HomeMy WebLinkAboutItem 7.1 - 1592 Staff Comments on BART to Livermore DEIR
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STAFF REPORT
CITY COUNCIL
DATE: October 3, 2017
TO: Honorable Mayor and City Councilmembers
FROM:
Christopher L. Foss, City Manager
SUBJECT:
BART to Livermore Draft Environmental Impact Report - Staff Comments
Prepared by: Obaid Khan, Transportation and Operations Manager
EXECUTIVE SUMMARY:
The City Council will receive Staff comments on the Draft Environmental Impact Report
(DEIR) for the BART to Livermore Extension Project. Staff comments are focused on
DEIR sections for Air Quality, Land-Use, Noise and Transportation.
STAFF RECOMMENDATION:
Receive Staff comments on the BART to Livermore Extension Project Draft
Environmental Impact Report.
FINANCIAL IMPACT:
None.
DESCRIPTION:
On July 31, 2017, BART issued a Draft Environmental Impact Report (DEIR) for the
proposed BART to Livermore Extension Project. The comment period for the DEIR will
close on October 16, 2017. The Proposed Project, which is also referred to as the
Conventional BART Project, would extend transit service 5.5 m iles east into eastern
Alameda County from the existing Dublin/Pleasanton BART Station (Dublin/Pleasanton
Station) within and adjacent to the I-580 right-of-way (ROW), through the cities of Dublin
and Pleasanton, to a proposed new terminus station located at the Isabel Avenue/I-580
interchange in the City of Livermore.
The DEIR evaluates the potential impacts of the Proposed Project and three Build
Alternatives - the Diesel Multiple Unit (DMU) Alternative (which includes a variant
referred to as the Electrical Multiple Unit [EMU] Option), the Express Bus/Bus Rapid
Transit (BRT) Alternative, and the Enhanced Bus Alternative. The three Build
Alternatives and a No Project Alternative (or No Build Alternative) are evaluated at the
same level as the Proposed Project in the DEIR. Below are summary descriptions of the
Proposed Project and the three Build Alternatives.
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Conventional BART Project (Proposed Project). The Proposed Project involves
extending the Daly City-Dublin/Pleasanton Line from its existing terminus at the
Dublin/Pleasanton Station approximately 5.5 miles to the east, to a new station located
at the Isabel Avenue/I-580 (State Route 84) interchange in the City of Livermore. The
new alignment and the new Isabel BART Station (Isabel Station) would be constructed
in the I-580 median. New parking facilities, a parking structure and surface lot
containing a total of approximately 3,412 spaces, would be constructed immediately
south of I-580 along East Airway Boulevard. In addition, a new, approximately 6 8-acre
BART storage and maintenance facility would be constructed north of I -580, beyond the
Isabel Station.
To accommodate the widening of the I -580 median for the new BART alignment and
Isabel Station, the California Department of Transportation (Caltrans) ROW would be
widened along approximately 5.6 miles. I-580 lanes would be relocated by a total of
approximately 46 feet, from just east of the Hacienda Drive interchange to west of the
Portola Avenue/I-580 overcrossing. At the proposed Isabel Station, I-580 would be
relocated by approximately 67 feet to accommodate the new station within the median.
The relocation of I-580 would require modification of some interchanges and surface
frontage roads.
DMU/EMU Alternatives. The DMU Alternative differs from the Proposed Project in
terms of vehicle technology. DMUs are self-propelled rail cars that use a diesel engine
to generate their own power and run on a standard -gauge rail track, whereas BART
trains use electricity and run on wide-gauge rail track.
The DMU Alternative would have a similar median alignment and station configuration
as the Proposed Project, but would have a longer total length of freeway alignment
changes and includes a new transfer platform at the Dublin/Pleasanton Station. A new
parking structure for the Isabel Station, with approximately 2,428 parking spaces, would
be constructed immediately south of I-580 along East Airway Boulevard. In addition, a
new, approximately 32-acre storage and maintenance facility would be constructed
north of I-580, beyond the terminus of the alignment.
To accommodate the median widening, approximately 7.1 miles of I -580 would be
relocated by a total of approximately 46 feet, from west of the Dougherty Road/Hopyard
Road interchange to the Portola Avenue/I -580 overcrossing. Around the
Dublin/Pleasanton Station, the north side of I -580 would be relocated to accommodate
the new DMU transfer platform. At the proposed Isabel Station, I-580 would be
relocated approximately 67 feet to accommodate the station within the median. The
relocation of I-580 would require modification of some interchanges and surface
frontage roads. The DMU Alternative includes the same feeder bus component as the
Proposed Project, including new and modified bus routes connecting the new sta tion to
areas east of the BART system.
A variant of the DMU Alternative-the Electric Multiple Unit (EMU) Option is also being
considered. The EMU Option is generally the same as the DMU Alternative, except that
it is electrically powered rather than diesel-powered.
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Express Bus/BRT Alternative. The Express Bus/BRT Alternative seeks to achieve the
project goals using bus technology only. This alternative does not include an extension
of BART rail service or development of a new rail station. Under this alt ernative, new
bus transfer platforms would be constructed at the existing Dublin/Pleasanton Station.
Buses would enter these bus-only transfer areas via direct bus-only ramps from the I-
580 express lanes, allowing passengers to transfer from bus to BART wi thin the station.
To accommodate the new bus transfer platforms and facilities under this alternative,
approximately 2.2 miles of I-580, from west of the Dougherty Road/Hopyard Road
interchange to the Tassajara Road/Santa Rita Road interchange, would be relocated by
approximately 88 feet. The relocation of I-580 would require modification of some
interchanges and surface frontage roads.
A new parking lot or garage on the Pleasanton side with approximately 210 parking
spaces would be constructed at the Dublin/Pleasanton Station to replace the 210
parking spaces removed for the relocation of I-580 to accommodate the bus platforms.
In addition, a remote, approximately 230 -space park-and-ride lot would be constructed
at Laughlin Road; regular bus service would be provided during peak hours from the
Laughlin parking lot to the Dublin/Pleasanton Station.
