
What effect will they have on the data in the DEIR?
One specific area of concern is that the forecasts predict seven times as .
many a.m. outbound passengers in 2005 as inbound, even though most
trends indicate that early in the twenty-first century there will be more
inbound employment oriented trips to the Tri-Valley area than
outbound employment oriented trips; the peak direction of the freeways
serving the Tri-Valley will actually reverse. Some explanation of the
• forecast methodology could clear up this apparent inconsistency or
result in changed forecasts.
2. The "service area" of the Dublin station(s) is not indicated. Of
particular interest is the north boundary of the service area, which
would tend to define the boundary between the Walnut Creek BART
station area and the West Dublin station area.
3. The freeway. network assumptions for the study appear overly •
optimistic. The DEIR states that even though Measure B is funding
only one flyover at the I-580/1-680 interchange, the full improvements
of the interchange are assumed to be completed and in place by 1997.
4637 Chabot Drive,Suite 214, Pleasanton,California 94566•(415)463-0611
PLEASANTON•SACRAMENTO•FRESNO•CONCORD
1
Larry Tong, Planning .ector -2- October 19, 1989
Even though this improvement is highly desirable, it seems unlikely
that the massive funding required for this interchange completion will
be available by the early 1990's, which would be required for a 1997
construction completion.
The significance of this to Dublin is that the new I-580/1-680
interchange will both allow and require a new interchange between
I-680 and central Dublin(near Dublin Boulevard) to replace the current
access to San Ramon Road from I-580 which would be eliminated by the
full improvements of the I-680/1-580 interchange. With the new access
to I-680, traffic patterns will be drastically changed near central
Dublin. Again, this new connection is highly desirable from a traffic
standpoint but has not received approval of the City of Dublin, there is
no freeway agreement between Caltrans and the City of Dublin and the
Federal Highway Administration has not approved this new connection
to I-680. Each of these needed steps is significant; it is, therefore,
suggested that an additional and alternative set of analyses should be
made which include a network consisting of only existing or funded
freeway improvements.
4. By making the assumptions described in Point 3 above, the DEIR has
significantly understated the impacts on one of Dublin's key
intersections: Dublin Boulevard and San Ramon Road. The new I-680
interchange would have a very beneficial impact to this intersection, as
much as one full service level, according to the DEIR. This and other
intersections should be evaluated both with and without the effects of
the new interchange.
5. Even though the DEIR states that the interchange improvements will
be in place by 1997, the intersection calculations seem to assume the
beneficial effects of the new I-680 interchange in the 1995 analyses.
•
6. There are some factual misstatements in the Technical Appendix. On
page 2-19 it states that San Ramon Road is four to six lanes in Dublin,
whereas some of it is only two lanes. Also, the Stoneridge Drive •
interchange (page 2-20) is a partial clover leaf(par-do), not a diamond.
On page 2-22 Dougherty Road is stated to be four lanes within the
"BART study area". Not all of Dougherty Road in Dublin is four lanes
at the present time, and essentially no portion of Dougherty Road in
southern San Ramon is currently four lanes.
7. The traffic analyses assume the extension of Hacienda Drive north of
Dublin Boulevard extension. The Hacienda Drive extension into the
City of San Ramon is not indicated on either the City of Dublin's or the
City of San Ramon's General Plan. Although this extension would be
very useful from a traffic standpoint, until this plan receives official
approval, it should only be considered as an alternative. The inclusion
of the Hacienda Drive extension results in an understatement of traffic
volumes on Dougherty Road between I-580 and San Ramon. Of
particular emphasis is the intersection of Dublin Boulevard and
Larry Tong,Plan iin;-'rector -3- October 19, 1989
Dougherty Road, whose traffic volumes and levels of service may not be
accurately stated by the DEIR due to the Hacienda Drive extension
assumption.
8. The DEIR is not current on anticipated street improvements in central
Dublin: 1)The City has adopted a plan line for Dublin Boulevard in the
vicinity of the BART station which calls for six through lanes, not four
as indicated in the DEIR. The widening has been contemplated, in
part, to accommodate BART station area traffic increases. 2) The
Dublin Boulevard/San Ramon Road intersection is not constructed to its
ultimate configuration. Again,partly due to the new BART traffic, the
City has adopted a plan line which results in a triple westbound left-
turn lane and other improvements. These improvements should be
incorporated into the mitigation section. 3) The "new" street south of
Dublin Boulevard is assumed to be in place even though it is primarily
planned to serve the BART area and is expected to be partially funded
by BART. It should be considered as a mitigation measure, not a
"given".
