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HomeMy WebLinkAboutAttach 8 FinalSEIRIKEA Project Final Supplemental Environmental Impact Report SCH# 2003092076 Lead Agency: City of Dublin Prepared By: Jerry Haag, Urban Planner February2004 ATTACI-IMENT ~ Table of Contents Introduction ......................................................................................... 2 Clarifications and Modifications to the DSEIR ....................................... 2 Summary of DSEIR Comment Letters ................................................... 3 Annotated Comment Letters and Responses ........................................ 4 Appendix A .......................................................................................... 22 Introduction A Draft Supplemental Environmental Impact Report (DSEIR) dated November 2003 was prepared for this Project and distributed for public review in November 2003 through January 2004. The proposed Project involves the approval of an IKEA retail center in the City of Dublin as well as related amendments to the General Plan and Eastern Dublin Specific Plan, a PD-Planned Development rezoning and related Stage 1 and Stage 2 PD Development Plans, Site Development Review (SDR), a Tentative and Parcel Maps and a Development Agreement. A full description of the proposed Project is contained in the DSEIR document. Under the California Environmental Quality Act (CEQA) and implementing CEQA Guidelines, after completion of the Draft EIR, lead agencies are required to consult with and obtain comments from public agencies and organizations having jurisdiction by law over elements of the Project and to provide the general public with an opportunity to comment on the Draft Supplemental EIR. Lead agencies are also required to respond to substantive comments on environmental issues raised during the EIR review period. As the lead agency for this Project, the City of Dublin held a 45-day public review period between November 19, 2003 and January 2, 2004. This Final EIR document (FEIR) contains all public comments received during the 45- day public review process regarding the DSEIR and the City's responses to those comments. Included within the document is an annotated copy of the comment letter, identifying specific comments, followed by a response to that comment. The FEIR also contains clarifications and minor corrections to information presented in the DEIR as well as revisions to the proposed Project. Clarifications and Modifications to the DEIR The following clarifications and modifications to the DSEIR are incorporated by reference into the DSEIR document. 1. Page 4: Section 6 of the DSEIR is actually "Required CEQA Discussion" rather than References as noted on this page. 2. Page 60: The reference to Table 5 in the traffic study (appended to the DSEIR) should be changed to Table 6 of the traffic study. 3. Page 64: The Hacienda Drive/1-580 Eastbound ramp improvement is anticipated to be funded by local developers on a pro-rata share. 4. As requested by the Alameda County Congestion Management Agency, the discussion text in the Mitigation Measure column corresponding to Supplemental Impact TRA-3 on page 1-3 of the DSEIR is hereby amended to read as follows: "Full mitigation not feasible. Project will be required to pay for its proportionate share of impacts to 1-580 and 1-680, by payment of Tri-Valley Transportation Development (TVTD) Fees to construct planned freeway improvements, including HOV lanes, auxiliary lanes, and interchange improvements. The Project will be required to pay its proportionate share IKEA Final EIR PA 02-034 City of Dublin Page 2 February 2004 toward public transportation improvements to help reduce traffic on the freeways and other roadways in the Tri-Valley area, by payment of the TVTD Fee to fund the West Dublin/Pleasanton BART Station Project." Summary of DSEIR Comment Letters Comment letters were received by the City of Dublin during the 45-day public comment period on the DEIR from the following agencies, organizations and other interested parties. Commenter Federal Agencies None Date State Agencies 2.1 State of California, Office of Planning 1/5/04 and Research 2.2* State of California, Department of 1/08/04 Transportation Local Agencies Dublin San Ramon Services DisWict (DSRSD) Alameda County Congestion Management Agency Alameda County Flood Control and Water Conservation District Zone 7 3.1 3.2 3.3 3.4 12/23/03 12/30/03 12/30/03 City of Livermore Interested Persons/Organizations 4.1 Michael Durkee 12/30/03 *Although this letter was received after the close of the 45-day comment period, it has been responded to in this FEIR. IKEA Final EIR PA 02-034 City of Dublin Page 3 February 2004 Arnold Schwarzenegger Governor STATE OF CALIFORNIA Governor's Office of Planning and Research State Clearinghouse and Planning Unit January 9, 2004 Andy Byde City of Dublin I00 Civic Plaza Dublin, CA 94568 ,~ECEt'¢ED ~IBLIN PLANNING Letter 2.1 Jan Boel Acting Deputy Director Subject: IKEA/ReIail Center Development Project (PA 02-034) SCH#: 2003092076 Dear Andy Byde: The enclosed comment (s) on your Draft EIR was (were) received by the State Clearinghouse after the end of the state review period, which closed on January 2, 2004. We are forwarding these comments to you because they provide information or raise issues that should be addressed in your final environmental document. The California Environmental Quality Act does not require Lead Agencies to respond to late comments. However, we encourage you to incorporate these additional conm~ents into your final environmental document and to consider them prior to taking £mal action on the proposed project. Please contact the State Clearinghouse at (916) 445-0613 if you have any questions concerning the environmental review process. If you have a question regarding the above-named project, please refer to the ten-digit State Clearinghouse number (2003092076) when contacting this office. Sincerely, Senior Planner, State Clearinghouse Enclosures cc: Resources Agency ~ECEIVED .JAN 1 ~ ZOO4 d400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 95812-3044 !"~JJt~LIN PLANNIN (916)445-0613 FAX(916)323-3018 ww-w.opr.ca, gov 01708/04 . 14:50 FAX 5102865513 SYSTEM&REGIONAL PLANNING ~ STATE CLEARINGHO [~001 ~Qp. NIA~BUSINEgS. TRANSPORTATION AND HOUSING AGENCY DEPARTM]ZNT OF TRANSPORTATION 111 GRAND AVENUE p. O. BOX 23660 oAKLAND, CA 94623-0660 PHONE (510) 256-5505 FAX (510) 256-5513 TrY (800) 735-2929 Letter 2.2 ARNOLD SCHWAR~ENEGGEtL Governor Flex your power! energy £fficient ! 3anuary 8, 2004 Mr. Andy Byde City of Dublin 100 Civic Plaza Dublin, CA 94568 dAN 8 20O4 STATE CLEARING HOUSE Ct.~'a. / ALA580780 [-7..-0 q ALA-580-18.82 [ cckq, .SCH2003092076 Dear Mr. Byde: DUBLIN IKEA -DRAFT SUPPLEMENTAL 'ENVIRONMENTAL IMPACT REPORT Thank you for including the California Department of Transportation (Department) in the environmental review process for the Dublin IKEA project. The following commen~s are based on the Draft Supplemental Environmental Impact Repor~ (DSZm). Mitigation 1. Contrary to the DSEIR's assertion that, "Mitigation for impacts to these freeway segments is not feasible since freeway improvements are not under the City of Dublin's jurisdiction", as lead agency the City of Dublin is responsible for all project mitigation, including roadway improvements on state highways. Mitigation should be idenn'fied for any roadway mainline section or intersection with insufficient capacity to maintain an acceptable Level of Service (LOS) with the addition of project-related and/or cumulative traffic. The project's fair share contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should also be 'fully discussed for all proposed mitigation measures. Where additional roadway improvements are not feasible, downsca, ling the project, and phasing project components so that adequate mitigation coincides with each development phase should be explored. See the Transportation-related Mitigation Monitoring and Reporting Guidelines (per Assembly Bill 1807) enclosure that requires lead agencies to submit transportation-related mitigation monitoring 'information to the Department. Page 67. 2.2.1 "Caltra.$ improves mobility across California" 01708/04 14:50 FAX 5102865513 Mr. Andy Byde January 8, 20434 Page 2 SYSTEM&REGIONAL PLANNING ~ STATE CLEARINGHO ~002 Project-related significant and unavoidable camulative impacts to freeway operations, i.e., the Project's contribution to LOS degradation should be clearly identified on Tables 4.3.12, 13. 2.2.2 Trip Generation 1. Since the Dublin IKEA will draw customers from the densely populated South Bay Area, including San Jose, and locations to the east such as Tracy, StOckton and Sacramento as well as serving the immediate area; unless supporting documentation showing a strong basis for assuming that Dublin IKEA will generate 25 percent fewer weekday .trips than the Emeryville store can be provided, project trip generatio'ri'estimates should be adjusted upward to more realistically reflect total project trips. The absence of an IX_lEA store in the fast- growing region between Sacramento and Tracy strongly suggests that demand from this area will be channeled to the Dublin store. Page 60. 2.2.3 2. How well does actual.trip generation from the Emeryville IKEA store correlate to trip generation estimates provided during that project's environmental review? Pass-by Rate Assumptions " Since furniture shopping usually involves transporting bulky items home from the store, as well as considerable lead time for planning that typically. Precedes suer purchases, and given the paucity of data for pass-by rates applicable to furniture stores, pass-by rates for this land use are likely negligible. Further, the Department does not accept pass-by rates in excess of 15 percent without prior consultation and sufficient data to support the esffraated decrease in project trip generation. See the Department's "Guide for the Preparation of Traffic Impact Studies" at the webSite link below. The Guide should be reviewed prior to initiating any traffic analysis affecting state facilities. 