Enhanced Bus Alternative. Like the Express Bus/BRT Alternative, the Enhanced Bus
Alternative uses bus-related technology only and does not include an extensio n of
BART rail service or the development of a new rail station. Unlike the Express Bus/BRT
Alternative, however, this alternative does not include any major capital improvements
and would not involve the development of bus transfer platforms or direct bus ramps.
Table 1 provides a summary of ROW take for Conventional BART and Build
Alternatives.
Table 1
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Staff Comments:
Staff has reviewed the relevant sections of the DEIR and has prepared comments
(Attachment 1) for the City Council’s consideration and input. The key issues and
concerns for the City to consider are summarized below.
Land Use and Business Impacts - While the Proposed Project would have some
impacts to the City’s ROW along the north side of the I -580, the two build alternatives
(DMU/EMU and Express Bus/BRT) would cause significant impacts to the businesses
and properties in the City.
Staff has significant concerns about some of the ROW acquisition required for the
DMU/EMU and Express Bus/BRT Alternatives. Many of Dublin’s key reven ue and
employment generators are located along I-580. As such, any potential purchase of
ROW will need to identify the full impacts, including short and long -term viability of
affected businesses and ongoing revenue impacts to both the businesses and to th e
City.
The DEIR identifies the surface frontage roads and structures adjacent to I -580 that
would need to be relocated in order to accommodate the Proposed Project and
Alternatives. The relocation of the frontage roads would result in potentially sig nificant
impacts to some of the existing and key businesses in the City of Dublin.
The DEIR did not provide specific details on each ROW impact. However, BART staff
provided additional details that are shown in attached Figures 1 to 3. Staff’s specific
comments on the land use concerns are detailed in Attachment 1.
Transportation Impacts - The DEIR discloses many Transportation Impacts and
provides mitigations. However, Staff noted several modeling assumption errors and
issues that could result in incorrect answers. Some of the key issues are listed below:
1) An overall problem with the Draft EIR is its failure to adequately analyze the
impacts of the DMU, Express Bus/BRT, and Enhanced Bus alternatives within
the City of Dublin, and particularly near the Dublin/Pleasanton BART Station.
2) The DEIR has assumed that the BART garage expansion at the
Dublin/Pleasanton Station would only occur with the Isabel Neighborhood Plan
(INP) implementation in Livermore. However, the DEIR did not include the
funding for the garage expansion as part of the BART system. This is not the
correct way to assume improvements while not including the funding for it,
especially when garage construction is the responsibility of BART on its own
property.
3) The DEIR assumed that under the Cumulative scenarios for 2025 and 2040, INP
in Livermore will have additional land -use changes that could not be evaluated
separately from the Dublin/Pleasanton Garage Expansion traffic patterns. This
leads to not knowing the impacts that would be with the INP land-use addition to
the Proposed Project and alternatives in conjunction with or without a
Dublin/Pleasanton Garage Expansion.
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4) The DEIR has proposed mitigation at Dublin Blvd and Dougherty Road
intersection due to the Proposed Project and the Alte rnatives. The proposed
mitigation would add a third southbound left-turn lane and a second westbound
right turn lane, which will require widening of the intersection through property
acquisitions from existing businesses. Widening of the intersection is no t
recommended due to a longer crossing distance for pedestrians and property
impacts to existing businesses. As an alternative mitigation, staff suggests that
BART should implement an Adaptive Traffic Signal system along Dougherty
Road to mitigate the significant impacts.
5) The DEIR has several incorrect model assumptions for the City of Dublin’s
roadway infrastructure. The incorrect assumptions would create incorrect model
results for impacts to the City of Dublin roadway infrastructure and intersections,
and any related mitigations need to be redone.
6) Under the DMU/EMU and Express Bus/BRT Alternatives, DEIR (Chapter 2,
Project Descriptions) did not provide any time loss for transfer of passengers
from one type of vehicle to the Conventional BART at Dublin/Pleasanton Station.
This loss of time is critical in comparing the Conventional BART with other
Alternatives.
Air Quality and Noise Impacts - The DEIR discusses Air Quality and Noise impacts
but did not disclose the impacts associated with the relocation of I-580 that will bring the
freeway closer to the City boundary, thus creating potential significant Air Quality and
Noise impacts. Additional construction related Noise impacts were disclosed by the
DEIR, but it failed to provide alternative approaches and technologies that could fully
address these impacts.
CONCLUSION:
Staff has found significant impacts to the City of Dublin's land -uses due to the BART to
Livermore Extension Project's Build Alternatives (Diesel Multiple Unit/Electric Multiple
Unit [DMU/EMU] and Express Bus/BRT) as compared to the Proposed Project
(Conventional BART). These Build Alternatives will significantly alter the City's ROW
along the north side of I-580 freeway causing impacts to the existing businesses and
public facilities. Furthermore, the DEIR failed to provide appropriate mitigation details for
the land-use impacts in the City of Dublin.
Staff has noted several errors in modeling assumptions in Transportation impacts
analysis. These errors may have led to incorrect res ults associated with various traffic
circulation and access impacts for the Proposed Project and Alternatives. Therefore it is
requested that the model assumptions be corrected and disclosed in the Final EIR.
Air Quality and Noise impacts are not properly analyzed especially those that will occur
due to the widening of the I-580. This shift will bring the freeway traffic closer to the City
of Dublin’s land-uses, thus creating significant impacts.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
None.
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ATTACHMENTS:
1. Staff Comments on the BART to Livermore Extension Project Draft Environmental
Impact Report
2. Exhibit A to the Staff Comments on the BART to Livermore Extension Project Draft
Environmental Impact Report
3. Figure 1 - Conventional BART Alternative Impacts
4. Figure 2 - DMU/EMU Alternative Impacts
5. Figure 3 - Express Bus/BRT Alternative Impacts
Attachment 1
Staff Comments on the Draft Environmental Impact Report for the
BART to Livermore Project
Proposed Project and Alternatives Descriptions
Conventional BART Project (Proposed Project). The Proposed Project involves extending
the Daly City-Dublin/Pleasanton Line from its existing terminus at the Dublin/Pleasanton BART
Station (Dublin/Pleasanton Station) approximately 5.5 miles to the east, to a new station located
at the Isabel Avenue/I-580 (State Route 84) interchange in the city of Livermore. The new
alignment and the new Isabel BART Station (Isabel Station) would be constructed in the I-580
median. New parking facilities—a parking structure and surface lot containing a total of
approximately 3,412 spaces—would be constructed immediately south of I-580 along East
Airway Boulevard. In addition, a new, approximately 68-acre BART storage and maintenance
facility would be constructed north of I-580, beyond the Isabel Station.
