11 ATTACHMENTS 6-9 - Laserfiche WebLink

December 11, 2019 Page 2 outside the impact analysis area for the health risk assessment (HRA).No other explanation is provided.The response does not acknowledge that the Bay Area Air Quality Management District's 2017 CEQA Guidelines specifically provide that: "[a] lead agency should enlarge the 1,000-foot radius on a case-by-case basis if an unusually large source or sources of risk or hazard emissions that may affect a proposed project is beyond the recommended radius." With respect to cumulative traffic and air qualityimpacts, the FRSEIR claims that"[a]ll of the Draft SEIR's analyses of these issues (the analysis of traffic and air quality impacts initially presented in the Draft SEIR,and the 2019 Recirculated Air Quality Analysis)were based on models from 2015 that accounted for regional cumulative growth," and that with two exceptions "[t]he traffic and air quality models used in the Draft SEIR already anticipated future development consistent with future development projections in the general plans of the cities of Pleasanton and Dublin." (FRSEIR,p. 3-91,3-92). Other than general statements that the various projects listed are consistent with the Dublin and/or Pleasanton General Plan,and were thus assumed by the cumulative traffic analyses in those Plans'years-old EIRs, there is no further discussion of this Project's potential cumulative traffic impacts considering the actual traffic generated by the other projects.There accordingly is no substantial evidence to support any finding concerning the JDEDZ Project's cumulative traffic and air quality impacts taking into account all these other projects in the vicinity. Additionally,in comments on the Draft RSEIR,we and others noted that the Draft RSEIR had updated the trip generation estimates for the Costco/Phase I portion of the Project, applying pass-by discounts that were approximately double the rates specified by Ca1EEMod and the ITE for general retail and warehouse club uses, and 60 percent more than for gas stations. We accordingly asked the City to disclose the data source or other evidentiary basis supporting these exceptionally high pass-by discounts,which if incorrect would mean a significant understatement of overall trip generation. The RFSEIR's response states that"the pass-by and diverted trip reductions in the 2019 Recirculated HRA were taken directly from the traffic study conducted for the Draft SEIR, prepared by Fehr&Peers (May 2015),and were developed specifically for a Costco store,"and refers to Appendix H of the Draft SEIR. The information in Appendix H of the Draft SEIR,consisting of memos from Costco's traffic engineering consultant,Kittleson and Associates, merely states