Loading...
HomeMy WebLinkAboutStaff Report 14601 City of Palo Alto (ID # 14601) City Council Staff Report Meeting Date: 8/8/2022 Report Type: Action Items City of Palo Alto Page 1 Title: Discuss and Provide Comments on the City's Draft Comment letter to the California High Speed Rail Authority (CHSRA) and Authorize the Mayor to Send a Comment Letter to the CHSRA on the Final Environmental Impact Report/Environmental Impact Statement (EIR/EIS) for the California High Speed Rail segment between San Francisco and San Jose, Which Traverses Palo Alto. From: City Manager Lead Department: Transportation Department Recommendation Staff recommends that the City Council: 1) Discuss and provide comments on the City’s draft comment letter (Attachment A) to the California High Speed Rail Authority (CHSRA) regarding the Final Environmental Impact Report/Environmental Impact Statement (Final EIR/EIS) for the California High Speed Rail San Jose to San Francisco segment, which traverses the City of Palo Alto. 2) Authorize the Mayor to sign the City’s comment letter, incorporating Council’s requested revisions (if any), and to submit the letter to the CHSRA prior to its consideration for approval of the proposed project and certification of the Final EIR/EIS. 3) Discuss and authorize further actions to advance the City’s interests related to the proposed High Speed Rail project, such as designating representatives to advocate support for the City’s position with state and regional bodies. Executive Summary On June 10, 2022, the California High Speed Rail Authority (CHSRA) released the Final Environmental Report/Environmental Impact in compliance with California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) for the proposed improvements of High-Speed Rail between San Francisco and San Jose. The CHSRA Board of Directors will consider approval of the proposed project and certification of the Final EIR/EIS at a two-day board hearing on August 17 and 18, 2022. If approved, certification of the EIR/EIS for the San Francisco to San Jose segment will complete environmental clearance for the California High Speed Rail in Northern California. As a responsible agency for the proposed project, which would traverse the City along the existing Caltrain tracks, the City of Palo Alto provided comments on the Draft EIR/EIS during the Draft EIR/EIS public comment period. The City’s comments on the Draft/EIS, and the Authority’s responses to those comments are included in Attachment B. City staff reviewed the Final EIR/EIS, including the responses to City of Palo Alto Page 2 comments. Staff believe that the Authority failed to adequately identify and mitigate the impacts of the proposed project on the City. In particular, the clear and significant impacts related to emergency response, noise, land use, and traffic warrant consideration of grade separation in the EIR/EIS. Staff prepared a draft comment letter in response to the Final EIR/EIS, which is included in Attachment A. Background In 2008, California passed a $9.95 billion bond measure for the High-Speed Rail (Proposition 1A) in order to connect major urban centers from San Francisco to Los Angeles. Since then, the following project milestones have occurred: • On July 18, 2012, Governor Brown signed Senate Bill 1029 authorizing the expenditure of voter- approved Proposition 1A funds and effectively initiating project construction. • On September 19, 2012, the U.S. Federal Railroad Administration (FRA) issued a Record of Decision that approved the alignment from Merced to Fresno. This allowed construction of the Initial Construction Segment (ICS) to begin in 2013. • On March 18, 2013, the CHSRA Board of Directors approved an MOU with the Peninsula Corridor Joint Powers Board (PCJPB) that authorized the Blended System concept for HSR in the San Francisco to San Jose project section. During the same time period California High Speed Rail Authority and Caltrain agreed to electrify the existing Caltrain corridor. The key component of this blended approach is to have the two rail systems share the tracks and maintain the corridor as primarily a two-track railroad. Thus, the High-Speed Rail will primarily utilize the existing Caltrain right-of-way through urban areas. Caltrain is currently in construction for the electrification of this corridor. • In July 2017, Caltrain broke ground to initiate construction for the modernization and electrification of the Caltrain Corridor. These improvements are anticipated to be complete by 2022 when the first electric trains are expected to arrive. In accordance with the 2014 Caltrain EIR, the full fleet of electric trains is anticipated by 2029. • In July 2020, CHSRA released the Draft Environmental Impact Report (EIR)/Environmental Impact Statement (EIS) for the California High Speed Rail San Francisco to San Jose Project section. The City of Palo Alto provided comments on the Draft report during the public comment period (Attachment B). On June 10, 2022, the CHSRA released the Final EIR/EIS for the High-Speed Rail San Francisco and San Jose Section. The CHSRA Board of Directors will consider certifying the Final EIR/EIS and approving the Preferred Alternative in this project section during its two-day board meeting on August 17 and 18, 2022. As this schedule did not allow for staff to analyze the documents and the City Council’s Rail Committee to discuss and develop recommendations on the issues, this item is being advanced for full City Council consideration. The Final EIR report and related documents are available on the CHSRA website.1 The Authority issued a new Notice of Preparation for the proposed San Francisco to San Jose project section in April 2016 based on substantial feedback from stakeholders encouraging a blended Caltrain 1 The Final EIR/EIS for the California High Speed Rail San Francisco to San Jose Section is available online at: https://hsr.ca.gov/programs/environmental-planning/project-section-environmental-documents-tier-2/san- francisco-to-san-jose-project-section-draft-environmental-impact-report-environmental-impact-statement/ City of Palo Alto Page 3 and High-Speed Rail system. The preferred Alternative A (proposed project) identified in the Draft and Final EIR/EIS proposes a predominantly two-track blended system with no additional passing tracks. The project includes: • Service at one future station (Salesforce Transit Center, which would serve as a HSR station when the Transbay Joint Powers Authority completes its Downtown Extension Project) • Service at three existing Caltrain stations to be shared by HSR and Caltrain (4th and King Street [an interim station only], Millbrae, and San Jose Diridon) • Construction of the East Brisbane light maintenance facility (LMF). Alternative B is similar to Alternative A; however, it includes a 6-mile-long, four-track passing track between San Mateo and Redwood City, the West Brisbane LMF, and an aerial viaduct approaching the San Jose Diridon Station. Both Alternatives have the same alignment and facilities within the jurisdictional boundaries of the City of Palo Alto. The environmental analysis concluded that Alternative A has fewer adverse visual impacts, displacements, road closures, and impacts on wetlands and aquatic habitats as well as a lower capital cost. The project alignment calls for shifts in the railroad alignment to accommodate an increased speed of up to 110 mph of high-speed trains. In addition, there are minor facilities proposed, including communication towers and train control facilities within Palo Alto. Although staff agrees with the conclusion that Alternative A would be the environmentally superior alternative in comparison to Alternative B, City staff have repeatedly expressed concern that the EIR/EIS must include an alternative that evaluates grade separation to address the numerous significant and unavoidable impacts of the High Speed Rail project, as identified in the EIR/EIS. In particular, staff disagrees with the CHSRA’s conclusion that the significant and unavoidable impacts under CEQA or NEPA with respect to traffic circulation and emergency response cannot be mitigated to a less than significant level. For example, for both traffic and circulation either no mitigation has been proposed or mitigation has been proposed that improperly defers responsibility and costs to the City. To the contrary, grade separation would clearly reduce these impacts to a less than significant level and therefore must be analyzed in the Draft EIR/EIS. Although the Authority has stated that it would support and provide cooperation with local jurisdictions, transportation funding agencies, and state and federal agencies, for community-initiated grade- separation efforts over time as funding becomes available, this does not provide any specific commitment for either resources or funding despite the high-speed rail’s direct impacts, which drive the need for grade-separation. Study of grade separation as mitigation or as an alternative in the EIR/EIS is appropriate to address significant impacts. Evaluation would clearly show that this alternative would reduce impacts to a less than significant level and therefore should be constructed and funded as part of the HSR project. Furthermore, the proposed project does not analyze the reasonably foreseeable future scenario of the blended Caltrain system with Caltrain’s anticipated growth scenario, which may include up to twelve (12) Caltrain trains and four (4) HSR trains per hour per direction, as identified in the adopted Caltrain Vision Plan. The draft comment letter identifies this deficiency in the EIR/EIS. By not analyzing this scenario, the CHSRA avoids the need to identify and evaluate the need for passing tracks, which, it is anticipated, could affect Palo Alto to accommodate Caltrain’s adopted vision plan. Failure to identify for City of Palo Alto Page 4 this reasonably foreseeable future scenario jeopardizes the City’s planning efforts with respect to grade separation projects as well as other land use planning efforts. The draft letter therefore raises the concern that CHSRA must evaluate this scenario in the EIR/EIS so that the location of these tracks would be known and so that the realistic impacts of the proposed project, along with other reasonably foreseeable projects, would be known. The significant cumulative impacts would only reinforce the need for the CHSRA to study and fund grade separation and passing tracks to reduce the impacts of the proposed HSR project. The Authority did, however, address some of the City’s previous concerns regarding safety and noise. As outlined in the Authority’s responses to the City’s comments in Attachment B, the Authority responded with modifications to the Draft EIR/EIS by agreeing to implement four quadrant gates along the corridor, which would improve safety and help to facilitate quiet zones for at-grade crossings. The Authority also modified noise mitigation measures to require that the Authority provide technical support for local jurisdictions filing for permits from the Federal Rail Authority to establish quiet zones. Timeline & Resource Impact With Council’s approval, the Mayor will send a final comment letter on behalf of the City to the CHSRA prior to its two-day public hearing on the proposed project on August 17 and 18, 2022. In the draft letter in Attachment A, the City has expressed concerns regarding the proposed project’s potential impacts on City resources, including reliance on the City to initiate projects of its own (e.g. expansion of roadways, grade separation, quiet zones, etc.) to reduce the significant impacts of the proposed project on the City. Environmental Review Transmittal of the City’s comments on the Final EIR/EIS for the California High Speed Rail San Francisco to San Jose segment does not constitute a project in accordance with Public Resources Code § 21065 and is therefore not subject to environmental review in accordance with the California Environmental Quality Act. Attachments: • Attachment A: Comments on the High Speed Rail Final EIR-EIS • Attachment B: City of Palo Alto Comments on the Draft EIR and Authority Responses to Comments [DRAFT – NOT YET APPROVED] August 8, 2022 Northern California Regional Office California High-Speed Rail Authority 100 Paseo De San Antonio, Suite 300 San Jose, CA 95113 Email: san.francisco_san.jose@hsr.ca.gov RE: The San Francisco to San José Project Section Final Environmental Impact Report/Environmental Impact Statement (EIR/EIS) Thank you for the including the City of Palo Alto (City) in the environmental review process for the above- referenced project. The California High Speed Rail (HSR) will have a long-lasting and far-reaching impact on the City of Palo Alto; therefore, we appreciate the opportunity to comment on this Final EIR/EIS as a responsible agency for the Project. Executive Summary The Final EIR/EIS, similar to the Draft EIR, remains seriously flawed in numerous respects, as outlined in this letter. As the City previously commented, the document fails to adequately analyze or to mitigate a variety of clear and significant impacts on the environment. The City disagrees with the Authority’s conclusion that grade separation of at grade crossings does not warrant evaluation, either as mitigation or as an alternative in the EIR, to address the clear and significant impacts on multi-modal transportation, land use, noise, and emergency response. We support the Authority’s addition of four quadrant gates, which improve pedestrian, bicycle, and vehicular safety at these crossings when compared to a project that does not include four quadrant gates. However, the EIR/EIS is flawed in its conclusion that there would be no impacts on safety and, therefore, mitigation to address safety concerns would not be warranted. The City also disagrees with the Authority’s position that the cumulative impacts of this project with the adopted Caltrain Vision Plan do not warrant analysis. By not planning for this reasonably foreseeable future condition, the Authority does not properly disclose impacts in accordance with CEQA and NEPA. For example, underreporting the realistic impacts on delays for emergency responders. In addition, it avoids identification of the need for passing tracks that the City understands would be necessary in Palo Alto, among other jurisdictions, under this cumulative scenario. Avoidance of appropriate planning for this reasonably foreseeable future condition jeopardizes local planning efforts in the design of grade separation projects. Therefore, the Final EIR continues to fall short of reasonable analysis, mitigation, and public disclosure in accordance with state law. Project Understanding The City understands that the San Francisco to San Jose Project Section (project) would provide High Speed Rail (HSR) service from the Salesforce Transit Center in San Francisco to Diridon Station in San Jose along approximately 49 miles of the Caltrain corridor. Within the City of Palo Alto, the project would be located along 3.8 miles of Caltrain right-of-way through the middle of Palo Alto, where the existing Caltrain tracks bifurcate the City from east to west. The current project design proposes a blended infrastructure with Caltrain operations through the City. The current proposed project, as well as both Alternatives carried forward in the environmental analysis, propose two at-grade tracks