To accommodate the widening of the I-580 median for the new BART alignment and Isabel
Station, the California Department of Transportation (Caltrans) right-of-way (ROW) would be
widened along approximately 5.6 miles. I-580 lanes would be relocated by a total of
approximately 46 feet, from just east of the Hacienda Drive interchange to west of the Portola
Avenue/I-580 overcrossing. At the proposed Isabel Station, I-580 would be relocated by
approximately 67 feet to accommodate the new station within the median. The relocation of I-
580 would require modification of some interchanges and surface frontage roads.
Diesel Multiple Unit/Electric Multiple Unit Alternatives. The (DMU) Alternative differs from
the Proposed Project in terms of vehicle technology. DMUs are self -propelled rail cars that use
a diesel engine to generate their own power and run on a standard-gauge rail track, whereas
BART trains use electricity and run on wide-gauge rail track.
The DMU Alternative would have a similar median alignment and station configuration as the
Proposed Project, but would have a longer total length of freeway alignment changes and
includes a new transfer platform at the Dublin/Pleasanton Station. A new parking structure for
the Isabel Station, with approximately 2,428 parking spaces, would be constructed immediately
south of I-580 along East Airway Boulevard. In addition, a new, approximately 32-acre storage
and maintenance facility would be constructed north of I-580, beyond the terminus of the
alignment.
To accommodate the median widening, approximately 7.1 miles of I-580 would be relocated by
a total of approximately 46 feet, from west of the Dougherty Road/Hopyard Road interchange to
the Portola Avenue/I-580 overcrossing. Around the Dublin/Pleasanton Station, the north side of
I-580 would be relocated to accommodate the new DMU transfer platform. At the proposed
Isabel Station, I-580 would be relocated approximately 67 feet to accommodate the station
within the median. The relocation of I-580 would require modification of some interchanges and
surface frontage roads.
The DMU Alternative includes the same feeder bus component as the Proposed Project,
including new and modified bus routes connecting the new station to areas east of the BART
system.
A variant of the DMU Alternative—the Electric Multiple Unit (EMU) Option—is also being
considered. The EMU Option is generally the same as the DMU Alternative, except that it is
electrically powered rather than diesel-powered.
Express Bus/BRT Alternative. The Express Bus/BRT Alternative seeks to achieve the project
goals using bus technology only. This alternative does not include an extension of BART rail
service or development of a new rail station. Under this alternative, new bus transfer platforms
would be constructed at the existing Dublin/Pleasanton Station. Buses would enter these bus-
only transfer areas via direct bus-only ramps from the I-580 express lanes, allowing passengers
to transfer from bus to BART within the station.
To accommodate the new bus transfer platforms and facilities under this alternative,
approximately 2.2 miles of I-580, from west of the Dougherty Road/Hopyard Road interchange
to the Tassajara Road/Santa Rita Road interchange, would be relocated by approximately 88
feet. The relocation of I-580 would require modification of some interchanges and surface
frontage roads.
A new parking lot or garage on the Pleasanton side with approximately 210 parking spaces
would be constructed at the Dublin/Pleasanton Station to replace the 210 parking spaces
removed for the relocation of I-580 to accommodate the bus platforms. In addition, a remote,
approximately 230-space park-and-ride lot would be constructed at Laughlin Road; regular bus
service would be provided during peak hours from the Laughlin parking lot to the
Dublin/Pleasanton Station.
Enhanced Bus Alternative. Like the Express Bus/BRT Alternative, the Enhanced Bus
Alternative uses bus-related technology only and does not include an extension of BART rail
service or the development of a new rail station. Unlike the Express Bus/BRT Alternative,
however, this alternative does not include any major capital improvements and would not
involve the development of bus transfer platforms or direct bus ramps.
DEIR’s Analysis Scenarios
Year 2040
Land use at
Isabel
Land use
elsewhere
DP
garage1
expansion
BART or
Alternative
Future Baseline
(PBA)
PBA2 2040 PBA 2040 No No
Future Project PBA 2040 PBA 2040 No Yes
Future Cumulative INP3 2040 PBA 2040 Yes Yes
Year 2025
Land use at
Isabel
Land use
elsewhere
DP garage
expansion
BART or
Alternative
Future Baseline
(PBA)
PBA 2025 PBA 2025 No No
Future Project PBA 2025 PBA 2025 No Yes
Future Cumulative INP 2025 PBA 2025 Yes Yes
Year 2013
Land use at
Isabel
Land use
elsewhere
DP garage
expansion
BART or
Alternative
Existing Conditions Existing Existing Existing No
1. DP Garage – Dublin Pleasanton BART Garage expansion
2. PBA – Plan Bay Area/ABAG
3. INP – Isabel Neighborhood Plan
City of Dublin COMMENTS
A. Land Use Impacts
The City of Dublin has significant concerns about some of the right-of-way (ROW) acquisition
required by the Proposed Project, DMU & EMU Alternative and Express Bus Alternative
currently being considered and we appreciate the opportunity to provide comments on the
DEIR. Many of Dublin’s key revenue and employment generators are located along I-580. As
such, any potential purchase of ROW will need to identify the full impacts including short and
long-term viability of affected businesses and ongoing revenue impact to both the businesses
and to the City.