'http://www.dot.ea. gov/hq/traffops/developserv/operationalsystems/reports/tisKuide.p d_f 2.2.4 2.2.5 Trip Distribution Project trip distribution should be revised to show the vast majority of project trips accessing the project site 'from Interstate 580 (I-580). For the majority of IKEA customers, 1-580 is the faster and' more efficient route for trips from all directions as few southbound or northbound Interstate 680 (I-680) customers will prefer travelling the slower local streets such as Dublin Boulevard or Las Positas Boulevard with their numerous controlled intersections and conflicting traffic movements. There is no feasible alternative to the site for westbound and eastbound 1-580 customers, page 61. 2.2.6 Level of Service 1. Intersection counts for the existing peak hour traffic volumes and ramp 2.2.7 intersection LOS do not appear to reflect current' conditions. If traffic count data "CaJtra/z~' lntproves mobility across Cal~for~)ia" 01)'08/04 14:50 FAX 5102865513 SYSTEM&REGIONAL PLANNING ~ STATE CLEARINGHO ~003 Mr, Andy Byde January 8,200a Page 3 was obtained prior to ramp metering installation on eastbound 1-580, current counts should be obtained and the data applied to an updated analysis of the intersections. Exhibit 14, Page 81 and Table 4.3.1, Page 70. Downstream effects of LOS F on 1-580 should be discussed. For example, since the 1-580 .segments between 1-680 and Dougherty Road and Tassajara Road to Fallon Road both operate at LOS F, clarify how the segments between these can operate more efficiently at LOS D and LOS E as shown in Table 4.3.13. Page 79. Clarify how the project's contribution of 16,100 Average Dally Trips (ADT), 460 AM peak'hour trips (PHT), 880 PM PHT and. 2,510 Saturday PHT decreases the volume to capacity ratio in some areas. Page 65. Right of Way 1. Of the ten design alternatives for the 1-580 High-Occupancy Vehicle Lane (HOV) project currently under consideration, vm'iation 2.2 represents the worst-case right-of-way (ROW) impact to the IKEA project. The remaining nine alternatives are not expected to impact the project. The HOV project may impact the proposed IKEA project a maximum distance of 12.378 meters from the existing state ROW to the proposed new state ROW. The' enclosed plan shows the approximate area of 2,772 square meters of potential impact to the IKEA project. Final HOV project design has not been determined. See enclosed graphic, estimates and descriptions. 2. Work that encroaches onto the ROW requires an encroachment permit that is issued by 'the Department. To apply, a completed encroachment permit application, environmental documentation, and five (5) sets of plans, clearly indicating State ROW, must be submitted to the address below. Traffic-related mitigation measures will be incorporated into the construction plans during the encroachment permit process. See the following website link for more information: http://www.dot, ca-govPaq/traffops!devel°pserv/permits/ Scan Nozzari, District Office Chief Office of Permits -. California DOT, DisU-ict 4 P.O. Box 23660 Oakland, CA 94623-0660 2.2.8 2.2.9 2.2.10 2.2.11 "Caltrcms improves mobility ac,'os$ Cal~fornia" 01/08/04 14:51 FAX 5102865513 SYSTEM&REGIONAL PLANNING ~ STATE CLEARINGHO ~004 Mr, Amdy Byde January 8,200~ Page 4 Please forward a copy of the rev/sed environmental document, staff report and the City's transportation impact fee policy to the address below as soon as they are available. Patricia Mauhce, Associate Transportation Planner Office of Transit and Community Planning, Mail Station 1 OD Califorma DOT, District 4 111 Grand Avenue Oakland, CA 94612-3717 Please feel free to call or email Patricia Maurice of my staff at (510) 622-1644 or patricia_maufice@dot.ca.~ov with any questions regarding this letter. Sincerely, T~~O~C. S'ABLE District Branch Chief IGR/CEQA Enclosure c: Ms. Terry Roberts, State Clear/nghouse "Cmltram~ it~pJ'o~'e.~' JnobiJity t=cro.~.* C'al~fornit~"  ~'O['qGES~ON JYJANAGEMENT 7333 BROADWAY, SUITE 220 · OAKLAND, CA 94612 - PHONE: (510) 836-2560., FAX: (510) 836-21 85 E-MAJI_: rnail@accma..ca.gov ,, WEB SITE: accma.ca.gov December 23, 2003 Andy Byde Senior Planner Planning Department City of Dublin 100 Civic Plaza Dublin, CA 94568 Letter 3.2' RECEIV;P DEC ~6 2003 DUBLIN PLANNIr~G SUBJECT: Corrmients on the Drall Supplemental EIR for the/KEA and Dublin Retail Center Projects in the City of Dublin Dear Mr. Byde: Thank you for the opportunity to comment on the City of Dublin's Draft Supplemental EIR (DSEIR) for the 14.34 acre IKEA project and 13.2 acre Dublin Retail Center project. The project would allow approval and construction of an IKEA retail store totaling 317,000 square feet including retail sales, restaurant, warehouse and 1,130 on- site parking spaces, and would include the Dublin Retail Center, consisting of up to I37,000 square feet of retail Space and related uses on 13.2 acres of land with 665 on- site parking spaces. The project requires an Amendment to the Eastern DuNin General Plan and Specific Plan, Stage 1 & 2 rezoning and Development Plans, Site Development Review for the IKEA store, subdivision maps and a Development Agreement. The project is located immediately north of the 1-580 Freeway, west of Hacienda Boulevard, east of Arnold Road and south of future Martinelli Drive. The ACCMA has reviewed the DSEIR and respectfully submits .the following comments. These comments are .consistent with the comments we made in response to the NOP for tahe P, DE/-R On April 18, .2003 and to the GPA for IKEA Project on October 22, 2003. Where possible, RDEIR page numbers are referenced. · Page 67, First Paragraph: [n the first sentence, reference to ACCMA standards for the LOS monitoring program should be deleted. LOS Monitoring Element of the Congestion Management Program (CMP) is applicable only for monitoring existing conditions. This project is subject to the requirements of the Land Use Analysis Program of the CMP and for that element the Alameda County CMA does not have a policy for determining a threshold of significance. Professional judgment should be applied to determine the significance of project impacts. Page 68, Table 4.3.10 - CMA Tr/p Generation Assessment: In order to calculate the net trips generated by the IKEA Project, trip generation estimated for the Campus 3.2.1 3.2.2 I Mr. Andy Byde December 23, 2003 Page 2 Office project was deducted from the IKEA Center*rips generation estimation. This could be done only if the Peak Hours used for both projects are the same. Page 57, 2nd paragraph of the report states that peak hours determined for the IKEA project were 7:30 - 8:30 AM and 5:00 - 6:00 PM. Please confirm whether the Campus Office project also used the above peak hours in its trip generation estimation. Page 76, Table 4.3.8 PM Peak Hour Conditions: This page is missing from the report. This table is essential for understanding the Buildout PM .Peak Hour Operations. Please incorporate it in the report. Page 78 - Tables 4.3.12 & 4.3.13 -Year 2025 Mainline Freeway Operations: Tables 4.3~ 12 & 4.3.13 show that the freeway capacity used in the DSEIR was 2300 pc/Mn. The adopted 2001 CMP of the CMA uses Highway Capacity Manual (HCM) 1985 wherein freeway capacity is 2000 pc/Mn. Therefore,.these tables should be revised using the HCM 1985 standards for freeway capacity as required by the 2001 CMP. Table 6, Appendix 8.7 - Traffic Impact Analysis: The analysis assumes the same percentage of pass-by traffic for both IKEA Store and the shopping center. Since the IKEA Store generally is more of a trip destination than the shopping center, the percentage of pass-by traffic assumed appears to be high. Therefore, please provide supporting documentation for the pass-by traffic assumption for the IKEA Store. In this regard, please compare the trip .generation estimation including the pass-by traffic assumption used in the Traffic Impact Analysis prepared for IKEA, Emeryville along with the actual traffic counts collected from [KEA~Emeryville for this DSEIR. Responses to the following comments communicated through our letter of October 22, 2003 have not been incorporated in the DSEIR. Please incorporate them. Potential impacts of the project on CMP transit levels of service must be analyzed. (See 2001 CMP, Chapter 4): Transit service standards are 15-30 minute headways for bus service and 3.75-15 minute headways for BART during peak hours. The analysis should address the issue of transit funding as a mitigation measure in the context of the CMA's policies as discussed above. The Dublin/Pleasanton BART Station, which appears to be approximately one-quarter mile from the proposed project site, is the site of an approved Transit Village with proposed high density transit-oriented development, and has been the recipient of funding for a parking structure to support the transit village. The Alameda County CMA is developing a policy to encourage transit-oriented development. How will the design and location of the 454,000 square feet. of retail, warehouse and related uses for Ikea and the Dublin Retail Center and the 1,795 parking spaces on the 27.54 acre site encourage transit and pedestrian use in the project area? 3.2.3 3.2.4 3.2.6 3.2.7 Mr. Andy Byde December 23, 2003 Page 3 The environmental document should provide information on how all of the mitigation measures .on the MTS will be funded. Regarding Supplemental Impact TRA-3, mitigation measures identified, in page 67 of the DSEIR, to contribute the proportionate share towards regional freeway improvements should be incorporated in the summary on Page 1-3. Once again, thank you for the opportunity to comment on this DSEIR. Please do not hesitate to contact me at 510/836-2560 ext. 24 if you require any additional information. Sincerely, Saravana Suthanthira Associate Transportation Planner CC** Chron file: CMl) - Environmental Keview Opinions - Responses - 2003 3.2.8 ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION DISTRICT 5997 PA~KSiDE DRIVE .:.4 PLEASANTON, CALIFORNIA 9,;.588-5127 ~ :=~c~e (925) 484-2600 December 30.. 