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<br />B. ALAMEDA COUNTY, <br />CONGESTION MANAGEMENT AGENCY <br />LETTER OF MARCH 22, 2006 <br /> <br />B 1 Comment: <br />This letter states that the DEI R project is exempt from the CMP's Land Use Analysis <br />Program because it would not (based on information provided by the City to the <br />CMA subsequent to the CMA comment letter) generate 100 or more PM peak hour <br />trips over existing or baseline conditions, <br /> <br />Response: <br />This letter resolves the issues raised in the CMA's previous communications, <br /> <br />B 2 Comment: <br />The Land Use Analysis Program of the Congestion Management Program requires <br />that "jurisdictions must address all potential impacts of the project on the Metropoli- <br />tan Transportation System (MTS)," If an alternative model other than the Alameda <br />Countywide Model is used for traffic impact analysis, it should: <br /> <br />a, be conservative in terms of traffic volumes on the specified MTS roadways and <br /> <br />b, the approach should be demonstrated as conservative and documented in the EI R, <br /> <br />With respect to the traffic analysis for this project, Pleasanton's traffic model is <br />reported to generate less traffic volume than the countywide model, which is not <br />normally the case; typically the countrywide model tends to generate relatively less <br />traffic volume than a city model, which is more detailed, The reasons why the <br />countywide model is thought to be generating a higher trip volume than the city <br />model should be discussed in the EIR, <br /> <br />Response: <br />The PM peak period impacts of the Bernal Phase II Specific Plan are considered to be <br />lower than those incorporated into the Congestion Management Plan because the <br />land use currently proposed differs from the land use designations in the 1996 Plea- <br />santon General Plan, This change in land use designations is the outcome of <br />subsequent planning actions taken by Pleasanton, Since 1996, Pleasanton has: <br /> <br />. Divided the Bernal Property into two Specific plan areas: <br /> <br />o phase I, a 19B-acre private development area, and <br /> <br />o Phase II" a 31B-acre public use area; <br /> <br />. Completed and certified an EI R (Bernal Property Phase I Specific Plan EI R) on the <br />19B-acre private use area; and <br /> <br />. Published the current DEIR (Bernal Property Phase II Specific Plan EIR) on the 31B- <br />acre public use area, <br /> <br />For the Bernal Property as a whole, the levels of residential and office/commercial <br />development provided for under the Phase I Specific Plan are substantially less than <br />those assumed in the 1996 General Plan: <br /> <br />Residential, As noted in the General Plan EI R, Table, 2, the residential component of <br />the Bernal Property site was assumed to be 2,257 units, The full residential <br /> <br />16 <br />