9. The basis for the estimation of parking space requirements is not given.
Is the full demand for parking expected to be served? When the
original BART system was planned and built, only approximately
50 percent of the forecasted demand was served by constructed parking
lots, due to financial limitations. As a result, undersupply of parking at
stations has constituted the major impact of BART on local
communities. Information on BART's intention on meeting parking
demand would be in order.
10. The DEIR indicates several visuals of how the station areas would
appear after the BART development. One additional area that should
be addressed is the view of the West Dublin station from the I-580
freeway. In the existing BART operations,it is somewhat unusual to
have an at-grade station served by overhead pedestrian access
facilities, both from an operations and a visual standpoint: In addition,
in this same area the future ramps and flyovers serving the ultimate
I-580/1-680 interchange will potentially affect the station and its design.
11. The widening of I-580 east of San Ramon Road/Foothill Road to
accommodate BART in the median is described in concept but no
indication of specific right of way impacts is included in the DEIR. Will
Scarlett Court and the businesses along it need to be relocated? Also,
doesn't the southbound overcrossing of I-580 at Hopyard/Dougherty
Roads need to be replaced to allow for the BART line and the future
widening of I-580? If so, what effect will this have on Dougherty Road
in the section between I-580 and Dublin Boulevard?
12. The DEIR assumes the existence of streets near the East Dublin station
(Dublin extension and Hacienda Drive). These streets may or may not
exist (in their initial or ultimate stages) at the time that a BART
station is developed. The report seems to assume no land development
will have occurred near the East Dublin station. If this is true, then the
Larry Tong, Plannin__ [rector -4- October 19, 1989
streets would probably not be in existence. It appears that if the streets
are assumed then the existence of some development in the area could
also be a logical conclusion. Additional details in this area would be
helpful.
13. Site plans or conceptual site plans for the stations are not included in
the DEER. This level of detail is necessary in order to determine
specific traffic and land use impacts near the station areas.
Please contact me if I can provide additional information.
rhm
157-001
•
MEYERS, NAVE, RIBACK & WRST
MICHAEL R.NAVE A PROFESSIONAL LAW CORPORATION PENINSULA OFFICE
STEVEN R.MEYERS R I.C" I I V E D 25o HOWARD AVE.,SUITE 250
NATALIE E.WEST GATEWAY PLAZA
BURLINGAME.CA 94010-4211
777 DAVIS STREET,SUITE 300 (415)346-7130
ELIZABETH H.SILVER c
MICHAEL S.RI SACK SAN LEANORO.CALIFORNIA 94577 OCT- 2 3 1989 FAX(415)342-0888
MOLLY T.TAMI (415)351-4300
ANNE E.MUDGE FAX(415)351-4451 MARIN OFPICE
MICHAEL F.RODRIQUEZ DUBUN PLANNING=GRANT AVE.,SUITE E
OF COUNSEL MEMORANDUM N (415)892-A 8878 9494E.2-887846
THOMAS F.BERT RAND
REPLY TO:
San Leandro
•
TO: Richard Ambrose, City Manager DATE: October 23, 1989
Laurence Tong, Planning Director
Lee Thompson, City Engineer
FROM: Elizabeth H. Silver, Assistant City Attorney
Kathleen Faubion
RE: Draft EIR for BART Extension
We have reviewed the Draft Environmental Impact Report
(DEIR) for the Dublin/Pleasanton extension of BART. The
following comments are submitted for your use and should be
consolidated with other city comments when responding to BART.
Four major concerns emerged from our review, however a number of
minor concerns are also listed.
•
MI(AJOR CONCERNS
1. The alternatives discussion on pp. 3-1 through 9
raise the question of whether the project description should
include extension of the BART line to Livermore. The "Planning
History" section beginning on p. 3-1 refers repeatedly to a -
Livermore terminus, however the project as described terminates
at Dublin and/or Pleasanton. without any explicit explanation,
it appears that the ultimate project has improperly been broken
up into components.