2003 Mr. Andy Byde, Sen/or Planner Community Development Department City of Dublin i00 Civic Plaza Dublin, Califomia 94568 R~: . Draft Supplemental EIR (DSEIR) IKEA Project (PA 02-034) Letter 3.3 Dear Mr. Byde: Zone 7 has reviewed this CEQA document in the context of our mission to provide wholesale treated water, non-potable water for agriculture and irrigated turf, flood protection, and groundwater and stream management.in the Livermore-Amador Valley. We do not have any comments to the Draft SEIR at this time. However, enclosed for your reference are copies of two previous Zone 7 comment letters (the first regarding the Initial Study and Notice of Preparation to the Draft SEIIL and the second regarding a development review, dated October 23, 2003, and August 26, 2003, respectively). These comments need to still be addressed. We appreciate the opportunity to comment on this document. Please feel flee to contact me at (925) 484-2600, ext. 400, jhoren~zone7water.com, or Jack Fong at ext. 245, jfong~zone7water, com, if you have any questions or comments. Sincerely, Jim Horen Principal Engfineer Advance Planning J-PH:JF:jr Enclosures CC: Ed Cummings, Zone 7 John Ma_honey, Zone 7 Y.K. Chart, Zone 7 Jack Fong, Zone 7 3.3.1 P:Advpln/CEQAReferralx-lkcaProject-DraftSE.rR AL.A!'TEDA COUI',ITY FLOOD CONTROL ,AND WATE~ COI',,!S--RVATiON DISTPtCT 5997 PARKSfD-~ ~RiVE ~ ~L_~ASANTO~, CALI=ORNIA 94588-5127 October 23, 2003 M~..~_ndy Bye, £enior Piarmer Connmunity Development Department Ci~ of Dub~ i 00 CMc ~ C& 94568 h~fi~ Study m:d Notice of~fion ~OP) for a ~ E~ ~e~e~ Cenmr Pev~lopm~n~ Proj eot ~A 02-034) Zone ~ Rgfe=J No. 0~093D . Dear i~. Byde: Zone ? has reviewed the referenced CEQA documents in the cont=x~ ofo~ r¢~onsibilides to prmdd¢ whol~s~ ~=d. w~r, non-pombl~ water for ~cul~ ~d.~gat~ ~ flood protecfio~ ~om~dwat~r and s~emm mm~agem~t ~ ~ Liw~or~-~or V~l~y. ,Mso, ~nclos~ .for yot~ reference is oz previo~ renew l¢~:r da~d Aunt 26, 2003 for ~c~a D:wlopm~t oo~n~ ~= ~ follows: 1. HydrotoD, and Water Qn,iiV, Paragraph ga,. page 35. The second paragraph smt~s that development projects timt result in soil d/starbm~ce of at least five acres of lined are required to submit a Notice of I2tent to the State Water Resom'ces Control Board. Please be a&dsed that, as of March 10, 2003, the size tt]2-eshold for a N'PDES O~nera! Co~z.~-uction Pemdt is reduced from five acres to one acre of dis.tm'bed land. 2. HydroloD' and Water Qua_Et},, Para~'aph Sd, peg= 36. Mitigation for the creation of any new impen,ious areas witkin the L~vermore-Amador Valiey is addressed through +ie collecdon of Sp~ial Drainage Area (SDA) 7-1 dr~Snage fees. Zone 7's stand~rd mitigation practice is to collect an SDA 7-! fee on anynev¢ buildings, improvements (including but not limited to paving), or structures to be consn'ucted that substantially increase the in:perviousness of*i-,e land surface. 7Ze proposed project v~ili be connecting to m2 existing Zone 7 flood con~'ol facility (Line G 2-1), a tributary to Ch£oot Canal. Hydraulic calculatSons for the proposed drainag~ system should be proxdd~d to Zone ? to ensure that design flows do not adversely ir_,2pact exSstmg hy&?.ulJcs downstremm of the project 3.3.2 3.3.3 Oc~obe~ 2}, 2003 Pa=~e 2 3. Hydrolog-y and Water QuaiiB5 Paragraph 8f; page 37. The Project Description, page 4, states that recycled water scrv/ces would be pm~dded by DSRSD in accordance with DSRSD's Eamem Dublin Facilities Master Plan, when and where available to reduce the need for potable water. The referenced.paragraph does not address the potent/al salt loading impacts over our main groundwater basin. Zone 7 considers ali applied water (rainwater is an exception), including both potable water and recycled .water, to contribute salt loading to the groundwater basin, and use of recycled water r~uires m/figation of the associated impacts. The Groundwater Dem/neralizafion Project is the recommended project to accomplish Zorie 7's Salt Management Pro~anfs goal of non-degradation of our main groundwater basin from the long-term buildup of salts. Zone 7 expects to con\r)lete the first phase of this project in 2006. We request *.hat the City support the Groundwater Denfineratization Project in the Dratt E!R as the appropriate m/t/gat/on for the proposed project. Otherwise, we request that the lead agency address the n:fit/gation of any salt loading impacts 'of the project should Zone 7's future Groundwater DemineralJzafion'Project not be constructed and placed into' operat/on. We appreciate the opportu~fity to comment on this document Please feel fi:ce to contact me at (925) 484-2600, ext. 400, jhoren~zone7water, com, or Jack Pong at ext. 245, jfong~zone7water, co~n, if you l~ve any questions or comments. Sincere/y, '3.3.4 Jim Horen P~incip a/B~a_~neer Advance Pi annmg Dave R. equa, DSRSD Ed Curam/~gs, Zone 7 John Mahoney, Zone 7 .roe Sero, Zone 7 Mona Olmsted, Zone 7 Jack Fong Zone 7 P:Ad~,pln/C ~_ C)AReferr~ls-tkeaRetailCenter JRN-O2-P004 16:38 FROM:CITY DF DUBLIN DP583366P8 12/30/2~05 14;~8 ZONE 7 WATEE DISTRICT T0:510 54861~3 P.009'013 N0.400 l~05 ALAMEDA COUNTY FLOOD CONTROL AND WATER CONSERVATION 5~97 pAi~l(gJ~'~ D~tV[~ ~ PLE~.,~ANTON, CALIFORNIA 9-'155~-$I~7 i$ ~Ho.~. I82~ 454-~'~0 F~ As vzr o~ ~c new d~wlcpm~t'~ come~o~ to ~e Zone 7 ~~ion ~ ~ not.~. ~me ~g ~ ~ c~i~ in rM o= ~ pl~ ~i~cd for review. PI~ xm~c ~ r~abi~t ~e pl~ fo~ ~ approve. is be, fc.~, vai~,'~ md otb,'~ ~lppiu-'~cn~nce~ ~it ~c loc~ ~b)~ ~z t~m:~ of commotion be ol~ty b~at~ p~or ~ co~cSo=. E~y ~~ or ~g work b ~wd ~y bond ~ Zo=a 7. co=tact Ialm~ FJos ,-i( extea:mion 407 for ma c~croac.,hm~t pm-mi~ md if]a3c hay= any 3.3.5 3.3.6 TEL)gE~5 4&2 3914 iD)CITY OF DU~_IN PAGE:005 16:38 FROM:CITY OF DUBLIN 925833GB28 12/3~/2~3 14:38 ZONE ? WATER DISTRICT o 8~28 T0:510 5486123 Orz r,cords indicate thet~ ar~ ne wats wel]g or mo~odng 'oo~. If~yw~l~ sm found witl~ Amy plz.m~ n~w weiI~ ~oil ~ving or ~mll ~tm'ting ~ho woZ!c Tn~p ~re na fe~s for ~ F~OOcI Coutroh DeCdopments that/n~e, asa imperv/ous arce ~ ~t m Sp=~ ~e ~ (~DA) 7-1 ~c~on fo~ ~pr~fl ofve~5 ~w ~ ~ m~) ~ bu~a~, ~vewa~, ~c. (upOn ~Hc~on for b~l~g p~t). ~ ~c no ~i~g Zone 7 flood eo~ol ~E~t at ~s lom~on. Should ~u h~'w ~y flood ~n~l rela~cd q,~o~s~'gI~e'con~ ~a~on Borchm~ at ~x~sion ~02, ~you haw an)' que~on~, pD.a~'Y do not h~i~t~ ~o oonta~ thc psrson idcnti~I V .e.-y 't:~,y ~: C]aym~ Bor:ho~ Z~o 7,~ood Cou~rot 3.3.7 3.3.8 DEC-ZO-2~3 01:44PM TEL)9~ 46~ 3~1~ IO]CITY OF DUBLIN PAGE:O~6 E ADI'.! I NISTRATIO N BUILDING 1052 S LivesmoreAvenue Livermore CA 94550-4899 Ph (925) 960~000 Fa.,: (,225) 960-a05~ 'I'DD (925) 960-a10~. MAYOR; COUNCIL Ph 960-z-010 · Fax 960-4025 CITY MANAGER ?h 950-4040 · Fax: 96D~04.5 CITY A'FrORNEY Pr: 960-4150 · Fax: 960-a-180 RISK MANAGEMENT Ph 960.41711 · Fax: 950-4180 CITY CLERK Ph 960-4200 · Fax ¢602.205 COMMUINTrY DEX~PM[~ Pr: 9~00 · Fix: 960.~59 Buigding Division Ph 960-~10 · Fax: ~nginee~g Ph 96~-45~0 · F~: 960~505 Housing Div~ion Ph 960-4580 · F~ 960~a9 Ph: 960~50 · Fax 960~59 ECONON~C Ph 9~4140 · F~: P60~149 F~'~CE DEPARTMENT Ph 9504300 * Fax' 9604309 F~E D EP~TM ENT 4550 E~t Avenue PB 4~-2551 , Fax: 454-2367 LIB~RY 1000 S. Lix'ermor: Avenue Ph 373-5500 · Fax: 373-5503 PERSO~EL Ph 960~100 · Fax 960~105 PONCE DEPARTMENT 1110 S Liv~or¢ Avenue Ph 37]-4900 , Fax: 371-4950 TDD 37t-4982 . PUBLIC SER~CES 5503 Roberuon P~k Rd. Pk. 960-8~00 · Fax: 960-8005 Airport Division 635 TemiaaI C;rcla Pn 373-5280 · Fax: 373-5042 Go~ Course Division 909 Clubhouse Drive ?h 373-5239 · Fax 373-5203 Ma~fenaace Division 3500 Robenson Park Rd. >h: 950-8020 · Fax 960-8025 ~arer Resources Division !01 W Jack London Bird :h 960-8~00 · Fax 960-8~05 2004 Country Since 1849" December 30, 2003 Andy Byde, Senior Planner City of Dublin - Community Development Department 100 Civic Plaza Dublin, CA 94568 Letter 3.4 RE: ]ICEA Development Project Draft Supplemental EIR Dear Mr. Byde: Thank you for the opportunity to review the Draft Supplemental Environmental Impact Report (EIR) for the proposed IKEA Development Project. The project includes a General Plan/Specffic Plan Amendment to provide for the development of a 317,000 square foot IKEA building and a 137,000 square foot retail center located west of Hacienda Boulevard and east of Arnold Drive in Dublin. The Draft Supplemental EIR acknowledges the significant and unavoidable cumulative impact of the project on regional roadways including-1-580. The Eastern Dublin EIR included mitigation measures, such as developments' contribution of its proportionate share towards roadway improvements and TSM programs to address, but not fully mitigate, the cumulative transportation impact of the East Dublin Specific Plan, which includes the project site. In addition to these mitigation measures, the proposed project should be required to implement ramp metering of the westbound 1-580 on-ramps at Hacienda Dr/ye. We encourage the City of Dublkn to implement ramp metering at all freeway interchanges within the City of Dublin to help increase traffic flow on the freeways. If you have any questions regarding this matter, please contact Susan Frost, Senior Planner at (925) 9604462 Sincerely, Susan Frost Senior Planner CC: Marc Roberts, Community Development. Director Eric Brown, Planning Manager Bob Vinn, Senior Transportation Engineer Allen Matkins Allen Matkins Leck Gamble & Mallory attorneys at taw 333 Bush Street :[7th Floor San Francisco California 94:[04-2806 telephone. 4~.5 837 ~.5:L5 facsimile. 4:[5 837 :[5:[6 www.allenmatkin$.com writer, Michael Patrick Durkee t. 415 273 7455 file number. 