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ConnectMenlo DEIR Comment letter-Compliance with Menlo Park City Council Approved TIA and CSA

From: domainremoved <George>
Date: Wed, 27 Jul 2016 14:53:50 -0700

Ms. Deanna Chow Via

Planning Division

City of Menlo Park

701 Laurel street

Menlo Park, CA


   RE. Connect Menlo DEIR

Dear Ms. Chow: July
27, 2016


The ConnectMenlo DEIR fails to include the analysis of proposed development
or changes of use required (
http://www.menlopark.org/1017/Development-guidelines) by Menlo Park’s
Transportation Impact Analysis (TIA) Guidelinesand Circulation System
Assessment (CSA) documents. There is no analysis of “potential cut-through
traffic generated by the project impacting other city Neighborhoods (TIA
VII F). There are no required traffic distributions, assignments, routes,
gateways, or even required ITE trip generation numbers. Although the DEIR
purports to describe regulatory framework of Federal, State, Regional, and
Local Regulations, 4.13-1 through 4.13.10, neither the TIA nor CSA are

The DEIR has arbitrarily, without Council approval, replaced the existing
City Council approved TIA, http://menlopark.org/DocumentCenter/Home/View/302
, (Exh. A, hereto) and CSA requirements and standards for analyzing traffic
and neighborhood safety
(Exh. B hereto). New DEIR methodologies include MPM, a travel demand
methodology purportedly based upon c/cag models, DTA, a new dynamic traffic
assignment methodology, as well TAZ methodologies and VTM methodologies.
As the comments by East Palo Alto, Atherton, and other commenters and
experts point out the DEIR fails to include “any actual data regarding the
model structure, which is essential for the reader to interpret the
project. . .”and no “descriptions and details of procedures to allow the
reader to understand and interpret its implications”

Both TIA And CSA Analysis is required to determine environmental Impacts
and mitigations by City requirements, and if those requirements are to be
changed in any way by ConnectMenlo the changes in analysis and impacts
found under other analyses compared to the TIA and CSA.


Compliance with the TIA was required for the Stanford and Greenheart
projects among others. In fact, Ray Mueller requested more specific
compliance for the Stanford Project, which generated a traffic report
demonstrating significant traffic issues (speed and volume) in the Allied
arts and other areas. Stanford then reduced its proposed commercial
project by 25%, reducing TIA traffic projections and neighborhood

Staff report 15-122-CC, July 21, 2015, supporting amendment of the TIA for
limited change of use projects in the M2 area , recently stated the
importance of the city’s TIA Guidelines: “ The Transportation Impact
Analysis Guidelines (TIA*) define the process, requirements and standards
for determining a development project’s potential impacts upon the [City’s]
transportation Network*.” The staff report also noted that the TIA
Guidelines were adapted by the city council in 2001.

TIA reports shall include conditions described based upon the most recent
Circulation System Assessment (CSA) document, which was adapted by City
Council in 2004. TIA guidelines require: 1. Traffic projections are to be
based upon project trip generation rates “from Institute of Transportation
Engineer’s (ITE) publication “Trip Generation” latest version; 2. Trip
distribution and assignment based upon CSA (including trip assignment
between and city gateways and trip routes used to and from project) and,
and (3) Impacts according to specified standards. Traffic impacts are
determined by LOS delays, as well as traffic impacts on minor arterial,
collector and local streets, if traffic counts exceed certain limited
thresholds will be reached. For example a net projected increase of only 25
trips per day is an impact on Local Street, if existing traffic is less
than 1,350 per day.

           The TIA Guidelines also require analysis of the project in
relation to the relevant polices of the General Plan Circulation Element
and analysis of “*potential cut-through traffic generated by the project
impacting other city neighborhoods” *as well as bicycle and pedestrian
safety and San Mateo county congestion management.

         The Menlo Park CSA requires an assumed distribution of generated
traffic for development or changes in use. Distributions are based upon ITE
trip generation and distributed on a recommended set of trip distribution
percentages for each of residential, office, and retail use historically
determined by surveys and interviews. The origins and destinations of each
category were assigned to specific “gateways” based on the preferred routes
to and from Menlo Park, with separate assignments made for each of four
areas of the city: 1, Sharon heights/sand hill road, 2 West Menlo Park/
Downtown/El Camino Real, 3 West of US 101 (between cal train and US 101)
and 4 East of US 101. Often trips were allocated to two routes using
estimated percentages. Local trips were divided based upon household
travel diary and interviews and divided into nine neighborhoods. The data
for the CSA was kept in the City’s Traffix computer program, and may or may
not have migrated into the City’s current computer traffic program.

          The Circulation System Assessment (CSA) document notes require
that“in distributing trips generated from a development project to their
origins or destinations, route selection should be based on the fastest
routes available, preferably based on a travel time study. Potential
cut-through traffic through residential neighborhoods should also be
identified in the travel time study.”


         The DEIR must be revised to include the TIA and CSA requirements,
and if any changes to them, must be revised to include a specific
comparison of any changes to the requirements or impacts resulting from
application of the TIA and CSA.

Respectfully submitted,

George C. Fisher

1121 Cotton Street

Menlo Park, CA.

Received on Wed Jul 27 2016 - 15:01:16 PDT

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