2.
Response
to
Comment
2.4
Master
Responses
to
Comments
guarantee
that
the
residents
would
be
employed
locally
and
therefore
drive
less.
These
comments
included
inquiries
and
concerns
about
internal
capture
adjustments
to
the
Institute
of
Transportation
Engineers
(ITE)
trip
generation,
how
they
were
estimated
and
applied,
and
why
they
are
appropriate.
Additional
comments
argued
that
since
a
large
amount
of
residential
development
is
proposed
adjacent
to
the
Baylands
within
San
Francisco
(e.g.,
development
of
the
Schlage
Lock
and
Hunters
Point-Candlestick
Point
projects),
providing
housing
within
the
Baylands
should
not
have
an
effect
on
home-to-work
trip
lengths,
since
housing
would
already
be
readily
available
in
proximity
to
employment
opportunities
within
the
Baylands.
Response
As
stated
on
pages
4.N-71
to
4.N-84
of
the
Draft
EIR,
trip
generation
estimates
were
based
upon
Trip
Generation
,
published
by
ITE
in
2008.
This
publication
provides
nationally
studied
trip
generation
rates
derived
from
surveys
for
a
variety
of
land
uses.
Because
the
ITE-developed
rates
generally
are
for
stand-alone
land
uses
and
not
for
large-scale
developments
where
a
proportion
of
project-generated
traffic
does
not
leave
the
project
site,
it
is
professional
practice
to
make
adjustments
to
the
raw
trip
generation
estimates
based
upon
the
internalization
of
trips
due
to
the
mixed-use
nature
of
proposed
land
uses
and
the
development
scale,
density,
diversity
of
uses,
and
design
of
the
project.
The
Trip
Generation
User’s
Guide
itself
suggests
modifying
the
published
trip
generation
rates
“…to
reflect
the
presence
of
public
transportation
service,
ridesharing,
or
other
TDM
measures;
enhanced
pedestrian
and
bicycle
trip-making
opportunities;
or
other
special
characteristics
of
the
site
or
surrounding
area.”
The
methodology
for
adjustments
undertaken
in
the
Draft
EIR
was
the
result
of
a
rigorous
peer-
reviewed
study
conducted
by
Fehr
&
Peers
and
prepared
for
the
United
States
Environmental
Protection
Agency,
based
on
the
following
state,
regional,
and
local
data:
Pooled
household
survey
data
for
239
mixed-use
developments
in
six
diverse
U.S.
regions;
Statistically
derived
equations
on
internal
trip
capture
and
mode
shares;
and
Validation
at
27
existing
mixed-use
development
sites
across
the
U.S.
This
methodology
is
recognized
industry-wide
by
transportation
engineers
as
resulting
in
appropriate
trip
generation
patterns
for
mixed-use
development
projects,
and
as
such
was
used
in
the
transportation
analysis
for
the
Project
Site
development
scenarios.
Furthermore,
under
CEQA,
the
City
is
entitled
to
make
reasonable
assumptions
in
its
analysis
of
a
project’s
impacts.
(
See
City
of
Long
Beach
v.
Los
Angeles
Unified
School
District
[2010]
176
Cal.App.4th
889;
Environmental
Council
of
Sacramento
v.
City
of
Sacramento
[2006]
142
Cal.App.4th1018
[“A
public
agency
can
make
reasonable
assumptions
based
on
substantial
evidence
about
future
conditions
without
guaranteeing
that
those
assumptions
will
remain
true
(Pub.
Res.
Code,
§
21080
(e);
City
of
Del
Mar
v.
City
of
San
Diego
(1982)
133
Cal.App.3d
401,
412,
183
Cal.Rptr.
898.”].)
In
the
case
of
Baylands
development,
the
application
of
internal
capture
accounts
for
a
proportion
of
three
categories
of
trips:
Brisbane
Baylands
Final
EIR
2.4-72
May
2015