through the City, mostly within the existing Caltrain right-of-way. The City understands that within Palo Alto, the project would require slight modifications (typically of less than one foot) to the tracks in several areas to straighten curves in order to support higher speeds. The project also requires the installation of two radio towers (one north of [DRAFT] San Francisco to San José Final EIR/EIS Comments Page 2 of 5 Embarcadero Road and one north of West Charleston Road), four-quadrant gates at existing at-grade crossings, and either fencing or sound walls along the entire corridor within the City. The Project will provide HSR services at a downtown San Francisco station, a Millbrae station, and the San Jose Diridon Station; no station is proposed within the City of Palo Alto under the current proposed project or either of the two alternatives. The blended system would accommodate operating speeds of up to 110 mph for up to four HSR trains and six Caltrain trains per hour per direction in the peak period. HSR and Caltrain are the only passenger rail services that would operate in the blended system. North of the Santa Clara Caltrain Station, freight would use the same tracks as HSR and Caltrain, but would operate at night with temporal separation to avoid conflicting with HSR and Caltrain operation, similar to existing conditions. Rail Alignment, Profile, and Safety 1. The EIR concludes that there would be a significant impact related to emergency response times within several jurisdictions, including within the City of Palo Alto’s jurisdiction at the Menlo Park/Palo Alto Boundary west of El Camino Real and North of Sand Hill Road. The impacted areas include specific land uses where response times for emergency vehicles would be particularly important, including, but not limited to, assisted living facilities. The EIR/EIS identifies SS-MM #4 which indicates that the City should implement measures to reduce impacts related to the Authority’s HSR project. Suggested measures provided in the EIR/EIS include construction of emergency vehicle and transit queue bypass lanes, modifying roadway capacity and operational improvements to facilities paralleling the rail line to improve access to adjacent grade-separated rail crossings, construction of new fire stations to reduce fire station response times in affected areas, and/or expansion of existing fire stations to reduce fire station response times in affected areas in order to reduce impacts from the Authority’s project. Alternatively, SS-MM #4 indicates that the Authority, with agreement from the local jurisdiction, could make a one-time contribution toward a project that reduce impacts related to emergency response such as those listed above or grade separation. The identified mitigation improperly defers the responsibility of mitigation for the HSR project to the City, both with respect to cost and implementation. It’s unclear whether any of these measures could be feasibly implemented (for example due to lack of right-of-way for expanding roadways, lack of land to build a new or expanded fire station, or with respect to funding or staffing to facilitate any of these future projects). Further, the EIR/EIS fails to analyze the associated environmental impacts of implementing such measures, improperly stating that the responsibility of preparing environmental analysis for that mitigation would fall on the local jurisdiction. The vague alternative mitigation of providing a one-time contribution toward an unspecified project for emergency response times fails to provide any realistic, concrete reduction to the identified impacts and therefore does not provide any meaningful mitigation. Grade separation would reduce this identified significant and unavoidable impact to a less than significant level and therefore must be analyzed. As stated in the City’s previous comments on this project, if the Authority does not pursue at-grade crossings as part of an alternative or as mitigation to restore response times, the Authority must bear the full cost of restoring response times to existing conditions. 2. The EIR/EIS analyzes the effect of HSR train operations on safety for vehicles, bicycles, and pedestrians crossing at at-grade crossings in section 3.11, Safety and Security. The EIR/EIS concludes that, with considerations of planned safety improvements as part of the project, there would be no significant safety impacts associated with the project and that no mitigation is therefore required. While the City concurs that the addition four quadrant gates improves safety at these crossings, particularly for [DRAFT] San Francisco to San José Final EIR/EIS Comments Page 3 of 5 vehicles, the City disagrees that this measure reduces the significant safety impacts from the proposed project to a less than significant level. The conclusion fails to consider other safety impacts caused by increased gate down times as well as the foreseeable risk of pedestrian collisions. For example, vehicle delays would result in extensive queueing spilling on to through lanes, which would create safety hazards near at grade crossings. 3. The City recognizes that the Authority’s implementation of four-quadrant gates as part of the proposed project in the Final EIR/EIS would assist the City in establishing a quiet zone for Palo Alto Crossings. The City also appreciates modifications to NV-MM#4 requiring that the Authority assist with the preparation of technical analysis and materials needed for local jurisdictions to file a Quiet Zone application with the Federal Railroad Administration. The City supports this requirement and appreciates the Authority’s response to the City’s comments on this matter to reduce operational noise impacts on surrounding uses. However, because approval of quiet zones is outside of the Authority’s purview and because alternative mitigation that requires construction of sound walls across most of the City’s jurisdiction would result in further impacts to aesthetics and land use, the City continues to assert that grade separation should be evaluated to reduce the identified significant impacts related to operational noise. This mitigation would be within the Authority’s purview and would eliminate the improper need for the City to provide resources and funding to mitigate the impacts of the Authority’s project. Cumulative Impacts 4. The City reiterates the concerns raised in its previous comments that the EIR/EIS does not address the cumulative impacts of CAHSR and Caltrain service vison plans. The EIR assumes 6 trains per direction per peak hour per day, however the Caltrain Vision Plans considers up to 12 trains per direction per peak hour per day. By not analyzing the reasonably foreseeable cumulative impacts of the Caltrain Vision Plan and the proposed project, the EIR/EIS does not properly disclose the realistic delays in response times, among other environmental impacts, including but not limited to, transportation operations and safety, which may result in new or more significant impacts than those identified. The City continues to assert that impacts to all elements combined, including vehicular, bike and pedestrian safety, delays, and emergency response warrants analysis of grade separation as an alternative to the proposed project or as mitigation. Proper analysis of the reasonably foreseeable future condition would only further demonstrate the need for a comprehensive plan to address the identified impacts such as grade separation. Because passing tracks and grade separation are necessitated by the proposed project, the CHSRA must be responsible for implementation and funding of these projects. The High- Speed Rail should not commence service until these infrastructure improvements are complete. Transportation 5. The EIR/EIS contemplates the gate close time of 40-48 seconds for peak hour for 8 trains during any weekday period. Considering the advanced preemption and gate down initiation and opening times, the times assumed in the analysis are not indicative of actual field conditions. Furthermore, there are existing gate closures due to the existing Caltrain running along this corridor. The EIR/EIS must evaluate the cumulative conditions for these gate time closures and based on the realistic delays on traffic. Even when utilizing less conservative assumptions for anticipated gate down times, as noted above, Appendix 3.2A (Page 45, 46, 94, 95) indicates that eight of Palo Alto’s intersections would be significantly impacted. TR-MM#1 in Section 3.2, Transportation, of the Final EIR/EIS discusses site- specific mitigation identified for adverse LOS effects under NEPA. The Authority developed site-specific mitigation for the Final EIR/EIS for certain locations where adverse NEPA traffic effects were identified. However, the Authority concludes that no feasible mitigation was identified that could address the [DRAFT] San Francisco to San José Final EIR/EIS Comments Page 4 of 5 effects of any of these intersections, including: El Camino Real/Palo Alto Avenue/Sand Hill Road, Alma Street/Palo Alto Avenue, Alma Street/Churchill Avenue, Mariposa Avenue/Churchill Avenue, Park Boulevard/Meadow Avenue, Park Boulevard/Charleston Road, Castilleja Avenue/Churchill Avenue, and Wilkie Way/West Charleston Road. Therefore, the significant impacts at all of these Palo Alto intersections remain unmitigated. The related impacts on the City with respect to multi-modal transportation and the physical division of the City due to these substantial delays is unacceptable. Grade separation would serve to address these impacts and therefore must be analyzed in the EIR/EIS. 6. Despite significantly higher train speeds, as noted in the Authority’s response to comments 1118-2530, the requirements for warning times and gate down times would not change. As the City previously asserted, this presents safety concerns in that there is reduced reaction time for pedestrians, cyclists and vehicles. The addition of four-quadrant gates does not address this reduction in reaction times, especially for children that may be crossing the tracks to attend one of the many nearby schools. Therefore, the conclusion that the project would have no impact on safety is flawed. The EIR/EIS must conclude that this is a significant impact and accordingly mitigate for the impact. 7. The Authority also notes that “Caltrain is the host railroad and is responsible for compliance with all FRA safety regulations with regard to track and warning systems and would be responsible to make any adjustments in gate activation and any connection to preemption of nearby traffic signal systems.” Again, no clarity on how the Authority may change the nearby traffic signal systems is provided and there is no requirement in the EIR/EIS to coordinate with local agencies to their traffic signal system. The EIR/EIS must be revised to address this. Land Use 8. The City continues to assert that the EIR/EIS fails to properly identify and mitigate land use impacts within the City of Palo Alto. The analysis concludes that because these tracks are existing, the project would not physically divide an established community. However, under current conditions, the gate down times do not discourage transit across the tracks. The significant increase in gate down times and substantial increase in delays at nearby intersections as a result of the proposed project will serve to discourage transit across these tracks, effectively dividing the community in a way that the existing conditions do not. Because these impacts have not been properly identified, appropriate mitigation to reduce impacts, such as grade separation, similarly has not been identified. Noise 9. Impact NV#1 in Section 3.4 of the EIR/EIS identifies temporary exposure of sensitive receptors to construction noise as a significant and unavoidable impact. The proposed mitigation (NV-MM#1) encourages, but does not require, daytime construction. Although the Authority’s response to comments states that some track realignments would require nighttime construction work that could exceed FRA construction noise limits at night, it’s unclear which locations these would occur, how often they may occur, and how many/what types of uses would be affected. The EIR/EIS must disclose this information. The City continues to assert that NV-MM#1 should be revised to require daytime construction given that no other measures can effectively reduce impacts to a less than significant level in accordance with the established thresholds for nighttime noise. Historic 10. The Final EIR/EIS indicates that tree trimming of the historic Palo Alto redwood would be required. The City of Palo Alto’s Urban Forestry Division should be on site to monitor during any tree trimming work for this historic tree. [DRAFT] San Francisco to San José Final EIR/EIS Comments Page 5 of 5 We appreciate the opportunity to comment and look forward to responses to the City’s concerns. Should you have any questions regarding this letter, please contact Philip Kamhi, Director of the Office of Transportation at (650) 329-2136 or via e-mail at Philip.Kamhi@CityofPaloalto.org Sincerely, Patrick Burt Mayor, City of Palo Alto Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) San Francisco - San Jose - RECORD #1118 DETAIL Status : Unread Record Date : 9/9/2020 Interest As : Local Agency First Name : Ed Last Name : Shikada Attachments : HSR San Francisco to San Jose Project Section EIR Comments_Palo Alto.pdf (1 mb) Stakeholder Comments/Issues : Dear Northern California Regional Office of the California High-Speed Rail Authority, On behalf of City Manager Ed Shikada, please find attached letter regarding the City's comments to the San Francisco to San Jose Project Section Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS). The California High Speed Rail will have a long-lasting and far-reaching impact on the City of Palo Alto; therefore, we appreciate the opportunity to comment on this Draft EIR/EIS as a responsible agency for the Project. Highest regards, Danille [cid:image003.png@01D685C9.0AD3C620]Danille Rice Executive Assistant to the City Manager (650) 329-2105 | danille.rice@cityofpaloalto.org<mailto:danille.rice@cityofpaloalto.org> www.cityofpaloalto.org<http://www.cityofpaloalto.org/> [cid:image004.png@01D685C8.6BFD8AE0]<https://www.facebook.com/cityofpaloalto/> [cid:image005.png@01D685C8.6BFD8AE0] <https://twitter.com/cityofpaloalto> [cid:image006.jpg@01D685C8.6BFD8AE0] <https://www.instagram.com/cityofpaloalto> [cid:image007.png@01D685C8.6BFD8AE0] <https://medium.com/@PaloAltoConnect> [cid:image008.png@01D685C8.6BFD8AE0] <https://www.linkedin.com/company/cityofpaloalto> C ITY OFPALOALTO OFFICE OF THE CITY MANAGER 250 Hamilton Avenue, 7th Floor Palo Alto, CA 94301 650.329.2392 September 8, 2020 Northern California Regional Office California High-Speed Rail Authority 100 Paseo De San Antonio, Suite 300 San Jose, CA 95113 Email: san.francisco san.jose@hsr.ca.gov RE: The San Francisco to San Jose Project Section Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS) Thank you for including the City of Palo Alto in the environmental review process for the above-referenced project. The California High Speed Rail (HSR) will have a long-lasting and far-reaching impact on the City of Palo Alto; therefore, we appreciate the opportunity to comment on this Draft EIR/EIS as a responsible agency for the Project. 