The DEIR identifies the surface frontage roads and structures adjacent to I-580 that would need
to be relocated outward in order to accommodate the Proposed Project and Alternatives. The
relocation of the frontage roads results in potentially significant impacts to some of the existing
and key businesses in the City of Dublin. The proposed roadway footprints as provided in
Appendix B: Footprint Map Books of the DEIR, provide insufficient information to determine the
severity of the potential impact to each parcel. The DEIR does not provide any dimensions or
details on the necessary roadway and parcel modifications required to relocate the ROW and
how those impacts will be mitigated. For example, under the DMU Alternative, the relocation of
Scarlett Court shows the potential roadway to extend into the Hyundai and Volkswagen
Dealerships parking areas; however, no details are provided as to how much of the existing
parking lots will need to removed, number of parking spaces eliminated, how the removal of the
landscape buffer strip will impact the public safety and aesthetics and how the new roadway
alignment will impact the on-site circulation. No mitigation has been provided to address these
impacts. Auto dealerships are very sensitive about location, visibility of dealership and
automobiles, and inventory storage. The ability to showcase and store vehicles is critical and
these ROW purchases could have significant impacts, not only to the dealership’s revenues, but
potentially the City’s tax base. The table below provides an outline of all potentially significant
ROW impacts to the City of Dublin identified in Appendix B of the DEIR that are not sufficiently
detailed in the analysis.
Table A. Potentially Significant ROW Impacts
PROPOSED PROJECT – Conventional BART
ROW Parcel Impact Potential Impacts
Northside Drive Lowe’s
(985-0061-007-00/-015-
00)
The relocation of Northside Drive shows the
potential roadway and ROW need impacting the
Lowe’s parking lot. Any reduction in parking level
may impact future ability to construct new stores
or replace existing tenants in the future.
PROJECT ALTERNATIVE – DMU & EMU Alternatives AND Express Bus Alternatives
ROW Parcel (APN) Potential Impacts
Scarlett Court Hyundai Dealership
(941-0550-025-02)
Volkswagen Dealership
(941-0550-032-02/-03)
The relocation of Scarlett Court shows the
potential roadway to extend into the Hyundai and
Volkswagen Dealerships parking areas, thus
removing the landscape buffer, parking area and
impacting on-site circulation. This parking impact
is a significant impact to access and circulation,
and no mitigation has been provided to address
this impact.
Scarlett Court El Monte RV Rentals
(941-0550-016-04)
U-Haul Truck Rental
(941-0550-037-05)
The relocation of Scarlett Court creates potential
access issues for the business west of Scarlett
Drive. This road serves the recreational vehicle
operator, U-Haul Truck Rental and El Monte RV
Rentals as well as automotive delivery trucks to
the Dublin Mazda Dealership. City staff feels that
any narrowing would cause significant impacts to
the adjacent uses.
Scarlett Court Alameda County Fire
Department and Dublin
City Maintenance
Building
(941-0550-077-01)
The relocation of Scarlett Court has significant
impacts for the City and Alameda County’s
operations. In 2014, the Alameda County facility
was remodeled and the City Corporation Yard
was constructed. Both of these facilities provide
maintenance support to local and regional
government agencies and will be challenging to
relocate, if necessary. The relocation will impact
the parking and frontage improvements at a
minimum. The loss of the City’s maintenance
facility will be costly to replicate.
I-580 Frontage Hacienda Crossings
(986-0008-001-00)
Hacienda Crossings is a very popular regional
shopping and entertainment destination with tight
parking during the weekend.
Express Bus Alternative:
ROW expansion identifies removal of the
landscape buffer along I-580 which serves both
an aesthetic and public safety function between
the parking lot and the freeway. This impact
could be a significant impact; however, no site
level details are provided so that the impacts can
be identified and no mitigation has been provided
to address this potential impact.
DMU/EMU Alternative:
The ROW expansion includes those impacts
identified above for the Express Bus Alternative
and further removal of a large portion of the
parking area near the Hacienda Drive off-ramp.
This ROW expansion will have a significant
impact to parking and on-site circulation in this
area of the shopping center and no mitigation
has been provided to address this impact. Any
proposed ROW adjustment will need to be
carefully crafted with the property owner to
ensure full replacement of the displaced parking,
as well as thoughtful construction placement to
ensure no loss of visibility of existing businesses.
I-580 Frontage Toyota Dealership
(986-0016-023-00/024-
00)
ROW expansion identifies removal of the
landscape buffer along I-580 which serves both
an aesthetic and safety function between the
parking lot and the freeway.
I-580 Frontage Chevrolet/Cadillac
Dealership
ROW expansion identifies removal of the
landscape buffer along I-580 which serves both
(986-0016-004-01)
an aesthetic and safety function between the
parking lot and the freeway.
PROJECT ALTERNATIVE – DMU & EMU Alternatives ONLY
ROW Parcel Impact Potential Impacts
Northside Drive Lowe’s
(985-0061-007-00/-015-
00)
The relocation of Northside Drive shows the
potential roadway and ROW need impacting the
Lowe’s parking lot. Any reduction in parking level
may impact future ability to construct new stores
or replace existing tenants in the future.
I-580 Frontage IKEA Retail Center
Project
(986-0033-005-02/-006-
00)
The impact to the future development of this
parcel is significant. The current property owner
is exploring development scenarios for this site
and we believe the impacts would be
unacceptable as they would significantly impact
the ability to develop the site.
Dublin/Pleasant
BART Station
Access Road
Dublin/Pleasanton
BART Station (986-
0034-019-00)
This alternative relocates the ROW into the
surface parking area of the future garage
expansion at the Dublin Pleasanton BART. This
alternative will move Altamirano Road into the
surface lot for Dublin/Pleasanton BART station
on the Dublin side next to the existing BART
garage removing available parking. This parking
impact is a significant impact to access and
circulation, and no mitigation has been provided
to address this impact. Our review indicates that
a similar parking impact on the south side of I-
580 in Pleasanton under the Express Bus/BRT
alternative was mitigated by either providing new
surface lot parking or by building a garage (see
Chapter 2, Page 151). So it is not clear why
BART has not addressed a similar significant
impact on the north side of I-580 in Dublin under
a different alternative. Additionally, the
Cumulative analyses for the Project and all
alternatives have assumed a future BART
garage expansion at the Dublin Pleasanton
BART station. By having the space for the future
BART garage expansion impacted without
mitigation, cumulative analysis results for the
Express Bus/BRT alternative are not valid and
need to be redone.
