2.
Response
to
Comment
2.4
Master
Responses
to
Comments
2.4.24
Master
Response
24,
Traffic
and
Circulation:
Applicability
of
Using
TDM
Measures
to
Mitigate
Impacts
Caused
to
C/CAG’
s
CMP
Network
Comments
Several
comments
questioned
the
use
of
Transportation
Demand
Management
(TDM)
measures
to
mitigate
impacts
on
the
Congestion
Management
Program
(CMP)
network.
Comments
also
raised
concerns
that
the
TDM
program
and
its
component
measures
are
not
enforceable
and
rely
on
voluntary
participation
by
employers
and
residents.
Response
Mitigation
Measure
4.N-13
(pages
4.N-147
to
4.N-149
of
the
Draft
EIR)
directly
addresses
the
requirements
in
the
Land
Use
Impact
Analysis
Program
in
the
City/County
Association
of
Governments
of
San
Mateo
County
(C/CAG)
San
Mateo
County
Congestion
Management
Program
,
2011.
For
individual
large
development
analysis,
mitigations
must
be
implemented
if
Project
Site
development
is
expected
to
generate
more
than
100
net
peak
hour
trips
on
the
CMP
network.
The
document
provides
several
methods
to
mitigate
the
impact,
including
requiring
the
developer
and
all
subsequent
tenants
to
develop
and
implement
TDM
programs
that
mitigate
the
new
peak
hour
trips.
The
TDM
measures,
as
proposed
in
Mitigation
Measure
4.N-13,
are
appropriate
to
mitigate
the
impact
on
the
CMP
network
under
C/CAG’s
guidelines.
There
are
several
levels
of
enforcement
for
the
implementation
of
TDM
programs
at
the
Project
Site.
Mitigation
Measure
4.N-13
would
require
that
implementation
of
TDM
programs
be
made
a
condition
of
approval
for
all
new
development
within
the
Project
Site
that
generates
100
or
more
net
new
trips
during
the
AM
or
PM
peak
hour.
Such
conditions
of
approval
would
include
monitoring
and
reporting
procedures
to
ensure
that
implementation
does,
in
fact,
occur.
It
is
also
the
City’s
intent
as
part
of
is
planning
review
process
to
require
implementation
of
TDM
programs
throughout
the
entire
Project
Site
as
part
of
any
development
agreement
between
the
property
owner
and
the
City
of
Brisbane.
Implementation
of
TDM
programs
would
also
be
required
to
be
written
into
the
required
Specific
Plan(s)
for
Project
Site
development,
which
would
govern
the
zoning
and
land
use
standards
for
the
lands
within
the
Baylands.
Finally,
because
the
Project
would
trigger
an
impact
under
the
C/CAG
CMP,
mitigation
measures
such
as
a
TDM
program
can
be
enforced
by
C/CAG.
2.4.25
Master
Response
25,
Traffic
and
Circulation:
Jobs
and
Housing
Linkage;
Calculation
of
Internal
Capture
in
Project
Trip
Generation
Comments
A
number
of
comments
raised
concerns
regarding
the
treatment
of
providing
housing
and
employment
opportunities
in
proximity
to
each
other,
stating
that
housing
near
jobs
does
not
Brisbane
Baylands
Final
EIR
2.4-71
May
2015
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