1118-2511 Executive Summary The Draft EIR/EIS is seriously flawed in numerous respects as outlined in this letter. Fundamentally, the document fails to adequately analyze, much less mitigate, a variety of clear and significant impacts that this project will cause to the Palo Alto community. Failure of the Draft EIR/EIS to consider the cumulative impacts of this project with the Caltrain business plan through the four at-grade crossings would pose an increased safety risk of collisions between trains and people walking, biking, and driving across these crossings. When examining impacts, the Draft EIR/EIS does not analyze the reasonably foreseeable consequences and impacts of the adopted or on-going planning efforts of other users of the corridor that are tied to the HSR project. Such a disconnect ignores the impacts related to the at-grade crossings and the additional four-tracking that may be needed within the corridor. The proposed project alternatives lead to significant impacts to emergency response, noise, and circulation. Grade separation between tracks and crossings at Meadow Drive, Charleston Road, Churchill Avenue, and Palo Alto Avenue would address the impacts related to noise with the elimination of train horns and alleviate the other safety concerns posed at-grade intersection. There is no rationale for excluding grade separations as a feasible mitigation particularly given the Federal Rail Administration's conclusion that the Palo Alto at-grade crossings are amongst the most dangerous in the State. The Draft EIR/EIS falls woefully short of any reasonable standard of environmental analysis. 1118-2512 Project Understanding The City of Palo Alto (City) understands that, Consistent with Tier 1 decisions, the San Francisco to San Jose Project Section (Project Section or project) would provide High Speed Rail (HSR) service from the Salesforce Transit Center (SFTC) in San Francisco to Diridon Station in San Jose along approximately 49 miles of the Caltrain corridor. Within the City of Palo Alto, the project would be located along 3.8 miles of Caltrain right- of-way through the middle of Palo Alto, where the existing Caltrain tracks bifurcate the City from east to West. The current project design proposes a blended infrastructure with Caltrain operations through the City. The current proposed project, as well as both Alternatives carried forward in the environmental analysis, propose two at-grade tracks through the City, mostly within the existing Caltrain right-of-way. CityOfPaloAlto.org Printed with soy-based inks on 100% recycled paper processed without chlorine, 1118-2512 The City understands that within Palo Alto, the project would require slight modifications (typically of less one than foot) to the tracks in several areas to straighten curves in order to support higher speeds. The project also requires the installation of two radio towers (one north of Embarcadero Road and one north of West Charleston Road), four-quadrant gates at existing at-grade crossings, and either fencing or sounds walls along the entire corridor within the City. The Project will provide HSR services at a downtown San Francisco station, a Millbrae station, and the San Jose Diridon Station; no station is proposed within the City of Palo Alto under the current proposed project or either of the two alternatives. The blended system would accommodate operating speeds of up to 110 mph for up to four HSR trains and six Caltrain trains per hour per direction in the peak period. HSR and Caltrain are the only passenger rail services that would operate in the blended system. North of the Santa Clara Caltrain Station, freight would use the same tracks as HSR and Caltrain but would operate at night with temporal separation to avoid conflicting with HSR and Caltrain operation, similar to existing conditions. 1118-2513 Rail Alignment. Profile, and Right-of-Wav 1.As discussed further throughout this letter, the EIR/EIS shall consider an alternative or mitigation that includes grade separation of the existing at-grade crossings within the City to reduce impacts related to land use, transportation, and safety that would result from the project. Impacts under these three resources have not been fully identified and mitigated in the Draft EIR/EIS. Additionally, the Authority shall begin inter-agency conversations with the City and other relevant state, regional and local agencies with respect to fair-share funding contributions for grade separations. 1118-2514 2. The City understands that two options are provided for each of the two radio towers required within the City. For each of these two options a site located on private property (4131 Park Blvd and 100 Addison Avenue) and a site located within Caltrain right-of-way is shown. The installation of these towers requires a discretionary permit from the City of Palo Alto and may require easements and/or encroachment permits, depending on which option is selected. The City would not support the location of these towers on private property if an alternate location within Caltrain right-of-way is viable. If construction of either of these radio towers is necessary on private property, the California High Speed Rail Authority (Authority) shall contact and inform these property owners and coordinate for such needs with these property owners prior to filing for any permits from the City. 1118-2515 3. The EIR baseline operational analysis considers only six (6) trains per direction during the peak hours for Caltrain services, which requires the two tracks currently proposed. However, Caltrain's 2040 Vision Plan identifies a moderate growth scenario that calls for eight (8) Caltrain trains per direction during the peak hours and a high growth scenario that calls for twelve (12) Caltrain trains per direction during the peak hours. This conflict in corridor planning needs to be reconciled. The City understands that if eight (8) trains are proposed during the peak hours, additional passing tracks would be necessary. Based on Caltrain's adopted 2040 Vision Plan, this shall be considered a reasonably foreseeable future project and shall be analyzed under the Cumulative scenario. The location of these additional passing tracks shall be disclosed, and the impacts of these tracks must be fully evaluated. 1118-2516 Land Use 4. In the City's scoping comments dated March 31, 2009, the City of Palo Alto requested that the Authority utilize the City's CEQA thresholds in evaluating impacts on components within the City's jurisdiction. However, the EIR/EIS established its own thresholds for land use impacts, which do not reflect the City's thresholds or the State CEQA Guidelines. As a responsible agency, the City of Palo Alto will rely on this EIR in issuing the necessary permits for construction of the project. Therefore, for the purposes of CEQA , the environmental analysis needs to evaluate impacts under land use consistent with the thresholds recommended by the state and adopted by the City of Palo Alto. This includes an analysis of: 1118-2516 whether the project would physically divide and established community; and whether the project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. 1118-2517 5. In accordance with the thresholds identified above, the EIR/EIS must analyze the impacts of HSR preemptions at at-grade crossings and the construction of a noise barrier across the City. With major educational (elementary, middle, high schools, Stanford University), employment centers, and central business districts across the train corridor, the addition of HSR preemptions for at-grade intersections and a 12-14 foot noise barrier across the majority of the tracks will significantly impact connections across the City, visually and physically dividing the community. Because these impacts have not been properly identified, mitigations measures have similarly not been identified to reduce these impacts. 1118-2518 6. In accordance with the thresholds identified above, the EIR/EIS must identify the project's conflicts with the City's Comprehensive Plan policies and Municipal Code Regulations. Land Use Section 3.13 does not identify any inconsistencies with the City of Palo Alto's policies or regulations and concludes that the projects impacts would be less than significant without the need for mitigation. However, Appendix 2-J clearly states that the project is inconsistent with the City of Palo Alto's Comprehensive Plan policies and regulations with respect to noise. Table 1 of Appendix 2-J acknowledges that "Although mitigation measures would be able to reduce project noise levels, they would not reduce all levels to the standards for residential, commercial, and institutional land uses due to the limitations in noise barrier cost effectiveness, implementation (HSR cannot implement quiet zones; only local jurisdictions can), and funding (in regards to grade separations)." Land Use Section 3.13 must be revised to accurately reflect that the project would have a significant impact with respect to inconsistencies with applicable plans and policies within the City of Palo Alto. It must clearly identify the mitigation measures that would reduce that impact to the extent feasible. If mitigation does not reduce this impact to a less than significant level, the EIR/EIS must conclude, for the purposes of CEQA, that impacts would be significant and unavoidable with respect to consistency with local land use policies. 1118-2519 Noise 7. Impact NV#1 in Section 3.4 of the EIR/EIS identifies temporary exposure of sensitive receptors to construction noise as a significant and unavoidable impact. The proposed mitigation (NV-MM#1) encourages, but does not require, daytime construction. It appears to allow the construction contractor to determine the appropriate measures to limit noise but does not set a performance measure that the contactor is required to meet. It only requires reporting after the fact (annually) to the Authority, identifying measures that were implemented. NV-MM#1 should be revised to require daytime construction if other measures cannot effectively reduce impacts to a less than significant level in accordance with the established thresholds for nighttime noise. 1118-2520 8. Table 3.4-25 of the Draft EIR/EIS explains that under Impact NV#8, temporary exposure of sensitive receptors and buildings to construction vibrations, the project "would cause annoyance at nighttime to sensitive receptors within 140 feet for infrequent events and within 300 feet for repetitive equipment such as pile driving, vibratory compaction, and ongoing demolition work with jackhammers or hoe- rams." However, NV-MM#2 only appears to address potential impacts to buildings and does not address impacts to sensitive receptors that may be impacted by vibrations at nighttime. Although NV-IAMF#1 (impact, avoidance and minimization feature) is identified to reduce impacts to sensitive receptors, this measure primarily reduces noise rather than vibration. The measure does not identify performance criteria that must be met to reduce impacts on sensitive receptors to a less than significant level. 1118-2520 Within the City there are hundreds of sensitive receptors along this corridor, many of which are residences that would be severely impacted due to nighttime vibrations during construction. The Draft EIR/EIS must identify mitigation with clear performance criteria to reduce impacts to these sensitive receptors to a less than significant level. Mitigation shall include prohibition of nighttime construction that causes vibration if other measures cannot effectively reduce impacts to a less than significant level. Pile driving at nighttime shall be prohibited. 1118-2521 9. The analysis of both noise and vibrations needs to clearly quantify the expected level of noise and vibration that sensitive receptors would experience before and after the implementation of mitigation. The analysis currently only provides information on the number of receptors that would be impacted before and after mitigation; not on the level of impact that those receptors would experience. 1118-2522 10. The proposed construction hours for track modifications are outside of the City's allowed construction hours, as established in Chapter 9.10 of the City's Municipal Code. Construction outside of the allowed construction hours requires a permit from the City. The City would not issue this permit for construction activities near residential areas if measures cannot be implemented to reduce impacts on receptors to a less than significant level. 1118-2523 11. Under Impact NV# 2, the Draft EIR/EIS concludes that implementation of the project alternatives would not change current practices regarding the sounding of train horns and crossing bells, but would change the amount of train horns and crossing bells sounding due to the additional trains. Additional trains will cause noise levels above existing ambient levels and in exceedance of FRA criteria, causing severe noise impacts at sensitive receptors. The City understands that the project has analyzed two scenarios with respect to mitigation for noise associated with train horns. The first scenario assumes that quiet zones have not been established within the peninsula and identifies the location where sound walls would therefore be constructed along the corridor to reduce noise levels associated. The City understands that sound walls would be constructed along the majority of the corridor within the City of Palo Alto if quiet zones are not established at the City's existing at-grade crossings. Under the second scenario, if the City were to establish quiet zones for the City of Palo Alto through the requisite process, this would eliminate the requirement for all trains to routinely sound their warning horns when approaching at-grade crossings. Under this scenario, the EIR/EIS shows that sound walls would therefore only be necessary in three locations with the City of Palo Alto. The City recommends that the Authority shall consider grade separation for at-grade crossings due to safety and other reasons stated in this letter, which is feasible mitigation that would also mitigate the need for train horns and therefore construction of noise barriers across the City. However, for the interim measures until grade crossings are built the City of Palo Alto recommends the Authority to establish a Quiet Zone within the City of Palo Alto. In addition, since this process is only necessary to address impacts of the proposed project (as an alternative to noise barriers) the City of Palo Alto shall not bear the financial burden of the process to establish a Quiet Zone. The mitigation measures must require that the Authority bear any costs and to support the process of establishing a Quiet Zone for any jurisdiction that elects to pursue this alternative as well as any liabilities associated with this. 1118-2524 Transportation 12. The City has established a Local transportation Impact Analysis Policy (See Attachment A). The City requests that the Authority comply with this policy, in addition to CEQA and NEPA guidelines, in order to assess the project's local impacts within the City's jurisdiction. The analysis of intersection delays 1118-2524 that was included in the Draft EIR/EIS under Impact TR#5 shall utilize the City's significance criteria when determining whether localized impacts would occur outside of CEQA. 1118-2525 13. Section 3.2 of the Draft EIR/EIS analyzes impacts on bicycle and pedestrian access and Section 3.11 of the Draft EIR/EIS studies hazards associated with the project. However, the Draft EIR/EIS does not adequately analyze the potential hazards associated with the increase in the number of trains and increase in train speeds on school age pedestrians and bicyclists. In Palo Alto, approximately 58 percent of students from elementary school to high school ages walked or hiked to school in 2019. Therefore, a significant number of school age children cross the train tracks at existing at-grade crossings in order to attend nearby K-12 schools (e.g. Hoover Elementary, Palo Alto High, Castilleja, etc.). The proposed four-channel crossing gate mechanism is not adequate to protect these children; this shall be identified as a significant impact with respect to safety and shall be evaluated further. Providing a grade-separated crossing would reduce impacts on pedestrians and bicyclists, including school age children. 