1409~005ISF603928.01 e. mdurkee~allenmatkins.corn December 30, 2003 VIA FAX (925.833.6628) Andy Byde Senior Planner City of Dublin P.O. Box 2340, 100 Civic Plaza Dublin, CA 94568 Letter 4.1 Re: Comments Regarding IKEA Project Draft Supplemental Impact Report Dear Mr. Byde: On behalf of our client, IKEA, the Project Sponsor, thank you for this opportunity to comment on the Draft Supplemental EIR ("DSEIR"). We appreciate the excellent job City Staff and the EIR Consultant have done on the DSEIR, and we believe that it, in conjunction with the original EIR it supplements, adequately addresses the potential direct and indirect impacts of the Project. Our comments follow, each designated with a number (and letter where appropriate) for ease of reference when responding. I. First, it is important to note that neither the Commerce One development proposal (approved earlier for this site) nor any other office development proposal would be viable on this site for 10 years or more. The simple fact is that the current market supply of office space far exceeds the market demand for office space, and will continue to do so for well into the foreseeable future. This is a scenario prevalent in the greater Bay Area,. not just the Th-Valley region. In fact, property owners within major Business Parks such as Hacienda Business Park are actively converting office space uses to non-office uses because of this market glut and "softness" for office space. In other words, office development of this site is simply not a viable option at this time or some time to come. 2. Second, as set forth in the SEIR, we wish to point out that the:Project would not increase significant impacts over those anticipated from development of the Commerce One project and area development, and in some cases the Project would actually lessen the impacts anticipated from such office development. San Francisco Century City Los Angeles Orange County San Diego Allen Matkins Leck Gamble & Mallory LLP attorney~ at law Andy Byde Senior Planner December 30, 2003 Page 2 a. Traffic impacts in the weekday "AM Peak Hour" would be similar for both the IKEA and Commerce One projects, but the IKEA Project would improve operations at 2 of the 18 key intersections studied over the Commerce One project. Weekend traffic impacts of the IKEA Project are greater than the Commerce One project, but nonetheless, intersection operations still would remain "acceptable" under City of Dublin criteria at all times under the IKEA Project. Overall AM and PM peak hour trips would decrease with the IKEA Project compared to the Commerce One project, while cumulative intersection and freeway segment conditions would be similar under both scenarios, with IKEA contributing less peak hour traffic than Commerce One to these conditions. b. Impacts to biological resources and construction-related air quality impacts would be identical for both the IKEA Project and the Commerce One proposal, because the same area would be equally disturbed for the two projects. c. While both the IKEA Project and Commerce One project would contribute similarly to regional ozone levels, the IKEA Project would have potentially improved roadside carbon monoxide concentrations compared with the Commerce One project, and the IKEA Project would not result in any exceedance of carbon monoxide standards (whereas the Commerce One project would). 3. Third and finally, we wish to underscore that the Project implements the City's vision for the fiscal health and development of this area (as reflected in its General Plan, Eastern Dublin Specific Plan and related land use regulations), and that the benefits of the Project far outweigh its impacts. In addition to further/ng the objectives identified in Section 3.4 of the DSEIR, the Project promotes the City's goals and policies in the following manner: a. The proposed development of an IKEA Store and Lifestyle Retail Center will complement the existing range of retail opportunities in Eastern Dublin. These uses will provide a source of attractive, well priced home furnishings, pedestrian-oriented retail center, and restaurant opportunities that will help establish Dublin as a center for destination shopping. The Project will provide new shopping and restaurant opportunities not yet available in this part of Dublin, within a short distance of existing retail opportunities, thus leading to an increase of shoppers for all businesses in the area. Additionally, the Project will be within walking distance from the higher density residential development existing and planned nearby. Allen Matkins Leck Gamble & Mallory LLP attorneys at law Andy Byde Senior Planner December 30, 2003 Page 3 b. The Project will further the General Plan objective for the Eastern Dublin Planning Area of providing a broad range of non-residential uses, including retail commercial. The General Plan's Guiding Policy for the Eastern Dublin Planning Area is to "encourage development of a full range of commercial and employment generating uses that will meet the needs of the City and the surrounding Th-Valley areas." This Project provides a much. ~)eeded retail center for existing and planned future residents within the approved distribution of commercial land. c. The primary Land Use Goal of the East Dublin Specific Plan is to "establish an attractive and vital community that provides a balanced and fully integrated range of residential, commercial, employment, recreational, and social opportunities." Another Land Use Goal is to serve "the shopping, entertainment and service needs of Dublin and the surrounding area." This Project helps the City achieve these goals by providing a variety of commercial, employment and social opportunities in a retail setting. A Policy supporting this Goal is to "concentrate regionally oriented commercial uses south of Dublin Boulevard and near freeway interchanges where convenient vehicular access will limit traffic impacts on the rest of eastern Dublin." The proximity of the Project site to the Highway 580 and Hacienda Drive interchange is consistent with these goals and policies and facilitates efficient transportation. The Project will provide a "destination retail" experience on a visually prominent site accessible from major regional traffic corridors. The site will be developed in a landscaped and "pedestr/an-friendly" fashion - - with restaurants and related leisure services - - to heighten the shopping experience and further enhance the concept of "spending the day out shopping." The combination of the IKEA store with the Lifestyle Retail Center will offer a shopping experience complementary to the nearby Hacienda Crossings retail center and add to the range of retail and restaurant opportunities available to the shopper in Dublin. d. The Project will provide sig-nificant fiscal contributions to the City. There will be a strong property tax income stream from the high value developments on the IKEA and Lifestyle Retail Center sites. Further, and more importantly, both retail efforts will generate substantial sales tax revenue to the City - - which would not be realized if the site is developed with an office use - - while creating no greater impact on traffic, biology, air, or municipal services (such as police and fire) than that presented by an office use such as Commerce One. Allen Matkins Leck Gamble & Mallory LLP attorneys at law Andy Byde Senior Planner December 30, 2003 Page 4 Again, thank you for this opportunity to comment. MPD/mpd cc: Doug Greenholz, IKEA Randy Ackerman, Opus West Annotated Comment Letters and Responses IKEA Final EIR PA 02-034 Page 4 City of Dublin February 2004 Letter 2.1: State of California, Governors Office of Planning and Research (OPR) · Comment 2.1: The commenter notes that no state agencies have submitted comments on the DSEIR. The DSEIR public comment period dosed on January 2, 2004. Response: Comment acknowledged. No further response required. Letter 2.2: State of California, Department of Transportation (Caltrans) This comment letter was received well after the close of the public comment period. Although CEQA does not require a written response, the City is including the following in the interest of providing the decisionmakers and the public with information on the issues raised in the letter. Comment 2.2.1: Mitigation should be identified for any roadway mainline section or intersection with insuffident capacity to maintain an acceptable LOS with the addition of project-related and/or cumulative traffic. The project's fair share contribution, financing, scheduling, implementation responsibilities and lead agency monitoring should be fully discussed for all proposed mitigation measures. Where additional roadway improvements are not feasible, downscaling the project should be explored. The commenter refers to the Transportation-Related Mitigation Monitoring and Reporting Guidelines (per Assembly Bill 1807) that requires lead agencies to submit mitigation monitoring information to Caltrans. Response: Pursuant to the discussion offered on page 67 of the DSEIR regarding project requirements to address the project cumulative impact on adjacent freeways, the project will be required to pay for its proportionate share of cumulative impacts to 1-580 and 1-680, by payment of Tri-Valley Transportation Development (TVTD) Fees to construct planned freeway improvements, including HOV lanes, auxiliary lanes, and interchange improvements. The project will be required to pay its proportionate share toward public transportation improvements to help reduce traffic on the freeways and other roadways in the Th-Valley area, by payment of the TVTD Fee to fund the West Dublin/Pleasanton BART Station project. In addition, as explained in the DSEIR on pages 55 and 56, the City of Dublin has fee programs in place that require developers in Eastern Dublin to pay for transportation improvements, including those regional improvements identified in the 1993 Eastern Dublin EIR as mitigation measures. Similar to other development projects in Eastern Dublin, the proposed project will contribute a proportionate share to the construction of improvements and mitigation measures along the 1-580 corridor. Such freeway-related improvements and mitigation measures include: IKEA Final EIR PA 02-034 Page 5 City of Dublin February 2004 Construction of approximately 8.2 miles of HOV lanes on 1-580 from Tassajara Road to Vasco Road. After addition of these HOV lanes, this segment of 1-580 will have a total of four mixed lanes and one HOV lane in each direction. $8.0 million in TVTD Fee funds, to which the proposed project will contribute a proportionate share, has been allocated to this improvement. The Project Study Report has been completed and approved by Caltrans. Several design alternatives are currently under consideration for th/s improvement. The proposed HOV lanes will