2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
2.9.15
Universal
Paragon
Corporation
January
23,
2014
Comment
Letter
UPC
As
stated
on
page
4.N-72
of
the
Draft
EIR,
adjustments
have
already
been
made
to
the
raw
ITE
trip
generation
in
order
to
account
for
trips
internal
to
the
Baylands
Site.
The
magnitude
of
internal
trips
was
based
on
the
development
scale,
density
of
Project
Site
development,
diversity
of
uses,
and
design
of
project.
These
aspects
of
Project
Site
development
do
account
for
certain
systemic
attributes
built
into
the
Project
design,
some
of
which
overlap
with
the
TDM
measures
in
Table
6-4
of
the
Specific
Plan.
This
overlap
includes,
by
broad
TDM
element:
Promote
Transit
Usage
Jobs-Housing
Linkage
Streets
Designed
for
Alternative
Transportation
Modes
Encourage
Walking
The
internal
trip
adjustment
does
not
account
for
programmatic
TDM
elements,
such
as
having
a
TDM
coordinator
or
guaranteed
ride
home.
Despite
the
potential
for
these
elements
to
be
enforced
by
the
City,
they
are
not
built
into
the
physical
scenario
design,
and
therefore
the
effects
were
not
calculated.
The
inclusion
of
Table
4.N-45
of
the
Draft
EIR
does
not
contradict
the
approach
described
above,
as
the
list
of
trip
credits
for
TDM
measures
specifically
mitigates
Impact
4.N-13.
Both
the
impact
and
the
mitigation
are
specified
by
C/CAG.
UPC
See
for
discussion
of
internal
capture
of
trips
based
on
mixed
use.
The
mere
presence
of
residential
land
uses
does
not
automatically
correlate
with
higher
transit
use.
The
distance
from
transit
of
both
home
and
work
are
factors
in
the
probability
of
using
transit.
The
mode
splits
used
in
the
Draft
EIR
were
developed
from
several
sources
of
data.
Mode
share
for
proposed
Baylands
development
is
described
on
page
4.N-76
of
the
Draft
EIR,
and
is
based
on
local
data
and
projections.
Mode
share
was
evaluated
and
compared
among
several
resources
including
the
Candlestick
Point/Hunters
Point
Shipyard
EIR,
San
Francisco
CEQA
Guidelines,
BATS
2000,
the
American
Community
Survey
2005-2009,
2010
Census,
and
travel
characteristics
of
comparable
transit-oriented
developments
in
California.
From
these
sources,
the
mode
split
used
for
the
Baylands
Draft
EIR
was
developed.
Brisbane
Baylands
Final
EIR
2.9.15-1
May
2015