2 . It appears that the "No Project" alternative has
been improperly defined and analyzed in the DEIR. The proposed
"No Project" alternative assumes that the BART extension is not
built, however it also assumes that other development will occur
at the project sites. (See, e.g. , p. 4-3, 4-17. ) While an
analysis of cumulative effects should consider possible and
likely future development, the "No Project" alternative should .
compare the proposed project to what is existing in the project
•
TO: Richard Ambrose, Laurence Tong, Lee Thompson
FROM: Elizabeth H. Silver, Kathleen Faubion
RE: Draft EIR for BART Extension
DATE: October 23, 1989
PAGE: 2
area now. Remy and Thomas, Guide to the California Environmental
Quality Act, 1989 edition, p. 205, 206.
The alternatives discussion is inadequate in two
other respects, as well, First, section 3 of the DEIR describes
alternate corridors and station locations considered throughout
the project's planning history, legal requirements for alternate
sites analysis are currently in flux. A preliminary reading of
the ens of Goleta - e v. Board • v sors 89 Daily
Journal D.A.R. 11920, September 22 , 1989, indicates that the
current alternate sites discussion may not be as extensive as
required. At the least, BART's decisions to reject other route
and station options would have to be better explained rather than
simply noted, as on p. 3-1.
Second, in P.R.C. section 21002, CEQA states that
proposed projects should not be approved if feasible alternatives
would substantially lessen the project's significant impacts.
CEQA Guidelines sections 15091(a) (3) and 15092 (b) (2) require that
approval of projects with significant environmental effects be
supported by findings that project alternatives which would
substantially reduce significant effects are infeasible. The
DEIR's section 5 summaries of Alternatives 2 and 3 indicate that
these alternatives would improve significant traffic and business
relocation impacts associated with the West Dublin station.
Neither the section 3 description of alternatives nor the
section 5 analysis of alternatives adequately explains why the
preferred project was chosen over apparently less adverse
alternatives.
3. The DEIR analysis of cumulative effects is
inadequate. The cumulative analysis must include existing,
approved and other reasonably anticipated projects in the project
area. Discussion of future traffic conditions on p. 4-14, 4-20,
21 does not disclose how traffic projections were calculated. It
is not clear whether the projections include some major approved
and pending projects in the Dublin area. For example, the City
is currently processing the West Dublin General Plan Amendment
Study and the East Dublin General Plan Amendment Study, both of
which would generate considerable traffic. Other general plan
amendments have recently been approved (i.e. , hansen Hill) .
After consulting with City staff to determine relevant pending
and approved projects, the DEIR should list the projects that
contribute to the cumulative effects; should summarize each
project's individual effects; and should analyze the cumulative
TO: Richard Ambrose, Laurence Tong, Lee Thompson
PROM: Elizabeth H. Silver, Kathleen Faubion
RE: Draft EIR for BART Extension
DATE: October 23, 1989
PAGE: 3
impacts and propose appropriate mitigation. Remy and Thomas,
p. 214, 15.
This same, concern applies to all topics for which
cumulative impacts are identified air quality, etc.
4. Although road widening is proposed to mitigate
other traffic effects, Impact and Mitigation 1 on p. 4-29 does
not propose widening for the significant effects at the
Dublin/San Ramon intersection. While the fact that the
intersection is built out may make widening more costly, it does
not appear to be any more impractical or infeasible than the
widening and acquisitions proposed elsewhere in the project
description and mitigation.
MINOR C9Np$ me
1. Page 1-5 should specifically identify the local
communities and agencies which will rely on the EIR for decision
making. If known, a list of approvals for which the document
will be used should be presented. Remy and Thomas, p. 182.
2. It is not clear whether the first and second set
of pocket tracks east of Castro Valley will also be in the 1-580
median. If not, additional description of location and proposed
improvements should be provided. The project description should
note if any extraordinary grading will be required for the
tunneling, widening, embankments, etc.
3. The air quality impacts analysis beginning on
p. 4-78 mentions congested intersections as a source of emissions
leading to increased carbon monoxide (CO) concentrations. Tables
4-9 and 4-10, however, focus on the station areas. It is not
clear from the discussion whether localized effects at congested
intersections like Dublin/San Ramon have been analyzed.
4. Where construction or other features which affect
the impacts analysis are not included in the project description,
they should be included as mitigation. For example, neither the
continuous-welded rail on p. 4-69 nor the concrete barriers on p.