help provide relief to traffic congestion on 1-580. Construction of auxiliary lanes on 1-580 between Tassajara Road and Airway Boulevard, and east of Airway Boulevard, as part of Mitigation Measures 3.3/3.0 and 3.3/5.0 of the Eastern Dublin El-R, respectively. The proposed project will contribute a proportionate share to the construction of these auxiliary lanes by paying a regional fee, which the City of Dublin has implemented through the Eastern Dublin Traffic Impact Fee (see Fee Programs discussion on pages 55 and 56 of the DSEIR). Auxiliary lanes in the vicini~ of the project site (i.e., between Tassajara Road and Fallon Road) were recently constructed as part of the Santa Rita Road/Tassajara Road interchange improvement project, which was sponsored and administered by the City of Dublin. The proposed auxiliary lanes are not intended to increase mainline freeway capacity per se, but will mitigate operational problems caused by merging and diverging vehicles at the interchanges, thereby reducing traffic congestion on 1-580. The planned six-lane Dublin Boulevard extension to connect existing Dublin Boulevard with North Canyons Parkway in Livermore will carry substantial volumes of 1-580 corridor traffic, providing relief to the freeway itself. The Eastern Dublin Traffic Impact Fee, to which the proposed project will contribute a proportionate share, will fund this extension. The tables referenced in the comment are included in the DSEIR's cumulative buildout analysis for year 2025 beginning on page 63. Cumulative freeway conditions are discussed beginning at page 66. The DSEIR analysis and conclusions are consistent with the Eastern Dublin EIR conclusions that even with roadway and highway improvements, cumulative freeway impacts will be significant and unavoidable. (Resolution 53-93). As noted in the DSEIR, "the proposed IKEA Project is expected to generate similar levels of freeway- related traffic as compared to the previous forecasts in the Eastern Dublin EIR." (p. 66). Further, adding the Project traffic to Year 2025 volumes would not change the levels of service for AM or PM peak hours (p. 67). Thus, future cumulative traffic impacts for the freeways will be significant and unavoidable with or without the Project. Downsizing the project as suggested in the comment would not be expected to substantially reduce, let alone avoid, Year 2025 cumulative freeway impacts. Similarly, phasing the Project would not affect the DSEIR conclusions since the impact is identified for cumulative buildout in 2025. Through the Eastern Dublin EIR and the DSEIR, IKEA Final EIR PA 02-034 City of Dublin Page 6 February 2004 the City has discussed feasible mitigations for reducing the identified freeway impacts of the Project. No further analysis is required. The City notes that because freeway impacts continue to be significant and unavoidable, a Statement of Overriding Considerations will be required for any Project approval. The commenter also directs the City to Caltrans' Mitigation Monitoring and Reporting Guidelines, pursuant to Assembly Bill 1807. This bill is contained in CEQA section 21081.7 and requires that transportation information that results from specified project mitigation monitoring programs be submitted to the regional transportation agency and to Caltrans. Any Project approval will require the City to adopt a mitigation monitoring program; transportation information resulting from the program will be submitted as appropriate under the statute. · Comment 2.2.2: The project contribution to LOS degradation should be clearly identified on Tables 4.3.12 and 4.3.13. Response: As shown on Tables 4.3.12 and 4.3.13 of the DSEIR, the proposed project would not degrade freeway LOS as compared to cumulative conditions under the approved Campus Office designation. The incremental changes to the V/C ratios on the study segments were derived from Tables 4.3.12 and 4.3.13 and are listed below: Year 2025 Mainline Freeway Impacts, IKEA Project Incremental ViC Contribution IKEA Project Incremental Location V/C Contribution AM Peak PM Peak Hour Hour 1-580, 1-680 to Dougher .ty Road Eastbound -0.013 +0.032 Westbound +0.014 +0.005 1-580, Dougherty Road to Hacienda Drive Eastbound -0.010 +0.019 Westbound +0.012 +0.002 1-580, Hacienda Drive to Tassajara Road Eastbound 0.00 -0.015 Westbound -0.026 +0.001 1-580, Tassajara Road to Fallon Road Eastbound +0.001 -0.018 Westbound -0.024 +0.002 IKEA Final EIR PA 02-034 City of Dublin Page 7 February 2004 1-680, 1-580 to Alcosta Boulevard Northbound +0.008 +0.003 Southbound -0.010 +0.017 1-680, 1-580 to Stoneridge Drive Northbound -0.008 +0.021 Southbound +0.010 +0.003 Comment 2.2.3: The commenter states that the IKEA store in Dublin would draw customers from the South Bay, including San Jose, and from locations to the east such as Tracy, Stockton and Sacramento, and that the assumption that Dublin IKEA would generate 25% fewer weekday trips than the Emeryville store should be adjusted upward to reflect the market demand potentials. The commenter requests that a comparison be made between the actual trip generation from Emeryville IKEA and trip generation estimates considered during the environmental review of that project. Response: Please see Comment 3.2.5 for a discussion of the trip generation methodology used in the DSEIR. Designed to achieve a worst case analysis, the DSEIR assumes 75% of the actual Emeryville trips during the AM and PM peak hours even though sales projections suggest an approximately 61% figure would be more appropriate. Furthermore, the Emeryville figures were generated before the recent opening of the East Palo Alto store. As such, they represent traffic when the Emeryville store was the only store in the Bay Area, and do not reflect traffic that has likely since been redirected to the new store. Trip distribution assumptions, shown on Figure 6 of the traffic analysis contained in the SDEIR Appendix, indicates hat nearly one half (46%) of the anticipated patronage of the proposed IKEA facility would originate either in the South Bay/San Jose area or from the Central Valley. The remaining visitors would originate either locally, within the Th-Valley area (14%), or would travel to and from the north on 1-680 (30%) or would travel to and from the proposed site from the west using 1-580 (10%). Therefore, a significant number of anticipated store visitors have been assumed from either the San Jose Area or the Central Valley. Comment 2.2.4: How well does actual trip generation from the Emeryville IKEA store correlate to trip generation estimates provided during that project's environmental review? Response: The City of Dublin does not have the Emeryville environmental review documents or traffic project:ions prepared before the store was approved and opened. However, this information is not relevant to the IKEA Final EIR PA 02-034 Page 8 City of Dublin February 2004 current Project traffic analysis since the analysis is based on actual traffic figures from the Emeryville store, not from projections. Comment 2.2.5: The pass-by trip rates for a store such as IKEA are likely negligible. Caltrans does not accept pass-by trip rates in excess of 15% without prior consultation with the Department. The commenter refers to the Department's "Guide for the Preparation of Traffic Impact Studies" for review by project sponsors prior to initiating traffic analyses affecting state facilities. Response: The City acknowledges that the referenced Guide recommends consultation for pass-by trips over 15%; however the DSEIR discussion establishes that this figure is not likely to be an accurate reflection of the expected pass-by occurrences for the Project. The traffic analysis presented in the DSEIR included an evaluation of pass-by rates for the Project and the authors of the DSEIR believe that the rates stated in the document are appropriate. Please see a detailed discussion of this topic under Response 3.2.5. The City's traffic engineer has reviewed both the DSEIR analysis and traffic report, as well as this comment from Caltrans. Based on the analyses and in his professional judgment, the pass-by rates in the DSEIR are appropriate and reflect the different Project peak hours and pass-by characteristics for weekends and weekdays, as discussed in Response 3.2.5. Furthermore, the 34% pass-by trip rate used for the project analysis is consistent with the ITE recommended practice for trip generation as outlined in ITE Trip Generation Handbook (October 1998). The commenter's pass-by figure does not appear to reflect either the documented traffic patterns of other IKEA stores or the most current ITE recommendation. Pursuant to CEQA, the City's analysis provides a more accurate estimate of the Project's traffic generation and patterns than the commenter's figure, and thus a more accurate identification of potential impacts and mitigation measures. Comment 2.2.6: Project trip distribution should be revised to show the majority of project trips accessing the project from 1-580. Response: Figures 7A and 713 (Proposed Project Trip Assigrunent) of the traffic study in Appendix 8.7 (Traffic Impact Analysis) of the DSEIR provide information regarding project trip assignment. As can be derived from these Figures, 86% of total project traffic was assigned to access the project via 1- 580, based on the project trip distribution listed on page 61 of the DSEIR, including 76% of total project traffic using 1-580 and accessing the site via the Hacienda Drive interchange which is immediately adjacent to the project site. Based on the above trip assignment percentages, the DSEIR did assign the majority of project trips to 1-580 to access the project site, and no revisions to the project trip distribution are required or necessary. The traffic impact conclusions and mitigation measures set forth in the DSEIR remain the same. IKEA Final EIR PA 02-034 City of Dublin Page 9 February 2004 Comment 2.2.7: The intersection traffic counts used in the DSEIR do not reflect traffic conditions with the current ramp metering in place on eastbound 1-580. Traffic data and intersection analysis should be updated