1118-2526 14. With the addition of new trains, the proposed gate down time during peak hours will increase by almost 67% (with the addition of 4 HSR). These additional trains throughout the day reduce the time available for pedestrians and bicyclists to cross through the at-grade locations in Palo Alto (Churchill, Meadow, Charleston and Palo Alto) crossings. The impact of the proposed project on these crossing connections for pedestrians and bicyclists must be analyzed and mitigated. 1118-2527 15. Impacts TR # 1 through TR #5 identify impacts and delays on intersection operations. As explained on page 3.2.63, the project results in a 334 second increase in delays at Churchill and 187 second increase in delays at West Meadow Drive. This will severely affect signal operations and controls and thus traffic flow in the area. Although under SB 743 vehicle delays are no longer considered a significant impact under CEQA, the delay at these intersections will impact other modes of transportation such as bicyclists, pedestrians, and bus transit. Such impacts to other modes of transportation still require analysis and appropriate mitigation in accordance with CEQA. These impacts have not been properly identified and TR-MM#1 does not adequately address these impacts. 1118-2528 16. Vehicle delays would also result in extensive queueing spilling on to through lanes and may cause the need for additional storage for turning movements. Extensive queueing will create safety hazards near at grade crossings. The intersection geometry at all four at-grade crossings within the City must be studied in order to properly identify potential hazards and these impacts shall be mitigated. 1118-2529 17. With major educational (elementary, middle, high schools, Stanford University), employment centers, and central business districts across the train corridor, the addition of HSR preemptions for at-grade intersections will significantly impact all modes of transit throughout the day, causing impacts on the transportation system. These impacts have not been properly identified; therefore, mitigations measures have similarly not been identified to reduce these impacts. 1118-2530 1118-2531 18. The project proposes a change in the speed of trains from 79 mph to 110 mph. This change will reduce the reaction time for pedestrian, bicycle, and vehicular activities. In addition, this will impact advanced preemption timings for nearby signals. The existing signals in the vicinity, until grade separated, will need to have advanced preemption to ensure that there is adequate queue clearance, pedestrian times, track clearance and signal operation coordination. These impacts are identified generally but are not quantified and clearly explained to address such impacts. The project shall describe how these improvements will be funded and constructed. The City does not support higher speeds of trains running through urbanized area and therefore requests to use Caltrain planned speed limits or speeds that match existing speed of Caltrain service unless grade separation is proposed at crossings. 1118-2532 19. The analysis shall evaluate service options that include HSR operating at the same speed as Caltrain from San Jose to San Francisco and must identify the safety benefits that could be derived by running slower speed trains in an urban environment. 1118-2533 20. Due to additional delay at the intersections near the at-grade crossings, the traffic may be diverted to other parallel residential streets, thus impacting the character of neighborhood and livability of Palo Alto residents. These impacts must be identified and mitigated and shall be studied in accordance to City of Palo Alto Traffic impact policy on Traffic Infusion and Residential Environment (TIRE) (Attachment B in Exhibit A). 1118-2534 21. Under Impact TR#7, the analysis identifies that the HSR will increase the parking demand on the other Caltrain stations with increased ridership to connect to get onto HSR at other HSR stations. This increase in ridership to get to HSR transit hubs will necessitate additional parking at other existing Caltrain Stations. This must be identified and mitigated in the EIR/EIS. 1118-2535 22. Impact TR# 9 and TR#11 study permanent and continuous impacts on bus transit. However, the Draft EIR/EIS fails to recognize existing transit routes near the corridor that are impacted by project. Alma Avenue, which parallels the HSR tracks in Palo Alto, is a major road used by express bus transit. The intersections along this corridor will experience significant delays at traffic signals adjacent to at-grade crossings, which in turn, will affect express bus service. TR-MM#2 identifies the transit priority for corridors but fails to identify such impacts on Alma Avenue, and therefore fails to provide any mitigation to address this impact. 1118-2536 Public Services 23. As discussed on Draft EIR/EIS Page 3.11-60, the reduced availability of crossings will impact emergency response times. The project includes mitigation, which includes the Authority's fair share toward reducing the vehicle response time; however, impacts are still identified as significant and unavoidable. Under CEQA, the analysis must analyze any feasible mitigation or alternatives to address impacts before identifying an impact as significant and unavoidable. An alternative or mitigation that includes grade separation for at-grade crossings must be evaluated to ensure adequate response times. If the Authority does not pursue at-grade crossings as part of an alternative or as mitigation to restore response times, the Authority shall bear the full cost of restoring response times to existing conditions. 1118-2537 Historic 24. The proposed project identifies track modifications, including horizontal alignment changes of more than 1 foot and less than 3 feet on the SPRR San Francisquito Creek Bridge, which is located approximately 10 feet west of the Historic El Palo Alto redwood tree. Track work in this location may also require relocation of OCS poles and OCS pole electrical safety zones. The EIR/EIS concludes that the project would not result in modifications to the El Palo Alto redwood, and that impacts would therefore be less than significant without mitigation. However, although the project does not propose direct removal or modifications to the tree, grading or the use of vibratory equipment for track work within 10 feet of the historic tree could result in direct or indirect impacts to the root structure. These impacts must be evaluated and mitigated to ensure that impacts to this historic landmark would remain less than significant. 1118-2538 Utilities 25. Impact PUE#2 identifies impacts associated with the relocation or removal of existing major utilities as less than significant without mitigation. However, construction activities that result in vibrations above or immediately adjacent to existing infrastructure could indirectly impact infrastructure. The City of 1118-2538 Palo Alto owns and maintains a wide variety of infrastructure that cross these tracks. The potential for indirect impacts must be identified and mitigation shall be included to require advanced coordination with the City when working in close proximity to its infrastructure as well as to verify, post- construction, that the City's infrastructure has not been damaged. 1118-2539 26. Although the analysis concludes that the Authority and service providers would work to relocate utilities on a long-term basis, the discussion identifies that temporary utility disruptions may occur. Although applicant proposed measures are identified to reduce these impacts and provide notifications to customers, the duration of these outages is unclear. The document needs to more clearly identify the anticipated temporary impacts on utilities, including the likely duration of outages that may be necessary. 1118-2540 Trees and Vegetation 27. The proposed project plans appear to show that new wails or fence would be installed up to the edge of the existing right-of-way, with no space planned for planting vegetation screening. It is unclear to what extent existing vegetation along the right-of-way, which currently provides effective screening in some locations, would be retained or replanted. Space needs to be provided for vegetation screening, especially where the rail is within close proximity to sensitive receptors. 1118-2541 28. MM-39 states that mitigation would be provided at no more than a 1:1 ratio unless the City's ordinance provides for stricter ratios. For mitigation within the City, the project would be required to replace trees in accordance with the City's Tree Tech Manual tree value replacement standard, as outlined in the City's Tree Technical Manual, which is codified in Chapter 8 of the City's Municipal Code. The Tree Technical Manual can be found at: https://tinvurl.com/PA-Tree-Technical-Manual We appreciate the opportunity to comment and look forward to reviewing the Final EIR/EIS, including responses to the City's comments. Should you have any questions regarding this letter, please contact Philip Kamhi at (650) 329-2500 or via e-mail at Philip.Kamhi@citvofpaloalto.org Sincerely, Ed Shikada City Manager Attachments: Exhibit A: Local transportation Impact Analysis Policy CC: Palo Alto City Council Members Expanded Community Advisory Panel Palo Alto Planning and Transportation Commission Palo Alto Pedestrian and Bicycle Advisory Committee Palo Alto Safe Routes to School Committee V CITY OFPALO ALTO CITY OF PALO ALTO LOCAL TRANSPORTATION IMPACT ANALYSIS POLICY Senate Bill (SB) 743, adopted in 2013, required the Governor's Office of Planning and Research (OPR) to prepare amendments to the CEQA Guidelines with respect to the analysis of potential transportation effects to provide an alternative metric to traffic congestion and delay at intersections (often referred to as Level of Service (LOS)). After five years of analysis and outreach, in December 2018, the California Natural Resources Agency approved OPR's proposed amendments to the CEQA Guidelines requiring agencies to use vehicle miles traveled (VMT) generated by a project as the metric for transportation impact analyses under CEQA effective July 1, 2020. Under SB 743 and the revised CEQA Guidelines, LOS may no longer be used to determine whether a project may have a significant environmental impact to transportation and traffic under CEQA. While statewide implementation of VMT analysis to replace LOS analysis is required under CEQA, SB 743 did not require changes to transportation analyses outside of CEQA, including the evaluation of regionally significant intersections under the Congestion Management Program (CMP) under a separate state law. Nor did SB 743 affect the discretion of public agencies to assess impacts on local streets and intersections for compliance with adopted plans and policies. As such, in conformance with Policy T-2.3 and Program T-2.3.1 of the City's Comprehensive Plan 2030,1 LOS standards are adopted through this policy to analyze potential local transportation impacts of projects in Palo Alto. I. Purpose The purpose of this Policy is to ensure consistency in reviewing and identifying transportation effects of proposed development projects for local intersections and facilities and to determine standards for necessary remediation measures. 1 Comprehensive Plan Policy T-2.3: Use motor vehicle LOS at signalized intersections to evaluate the potential impact of proposed projects, including contributions to cumulative congestion. Use signal warrants and other metrics to evaluate impacts at unsignalized intersections. Program T-2.3.1: When adopting new CEQA significance thresholds for VMT for compliance with SB 743 (2013), adopt standards for vehicular LOS analysis for use in evaluating the consistency of a proposed project with the Comprehensive Plan, and also explore desired standards for MM LOS, which includes motor vehicle LOS, at signalized intersections. Policy T-2.4: Consistent with the principles of Complete Streets adopted by the City, work to achieve and maintain acceptable levels of service for transit vehicles, bicyclists, pedestrians and automobiles on roads in Palo Alto, while maintaining the ability to customize to the Palo Alto context. Policy T-3.3: Avoid major increases in single-occupant vehicle capacity when constructing or modifying roadways unless needed to remedy severe congestion or critical neighborhood traffic problems. Where capacity is increased, balance the needs of motor vehicles with those of pedestrians and bicyclists II. Level of Service (LOS) Analysis LOS is the measurement of delay at intersections used to determine whether a project is consistent with the City's Comprehensive Plan and this Policy LOS is based on the Highway Capacity Manual (HCM) methodology where a letter grade is assigned to an intersection operation based on the amount of delay motorists experience in traveling through the intersection. Table 1 below shows the comparison in LOS depending on whether the intersection is signalized or not. Table 1: Level of Service Delay - Signalized vs. Non-Signalized Intersections Level of Service Grade Description Signalized Average Delay (Sec) Unsignalized Average Delay (Sec) A Signal Progression is extremely favorable. Little or no traffic delay. 10.0 or less 10.0 or less B Operations characterized by good signal progression and/or short cycle lengths. Short traffic delays. 10.1 to 20.0 10.1 to 15.0 C Higher delays may result from fair signal progression. Average traffic delays. 20.1 to 35.0 15.1 to 25.0 D Congestion becomes noticeable. Long traffic delays. 35.1 to 55.0 25.1 to 35.0 E Considered the limit of acceptable delay. 