As stated in the DEIR, “Acquisition of privately owned land—including businesses, farm
operations, and/or parking”—is considered a significant impact. Therefore, the Proposed Project
[DMU/EMU Alternative and Express Bus Alternative] would result in a potentially significant
impact related to displacement of businesses. This impact would be reduced to a less-than-
significant level with implementation of Mitigation Measure PH-2, which would require BART to
implement an acquisition and relocation program. (p. 543)
Mitigation Measure PH-2: Acquisition of Property and Relocation
Assistance. (Conventional BART Project and DMU Alternative/EMU
Option)
BART’s Real Estate Department will implement an acquisition and relocation
program that meets the requirements of applicable State acquisition and
relocation law. Acquisition will involve compensation at fair market value for
properties, and relocation assistance would include, but is not limited to, down
payments or rental supplements, moving costs, business reestablishment
reimbursement, and goodwill offers as appropriate. All benefits will be provided
in accordance with the California Relocation Assistance and Real Property
Acquisition Guidelines.
While the acquisition and relocation program may meet the applicable State acquisition
and relocation law, the issue lies in the DEIR not disclosing the actual physical impacts
to each property. The level of detail provided in the DEIR does not provide sufficient
information to determine what acquisition would be required and how that acquisition
would impact each parcel. As previously stated, the properties along I-580 are home to
some of the community’s key businesses and impacts to public safety, aesthetics and
functionality of the property that remove parking, modify circulation patterns, limit
visibility from I-580 are considered to be significant impacts and no mitigation has been
provided to address these impacts.
Requested Change:
Provide detailed ROW acquisition needs by each parcel and provide
description on how each acquisition would impact the property. Include
proposed mitigation to address public safety, aesthetics and functionality
of the property with removed parking, changed circulation patterns, and
visibility from I-580.
B. Transportation Impacts
An overall problem with the Draft EIR is its failure to adequately analyze the impacts of the
DMU, Express Bus/BRT, and Enhanced Bus alternatives within the City of Dublin, and
particularly near the Dublin/Pleasanton BART Station. Both the DMU and Express Bus/BRT
alternatives contemplate significant infrastructure improvements at the Dublin/Pleasanton BART
Station, including new platforms and track extensions. And the Enhanced Bus Alternative
contemplates operational changes at the Dublin/Pleasanton BART Station, particularly a
significant increase in bus traffic on existing streets. And yet, portions of the EIR expressly
exclude analysis of impacts in and around this station. For example, page 252 states that "The
bicycle study areas include all bicycle facilities within a 15-minute bike ride of the proposed
Isabel Station" and page 256 similarly states that "The study area for pedestrians comprises all
pedestrian facilities . . . within a 15-minute walk from the proposed Isabel Station." These
statements suggest that the Draft EIR did not study bicycle and pedestrian im pacts resulting
from project changes to the Dublin/Pleasanton BART Station, notwithstanding the fact that
these alternatives contemplate significant infrastructure and/or operational changes at that
location. This is a problem with the Draft EIR's analysis of those three Build alternatives but not
of the Conventional BART Project alternative, since that alternative does not contemplate
significant infrastructure or operational changes at the Dublin/Pleasanton BART Station.
Traffic Model Assumptions
1. The Draft EIR (DEIR) has assumed that the BART garage expansion at the
Dublin/Pleasanton Station would occur with the Project in Cumulative conditions, but did
not include the funding for the garage expansion. This is not the correct way to assume
Project Cumulative conditions while not including the funding for it, especially when
constructing a garage is the responsibility of BART on its own land. This needs to be
corrected in the model to reflect the proper No-Project conditions that would also change
the traffic patterns under the “With” and “Without” Project scenarios. Garage Expansion
at the Dublin Pleasanton Station should either be part of the future baseline (background
development) without Project or be kept as currently it is in the DEIR but with funding
provided for the garage construction as part of the Project. Furthermore, as per the
Chapter 3, Environmental Analysis, Page 226, DEIR assumed that under the Cumulative
scenarios for 2025 and 2040, Isabel Neighborhood Plan (INP) in Livermore will have
additional land use changes that could not be evaluated separately from the Garage
Expansion traffic patterns, which in turn impacts the With Project analysis results. For
example, it is not clear what impacts would be with the INP land use addition in
conjunction with the Project and the Alternative alone would have on the system.
Requested Change:
Move the BART Garage expansion at Dublin/Pleasanton BART Station to
the future 2025 and 2040 baseline Without Project Conditions, similar to
many other local and regional projects in this corridor.
2. The DEIR’s Chapter 3, Environmental Analysis, Table 3.B-18, Page 281, provides 2025
and 2040 roadway improvements assumptions used in traffic models. There are several
incorrect assumptions in this table for the City of Dublin’s roadway infrastructure. The
incorrect assumptions would create incorrect model results for impacts to the City of
Dublin roadway infrastructure and intersections, and any related mitigations need to be
redone.
Requested Change:
Use the attached (Exhibit A) corrections to Table 3.B-18 and update the
traffic models network.
Other Transportation Related Technical Issues
1. Under the DMU/EMU and Express Bus/BRT Alternatives, DEIR (Chapter 2, Project
Descriptions) did not assume any time loss for transfer of passengers from one type of
vehicle to the Conventional BART at Dublin/Pleasanton Station. This loss of time is
critical in comparing the Conventional BART with other Alternatives. Additionally, there
was no mention of travel time for buses under the Express Bus/BRT Alternative. This will
be an important factor to know and compare as part of the information disclosure about
project alternatives.
Requested Changes:
i. Provide the transfer time loss for DMU/EMU and Express Bus/BRT
Alternatives.
ii. Provide travel time of Express Bus/BRT from Park and Ride facilities
connecting the Express Bus/BRT to conventional BART at Dublin
Pleasanton BART station.
2. DEIR failed to evaluate bicycle and pedestrian related impacts outside the INP. The
bicycle and pedestrian impact evaluation was considered for access within 15 minute
ride or walk from the future Isabel Station.