to reflect ramp-metering conditions. Response: As indicated on page 57 of the DSEIR, weekday AM and PM turning movement counts were collected at the study intersections in February 2003, and the traffic analysis was begun immediately thereafter. At that time, the target date for implementing ramp metering on eastbound 1-580 (i.e., at the Dougherty Road/Hopyard Road, Hacienda Drive and Tassajara Road/Santa Rita Road interchanges) was unknown. As a result, it was not possible to postpone or delay traffic studies indefinitely in the area in anticipation of ramp metering activation at an undetermined future date. Nonetheless, in an effort to recognize the potential for ramp metering effects without delaying the project indefinitely, the traffic analysis in the DSEIR did take into consideration the effects of implementing ramp metering on eastbound 1-580 during the weekday PM peak period, based on engineering judgment and knowledge of the study area. For example, as indicated on page 64 of the DSEIR, the traffic analysis assigned freeway-bound trips to the closest proximity interchanges, while overall background traffic was re- distributed more evenly among the interchanges to simulate anticipated ramp metering effects on traffic patterns in the study area. Ramp metering was later activated on June 30, 2003 and traffic patterns in the area were expected to change gradually over the summer months in reaction to ramp metering. Under Pre-ramp metering ("before") conditions, approximately 50% of the trips bound to eastbound 1-580 from the Dublin side of the freeway used the Tassajara Road/Santa Rita Road interchange to bypass freeway congestion in this direction, as indicated on Exhibit 14 of the DSEIR. Citv of Dublin staff conducted Post-ramp metering ("after" condition) ffeld observations in September and October 2003 and confirmed that traffic patterns in the study area had changed in a manner consistent with the trip modeling assumptions that were used in the analysis to simulate the effects of ramp metering. For example, the "after" condition traffic flow on 1-580 appeared to have improved during the PM peak period, and trips have shifted more evenly among the three interchanges in the study area to access eastbound 1-580 during this period. Therefore, ramp-metenng conditions were reflected adequately in the intersection LOS analysis and no updated traffic data or additional analysis is required. The traffic impact conclusions and mitigation measures set forth in the DSEIR remain the same. Comment 2.2.8: Discuss the downstream effects of LOS F on 1-580; for example, clarify how certain 1-580 segments will operate at LOS F while other segments will operate at LOS D and E as shown in Table 4.3.13. IKEA Final EIR PA 02-034 Page 10 City of Dublin February 2004 Response: The LOS analysis reported on Table 4.3.13 of the DSEIR is based on the volume-to-capacity ratio for freeway segments in the vicinity of the project during the PM peak hour under year 2025 traffic conditions. The year 2025 traffic volumes were based on the Tri-Valley Transportation Model (TVTM). The PM peak hour LOS on 1-580 is projected to be F on the eastbound segments from 1-680 to Dougherty Road and from Tassajara Road to Fallon Road in year 2025. The table shows that the intermediate segments of eastbound 1-580 between Dougherty Road and Tassajara Road would operate at LOS D or E at Buildout with or without the Project. The more efficient LOS projected for these intermediate segments can be explained as follows: The intermediate segments have higher throughput capacity in the eastbound direction than the outer segments, as the intermediate segments consist of 5 to 6 eastbound lanes compared to 4 lanes for the outer segments. (2) Eastbound traffic volumes during the PM peak hour are projected to be lower on the intermediate segments based on the TVTM model because the model predicts that a portion of freeway traffic would exit the freeway at the Dougherty Road/Hopyard Road interchange and use Dublin Boulevard, Stoneridge Drive and other parallel surface streets as alternate cut-through routes to bypass freeway congestion. Some of this cut-through traffic would re-enter the freeway at the Fallon Road/E1 Charro Road interchange with the anticipated extensions of Dublin Boulevard and Stoneridge Drive to Fallon Road. Comment 2.2.9: Clarify how the proposed project would cause the V/C ratio to decrease at some locations. Response: The Project site is currently designated for Campus Office uses in the General Plan and Eastern Dublin Specific Plan, which uses were assumed in the Eastern Dublin EIR. The DSEIR examines how the current proposal to change the land use designations to General Commercial and develop the IKEA project would change the traffic analysis and assumptions in the prior EIR. As explained on page 65 of the DSEIR, the IKEA project would generate fewer trips during the weekday AM peak hour as compared to the existing Campus Office designation. During the weekday PM peak hour, the IKEA project and the existing Campus Office designation would generate similar levels of traffic; however, the trip distribution and assignment characteristics differ due to differences in land uses. As a result, the IKEA project would have mixed incremental impacts during the PM peak hour by increasing the V/C ratio at some locations and decreasing this ratio at other locations. For example, as explained on page 61 of the DSEIR, the regional trip distribution for the proposed project was derived from primary trade areas established by IKEA Property, Inc. and consisted of 75% of the trips accessing IKEA Final EIR PA 02-034 Page 11 City of Dublin February 2004 the project site from the west (via 1-580 and 1-680), 11% accessing the site from the east (via 1-580), and 14% of the trips originating within the Tri-Valley area using surface streets. In contrast, the trip distribution for office trips based on previous traffic studies conducted for office developments in the area, such as Commerce One, Transit Center and Sybase, indicates that 33% of the trips would access the office site from the west (via 1-580 and 1-680), 25% would access the site from the east (via 1-580), and 42% of the trips would use surface streets within the Tri-Valley area. As a result of these differences in trip distribution characteristics, the percentage assignments of total project trips to individual routes and intersection movements in the study area differ between the existing Campus Office designation and the proposed IKEA project. Comment 2.2.10: Ten designs are presently being considered by Caltrans for the widening of 1-580, one of which (variation 2.2) would impact approximately 2,772 square meters of the Project property to increase the future right-of-way of the 1-580 freeway. Response: The City acknowledges the comments and supports the construction of additional capacity for 1-580, however neither the City nor the Project applicant has any control over the ultimate right of way design adopted by Caltrans for the 1-580 HOV lane. Moreover, as noted by the commentator, only one of the 10 design alternatives would effect the property and that is the "worse-case" right of way scenario. In the event that Caltrans determines that it needs to condemn any portion of the Project property, it will have the legal authority to do so and will be required to proceed in the manner proscribed by law. Comment 2.2.11: Work that encroaches on the ROW requires an encroachment permit from Caltrans. Traffic-related mitigation measures will be incorporated into the construction plans during the permit process. Response: Comment regarding the need for encroachment permits for work in the ROW is acknowledged. If and when an encroachment permit is needed, the Project applicant will submit an application for this permit. Letter 3.1: Dublin San Ramon Services District (DSRSD) Comment 3.1.1: DSRSD operates a fluoridation facility at the southwest comer of the site. Response: Comment acknowledged. This is a statement of fact, not a comment on an environmental topic, therefore no further response is necessary. IKEA Final EIR PA 02-034 City of Dublin Page 12 February 2004 Comment 3.1.2: The aerial photograph (Exhibit 4) has Dublin Boulevard labeled as Martinelli Way. Response: Comment acknowledged. Exhibit 4 is hereby corrected by reference to note that the east-west roadway on the north side of the site is named Martinelli Way. Dublin Boulevard is located to the north of Martinelli Way. Letter 3.2: Alameda County Congestion Management Agency Comment 3.2.1: In the first sentence on page 67 the reference to ACCMA standards for the LOS monitoring program should be deleted. The monitoring standards are used by the ACCMA for existing conditions. The ACCMA does not have a policy for determining a threshold of significance. Professional judgment should be applied to determine the significance of project impacts. Response: It is acknowledged that ACCMA does not have a policy for determining a threshold of significance. However, the ACCMA standards, established for the purpose of monitoring existing LOS conditions are also appropriate for assessing the project's potential traffic impacts, and are used in this EIR as standards of significance based on the City of Dublin's professional judgment. Comment 3.2.2: Table 4.3.10, on page 68, the trip generation estimate for the previous campus office project was deducted from the proposed IKEA center trip generation. This could be done only if the peak hours for the uses were the same. Page 57 of the DSEIR notes that the peak hours for the IKEA Project were determined to be 7:30-8:30 am and 5:00 -6:00 pm. Please confirm whether the campus office project also used the same peak hours for determining trip generation. Response: It appears that the commenter misinterpreted the above AM and PM peak hours as being the peak hours for the IKEA project. Intersection turning movement counts were collected in the study area during the AM and PM peak periods. The peak hours of 7:30 to 8:30 AM and 5:00 to 6:00 PM represent the highest traffic volume hours during the peak period