55.1 to 80.0 35.1 to 50.0 F Level of delay is considered unacceptable by most drivers. Extreme traffic delays. Greater than 80.0 Greater than 50.0 Source: Transportation Research Board, Highway Capacity Manual 2010 III. Standards for Determining Transportation Analysis 1. Within the CMP Svstem Regional CMP Analysis Traffic Impact Analysis (TIA) reports vary in scope depending on the use of the report and size of the project. Under the purview of the California Congestion Management Program (CMP) Statute, Palo Alto must follow the methodologies presented in the VTA Transportation Impact Analysis Guidelines for intersections within the CMP system, to evaluate transportation effects and submit a full TIA report of all development projects that are expected to generate 100 or more net new weekday (AM or PM peak hour) or weekend peak hour trips, including both inbound and outbound trips. CMP intersections within Palo Alto are listed below. A map of all CMP intersections can be found in Attachment A. i. Middlefield Rd./Oregon Exp. ii. Middlefield Rd./San Antonio Rd. iii. El Camino Real/University Ave./Palm Dr. iv. El Camino Real/ Sand Hill Rd./Palo Alto Ave. v. El Camino Real/Embarcadero Rd. vi. El Camino Real/Page Mill Rd. vii. El Camino Real/Arastradero Rd./Charleston Rd. viii. Foothill Exp./Junipero Serra Blvd./Page Mill Rd. ix. Foothill Exp./Arastradero Rd. x. San Antonio Rd./Charleston Rd. 2. Outside the CMP System Local Analysis The City requires a Local Transportation Analysis (LTA) report for any project that is expected to generate 50 or more net new weekday (AM or PM peak hour) trips, including both inbound and outbound trips, prior to any reductions assumed for Transportation Demand Management (TDM) measures. The City may also require a LTA if in its reasonable judgement a project will potentially cause a deficiency in the operation of local intersections. A LTA report must include the following: i. Project description; ii. Existing conditions; iii. Site access and circulation; iv. Vehicle trip generation (weekday AM and PM peak); v.__Vehicle trip distribution; V. Vi. LOS analysis for selected study intersections: and vi. vii. Remediation measures (if proposed) Depending on the size and layout of the project, additional elements listed below may be required by the City to include in the LTA report. i. Traffic Infusion on Residential Environments (TIRE) Analysis is an analysis of new potential traffic disturbances along a local residential streets created by a project as described in the Attachment B. When a proposed development project is expected to add 10 or more peak hour vehicles per any direction to a local residential street that is not on a project's direct route to collector or arterial streets, the project is required to submit a TIRE analysis. ii. Queuing Analysis that identifies queues spilling beyond their current storage bays. Improvements may include lengthening storage bays to meet projected demand or roadway capacity improvements to add additional turn pockets at an intersection. The City typically takes the lead in identifying potential capacity improvements to help facilities site design. iii. Transit Analysis for projects located along a key transit route, such as El Camino Real, a focused analysis in partnership with the VTA or other transit operators is provided to determine if off-site improvement of a project should consider additional parking stop improvements such as shelters or bus duck- outs. iv. Bicycle and Pedestrian Circulation Study is an analysis of how the site operations may affect bicycle and pedestrian operations. Where appropriate, if a project is located along a major bicycle route in the City's Bicycle & Pedestrian Transportation Plan, the project may be required to help implement a portion of the recommended facility. Additional improvements may include limiting driveway curb-cuts to minimize conflicts with pedestrians or provision of enhanced crosswalk facilities. v. Parking Analysis is a study to determine location, use, and adequacy of the proposed parking facility. Projects should include a parking analysis under the following conditions: a. Change in the facilities' existing design or supply; or b. Change in the existing parking management; or c. Propose parking less than that required by the Palo Alto Municipal Code 18.52 (https://tinvurl.com/PA-Municipal-Code): or d. Use of parking adjustments by the Director as defined in the Palo Alto Municipal Code 18.52 (https://tinvurl.com/PA-Municipal-Code). When a proposed project requests a parking reduction or exception as allowed under the Municipal Code, a robust Transportation Demand Management (TDM) Plan is typically required independent of the LTA. For projects in a Parking Assessment District, required payment of assessments to the District will be noted in the LTA report and included in the project's conditions of approval. A project will provide an analysis of one or more of the above elements if the project is expected to substantially affect the identified local facilities, even if the anticipated number of new vehicle trips would not require a LOS analysis. _ IV. Local Transportation Impacts - Standards for Determining Transportation Consistency 1. Level of Service Standard The City of Palo Alto's Level of Service (LOS) standard is D, which is more conservative than the CMP LOS standard of E. If the LTA shows that a development project is anticipated to cause a transportation facility (intersection or roadway) to degrade below LOS D to LOS E or F, then the project will be deemed inconsistent with this Policy. For a transportation facility determined to have been at LOS E or F under existing and background conditions without the project, a project is said to have significant local impact if the LTA shows that the project will cause LOS to deteriorate by the following amounts: i. Addition of project traffic increases the average delay for critical movements by four or more seconds; or ii. Addition of project traffic increases the critical Volume/Capacity (V/C) value by 0.01 or more; or iii. Affects a freeway segment or ramp to operate at LOS F or project traffic increases freeway capacity by one or more percent. 2. Selection of Study Intersections or Roadways An intersection should be included in the LTA if it meets any one of the following conditions: i. Proposed development project is expected to add 10 or more peak hour vehicles per any lane to any intersection movement; or ii. The intersection is adjacent to the project; or iii. Based on engineering judgement, City staff determines that the intersection should be included in the analysis. Additionally, a roadway segment should be included in the LTA with a TIRE analysis if a proposed development project is expected to add 10 or more peak hour vehicles per any direction to a local residential street. More details on the TIRE analysis are available in Attachment B. 3. CMP Intersection Standard A CMP intersection must adhere to the standards set by the Congestion Management Agency2 (currently LOS E), as set forth in the VTA Transportation Impact Analysis Guidelines. The City's standard of LOS D would apply for determining local level impacts.. Any transportation impact triggered by VTA's standard for CMP intersections would need to be addressed following guidelines established by VTA. More information regarding mitigation measures and Multimodal Improvement Plans (MIP) are available in the VTA Guidelines for TIAs and Deficiency Plans. 4. Auto Level of Service Analysis at Unsignalized Intersections For all-way stop control, the LOS is based on the average delay. For 1- or 2-way stop control, the LOS should be based on the critical approach movement. The above standards for determining transportation consistency remain appropriate only if traffic volumes satisfy the peak hour traffic signal warrant. Meeting a peak hour traffic signal warrant does not automatically make a traffic signal an appropriate remediation measure. 5. Other Transportation Impacts Depending on the size and layout of the project, a LTA may require analysis to evaluate other project-related effects on the transportation system. The following is a list of elements that are considered to have project-related local impacts: i. Result in noticeable traffic effects on local residential streets defined as an increase of 0.1 or more using the TIRE methodology. ii. Impede the development or function of existing or planned pedestrian or bicycle facilities. iii. Increase demand for pedestrian or bicycle facilities that cannot be met by existing or planned facilities. iv. Impede the operation of a transit system as a result of increased traffic congestion. v. Create demand for transit services that cannot be met by current or planned services. vi. Create the potential demand for cut-through traffic or redistribution of traffic to use local residential streets, based on the TIRE methodology described above. vii. Create an operational safety hazard. viii. Result in inadequate emergency access. 2The Santa Clara Valley Transportation Authority (VTA) is the Congestion Management Agency (CMA) for Santa Clara County. V. Remediation Measures All Local Transportation Impacts under Section VI of this Policy must be addressed through the project's adoption or use of appropriate local remediation measures, including funding their associated costs. The LTA must include proposed remediation measures and identify any potential impacts of such measures. Remediation measures shall reduce the project-related local impacts to a level without the proposed project, and should not themselves create potentially significant CEQA impacts. These remediation measures will be incorporated in the project conditions of approval and not as part of the CEQA analysis. The following is a list of potential remediation methods in priority order: 1. Projects and programs that reduce a project's vehicle trip generation, including, but not limited to Transportation Demand Management (TDM) programs, capital improvements to transit, bicycle, and pedestrian facility enhancements within an influential project area.3 The following is a non-exhaustive list of potential remediation methods: i. Provide new or upgrade existing access to, from, and through the project for pedestrians and bicyclists. ii. Provide improvements to transit facilities or services. iii. Implement TDM programs such as flexible at-place working hours, telecommuting, carpools, shuttles, transit passes, parking cash-out, among others. 2. Multimodal operational or facility improvements including intersection operational efficiency treatments. Proposed improvements or treatments with geometric changes to an intersection are limited to features that would not likely lead to substantial or measurable increase in vehicle travel. 3. If project impacts cannot be remediated through methods 1 and 2 above, a fair share of the cost for multimodal network remediation shall be contributed to the City's transportation improvement funds. While the remediation measures in method 1, above, should be proposed within an influential project area, methods 2 and 3 may apply outside the area. However, these proposed improvements should substantially contribute to the City's Comprehensive Plan goals in expanding the City's multimodal transportation system. By implementing or funding these types of improvements, the project would therefore be consistent with the Comprehensive Plan and this Policy. 3 Area of influence of a project is defined as up to half-mile for pedestrian facilities and up to three miles for bicycle facilities, or bicycle facilities that provide a connection to the local or regional bicycle network. Unacceptable Measures In addition, remediation measures that will result in a physical reduction in the capacity and/or deterioration in the quality of any existing or planned transportation facilities are unacceptable. The following is a list of remediation methods that would be considered generally unacceptable without special justification, but are not limited to: 1. Roadway widening not directly related to site access and circulation, or specific conditions that reduce local impacts as a result of the project. 2. Negatively affecting a sidewalk or reducing the width of a sidewalk without substantial improvement to the overall pedestrian circulation. 3. Maintaining an existing sidewalk in the immediate vicinity that is below the current city standard. 4. Negatively affecting existing bicycle infrastructure or reducing the length of a bicycle infrastructure. 5. Maintaining existing bicycle infrastructure that is below the current city standard. 6. Eliminating a bus stop without adequate replacement or improvement to the system. 7. Encouraging neighborhood cut-through traffic (intrusion effects along local residential streets). VI. Authority to Adopt Guidelines The Chief Transportation Official is authorized to adopt guidelines to implement this Policy. ATTACHMENT A CONGESTION MANAGEMENT PROGRAM INTERSECTIONS O «**'***' ---------------------------ol 4 @ m ° CMPWe"*c“"W0 0 / ' 1 ° 0<5» b i o - r z . **4> ° 0 ° o „ ,I, O ° ^ O O l<gyt OO --------------------=E P Jg a -„ J° 8 O sfvcP oI ft- Q 0 ^ . 0 0* «b °o o ° ft O <P b O’ ° >°© S o o V0® ° /o ^ l ° o »«—l s off1 ® / ° V q, o° s r° . ft\ O o 30 0-0 OCCP8 Q o ^ O% * t ‘■''0«C 0° / 8 \0 8 * .,*.*,0 % k a" “ " 1 ) 0 0 O 0 0 ^0 0 — <b f' o ° O ----------------------- 0 | o o 9 oO o South County 0 # « 13 (fc Q ° 8 0 —^ \ > • % 0 0^ ° “ CO ° \ 8V Q O Braoh»ti O& o o 000 -a o® a 8 § 8 «o ® ° 6 0 * £ " “ ° 6 ‘ 3~...-■ - & 0\ Source: Santa Clara Valley Transportation Authority Congestion Management Program Document 2017 ATTACHMENT B CITY OF PALO ALTO - TRAFFIC INFUSION ON RESIDENTIAL ENVIRONMENTS (TIRE) ANALYSIS Excessive vehicular speed and traffic volume on residential streets pose a major threat to quality of life. Most Palo Alto streets are bordered by residential uses, and it is the City's priority to preserve local neighborhood characteristics. Additionally, the City has designated some streets as residential arterials to recognize that they carry large traffic volumes of through-traffic but also have residential uses on both sides of the streets. The objective of this analysis is to address the desires of residents of these streets who prefer slower vehicular speeds and to determine if implementation of a project would cause a substantial change in the character of these streets. The City of Palo Alto uses the Traffic Infusion on Residential Environments (TIRE) methodology to estimate residential perception of traffic effects based on anticipated average daily traffic growth. Although not required under the California Environmental Quality Act (CEQA) or pursuant to the Santa Clara Valley Transportation Authority (VTA) guidelines, this methodology intends to determine new potential traffic disturbances - cut-through traffic (intrusion effects) and direct traffic (infusion effects) - along local residential streets due to a proposed development project. For projects on a local residential street, new traffic disturbances along that specific street will likely be unavoidable. Thus, the potential infusion effects generated along a specific local residential street of which a project is proposed will be used only for informational purposes. A map of Palo Alto's local residential streets can be found in Map 1 in this attachment. The City aims to reduce potential adverse intrusion effects along local residential streets. Significant amount of vehicle intrusion on these streets may need to be addressed through traffic management strategies. Traffic Infusion on Residential Environments (TIRE) Index The TIRE methodology assigns a numerical value to "residents' perception of traffic effects on activities such as walking, bicycling, and maneuvering out of a driveway on local residential streets." The TIRE index scale ranges from 0 to 5 depending on daily traffic volume. An index of 0 represents the least traffic disturbances and 5 the greatest, and thereby, the poorest residential environment. Streets with a TIRE index of 3 and above are considered to function primarily as a traffic street and exhibit an impaired residential environment. Therefore, streets with a TIRE index below 3 are better suited for residential activities. Any projected change in the TIRE index of 0.1 or less is considered to have no noticeable effects. A change of 0.1 would be barely noticeable, and a change of 0.2 or greater would be noticeable. The TIRE Index can be found in Table 1 in this attachment. 