Requested Change:
Identify and evaluate the bicycle and pedestrian impacts at
Dublin/Pleasanton Station and surrounding streets that will be impacted by
the Project and Alternatives.
3. Chapter 3 of the DEIR on Page 226 provides the Cumulative Projections for population,
employment, and housing. It states that “For the quantitative sections, the cumulative No
Project Conditions for 2025 and 2040 are based on the traffic volumes forecast for those
years determined by the Travel Demand Model. The Travel Demand Model is a
computer model used to forecast travel volumes by different travel modes (BART, bus,
automobile, etc.) across a transportation network based on projected land uses.”
However in Appendix E, the DEIR states, “the proposed Dublin/Pleasanton Station
Parking Expansion and the City of Livermore’s INP are two specific probable future
projects/plans that are the focus of the projects/plans considered in the cumulative
analysis. In addition, a list of other approved or reasonably foreseeable projects in the
BART project corridor was developed.” Then in Chapter 3, Page 226, DEIR states, “This
EIR uses a combination of the two approaches for the analysis of cumulative impacts;
that is, the projections-based approach is used, but is augmented where appropriate
with the list-based approach of past, present, and probable future projects in the project
area.” It is not clear if list projects were coded into the model by replacing the assumed
land use in the Alameda CTC’s regional model’s TAZs with the projects in the list.
Requested Change:
Provide a clarification on how the list projects were used in the travel
demand model forecasts for Cumulative conditions in 2025 and 2040. Was
the model land use modified or not? Or something else?
4. Table 3.B-23 of the DEIR shows the Dublin/Pleasanton BART station boardings. Then
on the next page third paragraph, it states “Under 2040 Cumulative Conditions, which
includes a net expansion of the Dublin/Pleasanton Station parking by 540 spaces, that
station attracts a large number of additional park -and-ride BART patrons—a higher
number than the increase in supply, as some spaces are used more than once during
the day or serve multiple patrons who are carpooling together.” However, a similar
change or relative change did not occur between the No Project and With Project
conditions for Park and Ride mode when there will significantly be more BART service to
the Isabel Station. So why no change? Additionally, a recent BART Board action has
modified the garage construction with hybrid parking supply plan. The supply of hybrid
parking will not be concentrated at the planned garage site. How this Board action would
impact the assumed circulation under the cumulative scenarios for Project and other
build alternatives.
Requested Changes:
i. Provide the reasoning behind no change in Park and Ride mode share
between the No Project and Project Conditions in Table 3.B-23.
ii. Provide an analysis on traffic circulation changes due to a decision by the
BART Board on supplying planned 540 parking spaces through a hybrid
parking supply scheme instead of a parking garage on Dublin Side of
the Dublin/Pleasanton BART station. Also to note that the hybrid
parking supply will have different traffic circulation and operations due to
the distributed location of parking as compared to a garage. Due to
these changes many of the current traffic analysis outcomes may no
longer be valid.
5. Table 3.B-30 provides VMT Reduction summary for the Project and Alternatives for
various future year scenarios. The results indicate an increase in VMT when there is
additional parking spaces are provided at the Isabel Station and at the
Dublin/Pleasanton Station. The explanation on the next page states; “The cumulative
analysis for 2025 results in smaller VMT reductions for the Proposed Project and DMU
Alternative than the VMT reductions for the Proposed Project and DMU Alternative in the
2025 project analysis. This is due to the level of parking supply assumed for the
Proposed Project and the DMU Alternative under the cumulative analysis in comparison
to the project analysis. The Proposed Project and DMU Alternative provide enough
parking supply at the Isabel Station to meet the parking demand projected for the
station, as well as to absorb a substantial portion of the latent parking demand
originating from areas relatively close to the Dublin/Pleasanton Station. The presence of
new parking at the Dublin/Pleasanton Station under the cumulative analysis—in addition
to the significant proposed supply of parking at the Isabel Station—in total offers enough
parking to attract park-and-ride trips to the station from greater distances, ultimately
resulting in an increase in auto VMT under the cumulative analysis relative to the project
analysis.”
This conclusion is confusing. Given the fact that if one passenger goes to BART Station
due to the availability of additional parking supply, then there should be a reduction in
the length of the trip when compared to the same passenger driving to the final
destination, like San Francisco. So it is critical to check the difference or the delta of trip
length to BART and to that of driving all the way to the final destination. Also it is not
clear what share of riders came from San Joaquin County due to the expanded BART
service. This would provide some idea on trip lengths that were attracted to BART with
and without expanded parking.
Requested Changes:
i. Provide a comparison of trips diverted from the roadway network
including I-580 under various scenarios for 2025 and 2040 due to the
availability of expanded BART service and additional parking at
Dublin/Pleasanton BART Station and Isabel Station.
ii. Provide an explanation on how the Passenger VMT was calculated as
indicated in Table 3.B-30.
iii. Provide the actual number of riders that came from San Joaquin
County to take BART under the Project and Alternatives to properly
disclose the impacts.
iv. Provide a table that shows delta of trips that were attracted to BART
parking expansion VS those that had to drive after not finding parking.
6. Tables 3.B-32 to 3.B-35 have several discrepancies in V/C for freeway lanes when
compared to earlier tables 3.B-14 and 3.B-15. For example, V/C for freeway segment
between Vasco Road and Greenville Road is shown as LOS D in Table 3.B-14 with
delay of 0.87. But in Table 3.B-32 it is shown as LOS E with a delay of 0.977. Similar
issues were noted in Tables 3.B-36 to 3.B-39.
Requested Change:
Review and reconcile different numbers in tables for Freeway segments.
7. Table 3.B-40 indicates a significant impact at Segment 7 (Livermore Ave to Springtown
Blvd/First Street). But the text on Page 337 (page after Table 3.B-43) indicates a wrong
segment for mitigation under the DMU Alternative.
Requested change:
Correct text accordingly.
8. Mitigation Measures TRAN-7a, TRAN-7b, TRAN-19b, TRAN-19c, TRAN-20a, TRAN-
20b, TRAN-20c, and TRAN-20d recommend adding a third southbound left-turn lane
and a second westbound right turn lane at the intersection of Dublin Blvd and Dougherty
Road. This mitigation is suggested to address the peak hour significant impacts to this
intersection in 2025, and 2040 under with project/alternatives and Cumulative Scenarios.