traffic counts, as explained on pages 56 and 57 of the DSEIR under the section entitled "Existing Traffic Volumes and Lane Configurations", including the explanation offered in the 2~a paragraph on page 57. For the purpose of analyzing Project traffic impacts, it is common practice to use the weekday AM and PM peak hours of adjacent street traffic, determined by the intersection turning movement counts, as the appropriate hours for peak hour trip generation from the proposed Project. As such, it IKEA Final EIR PA02-034 Page 13 City of Dublin February 2004 was assumed that the peak hour trip generation for the IKEA and Campus Office projects would occur during the peak hours of 7:30 to 8:30 AM and 5:00 to 6:00 PM, which represents the worst-case scenario for analysis of project traffic impacts on adjacent streets. Comment 3.2.3: Page 76, Table 4.3.8, PM Peak Hour Conditions, is missing. Response: This table is included in the Final EIR in Appendix A. However, the same information contained in Table 4.3.8 is also available in Table 8B of the traffic study listed in Appendix 8.7 (Traffic Impact Analysis) of the DSEIR which was circulated for a 45-day period. Comment 3.2.4: Pages 78-79, Tables 4.3.12 and 4.3.13, Year 2025 Mainline Freeway Operations, show that freeway capacity used in the DSEIR was 2300 pc/h/ln. The 2001 CMP uses the Highway capadty manual standard of 2000 pc/h/ln. These tables should therefore be revised using the HCM standards as required by the CMP. Response: The 2,300 pc/h/In freeway capacity used in the DSEIR is based on the Highway Capacity Manual (HCM) 2000 standards for basic freeway segments. According to HCM 2000, Chapter 23, Exhibit 23-2 (LOS Criteria for Basic Freeway Segments), the maximum service flow rate for freeways ranges from 2,250 to 2,400 pc/h/In, depending on the estimated free flow speed. Based on the physical characteristics of the 1-580 and 1-680 freeway segments that were analyzed in the DSEIR, the free flow speed for these freeway segments was estimated at 60 mph. According to HCM 2000, the maximum service flow rate corresponding to this free flow speed is 2,300 pc/h/In. The City of Dublin respects ACCMA's decision to use HCM 1985 standards for the 2001 CMP. However, the HCM has undergone periodic updates since 1985 based on new research studies and updated traffic analysis methodologies. In the recent EIRs for the Dublin Transit Center and East Dublin Property Owners (EDPO) developments, a freeway capacity of 2,300 pc/h/tn was used for the above freeway segments and was accepted by Caltrans. Moreover, in order to be consistent with previous EIR studies in Dublin, The DSEIR used the same capacity of 2,300 pc/h/in based on the latest, nationally accepted HCM standards for basic freeway segment analysis. Therefore, no additional analysis is required and the traffic impact conclusions and mitigation measures set forth in the DSEIR remain the same. Comment 3.2.5: Table 6 in Appendix 8.7 assumes the same percentage of pass-by traffic for both the IKEA center and the shopping center. Since the IKEA store is generally more of a trip generation than the shopping center, IKEA Final EIR PA 02-034 City of Dublin Page 14 February 2004 the percentage of pass-by trips appears to be high. Please provide supporting documentation for the pass-by trips. Also, please compare trip generation estimations including pass-by traffic assumptions used in the traffic analysis for the IKEA facility in Emeryville along with the actual traffic counts collected from the Emeryville IKEA. Response: Trip generation assumptions for the IKEA store, shopping center and restaurant are discussed in detail in the "Trip Generation" section on pages 20 and 21 of the traffic study listed in Appendix 8.7 (Traffic Impact Analysis) of the DSEIR. Trip generation and pass-by trip assumptions are also explained on Tables 5 and 6 of the traffic study. The commenter's assertion that the IKEA store is more of a primary trip destination than the shopping center is only true during weekends. For example, the pass-by trip percentage for the IKEA store on Saturday was assumed to be zero, compared to 26% for the shopping center, as shown on Table 6 of the traffic study in Appendix 8.7 of the DSEIR. However, during the weekday PM peak hour, the IKEA store pass-by trip percentage is expected to be comparable to that for the shopping center [i.e., about 34% based on ITE Trip Generation Handbook (October 1998) and knowledge of the Project area]. This is due to their combined location and the close proximity of the Project site to both Dublin Boulevard and 1-580, which carry significant volumes of local and regional pass-through traffic during the PM peak commute period. The IKEA store and the shopping center are expected to attract an equal percentage of about 34% pass-by trips from Dublin Boulevard and 1-580 during this period. Some of these trips could be attracted simultaneously to both the IKEA store and the shopping center due to their combined location. The City also notes that the DSEIR analysis took a conservative approach to estimating trip generation for the IKEA store. For example, during the PM peak hour, it was assumed that IKEA Dublin would generate 75% of actual trips generated by IKEA Emeryville, even though IKEA Dublin is expected to generate about 61% of the sales at IKEA Emeryville. Moreover, the actual trip counts for IKEA Emeryville were collected when this store was the only IKEA store in the Bay area. IKEA Emeryville sales and trip generation are expected to drop with the recent opening of IKEA East Palo Alto and the possible opening of IKEA Dublin in the near future. The conservative trip generation assumptions used in the DSEIR were developed for the purpose of analyzing the "worst-case scenario" traffic impacts on the adjacent roadway system from the IKEA store. In sum, trip generation estimates for the IKEA store were calculated based on extensive empirical data, knowledge of the Project area, application of professional judgment, and use of conservative assumptions. As such, no additional analysis of trip generation estimates for the Emeryville IKEA store is required or necessary. Pass-by and destination assumptions in the analyses reflect the different traffic patterns for weekend and PM weekday traffic. IKEA Final EIR PA 02-034 City of Dublin Page 15 February 2004 Comment 3.2.6: Please discuss the potential impacts of the Project on CMP transit levels of service. Transit service standards are 15-30 minute headways for bus service and 3.75-15 minutes for BART during peak hours. The analysis should discuss funding of transit as a mitigation in the context of CMA policies discussed above. Response: Information provided by BART officials indicates that the AM peak load factor at the Eastern Dublin/Pleasanton BART station was 1.25 as of mid- December 2003 (source: personal communication, Janice Lee, BART, 1/9/04), which is consistent with BART standards for acceptable operations. This load factor allows each rider a seat with room for standees. The maximum load factor is considered 1.35 during peak hour periods. The anticipated peak hour use of BART by IKEA patrons is considered very low, since the great majority of BART patrons purchase furniture and other large items, which are not transportable on BART. Therefore, impacts to the BART are considered less~ than-significant. In regard to Bus service, local and Tri-valley bus service is provided by WHEELS. According to the WHEELS staff, the IKEA site is served by Route 12, a trunk line that provides service from the Eastern Dublin/Pleasanton BART station to Livermore, north and south of the 1-580 freeway, the ACE stat/on and returns to the BART station. Ridership on Route 12 is considered "moderate" by WHEELS staff (source: Cyrus Sheik, route planner 1/7/04). The Project site is also served by Route 1, a local route, that provides bus service from the Eastern Dublin/Pleasanton BART station, the Alameda County East County Government Center, Rose Pavilion in Pleasanton and back to the BART station. According to WHEELS staff, ridership on Route 1 is considered "low." Overall, given the moderate to low ridership, approval and implementation of the proposed Project would have a less-than-sigrdficant impact on the WHEELS bus system. The City of Dublin has conditioned the proposed Project to provide a bus stop on Martinelli Way, so future bus ridership to the IKEA center could be facilitated. Comment 3.2.7: The Dublin/Pleasanton BART station, which appears to be approximately one-quarter mile from the Project site is the site of the Dublin Transit Center and has been the recipient of funding for a parking structure to support a transit village. The Alameda County CMA is developing a policy to encourage transit-oriented development. How will the design and location of the IKEA facility, other supporting retail and parking encourage transit and pedestrian use in the Project area? Response: Although the proposed Project may not be viewed as a transit- oriented type Project, the City of Dublin complies with the proposed CMA policy of encouraging transit oriented development through the approval of the Dublin Transit Center in late 2002, which ih'dudes up to 1500 high density IKEA Final EIR PA 02-034 Page 16 City of Dublin February 2004 housing units, 2.0 million square feet of office space and 70,000 square feet of retail commercial in immediate proximity to BART and transit hub facilities. The Dublin Transit Center also includes a multi-story parking garage to accommodate BART users and Transit Center users. The City of Dublin also adopted the Western Dublin BART Specific Plan to encourage a mix of high-density housing, office, retail, lodging and other pedestrian-oriented uses adjacent to this planned BART station. This Specific Plan would comply with the proposed CMA policy as well. Comment 3.2.8: The environmental document should provide information on how the mitigation measures on the MTS will be funded. Regarding Supplemental Impact TRA-3, mitigation measures identified in the DSEIR regarding funding of regional freeway improvements should be