2020052801 2020052801 CITY OFPALO ALTO i CITY OFPALO ALTO v CITY OFPALO ALTO I. Standards for Determining Analysis A proposed development project expecting to add 10 or more peak hour vehicles per any direction to a local residential street. II. Selection and Data Collection of Roadway Segments Roadway segments should be included in the LTA if a proposed development project is expected to add 10 or more peak hour vehicles per any direction to a local residential street. Data collected under the TIRE methodology must be supported by 24-hour weekday traffic counts. For projects on a local residential street including both single- or multi-family, as defined in the City's Comprehensive Plan 2030, the TIRE analysis must include the following: 1. Direct routes to the project; 2. Immediate connections to a project's direct collector or arterial streets; and 3. Based on engineering judgement, City staff determines what roadway segments should be included in the analysis. A Palo Alto land use map can be found in Map 2 in this attachment. III. Standards for Determining Noticeable Effect Projected change in the TIRE index of 0.1 or more under existing and background conditions, is considered to cause noticeable effects on the character of local residential streets. These traffic effects may need to be addressed through traffic management strategies. v CITY OFPALO ALTO Table 1: Traffic Infusion on Residential Environments (TIRE) Index TIRE Index Existing Daily Traffic Volume Volume to Cause +0.1 Change in TIRE Index Volume to Cause +0.2 Change in TIRE Index Volume Description 1.5 29-35 6 15 Low 1.6 36-44 8 20 1.7 45-56 10 25 1.8 57-70 13 32 1.9 71-89 17 41 2.0 90-110 22 52 Moderate 2.1 111-140 29 65 2.2 141-180 40 80 2.3 181-220 52 100 2.4 221-280 65 125 2.5 281-350 79 160 2.6 351-450 94 205 2.7 451-560 114 260 2.8 561-710 140 330 2.9 711-890 170 415 3.0 891-1,100 220 520 High 3.1 1,101-1,400 290 650 3.2 1,401-1,800 380 800 3.3 1,801-2,200 500 1,000 3.4 2,201-2,800 650 1,300 3.5 2,801-3,500 825 1,700 3.6 3,501-4,500 1,025 2,200 3.7 4,501-5,600 1,250 2,800 3.8 5,601-7,100 1,500 3,500 3.9 7,101-8,900 1,800 4,300 4.0 8,901-11,000 2,300 5,300 Very High 4.1 11,001-14,000 3,000 6,500 4.2 14,001-18,000 4,000 8,000 4.3 18,001-22,000 5,200 10,000 4.4 22,001-28,000 6,600 13,000 4.5 28,001-35,000 8,200 17,000 4.6 35,001-45,000 10,000 22,000 4.7 45,001-56,000 12,200 28,000 4.8 56,001-71,000 14,800 35,000 4.9 71,001-89,000 18,000 43,000 Source: Goodrich Traffic Group 2020052801 2020052801 CITY OF PALO ALTO Mnn 1 Citv nf Pnln Altn I nrnl Rpsicipntinl Strppts CITY OFI f PALO ALTO 2020052801 2020052801 Source: City of Palo Alto Comprehensive Plan 2030 Map 2: City of Palo Alto Comprehensive Plan 2030 Land Use Designations Source: City of Palo Alto Comprehensive Plan 2030 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) 1118-2511 Refer to Standard Response FJ-Response-GEN-4: Consideration of 2040 Caltrain Service Vision and Caltrain Business Plan, FJ-Response-GS-1: Requests for Grade Separations. The comment asserts that the Draft EIR/EIS is inadequate as it fails to analyze and mitigate significant impacts in the City of Palo Alto. The Authority disagrees with this assertion. The Draft EIR/EIS provides sufficient information to inform the public and decisionmakers of the significant environmental effects of the project within the City of Palo Alto, and identifies mitigation measures to avoid, reduce, or minimize impacts, when feasible. In subsequent individual comments, the commenter raised specific concerns about the impact analysis or mitigation related to land use, socioeconomics and communities, noise and vibration, transportation, safety and security, cultural resources, public utilities and energy, and biological resources. Each of these specific comments has been addressed. Please refer to the responses to submission FJ-1118 as follows: comments 2516 through 2518 related to land use and communities; comments 2519 through 2523 related to noise; comments 2524 through 2535 related to transportation and safety; comments 2536, 2538, and 2539 related to public services and utilities; comment 2537 related to cultural resources; and comments 2540 and 2541 related to biological resources. The comment also asserts that the Draft EIR/EIS fails to consider cumulative impacts of the Caltrain Business Plan. Please refer to Standard Response FJ-Response-GEN-4: Consideration of 2040 Caltrain Service Vision and Caltrain Business Plan, which addresses this topic. The comment requests that the Authority consider grade separations as mitigation for project impacts. Please refer to Standard Response FJ- Response-GS-1: Requests for Grade Separations, which addresses this topic. 1118-2512 The comment summarizes information presented in the Draft EIR/EIS. The comment is noted but does not raise any specific concern regarding the conclusions or adequacy of the Draft EIR/EIS, nor did it result in any revisions to the Draft EIR/EIS. 1118-2513 Refer to Standard Response FJ-Response-GS-1: Requests for Grade Separations, FJ- Response-SS-1: At-Grade Crossing Safety. The comment asserts that land use, transportation, and safety impacts resulting from the project have not been fully analyzed and mitigated. The Authority disagrees with this assertion. Refer to Draft EIR/EIS Section 3.2, Transportation; Section 3.11, Safety and Security; and Section 3.13, Station Planning, Land Use, and Development which provide analysis of the environmental impacts of the project and identify mitigation measures to avoid, reduce, or minimize impacts, when feasible. In subsequent individual comments, the commenter raised specific concerns about the impact analysis or mitigation related to land use, transportation, safety and security. Please also refer to the response to submission FJ-1118, comments 2516 through 2518 related to land use and communities and comments 2524 through 2535 related to transportation and safety, which address the city’s concerns in more detail. The comment did not result in any revisions to the Draft EIR/EIS. California High-Speed Rail Authority June 2022 San Francisco to San Jose Project Section Final EIR/EIS Page | 20-711 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2514 Please refer to Table 8-3 in Section 8.4.4, Preferred Alternative Identification, of the Final EIR/EIS, which identifies the Authority’s preferred radio communication tower sites. In Palo Alto, the preferred radio communication tower sites are standalone radio tower 8 alternate site 2 (located southwest of the Embarcadero Road underpass of the Caltrain corridor immediately adjacent to the Caltrain right-of-way) and standalone radio tower 8A alternate site 1 (located within the Caltrain right-of-way). These locations are preferred because they would minimize additional right-of-way acquisition, which is consistent with the City’s preferences. With respect to the process for coordinating with property owners should the acquisition of private property be required, the Authority would begin the outreach process for acquisition during the final design phase. The Authority would hold community meetings to explain the acquisition process and answer questions. Individual affected property owners would receive an official communication from the Authority and be assigned a real property agent to work with. All acquisition would be conducted in accordance with the Uniform Relocation Act (42 U.S.C. Chapter 61), as described in SOCIO-IAMF#2. The Uniform Relocation Act establishes minimum standards for the treatment of and compensation to individuals whose real property is acquired for a federally funded project. Information about acquisition, compensation, and relocation assistance is also available on the Authority's website: hsr.ca.gov/programs/private-property/. 1118-2515 Refer to Standard Response FJ-Response-GEN-4: Consideration of 2040 Caltrain Service Vision and Caltrain Business Plan. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2516 Refer to Standard Response FJ-Response-OUT-3: Local Government Permits. The comment states that the Draft EIR/EIS needs to evaluate impacts on land use consistent with CEQA significance thresholds adopted by the state and the City of Palo Alto. This includes (1) whether the project would physically divide an established community and (2) whether the project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Please refer to Section 3.12.4.5, Method for Determining Significance under CEQA, which identifies the first CEQA threshold mentioned by the commenter (whether the project would physically divide an established community). Please refer to Section 3.13.4.5, Method for Determining Significance under CEQA, which identifies the second CEQA threshold mentioned by the commenter (if the project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulations adopted for the purpose of avoiding or mitigating an environmental impact). Please also refer to Appendix 2-J, Policy Consistency Analysis, which provides a policy consistency analysis for the project alternatives. The EIR/EIS includes the thresholds identified in the comment and no revisions are required. June 2022 California High-Speed Rail Authority Page | 20-712 San Francisco to San Jose Project Section Final EIR/EIS Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2517 The comment from the City of Palo Alto asserts that community division impacts associated with HSR preemptions at at-grade crossings and the inclusion of a noise barrier have not been adequately identified in the Draft EIR/EIS. The Authority respectfully disagrees with the assertion that the Draft EIR/EIS has not fully described these impacts. In both Alternative A and B, HSR trains would use the existing Caltrain tracks. To some extent, these existing tracks already visually and physically divide the community. Regarding the effects of HSR preemptions (gate closures) at at-grade crossings, refer to Draft EIR/EIS Section 3.12, Socioeconomics and Communities. In that section, refer to Impact SOCIO#3, which acknowledges that gate closures at the at-grade crossings could lead to greater delays to pass across such areas. Access would still be maintained and such temporary delays would not represent a physical division of the existing community. While the project would include bicycle and pedestrian facilities to maintain all forms of transportation across and along the rail corridor, such aspects of the project are noted for the record; the CEQA conclusion does not hinge on this point. Regarding noise barriers, refer to Draft EIR/EIS Section 3.4, Noise and Vibration. In that section, Table 3.4-21 identifies 13 locations in Palo Alto where noise barriers would be effective in reducing noise impacts. No noise barriers are proposed to be constructed across any at-grade crossings and thus would not cause or contribute to any road closures or decreased vehicle connectivity. Moreover, the Authority would not construct any noise barriers without the consent of 75 percent of all affected parties. Several sections of the Draft EIR/EIS consider the impacts of noise barriers. Refer to Section 3.4.7, Mitigation Measures, and Section 3.15.7, Mitigation Measures, particularly AVQ-MM#4, AVQ-MM#5, and AVQ-MM#6. Please also refer to the response to submission FJ-1118, comment 2540, which addresses the visual impacts of noise barriers. The analysis in these sections support the conclusion for Impact SOCIO#3 that there would be no secondary impacts on community cohesion associated with project operations, because the recommended noise barriers would be constructed within an existing transportation corridor and would not physically divide established communities 1118-2517 or disrupt community circulation to the extent that community character or cohesion would be affected. Accordingly, impacts on communities associated with transportation, noise and vibration, or visual quality would not physically divide established communities, and therefore no mitigation associated with Impact SOCIO#3 is required. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2518 The comment states that the EIR/EIS must identify any inconsistencies with the City of Palo Alto’s Comprehensive Plan and determine impacts based on this analysis. As the commenter notes, Draft EIR/EIS Section 3.4.3, Consistency with Plans and Laws, and Volume 2, Appendix 2-J, Policy Consistency Analysis, provide a policy consistency analysis for the project alternatives and identify that the project alternatives would be inconsistent with the City of Palo Alto’s Comprehensive Plan policies and regulations with respect to noise. However, as stated in Section 3.4.2.3, Regional and Local, of the Draft EIR/EIS, the HSR system is not subject to local general plan policies and ordinances related to noise limits or to locally based criteria concerning noise and vibration for the project alternatives. Instead, the project is subject to federal noise and vibration impact criteria (as set forth by the FRA). The noise and vibration impact assessments were conducted following FRA methodology and criteria. Please refer to Draft EIR/EIS Section 3.4, Noise and Vibration, Impacts NV#2 and NV#6, which identify significant and unavoidable operational impacts related to noise, even after the application of numerous mitigation measures. The comment did not result in any revisions to the Draft EIR/EIS. California High-Speed Rail Authority June 2022 San Francisco to San Jose Project Section Final EIR/EIS Page | 20-713 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2519 NV-MM#1 in Section 3.4.7, Mitigation Measures, discusses construction noise mitigation measures. NV-MM#1 requires the contractor to establish a construction noise monitoring program and implement measures to comply with FRA construction noise limits (an 8-hour Leq, dBA of 80 during the day and 70 at night for residential land use, 85 for both day and night for commercial land use, and 90 for both day and night for industrial land use) where a noise-sensitive receptor is present and wherever feasible. Measures for minimizing construction noise would include prohibiting certain noise- generating activities during nighttime hours, but due to the constraints of working within an active rail corridor some track realignments would require nighttime construction work that could exceed FRA construction noise limits at night. As described in mitigation measure NV-MM#1, the Authority would establish and maintain in operation until completion of construction a toll-free “hotline” regarding the project construction activities and would make a reasonable good-faith effort to address all noise concerns during construction. Accordingly, even with the implementation of NV-MM#1, the Draft EIR/EIS concludes that that some construction noise impacts would remain after mitigation, and the impact would be significant and unavoidable for both project alternatives. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2520 NV-IAMF#1 addresses both noise and vibration from construction. Consistent with typical construction practices contained in FTA and FRA guidelines for minimizing construction vibration, the contractor would route truck traffic away from residential streets, employ construction phasing, and use alternative construction methods to avoid the use of impact pile driving near vibration-sensitive land uses where possible. The contractor would document in a construction noise and vibration control plan how these measures would be employed to minimize construction vibration within 1,000 feet of sensitive receptors. Table 3.4-9 identifies the applicable FRA impact criteria that are the performance criteria the contractor must meet to avoid annoyance from construction vibration. As identified in Table 3.4-26, NV-MM#2 would be implemented to reduce this impact to less than significant levels under CEQA. NV-MM#2 would be effective in reducing human annoyance, as well as potential building damage. Additional information on the Authority’s noise and vibration mitigation guidelines is available in Appendix 3.4-B, Noise and Vibration Mitigation Guidelines. Changes in the sequence of operations and using alternative construction methods are available vibration mitigation options that will be identified in the required vibration control plan prepared by the contractor. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2521 Tables 3.4-23 and 3.4-24 in Section 3.4, Noise and Vibration, of the Draft EIR/EIS include the number of sensitive receptors that would experience moderate or severe noise impact before mitigation, with noise barriers, and with a combination of quiet zones and noise barriers. Additional detail regarding the specific noise impacts, levels, and locations before mitigation can be found in Volume 2, Appendix 3.4-A, Noise and Vibration Technical Report, in Tables 5-9 and 5-10, of the Draft EIR/EIS. Additional detail regarding the specific vibration impacts, levels, and locations before mitigation can be found in Tables 5-19 and 5-20. The comment did not result in any revisions to the Draft EIR/EIS. June 2022 California High-Speed Rail Authority Page | 20-714 San Francisco to San Jose Project Section Final EIR/EIS Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2522 Refer to Standard Response FJ-Response-OUT-3: Local Government Permits. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2523 Refer to Standard Response FJ-Response-GS-1: Requests for Grade Separations. Regarding establishing quiet zones, please refer to Section 3.4.7, Mitigation Measures, NV-MM#4, that states quiet zones can only be legally undertaken by local jurisdictions. The Authority cannot legally establish or require a quiet zone. However, this measure has been revised in the Final EIR/EIS to clarify that HSR would assist with the preparation of technical analysis and materials needed for the quiet zone application, which would then be provided to local communities for submittal to the FRA. 1118-2524 Refer to Standard Response FJ-Response-OUT-2: Consultation with Local Agencies and Consistency with Local Regulations. The comment requests that intersections be evaluated based on the adopted Local Transportation Impact Analysis Policy in Palo Alto. The Local Transportation Impact Analysis Policy was adopted by the City of Palo Alto in June 2020 in conjunction with new CEQA VMT thresholds pursuant to SB 743. The Local Transportation Impact Analysis policy establishes a process for conducting transportation analysis outside of the CEQA process, specially to address compliance with the City of Palo Alto’s LOS policy. The stated purpose of the policy is to review and identify “transportation effects of proposed development projects.” The Local Transportation Impact Analysis Policy standards for determining whether a transportation impact analysis is required are based on the number of net new weekday (AM or PM peak hour) trips generated by a development project. The HSR project would not add any new vehicle trips to local intersections or roadways in the City of Palo Alto. As such, the HSR project would not be required to prepare a transportation impact analysis under the standards for determining transportation analysis in Palo Alto's Local Transportation Impact Analysis Policy. The Draft EIR/EIS does, however, evaluate LOS impacts at eight intersections in the City of Palo Alto, all adjacent to at-grade crossings. As CEQA was amended in 2018 to eliminate the use of LOS as a threshold to identify significant CEQA transportation impacts, the Draft EIR/EIS addresses LOS impacts for NEPA purposes only. The Authority identified a single LOS methodology and criterion to identify adverse effects under NEPA that is applied for intersections in all jurisdictions along the corridor, and for other corridors throughout the state, to provide a fair and consistent evaluation of project impacts. As described in Standard Response FJ-Response-OUT-2: Consultation with Local Agencies and Consistency with Local Regulations, the Authority is not subject to local government general plan policies or zoning regulations. However, while the analysis of intersection delays in the Draft EIR/EIS was not based on the City of Palo Alto’s Local Transportation Impact Analysis Policy, the criteria for evaluating NEPA LOS effects in the Draft EIR/EIS is based on the same LOS D standard applied in the City of Palo Alto Local Transportation Impact Analysis Policy. Please refer to Sections 3.2.4.4, Method for Evaluating Impacts under NEPA, and California High-Speed Rail Authority June 2022 San Francisco to San Jose Project Section Final EIR/EIS Page | 20-715 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2524 3.2.4.5, Method for Determining Significance under CEQA, of the Draft EIR/EIS for a description of the methods and impact criteria incorporated within the transportation assessment. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2525 Refer to Standard Response FJ-Response-GS-1: Requests for Grade Separations, FJ- Response-SS-1: At-Grade Crossing Safety. The comment asserts that the Draft EIR/EIS does not analyze the potential hazards to school age pedestrians and bicyclists associated with increases in the number of trains and in train speeds. The comment also requests grade-separated crossings. These concerns are addressed by the standard responses referenced above. With regard to the assertion that the Draft EIR/EIS did not address project operation effects on children, please refer to Section 3.12, Socioeconomics and Communities. In this section, Impact SOCIO#6 specifically addresses the issues raised in the comment regarding children at at-grade crossings and found that the four-quadrant gates and perimeter fencing would improve safety conditions in the corridor. As there would be no disproportionate impacts on children’s health and safety due to project operations, no mitigation is required. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2526 The comment states that the project would increase gate-down time during peak hours by almost 67 percent, and that the impact on pedestrians and bicyclists must be analyzed and mitigated. Please refer to Impact TR#17 of Section 3.2, Transportation, of the Draft EIR/EIS, which evaluates pedestrian and bicycle impacts based on whether the project would conflict with a program, plan, ordinance, or policy regarding bicycle or pedestrian facilities, or otherwise materially decrease the performance of such facilities. The gate-down time for HSR trains at at-grade crossings in Palo Alto would range from 40 to 48 seconds depending on location. The addition of eight HSR trains during weekday peak hours would not have an effect on travel by pedestrians or bicyclists in Palo Alto about 90 percent of the time during peak hours when the crossing gates are not affected by HSR trains. For pedestrians or bicyclists arriving at the at-grade crossings in Palo Alto during the times when the gate is down for an HSR train, the wait time of up to 48 seconds is not considered a significant effect. The comment did not result in any revisions to the Draft EIR/EIS. June 2022 California High-Speed Rail Authority Page | 20-716 San Francisco to San Jose Project Section Final EIR/EIS Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2527 The comment states that the Draft EIR/EIS identifies an impact at the intersections in Palo Alto and that the delay at the intersections would affect other modes of transportation including bicyclists, pedestrians, and bus transit. Regarding delay impacts on bus transit, please refer to Impact TR#5 in Section 3.2, Transportation, of the Draft EIR/EIS, which incorporates impacts on local bus transit into the analysis of vehicle congestion/delay. Local bus routes and shuttle services are part of the vehicle volumes that are evaluated to identify continuous permanent congestion/delay consequences on intersection operations. The Draft EIR/EIS indicates that adverse NEPA effects would occur at eight Palo Alto intersections adjacent to at-grade crossings including El Camino Real/Palo Alto Avenue/Sand Hill Road, Alma Street/Palo Alto Avenue, Alma Street/Churchill Avenue, Mariposa Avenue/Churchill Avenue, Park Boulevard/Meadow Drive, Park Boulevard/Charleston Road, Castilleja Avenue/Churchill Avenue, and Wilkie Way/West Charleston Road (Impact TR#5). Refer to TR-MM#1 in Section 3.2, Transportation, of the Final EIR/EIS for a discussion of the site-specific mitigation identified for adverse LOS effects; however no feasible mitigation was identified for intersections in Palo Alto that met the Authority’s policy on traffic mitigation. Please also refer to Standard Response FJ-Response-TR-1: Site-Specific Mitigation for Traffic Impacts, regarding how the Authority analyzed and is mitigating LOS impacts. Regarding delay impacts on bicyclists and pedestrians, please refer to Impacts TR#16 and TR#17, which evaluate pedestrian and bicycle impacts based on whether the project would conflict with a program, plan, ordinance, or policy regarding bicycle or pedestrian facilities, or otherwise materially decrease the performance of such facilities. The gate-down time for HSR trains at at-grade crossings in Palo Alto would range from 40 to 48 seconds. For pedestrians or bicyclists arriving at the Palo Alto at-grade crossings during the times when the gate is down for an HSR train, the wait time of up to 48 seconds is not considered a significant effect. 1118-2528 Refer to Standard Response FJ-Response-SS-1: At-Grade Crossing Safety, FJ- Response-TR-1: Site-Specific Mitigation for Traffic Impacts. The comment suggests that the Draft EIR/EIS should evaluate the effect of queues spilling onto through lanes, which would create safety hazards near at-grade crossings. The intersection LOS analysis methodology employed in the Draft EIR/EIS takes into the account the effect of queues created by added gate-down time at the at-grade crossings on the operations/LOS of intersections adjacent to the at-grade crossing. This analysis is reflected in Impact TR#5 in Section 3.2, Transportation, of the Draft EIR/EIS. Refer to TR-MM#1 in Section 3.2, Transportation, of the Final EIR/EIS for a discussion of the site-specific mitigation identified for adverse LOS effects. As discussed in Standard Response FJ-Response-TR-1: Site-Specific Mitigation for Traffic Impacts, the Authority developed site-specific mitigation for the Final EIR/EIS for certain locations where adverse NEPA traffic effects were identified. However, no feasible mitigation was identified that could address the effects at the intersections of El Camino Real/Palo Alto Avenue/Sand Hill Road, Alma Street/Palo Alto Avenue, Alma Street/Churchill Avenue, Mariposa Avenue/Churchill Avenue, Park Boulevard/Meadow Avenue, Park Boulevard/Charleston Road, Castilleja Avenue/Churchill Avenue, and Wilkie Way/West Charleston Road. The Authority will construct improvements at at-grade crossings, including four-quadrant gates where not currently present, consistent with FRA standards to address safety at all at-grade crossings. As discussed under Impact S&S#14 in Section 3.11, Safety and Security, the Draft EIR/EIS analysis found that installation of improvements to at-grade crossings, perimeter fencing, and four-quadrant gates would improve safety along the right-of-way, providing sufficient protections. Volume 3, Preliminary Engineering Plans, of the Draft EIR/EIS reflects a conceptual level of design for four-quadrant gate applications. The design for at-grade crossings would be refined as part of the final design in compliance with all relevant engineering standards, including MUTCD and CPUC GOs, and in coordination with CPUC. California High-Speed Rail Authority June 2022 San Francisco to San Jose Project Section Final EIR/EIS Page | 20-717 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2529 Refer to Standard Response FJ-Response-TR-1: Site-Specific Mitigation for Traffic Impacts. The comment suggests that the project would significantly affect all modes of transit throughout the day and that impacts have not been properly identified. Please refer to Impact TR#11 in Section 3.2, Transportation, of the Draft EIR/EIS, which addresses the effects on high-frequency bus routes that operate near the HSR stations, maintenance facilities, or cross at-grade rail crossings. Significant effects due to added vehicle traffic in station areas or added gate-down time at at-grade rail crossings are identified for nine high-frequency bus routes. TR-MM#2 mitigates the effects identified in Impact TR#11. Local bus routes and shuttle services are part of the vehicle volumes that are evaluated to identify continuous permanent congestion/delay consequences on intersection operations in Impact TR#5. The Draft EIR/EIS indicates that an adverse NEPA effect would occur at eight Palo Alto intersections adjacent to at-grade crossings including El Camino Real/Palo Alto Avenue/Sand Hill Road, Alma Street/Palo Alto Avenue, Alma Street/Churchill Avenue, Mariposa Avenue/Churchill Avenue, Park Boulevard/Meadow Drive, Park Boulevard/Charleston Road, Castilleja Avenue/Churchill Avenue, and Wilkie Way/West Charleston Road. Refer to TR-MM#1 in Section 3.2 of the Final EIR/EIS for a discussion of the site-specific mitigation identified for adverse LOS effects; however, no feasible mitigation was identified for these intersections that met the Authority’s policy on traffic mitigation. 