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City of Pleasanton—Hidden Canyon Residences and Preserve Project Responses to Written Comments Final EIR 3-76 FirstCarbon Solutions https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480016/EIR/4 - Final EIR/21480016 Sec03-00 Responses to Written Comments.docx established in the General Plan, Pedestrian and Bicycle Master Plan, and other transportation studies. Study intersections for the proposed project were selected in consultation with City staff and according to the City’s criteria. Measurements for existing conditions were taken during the highest one-hour volumes during weekday morning and evening peak periods, when school was in session, to account for typical traffic volumes in the proposed project area, which includes the adjacent parcel APN 941-2600-1-3. Page 24 of Appendix H states that all of the study intersections are operating acceptably at LOS D or better during both the AM and PM peak-hours. Further, on page 7, the Transportation Impact Study found that all study intersections would operate at acceptable LOS with implementation of the proposed project, including the cumulative project scenario. Seasonal cattle movements associated with ranch operations are intermittent and episodic in nature, rather than a continuous or daily traffic generator. CEQA does not require that infrequent or seasonal activities be separately quantified or disaggregated in the traffic baseline where they do not materially affect average daily traffic volumes or operational performance of the roadway network. The Draft EIR therefore appropriately relies on standard traffic engineering practice to characterize baseline conditions. With respect to proposed project impacts, the proposed project does not eliminate, restrict, or physically block access to the Devany Parcel, nor does it propose changes that would interfere with continued ranch operations or associated access. As discussed in Section 3.14, Transportation, the proposed project would not result in inadequate access, unsafe roadway conditions, or conflicts between project traffic and existing roadway users. Accordingly, no project-related impact to ranch access or operations was identified. Similarly, the cumulative impacts analysis evaluates whether the proposed project’s incremental contribution, when combined with other past, present, and reasonably foreseeable projects, would result in a cumulatively significant transportation impact. Because the proposed project does not substantially affect access to the Devany Parcel and does not introduce traffic conditions that would conflict with existing agricultural uses, the absence of a separate line-item analysis of Devany Parcel traffic does not render the cumulative analysis inadequate. Moreover, the discussion in Chapter 6, Alternatives to the Proposed Project, describes how existing traffic to the proposed project site would remain if no development were to occur under Alternative 1 on Draft EIR page 6-11, as well as how by-right development under Alternative 2 would increase vehicle trips from existing conditions on Draft EIR page 6-22. However, there is an existing significant and unavoidable VMT impact in the project site area. As such, the required transportation impact is discussed in Chapter 6, Alternatives to the Proposed Project. Furthermore, despite the significant and unavoidable VMT impact, the proposed project would include VMT-reducing strategies such as reducing off-street parking spaces and enhancing multimodal infrastructure, as stated on Draft EIR page 3.14-13. The Alternatives analysis appropriately focuses on whether project alternatives would reduce or avoid significant environmental impacts of the proposed project. Because the Draft EIR does not identify a significant transportation impact related to Devany Parcel traffic under the proposed project, CEQA does not require a separate alternatives analysis addressing that issue.