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Sunnyvale_CommentLetter_VallcoAreaSP_NOP_FINALMarch 12, 2018 Piu Ghosh, Principal Planner City of Cupertino 10300 Torre Avenue Cupertino, CA 95014 piug@cupertino.org Sunnyvale 456 West Olive Avenue Sunnyvale, CA 94088-3707 TDD/TYY 408-730-7501 sunnyvale.ca.gov Re: Comments on the Notice of Preparation for the Vallco Area Specific Plan Dear Ms. Ghosh, Thank you for the opportunity to comment on the Notice of Preparation (NOP) for the proposed Vallco Area Specific Plan (Plan) in Cupertino. This letter includes all City of Sunnyvale comments. General Comments 1. The Plan proposes a development capacity of 600,000 square feet of commercial uses, 2.0 million square feet of office uses, 339 hotel rooms, and 800 residential dwelling units for the Vallco Special Area. The City of Sunnyvale is concerned with the Plan's imbalance in non-residential uses (commercial, office, and hotel) vs. proposed residential units, especially in regards to recent substantial office development in the immediate area. Although density may be regulated by the existing General Plan, the housing demand with the proposed non-residential development and recent office development is significant in size and may warrant additional housing units to be considered on the site. Please consider an alternative in the Plan's Environmental Impact Report (EIR) that includes additional residential units in an attempt to mitigate burden on the housing market, and other environmental impacts, such as traffic and transportation and greenhouse gas emissions. Traffic and Transportation Comments If you have questions on the following traffic related items, please contact Lillian Tsang, Principal Transportation Engineer, Department of Public Works at Itsang(a sunnyvale.ca.gov or (408) 730-7556. The City of Sunnyvale uses criteria of the Valley Transportation Authority (VTA) Transportation Impact Analysis (TIA) Guidelines as a basis for determining study Heart of 51licon Valley" Sunnyvale intersections. Accordingly, municipal and Congestion Management Program (CMP) intersections with ten or more project trips per approach lane should be analyzed. Due to the project size and location, it is expected that project trips would travel to the north through Sunnyvale, which is likely to trigger the need for intersection analysis along Wolfe Road, Sunnyvale -Saratoga Road, Hollenbeck Avenue, and Mary Avenue. The following intersections shall be included in the analysis: • Wolfe Road & Homestead Road • Wolfe Road & Inverness Way • Wolfe Road & Marion Way • Wolfe Road & Fremont Avenue • Wolfe Road & EI Camino Real • Quail Avenue/Tantau Avenue & Homestead Road • Heron Avenue & Homestead Road • Blaney Avenue & Homestead Road • Blue Jay Drive & Homestead Road • Sunnyvale -Saratoga Road & Homestead Road • Sunnyvale -Saratoga Road & Alberta Avenue/Harwick Way • Sunnyvale -Saratoga Road & Cheyenne Drive/Connemara Way • Sunnyvale -Saratoga Road & Fremont Avenue • Sunnyvale -Saratoga Road & Remington Drive • Sunnyvale -Saratoga Road & Mathilda Avenue • Mathilda Avenue & EI Camino Real • Hollenbeck Avenue & Homestead Road • Hollenbeck Avenue & Cascade Drive • Hollenbeck Avenue & Fremont Avenue • Hollenbeck Avenue & Torrington Drive • Hollenbeck Avenue & Remington Drive • Hollenbeck Avenue & EI Camino Real • Mary Avenue & Homestead Road • Mary Avenue & The Dalles Avenue • Mary Avenue & Cascade Drive • Mary Avenue & Fremont Avenue • Mary Avenue & Torrington Drive • Mary Avenue & Remington Drive • Mary Avenue & Heatherstone Avenue • Mary Avenue & EI Camino Real Traffic conditions at the study intersections are typically conducted for the AM and PM peak hours under existing and future analysis scenarios. Heart of Silicon Valley" Page 2 of 4 Sunnyvale 2. The need for evaluating alternative modes of transportation needs to be emphasized for this Plan. The VTA CMP Guidelines indicate that traffic analysis must include transit facilities in terms of transit service availability, transit capacity relative to the increased demand, impact of increased traffic delays on the service, and the need for transit access improvements. According to the CMP Guidelines, the traffic analysis must also evaluate bicycle and pedestrian facilities in terms of their availability, Plan effects on future bike/pedestrian plans, and improvements proposed by the Plan. Maps and information on existing and planned bicycle facilities can be supplied upon request. 