Fun with numbers
At tonight’s Planning Board meeting, the board will consider the Planned Development Agreement (PDA) and EIR certification for Towne Centre. This was to be heard in July but a community group requested it be continued until August, which it promptly was, and then many of the people who requested the continuance left town and requested another continuance. Whoops! Luckily, there’s been plenty of time to submit written comments.
One of the interesting “issues” has been around the numbers used in the EIR, with a local “traffic expert” sending tomes of critiques on the overall numbers. Interestingly, the first of these mirrored the comments the city’s Transportation Commission made during the first reading. (I’m not suggesting they were cribbed, they were submitted prior to the TC’s meeting, but it’s amusing. To defend the TC, tone of the comments were polar opposites.)
So the city has responded to all the community questions including accusations that Omini-Means, the company who prepared the ATC EIR, had goofed on the EIR. To their credit, the planning department hired a respected traffic engineering consultant to review the numbers.
Dowling Associates also did the traffic analysis for the General Plan Transportation Element Update EIR, and so had a lot of data to compare the ATC EIR to. What they came up with was that the ATC EIR most likely overestimated the traffic impacts in the ATC EIR. By up to 40% on some streets! Here’s their summary:
The approach and methodologies used in the Report are consistent with those in the Guidelines. The volume assumptions are generally conservative and the cumulative forecasts in the Report are significantly higher than those in the recent Transportation Element EIR. This combination most likely resulted in an assessment of higher impacts than would have been identified using new (2008) traffic counts and travel forecasts consistent with the Transportation Element EIR.
Dowling Associates does not possess the necessary CEQA expertise to fully assess the potential risk for CEQA challenge. The issue of project segmentation under CEQA should be further reviewed by appropriate counsel
Staff has addressed the segmentation issue repeatedly, it’ll be interesting to hear whether they have new information or not. The Dowling report acknowledges that it wouldn’t be unheard of to have included the previously accepted impacts from the initial 112,000 sf, but that there is also a double counting in the way that Omni-Means did their numbers (meaning very conservatively, double counting is not good for the project in an EIR, it makes the impacts look worse than they would be).
In reading the Transportation Element EIR, I was struck on how conservative the traffic numbers were. There were no predictions of any change in mode use, despite the changes that are starting to happen in the region (and state and country) with rising gas prices. This is a good thing. It presents a worse-case scenario. So when Dowling finds that the ATC EIR is that much more conservative, one almost wonders is Omni-Means was trying to tank the project. (it’s a joke).
The meeting will be held tonight in City Council Chambers at 7:00pm.

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