incorporated in the summary on page 1-3. Response: Supplemental Mitigation SM-TRA-2 is the only traffic mitigation measure identified in the DSEIR. This mitigation measure involves installing geometric improvements on the southbound approach of the Dublin Boulevard/Arnold Road intersection (Dublin Boulevard is on the MTS). Project developers are required to contribute their proportionate share toward funding this improvement. Pages 64 and 65 of the DSEIR provide information regarding the funding of future roadway improvements planned within the study area. As requested by the commenter, the text in the Mitigation Measure column corresponding to Supplemental Impact TRA-3 on page 1-3 of the DSEIR is hereby amended to read as follows: "Full mitigation not feasible. Project will be required to pay for its proportionate share of impacts to 1-580 and 1-680, by payment of Th-Valley Transportation Development (TVTD) Fees to construct planned freeway improvements, including HOV lanes, auxiliary lanes, and interchange improvements. The Project will be required to pay its proportionate share toward public transportation improvements to help reduce traffic on the freeways and other roadways in the Th-Valley area, by payment of the TVTD Fee to fund the West Dublin/Pleasanton BART Station Project." Letter 3.3: Zone 7 Alameda County Flood Control and Water Conservation District (Zone 7) Comment 3.3.1: Zone 7 has no comments on the DSEIR at this time, although Zone 7 believes that earlier comments submitted to the City of Dublin responding to the Notice of Preparation needs to be addressed. IKEA Final EIR PA 02-034 Page 17 City of Dublin February 2004 Response: Comment acknowledged that Zone 7 has no comments on the environmental document. Please see responses to other NOP comments below. Comment 3.3.2: The Initial Study notes that disturbance of land of at least 5 acres are required to submit a Notice of Intent to the State Water Resources Control Board (SWRCB). As of March 10, 2003 the threshold of size has been reduced to one acre. Response: Comment acknowledged. Since the proposed Project would disturb approximately 27 acres of land, a Notice of Intent will be required to be filed with the SWRCB. Comment 3.3.3: Mitigation for the creation of new impervious surfaces would be provided through the collection of Special Drainage Area 7-1 drainage fees. Fees are collected by Zone 7 for new buildings, paving and other impervious surfaces. Response: Comment acknowledged. Payment of drainage fees have been made a condit/on of Project approval by the City of Dublin. Comment 3.3.4: The Project Description for the proposed Project does not address potential salt loading impacts on Zone 7's main groundwater basin. All applied water in the basin, except for rainwater, contributes to salt loading in the groundwater basin and use of recycled water requires mitigation for this impact. Zone 7 recommends implementation of the Groundwater Demineralization Project to minimize salt loading impacts. City support of the Groundwater Demineralization Project is requested. Response: Salt loading in the main basin is a regional issue that is being addressed by both DERWA (for recycled water in Dublin and San Ramon) and by Zone 7 (for South Bay Aqueduct water being imported for irrigation in Livermore, Dublin and Pleasanton). DERWA is working in cooperation with Alameda County Water District (ACWD) to reduce salt loading in ACWD basins in Fremont. The City of Dublin supports the actions of Zone 7 to address salt loading impacts on the main groundwater basin. Comment 3.3.5: Zone 7 requests that an existing 16-inch water line be shown on Project plans as a Zone 7 water line. Two other details are shown on Project plans that may be in error, including a manhole and branch pipeline which are not shown on Zone 7 facility maps and a proposed direct connection between IKEA water lines and the 16-inch Zone 7 water line. IKEA Final EIR PA 02-034 Page 18 City of Dublin February 2004 Direct connections with Zone 7 facilities for new development Projects are not permitted. Response: Identified engineering design and drafting errors have been referred to the City of Dublin Engineering Department and to the developer's civil engineer to be corrected prior to approval of the infrastructure plans by the City of Dublin. Comment 3.3.6: Zone 7 requests that water valves and other appurtenances located within the limits of construction must be clearly located prior to construction. An encroachment permit must be obtained when working near Zone 7 facilities. Response: Comment acknowledged. Although this is not an environmental comment, the need to identify Zone 7 facilities on all const2'uction plans and the requirement to obtain an encroachment permit has been communicated to the Project developer for implementation. Comment 3.3.7:Zone 7 records indicate that no water wells or monitoring wells are located on the Project site. If these are found, they should be reported to Zone 7. Future wells or soil borings are only allowed with permits issued by Zone 7. Response: Comment acknowledged. The City of Dublin or project' contractor(s) will report any water wells to Zone 7 staff and will obtain permits for new wells or soil borings. Comment 3.3.8: Developments that increase impervious surfaces are subject to special drainage fees, which are collected by the governing agency. There are no Zone 7 flood control facilities on the Project site. Response: Comment acknowledged. Zone 7 will be collected by the City of Dublin from the project developer as a condition of project approval and forwarded to Zone 7. Letter · 3.4: City of Livermore Comment: The DSEIR acknowledges significant and unavoidable impacts on regional roads, including 1-580. The Eastern Dublin EIR includes traffic and transportation mitigation measures to partially mitigate such impacts. The City of Livermore requests that the City of Dublin require a ramp metering system on the westbound 1-580 ramp at Hacienda. Ramp metering systems are also encouraged for all other 1-580 ramps within Dublin. IKEA Final EIR PA 02-034 City of Dublin Page 19 February 2004 Response: The issue of implementing ramp metering at all freeway interchanges along the 1-580 corridor within the Tri-Valley area is a regional issue that requires a cooperative effort among the cities of Dublin, Livermore and Pleasanton to manage traffic flow in this corridor more efficiently and equitably. These three cities, as well as other outlying jurisdictions to the east, including San Joaquin County communities, all share the responsibility of contributing trips to 1-580. In Year 2025, traffic flow on westbound 1-580 is projected to operate at level of service E or F from Hacienda Drive to 1-680 during the AM and PM peak hours, as shown on Tables 4.3.12 and 4.3.13 of the DSEIR. Based on recent field observations, traffic backups on westbound 1-580 tend to occur during the peak hours from Hacienda Drive to the 1-680 interchange primarily because of the bottleneck created by the weaving segment between Dougherty Road and 1-680, whereby mainline traffic is forced to slow down considerably due to a conflict between vehicles diverg4ng from mainline to reach the connector ramps to 1-680 and vehicles merging the opposite way to join the mainline freeway after entering westbound 1-580 from Dougherty Road / Hopyard Road. It may seem logical to meter the Hacienda Drive westbound on-ramps at this time to help reduce traffic congestion on westbound 1-580. However, if the City of Dublin did implement ramp metering at a single location such as Hacienda Drive, a portion of the traffic that would otherwise use this interchange to access the freeway would now shift to downtown Dublin to access the freeway via the Dougherty Road and San Ramon Road interchanges in order to avoid traffic backups caused by the meters at the Hacienda Drive interchange. This, in turn, would result in unacceptable increases in traffic volumes at downtown intersections, which are highly congested during the commute peak periods. Moreover, by shifting trips to the Dougherty Road/Hopyard Road westbound on-ramps, the severity of the (bottleneck) weaving segment, described above, would likely intensify and overall traffic conditions on westbound 1-580 could worsen during the peak periods. Caltrans and the cities of Dublin, Livermore and Pleasanton should work cooperatively on a ramp metering plan for the 1-580 corridor that can be implemented in all three cities, while allowing any negative impacts from ramp metering on the adjoining surface streets and intersections to be distributed equitably among all three titles. The plan should ensure that vehicle queues and delays from metered ramps do not impose a disproportionate or excessive burden on any particular community or group of trip-makers. Based on the above, ramp metering of westbound 1-580 on-ramps at a single location such as Hacienda Drive (i.e., without consideration to implementation of a multi-jurisdictional, corridor-wide ramp metering approach) could have adverse impacts on traffic conditions in downtown IKEA Final EIR PA 02-034 City of Dublin Page 20 February 2004 Dublin and on the freeway, and is not required as a mitigation measure of the proposed project. Letter · 4.1: Michael Durkee (Allen Matkins Leek Gamble & Mallory) Comment: Comments are provided in the letter regarding a comparison of the proposed IKEA Project with the previous Commerce One project on the same site, that the proposed IKEA Project would not result in a significant traffic increase over the Commerce One project and that the proposed IKEA Project assists in implementing the City's vision for fiscal health and development of the area as reflected in the Eastern Dublin General Plan, Eastern Dublin Specific Plan and similar documents. Response: Comments acknowledged. The commenter provides opinions regarding the merits of the proposed Project and not environmental issues. No further response is therefore required. IKEA Final EIR PA 02-034 Page 21 City of Dublin February 2004 IKEA Final EIR PA 02-034 City of Dublin Appendix A Table 4.3.8 Page 22 February 2004