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-5— <br /> ® (EIR 4.1-14.) As an attorney, I come to the opposite conclusion. If the decision to use the <br /> word "structure" in two ways — once unmodified and once modified by "residential or <br /> commercial"—implies anything, it implies the adoption of different meanings between the two <br /> uses. This is, in fact, a basic canon of statutory interpretation taught in law school, called the <br /> "meaningful variation" principle. This principle can be summarized as: when the drafters of <br /> a statute use a word or phrase differently in different places, they are assumed to have meant <br /> different things.' (In any event, one only resorts to these sorts of interpretive principles if a <br /> term is ambiguous in the first place. In light of the Municipal Code's explicit definition of <br /> "structure," that is not the case here.) <br /> Traffic <br /> I devoted my own testimony at the Workshop to this subject, and remain of the opinion that <br /> if one puts aside arguments concerning PP and the Ventana side letter, the traffic analysis <br /> pushes heavily toward routing through Lund Ranch Road instead of Sycamore. <br /> There were numerous witnesses who offered anecdotal accounts regarding traffic along <br /> Junipero. I think it is safe to say that residents of all the involved neighborhoods think we <br /> presently have too much traffic. So to divorce out one's own subjective impressions, I write <br /> to draw attention back to the only neutral, comprehensive evidence we have regarding traffic <br /> along the various routes: the City's own analysis as reported in the EIR. <br /> • Those figures report quite plainly that the busiest street in Ventana is Junipero, with <br /> ® an existing average weekday traffic figure of 2,880 trips. You can see this graphically <br /> in Figure 4.6-2. In the Environmentally Superior Scenario (No. 1), Junipero is <br /> predicted to go to 3,140 trips. <br /> • The busiest street in Sycamore, on the other hand, has an existing average weekday <br /> traffic figure of 3,440 trips. So, even with the increase in traffic under <br /> Scenario 1, it is beyond debate that Junipero still will have fewer daily trips <br /> than Sycamore has now. Under Scenario 6, Sycamore will increase to 4,130 trips • <br /> per day. <br /> I thought also that the Traffic Engineer's comments at the Workshop were particularly <br /> helpful to understanding the various arguments raised: <br /> • The Engineer testified that Hanifen, at 32 ft. wide, was not built to support <br /> significant two-way traffic. Contrary to its design, Hanifen would be called upon to <br /> bear a large (700%) increase two-way traffic in Scenario 6. This is likewise true of <br /> Sunset Creek Lane. By contrast, all streets involved in Scenario 1 are at least 37 ft. <br /> wide, some 40 ft. <br /> 5 Indeed, the case law applying the meaningful variation principle makes clear that it applies with particular <br /> force when the comparison of phrase usage is taking place within the same statute adopted at the same time <br /> authored by the same people (as is the case here), as opposed to when the comparison is taking place, for <br /> ® example, between one usage in one statute passed at one time and another related statute passed some time <br /> later. <br />