4-95 appears in the project description. Since they appear to be
critical features in their relative analyses, they should be
proposed as mitigation.
TO: Richard Ambrose, Laurence Tong, Lee Thompson
FROM: Elizabeth H. Silver, Kathleen Faubion
RE: Draft EIR for BART Extension
DATE: October 23, 1989
PAGE: 4
5. The public services mitigations on p. 4-53, 54
should eventually be presented in list form to ensure that they
appear in the mitigation program. In the current format, it is
possible that mitigation such as clarifying the limits of BART
property could inadvertently be left out of the mitigation
program. This same concern applies wherever mitigation is not
plainly listed.
6. Only feasible mitigation is acceptable for
reducing the significance of impacts. It is not clear that all
of the mitigation proposed is feasible. Particular mitigations
of concern are listed below.
a. Widening and an alternative mitigation are
proposed at southbound 1-680/Stoneridge. It is not clear from
the discussion on p. 4-29, 30 that either is feasible. The
background text on p. 4-14 is also not clear whether the
"upgraded" interchange discussed is the same as the new
Stoneridge intersection which appears to be the subject of this
mitigation. The background text further clouds the feasibility
of the mitigation, for although CalTrans apparently expects to
Complete the interchange, unsupported and unfunded hopes are not
sufficient to serve as feasible mitigation.
b. No alternative mitigation is proposed on p.
4-54 in case the sewer moratorium occurs and BART is not
exempted. If BART has already inquired about an exemption and
has a reasonable expectation of receiving it, that fact should be
noted.
a. Where mitigation anticipates future study,
e.g. , noise mitigation, geotechnical reports (p. 4-93) , site
assessments for hazardous materials (p. 4-98) , the DEIR must
reasonably reflect that the future studies are simply a matter of
updating and refining impacts and mitigation. Critical analysis
cannot be put off to later review of particular aspects of a
project.
d. The effects of proposed mitigation must be
considered in a DEIR. Do the detention basins suggested on p. 4-
111 present any safety concerns since they would be located in
the station area?
•. Special rules apply to archeological
resources according to the CEQA Guidelines. The mitigation noted
TO: Richard Ambrose, Laurence Tong, Lee Thompson
FROM: Elizabeth H. Silver, Kathleen Faubion
RE: Draft EIR for BART Extension
DATE: October 23, 1989
PAGE: 5
on p. 4-122 should include specific reference to and/or a summary
of the Guidelines' Appendix K rules.
7. It is not clear to the non-technical reader where
the sound barriers in Table 4-7 will be.
8. The Alternative 2, East Dublin-Third Station
summary on p. S-13 notes that no unavoidable significant impacts
would occur with that alternative. It is not clear why the air
quality impacts for the proposed Dublin station are
unavoidable and significant but the impacts are less for an
additional station.
9. Do BART's seismic design criteria (p. 4-93) meet
all current State and other applicable standards? BART'S seismic
design standards and the proposed project should be carefully
evaluated in light of whatever relevant information becomes
available in the aftermath of the October 17, 1989 earthquake.
10. Mitigations are proposed at the top of p. 5-20 to
improve intersection LOS for north side parking at an East Dublin
station. The DEIR should clarify "improve", i.e. whether these
measures will mitigate impacts to LOS D or better.
ii. The DEIR identifies joint development alternatives
in section 3. Request confirmation that the sketchy scenarios in
sections 3 and 5 are not intended as full environmental
assessments should these alternatives be proposed as projects.
Further study and assessment under CEQA will be required as noted
on p. 5-45.
12. The DEIR discussed certain impacts which it
determines to be not significant, e.g. , cultural resources. If
any other potentially significant impacts were determined not to
be significant and were not discussed in the document, a copy of
the initial study for the project should be included in the DEIR.
TO: Richard Ambrose, Laurence Tong, Lee Thompson
FROM: Elizabeth H. Silver, Kathleen Faubion
RE: Draft EIR for BART Extension
DATE: October 23, 1989
PAGE: 6
If you have any questions on these comments or on any of the
DEIR material, please give me a call..
MEYERS, NAVE, RIBACK & WEST
r
Elizabeth H. Silver
EHS:KTT:dlg
114\MEMO\AMSROSE.MKF