1118-2530 Refer to Standard Response FJ-Response-SS-1: At-Grade Crossing Safety. The commenter states that the HSR train speeds would reduce the reaction time for pedestrian, bicycle, and vehicle activities at at-grade crossings, and that the project would affect intersections adjacent to at-grade crossings that require improvements. FRA regulations require that at-grade crossing warning systems must provide at least 20 seconds warning time for normal train operations (49 C.F.R. Section 234.225) and require crossing gates to lower no sooner than 3 seconds after flashing light activation and to reach horizontal no later than 5 seconds before a train enters the crossing (49 C.F.R. Section 234.223). These requirements do not change for trains operating at 79 mph or 110 mph. Caltrain is the host railroad and is responsible for compliance withal FRA safety regulations with regard to track and warning systems and would be responsible to make any adjustments in gate activation and any connection to preemption of nearby traffic signal systems. As discussed in Standard Response FJ-Response-SS-1: At-Grade Crossing Safety, the Authority would install four-quadrant gates, median channelization, and fencing, which would improve at-grade crossing safety. In addition, Caltrain is upgrading its signal system, which will improve connections between onboard train systems and wayside signal operations. Caltrain conducts periodic hazard analysis to determine when crossings will be upgraded. CPUC regulations (CPUC General Order NO. 75-D) require that traffic signals at at-grade crossings with automatic warning devices be interconnected with the automatic warning devices at locations where a diagnostic team determines that preemption is necessary (e.g., where vehicular traffic queues from traffic signal-controlled intersections exceed the Clear Storage Distance as defined in the MUTCD). Caltrain would be responsible for preemption improvements with regard to blended service operations. Caltrain will meet all state (CPUC) and federal (FRA) requirements for railroad operations and signaling. For further information about Caltrain’s existing and future plans concerning signal systems, please refer to Standard Response FJ-Response-SS-1: At-Grade Crossing Safety. The comment did not result in any revisions to the Draft EIR/EIS. June 2022 California High-Speed Rail Authority Page | 20-718 San Francisco to San Jose Project Section Final EIR/EIS Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2531 Refer to Standard Response FJ-Response-GS-1: Requests for Grade Separations, FJ- Response-SS-1: At-Grade Crossing Safety. The Authority acknowledges the City’s concern regarding the higher operating speeds of trains within the Caltrain corridor as compared to existing Caltrain speeds of 79 mph. As explained in Chapter 2, Alternatives, of the Draft EIR/EIS, with implementation of the HSR project, HSR trains and Caltrain trains would operate at speeds of up to 110 mph. Higher speeds are necessary for consistency with Proposition 1A travel time requirements for system design, which requires the HSR system to be designed to achieve maximum non-stop service times of 30 minutes between San Francisco and San Jose. Consistent with FRA safety guidelines for HSR systems with operating speeds of up to 110 mph, the blended system would install safety improvements (e.g., four-quadrant gates at at-grade crossings, perimeter fencing) to create a “sealed corridor” that would reduce conflicts with automobiles, bicycles, and pedestrians. The Draft EIR/EIS analysis under Impact S&S#14 found that installation of four-quadrant gates and median barriers consistent with FRA standards would improve safety along the right-of-way, providing sufficient protections. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2532 Please refer to the response to submission FJ-1118, comment 2531, which addresses the required design speeds needed for the project to remain consistent with Prop 1A. Due to this requirement, slower speed trains have not been evaluated, and are not required to be evaluated, in the EIR/EIS. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2533 Refer to Standard Response FJ-Response-OUT-2: Consultation with Local Agencies and Consistency with Local Regulations. The comment requests that the Draft EIR/EIS transportation analysis impacts and mitigations be studied in accordance with the adopted Local Transportation Impact Analysis Policy in Palo Alto. The Authority developed the methodology and significance criteria applied for the Draft EIR/EIS assessment in accordance with CEQA and NEPA guidelines. The Authority identified a single LOS criterion to identify adverse effects under NEPA that is applied for intersections in all jurisdictions along the corridor, and for other corridors throughout the state, to provide a fair and consistent evaluation of project impacts. As such, the analysis of intersection delays in the Draft EIR/EIS were not based on the City of Palo Alto’s Local Transportation Impact Analysis Policy on traffic Infusion and Residential Environment (TIRE). As described in Standard Response FJ- Response-OUT-2: Consultation with Local Agencies and Consistency with Local Regulations, the Authority is not subject to local government general plan policies or zoning regulations. Please refer to Sections 3.2.4.4, Method for Evaluating Impacts under NEPA, and 3.2.4.5, Method for Determining Significance under CEQA, of the Draft EIR/EIS for a description of the methods and impact criteria incorporated within the transportation assessment. Please refer also to Standard Response FJ-Response-TR-1: Site-Specific Mitigation for Traffic Impacts, regarding how the Authority analyzed and is mitigating LOS impacts. California High-Speed Rail Authority June 2022 San Francisco to San Jose Project Section Final EIR/EIS Page | 20-719 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2534 As discussed under Impact TR#13, the project is expected to result in a 6.5 percent increase in Caltrain ridership due to HSR riders using Caltrain to reach HSR stations for outbound trips and for inbound riders to reach destinations not served by HSR. It is possible that increased ridership may increase demand for parking at other Caltrain stations. However, as explained in the EIR for the Caltrain Peninsula Corridor Electrification Project (PCJPB 2015b), Caltrain does not plan to meet unconstrained parking demand at its stations, particularly in the urbanized portions of the Caltrain service area. Caltrain’s 2010 Comprehensive Access Program Policy Statement emphasizes station access by walking, transit, and bicycling over automobile access at most stations. For transit center stations like Palo Alto, access priority for autos is the lowest priority after transit, walking, and bicycles. A parking deficit in and of itself, or the need to find a parking space off-site, while inconvenient, is not in and of itself a significant physical impact on the environment. Some station users unaware of the parking deficits may circle while looking for parking, but experienced station users will modify their behavior to take into account the parking deficits and take alternative actions. Those actions may include arriving earlier, using other nearby stations with available parking, using the kiss and ride, using parking areas further from the station, or accessing the station via other modes such as transit, biking or walking. Given Caltrain’s policy approach to station access, the increased riders generated by the increased demand for Caltrain service due to the HSR project are expected to be accommodated by modes other than personal vehicle parking or by behavioral shifts. As such, there would be no significant physical impact on the environment and no requirement for mitigation. The comment does not identify any inadequacies in the analysis in the Draft EIR/EIS and no revisions are necessary. 1118-2535 Refer to Standard Response FJ-Response-TR-1: Site-Specific Mitigation for Traffic Impacts. The comment suggests that the project would significantly affect bus service on Alma Avenue. While the Draft EIR/EIS does not specifically identify individual local bus service routes, impacts on local bus transit are incorporated into the analysis of intersection operations. Please refer to Impact TR#5 in Section 3.2, Transportation, which analyzes local bus routes as part of the vehicle volumes that are evaluated to identify continuous permanent congestion/delay consequences on intersection operations. The Draft EIR/EIS indicates that an adverse NEPA effect would occur at eight Palo Alto intersections adjacent to at-grade crossings, including Alma Street/Palo Alto Avenue and Alma Street/Churchill Avenue. Local bus services are incorporated into this effect on intersection operations. Refer to TR-MM#1 in Section 3.2 of the Final EIR/EIS for a discussion of the site-specific mitigation identified for adverse LOS effects. No feasible mitigation was identified that could address the effects at the intersections of Alma Street/Palo Alto Avenue and Alma Street/Churchill Avenue. 1118-2536 Refer to Standard Response FJ-Response-GS-1: Requests for Grade Separations, FJ- Response-SS-2: Emergency Vehicle Response Times. The comment asserts that the Draft EIR/EIS must evaluate grade separation for at- grade crossings as mitigation measures for effects to emergency response times. The Draft EIR/EIS evaluation of continuous permanent impacts on emergency access and response times due to increased gate-down time under Impact S&S#6 concluded that there would be a significant impact along the Menlo Park/Palo Alto boundary in the areas west of El Camino Real and north of Sand Hill Road, but not for other portions of the City of Palo Alto. Mitigation Measure SS-MM#4, which calls for installing emergency vehicle priority treatments related to increased gate-down time impacts, indicates that the Authority and a local agency may make a mutual agreement to have the Authority make an in-lieu payment towards other infrastructure projects, as an alternative to the listed emergency vehicle priority treatments, including nearby grade-separation projects. June 2022 California High-Speed Rail Authority Page | 20-720 San Francisco to San Jose Project Section Final EIR/EIS Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2537 The comment states that the Draft EIR/EIS must evaluate and mitigate the impacts on the root-structure from grading or the use of vibratory equipment for track work within 10 feet of the Historic El Palo Alto Tree. The El Palo Alto redwood tree is located adjacent to the Caltrain right-of-way, and the tree branches and foliage are located within 5 feet of the right-of-way. As part of Caltrain PCEP, Caltrain will be performing some limited tree trimming that an arborist has determined will not compromise the health of the tree and will be installing OCS poles along the opposite side of the tracks to minimize effects on tree roots. As part of the HSR project, minor horizontal track shifts would be required further westward, away from the tree. This would be done using track-mounted equipment that would operate along the existing Caltrain track as it adjusts track and ballast; this equipment operates in a similar way to existing train operations in the Caltrain corridor. As the track bed is already compacted and the track adjustments would be shifting track further from El Palo Alto, it is not anticipated that additional compaction or vibratory impacts beyond the existing conditions would occur. Please refer to BIO-MM#39 of the Draft EIR/EIS, which requires the project biologist to establish environmentally sensitive areas around protected trees with the potential to be affected by construction activities. The intent of this measure is to avoid construction impacts on protected trees. Although, a 10 foot buffer will not be possible in this location, the Historic El Palo Alto Tree would be protected by the largest feasibly possible environmentally sensitive area, which would minimize root structure grading and vibratory impacts. BIO-MM#39 has been updated to reflect that locations near protected trees where a 10 foot buffer is not possible will have the largest possible buffer employed to avoid and minimize impacts. 1118-2538 The comment states that construction-related vibration could indirectly affect existing City of Palo Alto utility infrastructure in the vicinity of the project, particularly infrastructure that crosses the railroad tracks. Anticipated construction work within the city of Palo Alto is limited to minor track shifts, installation of four-quadrant gates, and standalone radio towers. These activities would not be substantial sources of construction-related vibration and therefore significant indirect vibration impacts on utilities are not expected and mitigation is not required. Any work in proximity to City- owned utilities would be coordinated with the City, and the Authority generally ensures that overall local government facilities and utilities function in a materially equivalent manner to prior to the relocations, modifications, or impact. This comment does not require any revisions to the Draft EIR/EIS. 1118-2539 The issue of temporary disruptions to utilities is acknowledged and explained at length in Impact PUE#1 in Section 3.6, Public Utilities and Energy, of the Draft EIR/EIS. Impact PUE#1 states that planned, temporary interruptions of major utility service to public utility customers could occur during construction at any given location and could interrupt utility services to industrial, commercial, and residential customers. Impact PUE#1 explains that the alternatives incorporate PUE-IAMF#3, which provides for advance notification of planned temporary outages. The alternatives also incorporate PUE-IAMF#4, which further commits the Authority to coordinate with utility providers such that outages can be avoided or minimized. Neither CEQA, NEPA, nor any other pertinent regulation require that outage durations be precisely defined or that the Authority speculate on the durations of such outages. The Authority recognizes that outages are inconvenient to surrounding utility users, but for health and safety purposes, some temporary outages would be required. The comment did not result in any revisions to the Draft EIR/EIS. California High-Speed Rail Authority June 2022 San Francisco to San Jose Project Section Final EIR/EIS Page | 20-721 Chapter 20 Local Agency Comments Response to Submission 1118 (Ed Shikada, City of Palo Alto, September 9, 2020) - Continued 1118-2540 As shown in Table 3.4-21 in Section 3.4, Noise and Vibration, of the Draft EIR/EIS there are numerous locations where noise barriers would be considered in Palo Alto. Mature vegetation already exists outside the railway right-of-way in most potential noise barrier locations to shield views from residences and other sensitive receptors. In locations where existing landscaping is minimal, AVQ-MM#4 and AVQ-MM#5 detail landscaping mitigations along the HSR corridor. Additionally, in accordance with AVQ-MM#6 as part of the final design and construction management plan, the Authority would work with local jurisdictions to develop the appropriate noise barrier style and treatments for visually sensitive areas, to reduce the visual effect of barriers on adjacent land uses. With respect to the commenter’s question about whether the Authority would retain or replant existing vegetation along the right-of-way, the Authority would replace removed trees based upon local jurisdictional requirements consistent with AVQ-MM#1. The comment did not result in any revisions to the Draft EIR/EIS. 1118-2541 The comment is noted but does not raise any specific concern regarding the conclusions or adequacy of the Draft EIR/EIS, nor did it result in any revisions to the Draft EIR/EIS. Appendix 2-I, Regional and Local Plans and Policies, of the Draft EIR/EIS includes a summary of the tree requirements in the Palo Alto Municipal Code. The project would replace trees in accordance with the City of Palo Alto’s Tree Technical Manual and use the City of Palo Alto’s required tree replacement ratios if they are greater than a 1:1 ratio. June 2022 California High-Speed Rail Authority Page | 20-722 San Francisco to San Jose Project Section Final EIR/EIS