The proposed mitigation is not compatible with the existing land use at this intersection.
It also would impact the pedestrian access by increasing the crossing distance for
pedestrians on two approaches. Therefore this mitigation is not supported by the City of
Dublin. In order to improve operations at this intersection, the City recommends that
BART contributes towards implementing an Adaptive Traffic Signal system along
Dougherty Road. Enhanced signal operations under the Adaptive Traffic Signal system
would minimize the significant impacts.
Requested Change:
Modify TRAN-7a, TRAN-7b, TRAN-19b, TRAN-19c, TRAN-20a, TRAN-
20b, TRAN-20c, and TRAN-20d by providing Adaptive Traffic Signal
system along Dougherty Road in the City of Dublin to minimize the
significant impacts at the intersection of Dublin Blvd and Dougherty Road.
C. Air Quality Impacts
1. The Draft EIR Does Not Adequately Address Toxic Air Contaminants and Health
Risks. The methodology and impact analysis (Draft EIR pages 1,120 – 1,125 and pages
1,160 – 1,165, respectively) indicate that the risk/TAC analysis focused on passenger
vehicles, DMU vehicles, maintenance trucks, buses, shuttle vans, and emergency
generators. However, there is no mention of an analysis associated with widening of the
I-580 freeway right-of-way (ROW ). I-580 currently has 219,000 daily vehicles, including
14,828 daily trucks traveling through Dublin.[1] Freeway ROW widening would move
truck traffic (and associated diesel particulate matter [DPM] emissions) closer to
receptors along the freeway. It should be noted that the VMT reductions associated with
implementation of the Build Alternatives would affect passenger vehicles and would not
reduce heavy duty truck traffic. As such, the Draft EIR does not demonstrate that it has
adequately analyzed operational TAC/risk impacts.
Requested Change:
The Draft EIR must be revised to clearly identify impacts
associated with moving heavy duty diesel vehicles (due to ROW
widening) closer to receptors located along the freeway.
D. Noise and Vibration Impacts
1. The Draft EIR Should Identify Additional Options to Mitigation Pile Driving Noise.
When technically feasible, silent press-in piling (such as the Giken Silent Piler) should be
the preferred method rather than drilling to reduce noise and vibration impacts. This
option should be included in Mitigation Measure NOI-1.
2. The Draft EIR Does Not Include All Feasible Options to Mitigate Construction
Noise. Mitigation Measure NOI-1 should include noise monitoring during construction to
ensure the 90 dBA Leq limit is not exceeded. If it is exceeded, construction activities
should halt until a remedy is implemented to reduce the noise levels below the 90 dBA
Leq limit.
Requested Change:
The noise monitoring should be incorporated into the following section of
Mitigation Measure NOI-1:
To reduce potential daytime construction noise impacts to
residential uses immediately south of the realignment of the
eastern extent of East Airway Boulevard (Proposed Project and
DMU Alternative), BART contractors shall employ moveable noise
curtains or barriers along the southern side of East Airway
Boulevard to shield daytime construction noise impacts to
residential uses to the south. These temporary noise barriers shall
be employed for construction along East Airway Boulevard, east
of Sutter Street. Implementation of this measure will ensure that
[1] California Department of Transportation, Traffic Data Branch, Annual Average Daily Truck Traffic on
the California State Highway System, 2015.
daytime construction activities do not exceed FTA noise criteria for
daytime construction at residential uses (90 dBA Leq).
Additionally, noise monitoring shall be conducted during
construction to ensure this limit is note exceeded. If it is
exceeded, construction activities should halt until a remedy is
implemented to reduce the noise levels below the 90 dBA Leq
limit.
3. The Draft EIR Does Not Include All Feasible Options to Mitigate Construction
Vibration Impacts. Vibration monitoring should be conducted while these construction
activities are taking place to ensure the vibration limit (0.2 PPV in/sec and 72 VdB) is not
exceeded. If it is exceeded, construction activities should halt until a remedy is
implemented to reduce the vibration levels below the limit.
Requested Change:
Mitigation Measure NOI-1 should be revised as follows:
To reduce potential vibration impacts to residential uses
immediately south of the realignment of the eastern extent of East
Airway Boulevard (Proposed Project and DMU Alternative), BART
contractors shall use non-vibratory excavator-mounted
compaction wheels and small smooth drum rollers for final
compaction of asphalt base and asphalt concrete. If needed to
meet compaction requirements, smaller vibratory rollers will be
used to minimize vibration levels during repaving activities where
needed to meet vibration standards. These methods shall be
employed for construction along East Airway Boulevard, east of
Sutter Street. Vibration monitoring shall be conducted while these
construction activities are taking place to ensure the vibration limit
(0.2 PPV in/sec and 72 VdB) is not exceeded. If it is exceeded,
construction activities shall halt until a remedy is implemented to
reduce the vibration levels below the limit.
