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Home My WebLink About7.1 - 1592 Staff Comments on BART to Livermore DEIR Page 1 of 6 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. Page 2 of 6 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. Page 3 of 6 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 Page 4 of 6 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. Page 5 of 6 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. Page 6 of 6 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