3. Analysis of potential cut -through traffic within the Birdland Neighbors residential area and Ortega Park residential area. Streets to be analyzed should at least include Marion Way, Dunford Way, Inverness Way, Quail Avenue, Heron Avenue, Canary Drive, and Locksunart Way (refer to Figure 1). 4. The Plan area is located on the southerly boundary of the City of Sunnyvale. Relevant approved projects within Sunnyvale and other neighboring jurisdictions need to be included in the study estimates of the Background traffic volumes. This is consistent with the CMP TIA Guidelines. Similarly, pending projects and/or the application of an annual growth rate need to be incorporated in the Cumulative traffic volume estimates to reflect the growth in both the local and regional traffic. Please be advised that the City of Sunnyvale regularly updates a list of its approved and pending development projects, and it can be provided upon request. 5. Besides capturing local and regional traffic growth, it should be noted that Background analysis is typically conducted for the year of project completion and occupancy, while the Cumulative analysis is performed for a longer term horizon year. 6. The Plan proposes a mixed-use development consisting of 600,000 square feet of commercial uses, 2.0 million square feet of office uses, 339 hotel rooms, and 800 residential dwelling units. Construction of the proposed buildings and associated amenities is expected to generate a significant amount of truck traffic. Truck routes and construction related impacts on the City of Sunnyvale and regional corridors need to be investigated and mitigated if necessary. 7. The NOP lists the EIR's requirement to identify the environmental consequences including (a) any significant environmental effects which cannot be avoided, (b) the growth inducing impacts, and (c) the cumulative impacts. Besides identifying the individual and cumulative project impacts along with associated feasible mitigations, it is important to also explain the project's full/pro-rata share financial contributions towards the implementation of these mitigations. Heart of Silicon Valley" Page 3 of 4 v Sunnyvale 8. Any mitigation measures or proposed roadway improvements along Homestead Road should be done in consultation with the City of Sunnyvale. 9. Detailed information on any proposed Transportation Demand Management (TDM) initiatives need to be provided, especially if it is offered as Plan mitigation. Assumptions regarding alternative means for traveling to/from this office development need to be realistic and achievable in light of their implementation and monitoring plan. 10. The Plan is significant in size and is expected to affect the Sunnyvale street system. The City of Sunnyvale is requesting to review the proposed Scope of Work prior to the Consultant starting on the traffic related analysis to ensure the TIA would include all the necessary analyses within the City of Sunnyvale. Then, following the CMP guidelines, the City of Sunnyvale is also requesting to review the draft TIA report. We believe that the early review of the project's traffic analysis and potential impacts could save time in the review and approval process of the EIR. The City of Sunnyvale appreciates your consideration of the requested study scope elements described above. Please contact Kelly Cha, Associate Planner, at (408) 730- 7408 or kcha(a-)-sunnyvale.ca.gov if you have any questions or concerns about items discussed in this letter. Andrew Miner Assistant Director Community Development Department Cc: Trudi Ryan, Director, Community Development Department Wayne Tanda, Interim Director, Department of Public Works Amber Blizinski, Principal Planner, Community Development Department Shahid Abbas, Transportation and Traffic Manager, Department of Public Works Lillian Tsang, Principal Traffic Engineer, Department of Public Works Heart of Silicon Valley' Page 4of4 City of Sunnyvale Comments to the NOP for Vallco Special Area Specific Plan EIR Figure 1: Cut -Through Traffic Analysis vaolIX runt Ave w Fremont Ave E Fremont AYe E F-01 Ave E PfMOnt Ave O India Cash & Carry 4% ashhuurneor 5 4rrunl War HankookSupermari S 4 fsrY.��nWay z Santa m Pei nMiddle School O e " PANAMA PARK a z Elementary o Denlseeway m cewllNo-,way SchoolO arx,,ye MY Y � 3 u,uck ❑r � � a E connoryra War – S _ m se or N I M I T i m � Dublin a Pe shire wev war � n aevmehve war $ .3 2aunholne �-,� auncabinc Wdr ui W. 11 1-t Or ' N Way � Pursh-Way AP 91 - t - Hra war B 6 flMoo� ., Raynor ik ". 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