Attachments:
Exhibit A
EXN /B /T_ q
JULY 2017 BARTTo LIVERMoRE EXTENSION PROJECT EIR
CHAPTER 3 ENVIRONMENTAL ANALYSIS
B. TRANSPORTATION
TABLE 3.8 -18 LOCAL ROADWAY IMPROVEMENTS, 2025 AND 2040 NO PROJECT CONDITIONS
Relevant Relevant
Analysis Study
Street Limits Improvement Year Intersection #
Livermore
Isabel Avenue
1 -580 EB Ramps
Widen overpass
2040
#30
Isabel Avenue
1 -580 WB Ramps
Widen overpass
2025 and
#28 and #29
Dublin
Dougherty Road to North
Extension
2040
Isabel Avenue
Stanley Boulevard to Ruby
Widen to four lanes
2040
#33
Fallon Road
HIII Drive
Extension
N/A
Isabel Avenue
Isabel and Jack London
Intersection
2025 and
#36
Gleason Drive
Boulevard
improvements
2040
Csv✓PLiEta
Vasco Road
Northfront Road to Las
Widen to eight
2040
#43 and #44
Fallon Road
Positas Road
lanes
2040 ' #20
Greenville Road
Interchange improvements
Widen underpass
2025 and
#48
Dublin
To Schaefer Ranch Road
to six lanes
2040
Greenville Road
Las Positas Road to
Widen to four lanes
2025 and
#48
Paterson Pass Road
2040
Greenville Road
Westbound ramp
Signalize
2025 and
#46
-
intersection and
2040
add westbound
left -turn pocket
and eastbound
right -turn pocket
Greenville Road
Greenville Road and
Signalize
2025 and
#48
Altamont Pass Road
intersection
2040
Greenville Road
Greenville Road and
Signalize
2025 and
#50
Patterson Pass Road
intersection
2040
Pleasanton
El Charro Road Stonerldge Drive to Jack Extension 2040 #23
London Boulevard
El Charro Road Jack London to Stanley Extension After N/A
Boulevard 2040
Dublin
Dublin
Brannigan Street to Fallon
Widen toj{ --
2025 and #19
Boulevard
Road
lanes six
2040
Dublin
Dougherty Road to North
Extension
2040 N/A
Boulevard
Canyons Parkway
Fallon Road
Connect to Tassajara Road
Extension
N/A
291��2025/2 o�jv
Gleason Drive
To Fallon Road
Extension
N/A
Csv✓PLiEta
20 S -2 o �&
_�dREyDf
Fallon Road
N/A
Upgrade
2040 ' #20
Interchange
Dublin
To Schaefer Ranch Road
Extension
010 N/A
Boulevard
CoA✓%e/2
281
BART To LIVERMORE EXTENSION PROJECT EIR
CHAPTER 3 ENVIRONMENTAL ANALYsis
B. TRANsPORTAT1oN
JULY 2017
TABLE 3.6 -18 LOCAL ROADWAY IMPROVEMENTS, 2025 AND 2040 No PROJECT CONDITIONS
Relevant Relevant
Analysis Study
Street Limits Improvement Year Intersection #
Tassajara Road Dublin Boulevard to 1 -580 Widen to eight 2025 and #14
lanes 2040
Tassajara Road Fallon to Dublin Widen to six lanes 2040 #14
Hacienda Road Dublin Boulevard to Central Widen to six lanes 2040 #9
Dougherty Sierra Court [ ity Limits Widen to 2025 and #1
Road lanes .SiX 2040
Notes: EB = eastbound; WB = westbound; N/A = no applicable.
Local roadway improvement assumptions were mad ith input from the Cities of Livermore, and
Pleasanton. I/ to 7—,9 .7- Sb —0 6'-* �G T Li 11T
Sources: 49 % E l✓O91r# -
City of Livermore, 2009; City of Pleasanton, 2009; City of Dublin, 2013. A �D 7 �
The Pleasanton General Plan has identified major roadway improvements. Table 3.13-18
summarizes the intersection and roadway lane improvements near the study area.
Completion of the Stoneridge Drive extension, Busch Road, and El Charro Road are
significant and necessary parts of Pleasanton's local circulation system. The extension of
Nevada Street has the potential to provide some traffic relief to the Stanley
Boulevard/Valley Avenue /Bernal Avenue intersection.
In addition to these improvements, the Triangle Study" identified projects required for a
strategic approach to relieving traffic congestion in the Tri- Valley Area. The Tri - Valley
Triangle Study Final Plan Recommendations were approved in February 2011. This
included an agreement on the sequencing of projects, specifically that the Stoneridge
Drive extension be completed before construction can begin on State Route 84 as a
four -lane facility between west of Ruby Hill Drive and 1 -680.
Table 3.6 -19 presents the No Project Conditions in 2025 and 2040.
n Alameda County Transportation Commission (Alameda CTC), 2007. Tri - Valley Triangle
Study.
282
Figure 1 - Conventional BART Alternative
Lowes: 30
parking spaces
lost
N
Figure 1 - Conventional BART Alternative
Figure 2 - DMU/EMU ALTERNATIVE
Dublin
Volkswagen:
25 parking
spaces lost
Dublin
Hyundai: 45
parking
spaces lost
Scarlett Court
moved 35 ft North.
Turn around at E end of
Scarlett court is moved
35 ft. north and 100 ft.
west
Parking along the
southern edge of the
Corp yard would be
removed
I-580 road widening begins .2 miles W est of
Dougherty/Hopyard overcrossing and reaches maximum at .2
miles W est of Iron Horse Trail. Widening continues on Dublin
side until Livermore border.
N
Figure 2 - DMU/EMU ALTERNATIVE
Dublin Toyota Scion: 40
parking spaces lost Hacienda Shopping center: 75
parking spaces lost
I-580 road widening begins 0.2 mile West of Dougherty/Hopyard
overcrossing and continues to Livermore
N
Figure 2 - DMU/EMU ALTERNATIVE
Lowes: 30
parking spaces
lost
N
Figure 2 - DMU/EMU ALTERNATIVE
N
Figure 3 - Express Bus/BRT Alternative
Dublin
Volkswagen: 25
parking spaces
lost
Dublin
Hyundai:
45 parking
spaces lost Turn around at east end of
Scarlett court is moved 35 ft.
north and 100 ft. west
Parking along the
southern edge of the Corp
ward would be removed
Scarlett Court
moved 35 ft. north.
Widening of I-580 begins 0.2 miles W est of Dougherty/Hopyard overcrossing. Widening
gradually starts and reaches maximum at 0.2 miles W est of Iron Horse Trail. The maximum
widening occurs from there to about .2 miles East of Iron Horse Trail. From there, widening
tapers down and ends on Dublin side at Tassajara/Santa Rita overcrossing.
Max widening of 88 ft.
from about 0.2 miles
west of Iron Horse Trail
to about 0.2 M east of
Iron Horse Trail. More
widening on
Pleasanton side then
on Dublin
N
Figure 3 - Express Bus/BRT Alternative
N
Figure 3 - Express Bus/BRT Alternative
Widening ends on Dublin
side.
N